For the 2008 RA Compliance Year, the CPUC is issuing this guide to specify how to fill out the RAR reporting templates. This guide combines the guide for both Year Ahead and Month Ahead filings, although there are still separate three separate RA compliance templates (Local, System Year Ahead, and System Monthly). There have also been minor changes to this guide throughout, and LSEs are encouraged to read this guide carefully.

Changes to the guides and templates for 2008 include the following:

_ The addition of a new local Area in Big Creek/Ventura

_ Implementation of a RA counting constraint on Path 26

_ Revised procedures for submission of Advice Letters

_ Implementation of the CPUC's rounding convention as codified in D.07-06-029

2. Zonal RA: Constraint on Flows Across Path 26

The CAISO demonstrated that a potential overload on Path 26 can occur due to a RA capacity distribution problem; without addressing the problem, the possibility existed that an over abundance of RA capacity could be contracted for north of Path 26 that is ultimately needed to serve load south of Path 26 (and vice versa) in an amount that exceeds the transfer capability across Path 26. The methodology for allocating commitments across Path 26 was adopted in D.07-06-029 and is summarized below.

Step 1 - July 19^th, 2007. The CAISO will determine the amount of Path 26 transfer capacity available for RA counting purposes after accounting for Existing Transmission Contracts (ETCs) and loop flow.¹ The CAISO will notify the LSEs via their Scheduling Coordinators.

Step 2 - July 19^th, 2007. The CAISO will allocate a baseline "Path 26 transfer capability" to each LSE, and notify them via their Scheduling Coordinator. The baseline allocation is the higher of (1) their Load Share Ratio of load in the zone into which capacity is being transferred, or (2) the sum of the LSE's existing commitments including ETCs, TORs, and RA Commitments executed prior to March 22^nd, 2007. Any LSE with a baseline allocation in excess of Load Ratio Share due to existing commitments will receive Path 26 transfer capability to cover those commitments, which will be taken out of other LSE's baseline allocations.

Step 3 - August 2^nd, 2007. Once the baseline quantities are determined, LSEs will have an opportunity, but not an obligation, to submit RA resource contract commitments (Preliminary Path 26 Submittals) that exist as of July 31^st, 2007, including Grandfathered RA Commitments, that need to use Path 26 to deliver to the LSE's loads (Existing RA Commitments). The CAISO will use these Preliminary Path 26 Submittals to "net" the north-to-south and south-to-north Path 26 RA counting impacts associated with the Existing RA Commitments. An LSE's Preliminary Path 26 Submittal cannot exceed its baseline Path 26 RA counting capacity. Once submitted, the Preliminary Path 26 Submittals will create a binding obligation on the LSE to include the Existing RA Commitments in its Year-Ahead and month-ahead RA compliance filings, and make them subject to the CAISO Tariff regarding RA Resources.

Step 4 - August 9^th, 2007. The CAISO will allocate the additional Path 26 RA counting capacity that was made available due to netting of existing commitments. This additional counting capacity will be allocated to LSEs based on load-ratio shares, and will be additive to the LSEs' baseline allocations. However, LSEs whose baseline Path 26 RA counting capacity exceeds their load-ratio shares because of Grandfathered RA commitments in Step 2 will only receive additional Path 26 RA counting capacity after all other LSEs have been allocated additional Path 26 RA counting capacity in an amount that causes them to exceed their respective load-ratio share by the same percentage that the initial LSE received because its baseline allocation exceeded its load-ratio share.

Step 5 - August 9^th, 2007. The CAISO will notify LSEs of the final results of the Path 26 RA counting capacity process. This final notification can add to the baseline allocation in Step 2 but cannot decrease it.

The reporting and offer requirements of resources listed in the Preliminary Path 26 submittals is the same as with a standard RA resource. There is the binding obligation that a resource listed in the Preliminary Path 26 submittals also be used to satisfy an LSE's RAR and thus be offered to the CAISO under an RA MOO in the subsequent System RA Filing and in all applicable Monthly RA Filings.

The System and Monthly templates implement this Path 26 transfer constraint by requiring the LSE to enter their load separately by TAC Area (PG&E, SCE, and SDGE) in Summary Table 1. The LSE then enters the Zone (either NP26 or SP26) where each resource is located or delivers into. Imports, portfolios, units under construction, and demand response resources are also designated according to Zone. The template then subtracts the amount of demand response resources located in the zone from the load within the zone, computes a RAR with PRM, tallies the resources listed to meet that load, and computes a necessary flow across Path 26 to meet load plus Planning Reserves in each Zone. The LSE then enters their appropriate Path 26 allocation received at the conclusion of this process to accommodate those necessary flows. Imports delivered across a particular import branch and then traveling across Path 26 must be accommodated by both an import allocation and a Path 26 allocation. Additionally, contracts that do not specify either a particular generating unit or a specific zone of delivery will not be included as resources in the zone to serve load, and are unavailable to offset necessary flows across Path 26.

3. The Filing Process and the Local RAR

Decision (D.) 05-10-042 established a Year-Ahead and monthly System Resource Adequacy Requirement (RAR) for Load Serving Entities (LSEs) under the jurisdiction of the California Public Utilities Commission (CPUC). D. 06-06-064 expanded the RA program to include a Year-Ahead Local RAR and a Preliminary Local RAR, and D.07-06-029 adopted Local RA procurement obligations for compliance year 2008. D.07-06-029 also adopted a new Local Area located in the Big Creek/Ventura area, and established an earlier set of deadlines for the CAISO to refine, develop, and discuss both the process and results of the 2009 LCR study.

(1) September 19^th, 2007: The Preliminary Local RAR compliance filing covers the full 12-month period of 2008 and requires LSEs to demonstrate if they have procured any unit that is listed on the 2008 CAISO NQC List as being located in a Local Area. LSEs should show all resources under contract, including non-local area resources, in the preliminary showing as incorporating these resources in the CAISO's analysis could ultimately help minimize the CAISO's need to renew certain existing RMR contracts. Due September 19^th, 2007.

(2) October 31, 2007: LSEs are required to make a 2008 Year-Ahead System and Local RAR compliance filing that demonstrates compliance with the 90% of system RAR obligation for the five summer months of May through September 2008, as well as 100% of the Local RAR for all 12 months of 2008. LSEs must include in the local showing any unit that is on the California Independent System Operator NQC list and listed as located within a Local Area. Due October 31, 2007.

(3) Monthly: LSEs are required to continue making monthly forecasts and monthly system RAR showings that track load migration and demonstrate compliance with the 100% system RAR. Due monthly with no set end date. There is no monthly Local RAR or required Local RAR monthly filing. The 2008 Monthly RA template accompanies this guide.

Templates

The RAR Filing Guide herein and the accompanying RAR reporting templates (Standard and Local Only templates) provide the means for LSEs to demonstrate compliance with the Year-Ahead System RAR, as well as the Local RAR. LSEs are required to use the following templates to demonstrate compliance with the RA Program:

(1) For 2008 Preliminary Local RAR filing - LSEs are required to use the Local Template to demonstrate Preliminary Local RAR for all 12 months. LSEs must demonstrate whether they have any unit under contract that is listed on the CAISO's The Net Qualifying Capacity for Compliance Year 2008 ("2008 NQC list") as located within a Local Area or any unit with a 2007 RMR contract. LSEs may also show any other unit under contract by the date of the filing, even if it is not in a local area. The CAISO will consider all units under contract (even those outside local areas) before making final determinations for RMR contracts for 2008.

(2) For 2008 System RAR - LSEs are required to use the standard template for the period of May through September (This item is a repeat of the 2007 Year-Ahead System RAR process.)

