Comments on Draft Final Proposal

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

ACP-California appreciates CAISO work on evaluating changes to the interconnection request intake process. As CAISO continues to gain experience with the queue intake process with further processing of Cluster 15 and with the upcoming intake of Cluster 16, we hope CAISO will continue to be open to making needed modifications that may be warranted in the future. We appreciate CAISO making the modifications it deems necessary at this time through the IEP 5.0 Draft Final Proposal.  

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

ACP-California greatly appreciates CAISO’s proposal to allow operational Energy Only projects to seek deliverability (Section 3.1 of the Draft Final Proposal).  ACP-California has long supported this option and supports CAISO’s proposal to allow Cluster 15 and future cluster interconnection requests that started as Energy Only to obtain a deliverability allocation through the Commercial Operation group. However, we request that CAISO provide clarity and flexibility on the documentation of an agreement that a Cluster 15 and later customer needs to provide in order to seek an allocation through the Commercial Operation group. Additionally, we urge CAISO not to apply the additional restrictions requiring a contract to Cluster 14 and earlier projects seeking an allocation through the Commercial Operation group. Adding this new requirement to Cluster 14 and earlier projects would conflict with CAISO’s long-standing policy – and a core tenant of many recent interconnection enhancements – that seeks to retain the rules that were in place when projects entered the queue.

ACP-California has consistently advocated for a pathway for projects in Cluster 15 and future clusters that entered the queue as Energy Only to be able to obtain a deliverability allocation. Our prior comments highlighted the benefit of allowing a limited pathway for these resources to obtain a deliverability allocation and we are pleased to see that CAISO has incorporated a proposal of this nature into the IPE 5.0 Draft Final Proposal. CAISO has also proposed that, in order to seek an allocation in the Commercial Operation group, Energy Only project must “demonstrate having a procurement agreement that requires the project or Energy Only capacity to seek TPD and procures its RA eligible capacity for five or more years.” Given CAISO’s willingness to incorporate this pathway for Energy Only projects, ACP-California will not oppose including a requirement that Energy Only projects demonstrate a viable path to an offtake agreement for its RA eligible capacity. However, requiring an executed PPA simply to seek a deliverability allocation is too stringent a requirement and likely out of step with common contract negotiation processes, which, for projects selling RA, require the developer to demonstrate deliverability. Instead, ACP-California urges CAISO to require these projects to demonstrate an executed term sheet, or similar agreement, with the same provisions (a five-year or longer term for the project’s RA capacity, if it obtains a TPD allocation). Requiring a fully executed PPA should not be required for operational Energy Only projects to seek a deliverability allocation. A term sheet or similar pre-PPA agreement should be sufficient documentation for operational projects to seek a TPD allocation. In the Final Proposal, we urge CAISO to specifically note this type of contractual documentation would be allowed for Energy Only projects seeking an allocation through the Commercial Operation group.

Additionally, ACP-California opposes CAISO’s proposal to retroactively impose these requirements on the Commercial Operation group for Cluster 14. Throughout recent IPE processes, CAISO has sought to avoid changing the rules for interconnection clusters that are in process. Even in IPE 2021, CAISO looked to make the more meaningful changes to the interconnection process for Cluster 15, since Cluster 14 was already underway. It is inconsistent with CAISO’s own policy positions for numerous years to seek to impose more restrictions on Cluster 14 Energy Only projects seeking a deliverability allocation. Therefore, ACP-California opposes this element of the proposal and urges CAISO to retain the existing rules for Cluster 14 and apply a slightly more flexible requirement for Cluster 15 operational Energy Only projects seeking a deliverability allocation

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

ACP-California supports CAISO’s effort to develop additional tools to help clear stagnant projects from the queue. However, we also urge caution in implementing too stringent requirements that could actually derail viable projects, particularly at a time where projects are simultaneously trying to expedite commercialization to secure expiring tax credits and facing uphill battles with permitting challenges. Unless CAISO includes exceptions and flexibility in its proposed queue management process, ACP-California opposes this aspect of the proposal. Notably, CAISO must provide more flexibility to interconnection customers than the strict three-year limitation on COD extensions, which could be problematic particularly when Deliverability Network Upgrades (DNUs) are slated to come online later than a generator-planned COD.

Consistent with Governor Newsome’s Executive Order N-33-25, CAISO has been working to identify and prioritize the connection of commercially ready generation and storage resources. ACP-California requests that CAISO continue to ensure that it will expedite commercial ready projects where possible and avoid instances where proposed modifications on queue management could derail otherwise ready projects. The CAISO should exercise extreme caution with the implementation of its queue management proposal which could inadvertently impede development of projects in the queue.

To the extent that CAISO seeks to implement these reforms, it should do so with the capability to grant exceptions that may be necessary, including COD extension beyond three years that are clearly a result of state or federal permitting delays or a result of longer lead time network upgrades. ACP-California is concerned that CAISO’s proposed limitation could be too simplistic and restrictive. For instance, this policy could be problematic for projects seeking to align their COD with DNU online dates when a project is progressing but the DNU has a longer timeline than the Reliability Network Upgrades (RNUs). ACP-California is concerned that this situation could be viewed as the customer seeking a COD extension, though they are simply trying to align their COD with their ability to secure deliverability and meet the terms of an underlying PPA. Therefore, we request that CAISO add some flexibility to its proposed queue management process to allow COD extension beyond the strict three-year limit where there are permitting delays or where the project is seeking to align its COD with the latest associated network upgrade. These important exceptions will better position CAISO’s queue management proposal to clear the queue without inadvertently undermining otherwise viable projects.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

ACP-California appreciates CAISO ongoing diligence and efforts to improve its interconnection processes. We look forward to continuing to work with the CAISO on finalizing IPE 5.0 and on any future interconnection enhancements that may be needed at a later date, including future consideration of whether additional TPD reforms are necessary for long lead-time resources.

Additionally, we urge CAISO to reconsider its decision not to propose revisions to adjust the GIA execution timelines. As Cluster 15 studies are being released, it is becoming increasingly clear that there is a need to adjust the timelines in a way that would allow projects to wait to execute GIAs until after the completion of their first TPD allocation cycle. In our last set of comments, ACP-California highlighted that various parties had called out the disconnect between the FERC Order 2023 timeline for execution of GIAs and the CAISO’s deliverability allocation process timelines. The current timelines are highly problematic in that they can require generators to sign GIAs before knowing whether they have been allocated deliverability or not. Unfortunately, CAISO continues to decline to consider further modification to address this disconnect. However, this is an area of critical importance, and we urge CAISO to address it in the Final Proposal for IPE 5.0 proposals. As previously stated, failing to address this disconnect will result in significant (and unnecessary) churn and create a new set of questions and issues that will need to be addressed. CAISO can avoid these undesirable outcomes by simply proposing a modification to the GIA signing timelines that were a part of Order 2023. ACP-California previously noted that we believe CAISO would be well justified in proposing this type of deviation from the Order 2023 timelines at FERC and that doing so would greatly reduce the administrative and process burden of having more generators sign GIAs than will ultimately connect and of having to address situations where GIAs are signed, the generator does not receive a TPD allocation, but proceeds to commercial operation under the GIA anyway. If CAISO does not address the timing disconnect, it will have to provide guidance on what would happen in these cases and whether the project would be Energy Only, whether (because it entered the queue as deliverable) it would be eligible for a subsequent TPD allocation, etc. While it may be possible to answer these questions, ACP-California – instead – strongly supports CAISO addressing the underlying issue and proposing modifications to the Order 2023 timelines within CAISO such that projects are not required to sign a GIA before having the results of their first TPD allocation cycle. This will reduce administrative churn and the need to answer the policy questions discussed above.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

The Alliance for Retail Energy Markets (“AReM”) has no comment on this section of the Draft Final Proposal.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

AReM supports a pathway to allow operational Energy Only projects to seek deliverability, a need long championed by California Community Choice Association. As such, AReM supports the Section 3.1 proposal in the Draft Final Proposal. As other load-serving entities (“LSEs”) have commented, the new slice-of-day framework for resource adequacy (“RA”) implemented by the California Public Utilities Commission (“CPUC”) requires LSEs to show adequate battery charging capacity to count batteries as RA-eligible. AReM generally supports policies that create greater flexibility for LSEs to meet their reliability requirements. This proposal provides such flexibility in that it allows Energy Only projects to seek deliverability and become RA-eligible, providing another pathway to increase RA-eligible capacity on the grid. Recent analysis by the CPUC in support of the proposed Transmission Planning Process portfolio indicates ensuring adequate battery charging capacity will be an increasingly important consideration for maintaining grid reliability, so adding pathways to allow LSEs to meet this need successfully is logical. For these reasons, AReM supports this proposal.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

AReM has no comment on this section of the Draft Final Proposal. 

