Comments on April 17, 2024 GHG Coordination Working Group and revised discussion paper

1. Provide a summary of your organization’s comments on the April 17, 2024 GHG Coordination Working Group and revised discussion paper:

CRS summarizes information previously submitted regarding how double counting might arise, whether double counting relates to existing or planned GHG market design, and what the ISO’s role should be in a solution in response to CAISO Staff’s data request presentation. We also provide general reactions to WPTF’s presentation on GHG accounting and reporting (PS 7), including support for null power adjusted residual mix metrics along with coordination with WREGIS. Finally, we appreciate the introduction of accounting for storage in this context and the distinctions made between storage that has relationships with specified load and/or generation. We believe that coordination with REC systems is also required where specified emissions are assigned to storage, and we look forward to continuing discussions on that topic.

2. Provide your organization’s comments or questions in response to PG&E’s presentation on Problem Statement 1, which focused on balancing the optimized attribution with constraints to limit secondary dispatch:

None at this time.

3. Provide your organization’s comments or questions in response to WPTF’s presentation on Problem Statement 4, which focused on GHG price formation:

In your comments, please include 1) your organization’s perspective on what the marginal GHG component should represent, and 2) if or how the GHG marginal cost factors into investment decisions for your organization.

None at this time.

4. Provide your organization’s comments or questions in response to Vistra’s presentation on Problem Statements 1-3, which focused on potential limitations in the GHG design: 1.) identifying surplus due to counterfactual run, 2.) when there are insufficient GHG bids, and 3.) when resources are not fully awarded in the IFM.

None at this time.

5. Provide your organization’s comments or questions in response to the ISO’s data request presentation:

CRS appreciates CAISO Staff’s clarification that the second category of data presented—data to support “Market participants ability to meet existing compliance obligations: ensure market participates have what they need to inform procurement decisions (opportunity costs that we are not accounting for)”—is meant to include voluntary sales/program obligations and the “compliance obligations” in this context refers to both state and voluntary programs.

CAISO Staff stated that while they have been provided with some solutions, including coordination between the ISO and WREGIS, development of a residual mix, etc., the ISO needs more information about how double counting might arise, whether double counting relates to existing or planned GHG market design, and what the ISO’s role should be in a solution. As we have described in previous comments, double counting can occur where there is resource-specific MWh or GHG attribution or allocations to load (either states/zones or individual LSEs) in the market and there is also separate attribution of specified/renewable generation to load (assignments of generation to load) by account holders (e.g. LSEs) in WREGIS recognized under different programs. Multiple and inconsistent attribution methods create a risk of double counting. See our 11/7/23 comments. This risk of double counting relates to both existing (GHG attribution for GHG-pricing programs) and proposed GHG market design (any future attribution for LSEs in non-pricing states or comprehensive post-dispatch allocation of generation and/or emissions). See our 4/2/24 comments.

From our 11/7/23 comments:

Are there examples of double counting that the working group can provide either as a case study or a comprehensive list?

• Every case where the generation is deemed delivered to CA or WA load and the REC is retired for load in a different state for a retail emissions claim/report (compliance or voluntary).
• Hypothetical example: Generation and associated emissions from a wind generator located in WY participating in EDAM are attributed and deemed to serve load in the CA GHG compliance area in EDAM, while the RECs associated with this generation are sold and transferred in WREGIS to an LSE in CO and retired for compliance with CO’s RPS program. In this case, the same generation and associated emissions are reported as serving load in two different states.
• More data, from WREGIS, states, and the ISO would be needed to identify examples of actual double counting.

What is the role of CAISO?

• CAISO should coordinate with other systems for attribution (e.g. WREGIS) to prevent double counting regionally. CAISO should not adopt a resource-specific attribution mechanism in market design that gives preference to a specific state or market participant, or that only accommodates a single type of state program such that it may harm other existing state and voluntary programs or create inconsistency that can damage the market or these programs.

