Comments on Track 3A revised straw proposal and 3B straw proposal

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

ACP-California appreciates the opportunity to comment on CAISO’s Track 3A proposal in the IPE 2023 initiative. While we appreciate the challenges CAISO has faced in managing its interconnection queue and in allocating TPD, and support modifications to make the processes more manageable for all, ACP-California is strongly opposed to the current direction of the Track 3A proposal. The current proposal prioritizes providing CAISO certainty on project commercial viability over an efficient development process for resource developers and offtakers alike. If implemented, this proposal would require too much commercial activity to be performed too early in the development process and is likely to drastically increase developer risk (including, for instance, forcing developers to determine PPA prices before they have cost certainty or a clear path to deliverability) which will increase risk premiums and drive up the cost of resource development in the state, ultimately costing consumers. ACP-California urges CAISO to consider this reality, and the negative impacts this proposal would likely have on future energy prices in the state, and to adjust course on the Track 3A proposal.

ACP-California also urges CAISO to prioritize Track 3B (as discussed more in response to Question 2), given the urgent need to address Cluster 14 intra-cluster prioritization and interim-deliverability. Prioritizing Track 3B and allowing more time for Track 3A would also allow CAISO and stakeholders to have the benefit of greater certainty on the Track 2 IPE proposals and whether they will be implemented by FERC. If the Track 2 proposals are accepted by FERC, CAISO may not need to make such significant changes to the TPD allocation process, given that the volume of future queues (including Cluster 15) will be much more manageable and limited.

While we urge CAISO to pause the Track 3A proposal and revisit it at a later date, ACP-California also offers the following responses to specific aspects of the Track 3A Revised Straw Proposal:

• The proposed discontinuation of Group D is highly concerning and an alternative path to deliverability without a PPA or short-list needs to be maintained
  • ACP-California proposes renaming Group D to “Conditional Deliverability” group and allowing all Conditional Deliverability to be considered as remaining available when determining the available deliverability in TPD zones for future clusters
  • CAISO also needs to further consider the timelines it is seeking to impose on resources in light of the current transmission lead times (which are often 10+ years)
• Allowing Energy Only resources to only secure deliverability through allocation group C (commercial operation) requires modification and the proposal to only allow storage additions through Commercial Operation will have a negative impact on projects that would otherwise be efficient and beneficial additions to the grid
• Long lead-time resources require additional consideration and assurances that timelines can actually be workable
• The revised TPD scoring criteria require modification
  • Rather than provide additional points to expansion of a generating facility, CAISO should provide extra points for earlier CODs to provide equal opportunities to all project types
  • Projects without a regulatorily approved PPA, but with an executed PPA, should still receive points; to avoid undue preference to LSE projects, ACP-California recommends these projects receive 3 points (the same as an LSE constructing a project to serve its own load)
• Support CAISO’s ability to reserve capacity for resources that meet specific CPUC portfolio requirements (including AB 1373 resources) but transparency on when and where this is happening is imperative

Track 3B Should Be Prioritized and Track 3A Should Await Certainty from FERC on Track 2 Implementation

ACP-California reiterates concerns that the current proposal for Track 3A is highly problematic and, in its current form, likely to be unworkable for developers and for LSEs and other offtakers. Additionally, ACP-California urges CAISO to focus immediate efforts on Track 3B, which addresses Cluster 14 intra-cluster prioritization and interim deliverability. Developing workable solutions for these Cluster 14 issues should take precedence over modifications to the TPD allocation process, which have a longer runway.

We recommend that CAISO revisit the Track 3A proposal once FERC has issued an Order on the forthcoming IPE Track 2 tariff filing for queue intake (which will apply to Cluster 15). Having the benefit of more certainty on IPE Track 2 will be crucial to developing an appropriately targeted solution for Track 3A. If the Track 2 proposals are accepted by FERC, then as a result, going forward CAISO will have a much smaller volume of resources in the queue to allocate TPD to and may not need to make such significant modifications. The currently proposed modifications appear aimed at the larger queue volumes that have been observed historically and are not warranted for a very limited queue size, which will result if the Track 2 proposal is accepted by FERC. Having certainty on the future queue volumes that CAISO can expect will serve to appropriately target the Track 3A proposal.

Track 3A Should More Explicitly Consider Timelines of Various Requirements Especially in Light of Long Development Horizons for the Transmission Upgrades

ACP-California requests that CAISO explicitly consider the timelines for resource development, the underlying commercial implications of this proposal and track 2, along with the current timelines for achievable operations given the long lead-times for transmission upgrades that the industry is facing. Only with this type of consideration can successful solutions be developed.

It is important to understand that, in general, even if authority is provided for LSEs to enter into PPAs further into the future (as CAISO has advocated for), there are still barriers to contracting more than five years ahead. Generally, PPA contracting occurs for resources that can achieve commercial operation within five years or less. This timeline isn’t just a factor of regulatory impediments, it is also tied to financing requirements, underlying cost/component uncertainty and more. Contracts signed for resources that are seven or even ten years out from their commercial operation date may require variable or escalating prices, given the uncertainty in capital and financing costs that far in the future. Additionally, the need to secure financing for projects this far in the future would also present problems and likely increase underlying resource costs. Thus, incentivizing earlier contracting through changes to the interconnection and TPD allocation process may solve some of the problems CAISO has observed but create additional, more problematic issues, across the industry. Thus, CAISO proposing to require projects to have a PPA or be on a short list to secure TPD presents a timing problem when the resources require transmission upgrades that are expected to take around ten years to complete and are required for a project to reach commercial operation with FCDS.[1]

ACP-California urges CAISO to consider these development timelines in conjunction with the TPD allocation group requirements, the number of chances projects are provided to secure TPD and other factors to develop a comprehensive and workable proposal that doesn’t just seek to “frontload” all commercial contracting. Although the central procurement program (AB 1373) could accommodate some of these requirements for certain resources, it is not clear how timelines of procurement and long lead-time interconnection requests will align to facilitate both solicitation responses and progress through the interconnection queue. We request a working group meeting that reviews the various timelines and requirements that are part of Track 2 (including the updated Commercial Viability Criteria) and what is being proposed for Track 3A. Doing this type of legwork may help CAISO and the industry land on solutions that are implementable and are less likely to present fundamental challenges to the resource development and contracting processes.

Track 3A Proposal #2: Discontinuation of Allocation Group D Requires Revision to Provide a Path to Deliverability and CAISO Must Consider Development Timelines

ACP-California is highly concerned that the current proposal to eliminate Group D creates an unachievable commercial bar for remaining TPD groups (PPA group, Shortlist group and Commercial Operation group) and will not be feasible for developers or LSEs/other offtakers to implement. Requiring projects to be commercially developed enough to have a full PPA or be on a shortlist prior to having a line of sight to deliverability and, in some cases, prior to having certainty on interconnection costs (which impact PPA pricing and shortlist selection) puts the commercial “cart” before the horse. Requiring this type of commercial activity to take place too early will increase the risks developers face in providing pricing to offtakers and will, therefore, increase risk premiums and, in turn, resource pricing. And it is especially problematic to implement during a time when the industry is facing unprecedented challenges, including very long transmission delays.  

To address this and continue to provide a pathway to deliverability prior to a project securing a shortlist position or a PPA, ACP-California recommends renaming Group D to “Conditional Deliverability” group. The Conditional Deliverability group could even be subject to certain development requirements and a scoring process for allocations. But most importantly, Conditional Deliverability allocated would not reduce the calculation of deliverability available for future clusters. Thus, projects allocated Conditional Deliverability (in Cluster 15, for example) would not count against the deliverability available when calculating the 150% limit in TPD zones for Cluster 16. This would then allow Cluster 15 projects receiving Conditional Deliverability to work towards a shortlist or PPA to “secure” their deliverability, while providing Cluster 16 projects an opportunity to compete for it and, if they are more commercially developed, secure the deliverability themselves.

While ACP-California recognizes that development of additional scoring criteria may be challenging, we recommend considering new scoring criteria for Conditional Deliverability allocations (which are not the same as the IPE Track 2 scoring criteria). Alternatively, technical readiness requirements or minimum bars could be developed through the stakeholder process.

If, despite opposition to this proposal, CAISO continues forward with the discontinuation of Group D it is imperative that projects currently in Group D not be negatively impacted by this proposal and be afforded additional time to proceed towards a shortlist or PPA before having their deliverability undermined by this proposal. Projects that already have deliverability allocation in Group D and that are slated to be signing LGIAs in October need a minimum of another year for the transition. If they are not provided additional time, ACP-California is concerned they could lose their current deliverability on February 1, 2025, which is an incredibly short amount of time for these resources to secure a short list or PPA to retain their deliverability.

Track 3A Proposal #4: CAISO Should Consider Providing Four or Five Opportunities Given Long Timelines for Transmission Build Out

CAISO proposes to eliminate parking in the TPD process and, instead, provide projects with three opportunities to secure a TPD allocation. ACP-California urges CAISO to consider additional opportunities (e.g., four or five) to secure a TPD allocation. This might help address the timing concerns that we’ve previously highlighted with transmission lead-times of ten years or more and issues that are created by contracting for resources more than five years in the future. Additionally, ACP-California urges CAISO to consider the ability for more opportunities in light of the proposed modifications to the Commercial Viability Criteria (CVC) which will serve as a tool to push stagnating projects out of the queue. With the new CVC requirements in place, providing additional opportunities for TPD could help provide an opportunity for projects that are advancing but haven’t secured a TPD allocation to secure one. This may be preferable to kicking these advancing resources out of the queue and “starting over” with new resources in a later cluster.

We also urge CAISO to provide Cluster 14 with a full set of opportunities under the new process, should it be implemented. For instance, if CAISO provides three opportunities for TPD, Cluster 14 should be provided three opportunities in the new process (and should not have prior chances counted against them).

Track 3A Proposal #6: Treatment of Energy Only Resources Requires More Development

CAISO proposes that Energy Only projects can only secure TPD through the Commercial Operation group, regardless of how they became Energy Only. ACP-California understands that CAISO is seeking to ensure these projects don’t “clog up” the queue. However, we urge CAISO to consider instances where an Energy Only project is short-listed or receives a PPA. In this instance, would CAISO prefer to move that project out of the queue (since it can only secure TPD when it goes online, which is not commercially viable) and start over with projects in earlier stages of development? This outcome does not seem efficient. Thus, we urge CAISO to consider retaining a path for Energy Only projects to secure deliverability under the new rules.

One option to consider would be to limit the CAISO’s proposed restriction on Energy Only resources to securing deliverability through the Commercial Operation group to only those in areas with no planned Area Deliverability Network Upgrades (and, thus, no reasonable hopes of securing new TPD). Additionally, we’d urge CAISO to consider different application of this rule for Cluster 14 and 15 and suggest this delineation should be subject to additional stakeholder discussions.

Track 3A Proposal #6.2: Proposal to Require Commercial Operation for Storage Additions will Halt this Type of Resource Development, Reducing otherwise Efficient Grid Additions

CAISO has proposed that storage additions can only be added through the Commercial Operation group. This would require storage additions to come online before securing a TPD allocation. This proposal will likely stop the addition of storage resources to existing facilities in their tracks, as it is not commercially viable, and presents too much risk, to develop an energy storage addition and have it reach commercial operation before having a path to TPD.

ACP-California urges CAISO to carefully consider if this is really a policy change it wants to pursue. Generally, energy storage additions to existing facilities are highly beneficial to the grid and allow additional capacity to come online in an area where there is already transmission capacity. These additions offer significant benefits to the grid under the current rules. And CAISO should seriously consider whether it wants to create major disincentives, and potentially unachievable roadblocks, for these types of resource additions.

Track 3A Proposal #6.2: Long Lead-Time Resources

As a threshold matter, the timelines contemplated for long lead-time resources development under the CAISO’s proposed rules require additional consideration and examples. The current proposal appears to suggest that long lead-time resources need to be accommodated through LRAs allowing for procurement of projects further out in time and that long lead-time should simply wait to submit Interconnection Requests until a later date when they can meet Commercial Viability Criteria and contracting requirements. ACP-California is not convinced this is the appropriate solution for long lead-time resources or for other resources that have CODs far into the future due to the long lead-time for transmission development. As articulated below, we agree the CAISO has existing authority to reserve certain transmission resources for specific resources linked to the transmission plan process, but even in this instance developers require greater understanding and confidence in when and where deliverability is being reserved (and how it will be reserved in the future) before simply deciding to wait to enter the queue. We reiterate the previous request for one more working group meetings that reviews the various timelines and requirements placed on projects and a review of the implications for long lead-time resources should be part of that discussion.

Track 3A Proposal #10: TPD Scoring Criteria Should be Modified 

ACP-California recommends two changes to the TPD scoring criteria proposed by CAISO:

• First, the expansion of a generation facility should not be receiving extra points separate from other project types. It seems as though the perceived benefit of an expansion of an existing facility is that it may be able to come online earlier than other types of projects. Thus, we urge CAISO to modify this scoring criteria to instead provide extra points for projects with earlier achievable COD. This will provide a level playing field for all project types while recognizing the benefits from projects that can come online earlier.

• Additionally, it is highly problematic and potentially discriminatory to provide no points to PPAs that are not regularly approved while at the same time providing points to LSE self-developed projects. A project that has secured a PPA (even if not regulatorily approved) has likely done far more development work than a self-build project from an LSE. Thus, CAISO should award all executed PPAs with points under this with at least three points (the same as an LSE would receive for a self-build project).

Track 3A Proposal #11: Deliverability Capacity Can be Reserved but Transparency in use of this Tariff Authority is Imperative

As stated in prior comments, ACP-California agrees with CAISO that it already possesses the tariff-based authority to reserve TPD capacity for resources that meet specific CPUC portfolio requirements (including AB 1373 resources). And ACP-California supports this process to reserve capacity for resources that require such a reservation to ensure alignment between their development timelines and the transmission build-out and interconnection/TPD allocation timelines.

We reiterate our request for CAISO to provide transparency on when it is using this tariff-based authority, where that is occurring on the system and how much capacity is being reserved. Having transparency into where on the system TPD is being reserved is critical for developers to understand in order to best position their other projects for success.

Therefore, CAISO should provide, as part of the TPD reports or in another document, a clear summary of where on the system TPD is being reserved and for which resource types in the CPUC portfolio and how much (MW). This is critical for developers to understand as they seek to site projects in areas where there is available deliverability and will provide appropriate transparency for resources that have capacity reserved as well. CAISO should commit to this level of transparency for the 2024 TPD allocation cycle and all future cycles.

[1] Otherwise for example, a PPA executed in July 2024 with a guaranteed COD of less than five years, assume June 2029, would not achieve deliverability (FCDS) until the assigned ADNUs are in service which are currently expected in 2034. There is little to no value to the offtaker nor the developer to achieve COD without deliverability.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

As previously stated, ACP-California urges CAISO to re-prioritize the tracks in this initiative and focus all immediate efforts on the Track 3B proposal, including intra-cluster prioritization. The proposals in Track 3B, particularly on intra-cluster prioritization, have broad support for proceeding in development. And implementation of this proposal is more time-sensitive than Track 3A, given that the Cluster 14 study process is ongoing, and the result of this proposal could provide faster interconnections for a subset of projects in Cluster 14.

We applaud CAISO for putting forward a process that would allow generators to interconnect up to an amount that would not trigger the need for long lead-time short-circuit mitigation. Using the affidavit process similar to what is currently used for the TPD allocation process seems to be a reasonable approach to this type of intra-cluster prioritization and ACP-California generally supports the CAISO’s proposal on this front and looks forward to additional discussion on this item.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

ACP-California urges CAISO to reconsider including the multi-year Interim Deliverability topic that had previously been contemplated in this initiative. We understand that CAISO feels there is not expected to be a significant amount of longer-term deliverability available, but other developers have come to a different conclusion when assessing specific projects adversely affected by upgrade delays. Developers have also articulated that there are times when capacity is available before upgrades are completed and the current process does not allow projects to secure contractable assurances of being able to access that capacity in the interim. This type of framework is increasingly important for projects waiting for long lead-time upgrades that have recently been approved. The need to find creative solutions is imperative and we urge CAISO to reconsider including multi-year interim deliverability within the scope of track 3.

4. Please provide any additional feedback.

CAISO should prioritize this initiative placing the immediate focus on Track 3B and postponing Track 3A, ideally, until there is more certainty regarding FERC’s approval of the Track 2 IPE policy updates. If FERC approves all of CAISO’s requested Track 2 elements, it is likely that more modest changes to the TPD allocation process can be implemented and provide a process that is more workable for CAISO to administer, given that the volume of the queue will be drastically reduced going forward.

Additionally, ACP-California cautions CAISO that the current proposal for Track 3A is unworkable and is likely to increase development costs, and raise future energy costs for consumers. CAISO’s proposal seeks too much commercial certainty too early in the development process and does not provide LSEs/offtakers or developers with any clear line of sight to deliverability prior to selecting preferred resources and/or signing a PPA. As stated earlier in these comments, if this proposal proceeds without any option for “Conditional Deliverability” or a revised Group D, it will significantly increase the risk associated with project development, which will increase risk premiums and, ultimately, drive up costs. This proposal may create a more manageable process for CAISO, but that comes at the expense of offtakers, developers, and electricity customers. We therefore urge CAISO to rethink this proposal and, if implementation does move forward to, at a minimum, include the modifications proposed in these comments.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

• AES generally supports the revised nomenclature for Groups A-C, but for sake of brevity will continue to use these old terms in our comments below. AES also supports CAISO’s proposal to further differentiate projects that have requested FCDS vs. those that have been allocated vs. those that are operational with FCDS.
• Section 4.1 Acceptance of TPD: AES seeks clarity on the phrase- “Once a project receives its requested TPD allocation, it must accept it or withdraw. It may not decline the allocation to re-seek TPD the following year.” Does this mean that projects must accept partial FCDS or be withdrawn? For example, would a 200 MW storage project granted only 50 MWs of FCDs be obligated to accept this or be withdrawn? If the answer to this question is yes, then AES recommends the CAISO develop some threshold- for example projects would not be obligated to accept less than 75% of their request FCDS.
• Section 5: three allocation cycles before EO conversion: AES opposes the first of three opportunities to seek TPD to begin with the March 15^th deadline during the cluster’s interconnection facility study. The revised TPD allocation groups heavily prioritize projects that have PPAs or are shortlisted. However, without final interconnection facility study costs there is a low probability that projects will be able to execute PPAs without their final cost, cost caps and construction schedule being known. Any PPAs submitted at this point in the process will likely have liberal exit clauses to manage the risk of these costs not being finalized. AES would support this being optional for projects to be able to utilize their first opportunity to seek an allocation at this point, but they should not be required to utilize one of their opportunities and should be allowed to wait until the TPD allocation cycle after the completion of the cluster’s interconnection facility study. If CAISO is concerned with tracking, they could add 1-3 at the end of the FCDSR to reflect how many cycles they have utilized. For example, a project that is on their first cycle could be designated FCDSR1, those on their final cycle could be designated FCDSR3.
• Section 6: Energy Only may only seek TPD through Group C: AES continues to oppose CAISO’s proposal to limit existing Energy Only projects to seek TPD through Group C- now known as the Commercial Operation Group. These changes do not reflect CAISO’s goal to ensure that the most ready projects be allocated TPD first. For example, some Cluster 13 projects were forced to convert to Energy Only projects due to lack of TPD to allocate. Therefore, Energy Only projects in Cluster 14 projects and earlier should be allowed to seek an allocation through Groups A and B, in addition to C, if they are able to meet these other group requirements.
  • Section 6.2: AES also strongly opposes the proposal that storage added through the MMA process can only request TPD once they have achieved COD. This proposal is a marked change from CAISO’s previous policy orientation that was generally favorable to expediting the addition of storage. Storage has already shown itself to be invaluable in managing the grid through extreme heat waves and generally provide more flexibility to the grid. Allowing other generating assets- like wind and solar- to add storage to those site greatly increases the CAISO’s ability to move energy from time of overproduction to times of greatest need, i.e., help fill in the belly of the duck and be able to manage the evening net load ramps. Furthermore, given the high cost of storage, its ability to qualify for RA through FCDS is still determinative of a storage project’s financial viability. Therefore, no reasonable developer will move forward with an energy only storage project at today’s market conditions, and so this change will effectively kill Interconnection customers’ ability to add storage to a project through the MMA process.
    • AES seeks clarity on whether projects would be able to transfer FCDS to storage added through the MMA process, or if this proposal would negate that possibility?
• Section 8: AES opposes the proposal to split the deadlines for projects seeking TPD vs those seeking to retain it. AES believes that most resources should know in advance whether they have met the TPD retention criteria, and therefore they should be able to determine whether they need to submit a retention affidavit or reapply for TPD through a seeking affidavit. Therefore, AES recommends that CAISO modify this proposal to have a single affidavit due date of March 15^th for both seeking and retention affidavits.
• Revisions to the scoring Table 2: AES opposes only LSE IC’s being eligible to receive 3 points if the project is meant to serve load. CAISO should revise this so that if the RA value of the project is sold to a LSE in the PPA, that project should be eligible to receive 3 points. As written, this is unduly discriminatory towards IPPs, and CAISO should prioritize projects that serve load as reflected in the PPA but should not care who the IC is sponsoring the project. AES seeks further clarification on whether this proposal modifies the minimum term lengths of eligible PPAs, and whether non-LSEs must still pay an additional deposit and be committed to sell the RA within a certain timeframe to retain the TPD allocation? AES seeks clarification on how the expansion of a generation facility column would work in practice. Would these points be used to help rank within group A-C projects, similar to how permitting and Table 3 points are utilized in the process? Are PPA’s even able to achieve final regulatory approval if the project does not have FCDS?
• Section 11: Long- lead time resources: AES continues to seek more implementation details on this proposal. How would long-lead time resources be factored into identifying the deliverability zones? How would this proposal to reserve TPD align with the intake scoring criteria that awards points to long-lead time resource? In the next proposal it would be helpful to have some explanation of how long lead-time resources would be treated at every step of the interconnection process, and how the prioritization of these resources would align across all the processes.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

AES generally supports this proposal and could support the same scoring used for TPD allocation, and tie breaking through those that have sold the RA, earliest COD, and lowest Dfax, with further modifications to the scoring criteria as suggested above. AES also encourages the CAISO to consider establishing this process more generically so that any long-lead time upgrade could be evaluated for some projects to come online before those upgrades’ completion. Also, this process should be available for Cluster 15 projects and beyond. Even if not utilized after Cluster 14, it would still be beneficial to have this kind of proposal captured in the tariff/BPMs in case the need should arise in the future.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

 AES strongly opposes this proposal. CAISO should not modify its practice of using the request date to determine interim deliverability rather than TPD allocation date. AES opposes the CAISO move to undermine its best-in-class policy to allow storage to be added through the MMA process to be awarded interim deliverability on the basis of TPD allocation date rather than the original resource’s request date. If CAISO moves forward with this proposal, it should provide more information about the problem it is trying to solve or a more detailed argument about why this change is necessary. TPD is not available every year or in every region, resources should not be penalized because they may have had to wait additional cycles to receive TPD allocation. Prioritizing interim deliverability initially by request date ensures that projects that have been in the queue longer have a chance to go into operations sooner.