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

AReM thanks CAISO for its commitment to continuous improvement of its interconnection processes through this initiative and looks forward to reading the Final Proposal. 

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

 Avantus appreciates the opportunity to comment on the Interconnection Process Enhancements (IPE) 5.0 draft Final Proposal. We thank the CAISO for its ongoing efforts to improve the interconnection process. Avantus generally agrees with the principles behind the CAISO’s proposal; however Avantus believes the CAISO should adjust the 3-year cumulative COD request limitation of the IPE 5.0.

There is a misalignment with the study process and having to prove that a project is commercially viable by requiring an executed PPA in order to extend a project’s COD beyond 7 years in the queue, when a project that could take significantly less time to construct and be operational were assigned long lead Network Upgrades that push its COD timeline out.

As part of the Interconnection Process Enhancements (IPE) 2021, the California Independent System Operator (CAISO) revised its Transmission Plan Deliverability (TPD) group allocation framework. Under this revision, the prior Group 3 (projects proceeding without a Power Purchase Agreement, or PPA) was reclassified as Group D and subjected to new restrictions. Specifically, projects receiving a TPD allocation under Group D are now required to:

• Demonstrate a PPA within two years of receiving the TPD allocation; and
• Adjust major milestone dates only in alignment with an executed PPA or a PTO schedule delay.

The rationale for these changes was CAISO’s assertion that, despite developers’ attestation that projects could proceed without a PPA, nearly all projects ultimately require one to secure financing and achieve commercial operation. In effect, the presence of a PPA has become the primary determinant of project “viability.”

Further, IPE 2023 introduced additional constraints by requiring that any project submitting a  Material Modification Assessment (MMA) that extends its timeline beyond the seven-year Commercial Viability Criteria (CVC) threshold must demonstrate CVC compliance at the time of MMA submission.

Now, the IPE 5.0 proposal further exacerbates the timeline challenges by not allowing an Interconnection Customer to extend its COD by more than 3-years from the CAISO approved COD.

However, several critical challenges have emerged as a result of these policy changes:

1. Extended Network Upgrade (NU) Lead Times
   Network Upgrade lead times have expanded dramatically—from an estimated 12–36 months to 48–84 months in most cases, with some extending up to 120 months. This fundamental shift has been recognized in FERC Order No. 1920, which now requires ISOs and RTOs to produce 20-year transmission outlooks. These extended planning horizons directly impact both CVC demonstration and PPA timing requirements.

2. Misalignment Between Queue Duration and Project Realities
   The current 10-year interconnection queue limit and 7-year CVC demonstration requirement are no longer aligned with actual project development timelines. The original 10-year framework reflected historical planning cycles that assumed commercial operation within roughly five years of queue entry. Today, however, developers face unprecedented permitting challenges and study results that frequently include achievable milestones extending well beyond 7–10 years. As a result, projects are being forced to satisfy CVC requirements much earlier in their development cycle, long before construction or financing can reasonably proceed. The 3-year COD cumulative extensions by the Interconnection Customer driven by IPE 5.0, do not take into account the massive delays that are not under the customer’s control that are driven by permitting and utility timelines. A 3-year cumulative delay will accomplish CAISO goal of queue reduction, but will also succeed in removing viable projects with Force Majeure types of delays during the interconnection process.

3. Unreasonable PPA Procurement Timelines
   Given today’s extended project lifecycles, requiring developers to secure firm-priced PPAs 6–10 years prior to COD is economically impractical. Market conditions and energy prices can fluctuate significantly over that period, potentially leaving projects locked into uneconomic contracts. The resulting financial strain could ultimately be passed on to ratepayers.

CAISO should not impose an arbitrary 3-year cumulative COD extension requirement, but instead should reassess both the timing and definition of project viability in its queue management changes. Specifically, CAISO should:

1. Reevaluate PPA timing requirements to reflect the extended lead times and evolving transmission planning horizons under FERC Order 1920.
2. Redefine project viability to focus less on the existence of a PPA and more on demonstrable project progress—such as site control, permitting milestones, interconnection readiness, and engineering completion.
3. Create additional exceptions or extension rights for circumstances outside a customer’s control to remove PPA and CVC requirements to a reasonable extend for projects whose COD is impacted by long-term Network Upgrade needs.  Or alternatively, align the PPA requirement within a reasonable window of when the CAISO can actually provide interconnection service.

A more balanced and forward-looking approach will ensure that CAISO’s interconnection process remains equitable, consistent with Open Access principles, and aligned with the realities of modern infrastructure development.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

 CalCCA has no comments on Section 2 at this time.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) Interconnection Process Enhancements (IPE) 5.0 Draft Final Proposal. The ability to interconnect viable projects in a timely and cost-effective manner is critical for ensuring the state meets its reliability and clean energy objectives. In these comments, CalCCA recommends that the CAISO refine its proposal to allow operational energy only (EO) projects to seek deliverability so that EO projects can finance upgrades if there is not existing transmission plan deliverability (TPD) to allocate to them and the projects have resource adequacy (RA) contracts with LSEs of five or more years.

Section 3.1: Allowing Operational EO Projects to Seek Deliverability

CalCCA greatly appreciates the CAISO including a proposed pathway for operational EO projects to seek TPD. The primary difference between the CAISO’s proposal and CalCCA’s proposal is that the CAISO’s proposal would result in these projects being included in the commercial operations group rather than applying and going through the interconnection intake scoring process with other projects seeking TPD. The result of this difference is that under the CAISO’s proposal, EO projects seeking TPD through the commercial operations group would be allocated TPD only if there is existing deliverability to be allocated. Where there is not existing deliverability to be allocated, these EO resources would not be able to finance upgrades to increase deliverability, like projects seeking TPD from the outset can. This may limit the usefulness of the CAISO’s proposal, as there is currently very limited existing TPD available for allocation without upgrades.

For the reasons described in CalCCA’s August 25, 2025, comments in this initiative, including the need for development of new resources for reliability and clean energy objectives coupled with challenging market realities, a pathway for EO resources to obtain TPD is crucial to ensure the viability and cost-effectiveness of new resources to meet capacity needs.[1] Requiring EO projects to have an RA contract with an LSE for five or more years to use this pathway will ensure it is limited to projects that are commercially viable and intend to provide reliability benefits to California through the RA program subject to a deliverability allocation. CalCCA therefore urges the CAISO to consider allowing a limited amount of EO projects to finance upgrades if there is not existing TPD to allocate to them and the projects have RA contracts with LSEs of five or more years.

In comments filed on October 31, 2025, in the California Public Utilities Commission’s (CPUC) Integrated Resource Planning proceeding (R.25-06-019), CalCCA has asked the CPUC to explore including EO resources seeking TPD in its busbar mapping process, including situations when upgrades are needed to address constraints preventing these resources from obtaining full capacity deliverability status (FCDS).[2] CalCCA sees an opportunity in which EO to FCDS conversions could play an important role in affordably meeting the state’s reliability and climate needs. Including EO to FCDS conversions as a resource and/or strong signal of commercial interest in the CPUC’s busbar mapping process could provide an alternative pathway to addressing CalCCA’s concern with the limitations of the CAISO’s existing proposal that only allows conversions in areas with existing TPD. CalCCA encourages the CAISO to consider how IPE 5.0 might align with CPUC processes to accommodate policy-driven conversions. As an example, it may be prudent to prioritize conversions that align with policy needs in the TPD allocation or consider a TPD reservation similar to how long-lead time resources are handled.

