The ISO received comments on PRR-1067 of the Business Practice Manual Change Management process from the following:

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1 The ISO received comments on PRR-1067 of the process from the following: 1. Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California (Six Cities) 2. Southern California Edison (SCE) Copies of the comments submitted are located on the page at: The following are the ISO s responses to the comments. Page 1 of 7

2 1. Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California a Municipal Transmission (Six Cities) Submitted by: Margaret McNaul and Rebecca Shelton 1a (1) The CAISO has not identified a specific reliability need for modeling data The ISO is aware that Category 2 generators are not directly connected from Category 2 generating resources. Section of the TPP BPM to BES, and are thus not part of the scope of NERC Reliability defines Category 2 generators as Participating generators connected to Standards. Nevertheless, the Category 2 generators have an impact on facilities 60 kv and above, and not covered in category 1. Thus, Category the BES in terms of power flow and stability studies. As a result, the 2 generators are not connected to the Bulk Electric System ( BES ), but the CAISO believes it is necessary to ensure data and model quality for CAISO nevertheless is proposing that these generators submit test reports Category 2 generators. The data requirements including test reports and modeling data. (See Section ) Because these generators are are based on the NERC reliability standards for BES connected not connected to the BES, it is not clear for what reason the CAISO would generators (MOD-025, MOD-026 and MOD-027) and WECC need such extensive information. Further, the CAISO s request for test generating facility data, testing and model validation requirements. reports and modeling data from Category 2 generators appears to go Where WECC requirements are more stringent than the NERC beyond the scope of information required from these resources by NERC reliability standards, requirements are set based on the NERC reliability Reliability Standards. standard. For example, WECC policy requires generators being tested every five years while NERC MOD-026 and MOD-027 require the test every ten years. The CAISO proposes 10 year periodicity for dynamic 1b (2) Given that Category 2 generators are not connected to the BES, in the event that the TPP BPM is modified to require from Category 2 Participating Generators modeling and testing data that meets WECC requirements, the CAISO should accept the most recent WECC model data test results for modeling purposes. The generator would only have to be retested pursuant to any equipment modifications since the last test. This would provide the CAISO with the requisite modeling data without placing an undue burden on generator operators. model testing. See response above for 1a. It is necessary to test the facilities periodically even if there has been no major modifications to the facilities to ensure that the models reflect the actual performance and settings of the generator. 1c (3) The penalty provisions pursuant to Section 10 of the TPP BPM are unreasonable. A $500/day sanction for late submission or inadvertent submission of inaccurate information is unreasonably high. Additionally, the CAISO proposes to penalize not the Participating Generator, who is responsible for supplying the requested modeling data under the proposed procedures, but the Scheduling Coordinator. (See Section 10, Overview; and Section ). The Scheduling Coordinator could be a third party and may have no control over whether the Participating Generator submits accurate information or any information at all. Any penalties the CAISO Page 2 of 7 Under Section of the CAISO Tariff, the ISO is enforcing the $500/day penalty on late submissions. Please note that the ISO is allowing a 15 calendar day cure period if the submission is considered deficient prior to penalty being applied, as identified in section of the BPM Section 37 of the CAISO Tariff makes clear that the scheduling coordinator is the proper entity against which to levy penalties in the first instance. Where the scheduling coordinator can demonstrate that