4. Please provide any additional feedback.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) Interconnection Process Enhancements Track 3. Track 3 will address the allocation of Transmission Plan Deliverability (TPD). The CAISO’s proposal to remove allocation group D (proposal #2) presents concerns. As CAISO is aware, load serving entities (LSE) typically require projects to have a deliverability allocation prior to executing a contract or putting projects on a shortlist so that they have a full understanding of costs and timelines, and assurance that the projects will count towards their compliance obligations. Removing allocation group D would essentially require a power purchase agreement (PPA), shortlist, or commercial operation to receive a deliverability allocation. This could interfere significantly with well-established procurement practices by shifting procurement risks and costs to LSEs and customer ratepayers without any discernible benefit. Removing allocation group D could result in PPAs or shortlisting with exit clauses, increasing risks for LSEs and developers. The CAISO should instead consider scoring projects for TPD in the same manner it scores interconnection requests under the zonal model. This would ensure projects deemed most ready receive TPD allocations first without disrupting the existing procurement landscape. The CAISO could also revisit removing allocation group D after it has experience with the new zonal approach to interconnection intake to ensure that it does not interfere with procurement practices that may or may not evolve after the implementation of the zonal approach.

The CAISO must amend its proposal to modify the TPD scoring criteria (proposal #10) to ensure the criteria for projects in the PPA group are fair to all types of LSEs. Specifically, the CAISO’s TPD scoring criteria would give 5 points to projects with a “regulatory approved” PPA and 0 points to projects with an executed PPA. During the workshop, the CAISO clarified that a regulatory-approved PPA means a PPA approved by the LSE’s local regulatory authority (LRA). The LRA for community choice aggregators (CCA), investor-owned utilities (IOU), and electric service providers (ESP) is the California Public Utilities Commission (CPUC). However, the CPUC only has the authority to approve IOU PPAs.  CCA PPAs are approved through their internal procedures including, in most circumstances, approval by the governing body. Thus, even though a CCA PPA might be executed and approved by the entity with ultimate approval authority, such PPAs would be ineligible for the 5 extra points. Accordingly, IOU PPAs would have an opportunity to earn an extra 5 points whereas CCA PPAs would not. 

This gives IOU PPAs an unfair advantage over PPAs with other LSEs. The CAISO should modify this criterion from “has regulatory approved PPA” to “has a PPA that has received all State and local approvals needed for the PPA to be executed and become effective.” CCAs have their PPAs approved by their governing body, bodies made up of local elected or appointed officials with open and transparent meetings, or their delegates. Interconnection customers could validate that their PPA has this approval through public documentation, such as CCA governing body meeting minutes, or through attestations from LSEs that the contract has been approved by a delegate through the CCA’s governing body-approved process. This modification would put all CPUC-jurisdictional LSE customers on a level-playing field by ensuring their PPAs are prioritized for TPD consistently.

Finally, CalCCA agrees with the CAISO that it will be necessary to allocate TPD to long-lead time resources such as offshore wind, out-of-state wind, and geothermal that currently have longer project development cycles than other renewables and may not be compatible with the updated process (Proposal 11).  The straw proposal implies that the CAISO is monitoring the outcome of the CPUC’s central procurement entity (CPE) proposal for guiding long-lead time TPD allocation.  However, the CAISO must take a more expansive view of long-lead time resources, to avoid discriminating against LSEs that are also pursuing long-lead time resources. The CAISO should adopt a similar scope as it did in Track 2, where both CPE resources and resource types designated by the CPUC when submitting their Transmission Planning Process portfolio are counted as long-lead time. Until that first designation is made, CalCCA agrees with offshore wind, out-of-state wind, and geothermal being in-scope given their geographic specificity and development timelines.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

The CAISO’s proposal to allow generators to interconnect up to an amount that would not trigger the need for long-lead time short-circuit mitigations would provide opportunities for projects to come online and obtain deliverability more quickly and with more certainty than under the existing processes. For this reason, CalCCA supports the CAISO exploring this proposal.  In order to further alleviate the current crisis of interconnection capacity scarcity, CalCCA encourages CAISO to explore any opportunities to make use of this provision as much as possible without risking grid reliability—including Area Deliverability Network Upgrades.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

CalCCA supports the CAISO’s proposal to explore modifying interim deliverability allocations to prioritize the date of the TPD allocations over queue number.  This approach could reduce incentives for projects to enter the queue and linger there before they are ready or commercially viable because such projects would not receive higher priority for interim deliverability allocations.

4. Please provide any additional feedback.

Maximum Import Capability (MIC)

LSEs are facing challenges in contracting out-of-state (OOS) resources for Integrated Resource Planning (IRP) and Resource Adequacy (RA) because of a lack of availability of MIC at present and uncertainty around the availability of MIC in future. California depends critically on contracted import capacity to maintain reliability. This is demonstrated by data provided by the California Independent System Operator Corporation (CAISO) on January 12, 2024, informing sources of RA and showings for LSEs in the CAISO balancing authority area (BAA) over the last five years. The data, when combined with the Net Qualifying Capacity (NQC) lists over the same five-year period, depict an RA requirement that has only grown more import-dependent (See Table 1).

Table 1: Amount of RA Requirement Not Covered by CAISO NQC[1]

This trend is likely to continue in the coming years.

The CPUC recently adopted Preferred System Plan (PSP), a resource planning tool that informs new capacity that will be built to support reliability requirements, includes over 7 gigawatts of new OOS wind by 2035.2 These OOS wind resources will require MIC to count towards LSEs’ RA and IRP obligations. Therefore, uncertainty around whether MIC will be available to support these projects is a barrier to LSEs moving forward with PPAs for OOS projects. Moreover, the total amount of MIC allocated to each LSE by the CAISO (based on total MIC that is available) is insufficient to support the level of imports needed by each LSE to contract for the level of OOS wind and geothermal needed to meet IRP goals.  This is particularly true since the bulk of new geothermal resources are being developed outside of the CAISO BAA, including new geothermal in IID. Enhancements in the efficiency of MIC allocations and increasing the availability of MIC should help make import capacity more available to meet RA and IRP requirements.  The CAISO should consider expanding the scope of Track 3 to include an assessment of MIC availability and the MIC allocation process. The issue of MIC availability is inextricably linked to the deliverability of internal resources. The CAISO posted a report indicating a decrease in the amount of MIC for RA year 2025, especially on popular intertie points NOB and Palo Verde.[2] MIC is calculated using historical data, and while the CAISO could adjust the MIC methodology to increase the amount of available MIC, it could not do so reliably without decreasing the amount of deliverability available for internal resources. The CAISO should take up MIC enhancements in this initiative to ensure a coordinated review of deliverability allocations for both in-state and out-of-state resources.

Conditional Deliverability

Within the Generator Deliverability Review initiative, the CAISO put forth the concept of providing “conditional” deliverability when delivery network upgrades are delayed beyond their originally identified in-service date. In the Generator Deliverability Review Final Proposal, the CAISO states, “[t]he issue of delayed reliability and delivery network upgrades delayed beyond their originally identified in-service date will be explored in the interconnection process enhancements, and will need to be coordinated with other policy venues and industry efforts to address concerns with the pace of resource and transmission development.”[3] The CAISO should explain where and how the CAISO will address the issue of delayed network upgrades within this initiative.

[1]            If the amount of resources not covered by CAISO connected resources is negative (in parenthesis), then the RA requirements could have been met entirely by resources internal to the CAISO BAA. If the amount of resources not covered by CAISO connected resources is positive, then CAISO LSEs must secure imports up to the amount shown in the table, assuming all CAISO connected resources are also secured for CAISO RA requirements, in order to meet aggregate RA requirements.

[2]            https://www.caiso.com/documents/iso-maximum-resource-adequacy-import-capability-for-year-2025.pdf.

[3]            Generator Deliverability Review Final Proposal at 26-27: https://stakeholdercenter.caiso.com/InitiativeDocuments/Final-Proposal-Generation-Deliverability-Methodology-Review-Jan-04-2024.pdf.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

In regard to the scoring criteria for TPD allocations, CPUC staff generally supports the CAISO’s proposal (including discontinuation of Group D projects) because it would significantly clear the queue of projects that lack commercial traction and would establish priority for ready-to-go projects that are linked with transmission planning and LSE procurement.  We note that the first application of this scoring criteria will be a challenging though important transition to the new paradigm in which CAISO’s interconnection queue becomes more manageable and the practical results better support the state’s efforts to accelerate development of renewable resources.

CPUC staff also recognizes the stakeholder comments submitted during Track 2 that highlight this scoring criteria is generally more favorable to projects with expected online dates in the next five years.  These are the projects most likely to have acquired a PPA or be able to demonstrate LSE interest.  CPUC staff encourages further exploration of ways that the application of the scoring criteria might help viable projects with expected commercial operation dates beyond 2030.  We suggest the CAISO and stakeholders examine ways for truly viable projects with extended timelines for operation to demonstrate their viability.

 Perhaps there are ways for projects that are tied to long lead-time transmission upgrades to have exceptional opportunities to stay in the queue and seek an allocation of TPD. It would be helpful if the CAISO could provide more information about the 14,000+ MW within the proposed Category D that lack commercial viability, specifically how these affected projects might be associated with long lead-time upgrades.  

CPUC staff encourages further focus on easing the impacts, if possible, on longer-term projects during this transition to the new TPD allocation methodology.  

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

CPUC staff views this as a laudable proposal to enable a limited set of generation projects manage through potential delays in needed transmission upgrades in a way that maintains their viability.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

CPUC staff supports this creative and reasonable proposal to fairly manage and encourage interim deliverability so that projects can get online as quickly as possible, and not to wait for certain transmission upgrades.

4. Please provide any additional feedback.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

CalWEA generally supports the Track 3A proposals, commenting only on the following two elements.

Proposal Element 6

For practical reasons, CalWEA recommends that operational EO projects that apply for deliverability receive highest priority for TPD capacity because capacity from these projects will be immediately available to meet LSEs' capacity needs and should be recognized for the value they are providing.  Prioritizing EO projects will also encourage viable projects to develop without FCDS capacity.

Proposal Element 11

CalWEA supports the CAISO’s broadly stated proposal to reserve and allocate TPD capacity from public policy network upgrades in the TPP “to the long lead-time resources those upgrades were intended to support.”  (Straw Proposal at p. 22.)  CalWEA agrees with CAISO (Straw Proposal at p. 16) that that this proposed policy is necessary to align the TPP with specific CPUC portfolio requirements and therefore does not represent undue preference.  CAISO notes that its proposal is based on an existing provision of its FERC-approved tariff.

Consistent with CAISO’s Track 2 draft final proposal (noted on p. 11 of the Track 3A proposal), CalWEA recommends that CAISO define this policy more specifically to state that CAISO will reserve TPD capacity for all location-constrained resources as identified by the CPUC in its most recent Preferred System Plan (PSP) as well as the resources identified in the final decision on Central Procurement.  “Location-constrained” should be defined as commercial-grade resources that are not widely distributed, including wind energy (onshore and off), geothermal, and any location-specific storage resources (such as compressed air and pumped hydro) identified in the PSP and in the final decision on Central Procurement.  These resources can only be developed in these specific areas, unlike solar and battery resources that have far greater location flexibility, as demonstrated by their large volumes in the queue. (Of the >174 GW active in the queue up to QC14, 160 GW are battery or solar; only 14 GW are non-battery/solar location-constrained resources.)

The Straw Proposal states (p. 22) that CAISO will consider the CPUC’s April 2024 Ruling (now Proposed Decision) on Central Procurement to “determine if it provides any relevant guidance on further TPD allocation modifications for long lead-time resources.”  However, that CPUC inquiry has been focused solely on what resources might require central procurement, not on what resources might require TPD capacity reservation. Therefore, CAISO should not look solely to the final decision in this case for guidance unless it specifically addresses TPD allocation. Rather, it should refer to the CPUC’s most recent PSP, as well as the resources identified in the final decision on Central Procurement.

TPD capacity reservations for location-constrained resources should not be limited to the upgrades that “would not be developed but for those resources being prioritized in the CPUC integrated resource planning (IRP) process” (Straw Proposal at p. 16).  Such reservations should extend to all location-constrained resources in the PSP that pre-date this capacity reservation proposal, including resources that would utilize existing transmission capacity or capacity from projects adopted prior to the most-recent PSP (where the resource was not previously identified by the CPUC).  This preference is necessary because there are insufficient diverse resources in the pre-C15 queue to meet the CPUC’s PSP goals for 2039, and projects in the queue may not have PPAs for many years:

• Only ~7 GW is onshore CAISO-interconnected wind vs. 7 GW in 2035 plan – this is only 1.0x the needed capacity which provides no room for competition and project failures; many projects in queue have been there for years; new projects in QC15 or later queues may be more likely to succeed.
• Only 60 MW is geothermal vs. 2 GW in CPUC plan – this is far less than 1.0x the needed capacity.  Further, there is only ~1 GW of geothermal in IID queue, which is MIC-constrained; only 700 MW of MIC is available for all IID resources (mostly being used by solar/storage). 
• While ~2 GW of non-battery storage is in the pre-C15 queue -- double the 1 GW in the CPUC plan, more than 2x the needed capacity is necessary to enable competition and project failures.

The location-constrained resources included in the PSP, whether presently in the queue or not, should be treated as “prior commitment” (per CAISO tariff Appendix DD section 8.9.1 “First Component: Representing TP Deliverability Used by Prior Commitments”) so that they will be prioritized over all other resources for the TPD capacity that is available from previously approved upgrades as well as newly approved TPP public policy network upgrades.  Thus, using the busbar mapping for 2039 from the CPUC’s PSP adopted in February 2024, these resources would, for example, be included:  

• 849 MW of FCDS capacity should be reserved for geothermal resources in the East of Pisgah Study Area
• 2,924 MW of FCDS capacity should be reserved for offshore wind resources in the PG&E Kern Study Area.
• 1,325 MW of FCDS capacity should be reserved for wind resources in Baja CA in the SDG&E Study Area
• 1678 MW of FCDS capacity should be reserved for wind resources in the PG&E North of Greater Bay Area Study Area.

Where there are not enough interconnection applications in the CPUC’s identified location-constrained resource areas, CAISO should add resources as needed to fulfill the CPUC’s Preferred System Plan (PSP).   As CAISO noted in Element 11.1, this will enable such projects to enter the interconnection process prior to any realistic opportunity for procurement of their resource.  These location-constrained projects should receive TPD allocation priority according to when they entered the queue. 

Projects dependent on new upgrades should be required to meet reasonable milestones as transmission projects advance through permitting and construction to ensure that the transmission projects will be used for the location-constrained resources as intended. A sufficient amount of location-constrained capacity should be in the queue prior to commencement of construction.

CAISO should propose such milestones and queue-sufficiency metrics for consideration by the parties and should include these details in the final proposal. 

To facilitate project entry into the interconnection process, CAISO should implement special rules for LLT/location-constrained (“LLT/LC”) resources in the intake process beyond assigning points for these resources in the scoring process. LLT/LC resources should be treated separately from non-LLT/LC resources in the intake process to ensure that all such resources obtain FCDS. 

Currently, for example, when CAISO reserves TPD for LLT/LC resources in PG&E NGBA, CAISO claims no deliverability remains behind the Delevan 500kV constraint. So additional QC15 LLT/LC projects at POIs constrained by Delevan 500kV are rejected, including offshore wind projects.  Instead, LLT/LC resources should be treated separately from non-LLT/LC resources in the intake process. CAISO should make clear what amount of TPD will be reserved for each type of LLT resource in each zone. Then up to 150% of the reserved amount for each type of LLT/LC resource should be included in the study. This way, capacity for QC15 offshore wind and all other LLT/LC resources in NGBA will be reserved, including capacity for QC16 Northeastern California wind projects.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

CalWEA strongly supports CAISO’s proposed broad approach for allowing “eligible resources” to use existing headroom in the system ahead of the in-service date of the long-term GRNUs required for those resources per CAISO cluster studies.  The details of the scoring used to determine eligibility of resources to use existing headroom in the system should be carefully vetted as part of Track 3B. 

Furthermore, these eligible resources should have their earlier allowed milestone dates reflected in their Generation Interconnection Agreements without any condition placed on the earlier milestone dates, such as the need to perform a Limited Operational Study a few months before earlier allowed Initial Synchronization Date.

The solution that is devised for Track 3B, which will enable many projects to commence operations while awaiting long-term GRNUs, should be made available for future clusters as well for when similar conditions arise.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

CalWEA supports CAISO’s proposal to give interim deliverability priority based on when TP Deliverability was allocated.

4. Please provide any additional feedback.

No additional comments at this time.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

The California Energy Storage Alliance (CESA) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 3 Straw Proposal. 

1. Renaming:  Support

2. Discontinue group D:  CESA recognizes the need to align the TPD allocation process with the pending use of TPD availability in determining the quantity of interconnection request to be studied.  CESA recommends CAISO transition to eliminating Group D, eliminating parking and moving to three annual TPD allocation opportunities.  Cluster 14 and earlier projects should be allowed to use both Group D and parking for the 2025 TPD allocation process.  Group D and parking could be eliminated for all projects starting with the 2026 TPD allocation.  This would allow the 150% study limit for Cluster 16 to reflect the proposed TPD allocation changes.  The three-year window for Cluster 14 and earlier projects would start with the 2025 TPD allocation.  This will allow Cluster 14 and earlier projects to be moved to energy only status one year prior to Cluster 15. 

CESA recommends better coordination with CPUC procurement orders when long-lead time area deliverability network upgrades push commercial operating dates beyond what load serving entities need to meet procurement requirements and enter into a power purchase agreement.  With the introduction of the three annual TPD allocation opportunities, CAISO must ensure that this window does not expire before load serving entities are able to enter into power purchase agreements.  This is especially acute for Cluster 14.  CAISO has identified that the Cluster 14 deliverability requires several long lead-time mitigation projects resulting in pushing the earliest commercial operation date into 2034. CPUC procurement orders do not go out this far nor is there sufficient time for the CPUC to address this in a new proceeding. This creates a real risk that viable Cluster 14 projects will be pushed out of the queue even though many of these projects are located in IRP/TPP aligned areas.  The Cluster 14 issues are another justification for transitioning to the new TPD allocation process over the next two cycles.    

3. Energy only project PPA must specify energy only:  No comment.

4. Discontinue parking: See answer 2

5. Three annual TPD allocation opportunities:  See answer 2

6. Energy only project can only receive TPD allocation through commercial operation group:  CESA continues to oppose restricting energy only projects to the COD group but recognizes that the proposed modification to the scoring criteria is seeking to prioritize projects with power purchase agreements within the COD group.  Based on discussions during the stakeholder call, CESA recommends CAISO consider allowing fast-track projects to seek at TPD allocation through the COD group.

7. GIA milestones defined by Order 2023 compliance:  Support

8. TPD affidavit due dates:  Support

9. Assessment based on documentation at due date:  Support

10. Modification to TPD scoring criteria:  CESA currently believes additional discussion is needed on including GIA criteria in the PPA group and Shortlist group scoring criteria.  It is unclear if it is appropriate for the GIA criteria to prioritize which interconnection requests will be studied and then be used again to prioritize which projects will receive a TPD allocation.  CAISO should outline the benefits it sees from modifying the PPA group and Shortlist group scoring criteria.  CESA supports additional scoring criteria granularity within the COD group.

11. TPD held back for long lead-time projects: CAISO should provide greater transparency on the process to determine the quantity of TPD held back for long lead-time resources from the TPD allocation process and other processes.  During the call, it was unclear if the TPD held back for long lead-time resources would also reduce the MW quantity used to set the 150% zonal study limit.  CESA recommends that the CAISO leverage the Constraint Mapping with TPD Allocated spreadsheet to add Reserved TPD for each area deliverability constraint.  CESA would appreciate it if this additional line item could be included in the update of the spreadsheet planned for mid-August to inform Cluster 15 interconnection requests.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

CESA supports leveraging the TPD allocation process to determine which projects can come on-line earlier when long lead-time reliability network upgrades are delaying requested in-service dates of multiple projects.  CESA looks forward to additional detail in the next paper on the scoring criteria and efforts taken to ensure the process is fair and creates appropriate incentives.  In the straw proposal, CAISO recommended limiting this new process to just Cluster 14 and short circuit duty reliability network upgrades.  CESA recommends the CAISO explore expanding the use of this new process to other instances where in-service dates are being delayed because of long lead-time network upgrades.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

CESA recommends that CAISO consider transitional measures to minimize disruption to existing contracting.  It would be beneficial if CAISO could perform an assessment of how this would potentially impact current projects receiving interim deliverability to better inform the necessary transition approach.  For example, how many earlier queue projects would lose interim deliverability if the proposed change from queue position to TPD allocation date had been in effect.  Previously in this initiative there was discussion about multi-year interim deliverability, CESA request CAISO provide an update on when this subject will be discussed.

