CAISO – Gary DeShazo
The ISO desires to restate our position with regard to the ADSTF charter in that the charter as amended by the ADSTF on September 11, 2017 is acceptable to the ISO and we seek no further changes at this time. Further, the ISO has no position on whether or not WECC Membership Classes 4 and 5 should be members of the ADSTF. The ISO does have a position with regard to submitted comments that WECC Membership Classes 4 and 5 were “ignored” or “excluded” from membership on the ADSTF. As the ISO stated in its previous comments on this subject (you will have to ask WECC where those comments are posted because I can’t find them) exclusion of WECC Membership Classes 4 and 5 from the ADSTF is a false premise; all WECC Membership Classes were provided the opportunity to submit membership applications to the ADSTF. The fact that only one class 4/5 member submitted an application and was not selected because they were not “qualified” cannot rationally be blamed on exclusion. Further, submitted comments state that not having class 4/5 representation on the task force suggests that the knowledge base of the task force is somehow inferior to what it could be if class 4/5 members were included on the task force. This is not a rational argument either; all WECC members, specifically class 4/5 members, may participate in task force activities but not everyone can “vote” as part of task force activities. Is it the opportunity to “vote” that makes class 4/5 membership so important? What is the rationale for that?
Considering the process that the RAC followed in developing the draft ADSTF charter, the ISO considered WECC’s “ADSTF Post-Mortem Report - 2017-09-12” that provided information on the WECC process which was followed by the RAC in developing the ADSTF charter. According to that report, the draft was circulated to all RAC groups (209 recipients) and two weeks were provided for review and comment by these recipients. The ISO also reviewed the comments that were submitted to the RAC on the draft charter; there were no comments submitted by class 4/5 members. The record is self-evident that the WECC Membership Classes 4 and 5 were provided equal opportunity to comment on the draft ADS charter and state their concerns but failed to avail themselves of that opportunity.
The ISO’s position is that WECC Membership Classes 4/5 members were not “excluded” from consideration; they had the same opportunity to participate in the process commensurate with all WECC Membership Classes. The one individual who submitted a membership request failed to meet the qualifications outlined in the charter. Further, WECC Membership Classes 4 and 5 were provided the same opportunity to review and comment on the draft charter but failed to take advantage of that opportunity; no comments were submitted to the RAC on their behalf. This issue is not about “exclusion”; it isn’t even about “consideration”; it is about the failure of WECC Membership Classes 4/5 to follow the established process; to avail themselves of the opportunity to provide input to RAC to make their concerns known. The ISO believes that to “reopen” the ADS task force membership without reasonable rationale and/or consideration of the process followed sets a bad precedent, placing WECC’s processes at risk of future challenges.
The ADSTF is being asked to consider adding WECC Membership Class 4/5 members to the task force; the ISO opposes this proposal; they were provided their opportunity through a non-biased process. The ISO also opposes adding any additional members without a reasonable rationale to do so. The ISO suggests that the task force consider that the planning regions start a new interregional planning cycle in January 2018; we are well into September and the task force has yet to accomplish anything of value. Please be aware that the planning regions’ Appendix Ks/Tariffs are process and date specific and do not provide for failure to meet prescribed dates other than being out of compliance with these legal documents. We must keep our “eyes on the ball” for the ADS to retain its value to the planning regions.