Comments on February 22, 2024 working group

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

Bonneville appreciates the CAISO extending the opportunity to Bonneville to suggest exploring a post-dispatch accounting option in this stakeholder process.  Bonneville ranks this as a high priority issue for this work group to tackle. Compared to a solution that involves developing a dispatch-based approach for entities outside of the GHG Pricing Areas, Bonneville believes a post-dispatch accounting solution can be implemented more expediently, provides equal opportunity for use of an accounting solution for all market participants that need or want such a solution, avoids creating inefficiencies within the market dispatch, and may go a long way in meeting a wide range of entities’ needs for at least the near-term time horizon. Bonneville suggests that the accounting should be based on ownership and contractual rights to power and looks forward to further discussion of this topic in the workgroup. 

Bonneville also recommends the work group consider adjustments to the market design for GHG pricing programs to better enable attribution of resources committed to load in the GHG pricing area. Bonneville is concerned that the current design will not ensure attribution of Bonneville’s resources to Washington. Bonneville serves nearly 50 percent of the power consumed in Washington, with much of that sold to its public power customers under long-term (20 year) contracts. There will be adverse impacts to Bonneville if energy from the federal system that is contracted to Bonneville’s customers in Washington is not given equal opportunity (as compared to generation physically located inside the state) to be attributed to Washington. This is because at times when the federal system is not attributed to Washington, Bonneville may not be able to recover the difference between the price Bonneville receives for the federal system and the cost Bonneville pays for its load in the GHG area. This adverse impact could be felt not just by Bonneville, but by any load in Washington that contracts for clean energy that is located outside the state. As a result, Bonneville is concerned the current market design could disincentivize investment in renewable energy located outside GHG pricing areas and/or dissuade loads and resources from fully participating in the market. 

This issue has parallels to a post-dispatch accounting framework that is based on contractual rights to power. Bonneville suggests the work group consider adjustments to the market design for GHG areas to provide similar opportunity for GHG accounting (attribution/assignment) of power that has been contracted to loads in the market footprint, regardless of whether the load and resources are inside a GHG pricing area or not.

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

No comment.

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

No comment.

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

No comment.

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

No comment.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

No comment.

7. Provide your organization’s comments on the emissions reduction policies topic:

See comment #1

8. Additional comments:

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

CRS supports better AER data but encourages CAISO to pursue market residual mix emissions factors which are more appropriate to replace default emissions factors used to characterize market purchases for retail sales. We emphasize the importance of coordination with other accounting systems/frameworks both to avoid double counting of attributed generation using new metrics (PS 6d) and when potentially introducing new post-dispatch accounting frameworks to enable market participation by entities in states with non-pricing GHG programs (PS 7) and that serve the needs of customers with energy and emissions reporting requirements. We also emphasize that this coordination falls within CAISO’s jurisdiction.

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

None at this time

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

None at this time

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

None at this time

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

We support producing better AER data and we have commented on some of the uses for this data in previous comments. At the working group meeting, it was suggested that better AERs could replace default emissions factors currently used in some states/programs. However, an AER should not necessarily be used to replace default emissions factors everywhere they are used. An AER is not the market residual mix number that is really needed to characterize retail deliveries/purchases, for example. There is double counting of some generation in that case. Working group participants mentioned the need for averages of different subsets of resources. One subset is the subset of generation that has not been attributed to GHG zones or otherwise transacted on a resource-specific basis. That could be useful to replace default emissions factors that are currently used to characterize market purchases. We encourage CAISO to also pursue this and other metrics along with improved AERs.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

Regarding 6d, there was some discussion of whether this problem statement falls within CAISO’s jurisdiction. It is within CAISO’s jurisdiction to coordinate with WREGIS to identify WREGIS generation that has been attributed to GHG compliance zones in the market. WREGIS can tag generation and then different states and programs can decide whether using those RECs should be eligible in their programs. This problem statement pertains to data transparency and coordination among attribution systems.

One participant commented that there is not agreement that coordination is necessary and suggested that this problem statement say that there is no requirement from states that there be coordination. There does not need to be a state requirement for coordination, though states could request it, and coordination would not affect the ability of any state or market participant to do what it wants. Neither would a problem statement about the lack of state requirements be relevant for CAISO. As written, 6d is a problem statement for CAISO—the lack of coordination on market attributions with WREGIS. It is not required that everyone agree that coordination is necessary or that market attribution affects WREGIS. It is relevant to jurisdictions that do think resource-specific attributions in the markets to certain states and zones affect other attribute transactions.
Coordination and data sharing to address the problem statement would not change market or WREGIS functionality or state policy.

7. Provide your organization’s comments on the emissions reduction policies topic:

The discussion about prioritizing development of a post-dispatch accounting framework (vs. dispatch-based framework/solution) to facilitate goals and needs of LSEs in states with emissions regulations/caps (non-pricing) again highlights the need for coordination with other accounting frameworks. Coordination with other accounting instrument systems must be a part of the discussion. Such an accounting framework should be coordinated with existing accounting systems that are used for resource-specific retail delivery claims, whether related to resource type or emissions. If there are multiple systems/frameworks in the region for accounting for generation attributes (e.g. emissions), then we run the risk of double counting.

During the discussion, CAISO asked how this relates to reporting metrics problem statement (PS 6). We view this as related to a different problem statement (PS 7). The problem here is that entities with emissions reduction goals or obligations cannot currently choose what they get from the market. That requires a new non-price-based attribution accounting system. Coordination to avoid double counting is needed for both reporting about existing attribution and for any future attribution or accounting frameworks/mechanisms.