[1]            CalCCA Comments on IPE 5.0 Straw Proposal (Aug. 25, 2025): https://stakeholdercenter.caiso.com/Comments/AllComments/9b0551da-cdeb-4413-8629-3801bb56231e#org-a1da5f2a-7e9a-4e52-a586-dc0d205462fa.

[2]            California Community Choice Association’s Reply Comments on Administrative Law Judge’s Ruling Seeking Comments on Electricity Portfolios for 2026-2027 Transmission Planning Process and Need for Additional Reliability Procurement, R.25-06-019 (Oct. 31, 2025).

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

CalCCA has no comments on changes to queue management and other processes at this time.  

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

CalCCA has no additional comments at this time.  

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

5.2. Transparency, rigor, and integrity of the Load-Serving Entity (LSE) commercial interest point allocation process

The California Department of Water Resources (DWR) through its Statewide Energy Office (“DWR-SWEO”) appreciates the opportunity to provide comments on the Draft Final Proposal in the Interconnection Process Enhancements 5.0 initiative. DWR-SWEO agrees with CAISO’s decision not to include DWR as an LSE for purposes of the commercial allocation process for the reasons set forth below and as stated by CAISO in the Draft Final Proposal.

First, it seems as though some stakeholders have erroneously conflated DWR-SWEO with DWR-State Water Project (SWP), which is also a division within DWR and an active CAISO market participant. SWEO (the division with central procurement authority) and SWP are two distinct divisions within DWR, each with its own statutory authority. The two divisions do not act in concert, and do not and will not procure for the same purpose.

SWEO has the authority under AB 1373 and Division 29.5 of the Water Code to engage its central procurement function if so requested by the California Public Utilities Commission (CPUC). The authority, tasks, and goals of SWEO when procuring long-lead time resources are distinctly different than SWP. SWP is its own market participant with its own procurement needs and determinations, with contracted capacity in the CAISO’s interconnection queue that is not in any way related to SWEO’s central procurement function. Furthermore, Section 80805(a) of the Water code explicitly states that the central procurement authority granted in Division 29.5 of the Water Code is separate and distinct from the powers of SWP.

One key difference in the programs is that while SWP procures to serve its own load, SWEO does not and will not have its own load and instead may procure for the benefit of utility ratepayers. As CAISO states in the Draft Final Proposal (Section 5.2, page 26), the basis for the commercial allocation process is currently the California Energy Commission coincident peak demand forecast. Since SWEO does not have any load, it is not included in this forecast and therefore CAISO cannot use the forecast as the basis for the allocation. It would be illogical to use a different forecast or some other method for one entity for the benefit of a small subset of projects.

Additionally, in advocating for DWR as a LSE, stakeholders may be referring to the narrow use case of offshore wind. However, the CPUC has requested central procurement of long-duration storage, geothermal (of all types), and offshore wind. Some of these resources are already being procured by LSEs and additional points to a “DWR LSE” may detract from this traditional procurement.

Finally, as CAISO noted, additional points to a “DWR LSE” may potentially skew the interconnection study process since long-lead time resources already receive significant points in the interconnection scoring process to advance to the study process. This may give an unfair advantage to a small subset of projects that may qualify to participate in the DWR-SWEO central procurement solicitation.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

No CPUC staff comments at this time.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

CPUC staff supports enabling Energy Only projects to seek deliverability in a fair way that enhances competition.  The proposed approach should expand opportunities for developers to finance and construct projects without a deliverability allocation and thereby give LSEs more affordable and timely pathways for additional deliverable supply. 

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

No CPUC staff comments at this time.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

Overall, CPUC staff supports the proposed changes in the Draft Final Proposal.  We look forward to additional opportunities to tighten linkages between planning, procurement, and interconnection of new resources.  

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

 No comments.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

CalWEA supports CAISO’s proposal to allow Energy Only projects in Cluster 15 and later that have completed the interconnection process and are in commercial operation to seek TPD capacity in the Commercial Operation allocation group developed in IPE 2023 Track 3.  We appreciate CAISO acknowledging the desires of developers and LSEs that support this option as a timely and cost-effective means of ensuring sufficient deliverable resources, especially in the 2029-2030 timeframe when, as CAISO states, the system will likely need additional RA capacity.

However, we encourage CAISO to eliminate the requirement that such EO projects “demonstrate having a procurement agreement with an LSE that has a resource adequacy obligation.” The purpose of the PPA requirement is to demonstrate commercial viability, ensuring the project is built.  In this case, the project has been built and can be expected to find a buyer for its RA capacity, given the economic opportunity and the near- and long-term need for system RA.

The CAISO provided similar reasoning when it found that EO projects need not post increasing amounts of commercial readiness deposits because such projects are in operation and “have no risk of withdrawal.”

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

 No comments.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

 No comments.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

No comment.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

No comment.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

Calpine appreciates the opportunity to comment on IPE 5.0 and notes that litigation challenging IPE 2023 Track 2 is still on going. Calpine appreciates CAISO’s efforts to improve queue efficiency and address the accumulation of inactive projects. However, the proposed reforms do not adequately account for the operational and regulatory realities of repowering projects. We request the following clarifications and modifications to the proposal to address these issues.

We emphasize that repowering projects are distinct from standard Energy Only (EO) queue positions. While they may appear as EO in the interconnection queue, their redevelopment efforts are tied to existing assets that already hold deliverability allocations. These projects do not trigger new long-lead transmission upgrades and do not block other projects under development. Their queue positions are transitional and should not be treated as speculative.

We also highlight that some repowering efforts have experienced delays due to factors outside of developer control, including CAISO-driven changes to retirement schedules and study timelines. Applying the proposed commercial viability criteria without accounting for these delays unfairly penalizes projects that are otherwise viable and committed to proceeding.

We recommend that CAISO exempt repowering requests from the time-in-queue requirements being extended under this proposal.  If CAISO declines to exempt repowering requests from time-in-queue requirements, we request that CAISO allow the ongoing utilization of the deliverability by the existing resource to satisfy the requirement for demonstration of commercial viability. Requiring a new EO-specific PPA for a project that is already delivering energy and holds deliverability is duplicative and unnecessary. This adjustment would better reflect the commercial reality of repowering and avoid imposing artificial barriers.

We appreciate that CAISO’s proposal clarified that delays caused by CAISO or Participating Transmission Owner (PTO) actions do not count against the three-year Interconnection Cummulative (IC) cumulative extension limit. This clarification is necessary to ensure that developers are not penalized for delays beyond their control.

In summary, we strongly recommend that CAISO exempt repowering project queue requests from the 7-year time-in-queue PPA requirement. If CAISO declines to exempt repowering queue requests from the time-in-queue PPA requirement, we recommend that CAISO allows the ongoing utilization of the deliverability by the existing resource to satisfy the requirement for demonstration of commercial viability.

These changes will ensure that the proposal supports queue efficiency without penalizing viable repowering projects.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

No comment.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

Clearway welcomes CAISO’s decision to allow C15 and later projects to seek TPD post-COD. However, under Section 3.1, Clearway has significant concerns about some aspects of the proposal. First, Clearway opposes the proposal to require an executed PPA for operational C14 and earlier projects. If an EO project has already reached COD, this is a clear demonstration that the EO project has reached commercial and economic viability. The additional requirement to show a PPA to seek TPD is redundant in this case. Additionally, the concern that an operational EO project that is awarded TPD would not offer valuable deliverability into the market is unfounded.

If CAISO opts to retain the PPA showing requirement for EO projects that have reached COD, the requirement should be expanded to include non-LSE PPAs, which would make the requirement more equitable and efficient.

