Comments on Final Proposal

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

ACP-California appreciates CAISO’s work to provide an intra-cluster prioritization process to help connect more resources in a timely manner. As part of this proposal, CAISO indicated that customers submitting information for the intra-cluster prioritization will need to submit that information by August 15, 2025, which raised concerns that CAISO was accelerating the affidavit date for all projects participating in the 2025 TPD allocation cycle. In the Updated Final Proposal, CAISO added language that states that the dates in Table 2 (including the August 15^th date) “only refer to the intra-cluster prioritization schedule.” ACP-Calfornia reads this to indicate that CAISO will, therefore, retain the September 1, 2025 due date for affidavits for the 2025 TPD allocation year (in other words, the timelines in this market notice remain valid). However, we request that the CAISO clarify this via a new market notice or in another written/documented manner. It is critical for those that will be seeking TDP, or are seeking to retain it in the 2025 TPD allocation cycle, have a clear understanding of the timelines they are operating under. And while an acceleration of a few weeks acceleration of the deadline may not seem all that significant, it is incredibly impactful and problematic for developers and the offtakers they are working with. Thus, we would appreciate CAISO retaining the September 1^st deadline for the regular TPD cycle and clarifying the retention of this date in a formal manner.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

 No further comments at this time.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

 No further comments at this time.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

ACP-California appreciates CAISO’s efforts to consider measures necessary to address the unique needs of Long Lead-Time resources in the IPE Track 3 initiative. In order to achieve the state’s policy objectives and ensure that transmission approved or identified specifically for these resources is available for them, it is necessary for CAISO to reserve the deliverability that was approved to support these resources. CAISO’s proposal to provide more information on where TPD is reserved under the CAISO’s existing authority to reserve capacity for these resources will improve transparency and should be applauded. By providing transparency to all customers and stakeholders while closely coordinating with Local Regulatory Authorities on their requests to reserve certain transmission capacity for long-lead-time resources that require it, the CAISO can provide a fair and effective pathway for the unique circumstances of long-lead time generation resources. We applaud CAISO for these efforts.

While we are disappointed that CAISO has decided to postpone consideration of the proposal to provide Long-Lead-Time resources with an opportunity to defer their chances to secure TPD, we appreciate that additional time may be helpful to further refine this proposal. We look forward to working with the CAISO on this proposal in an upcoming IPE initiative. We urge CAISO to start that new initiative as soon as possible (ideally in late Q2 or early Q3 2025) to ensure that there is sufficient time to consider the Long Lead-Time proposal and other enhancements and implement them ahead of the opening of Cluster 16. We continue to believe that a deferral program similar to the proposal CAISO developed previously will be essential for LLT generation projects dependent on central procurement, where procurement opportunities will be limited and scheduled multiple years out. And, as this process continues, we ask that CAISO consider applicability of these opportunities to C14 or C15 customers that may be in the middle of their “three chances to secure TPD but could benefit from a deferral option.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

Please see response to quesiton 4 regarding Long Lead-Time Resources in the next IPE. And ACP-California looks forward to putting foward other ideas going forward.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

AES Clean Energy, “AES”, appreciates the opportunity to submit comments on the Interconnection Process Enhancements Track 3 Final Proposal. AES supports the proposal to allow the additional use of the existing short-circuit duty/ reliability network upgrade (SCD/RNU) headroom. AES requests the CAISO to clarify the intra-cluster prioritization process schedule. In the Final Paper, it states that the affidavits are due August 15, 2025 while the stakeholder presentation states August 1, 2025. To be aligned with the remainder of the transmission plan deliverability (TPD) affidavit due date, AES recommends the CAISO changing the affidavit for headroom due date to September 1, 2025, for simplicity.  

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

?For the 2025 TPD allocation cycle, AES supports keeping the existing allocation Groups A-D. For the 2027 TPD allocation and beyond, AES is not opposed to the changes to the TPD allocation groups: PPA Group, Commercial Operation Group, and Conditional Group. However, AES continues to oppose Energy Only projects’ inability to seek a TPD allocation once it reaches commercial operation. AES believes this prohibition works counter to the CAISO’s goal of ensuring that the most ready projects receive TPD. Energy Only projects that reach commercial operation have demonstrated their ability to be viable and should be provided with the opportunity. In addition, AES continues to oppose requiring technology additions to Cluster 15 and beyond projects to only be able to seek TPD once they have reached commercial operation. AES notes that storage additions are usually added as a grid benefit and eliminating its ability to seek TPD until it reaches commercial operation can jeopardize storage deployment onto the grid.  

The CAISO stated at its February 25, 2025 stakeholder meeting that TPD transfers are limited to the existing rule that requires the projects to be at the same POI and voltage level. The CAISO should clarify if this rule applies to Cluster 15 and later projects. The Final Proposal currently states, “For Cluster 15 and later projects, intra-cluster transfers will be permitted for projects in the TPD Study Group…”¹ From this language, it appears that intra-cluster TPD transfers are allowed as long as the projects are in the same study group, which AES interprets as projects in the same zones can transfer deliverability to one another.  The CAISO should also clarify if the existing rule also applies to Cluster 14 projects transferring deliverability to Cluster 15. AES recommends the CAISO permit TPD transfers if they are within the same study group and have the same Dfax value, rather than requiring the projects to be at the same POI and voltage level.  

¹ Track 3 Updated Final Proposal, p. 42.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

?AES supports the CAISO proposal to adjust the 2nd interconnection financial security posting for Cluster 14 to May 29, 2026. This is sufficient time between the postings of the 2025 TPD allocation results and making the second interconnection financial security posting. In addition, AES is not opposed to the additional opportunity to extend a project’s COD by ten months. 

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

?AES has no comment. 

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

?AES appreciates the CAISO willingness to consider additional changes to the next IPE initiative. At this time, AES recognizes three concerns with the new interconnection landscape.  

Lack of certainty of available TPD: There is no certainty that the 150% of existing transmission capacity is still going to be available once the cluster reaches the TPD studies. Given that every cluster admits 150% of the available transmission capacity, once that cluster reaches the TPD studies, there is no guarantee that TPD is still available because a previous cluster could be allocated the TPD. AES recommends that the CAISO consider a reservation system, where the CAISO reserves a 100% of the deliverability for the incoming cluster to ensure that the cluster can properly compete for the TPD once it reaches the TPD allocation studies.  

Lack of regulatory oversight on commercial interest points: AES continues to be concerned about the lack of regulatory oversight on the allocation of commercial interest points from load-serving entities (LSEs). For the Cluster 15 process, AES has seen a large variation of deposits required from LSEs, with some deposits that are non-refundable regardless of whether the project enters the interconnection queue study. Given the lack of granularity of points in the scoring criteria, the commercial interest points from LSEs are crucial in a project’s ability to enter the interconnection study. AES recommends the CAISO to work with the CPUC to identify methods in regulating the commercial point allocation process to ensure that deposits are within a reasonable range and refundable depending on whether a project enters the interconnection study.  

LGIA execution prior to TPD allocation: AES recommends the CAISO to amend the LGIA execution requirements given the CAISO’s unique TPD allocation process.  As previously stated, with the new FERC Order 2023 process, LGIA execution and deposits will occur prior to the results of the TPD allocation studies. In the prior process, projects do not execute LGIAs until TPD is allocated. Requiring a project to execute an LGIA before receiving TPD puts substantial financial risk on the developer. This substantial risk cannot be justified in this new process as even with the 150% intake cap, there is no certainty of TPD without a reservation system. While AES recognizes that the new interconnection process aims to increase requirements, AES believes there needs to be an appropriate balance between the developer, CAISO, and PTO. As such, AES urges the CAISO to reconsider adjusting LGIA requirements in light of the CAISO’s unique TPD allocation process. 

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

Avangrid opposes the proposed change in the Track 3 Final Proposal to move the due date for affidavit submission in the 2025 TPD allocation process from September 1 to August 1 (as outlined in slide 14 of the Stakeholder Workshop presentation). CAISO notified stakeholders of the September 1 due date in a market notice on October 29, 2024, and stakeholders have been preparing submissions to the 2025 TPD process with this date in mind ever since.  Moving back the deadline by a month this late in the 2025 TPD process will create problems in completing the technical work necessary for a 2025 TPD application, such as Material Modification Assessment (MMA) studies.  

