RSS Feed for Proposed Revision Request - 1610

PRR - 1610

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Initial Comment for PRR - 1610

Description: NCPA requests for CAISO to reconsider the self-schedule requirement for Stage 2 VERs proposed in PRR 1610. CAISO describes Stage 2 as the period between COD and issuance of the CAISO VER Forecast. CAISO reasons that the EIR must self-schedule due to the lack of a forecast. Counter to CAISO’s points, NCPA successfully bids in Stage 2 resources by utilizing non-CAISO VER forecasts. In an effort to formalize this practice, NCPA is currently working with CAISO staff to utilize ALFS for Stage2 VER Forecast submittals (see CIDI 00278958). NCPA strongly opposes any self-schedule requirements for an EIR due to extreme price risk associated with negative pricing. Economic bidding is an essential tool required to mitigate such price risk.
-By Mike Whitney (NCPA) on Thursday, January 9, 2025 9:25:17 AM

Initial Comment for PRR - 1610

Description: WPTF opposes the CAISO proposed BPM language in PRR 1610, specifically the new requirement for VER resources to self-schedule while they are in Stage 2. Any bidding restrictions (in this case not allowing VERs to economically offer) directly impact rates, terms, and conditions and thus must be reflected in the Tariff. We not only oppose this from a market perspective, but also the fact that the change is being done through the BPM change process rather than a policy effort and subsequent FERC filing. Additionally, this language now creates a conflict between the CAISO Tariff and BPM as it relates to the bidding of VER resources.
-By Gridwell Consulting for WPTF (Western Power Trading Forum) on Thursday, January 9, 2025 1:34:34 PM

Initial Comment for PRR - 1610

Description: Terra-Gen, LLC - Initial Comments on PRR 1610 Terra-Gen opposes PRR 1610 and concurs with the initial comments of NCPA and WPTF opposing the PRR. Terra-Gen owns and operates VER resources and would be faced with undue price risk if forced to self-schedule Stage 2 VERs and, similar to NCPA, has good experience providing forecast based economic bids for Stage 2 VERs. Terra-Gen also highlights the WPTF feedback that this modification amounts to a policy change and is not appropriate for a PRR BPM change. Such modifications should be developed through formal stakeholder proceedings and CAISO Board of Governor's consideration.
-By Chris Devon (Terra-Gen, LLC) on Thursday, January 9, 2025 4:45:48 PM

Announcement for PRR - 1610

Description: To allow additional commenting time and stakeholder review, this PRR will be in the initial phase for 2 months. We have extended the initial comment phase to Feb 19.
-By Hines, Nicole on Wednesday, January 29, 2025 9:50:26 AM

Initial Comment for PRR - 1610

Description: Please see the attached comments from the Large-scale Solar Association (LSA).
-By Susan R. Schneider (Phoenix Consulting) on Wednesday, February 19, 2025 11:47:57 AM

Initial Comment for PRR - 1610

Description: On 2/19 CAISO received written comments from Jack Watson at Clearway Energy.
-By Hines, Nicole on Wednesday, February 19, 2025 6:31:32 PM

Announcement for PRR - 1610

Description: To allow additional commenting time and stakeholder review, this PRR will be in the initial phase for another month. We have extended the initial comment phase to Mar 18.
-By Hines, Nicole on Tuesday, February 25, 2025 2:48:27 PM

Initial Comment for PRR - 1610

Description: The ISO has received written comments on 3/17/2025 from Ben Gustafson from Clean Power Alliance.
-By Williamson-Duffney, Joseph on Wednesday, March 19, 2025 3:09:03 PM

Announcement for PRR - 1610

Description: This PRR is now On-Hold pending a review of all comments received and forthcoming response from the CAISO.
-By Martin, Michael on Thursday, March 27, 2025 8:59:07 AM

Announcement for PRR - 1610

Description: This PRR has been Withdrawn. Should any new BPM language be proposed on this topic, a new PRR will be created.
-By Martin, Michael on Monday, March 31, 2025 10:19:35 AM