We have two comments related to the Emissions Reduction Policies presentation. First, while in most cases we have not yet reached the target dates set by these policies, reporting is happening now in most states. As such, these policies are affecting the needs and behavior of entities in those states now. Second, we recommend framing this problem to be a bit broader than states and utilities. It is also about the needs of energy users with emissions targets or requirements that will need to report retail consumption and will need to choose clean or carbon-free from their suppliers. It is not just states and voluntary programs anymore, but now federal policy and incentives affecting the need to track emissions to load. For example, the SEC may be requiring or advising corporate users to report. The Department of Treasury has also new proposed requirements for the IRA 45V tax credit for clean hydrogen, specifically for electrolytic hydrogen production, under which those users will need to demonstrate use of low-emitting power to receive the tax credit. Consistent tracking of GHG emissions to load is needed in order for energy users to participate in federal programs. Specifically, an accounting mechanism that serves the needs of these users and federal programs must be coordinated with energy attribute certificate (EAC), or REC, systems since that is the direction that is those programs are heading:
https://www.federalregister.gov/documents/2023/12/26/2023-28359/section-45v-credit-for-production-of-clean-hydrogen-section-48a15-election-to-treat-clean-hydrogen  
 https://www.energy.gov/sites/default/files/2023-12/Assessing_Lifecycle_Greenhouse_Gas_Emissions_Associated_with_Electricity_Use_for_the_Section_45V_Clean_Hydrogen_Production_Tax_Credit.pdf  
 

8. Additional comments:

None at this time

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

PG&E appreciates the opportunity to offer its comments on the GHG Working Group session 7. PG&E’s comments can be summarized as follows:

• PG&E continues to support Problem Statement 1 and is willing to sponsor it.  We suggest addressing PS 1 prior to addressing PS 2 and 3.
• PG&E support CAISO’s “evergreen training” effort and look forward to seeing it in practice.
• PG&E appreciates the transparency on the Average Emissions Rate and would appreciate hearing CAISO’s thoughts on these data.

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

PG&E continues to support Problem Statement 1 and is willing to sponsor it.  PG&E suggests performing analysis and discussion of PS 1 prior to addressing Problem Statements 2 and 3.  

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

PG&E strongly supports Evergreen Training. It sounds like an excellent idea (for all initiatives) and should help stakeholders focus on the issues core to each initiative.

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

PG&E continues to volunteer to sponsor problem statement 1.  Finally, the lack of sponsorship suggests that these problem statements should be de-prioritized.  If no-one is willing to speak up for the problem statement, why are we spending time on it?

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

PG&E supports additional transparency and the Average Emissions Rate and the Average “Deemed Delivered” Emissions Rate.

We do have concerns that these data could be misinterpreted. It may be helpful for the CAISO staff to spend some time in the next working group discussing these data to provide further context and interpretation.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

No comments.

7. Provide your organization’s comments on the emissions reduction policies topic:

No comments.

8. Additional comments:

No comments.

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

PacifiCorp appreciates the working group conversations moving toward potential solutions for the beyond price based GHG policy topic and looks forward to further discussions at the March 14, 2024, working group meeting. Overall, PacifiCorp supports the proposed evergreen trainings, problem statement sponsors and co-sponsors, the roll out plan for the average emission rate report, continued collaboration on gearing the problem statements to what the CAISO can help solve as the market operator (as opposed to what problem statements can be solved by regulators or complying entities) and consolidating problem statements.   

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

PacifiCorp does not have suggestions at this time; However, PacifiCorp believes problem statements1 through 3, and 6g are all problem statements that are related in that each relate to how the market is identifying surplus, attributing resources, and balancing leakage and costs.  

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

PacifiCorp supports the ISO’s proposal to publish Evergreen Trainings. As referenced in prior comments, PacifiCorp believes having a solid foundation of understanding will help the stakeholder community progress to the solution phase of this effort then proceed to a full stakeholder initiative. PacifiCorp looks forward to submitting topics and reviewing posted training sets before engaging those topics in the working group.  

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

PacifiCorp believes a problem statement sponsor or co-sponsor is a stakeholder that either proposed the problem statement and has the background knowledge or experience to lead a robust discussion. The CAISO role should be to work alongside the stakeholder(s) to create discussion materials for the group that are in the scope of the market operator, so the working group is kept on track in creating solutions. Additionally, the CAISO should continue to set up, attend, and record the meetings like what is in place today. 

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

PacifiCorp supports exploring different permutations of the calculation, as noted in the past, and believes the roll out plan for publishing the average emission rate data is sufficient. As more data becomes available, PacifiCorp would like to continue to discuss within the working group the outcomes of the varying methodologies.  

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

PacifiCorp agrees there are problem statements that could either be consolidated or are out of scope of the market operator. Problem statements 6a and 6b are both true statements inherently describing the same compliance framework (assigning total emissions to retail load) and could be consolidated to say, “Entities in jurisdictions with emissions reductions targets must fulfill reporting obligations with state policy, which requires reporting of total emissions to serve load, including market imports.” PacifiCorp believes problem statements 6c and 6d are out of the scope of the market operator’s role to solve them, and although they are known issues, both statements should be eliminated from the discussion as problem statements for CAISO to solve.  Different regulatory agencies in different states would have authority to address those issues. 

7. Provide your organization’s comments on the emissions reduction policies topic:

As discussed during the February 2024 working group meeting, there are multiple emissions reduction policies in the West that currently are not accounted for within the market due to their lack of a pricing component. Through the working group, Bonneville Power Administration (BPA) proposed that a post-dispatch accounting framework could work to address this issue as, depending on details, it could resemble what entities use today in such jurisdictions and represent an incremental improvement on current practices rather than require a market design overhaul. PacifiCorp believes scenarios A through D could essentially all be addressed through a post-dispatch accounting framework, provided that the accounting methodology supports the ability to meet those emissions targets. PacifiCorp thanks BPA for bringing this proposal forward and would like to see stakeholders further explore if this is a viable solution.

8. Additional comments:

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

PGE particularly appreciated the discussion of emissions reduction policies in different states and the conversation about the average emissions rate. PGE recommends that framing and consolidation of the problem statements be finalized soon so that concerted discussion and stress testing of solutions can accellerate.   We appreciate the iterative process and observe increasing coalescence around the problem statement themes. 