The justification for this change is unclear in the Final Proposal.  It appears that CAISO is proposing this change to expedite intra-cluster prioritization, but the negative impact on both requests from Energy Only projects planned for submission into the 2025 TPD allocation process as well as the need to accommodate Cluster 15 studies (as outlined in the October 29, 2024, market notice) is not addressed.  In addition, the final report inaccurately states “the next affidavit process and TPD allocation process is scheduled for this August”, making it further unclear if this change was intended or an oversight of the previously mentioned September 1 affidavit due date.

For these reasons, Avangrid requests that in the Final Proposal submitted to the Board of Governors that the 2025 TPD affidavit due date of September 1 is retained. 

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

No comments 

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

No comments 

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

No comments 

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

Avangrid appreciates the time and effort undertaken by CAISO staff to listen to and respond to stakeholder feedback in the IPE initiative. 

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

N/A

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

Avantus opposes the inability for pre-C15 projects not being able to seek TPD until COD after their 2^nd attempt or coming out of parking in future TPD cycles.

Avantus disagrees that a PPA with a RA component that is inclusive of any EO portion of a project to continue to seek TPD in future cycles are not sufficient to satisfy the PPA requirements for retention and CVC criteria. A project studied as FCDS should be allowed to utilize this option as at any point a project receives an allocation whether it be pre or post COD, will require the RA contract to support its allocation versus just an energy only PPA.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

Avantus fully supports adjusting the 2^nd IFS for C14 parked projects to May 29^th, 2026.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

Avantus opposes this initiative as it goes against the overall concept that TPD is allocated to the most “ready/viable” projects.

Projects passing the barriers of entry by qualifying for one of the respective groups to submit should be given an equal opportunity to ALL available TPD based on their respective Groupings. Any projects that receive an allocation are required to maintain retention annually.  By carving out MW’s specifically designed to allocate TPD to projects that may take longer to establish viability gives special treatment that the rest of the queue is not subject to.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

 Avantus would like to take this opportunity to express its opposition to accelerating the 2025 TPD Allocation process from September 1, 2025, to August 1^st or August 15^th.  Our preference would be to maintain its current due date of September 1^st.

When initially confirmed verbally at the 2024 Interconnection Resource Fair through the Q&A session, developers and LSE’s alike structured their marketing efforts to support the September 1^st due date.  Because of this, LSE’s are already planning their next procurement activity and by moving up the date, this could limit the candidate pool of offtakers for contracting opportunities that have already been engaged forcing developers to scramble last minute for new opportunities.

Additionally, changing this deadline 4 months after the initial deadline was set leaving only 5 months months to adjust efforts to support this new timing, means time lost on both sides. Developers and LSE’s are already struggling to negotiate PPA pricing so early on in the development cycle with some projects being left to negotiate pricing anywhere between 6-10 years in advance of COD due to the timing of when a PPA is needed to support the TPD process.  Though 30 days doesn’t seem like much, developers need all the time allowed to ensure pricing and term structures are not rushed to ensure the overall long-term viability of the projects.  Failure to give adequate time to do so, leaves developers in a position to rush negotiations therefore potentially requiring projects to re-open PPA negotiations at a later date.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

Aypa Power strongly opposes CAISO’s current approach to SCD/RNU headroom allocation, which is actively preventing ready projects from coming online and unnecessarily stalling progress on California’s energy transition. CAISO’s failure to implement a dynamic prioritization process has allowed stalled projects that have not provided Notice to Proceed (NTP) to monopolize critical network upgrade capacity, effectively blocking viable projects from achieving commercial operation. This bottleneck is creating artificial delays, undermining grid reliability, and directly hindering California’s ability to bring much-needed energy resources online.

CAISO must take immediate action to reform its process and prioritize projects that have demonstrated material progress—including financial commitments and advanced engineering milestones—rather than allowing speculative projects to hoard capacity indefinitely. A quarterly reassessment process, modeled after MISO’s Quarterly Operating Limit Study, should be implemented to ensure that existing headroom is reassigned dynamically, allowing projects that are ready and capable to interconnect and operate. It is unacceptable for CAISO to continue restricting projects that have already found ways to energize their interconnection facilities from moving into commercial operation when the grid has the capacity to accommodate them. This is an unnecessary and unjustifiable barrier that actively prevents critical energy infrastructure from delivering power to the system.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

Aypa believes that all projects should have an opportunity to enter any queue cluster and be evaluated for, provided cost estimates, and/or awarded TPD if they choose to participate in that cluster, regardless of status (previous EO project, PCDS project, pre-operational project, operational project, etc.). The projects in a cluster should be afforded a single opportunity to request TPD cost estimates and/or be awarded TPD headroom. The network upgrades, including policy projects, should be known prior to a queue cluster opening and associated/available to that queue cluster. If a project is unsuccessful it should be converted to EO and not allowed multiple opportunities to see across clusters which exacerbates uncertainty and encourages speculation in the process.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

Aypa supports modifying the full 2nd IFS timing to after the TPD allocation results are known to be consistent with past practices and allow projects to make an informed decision. We would expect this to be compatible with the requirement for cluster 14 projects with shared network upgrades to at least post security for their portion of a shared network upgrade to allow any ready projects to move forward.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

As of today, we do not believe that CAISO is providing enough transparency as to the amount and locations of TPD that is being reserved for these resources. We request further transparency so that projects can better understand/determine how much headroom is available to non-LLT resource types.

Given the timing concerns around LLT, the CAISO should require that these projects timely enter the queue to identify other non-deliverability upgrades that may impact the timing of those resources and require that the complete the process, sign their LGIAs in a timely manner, provide all necessary 3^rd postings to not delay other queue projects, and develop LLT-specific CVC criteria to ensure the service that is being assigned to these resources is not being squandered. Further, TPD held by these resource types should be made available in any interim-TPD process developed by CAISO to ensure available transmission capacities are effectively utilized.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

TPD Affidavit Timeline

Aypa Power strongly opposes any advancement of the current deadlines that have been officially posted and reflected in the posted cluster schedules and/or that have been established through formal market notices. Many Developers such as Aypa are currently negotiating PPAs in good faith with LSEs in California and have established a negotiation timeline in support of the current, officially posted deadlines established by CAISO. CAISO has not provided any material reason how accelerating the date will positively impact either CAISO and/or Developers and instead are making an arbitrary decision to accelerate the timing just 4 months after the market notice establishing the current schedule. The CAISO has suggested that moving the date forward will allow it to complete the TPD analysis on-time, however, all of the TPD that is expected to be available/awarded is either predicated on policy plan network upgrades that will not be in service for years or would be granted to C14 project which have a minimum 2.5 year timeline to complete interconnection facilities and/or other network upgrades. There is no evidence that the study cannot be complete on-time or that if the study were delayed by 2 weeks that this would negatively impact CAISO or C14 projects.

Next IPE

1. Additional data and process transparency
2. Building in quick, iterative security posting milestones/offramps instead of limiting up-front participation
3. Eliminate the scoring process for queue entry
4. Publishing a table of upgrade cost assignments in reports
5. Making interconnection facilities costs available in reports
6. Reduce TPD allocation to 1 opportunity per cluster

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) Track 3 Final Proposal.

CalCCA continues to support the CAISO’s proposal to use its transmission plan deliverability (TPD) allocation process scoring methodology to allow generators to interconnect up to an amount that will not trigger the need for a long lead-time (LLT) short circuit upgrade or other reliability network upgrades. This proposal will provide opportunities for projects to come online and obtain deliverability more quickly when there is headroom, helping to alleviate the current interconnection capacity scarcity.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

CalCCA supports the proposed modifications to the TPD allocation process, including the new definitions for the TPD allocation groups and the three opportunities to seek and retain a TPD allocation. This support is contingent upon a future IPE initiative addressing opportunities for energy-only (EO) projects to later obtain deliverability without enabling the EO pathway to circumvent a competitive process for TPD allocation.

While the Final Proposal prohibits EO projects in Cluster 15 and later from ever seeking a TPD allocation, there are legitimate reasons why projects may pursue interconnection via the EO process, such as a willingness on the part of both developers and LSEs to contract for a period of time for EO deliveries. CalCCA, therefore, proposed in its comments to the Draft Final Proposal that the CAISO should not prevent EO projects from ever seeking deliverability. Instead, if a project enters the queue and comes online as EO, the project should be allowed to submit a new interconnection request and follow the intake and study process for obtaining deliverability.[1] The Final Proposal states that the CAISO has considered the issue of EO resources seeking TPD, identified several policy issues that need to be discussed with stakeholders, and determined that the issue will need to be deferred to a future IPE initiative.[2] CalCCA supports moving forward with seeking the CAISO Board of Governors and Federal Energy Regulatory Commission approval of the Final Proposal contingent upon the commitment to consider these issues in a future Interconnection Process Enhancements initiative.

