By Jason Fordney

Generation owners in CAISO are urging changes in an ISO reliability proposal for determining which unprofitable generators are eligible to receive payments in order to remain operational.

The power sellers were commenting on the ISO’s Capacity Procurement Model Risk-of-Retirement (CPM ROR) initiative, which is due to be reviewed by the Board of Governors on Nov. 1. The ISO is proposing to open timing windows each year — in April and November — for three types of ROR designations. (See CAISO Seeks Changes to Boost Retirement Program.)

CAISO earlier this month included 20 changes to its revised straw proposal. It added a requirement for applicants in the April window to demonstrate that their resource is unlikely to receive an annual resource adequacy (RA) contract in early fall for the upcoming RA compliance year.

CAISO has proposed that a resource may not submit an ROR request in the April window unless its costs exceed the CPM soft offer cap. The ISO reasons that higher costs indicate the resource will likely not be chosen as an RA resource. It said it wants the CPM ROR payment to be based on cost of service and that the resource should be the only one that could meet an identified reliability need.

NRG Energy in its comments said the requirement effectively means that a resource with costs below the soft offer cap must wait until the November window.

“Forcing generator owners to wait until November to seek a CPM ROR designation effectively negates one of the primary reasons why resource owners sought a change in the ROR process, namely, to provide for a longer ‘runway’ with regards to seeking, and the CAISO evaluating and granting, an ROR designation prior to the end of a calendar year, to allow for better planning and coordination,” NRG said. “As a result, this new proposed requirement calls into question the value of this initiative.”

San Diego Gas & Electric said it did not believe that a resource’s costs need to be above the current CPM soft offer cap to receive a ROR designation.

“CAISO should not filter out less expensive but similarly qualified resources from the CPM ROR process,” the utility said, adding it sees no reason to keep more expensive resources online over less expensive ones. It said it supports requiring resources to justify costs even if below the soft offer cap.

Pacific Gas and Electric said it understands the CAISO position that the CPM ROR payment be based on cost of service.

“However, if a resource is granted a conditional CPM in April, it does not have an incentive to bid competitively when it knows it can receive cost-of-service recovery,” the company said in its comments.

Earlier this year, market participants said the CPM ROR initiative does not address the fact that CAISO’s energy market can no longer adequately compensate generation resources that are needed for reliability. (See CAISO Stakeholders Question Risk-of-Retirement Initiative.)