Of all of the concepts and proposals presented in the Discussion Document and in working groups, what concepts or proposals do you think will be most meaningful in addressing the problem statements?
1) Interconnection request intake, 2) Queue management
New Leaf Energy, Inc. (“NLE”) appreciates the CAISO’s leadership in the time-intensive but valuable working group process, including the opportunity it has afforded stakeholders to present their own proposals. NLE thanks the CAISO again for the opportunity to present its proposals at the July 11, 2023 working group meeting. Below we offer comments regarding our Local Resource Adequacy (“RA”) proposals and a number of stakeholders’ proposals that address the interconnection request intake and queue management problem statements.
The first section of the response to Question 1 covers NLE’s proposals that could address both problem statements. The proposals focus on three main concepts: (1) prioritizing projects sited in Local Capacity Areas (“LCAs”) within the proposed scoring criteria to select projects to study, (2) prioritizing these projects later within the transmission planning deliverability (“TPD”) allocation process, and (3) prioritizing projects with low distribution factors (“DFAX”) ratings (i.e., low impacts on transmission constraints). As explained further below, the Local RA proposals would recognize the combined benefits provided by such resources – enhancing reliability within LCAs and for the system overall. Additionally, the third concept – suggested by the CAISO in the Discussion Paper1 – would maximize benefits from existing and approved transmission by increasing the resulting deliverability awards.
NLE is heartened by the positive response to its proposals, which have garnered support from load-serving entities, renewable energy developers, energy storage developers, and independent power producers. NLE has been actively seeking feedback from diverse stakeholders and welcomes continued engagement.
The second section of the response to Question 1 below covers NLE’s support for other stakeholder proposals to address the interconnection request intake problem statement, and the third section covers NLE’s support for other stakeholder proposals to address the queue management problem statement.
I. NLE’s Proposals to Prioritize Resources Providing Local RA
A. Creation of a Scoring Criterion for Resources Providing Local RA
NLE agrees with many stakeholders that a scoring rubric to prioritize which projects to study will likely be necessary, and NLE proposes that significant points be allotted to projects located in LCAs within that process. This proposal fits well within the CAISO’s proposals (e.g., Concept 1 in the Discussion Paper).
For the yet-to-be-developed scoring rubric, NLE believes it is premature to suggest a specific number of points as the CAISO and stakeholders must consider how the adopted number relates to the total points available and the points available for other project attributes. However, NLE suggests that it should be a significant component of the rubric (e.g., similar to the 5 points of a possible 10, as discussed below in the context of TPD allocation).
B. Prioritizing Resources that Provide Local RA within the TPD Allocation Process
To date, NLE has presented its proposals in concept only. Stakeholders have inquired about the specific number of points that NLE proposes should be awarded to projects sited in LCAs. NLE offers the following proposal specifics for further discussion and refinement, while reiterating that these details are less important at this point in the stakeholder process than continued consideration of the proposal itself. NLE seeks confirmation that the CAISO and stakeholders endorse this concept. Future discussions are needed to further scrutinize the details.
1. Proposed Points for Resources Sited in LCAs within the TPD Allocation Process
The existing scoring rubric for the TPD allocation process contains four categories of commercial readiness criteria: Permitting, Power Purchase Agreement Status for Group A only, Shortlist Status for Group B only, and Land Acquisition. Within each category, the rubric allots a minimum of 0 points (i.e., the minimum requirement to be considered for a given TPD allocation group) and a maximum of 10 points, as shown in the table below.2
NLE’s proposal would add a new column to this scoring rubric, in which a project that the CAISO verifies is sited in an LCA receives 5 points. This would achieve the appropriate balance of giving Local RA projects a meaningful boost in instances where there is less TPD available than megawatts (“MWs”) in a given TPD allocation group, while ensuring that the development maturity criteria that the CAISO is concerned about in problem statements 1 and 2 continue to have the highest value. NLE reiterates that the specific point value proposed is a starting point for further discussion.