CalCCA continues to support the proposed requirement for offtakers to confirm active PPAs annually for projects within the power purchase agreement (PPA) group to retain their deliverability allocations. This will help ensure PPAs are executed in good faith rather than with the intention of getting scored in the highest TPD allocation group and then canceling the PPA after receiving a TPD allocation. In addition, CalCCA supports categorizing projects within the PPA group based upon whether its PPA is with an offtaker that has an RA obligation. This will result in a meaningful differentiation of projects that meet versus exceed the minimum requirement, because it bases its ranking on RA obligations which drive the need for TPD. It will also provide for uniform treatment of all PPAs with load-serving entities. 

[1]            CalCCA Comments on the IPE Track 3 Draft Final Proposal (Jan. 29, 2025) (CalCCA January 29 Comments): https://stakeholdercenter.caiso.com/Comments/AllComments/8a955f32-33fc-4025-8bc3-f693c5636ad4#org-78cfcc2e-4148-4886-8da4-b884e0910de5.

[2]            Final Proposal, at 26-27.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

CalCCA has no comments at this time.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

CalCCA appreciates the Final Proposal’s clarifications in response to CalCCA’s requests in comments to the Draft Final Proposal.[1] Specifically, CalCCA supports: (1) the CAISO’s recognition that it and CPUC “should be careful not to oversize TPD reservations for these resources to the point that other technologies are unable to obtain TPD when commercially viable and support system portfolio needs;” and (2) the CAISO’s view of its proposed process as a “limited option to ensure that policy-driven, long lead-time location-constrained resources that require their own specific transmission actually have that transmission available to them by the time they are ready to interconnect.”[2] CalCCA also supports the CAISO’s clarification that the process for identifying long lead-time resources requiring TPD reservations does not apply to any particular procurement entity and that once a LLT resource seeks a deliverability allocation, it would need to follow the standard process for TPD allocation.

[1]            CalCCA January 29 Comments.

[2]            Final Proposal, at 46.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

As described in Section 3, CalCCA recommends the scope of the next IPE initiative include a process for energy-only (EO) projects to later obtain deliverability without enabling the EO pathway to circumvent a competitive process for TPD allocation.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

CPUC Staff support utilizing the TPD scoring system for this intra-cluster prioritization of a set of generation and storage resources that are dependent upon a Reliability Network Upgrade with an estimated construction time of more than four years.  We note that the TPD scoring system awards the highest “points” for projects with an executed PPA; thus, the scoring system largely reflects LSE preferences.  CPUC Staff agree that this scoring system is appropriate for allocating scarce headroom. 

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

CPUC Staff supports CAISO’s proposed changes to simplify and reduce the number of groups and clarify the priorities for deliverability allocation. We believe this proposal allows reasonable opportunity for projects to seek deliverability in a timeframe that generally matches the expected commercial operation date of the project.?We agree this approach puts the bilateral procurement process in the driver’s seat for determining the value and viability of projects competing for a PPA. 

CPUC Staff also support CAISO’s proposal to allow no more than three opportunities for projects to receive a deliverability allocation, noting the special consideration included in this Final Proposal for the transparent reservation of deliverability for particular resource types identified by the CPUC and other local regulatory authorities.  
 

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

CPUC Staff has no comments.   

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

CPUC Staff strongly support this proposal to structure a transparent process for the reservation of capacity for which “non-routine” or “long lead-time” resource types can compete for deliverability at a time closer to the beginning of their commercial operation, in MW amounts that are identified by the CPUC or Local Regulatory Authorities (LRAs).

We note that Decision 25-02-026[1] (issued February 26, 2025) in the CPUC’s integrated resource planning proceeding (R.20-05-003) along with related posted documents, which detail the CPUC’s proposed electricity resource portfolios to be utilized in CAISO’s 2025-2026 Transmission Planning Process, set the example for initiating the “clear and transparent process in the annual transmission planning process in coordination with the LRAs to clearly identify TPD reservations.[2]”   

This Decision, which was developed as part of the CPUC’s IRP process and commented upon by many parties, is where the CPUC identifies the amount and location of specific resource types for which the Commission requests CAISO to reserve transmission capacity for long lead-time resource deliverability.

CPUC Staff suggest CAISO clarify that reserved transmission capacity should only be released into the generic deliverability pool when the CPUC or LRA explicitly requests through a regulatory proceeding (or decision of an executive board or similar in the case of a Municipal Utility) that CAISO stop reserving the specific capacity that had been previously requested for reservation.  We believe this change would add greater clarity and transparency to the process, as opposed to the language in the Final Proposal stating that reserved TPD would be released “if specific long-lead-time resources or their associated transmission upgrades identified in the transmission plan do not materialize.”[3]  We suggest that a “formal written decision” by the LRA be the only trigger for releasing reserved TPD.

[1] Decision Transmitting Electricity Resource Portfolios to the California Independent System Operator for the 2025-2026 Transmission Planning Process, issued 2/26/2025

[2] CAISO’s Final Proposal for IPE Track 3, February 18, 2025, page 52

[3] CAISO’s Final Proposal for IPE Track 3, February 18, 2025, page 54

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

CPUC staff support the CAISO Board’s approval of this IPE Track 3 Final Proposal. We emphasize this transparent process to reserve deliverability for long lead-time resources would not guarantee deliverability for any specific project. They would still compete for an allocation of deliverability under the Cluster 15 (and beyond) process for TPD allocation.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

 No comment.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

 No comment.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

 No comment.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

CalWEA generally supports the proposal to reserve TPD capacity for long lead-time (LLT) resources but is very concerned that CAISO is “no longer propos[ing] to provide eligible long lead-time resources with an option to take additional time to seek TPD to better align with commercial milestones and procurement.”  This important LLT TPD reservation policy is necessary to facilitate the achievement of LRAs’ policy goals, but it must be accompanied by a policy allowing additional time for LLT interconnection customers (ICs) to seek and retain TPD capacity.  Rather than leaving the issue open to be “resolved prior to the cluster 16 interconnection request application window,” as stated on p.54, CalWEA strongly urges CAISO to at least clearly state its general intention to provide IC customers with an option to take additional time to seek and retain TPD capacity, with details to be addressed before opening the cluster 16 interconnection request application window. 

Without a policy element that allows LLT Interconnection Customers to take additional time to seek TPD, the proposal would be severely weakened because such customers will not be able to retain the reserved TPD capacity.  This policy is necessary because the development lead-times of LLT resources are substantially longer than those of solar and battery resources.  As CalWEA stated in related comments before the CPUC in its IRP-TPP proceeding, onshore wind energy has a much longer development timeline than solar (recent projects have required more than a decade to develop) and face greater geographic constraints.[1]

As evidenced by the latest major policy upgrade that CAISO approved in the 2022-23 TPP process, the “South Area Reinforcement Projects,” in which 4,700 MW of TPD capacity was fully allocated almost entirely to solar and batteries, we can expect the same to occur without enabling both TPD capacity reservation and providing additional time for ICs to seek TPD. 

Lastly, CalWEA responds to a stakeholder comment that, under the LLT capacity reservation policy, LLT resources could obtain market power by holding limited FCDS capacity at a particular busbar. CalWEA disagrees with the concern.  LSEs are not generally required to purchase specific LLT resources, let alone in particular locations.  Even under a policy that might require procurement of LLT resources, those resources will generally be available at many busbar locations.  Where resource locations are highly constrained, such as with offshore wind, the CPUC discussed these concerns and expects them to be addressed in the central procurement process.[2]

[1] See CPUC R.20-05-003, CalWEA’s Comments on Busbar Mapping of Electricity Resource Portfolios for 2025-2026 Transmission Planning Process (November 18, 2024). The map on p.5 shows that extremely limited wind resource areas with commercial-grade winds remain after the agencies’ environmental screening.

[2] See CPUC D.24-08-064 (August 22, 2024). 

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

(1) Given the number of projects discarded by CAISO in QC15 mainly due to the lack of clear rules and transparency, CAISO should prioritize valuing projects that were part of the QC15 application process in 2023 and 2024 for QC16. Providing a clear and fair path forward for these projects would enhance transparency and encourage developers to continue investing in their development efforts on these projects with confidence.

