Comments in Support of CAISO’s Package of Reforms for On- and Off-peak Deliverability

Pursuant to Rules 213 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission, AWEA respectfully moves to intervene and submit comments in support of the California Independent System Operator Corporation’s January 2, 2020 filing seeking to implement reforms to enhance its deliverability assessment methodology to reflect changing system conditions.