(3) For 2008 Local RAR - LSEs are required to use the Local RAR Template to demonstrate compliance with the Local RAR for all 12 months (This item is a repeat of the 2007 Year-Ahead Local RAR process.)

(4) For 2008 Monthly RAR, LSEs are required to use the 2008 Monthly Template issued along with this guide. Please consult this guide for instructions regarding the Monthly RA Filings.

(5) Local RA obligations have been rounded off to the nearest MW pursuant to the convention adopted in D.06-06-064, and System RA obligations have been similarly rounded pursuant to conventions adopted in D.07-06-029. The Local RA allocations and the System RA templates have been adjusted to reflect these rounding conventions.

Notification of RAR by Energy Division

Each LSE will be notified by the CEC/CPUC Energy Division of their Local RAR and System RAR. This notification process will consist of three parts.

(1) For System RAR - LSEs were notified of their adjusted forecast System load on July 6^th, 2007. Each LSE's System RAR is 115% of this expected peak load by month. LSEs will receive their final Condition 2 RMR allocation on or about October 5^th, 2007 to aid them in preparing their Final System RA Filing. On a separate timeline, each LSE will receive notification of their import allocation and Path 26 Allocation for use in their System RAR filing. See Section 7 for more details regarding Import Allocation.

(2) For Local RAR -- LSEs were notified of their final Local RAR by the CPUC via certified letter on July 6th based on the methodology used in last year's allocation. This was included in the letter mailed with the Demand Response and Load Forecasts. LSEs will receive Condition 1 RMR credits by October 5, 2007.

(3) For Monthly System RAR - LSEs were issued their System RAR for all months of 2008 on July 6^th, 2007. LSEs are required to comply with the Monthly Load Forecast Adjustment process throughout 2008 as done during 2007. CPUC Energy Division will notify LSEs of any change to Condition 2 RMR allocations as they occur throughout compliance year 2008 for use in subsequent Monthly RA Filings.

4. Energy Auction and the Capacity Allocation Mechanism

Pursuant to the Energy Auction and the Capacity Allocation Mechanism outlined in D.06-07-029, LSEs may receive an allocation of capacity for resources that are constructed to provide system benefit. The mechanism for auctioning this energy will be developed pursuant to D.06-70-029. The particular mechanism for allocating capacity from these resources is not yet in place for the 2008 Year Ahead System and Local Filings, but there may be a mechanism in place for the Monthly RA Filings in 2008. This capacity, once allocated, may be entered into the RA template as a Physical Resource with the name "Capacity Allocation" and the other appropriate information. The template gives directions for doing this. New resources that come online and into the allocation mechanism, as well as adjustments to allocations to accommodate for load migration among LSEs, will be done via the mechanism adopted by the Commission in a future decision.

5. Confidentiality and RA Filings

D.06-06-066 revised the Commission's confidentiality procedures and placed the burden of justifying protection of confidential information on the party asking for the protection, not the party that wants the information released. Pursuant to this decision, the Revised Protective Order issued in R.05-12-013 on February 10^th, 2006 will undergo changes. Key among the changes is a revised designation of which material can be kept confidential, and the method for protecting such information. Certain classes of information are described in the matrices attached to D.06-06-066; the matrices break the information down into specific types that are to be public and specific types that are to be confidential.² There is also a description of the purpose and requirements for a declaration to protect information included on page 24 of D.06-06-066.

LSEs must file a declaration to retain confidential treatment for any information contained in RA filings, including Monthly RA filings, Preliminary Local RAR showings, System RA filings, and Local RAR filings. In response to a declaration to request confidentiality, the Administrative Law Judge may find some parts of the RA Filings to still be confidential. LSEs should match the type of information contained in the RA Filings against the matrices in Appendix 1 and 2 in D.06-06-066 and prepare a declaration accordingly.

Protection of any information to be designated as confidential shall be requested and justified with a declaration that proves the following:

1. That the material it is submitting constitutes a particular type of data listed in the Matrix,

2. Which category or categories in the Matrix to which the data correspond,

3. That it is complying with the limitations on confidentiality specified in the Matrix for that type of data,

4. That the information is not already public, and

5. That the data cannot be aggregated, redacted, summarized, masked or otherwise protected in a way that allows partial disclosure.

6. Load Forecast Adjustments

D.05-10-042 stated "[w]e require that month-ahead compliance filings include adjustments for positive and negative load growth due to migration. Apart from load changes due to load migration, load forecasts should not be updated from LSE's Year-Ahead filing."

On July 6, 2007 the CEC sent each LSE its month specific RA obligation for January-December 2008. Because the Year-Ahead forecasts made assumptions about direct access load, the Year-Ahead forecasts need to be revised to account for actual direct access customer migration to date, and expected additional load migration prior to the obligation period. No other adjustments may be made to the load forecasts approved for the Year-Ahead filing.

Each LSE is responsible for adjusting its load forecast for migration of existing direct access load. An LSE with migrating direct access customers must adjust its monthly load forecast and monthly RA obligation and reflect those changes on the monthly RA Template. IOUs should adjust their forecast to account both for customers who are known to have returned to bundled service and for those that have notified the IOU that they intend to return to bundled service prior to the Filing Month. ESPs should account for contracted load and a reasonable expectation for the rate of contract renewals of non-firm load or load with expiring contracts. If the CEC determines that the assumptions made are not plausible, the CEC may make a plausibility adjustment to account for a more plausible rate of customer retention. The CPUC requires LSEs to procure to meet RAR based on the load forecasts that are submitted to the CEC and adjusted by the CEC. The CEC will communicate these monthly adjusted forecasts to the CPUC for compliance validation purposes.

The CEC has provided a separate template to facilitate the forecast revision process and verify that migrating load is correctly accounted. LSEs which have gained or lost customers since their Year-Ahead forecast will enter the amount of monthly peak load associated with the change in customers, and the template will make the appropriate adjustments, including coincidence. A complete submission of the load forecast adjustments each month including the certification sheet signed by an officer of the company, as well as the electronic template and all supporting data required, is to be submitted to the CEC. The CPUC and CAISO do not need to receive this submission. LSEs may voluntarily submit their load forecast adjustments to the CEC via email if they prefer, or they may continue to submit load forecast adjustments on CDROM. For convenience, the table below summarizes the load forecast and Month Ahead System RA filing dates for 2008 compliance year.

Load Forecast and Month-Ahead filing dates for 2008 RA Compliance

RA filing month	Load Forecast month	Due Date
January	February	November 30
February	March	December 31
March	April	January 31
April	May	February 29
May	June	March 31
June	July	April 30
July	August	June 2
August	September	June 30
September	October	July 31
October	November	September 1
November	December	September 30
December	January 2009	October 31

7. Qualifying Capacity

D. 05-10-042 requires all LSEs to fulfill their allocated system RAR through purchase of Net Qualifying Capacity (NQC). A link to the Final 2008 CAISO NQC List is available under "Current Net Qualifying Capacity (NQC)" on the CAISO website at: http://www.caiso.com/1796/179688b22c970.html

Please refer to this list when identifying a resource with Scheduling Resource ID, its associated NQC, Path 26 and Local Area Designations.

The Final 2008 NQC list was published by the CAISO on August 10, 2007 and covers compliance year 2008. The information on this list will not be changed except for data maintenance and correction of errors, and addition of new resources that come online during the course of 2008. Any revisions made by the CAISO after August 10, 2007 can raise a given unit's NQC, but revisions cannot lower it.

