PRR - 1630

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Impact Analysis for PRR - 1630

-By Bogen, Melanie on Monday, June 2, 2025 8:28:42 AM

Initial Comment for PRR - 1630

Description: NCPA seeks clarification on the result of the changes proposed in PRR 1630 regarding Generating Units’ deliverability status. We understand the deletion to mean that CAISO will no longer eliminate or reduce deliverability rights as a result of a consecutive three-year period of becoming incapable of operating at the capacity level associated with its rated deliverability. As a result, a Generating Unit will retain deliverability, regardless of whether it demonstrates that it is actively engaged in the construction of replacement generation to be connected at the bus associated with the deliverability priority. NCPA requests for CAISO to withdraw PRR 1630 and instead proceed through a stakeholder initiative to provide clarity on this important issue. NCPA relies on language from RR BPM 6.1.3.4 in its planning process, and further explanation and clarity is needed to ensure that deliverability is not inappropriately reduced. Moreover, further changes would be needed to ensure that the BPM and Tariff are consistent throughout—e.g., the BPM for Generator Management 13.1 refers to the struck language in the RR BPM, which would create further confusion.
-By Mike Whitney (NCPA) on Tuesday, June 17, 2025 4:19:18 PM

Response: The CAISO plans to address this policy more holistically with stakeholders in the future, both in the BPMs and the tariff. PRR 1630 is the direct result of FERC’s recent finding against the specific BPM provision, which is no longer tenable to maintain in the BPM. https://www.caiso.com/documents/apr-29-2025-order-addressing-arguments-raised-on-rehearing-and-setting-aside-prior-order-in-part-saavi-v-caiso-cometa-energia-complaint-el24-92.pdf
-By Bogen, Melanie on Monday, June 23, 2025 4:44:41 PM

Recommendation for PRR - 1630

Proposed Language:

Approve the BPM PRR as submitted

Apparent Requirement: N/A
Priority: N/A
Action: Approve the BPM PRR as submitted
Effective Date: 01/01/0001
Other Actions: N/A

Final Decision for PRR - 1630

Final Decision: Approve the PRR as submitted.
Stakeholder Comment: N/A
Action: Adopt the recommendation as originally issued
Effective Date: 07/28/2025

RSS Feed for Proposed Revision Request - 1630

PRR - 1630

Impact Analysis for PRR - 1630

Initial Comment for PRR - 1630

Recommendation for PRR - 1630

Final Decision for PRR - 1630