4. Please provide any additional feedback.

 No additional comments.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

Proposal 3: A project that has been converted to Energy Only and later provides a PPA to modify its COD must provide a PPA that specifies an Energy Only product

Clearway opposes this proposal. If an Energy Only project meets certain milestones under the LGIA (e.g., security postings, NTP, and upgrade payments) and has a PPA of any type, it should be able to remain in the queue and compete for TPD. Without this provision, it would be more logical for an Interconnection Customer to withdraw a project from the queue and resubmit it as a new project in the next queue cluster, potentially wasting time and resources en route to the same outcome. This rule especially should not apply to energy storage additions to operational projects, since it is extremely unlikely that any offtaker would sign an Energy Only PPA with an energy storage project.

It is especially important for Energy Only projects to be able to provide a PPA that does not specify an Energy Only product if the plan of service upgrade timelines exceed 7 years in the queue. An EO project (similar to FC projects) should be allowed to adjust project COD to align with plan of service in-service dates without needing to demonstrate CVC, since regardless of contract status, it is not possible to bring the project to commercial operation before the plan of service upgrades are complete.

Proposal 6: Energy Only projects will only be eligible for an allocation through the Commercial Operation group, regardless of how they became Energy Only.

Clearway opposes this proposal and proposes an alternative: Energy Only projects should be allowed to seek TPD in the PPA or Shortlist group if the projects can demonstrate those commercial arrangements. In areas that have triggered any LDNUs, EO projects seeking TPD under the PPA or shortlist group should be given a lower priority than any project in the same group that is an active FCDS project in the queue. We understand that CAISO has concerns about potential free ridership if the study area has triggered an LDNU, as discussed on page 13 of the Revised Straw Proposal. However, this concern does not apply in areas that have not triggered an LDNU, and our proposal to give EO projects a priority lower than the FCDS projects within the same group addresses any free rider concerns in those areas.

Proposal 6.1: Treatment of Energy Only projects in prior clusters

Clearway opposes the proposal to limit the ability of Energy Only projects from prior clusters to seek TPD.

The system-wide need for Energy Only projects was discussed extensively in workshops and comments on IPE Track 2. In Track 2, the CAISO acknowledged that, while historically the commercial opportunity for Energy Only projects has been limited, this is no longer the case going forward given changes to the IRP and RA policy frameworks. In this changing policy environment, there are valid reasons that a prior-queued project may have Energy Only status and be viable as an Energy Only project, while also being a “ready” and competitive project that should be eligible to compete for TPD.

Clearway proposes that the CAISO allow Energy Only projects from prior clusters to compete for TPD if they meet certain milestones, including LGIA execution, specific financial security postings and issuance of Notice to Proceed. There are earlier-queued Energy Only projects that are advancing commercially and meeting the requirements of the LGIA; these projects may be among the most “ready” and commercially viable in the near term, and they should have a path to proceed and compete for TPD.

We also note that the Revised Straw Proposal includes two conflicting statements about the treatment of pre-Cluster 15 projects and request that the CAISO clarify what is being proposed:

Page 13: “All pre-cluster 15 Energy Only projects will be eligible to seek an allocation in allocation groups A, B, and C in 2025 and 2026.”

Page 20: “Projects in clusters prior to cluster 15 that are Energy Only will have one additional opportunity during the 2025 TPD allocation year to seek an allocation under all allocation groups.”

Proposal 6.2: Energy storage system additions can only seek TPD in the Commercial Operation group

Clearway strongly opposes this proposal. In an environment where many new projects in the queue are facing in-service dates that are 8-10+ years in the future because of long-lead network upgrades, retrofits and repowers of operating projects are uniquely valuable as “interconnection-ready” assets that can add capacity in the near term. Energy storage additions generally do not make commercial sense without deliverability, so the CAISO’s proposal would effectively close the door on these retrofit opportunities – slowing down near-term capacity additions when the opposite is needed.

To meet the near-term needs of the grid, Clearway proposes that capacity additions to operating projects – including energy storage additions as well as repowers or replacements of existing projects that increase project capacity – should instead be given priority access to available TPD. These projects should have access to the PPA and Shortlist groups for TPD allocations, and projects demonstrating PPAs should be eligible for out-of-cycle, priority TPD allocations.

Proposal 10.1: Modifications to TPD scoring criteria

Clearway supports the proposal to provide points for expansion of a generating facility. As noted in IPE Track 2, these are valuable opportunities to add capacity in the near term with fewer development obstacles than greenfield projects.

Proposal 11: Reserving TPD for long-lead-time resources

Clearway requests more transparency on the process the CAISO will use to reserve capacity for specific projects or technologies, including the process for revising those reservations over time as the CPUC’s IRP portfolio changes. There must be a process to release reserved capacity where appropriate. Resource portfolios are always changing as the CPUC goes through IRP cycles, and long-lead-time resources are particularly subject to change in the portfolios given that they are relatively more speculative technologies whose costs are higher and more uncertain than other resources. California has a policy objective of advancing emerging technologies, but this objective does not take priority over ensuring system reliability and meeting decarbonization mandates. The process for reserving TPD for specific resources must balance these priorities as well.

Proposal 11.1: TPD allocation modifications for long-lead-time resources

Clearway supports the application of this proposal in a technology-neutral manner. As the Revised Straw Proposal notes, the CPUC is well along the way toward directing procurement of specific resources designated “long-lead-time resources” – namely offshore wind, long-duration energy storage, and geothermal. However, there are many other resources “that are designated as resource technologies and in locations that are needed to meet state policy goals,” as described in the Revised Straw Proposal. These include solar and energy storage resources, as well as land-based wind resources, which are included in large volumes in the CPUC’s Preferred System Plan. Many of these resources are facing in-service dates as late as the mid-2030s because of the timeframe expected to complete network upgrades. Currently, the CPUC has made less progress toward creating a procurement framework for these resources – this is expected to be addressed in a new procurement program in the IRP proceeding, but CPUC staff are still developing the proposal for this new procurement program, whereas a Proposed Decision has already been issued that would direct procurement of offshore wind, long-duration storage, and geothermal resources starting in 2026.  

In this context, there is no justification for treating certain long-lead projects differently than others. All resources with current expected in-service dates beyond the window of the existing CPUC procurement framework (currently 2028) should be eligible for the same treatment for TPD allocation and retention purposes.

If enforced, the strict PPA deadlines for resources with long-lead network upgrades would result in many projects with TPD losing their allocations and having to reenter the queue in a future cluster. This churn would increase project costs and delay in-service dates unnecessarily.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

Clearway strongly supports this proposal; we recommend that CAISO staff separate this proposal into its own track and expedite it to achieve Board approval and implementation before Q1 2025, so that Interconnection Customers can learn whether their Cluster 14 projects can be expedited and make other development decisions accordingly (e.g., making major equipment purchases). This proposal has the potential to provide a pathway to early interconnection for several C14 resources with TPD allocation that need to wait for 8+ years for deliverability upgrades but could achieve early commercialization through a combination of intra-cluster prioritization and a multi-year interim deliverability framework.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

Rather than prioritizing based on interconnection request date or TPD allocation date, Clearway proposes allocating interim deliverability based on project viability and readiness, including whether the project has a PPA and whether it has met certain milestones under the LGIA, including issuing NTP and posting the 3^rd IFS. Projects should be eligible for interim deliverability based on the date they achieve both of these requirements, following the “first ready, first served” principle.

In addition, as previously discussed in this proceeding, Clearway requests that CAISO create a framework for multi-year allocation of interim deliverability. Providing contractual assurance of interim deliverability a year or less in advance of COD, as currently structured, is almost meaningless for successful commercialization. Contractual assurance of ID several years in advance of COD is critical, especially for projects that have TPD allocation but held up by very long-lead transmission upgrades (including much of Cluster 14 and later).

Providing a practical means to access transmission capacity through interim deliverability is also in the interest of ratepayers. In the context of capacity shortfalls and ratepayer concerns about affordability, CAISO cannot afford to leave any available transmission capacity unused. With earlier opportunities to access interim deliverability, projects that are advancing in the queue will be able to accelerate completion dates and increase system reliability – especially projects that were originally aiming for earlier CODs (and therefore have completed other development milestones) but have been affected by PTO delays.

The existing transmission system in several zones has available transmission capacity that is not utilized because of queued projects that are not yet constructed. When CAISO removed this proposal from Track 2 at the Draft Final Proposal stage, the rationale given was that the CAISO expects projects with TPD allocations to use all available deliverability as soon as it is available, and therefore there may not be be a significant amount of long-term interim deliverability available in the future. However, there are transmission zones where deliverability is reliant on several long-lead transmission upgrades, which will likely create interim deliverability as the transmission facilities are completed and placed in service over time. Clearway is aware of at least one example where a deliverability study revealed that significant deliverability is available several years in advance of the COD extended by PTO delays (driven by the current expected date of completion for NUs).

We understand that study assumptions for determination of ID several years in advance of project COD can be challenging. To remedy this challenge, CAISO should score eligible projects based on project viability and readiness milestones such as financial commitments, issuance of notice to proceed, commencement of upgrade payments, etc. and allocate available ID in descending order of this score.

4. Please provide any additional feedback.

Timing of TPD allocations post-IPE Track 2

Clearway requests that the CAISO ensure that for future queue clusters, TPD results are known well in advance of the next IR window opening (ideally several months in advance), so that developers can make decisions about new IRs and secure site control based on knowledge of the outcome of the prior TPD cycle.

TPD allocation and retention in merchant zones

Clearway recommends that if a project enters in a merchant zone as an FCDS project and CAISO’s studies determine no additional deliverability upgrades are required, then the project should be allocated the requested FCDS without needing to participate in the subsequent TPD allocation because the project has posted the $10k/MW deposit to enter the merchant zone. This would be similar to how a project under current Option B can achieve FCDS by agreeing to pay for any deliverability upgrades.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

EDF Renewables (EDF-R) appreciates the opportunity to provide comments on CAISOs IPE Track 3A revised straw proposal and 3B straw proposal, and that the CAISO has stated that they are flexible, actively desiring feedback, and open to modifications to ensure they work effectively for everyone.

Need for accommodation when DNU in-service dates are 7 years out or further

EDF-R requests that the CAISO consider a modification to the TPD allocation process to reasonably accommodate projects where their assigned delivery network upgrades won’t be in service for 7 years or more. Group allocations based on the criteria of being on a shortlist require the execution of PPAs very soon thereafter. PPAs with a COD that is more than five years is quite uncommon. So, an issue arises when a project is allocated TPD, but the network upgrade required won't be in service for 7 or more years. This creates a time gap between the PPA guaranteed COD (PPA execution date plus five years or less) and the network upgrade completion (PPA execution date plus ten years or more to achieve FCDS/deliverability). EDF-R believes this is an important discussion item moving forward. EDF-R request a working group meeting that reviews the various timelines and requirements that are part of Track 2 (including the updated Commercial Viability Criteria) and what is being proposed for Track 3A. This current proposal would change the long-established approach to the resource development and contracting processes.

CAISO indicated on the call that CAISO thinking is that developers should not seek to execute a PPA for any ADNUs that have 7-year plus buildout time frame until the upgrades are close to 5 years out from being in-service. However, CAISO’s cluster study process requires GIA execution within a certain timeframe along with binding cost responsibility payments in accordance with its respective Appendix B. In a traditional sense, CAISO prioritizing TPD allocation to commercially viable projects required a PPA shortlisting and up to PPA execution. Conversely, LSEs typically require demonstration of CAISO TPD as a binding requirement in PPA negotiations – hence Group B classification as a short list group. There is a common practice (in the interest of both developer and offtaker) to not execute a PPA with a COD further than five years out from PPA execution^[1]. GIA execution is an important milestone in a project’s development status for LSEs and developers alike for greater cost certainty.

Commensurately from a development perspective, the timing of GIA execution and PPA negotiation and execution are critical, especially going forward. First, FERC Order No. 2023 and 2023A require higher financial security deposits in addition to higher withdrawal penalties. Second, CAISO staff generally acknowledges the need to bring about 7 GWs of new clean resources online on an annual basis from now (year 2024) through 2045 in order to meet SB100 clean energy goals. Third, with the significant development coupling of new generation resources and associated transmission resources, CAISO’s transmission capability estimates released June 2023^[2] identifies numerous potential ADNUs to address current transmission constraints. Of the 104 identified ADNUs, fifty-two (52) include a seven years or more time to construct [six (6) ADNUs in 7 to 7.9 years, seven (7) in 8 to 8.9 years, seven (7) in 9 to 9.9 years, and thirty-one (31) in 10.0 to 18.0 years].^[3]

Lastly, assuming FERC accepts CAISO IPE Track 2 150% cap and transmission constraints zonal approach proposal elements, CAISO should assume the current CPUC, CEC & CAISO MOU will continue to facilitate specific resource and MW development in specific CAISO Study Areas. This collective effort, which includes offtakers and developers, has implications for new ADNUs to support this approach. It will impact C15 and beyond, but also adversely impact C14 and prior projects in CAISO study areas with existing and planned generation resources and associated network upgrades. There are C14 and prior projects in Group B (and possibly Group A) allocated TPD in the 2024 TPD study cycle with the caveat of not receiving FCDS or deliverability until the assigned ADNUs are online which include ADNUs expected to be in service in 2034.

When this item was briefly discussed on CAISO’s call, CAISO mentioned that it was a general hope that LSEs and developers would work on procurement of supply further out than five years. Yet without deliberate review, this change could seriously disrupt procurement and create significant RA market volatility.

The timing of this issue is very important as it will directly affect the viability of cluster 14 projects that received TPD allocations in Spring 2024 based on being on a short list (Group B). These projects (and the LSEs who made the shortlists) are now in receipt of pertinent information that extremely disrupts previous planning. As CAISO is aware, many cluster 14 Phase II reports show projects that cannot expect FCDS until 2030, 2032, and beyond.

EDF-R requests CAISO prioritize this issue such that it be filed with FERC in time to accommodate the needs of cluster 14 projects whose PPA attestations are due later this year, including filing this item separate from other items if needed or other plausible solutions to address this immediate issue.

Considerations for projects receiving TPD allocations less than 100% of their requested allocation

On the call CAISO indicated that most projects that receive allocations are expected to get substantial amounts. However, it is easy to imagine a situation where projects receive allocations for less than their requested MW. In these instances, CAISO’s current policy requires projects that receive any allocation to be withdrawn if they do not proceed with the allocation. EDF-R suggests that there should be some sort of threshold for what constitutes a meaningful allocation, and for projects that do not receive a meaningful allocation be able to stay in queue for additional allocation opportunities. For instance, a 300 MW storage project cannot move forward with an allocation of only 35 MW, but perhaps 150 MWs (50%) is reasonable?

Discontinuation of Allocation Group D

EDF-R is interested in continued discussion on modifications to TPD allocation procedures, and requests that CAISO provide data on the historical success of Group D projects. Specifically, EDF-R seeks empirical reports or data that demonstrate how these projects have performed compared to other groups over the past eight years. It would be useful to see how and to what magnitude group D projects performed compared to other groups. Additionally, Group D might be a plausible option to address projects in Group B needing to execute a PPA to retain their allocation. However, during the proceeding TPD study cycle, the project is allocated TPD that is made deliverable contingent upon an ADNU with a ten year out online date. CAISO should consider holding a working group meeting to address commercially viable projects that will not be deliverable for seven plus years yet meet the queue intake 150% cap of available and planned transmission capability.  

Energy Only Access to TPD

EDF-R requests CAISO consider changing TPD allocation procedures to allow for batteries added via the MMA process to request TPD if they are on a shortlist or if they have a signed PPA. The current CPUC RA counting process does not assign value to Energy Only energy storage, and without a pathway to getting deliverability these battery storage additions do not have a viable development pathway. EDF-R can imagine that because there is “technically” a pathway for these batteries to come online and then request TPD in group C, that is could be argued sufficient opportunity exists. However, this pathway is high risk and impractical, prudent developers cannot proceed with financing and construction with that much risk. Allowing energy storage added via MMA to seek TPD if they have a signed PPA or are on a shortlist is consistent with CAISO’s goal of commercially viable projects moving through the queue expeditiously with a first ready, first served principle.

Allocate TPD to PPAs with earlier CODs

EDF-R opposes CAISO’s proposal that projects with earlier CODs receive priority when CAISO is allocating TPD to projects that have achieved commercial operation. In this case all CODs have already passed, the projects are online, and the CODs are thus arbitrary. CAISO does not treat online projects differently as it relates to FCDS reductions (if there is not sufficient capacity on the system to accommodate all FCDS projects in a particular year, CAISO gives all online generators an equitable pro-rata reduction.)  The logic for this new policy should mirror other processes that apply to online generation and not consider online date.

Reserving capacity for long term projects

EDF-R understands CAISO’s goals in creating a procedure that allows for the reservation of transmission capacity intended for certain project technologies, and does not generally oppose the notion, however EDF-R requests CAISO provide procedure details so that the policy can be considered in the larger context of the TPP and the RIS. EDF-R requests CAISO provide additional information on the proposal for stakeholders to consider:

• Does the CAISO propose to reserve transmission for a particular resource type, or a specific queue position? If so, how can this reserved transmission option not be available for all resource types without appearing to be preferential towards a select few technologies?
• What will be the requirements and timelines for retaining that reservation?
• Will there be amended queue management requirements for GIA execution and commercial viability requirements for long-lead resources?
• In the event a resource does not retain its long lead deliverability; how, when, and to whom will that deliverability be released?
• How will transmission construction progress change these questions? For example, if construction has not started, deliverability could be released to “the pot” and upgrade changed as needed in restudy; vs when construction is underway and a resource loses deliverability, the capacity will still be in that specific study area or POI. Will CAISO allow interconnection customers to submit interconnection requests in that area for alternate resource types? 

EDF-R also notes that there is a puzzle baked into the development of these long-term resources that CAISO, the CPUC, LSEs, and developers still must solve. It is already difficult for resources and LSEs to consider contracting for long-term resources because of uncertainty around transmission in service dates, as discussed elsewhere in these comments. This issue is exacerbated for long-term resources, and these resources will also need accommodations like the PPA execution considerations discussed above.

[1] https://cal-cca.org/wp-content/uploads/2023/11/CCA-Clean-Energy-PPAs-11.2.2023.pdf

[2] https://www.caiso.com/documents/transmission-capability-estimates-for-cpuc-integrated-resource-plan-portfolio-development-call-on-070523.html

[3] Eight (8) of the 104 identified ADNUs did not include a specific time to construct

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

EDF-R looks forward to continued discussions on this important topic and recommends CAISO first focus on implementation of time-sensitive issues in Track 3A & 3B. The Cluster 14 Phase II study process is complete as well as their first round of TPD Allocation from the 2024 TPD study process. The results of this Track 3B: Intra-cluster prioritization proposal could provide faster interconnections for a subset of projects in Cluster 14. Additionally, EDF-R strongly requests CAISO resolve specific 3A topics, in particular, creating a pathway to resolve deliverability network upgrade delays and PPA execution deadlines.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

CAISO’s proposal did not provide consideration for legacy contracts. EDF-R requests that the CAISO retain the IDS process in place for projects with existing contracts, e.g. Power Purchase Agreements (PPAs) that were signed under the allocations in Group A (signed PPA) or Group B (shortlist) 2024 or prior.

CAISO is certainly at liberty to reconsider how interim deliverability (ID) allocations are managed in the future; however, it is crucial not to disrupt contracted projects that received an allocation and prepared to come online under the existing rule set. Failing to honor the procedures in place risk project stability, project finances, and ultimately reliability as projects planning to move forward under current ID procedures may not be able to under suddenly-changed rules.

To avoid these outcomes and ensure equity and fairness, CAISO should implement a clear legacy treatment policy. This is not about leapfrogging or taking undue advantage of CAISO's current rule set but about adhering to the established rules under which these contracts were signed. Stakeholders have made their contracting decisions in good faith, based on the rules that were in place at that time.

There is precedent for implementing a legacy process to protecting “existing” generators from mid-flight NQC changes. When CAISO changed deliverability procedures and implemented the GIDAP, CAISO established "existing" status^[1],[2] to ensure appropriate allocation of net qualifying capacity (NQC) to generators with executed PPAs before new procedures were implemented. This status was crucial in areas where transmission capacity constraints existed, and mitigating network upgrades were initially identified but later removed. In this circumstance, the ISO’s practice was to reduce dispatch levels first for the “new” group of generators, and then reduced dispatch levels for the “existing” group only if the overloads cannot be eliminated by reducing the dispatch levels of the “new” group to zero.

The CAISO’s current proposal for deliverability changes should protect projects that received a TPD allocation based on Group A (signed PPA) or Group B (shortlist) in 2024 or prior.

[1] January 22, 2013 Affidavit for Establishing “Existing” Generation Classification For Net Qualifying Capacity Allocation  https://www.caiso.com/documents/technicalbulletin-affidavit_establishingexistinggenerationclassification_nqcallocation.pdf

[2] June 12, 2012 Revised Technical Bulletin Deliverability Requirements for Queue Clusters 1-4 and Determination of Net Qualifying Capacity https://www.caiso.com/documents/revisedtechnicalbulletin-deliverabilityrequirements-queueclusters1-4_determination-netqualifyingcapacity.pdf

4. Please provide any additional feedback.

EDF-R respectfully requests that CAISO post the deliverability base case for Cluster 14 on the secure transmission planning site as it has for all years preceding this one. With so many changes to the CAISO processes and an increased onus on developers to bring mature requests to the CAISO and provide amble financial security subject to serious non-performance risk, developers need base case information to perform research and engineering activities to prepare these requests.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

ENGIE NA (“ENGIE”) appreciates the opportunity to comment on CAISO’s Track 3A proposal in the IPE 2023 initiative. The proposals included in track 3A are highly problematic as they require commercial activity to be performed very early in the development process. These changes paired with the Track 2 intake proposals that will soon be filed with FERC will increase risk for developers and LSEs significantly which will ultimately reflect in higher downstream costs to consumers. In addition, none of the proposed reforms in track 3A take into account the reality of long transmission lead times that span 10 plus years on many projects.