QC and Local RAR

D.06-06-064 adopted a program of Local RAR for LSEs that are under the jurisdiction of the CPUC, while D.7-06-029 adopted Local RA totals for 2008 compliance year. These decisions require all LSEs to procure physical resources to meet the Local RAR. These units are to be located in the ten local areas identified in the CAISO NQC list. For purposes of RA compliance, the ten local areas have been aggregated into five Local Areas (LA Basin, Big Creek/Ventura, San Diego, Other PG&E Local Areas, and the Greater Bay Area). The Other PG&E Local Areas include the Local Areas of Fresno, Humboldt, Kern, North Coast/North Bay, Sierra, and Stockton. The LSE is responsible for verification of the Local Area Designation of the unit, as well as the NQC value and the Scheduling Resource ID. The NQC that is to be entered for compliance with the Local RAR is either 1) the NQC listed, for resources that have only one annual NQC value or 2) the August NQC value for resources that have monthly NQC values which reflects performance of the unit at IOU Service Area Peak. LSEs are also to use the August monthly value for entering Local DR Allocations as well. Please refer to the 2008 NQC List to locate a particular generating unit within a Local Area.

Every resource has a resource name ("RES Name") and associated resource identification ("Scheduling Resource ID"). Each unit also has a Path 26 and Local Area designation. Resources not located in Local Areas are labeled as "not in Local Area" and can only count toward the System RAR.

To report a contract with a unit located within a Local Area on the Local Template, LSEs are required to select from a drop down list of local areas on the template. The template gives the choices of LA Basin, Big Creek/Ventura, San Diego Area, Other PG&E Local Areas, or Greater Bay Area. All units within any of the Other PG&E Local Areas are to be entered as Other PG&E Local Areas, not as Humboldt, Fresno, Kern, etc. Local RARs above 1 MW are rounded to the nearest MW while obligations less than 1 MW receive an exemption from Local RAR procurement.

QC and Outages

While outages do not change a units NQC value during an RA compliance year, LSEs are expected to verify with the Scheduling Coordinator the availability of any units the LSE wishes to include in their Monthly System RA Filings, and compute the appropriate amount of capacity that is affected pursuant to the formulas in Section 9 below. The Local RAR Filings will not be affected by either scheduled or forced outages.

8. Maximum Cumulative Capacity and Resource Categories

The 2008 Local and System RAR Filings will use the resource eligibility criteria developed for the 2007 Year-Ahead System RA filing through the December 9, 2005 workshop. The Maximum Cumulative Capacity (MCC) percentages established for the 2006 filings will still be used for 2008, but for purposes of the 2008 year ahead filings, the MCC restrictions will be based on the 115% RAR, not the 90% year ahead RAR as before. This change will provide more consistency with the Monthly RA filing process.³.


Summary of Resource Categories
Category	Consensus Agreement Resources may be categorized into one of the four categories shown below, according to their planned availability as expressed in hours available to run or operate per month (hours/month):
1	"Greater than or equal to" the ULR [Use Limited Resource] monthly hours as shown in the Phase 1 Workshop Report, Table "Number Hours ISO Load Greater than 90% of the Monthly Peak," p.24-25, last line of table, titled "RA Obligation," http://www.cpuc.ca.gov/word_pdf/REPORT/37456.pdf These ULR hours for May through September are, respectively: 30, 40, 40, 60, and 40, which total 210 hour and have been referred to as "the 210 hours."
2	"Greater than or equal to" 160 hours per month.
3	"Greater than or equal to" 384 hours per month.
4	All Hours (planned availability is unrestricted)

9. Demand Response (DR) Resources

Dispatchable Demand Response (DR) resources shall be `taken off the top' of the RAR and entered into a separate DR worksheet that will not have a maximum cumulative contribution (MCC) percentage. The amount of capacity in megawatts (MW) entered into the DR worksheets will be multiplied by 115% percent to reflect their status as dispatchable load based resources and will be subtracted from the overall 115% System RAR. For example, if LSE-ABC has a 1,000 MW RAR in June 2008, and LSE-ABC shows 100 MW of DR resources in the DR worksheet, that 100 MW will be multiplied by 115% and subtracted from the 1000 MW to leave 885 MW to be met with an acceptable combination of resources. Note that this process is the same as subtracting the 100 MW of DR from the forecast peak load before multiplying by 115% to calculate RAR.

For DR programs that are operated by the IOUs and where cost is allocated across all transmission customers, the RA counting credit for these programs will also be allocated across all LSEs in a transmission service area based on share of program cost that customers of the LSE have paid⁴. Allocations of DR resources are all allocations for programs that exceed 2 hours a day maximum, and thus should be recorded in the System RA template on the DR-a_2hr-Plus sheet. LSEs that receive allocations for programs which they do not administer need only include the total summary information from the Allocation, and the total MW amount of QC. LSEs are required to provide all program details for DR programs which they themselves operate. Please list a zonal designation for the DR programs, noting which allocations are for programs that operate in SP26 and which in NP26 according to the directions in the template, as these resources are tabulated for purposes of the Path 26 constraint.

D.06-06-064 determined that dispatchable DR credit should be allocated to each Local Area and counted towards meeting Local RAR. This was completed during the DR forecast and allocation process for RA compliance year 2008 in all three IOU TAC areas. Local DR Allocations were included in the letters sent to the LSEs on July 6, 2007 and should be entered in the Local Template according to the directions provided therein. The July 6 letter breaks the DR allocation up into DR located within each Local Area and DR outside of Local Areas. Then the letter provides a total DR Allocation. For reference, the value for each Local Area is to be used for the Local Filing, and the month specific total across all TAC areas is still to be used for each month of the System Year-Ahead and Month-Ahead RA Filings.

Non-dispatchable demand response resources are considered a reduction in demand and were included in the Load Forecasts. Therefore, they are not to be listed as resources in the System RA Filing.

10. Outages

D. 06-07-031 adopted the following system for the counting of scheduled and forced outages for purposes of the System Monthly RA Filing. Please note that the Local RA Filing will not be affected by scheduled or forced outages and the following section and table apply only to the System RA Filings, not the Local RA Filings.

Scheduled Outages:

For RA counting purposes, a Scheduled Outage is any outage that is designated "Approved Planned" in the SLIC system. In determining the impact of outages, LSEs should use the scheduled outage criteria in the table below. LSEs are advised to verify a unit's outage status with the Scheduling Coordinator for that unit prior to including it in the RA filing. The CPUC and the CAISO will compare the amount of claimed capacity in the System year ahead and Monthly RA filings with the CAISO's outage information to verify compliance. An LSE's filings may be disapproved if there is a variance between unit availability and the capacity listed in the System year ahead and Monthly RA filings.

All outage schedules and changes to outage schedules for a RA resource are subject to CAISO approval. If the CAISO approves a change to the outage schedule, the outage schedule change will not change the RA counting of the resource. If the CAISO denies an outage request, the RA resource is expected to remain available.

If a unit has a scheduled outage pursuant to the direction above that curtails only part of the unit's capacity, a LSE may count for RA the capacity that is not curtailed.

Outages and the SLIC system

The magnitude in MW of curtailment and the length of an outage are both taken directly from the SLIC system. Any unit that has an outage designated as "Approved Planned" in the SLIC system for a particular month should use the scheduled outage criteria in the table below to determine the impact of scheduled outages on that unit's ability to count as Resource Adequacy Capacity. Any LSE listing a resource in an RA Filing must confirm that the amount of capacity to be listed is not subject to curtailment prior to the filing date.

The amount of capacity that can count towards an LSE's System RAR will be the total NQC for the applicable filing month minus the computed curtailment amount. The Energy Division will verify all Resource Adequacy Capacity against scheduled outage information in SLIC and will only allow capacity that is not under a scheduled outage to count towards all LSEs' System RAR, subject to the scheduled outage counting rules in the table below. Any approved changes to outages occurring after the filing due date will not affect an LSE's compliance.