2. Justification for the Proposal to Prioritize Resources that Provide Local RA within the TPD Allocation Process
Prioritizing Local RA resources in the TPD allocation process would address the need for greater efficacy in the volume and location of interconnection requests (“IRs”) the CAISO studies.3 Giving points to resources in LCAs would help to meet state policy goals, as the retirement of thermal generation resources – many of which are serving as Local RA resources – is critical to meeting the state’s greenhouse gas reduction goals.4 Retiring these resources while maintaining reliability in LCAs is only possible if new clean Local RA resources are commercially available. Moreover, this proposal would meet reliability needs by increasing the potential pool of commercially viable resources located in LCAs, which are inherently more vulnerable during reliability events when System RA resources cannot always be counted on to serve load in LCAs. The CAISO has already adopted such scoring criteria for use in the TPD allocation process;5 a project’s Local RA attributes would be another strategic criterion to add to the existing scoring rubric for use when there are more projects in a given TPD allocation group than TPD available to award.
3. Addressing Questions Raised by the CAISO and Stakeholders about Prioritizing Resources that Provide Local RA within the TPD Allocation Process
a. Consideration of the CAISO’s Preference for Only Allocating TPD to Projects with PPAs
At the August 1, 2023 stakeholder meeting, the CAISO expressed its preference to award TPD to the first projects with power purchase agreements (“PPAs”).6 NLE interprets this to mean that the TPD allocation groups would be eliminated, effectively creating a minimum criterion for TPD eligibility – that of presenting a qualifying PPA. Additional details and consideration by the CAISO and stakeholders is necessary to more fully evaluate this proposal.
If the CAISO were to adopt a requirement for projects to have a PPA in order to apply for TPD, it would fundamentally remake the timing and nature of the LSEs’ procurement processes. It is not hard to imagine that more MWs of PPAs may request TPD than there are MWs of TPD available – especially since parties will have to contract before knowing if they have secured the most important component of their contract (i.e., the deliverability that the resource’s participation in the RA program is contingent on). As such, the scoring rubric would still be necessary, and NLE’s proposed priority for Local RA resources could then be applied if there are more MWs of PPAs requesting TPD than there are MWs of TPD available.
b. Consideration of Local Capacity Area Deficiencies
Stakeholders have acknowledged that LCAs are not all similarly situated in terms of capacity. While some have sufficient resources, others are more resource-deficient. According to the most recent Local Capacity Technical Report, the amount of Net Qualifying Capacity (“NQC”) equals or exceeds the need in nine of the ten LCAs – all except Stockton – until 2032. By that year, the Greater Bay Area will also be deficient.7 This analysis might suggest that there is only a need to prioritize commercialization of Local RA resources in the Stockton LCA and the Greater Bay Area LCA.
However, such a view misses the broader point: that a great proportion of the Local RA capacity available statewide is currently thermal generation that will have to retire in the years ahead – beyond the known retirements that are incorporated into today’s studies – if the state is to meet its greenhouse gas reduction goals. Just because an LCA has sufficient thermal generation does not mean that there is no need for new resources in those LCAs in the medium and long term; in fact, quite the opposite is true.
In order for existing thermal generators to retire while maintaining reliability, either new Local RA resources must come online or new investments must be made in transmission. With so many transmission investments needed in the years ahead for other policy- and economic-driven reasons, NLE considers that supporting the commercialization of new Local RA resources may be a better option. For new clean Local RA resources to come online, they must get the deliverability that allows them to qualify for the RA program. Only then can they compete with the incumbent generators – which, in the meantime, will reduce their market power and reduce ratepayer costs – and eventually supplant them.
Finally, the proliferation of load-serving entities (“LSEs”) seeking waivers from their Local RA procurement obligations shows that this need is very real across the LCAs, even if there is not a documented deficiency.8 Therefore, NLE recommends that points be awarded in the TPD allocation process – and as a criterion to prioritize which projects to study – for any project sited in an LCA, regardless of whether that LCA appears resource-deficient within today’s analyses.
c. Consideration of Recent Procurement Orders
Stakeholders have noted that the many recent procurement orders from the California Public Utility Commission (“CPUC”),9 totaling 15,500 MWs, have been for specific quantities of NQC. They have not specified that Local RA specifically be procured. This might be viewed to suggest that there is not a need to procure new Local RA resources. However, prioritizing Local RA resources in the TPD allocation process would not in any way limit the volume of NQC available to the LSEs pursuant to their procurement orders. Under the current methodology, all RA resources – whether System or Local – must be deliverable to the aggregate of load. As such, any Local RA resource can bid as System RA – though of course the reverse is not the case. As such, prioritizing Local RA in the TPD allocation process would not limit the amount of NQC that could bid into any LSE solicitation pursuant to the procurement orders, it would just increase the volume of resources with Local RA attributes that are doing so.