(2) To provide greater transparency on the TPD allocation process, CAISO should develop protocols for future clusters for LSEs to publicly report on how commercial interest points were allocated to specific projects.

(3) CalWEA also reiterates the importance of finalizing, before opening the window for QC16, the LLT TPD capacity reservation policy provision that will enable eligible LLT ICs to take additional time to seek and retain TPD capacity.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

Support

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

In the updated final proposal, CAISO added a footnote stating that the dates in Table 2 refer to the intra-cluster prioritization process and that the TPD allocation process dates will be updated through a market notice.  CAISO should not change the September 1, 2025 due date for affidavits seeking and to retain Transmission Plan Deliverability (TPD) for the 2025 TPD allocation year as announced in the October 29, 2024 market notice.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

Support

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

No comment.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

No comments at this time.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

Clearway appreciates the CAISO’s modification that the headroom process will be ongoing and is not constrained only to C14. While we understand CAISO’s argument against inter-cluster prioritization, it seems disconnected from the principle of first ready first served. We also note that in the Final Proposal, PNUs are treated inconsistently depending on whether they originated in the TPP or GIDAP. The CAISO is allowing more ready C14 projects to access TPP-approved PNUs before less ready C13 projects can. Unless the CAISO treats the GIDAP PNUs the same way, the proposed framework will not produce the desired result of serving more ready projects first.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

Eligibility of Energy Only projects to seek TPD

Clearway continues to believe that there is value in pre-Cluster 15 Energy Only projects with PPAs being allowed to seek TPD before COD in the regular TPD Allocation process and for C15 and beyond EO projects to be allowed to seek TPD after COD. We encourage the CAISO to allow for greater flexibility for these projects and to revisit this question in a future IPE initiative.

Multiyear Interim Deliverability

Clearway has advocated throughout this process and continues to see value in the creation of a multiyear interim deliverability process in a future IPE process. We understand that it is not certain today how much interim deliverability will be available in the future. However, if network upgrade delays subsequently emerge and create an opportunity for interim deliverability to be available for multiple years, there should be a process for allocation.

Scoring methodology for prioritizing TPD and RNU headroom

Clearway supports the change to wording in Table 6 (points used to prioritize projects in the TPD allocation process) from “Draft Environmental Report w/no significant impact that cannot be mitigated” to “Draft environmental report indicating likely approval of the requested permit and/or which indicates that the permitting authority has not found an environmental impact which would likely prevent the approval.” This change aligns the language in the table with the existing tariff language and provides welcome clarity on what is needed for a project to qualify for points. The same change should also be made in Table 1 (scoring for intra-cluster priority) to maintain alignment between the two scoring processes.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

Clearway continues to support the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

Eligibility

Clearway supports CAISO’s proposed process to work with LRAs to designate LLT resources in a transparent manner. Relying on LRAs and market competition is likely to lead to more efficient results without resulting in significant portions of TPD being reserved for LLT resources that may never materialize. Additionally, Clearway appreciates the ISO’s commitment to clearly specify the busbar and amount of capacity reserved in future TPD reservations. However, additional transparency would be useful on certain points:

• CAISO should work with LRAs to clearly define TPD reservations and eligible resources in the TPP and subsequently specify those reservations in the Transmission Plan.
• The 426 MW of 2024 TPD reservations should be identified to the busbar.
• CAISO should clarify how reservations for deliverability through the Subscriber PTO process will intersect with the reservation process for LLT resources and the standard TPD allocation process and should identify (to the MW and busbar) any TPD currently being reserved through the Subscriber PTO process.

Additionally, before C15 merchant deposits go fully at risk, developers need more information about the following:

• CAISO should clearly identify which TPP cycle will define the LLT resources eligible for TPD reservations.
• CAISO should commit to ensuring that C15 merchant projects that are going to risk significant deposits and may rely on future TPP upgrades to receive TPD are held harmless or given priority over any LLT reservations, Cluster 15 merchant projects are making significant financial commitments now to advance to interconnection studies based on the expectation that they will have the right to deliverability through ADNUs that they finance, or if no ADNUs are initially identified, an opportunity to compete for any TPD that subsequently becomes available through the TPP. We request that the CAISO clarify whether future reservations of TPD for LLT resources could reduce the TPD available to C15 merchant projects.

Releasing reserved TPD

In response to Clearway’s recommendation that CAISO require LLT resource developers to demonstrate that they are taking steps towards commercialization, CAISO states in the Final Proposal that this is a role of the LRAs. If this is the case, the CAISO should commit to checking in regularly with LRAs to confirm that LLT resources with reserved TPD are making progress toward commercialization. The CAISO has an interest in making sure that these resources will in fact be able to use the deliverability that is being reserved for them.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

Clearway strongly opposes CAISO’s proposal to move the TPD Allocation affidavit due date from September 1st to August 1st or August 15^th. While CAISO states that they are seeking to validate all the requests by October 1st, a move now would provide insufficient time for developers to be ready to submit the required information in the TPD Allocation affidavits. For example, Group B projects are on track to receive an executed PPA on the previously established September 1st timeline. LSEs and other offtakers cannot suddenly change their Board meeting schedules or other internal approval timelines to match CAISO’s proposed change.

In the next IPE initiative, Clearway recommends that the CAISO solicit and incorporate lessons learned from Cluster 15. For example, many parties raised concerns during the development and approval of IPE Track 2 about the process for LSEs to allocate commercial interest points, including concerns raised at FERC as well as in the CAISO’s stakeholder process. Many LSEs chose not to follow CAISO’s non-binding guidance for the allocation of commercial interest points and instead required cash payments or large deposits with limited refundability. The collective impact of these fees and deposits surely drove up costs for Cluster 15 projects overall, and if this pattern continues it will drive up costs for all projects in future clusters. There may be solutions within the CAISO’s authority that would help address this problem, such as providing a suggested form agreement for commercial interest points allocation. Clearway also suggests that the next IPE initiative include an early focus on the timeline for Cluster 16, to make sure that all relevant information (available transmission capacity, TPD vs. merchant zones, TPD reservations, etc.) is published with enough lead time to be used in the process.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

 No comment at this time.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

We strongly support including a draft environmental report as an important project milestone that indicates a certain level of project permitting maturity.  However, the statement: “Draft environmental report indicating likely approval of the requested permit and/or which indicates that the permitting authority has not found an environmental impact which would likely prevent the approval.” on pages 39 and 41 and Table 6 misrepresents the purpose and function of environmental reports under the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA). 

CEQA and NEPA environmental documents are intended to support informed decision-making by permitting authorities that includes consideration of the potential environmental effects of proposed projects and provide a transparent process to the public.[1] The existence of a draft environmental report does not indicate the “likely approval of a requested permit.”  Permit approval is at the discretion of the permitting authority after considering the whole of the record including the analysis contained in the environmental report.  Furthermore, Cal. Code Regs. Title 14, Section 15042 specifically provides the authority to disapprove projects that would have a significant effect on the environment. 

We request the following revision:

“Draft environmental report indicating a key permitting milestone has been met.  likely approval of the requested permit and/or which indicates that the permitting authority has not found an environmental impact which would likely prevent the approval.”

[1] See 40CFR Part 1500.1(c) and CEQA Guidelines 15002(a)(1)-(4))

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

No comment at this time.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

No comment at this time.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

No comment at this time.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

Engie NA supports CAISO’s proposal for an intra cluster prioritization process to help delayed projects come on line sooner but raises three concerns/requests for clarification below.

1. ENGIE appreciates the CAISO returning the due date for  the first applications for RNU headroom to August 15^th, 2025, rather than changing it to August 1 as was shown  in the meeting slides.  However, ENGIE is very concerned that after announcing a September 1 due date for the TPD Allocation Process request/retention affidavits, the CAISO now indicates it plans to accelerate the date to possibly August 1 which is hugely problematic.  If the CAISO feels it needs more time the CAISO could address this challenged by requesting certain necessary information ahead of that date but still leaving the due date for the Affidavit at Sept 1. Interconnection customers need more time not less to demonstrate shortlisting or a PPA. As it is interconnection customers will be challenged to secure contracts on a short time line especially when faced with long-lead time transmission upgrades that fall outside of LSE’s current procurement timeframes. ENGIE requests the CAISO leave the TPD Affidavit due date at Sept 1 as was previously announced.

2. In CAISO’s,  Intra-Cluster Prioritization Proposal, the latest eligibility criteria is

"All RNUs could be considered in this process provided (1)  estimated time to construct of four or more years, and (2) delaying the in-service date of multiple generation projects by two or more years."

