By Jason Fordney

Developers of renewable energy and emerging technologies are predictably supportive of CAISO’s vision for the grid of the future, but operators of more traditional resources say the proposal drifts outside the ISO’s purpose of assuring reliability and managing markets.

The nearly 200 pages of comments on CAISO’s Vision 2030 paper illustrate concerns about the ISO’s changing grid mix, laying out arguments that the transition is coming at the expense of reliability, fair markets and reasonable costs to ratepayers.

CAISO’s Board of Governors and management published the discussion paper in October, saying it was “intended to help focus discussion on both technical and policy issues involved in decarbonizing and decentralizing electric service.” The document identified California energy trends over the next 12 years, including more efficient energy use, a significant decline in gas-fired generation, more variable energy resources, decentralized service, regional collaboration and integration of electric vehicles. (See CAISO Symposium Panelists Talk Grid of the Future, Western RTO.)

The Independent Energy Producers Association, which includes both fossil fuel and renewable interests, suggested that CAISO had wandered from its core mission and is picking winners and losers by focusing on decarbonization and distributed resources.

“Overall, we find the Vision Paper not particularly helpful in illuminating what, if anything, the CAISO management will be ‘tasked’ to accomplish over the near term, e.g. one to five years, related to the CAISO’s primary function to maintain 60 Hz on the electric transmission grid and administer just and reasonable wholesale markets,” said IEPA CEO Jan Smutny-Jones, a former CAISO board chair.

The group urged the ISO to focus on accessing low-cost, transmission-connected renewables. It also complained that while the California Public Utilities Commission’s integrated resource plan assumes that about 30,000 MW of gas-fired generation will not be subject to retirement because of environmental rules by 2030, CAISO’s paper makes no accommodation for sustaining those resources.

“The evidence clearly recognizes a need for this type of generation (flexible capacity), yet the market provides little if any means to ensure that competitive resources that can provide these necessary services are available to the CAISO when and where needed. Importantly, the Vision Paper is silent on what, if anything, CAISO intends to do to address this matter,” the group said.

The California Municipal Utilities Association (CMUA) filed brief comments saying that issues identified in the paper, such as energy efficiency, vehicle electrification and economic impacts, “may all have an indirect impact on how the CAISO operates the grid. But the policies and choices inherent in each of these issues are not the CAISO’s core function, which is critical and complex [in its] own right without these additional challenges.”

CMUA Executive Director Barry Moline mentioned reliability-must-run agreements, the congestion revenue rights auction and the fact that most load-serving entities in the Western U.S. are vertically owned utilities that regulators want to remain in business.

“The CAISO should be cautious when opining on these issues of industry structure, rather than focusing on its core functions, as it seeks to expand collaboration beyond California,” Moline said.

NRG Energy, which operates some fossil fuel plants, said that relying on natural gas plants in constrained areas “is environmentally preferable to spending large amounts of money to eliminate those resources.” CAISO recently determined that NRG’s proposed Puente power plant would be the cheapest alternative out of a mix of alternative resources, but the company suspended its application after the California Energy Commission indicated it would not approve the plant. (See CEC Members Recommend No-Go for Puente Plant.)

NRG also noted that many topics in the paper are outside of CAISO’s traditional role, such as developing a new zero-energy building plan and shaping the state’s resource adequacy plan, which is under CPUC jurisdiction.

In Powerex’s comments to the ISO, CEO Teresa Conway promoted “forward arrangements” for flexible capacity and renewable integration. The Canada-based power marketer is due to join the CAISO-run Energy Imbalance Market (EIM) in April 2018. (See FERC Approves Powerex EIM Agreement.)

“We believe the pursuit of forward arrangements, along with expanding short-term energy markets like the EIM, can be an effective strategy for unlocking the capabilities of existing clean resources outside of California, and in particular the unique capabilities of northwest hydro systems,” Conway said. She said the state is at a “critical point” in the transformation of its energy grid and “the initial approaches responsible for the state’s success cannot be scaled indefinitely, and signs of renewable integration challenges are already present.”

Increased regional electricity trade and coordination will provide economic and environmental benefits by meeting customer needs with the cheapest resources, Powerex said, but increased coordination must accommodate differing and sometimes conflicting policy goals.

Powerex proposed establishing a “clean” resource adequacy requirement, aggressively pursuing storage, expanding forward commitment and procurement, and accurately measuring California’s greenhouse gas emissions associated with out-of-state resources.

Southern California Edison said it is not sure it agrees with CAISO’s assessment that, by 2030, demand-side resources will be as important as supply in balancing the system. About 4,500 MW of San Diego peak load will need to be met with supply sources, and “similar conclusions apply to loads in the SCE and [Pacific Gas and Electric] distribution service areas.”

SCE said it supports a “well-designed” carbon cap-and-trade program and properly implemented regionalization, including a Western states committee advisory body.

The Public Generating Pool, which represents 10 publicly owned utilities in Oregon and Washington, gave a regional perspective as other states look to possibly join markets operated by CAISO. California’s neighboring states have more hydro and coal resources and traditional cost-based utility regulation.

“The broad nature of this document and the numerous recommendations for policy, however, do not seem to fit the expected role of the CAISO as an independent system operator,” the group said. “If there are future versions of this document, it would be helpful for the CAISO to be more specific about its role relative to California legislature and state agencies.”

But the ISO’s vision did get solid support from some corners. The California Electric Transportation Coalition said, “We agree with and support Cal ISO’s emphasis on transitioning from fossil fuels to electricity in the transportation sector.” The group said that EVs will be increasingly important to manage load and store excess renewable generation. The ISO’s plan stated that California cannot reach its greenhouse gas reduction goals without electrifying the fossil energy now used in buildings and vehicles.

Arizona-based First Solar, which develops utility-scale photovoltaic modules, offered praise for the CAISO board’s effort to provide a “guiding vision” for strategic planning. And while the company agreed with the “trends and solutions” offered in the paper, it also urged the ISO to consider transmission needs for renewable integration goals.

“Again this year, the CAISO is not addressing additional policy-driven transmission projects in its Transmission Planning Process, creating potential problems for the increased interconnection of renewables required to meet California’s policy goals,” First Solar said.

The CAISO board issued a statement of appreciation for the comments Tuesday, saying they “will be valuable input into the ISO’s ongoing strategic planning process.”