d. Consideration of Ability to Charge
Stakeholders have questioned whether there is sufficient energy to charge storage resources proposed within LCAs. However, the CAISO has robust processes for ensuring reliability via the Transmission Planning Process (“TPP”). If energy adequacy for storage charging in LCAs becomes a more pressing issue in the near term, which does not seem likely, the TPP and other forums could modify or tweak the approach. For example, the CAISO, the CPUC, and stakeholders could address the issue through the CPUC’s portfolio development and busbar mapping process and in the Local Capacity Technical Study process, when approving transmission to accommodate the CPUC’s portfolios and busbar mapping. With the range of critical issues the CAISO must address on a tight timeline in the IPE initiative, this is not the proper venue to consider this potential issue.
C. Prioritizing Resources with Low DFAX Ratings within the TPD Allocation Process
NLE continues to support the CAISO’s proposal to utilize DFAX in the TPD allocation process. This proposal would provide a boost to projects that have the least impact on grid congestion (i.e., the lowest DFAX scores) and, therefore, allow larger MW quantities of TPD to be awarded on the same transmission infrastructure.10 Doing so would allow the CAISO to prioritize the projects that do the least harm on the system from a reliability perspective, increase the amount of resources that can participate in the RA program without transmission system upgrades, and maximize the RA benefit from newly approved upgrades.
Similar to the proposed points for resources sited in LCAs, NLE offers the following details as a starting point for further discussion and refinement. Continued consideration of the concept is more important at this stage in the stakeholder initiative than the specific points discussed below. NLE once again seeks confirmation that this concept belongs within the IPE and offers these proposed specific point values for consideration in subsequent discussions.
As with our Local RA proposal concerning TPD allocation, NLE suggests adding a new column to the scoring rubric from the Business Practice Manual (“BPM”) for Generator Interconnection and Deliverability Allocation Procedures, Section 188.8.131.52.2, shown above. NLE proposes that the CAISO rank projects in each area – based on a project’s combined DFAX ratings – and then award points to the lowest ranking projects. NLE recommends that projects in the top quarter ranking receive 5 points; projects ranking in the second quarter (i.e., 25-50 percent) receive 3 points; projects ranking in the third quarter (i.e., 50-75 percent) receive 1 point; and all others receive 0 points.
Alternatively, the CAISO could consider awarding points based on the average of a project’s DFAX ratings rather than its relative DFAX ranking. Under this approach, projects with the lowest average DFAX rating of 0-5 percent would receive 5 points; those with an average DFAX rating of 5-10 percent would receive 4 points; those with an average DFAX rating of 10-15 percent would receive 3 points; those with an average DFAX rating of 15-20 percent would receive 2 points; those with an average DFAX rating of 20-25 percent would receive 1 point; and all others would receive 0 points.
Additionally, the data needed to support the application of this framework could be included in the CAISO’s proposal to publish substantially more information prior to the submission of IRs – supported by AES Clean Energy,11 Middle River Power,12 and GridStor.13 NLE agrees this could be extremely useful to guide project development at the most high-value locations and proposes that such a report could include the DFAX rating for each point of interconnection (“POI”) as it relates to known, binding constraints within the CAISO’s target zones.
D. Updating the BPM to Implement NLE’s Proposed Modifications to the TPD Allocation Process Could Be Done in Q1 2024
It is important for the CAISO to move quickly to adopt proposals with a positive impact that have a pathway for rapid implementation, while continuing to consider more complex related concepts that require more time to develop, refine, and implement – in this and other stakeholder initiatives.
The CAISO Tariff Appendix DD Section 184.108.40.206 lays out the project attributes that Interconnection Customers must attest to in their deliverability affidavits, including permitting status, project financing status, and land acquisition status.14 The BPM for Generator Interconnection and Deliverability Allocation Procedures Section 220.127.116.11.2 expounds upon the scoring methodology in greater detail.15
The CAISO could consider implementing NLE’s proposals to incorporate new criteria within the TPD allocation scoring rubric through an update of the BPM, rather than waiting to modify the tariff. The CAISO would be the entity to make the determination as to whether a given project was sited in an LCA or not and would be the entity to determine the project’s DFAX rating. This would require no changes to the IC’s affidavit and, as such, it may be possible for the CAISO to implement these changes to the TPD allocation process without altering the tariff.
