Please provide your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 - Data Transparency May 31, 2022 stakeholder call discussion:
LSA appreciates the opportunity to comment on the CAISO’s May 24th document, Data Transparency Stakeholder Process as part of the Interconnection Process Enhancements 2021 (Paper), and the discussion about the Paper at a May 31st stakeholder meeting (Meeting). While we appreciate the CAISO’s efforts to hold this part of the 2021 IPE initiative, unfortunately it appears that the CAISO may not have the capability to make the improvements stakeholders want for data transparency.
As noted by Gridbright, both the Paper and the Meeting presentation were generally explanations of why the CAISO cannot or would not agree to virtually any of the 40-odd data transparency changes suggested by stakeholders. The reasons include: (1) Data that are “already available” in bits and pieces; (2) systems that do not communicate with one another; (3) systems that cannot easily be updated or modified; and/or (4) workload issues.
LSA is sympathetic, but we have two major concerns with this situation.
First, to the extent that the systems and process limitations are preventing beneficial data-transparency improvements, the CAISO should investigate those used by other ISOs/RTOs and develop a long-term plan to improve and/or replace those inflexible and disparate systems and processes. The CAISO is proposing in 2021 IPE Phase 2 a major increase in Study Deposit amounts, far in excess of actual study costs, and the CAISO should consider diverting some fees from each project toward funding those improvements. The opinion of many LSA members is that the CAISO is “behind the curve” compared to other jurisdictions, and that it should be open to more comprehensive improvements.
Second, we are concerned that at least some of the Paper and Meeting conclusions are misplaced, i.e., are based on incorrect information. The section below provides examples indicating that the basis for some CAISO conclusions may be in error.
Several CAISO statements about where certain data are already “available” are not accurate. Examples include:
- Available deliverability information: LSA and other suggested that the CAISO add to the annual TPD Allocation Report “estimated available TPD in areas where it has not ‘run out.’” This concern is stated as #9 on p.13 of the paper as:
Information provided about areas where TP Deliverability is still available, and how much. The annual TPD Allocation Reports contain useful information about areas where deliverability has run out but relatively little information about where, and much, deliverability remains.
The CAISO’s response in the Paper is that “The 2022 TPD Allocation report includes this information.” However, that report identifies binding constraints and then describes how much is left in those areas (zero in every case), but it does not say anything about areas where deliverability has not run out or how much is left in those areas.
Likewise, Slide 8 of the meeting presentation says that “…the transmission capabilities paper also provides TPD information.” This reference appears to be to the July 2021 Transmission Capability Estimates for use in the CPUC’s Resource Planning Process – White Paper. However, those “transmission capability” estimates do not show how much deliverability is available for a project in the queue. Instead, the Paper states in a footnote:
The transmission capability estimates are over and above the baseline contracted future resource amounts the CPUC transmitted as part of its resource portfolios for use in the CAISO 2020-2021 TPP. The CPUC will need to adjust the estimates to account for additional resources that have been added to the baseline resource list since then. Retirements of Diablo Canyon and OTC generating units are accounted for in the estimates assuming the replacement resources are at the same or similar locations.
In other words, these figures are based on the CPUC portfolios, which have far less capacity than the CAISO interconnection queue, and it’s not even clear which “baseline” amounts are referenced. Thus, they do not provide information on deliverability (location or amount) available to a project in the queue.
- Consolidated interconnection-capacity availability date: LSA suggested that the CAISO explore offering interconnection location data in a “heat map” format similar to MISO, showing areas where the system is constrained. (LSA notes that SPP has adopted a similar data format.) The CAISO offers instead (as “already provided”) a “Map of Interconnection Queue data by California County” that simply shows the queue resources and type by county, with no information about system constraints.
As LSA will explain further in its comments on the 2021 IPE Phase 2 proposal on Study Deposit amounts and refundability, the CAISO is missing completely the strong connection between the lack of readily available information on transmission constraints/deliverability availability and any tendency of large developers to submit “numerous [IRs] requests to see which work out,” instead of “a small number of well-developed, viable projects.”
- COD differentiation within clusters: LSA asked the CAISO to “include in Phase II Studies an examination of the longest lead-time Network Upgrade and determine/state the MWs that could connect without it.” Slide 9 of the Meeting presentation responds by saying:
Phase II studies examine long-lead NUs to determined [sic] if a project can connect without it – This would add a significant burden and time to the already lengthy process and assumptions for the analysis would not be reliable at the time of the Phase II study.
This response is internally inconsistent. If the information were already available in Phase II Studies, why would providing it “add” any burden at all? In fact, while Phase II Studies have an “Operational Deliverability Assessment,” they do not contain any information about how much capacity could interconnect (reach COD) without the longest-lead-time upgrade.
The CAISO also cites “confidentiality” to describe why it cannot provide numerous data requested by stakeholders (e.g., project phasing, suspension, parking, TPD Allocation Group, etc). The CAISO does not cite any specific reason or evidence (e.g., FERC orders or tariff provisions) to support its belief that such information is confidential.
LSA represents many of the largest project developers in the state, and its members are well aware that CAISO provision of the information requested would require them to provide it. Their data transparency requests reflect their judgment that the benefits of receiving this information from others would outweigh the loss of their own confidentiality in providing it for their own projects. (CAISO confidentiality concerns with project phasing information were particularly puzzling to LSA, since such phasing information is already available in public LGIAs.)
LSA appreciates the CAISO’s willingness to discuss this issue further and looks forward to offering additional perspectives in 2021 IPE Phase 2.
INTERCONNECTION QUEUE CLEAN-UP
The CAISO’s comments on cleaning up the queue are vague and puzzling. For example, there are Cluster 7-10 projects that still do not have executed GIAs, though their studies are complete and some of the listed CODs are either past or this year. The Paper states at p.17:
The ISO also understands that some information can become inaccurate, or maybe better stated, unrealistic at times. ISO teams are making efforts internally as well as asking developers to submit a Permissible Technological Advancements (“PTA”) request or Material Modification Assessments (“MMAs”) to provide the ISO/Participating TOs with more realistic milestones and status’ for their projects as soon as they become aware of them.
The ISO does have a number of key mechanisms for requesting that a project maintains its momentum towards commercial operation, however is limited by the legal obligations of the LGIA and Tariff to immediately withdrawal them.
The CAISO states that it uses Commercial Viability Criteria, “PPA requirements, GIA breach/default notices, and milestone/financial/information-sharing “responsibilities” to “help limit a project’s lingering.” While these “responsibilities” are not defined, surely a project in the queue for many years without even executing a GIA (or requesting that a GIA be filed unexecuted) would merit a “breach/default” notice for missing milestone, financial, and information-sharing “responsibilities,” by any definition. The existing CAISO tools certainly seem to allow such action long ago, under the current rules. (The 2021 IPE proposals cited would apply only going forward and so would not seem to help here.)