Please see our 9/26/22 comments on the EDAM Revised Straw Proposal for a specific proposal for coordination: https://stakeholdercenter.caiso.com/Common/DownloadFile/b4f1bd16-b72b-4b42-8c32-2fc40ecbc7ef.

6. Provide your organization’s comments or questions in response to WPTF’s presentation on example of its after-the-fact accounting and reporting approach, related to Problem Statement 7:

CRS appreciates WPTF’s presentation and the work they have done in preparing the proposed framework and examples. We would describe the different state policies and the two residual mixes slightly differently than they have. For example, we would clarify that the second residual mix that is adjusted for null power is correct for load-based emissions accounting and reflects transactions that have occurred outside of the market. Those MWh should be treated as specified/allocated outside of the market and not included in the residual mix. But in general, we support the inclusion of a residual mix that is adjusted for null power. The proposal to remove null power generation for this adjustment is preferred over assigning emissions to this generation.

We continue to see value in coordination and data sharing with WREGIS so that all tracked generation that is allocated in the market gets reflected on WREGIS certificates, and potentially an agreement by market participants that associated RECs be transferred for attributions or allocations of renewable generation in the market.

Regarding hourly accounting of storage, we understand WPTF’s presentation as distinguishing between storage that is serving a specific load and “market” storage that is not serving specific load, i.e. that does not have contracts with specific load. We generally support the proposal to treat storage that is committed to specific load as load. We understand that WPTF is making another distinction between storage that does or does not have a contract with specific generation, and that storage with a contract with specified solar, for example, could claim the specified emissions factor of that solar generation. Otherwise, we understand that they are proposing that the residual mix be assigned to market storage. If a contract with a generator is used to assign generation attributes to storage, then any associated RECs/certificates should be included to prevent double counting.

We look forward to continuing this discussion.

7. Provide your organization’s comments or questions in response to PNM’s case study presentation related to Problem Statement 7, which focused on the overlap of the New Mexico Energy Transition Act and PNM’s participation in the Western Energy Imbalance Market:

None at this time.

8. Provide your organization’s comments on the proposed revised work streams:

None at this time.

9. Additional comments:

None at this time.

1. Provide a summary of your organization’s comments on the April 17, 2024 GHG Coordination Working Group and revised discussion paper:

PacifiCorp appreciates the hard work and dedication from each of the presenters. Continued discussion and refinement of treatment of GHG within the market is essential for ideal market outcomes and to reflect market participation in compliance reporting. With the limitations of the GHG solver that was developed two years ago used in the examples, PacifiCorp believes operational data would be needed to accurately assess whether the enhancements made to the market design as part of the EDAM stakeholder initiative process would function as intended. Once the data has been received, PacifiCorp is optimistic that the Department of Market Monitoring and the CAISO will work in parallel to ensure that no distorted benefits are realized or undesired market outcomes from the GHG reference pass. PacifiCorp generally supports continued discussion on the representation of the marginal GHG component to understand what can be gained through the lens of all market participants.  

As stated in previous comments, PacifiCorp generally supports WPTF’s after-the-fact accounting approach but has concerns on the possibility of excess California solar being withheld from the broader market due to the market transferring within a GHG regulation area before exporting out of the region. Regarding the treatment of null power within the market, PacifiCorp does not believe there is a need for two emission factors unless a regulatory requirement would necessitate such treatment. Generally, incorporating REC-based accounting into outcomes of organized markets is not within the scope of responsibilities of organized market operators. But, if this responsibility to undertake regional accounting obligation is employed by CAISO or a third-party as suggested, the residual mix emissions factor that eliminates null power could be used by regulators and customers as proposed by WPTF to align with practices of state policies.  

2. Provide your organization’s comments or questions in response to PG&E’s presentation on Problem Statement 1, which focused on balancing the optimized attribution with constraints to limit secondary dispatch:

No comment. 

3. Provide your organization’s comments or questions in response to WPTF’s presentation on Problem Statement 4, which focused on GHG price formation:

In your comments, please include 1) your organization’s perspective on what the marginal GHG component should represent, and 2) if or how the GHG marginal cost factors into investment decisions for your organization.