Track 3B Should Be Prioritized Over 3A

ENGIE recommends the CAISO prioritize track 3B which focuses on Cluster 15 intra-cluster prioritization and pause 3A until a FERC order is issued on IPE Track 2 intake. Having certainty on IPE Track 2 will be critical towards developing targeted proposals for Track 3. If CAISO’s Track 2 proposal is accepted by FERC it will result in much smaller queue volumes which may require less or different modifications in Track 3. Developing workable solutions to clear the log jam for Cluster 14  projects should take precedence over modifications to the TPD allocation process that the CAISO has more time to develop,

Section 2.1 TPD Allocation Process Modifications

While ENGIE proposes that CAISO pause track 3A until a FERC Order is issued, we offer the following comments to CAISO’s proposals.

Elimination of Group D

An alternative path to deliverability needs to be maintained especially considering the reality of long transmission lead times, at least until a time when transmission lead-times are resolved to manageable levels. The industry has experienced some unprecedented geopolitical and supply chain issues the past few years that will continue to persist for a period of time. This dynamic must be taken into consideration in the development of these proposals.

Requiring projects to secure a PPA or shortlist prior to attaining deliverability does not represent commercial realty for developers or LSEs and even less so with projects tied to long lead time transmission upgrades as is now the norm. Even if LSEs change their practices to procure projects further out in time, so much risk premium would need to be priced into PPAs it would significantly increase the costs to downstream consumers.  Financing a project with this level of uncertainty would be another challenge. Ultimately, under this framework California could become an undesirable place to develop clean energy projects as compared to other markets. While queue volume may be minimized this approach will create more problems than it solves and is unattainable for developers and LSEs.

ENGIE maintains its prior position that Group D should continue to exist but that any conditional deliverability assigned  should not count against the 150% zonal limitations for the next queue cluster. This would require the CAISO to relax the 150% limit to accommodate the additional deliverability required for Group D. This paradigm should stay in place at least for the next three clusters (Cluster 15, 16, 17) or until a later time when transmission lead times have been mitigated to more industry standard levels. If transmission continues to be constrained and supply chain issues persist resulting in many upgrades more than five years in the future, CAISO cannot eliminate Group D.

If despite opposition the CAISO proceeds with eliminating Group D it must allow a transition for Cluster 14 projects both that already have conditional deliverability in Group D and those seeking deliverability under today’s rules. Changing the rules of the game midway for these projects is highly problematic.

• Cluster 14 projects must have at least three opportunities to seek TPD, rather than counting that one has already been used prior to these rules being instilled

• Cluster 14 projects that have been assigned deliverability and are in Group D currently should have a minimum of another year to make the transition. Absent that, projects signing LGIAs in October will lose deliverability on February 1, 2025 under these new proposed rules in short notice. It is not reasonable to penalize these projects by changing the rules. 
• CAISO should consider allowing more than three consecutive years to get TPD considering the long transmission lead times. This could be another way to address this issue.

Energy Only Projects

If an energy only project is short-listed or has a PPA it should be able to seek deliverability prior to commercial operation. This also applies to the addition of storage to a project. Eliminating this ability could prevent efficient and cost effective additions to grid. If there is a problem that needs to be solved by eliminating EO projects from attaining TPD prior to COD it requires further discussion.  

Revised TPD scoring criteria

It is unclear why the CAISO is allotting extra points to the expansion of a generating facility. The CAISO should simply provide extra points for earlier CODs to provide equal opportunities to all project types

All projects with an executed PPA, whether it is regulatory approved or not should receive the same points.

TPD for Long-Lead Time Projects

The CAISO must provide transparency on the process to determine the quantity of TPD held back for long lead-time resources from the TPD allocation process and other processes and where it will be held back. Having transparency into where on the system TPD is being reserved is critical for developers to understand  how their projects are impacted for siting purposes. The CAISO also needs to clarify if the TPD held back for long-lead time resources reduces the MW quantity used to set the 150% zonal study limit.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

As noted previously, ENGIE encourages the CAISO to prioritize its efforts on Track 3B and address Track 3A after there is certainty from FERC for Track 2 of the IPE intake process.

ENGIE strongly supports the CAISO’s proposal to develop a process that would allow generators to interconnect up to an amount that would not trigger the need for long lead-time short-circuit mitigation. Using the affidavit process seems to be a reasonable approach to this type of intra-cluster prioritization and ENGIE looks forward to additional discussion on this item.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

No comment at this time.

4. Please provide any additional feedback.

No additional comments.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

Introduction

By tying future queue access to TPD availability, CAISO has created a difficult landscape where it must prevent the TPD allocation process from overly limiting future interconnection requests while also providing a viable path for projects in the queue to provide RA. Several Track 3A proposals make it harder to receive an allocation of TPD, which helps ensure there is available TPD to enable future projects to apply for interconnection by making it less likely all the TPD gets allocated each allocation cycle, but it then makes it more challenging for projects in the queue to become FCDSA and provide RA. Between the new hurdles to seeking interconnection, the difficult and limited window for seeking deliverability, and the new commercial viability criteria pushing projects out of the queue, CAISO is creating uncertainty as to whether viable projects can succeed under these rules.

Golden State Clean Energy’s (“GSCE”) comments herein focus on Track 3A. The following are some of GSCE’s key comments:

• GSCE opposes limiting projects to three consecutive opportunities to seek a TPD allocation, after which the project is converted to energy only and can only obtain TPD via Group C (or a TPD transfer). GSCE supports CAISO rescinding these Track 3A proposals because they are unnecessary given the package of queue reforms are sufficient to manage the deliverability allocation process. If CAISO retains these Track 3A proposals, GSCE suggests CAISO allow projects that have taken demonstrable development steps to remain eligible for an allocation of deliverability in a fourth and fifth year so they are not prematurely discarded. Proof of demonstrable development steps can be achieved by looking to certain criteria in the existing TPD allocation scoring process, as detailed below.
• GSCE opposes portions of the TPD allocation scoring process. GSCE believes certain scores in the proposed TPD allocation process do not reflect their value to the development process and suggests some shift in the points awarded. GSCE also proposes additional scoring criteria to have a more robust process.

• GSCE supports the reservation of TPD but cautions CAISO against creating unnecessary rules or process at this stage. It is still unclear when reserving TPD will be beneficial to the state, so CAISO should avoid unintentionally and needlessly creating hurdles for potential future uses. Reserving TPD for long lead-time resources is just the newest example of a potential use case, and the application of reserved TPD to long lead-time resources may need to be clarified, but future cases may emerge that are not currently considered and thus CAISO should protect the broad authority it currently has to reserve TPD.

Limitations on future ability to seek TPD

• GSCE does not oppose discontinuing Group D, but there may be better solutions to this issue.
  • Future interconnection requests should not be blocked due to TPD being allocated to projects that are still undergoing studies and have not executed a PPA. CAISO must continue to study a significant amount of new interconnection requests each cluster cycle in order to bring online the 7 GW per year that is required to meet SB 100, and it should do so while also maintaining sufficient competition among those selling power to LSEs.
  • GSCE does not oppose discontinuing Group D because the new interconnection request intake rules make available TPD necessary for most projects to apply for interconnection. However, GSCE agrees with concerns that this proposal could disrupt the marketing of RA.
  • GSCE supports proposals to make allocations under Group D conditional (i.e., to not count Group D allocations against available TPD in the interconnection request intake process).
• GSCE opposes limiting projects to three consecutive opportunities to seek a TPD allocation, after which the project is converted to energy only and can only obtain TPD via Group C (or a TPD transfer).
  • These proposals create a strong risk that projects which are reasonably progressing and taking concrete development steps are forced out of the queue prematurely (i.e., by converting the project to energy only, which could frequently lead to withdrawal given the inability to later seek TPD).
    • CAISO’s timeline for when the commercial viability criteria applies can be viewed as a proxy for a reasonable development timeline, but the instant proposal undercuts that judgment of a reasonable timeline by pushing projects out ahead of the time-in-queue limit.
    • Considering extended network upgrade timelines and other factors, it will likely be unreasonable and premature for a project to enter into a PPA the first year the project is eligible to seek TPD given PPAs require COD certainty, which is driven by network upgrade timelines. Yet CAISO is forcing the project’s hand to attempt to enter into a PPA early, regardless of the reality of the situation. This may result in executed PPAs that must later be re-negotiated to postpone the COD, which will have adverse impacts on buyers, sellers, and CAISO.
    • CAISO must ensure that projects that are progressing in their development efforts and are still viable are not too quickly dismissed. If receiving and retaining an allocation of TPD in a three-year period becomes routinely difficult, CAISO will create excessive churn in the queue by casting aside projects as they reach a more mature stage of development and are finally in a position to execute a PPA, only to make room for new projects that may face the same timeline challenges.
  • GSCE proposes CAISO rescind this proposal because it is unnecessary.
    • With the limited amount of projects that will be allowed in the queue and the new, stricter requirements for staying in the queue past the time-in-queue limit, there does not seem to be a need to force projects out prematurely in order to manage the queue.
  • If CAISO does not rescind this proposal, GSCE proposes that CAISO adopt rules that reduce the risk that many viable projects get forced into energy only too early and thus withdraw prematurely. This includes the following potential rules:
    • Provide a conditional fourth and fifth year to attempt to receive a TPD allocation for projects that can demonstrate at least one of several readiness requirements that show significant steps are being taken to develop the project.
      • CAISO should look to the TPD allocation scoring for ease of implementation and because the scoring already considers project viability and commercial readiness.
      • The readiness requirements that make a project eligible to seek TPD for a fourth and fifth year should include the following options, any one of which alone should allow a project to remain eligible in the fourth and fifth year: (i) having a draft environmental report (permitting), (ii) having an executed PPA, (iii) expansion with existing gen-tie headroom, (iv) gen-tie site control (proposed new scoring category, below), or (v) any of the proposed GIA scoring options. All are serious development steps taken and individually indicate projects CAISO should not cast away prematurely.
        • CAISO would check the seeking TPD affidavit in the third year a project is eligible for an allocation of TPD to see if the project meets any of the criteria to allow it to proceed to a fourth year of eligibility, and if so then similarly in the fourth year of eligibility the project would need to demonstrate one of the criteria to qualify to seek an allocation in a fifth and final year before being converted to Energy Only (if it continues to not be allocated TPD).
    • Senior projects
      • If CAISO continues to limit projects to a finite number of opportunities to seek TPD, it should also award points to projects the longer they have been in the queue.
        • A limited number of points should be awarded, with the goal being for the point(s) to act as a tie breaker in a scenario where an older project is going up against a project in its first year of eligibility for a TPD allocation. This acknowledges that projects may be prematurely forced into energy only and limits the number of older projects that are cast away in situations where they are competitive for deliverability.
        • GSCE suggests that one point be awarded the first year a project can seek TPD, two points be awarded the second year a project can seek TPD, and three points be awarded the third year a project can seek TPD (and so on).
      • This can help reduced the churn of late-stage projects being forced into energy only/withdrawal when they can justify an allocation of deliverability.

TPD allocation scoring

• GSCE urges CAISO to better recognize the value permitting has in the development process by awarding more points for a draft environmental report.
  • Permitting can be a major obstacle, so recognizing the major milestone of a draft environmental report is warranted. If permitting fails, so does a project.
  • GSCE suggests seven points be awarded to projects with a draft environmental report, instead of the current award of five points.
  • At this mid-point in the queue process (i.e., TPD allocation), a draft environmental report is likely as far of a permitting step as is reasonable to take until the project is closer to beginning construction. This is especially true considering CAISO’s proposal to limit TPD eligibility to three consecutive attempts, because it means TPD allocation is not occurring later in project development.
    • Incentivizing receipt of a final governmental permit too early in development can actually cause issues and delays if there is any material change after the permit is granted but before the project begins construction.
• New scoring opportunities
  • GSCE supports the GIA-related scoring criteria.
  • GSCE opposes the amount of points proposed to be awarded for the expansion of a generation facility and generally questions doubling down on rewarding such projects (here in the TPD allocation process and also in the interconnection request intake process).
    • GSCE recommends the two expansion options that do not involve a gen-tie with headroom receive one and three points, if any points at all.
  • GSCE also supports additional scoring criteria to better differentiate projects and make CAISO’s overall readiness assessment more robust. These additional scoring criteria should include:
    • Gen-tie site control
      • CAISO is proposing to award seven points to an expansion project if the gen-tie has headroom. For projects other than expansions, securing the land for a gen-tie is a necessary step and it should be awarded five points.
      • Including this as a scoring criterion incentivizes projects to continue to take steps toward development and awards those who have overcome an obstacle that could derail development.
    • Senior projects
      • As discussed in GSCE’s comment on the proposal to limit projects to three consecutive opportunities to seek a TPD allocation, GSCE supports awarding points to projects the longer they have been in the queue.

TPD reservation

• GSCE is supportive of CAISO using its broad authority to reserve TPD under GIDAP/RIS Section 8.9.1(b) and (c). Section 8.9.1(b) and (c) allows CAISO to identify TPD “commitments” before allocating TPD under Section 8.9.2, including “any Maximum Import Capability included as a planning objective in the Transmission Plan” and “any other commitments having a basis in the Transmission Plan . . .”
• CAISO has previously discussed how TPD can be reserved for a Subscriber PTO project, and it is now teeing up the potential to reserve TPD for long lead-time resources. Given the broad tariff authority and potential for future situations to arise that would also benefit from a TPD reservation, GSCE cautions CAISO against creating additional rules and process for reserving TPD that could unintentionally and needlessly create hurdles for potential future uses. Additional transparency and information around the TPD reservation process for long lead-time resources can be provided without BPM changes, such as documentation in the TPP process or elsewhere that explains the latest reservation of TPD as applied in that case.
• GSCE agrees with previous comments that reserving TPD creates the risk of undue preference, and thus it must ensure it leaves the TPD reservation process open for additional potential use cases that may arise in the future.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

4. Please provide any additional feedback.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

Comment on 10. Modifications to TPD scoring criteria

The use of the criterion that prioritizes expansion of existing or queued generation is both unnecessary and unduly discriminatory.

The criterion is unnecessary because the scoring matrix is likely to accomplish its goals even without the expansion criterion. A smaller number of projects in QC15 and beyond are expected to seek TPD allocation than under current conditions, due to the significant intake reforms that CAISO is planning to implement. The already-existing permitting criterion sufficiently captures a proxy for project viability and speed—which were the two rationales CAISO staff indicated for justifying inclusion of the expansion criterion.

The criterion is unduly discriminatory because repeated use of that criterion for TPD allocation further advantages incumbent interconnection customers and is unduly discriminatory. CAISO is already planning to use the expansion criterion to prioritize interconnection requests for entry into the cluster study. Projects that have proceeded to requesting TPD—and thus already passed that intake screen and have been studied—should not be again scored on this criterion, as they will have already passed legitimate project viability, system need, and/or LSE interest criteria. CAISO has not made a convincing case that the success rates of projects allocated TPD will differ significantly between expansion and non-expansion projects, particularly in a future where fewer projects overall are competing.

Comment on 11. TPD held back for long lead-time projects

CAISO should provide more detail on the process to determine the quantity of TPD held back for long lead-time resources from the TPD allocation process and other processes. While it is understandable that CAISO would like to preserve TPD for CPUC-directed portfolio resources that have long lead times, it is unclear whether and how those reservations might affect other resources that are sited on or near shared transmission infrastructure in earlier clusters. Additionally, CAISO should indicate how the TPD reserved for long lead-time resources would affect the 150% zonal study limit, if at all.

Questions on 2. Discontinuing the parking process

• Can CAISO clarify that if it is seeking IA Execution and 2^nd Financial security posting even for projects that want to participate in 2^nd round of TPD study?
• For projects that sign an IA and make necessary financial postings to stay active in queue for TPD round 2, will the postings be 100% refundable if the project decides to withdraw after the TPD round 2 results are out?

Questions on 5. Discontinuing Group D

• Do Group B projects need to demonstrate an executed PPA in their second and third round of TPD study?
• Since parking is no longer allowed, how will projects get these 3 consecutive opportunities if the PPA execution is needed in the 2^nd TPD cycle itself?

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

Section 3.1 Proposal: “Affected generation projects could then submit affidavits with similar information as those submitted for the TPD allocation process as described in section 8.9.2.1 of GIDAP and around the same time. “

Can CAISO clarify if this same time refers to the March 15^th TPD affidavit timeframe or something else. Further, can CAISO Clarify if they plan to use the same scoring table as TPD allocation scores or something else that will be created as part of this effort?

Instead of using a scoring mechanism would it not be better for CAISO to use the Amperage contribution to the issue as a factor where the lowest amperage contributing projects get to use the availability capacity on the breakers first so that a greater number of projects get to utilize this provision to come online sooner?

CAISO has refrained from supporting developers in fixing the short circuit methodology process at the PTO level so far. If the actual methodology and modeling errors are fixed a lot of these issues may go away. Should we not prioritize that effort over this score mechanism to ensure projects are not getting delayed due to erroneous model-based runs?

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

4. Please provide any additional feedback.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

Intersect Power strongly opposes CAISO's modification of the "Regulatory-approved PPA" qualification criteria. Footnote 7 of CAISO's proposal explicitly disqualifies Non-LSEs from this scoring item. This change exacerbates the competitive imbalance created by last year's CAISO modifications, which already imposed significant burdens on resources with Non-LSE contracts participating in the TPD allocation process. CAISO has failed to provide any rationale for this change or demonstrate how it enhances the existing process.

Intersect Power opposes the inclusion of Generator Expansion criteria in the TPD scoring rubric. This metric offers no reliable measure of project feasibility or ability to achieve timely online status, particularly when Network Upgrades, beyond IRNUs, are triggered. Moreover, it unfairly advantages smaller projects that do not fully utilize existing gen-tie line capacity. Given these shortcomings, introducing this new scoring criterion is unwarranted. If CAISO seeks additional viability metrics to better differentiate TPD allocations, Intersect Power recommends revisiting our Track 2 initiative comments, which proposed various alternatives centered on procurement of generator equipment and long-lead high-voltage equipment. 

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

Intersect Power commends CAISO for promptly recognizing this issue and developing a practical, viability-focused solutionn.

We offer the following recommendations for process structure:

• As discussed in the stakeholder call, Intersect Power requests that CAISO explicitly confirm this process is not limited to QC14-triggered upgrades, and can be applied to Pre-Cursor Upgrades and Conditionally Assigned Network Upgrades as well.
• In order to participate in the prioritization scoring process, CAISO should require that projects are not “parked” and if coming out of parking status for the purpose of participation, that those resources have satisfied their Interconnection Financial Security (IFS) obligations.
• To expedite project in-service dates, Intersect Power strongly recommends an immediate commencement of the affidavit process for headroom prioritization upon the effective date of the new Tariff language. While combining this process with TPD allocation affidavits might offer resource efficiencies, accelerating headroom prioritization will identify and focus CAISO and PTO efforts on critical projects, thereby alleviating near-term workload.

Intersect Power puts forth the following scoring rubric to determine project prioritization for the utilization of existing system headroom where upgrades have been triggered. The rubric is a combination of existing scoring criteria that the CAISO utilizes for TPD allocations, along with additional project viability and advancement measures, some of which were proposed by Intersect Power during the Track 2 process.

Intersect Power’s Proposed Scoring Rubric:

Rationale for Proposed Scoring Rubric:

Permitting

• These criteria align exactly with the CAISO’s current TPD allocation scoring rubric.

PPA Status

• These criteria are adapted from the CAISO TPD allocation scoring rubric. Due to the absence of the "Groups" concept in this context, the PPA and Shortlist Group criteria have been consolidated and redistributed across the available point levels.

GIA Status

• This category rewards projects demonstrating significant progress in the interconnection process through contractual engagements with the Participating Transmission Operator (PTO) and irrevocable financial commitments for Network Upgrades. Projects with executed Engineering and Procurement (E&P) Agreements or Generator Interconnection Agreements (GIAs) and a posted Third Interconnection Financial Security (IFS) receive maximum points.

Key Generator Equipment

• This category rewards proactive supply chain management by prioritizing projects that have advanced procurement of key generator equipment such as solar modules, batteries, wind turbine generators, and thermal generators. Furthermore, given the increasing volatility and geopolitical risks associated with global supply chains, supply chain resilience is paramount to project success. Prioritizing projects with secured domestic supply chains aligns with the Inflation Reduction Act's emphasis on domestic manufacturing. This approach enhances project viability, accelerates timelines, and reduces overall project risk, all of which warrant prioritization for the utilization of existing system headroom.

Long-Lead High Voltage Equipment

• As demonstrated by numerous Cluster 14 Phase II Study Results, lead times for critical high-voltage equipment, including step-up transformers and circuit breakers, have significantly extended, often exceeding five years. This category acknowledges the critical role of these components by rewarding projects that have successfully procured them. While the quantities may be smaller than key generator equipment, the procurement of long-lead high-voltage equipment is equally vital to project success and interconnection to the transmission system.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

Intersect Power generally agrees with the CAISO’s modifications to the prioritization for awarding Interim Deliverability.

As discussed in the stakeholder call, Intersect Power requests that CAISO explicitly confirm these changes will not affect transferred TPD. Such TPD should continue to be treated based on the original resource's allocation date.

As highlighted during Track 2 discussions, stakeholders expressed strong interest in CAISO extending Interim Deliverability Status (IDS) beyond the current one-year timeframe. This would significantly enhance the current year-by-year process, encouraging greater capacity to progress toward commercial operations even amidst the uncertainty surrounding five-to-ten-year Full Capacity Deliverability Status timelines. Intersect Power encourages CAISO to explore the feasibility of multi-year IDS awards. 

4. Please provide any additional feedback.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

LS Power appreciates the opportunity to comment on CAISO’s Track 3 proposal and provides the following input on Track 3A proposal number 11.

LS Power supports the CAISO proposal to reserve and allocate Transmission Plan Deliverability (TPD) from policy network upgrades in the TPP to the long lead time resources those upgrades were intended to support.  Inclusion of out-of-state (OOS) wind as a long lead time resource for this purpose is imperative to ensure LSE contracting occurs in a timely manner and that there is adequate Maximum Import Capability (MIC) to support deliverability of OOS CPUC portfolio resources.  The latest CPUC portfolio[1] includes 1,060 MW of OOS wind from Idaho, 2,900 MW from Wyoming, and 2,131 MW from New Mexico, all of which is modeled with deliverability.

