Comments on 5/27 comment template

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

AReM recommends CAISO clarify in its final tariff revisions that “RA-eligible” capacity as used in this proposal is capacity from resources listed on CAISO’s net qualifying capacity (NQC) list. This will resolve any ambiguity that CAISO is not seeking data on capacity deemed “RA-eligible” by a local regulatory authority (LRA) but not eligible by CAISO. AReM understands discrepancies in RA eligibility by CAISO and LRAs will be considered further in Track 3B of the policy initiative. AReM looks forward to further work on this issue. 

AReM also supports the idea raised at the May 27th meeting that CAISO generate an aggregated public report summarizing data submitted through this new process.

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

AReM does not have any feedback on the five categories at this time.

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

AReM has no further feedback at this time. 

4. Please provide any additional feedback not already captured.

AReM has no further feedback at this time. 

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the Resource Adequacy Modeling and Program Design Track 3A Straw Proposal (Straw Proposal). CalCCA supports the California Independent System Operator’s (CAISO) goal of enhanced visibility into the amount of capacity potentially available for capacity procurement mechanism (CPM) designations. Understanding if and how resource adequacy (RA) capacity is dedicated for other purposes will provide valuable insight into the CAISO’s ability to procure backstop capacity should RA requirements not be met or if reliability issues arise. This understanding is especially relevant when the RA market is tight, as it has been for the last several years.

The CAISO should provide a publicly available summary of its findings from the Summer 2025 data request and future data requests resulting from this initiative. Just as it is imperative for the CAISO to understand why RA resources are not shown on a supply plan, it is imperative that load-serving entities (LSE) have as much information as possible to aid in their procurement processes.

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

The definitions of the five categories outlined in the Straw Proposal and on slide 11 adequately reflect how RA that is not shown could be used. There are instances in which capacity could fall into multiple categories, for example, capacity that is reserved for substitution and contracted to a CAISO balancing authority area LSE but not shown. The CAISO should therefore ask scheduling coordinators (SC) to categorize the capacity to the best of their knowledge and recognize that the amount of capacity in those categories may be over- or understated depending upon the SC’s knowledge of how the capacity is being used by LSEs.

The CAISO should publicly report aggregate net qualifying capacity in each category by month. As stated in Section 1, it is imperative that LSEs have as much information as possible to aid in their procurement processes. In addition, CalCCA and other stakeholders use publicly available RA market data to analyze the state of the RA market, and this information could be beneficial in informing the reliability of the RA program, the RA market’s competitiveness, and the RA fleet’s interactions with the broader West.  

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

CalCCA has no comments on other aspects of the Straw Proposal.

4. Please provide any additional feedback not already captured.

CalCCA has no additional feedback at this time.

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

CDWR agrees with the CAISO statement: “Currently, the ISO lacks visibility into the contractual status of Resource Adequacy (RA)-eligible capacity not shown as RA. Obtaining this information will better inform the ISO’s year-ahead, month-ahead, and intra-month Capacity Procurement Mechanism (CPM) processes. Improving visibility into resource status is a crucial first step in a multi-phase effort to enhance the effectiveness of the ISO’s backstop processes.”

Track 3A of the Resource Adequacy Modeling and Program Design (RAMPD) initiative is to provide ISO personnel with enhanced visibility into the amount of capacity potentially available for Capacity Procurement Mechanism (CPM) designations. Today ISO personnel can identify capacity not shown as RA but nothing about its contractual status, and limited information about availability. In this regard, the proposal lays out a new reporting requirement (annual and monthly) for RA-eligible capacity not shown as RA that could help optimize CAISO outreach to suppliers in the event not enough CPM capacity offers are available.

The straw proposal includes 5 capacity status categories which appear to capture enough resources that may need reporting. While providing such reporting requirement information, CDWR supports the following provisions:

a) No new availability requirements associated with providing the information

b) Minimization of administrative burden

c) Understanding that intra-month changes in status will happen

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

CDWR as an LSE for RA purposes and a supplier scheduling coordinator (SC) for its own resources and loads that become part of its RA portfolio, does not have an explicit RA contract. With this fact in mind, CDWR believes category 5 (not contracted) would be the appropriate category to report the information.

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

CDWR has the following comments:

1. Submitted information should be treated as confidential, like submitted RA and Supply plans.
2. The entity responsible for submitting the information (LSE or supplier) should be clarified.
3. For summer 2025 reporting requirements, the deadline to submit the data to ISO and the monthly plan (for example, September 2025) could have conflicts if September 2025 plans deadline falls beyond the 2025 summer reporting requirements. In such case, information on September month absent final September 2025 monthly plan could be misleading.