Counting Resources with Scheduled Outages

Time Period

Description of How Resource Would Count at Time of the Showing

Summer

May through September

Any month where days of scheduled outages exceed 25% of days in the month, the resource does not count for RAR. If scheduled outages are less than or equal to 25% the resource does count for RAR.

Non-Summer Months

October through April

For scheduled outages less than 1 week, the resource counts for RAR.

For scheduled outages 1 week to 2 weeks, the amount counted for RAR is prorated using the formula:

[1 - (days of scheduled outage/days in month) - 0.25] * MW = RAR

The formula will allow resources to count between 50% and 25% of NQC.

For scheduled outages over 2 weeks, the resource does not count for RAR.

Forced Outages:

Forced outage of a RA resource occurring during a month does not change the RA compliance established for that LSE for that month. If the forced outage continues into a succeeding month, or months, the resource may still be counted towards the LSE's RA compliance. The SLIC system verifies forced outages; units that, according to the SLIC system, have an outage designated as "forced" will not be derated for RA purposes and can sell capacity equal to the unit's NQC in the 2008 CAISO NQC list.

11. Allocation of Reliability Must Run (RMR) Units for Local and System RAR

D.06-06-064 requires that all LSEs file Preliminary Local RAR compliance showings on September 19, 2007.⁵ This Preliminary Local RAR demonstration must, at a minimum, accurately show whether the LSE has, by September 19, 2007, entered into a contract with any unit that is listed on the 2008 NQC List. The Preliminary Local RAR demonstrations will not be used to determine compliance with local procurement obligations but they are required to be accurate. The LSEs are required to include other units in their Preliminary Local RAR demonstrations --including units not in designated local areas -- because complete data on LSE procurement may help to reduce RMR procurement and the associated costs that are allocated to LSEs. An LSE that has no 2008 units designated as in Local Areas on the 2008 NQC list under an RAR contract prior to September 19, 2007 is required to state this in a simple Advice Letter filing; however, even the identification of non-local units may reduce RMR procurement, and therefore all LSEs are encouraged to be as complete as possible in Preliminary Local RAR Filings.

To the extent that an LSE's Preliminary Local RAR showing contains any RMR units, the showing needs to indicate whether the LSE contracted for the RMR unit's full RA capacity outright or contracted for only the Local RAR counting benefits via a "wraparound" contract to the RMR contract. To qualify as providing Local RA, a wraparound contract must fully displace the RMR contract fixed costs such that no other transmission customers are paying for that part of the RMR contract obligation.

In requiring a Preliminary Local RAR demonstration on September 19, 2007, the CAISO will have a week to review the filings prior to issuing RMR contract renewal notices. If a unit is bought under a full RA contract, there should be no CAISO RMR contract renewal. If a unit is bought by wraparound contract, then the CAISO may still execute an RMR contract renewal but the Local RAR capacity credit of the RMR contract would not be distributed to all LSEs as Local RAR credit; instead the Local RAR counting benefit would accrue only to the LSE that is paying for the wraparound contract. If an LSE has a wraparound contract that does not fully displace fixed cost recovery, the Local RAR credit would be allocated as if it were an RMR unit without any wraparound contract. However, in that case the LSE that pays for the wraparound contract may still receive System RAR credit for the unit.

After finalizing the RMR contracts for 2008 by October 1, 2007, the CAISO will know which RMR units are available and the total MW of RMR capacity. The CAISO, in coordination with the Energy Division, will then separate the total RMR contract amount (in MWs) by Commission-jurisdictional and non- jurisdictional, RMR-paying entities, and also by the four Local Areas. Each LSE will be notified by the Energy Division of their System RMR Allocation based on the expectation that any Condition 2 RMR unit that has a contract renewed by October 1, 2007 will likely continue to elect Condition 2 for 2008 on October 5, 2007. If there is any change to the Condition of a unit throughout the year, LSEs will be notified of an updated RMR Allocation for use in their subsequent Monthly RA Filings.

Both Condition 1 and Condition 2 RMR contracts will be allocated for purposes of Local RAR, while only Condition 2 units can be allocated to LSEs for purposes of System RAR. D.06-06-064 specifically rejected the sale of separate System and Local RA counting credits; however RMR Condition 1 contracts that count towards Local RAR will not count towards System RAR. Therefore, a unit that is under an RMR Condition 1 contract may separately sell its System RAR credit.

The following schedule summarizes the process:

Schedule for Coordinating RAR and RMR Processes for 2008⁶

June 21, 2007	Commission adopts Local RAR Decision.
July 6, 2007	Energy Division notifies LSEs of their Local RAR for 2008
September 6-7, 2007	CAISO Board meets to consider RMR contract designations.
September 19, 2007	LSEs file Preliminary Local RAR showings.
September 29, 2007	CAISO finalizes (by October 1, 2007) its RMR contract renewal process by sending renewal notices.
October 5, 2007	Energy Division notifies LSEs of their 2008 RMR credit for Local RAR.
October 31, 2007	LSEs make Year-Ahead System and Local RAR showings for 2008.
November 8, 2007	CAISO notifies all LSEs of any collective deficiencies to allow for additional LSE procurement.
December 3, 2007	Last date for LSE to file amended Local RAR or System "year ahead" RAR showing to reduce CAISO backstop for collective deficiency.
After December 3, 2007	CAISO engages in any backstop required to cure collective local deficiencies and notifies the Energy Division so that it can notify LSEs of their System RAR credit to their monthly showings.

12. Import Capacity Allocation Process for 2008

Note: Please refer to the CAISO Tariff, Section 40.5.2.2 for the express language on this topic and Appendix C of this Guide for a quick reference guide as to the timelines and tasks that are codified in this section of the CAISO Tariff.

The CAISO's Tariff, section 40.5.2.2- Deliverability of Imports, outlines the process necessary to allocate import capacity to all load serving entities.

In summary, import capacity will be assigned to entities that serve load in the CAISO Control Area in 2008 per the following steps:

1. For 2008, the CAISO will establish for each branch group the total import capacity values into the CAISO Control Area and publish these values on its website by July 1, 2007. The information can be found on the CAISO website at: http://www.caiso.com/1c0c/1c0cda9b33460.pdf

2. For each branch group, the CAISO will determine the Available Import Capability into the CAISO by taking the Total Import values from Step 1 and deducting the import capacity associated with (i) Existing Transmission Contracts and (ii) Encumbrances and Transmission Ownership Rights.

3. The import capability associated with ETCs and TORs in Step 2 will be reserved for the holders of such commitments, and will not be reduced subsequent to the following process.

4. The LSEs submitted their existing commitments from resources outside CAISO Control Area entered into before March 10, 2006 and with a term lasting through the year 2007 as part of the 2007 Compliance Year Import Allocation Process. The CAISO will use this information to determine Import Capability reserved for Pre-RA Commitments. Previously, LSEs selected particular branch groups based on the primary branch group that energy or capacity from each particular import resource commitment had historically been scheduled. For resources that did not have deliveries in 2007 or were not included in the Compliance Year 2007 Import Allocation process, the CAISO will assign capacity based on which branch group the energy or capacity was anticipated to be scheduled. This is the Pre-RA Import Capability.