PacifiCorp thanks WPTF for their presentation on what the marginal GHG component should represent. At this point in the discussion, PacifiCorp does not have a position, however, PacifiCorp would like to understand the benefits to be gained through increased transparency. 

4. Provide your organization’s comments or questions in response to Vistra’s presentation on Problem Statements 1-3, which focused on potential limitations in the GHG design: 1.) identifying surplus due to counterfactual run, 2.) when there are insufficient GHG bids, and 3.) when resources are not fully awarded in the IFM.

PacifiCorp thanks Vistra for their detailed presentation at the April GHG working group. During the EDAM policy discussion phase, the CAISO and Department of Market Monitoring dedicated themselves to evaluate the EDAM design for undesired market outcomes. PacifiCorp agrees the GHG reference pass needs to be set appropriately so each entity is adequately compensated for making resources available to serve a GHG regulation area. On the topic of insufficient GHG bids, PacifiCorp supports the data request from Vistra asking the CAISO to show stakeholders how the GHG shadow price is calculated when GHG bids are exhausted.  

5. Provide your organization’s comments or questions in response to the ISO’s data request presentation:

PacifiCorp supports the process the CAISO is asking stakeholders to submit data requests.

6. Provide your organization’s comments or questions in response to WPTF’s presentation on example of its after-the-fact accounting and reporting approach, related to Problem Statement 7:

As discussed in past comments, PacifiCorp generally supports exploring WPTF’s after-the-fact accounting and reporting approach. PacifiCorp maintains that an out of market accounting framework is needed over an in-market emission constraint and looks forward to continued discussion. However, PacifiCorp believes that dedicated consideration would be needed pertaining to how multijurisdictional utilities would fit into the accounting approach. PacifiCorp optimizes generation from resources across its multi-state service territory and allocates based on its multi-state protocol. This cost-based allocation of generation among its six states would create difficulties for PacifiCorp’s adherence to an hourly accounting framework, depending on the information required. For example, PacifiCorp has asked the California Energy Commission for an exemption of hourly accounting of emissions, as has been proposed as part of their Power Source Disclosure rulemaking.  

During the workshop, a question was raised regarding how excess solar would be treated. The methodology would first set transfers between entities within a GHG regulation area before exporting/importing from the remainder of the market. PacifiCorp believes there will be operational and economic impacts from this framework and requests additional discussion or an alternate approach. Specifically, how much solar would be essentially withheld from the broader market? Additionally, WPTF presented that CAISO could offer two emission factors when accounting for contribution to the residual mix from null power (one with the inclusion of null power within the residual supply mix emissions factor, and one without). PacifiCorp is generally supportive of avoiding complexity, and as such does not believe there is a clear need for two emission factors, unless explicitly communicated by regulators. If two emissions factors were to exist, clear direction would be needed from regulators as to which factor should apply to an LSE’s unspecified purchases. 

7. Provide your organization’s comments or questions in response to PNM’s case study presentation related to Problem Statement 7, which focused on the overlap of the New Mexico Energy Transition Act and PNM’s participation in the Western Energy Imbalance Market:

No comment. 

8. Provide your organization’s comments on the proposed revised work streams:

No comment. 

9. Additional comments:

1. Provide a summary of your organization’s comments on the April 17, 2024 GHG Coordination Working Group and revised discussion paper:

See below comments

2. Provide your organization’s comments or questions in response to PG&E’s presentation on Problem Statement 1, which focused on balancing the optimized attribution with constraints to limit secondary dispatch:

PGE appreciates PG&E’s presentation and welcomes additional data from the CAISO regarding the current extent and value of emissions leakage in the WEIM.

3. Provide your organization’s comments or questions in response to WPTF’s presentation on Problem Statement 4, which focused on GHG price formation:

In your comments, please include 1) your organization’s perspective on what the marginal GHG component should represent, and 2) if or how the GHG marginal cost factors into investment decisions for your organization.

No comments at this time.

