CAISO: Deliverability determination for DG, CAISO straw proposal

Reason For Submission: Initial comments prior to a formal proposal

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This filing represents the Clean Coalition's comments on a straw proposal by CAISO prior to development of a formal proposal for determination of guaranteed deliverability of energy from Distributed Generation facilities.  Clean Coalition supports the proposed for simplified determination and allocation of capacity by Local Resource Agencies, but disagrees with restricting consideration to low base case capacity scenarios where these are being exceeded in practice.