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

 No comments

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

PGE appreciates this idea and effort as a helpful way to inform the stakeholder discussion.

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

A problem statement sponsor or co-sponsor is a convener and discussion driver. The work done by the sponsor and any organizations they convene must be brought back to the full working group. The CAISO should schedule and help administer problem statement meetings. CAISO staff should attend any official problem statement meetings. CAISO staff should provide data or analysis as needed to support solutions.

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

PGE appreciates CAISO’s efforts to define and provide an average emissions rate that is published regularly for participants and the public.  We look forward to working with CAISO staff and Oregon regulators to determine how to utilize this data for state-required greenhouse gas reporting.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

• PGE finds problem statement 6(a) and 6(b) very similar as discussed in the workshop and believes any combined problem statement should retain the element of state policy compliance and the associated reporting. PGE requests that the final version of problem statements 6a and 6b continue to reference reporting related to emissions reduction targets established by state policy.
• PGE agrees with comments in the working group meeting that statement 6(c) is better left to state regulators that set unspecified emissions rates by rule. 
• PGE believes that problem statement PGE believes that problem statement 6e would apply in RT and in the EDAM.

7. Provide your organization’s comments on the emissions reduction policies topic:

PGE is interested to better understand the residual emissions factor concept discussed at the last meeting; we have not yet evaluated this concept in the context of CAISO GHG attribution or accounting. We also appreciate CAISO staff’s presentation on the range of states with non-price GHG reduction policies in the electricity sector, underscoring the importance of addressing policy compliance needs for many of the utilities in these states to participate in expanded regional electricity markets.

8. Additional comments:

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

PGP appreciates the opportunity to submit comments on this greenhouse gas (GHG) working group discussion. So far in this process, CAISO staff has compiled a significant amount of information from stakeholders and has identified a series of issues and workstreams that are likely to ultimately improve current and future market interactions with GHG accounting, state policies, and individual market participants and/or customer voluntary GHG or clean energy goals. However, at this point in the process there is a need to consolidate issues more concisely and identify specific workstreams and actions that the working group will take. The problem statements, as currently written and organized, contain a wealth of good content but are not organized in a way that can be clearly understood nor are they grouped consistently by issue. For instance, Problem Statement #6 (emissions tracking and accounting), as subdivided in the presentation at the workshops, includes a series of issues related the other problem statements, including: 1) the current approach to GHG pricing programs in EIM and proposed approach in EDAM; 2) reporting obligations and needs outside of the current EIM and proposed EDAM designs; 3) GHG metrics; and 4) coordination with state policies / other existing accounting mechanisms. In this context, the task of articulating discrete problem statements and issues is challenged due to the relatedness and interdependencies of many of the problem statements and issues. In these comments, PGP suggests a way to consolidate and organize the issues and problem statements.  Regardless of if this specific proposal is adopted, PGP recommends that working group members and/or CAISO staff consolidate the issues and problem statements concisely and proceed very quickly from the problem statement development phase to substantive discussions and evaluating solutions.   

Below is PGP’s re-framing of the issues for consideration by the working group.  PGP believes the below four categories can be approached discretely, though there are overlapping issues and in particular PGP recommends that Issue Category #2, addressing non-pricing programs, be completed prior to Issue Category #3, exploring whether market mechanisms are appropriate or necessary for addressing non-pricing programs or reflecting voluntary goals. The specific reasons for this are described in more detail in response to Question # 7.

Issue Category #1: ISO Market Operations & GHG Design – Current Approach to GHG Pricing Programs in WEIM

• Problem Statement: market participants and stakeholders do not have enough information to evaluate whether the WEIM design works as intended
  • Identifying available surplus for attribution to a GHG zone
  • How much secondary dispatch is occurring
  • Relationship between how leakage is addressed and price signals / cost
  • Understanding marginal GHG costs
  • Documentation of additional metrics to enable stakeholders to better evaluate the design

Issue Category #2: Addressing Non-Pricing and Clean Energy Policies, and Voluntary Goals

• Problem Statement: the current WEIM and proposed EDAM GHG designs only address GHG pricing programs and do not facilitate the needs of other types of GHG or clean energy state policies or voluntary utility or customer GHG or clean energy goals
  • Metrics and accounting frameworks are needed to facilitate mandatory and voluntary reporting of emissions and clean energy
  • Calculating unspecified or market mix emissions rates
  • Addressing double-, under-, or over-reporting and areas where different accounting frameworks cannot be reconciled
  • Emissions intensity and/or specified resource transfers or imports and/or total emissions /specified imports used to serve load
  • Is a dispatch solution needed or will a transparent accounting framework sufficiently meet needs
  • Relationship with GHG pricing program design   

Issue Category #3: Exploring Mechanisms for Addressing Non-Pricing and Clean Energy Policies, and Voluntary Goals

• Problem Statement: no market mechanism currently exists to reflect policies that require emissions reductions but do not establish a GHG price
  • Ensuring load is served by resources that meet emission reduction requirements or goals

Issue Category #4: Other GHG & Policy Metrics – Stakeholders desire additional metrics not currently available related to emissions and renewable energy (anything not covered in other Issue Categories)

• Problem Statement: granular information regarding emissions rates, renewable curtailment, and GHG cost data is not uniformly available
  • Average emissions rates (different permutations)
  • Other as suggested

With the above re-framing, PGP suggests incorporating the ‘state coordination’ topic into the issue categories identified above where appropriate. While PGP supports identifying areas where state coordination is necessary and/or helpful, the issue categories should be focused on what is within the working group’s and the market operator’s scope.

PGP recommends that the working group establish participant co-sponsors and/or leadership roles for the each of the above issue categories to help guide next steps.