There are some projects that have two ( or possibly more) RNUs with times to construct (TTC) of 4 years or more.   If there is sufficient headroom under each "high TTC"  RNUs and the Project "wins" in the scoring process for each RNUs, it should be allowed to  participate and come online early.  In other words, CAISO should not preclude project participation in the intracluster prioritization process if it faces 2 or more long-dated RNUs, provided all such RNUs are eligible for the process; i.e. have TTCs >= 4  years.  If this is CAISO's proposal, then we simply ask that CAISO clarify that this is their intent.

The CAISO should clarify that if a project comes online early as a result of the intra cluster prioritization proposal it is eligible to be deliverable  under Full Capacity or Interim Delivery like any project that did not participate in this process to get online early.  Both PG&E and SCE have language in their LGIA appendix "templates" that can be interpreted to mean that a project may operate as Energy Only  until such time as all identified network upgrades are in service.   Engie understands that Full Capacity or Interim Delivery Status may be delayed due to precursor upgrades sill under construction but if the interim deliverability assessment.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

ENGIE is still concerned about the limited time cluster 14 projects will have to attain a PPA before potentially losing deliverability. It would benefit the market at large for the CAISO to allow these projects more time to retain valuable deliverability considering the supply chain constraints and geo political issues the market has been subject to that will not be resolved for another few years. Projects coming behind cluster 14 will be subject to similar challenges so why not allow more time for the projects that are further along and have significant invesment to have an opportunity to be sucessful? 

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

No futher comments

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

No futher comments

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

Engie NA requests the CAISO delay further refinements to the interconnection process until 2026 unless there is a critical fix or improvement needed due to recent rule changes.  There has been a tremendous amount of change that has yet to be tested. Interconnection customers need a period of stability with no changes to rules and time to see how interconnection reforms are working.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

I am writing in response to the proposal discussed during the February 25, 2025, Interconnection Process Enhancements (IPE) Track 3 Final Proposal – Stakeholder Meeting, which suggests accelerating the due date for the Transmission Development Plan (TDP) allocation affidavits from September 1st to August 1st.

Moving the TDP allocation affidavit due date to August 1st increases the timing risk for our power contracting process. Currently, we are negotiating offtake contracts with counterparties for two projects and require as much time as possible to complete these negotiations and obtain the necessary internal approvals for execution. Drafting and negotiating the terms within an offtake contract involve variables that are difficult to control, such as drafting turnaround time and legal review board schedules.

We have relied on the timing guidance provided by CAISO to allocate the appropriate amount of time for this critical process. Changing this guideline midstream unnecessarily complicates our efforts and adds significant risk to our project timelines.

Given these challenges, I respectfully request that CAISO reconsider the proposed change to the TDP allocation affidavit due date. Maintaining the original September 1st deadline would provide us with the necessary time to complete our negotiations and approvals without compromising the integrity of the process.

I appreciate your attention to this matter and hope that CAISO will take my concerns into consideration.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

Intersect Power appreciates the CAISO’s efforts to create a new process to allocate available RNU headroom. However, the proposed intra-cluster prioritization process presents several blind spots that significantly limit the potential of this initiative.

Available Headroom Calculation

Intersect Power notes that CAISO has not provided clarity regarding the assumptions underpinning headroom calculations for applicable RNUs. To ensure project certainty, Intersect Power strongly urges CAISO to affirm that headroom utilization already subject to executed LGIAs, inclusive of those awaiting limited operation studies, will be definitively reserved and not subject to the upcoming headroom prioritization.

Eligibility Limitations

Intersect Power disagrees with the limitations that the CAISO is imposing to the intra-cluster prioritization process and believes that these limitations will end up significantly restricting both the RNUs and the projects eligible to be included in the process to start with, thus leaving available headroom, that would have otherwise accelerated mature projects, unused. 

An RNU would have to “serve as the sole reason for delaying the in-service date of multiple  generation projects by two or more years” means that:

• If an RNU is delaying a single project, that project cannot make use of the available headroom (i.e. bring a portion of its project online earlier)

• A project will only qualify for the headroom of the one RNU that’s delaying it by 2 or more years. Looking at IRs currently in the queue, several projects are affected by several RNUs, many with available headrooms that collectively currently delay the project by 2+ years, and that together, could accelerate the projects’ CODs. The CAISO should confirm whether all such RNUs will be considered in the analysis. E.g. if a project is behind 2 RNUs that each equally delay it by 4 years, will this project be considered in the intra-cluster prioritization for available headroom for each of the two RNUs?

Finally, the CAISO should investigate the number of network upgrades and projects that would qualify given the current proposed rules before finalizing the final proposal and revisit its limitations if the analysis confirms that not many projects would benefit from the proposal as it is written or that much of the available headroom would be left unallocated.

Argument for Inter-cluster prioritization - Allowing competition between different clusters is fair

Older cluster projects will on average be able to score better (they’re generally more advanced) and will already have an advantage going into the process. However, if a newer cluster project exhibits better readiness and is able to score higher, there is no reason to disadvantage it. This can actually be done without impacting the previous cluster projects. Please see below example:

Project A: Cluster 13 project - triggering RNU1

Project B: Cluster 14 project - triggering RNU1 (considered a PNU here) and RNU 2 (additional NU caused by the same reliability issue)

If project B scores > project A and can bring its project online faster, then project B should benefit from the available headroom for RNU 1, while still funding RNU 2. Project A would then not be affected and would still be reliant on RNU 1 as it would have been anyway.

CANUs and PNUs exclusion

Additionally, Intersect Power disagrees with the CAISO’s updated final proposal changes that exclude CANUs and non-TPP PNUs from the headroom allocation process. 

The current proposed process leaves untapped available headroom that could otherwise be utilized to bring more recent queue cluster projects online, earlier. 

For example, if a QC14 project is dependent on a CANU/PNU (also a QC13 RNU) that is solely delaying its COD by 2 or more years, and the QC13 projects dependent on this NU do not qualify for the available headroom, the QC14 project, under the current rules of the process, would not qualify to benefit from any of the available headroom for that CANU/PNU. This leaves available headroom unutilized, and delays the QC14 project’s ability to go online and support the grid with additional resource adequacy and reliability.

GIA Modification

During the stakeholder meeting, there was a discussion regarding the GIA modifications required after a certain headroom is allocated to a project. Intersect Power believes that the GIA modification should just be a step in the intra-cluster prioritization process, rather than its own separate request. Given the CAISO is only allowing projects to receive headroom for RNUs that are solely delaying their COD by 2 or more years, it should be very straightforward to update the GIA to reflect the new COD.

Additionally, the GIA modification should also clarify that the project deliverability status is not reliant on the completion of the RNU either, and that when the project reaches COD, its deliverability status would be based on the completion of the rest of the deliverability upgrades needed only, regardless of whether the RNU originally assigned is completed or not (at this point, the project schedule is no longer reliant on the RNU).

Proposed Revision to Intra-Cluster Scoring Criteria for Deliverability Upgrade Status

In response to Intersect Power’s comment regarding the intra-cluster scoring criteria for the deliverability upgrade status (i.e. proposing to assign 5 points to both EODS and FCDS projects operating as Energy Only while awaiting transmission upgrades), the CAISO stated that “an EO project with a PPA is better positioned to move forward than an FCDS project with a PPA that is still waiting for a deliverability driven transmission upgrade”. While this statement is valid, the CAISO is not considering the case where the FCDS project has an EO PPA in place for the period between its COD and DNU completion or where it chooses to operate as EO while awaiting transmission upgrades. Such projects should not be penalized in the scoring compared to a project that was initially designed as EO. As mentioned in our previous comment, there are several reasons why a project may choose to go online as EO while awaiting a DNU completion, including meeting deadlines such as the CA property tax exemption sunset, or favorable project economics. 

As a backstop to the risk that an FCDS project waiting for a DNU may choose not to go online as EO after having received the RNU headroom, the CAISO can note that the headroom award is conditional upon the earlier project COD and that any request to push out COD would then release that headroom and the project would have to compete for it with other projects again. This ensures fairness given that every project proposing to push out its COD has to go through a GIA modification.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

QC15 TPD Allocation Timing

Intersect Power still does not agree with the CAISO’s decision to require the QC15 projects to execute their GIA ahead of having the opportunity to seek TPD allocation, given the high risk and step up in the financial posting associated with the GIA execution, ahead of receiving the TPD allocation results. The CAISO is unfairly disadvantaging Cluster 15, by allowing a fourth TPD allocation opportunity to all future clusters but QC15.

