ATTACHMENT A
The CAISO generally supports the proposals in the ACR, and applauds the Commission's initiative and proposed quick action by decision in early July 2004. Further, CAISO contends that RMR contracts are an inferior tool for achieving reliability, SCE's scheduling proposal cannot be implemented in the timeframe needed to meet the goals of the ACR, the policies in the ACR should not be limited to only the SCE area, and the potential cost-shifting impact of the ACR is not inequitable. The CAISO also agrees to provide supplemental information to market participants in a manner that does not increase the ability of generators to exercise locational market power.
IEP supports the goals sought in the ACR, but is concerned about the process that led to consideration of these extraordinary steps. Nonetheless, recognizing the apparent urgency, IEP recommends as an expeditious resolution that (a) the Commission encourage utilities to enter into contracts to meet system and local reliability needs and (b) the CAISO enter into short-term reliability contracts (STRCs) to backfill Summer 2004 needs to the extent utility/supplier contracts are inadequate.
Calpine generally concurs that utilities should be obligated to enter into STRCs to procure energy for local reliability needs for summer 2004 and summer 2005, with two modifications. First, after summer 2005 a load pocket procurement obligation should become an integral component of an LSE's formal procurement planning process. Second, Calpine endorses IEP's proposal on STRCs.
TDM, TURN, SCE, CCSF, PG&E, ORA and others express reservations about adopting the ACR's proposals. Many believe too much is proposed too quickly.