In addition to the above, PGP proposes an additional issue for consideration by the working group which most likely fits into either Issue Category #1 or Issue Category #2. The issue relates to the treatment of existing long-term contracts and how they are attributed to the GHG Regulation Area specifically in the context of energy attributed to Washington. PGP is concerned with a potential issue if entities with long-term contracts or owned resources located outside of the state of Washington are not able to credit those resource to hedge their GHG cost exposure. This is particularly potentially an issue where the load and resources may be within the same balancing authority area (e.g., Bonneville) but the resources are programmatically treated as outside of Washington. PGP is interested in dialogue on this issue and potential further articulation of a sub-category problem statement.

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

See above proposed Issue Statement #1. PGP recommends that all issues related to the performance of the current WEIM GHG design and how the potential impact on the EDAM design be consolidated into a single problem statement with sub-categories of problems.  This can include metrics that are needed or will be needed to assess the performance of the design in the context of the WEIM or EDAM.

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

PGP is supportive of the concept of “Evergreen Trainings” and would appreciate having a library of materials that can be drawn upon as educational for new stakeholders or as a refresh of topics that may not have been discussed for some time.  PGP recommends that the CAISO start with foundational background and established topics that are unlikely to change or need to be updated frequently. PGP recommends against addressing topics that are directly relevant to current decision-making – if there are relevant foundational topics that are directly relevant to a current decision-making topic, it may still be appropriate to present the foundational information in a regular stakeholder meeting.

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

PGP is supportive of establishing sponsors or co-sponsors for specific issue categories and/or individual problem statements. Sponsors of a particular issue could serve as a leadership team for the working group on a particular topic and could provide key support in terms of guiding discussion, defining issues and solutions, and articulating action items. As has been discussed extensively in the context of the working group meetings, the GHG topic is very challenging both from a technical market design perspective as well as determining where and how state policies should be implemented in the context of an organized market. Sponsors can play a key role for the working group in terms of: 1) helping to synthesize information from stakeholders and suggest next steps and solutions; 2) bring context and a broader framework to the discussion based on specific expertise or experience. Further, given the likelihood of diverse views within the working group as solutions are developed, PGP believes that the sponsors can play a key role in terms of driving the working group toward consensus or near-consensus approaches. Importantly, the sponsor role should be that of guiding the intention of the working group as a whole and not an opportunity to advance an individual agenda or position.

PGP is interested in a sponsor or co-sponsor role associated with Issue Category #2 identified above (Addressing Non-Pricing and Clean Energy Policies, and Voluntary Goals). PGP believes that this translates to elements of current problem statements 5, 6, and 7.  PGP is not proposing to sponsor all three but would appreciate discussion with CAISO staff and other interested co-sponsors on how best to allocate sponsorships if the current problem statements are maintained.  PGP also recommends considering ensuring representation from geographically diverse areas as well as states with different types of programs represented.

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

No comment at this time.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

PGP would propose re-framing and re-categorizing the metrics problem statements as defined in the response to Question # 1. As noted above, problem statements 6a – 6g incorporate many issues associated with the other problem statements including current WEIM GHG design, tracking and reporting, and state coordination.  Rather than include a separate problem statement for metrics, PGP proposes that each issue category include a sub-category or sub-problem statement dealing with metrics and identifying the metrics specifically related to that issue category or problem statements.

Furthermore, the current problem statement 6a – 6g does not adequately address the issue of key metrics that stakeholder would like to see for transparency purposes but that are not necessarily otherwise tied to a particular issue category or problem statement. The availability of metrics should not be tied to a specific problem statement since data availability generally supports transparency and assists stakeholders in evaluating issues generally.  PGP understands that every request for a specific metric may not be prioritized for a variety of reasons but PGP strongly asserts that the availability of data and transparency is a general value and requests for metrics should be supported regardless of their relationship to a specific problem statement.

7. Provide your organization’s comments on the emissions reduction policies topic:

PGP recommends that the working group first pursue an accounting framework for addressing non-pricing GHG reduction and clean energy programs as well as voluntary goals prior to pursuing a dispatch solution for incorporating price signals into the market that reflect these policies. At a minimum, the exercise of understanding both voluntary and mandatory reporting requirements across the market footprint, and the challenges associated with reconciling differing accounting frameworks, will enhance stakeholders’ ability to understand whether a dispatch solution is needed or appropriate. Furthermore, PGP believes that an accounting framework can be used a tool for future interaction with state regulators and policymakers who are in the process of developing rules for how programs will be implemented. Given the potential complexity of potential dispatch solution(s), PGP recommends that specific guidance and input from states may be helpful so that tradeoffs are fully understood before solutions are adopted.

8. Additional comments:

Thank you for considering these comments and thank you to CAISO staff and working group members who have been advancing the conversation on these complex issues to date.

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

Puget Sound Energy (PSE) appreciates the work CAISO has done in collecting and compiling the input of various stakeholders in this process of evaluating its greenhouse gas (GHG) design and the metrics and reporting that are produced by the market operator. This is a complex issue with diverse and strong perspectives. PSE supports the March 7, 2024 comments of the Public Generating Pool (PGP) with respect to the need to refine and consolidate the existing problem statements to more clearly categorize and address the issues at hand. PSE also appreciates CAISO’s exploration of options for stakeholders to drive initiatives within CAISO’s existing governance structure and supports the proposal for an “issue sponsorship” model. With respect to the post-dispatch attribution framework discussed at the February 22, 2024 working group meeting, PSE supports pursuing this approach and recommends the working group explore this framework in more detail before delving into market mechanisms that may create additional constraints for an efficient economic market dispatch. Lastly, PSE supports CAISO’s ‘Evergreen Training’ proposal and recommends CAISO revisit the training after this initiative to ensure it remains relevant.

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

As stated above, PSE supports the recommended refinements and consolidation of problem statements proposed by PGP in its March 7, 2024 comments with a few minor modifications, as provided below. Consolidating some of these issues and tightening up the focus of the group should help move this effort forward in a productive manner. PSE recommends CAISO explore a post-dispatch attribution framework, as a first priority, to addressing Issue Category #2. A phased approach could be taken to this design, focusing initially on high-quality identification of owned and contracted resources. If such an attribution framework is found to be insufficient for the needs of entities with non-pricing GHG programs, the working group could explore the need for market mechanisms. In any case, market mechanisms should only be considered in the context of addressing states with jurisdictional GHG reduction or clean energy programs that contemplate transactions in a centrally dispatched, or organized electricity market. State coordination should be viewed as an integral element within each issue category below versus a stand-alone issue.