Annual PPA Verification Requirement

Separately, Intersect Power is requesting clarification to the annual PPA verification requirement. Can the CAISO please confirm that Interconnection Customers are allowed to replace a PPA with another that meets the CAISO’s requirements should they choose to?

Load-Serving Entity 5-point Scoring Advantage

Intersect Power recommends that the CAISO reverts back to requiring LSEs serving their own load to provide a signed PPA to receive the 5 PPA points as part of the TPD prioritization scoring process. Removing this requirement and automatically giving away the 5 points (20% of overall score) to the LSE projects presents undue discrimination against every other developer that has to market their project and negotiate a PPA for several months to achieve the maximum PPA score.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

No comment.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

Intersect Power appreciates the CAISO’s decision to defer some of the Long Lead Time Resources topics to an additional IPE track 4.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

GIA execution timing with respect to the 1st TPD allocation cycle for QC15+

As discussed in our TPD allocation process modifications comment, Intersect Power is concerned with the requirement to execute a GIA ahead of receiving the initial TPD allocation results for FCDSR projects, especially given the new “3 strikes and the project is out” rule. If this issue is not addressed in IPE track 3, it should be included in the next IPE initiative.

Stand Alone Network Upgrades - Delays and cost overruns outside the IC's control

The tariff and BPM do not currently address delays and cost overruns that are fully outside the Interconnection Customer’s control and that the PTO would have equally incurred and been able to receive full reimbursement via the rate making process, if it was building the SANUs instead.

E.g. long lead-time equipment required to be procured from a single vendor selected by the PTO, with no flexibility to accelerate the long lead time or negotiate competitive pricing.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

LSA strongly supports the implementation of this feature.  As noted in #5 below, we do not  object to coordinating the headroom allocation feature with the TPD Allocation process but strongly object to such coordination if it would lead to the acceleration of the request/retention affidavit due date for the TPD Allocation process. 

However, we have several questions and comments on the details of the proposal, as described below, in no particular order.

RNU criteria:  LSA understands that the CAISO is concerned about the number of RNUs and projects that could be involved in this process, and the resulting effort needed.  However, the proposed criteria – 48-month minimum RNU duration, and delaying project CODs by at least 24 months – are somewhat arbitrary and may not help many projects.  LSA suggests that the CAISO should investigate the number of upgrades/projects that could qualify, before finalizing the final proposal, and loosen the restrictions if it turns out that not many projects could take advantage of the proposal as it is written.

Prioritization scoring rubric:  In response to LSA’s earlier comments about the proposed 5-point assignment to both EODS and FCDS projects operating as Energy Only while awaiting transmission upgrades, the Update states: …“an EO project with a PPA is better positioned to move forward than an FCDS project with a PPA that is still waiting for a deliverability driven transmission upgrade.”

However, this statement reflects a value judgment on the CAISO’s part that is not necessarily accurate, nor the CAISO’s to make.  While some projects may want to delay their CODs to match their desired deliverability status, developers should have the option to make that judgment for themselves, without the CAISO prejudging for them this important business decision. 

For example, some FCDS projects may have Energy Only PPAs, or otherwise choose to operate as EO, for the period between COD and DNU completion.  Other projects may want accelerated CODs to meet deadlines like the California property tax exemption sunset, or to take advantage of other favorable project economics sooner.

Such FCDS projects should not be penalized in the scoring compared to EO projects.

If the CAISO wishes, it can condition the headroom award upon the earlier project COD and provide that requests to extend CODs would then release that headroom.

Multi-cluster headroom allocations:  LSA wants to follow up on the discussion at the February 25^th stakeholder meeting about inclusion of CANUs and PNUs in this process.  The Final Proposal specifically included them on p.15, referencing “eligible long lead-time RNUs, including Conditionally Assigned Network Upgrades (CANUs) and Precursor Network Upgrades (PNUs).” 

CANUs and PNUs are typically upgrades assigned to earlier-queued projects but also needed by later-queued projects.  PNUs can also be identified in the Transmission Planning Process (TPP).  However, the Updated Final Proposal (Update) excluded CANUs and PNUs assigned to earlier-queued project, limiting this proposal in that respect to only PNUs identified in the TPP.

LSA opposes this change in the Update.  Including CANUs and PNUs assigned to earlier-queued projects would allow, for example, a Cluster 14 project depending on a CANU/RNU assigned to Cluster 13 to apply for available headroom and thus accelerate its COD. It is entirely possible that some of the C13 projects may either have other long-lead-time upgrades that would disqualify them from submitting a headroom request, or may be otherwise satisfied with the later COD and thus would not submit a request.  Thus, the C14 project could conceivably receive a headroom allocation and should at least qualify to submit a request.

LSA does not object to consideration of queue position in this process, either as a primary factor (since the earlier-queued projects are funding the upgrade) or as a tie-breaker between projects with the same scores.  However, there is no reason for excluding the later-queued projects from submitting COD acceleration requests under this process if they otherwise qualify.

GIA modification:  The CAISO stated at the stakeholder meeting that, once the headroom is allocated, projects (at least for recipients with margins above 3%) would have their GIAs modified to reflect the fact that the RNUs in question are no longer needed for COD.  This feature should be specific in the Proposal and associated implementing tariff language.

In addition, the question asked at the meeting about deliverability status was legitimate.  The GIA modification should also clarify that the project deliverability status also is not reliant on completion of the RNU.  In other words, once the project reaches COD, its deliverability status would be based on completion of the rest of the upgrades needed, e.g., if those other upgrades are complete and the project had received a full TPD Allocation, it would have FCDS even though the RNU originally assigned and then not needed might not be complete. 

(If the other upgrades are incomplete at COD, the project could qualify for available Interim Deliverability Status (IDS) like other projects.)

Modification request not needed:  The headroom-allocation request should serve as a modification request.  In other words, the developer should not have to submit an MMA request, and incur the associated expense and additional processing time, in order to accelerate the project COD once the headroom allocation is received; the parties should proceed to the GIA modification described above without the need for that additional step.

Reduced COD acceleration:  LSA asks for clarification on the terms of the COD acceleration feature.  For example, if a project requests and receives a headroom allocation that would accelerate its COD by three years, and by the time the results are known it turns out that the project would like to accelerate the COD by only two years, would that option be available?

Multiple RNU qualifications:  LSA asks for clarification, specifically of the CAISO’s requirement that an RNU for this process must be the “sole reason” for causing a project COD delay of two or more years.  Projects with multiple long-lead-time RNUs qualifying for this process should be allowed to apply for headroom for each of those.  To take a couple of simple examples:

• Project A has two 96-month RNUs, both of which make the CAISO RNU headroom eligibility list, and all other upgrades needed by the project have durations of 48 months or less.  Each RNU is delaying the project COD by more than 2 years, though neither is “solely” doing so.

The project should be allowed to apply for available headroom for both upgrades.  Of course, if the project is awarded headroom for only one of the two upgrades, that headroom will not be useful and can be assigned to another project.

• Project B has two long-lead-time RNUs – one with 72 months duration and one 96 months duration – and all the other upgrades needed by the project have durations of 48 months or less.  As with Project A above, each RNU here is delaying the project COD by more than 2 years, though neither is “solely” doing so.

Again, the project should be allowed to apply for available headroom for both upgrades. 

• If the project is awarded headroom only for the 72-month RNU, then that headroom would not be useful and could be assigned to another project. 

• If the project is awarded headroom only for the 96-month RNU, the project COD should be revised to reflect the 72-month RNU as the applicable longest-lead-time upgrade.

• If the project is awarded headroom bot both RNUs, the project COD should be revised to reflect the 48-month RNU(s) as the applicable longest-lead-time upgrade(s).

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

LSA still does not agree that pre-Cluster 15 Energy Only projects should not be allowed to seek TPD before COD in the regular TPD Allocation processes, and we believe that C15+ EO projects should be allowed to seek TPD after COD; however, we understand the CAISO’s position and that the Final Proposal is not likely to change in this respect.

However, we do request several clarifications below.

Group A TPD retention:  Several years ago, the CAISO removed the need for Group A (or the earlier Group 1) projects to continue to demonstrate an executed PPA in subsequent TPD Allocation processes.  Please clarify that projects receiving a Group A allocation in the 2025 TPD Allocation process would follow that same practice.

