666 Grand Avenue Suite 500

MidAmerican Renewables, LLC

666 Grand Avenue Suite 500

Des Moines, Iowa 50309-2580

Phone: 515-252-6754

Steve Rowley

Director, Asset and Risk Management

Submitted By / Company / Date Submitted
Steve Rowley

(515) 252-6754 / MidAmerican Renewables, LLC / February 26, 2014

VIA E-MAIL

To:

Re: Proposed Revision Request (PRR) 719 – “FERC 764 Order updates”

MidAmerican Renewables, LLC (MidAmerican), based in Des Moines, Iowa, owns and operates solar and wind projects that participate in the CAISO market as Eligible Intermittent Resources (EIRs). MidAmerican submits the following comments in response to PRR 719.

MidAmerican is supportive of the CAISO’s effort to improve forecasting and situational awareness by harvesting available meteorological data.It would be prudent to allow both CAISO and EIRs some flexibility with respect to providing this data.

For example, one MidAmerican solar project expects to transmit data from hundreds of meteorological measurement devices to another party. If CAISO was either not prepared to integrate or not interested in integrating hundreds of measurements from a single solar resource into its operational systems, it would be advisable to allow the parties to agree to share something other than all available data at their discretion, particularly if doing so would impose unreasonable incremental costs upon the EIR.

MidAmericanrecommends changes to the draft BPM language along the lines of the highlighted text below:

“If an EIR, as part of compliance with any other contractual or regulatory requirement outside of this BPM, provides data from more than the two minimum required meteorological stations to a party other than the ISO, then the data from those additional meteorological stations must also be submitted to the ISO. If the ISO does not have the ability to useall or a portion of this additional data or otherwise deems it to be unnecessary for operational purposes, the EIR and ISO may mutually agree to provide only such data as may actually be used by the ISO.

Thank you for the opportunity to comment.

Very truly yours,

/s/ Steve Rowley

Director, Asset and Risk Management

MidAmerican Renewables, LLC