Clearway also concurs with the Large-scale Solar Association’s comments that explain why requiring this group to have PPAs is inefficient, as well as LSA’s arguments against requiring a five-year minimum PPA term.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

Within Section 4.1 of the proposal, Clearway is supportive of applying the CVC to EO projects in the queue. However, the three-year COD-request extension limit for all projects should be removed from the proposal. Interconnection customers should be allowed to move their COD if the CVC are met and a PPA supports the COD. This proposal is unduly restrictive on projects at a time when significant changes are occurring that are entirely outside of Interconnection Customers' control. With uncertainty and very long timelines to resolve affected system impacts (due to non-responsiveness and lack of tariff), changes to federal permitting processes that are introducing significant timeline uncertainty for many projects, and supply-chain disruptions, projects are experiencing major delays that may necessitate a COD extension but do not mean the project is no longer viable. CAISO should remove this requirement from the proposal to reflect the reality of today’s permitting and supply chain landscape.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

Clearway recommends that CAISO reinstate Section 5.8 in the scope and allow projects in Cluster 15 to execute GIAs after the first TPD allocation cycle is complete. The argument that delaying the GIA execution post-TPD causes delays to shared NU is flawed. Based on the latest C15 schedule, TPD affidavits are due in March 2027 and LGIA execution is expected in April 2027. TPD allocation results should be available by August 2027. Extending the LGIA execution milestone to September 2027 would have a minimal impact (six months or less) to any project that is ready to fund shared NUs. This should address CAISO’s concern of unreasonably delaying any ready projects that want to proceed with construction of upgrades. If a PTO demonstrates that it is ready to proceed with a shared NU, developers could execute E&P agreements to allow that work to proceed on time. CAISO has already required existing C14 'parked' projects to secure shared NU via E&P agreements, demonstrating the effectiveness of this mechanism without impacting other IC timelines reliant on shared NU.

Clearway’s concern with the timing for LGIA execution is due to the linkage between LGIA execution and posting requirements for NU costs. Cluster 15 study results are starting to come out now, and the study reports for some TPD zones are showing significant upgrade costs: Upgrades for one TPD zone were estimated at approximately $100 million. Clearway does not take issue with the initial posting due this year, which is only 5% of the total network upgrade cost. However, looking ahead, the current schedule will force these projects to post security for 100% of the network upgrade costs, fully at-risk, before their first TPD allocation cycle is complete. (While the posting requirement upon LGIA execution is only 20% of NU costs, PTOs have a practice of requiring 100% posting within 120 days of LGIA execution, fully at-risk.)

Since queue entry in C15 was based on 150% of available TPD, ICs know that not all projects entering the first C15 TPD cycle will receive TPD, even with high commercial readiness. The stakes are even higher in the TPD allocation process now that projects that do not receive TPD will be required to withdraw. Posting tens of millions of dollars of security at-risk is not justified before ICs have a view into their projects’ chances at TPD. It is critical that this timing issue is addressed before C15 projects’ postings step up beyond 5% next year.

Within Section 5.1, Clearway recommends that CAISO consolidate and make Network Upgrade data searchable, reinstating and committing to providing data on substation access and physical interconnection feasibility. As CAISO works to finalize the removal of the preapplication process, it is imperative that CAISO, with support of the PTOs, enhances the availability of substation access data. While this data may require some upfront work from CAISO, it would be extremely valuable to understand which substations have open bays for interconnection and which do not. Subsequent updates could delve deeper into substation data, such as which substations could be expanded within the current footprints, or which substations have potential land nearby to expand.

Additionally, within Section 5.1, Clearway recommends that CAISO publish the TPD constraint mapping significantly earlier than the current schedule. Releasing this data in August provides only two months to process the information, which is insufficient given the substantial site control required for queue entry. Early publication of TPD constraint data is essential for developers to make informed decisions., CAISO should release preliminary TPD constraint mapping data as soon as possible following the TPD allocation process in March, and update the TPD constraint mapping after the TPP release in May.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

We appreciate the opportunity to comment on IPE 5.0 Draft Final. Stakeholders have requested that a wide array of issues be addressed within this initiative; however, CAISO has appropriately remained committed to keeping the scope focused, allowing recent interconnection policy reforms to take hold and evaluating their results before undertaking broader changes. The draft final proposal includes a number of refinements that EDFps supports, including efforts to make non-LSE counterparty contracting more flexible, to enable smaller LSEs to allocate up to 50 percent of their load share or 500 MW, to allow Energy-Only projects in Cluster 15 and later that are in commercial operation to seek TPD through the Commercial Operation allocation group, and to incorporate distribution-system interconnection projects into the intake scoring and 150 percent study-limit processes, along with several other procedural improvements that will strengthen transparency and efficiency across the interconnection framework. 

In comments below we outline concerns with other proposals in the paper and concerns where proposals have been dropped, and respectfully request that CAISO either modify the proposals, or table them for workshopping in a future IPE initiative designed for more robust policy discussion

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

We strongly support the CAISO's new proposal in Section 3.1. This is a significant and positive improvement from the Straw Proposal, and it directly addresses the recommendation we made in our previous comments.

Allowing proven, operational assets to compete for Transmission Plan Deliverability (TPD) is a critical, low-cost pathway to enhance grid reliability and is consistent with the goal of maximizing our most viable resources. The new requirement for a 5-year Resource Adequacy (RA) procurement agreement is a robust and appropriate viability screen. It effectively addresses concerns about speculation while providing a necessary market signal that identifies locations where viable generation already exists, which can inform future TPD upgrade planning.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

Section 4.1: Manage the accumulation of stagnant projects in the queue

We oppose the proposals and find the proposals in this section to be unduly limiting. Both the new criteria for Energy Only projects and the new cap on extensions fail to account for the current realities of project development.

We appreciate and share CAISO’s objective to maintain a manageable and commercially viable interconnection queue. Those of us who work closely with projects at every stage of development are deeply familiar with the burden that queue management places on both developers and the ISO.

That said, we are concerned that the current proposal to apply Commercial Viability Criteria (CVC), including an executed PPA, to all projects seeking an extension beyond seven years. We believe this, is unduly limiting given the widespread market development difficulties. The current proposal that projects in queue for seven-years be automatically withdraw for failure to demonctrate CVC are likley to remove viable projects facing delays beyond their control.

In prior comments, EDFps and others noted that federal-level policy shifts are significantly changing the permitting and procurement landscape. These include:

• Federal reforms to environmental and land-use permitting processes;
• Supply chain and materials procurement constraints driven by federal manufacturing incentives; and
• Labor market and wage policy changes affecting project timelines.

Furthermore CAISO and PTOs are seeing minimum construction times push beyond 7 years. PTOs assert that these timelines would not exist if the queue was leaner, but we wonder if that is true, or if withdrawng some projects would just create a situation where a future cluster will trigger the same needs again, "kicking the can down the road" and ultimately not solve transmission needs. Said another way, if these facilities are an eventuality, it's not appropriate to use their existence as a reason to further tighten queue policies. This, and the policy items mentioned above, are real-world developments that are extending project development schedules in ways neither developers nor the CAISO could have anticipated when the original seven-year limit was conceived more than a decade ago.

CAISO has a unique opportunity under this initiative to map out those external drivers of delay and provide structured relief mechanisms for projects that are otherwise viable but delayed due to circumstances beyond their control. The proposal would be much more palatable if these sorts of delays, which are beyond the interconnection customers control and would exist even in a world where PTOs build their own generation. These detals should be considered outside of the interconnection customer's control, rather than coloring these COD extensions as “elective.” The proposal to cap cumulative, project-requested COD extensions at 3 years is also unduly limiting. These arbitrary time limits do not reflect the fact that large and long-lead-time upgrades are still needed to meet the state's ambitious clean energy goals.

The proposal to skip breach procedures seems to eliminate the due process that projects currently receive via pro-forma FERC approved GIA language. Breach procedures are a cornerstone of contracting, and provide an opportunity for case-by-case review before a project is terminated. Reinstatement into the queue is extremely difficult once a project is withdrawn, so the value of that individual review cannot be overstated.

A contributing factor to perceived stagnation in the queue is the lack of longer-term deliverability certainty. Stakeholders have repeatedly urged CAISO to consider multi-year deliverability allocations, similar to the structure of the new RNU (Resource Need Upgrade) capacity allocations.

Expanding interim deliverability beyond one year, or enabling a “multi-year conditional deliverability” structure, would substantially improve the marketability of otherwise viable projects.

We also encourage CAISO to explore whether precursor or intra-cluster network upgrades can be considered as part of that framework to support project advancement in constrained zones.