PPA Group TPD retention:  LSA has two questions about this Proposal provision, at p.20:

The ISO will require that the LSE or non-LSE off-taker verify that the PPA provided by the interconnection customer is active and meets the tariff requirements for a PPA, including annually, as part of the TPD retention process, confirming that the PPA is still active and continues to meet tariff requirements.

First, the CAISO should say why it is returning to this annual demonstration requirement after eliminating it as unnecessary earlier for Group A.

Second, the CAISO should clarify that Group A projects can acquire and demonstrate “substitute PPAs” to retain their TPD Allocations.  In other words, as long as they demonstrated executed PPAs by each compliance deadline, the executed PPAs can change over time.  For example, if the project loses its PPA but can secure another by the next compliance deadline, its TPD Allocation should be retained.

“Contingent” PPAs 

• PPAs submitted for TPD Allocations:  The CAISO said at the stakeholder meeting that PPAs to support Group A/PPA Group TPD Allocation requests can contain provisions requiring Resource Adequacy (RA) but allowing for cancellation if the project does not receive a allocation.  However, the CAISO said that PPAs containing a price penalty if a TPD Allocation is not received but allowing the PPA to remain in effect for the Energy Only project (perhaps also providing for a post-COD Commercial Group request) may be allowed if CAISO is convinced the project would actually be built as Energy Only.

However, it is not clear how the CAISO will determine whether the developer is “serious” about building the project as Energy Only if an allocation is not received.  As long as the PPA contains provisions that would be acceptable in an Energy Only PPA (e.g., mutual commitments and typical damages provisions), such PPAs should be acceptable. 

Such PPAs should also be allowed to contain a provision for a post-COD TPD Allocation request through the Commercial Operation Group if the project qualifies (e.g., pre-C15 projects) and the contract is not cancelable if an allocation is not received.

• PPAs to support capacity retention after transfer of its TPD to another project:   These PPAs must be Energy Only, i.e., must provide for construction as Energy Only and cannot require TPD.   However, similar to the point above, they should be allowed to contain a provision for a post-COD TPD Allocation request through the Commercial Operation Group if the project qualifies (e.g., pre-C15 projects), and the contract is not cancelable if an allocation is not received.

(The same is true for EO PPAs submitted in compliance with the EO Commercial Viability Criteria from Track 2, when those rules are filed with FERC.)

Group D:  The CAISO should specify that Group D will be available in the 2027 TPD Allocation Process to any C14 projects eligible for, and electing, extended (second year) parking.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

LSA strongly supports the CAISO’s inclusion of this item in the Track 3 initiative and thanks the CAISO for including it.  We support the May 29^th, 2026 proposed due date for the second posting, for C14 projects coming out of parking.

Consistent with our position at the stakeholder meeting, we ask that the CAISO also include second-posting dates and related provisions for any C14 projects that qualify for extended (second year) parking, in case there are some.  These provisions could be the same as specified for those coming out of parking this year, e.g.:

• Postponing the second posting until 60 days after the TPD Allocation; and

• Providing COD extensions commensurate to the 10-month delay provided to C14 projects parking once.  This COD extension should recognize that there will be no 2026 TPD Allocation.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

LSA continues to oppose the reservation of capacity for so-called “Long Lead Time” (LLT) resources as unnecessary and inefficient. 

The new CAISO intake and TPD Allocation framework is based mainly on PPAs.  Resources with executed PPAs get first priority for TPD Allocations, and those in other allocation groups must acquire executed PPAs to retain any allocations they will receive.

Thus, if non-LLT resources acquire TPD that is needed for LLT resources later, generally they would either already have a PPA (PPA Group) or they could only keep it for a year before having to acquire a PPA (Conditional Group) or lose it.  Annual PPA compliance demonstrations will be required.

LRAs should be responsible for exercising their procurement-oversight authority.  If LSEs are executing PPAs consistent with the applicable LRA portfolios provided to the CAISO for transmission planning purposes, then the “excess” non-LLT resources in LLT areas will not acquire PPAs and will not obtain or retain TPD Allocations, and the TPD will be available there later for LLT resources. 

Trusting the combination of LRA authority and market competition between suppliers is a much better and more efficient way to achieve the state’s resource goals than having the CAISO – which is supposed to be adhering to open-access and non-discriminatory policies – perverting the TPD Allocation process tin an attempt to achieve the same result.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

LSA offers comments on an immediate issue – the affidavit due dates for the next TPD Allocation process – and also suggestions for the scop of the next IPE initiative.

TPD Allocation/RNU headroom affidavit due date 

The Final Proposal showed an August 15^th due date for RNU headroom requests, and the February 25^th stakeholder meeting slides showed an August 1^st affidavit due date and said the CAISO is planning to accelerate the 2025 TPD Allocation due date for TPD requests and retentions to August 1^st as well.  However, the Update still shows August 15^th as the RNU headroom request due date, with a footnote that the TPD Allocation affidavit due date may be modified in a future Market Notice.

Apparently, the CAISO engineers that will perform the TPD Allocation studies want all the requests to be validated by October 1st, and the CAISO decided it needed more validation time than originally expected, due to: (1) the complexity of the transitional TPD Allocation priorities; and (2) the additional validation and processing needed for the new RNU headroom process.

LSA strongly opposes the CAISO’s proposal to accelerate the TPD Allocation affidavit due date from the previously announced September 1^st date to August 1^st or 15^th.  We are dismayed that the CAISO would undermine its own earlier helpful act in setting a date certain for affidavit submittals by changing its mind and reducing the timeline by an entire month, four months after the prior announcement.

LSA’s opposition is based on the fact that developers are already scrambling to be ready for the September 1^st announced deadline, which is a significant challenge.  This includes developers of:

• Projects with TPD Allocations having retention obligations requiring shortlist positions or executed PPAs; and

• Projects with Energy Only status trying to obtain shortlist positions or PPAs to support this last opportunity for a pre-COD allocation.

• Projects that have submitted, or plan to submit, MMA requests to add storage and then request TPD Allocations for that capacity in this last opportunity for a pre-COD allocation, especially given the extended timelines sometimes needed lately to process MMA requests.

LSEs have also established procurement/PPA processes based on the CAISO’s announced September timeline, and a change at this late date would also undermine those processes.  CAISO staff may consider the proposed change to the TPD affidavit due date to be relatively minor and inconsequential, but LSEs are on a tight timeline to launch solicitations and award shortlists/PPAs to projects before the affidavit deadline, which is already less than six months away.

LSA does not object to the CAISO setting an August (or earlier) date for the RNU headroom application process.  Remember, LSA had advocated for an even greater acceleration of that process, so projects could know whether they received an accelerated COD before they had to acquire PPAs for TPD allocation/retention purposes. 

It would be better to have an earlier due date for the new RNU headroom allocation process, and lose the benefits of coordination with the TPD Allocation process, than to have its incorporation into the TPD Allocation process force an acceleration of TPD acquisition/retention affidavit submittals.

Suggested topics for the next IPE process

• Fixing GIA execution timing:  LSA continues to believe that the CAISO should address the absurdity of requiring Cluster 15+ GIA executions before TPD Allocation results are known.  This is particularly needed under the new “three strikes and you’re out” rule, where projects would be forced to executed GIAs, and begin paying toward upgrades, without knowing whether their projects will exist beyond two more years.  Funding upgrades without any certainty that the project can move forward is wasteful and unnecessarily costly.

• Stand-Alone Network Upgrades

Several issues have arisen that have no clear guidance in the tariff or BPMs, such as:

• “PTO delays” – obviously not technically applicable, since the PTO is not building the upgrade, but in this context these are delays that the PTO itself would likely have encountered if it was building the upgrade, especially where the delay involves: (1) required purchase of key equipment (e.g., circuit breakers) where the PTO has identified only one (or a small number) of approved suppliers; or (2) redesign or permitting delays that the PTO would also likely have encountered.  COD delays for this purpose should be allowed, similar to PTO delays.

• Reimbursement including cost overruns – again, obviously not the PTO’s cost overruns, but situations where the IC acted reasonably and the PTO would have likely incurred the same overruns (e.g., due to price increases for required equipment from PTO-mandated suppliers).  BPM for GIDAP Section 8.4.6 states:

Reimbursement of SANU Construction Costs:  An Interconnection Customer that constructs a Stand Alone Network Upgrade, or task is entitled to receive reimbursement for construction costs up to the cost estimate provided by the PTO in the Interconnection Customer’s Phase II study report, or Reassessment report, as applicable.  The reimbursable amount will be documented in the GIA.  Reimbursement of the costs to construct Stand Alone RNUs will not exceed the RNU reimbursement cap established in Appendix DD Section 14.3.2.

