February 3, 2023. Western Grid Group joined The Environmental Defense Fund, Northwest Energy Coalition, Sustainable FERC Project and Western Resource Advocates in filing comments on the draft summary report issued by CAISO: Impacts of Expanded Regional Cooperation on California and the Western Grid Draft Report for Stakeholder Review (Draft Report) that was released January 20, 2023.
Submit comment on draft summary report
Initiative: Assembly Concurrent Resolution 188
Submitter information
Name: Kelsie Gomanie
Organization: Sustainable FERC Project Email: kgomanie@nrdc.org
Name: Michael Colvin
Organization: Environmental Defense Fund Email: mcolvin@edf.org
Name: Fred Heutte
Organization: Northwest Energy Coalition Email: fred@nwenergy.org
Name: Amanda Ormond Organization: Western Grid Group Email: asormond@msn.com
Name: Vijay Satyal
Organization: Western Resource Advocates Email: vijay.satyal@westernresources.org
1. Provide a summary of your organization’s comments on the draft summary report and January 20, 2023 stakeholder call discussion:
The Environmental Defense Fund, Northwest Energy Coalition, Sustainable FERC Project, Western Grid Group, and Western Resource Advocates (Public Interest Organizations “PIOs”) appreciate the opportunity to respond to the Impacts of Expanded Regional Cooperation on California and the Western Grid Draft Report for Stakeholder Review (Draft Report) posted by the California Independent System Operator (CAISO) on January 20, 2023. The Environmental Defense Fund, Northwest Energy Coalition, Sustainable FERC Project, Western Grid Group, and Western Resource Advocates are public interest organizations that advance policies to further a low-carbon grid and reduce harmful emissions from fossil-fuel generation through market-based solutions. We support a successful, broadly utilized, inclusive, and transparent Extended Day- Ahead Market (EDAM) that leads market participants on a glide-path to a West-wide regional transmission organization (RTO). We appreciate the exploration of the various modes of regional cooperation in the Draft Report, especially the expansion of CAISO to become a multi-state RTO. We have provided comments on several elements of the Draft Report. Any element we did not directly comment on in this document does not indicate full support.
PIOs appreciate the quick turnaround on the Draft Report and recognize that the scope of the Draft Report was to summarize impacts of expanded regional cooperation on California and California ratepayers, as well as collaboration and engagement between neighboring states on the future of RTOs in the West. We appreciate the qualitative and quantitative information provided in the Draft Report that is specific to California or that applies to the whole of the region while recognizing that additional analyses may be required on a state-by-state or utility-by-utility level to determine net benefits on an individual basis.
Section 1.1 of the report notes three important needs for California that can be addressed with regional market expansion: (1) more power procurements from outside the state; (2) more exports, especially mid-day solar that might otherwise be curtailed for local needs but has substantial value in the rest of the West; and (3) optimized reserve sharing, especially with the Southwest.
PIOs agree with these identified benefits but also propose that the key points should be expanded to include improved reliability during stressed grid conditions and the opportunity to reduce over-procurement of future resources.
On the first point, we note the critical role that cross-regional coordination played in addressing the unprecedented heat wave in early September 2022 that broke temperature and demand records in California and across the West. Expansion of market function will reduce the need for bilateral coordination, manual adjustments, and use of other emergency actions in the future. While reliability benefits are difficult to quantify in monetary terms, we anticipate the full event analysis for September 2022 will demonstrate the very high value of operational coordination in reducing reliability risk.
Likewise, as discussed in the summary of the State Led Market Study, over time the cumulative economic savings from optimizing capacity expansion across a wider market footprint could even exceed the production cost savings…