We understand and support the ISO’s intent to bring accountability and transparency to the queue. However, rather than imposing automatic withdrawal:

• Retain individualized review through the existing breach process or a modified “viability review” panel;
• Establish clear criteria to recognize federal permitting or procurement delays as valid grounds for extension;
• Allow Energy-Only projects to demonstrate operational viability or market participation in lieu of a PPA; and
• Pair stronger queue management with forward-looking reforms to deliverability and marketability.

These adjustments would balance the ISO’s need for queue discipline with California’s need to maintain a robust pipeline of buildable, policy-aligned resources.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

We are also concerned with the Draft Final Proposal to move several critical issues out of scope, particularly Section 5.8: Adjust required generator interconnection agreement (GIA) execution to be after all deliverability allocations are complete.

As we and other stakeholders have repeatedly stated, the current timeline requires interconnection customers to execute a GIA and post significant financial security before they know if they will be allocated deliverability. This creates an unreasonable and significant commercial risk for even the most viable projects.

While we understand CAISO's intent to keep projects on schedule, this specific timing misalignment is a major source of friction that can deter, rather than accelerate, the development of needed resources. We strongly urge CAISO to prioritize addressing this GIA execution and funding timeline issue in the very next IPE initiative, as it remains a critical barrier to interconnection.

CAISO’s initial justification for the misalignment between C15 GIA timeline and the TPD Allocation Report publication was to better align C16 and on with CAISO’s TPP and other processes. However, with the unforeseen Order 1920 compliance requirements, the 2027-28 TPP will be a transitional cycle to the new 2030 Comprehensive Plan and the 2030 Long Term Regional Plan. Cluster 16’s GIA timeline and the 2028 TPD Allocation Report might be aligned but will not remain aligned with Cluster 17 and on. EDFps urges CAISO to reconsider C15 GIA timeline with this new understanding.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.1 Non-LSE Commercial Interest (CI) points process: 

Intersect appreciates the CAISO’s efforts to improve the Commercial Interest allocation process and agrees with the proposed changes to the non-LSE affidavit.

2.2 Cap on Full Allocation Election

Intersect supports the modified cap on the full allocation election concept to enable broader participation from LSEs.

Intersect further requests that the CAISO provides detailed, representative examples to illustrate how the proposed methodology would be applied in practice and its potential impact on different LSE types.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

3.1 Allowing operational Energy Only projects to seek deliverability

Intersect supports the CAISO’s proposal for Cluster 15 and later Energy Only projects to seek a post-COD TPD Allocation.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

4.1. Manage the accumulation of stagnant projects in the queue: 

Intersect appreciates the CAISO’s effort to clear the queue from non-viable projects that are clogging the queue and supports subjecting EO projects to the CVC test.

We, however, believe that the new proposed restrictions to cumulative COD extensions beyond 3 years is overly constraining for the following reasons:

1. It does not take into account justified unavoidable delays that extend beyond developers’ control (e.g. federal permitting delays, etc.).
2. This rule, if implemented, may inadvertently jeopardize perfectly viable projects that require some additional time to go online.
3. The CVC criteria provide a suitable assessment of viability and should be enough to address stagnant projects in the queue.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

As mentioned in previous rounds of comments, Intersect urges the CAISO to either reconsider including the below topics in this initiative, or to commit to address them in the following IPE track.

1. Delaying the LGIA execution deadline till after the first TPD Allocation cycle results for the following reasons:

• Risk of Network Upgrade delays

The CAISO’s intention to ensure that Network Upgrade construction for “first-ready” projects remains on schedule is valid and can be achieved via execution of Engineering & Procurement agreements rather than GIAs by such first-ready projects. This is also achieved by the CAISO Tariff that requires other projects to make the necessary postings for shared Network Upgrades as soon as any one project makes their posting to kick them off, to avoid any delays.

• Abandoned partially completed NUs

Imposing an early GIA execution that precedes TPD allocation, will likely result in a series of abandoned partially completed NUs that were initially triggered by projects in the queue, that ended up not receiving TPD allocation and withdrawing from the queue, rendering such upgrades unneeded.

• GIAs may include Infeasible CODs

By executing a GIA ahead of receiving TPD allocation, Interconnection Customers may be signing up to an infeasible COD that would require extension should they not receive TPD allocation or should their TPD allocation be contingent on long lead time DNUs.

2. Sharing TPD constraints mapping as soon as the data is available

• TPD constraints mapping should be published as soon as the 2025-2026 Transmission Plan is complete in May 2026, in preparation for the Cluster 16 intake process, to ensure Interconnection Customers have enough time to secure land rights and site their projects.

3. The CAISO should take a more active role in resolving Affected Systems impacts

• Affected Systems impacts are often challenging to resolve, and the CAISO currently lacks a formal process for resolving these impacts, requiring ICs to work directly with neighboring systems, who don’t necessarily have a standard study methodology and generally have very little incentive to expedite their studies and finalize mitigation agreements.
• Projects would highly benefit from the CAISO taking a more central role in evaluating and resolving affected systems impacts in the interconnection study process. At a minimum, the CAISO should impose timeline constraints for Affected Systems to complete their studies, determine impacts, execute a mitigation agreement, and avoid delays to projects energization.

4. Implement solutions to mitigate the delays in Network Upgrades currently plaguing the industry

• Increased oversight on PTO-lead Network Upgrades and more visibility for Interconnection Customers onto expected delays.

PTO reports indicate that more than 60% of planned upgrades are experiencing delays averaging 4.4 years, effectively doubling their timelines.The Transmission Development Forum, while helpful to inform updated NU ISDs, does not provide much details or justification of expected delays, nor does it open the door for the potential collaboration between PTOs and ICs to find creative solutions to bring in ISDs (e.g. leveraging ICs’ supply chain for potential procurement acceleration).

• A consistent & proactive procurement approach across different PTOs

Historically, different PTOs have provided different vendor and factory requirements to ICs. PTOs should agree on a combined vendor list and vendor factory list to streamline the procurement of equipment needed for Network Upgrades. This would also allow them to benefit from the below:

1. Create larger purchasing power across the PTOs
2. Create an emergency pool of equipment that could be shared across PTOs during times of crisis (e.g. wildfire recovery)
3. Execute larger, cancelable capacity reservations in anticipation of future needs (cancelation costs can limit cost liability of Network Upgrades that may eventually not be required). This can also significantly reduce network upgrade timelines by shrinking procurement lead times, notably for Short Circuit Duty Upgrades, where breakers lead times can span multiple years

Additionally, it is unclear why certain PTOs may deem certain vendors/factories to be satisfactory, while others do not, while all such PTOs are operating facilities included in the CAISO system. It's unclear how the system can be deemed reliable if that's truly the case, since a major failure in one PTO's service territory will almost certainly have cascading impacts in another PTO's territory.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.1 Non-LSE Commercial Interest (CI) points process: 

LSA suggested that the attestation concerning compliance with corporate sustainability goals be removed from the non-LSE CI points affidavit, and we support that proposal here. 

2.2 Cap on Full Allocation Election

The CAISO proposal would set a new cap on Full Allocation election capacity at the lesser of 500 MW or 50% of the LSE forecasted RA load share, based on CEC Coincident Peak Demand/Load Ratio Share Forecasts.

LSA supports lifting the cap but is having trouble determining whether and how much this would actually loosen it. For example, it’s not clear how the proposal described above compares to the current system, where the CAISO multiplies the total FCDS points by 50%, allocates them to LSEs by load share, and LSEs can award all the points to one project up to 150% of their allocation.

It would be very helpful if the CAISO could include, in the final proposal: (1) A link to a specific report or other CEC document where the “Coincident Peak Demand/Load Ratio Share Forecasts” are posted; and (2) at least one example, illustrating how that information would be used in the new calculation and how it compares to the current methodology.

2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes

The CAISO’s proposal is for distribution-level projects to participate in the cluster-study process, including the competitive intake process, on the same basis as transmission-level projects.  The CAISO said at the recent stakeholder meeting that it will work with distribution providers to determine project eligibility.