3 assesses for failure to comply should focus on the entity responsible for providing the test reports and model data, rather than the Scheduling Coordinator. 1d (4) With regard to the Generator Data Templates posted by the CAISO, Section 10.3 of the proposed TPP BPM provides that the CAISO will provide Participating Generators with request letters for each unit, accompanied by completed Generator Data Templates reflecting the information that the CAISO and the relevant Participating TO currently have on file for the unit(s). The Six Cities urge the CAISO to provide this information to Participating Generators as promptly as possible. Without knowledge of the scope of information that the CAISO will supply versus the amount of information the Participating Generator is required to supply, it is difficult to assess the magnitude of the burden imposed by the requirement to provide a populated Generator Data Template. it played no part in the generator s failure to provide the required documentation, the scheduling coordinator potentially may avoid the impact of any such penalties. Section 37.8 contemplates that in some cases the ISO investigation must involve outreach to the market participant in addition to, or instead of, the scheduling coordinator. Under the circumstances covered by this BPM change, that means that where a participating generator does not submit the required information, any investigation the ISO conducts prior to assessing penalties may involve outreach to both the generator and its scheduling coordinator. Section 37.9, however, is specific that any Section 37 penalties first be assessed against the scheduling coordinator. Section , however, goes on to state that if a party other than the scheduling coordinator is responsible for the conduct giving rise to a penalty reflected on a Settlement Statement, and where the Scheduling Coordinator bears no responsibility for the conduct, such other party or parties ultimately shall be liable for the penalty. This Tariff section provides further detail on the procedures to follow where a scheduling coordinator looks to invoke this option. The ISO will be providing the data request letters and generator data templates reflecting the information on record, 6-7 months prior to submission deadline, which seems to be sufficient time for the generator owner to validate and update the data. The ISO believes that it already has clearly identified the requirements for each category through its BPM PRR and posted generator data templates, which allows generator owners to begin the required work now. Generator owners are encouraged to commence long lead items like generator testing as soon as possible, since the requirements are already clarified in the posted generator data templates. 1e (5) Section 10 does not specify the frequency of which it will require test reports and modeling data. The Overview section states that CAISO Tariff Section requires Participating Generators [to] provide the CAISO on an annual or periodic basis in accordance with the schedule, procedures and in the form required by the Business Practice Manual any information Page 3 of 7 The ISO notes this comment and will add additional clarification in the PRR revision addressing this concern. Due to the long lifecycle of the initial request, the ISO s intention is to propose the schedule for the next lifecycle of this process at a future time, based on data responses

4 and data reasonably required by the CAISO to perform the Transmission Planning Process..., but it does not go further in explaining whether the information is required annually or based on some other time period. received in this cycle and additional new generators becoming operational. 1f 1g 1h 1i (6) The proposed deadlines, particularly for Category 2 resources, may be inadequate. The Six Cities understand that Participating Generators may need to engage outside vendors in order to perform the model verification and testing required under the proposed TPP BPM provisions, and there are a limited number of vendors with the necessary capabilities and equipment. If the CAISO proceeds with the testing and verification requirements as proposed, it is possible that a large number of resources classified under Category 2 will need to have this testing and verification completed in advance of the 2021 deadlines. It may not be feasible for all Category 2 Participating Generators to schedule testing with a finite pool of vendors in the limited time allotted. (7) The CAISO s proposed testing and validation requirements do not account for the cost to perform the testing and validation. The Six Cities understand that the cost to complete the activities specified in the proposed TPP BPM provision may exceed $8,000-$10,000 per unit, separate and apart from any costs associated with removal of the unit(s) from service. Given the limited discussion of the need for this information from Category 2 resources, it is not clear that these costs are justified. (8) The CAISO and SCE have previously developed a Joint Transmission Planning Base Case Preparation Process pursuant to NERC Reliability Standard MOD How will this document interrelate with the proposed requirements of the TPP BPM? (9) The proposed revisions to the TPP BPM are far more specific and detailed than the Tariff provisions that the CAISO cites as authority for imposing Section 10 s requirements. Because the proposed changes to the TPP BPM arguably go beyond the scope of the current Tariff, the CAISO s Page 4 of 7 The ISO is allowing up to 3 years for Category 2 generators to schedule and complete their testing, which it considers to be sufficient lead time to complete this process. The ISO is not proposing any changes to the schedule at this time. Please note response to comment 1a, in terms of reliability need for this request. The ISO notes the comment on costs for generator testing. As per NERC MOD-032-1, the ISO, as a Planning Coordinator (PC), can request modelling data from its Generator Owners (GOs). The current initiative, PRR 1067 is in line with MOD The ISO will be updating all the different ISO-Transmission Planner (TP) Joint Transmission Planning Base Case Preparation Process documents to reference this BPM change in the generator data section, once the BPM is approved. Section of the CAISO Tariff provides the ISO with authority and discretion to require any information and data reasonably required by the CAISO to perform the Transmission Planning Process.... The ISO has determined that each data element required under the BPM