With the current track of the IPE initiative proposed to conclude in February 2024, the CAISO could expedite the short-term benefits of NLE’s proposals by ensuring that the BPM modifications were implemented quickly, before the TPD process results are posted on May 31, 2024, as adopted in Track 1 of this initiative.16 Given the uncertainty surrounding the timeline for Cluster 15 and beyond, the Spring 2024 TPD allocation process may be the last one with a significant amount of new generation – namely, Cluster 14 projects that have recently received their Phase II study results – for quite a while. Indeed, with Cluster 14 projects able to enter the Spring 2024 TPD allocation process, it is possible that some of these projects will be able to meet the Mid-Term Reliability (“MTR”) procurement timelines. It will benefit offtakers, and ultimately ratepayers, to have a larger pool of projects participating in these solicitations.
II. NLE’s Support for Proposals to Address Problem Statement 1 Regarding Interconnection Request Intake
NLE supports several proposals to address the first problem statement aimed at reducing the number of IRs the CAISO receives. First, NLE supports the CAISO’s creation of more stringent eligibility requirements in order to prevent overly speculative projects from entering the queue. NLE proposes that the CAISO align its queue entry requirements with other ISOs and require Site Control without an in lieu of deposit option. At minimum, the CAISO should require 90 percent Site Control, which would provide some flexibility for project-specific issues.17 Regardless of the adopted site control requirement, the CAISO should not provide an in lieu of deposit option, which would allow overly speculative projects to enter the queue. Sufficient progress on land acquisition should be the floor for the CAISO to consider a project viable and to allow it to enter the queue.
To further reduce the number of IRs received, NLE supports proposals by AES Clean Energy and Avantus urging the CAISO to publish data that would assist developers in evaluating whether projects are viable. We applaud the CAISO’s presentation at the August 1, 2023 stakeholder workshop where the CAISO proposed to increase data transparency by providing: zonal information, transmission constraints within zones, allocated deliverability within zones, public queue data, and a heat map. The CAISO should also publish data showing what POIs are located in LCAs and on each POI’s DFAX as it relates to known, binding constraints within the target zones. If the CAISO has concerns with making any of this grid information public, it can use the market participant portal to host the data.
Finally, NLE supports proposals by GridStor, LSA, Middle River, and NextEra for the interconnection process to utilize advanced technology and automation. This represents a significant opportunity to reduce staff resources during interconnection request intake process – one of the CAISO’s main objectives in this initiative.
III. NLE’s Support for Proposals to Address Problem Statement 2 Regarding Queue Management
NLE supports several proposals to address the second problem statement concerning queue management. First, NLE supports the development of scoring criteria to rank projects and determine which ones the CAISO will study. To clarify, NLE urges the CAISO against applying the scoring criteria during the interconnection request intake stage. Instead, an increased Site Control requirement, discussed above, should be the only limitation placed on queue entry.
NLE believes AES Clean Energy’s proposal is a good starting point to develop the scoring criteria, but stakeholders should work together in a subgroup of the IPE initiative to finalize the scoring criteria and the points awarded for each criterion. NLE supports GridStor’s proposal to prioritize resources sited in locations with local capacity shortfalls, having faster construction timelines, and exhibiting other characteristics needed to meet state needs or goals. Specific criteria that NLE supports at this time include: (1) whether a project is sited in an LCA, as discussed above, (2) whether a project is sited in an energy community or Disadvantaged Community (“DAC”), and (3) permitting – with projects that have progressed farther in the permitting process receiving more points, as is currently done currently in the CAISO’s TPD allocation groups.
Additionally, NLE supports LSA’s proposal to supplement the initial project study list/ranking with an appeals process to consider other desirable project attributes. Both LSEs and developers should have the opportunity to submit an appeal to argue why the CAISO should include a specific project in the study list. This would provide flexibility for the CAISO to consider studying projects that may not rank highly under the scoring criteria but are nevertheless valuable projects to study.
Regarding proposals to reform the study process, NLE is agnostic regarding whether the CAISO adopts its single-phase study approach or other stakeholders’ proposals for a multi-phase study that utilizes a generic study at some point in the process. Regardless of which approach the CAISO moves forward with, NLE urges the CAISO to adopt the following recommendations. First, the CAISO should postpone validating individual projects until after it determines which projects to study – in order to reduce staff time spent on this onerous function. Second, NLE supports providing interconnection facilities cost estimates during the Scoping Meeting to encourage less viable projects to exit the queue early in the process. Finally, NLE urges the CAISO to refund deposits if upgrade costs escalate significantly above initial estimates. Eliminating Phase 1 or adopting a generic Phase 1 study process will result in less certain interconnection cost estimates. Recognizing that cost estimates will have a larger range and be less reliable under either of the new study approaches, this proposal would encourage developers to withdraw any projects that they find are no longer viable.