4. Provide your organization’s comments or questions in response to Vistra’s presentation on Problem Statements 1-3, which focused on potential limitations in the GHG design: 1.) identifying surplus due to counterfactual run, 2.) when there are insufficient GHG bids, and 3.) when resources are not fully awarded in the IFM.

PGE appreciated this presentation but underscores the importance of ensuring market participants in non-priced GHG capped states are not disadvantaged as the working group addresses this problem statement.  

5. Provide your organization’s comments or questions in response to the ISO’s data request presentation:

PGE appreciates the CAISO’s understanding of the need for additional data including emissions rate, total emissions, and intensity of MW attributed below the base schedule. 

PGE also encourages the CAISO to continue engagement with EDAM participants subject to non-priced GHG reduction policy, as rules change quickly and updates to accommodate such market participants may be required in future years.  

6. Provide your organization’s comments or questions in response to WPTF’s presentation on example of its after-the-fact accounting and reporting approach, related to Problem Statement 7:

PGE is interested in the WPTF’s energy and GHG accounting framework. The WPTF presentation clarified important questions for PGE, including emissions accounting practice for battery energy storage systems (BESS) and clarifying the distinction between (1) a BESS associated with a LSE-owned/contracted resource and (2) a non-dedicated BESS resource available to the market.. PGE encourages the WPTF to continue developing specific details on the reporting and accounting framework.

7. Provide your organization’s comments or questions in response to PNM’s case study presentation related to Problem Statement 7, which focused on the overlap of the New Mexico Energy Transition Act and PNM’s participation in the Western Energy Imbalance Market:

PGE appreciated the presentation from PNM explaining the complexities of market participation for entities subject to non-priced emission reduction policy. While PGE is also subject to non-priced GHG reduction policy, Oregon’s policy is structured very differently so conclusions regarding PNM’s position should not be assumed to extend to other non-priced market participants. 

PGE also appreciates the CAISO’s engagement with PNM in addressing any current resource participation challenges in the WEIM, which will be critical to integrate market participation from entities operating without a set carbon price. 

8. Provide your organization’s comments on the proposed revised work streams:

PGE supports the proposed revisions but wants to clarify that we do not intend to co-sponsor all three problem statements as currently indicated on CAISO’s revised work streams slide.

PGE is interested in sponsoring the revised problem statement 2 (Addressing Non-Pricing and Clean Energy Policies, and Voluntary Goals).

9. Additional comments:

No additional comments at this time.

1. Provide a summary of your organization’s comments on the April 17, 2024 GHG Coordination Working Group and revised discussion paper:

The Salt River Project Agricultural Improvement and Power District (SRP) appreciates the opportunity to comment on the April 17 GHG Coordination Working Group (WG) and the comprehensive discussions on GHG pricing, accounting frameworks, and problem statement revisions. SRP supports the continued focus on accurate and robust mechanisms for GHG accounting, which are essential for managing both mandatory and voluntary emissions targets effectively.

2. Provide your organization’s comments or questions in response to PG&E’s presentation on Problem Statement 1, which focused on balancing the optimized attribution with constraints to limit secondary dispatch:

SRP agrees with PG&E’s suggested approach for evaluating the cost of secondary dispatch within the GHG pricing framework. SRP would appreciate feedback from the CAISO on the feasibility of performing a detailed cost-benefit analysis, including insights into how accurate an estimate could be with the available data and assumptions.

Additionally, SRP encourages the exploration of different baselines for measuring the amount of secondary dispatch occurring, as suggested by stakeholders during the discussion. This exploration should include analyzing different options for baselines and how each might impact the cost of secondary dispatch.

3. Provide your organization’s comments or questions in response to WPTF’s presentation on Problem Statement 4, which focused on GHG price formation:

In your comments, please include 1) your organization’s perspective on what the marginal GHG component should represent, and 2) if or how the GHG marginal cost factors into investment decisions for your organization.