To the extent a particular branch group is over requested due to Pre-RA commitments not included in the Compliance Year 2007 Import Allocation process or changes to system conditions that affect total import capability into the CAISO, the requested Pre-RA Import Capability will be allocated based on the Import Capacity Load Share ratio of each Load Serving Entity that submitted such resource commitments. However, to the extent this initial allocation has not fully assigned the total import capacity of a particular branch group to the requested resource commitments, the remaining capacity will be allocated until fully exhausted based on the Import Capacity Load Share ratio of each Load Serving Entity whose quantity of submitted resource commitment have not been fully satisfied. Import Capacity Load Share is each Load Serving Entity's proportionate share of the forecasted 2008 coincident peak load for the CAISO Control Area relative to the total coincident peak load of all Load Serving Entities that have not had their request for import capacity for a resource commitment on a particular branch group fully satisfied. The proportionate share of the forecasted 2008 peak load for the CAISO Control Area for each Load Serving Entity is the "Coincident Load Share" as determined by the California Energy Commission.

The CAISO will assign Remaining Import Capability to LSEs that have not received Existing or Pre-RA Import Allocations in excess of their Import Capability Load Share due to the steps above. This is not a branch specific allocation.

5. By July 9, 2007 the CAISO will publish on their website the following information:

a. Total Import Capability;

b. Quantity in MW of ETCs and TORs assigned to each branch group, distinguishing between ETCs held by LSEs within the CAISO and those held by LSEs outside the CAISO;

c. The aggregate quantity in MW, the holders, of Pre-RA Import Commitments assigned to each branch group;

d. Remaining aggregate import capacity, the identity of the branch groups with available capacity, and the MW quantity remaining on each such branch group.

This information can be found on the CAISO website at http://www.caiso.com/1c16/1c16e1af61420.pdf

6. By July 9, 2007 the CAISO will notify the Scheduling Coordinators of each LSE of the following information:

a. LSE's Import Capability Load Share;

b. LSE's Load Share Quantity

c. Amount and branch group on which the LSE's Contract Import and Pre-RA Import Capability has been assigned;

d. LSE's Remaining Import Capability

7. Load Serving Entities will be allowed to trade some or all of their remaining import capability to any other Load Serving Entity or market participant. The CAISO will accept trades among LSEs and market participants only to the extent such trades are reported to the CAISO as outlined in a CAISO Market Notice. LSEs must report to the CAISO the following:

a. Name of counterparty

b. MW quantity

c. Term of transfer

d. Price per MW

LSEs must report their trades to the CAISO by July 18, 2007.

8. By July 19, 2007, Scheduling Coordinators for LSEs and other market participants shall report to the CAISO requests to allocate post-trading Remainder Import Capacity on a MW per available branch group basis. The CAISO will honor the requests to the extent a branch group has not been over-requested. If a branch group is over requested, the requests for Remainder Import Capacity on that branch group will be allocated based on the ratio of each Load Serving Entity's Import Capacity Load Share, as used in Step 4. A market participant without an Import Capacity Load Share will be assigned the Import Capacity Load Share equal to the average Import Capacity Load Share of those Load Serving Entities from which it received Remainder Import Capacity.

9. By July 27, the CAISO will notify each Scheduling Coordinator for Load Serving Entities of their accepted allocations and publish on its website remaining aggregate import capacity, the identity of the branch groups with available capacity, and the MW quantity remaining on each branch group.

10. To the extent import capacity remains unallocated pursuant to Step 10, all LSEs will notify the CAISO by August 1, 2007 of their request to allocate any Remainder Import Capacity on a MW per available branch group basis. The CAISO will honor the requests to the extent a branch group has not been over requested. If a branch group is over requested, the requests on that branch group will be allocated based on the ratio of each Load Serving Entity or market participant's Import Capacity Load Share, as used in steps 3 and 6.

11. By August 8, 2007 the CAISO will notify each Scheduling Coordinator for a Load Serving Entity of the Load Serving Entity's accepted allocation under this Step 12 and publish on its website the quantity and branch group identity of Remaining Import Capability that has not been assigned pursuant to the steps above.

12. To the extent total Available Import Capability remains unassigned pursuant to Step 12, Scheduling Coordinators for Load Serving Entities shall notify the CAISO pursuant to limitations discussed below, of a request to assign the Remaining Import Capability on a branch group. The CAISO will accept two (2) requests per calendar week from any Scheduling Coordinator on behalf of a single LSE or market participant. The CAISO will honor requests on a first come first served basis and without regards to the LSE's Load Share Quantity. Requests will be honored and assigned for the balance of the Compliance Year, however requests honored by the CAISO and notified to the LSE after the 20^th day of the month cannot be included in the Monthly RA Filing submitted at the end of that month, but may be used for subsequent RA Filings.

This multi-step allocation of import capacity does not guarantee or result in any actual transmission service being allocated and is only used for determining the maximum import capacity that can be credited towards satisfying a Load Serving Entity's planning reserve margin, or appropriate Resource Adequacy Obligation. Upon the request of the CAISO, Scheduling Coordinators must provide the CAISO with information on existing import contracts and any trades or sales of their load share allocation. The CAISO will inform the CPUC or other Local Regulatory Authority of any Resource Adequacy Plan submitted by a Scheduling Coordinator for a Load Serving Entity under their respective jurisdiction that exceeds its allocation of import capacity.

Please refer to Appendix C of this Guide for a quick reference guide as to the timelines and tasks that are codified in Section 40.5.2.2 of the CAISO's Tariff.

13. Department of Water Resources (DWR) Contracts

All DWR CERS contracts shall be entered on a separate worksheet page in the System RA Filing Template. This page allows the LSE to enter DWR contracts that may or may not fit in the other pages of the template. In order to facilitate evaluation of Local RAR procurement, please enter all unit specific DWR contracts and their CAISO IDs on the Physical Resource page in the Local RA template, as they are possibly Local RA units. Please enter all DWR contracts on the DWR page of the System and Monthly template however. Additionally, enter the Scheduling Resource ID in the appropriate column of the DWR page for all unit specific DWR contracts.

14. Liquidated Damages (LD) Contracts

Liquidated damage (LD) contracts do not count towards fulfillment of Local RAR, due to their nature as non-unit specific. Additionally, in order to be counted for the 2008 System RAR Filing, LD contracts must comply with the following rules:

1. No LD contract entered into after October 27, 2005 can be used for RA purposes.

2. LD contracts entered into on or before October 27, 2005 can not be modified to increase the number of MW or the duration of the contract for RA purposes.

For all filings applicable to 2008, LD contracts cannot count for more than 25% of the LSE's RAR portfolio. This phase out is reflected in the last line of Summary Table 6 on the template. LD contract MW in excess of 25% of an LSE's RAR portfolio do not count for RA compliance. For example, if LSE-ABC's total RAR is 1,000 MW, then LSE-ABC must demonstrate at least 75% of their RA procurement via non-LD contracts.

Firm import LD contracts with specific Intertie Points and Import Allocations are not subject to these phase-out provisions and should not be included on the LD page, but listed instead on Worksheet III Non-Unit Contingent Import. LD contracts do not count for Local RA, and when an LD contract delivers to any point in the CAISO, it is not viewed as a resource in one of the two zones of California for purposes of the Path 26 constraint.

To the extent that procurement meant to satisfy Local RAR summed with the rest of the LSEs procurement causes over procurement, and in effect restricts the counting of LD contracts further than the phase out percentage would otherwise accomplish, the Local RAR takes precedence.

15. Resource Adequacy (RA) Portfolio Resources

D.06-07-031 determined that the RA compliance process can accommodate the limited use of Resource Adequacy (RA) Portfolios, which are plant-specific RA contracts, not unit-specific RA contracts. For example, for the System Year-Ahead compliance filing, LSE-ABC may want to enter into an RA contract with a generator for 200 MW to be provided by any one of three units at the Acme Power Plant, as opposed to a specific unit.