The CAISO should clarify in the final proposal that:

• Distribution-level projects can qualify for post-COD Commercial Operation Group TPD Allocations.  If they must follow the same rules as transmission-level projects, they should have the ability to participate in this part of the process also.

• This proposal does not impact the existing Deliverability for Distributed Generation process.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

3.1 Allowing operational Energy Only projects to seek deliverability

LSA has supported an opportunity for Cluster 15 and later Energy Only projects to seek a post-COD TPD Allocation and appreciates the CAISO adopting this approach.  However, LSA has two specific concerns about the proposal as stated:

(1) The PPA requirement for Commercial Operation Group TPD Allocation requests, which should be eliminated, especially for C14 and earlier projects and, if retained, exclude any minimum-term requirement; and

(2) Certain statements concerning TPD allocation transferability, which should be corrected or modified in the final proposal document.

Both of these concerns are described in more detail below.

PPA requirement for Commercial Operation TPD Allocation requests

LSA has three significant concerns with the requirement for an executed LSE PPA to submit a Commercial Operation Group TPD Allocation request.

• Executed PPA requirement for Cluster 14 and earlier projects:  The CAISO said at the recent stakeholder meeting that “consistency” was the reason for imposing this requirement on these projects, i.e., it proposes to require a PPA for Cluster 14 projects because it is requiring a PPA for Cluster 15 and later-queued projects. 

The CAISO retained the Commercial Group for these projects in order to minimize retroactive rule changes.  They have already lost the right to unlimited pre-COD TPD Allocation requests, and “consistency” is not sufficient justification for imposing a new restriction on exercise of this already greatly limited opportunity. 

• Executed PPA requirement generally:  There is no need for projects that have reached COD to demonstrate commercial or economic viability, so it is not clear what purpose an executed PPA serves for any Commercial Group projects, in any cluster.  There is no reason to expect that projects with valuable deliverability will not offer it in the market, with or without an executed PPA before the award is made.

In addition, given the already existing viability proof, it is wasteful and inefficient to require this group to have PPAs just to request TPD Allocations.  For example:

• LSEs have provided plentiful feedback that they prefer to devote their scarce time and effort to negotiating PPAs with projects that have already received TPD Allocations, usually only a subset of the projects seeking such allocations. 

• PPA execution typically requires developers to post expensive security, some of which may not be releasable if the project does not receive a TPD allocation. 

• Even if a TPD Allocation is received, it may depend on upgrades not scheduled for completion for many years afterward, making it much more sensible for all parties to wait until after the allocation process for any PPA execution.

• Five-year minimum PPA term:  This minimum-term requirement was originally introduced to ensure that PPAs were legitimate bases for project financing and other viability proof.  Projects that have reached COD have already demonstrated their viability, as noted above, and there is nothing wrong with such projects deciding to sell their Resource Adequacy on a short-term or seasonal basis. 

In fact, there is a legitimate need for such flexible RA arrangements, e.g., to provide substitute RA for RA Resources on Planned Maintenance Outages, for RA Resources to avoid PPA RA deficiency penalties, or for LSEs seeking temporary or bridge resources to compensate for late project CODs or failures of contracted resources.  Thus, if any PPA requirement is imposed (which, as noted above, we believe is not necessary), there should be no minimum term.

Certain statements regarding TPD Allocation transferability

LSA asks the CAISO to either change or correct certain statements in the Proposal, Section 3.1, specifically, this text on p.17:

Any TPD that is allocated through the Commercial Operation allocation group cannot be transferred. In addition, the ISO includes the clarification that allocations obtained through allocation group D and the Conditional allocation group are not transferable.

LSA offers the following comments on this text.

• Transferability of Commercial Operation Group TPD Allocations:  TPD transfer restrictions for these allocations would be a new condition not supported by the tariff (GIDAP or RIS) or discussed at all in the stakeholder process.     

For example, TPD transfers within projects, and to other projects at the same POI and voltage level, are allowed, with no exclusions for the Commercial Operation Group.  The Proposal contains no justification for this additional restriction for this allocation group, and it should be removed in the Final Proposal. 

• Transferability of Group D TPD Allocations:  Likewise, there is no support in the tariff or BPMs for the Proposal statement about restrictions on Group D allocations (other than ensuring that the “to” project assumes the same retention requirements, a condition for transfers generally).  For example, the BPM for Generator Management, Section 6.5.4, contains an explicit example of a TPD transfer from a Group D project:

3. If Project A requested and received FCDS via Group D, retained that TPD allocation in the following retention cycle via demonstration of being shortlisted or actively negotiating a power purchase agreement, and then requested a TPD Transfer to Project B, Project B must comply with the Group D retention requirements, including the demonstration of an executed power purchase agreement by the next TPD retention cycle.  

• Transferability of Conditional Group TPD Allocations:  Neither Appendix KK (RIS) language nor the IPE Track 3 materials (the last time the CAISO addressed TPD transfers in a policy initiative) contain any restrictions on Conditional Group TPD transfers, separate from other C15+ TPD transfers.  All these documents refer to C15+ TPD transfers generally, not to any distinction between different TPD Allocation groups.

For example, the Track 3 Board memo states (on p.5) that TPD can be transferred to and from Cluster 15 and later-queued projects under certain conditions, with no exclusion of Conditional Group TPD Allocations:

Deliverability transfers from cluster 15 and later clusters to earlier queued projects will be prohibited. Intra-cluster transfers will be permitted for cluster 15 and later projects in the deliverability study group, following existing rules. Deliverability transfers from cluster 14 and earlier to cluster 15 will be permitted, with the receiving customer maintaining the requirements and obligations of the transferring project. Finally, the ISO proposes to clarify that energy only projects may not submit a PPA requiring deliverability unless they are using it to seek deliverability.

Also, RIS 8.9.9 (Deliverability Transfers) states as follows, for C15 and later-queued projects, again with no exclusion of Conditional Group TPD Allocations:

An Interconnection Customer may request to reallocate its Deliverability among its Generating Units and to other Interconnection Customers interconnected at the same substation and at the same voltage level pursuant to Section 6.7.2.2 of this RIS, Article 5.19 of the LGIA, and Article 3.4.5 of the SGIA, as applicable. A repowering Interconnection Customer may transfer Deliverability as part of the repowering process pursuant to Section 25.1.2 of the CAISO Tariff. An Interconnection Customer expanding its capacity behind-the-meter as a modification request also may transfer Deliverability as part of that process, or subsequently under the other processes in this Section.  (RIS 6.7.2.2 is just the general “Modification” section.)

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

4.1. Manage the accumulation of stagnant projects in the queue:  LSA comments below on the two main elements of this proposal.

• Energy-Only Commercial Viability Criteria:  LSA has supported CVC applicability to EO projects and supports this proposal.  However, the Proposal describes the PPA compliance-extension provision in an incomplete fashion, referencing only the ability to delay compliance by one year after the COD extension request beyond 7 years in queue is made. 

The CAISO should clarify in the final proposal that the EO CVC PPA compliance-extension provision is the same as in the FCDS/PCDS CVC, i.e., that the executed PPA is due at the later of one year after the COD extension is submitted or 8 years in queue.

• Three-year COD-request extension limit for all projects:  This new rule, newly proposed in the Draft Final Proposal, is unduly restrictive.  Projects need more flexibility to deal with federal policy and supply-chain uncertainties, not less, and there is no need for this additional restriction if a project is demonstrating annual CVC compliance.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

LSA asks the CAISO to reconsider excluding the topics from below from this initiative. 

• 5.8 Adjust required generator interconnection agreement (GIA) execution to be after all deliverability allocations are complete:  The Proposal does not address the many problems under the current approach that make it infeasible.

• 5.1. Provide additional consolidated and searchable data on network upgrades – and more:  The Proposal does not address the larger issues of the information needed to make the new interconnection process work efficiently and in a cost-effective manner, given the increased requirements applicable earlier in the process.  While the potential solutions do not require tariff changes, this information is critical to realizing the full potential benefits of the new framework.

LSA’s reasons for making these reconsideration requests are explained further below.

5.8 Adjust required generator interconnection agreement (GIA) execution to be after all deliverability allocations are complete

There are several ways to address this problem, but ignoring it will not make it go away.  The Draft Final Proposal determination not to change the current schedule does not address any of the issues LSA and others have raised with the current process.