SRP values the WPTF’s detailed examples and price formation policy discussion. SRP agrees that more discussion is warranted about the marginal GHG component's meaning. SRP also agrees that the current definition of the GHG marginal cost may be confusing as it only represents the marginal cost of GHG for the non-pricing zone and could send misleading signals to investors. However, SRP understands that the GHG price in the pricing zone does not need to be split out for market optimization purposes. SRP would like to discuss what options exist to provide more transparency into this price.

4. Provide your organization’s comments or questions in response to Vistra’s presentation on Problem Statements 1-3, which focused on potential limitations in the GHG design: 1.) identifying surplus due to counterfactual run, 2.) when there are insufficient GHG bids, and 3.) when resources are not fully awarded in the IFM.

SRP appreciates the thoughtful examples and questions from Vistra concerning the potential limitations in the GHG design and remains engaged on this topic.

1) On identifying surplus due to counterfactual run SRP agrees that exploring more complex examples may help illustrate potential pricing impacts from using a counterfactual that treats BAAs individually and agrees that this complex policy question requires additional stakeholder discussion.

2) Regarding scenarios with insufficient GHG bids SRP requests that the CAISO disclose the optimization model’s logic and penalty prices associated with relaxing a GHG constraint for enhanced transparency and suggests including this information in a Business Practice Manual (BPM) if not already present. SRP further suggests that the CAISO share historical data or specific instances when GHG constraints were relaxed to allow stakeholders to better understand the frequency of the occurrences.

3) For instances where resources are not fully awarded in the IFM, SRP is open to further discussions on viable solutions for addressing these concerns effectively.

5. Provide your organization’s comments or questions in response to the ISO’s data request presentation:

SRP appreciates CAISO’s effort to streamline and categorize GHG data requests. SRP requests that the CAISO provide a list of metrics requested by stakeholders with a progress status indicator.  If some metrics are not possible to provide, the CAISO can specify what information is missing. Additionally, SRP recommends that the CAISO include explanations or use cases for each metric provided, detailing how they can be effectively utilized by stakeholders to manage their GHG compliance and market operations.

6. Provide your organization’s comments or questions in response to WPTF’s presentation on example of its after-the-fact accounting and reporting approach, related to Problem Statement 7:

SRP appreciates WPTF’s presentation clarifying the after-the-fact (ATF) emissions accounting approach presented. SRP is generally supportive of this approach, with a few caveats and seeks further clarification on key aspects.  

SRP acknowledges that various state and corporate sustainability programs may have different requirements for how entities assign MW and GHG emissions to specific loads or to a residual mix.  Therefore, it may be necessary to accommodate different methodologies for assignment. However, SRP believes the methodology should consider resources that are self-scheduled or otherwise required to run in the market optimization so that emissions that are attributed to a resource required to serve that entity’s load do not get attributed to the residual mix instead. For example, if a coal resource is self-scheduled at a minimum load of 200MW, the emissions from those 200MW should be attributed directly to the corresponding load-serving entity (LSE). SRP understands that it may not be practical to account for every constraint in the accounting methodology, but there may be simple rules, such as self-schedules, that can be incorporated to produce a more accurate residual emission rate.

Additionally, SRP agrees with WPTF’s proposal to have dual residual emission rate calculations, with one adjusted for null power. This approach would provide entities the flexibility to use either rate for their operations and enhance transparency into how much null power exists for a given interval.

For battery and pumped hydro storage, SRP agrees with WPTF’s proposed methodology to account for charging/discharging activities as adjustments to load. However, SRP requests that stakeholders do a comprehensive review as to how this methodology may conflict with the California Air Resource Board’s (CARB) methodology for WEIM storage resources that may be required to register an emission rate if they can be grid-charged. Preliminary conversations with CARB have not clarified if allowances will be required to be purchased for grid-charged storage resources’ energy that is deemed to the state of California. Because of this, SRP is concerned that the two methodologies may lead to some double counting, and stakeholders should discuss how to best approach this issue. SRP further suggests that CAISO explore ways to standardize the treatment of energy storage in emissions accounting and ensure that the methodology can reflect operational realities and regulatory requirements.

In regards to the assignment of Renewable Energy Credits (RECs), SRP requests flexibility in determining whether RECs should accompany energy transactions to California LSEs, due to varying environmental policy throughout the Western region.