There is also a need to provide equal access to deliverability for OOS wind resources regardless of whether they are obtaining access to CAISO markets through transmission approved as part of the Subscriber Participating Transmission Owner (SPTO) model or a standard CAISO approved transmission line.  Providing priority access to deliverability only to resources interconnecting through the SPTO model provides those resources an advantage over other OOS wind portfolio resources.  Applying the existing tariff language in Section 8.9.1 beyond resources utilizing the SPTO model will allow all OOS wind portfolio resources to move forward on equal footing. 

LS Power requests additional clarification on how this proposal will be implemented, particularly around MIC and the allocation of deliverability within a subgroup of eligible resources.  Providing clarity around the proposed priority access to deliverability for long lead time resources, along with information as to when MIC will be available to support portfolio resources will help ensure contracting and development of these resources occur in a timely manner.  Clarity around how the reserved TPD will be allocated within the subgroup of resources eligible for the deliverability is also needed.  For instance, if deliverability up to the amount of OOS wind in the portfolio isn’t available at Harry Allen by the time OOS wind coming in from Idaho and Wyoming are online, how will the available deliverability be allocated?

[1] https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M525/K918/525918033.PDF

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

LS Power has no comments at this time.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

LS Power has no comments at this time.

4. Please provide any additional feedback.

LS Power has no additional feedback at this time.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

These proposal reference numbers are from Section 2.1.

TPD Allocation schedule (2025 & beyond) – affidavit due dates (#8):  TPD retention affidavits would be due February 1^st, and “seeking TPD” affidavits due March 15^th.  This schedule would inform developers whether they have retained prior awards first, so they can request a new allocation if not.  The CAISO has also cited workload factors for dividing the process into two parts.

LSA supports a single affidavit due date of March 15^th, for the following reasons.

• Developers already know whether they meet the requirements for retaining their prior allocations, in the experience of LSA members.  The retention requirements are straightforward, and it is not necessary to divide the process into two parts for this purpose.

• Developers with retention requirements need more time for compliance with those requirements.  Historically, both retention and “seeking” TPD affidavits were due in early December, about 9 months after the prior-cycle TPD Allocation results were released around the previous March.  This schedule was already tight for compliance activities.

2023-2024 TPD Allocation results were released on May 31^st, 2024.  Thus, a February 1^st, 2025 retention-affidavit due date would allow only 8 months to meet the retention requirements.  The prior nine-month schedule was already a challenge, and the additional month is needed for the required retention activities (executed PPAs for Group B, executed PPAs or shortlist/active negotiations positions for Group D). 

Thus, LSA recommends a March 15^th due date for retention affidavits, at least.  The CAISO could make the seeking-TPD affidavit due date later if workload issues would be eased that way.

Additional timing issue – C14 security postings:  The second Interconnection Financial Security (IFS) posting for Cluster 14 projects coming out of parking should be coordinated with release of 2025 TPD Allocation results.  Under the current tariff, parking delays the due date for this posting by one year.  CAISO should ensure that developers for these projects receive their TPD Allocation results early enough (at least two weeks in advance) before the posting is due, so they can make a reasonable determination whether the project should proceed or withdraw from the queue.

TPD intra-group scoring/priority criteria (#10)

• Nomenclature clarification:  The CAISO should change the name of this section, to “Intra-TPD Allocation Group Prioritization.”  There may be projects from many clusters seeking TPD in any given allocation cycle, and the current title has caused confusion among stakeholders.

• Format clarification:  The CAISO should clarify that the permitting and GIA progress points apply only to the PPA and Shortlist Groups.  [We have made that clarification in our reports, and it was confirmed by the CAISO at the June 15^th meeting.]

• GIA progress metric:  LSA supports adding this scoring metric.  The proposed milestones are easy to measure, and they are indicative of project readiness to proceed.

• PPA Group - “Regulatory-approved PPA” metric:  LSA recommends two clarifications and one modification, for the full (5 points) award.

• Clarification 1:  The full points should be awarded for PPAs that can become effective without any regulatory approval.

• Clarification 2:  The full points should be awarded for PPAs where the approval authorities (which may not be Local Regulatory Authorities – e.g., CCA Boards, municipal utility City Councils or utilities directors) have approved the agreement.

• Modification:  The points full should be awarded for executed PPAs with non-LSEs, as long as the PPA approval authorities (e.g., Boards of Directors, procurement officers, or other entities with final approval authority) have approved the agreement.

• PPA Group - “LSE serving its own load” metric:  LSA recommends removing this metric or, at a minimum, providing equivalence for third-party projects having PPAs with LSEs that are intended to meet the LSE’s regulatory obligations.  While we recognize that this is a current intra-group metric, it is blatantly discriminatory and unduly favors LSE self-builds over projects under contract to meet the same purpose.

• Commercial Operation Group prioritization:  LSA supports the proposed prioritization order generally.  However, the executed PPA should be one that supports the project COD, or there should be other restrictions on later COD changes.  Otherwise, the prioritization order supports assertion of unrealistic CODs that could easily be changed later, after the awards are secured.

Energy Only (EO) project TPD requests

• TPD Allocation Group qualification (#6):  The proposal provides that EO projects could only seek a TPD Allocation under the Commercial Operation Group, even if they have PPAs or are shortlisted.   LSA strongly believes that this proposal is contrary to the concept espoused by the CAISO of providing scarce deliverability to “most ready” projects most likely to succeed.  By definition, projects that reach COD have already satisfied all the permitting and GIA milestones by definition, and it’s hard to be “more ready” that reaching COD. 

There is no reason why a project that has not even begun construction yet should receive a TPD award ahead of an already-operating project when they have the same PPA status.

• 2025 “last chance” (#6.1):  The proposal at least offers this last opportunity, instead of suddenly removing the opportunity altogether.  However, LSA still believes that Energy Only projects should be allowed to request TPD Allocations in any TPD Allocation cycle in the PPA and Shortlist Groups.  These projects may be considerably more advanced than those still in the study process and should be able to offer that viability proof to move ahead with deliverability.

In addition, LSA supports an additional opportunity for projects that submitted MMA requests to add storage well in advance of the 2023-2024 TPD Allocation affidavit due date but where processing was delayed well beyond the CAISO tariff MMA request processing target timelines.  For example, LSA is aware of at least one such request submitted in August 2023 – six months before the February 2024 affidavit due date – where CAISO approval is still pending.  Thus, the project missed the opportunity to request an allocation in the last cycle.

LSA understands that the CAISO and PTO have many priorities, but it is unfair at this time of major change to penalize Interconnection Customers that responsibly complied with the rules for such significant processing delays.  Thus, developers in this situation – who submitted MMA applications for storage additions three or more months before the last affidavit due date, or by November 1, 2023 – should have an additional opportunity in 2026 to apply for a TPD allocation.

Three tries for TPD Allocation (#5):  The CAISO clarified at the July 15^th meeting that the first of the much-cited three allowed TPD Allocation requests would be the allocation cycle starting during the Interconnection Facilities Study, i.e., before the cluster studies are even complete.  The CAISO said it wanted to provide this “early” opportunity to projects that may be ready to move that soon, (e.g., expansions of projects sharing Interconnection Facilities with earlier-queued capacity).

LSA does not object to allowing projects still in the study process to request TPD – even in cycles starting during earlier studies, if they will qualify and wish to take the risk of proceeding.  However, projects that wish to wait until their studies are complete, and their Network Upgrade cost cap amounts are set, should not be forced to forfeit one of their three tries as a result.

We understand the CAISO’s desire to have the entire cluster “move together” for ease of administration and tracking.  However, there will likely be many fewer new projects in future clusters, and this should not be a reason for forcing projects to move ahead before studies are complete or forfeit one of their three request opportunities.

Fast-Track Project/capacity eligibility for TPD Allocations (additional issue):  LSA sees no substantive reason for prohibiting FT projects (or capacity additions to existing projects) from seeking TPD Allocations, under the same rules as energy storage additions.

TPD request timing for energy storage additions (#6.2):  The Proposal could have two kinds of unintended consequences:

• Potential “gold rush” for the 2025 TPD Allocation cycle, as projects rush to add storage through MMA requests in time to qualify for Group A or B requests; and/or

• Complete cessation of any storage additions after that point, since few or no developers would likely build storage capacity without a TPD award in hand.

Energy storage additions offer cost-effective means of improving system reliability, and the CAISO should carefully consider both of these possible impacts before imposing such stringent rules.

Long-lead-time (LLT) resources (#11):  Stakeholders have asked numerous times for more information on the CAISO’s intentions with respect to LLT resources, and we appreciate the information provided that off-shore wind, out-of-state wind, and geothermal resources are the resources the CAISO will consider.  However, other than citations to GIDAP 8.9.1(b) & (c), the CAISO has not provided responses to the growing number of other questions, e.g.:

• Which areas and how much capacity would be reserved

• How CAISO will distinguish between capacity for off-shore wind (Humboldt, Northern Greater Bay Areas) and the considerable FCDS capacity in the CPUC portfolios in the same areas

• Whether the August C15 information release (Deliverable vs. Merchant Zone definitions, available TPD capacity, POI/constraint updates) will subtract this reserved capacity, and if so, how the CAISO will treat any C15 Interconnection Requests in the identified LLT categories

• How the capacity reservation will be reflected in the various CAISO analyses

• How the reservation process for out-of-state wind will work with the Subscriber PTO (SPTO) processes for TransWest Express (Wyoming) and SunZia (New Mexico)

Stakeholder unease with this concept will continue until all of these questions are addressed.

Moreover, the CAISO should reconsider this entire proposal.  The CAISO is proposing here to reserve capacity for projects that have not even entered the queue yet, but also increasingly stringent requirements (e.g., PPAs) on “long-lead-time” projects with very similar development timelines only because upgrades needed for interconnection and/or deliverability are years into the future. 

The PPA windows for these involuntary LLT projects are similarly outside the procurement windows of most LSE compliance obligations, and at a minimum, the requirements for such projects should be relaxed.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

 LSA supports the concept of allowing projects to use the “headroom” available before RNUs such as circuit breakers.  However, as explained further below, LSA believes that the concept should be broadened in scope and timing, i.e., the proposed one-time implementation of this concept should be extended.

Applicable RNUs:  CAISO said that it had the SCD mitigation in mind specifically, but technically the proposal could apply to any RNUs meeting the timing and project-delay criteria.  For example, new or reconductoring lines, control buildings, and other upgrades can delay CODs. Thus, the CAISO should leave open possible application to different RNUs meeting the proposed criteria.

Applicable projects:  CAISO said it had Cluster 14 in mind due to the number of SCD-related mitigation elements identified in Cluster 14 studies specifically.  While the 150% capacity limits on acceptance of C15 and later projects for study would reduce the need for this type of mechanism later, it is possible that more than 100% of the capacity that can be accommodated will make it through the study process, so the possibility of applications to different clusters should be left open.

However, the proposal could apply to any cluster with upgrades that would meet the criteria, and that this could apply to: (1) later clusters relying on the C14 mitigation measures; and (2) other RNUs for those later clusters, since 150% of available capacity still exceeds available capacity.

“One and done:”  The CAISO’s expectation that this proposal could be implemented once, for C14 circuit-breaker upgrades, seems unrealistic.  Over time, projects awarded “headroom” could drop from the queue and need to be replaced if the mitigation is still needed.  The CAISO should also consider whether projects should demonstrate continued compliance with the award criteria to retain the priority position.

Timing:  LSA supports expedition of this proposal, if possible, so projects don’t have to wait another year to learn if their CODs can be expedited.  This is particularly important for PPA Group projects, which have already made PPA commitments.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

Applicable situation:  It appears that this issue applies to a fairly specific Interim Deliverability (ID) situation – where, in the following order:

(1) A project (call it “Project A”) entered the queue via a regular Interconnection Request (IR);

(2) Another project (“Project B”) entered the queue via a regular IR and received a TPD award;

(3) Project A requested a storage addition via an MMA request and then received a new TPD award for the added storage; and

(4) The Project A storage capacity and Project B both reach COD before the upgrades needed to support their respective TPD awards are not yet complete, so both are relying on Interim Deliverability (ID) to provide Net Qualifying Capacity (NQC) to off-takers.

The proposal would not address situations where, for example, Project A added storage after Project B entered the queue, received a TPD Allocation, and transferred TPD from the original storage capacity to the added storage.  In that case, even though the storage was added after Project B entered the queue, the TPD award date for the original Project A capacity would still apply under the CAISO proposal. 

Similarly, the CAISO confirmed at the June 15^th meeting that the queue position under both the current and proposed ID treatment was the position of the project that originally received the TPD award, the project receiving the transfer.  Thus, the CAISO proposal would not apply in these situations.

Substance of the proposal:  At the June 15^th meeting, many parties said that they have made PPA and other commitments based on the CAISO’s current ID policy, and they requested some kind of grandfathered or legacy treatment for projects in flight, to avoid disrupting these arrangements.  They said revision of this policy without grandfathering/legacy treatment would impose significant financial burdens.  No parties spoke in favor of the CAISO proposal, with or without such treatment.

The CAISO seemed troubled by this suggestion, as it would complicate further the current complex requirements to track TPD awards and rules (e.g., projects that received different allocations at different times and/or under different rules, projects that did not receive requested Group D awards but are still subject to Group D restrictions, etc.).

LSA recommendation:  The CAISO LSA does not see any compelling reason to make this change at this time, especially if the CAISO cannot manage a legacy or grandfathering process.  The circumstances where the CAISO proposal would apply seem very narrow, and it would obviously be extremely disruptive to revise the current policy for projects that have made commitments relying on it (and may be relying on it today).

4. Please provide any additional feedback.

Multi-Year Interim Deliverability Status:  While LSA appreciates the “headroom” allocation and IDS proposals in Track 3B, LSA believes that the CAISO should reconsider the concept of a multi-year Interim Deliverability Status (IDS) framework for inclusion in Track 3.  The CAISO removed this concept from earlier initiatives due to concern that ID would not be available generally, and under the assumption that certain reforms (e.g., earlier FCDS by removing N-2 upgrades) in the Generation Deliverability Methodology Review would provide a viable substitute for such a framework.

However, providing contractual ID assurance only one year before COD is almost meaningless for successful commercialization when many or most projects with TPD Allocations depend on TPP upgrades with 8+ years duration. Many of these TPP upgrades are complex and may be placed into service in a piecemeal fashion, providing incremental capacity over several years. Given this situation, providing a pathway and a means to access deliverability available in the interim is in the interest of CAISO ratepayers.

Studies commissioned by LSA members have shown one or more areas with significant deliverability available several years in advance of the COD extended by PTO delays.  LSA understands that study assumptions for determination of ID several years in advance of project COD can be challenging, but this kind of longer-term ID framework can greatly benefit projects behind such long-lead-time deliverability upgrades.   Applicable award criteria could include specific milestones such as offtake status, financial commitments, NTP issuance, commencement of upgrade payments, etc., with available ID allocated in descending order of this score.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

1. Rename allocation groups

MN8 supports this proposal.

2. Discontinue TPD Allocation Group D

CAISO should implement this proposal on a prospective basis beginning with Cluster 15. For projects studied in Cluster 14 or earlier, and MMAs approved prior to CAISO’s IPE Track 3 filing, Group D should remain an option.

3. Energy Only PPAs

MN8 supports this proposal.

4. Discontinue the parking process

MN8 reiterates comments submitted during IPE Track 2 regarding the importance of reserving deliverability upgrades for specific clusters. If CAISO implements caps on IR intake, then it should also aim for the intake process to be back-to-back with the TPD allocation process. Specifically, CAISO should designate TPP deliverability upgrades to the subsequent cluster (i.e., the first cluster that will take in projects on the basis of deliverability enabled by these upgrades). This means that the deliverability from these upgrades should not be introduced into the TPD allocation process until the next cluster study after their approval, which is the first cluster where they could affect intake levels. This will better align the IR intake process with the TPD allocation process, which will reduce regulatory risk and ultimately result in lower costs for consumers.

As CAISO notes in the Track 3 straw proposal, projects that do not receive a deliverability award in the first attempt will be required to submit a GIA deposit per Order 2023 rules should they choose to remain in the queue and seek an allocation for a second time. In many cases, this will lead the interconnection customer (“IC”) to drop out after its first attempt, because it will often be impossible to accept the risks that come with putting down a GIA deposit without first having deliverability, or a very high degree of confidence that one will receive deliverability in the future, since deliverability is often necessary for a project to be economically viable. It is already difficult to have any confidence that a project will receive deliverability, and many prospective IPE and Order 2023 reforms increase the consequences of not receiving deliverability on the first try. Specifically, these reforms require developers to invest more in early-stage projects, including via site control, readiness deposits, and (likely) maturity indicators to earn points from LSEs on scoring. A project that withdraws after one failed attempt to receive TPD would lose a readiness deposit equal to 10% of its assigned cost allocation for network upgrades (“NUs”) (assuming it had not executed a GIA), and a project withdrawing after a failed attempt to receive TPD at a later time would lose 20% of its assigned NUs. These costs are substantial, and the risk of failing to receive deliverability and forfeiting these costs will be reflected in RA prices and ultimately passed along to consumers. Anything that CAISO can do to reduce uncertainty and regulatory risk regarding deliverability allocation will ultimately benefit consumers.

Along these lines, we also reiterate the requests included in our comments on the Track 2 Draft Final Proposal (February 15) and Revised Straw Proposal (December 19) for CAISO to publish more information on the residual action schemes (RAS) and congestion management protocols to allow ICs to reproduce deliverability studies. Increased transparency on the modeling assumptions used in these studies will enable developers to make informed decisions about likely TPD awards, which will improve the viability of interconnection requests.

5. ICs will have three consecutive opportunities for an allocation

See comments on 4. Further, we request that CAISO confirm that PCDS awards are rationable: i.e., a project that receives a partial award can accept its partial award and keep the remainder of its project in the TPD allocation process until it gets a full award or until it has failed to get an award in three consecutive cycles.

6. Energy Only projects can only seek TPD after achieving COD

MN8 supports a grandfathered version of this proposal for MMAs for battery storage additions. Specifically, any project studied as an Energy Only resource or as an MMA addition that has been fully studied by the time that CAISO files these changes should be allowed to seek a TPD allocation under the status quo rules (i.e., Groups A-D with the current scoring rubric). A prospective implementation of this proposal would ensure that projects that have made commercial decisions based on the current rules would not be adversely impacted by the changing of these rules retroactively.

7. GIA tendering, execution, and securities follow Order 2023

MN8 supports this proposal.

8 and 9. TPD affidavit dates

MN8 supports this proposal.

10. Modifications to TPD scoring criteria

We request clarification as to what benefit expansion projects provide that isn’t already captured in the interconnection intake and TPD allocation processes. In the past, CAISO has cited an increased likelihood of permitting success as a reason why expansion projects are more viable, though the current TPD rubric already awards points explicitly for projects that have made progress towards securing permits. For this reason, we are concerned that awarding additional points for expansion projects is duplicative and therefore unduly preferential.

11. TPD withheld for long lead time projects

MN8 requests more information on the process by which CAISO will determine how much TPD it will withhold for long lead time resources, and how this will be communicated with stakeholders through the TPP and related venues. We also request clarification on whether this TPD will be made available for non-long lead time resources to use on an interim basis.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

We support the current proposal. We suggest that CAISO add to its proposal a process that allows projects to come online under provisional interconnection service in case projects are delayed in coming online. At a high level, we envision this proposal working as follows:

1. CAISO follows its current proposal to reset CODs for affected projects.
2. Each year thereafter, CAISO collects an update from affected projects and refreshes its analysis to see if there is any additional transmission capability because of attrition or delay.
3. CAISO runs a similar process as in Step 1 to allow projects to pull up their in-service dates and interconnect under provisional service.
   1. Projects that had been identified in Step 1 will retain priority over projects on provisional service for accessing system capability.
4. Projects interconnected under provisional service must accept operational constraints that CAISO may need to impose to maintain reliability. Operational constraints can be managed using a maximum set point on resource output.
5. In case there is not enough system capability to support multiple projects that have interconnected under provisional service, CAISO should allocate system capability in a fashion similar to what is used for Interim Deliverability today.
   1. Provisional service would be allocated as a percentage of installed capacity to resources that achieve commercial operation in order of 1) cluster, 2) short circuit duty (SCD) impact as a fraction of their interconnection service level, and 3) overall contribution to SCD.

To improve the usefulness of provisional interconnection service, CAISO should also publish sufficient information to enable ICs to make informed decisions on when to achieve commercial operation. Specifically, CAISO would need to publish the total amount of allowable SCD increase for each constrained area, a list of all affected generators, the CODs of each generator, and the SCD contribution of each generator. We welcome feedback from CAISO and other stakeholders on both the feasibility of this idea and other improvements that might be necessary to ensure that it would be a worthwhile endeavor.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

CAISO should implement its proposed changes to the TPD allocation method on a prospective basis. Specifically, any project that has already received a TPD allocation should be allocated interim deliverability (ID) under the status quo rules (i.e., projects should receive ID in order of 1) cluster, 2) dfax, and then 3) flow impact). All others should be allocated based on CAISO’s proposal, which would insert TPD allocation year as the first tiebreak.

A prospective implementation of this proposal would ensure that projects that have made commercial decisions based on the current rules would not be adversely impacted by the changing of these rules retroactively. It is important that CAISO maintain predictable rules and consistent business practices that uphold marketplace integrity, which contributes to market efficiency and reliability. Changing rules after the fact poses risks to projects with existing commercial arrangements that were structured based on an existing set of rules; it can also increase the perceived regulatory risk in the market and thereby lead to higher underwriting costs, which may have a cooling effect on investment in the market.

There is precedent for prospective implementations of rules that govern the allocation of transmission capability in CAISO. In the early 2010s, when CAISO made changes to its deliverability policies, it introduced a special status for “existing” generation (i.e., generators that had entered the market and been studied under a previous set of rules) in order to prioritize these generators’ access to deliverability when determining net qualifying capacity. The process is described in this revised technical bulletin. This is an example of an instance in which CAISO employed a transitional mechanism to protect legacy generators when adopting a new policy.