Issue Category #1: ISO Market Operations & GHG Design – Current Approach to GHG Pricing Programs in WEIM and proposed approach in EDAM

Problem Statement: Market participants and stakeholders either do not have enough information to evaluate whether the WEIM design works as intended, or desire modifications to the design.

• • Identifying available surplus for attribution to a GHG zone
  • How much secondary dispatch is occurring
  • Relationship between how leakage is addressed and price signals / cost
  • Understanding marginal GHG costs
  • What additional metrics are needed to enable stakeholders to better evaluate the design
  • Consider whether modifications to the design are necessary to enable entities to direct attribution of clean resources to loads, to honor forward commitments, or to address other state policy objectives
  • Need for coordination with other markets in the west to address accounting seams

Issue Category #2: Addressing Non-Pricing and Clean Energy Policies, and Voluntary Goals

• Problem Statement: The current WEIM and proposed EDAM GHG designs only address GHG pricing programs and do not facilitate the needs of other types of GHG reduction, clean energy procurement policies, or voluntary clean energy goals.
  • Metrics and accounting frameworks are needed to facilitate mandatory and voluntary reporting of emissions and clean energy
  • Calculating unspecified or market mix emissions rates
  • Addressing double-, under-, or over-reporting and areas where different accounting frameworks cannot be reconciled
  • Identifying emissions intensity and/or specified source transfers or imports and/or total emissions /specified imports used to serve load
  • Does a transparent accounting framework sufficiently meet the need, or is a market mechanism needed?
  • Interaction with GHG pricing program design  

Issue Category #3: Exploring Market Mechanisms for Addressing Non-Pricing and Clean Energy Policies, and Voluntary Goals

• Problem Statement: If stakeholders determine a market mechanism is needed to address state policies that require emissions reductions but do not establish a jurisdictional GHG price, no such mechanism exists.
  • Ensuring load is served by resources that meet emission reduction requirements or goals
  • Minimizing impacts to efficient economic market dispatch
  • Understanding interaction with GHG pricing program design

Issue Category #4: Other GHG & Policy Metrics – Stakeholders desire additional metrics not currently available related to emissions and renewable energy (anything not covered in other Issue Categories)

• Problem Statement: Granular information regarding emissions rates, renewable curtailment, and GHG cost data is not uniformly available.
  • Average emissions rates (different permutations)
  • Other as suggested

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

PSE supports the proposal for “Evergreen Trainings” as a means for greater information availability and transparency into CAISO’s market structure. CAISO should revisit its Evergreen training material to ensure it remains consistent with any changes adopted at the end of this, and future, working group processes.

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

PSE supports CAISO seeking ways for stakeholders to drive initiatives and take ownership of problem statements within the structures of its governance model. This is an important step to enable involved parties to guide issues important to them. PSE recommends that problem statement sponsors be organizations with experience in the market and a financial stake in the process and outcome for the market. As such, sponsors should be market participants themselves or a market trade organization with a majority of its membership having either load or generation within the market. This is important for two reasons - 1) to ensure sponsors have the necessary experience participating in the market, and 2) to ensure entities for whom the outcomes will have direct financial implications have ownership and accountability for the issue.

The CAISO should provide data and analysis support to problem statement sponsors, as requested, providing historical data, scenario modeling, or forecast analysis as needed to inform the conversation the sponsors are guiding.

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

PSE appreciates CAISO publishing the January 2024 emissions report, and supports further exploration of various permutations of calculating average emissions rates in the context of Issue Category #1.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

Please see PSE’s response to question #2.

7. Provide your organization’s comments on the emissions reduction policies topic:

PSE supports this working group pursuing the post-dispatch attribution framework discussed at the February 22 working group meeting. Such a framework enables participants to demonstrate compliance with various regulatory programs, voluntary commitments, company goals, and corporate buyer and seller requirements. A phased approach to this model could be taken, focusing first on implementing high-quality attribution of owned and contracted resources. This first phase of implementation should include the following, to be discussed in more detail by the Western Power Trading Forum in CAISO’s March 14, 2024 working group meeting:

1. 1. A pre-dispatch declaration of claims, for owned and contracted resources.
   2. Ex-post attribution of owned and contracted resources.
   3. Calculation of a residual emissions rate which market participants may use to demonstrate their compliance with their respective program or company goal, or use their state-mandated rate, if different.
   4. Provision of reports to those with claims on resources and to regulators on request.
   5. Calculation and posting of average and residual emissions rate data for informational purposes and for use by market participants to demonstrate their compliance, as allowed by a given jurisdiction or company goal.

8. Additional comments:

None at this time.   

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

The Salt River Project Agricultural Improvement and Power District (SRP) appreciates the opportunity to provide comments on the February 22 working group (WG) discussion. SRP values CAISO's efforts in the recent GHG Working Group session, appreciating the discussions on problem statement consolidation, Evergreen Trainings, sponsorship roles, and Average Emission Rate (AER) data publication. SRP is supportive of improving AER data to reflect operational realities and requests further clarity on energy storage and distributed energy resource accounting. Additionally, SRP acknowledges the effort to align emissions reduction policies with state mandates, but strongly recommends including corporate goals or objectives as well. There is a need for reporting mechanisms that accommodate the objectives of multiple entities.

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

SRP appreciates the CAISO’s proposal to consolidate problem statements 1-3 as they share a common theme related to secondary dispatch., Further, it may be challenging to differentiate and discuss these independently in future working group sessions. The consolidation of these problem statements may allow stakeholders to more effectively engage in discussion on the issues. However, SRP encourages the CAISO to ensure that the consolidation of problem statements maintains the unique aspects of each statement to ensure comprehensive solutions are developed.