7. Provide your organization’s comments or questions in response to PNM’s case study presentation related to Problem Statement 7, which focused on the overlap of the New Mexico Energy Transition Act and PNM’s participation in the Western Energy Imbalance Market:

SRP appreciates PNM sharing their case study. However, SRP is concerned that environmental policy changes across the West will lead to price impacts as entities manage their bidding strategy to meet goals or requirements.

8. Provide your organization’s comments on the proposed revised work streams:

SRP has no comments at this time.

9. Additional comments:

SRP has no comments at this time.

1. Provide a summary of your organization’s comments on the April 17, 2024 GHG Coordination Working Group and revised discussion paper:

The Six Cities strongly support PG&E’s recommendation that the CAISO conduct a cost/benefit analysis of the optimization constraints applied to limit secondary dispatch.

The Six Cities support further evaluation of the consequences of conducting the GHG counterfactual runs based on aggregated non-GHG areas rather than on a BAA by BAA basis.

The Six Cities take no substantive position at this time regarding WPTF’s proposed approach for after-the-fact tracking and assigning of energy but request that the CAISO provide feedback on the proposal, particularly with respect to implementation challenges and costs.

The Six Cities agree with the revised grouping of problem statements included in Work Stream # 1 and provide recommendations for relocating or deleting several problem statements included in Work Streams # 2 and # 3. 

With the deletion of Problem Statement 6b as recommended below, the Six Cities support moving forward promptly with parallel policy development initiatives to address the problem statements in Work Stream # 1 and Work Stream # 3.  As to Work Stream # 1 and Work Stream # 3, it is time to begin focusing on identifying and completing necessary analyses and crafting cost effective solutions where justified by such analyses.

As to Work Stream # 2 (Problem Statement 7), the Six Cities strongly recommend deferring further activity until there has been greater progress with regard to development and implementation of data collection, accounting, or reporting mechanisms that may provide information necessary to support compliance with non-priced requirements and alleviate concerns about double counting. 

2. Provide your organization’s comments or questions in response to PG&E’s presentation on Problem Statement 1, which focused on balancing the optimized attribution with constraints to limit secondary dispatch:

The Six Cities strongly support PG&E’s recommendation that the CAISO conduct a cost/benefit analysis of the optimization constraints applied to limit secondary dispatch.  The Six Cities further support PG&E’s suggestion that the analysis rely initially on higher level or less granular information subject to further refinement if that appears necessary.

3. Provide your organization’s comments or questions in response to WPTF’s presentation on Problem Statement 4, which focused on GHG price formation:

In your comments, please include 1) your organization’s perspective on what the marginal GHG component should represent, and 2) if or how the GHG marginal cost factors into investment decisions for your organization.

The Six Cities have no comments at this time on the WPTF presentation on GHG pricing.

4. Provide your organization’s comments or questions in response to Vistra’s presentation on Problem Statements 1-3, which focused on potential limitations in the GHG design: 1.) identifying surplus due to counterfactual run, 2.) when there are insufficient GHG bids, and 3.) when resources are not fully awarded in the IFM.

The Six Cities support further evaluation of the consequences of conducting the GHG counterfactual runs based on aggregated non-GHG areas rather than on a BAA by BAA basis.  The analysis presented by Cathleen Colbert indicated that conducting an EDAM GHG counterfactual based on aggregated non-GHG areas would attribute more economical resources first to non-GHG areas, thereby increasing costs to GHG areas.  Further analysis should be conducted to consider the potential frequency and magnitude of such impacts as well as potential off-setting considerations.

5. Provide your organization’s comments or questions in response to the ISO’s data request presentation:

The Six Cities have no comments at this time on the CAISO’s data request presentation.

6. Provide your organization’s comments or questions in response to WPTF’s presentation on example of its after-the-fact accounting and reporting approach, related to Problem Statement 7:

The Six Cities take no substantive position at this time regarding WPTF’s proposed approach for after-the-fact tracking and assigning of energy but support further consideration of the proposal.  The Six Cities would appreciate the CAISO providing feedback on the proposal, particularly with respect to implementation challenges and costs.