4. Please provide any additional feedback.

MN8 Energy appreciates the opportunity to provide feedback on CAISO’s IPE Track 3 straw proposal and looks forward to future discussions.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

New Leaf Energy, Inc. (“NLE”) appreciates the CAISO’s continued leadership in the Interconnection Process Enhancements (“IPE”) initiative and its work on the Track 3-A Revised Straw Proposal and the Track 3-B Straw Proposal. NLE provides comments below on specific Track 3-A proposals.

1. Proposal 5

Proposal 5 states that “[p]rojects will have three consecutive opportunities to seek [a Transmission Plan Deliverability (“TPD”)] allocation.”[1] NLE is concerned with the current proposal because projects seeking TPD during the first allocation cycle in which they are eligible will not yet have received a binding cost cap. The cost cap is not provided until after the Interconnection Facility Study, which will not be complete before that first allocation cycle. The current proposal incentivizes projects, which do not have final interconnection cost information, to apply for TPD before fully knowing how viable the projects are.

NLE recommends modifying this proposal to allow developers to choose when to exercise the first of their three opportunities—either after the Restudy or after the Interconnection Facility Study. This would encourage projects to delay seeking TPD until after they have better visibility into their final interconnection costs. Alternatively, NLE recommends modifying the proposal so that applying during the first allocation cycle following the Restudy would not be counted as one of the three consecutive opportunities. In other words, projects would have three consecutive opportunities to apply for TPD after the Interconnection Facility Study is complete, and if a project chose to seek an allocation after the Restudy, this would not be counted towards one of the three opportunities.

2. Proposal 6

Proposal 6 addresses Energy-Only projects’ eligibility to seek TPD, and Proposal 6.1 states “[p]rojects in clusters prior to cluster 15 that are Energy Only will have one additional opportunity during the 2025 TPD allocation year to seek an allocation under all allocation groups.”[2] However, there is conflicting language earlier in the Straw Proposal that states “[a]ll pre-cluster 15 Energy Only projects will be eligible to seek an allocation in allocation groups A, B, and C in 2025 and 2026.”[3] NLE respectfully urges the CAISO to adopt the later proposal and allow all pre-cluster 15 to apply for TPD through groups A, B, and C in both 2025 and 2026.

Adopting a retroactive rule change that prevents cluster 14 Energy Only projects from applying for TPD in groups A and B beginning in 2026 is unjust. Further, this proposal would raise costs for ratepayers because it would prevent more mature pre-cluster 15 projects from receiving TPD. These projects have remained in the queue and continued to meet development milestones under the assumption that they could convert to Energy Only and later seek a deliverability award through TPD allocation groups A and B. Pre-cluster 15 projects should receive the same number of opportunities to apply for TPD as cluster 15 projects, and cluster 14 projects should be eligible to apply under groups A, B, and C during both the 2025 and 2026 TPD allocation cycles.

3. Proposal 8

Under Proposal 8, “TPD seeking affidavits” would be due on March 15, and “TPD retention affidavits” would be due on February 1, beginning in 2025.[4] The proposal reasons that “[t]he February 1 due date for retention affidavits will allow interconnection customers that are not able to retain their TPD through the retention process to seek a new allocation in the March 15 process for seeking an allocation (if the cluster has not exhausted its three opportunities to seek an allocation).”[5]

NLE recommends the CAISO continue its current practice of having one deadline for both TPD affidavits because two application windows do not appear to be necessary. Developers will know if a project is not able to retain its TPD allocation and should just submit a new TPD seeking affidavit. There is no reason to require these projects to also submit retention affidavits, wait 45 days to confirm they did not retain their allocations, and then reapply for TPD during the second window. If CAISO staff need time to process retention affidavits before reviewing new TPD applications, they should simply take the time necessary to review the affidavits in the desired order after receiving them all on the same date.

Further, NLE recommends that the due date for both affidavits be March 15. The deadline for the 2024 TPD allocation cycle affidavits was February 14, 2024, and developers should be given at least a year to meet the retention requirements before the 2025 allocation cycle. Also, during the IPE Track 2 workshops, CAISO staff indicated that the retention affidavits would not likely be due until March 2025 at the earliest. Developers are currently bidding into solicitations for power purchase agreements and shortlists. They should be given as much time as possible to do so and satisfy the retention requirements.

Additionally, the Straw Proposal’s reasoning for creating two separate affidavit deadlines (i.e., the February 1 due date for retention affidavits would allow projects that are not successful in the retention process to seek a new allocation on March 15) implies that projects will not be converted to Energy Only after failing to retain an allocation—as these projects would continue to be eligible to seek a new award in the second affidavit window. NLE agrees that projects should not be converted to Energy Only after failing to retain TPD. However, NLE notes that this process provides an incentive for projects to accept allocations that they know they will later forfeit because projects that decline allocations would be required to withdraw from the queue under Proposal 4.2.[6] Under the current proposal, all projects will just accept TPD allocations as they would not face a similar withdrawal requirement for failing to retain their awards. It is also unclear why the Straw Proposal requires projects to accept TPD allocations or withdraw from the queue. The CAISO should provide justification for this withdrawal requirement or remove it from the next version of the Straw Proposal.

Finally, in the Track 3 workshop on July 15, 2024, CAISO staff alluded to the fact that under the proposed timeline, the TPD allocation study would include upgrades from the current Transmission Plan, which is scheduled for approval on May 31, 2025—rather than only including upgrades from the prior year’s Transmission Plan. NLE respectfully urges the CAISO to include language in the next version of the Straw Proposal explicitly stating which Transmission Plan’s upgrades will be included in each TPD allocation study.

4. Proposal 10

Proposal 10.1 provides TPD intra-group scoring criteria and adds a new category of points for “Expansions of Existing Facilities.”[7] During the Track 3 workshop on July 15, 2024, CAISO staff provided justification for this new category—claiming that expansions of existing facilities are more viable projects. However, the IPE Track 2 proposal already provides extra points for this type of project during the intake scoring process. Additionally, in rejecting NLE’s proposal to add a local resource adequacy component to the TPD allocation scoring rubric, the Straw Proposal reasoned that these projects are already given an advantage to enter the study through the intake scoring process.[8] NLE asserts that the same reasoning applies here. Therefore, the new category of points for expansions of existing facilities is duplicative and should be eliminated.

[1] CAISO, 2023 Interconnection Process Enhancements, Track 3-A Revised Straw Proposal and Track 3-B Straw Proposal at 19 (July 8, 2024).

[2] Id. at 19-20.

[3] Id. at 13.

[4] Id. at 20.

[5] Ibid.

[6] Id. at 19.

[7] Id. at 21.

[8] Id. at 17.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

NLE does not have any comments on this item.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

NLE does not have any comments on this item.

4. Please provide any additional feedback.

NLE does not have any comments on this item.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

NextEra Energy Resources, LLC (“NextEra Resources”) appreciates the opportunity to comment on CAISO’s Interconnection Process Enhancements (“IPE”) – Track 3A revised straw proposal and 3B straw proposal. NextEra Resources commends CAISO’s commitment to accelerating interconnection progress for the most viable projects to come online quickly. While some aspects of the Track 3A proposal meet this goal, others fall short. NextEra Resources supports the following proposals: [1] renaming the Transmission Plan Deliverability (“TPD”) allocation groups, [5] three consecutive opportunities to seek a TPD allocation, [6.4] a flat fee of $5,000 for Energy Only (“EO”) projects to seek TPD allocation, [7] Generator Interconnection Agreement (“GIA”) tendering and associated financial requirements, [8] 2025 TPD affidavits timeline, [9] affidavit and substantiating documentation requirements, and [10] modifications to TPD scoring and GIA related scoring.

NextEra Resources strongly opposes CAISO’s proposal [3] to limit EO projects, that later provide a Power Purchase Agreement (“PPA”) to modify a Commercial Operation Date (“COD”), to only be allowed to provide a PPA specifying EO product. CAISO does not have sufficient insight into contract negotiations between developers and Load Serving Entity (“LSE”) offtakers. There are various reasons to include contingent language in contracts, including but not limited to the obligation to seek TPD based on any newly approved Transmission Planning Process (“TPP”) upgrades that were not in the plan at the time of the initial TPD allocation request. EO projects still have opportunities to obtain TPD so they should be allowed to include contingencies in the PPA when necessary.

NextEra Resources conditionally supports CAISO’s proposal [4] to discontinue the parking process but requests the following additions: If the option to park a project is removed, all projects must post readiness deposits and continue through the process. NextEra Resources suggests that a project that has already posted commercial readiness deposits be evaluated or scored higher than projects going through the TPD allocation process the first time that have not made any commercial readiness deposits. Posting commercial readiness deposits is a strong indicator that a project is viable and ready to come online. Also, NextEra Resources requests clarification on whether Cluster 14 and earlier projects will proceed with existing processes of seeking allocation and can remain parked until their eligibility for parking is finished.

NextEra Resources opposes CAISO’s proposal [6] to restrict EO projects from only being eligible for a TPD allocation until after they reach COD. EO projects should be allowed to continue to apply for TPD in the “PPA” and “Shortlist” groups going forward, and for avoidance of doubt, prior to COD. Existing EO projects are likely further along in development than later-queued projects. Previous Clusters (Cluster 13 and earlier) were forced to convert to EO due to a lack of TPD from previous cycles [largely due to a misalignment in timing between when network upgrades were approved in the Transmission Planning Process (TPP) and when the TPD allocation cycle was completed]. While CAISO has addressed the misalignment in timing between the TPP and TPD allocation windows in IPE Track 2, many of these earlier projects agreed to convert to EO with the existing TPD allocation rules in mind, which provided an annual opportunity to seek TPD and benefit from TPP upgrades approved after the project’s conversion to EO but prior to COD. Further, as it relates to Cluster 14 projects that didn’t get an allocation of TPD and were required to either park or convert to EO prior to the CAISO’s proposal in this Track 3A, it would be unreasonable for CAISO to apply new allocation rules to any Cluster 14 and earlier EO projects and risk disenfranchising them further when in fact they are more commercially ready than any subsequent project entering Cluster 15 or later. Cluster 14 and earlier should not be subject to seeking allocation in the newly proposed limited allocation groups of A, B, and C in 2025 and 2026.

NextEra Resources opposes proposal [6.2] to restrict energy storage added through the modification process to remain Energy Only and only be permitted to seek TPD through allocation group C, regardless of whether the energy storage addition is via a MMA or Post-COD modification. The addition of storage demonstrates actions the project developer may take to increase the project’s viability and commercial interest, and it advances technology to meet the needs of the grid. Furthermore, the addition of storage could be recognized as being similar in nature to proposing the expansion of a generating facility and should be afforded similar advantages given it provides diversity of generation at a lower cost to customers.

Finally, NextEra Resources recommends that CAISO include a modification to Group A that would remove “Interconnection Customers in the current Queue Cluster that are Load Serving Entities serving their own Load” from the deliverability process. Under the CAISO’s proposed project scoring system (under IPE Track 2), the CAISO has already given priority to LSEs serving their own load to enter the queue. Allowing LSEs to receive preferential treatment again in the allocation of TPD is discriminatory.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

NextEra Resources supports CAISO’s proposal to introduce a new intra-cluster prioritization process, with the caveat that CAISO does not add overly complex scoring criteria. CAISO needs to make it clear when FCDS will become available for projects that were not given priority. Ideally, CAISO would utilize the existing TPD process versus implementing a secondary process that could become onerous. CAISO recommended limiting this new process to just Cluster 14 and short circuit duty reliability network upgrades. NextEra recommends CAISO explore expanding this process to other instances where in-service dates are being delayed because of long lead-time network upgrades.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

NextEra Resources supports CAISO’s proposal, as this change in priority order is a better reflection of the potential readiness and maturity of a project than one initially ranked by their queue position.  This modification aligns closely with the first-ready, first-served principles established in FERC Order 2023. NextEra Resources supports implementing these changes on a comprehensive rather than prospective basis to ensure that they apply to projects that received TPD allocation in earlier years and will help to avoid any further delays to viable projects. While this change will disadvantage some of NextEra Resources’ existing queue positions, we still support it because it's a superior approach to interim deliverability and offers a more comprehensive resolution.

4. Please provide any additional feedback.

CPUC Procurement and TPD Retention Misalignment:

CAISO must address the TPD retention and procurement timeline mismatch for Cluster 14 projects. CAISO has identified that the Cluster 14 report included several long lead-time mitigation projects that push projects’ earliest CODs into 2034. The California Public Utility Commission’s (CPUC) procurement orders do not extend this far, nor is there sufficient time for the CPUC to address this in a new proceeding. Projects awarded TPD in 2024 currently face a deadline of February 2025 to sign PPAs or be shortlisted to retain deliverability. It is very unlikely that LSEs will sign offtake contracts for CODs in the 2030+ timeframe. This creates a real risk that viable Cluster 14 projects will be pushed out of the queue even though many of these projects are located in Integrated Resource Portfolio/TPP aligned areas. NextEra Resources has advocated throughout the IPE initiative that CAISO treat earlier projects fairly and non-discriminatorily in terms of access to deliverability, and failing to address this inconsistency will inadvertently result in more mature Cluster 14 projects getting sidestepped.

Clearway Energy Group identified these timing challenges over a year ago in its presentation at the July 11, 2023, stakeholder working group[1]. Given the lack of time now left for the CPUC and CAISO to coordinate, NextEra Resources supports Clearway’s suggestion of relaxing the TPD retention requirements for projects in the 2024 TPD allocation cycle. For projects awarded TPD in Group D (no PPA/shortlisted), NextEra Resources suggests extending the deadline to show progress towards shortlist or PPA closer to earliest online COD date.

Further, in CAISO’s future allocations of TPD and related notices to Interconnection Customers of such allocation, CAISO should work closely with the Participating Transmission Owners (“PTO”) to more clearly identify the upgrades that the TPD allocations are contingent upon.  That level of specificity would facilitate the negotiation of PPAs to address the commonly existing time gap of when a project can connect to the grid (based on completion of RNUs relative to the time the project can obtain FCDS).

Reservation and Allocation of TPD for long lead-time projects:

CAISO has proposed reserving TPD capacity for resources outside the CAISO and resources internal to the CAISO that are designated as specific resource technologies (and in specific locations) that are needed to meet state policy goals. While NextEra Resources recognizes that offshore wind and out of state wind may be prioritized in the CPUC resource portfolio, it is vital for CAISO to ensure that all viable and ready projects (regardless of resource type) are treated consistently and in a non-discriminatory manner. As NextEra Resources has noted in past comments, given the supply chain and installation challenges that some long-lead time resources must overcome to bring energy to demand centers, it’s equally important that CAISO ensure that California’s ability to meet aggressive decarbonization goals aren’t unintentionally undermined by overlooking resources that can reach earlier CODs.

At a minimum, NextEra Resources requests that CAISO provide more details regarding how TPD will be carved-out for each of these resources, when and for how long, and any associated stipulations. At present, it’s unclear whether these carve-outs are intended to be held in perpetuity or, whether there are some restrictions that can be implemented to allow more ready projects to obtain an increasingly limited amount of deliverability on the CAISO’s transmission system.  NextEra would also note that under the CAISO’s Subscriber Participating Transmission Owner (“SPTO”) model, such stipulations were developed for out of state resources, and the CAISO identified a clear set of criteria that a project must meet before it can apply to the TPD process. The CAISO has not proposed a similar set of criteria for reserving TPD for the other resources identified in the CPUC’s resource portfolio. 

[1] CAISO, 2023 Interconnection Process Enhancements: Track 2 Working Group at 77 (July 11, 2023).

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

PG&E appreciates the opportunity to provide comments on CAISO’s Track 3A revised straw and Track 3 straw proposal.  PG&E provides comments on the CAISO’s Track 3A proposal below but first addresses the need for CAISO to evaluate how to remove speculative and stagnant projects from the existing queue in parallel with the other proposals.

Proposal to Review Scrubbing of the Existing Queue

While PG&E acknowledges the importance of the issues presented by CAISO staff for consideration in Track 3, PG&E also recognizes that the size of the existing queue pre-Cluster 15 continues to be problematic as the inclusion of speculative projects will continue to produce meaningless study results hindering the ability of generators to interconnect efficiently.  For these reasons, PG&E urges the CAISO to expand that scope of Track 3 to undertake a review of how to remove speculative or stagnant interconnection requests from the queue prior to the start of the Cluster 16 studies.  While the Track 2 queue management enhancements adopted by the CAISO Board of Governors in June 2024 will help with removing speculative or stagnant projects from the existing queue, those enhancements will not significantly help until after the likely start of Cluster 16.  One of the actions CAISO can take is to implement the provisions from FERC Order 2023-A in which FERC clarified that “[existing] interconnection customers that have not executed an LGIA or requested an LGIA to be filed unexecuted with the Commission must meet the transmission provider’s new readiness requirements for the relevant study phase, such as updating their respective study deposits, providing commercial readiness deposits correlating to the amounts required at the various stages of the process, and demonstrating site control.” (FERC Order No. 2023-A, P 75)

Track 3A Proposal

PG&E is generally supportive of changing groups A-D of the TPD affidavit process to the PPA, Shortlist, and Expansions groups with the following modifications.

First, PG&E suggests modifications on how projects receive additional points in the PPA category. PG&E does not believe regulatory approval should merit additional points. There is substantial work and time (well over 6 months) associated with writing an Advice Letter, getting an Independent Evaluator report, Energy Division review of the Advice Letter, publication of the Proposed Decision, Commission approval of the PPA, and final and non-appealable approval. If less onerous approvals processes of non-IOUs are considered equivalent to this process, then IOU PPAs would have a higher barrier to obtaining points than non-IOUs. Further, while it is certainly possible for IOUs to request CPUC approval subject to deliverability, investing in this process may not be a good use of CPUC time.

Rather, PG&E supports assigning 5 points to projects that (1) have minimum criteria in their executed PPAs or (2) where the Interconnection Customer is a load serving entity constructing its project to serve its own Load. Minimum criteria could include having an LSE off-taker commitment for resource adequacy for 5 years or more with the addition of a minimum amount of security posting through the TPD allocation process.  PG&E does not support LSE sponsored projects receiving fewer points than any project which has a PPA because LSEs are proposing these projects to reliably serve their own load.

All other PPAs would receive 0 points.

PG&E understands that any project in the PPA, Shortlisting, and Expansions group is eligible for Permitting and GIA points, but that all projects in the PPA group would have priority over all projects in the Shortlisting group, etc.  PG&E would appreciate CAISO clarification on this. In addition, the CAISO should add “final authorization to construct” to gain 10 points in the Permitting category for those projects which do not require government permits.

Finally, PG&E continues to support the CIASO’s proposal to eliminate the parking process that currently allows projects to linger in the queue for the opportunity to receive TPD.  The proposal should eventually help reduce over cluster study volumes but will take multiple years to see the effects.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

While PG&E believes there may be the potential for this proposal to be implemented to enable for timelier and more efficient interconnection of new generation and storage that are behind short-circuit duty reliability upgrades, PG&E would like clarification from CAISO on the following items to help better understand the proposal and its ramifications:

1. When would this evaluation or scoring of projects take place?
2. Would the evaluation be performed using short circuit results from reassessment study and already used appendices? 
3. Breaker margins can change based on Rule 21 projects, WDT projects and base case changes. How would CAISO ensure margin availability?
4. How would projects that have other upgrades with leads time longer than those for short circuit mitigation be considered?

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

PG&E is supportive of CAISO’s proposal to prioritize interim deliverability allocations based on the date the generating or storage unit received the TPD allocation rather than its interconnection request date.  This will help ensure an equitable process exists and prevent interconnection customers with Material Modification Assessment (MMA) submittals for the addition of a second resource to have that resource receive the same queue position and priority for interim deliverability assignment rather than an interconnection customer that entered the queue before the MMA by the first interconnection customer was submitted.

4. Please provide any additional feedback.

PG&E has no additional feedback at this time.  

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

Proposal #6

Pattern Energy appreciates the opportunity to comment on the Track 3A proposal. Pattern Energy generally supports modifications to the TPD allocation process which allocate interconnection and transmission capacity to those projects most valued by the system and most viable to be completed.

Concerning proposal #6, Pattern Energy generally supports the restriction of Energy Only resources to the Commercial Operation group. A project should not be able to bypass the new queue intake rules by submitting an Interconnection Request as an Energy Only project and thus not compete with FCDS requests and then later compete equally for TPD. Without proposal #6, there would be a clear loophole undermining the intent of this allocation process.

Pattern energy appreciates that generator expansions are generally the projects most likely to interconnect, as acknowledged by CAISO in allocating additional points to these projects in proposal #10. Thus, Pattern Energy opposes proposal #6.2 because it would relegate storage facilities added through Material Modification Assessments or Post-COD modifications to the Commercial Operation group, thereby penalizing exactly the projects this process is intended to move forward.

It may be the case that CAISO’s intention with proposal #6.2 is to prevent projects from circumventing deliverability studies for storage additions seeking deliverability.[1] To address this concern, Pattern Energy suggests CAISO create a Surplus Interconnection Service (SIS) queue process, where Pre-COD or Post-COD projects seeking to optimize Interconnection Service and receive deliverability for any additions or expansions would be studied beyond the standard  MMA and Post-COD modification studies.

Pattern Energy reiterates that the proposal should reward projects which seek to interconnect with deliverability, and which are able to secure PPAs commensurately, whether those projects are modifications, queue positions, or take any other future path to interconnection.

Proposal #10

In the same spirit, regarding proposal #10, Pattern Energy supports additional TPD scoring points for expansions of existing generation facilities but asks for clarification of the definition of expansions and of surplus capability.

• Is the addition of storage through a Post-COD modification an expansion? Pattern Energy believes these projects should be allocated expansion points.
• Is the addition of storage through a transfer of Surplus Interconnection Service an expansion? Pattern Energy believes these projects should be allocated expansion points.
• Does surplus capability mean capacity above an existing project’s Net Qualifying Capacity or capacity above an existing project’s nameplate capacity? Pattern Energy believes it should mean capacity above an existing project’s Net Qualifying Capacity.