For purposes of the Year-Ahead 90% compliance filings only, RA portfolios are acceptable, subject to the following conditions:

1. The portfolio must be eliminated and converted to specific units in the Monthly System RA showing.

2. Any portfolio must be unique and the units behind that portfolio must be specified, communicated to the CAISO/CPUC, and not allowed to change.

3. The portfolio may not have total capacity greater than the summed Qualifying Capacity of the individual units.

4. Portfolio may only be comprised of units served by the same busbar.

5. All units are located in the CAISO control area.

The 2008 Local RA compliance showings do not allow the use of portfolio resources.

16. Certification of LSE Resource Adequacy Compliance Filing

As confirmed in D. 06-07-031 all RA Filings shall be filed under the following certification; a certification sheet must accompany each template.

Consistent with Rules 1 and 2.4 of the CPUC Rules of Practice and Procedure, this Resource Adequacy compliance filing has been verified by an officer of the corporation who shall expressly certify, under penalty of perjury, the following:

1. I have responsibility for the activities reflected in this filing;

2. I have reviewed, or have caused to be reviewed, this compliance filing;

3. Based on my knowledge, information, or belief, this filing does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements true;

4. Based on my knowledge, information, or belief, this [filing] contains all of the information required to be provided by Commission orders, rules, and regulations.

The actual certification page must be completed and signed; it is included as a separate tab in each of the template workbooks.

17. RA Filings Instructions

The 2008 Local RA Filings cover Local RAR for the entire 2008 compliance year, and the System RA Filings cover System RAR for the months of May through September 2008. These filings are due at the Commission Office and at the CEC and ISO offices, according to the detailed schedule below. Postmarks will not be accepted. Pursuant to D. 05-10-042, filings are to be made via Advice Letter. Instructions for filing Advice Letters for RA compliance follow in Appendix A, and an Advice Letter Summary Sheet to be included in the RA Filing follows in Appendix B. Importantly, due to revised Advice Letter procedures adopted in Commission Decision D.07-01-024, there have been some edits to the Advice Letter Primer in Appendix A. These are summarized below:

The LSE will no longer receive a stamped copy of the Advice Letter and the approval mailed via first class mail, but instead will receive an electronic copy of the approval letter via email.

LSEs must designate that this is a Tier 2 Filing, and the effective date is to be the first date of the applicable compliance month, not the date that the Advice Letter is filed.

Type of Filing	Due Date
Preliminary Local and System RAR Year-Ahead	September 19, 2007
Final Local and System Year-Ahead	October 31, 2007
CAISO notifies all LSEs of any collective deficiencies to allow for additional LSE procurement.	November 8, 2007
January Month-Ahead	November 30, 2007
Last date for LSE to file amended Local RAR or System Year-Ahead RAR showing to reduce CAISO backstop for collective deficiency.	December 3, 2007

File with the agencies at the addresses below:

1. An Advice Letter that complies with the rules in Appendix A and includes a Summary Sheet;

2. Completed workbooks covering System RAR for the summer months of May through September and the Local Template which covers all months of the year

CPUC Energy Division
505 Van Ness Ave. 4^th Floor

San Francisco, CA 94102

Attn: Tariff Room (RAR Filing)

jnj@cpuc.ca.gov

California Energy Commission

1516 Ninth Street

Sacramento, CA 95814

Attn: Mike Jaske (RAR Filing)

R Afiling@energy.state.ca.us

CAISO

151 Blue Ravine Road

Folsom, CA 95630

Attn: RAR Filing

reliabilityrequirements@caiso.com

TWO hardcopies and one electronic copy (by CDROM in Word and Excel format) of the entire RA Filing (Advice Letter with Summary Sheet and RA Templates) shall be submitted to the CPUC Energy Division at the address above. The entire RA Filing is also to be submitted electronically to the CEC and CAISO at the addresses listed above. LSEs may voluntarily submit filings via email to the CEC and CAISO at the email addresses above, but if they do not wish to, LSEs must still submit the electronic version via CDROM. The RA Filing, whether physical or email, must arrive by the due date and postmarks are not accepted. Due to recent revisions to Advice Letter procedures, LSEs will no longer receive a stamped copy in the mail, nor receive a hardcopy of the approval letters. The LSE will receive an emailed approval letter instead. For this reason, the LSE must provide an email address to which the Energy Division will email the approval letter. The Energy Division will report Advice Letters and related documents, and the date of their receipt, in the Daily Calendar.

We have included one page for each worksheet. If more are needed, add rows to the Excel spreadsheet. We have locked all formulas in the template so LSEs are unable to alter them. It is the responsibility of the LSE to ensure that all information is integrated into the formulas correctly. In addition, any cell that is not colored blue on the Summary Worksheet of the RA Template is not to be changed. Please do not print out and mail this RA Guide or the template instructions. You can remove these from your filing, as they are unneeded for compliance review. LSEs are also encouraged to print double sided whenever possible both to conserve paper and to reduce the mass of the filings.

18. Correction of Errors: Minor or Substantial

There are specific Advice Letter rules and procedures LSEs must follow when making corrections or addition to their RA Filings. These are detailed in Appendix A, Primer for the Filing of Advice Letters. There are three classes of corrections: those that require replacement sheets to correct typos and numerical errors that do not affect compliance and the LSE is not required to procure additional capacity; errors that require the LSE to procure and demonstrate additional capacity which require a Supplemental Advice Letter filings clearly explaining the corrections; and more substantial errors which require the filing of an entirely new Advice Letter. The CPUC has discretion over classifying errors, and ordering corrections.

LSEs that wish to do so may submit correction sheets electronically to the CPUC, CAISO, and CEC at the email addresses listed above. Supplemental and entirely new Advice Letters cannot be done via email and must be done via physical mail.

APPENDIX A

Submission of Advice Letters for Resource Adequacy Compliance Filings

1. Applicability

D.05-10-042 ordered LSEs to make RAR compliance filings via the Advice Letter process, including Annual Local, Annual System, and Monthly RA Filings. These instructions are not meant to replace the provisions of GO 96-B or the Energy Industry Rules. They are meant to explain and supplement those rules, but the LSE is still responsible for knowing and following the rules of GO 96-B and the Energy Industry Rules.

1.1 Code of Ethics

Rule 1 ("Code of Ethics") of the Commission's Rules of Practice and Procedure (California Code of Regulations, Title 20, Division 1, Chapter 1) shall apply to all RA Filings submitted as Advice Letters.

1.2 Computation of Time

As used in these rules, "day" means a calendar day, and "business day" means a calendar day except for Saturdays, Sundays, and weekdays when the Commission's offices are closed, due either to a State holiday or to an unscheduled closure (e.g., an emergency or natural disaster). The Commission's Internet site (www.cpuc.ca.gov, under "About CPUC") will maintain a list of State holidays for the current calendar year and a list for the following calendar year as soon as that list is available.

When these rules set a time limit for performance of an act, the time is computed by excluding the first day (i.e., the day of the act or event from which the designated time begins to run) and including the last day. If the last day does not fall on a business day, the time limit is extended to include the first business day thereafter.

2. Advice Letter format

The RA Filings (Advice Letter with Summary Sheet and all RA Templates) shall include an Advice Letter, which shall state the person to contact for questions, and the date when the LSE expects the Advice Letter to be received by the CPUC. A Summary Sheet is attached as Appendix B. The Advice Letter shall summarize the contents as follows:

(1) Indicate requested effective date, which is the first day of the applicable compliance month;

(2) Indicate service affected by the Advice Letter (in this case Retail Electric Service);

(3) Cite Commission orders by decision or resolution number (in this case D.05-10-042 and D.06-06-064) and Public Utilities Code or other statutory provisions (by section) related to the substance of the Advice Letter, and identify as compliance filing (where applicable);

(4) Indicate whether the LSE believes disposition of the Advice Letter by Commission resolution is necessary or appropriate (RA compliance filings do not require a resolution);

(5) Show contact person, telephone number, and e-mail address for additional information regarding the Advice Letter and the person to whom the approval letter is to be sent.

