Reply Comments on Track 3B.1 and Track 4

SDG&E:

• Commission should establish a working group to identify the optimal method for valuing qualifying capacity; and
• Should modify CAISO’s proposed ELCC methodology to evaluate DR QC based on top 20% of hours of each month.
• For 2022 only SDG&E is willing to establish a QC value for DR by applying a small derating factor from its ex-ante load impacts.

CalCCA:

• System and flexible RA waiver processes are critical to mitigate market power in today’s severely constrained market conditions.
• The Commission should not make hasty changes to the penalty structure, particularly under current market conditions
• Waivers are a fair and necessary component of the RA market and cautions against hasty increases in penalties without further analysis.
• CalCCA supports AReM’s proposed penalty rebate and moderate 10% increase in penalties provided that the CPUC concurrently adopt a system and flexible penalty waiver framework.
• More seismic shifts should be deferred to a new sub-track for consideration of existing market and regulatory conditions and coordination with the PCIA Working Group 3 RA allocation.