Proposed Revision Request Detail Help
PRR Life Cycle********Appeal Pending*
PRR Details
Title Local regulatory authority resource adequacy adjustments
Date Submitted 8/27/2020 5:39 PM
PRR Category B
Priority Normal
Owner Mohammed-Ali, Abdulrahman (CAISO)
Status Appeal Pending
Status End Date 11/13/2020 11:59 PM
Related BPM Reliability Requirements
BPM Section 4.1
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Existing Language
See attached redline BPM version
Proposed Language
See attached redline BPM version
Reason For Revision
Process for local regulatory authority resource adequacy (LRA RA) adjustments (credits) submission and when/how they can be applied
Click here to view the Recommendation Details for this PRR
BPM PRR Submitter

Mohammed-Ali, Abdulrahman (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

See attached revised document with proposed modified BPM language.
Identification of the authorship of comments


Approve the BPM PRR as modified.

Statement of apparent requirements of the BPM PRR

Priority and rank for any BPM PRR requiring a CAISO system change

Proposed effective date(s) of the BPM PRR

Other recommended actions

Click here to view the Final Decision for this PRR
Final Decision

Approved posted revised language
Stakeholder Comment

Reponses matrix attached

Effective Date


Adopt the recommendation as modified

New Emergency PRR 1316 has clarifying language in regards to PRR 1280 appeal. Please review PRR 1316 for current update.
Posted On - 1/12/2021 10:11 AM
The following market notice was posted on December 9, 2020:
BPM Change Management PRR 1280: Executive Appeals Committee Decision Posted

The California ISO Business Practice Manual (BPM) Change Management process enables the ISO and affected parties to appeal a final decision for reconsideration on a Proposed Revision Request (PRR) to an appeals committee. As a follow up to the Dec. 1, 2020 appeals committee meeting, the written decision of the Executive Appeals Committee for PRR 1280, Local Regulatory Authority Resource Adequacy Adjustments, has been posted to the ISO website at

The appeals and appeals process documentation are available on the ISO website at
Posted On - 12/24/2020 1:13 PM
CAISO attached the expedited timeline for an appeal process for PRR 1280. In order to follow this timeline, any appeals must be filed by 11/13/2020. Please reach out to if there are any questions.
Posted On - 11/5/2020 10:44 AM
The ISO has posted a response to initial comments.
Posted On - 10/6/2020 4:46 PM
The ISO has attached a revised version of the BPM for Reliability Requirements.
Posted On - 10/6/2020 4:45 PM
Impact Analysis
Impact Analysis not available.
Initial Comments
ISO responses to initial comments
10/6/2020 4:43 PM
Logged By - Nicosia, Isabella (CAISO)
Please see attached.
9/16/2020 3:48 PM
Logged By - Aditya Chauhan (SCE) (Southern California Edison)
Please see PG&E's comments to PRR 1280 in the attached document.
9/16/2020 1:21 PM
Logged By - Pedram Arani (Pacific Gas & Electric)
Please see SDG&E's comments to PRR 1280 in the attached document.
9/16/2020 10:05 AM
Logged By - Nuo Tang (SDG&E) (San Diego Gas & Electric Company)
CPUC Energy Division Comments on CAISO's BPM PRR 1280
9/15/2020 7:57 PM
Logged By - Michele Kito (CPUC)
Recommendation Comments
Please see the attached comments for the recommendation phase of PRR 1280.  Thank you.
10/20/2020 4:50 PM
Logged By - Nuo Tang (SDG&E) (San Diego Gas & Electric Company)
Please see attached CalCCA reply comments on CAISO PRR 1280.
10/20/2020 4:16 PM
Logged By - Stefanie Tanenhaus (CalCCA)
Please see attached.
10/20/2020 3:41 PM
Logged By - Aditya Chauhan (SCE) (Southern California Edison)
CLECA Comments on PRR1280
10/20/2020 3:39 PM
Logged By - California Large Energy Consumers Association (CLECA) (California Large Energy Consumers Association (CLECA))
Please see NCPA's attached Recommendation Comments for PRR 1280
10/20/2020 2:36 PM
Logged By - Mike Whitney (NCPA)
Please see PG&E's attached Recommendation Comments for PRR 1280.
10/20/2020 11:20 AM
Logged By - Pedram Arani (Pacific Gas & Electric)
CPUC Energy Division Staff Recommendation Comments
10/20/2020 10:11 AM
Logged By - Michele Kito (CPUC)
Click here to view the Appeals for this PRR
Click on the '+' icon to submit a New Appeal

# of Appeals In Progress - 6
# of Appeals Closed - 0
# of Appeals Abandoned - 0
#Appeal ReasonStatusResponseAppealed ByAppealed On
1Please see attached appeal.SubmittedMichele Kito (CPUC)11/13/2020
2Please find attached the Metropolitan Water District of Southern California's Notice of Appeal of the CAISO's final decision on PRR 1280..
SubmittedMark Parsons (Metropolitan Water District of Southern California)11/13/2020
3Please see attached.SubmittedAditya Chauhan (SCE) (Southern California Edison)11/13/2020
4CLECA hereby submits its NOTICE of appeal of PRR 1280; CLECA's appeal is based on the following: (1) the CAISO Board did not approve an all-encompassing requirement for all demand response to be shown on supply plans, just "slow" PDR; (2) the PRR is not necessary for any other PDR, nor is it necessary for RDRR, as demonstrated by RDRR's successful performance during the August and September heat wave events; (3) the PRR contravenes the State's Loading Order and Public Utilities Code section 454; (4) the PRR is not ministerial in nature, and could have a material impact  on rates and accordingly should be a tariff filing submitted to FERC; (5) the PRR wrongly, unilaterally and without partnership with the CPUC, would change current RA crediting and counting practices for demand response, a preferred resource, impacting the Base Interruptible Program, which as RDRR performed very well during the August and September heat storms and prevented additional blackouts; any claim of a lack of confidence in the BIP/RDRR resources is both spurious and insulting.   
CLECA's actual appeal brief will be submitted on Nov. 23, 2020, concurrently with the CAISO's brief.                                                                                   

SubmittedNora Sheriff (CLECA)11/13/2020
5PG&E is submitting an intent to appeal on PRR 1280. PG&E’s appeal will primarily center on the issues previously identified in earlier comments. PG&E has been actively working with the CAISO and other stakeholders to address the issues related to PRR 1280.”SubmittedPedram Arani (Pacific Gas & Electric)11/13/2020
6The CAISO has received written appeal for PRR 1280 on 11/13/2020 from Luke Tougas representing California Efficiency and Demand Management Council. Please find appeal attached. SubmittedHines, Nicole (CAISO)11/16/2020