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

 SRP is appreciative of the CAISO’s proposal to publish Evergreen Trainings in effort to further enhance stakeholder understanding and engagement in the greenhouse gas accounting and attribution process. SRP recommends that the Evergreen Trainings include examples and scenarios that demonstrate how stakeholders can calculate different emission rates under various market conditions and with different data inputs. Further, SRP agrees with the CAISO’s proposal to publish the materials at least 2 weeks in advance of the discussion topic to ensure stakeholders have adequate time to review.

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

In addition to slide 18 of the CAISO’s presentation, SRP believes that a problem statement sponsor or co-sponsor should assist in facilitating discussions, while ensuring that all relevant perspectives and insights are considered and lead the development of solution(s). SRP recommends the CAISO support sponsors and co-sponsors by providing them clear guidelines of their responsibilities as a sponsor/co-sponsor. The CAISO should support sponsors/co-sponsors and stakeholders by ensuring the sponsor/co-sponsors lead the discussions and resolutions in a fair, transparent, and impartial manner. Additionally, the CAISO should offer sponsors/co-sponsors with necessary resources, technical expertise, and data analysis tools where appropriate and in a timely manner to help facilitate effective discussions. Lastly, SRP suggests the CAISO quickly evaluate and communicate the feasibility of any proposals or efforts brought forth by sponsors or co-sponsors to ensure that discussions remain realistic, and stakeholders' time and contributions are directed towards practical solutions.

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

SRP values CAISO's initiative to publish Average Emissions Rate (AER) data to improve market transparency. However, SRP recommends CAISO continue to consider adding a “residual” emission rate that excludes the energy already claimed by another state or balancing authority (BA). This refinement may better align the data with the operational realities of WEIM entities. Additionally, SRP requests clarification on how the AER counts distributed energy resources as well as energy storage, including round trip efficiencies and the treatment of standalone versus hybrid battery systems.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

SRP generally agrees with the proposed metrics in Problem statement (PS) 6a-g.  However, SRP requests that the PS be amended where there is a reference to a state program but not a program tied to corporate goals, both of which dictate accurate and complete reporting.  SRP recommends the following adjustments:

6a) Entities with annual reporting obligations or corporate goals associated with emissions reduction targets require reporting of total emissions to serve loads.

6b) LSEs in jurisdictions with emission reduction policies or corporate goals must fulfill voluntary reporting or reporting obligations with state policy such as market imports to serve load or total emissions to serve load.

6c) The unspecified emissions rate used by states with an absolute reduction program or entities with voluntary reporting for corporate goals or objectives fails to reflect the accuracy of generation and consumption at a local level.

6e) Entities with jurisdictional requirements for retail claims or that have corporate emissions goals for retail claims may not cover 100% of their real-time load obligation with owned or contracted power. In areas where LSEs are responsible for both owned/contracted power and real-time imbalance transfers, entities may experience challenges meeting corporate goals or jurisdictional requirements when they do not have sufficient information to report on the emissions intensity of net transfers.

For reference, SRP’s current public carbon goal for retail energy is to reduce the amount of CO₂ emitted by generation (per MWh) by 82% from 2005 levels by 2035 (~284 lbs/MWh) and by 2050, have net-zero carbon emissions. SRP’s carbon intensity is measured following a protocol developed by the Climate Registry (TCR), and SRP uses an Environmental Protection Agency (EPA) subregion emission rate to calculate overall market emissions from unspecified market purchases. More accurate representation of the emission rate from WEIM activity will give a better representation of SRP’s carbon intensity.

7. Provide your organization’s comments on the emissions reduction policies topic:

SRP appreciates the CAISO providing example scenarios to illustrate PS7.  As written, this PS does not reflect the needs of entities with corporate goals which are often similar to state emission policies. SRP suggests re-writing the PS as follows:

There is not a market mechanism in states with a declining cap on emissions or entities with corporate goals or objectives that dictate a declining emission cap for:…

SRP also recommends adding a Scenario (or refining Scenario C) to reflect that this PS is relevant for entities with corporate goals in addition to state mandates. For instance:

Scenario E: Entities with a corporate goal or objective of a declining cap on emission intensity for serving retail load.

Example: SRP to (for retail energy) reduce the amount of CO2 emitted by generation (per MWh) by 82% from 2005 levels by 2035 (~284 lbs/MWh) and achieve net-zero carbon emissions by 2050.

At a minimum, SRP believes that the Scenario E above will need to be addressed by a post-dispatch accounting framework that allows resources that are not in a GHG zone to be claimed by the entity that owns or contracts the resource. This element is critical for honoring pre-existing agreements and to avoid double counting. The claiming methodology would need to be a topic of a future discussion to ensure entities are not claiming more than their obligations or excluding baseloaded/self-scheduled energy.  Additionally, the post-dispatch framework would need to ensure that attribution and accounting of an emission rate is done on a sufficiently granular basis to reflect that emission rates are vastly different during different market conditions.

While a market mechanism to control emission intensity by entity may be preferred, SRP understands that this may not be practical and encourages the CAISO to have further discussion on what is technically feasible. In lieu of a market mechanism, entities may need regular updates on the estimated default emission factor in order to manage their internal requirements with other market mechanisms such as bids or self-schedules. SRP is very interested in the analysis that will be presented in future meetings to provide additional comments on market mechanisms or accounting.

8. Additional comments:

 No additional comments at this time.

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

The Six Cities support consolidation of problem statements 1-3 and suggest a consolidated formulation.

The Six Cities support implementation of Evergreen Training modules subject to inclusion of a rigorous updating process to ensure consistency of training modules with CAISO tariff and Business Practice Manual provisions.

The Six Cities generally support the description of the role of problem statement sponsors set forth on Slide 18 of the presentation materials for the February 22^nd working group meeting but recommend an additional bullet point on coordinating presentation and evaluation of alternative solutions to the problem statement proposed by other stakeholders.

