California ISO
Competitive Solicitation Process Enhancements
Stakeholder Comments Template
Submitted by
Company
Date Submitted
Please fill in the name, e-mail
address and contact number of a
specific person who can respond to
any questions about these
comments.
Please fill in here
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Please use this template to provide your comments on the presentation and discussion
from the stakeholder web conference held on June 16, 2015.
Submit comments to InitiativeComments@caiso.com
Comments are due June 30, 2015 by 5:00pm
The June 9, 2015 straw proposal may be found at:
http://www.caiso.com/Documents/StrawProposal_CompetitiveSolicitationProcessEnhancemen
ts.pdf
The presentation discussed during the June 16, 2015 stakeholder web conference may be found
at: http://www.caiso.com/Documents/AgendaPresentationCompetitiveSolicitationProcessEnhancements-StrawProposal.pdf
Please provide your comments on the ISO’s straw proposal for each of the nine issues identified
by stakeholders through this initiative. For your convenience, the nine issues are listed below
along with the ISO’s straw proposal.
Independent evaluator
The ISO believes that the current process provides for thorough, independent and expert input
into the selection of project sponsors and does not propose to use an independent evaluator.
Comments received on this topic were mixed with more opposing than in favor of adding any
additional layer of review. To respond to comments received in favor of adding an additional
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layer of independent review or to change the existing construct of the current expert
consultants, the ISO provides in this straw proposal more details on the expert consultants
currently engaged in this process (without releasing their actual identities which is kept
confidential to maintain the integrity of the process) and how the ISO coordinates and works
with these consultants. Refer to section 5.1 of the straw proposal.
Comments:
Financial comparison process
The ISO believes that the current financial comparison process is aligned with the ISO’s
commitment to run a fair and non-discriminatory competitive solicitation process and does not
propose further enhancements. There was support for the ISO’s current process among a
number of stakeholders. While no changes are being proposed to the financial comparison
process at this time, the ISO will amend the application in the future to eliminate any perceived
disadvantage of a project financed proposal by clarifying that questions F-11 through F-16 apply
to all applicants. Refer to section 5.2 of the straw proposal.
Comments:
Collaboration period
The ISO continues to support the collaboration period as currently provided for in the tariff and
does not propose to make any changes at this time. A majority of comments received
supported the retention of a collaboration period with a couple of entities proposing certain
modifications to the existing construct. The ISO discusses these proposed modifications in the
straw proposal, but does not recommend moving forward on them at this time. Refer to
section 5.3 of the straw proposal.
Comments:
Collateral/credit requirements for approved project sponsors
The ISO does not believe that posting of financial security should be a requirement placed on
project sponsor applicants. This position is supported by a majority of the comments received.
Nevertheless, the ISO would be open to allowing project sponsors to voluntarily post financial
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security to strengthen its application in the financial area. Refer to section 5.4 of the straw
proposal.
Comments:
Evaluation of selection criteria
In future competitive solicitation reports the ISO will strive to provide clearer explanations of
the differences between project sponsors with respect to meeting the applicable criteria and
their relevance in the decision making process, while balancing confidentiality concerns.
Further, the ISO will revise the project sponsor application to solicit additional information from
project sponsors intending to seek FERC rate incentives. As described in Section 5.1 of the
straw proposal, the CAISO has retained two expert consulting firms to ensure that all selection
factors, both cost and non-cost, are examined in an independent, fair, and comprehensive
manner. Refer to section 5.5 of the straw proposal.
Comments:
Project-specific weighting and scoring methodology
As the ISO explained in the October 7, 2014 issue paper, this initiative does not consider issues
such as weighting, scoring, and mathematical formulas for selecting project sponsors. As
explained in response to the previous issue, the ISO will strive to improve the clarity and detail
provided in decisional reports and will revise the project sponsor application to solicit
additional information from project sponsors intending to seek FERC rate incentives. Refer to
section 5.6 of the straw proposal.
Comments:
Obligation regarding the transfer of assets
Comments received on this issue were split on whether the approved project sponsor should
have a requirement or obligation to transfer the assets to the alternative project sponsor. To
further the discussion, the ISO proposes that if the alternative project sponsor desires the
project assets, the approved project sponsor shall negotiate in good faith with the alternative
project sponsor to transfer such project assets. The ISO does not believe that the approved
project sponsor should be obligated to transfer project assets absent (i) determination by the
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alternative project sponsor that the assets are desired to continue the project and (ii) fair
compensation of the assets (however the ISO is not in a position to determine what the “fair
compensation” should be). Refer to section 5.7 of the straw proposal.
Comments:
Cost estimate standard
The ISO agrees that a minimum level of detail is required when a project sponsor submits cost
estimates, and proposes to update the project sponsor application to clarify the amount of cost
estimate detail a project sponsor is required to provide. Refer to section 5.8 of the straw
proposal.
Comments:
Pre-qualification outside of bidding scheme
The ISO believes that this issue was addressed during the FERC Order No. 1000 stakeholder
process and continues to favor an approach that allows for flexibility. Refer to section 5.9 of
the straw proposal.
Comments:
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