Specifically, the current GIA execution and TPD Allocation sequencing requires ICs, and the respective PTOs, to execute an agreement that – if the project does not receive a TPD Allocation – will commit both parties to begin incurring costs and payments for upgrades to accommodate a project that may not exist two years later (if an allocation is not received on either of the two remaining tries).  The Proposal does not address this problem at all.

This is a worse problem under the new interconnection framework.  Cluster 14 and earlier projects failing to receive TPD Allocations could: (1) proceed as Energy Only; and (2) continue to try for TPD Allocations every year, before and after COD.  Under the new framework, C15+ projects seeking deliverability that receive no TPD Allocations will simply be removed from the queue.  Thus, any PTO and IC efforts and resources spent on those projects will simply have been wasted.

LSA understands the CAISO’s concern about shared Network Upgrades (SNUs), to keep all projects in a cluster requiring those upgrades moving forward, and that the provisions in GIDAP 11.3.2.6 (Shared Network Upgrades) do not appear to be included in Appendix KK at this time.  However, it would be better to explore extending that concept (including the E&P Agreement instrument where GIAs have not yet been executed) to Commercial Readiness (CR) Deposits under the RIS framework than to require PTOs and developers to negotiate and execute GIAs, and begin expending scarce resources, for projects that could very well prove to be non-viable. 

Requiring FCDS projects to execute GIAs before they know whether they will receive a TPD Allocation leaves developers few options other than to suspend their GIAs, to avoid making commitments that may not ever be needed.  The CAISO can expect to see many more project suspensions for PTO’s Interconnection Facilities and non-shared NUs if this problem is not addressed.    

At a minimum, if GIA execution is required and a project does not receive a TPD Allocation on the first try, CODs and other project milestones – including postings for non-shared NUs – should be delayed automatically by a year.  (This is similar to the milestone delay CAISO offered C14 projects earlier, for the same reasons related to TPD allocations and COD uncertainty.)  If the project does not receive a TPD Allocation on the second try, then a second 1-year delay should be granted.  This would at least postpone the need to start PTO and developer construction for potentially infeasible projects that may never be built.

5.1. Provide additional consolidated/searchable data on NUs – and more

The demands on developers to meet new intake-process rules are far greater under the RIS than before, especially given the new Site Control rules.  The CAISO should assist developers in meeting these responsibilities by providing more information, and earlier, on which Points of Interconnection (POI) are actually feasible, in two ways:

• Deliverability information:  The CAISO should provide preliminary Cluster 16 POI/TPD constraint mapping data in March-April 2026 – including identification of likely Merchant and TPD Zones – i.e., significantly earlier than the current schedule.  

The CAISO first released C15 POI mapping data in August 2024, over a year before the December 1^st, 2025 Interconnection Request re-submittal date, based on the results of the 2023-2024 TPD Allocation cycle.  While the data were updated several times before the C15 application window, developers had a valuable opportunity to identify potentially promising or infeasible POIs far in advance and take action to secure (or release) land rights accordingly.  Even then, the process was challenging.

A July 2026 data release provides only two months to process the information before the C16 application window opens.  That is much less than for C15, where the potential projects were already identified by that point; it is simply insufficient for informed decisions on project locations, and finalization of the substantial Site Control arrangements required for queue entry. 

• Substation interconnection information:  This is the logical counterpart to the CAISO’s efforts to focus FCDS project development where there is available deliverability.  Information about which substations can readily accommodate project interconnection (both FCDS and EO projects) would allow developers to concentrate their efforts on the most available substation locations (especially given the timing challenges discussed above), just as POI/TPD constraint mapping allows developers to focus FCDS project development on locations with available TPD. 

LSA understands the effort needed to provide detailed information, but the CAISO and PTOs could start by releasing information as soon as possible on which substations have available interconnection capability – e.g., open bays – and which have none currently.  PG&E already took that approach on its own initiative – though late in the process – for Cluster 15; CAISO could coordinate PG&E updates, and information from other PTOs, for earlier release in the C16 intake process. 

Later enhancements should include data on which substations: (1) could be expanded within the current substation footprint; (2) have feasible substation expansion potential; or (3) have no substation expansion potential.  This information may require more analysis but should still be provided, to increase the efficiency of the intake process.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

NCPA appreciates the CAISO’s consideration of its concerns with the expanded allocation election and believes that the limited expansion of the cap is a reasonable way to proceed.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

 No comments at this time.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

 No comments at this time.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

NCPA supports the CAISO’s approach of limiting changes to the process to items it committed to investigate further and to actual problems raised by stakeholders, in order to better assess how the Track 2 reforms are working.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

PG&E has no comments in this section. 

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

PG&E supports CAISO’s inclusion of the opportunity for energy-only projects to receive TPD after they come online. PG&E also appreciates CAISO’s reasons for not addressing the “three strikes” policy, whereby a project that has not received TPD after three cycles must withdraw from the queue.  PG&E proposes the CAISO actively monitor these projects and identify reasons for failure that may not warrant queue withdrawal and/or to reconsider the logic associated with the policy. 

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

PG&E supports CAISO’s proposal to apply commercial viability criteria to all projects requesting an extension of the project’s Commercial Operation Date (COD) beyond 7 years. PG&E further requests that CAISO clearly define the timeframe within which projects must submit a Material Modification Assessment (MMA) when they fail to meet milestone dates outlined in their Large Generator Interconnection Agreement (LGIA). 

Additionally, PG&E recommends that CAISO establish a firm deadline for all pre-Cluster 15 projects with executed LGIAs to submit their third financial security posting. This measure would help mitigate delays associated with the procurement of long lead-time materials and support timely project development. 

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

PG&E has previously expressed the need for additional information transparency. For example, while Cluster 14 Phase 2 reports list queue positions behind each constraint, there is no easily searchable database that lists queue positions and all the constraints impacting each queue position. PG&E appreciates that developers may consider this information sensitive, but, as an LSE, PG&E believes that making more information available will help inform the CPUC’s Integrated Resource Planning process as well as other planning activities.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

REV has no comment at this time. 

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

REV has no comment at this time. 

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

CAISO must ensure that the proposed approach aligns with the current commercial viability criteria for projects. These criteria permit extensions beyond seven years from the interconnection request date and an eight-year COD from the original IR date on an exceptional basis. 

Based on these criteria, our understanding is that the ISO’s proposal to limit extensions to three years from the COD should still allow projects to remain in the queue for up to ten years. However, we want to confirm that this total duration will not be reduced in cases where a project’s LGIA-based COD is less than seven years before commercial viability criteria apply. Applying a three-year extension on top of an earlier LGIA-based COD would limit the project’s ability to utilize the full ten-year duration. For example, a project that entered the queue in 2020 with an LGIA-based COD of 2026 should still be able to extend its PPA-based COD to 2030 rather than 2029 under this framework. 

Additionally, if PTO-driven network upgrade delays extend a project’s COD beyond seven years, CAISO should allow projects to adjust their PPA-based COD incrementally to align with the revised PTO schedule. This is especially important given the long lead-times and delays currently occurring for network upgrades. For example, if the PTO schedule does not have the network upgrade expected until 9 years, then the project should be permitted to remain in the queue for 12 years (9+3) rather than 10 years under the ISO’s proposal. 

CAISO may already be considering this approach, but providing clear examples in the final documentation would help ensure consistent understanding among all stakeholders.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

REV has no comment at this time. 

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

San Diego Gas and Electric (SDG&E) thanks CAISO for its effort to address remaining stakeholder concerns regarding the previously approved Interconnection Process Enhancements. As noted in prior comments, SDG&E appreciates and supports the effort CAISO has dedicated to refine elements of the IPE proposal, particularly with respect to the latest set of revisions to the full allocation election, rules for energy-only projects seeking deliverability, and other aspects of the final design.

SDG&E’s comments focus on the following elements of the proposal that have changed in the Draft Final Proposal, as well as a suggestion for continued monitoring that was not adopted.

