Simplifying Policy Management

extension was granted in response to stakeholder concerns about the compressed timeframe for modeling and quality control following the issuance of final inputs and assumptions. This extension follows broad support under Rule 11.6.

Corrections to Data Tools

Commission staff have identified errors in the Resource Data Template and the Clean System Power calculator. These errors will be corrected shortly. LSEs are advised to monitor the service list for updates and postings related to these corrections.

Procurement Data Compliance Filings

Procurement data compliance filings remain due on June 1, 2026. These filings are separate from the August IRP submissions and must be submitted independently.

related RA program design topics. This summary provides a sampling of positions from the parties listed in the instructions.

Transactability and RA Trading Mechanisms

• WPTF supports continued consideration of hourly load‑obligation trading and proposes a pre‑filing trade submission window and a standardized trade template to reduce administrative burden and avoid “cascade” reconciliation issues.

UCAP Framework, Outage Treatment, and Implementation Timing

• WPTF recommends deferring UCAP adoption until Energy Division resolves foundational issues, including whether CAISO receives UCAP‑based QC values and how hybrid storage is treated, and supports limiting assessment hours to top ten net‑peak days.
• CAISO supports adopting the Energy Division’s resource-specific UCAP for 2028, urges development of a hybrid methodology, and opposes class‑average UCAP due to incentives misalignment.
• CalCCA supports UCAP development but requests making a 2028 implementation contingent on resolving data accuracy issues and avoiding double‑counting (e.g., foldback in QC and UCAP).
• Cal Advocates supports Energy Division’s proposed UCAP outage categories and hours, applying consistent treatment across technologies, and maintaining operator responsibility for UCAP revision risk.
• CESA supports ED’s principles‑based UCAP approach but requests a clear forced‑outage definition, a structured data‑review process, and excluding outages outside operator control.
• SCE supports implementing UCAP for System RA beginning in 2028 with technology‑neutral, clearly defined forced‑outage rules and a structured preliminary data‑review process.
• AES urges delaying binding UCAP implementation until storage and hybrid outage‑reporting defects in CAISO OMS are resolved, and recommends adopting a regulatory definition of forced outage.
• MRP requests UCAP revisions to exclude outages outside management control, provide reset mechanisms after major maintenance or force majeure, and clarify treatment of co‑located hybrid gas+storage configurations.

DAME/EDAM (IR/RC) Bidding and Revenue Allocation

• CAISO opposes restrictions on RA bidding or revenue allocation for DAME products, arguing limitations would harm reliability and raise costs; supports using transitional mechanisms and bilateral negotiations.
• CalCCA opposes mandatory IR/RC revenue passthroughs, citing jurisdictional limits, contracting complexity, and risk of higher RA costs.
• Cal Advocates recommends modifying CAISO product design to reduce ratepayer costs and, if no bid‑design correction is adopted, requiring LSEs and resource operators to share IR/RC revenues using fixed fractions.
• SCE supports Energy Division’s proposal with modifications, including allocating capacity‑related IR/RC revenues to RA buyers without reopening existing contracts, and removing the zero‑dollar bid mandate.
• AES opposes a zero‑dollar bid requirement and supports bilateral negotiation of revenue allocation under CAISO’s DAME framework.
• MRP supports CAISO’s approach, rejecting zero‑bid or revenue‑clawback rules and favoring RA contract flexibility.

Energy-Only (EO) Resources and Charging Sufficiency

• CAISO urges the Commission not to allow EO resources to count for charging sufficiency until after CAISO completes its 2026–2027 transmission deliverability study; opposes EO counting toward RA requirements under any conditions.
• CalCCA supports recognizing EO reliability value for co‑located resources and recommends an approach based on hourly POI deliverability attributes.
• Cal Advocates recommends deferring EO accreditation proposals to Track 2 and requests CAISO conduct an informational midday deliverability study.
• CESA supports expanding eligibility for EO resource charging sufficiency with appropriate safeguards and verification processes.
• SCE supports allowing excess energy from paired EO resources at the POI to count for charging sufficiency but opposes broader EO constructs until CAISO validates off‑peak deliverability.
• AES supports a geographic, study‑area‑based approach for EO charging sufficiency and endorses the Joint Parties’ framework with SC attestations and MRD updates.
• MRP opposes allowing EO resources to meet RA or charging sufficiency requirements due to deliverability concerns and reliability risks.
• ACP‑California urges near‑term adoption of an EO charging‑sufficiency pathway aligned with IRP/TPP modeling and supports North/South geographic pairing with contractual bidding and attestation requirements.