(6) Protest Period; state that RA compliance filings are not subject to protest.

(7) State that this is a Tier 2 Filing, which requires approval of the Energy Division.

If an RA Filing does not include a complete Advice Letter, as described above, the Energy Division may reject the Advice Letter without prejudice or extend the protest period unless and until the LSE files the information that is missing or incomplete with the CPUC.

3. Form and Content

An LSE shall:

(1) number the Advice Letter sequentially, beginning with No. 1 for the first Advice Letter filed by the LSE, followed by the letters ESP if the LSE is an ESP or E if the LSE is an IOU.

(2) state whether any deviations would be created, service withdrawn from any present customer, or more or less restrictive conditions imposed;

(3) state the notice requirements applicable to the Advice Letter, and describe how those requirements were satisfied.

4. Filing Advice Letters and Related Documents

The RA filing (Advice Letter with Summary Sheet, and all applicable RA Templates) shall be submitted to the CPUC Energy Division, CEC, and CAISO. The number of copies and method of filing are summarized in Section 16 of the RA Guide, along with the exact mailing addresses to be used at the CPUC, CEC, and CAISO.

5. Service to Other Parties

The System and Local 2008 RA filings are compliance filings and not subject to protest. Therefore, service beyond the parties listed in Section 16 of the RA Guide (CPUC, CEC, and CAISO) is not required.

6. Correction of Errors made in RA Filings

Corrections to the RA Filing are to be made according to the rules for correcting errors in Advice Letters as established in GO 96-B. Minor typographical or numerical inaccuracies that do not affect compliance and do not require the procurement of additional capacity can be made by submitting corrected sheets to replace incorrect sheets. Corrections of this type may be submitted via email, if the LSE so wishes. The LSE must type REVISED at the top of all corrected pages and highlight any changed cells in the spreadsheet. Errors that do affect compliance and require the LSE to procure additional capacity must be submitted via supplemental Advice Letter that details any additional procurement. Major errors may require the filing of an entire replacement RA Filing with advice letter. The PUC Staff reserves the discretion to classify errors as one of the three classes, and to order corrections. Directions for all three cases follow.

· Typographical and Numerical Errors:

Simple typographical or numerical errors can be corrected by the LSE or upon request by the PUC by submitting correction sheets to replace the pages with the errors. Corrections of this type specifically are corrections that do not affect compliance or do not invalidate resources sufficient to drop the LSE below RAR. In the case of a supply plan mismatch or a scheduled outage that invalidates a portion of the LSE's capacity, if the supplier has submitted replacement capacity via a supply plan, the LSE may submit corrections to list the correct source of capacity via correction sheets. If the LSE must procure additional capacity, that must be demonstrated via a Supplemental Advice Letter. Service of correction sheets may be done via email, at the email addresses detailed in Section 16 of this RA Guide. LSEs must type REVISED at the top of any page that contains corrections and must highlight cells that have been altered. If the LSE does not wish to email the correction sheets, the LSE must submit a corrected version on CDROM and provide printouts of the corrected sheets. Either by email or physical mail, corrections must be submitted within five business days after notification by the CPUC. Corrections of this type do not require an Advice Letter Cover Sheet or Summary Sheet.

Submission of correction sheets must arrive at the CPUC within five business days after notification by the CPUC Energy Division via telephone or email. Postmarks will not be accepted.

· Other Minor Errors

Errors that affect compliance, where removal of capacity in question would leave the LSE without sufficient capacity to meet RAR, must be corrected via the filing of a Supplemental Advice Letter. Specifically, if the LSE must procure additional capacity, then the additional procurement must be demonstrated via a Supplemental Advice Letter and the LSE is to ensure that a revised supply plan documenting that additional procurement is filed by the supplier. Corrections and additional procurement must be clearly explained in the Advice Letter Cover Sheet and noted on the Summary Sheet in Appendix B. Also the LSE must state in the Advice Letter that the purpose of the Supplemental Letter is to replace the original "in its entirety". The numbering of the Advice Letter is to be the same as the original Filing, with the addition of the letter `A' to the end of the number (e.g. 1ESP-A). Subsequent corrections to the same original Advice Letter should use subsequent letters. For example, the second correction of the original letter detailed above would hold the number 1ESP-B.

Supplemental Advice Letters are evaluated similarly to regular Advice Letters, and are subject to the same filing provisions. Examples of minor errors include omitting resource availability, filing a resource under an incorrect tab (recording an LD contract as an import), and any typographical or numerical error that would change an LSE's compliance status. The Supplemental Advice Letter is to be mailed to the CPUC at the address in section 16 of this RA Filing Guide.

Submission of correction sheets, either email or physical mail, must arrive at the CPUC within five business days after notification by the CPUC Energy Division via telephone or email. Postmarks will not be accepted.

· Substantial Revisions - Entirely New Advice Letter

For more substantial errors, the LSE may be asked to refile a second complete RA Filing including RA Filing workbooks and advice letter with Summary Sheet. The numbering of the Advice Letter will use the next available number, and list the original Advice Letter that is being replaced on the appropriate spaces on the Summary Sheet. The Advice Letter Cover Sheet should also clearly explain the reasons behind the second filing of the entire RA Filing. The new Advice Letter is to be mailed to the CPUC, CEC, and CAISO at the addresses in section 16 of the Filing Guide.

CALIFORNIA PUBLIC UTILITIES COMMISSION

ADVICE LETTER FILING SUMMARY

ENERGY UTILITY


MUST BE COMPLETED BY LSE (Attach additional pages as needed)
Company name/CPUC Utility No.
Utility type:			Contact Person for questions and approval letters: _______________________________
· ELC	· GAS		Phone #:
¨ PLC	¨ HEAT	¨ WATER	E-mail:
EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water				(Date Filed/ Received Stamp by CPUC)
Advice Letter (AL) #:
Subject of AL: Tier Designation: ¨ 1 ¨ 2 ¨ 3 Keywords (choose from CPUC listing):
AL filing type: ¨ Monthly ¨ Quarterly ¨ Annual · One-Time ¨ Other _____________________________ If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution: Does AL replace a withdrawn or rejected AL? If so, identify the prior AL ____________________________ Summarize differences between the AL and the prior withdrawn or rejected AL¹: ____________________ Resolution Required? ¨ Yes · No
Requested effective date:					No. of tariff sheets:
Estimated system annual revenue effect: (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting).
Tariff schedules affected: Service affected and changes proposed⁷:
Pending advice letters that revise the same tariff sheets:
Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to:
CPUC, Energy Division Utility Info (including e-mail)
Attention: Tariff Unit 505 Van Ness Ave., San Francisco, CA 94102 jjr@cpuc.ca.gov and jnj@cpuc.ca.gov