However, the PTO would have received full reimbursement through the ratemaking process if it could demonstrate that the costs were just and reasonable, even if they were higher than originally estimated, and the IC should have that same ability.

• Interaction with RNU reimbursement limit:  Related to the cost-overrun issue, but a different impact.  If full reimbursement was justified (see above) but would cause the IC to exceed the RNU reimbursement limit, or if the original situation already had the IC going over the limit, the reimbursement should be based on the original estimated cost, with the IC also receiving the overrun amount – the same outcome as if the PTO built the SANU.

For example, say a SANU switching station was estimated to cost $20M for a 200MW project.  If the PTO builds the SANU, the IC would pay $20M and receive a ~$17M repayment after COD (at ~$85K per MW, and ignoring any other RNUs) – a $3M forfeit.  If the IC builds the SANU and the cost comes in at $22 million, and the IC can demonstrate that the overrun was reasonable and would likely have been incurred by the PTO had it built the SANU, the reimbursement should be the $17M regular reimbursement plus the $2M overrun – the IC would suffer a $3M forfeit, the PTO would put the SANU into its rate base at $22M, and the parties would be in the same position as if the PTO had built the SANU.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

PG&E appreciates CAISO for the clarification provided and looks forward to working with CAISO to develop a study plan for this process.  

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

The CAISO has determined that projects that do not get TPD after three cycles must withdraw, even if they are making commercial progress and have an offtake agreement. PG&E requests the CAISO actively monitor this process starting in the 2027- 2028 timeframe to see if the “3 TPD cycle” policy has negative consequences potentially eliminating good projects aligned with energy goals. The 2027-2028 time period could allow for policy changes, if negative consequences surface, prior to Cluster 15’s final opportunities for TPD allocation. 

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

N/A

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

N/A

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

The new TPD allocation cycle will require much faster procurement timelines than seen historically. To facilitate this, PG&E requests more searchable, transparent data on projects. To date, PG&E has not seen a response to our previous comments reflecting this need.  

PG&E strongly recommends organizing data for each project to show associated RNUs and DNUs (or minimally, queue positions) in a searchable form, such as an excel spreadsheet. While data is available in various sources, it is not often readily searchable. Given the market and CAISO processes will require procurement with a faster turnaround, LSEs need better, more digestible knowledge of the queues earlier on. While PG&E appreciates that there have been concerns about confidentiality previously, the new emphasis of expediting procurement necessitates changes.  

PG&E would appreciate a dialogue on how to make data accessible. An important minimum set of information available in a searchable, excel format would be tables of queue positions behind constraints from the TPD allocation report. Additionally, the ability to review available project locations (with location information) in programs such as Google Earth (for mapping purposes) would be valuable and accelerate the process.  

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

Prologis appreciates the CAISO's efforts to create a process that allows developers to avoid delays associated with long lead-time network upgrades. These efforts are critical in ensuring that projects can progress without unnecessary delays.

Prologis respectfully urges CAISO to accelerate the timing of this process to the extent possible, especially for projects that have already obtained deliverability. For many of these projects, the availability of network upgrade headroom is the only factor preventing them from signing Power Purchase Agreements (PPAs). By expediting this process, CAISO can help unlock the potential of these projects, enabling them to secure PPAs and proceed with development.

Prologis appreciates that projects with Full Capacity Deliverability Status (FCDS) are prioritized in the scoring process, providing them with a better chance of receiving a headroom allocation. However, if that allocation is not made until December, these projects are essentially on hold for ten months. Accelerating this schedule would allow these projects to execute their PPAs and come online sooner, contributing to Resource Adequacy requirements and climate goals more promptly.

CAISO proposes to post a list of eligible upgrades by July, require developers to submit scoring by August, and inform developers of the study results by December of 2025. Prologis acknowledges that CAISO must obtain FERC approval and perform studies to determine which projects can proceed, and that this process takes time. Nevertheless, Prologis urges CAISO to proceed as expeditiously as possible to give these projects the best opportunity to move forward without undue delays.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

The Six Cities do not oppose the CAISO’s proposal on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom, including with respect to the CAISO’s updated proposal to add scoring data based on TPD allocation status and associated deliverability network upgrade status.  See Final Proposal at 16.

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

The Six Cities acknowledge that in its Final Proposal, the CAISO agreed to explicitly include projects where the interconnection customer is a Load-Serving Entity (“LSE”) serving its own load in the applicable language defining the first priority allocation group.  Specifically, the CAISO agreed “to be explicit in the tariff language for including LSE projects.”  Final Proposal at 29.  Further, the CAISO clarified that it will “continue use the current FERC approved tariff language of Appendix KK 8.9.2(A),” i.e., assigning highest priority “[t]o Interconnection Customers that have executed power purchase agreements, and to Interconnection Customers in the current Queue Cluster that are Load Serving Entities serving their own Load.”  Id.

As previously noted in the Six Cities’ December 3, 2024 and January 29, 2025 comments requesting that the CAISO explicitly include such LSE projects in the applicable language defining the first priority allocation group, as reflected in the current definition of priority group A, the Six Cities’ support for the CAISO’s proposal is contingent on continued recognition of the current LSE project priority.  Accordingly, the Six Cities appreciate and support the CAISO’s commitment to adopting explicit tariff language reflecting this understanding.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

The Six Cities do not have any additional feedback at this time.

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

The Six Cities generally support the CAISO’s proposal to coordinate with the CPUC and Local Regulatory Authorities (“LRAs”) in connection with implementing the modified TPD allocation process on a going-forward basis.  In particular, the Six Cities acknowledge the CAISO’s agreement and commitment to close coordination with all LRAs and non-CPUC jurisdictional LSEs.  See Final Proposal at 47.  As noted in the Six Cities’ prior comments, such coordination is especially necessary to ensure that procurement requirements of non-CPUC jurisdictional LSEs are addressed for purposes of assigning deliverability to long lead-time resources.

The Six Cities encourage the CAISO to provide transparency regarding any TPD (including amounts and locations) that is set aside for long lead-time resources in the annual Transmission Planning Process reports or in another public document.

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

The Six Cities do not have any additional feedback at this time.

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative

SCE requests the CAISO include, as part of the next IPE initiative, integration of the Wholesale Distribution Access Tariff (WDAT) into the Interconnection Process Enhancements (i.e. 2023 IPE Tracks 2 and 3).

1. Please state your organization’s position and provide questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom

2. Please state your organization’s position and provide your organization’s questions or comments on the Modifications to the TPD Allocation Process

Terra-Gen appreciates the opportunity to comment on the CAISO's IPE Track 3 Final Proposal. 

Terra-Gen is concerned about the proposed changes to the proposed Transmission Plan Deliverability (TPD) Allocation affidavit deadline. Terra-Gen objects to CAISO’s proposal to move the TPD Allocation affidavit deadline from the previously established September 1st to either August 1st or August 15th. We understand the CAISO's intent to allow enough time for its planning team to validate all submissions by October 1st, and that this accelerated timeline is driven by the complexity of transitional TPD Allocation priorities and the added validation required for the new proposed headroom process. However, we strongly object to this proposed acceleration.  CAISO’s initial announcement of a September 1st deadline provided much-needed certainty to project developers. Changing this timeline by a full month, especially after four months of planning, undermines that assurance.

Terra-Gen take this opportunty to highlight the fact that developers are already working hard to meet the September 1st deadline and a variety of projects are likely to be affected by such a change, especially projects that have submitted, or plan to submit, Major Modification Applications (MMAs) to add energy storage and then seek TPD Allocations, especially given the lengthy MMA processing times we've seen recently. In short, many developers are facing a tight deadline already. Additionally, Load Serving Entities (LSEs) have based their procurement and PPA processes on the original September timeline. Changing this deadline now would disrupt and potentially derail these established processes.

Terra-Gen respectfully requests that the CAISO reconsider the proposed acceleration of the TPD Allocation affidavit deadline and maintain the previously established September 1st deadline. This would provide the necessary stability and predictability for both project developers and LSEs.

3. Please state your organization’s position and provide your organization’s questions or comments on the Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects

4. Please state your organization’s position and provide your organization’s questions or comments on the Process for Reserving TPD for Long Lead Time Generation and Storage Resources

5. Please state your organization’s position and provide any additional feedback on the broader track 3 initiative, including requests for the scope of the next IPE initiative