Next, NLE supports LSA’s and Rev Renewables’ proposals to reform Option B to make it a more fair and viable alternative study pathway. Specifically, the CAISO should allow Option A projects that are not awarded deliverability to elect Option B, fund area deliverability network upgrades (“ADNUs”) themselves or with other projects, and receive a higher TPD allocation priority in the next TPD cycle. The CAISO should also provide projects an opportunity to revert from Option B back to Option A if ADNU costs escalate. Additionally, although the CAISO indicated that Vistra’s proposal to create a network upgrade subscription model is outside of the scope of the IPE initiative at this time, NLE conceptually supports this proposal. Having the CAISO administer the process to crowdfund upgrades would create a more workable Option B framework.
NLE additionally supports the CAISO’s proposal at the August 1, 2023 workshop to create both additional project milestone requirements and a regular process to receive and evaluate milestone updates – also supported by Vistra and Gridwell. NLE suggests that one new project milestone requirement could be requiring 50 percent gen-tie site control following the first, or perhaps only, study phase – with an in lieu deposit option that would fund upgrade costs.
Regarding Material Modification Assessment (“MMA”) requests, NLE continues to support LSA’s and Gridwell’s proposals to expand the list of changes in the BPM for Generator Management that do not require MMAs (e.g., inverter changes and gen-tie combinations, which the CAISO nearly always approves in its current process). The CAISO should allow developers to enter these changes into the Resource Interconnection Management System (“RIMS”) or, alternatively, create an automated process for accepting these types of modifications. If the CAISO determines that there are issues with certain modifications (e.g., inverter changes), it could reserve the right to require an MMA and later adjust the list of modifications requiring MMAs.
NLE also supports Clearway’s proposal to require a joint meeting with the CAISO, the relevant participating transmission owner (“PTO”), and the developer to address validation issues within 15 calendar days of MMA submission. The proposal would allow these entities’ engineering teams to expeditiously address any validation issues. Further, NLE supports LSA’s and Vistra’s proposals to increase MMA timing certainty by adopting targets for the CAISO’s and PTOs’ initial and subsequent validation reviews. Lastly, NLE supports Clearway’s proposal to allow MMAs to proceed separately from the Limited Operation Study process.
Concerning deliverability, if the CAISO decides to modify the TPD allocation process – as proposed during the August 1, 2023 workshop – to award deliverability to projects as they receive PPAs, a revised process with a standard cadence (e.g., quarterly) should utilize a TPD scoring rubric similar to the current one in order to prioritize projects that have received PPAs. If more projects have PPAs during the quarterly TPD allocation process than there is deliverability to award, projects with more points (e.g., those in LCAs under NLE’s proposal described above) would receive deliverability awards over those with fewer points.
Finally, NLE strongly supports LSA’s proposal for a one-time queue withdrawal opportunity in order to allow projects to exit the queue voluntarily and receive refunds for all posted financial security. NLE is sympathetic to arguments that this could lead to increased costs in the short term if projects currently responsible for approved upgrades exit the queue, but the reduced need for future developer/ratepayer funding for unneeded upgrades would outweigh the costs of any refunds. If the CAISO decides against providing a one-time withdrawal opportunity, it would miss the single largest opportunity to relieve queue congestion and ensure that only the most viable projects remain in the queue.
1 2023 Interconnection Process Enhancements Track 2 Discussion Paper (May 31, 2023), p. 12-13, available at: http://www.caiso.com/InitiativeDocuments/Discussion-Paper-Interconnection-Process-Enhancements-2023-Track%202-May312023.pdf.
2 CAISO Business Practice Manual: Generator Interconnection and Deliverability Allocation Procedures v33 (April 26, 2023), Section 18.104.22.168.2 (p. 107-109), available at: https://bpmcm.caiso.com/Pages/BPMDetails.aspx?BPM=Generator%20Interconnection%20and%20Deliverability%20Allocation%20Procedures.