Storage Accreditation, Foldback, Charging Sufficiency, and LDES

• Hydrostor urges adopting the Joint LDES Proposal without modification, recommends resource‑specific UCAP with sufficient outage history, and proposes QC adjustments for post‑2031 storage aligned with IRP needs.
• CESA opposes treating battery foldback as a forced outage, citing double‑counting and perverse incentives, and requests Track 2 examination of storage‑specific UCAP failure modes.
• CalCCA supports modifications to ED’s foldback QC approach that allow full output in peak hours while respecting total energy limits and requests avoiding double‑counting between QC and UCAP.
• Cal Advocates recommends deferring foldback policy changes until data availability and fleet impacts are better understood.
• SCE supports Energy Division’s penalty conversion for charging sufficiency deficiencies and proposes modifications to simplify application; supports a modified Cal Advocates MDESR approach for LDES with a 7‑day forward charging period and a 50% initial SOC assumption.
• MRP insists on explicit charging sufficiency requirements for LDES and opposes ED’s flat 24‑hour penalty conversion, recommending penalty calculations based on actual MWh deficiency.
• AES highlights OMS data problems for hybrid resources and urges CPUC to request CAISO fix component‑level outage reporting before UCAP becomes binding.

Solar and Wind QC Methodologies

• LSSA (Joint Solar Parties) support MN8’s proposal to align monthly solar QC with LOLE‑identified high‑risk hours to avoid POI deliverability downgrades for paired configurations and recommend CPUC–CAISO coordination.
• ACP‑California supports replacing the exceedance translation step with direct use of worst‑day profiles as an interim solution while broader RA/IRP alignment is developed.
• Cal Advocates opposes eliminating exceedance without further analysis and recommends CAISO conduct a midday deliverability study to support any revisions.
• CESA notes concerns about exceedance‑driven QC inflating solar values and supports exploring coordination options to avoid unintended PCDS notations.
• MRP opposes ACP‑California’s proposal to remove exceedance, citing the need to preserve ELCC linkage.

Data Center Load Forecasting and Allocation

• CalCCA requests adopting its milestone‑based data center load allocation proposal to reduce RA forecast volatility, including year‑ahead and month‑ahead allocation rules tied to interconnection milestones.
• MRP opposes separating data center loads from IEPR forecasts, citing risks of distorted procurement signals and local reliability impacts.
• SCE recommends safeguards against speculative large‑load forecasts and supports refining processes for RA allocation.
• Cal Advocates supports CEC–CAISO coordination and milestone‑based study to better understand deliverability and reliability impacts but does not endorse specific allocation reforms at this stage.

Local RA, CPE Processes, and LCR‑RCM

• CalCCA opposes eliminating LCR‑RCM until a replacement mechanism compensating LSEs for local RA attributes is established.
• SCE supports eliminating LCR‑RCM to reduce administrative burden, with existing agreements honored through contract end dates.
• MRP opposes PG&E’s proposed elimination, arguing the mechanism supports local procurement incentives.

Other Program Design and RA Framework Issues

• ALLIANCE FOR RETAIL ENERGY MARKETS requests CAISO–CPUC UCAP alignment to avoid dual‑PRM compliance exposure and requests earlier UCAP values (January 2027) for 2028 compliance.
• Hydrostor and ACP‑California request broader RA framework reforms to reflect emerging system needs as renewable penetration grows.
• WPTF requests workshops and a dedicated comment cycle for further development of transactability and hourly RA constructs.