[1] A modification approved through the MMA process or Post-COD modification process cannot change the overall electrical behavior of the generating facility, but if the modification request followed the deliverability study process, any TPD allocated to the modification was not dispatched in the original Interconnection Request’s Phase I and Phase II studies (now Cluster Study and Cluster Restudy).

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

No comments at this time. 

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

No comments at this time. 

4. Please provide any additional feedback.

Thank you for the opportunity to comment.  

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

REV Renewables (REV) appreciates CAISO’s proposal to revise TPD Allocation, which is a challenging topic considering the critical importance of having deliverability in order to be commercially viable for Resource Adequacy contracts. REV acknowledges CAISO is also working to manage how to align TPD Allocation with the proposals in Track 2 IPE. REV suggests further revisions and clarifications are needed to the straw proposal to provide clear rules on deliverability and so as not to disrupt Cluster 14 projects that have committed significant financial resources to continue towards commercialization. CAISO must ensure it does not discriminate against Cluster 14 and earlier projects (which are further along in the development process) in order to make headroom for Cluster 15 and later projects that have not made significant financial commitments and are many years from commercial operation. In general, REV suggests that any TPD Allocation process changes should apply starting in 2026 TPD Allocation cycle, which is the first year that Cluster 15 may enter TPD Allocation. This would provide a clearer demarcation of the new vs. current/old rules and treat Cluster 14 and earlier projects fairly. REV’s comments on specific proposal items are below.

1. Rename groups - support
2. Discontinuing Group D – REV suggests that CAISO provide a transition for discontinuing Group D so as not to discriminate against projects in Cluster 14 and earlier. In particular, REV recommends that Group D be allowed for 2025 TPD Allocation, but it could be eliminated in the TPD Allocation year when Cluster 15 becomes eligible. This compromise could also help projects that are stuck behind long-lead time network upgrades and not able to secure a PPA or short-list because very few LSEs are procuring out to 2030 or later (which is expected online date for some upgrades). While CAISO is working with CPUC to encourage procurement further out, there is little indication this is changing yet. Therefore, at least one year of additional flexibility could provide time for these procurement timelines to shift and support the proposed TPD Allocation changes.
   • Further, REV requests CAISO provide data on its statement that Group D projects lack the hallmarks of potential commercial success. REV posits that by the nature of getting TPD through Group D, that project is now significantly more viable and able to be more competitive in a procurement solicitation. If Group D is eliminated, LSEs must become more comfortable in short listing or contracting with projects that do not have certainty on deliverability.
3. Energy Only PPA must specify Energy Only - support
4. Discontinuing Parking – REV opposes this proposal for Cluster 14 and earlier, but supports it starting with Cluster 15. Cluster 14 and earlier are not subject to FERC Order 2023, therefore the requirements of that order should not apply. By starting with Cluster 15, this would effectively discontinue parking starting with the TPD Allocation process when Cluster 15 becomes eligible. For the reasons stated in item 2, this should not impact other clusters and would provide additional time for projects behind long-lead time network upgrades. If this proposal does move forward, CAISO needs to provide more clarity and deadlines around when additional financial deposits would be due for currently parked projects.
5. Three consecutive annual opportunities – REV supports this item, but recommends that for Cluster 14 the three-year opportunity start with 2025 TPD Allocation. As discussed in item 2, this can be particularly helpful for projects stuck behind long-lead time network upgrades. While the Track 3B proposal is designed to help projects behind these upgrades, this additional year can also help bridge that procurement timing gap.
   • REV requests clarification on how the three annual opportunities process will work. For example, how will projects be able to determine whether they have deliverability in order to be successful in the procurement process? Is CAISO’s goal that the new POI tool will help projects evaluate deliverability prior to TPD Allocation? Would projects that don’t have a shortlist or PPA still enter the TPD Allocation process for each year (and would not get anything) and have until year 3 to get at least a shortlist? It is currently difficult to be successful in the procurement process if deliverability is uncertain, so if Group D and parking are eliminated, LSEs must become more comfortable in short listing or contracting with projects that do not have certainty on deliverability.
6. Energy Only projects eligible through Commercial Operation group – REV supports this item. REV also suggests that for the 2025 cycle, any project that converted to EO because they could not retain deliverability should also qualify for this under any of the Group A/B/C and D (assuming Group D is retained for a limited time).
7. GIA requirements aligned with Order 2023 – REV supports this for Cluster 15 and beyond, as prior cluster projects should not be impacted by these new requirements.
8. TPD retention and seeking deadlines – REV supports this item, but requests that additional time be given for 2025 TPD Allocation deadlines given that 2024 TPD results were not received until June 2024. REV requests deadlines of April 2025 for TPD retention and May for TPD seeking.
9. TPD Affidavits documentation - support
10. Modifications to the TPD scoring criteria – REV supports most of the modifications, including the addition of scoring criteria for Expansion of Generation Facility. REV agrees with CAISO that expansion projects have a high likelihood of commercial success and should receive additional points in the TPD Allocation. However, REV does not agree that regulatory approval for a PPA should provide additional points, as projects that are contracted with any LSE and do not need regulatory approval should be equally viable for points. REV would support language to expand the approved PPA section to include approval by LSE-governing body. REV also suggests that for Cluster 14 and earlier projects, that site control/land acquisition be added back to the scoring criteria for TPD Allocation since those projects were not required to have site control at intake.
11. Reserving and allocation TPD for long-lead time resources – REV opposes reserving TPD for long-lead time resources, especially if there are other projects that could come online sooner and provide resource adequacy to the grid. If this proposal continues, REV requests more details around the process for TPD reservation, including timing and retention deadlines, and impact to available capacity for future clusters.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

REV greatly appreciates CAISO having a proposal to specifically address Cluster 14 and earlier projects stuck behind long-lead time network upgrades. REV supports this proposal and using scoring criteria similar to the TPD Allocation process to determine priority.

REV supports CAISO’s proposal to use a affidavit similar to the ones used for TPD allocation process. However, it appears that Table 2 for TPD scoring criteria in this paper has modifications. REV requests CAISO to clarify that it plans to remove the land acquisition score from the table, and if so what is the rationale.  As stated above for item 10 response, REV thinks that the land acquisition criterion is a critical demarcation for pre-Cluster 15 projects and would encourage CAISO to take out this criteria only after Cluster 15 enters (which is when projects needs to have site control to enter the process).

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

REV requests clarification on what types of projects this will impact. For example, does CAISO expect this will primarily impact projects that are adding storage, or could it also have an impact on parked projects?

4. Please provide any additional feedback.

 REV has no other comments at this time.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

SDG&E sees some of the items proposed in this section as incremental improvements to a generally positive IPE outcome overall.

• Renaming the TPD allocation groups A, B, C to more intuitive names is a welcome change that cuts down on jargon.
• SDG&E supports discontinuing project parking, as this step will prevent projects from lingering in the queue, taking up deliverability and interconnection capacity.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

SDG&E is generally supportive of CAISO’s proposal. SDG&E believes that improvements to the CAISO tariff could help better align short circuit studies performed as part of the cluster study process with the annual ORS study that SDG&E performs, GIA execution, and milestone date selection. Just like for deliverability allocation, CAISO’s short circuit headroom allocation proposal will provide more certainty to both the developers and the PTOs on how to decide which project moves forward with construction activities without triggering short circuit upgrades. SDG&E looks forward to reviewing more details as part of the stakeholder process to help finalize the CAISO’s proposal. In the meantime, SDG&E believes that the CAISO should:

1. Expand its proposal to all clusters, not just to projects that requested interconnection before Cluster 15. The reason is because short circuit issues will only continue to grow as the IRP portfolios grows; and the IPE track 2 intake scoring procedures might not be sufficient for Energy Only projects. The IRP portfolio is expected to double between 2039 and 2045. This means that more long lead time upgrades will be needed beyond the ones that are currently identified as part of the TPP process. Furthermore, based on the current CAISO tariff, speculative Energy Only projects that will fully pay for their upgrades, could still potentially clog the CAISO queue and trigger long lead time upgrades.
2. Incorporate a process to allocate short circuit headroom availability to projects, following similar approach to what CAISO takes with deliverability allocation today. Furthermore, PTO and developer needs to know before GIA execution if a project will require the start of construction of short circuit upgrades in order to reflect realistic and practical timeline in the GIA’s milestone tables.
3. File this proposal at FERC before Cluster 15 starts to ensure all pre-cluster 15 projects that wishing to move forward with construction activities are clear on whether they will need to fund short circuit upgrades. If the CAISO believes that new affidavits are needed beyond what the CAISO has already received for deliverability, SDG&E encourages the CAISO to share additional details on why new affidavits will be needed.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

No Comment

4. Please provide any additional feedback.

SDG&E offers the following additional comments:

WDAT Impact: SDG&E previously raised the issue of how WDAT generation interconnection capacity (on the distribution side) might impact the way CAISO will calculate available transmission interconnection capacity. No concrete responses or resolutions resulted from those discussions. SDG&E requests that CAISO add this topic to the track 3 discussion.

Energy Only Projects that will fully fund Network Upgrades: Current CAISO has implemented good processes to ensure we do not have a mega cluster for projects that are seeking deliverability or will want to be allocated a portion of the IRP Energy Only procurement needs. However, these processes do not do anything to prevent EO projects that will fully fund Network Upgrades to create a mega cluster in the future. SDG&E strongly recommends that the CAISO require in the tariff that these potentially speculative projects  fully pay their third posting right after GIA execution.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

SEIA appreciates the opportunity to comment on the Interconnection Process Enhancements (IPE) Track 3 straw proposal. SEIA agrees with CAISO that the TPD allocation methodology needs to be modified to align with the tariff changes resulting from IPE Track 2 and FERC Order 2023 compliance. SEIA is concerned, however, that the straw proposal introduces significant uncertainty for independent power producers looking to provide resource adequacy in California which may hinder the state’s ability to achieve its stated clean energy objectives. More specifically, proposal numbers 4 and 5 increase the significance of the first TPD allocation cycle for which a project is eligible; failure to receive a TPD allocation in that first cycle will require interconnection customers execute GIAs and take on significant financial risk to remain eligible for TPD allocation. Projects that do receive a TPD allocation regardless of the cycle will also face a significant mismatch between the timing of the allocation and the date the project is deemed deliverable. The ISO has indicated its preference that projects enter into longer-term contracts to address this timing mismatch, but these long-term contracts are uncommon and uneconomic – it is difficult to secure financing for a project that will not be deliverable for several years.

The straw proposal does not provide independent power producers with sufficient visibility to confidently interconnect to the ISO. Developers will need to speculate potential deliverability upgrades that will be identified and approved in the transmission plan that aligns with their first TPD allocation cycle to have a chance at receiving a TPD allocation, and, as stated above, would then have to account for the long-lead time of that upgrade. This uncertainty will likely put upward pressure on contract prices and make it more difficult for independent developers to compete with the incumbent TOs.

Finally, SEIA does not believe the ISO has adequately justified the need for proposal number 6 to require battery additions made via the MMA process to proceed only as EO.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

SEIA proposes that CAISO proceed with the headroom proposal even if the immediate need is eliminated. As mentioned above, interim deliverability will become even more critical to project viability if CAISO proceeds with the Track 3A proposal.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

SEIA believes that this proposal, if approved, should be implemented prospectively.

4. Please provide any additional feedback.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

In general, the Six Cities support or do not oppose the proposals for the Track 3A modifications to the Transmission Planning Deliverability Allocation (“TPD”) process.  These include elimination of the TPD Allocation Group D (Topic 2), discontinuation of the parking period and adoption of requirements to provide increased commercial readiness deposits and timely execute an interconnection agreement (Topic 4), the availability of three annual opportunities to seek a TPD allocation (Topic 5), and requirements related to projects that are required to convert and subsequently remain in the queue as Energy Only (Topics 3 and 6). 

With respect to Topic 10, the Six Cities concur in the retention of the existing TPD allocation groups (i.e., the “PPA group” f/k/a Group A, the “Shortlist group” f/k/a Group B, and the “Commercial Operation group” f/k/a Group C).  However, for the proposal to formalize a scoring system for TPD allocation within these groups, the Six Cities request a change to the PPA group points in Table 2.  Specifically, Table 2 provides that having a regulatory-approved power purchase agreement (“PPA”) will result in the award of 5 points to a project, while only 3 points are available for interconnection customers that are load-serving entities (“LSEs”) constructing projects to serve their own loads.  The Six Cities do not support this element of the scoring criteria and request that the criteria be revised so that the points allocable to a project with a PPA and the points allocable to a project that is LSE-developed pursuant to local regulatory authority (“LRA”) directed procurement are equal.  As currently proposed, the scoring provides an undue advantage to third-party developed projects, but there is no clear basis for awarding such projects higher points relative to LSE-directed project development.  An LRA decision to approve a PPA should be considered functionally equivalent to an LRA decision to authorize project development for TPD allocation purposes.  For this reason, the Six Cities support allocating each category of projects within a PPA group 5 points. 

As to Topic 11, the Six Cities request that the CAISO revise the discussion to reference LRA portfolio requirements, in addition to California Public Utilities Commission (“CPUC”) portfolio requirements.  Non-CPUC LRAs may authorize procurement of long-lead time resources such as offshore wind, out-of-state wind, and geothermal.  TPD associated with network upgrades needed to support non-CPUC LRA procurement pursuant to policy goals should likewise be reserved and allocated to meet these policy purposes on equal footing to the CPUC’s policy choices. 

The Six Cities take no position on the proposals related to changes to the TPD allocation process that are administrative and/or procedural in nature, including the re-naming of allocation groups (Topic 1), processes and timing for completing interconnection agreements consistent with Federal Energy Regulatory Commission Order No. 2023 (Topic 7), and affidavit deadlines and procedures (Topics 8 and 9). 

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

At this time, the Six Cities do not have comments on the intra-cluster prioritization proposal—namely, the CAISO’s proposal to use an allocation process to enable projects that are able to come online prior to the completion of certain short circuit duty mitigation projects that are pending and may be eliminated depending on project attrition.  It would be helpful in the next iteration of this proposal and/or during stakeholder meetings to provide one or more examples of the situation that the CAISO proposal is purporting to address and how the proposal to use the TPD allocation process would work in practice. 

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

The Six Cities do not oppose the CAISO’s proposal to use the TPD allocation date as the basis for determining priority for awarding interim deliverability, in lieu of the interconnection request date (which is the current approach).  Breaking ties through the successive use of queue position, distribution factor, and then flow impact appears to be reasonable.

4. Please provide any additional feedback.

The Revised Straw Proposal/Straw Proposal (“RSP/SP”) references discontinuation of the Distributed Generation Deliverability process.  (See RSP/SP at 4.)  However, this is not discussed as a stand-alone topic.  Will this be included in the scope of this initiative during a future phase?

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

SCE generally supports the proposed modifications to the TPD allocation process with some modifications.  SCE agrees with the CAISO’s proposal to reduce the number of TPD allocation prioritization categories from four to three and the corresponding groupings – PPA Group, Short-List Group, and Commercial Operation Group – streamlines the existing TPD allocation process and will aim to award deliverability to the most commercially viable projects.  SCE supports EO projects being eligible for a TPD allocation only through the Commercial Operation Group, after the EO project has achieved commercial operation for its entire capacity.  With FERC Order 2023’s requirement for interconnection customers to make certain Commercial Readiness deposits as they advance through the interconnection process, SCE supports the elimination of the parking process as it negatively contributes to projects lingering in the queue without making progress toward commercial operation.  Further, the CAISO’s proposed process would still allow for interconnection customers three opportunities to seek/obtain their sought level of deliverability.  SCE agrees with the CAISO proposal to eliminate Group D because current Group D would likely hinder new projects seeking to interconnect by reducing the amount of available transmission capacity used to determine the amount of capacity to be studied in zones that have available (unallocated) TPD. 

Although SCE generally supports the CAISO’s proposed reforms to the TPD allocation process, SCE opposes the proposed revision within the PPA Group to assign 5 points for a project that has a regulatory approved PPA and only 3 points if the interconnection customer is an LSE serving its own load.  SCE does not support the regulatory approved PPA criteria. Obtaining CPUC approval after contract execution generally takes a half a year, therefore imposing this criterion creates an unintended consequence wherein ICs that sign with LSEs that are required to have CPUC approval of its contracts will be discriminatorily disadvantaged in obtaining deliverability. Specifically, the timeline of CPUC approval will likely cause the ICs to have 0 (zero) points within the PPA group that IC’s first round of the TPD allocation process.  

SCE only files an advice letter or application for approval of a contract after that contract is deemed cost-competitive, viable, and to contribute to its procurement needs by its internal executive risk management approval process. Furthermore, the Procurement Review Group is also consulted on the contract’s quantitative and qualitative attributes. Therefore, SCE believes that imposing the regulatory approval requirement creates an unfair process for obtaining deliverability for IOUs.  Such a structure would jeopardize IOUs ability to meet its mandated procurement targets. 

To ensure that the most viable projects are being prioritized for deliverability within the PPA Group, SCE proposes additional criteria which developers must attest to. SCE proposes to have developers attest to an off-taker commitment greater than 5 years and that they have posted a minimum development security of at least $40/kW to demonstrate that the contract is not an illusory agreement. Furthermore, these criteria will ensure that LSEs are not signing shorter term contracts and there is commercial certainty from a cost and timing perspective. Not imposing such requirements creates an incentive for parties to enter into a PPA with sham terms solely for the purposes of gaining a higher TPD allocation score. 

Furthermore, SCE does not see a distinction in the effectiveness to provide deliverability between a project that has a signed PPA with an LSE and a project owned by an IC that is serving that IC’s own load. As long as the off-taker has a commitment of the project’s capacity and a financial commitment for the development of the project, either through a PPA or through the ownership of the project, that project should be highly ranked within the PPA Category.  Therefore, SCE proposes to remove that distinction. 

SCE also proposes a clarification on the Permitting Category that acknowledges that certain projects, specifically utility owned projects, may not need a permit to construct; rather, these projects qualify for an exemption within section III.B of GO-131-D. Therefore, SCE proposes including either a Permit to Construct or a qualifying exemption within section III.B within the 10-point permitting category.  

Finally, SCE would also like to note that expansion of existing generating facilities still requires a permit to construct or an associated exemption. As written, two identical projects with one attached to an existing generation facility would identify the existing generator as the ideal project; however, both projects would have similar feasibility and schedule. Any advantages that may exist would already be captured within the "Permitting” and “GIA Related Scoring” categories. For this reason, SCE proposes removing the “Expansion of a Generation Facility” category. 

SCE offers the following suggested revisions for prioritizing the projects seeking a TPD allocation (Table 2): 

Permitting Category 

• 10 points category: revise existing language with “Has final government permit to construct” or has the required authorization to construct” 

PPA Category 

• 5 points category: remove PPA regulatory approval requirement and replace with: 

•   -  An executed PPA or an LSE owned project  meeting the following specific requirements: 

•  ----- Minimum off taker commitment (e.g. more than 5 years) 

• ----- Minimum development security posting requirements ($40/kW) posted prior to submitting the TPD affidavit and must remain posted until the delivery date listed in the executed PPA. Project with executed PPAs who have not met this requirement get 0 points.  

• 3 points category: removed. 

• 0 Point: retain this category as is. 

Expansion of Generating Facility 

• SCE seeks confirmation from the CAISO that “Expansion of a Generation Facility” is its intended representation of the 3rd category with 3rd priority (i.e. Commercial Operation Group).  

• SCE requests the CAISO to clarify if permitting points are additive to the points received in either the PPA, Shortlisting, or Commercial Operation categories. 

•  In Table 2 of the Revised Straw Proposal, 5th column, is “Expansion of Generation Facility” the same as “Commercial Operation Group”? 

• SCE recommends the CAISO add a column in the TPD Allocation table that indicates Allocation Rank to make it clear how the priorities work.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

SCE generally supports CAISO’s proposal but would like to understand when CAISO anticipates performing the intra-cluster prioritization assessment (“SCD Study”) for pre-cluster 15 projects and how long CAISO anticipates it will take to rank projects using either a similar TPD allocation scoring mechanism or some other equitable alternative method yet to be considered. SCE would also like CAISO to clarify that projects prioritized through this process would not be subject to a limited operational study for the SCD long lead time upgrade.  SCE encourages CAISO to allow intra-cluster prioritization for long-lead time short circuit duty as an ongoing process and not be limited as proposed. While SCE similarly hopes that right-sizing of the queue and proactive transmission buildout through the TPP will make this prioritization unnecessary, these processes don’t explicitly prevent long lead time short circuit duty upgrades.  Intra-cluster prioritization will help generating customers use available capacity in the event these upgrades are identified in the future. 

SCE encourages CAISO to prevent a project that is still subject to another similarly long lead time upgrade (e.g. within 2 years) from being eligible for intra-cluster prioritization as this conflicts with the goal of using this to fast-track the readiest projects. Similarly, projects that benefit from this process should not be allowed to suspend or request a COD extension through the modification process. These projects must sign a GIA within a reasonable amount of time, such as 4 months after completion of the prioritization study. 

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

SCE supports the proposed modifications to the priority for awarding interim deliverability, which currently gives higher priority to earlier queued projects over later queued projects. SCE agrees that under the current interim deliverability allocation process it is possible for an addition (i.e., battery storage) to an existing queue position which inherits the queue priority of the original project leapfrogs a later queued project already established in the interconnection process for years before the battery facility was added.  Awarding interim deliverability based on the date the generating facility unit received the TPD allocation rather than its interconnection date should be an effective means to prevent the inappropriate jumping ahead of a later queued project. 

4. Please provide any additional feedback.

SCE has no additional comment at this time.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

Terra-Gen, LLC (Terra-Gen) appreciates the opportunity to provide initial comments on CAISO’s Interconnection Process Enhancements 2023 Track 3 proposals.

Proposal 1 – Rename allocation groups: Support.

Proposal 2 – Discontinuation of Group D: Terra-Gen recognizes the importance of aligning the TPD allocation process with use of TPD availability in determining interconnection study queue sizes. To achieve this, Terra-Gen recommends that CAISO proposes a transition to removing Group D and parking opportunities (also see feedback on Proposal 4 below) while implementing the proposed three annual TPD allocation opportunities.

