CLECA has filed its third round of comments in the CAISO's Demand and Distributed Energy Market Integration (D-DEMI) initiative — the stakeholder process redesigning how demand response and distributed resources participate in California's wholesale markets.
CLECA's positions
CLECA supports the Track 1 export-zeroing reform. But its March 27 comments strongly object to Track 2's exclusion of the two fixes that matter most for reliability demand response: incorporating RDRR startup costs into dispatch, and reforming the minimum-on-time parameter to the 255-minute value aligned with CAISO's own short-term unit commitment — reforms CLECA first proposed in Working Group Session 10 and has carried through the discussion paper phase with a phased implementation compromise.
The stakes are practical: Base Interruptible Program resources are dispatched through RDRR. Market rules that misprice startup costs and on-time constraints dispatch industrial curtailment inaccurately — degrading both grid value and the economics of the state's longest-standing demand response fleet.
All three CLECA D-DEMI filings are in the filings library; the initiative page is at CAISO's stakeholder center.