The Six Cities generally support the CAISO’s plan to publish data on average emissions rates as described during the February 22^nd working group meeting and support consideration of additional formulations for presentation of emissions rate data, subject to evaluation of cost effectiveness.

The Six Cities recommend deleting problem statement 6 subparts 6a, 6c, 6d, and 6g and further refining subpart 6e.

On a preliminary basis, the Six Cities support further consideration of after-the-fact accounting approaches that may assist in supporting state policies or emissions targets that are not reflected in market optimization, subject to consideration of implementation costs. 

The Six Cities reiterate their recommendation to defer consideration of problem statements or elements of problem statements that concern GHG accounting, coordination, or impacts under the EDAM design until the EDAM has been operating for a reasonable period of time.

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

The Six Cities support consolidation of problem statements 1-3, because all three problem statements raise concerns with the scope and consequences of secondary dispatch under the current design of the optimization for attribution of resources to serve load within GHG BAAs.  A general formulation for a problem statement that would incorporate problem statements 1-3 could be: “It is not clear that the current design of the optimization for attribution of resources to serve load within GHG BAAs results in appropriate and cost-effective limits on secondary dispatch.”

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

The Six Cities welcome and support the concept of Evergreen Trainings.  As noted in discussion during the February 22^nd working group, it will be critically important to update the training modules on a regular basis to maintain consistency with the CAISO tariff and Business Practice Manuals.  Although the updating process will require commitment of CAISO resources, if consistency with the tariff and BPM provisions is not rigorously maintained, the training modules could become a source of disinformation.  With an effective updating process, however, the proposed Evergreen Trainings could provide a valuable resource both for new and experienced market participants that would help to streamline stakeholder initiatives and related working groups.

In response to the CAISO’s notation on Slide 13 of the presentation for the February 22^nd working group meeting that it plans to set aside time for discussion of previously posted training sessions during working group meetings, the Six Cities recommend that discussion of training materials during the working group meetings be limited so as not to unduly deflect the focus of the working group meetings on definition of problem statements and identification of potential solutions.

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

The Six Cities generally support the description of the role of problem statement sponsors set forth on Slide 18 of the presentation materials for the February 22^nd working group meeting.  The Six Cities recommend adding an additional bullet to the description to read: “Coordinating with respect to presentation and evaluation of alternative solutions to the problem statement proposed by other stakeholders.”

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

The Six Cities generally support the CAISO’s plan to publish data on average emissions rates as described during the February 22^nd working group meeting.  The Six Cities also support consideration of additional formulations for presentation of emissions rate data, subject to the caveat that the costs and resource requirements for assembling and presenting additional data formulations should be considered in evaluating the appropriateness of providing potential additional formats.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

With respect to the subparts of problem statement 6 as described at Slides 26-29 of the presentation for the February 22^nd working group meeting and discussed during the meeting:

• The Six Cities agree that subparts 6a and 6b appear to raise the same concerns and concur in the suggestion made during the working group meeting to delete problem statement 6a and retain 6b.
• The Six Cities agree with comments made during the meeting that subparts 6c and 6d should be deleted, because the concerns identified in those subparts are outside the scope of the CAISO’s jurisdiction or ability to address.
• The Six Cities agree with the suggestion made during the meeting that subpart 6e should be further refined and recommend doing so to focus on transactions effectuated through the CAISO’s markets.
• The Six Cities recommend that subpart 6g be deleted, as it would be subsumed within the consolidated version of problem statements 1-3.

7. Provide your organization’s comments on the emissions reduction policies topic:

On a preliminary basis, the Six Cities support further consideration of after-the-fact accounting approaches that may assist in supporting state policies or emissions targets that are not reflected in market optimization.  Such evaluation of potential after-the-fact accounting approaches should include consideration of the costs and resource requirements for implementing a particular accounting program.

8. Additional comments:

To the extent problem statements include potential concerns with GHG accounting, coordination, or impacts under the EDAM design, the Six Cities continue to recommend deferring further consideration of such problem statements or EDAM-related elements of problem statements until the EDAM has been operating for a reasonable period of time (e.g., one year following implementation of the EDAM).

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

WRA appreciates the effort to transition to the “assessment” phase of this working group, and our comments on specific topics follow.

We recognize the explanation of the prioritization of problem statements on page 8 of the presentation and all problem statements require resolution.  However, we reiterate the necessity of ensuring GHG design, tracking, and reporting support compliance with states with non-pricing emission reduction programs (e.g. CO, OR, NM, NV). This is fundamental to the operability of EDAM with a broad geographic footprint and for load-serving entities, transmission-owning utilities, and Independent Power Producers with different load and generation possibilities.

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

WRA offers: “The workability, accuracy, and transparency of the CAISO attribution process require further evaluation, particularly in the areas of available surplus, secondary dispatch, leakage, and costs.”

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

WRA supports the proposal to publish “Evergreen Trainings” as a mechanism to build stakeholder knowledge and address outstanding questions.

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

Being a problem statement sponsor or co-sponsor should mean defining the problem statement, proposing information needed to assess the problem statement, and identifying milestones relevant to prioritization. It should not indicate sole or predominant “ownership” of the topic and should facilitate finding solutions with multistakeholder input.

CAISO can provide relevant data and any existing analysis or research conducted by the ISO on the given topic. WRA requests that the ISO staff be available to answer questions and help identify solutions based on their expert knowledge of ISO software and operational capabilities.

WRA can co-sponsor one problem statement, with a preference for PS 7 (emissions reduction policies). We also recommend that state regulator representatives be involved in this effort, as regulators from numerous states and departments have indicated a need to find design and tracking solutions that will work for their state programs.

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

WRA appreciates the roll out plan for publishing AER data, as essential to understanding the overall impact of the market on emissions.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

WRA appreciates the existing problem statements. In addition to addressing the fact that “the ISO does not provide all metrics desired by market participants,” we recommend evaluation of where a West-wide reporting platform may be best suited to house tracking/reporting data and help address emissions tracking under market seams in the region.