Terra-Gen believes that projects in Cluster 14 and earlier should be grandfathered to allow them to utilize both Group D and parking, preferrable during the three subsequent TPD allocation cycles, but at minimum at least for one additional TPD allocation cycle for the 2025 TPD allocation cycle. Thereafter, Group D and parking could be phased out for all projects from all clusters. This change would enable the 150% study limit for later clusters to accurately reflect the proposed TPD allocation adjustments.

Proposal 3 – Energy Only project PPAs must specify Energy Only product: Support.

Proposal 4 – Discontinuation of Parking Process:  Terra-Gen supports discontinuation of parking opportunities if CAISO clarifies that Cluster 14 and earlier clusters may still exercise parking under existing rules until they are no longer eligible as a transition mechanism.

Proposal 5 – Three consecutive TPD allocation opportunities: CAISO clarified that the initial TPD allocation request opportunity will occur during the Interconnection Facilities Study phase, prior to cluster study completion. The intent is to accommodate projects, such as expansions of existing facilities, that may be prepared to proceed early. Terra-Gen supports offering this option to projects willing to assume the associated risks, however, projects should not be compelled to request TPD allocation because this initial TPD allocation will occur before the Projects’ study is completed and before project network upgrade cost caps have been determined. Terra-Gen believes that projects choosing not to participate in the initial TPD allocation opportunity should not be required to forfeit a valuable allocation opportunity and they should be allowed to participate in three subsequent, consecutive TPD allocation opportunities.

Although the CAISO proposal aims to streamline the process by advancing the entire cluster simultaneously, the anticipated decrease in new project volume for future clusters suggests that this should not necessitate premature project advancement.

Proposal 6 – Energy-Only projects TPD allocation group restriction: Terra-Gen strongly opposes the proposal restricting Energy-Only (EO) projects to seeking TPD allocation exclusively within the Commercial Operation group. Such a limitation contradicts the CAISO’s stated objective of prioritizing “most ready” projects for scarce transmission plan deliverability. By definition, projects achieving Commercial Operation have already fulfilled all permitting and grid interconnection approval requirements, representing the highest level of project readiness.

It is contradictory to allocate TPD to a project yet to commence construction over an operational project, especially when both possess comparable power purchase agreements (PPAs). Terra-Gen recommends allowing EO projects that have achieved commercial operation to compete for TPD allocations in any TPD allocation cycle within the PPA and Shortlist groups. Advanced EO projects may exhibit significantly greater viability than those still in the study phase and should be afforded the opportunity to demonstrate their eligibility for TPD allocation. Furthermore, CAISO has pointed to past experience with EO project viability as justification for this proposal, but it is shortsighted to assume that past experience will continue in the future under the drastic transformational changes that CAISO has proposed in its Order No. 2023 compliance filing and IPE 2023 Track 2 and Track 3 proposals, thus it is prudent to still allow for this opportunity for EO projects to have a reasonable path to achieve TPD allocation.

• Proposal 6.1 – Last opportunity for EO to seek TPD allocation in 2025: Terra-Gen opposes CAISO’s last chance proposal. Terra-Gen recommends allowing EO projects to request TPD allocations within any TPD allocation cycle designated for projects with PPAs or shortlisted projects. Given their potential advanced development compared to projects still undergoing the study process, EO projects should be afforded the opportunity to demonstrate their readiness for deliverability.
• Proposal 6.2 – Energy Storage addition timing via modification process: Terra-Gen strongly opposes the CAISO's proposal mandating energy storage additions as Energy Only projects and restricting their TPD allocation eligibility to the Commercial Operation group, irrespective of whether the addition occurs before or after COD.

Energy storage additions are essential to enhancing grid reliability, mitigating renewable energy curtailment, and achieving the state's ambitious climate and policy goals. These additions represent cost-effective solutions to adding needed capacity to existing queue positions and should be encouraged by CAISO. Terra-Gen urges the CAISO to reconsider this proposal and conduct a thorough evaluation of potential impacts before implementing such restrictive measures.

Proposal 7 – GIA Milestones: Support.

Proposal 8 – TPD affidavit due dates: Terra-Gen recommends CAISO consider a single affidavit deadline for both retention and seeking allocation affidavits to be due each year on March 15.  Based on Terra-Gen’s experience, developers typically possess clear knowledge of their eligibility for retaining prior allocations. Given the straightforward nature of retention requirements, a bifurcated process is unnecessary. Projects should be allowed to submit both retention and seeking TPD affidavits concurrently as part of the proposed aligned submission timing requirement.

Developers requiring retention necessitate additional time to fulfill compliance obligations. Historically, both retention and TPD seeking affidavit deadlines occurred in early December, approximately nine months after the preceding cycle's TPD allocation results were announced around the previous March. This timeline proved to be restrictive for compliance activities.

Considering the 2023-2024 TPD allocation results release on May 31, 2024, a February 1, 2025, retention affidavit deadline would afford developers only eight months for compliance. To accommodate necessary retention activities, such as executing PPAs for Group B or securing shortlist/active negotiation positions for Group D, Terra-Gen recommends a minimum March 15th deadline for retention affidavits. CAISO could potentially extend the TPD seeking affidavit deadline to mitigate potential workload challenges.

Proposal 9 – TPD allocation assessment based on due-dates: Support.

Proposal 10 – Modifications to the TPD scoring criteria: Terra-Gen generally supports the proposed modifications with one caveat. Terra-Gen recommends that CAISO modify the proposal for the PPA Group’s regulatory-approved PPA criteria as follows:

• Full points should be awarded for PPAs that can become effective without requiring any regulatory approval.
• Full points should be awarded for PPAs where the necessary approval authorities (which may differ from Local Regulatory Authorities, such as CCA Boards, municipal utility City Councils, or utilities directors) have granted approval.
• Full points should be awarded for executed PPAs with non-Load Serving Entities (LSEs), provided the PPA has been approved by the relevant approval authorities (e.g., Boards of Directors, procurement management, or other entities with final approval authority).

Proposal 11 – Long Lead Time deliverability reservation process:  Several stakeholders have repeatedly sought clarification on the CAISO's intended approach to LLT resource deliverability reservations, specifically regarding offshore wind, out-of-state wind, and geothermal projects. While the CAISO has identified these as potential LLT resources, critical questions remain unanswered, including the specific regions and capacity to be reserved, differentiation between offshore wind capacity and existing Full Capacity Deliverability Status (FCDS) capacity, the impact of reserved capacity on Cluster 15 information releases and interconnection requests, the integration of reserved capacity into CAISO analyses, and the coordination between capacity reservation and Subscriber Participating Transmission Owner (SPTO) processes for out-of-state wind projects.

To address stakeholder concerns, Terra-Gen requests CAISO provide a comprehensive proposal and outline the related information regarding the methodology and transparence for determining TPD held back for LLT resources and its implications for other processes, such as the 150% zonal study limit. To further enhance transparency, Terra-Gen recommends incorporating a "Reserved TPD" line item into the Constraint Mapping with TPD Allocated spreadsheet that CAISO has indicated will be updated in mid-August. This addition will provide valuable insights for Cluster 15 interconnection requests. CAISO cannot continue to defer providing these key details to the development community regarding such an important and significant issue impacting existing and future queue positions.

In addition to the above recommendations, Terra-Gen also requests that CAISO seriously consider the potential impact of LLT deliverability reservations on existing projects that have advanced to more developed and highly viable status, particularly those solar and storage projects that will be thwarted by the CAISO’s reservation of LLT deliverability. 

Many developers have spent significant time and money in the advancement of previously viable projects that may now be made entirely unviable due to the inability to receive some portion of deliverability. Terra-Gen has recommended that this impact be clarified and made transparent in our above recommendations, however CAISO should also seriously consider how it can mitigate the likely impacts of such a drastic change in practice on those resources that are currently advancing and must receive some TPD allocation to achieve commercialization.

In developing TPP transmission for LLT resources, Terra-Gen recommends CAISO should consider the other viable projects in each transmission area and consider the development of the TPP to include some additional capacity which could be utilized for addressing deliverability needs of other non- LLT projects, and variations of the amount and timing LLT projects, and the accuracy of the amount of TPD that would be enabled based on the recommended TPD project.

For example, the approved new Humboldt-Collinsville 500kV project to accommodate the offshore wind in the Humboldt area might not be adequate for the entire portfolio of Offshore Wind in the CPUC IRP.  Terra-Gen takes this opportunity to explain one current example that can inform the need for the above mentioned flexibility; Extending the 500 kV transmission line from Collinsville to the Tesla 500kV Substation would represent only a modest capital cost, and the resulting upgrade will not only create enough TPD for all of the Offshore Wind in the Humboldt area, but also it will create incremental TPD that might be utilized by either other ready projects or additional offshore or other LLT projects. Terra-Gen also highlights that CAISO should consider interim options to release some deliverability to mitigate the impacts of LLT deliverability reservations. For example, given the extended timeframe to reach in-service dates for the recent TPP policy-driven projects, CAISO should consider interim solutions to create some TPD on a case-by-case basis to allow TPD allocation to the most viable and ready projects.

Terra-Gen also notes that the impacts of the proposed LLT deliverability reservations are heightened and increase concerns for existing project development of non-LLT resources in affected areas of the system. For example, in the CPUC’s 2035 30 MMT Base Case IRP busbar mapping portfolio, the CPUC has transmitted 1,900 MWs of FCDS Battery Storage at the 230 kV and 115 kV level mapped to the North of Greater Bay Area planning area,  with a total of 5,264 MWs of FCDS resources, including 1,446 MW of Offshore Wind mapped to the North of Greater Bay Area planning area.[1] In contrast, CAISO’s approved 2023-24 TPP Base Case portfolio includes only 674 MWs of FCDS battery energy storage while also including the full 1,446 MWs of Offshore Wind mapped in the busbar mapping portfolio, and a total of 2,895 MWs of FCDS resources.[2]  This discrepancy in TPP and IRP resource portfolio treatment and mapping appears to undercut the ability for the TPP to identify transmission for up to ~1,226 MW of energy storage resources, which are non-LLT resources and have been mapped to the planning area by the CPUC IRP process.  This discrepancy is concerning itself, but is even more concerning when CAISO is planning to reserve the full amount  of mapped OSW MWs under its new LLT deliverability reservation process. The likely outcome of this combination of Base Case portfolio adjustments and LLT deliverability reservations will be to undermine a significant volume of new battery energy storage projects that have been under development in the North of Greater Bay Area planning area.  This is just one area example and other planning areas are likely to experience similar challenging outcomes for non-LLT resources. Overall, these concerns rise to the level of challenging the ability for some resource types in some areas of the system to receive due process and open access treatment and CAISO should consider how to best address these issues concurrently with its efforts to reserve capacity for LLT resources.

Terra-Gen requests CAISO consider including a mechanism into its TPP and TPD allocation reservation proposal to allow some amount of LLT reservable capacity to be released for interim use by other non-LLT resources, or to include some portion of additional headroom in the transmission studies in the TPP to allow for resource diversity and avoid blocking significant areas of prospective development from entire classes/technologies of resources.

Terra-Gen believes that CAISO should seriously consider these concerns regarding the potential for open access to be threatened by significant areas of the CAISO’s system becoming effectively blocked from development for only a subset of resource types. Many of the significant amount of solar and storage resource projects that have been advanced in prior clusters and Cluster 15 will be needed to meet the State’s policy and carbon-reduction goals. Such projects can also provide cost-effective reliability services and resource adequacy and all viable queue positions should have a fair opportunity to receive TPD allocation opportunities to achieve commercialization. Therefore, Terra-Gen recommends that CAISO should consider proposing some related planning mechanism or interim deliverability allowances for resource locations that will be impacted by the proposed LLT deliverability reservation process.

[1] See: CPUC and CAISO staff technical adjustments to the final 30 MMT base case portfolio (2035) — Updated 2035 Busbar Mapping Dashboard.

[2] See: CAISO Board Approved 2023-2024 Transmission Plan, Section 3.5.1 PG&E North of Greater Bay Interconnection Area, Table 3.5-1Base Portfolio.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

Terra-Gen supports the concept of allowing projects to utilize available capacity before the installation of necessary Reliability Network Upgrades (RNUs), such as circuit breakers. While recognizing the CAISO's focus on Short Circuit Duty (SCD) mitigation for Cluster 14 projects, Terra-Gen believes this concept should be expanded in both scope and duration beyond a one-time implementation. The potential for project delays extends beyond SCD mitigation, encompassing other RNUs like new or reconductoring transmission lines, control buildings, and other various RNU upgrades. Therefore, the CAISO should consider applying this concept to any RNUs meeting the specified criteria. Terra-Gen also recommends that CAISO should explore expanding the use of this new process to other instances where in-service dates are being delayed because of long lead-time network upgrades.

Similarly, while Cluster 14 is the initial target due to its identified SCD mitigation needs, the possibility of exceeding capacity limits in subsequent clusters cannot be ruled out. Terra-Gen recommends maintaining flexibility to apply this concept to future clusters as needed. This approach accommodates projects reliant on Cluster 14 mitigation measures and addresses potential capacity constraints arising from other RNUs in later clusters.

Terra-Gen believes the CAISO's expectation of a one-time implementation for Cluster 14 circuit breaker upgrades is unrealistic. Over time, projects granted "headroom" may withdraw from the queue, necessitating replacements to maintain mitigation effectiveness. To ensure ongoing program efficacy, the CAISO should consider implementing a mechanism to verify continued project compliance with award criteria.

Terra-Gen supports expediting this proposal to enable projects to potentially accelerate their CODs without unnecessary delay. This is especially critical for projects with existing PPAs, which have already made significant financial commitments.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

Terra-Gen recommends the CAISO explore transmissional measures to mitigate disruptions to existing contracts. A comprehensive assessment of the potential impact on projects currently receiving interim deliverability would be beneficial. For instance, the CAISO could analyze the number of earlier queue projects that might lose interim deliverability under a proposed shift from queue position to TPD allocation date. Additionally, Terra-Gen requests an update on the timeline for addressing the previously discussed concept of multi-year interim deliverability.

Numerous stakeholders expressed concerns about the potential financial burden of revising the interim deliverability policy without grandfathering or legacy provisions for existing projects, as many have made significant commitments based on the current policy. No parties voiced support for the CAISO's proposal, regardless of whether such provisions were included.

While acknowledging the CAISO's concerns about increased complexity in tracking TPD awards and rules, Terra-Gen aligns with the Large-scale Solar Association (LSA) position that CAISO has failed to put forth compelling reasons for immediate policy changes, especially in the absence of a manageable legacy or grandfathering process. The proposed changes appear narrowly applicable and could severely disrupt projects that have made commitments based on the existing policy.

4. Please provide any additional feedback.

 No additional comments.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

Page 18, CAISO Proposal #2: Elimination of Allocation Group D

Upstream supports the elimination of Allocation Group D.  Allocation Group D effectively worked as a transition away from the pre-2021 IPE Allocation Group C – Proceeding to Commercial Operation.      

Page 19, CAISO Proposal #6: New and Existing EO Projects Only Qualify for Allocation Group 3 – In Commercial Operation

Upstream understands the need to ensure that only commercially viable projects remain in the interconnection queue, but strongly opposes CAISO’s proposal to relegate Energy Only Projects to Allocation Group 3. 

1. A parked project cannot negotiate its LGIA unless it comes out of parking or converts to Energy Only.  Over the pasts several years, many projects have voluntarily converted to Energy Only under CAISO’s guidance so that they could proceed with execution of their LGIA.  After the reforms CAISO enacted in the 2021 IPE, this did not place a EO project at a disadvantage to a queued project that was FCDS.  CAISO’s proposal to relegate Energy Only projects to Allocation Group 3 would be a complete “about face” from policy that CAISO and stakeholders agreed to in the 2021 IPE.  
2. The time required to entitle and permit a utility-scale solar or wind project in California under CEQA or NEPA can take more than five years.  Many of the projects coming online to meet current MTR obligations entered the interconnection queue in QC10 (2017), QC11 (2018), or QC12 (2019).  CAISO implies in their proposal that a project that recently entered the queue in QC14 or QC15 would be more viable than an earlier queue project – this is false.  A review of CPUC and CCA Board approved MTR contracts shows that a substantial number of projects coming online to meet LSE obligations were energy only before receiving an allocation.

If CAISO is intent on proceeding with this proposal despite strong stakeholder opposition, then a transition should be implemented that allows Energy Only projects to seek an allocation from any of the eligible Allocation Groups in the next two consecutive TP Allocations.  This approach is warranted considering CAISO and stakeholders agreed in the 2021 IPE (only several years ago) that EO projects and FCDS projects would be eligible for the same Allocation Groups.  

Page 19, CAISO Proposal #6.1: Energy Only Project Prior to QC15 Will Get One Last Opportunity to Obtain TPD

Upstream opposes CAISO’s proposal to allow EO projects a single opportunity in the next TP Allocation on the grounds that it’s insufficient.  In the 2021 IPE, CAISO modified the Allocation Groups so that Energy Only projects were treated similar to FCDS projects and could qualify for Allocation Groups A through D.  Responding to this policy decision, Interconnection Customers at the guidance of CAISO converted projects to Energy Only to proceed with negotiating their LGIAs.   If CAISO views Energy Only projects as not viable, then why were these projects elevated to the same status for the TP Allocation as FCDS projects only a few years ago?  

If CAISO insists on moving forward with this proposal, EO projects should be allowed to seek an allocation from any of the eligible Allocation Groups in the next two consecutive TP Allocations.  CAISO will have eliminated Allocation Group D, which means these Energy Only projects will only receive an allocation through Allocation Group A (PPA) and Allocation Group B (Short-list).  If EO projects truly aren’t viable as CAISO beleives, then these projects won’t be eligible for Group A or Group B and won’t receive an allocation in the next two consecutive TP Allocations (and therefore not harm any other projects in the queue).    

Page 20, CAISO Proposal #8: TP Affidavits Due February 1, 2025

What is the rationale of starting the TP Allocation on February 1, 2025 rather than wait until after the CAISO Board approves the policy-driven upgrades put forth in the 2024/2025 Transmission Planning Process?  If CAISO eliminates Allocation Group D, then wouldn’t the TP Allocation be more effective if CAISO waits until the policy-driven upgrades are modeled in the deliverability study so that CAISO gets the most “bang for its buck” in terms of allocating deliverability to projects qualifying for Groups A and B?

Page 23, CAISO Proposal 11: Reserving TPD for Long-Lead Resources

Upstream opposes reserving TPD on the grounds that it will ultimately harm ratepayers through increased costs and stranded transmission assets.  Project development carries significant risks that is currently worn by project developers.  Reserving transmission capacity for speculative projects utilizing unproven technologies shifts a portion of the risk onto the ratepayer.  Offshore wind has performed horribly in New England and saddled ratepayers with significant costs.  Offshore wind in California carries significantly more technological challenges than offshore wind in New England.  

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

Upstream supports this proposal pending further development of the “TPD like” allocation process.     

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

Upstream supports the CAISO proposal related to interim deliverability.   

4. Please provide any additional feedback.

1. Please provide your organization’s questions or comments in response to the Track 3A: Modifications to TPD Allocations. Please reference the proposal’s numbered item you are commenting on.

Wellhead Electric Co. Inc. (Wellhead) appreciates the opportunity to provide comments on CAISOs IPE Track 3A revised straw proposal and 3B straw proposal. CAISO has demonstrated an openness to flexibility in this initiative and is expressly seeking feedback to make adjustments to ensure that the policies are effective for all stakeholders.

2. Please provide your organization’s questions or comments in response to the Track 3B: Intra-cluster prioritization.

Wellhead fully supports the CAISO proposal for  Intra-Cluster Prioritization for Use of Existing SCD/RNU Headroom.

3. Please provide your organization’s questions or comments in response to the Track 3B: Interim deliverability.

Wellhead respectfully submits that that the CAISO-proposed changes to the method of allocation of interim deliverability is an indirect method of dealing with the CAISO-described fairness issue and will have dramatic, negative consequences for projects that have signed PPAs and received TPD allocation via Group A.

The CAISO-described problem (stated on the first stakeholder call) is that a fairness issue arises when a battery facility is added to an existing queue position through the MMA process and inherits the queue priority of the original project, thereby jumping ahead of a later queued projects already established in the interconnection process (perhaps years) before the battery facility was added.

Wellhead has several earlier-queued Interconnection Requests in the CAISO Queue with executed LGIA’s. Our earlier-queued projects did not receive their position through an MMA process. These projects are now in late-stage development and have entered commercial arrangements (including executed long-term PPA’s) and received deliverability allocations under Group A. Wellhead structured its commercial commitments based upon the “rules set” as it existed at the time of execution, including the present Interim Deliverability allocation methods in the GIDAP, confirmed by CAISO in the recent presentation for stakeholders. We understand that other stakeholders have behaved similarly.

CAISO’s proposed changes to the Interim Deliverability allocation method in the GIDAP will have a material adverse impact on our earlier queued projects with severe financial consequences because the CAISO-proposed change to the allocation method will reduce the probability of our (or any) earlier queued projects receiving Interim Deliverability awards in the future. The material adverse impacts include, but are not limited to:

• Rendering our projects uncertain of being able to perform their long-term commercial obligations with:
  • Forfeiture risk of the performance security, and
  • Possible termination for event of default
• Threatening the placement of capital by financing parties, and
• Unreasonable risk of project attrition.

Wellhead strongly urges the CAISO to address the stated problem by adjusting the priority for awarding Interim Deliverability as follows:

• Maintain initial priority for earlier queued projects, and
• Establish queue positions for MMA projects via the request date of the MMA instead of using the queue position of the original project. This approach will be more in line with the result which would have occurred had the project been interconnected via Independent Study.

If the CAISO is unable to abide by the preceding recommendation, then Wellhead strongly urges CAISO to retain the existing rules in the GIDAP for all TPD allocations made to date, and to only change Interim Deliverability allocation procedures on a going forward basis. Under this proposal, all future TPD allocation cycles would automatically be prioritized after the present group of projects that have been awarded TPD.

4. Please provide any additional feedback.