4. Please provide any additional feedback not already captured.

No further comments.

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

Comments on Resource Adequacy Modeling and Program Design

Track 3A: Resource Visibility Straw Proposal

Department of Market Monitoring

June 17, 2025

Overview

The Department of Market Monitoring (DMM) appreciates the opportunity to comment on the Resource Adequacy Modeling and Program Design Track 3A: Resource Visibility Straw Proposal and Working Group Meeting dated May 23 and 27, respectively.[1]^,[2] In these comments, DMM adds to our previous comments from the ISO’s Resource Adequacy Modeling and Program Design (RAMPD) Revised Discussion Paper and Final Recommendation Plan and Issue Paper.[3]^,[4] DMM includes an additional comment on the following issue:

• Resource visibility. DMM supports increased resource reporting to improve system reliability, and a system understanding of market dynamics to improve reliability backstop measures and studies.

Comments

Resource visibility

The ISO can procure backstop reliability capacity through the capacity procurement mechanism (CPM) using the competitive solicitation process (CSP). The CSP uses a self-bid auction process and reveals potential resources to the ISO in the case the ISO needs to make bilateral backstop procurement to overcome system or local deficiencies. However, if the CSP does not have any available capacity, the ISO will move to bilateral outreach in the need of backstop procurement. Effective bilateral outreach depends upon the ISO having good visibility into the amount of available non-RA capacity that could be potentially procured through CPM. Such visibility is currently limited for capacity not offered into the CSP. Track 3A introduces valuable informational improvements to improve visibility, and facilitate efficient and expeditious bilateral outreach.

The ISO has not recently been deficient for generic or local resource adequacy obligations. However, these planning targets may differ from realized conditions that may necessitate backstop procurement. The most recent case where bids from resource adequacy were not sufficient to cover the market requirements for energy and upward ancillary services was in the first week of October 2024.[5] If cases such as this were to be more persistent and extreme, the ISO has the capability to use backstop procurement to meet system reliability needs, and the ISO would benefit from improved resource visibility to meet the needs of the system expeditiously.

In addition to reliability improvements, the increased visibility has value to improve policy and modeling for the CAISO system. Additional RA visibility into resources internal to the CAISO BAA would improve a system wide understanding of recent trends in the CPM and CSP, and potential improvements to the CPM.[6] This will assist in track 3B, and further improvements, as technologies and policies evolve. Further, a better understanding of resource availability would improve the ability of the ISO to model system reliability.[7]

[1] Resource Adequacy Modeling and Program Design Track 3A: Resource Visibility, California ISO, May 23, 2025: https://stakeholdercenter.caiso.com/InitiativeDocuments/Straw%20Proposal%20-%20Track%203A%20Resource
%20Visibility%20-%20Resource%20Adequacy%20Modeling%20and%20Program%20Design%20-%20May%2023%202025.pdf

[2] Resource Adequacy Modeling and Program Design Track 3A: Resource Visibility Straw Proposal Meeting, California ISO, May 27, 2025: https://stakeholdercenter.caiso.com/InitiativeDocuments/Presentation%20-%20Resource%20Adequacy%20Modeling%20and%20Program%20Design%20-%20May%2027%202025.pdf

[3] Comments on Resource Adequacy Modeling and Program Design Issue Paper, Department of Market Monitoring, December 6, 2024: https://www.caiso.com/documents/dmm-comments-on-resource-adequacy-modeling-and-program-design-issue-paper-dec-06-2024.pdf

[4] Comments on Resource Adequacy Modeling and Program Design Working Group, Department of Market Monitoring, March 13, 2025: https://www.caiso.com/documents/dmm-comments-on-resource-adequacy-modeling-and-program-design-working-group-mar-13-2025.pdf

[5] Q4 2024 Report on Market Issues and Performance, Department of Market Monitoring, March 26, 2025, p 119, Table 12.1: https://www.caiso.com/documents/2024-fourth-quarter-report-on-market-issues-and-performance-mar-26-2025.pdf

[6] Resource Adequacy Modeling and Program Design Track 3A: Resource Visibility Straw Proposal Meeting, California ISO, May 27, 2025: https://stakeholdercenter.caiso.com/InitiativeDocuments/Presentation%20-%20Resource%20Adequacy%20Modeling%20and%20Program%20Design%20-%20May%2027%202025.pdf