3 2023 Interconnection Process Enhancements Summary of June 20 & 21 Track 2 Working Group Meeting Revised Principles and Problem Statements 1 and 2 (June 23, 2023), p. 4, available at: http://www.caiso.com/InitiativeDocuments/Revised-Principles-and-Problem-Statements-Interconnection-Process-Enhancements-2023-Track%202-Jun%2020-212023.pdf.
4 SB 100 (de León, 2018) increases the RPS to 60 percent by 2030 and requires all the state's electricity to come from carbon-free resources by 2045. Available at: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100.
5 CAISO Business Practice Manual: Generator Interconnection and Deliverability Allocation Procedures v33 (April 26, 2023), Section 22.214.171.124.2 (p. 107-109), available at: https://bpmcm.caiso.com/Pages/BPMDetails.aspx?BPM=Generator%20Interconnection%20and%20Deliverability%20Allocation%20Procedures.
6 2023 Interconnection Process Enhancements Track 2 Working Group (August 1, 2023), p. 21, available at: http://www.caiso.com/InitiativeDocuments/Presentation-Interconnection-Process-Enhancements-Track-2-Aug12023.pdf.
7 2022-2023 Transmission Plan (Board Approved), Appendix J, p. J-3 to J-4, available at: http://www.caiso.com/InitiativeDocuments/Appendix-J-Board-Approved-2022-2023-Transmission-Plan.pdf.
8 CPUC Local Waivers Issued (2018-2022) (accessed July 31, 2023), available at: https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-power-procurement/resource-adequacy-homepage/local-waviers-issued.
9 CPUC Decision 21-06-035 (June 30, 2021) ordered the procurement of 11,500 MW of new NQC to come online in 2023-2026 (see Ordering Paragraph 1, available at: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M389/K603/389603637.PDF). CPUC Decision 23-02-040 (February 28, 2023) ordered an additional 4,000 MW NQC of new procurement in 2026 and 2027 (see Ordering Paragraph 2, available at: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M502/K956/502956567.PDF).
10 2023 Interconnection Process Enhancements Track 2 Discussion Paper (May 31, 2023), p. 12-13, available at: http://www.caiso.com/InitiativeDocuments/Discussion-Paper-Interconnection-Process-Enhancements-2023-Track%202-May312023.pdf.
11 2023 Interconnection Process Enhancements Track 2 Working Group, (July 11, 2023), AES Interconnection Intake Proposal, p. 41-42, available at: http://www.caiso.com/InitiativeDocuments/Presentation-Interconnection-Process-Enhancements-2023-Track%202-Working-Group-Jul112023.pdf.
12 2023 Interconnection Process Enhancements Track 2 Working Group, (July 11, 2023), Middle River Power CAISO IPE 2023 Phase 2 Proposals, p. 112-113, available at: http://www.caiso.com/InitiativeDocuments/Presentation-Interconnection-Process-Enhancements-2023-Track%202-Working-Group-Jul112023.pdf.
13 2023 Interconnection Process Enhancements Track 2 Working Group, (July 11, 2023), GridStor CAISO IPE Track 2 Working Group, p. 136, available at: http://www.caiso.com/InitiativeDocuments/Presentation-Interconnection-Process-Enhancements-2023-Track%202-Working-Group-Jul112023.pdf.
14 CAISO Tariff, Appendix DD, Section 126.96.36.199 (p. 65-66), available at: http://www.caiso.com/Documents/AppendixDD-GeneratorInterconnectionDeliverabilityAllocationProcedures-asof-Mar28-2023.pdf.
15 CAISO Business Practice Manual: Generator Interconnection and Deliverability Allocation Procedures v33 (April 26, 2023), Section 188.8.131.52.2 (p. 107-109), available at: https://bpmcm.caiso.com/Pages/BPMDetails.aspx?BPM=Generator%20Interconnection%20and%20Deliverability%20Allocation%20Procedures.
16 CAISO Tariff, Appendix DD, Section 16.1(h) (proposed revisions submitted to FERC on June 2, 2023), available at: http://www.caiso.com/Documents/Jun2-2023-TariffAmendment-InterconnectionProcessEnhancements2023-Track1-ER23-2058.pdf.
17 FERC Order 2023, Improvements to Generator Interconnection Procedures and Agreements, requires 90 percent Site Control, eliminates deposits in lieu, and requires 100 percent Site Control at the facilities study and Large Generator Interconnection Agreement stage. FERC Order 2023, paragraphs 594 and 600, Docket No. RM22-14-000 (July 28, 2023), available at: https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20230728-3060.