Findings of Fact
1. A "forced is forced" policy whereby LSEs would be able to rely upon the QC of a unit that is established by the CAISO for a given RAR compliance year, and not incur a penalty or replacement obligation in the event of a forced outage of that unit, is consistent with our prior RAR decisions establishing a planning reserve requirement.
2. Because the reserve margin requirement adopted in D.04-01-050 encompasses forced outages, requiring LSEs to engage in replacement procurement following a forced outage would effectively require them to procure more than the adopted reserve margin.
3. LSEs need to know the extent to which the resources they acquire and use for their RAR compliance showings will count toward meeting their procurement obligation.
4. The Commission understands and expects that the CAISO will establish and publish a list of generating units and the QC for those units.
5. In order for LSEs and others to make informed decisions regarding the products they will use in their upcoming year-ahead compliance filings, the QC for any generator needs to be established approximately 90 days before the year-ahead compliance filing is due, or on or about July 1.
6. The imposition of QC adjustments on a regular cycle and the potential for suppliers to lose a quantity of product they would otherwise be able to sell in the RAR market provide an incentive for suppliers to maintain the availability of capacity.
7. RAR violations will be handled first through action by the Energy Division such as a notification letter providing the LSE with a limited time to resolve the violation, and then, if the LSE fails to do so, the Energy Division would recommend that the Commission initiate an enforcement proceeding.
8. While General Order 167 adequately addresses maintenance and repair obligations for those units to which it applies, it is reasonable to require that all suppliers of qualifying RAR capacity agree to follow Good Utility Practices as defined in CAISO tariffs and to comply with all applicable laws, regulations, and standards regarding maintenance and repair.
9. A bulletin board on which bids and offers for qualifying RAR capacity are posted would be a useful tool for promoting transparency and liquidity in the market.
10. With respect to qualifying imports as a tradable capacity product that counts for RAR, it is more appropriate to use specific elements of the transmission requirement in the counting protocol for imports rather than the designation "firm."
11. Intermediaries can provide a valuable function in bringing parties together to achieve economically efficient transactions.
12. The CAISO needs full authority to determine whether a substitution of assets can be made since the information and knowledge to do so is in its purview.
13. Changing the rules of the RAR program too frequently, or with too little sensitivity to the needs of the contracting parties for regulatory stability, could discourage contracting and undermine RAR program goals.
14. A standardized capacity product that might be developed in the near term would be beneficial to the RAR program's success if it (1) can be readily bought, sold, or traded by and among market participants; (2) ensures continued availability of the underlying generation resource to the CAISO at the times and places the CAISO needs to be able to call upon the resource; and (3) comports with our RAR program requirements.
15. Establishing essential elements of an RA Capacity contract that qualifies toward meeting an LSE's procurement obligation could contribute to the development of a standardized, tradable RA Capacity Product.
16. The compliance filing templates developed by the Energy Division can be modified to provide the ability to specify or highlight limitations associated with legacy contracts.
17. SCE's proposed modifications to Statements 2, 3, and 4 of the compliance filing verification are consistent with Rule 2.4 of the Rules of Practice and Procedure.
18. The proposed adjustment to the MCC calculation whereby the LSE obligation for each resource category, for both year-ahead and monthly RAR showing, is based on the LSE's RAR (115% of forecast load), should be approved.
19. SCE's proposed approach to accounting for transmission losses would add administrative complexity that could be costly for some participants as well as the Commission and the CAISO to administer.
20. In its IRR tariff filing, the CAISO has proposed parameters of the role it would assume in resolving discrepancies between the CAISO's Monthly Supply Plan submitted by generators and the LSE's monthly RAR showings.