[7] E.g., 2025 Summer Loads and Resources Assessment, California ISO, May 5, 2025: https://www.caiso.com/documents/2025-summer-loads-and-resources-assessment.pdf

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

4. Please provide any additional feedback not already captured.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

On May 27, 2025, CAISO held a stakeholder meeting to discuss its Resource Adequacy Modeling and Program Design Track 3A: Resource Visibility straw proposal.   In the straw proposal, CAISO explains that it currently:[1]

... lacks visibility into the contractual status of Resource Adequacy (RA)-eligible capacity not shown as RA [on supply plans]. Obtaining this information will better inform the ISO’s year-ahead, month-ahead, and intra-month Capacity Procurement Mechanism (CPM) processes. Improving visibility into resource status is a crucial first step in a multi-phase effort to enhance the effectiveness of the ISO’s backstop processes.

CAISO notes that since 2019 there has been a decline in offers into the Competitive Solicitation Process (CSP) which is part of the CPM backstop process.  To improve the visibility of available capacity to the balancing authority area (BAA), CAISO proposes new annual and monthly reporting requirements for RA-eligible capacity not shown as RA supply plans to CAISO. Specifically, the CAISO proposes that scheduling coordinators report to the CAISO what quantities of RA-eligible capacity are in each of the following categories:[2]

• Sold outside the CAISO BAA.  This refers to RA-eligible capacity that has been committed outside of the CAISO BAA.
• Not shown due to being reserved for substitution.  This would include, but not limited to, the following scenarios:
  • The SC for resource A was contracted to serve as substitute capacity for resource B, controlled by a different SC.
  • The same SC controls both resources A and B so there is no contract, but resource A is being used as substitute capacity for resource B.
  • The SC for resource A is planning to sell resource A as substitute capacity
• Not shown due to potential unavailability. This refers to RA-eligible capacity that, whether contracted for RA or not, is not shown to the CAISO due to anticipated ambient derates or other outage events that suppliers believe might prevent it from operating. This includes known outages already reported in the Outage Management System (OMS).
• Contracted to a CAISO BAA LSE but not shown. This refers to RA-eligible capacity that is contracted to a CAISO BAA LSE but not shown as RA and does not fit under any of the categories above.
• Not contracted. This refers to RA-eligible capacity that is not under any kind of capacity contract and does not fit into any of the categories above.

CAISO states that the existing tariff Section 4.6.7.1 currently provides the CAISO authority for this reporting requirement.[3]  However, this summer CAISO plans to develop a tariff specific to this issue to provide greater details and include information in the business practice manual.   CAISO explains that “these reporting requirements will provide visibility without imposing new availability requirements on the reported capacity”[4].  CAISO anticipates the reporting would be done via the CIRA platform.

The CPUC Energy Division Staff (ED Staff or Staff) shares CAISO’s concern regarding the lack of visibility into RA-eligible capacity that is not reflected as RA on supply plans.   Accordingly, ED Staff is strongly supportive of the CAISO’s proposal.

[1] CAISO, (May 2025) “Resource Adequacy Modeling and Program Design Track 3A: Resource Visibility” at 3.

[2] CAISO, (May 2025) “Resource Adequacy Modeling and Program Design Track 3A: Resource Visibility” at 8.

[3] CAISO tariff 4.6.7.1: Requirements for Maintaining Records.  Participating Generators shall provide to the CAISO such information and maintain such records as are reasonably required by the CAISO to plan the efficient use and maintain the reliability of the CAISO Controlled Grid.

[4] CAISO, (May 2025) “Resource Adequacy Modeling and Program Design Track 3A: Resource Visibility” at 3.

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

 ED Staff supports the five categories

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

ED Staff recommends RA eligible resources include resources not currently on the NQC list such as new resources that are not yet on the NQC list.

4. Please provide any additional feedback not already captured.

None a this time.

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

MRP does not support the Track 3A straw proposal as proposed because (1) providing the additional data for non-RA capacity is administratively burdensome for suppliers and (2) the data does not solve the lack of participation in the Competitive Solicitation Process (CSP).

The CAISO states that “[c]onducting efficient and effective backstop procurement requires understanding what capacity is still available after accounting for all RA-shown resources.  The CSP is designed to provide this understanding.”[1]  MRP disagrees that the CSP is designed to provide such understanding.  Rather, the CSP is simply intended to efficiently and effectively procure backstop capacity under certain circumstances.  The CSP is the mechanism through which the CAISO selects backstop capacity offered. It is not intended to provide an understanding as to why capacity is NOT offered.  While LSE procurement obligations have increased, capacity accreditations have decreased and more stringent rules for imports have reduced the amount of external capacity made available for purchase in the past several years.  The CAISO does not account for these reasons as to why there is less non-RA capacity, including that available to offer in the CSP, in the past few years. 

MRP agrees with the CAISO in principle that non-RA capacity may be sold outside the CAISO BAA, not shown due to potential outage, reserved for substitution, not shown by an LSE, or simply not contracted.  MRP recommends the CAISO request such information purposefully through a one-time data request to help develop its policy in Tracks 2 and 3B.  MRP does not support providing such information on non-RA capacity on a monthly basis, especially for all months, because that information does not address the root cause of the issue, namely, the lack of CSP offers.  Specifically, the CAISO has very rarely even needed to procure backstop capacity during non-summer months and the real concerns of capacity shortfalls are still during the summer months. 

As an initial step, MRP would support a data request on non-RA capacity prior to summer 2025 so that such information can be utilized to inform Track 3B.  However, suppliers should not be required to regularly provide non-RA capacity data.

[1] CAISO Proposal at pages 6-7

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

As noted during the meeting, the reasons for why capacity is not shown as RA may fit into multiple categories.  The CAISO should not hold Scheduling Coordinators (SCs) and suppliers accountable for choosing one category over another based on their expectation of future use and need. 

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

No.

4. Please provide any additional feedback not already captured.

MRP agrees with the CAISO that the CAISO should provide better incentives for participation in its CSP, a topic slated for Track 3B.  Track 3A’s proposed solution is not the correct way to do so. 

MRP proposed a method to help CAISO and SCs track RA sales by registering transactions in the CIRA application and by allowing LSEs select the amount of capacity to show within CIRA.  This tracking addresses the CAISO’s visibility concerns for capacity (1) sold to LSEs, (2) sold outside the CAISO BAA, (3) contracted to a CAISO BAA LSE but not shown by that LSE and (4) not contracted as RA.  With regards to the other visibility issues for capacity not being shown due to it being reserved for substitution or potential unavailability, MRP’s proposal would be to rely on an outage market to encourage suppliers to make non-RA capacity available to the CAISO. 

MRP believes CAISO would have all the same information by adopting MRP’s proposed tracking system without the additional administrative burden associated with the CAISO’s proposal.  In fact, MRP’s proposed CIRA transaction tracking function would actually reduce administrative burden on SCs.  While the CAISO offered during the May 27 call that adopting a tracking system would be a broader framework change, MRP offers that it would only be an implementation change, as it would not change the RA product or the RA framework. 

MRP recommends the CAISO move forward only with its non-RA capacity data request for Summer 2025 and not implement a system requiring SCs to provide monthly data on non-RA capacity.

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

PG&E continues to support improving CAISO’s visibility into RA-eligible capacity, not shown as RA, to avoid unnecessary costs from backstop procurement or EDAM RSE failure. PG&E supports further discussion on how this information will be used to help CAISO make better decisions. 

As commented previously, the reporting should be simple, easy to implement, and should not require duplication of the current annual and monthly reporting. The template and process need further improvements before PG&E can support the proposal. PG&E encourages CAISO to work with stakeholders on an efficient solution to reduce administrative burden for LSEs, generators, and SCs.

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

No comments. 

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

No comments. 

4. Please provide any additional feedback not already captured.

No comments. 

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

SDG&E appreciates CAISO’s explanation of the problem statement and proposed solution. We support the objective of streamlining CAISO’s backstop procurement process and believe that the proposal put forth is workable. That said, reporting on a monthly and annual basis the daily contract status for each resource in a portfolio could prove administratively burdensome for Scheduling Coordinators. This information is also likely not useful for every month of the year. SDG&E encourages CAISO to consider requiring this data only for those months during which the Competitive Solicitation Process (CSP) is needed, which we anticipate would be some combination of summer months (e.g., August and September). Additionally, SDG&E appreciates that the Straw Proposal makes clear that this reporting requirement is intended to capture a snapshot in time and that there will be no penalty if a resource’s contract status changes after a report made in good faith. This acknowledges the reality that contract status is not static and provides common sense treatment of changes in contract status.

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

No comment.

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

No comment.

4. Please provide any additional feedback not already captured.

No comment.

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

The Six Cities do not oppose the CAISO’s proposed reporting requirements, subject to the CAISO’s confirmation that (1) the reporting requirements do not result in any additional must-offer or other availability obligations or commitments for the resources reported as unavailable; (2) the reporting requirements are explicitly intended to represent a “snapshot” of the resources’ status at the time of completion of the report; and (3) there is no ongoing reporting obligation or requirement to update resource status or the reason for the resources’ unavailability in the event of a post-report change.  The Six Cities likewise do not oppose the proposal to place this reporting requirement on Scheduling Coordinators for generating resources.  The Six Cities encourage the CAISO to ensure that both interim (i.e., summer 2025) reporting and longer-term reporting mechanisms minimize the administrative burden of this additional submittal requirement on reporting entities. 

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

At this time, the Six Cities do not oppose the reporting categories. 

For the reporting category of “Contracted to a CAISO BAA LSE but not shown,” the Six Cities request clarification regarding whether resources owned by an LSE (as opposed to contracted to an LSE) that the LSE elects not to show as RA (for whatever reason) should be reported in this category. 

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

 The Six Cities have no additional feedback at this time.

4. Please provide any additional feedback not already captured.

N/A

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

SCE supports the straw proposal and was happy that the majority of stakeholders at the May 27, 2025 meeting also seemed to be supportive.

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

SCE agrees that the proposed capacity categories in the straw proposal provide the proper information for the CAISO to know the status of CAISO generators and to quickly determine which resources might be available to provide CPM capacity if and when it is needed.

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

SCE appreciates the CAISO’s efforts to minimize the administrative burden and believes that this proposed mechanism achieves that goal. Similarly, SCE appreciates that the CAISO is not creating new availability requirements associated with the information provided and states that it understands that intra-month changes in status will happen.

4. Please provide any additional feedback not already captured.

No additional feedback.

1. Please provide your organization’s overall feedback on the Resource Adequacy Modeling and Program Design Track 3A straw proposal and the meeting discussion on May 27, 2025.

Terra-Gen has concerns about the California Independent System Operator's (CAISO) proposal for mandatory reporting of contracted Resource Adequacy (RA) resources that are not currently being used for RA purposes. 

Terra-Gen opposes the CAISO Track 3A proposal.  Terra-Gen recommends that CAISO should prioritize improving its existing outage and substitution rules, along with broader RA program elements, instead of taking the approach of implementing its proposed RA contracting status reporting requirements. Focusing on these areas would lead to better outcomes without imposing additional reporting burdens.

Terra-Gen highlights that the proposed reporting obligation is somewhat onerous and would require suppliers, Load-Serving Entities (LSEs), and CAISO to dedicate staff time and resources for information that CAISO has only indicated would be "nice to have," rather than demonstrating it as necessary.

Terra-Gen beleives that CAISO has not provided adequate data- and analytical-driven justification for these additional reporting requirements on unshown RA capacity contracting status. CAISO's decision to simply provide aggregate figures on the total number of MWs bid into the CAISO’s Competitive Solicitation Process (CSP) by month, as outlined in its Track 3A proposal, is hardly support for for the need for its proposal. This data is more simply an approach to identify a potential problem.  The CAISO's entire reporting requirements proposal appears to rest on its "want to have" and limited CSP participation data. Data that amounts only to a first step in indicating there is some driver for a lack of participation in the CSP process.  Further, a lack of participation in CSP could likely be explained by other dynamics, such as the existing CAISO’s Capacity Procurement Mechanism (CPM) Soft Offer Cap and current bilateral RA contract pricing divergence, as well as interactions with incentives for managing portfolios to mitigate impacts from the CAISO’s existing outage and substitution provisions.

Therefore, Terra-Gen requests that if CAISO moves forward with this reporting requirement proposal, it must provide a more data-driven justification on the magnitude and impact of the problem it is looking to address. This justification should include some additional data on the following:

• Evidence of the number of backstop mechanism offers made to contracted RA resources.
• Instances where the lack of such information has led to reliability concerns.

Without some reasonable supporting data, Terra-Gen believes the proposed reporting is an unnecessary burden on Scheduling Coordinators.

2. Does your organization have any feedback on the definitions of the five capacity categories outlined in the straw proposal and on slide 11 of the meeting presentation?

No comment.

3. Does your organization have any feedback on other aspects of the proposed reporting requirements?

No comment.

4. Please provide any additional feedback not already captured.

No comment.