5 proposal to require Participating Generators to submit test reports and modeling data should remain an issue for discussion in the ongoing stakeholder initiative on 2018 Interconnection Process Enhancements. This initiative, which was the catalyst for the proposed revisions in PRR 1067, provides a broader forum for addressing the CAISO s proposed requirements. revision is reasonably related to the transmission planning process. As the nature of the transmission planning process changes over time, the ISO may adjust the information requirements, either by expanding or reducing the scope of information it requires under its section authority. The CAISO Tariff Section , defers to the BPM for requirements, schedule and process. The ISO has leveraged this authority in development of the proposed section 10 of the BPM for Transmission Planning Process, in order to provide greater detail and clarity to generator owners to respond to its request. Consequently, the ISO believes this issue is not required to be addressed in the ongoing 2018 Interconnection Process Enhancements. Page 5 of 7

6 Page 6 of 7 2. Southern California Edison (SCE) Submitted by: Aditya Chauhan 2a The CAISO has incorrectly identified the scheduling coordinator as responsible for compliance The technical data requested by the CAISO is relevant to physical design attributes of the generator and are known only to the generator owner (GO). The GO is not always the scheduling coordinator (SC). In such a case, the SC has not control over the GO s compliance with the result that the SC will simply be penalized without any change in data submission compliance. As the CAISO already has a participating generator agreement (PGA) with the GO, the CAISO should directly assign the penalty to the GO. The SC is not party to the PGA and inclusion of the SC in this process is unnecessary. Excluding any impact to the SC will not only guarantee the GO s compliance with data submission but will also maintain consistency with the CAISO policy of keeping contractual dealings independent from uninvolved parties in this case keeping the SC independent of PGA enforcement between the CAISO and the GO. Thus, SCE proposes the following language: Section 10 The failure of a participating generator to make a timely submission of the required information will subject the participating generator s scheduling coordinator to sanctions under CAISO Tariff Section Section Failure to make an initial submission by the deadline or failure to resubmit requested data during the 15-day cure period will subject the generating unit s scheduling coordinator owner to a $500/day penalty, as per CAISO Tariff section In the alternative, the CAISO should, at minimum, clearly delineate that the GO is responsible for the non-compliance penalty. In this case, SCE proposes the following language: Section 10 The failure of a participating generator to make a timely submission of the required information will subject the participating generator s Under Section of the CAISO Tariff, the ISO is enforcing the $500/day penalty on late submissions. Please note that the ISO is allowing a 15 day cure period if the submission is considered deficient before the penalty is applied, as identified in section of the BPM Section 37 of the CAISO Tariff makes clear that the scheduling coordinator is the proper entity against which to levy penalties in the first instance. Where the scheduling coordinator can demonstrate that it played no part in the generator s failure to provide the required documentation, the scheduling coordinator potentially may avoid the impact of any such penalties. Section 37.8 contemplates that in some cases the ISO investigation must involve outreach to the market participant in addition to, or instead of, the scheduling coordinator. Under the circumstances covered by this BPM change, this means that where a participating generator does not submit the required information any investigation the ISO conducts prior to assessing penalties may involve outreach to both the generator and its scheduling coordinator. Section 37.9, however, is specific that any Section 37 penalties first be assessed against the scheduling coordinator. Section , however, goes on to state that if a party other than the scheduling coordinator is responsible for the conduct giving rise to a penalty reflected on a Settlement Statement, and where the Scheduling Coordinator bears no responsibility for the conduct, such other party or parties ultimately shall be liable for the penalty. This Tariff section provides further detail on the procedures to follow where a scheduling coordinator looks to invoke this option.

7 scheduling coordinator to sanctions under CAISO Tariff Section 37.6, through notifications sent to the scheduling coordinator. Section Failure to make an initial submission by the deadline or failure to resubmit requested data during the 15-day cure period will subject the generating unit s scheduling coordinator owner to a $500/day penalty, as per CAISO Tariff section , through notifications sent to the scheduling coordinator. 2b SCE requests additional time for Category 3 generators SCE requests that the schedule proposed in Section be extended for Category 3 to SCE s Category 3 units are numerous, small, low capacity units of advanced age. These have been modified or retrofitted over the past several decades. Manufacturer data may be not be relevant for these units, and SCE is requesting additional time so it may perform tests on the units where manufacturer data may no longer apply. The ISO notes this comment but does not have a proposal for extending the submission deadline for Category 3 generators, at this time. Page 7 of 7