7. Provide your organization’s comments on the emissions reduction policies topic:

WRA appreciates the overview of the four kinds of emission reduction policies in Western states. Addressing non-pricing emission reduction policies, in addition to carbon pricing programs, is essential to market operability and Western grid decarbonization. WRA also recommends that CAISO invest in a third-party consultant to assist in the evaluation of the different possibilities to ensure compliance. We look forward to ongoing discussions of market mechanisms and post-dispatch accounting solutions.

8. Additional comments:

 N/A

1. Provide a summary of your organization’s comments on the February 22, 2024 working group discussion:

2. Provide your organization’s comments on how problem statements 1-3 should be consolidated:

WPTF is generally supportive of consolidating problem statements 1-3.  The three problem statements seem to identify different undesirable market outcomes or impacts that are a result of the same underlying problem. Specifically, the attribution methodology does not limit attribution to incremental dispatch above a baseline such that the least-cost optimization creates the issues identified in each of the current problem statements (price formation, secondary dispatch, and to date there has not been a true evaluation of the cost impact). Additionally, alternative baseline approaches should be explored.

3. Provide your organization’s comments on the ISO’s proposal to publish “Evergreen Trainings”:

WPTF is generally supportive of the Evergreen Trainings and recommends that any relevant trainings are provided prior to the working group that will focus on that same topic. For example, if the CAISO were to schedule a working group meeting that focuses on the issues of GHG attribution, then ideally the Evergreen Training on attribution would be provided at least one week prior to the working group session. This provides ample time for stakeholders to attend the trainings, gain a better understanding, digest the information, and then be in a better position to engage on policy discussions during the working group meeting.  

4. Provide your organization’s comments on what it means to be a problem statement sponsor or co-sponsor, and how the ISO can best support those who volunteer to be a sponsor or co-sponsor:

If you are not currently a sponsor or co-sponsor and would like to volunteer as one, please indicate that here or send an email to ISOStakeholderAffairs@caiso.com.

To WPTF the concept of being a sponsor or co-sponsor to a problem statement seems to indicate that the sponsor will take responsibility for setting up and explaining the problem, facilitating discussions, and providing analytics as needed to help guide discussions towards a solution or set of solutions for consideration. First, for any problem statement that would benefit from any form of analysis, WPTF believes that CAISO staff should provide the needed analytic support to the problem statement sponsor and co-sponsors to illustrate specific problems and potential solutions. The CAISO has access to significantly more data than any stakeholder and the necessary tools to provide robust data analysis. Second, WPTF would like to take this opportunity to note that most companies engaging in these stakeholder processes are not set up to have resources with the bandwidth to dedicate the necessary time to be a sponsor or co-sponsor (potentially with the exception of the larger IOUs and trading forums). The reason being is that, unlike some other ISOs/RTOs, the CAISO stakeholder process does not incorporate any form of a voting structure such that it makes sense from a company perspective to have at least one full time dedicated employee to follow CAISO policy efforts. Thus, while we understand where the CAISO is coming from in trying to solicit problem statement sponsors, it may not be as practical given the distinct differences in how the CAISO has structured its stakeholder process compared to others. 

5. Provide your organization’s comments on the roll out plan for publishing average emissions rate data shared during the working group discussion:

WPTF greatly appreciates the CAISO’s pro-active nature in providing much needed data. We ask that along with the reports, the CAISO provide an accompanying document that can act as a “data dictionary” of sorts for the report. Ideally the definitions would help explain not only how the data value is calculated, but the source of the data (in the event participants want to try and replicate), and what it represents.

Additionally, WPTF appreciates that the data thus far has been provided in an excel format for ease of use and we ask the CAISO to continue with this practice. While the CAISO posts an immense amount of market data, data that is provided in PDF format loses some of its value because participants are unable to easily access that data when needed for other analysis purposes. In other words, data accessibility is also key to ensuring the data provided can be of utmost value.

With respect to the specific AER metrics, WPTF recommends that CAISO also calculate and publish the AER for individual BAAs. 

Lastly, WPTF asks that during the next working group the CAISO provide a similar plan for the other remaining metrics, and permutations of the average emissions rate metric, that have been discussed in this working group process. For example, residual and marginal emissions rates have been routinely discussed. It would be useful to know what metrics discussed the CAISO plans to also publish, when, and in what format.

6. Provide your organization’s comments on the metrics problem statements shared during the working group discussion (PS 6a-g):

If the statements need refinements, further consolidation, or if your metrics request was not accurately represented or included in a proposed problem statement, please provide that feedback here in the form of a refined, consolidated, or new problem statement.

Problem statements 6a and 6b, as currently worded, are redundant.  More detail is provided within 6b whereas 6a is still more general such that it may better capture all potential reporting needs. Thus we recommend the CAISO combine the two problem statements while retaining the appropriate level of detail to help direct potential solutions while remaining broad enough to ensure it meets the needs of all market participants.

Problem statements 6c and 6d, as currently worded, seem to identify issues that would be considered outside the CAISO’s purview such that this working group effort would not be able to implement a solution. However, if 6c and 6d are reworded to focus more on the coordination element as discussed during the stakeholder meeting, then this may make more sense in terms of having a problem statement that a potential solution or plan can be developed to help address or facilitate any needed coordination. Additionally, it would be useful to know where the data gaps are that warrant more coordination if such coordination is required.

7. Provide your organization’s comments on the emissions reduction policies topic:

WPTF appreciates the discussion during the last workshop on this topic, specifically the consideration of an accounting framework to help facilitate emissions reductions policies that are not priced-based. We believe that it is possible to develop a comprehensive accounting framework that will meet the needs of both states with GHG pricing programs and those with GHG reduction or Clean Energy Programs, as well as market participants subject to these regulatory programs or with voluntary goals. We look forward to presenting our views on this matter at the meeting on March 14^th.  

8. Additional comments: