​​​

Proposed Revision Request Detail Help
PRR Life Cycle*********On Hold
PRR Details
PRR #
1659
Title Flexible resource adequacy showings must-offer obligation clarification
Date Submitted 1/12/2026 7:45 AM
PRR Category A
Priority Normal
Owner Bogen, Melanie (CAISO)
Status On Hold
Status End Date 2/18/2026 11:59 PM
Related BPM Reliability Requirements
BPM Section 7.3.4, 10, 10.1.2, 10.3.5
RSS Subscribe
Existing Language

​Please see attached redline​​

Proposed Language

​Please see attached redline​

Reason For Revision

​This PRR reminds scheduling coordinators to consider how operating limitations, including those that may not be accounted for in the process of setting Effective Flexible Capacity (EFC), can impact a resource's ability to meet the flexible RA must-offer obligation for a given quantity of flexible capacity in a particular category of flexible capacity.  This change to the BPM is important to help ensure the flexible RA capacity used to meet the flexible RA requirements is operationally available.  This in turn will benefit the CAISO in meeting its operational needs.​

Announcements
This PRR has been placed on hold to allow additional time to review and consider the comments received.
Posted On - 3/2/2026 5:20 PM
Impact Analysis
Impact Analysis not available.
Initial Comments
CPA Comments on PRR 1658 & 1659_Final.pdf    
We have received written comments from Ben Gustafson on behalf of Clean Power Alliance on 2/18/26. Please see attached.
2/18/2026 4:46 PM
Logged By - Madrigal, Radha (CAISO)
Joint CCA Comments on PRR 1659.pdf    
We have received written comments from Sabrinna Soldavini on behalf of Marin Clean Energy, Pioneer Community Energy, San Diego Community Power, and San José Clean Energy on 2/18/26. Please see attached.
2/18/2026 4:32 PM
Logged By - Madrigal, Radha (CAISO)
WPTF appreciates the opportunity to submit these very brief comments. We believe that these changes warrant further policy discussions as they seem to potentially reach beyond changes that should be made through the BPM process. Additional policy discussions would allow for stakeholders to engage in dialogue with the CAISO staff and provide feedback in a more interactive manner.
2/18/2026 3:57 PM
Logged By - Gridwell Consulting for WPTF (Western Power Trading Forum)
The Six Cities request further explanation of the underlying purpose for and the intended scope of the language the CAISO proposes to add to Sections 7.3.4, 10.1.2, and 10.3.5 of the BPM for Reliability Requirements regarding adjustment of Flexible Capacity showings “in the RA process” to reflect the impact of “operating limitations” on capacity “the Scheduling Coordinator reasonably expects can be met with feasible bids.”  The Six Cities have followed the discussion of foldback/non-linearity issues in the Storage Design and Modeling initiative and question whether the language proposed for Sections 7.3.4, 10.1.2, and 10.3.5 seeks to address the foldback/non-linearity concerns.  If that is the case, more focused and targeted BPM revisions may be acceptable.
The Six Cities are concerned, however, with the potential breadth of the language proposed.  It is not clear, for example, whether the term “operating limitations” in the proposed language is meant to be synonymous with “use limitations” reflected in the categories of Flexible Capacity for Use-Limited resources.  See, e.g., BPM Section 10.3.5.  If, however, the CAISO intends the terms to be interchangeable, the proposed new language is inconsistent with the eligibility criteria for the Flexible Capacity categories based on use limitations established in the tariff and registered in the master file data.  See Tariff Section 40.10.3.
The proposed additions to Sections 7.3.4, 10.1.2, and 10.3.5 appear to add a new requirement for Scheduling Coordinators to assess “at the time of flexible RA supply plan submission” whether “operating limitations would prevent the resource from meeting the must-offer obligation for that minimum qualified capacity with feasible bids.”  If a resource’s “scheduling coordinator reasonably could foresee at the time of flexible supply plan submission that operating limitations would prevent the resource from meeting the must-offer obligation for the full EFC value with feasible bids,” the Scheduling Coordinator would be required to adjust the category (Sections 7.3.5 and 10.3.5) or quantity (Section 10.1.2) of Flexible Capacity shown.  Because the use limitations that define three of the Flexible Capacity categories include maximum starts per month, Scheduling Coordinators would be forced to “reasonably foresee” how often the CAISO might wish to dispatch their resources.  Scheduling Coordinators also would be expected to “reasonably foresee” the frequency of conditions that might trigger other types of use limitations, such as environmental limitations.  Such a requirement would significantly alter the eligibility criteria for Flexible Capacity set forth in the tariff, would impose unreasonable burdens and risks on Scheduling Coordinators, and would be difficult to administer and enforce.
2/18/2026 2:52 PM
Logged By - Bonnie Blair (Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, CA)
2026-02-18-CESA Comments on PRR1659.pdf    
We have received written comments from Perry Servedio on behalf of CESA on 2/18/26. Please see attached.
2/18/2026 1:55 PM
Logged By - Madrigal, Radha (CAISO)
Recommendation Comments
No Recommendation Comments available for this PRR.
Attachments