Appendix C

California Independent

System Operator Corporation


*CAISO Tariff Section 40.5.2.2 - Deliverability of Imports*		SC/LSE OBLIGATIONS		CAISO OBLIGATIONS
Tariff Step	Required Tasks by Step	Due Date	Status	Due Date	Status
1	CAISO will publish Total Import Capacity on CAISO website			1-Jul	Complete
2	CAISO will determine Available Import Capability by taking Total Import Capability and subtracting ETCs and TORs			1-Jul	Complete
3	CAISO will reserve Import Capability for holders of ETCs and TORs and will not reduce them pursuant to following steps.			1-Jul	Complete
4	CAISO will reserve Import Capability for the holders of Pre-RA Commitments reported as part of the 2007 Import Allocation process pursuant to Branch Group ratings			9-Jul	Complete
5	LSEs receive allocation of Remaining Import Capability reduced by allocations for ETCs, TORs, and Pre-RA Commitments from previous steps			9-Jul	Complete
6	CAISO will post amounts of Total Import Capability, the aggregate amounts and identity of holders of ETCs and TORs, aggregate amounts of Pre-RA Commitments, and the Remaining Import Capability by branch group after previous steps on their website			9-Jul	Complete
7	CAISO will notify the SC for each LSE of the LSE's import capability Load Share, Load Share Quantity, accepted branch group allocations, and Reminder Import Capability.			9-Jul	Complete
8	LSEs will notify CAISO of any trades of Remainder Import Capability with necessary information	18-Jul	Complete
9	SCs for LSEs will report to the CAISO requests to allocate Remainder Import Capability to particular branch groups	19-Jul	Complete
10	CAISO will notify LSEs of their accepted allocations of Remainder Import Capability and post the aggregate Remainder Import Capability to their website			27-Jul	Complete
11	LSEs can request allocations of Import Capability remaining after the steps above. CAISO will honor requests pursuant to Branch Capability	1-Aug	Complete
12	CAISO will notify the LSE of the LSE's accepted allocation based on Step 11 above and publish the amount and identity of any remaining Import Capability on their website			8-Aug	Complete
13	SCs for LSEs may at any time in the year request allocations of Import Capability remaining after Step 12 above, which will be effective for the remainder of the Compliance Year, on a first come - first serve basis.	Continuous

Appendix D

Frequently asked questions and clarifications to the filing instructions:

1. Question: What if I have more than one contract with facilities under the same Scheduling Resource ID such as a set of QFs or maybe there is a baseload contract with a generator for part of the capacity, but also peak capacity contract for the rest? How should I file that in the RA template; should I include all that information in one line with one contract ID?

Answer: For multiple QF units under one aggregate ID that are all for as available capacity, please roll them all up under one Scheduling Resource ID and report the total capacity in one line of the template with the same hours of availability. For multiple contracts with the same Scheduling Resource ID that have different hours of availability, please list each separate contract on separate lines consecutively in the RA template. The Scheduling Resource ID (column C) will remain the same, but the Resource contract number (column G) will be different. Please list all information for each contract to the extent that functionally they are different contracts.

2. Question: What if I have one contract for peak capacity for 15 MW and a second contract for off-peak capacity for 5 MW? How should I report these contracts in the RA template; should I include all that information in one line with one contract ID?

Answer: If the peak and off peak contracts combine to cover a 24 x 7 period, split the peak contract into two components; 5 MW to match with the off-peak contract and 10 MW that remain peak. Then, on one line report the 5 MW peak and 5 MW off peak contracts as a single resource in category 4 with unrestricted availability (all hours). On a second line report a 10 MW peak contract. On the line with two contracts, both contract numbers should appear in the contract ID cells.

3. Question: What if I have one contract with a facility, or an LD contract, that includes different components? For example 100 MW 7x24, and 15 MW 7x16? How should I report that in the RA template; should I include all that information in one line with one contract ID?

Answer: If a single resource contract has separate components that qualify in different resource categories, the contract should be entered in the RA Template in multiple lines. Using the example, one line should be completed using the 100 MW 7x24 component and a separate line should be completed using the 15 MW 7x16 component. Each line should include all information.

4. Question: What does it mean in the instructions for Minimum Hours in Month, where the directions refer to "during peak load hours?"

"Minimum Hours in Month - The minimum number of hours in the RA month that the RA resource is contractually or physically available and capable of operating at its Qualifying Capacity during peak load hours to meet the LSE's RAR."

Answer: The minimum hours in a month are the minimum hours that a resource is available. For example a 5x4 contract is available for 80 hours a month. To count, those hours must be peak hours. A 5x4 contract that is available between 2 and 6 am would not deliver RA benefits. Different programs have different definitions of peak hours, so for this template peak hours are counted in accordance with program rules. For example, solar and wind resources define peak as noon to 6pm per D 05-10-042.

5. Question: Do firm import LD contracts signed after October 27, 2005 still count towards RA requirements, or are they subject to the same sunset date and phase out percentages as in-area LD contracts are pursuant to page 65 of D. 05-10-042?

Answer: Firm import LD contracts do not fall under the sunset and phase out provisions because they do not present the same deliverability and reliability issues as in-area LD contracts. Thus Firm import LD contracts with specific intertie agreements do not fall under the same phase out schedule.

6. Question: What is the difference between Scheduling Resource ID in Column C and the Resource Contract Number in column G in Worksheets I, II, and IV in the RA Template?

Scheduling Resource ID - The CAISO-assigned Scheduling Resource ID.

Resource Contract Number - LSE specified number that identifies the relevant contract(s). This information will be used to identify supporting documentation during compliance verification.

Answer: Column C, Scheduling ID in CAISO Master File is a standard ID name supplied for a particular unit from the CAISO Master File. Column G, Resource Contract Number, refers to the LSE's contract ID number. If there are two contracts with the same unit, then contract numbers (column G) would be different, but the Scheduling Resource ID or CPUC LD contract number (Column C) would be the same. Please refer to Question 1 above.

7. Question: The RA guide tells an LSE to input into separate DR worksheets those programs that are over 2 hours per day and those that are under 2 hours per day. The guide also states that the total amount of DR Allocation is to be found in a letter received from the CEC. This letter from the CEC does not make clear which programs are under 2 hours a day and which are over 2 hours a day; the letter only gives total capacity. Where do I enter this allocation?

Answer: All the programs listed in the CEC letter are for over 2 hours a day; that was how the CEC analyzed it. Put all programs listed on the CEC letter for over 2 hours a day.

8. Question: What is the desired level of accuracy for numbers, 1 MW, 0.5 MW, 0.01 MW? Do I round numbers off to the nearest 1MW, 0.5MW or 0.01 MW?

Answer: For purposes of filling in the templates, round off to the nearest 0.01 MW like the load forecasts and RMR allocations do. Do not round any more than that. Precision is important, particularly for smaller LSEs

9. Question: If I have no LD contracts, do I need to file the LD worksheet in the RA Template?

Answer: No. Just state it in the Advice Letter that the LD worksheet is unneeded. In fact, any part that does not apply to the LSE can be left out, such as DWR contracts, with a statement in the Advice Letter stating which parts are missing and why. Please also limit submissions of blank pages. Just use the sheets that you need. Also the PUC encourages the LSEs to print double sided whenever convenient, to conserve paper and reduce the mass of the filings. It is the responsibility of the LSE, however, to ensure that no formulas on the Summary Page are damaged by the removal of worksheets, as summary data is drawn from all parts of the template.

10. Question: What if I have a contract with a unit that lasts for only part of the month?

Answer: Please pair up the resource with another resource that can fill out the month as done for peak/off peak pairings in question 2 above. If that is impossible, a contract for part of a month will not count for RA and should not be listed.

¹ The transfer capacity on Path 26 must be de-rated to accommodate ETCs that are used to serve load outside the CAISO control area. "Loop flow" is common to large electric power systems and must be accommodated to prevent overloading of lines.

² Appendix 1 deals with IOU data, and Appendix 2 deals with ESP data.

³ Pursuant to Commission Decision 06-07-031 section 4.1 and 4.2

⁴ The CPUC mailed out 2008 DR allocations, Local RA, and load forecasts by certified mail on July 6, 2007. Some of this information originated with the CEC, but it was mailed to the LSEs by the CPUC.

⁶ Does not include filings for System RAR

⁷ Discuss in AL if more space is needed.