7. Provide your organization’s comments or questions in response to PNM’s case study presentation related to Problem Statement 7, which focused on the overlap of the New Mexico Energy Transition Act and PNM’s participation in the Western Energy Imbalance Market:

The Six Cities have no comments at this time on PNM’s presentation. 

8. Provide your organization’s comments on the proposed revised work streams:

The Six Cities agree with the revised grouping of problem statements included in Work Stream # 1 as set forth at page 18 of the Discussion Paper and encourage the CAISO to move forward promptly to (1) perform any analyses necessary to evaluate the problem statements included in Work Stream # 1, and (2) to develop substantive proposals to resolve problems identified and supported through such analyses. 

With respect to the revised version of Work Stream # 2 set forth at pages 18-19 of the Discussion Paper, it would be appropriate to move Problem Statement 6c to Work Stream # 3, as Problem Statement 6c, like the other problem statements currently included in Work Stream # 3, relates to the general topic of information and data requirements requested or needed by market participants. 

With regard to the remaining problem statement in Work Stream # 2, Problem Statement 7, the Six Cities recommend deferring consideration of new market mechanisms, such as dispatch or transfer constraints, until after thorough evaluation of potential accounting or data reporting measures has been completed.  As noted in their comments on the March 14, 2024 working group, dispatch or import constraints would dramatically increase the complexity of market operations and potentially undermine market efficiency or reliability or both.  In addition, all three of the Problem Statement 7 sub-issues (i.e., Problem Statements 7a, 7b, and 7c) raise the question of whether it is sound policy to expect markets to implement or ensure compliance with non-priced policies or goals.  Such an expectation is especially problematic when the market footprint encompasses multiple regulatory jurisdictions that have differing policies and goals.

As to other problem statements in revised Work Stream # 3 as set forth at page 19 of the Discussion Paper, the Six Cities recommend deleting Problem Statement 6b altogether.  As noted in their comments on the March 14th working group, Problem Statement 6b appears to be overly broad and to exceed the appropriate scope for a CAISO initiative.  It is the Six Cities’ understanding that the CAISO has no responsibility for nor authority over generation/tag data reported to WREGIS.  If that is the case, the CAISO cannot and should not unilaterally undertake an effort to identify and redress any inconsistencies between WREGIS reporting conventions and the CAISO’s GHG attribution methodology.  If WREGIS and the CAISO concur that differences between reports to WREGIS and CAISO’s GHG attribution methodology may give rise to double counting, a joint effort to evaluate issues and develop resolutions may be appropriate.

With regard to Problem Statement 6f (now included in Work Stream # 3), the Six Cities noted in their comments on the March 14^th working group that CAISO reports currently include some metrics that quantify financial and emissions impacts of the CAISO’s GHG design.  As part of the initiative to address Work Stream # 3 problem statements, stakeholders who believe that additional metrics should be developed and reported should identify such additional metrics with specificity so that the costs versus benefits of assembling the additional data can be evaluated.

With the deletion of Problem Statement 6b as recommended above, the Six Cities support moving forward promptly with parallel initiatives to address the problem statements in Work Stream # 1 and Work Stream # 3.  The working group process has reached the stage of diminishing returns, and further word-smithing of problem statements is unlikely to be constructive.  The lengthy history of the GHG Coordination working group process set forth in the Discussion Paper illustrates that working group activities are becoming repetitive and circular.  As to Work Stream # 1 and Work Stream # 3, it is time to begin focusing on identifying and completing necessary analyses and crafting cost effective solutions where justified by such analyses.

As to Work Stream # 2 (Problem Statement 7), the Six Cities strongly recommend deferring further activity until there has been greater progress with regard to development and implementation of data collection, accounting, or reporting mechanisms that may provide information necessary to support compliance with non-priced requirements and alleviate concerns about double counting. 

9. Additional comments:

The Six Cities have no additional comments at this time.