challenging, often iterative process to determine the final study parameters for each local study. However, it is difficult to provide informed feedback to the CAISO and the Commission if study assumptions are not clearly set out. (PG&E May 5, 2017 Comments at 23.) The Center for Energy Efficiency and Renewable Technologies (CEERT) similarly argues that: “[T]he current complexity and lack of transparency continue to adversely impact any assessment of the LCR and FCR requirements…” (CEERT May 5, 2017 Comments at 3.) Specifically, CEERT states: In CEERT’s Opening Comments on the Draft 2018 LCR and Draft 2018 FCR Studies, CEERT expressed concern that the “CAISO calculates the Local Capacity Requirements (LCR) need by a complex, but completely transparent process whose mere outline requires some twentyfive pages to describe” and that, while “the FCR need” calculation methodology is transparent, “the underlying metric and the resources deemed qualified to satisfy that need are anything but clear,” including “what the incremental cost of FCR actually is or what resources are actually supplying flexibility in real time.” [fn. omitted] The Final 2018 LCR Study and Final 2018 FCR Study, for which links were served by CAISO to the service list in this proceeding on May 1, 2015, do not provide any greater clarity for either study. Thus, not only has a very limited amount of time (4 days) been allowed to review these final studies, but neither includes redlined revisions, so it is nearly impossible to quickly determine what changes, if any, have been made and whether those changes are meaningful or responsive to comments by parties. (Id. at 23.) Significant for purposes of this proceeding is the fact that the final LCR and FCR studies were not filed and served in this proceeding by April 15, but rather were filed and served on May 1. Given the need for the CPUC to provide
challenging, often iterative process to determine the final study parameters for each local study. However, it is difficult to provide informed feedback to the CAISO and the Commission if study assumptions are not clearly set out. (PG&E May 5, 2017 Comments at 23.) The Center for Energy Efficiency and Renewable Technologies (CEERT) similarly argues that: “[T]he current complexity and lack of transparency continue to adversely impact any assessment of the LCR and FCR requirements…” (CEERT May 5, 2017 Comments at 3.) Specifically, CEERT states: In CEERT’s Opening Comments on the Draft 2018 LCR and Draft 2018 FCR Studies, CEERT expressed concern that the “CAISO calculates the Local Capacity Requirements (LCR) need by a complex, but completely transparent process whose mere outline requires some twentyfive pages to describe” and that, while “the FCR need” calculation methodology is transparent, “the underlying metric and the resources deemed qualified to satisfy that need are anything but clear,” including “what the incremental cost of FCR actually is or what resources are actually supplying flexibility in real time.” [fn. omitted] The Final 2018 LCR Study and Final 2018 FCR Study, for which links were served by CAISO to the service list in this proceeding on May 1, 2015, do not provide any greater clarity for either study. Thus, not only has a very limited amount of time (4 days) been allowed to review these final studies, but neither includes redlined revisions, so it is nearly impossible to quickly determine what changes, if any, have been made and whether those changes are meaningful or responsive to comments by parties. (Id. at 23.) Significant for purposes of this proceeding is the fact that the final LCR and FCR studies were not filed and served in this proceeding by April 15, but rather were filed and served on May 1. Given the need for the CPUC to provide