• Section 2.2 – Cap on Full Allocation Election: SDG&E appreciates CAISO’s continued work to acknowledge the concerns of smaller LSEs regarding their ability to prioritize projects in the queue under the full allocation election methodology. SDG&E strongly supports the revised methodology for determining an LSEs cap, as it provides much needed flexibility to indicate commercial interest for larger projects that align with procurement needs. SDG&E also supports the 500MW threshold, which serves as a reasonable and evidence-based upper boundary. However, to enhance transparency and assess the effectiveness of this revised approach, it may be useful for CAISO to report on the outcomes of the full allocation election and the new criteria in its report on the C16 intake results. SDG&E suggests CAISO present analysis on these outcomes to the extent they are generalizable and can maintain customer confidentiality.
• Section 5.2 – Transparency, rigor, and integrity of the LSE commercial interest point allocation process: Based on the description in the Draft Final Proposal, at this time it is not possible for CAISO to allocate additional time for LSEs to review the full set of eligible projects prior to submitting final scoring decisions due to tight sequencing of processes. However, SDG&E notes CAISO’s commitment to reviewing the overall process timeline and believes these timelines may warrant additional adjustments following additional experience via the C16 window. We look forward to continued engagement on this topic in the future if warranted.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

No comment.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

SDG&E supports the CVC framework outlined in Section 4.1 at a high level, as it incorporates elements of the previous Track 2 proposal and introduces a mechanism to address stagnant projects in the queue. This represents a positive step forward.

However, SDG&E remains concerned that projects could still remain in the queue for an excessively long period. For example, a project with an IR date of 2024 could have a COD of 2034, and if it demonstrates CVC, it could be extended for an additional seven years (to 2041). When combined with the maximum COD extension limit via MMA/PTA of three years, a project could potentially remain in the queue until 2044—nearly 20 years. This raises questions about whether the proposal adequately addresses long-term queue management. SDG&E recommends that CAISO clarify that a project may remain in the queue for a maximum of seven years from the receipt of its IR, with the possibility of extending up to eleven years through the one-year cure period and the three-year maximum COD extension allowed via MMA when a project has a PPA. This approach will help ensure that projects are less speculative and only enter the queue with a genuine intention of moving forward after completing the required studies.

Additionally, SDG&E encourages CAISO to clarify that Section 4.1 proposal will apply retroactively to all projects currently in the queue, not just those entering the process going forward. Meaning that any project that has been in the queue for more than seven years should enter a one-year cure period and only remain in the queue if it has an executed PPA. For these projects, the COD should be extended to the greater of three years or the duration of their assigned longest lead-time construction item. The CAISO interconnection queue is already substantially saturated, even before accounting for Cluster 15 and future clusters. This level of congestion underscores the urgency of implementing effective measures to manage long-term queue participation and ensure that interconnection resources are allocated to viable projects.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

No comment.

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.2 – The Six Cities support the CAISO’s proposal to revise the cap on the full allocation election option as proposed in the Draft Final Proposal.  The Six Cities agree that an example of how the revised cap will be determined would be helpful in assisting stakeholders’ understanding of the Draft Final Proposal.

2.3 – The Six Cities do not oppose the CAISO’s proposal to require Wholesale Distribution Access Tariff (“WDAT”) projects that require deliverability to be included in the CAISO’s intake scoring process.  The Six Cities’ understanding of this proposal is that LSEs may allocate commercial interest points (including exercise of the full allocation election option) to WDAT projects and that no changes to the deliverability allocation process itself (including the currently-effective requirement that WDAT projects are subject to this process if they seek deliverability) are being made. 

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

3.1 – The Six Cities support the CAISO’s proposal to allow operational Energy Only projects to seek deliverability through the Commercial Operation allocation group.  There could be value in exploring whether to permit Energy Only projects located behind deliverability constraints to also seek allocations contingent on the project’s agreement to fund any required deliverability upgrades.  If the complexity of or policy issues surrounding implementation of this change to the Draft Final Proposal make it infeasible, then it would make sense to move forward with the Draft Final Proposal and consider in a future IPE process whether expansion of the policy is needed and would be workable. 

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

The Six Cities do not have comments on the proposals in section 4 relating to Queue Management and other topics. 

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

The Six Cities have no additional comments at this time. 

1. Please provide your organization’s comments on Section 2: Interconnection Request Intake Process.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.3 Incorporating WDATs into the intake scoring and 150% study limit processes

SCE supports the CAISO’s proposal to require distribution-level projects seeking to participate in the CAISO markets with deliverability to take part in a cluster deliverability study.  As part of this process, distribution projects will be required to submit their project intake scores using the same application process that CAISO interconnection customers are required to use to provide their scores during the open window period of a new cluster. SCE appreciates CAISO’s willingness to work with the UDCs/PTOs to validate eligibility of a distribution-level project seeking full capacity deliverability status. However, SCE seeks clarity from the CAISO on how the collaborative process will be implemented.  SCE requests the CAISO provide additional detail, to the greatest extent possible, on how the coordinated process will work, particularly the timing of the Interconnection Request submittal and provision of scores during a cluster’s open window.  Regarding implementation and coordination details outside those included in the CAISO tariff modifications, SCE expects to be actively involved in any efforts to change the Business Practice Manual and expects the CAISO to actively reach out to the PTOs to ensure consistency with the tariff and overall coordination.

Separately, as a follow-up to the CAISO’s statement that “in the ISO tariff WDAT projects are not eligible to participate in the Merchant option, which the ISO does not propose to change”, SCE requests the CAISO further explain why WDAT projects are not eligible, as WDAT customers are likely to view this as discriminatory.

2. Provide your organization’s comments on Section 3: Changes to Deliverability Allocation Practices.

SCE currently has no comment.

3. Provide your organization’s comments on Section 4: Changes to Queue Management and Other Processes.

4.1 Mange the accumulation of stagnant projects in the queue

SCE suppports CAISO's proposal to apply  commercial viability criteria, including having an executed PPA that matches the project's deliverability status to all projects, including EO projects, seeking COD extensions beyond 7 years.  Projects that cannot meet such commercial viability criteria will be withdrawn

Additionally, the Draft Final Proposal indicates “The ISO has implemented other components of the IPE 2023 track 2 initiative, such as the posting dates for shared network upgrades and first notice to proceed, to address this broader issue. Both commercial development and infrastructure development must work in tandem to onboard the new resources necessary to meet near-term reliability needs and long-term policy objectives”.

In SCE’s prior comments submitted concerning the IPE 5.0 Straw Proposal, SCE raised the following concerns regarding the use of the term “Construction Activities” in GIDAP Section 11.3.2.6 (CAISO did not address this concern in the Draft Final Proposal): The outcome of IPE 2023 Track 2 discusses setting requirements on “when activity has begun on the network upgrade and interconnection facilities.” However, the subsequent final tariff references a requirement using the specific term of starting “Construction Activities” no later than 30 days after receiving the third interconnection financial security posting. This CAISO term is defined as occurring “after receipt of all appropriate governmental approvals needed.” Licensing and permitting activities covered as “Pre-Construction Activities” can take years to secure and it is not reasonable that such activities can be completed within the 30-day timeframe. To make Section 11.3.2.6 practical and feasible, the CAISO tariff needs to be revised to instead require the start of “Pre-Construction Activities” within 30 days. Alternatively, if the CAISO prefers to continue with the use of “Construction Activities”, then the CAISO must either limit the type of “Construction Activities” that will be subject to the 30-day window or remove the 30-day requirement from the tariff.  As written, the tariff is unworkable, and it must be modified. 

SCE requests the CAISO clarify if the CAISO intends to add the shared network upgrade requirements in GIDAP Section 11.3.2.6 to the RIS as part of the IPE 5.0 filing with FERC.  If yes, does CAISO anticipate any revisions to 11.3.2.6, e.g., modifying “construction activities to “pre-construction activities” as shown below?

No later than thirty (30) days after each Interconnection Customer sharing the Assigned Network Upgrade complies with this Section, the Participating TO will commence Pre-Construction Activities on the shared Assigned Network Upgrade.

4.2 CAISO as an Affected System process modifications

SCE supports the CAISO’s proposal to require technical data and an initial $1,500 study deposit from the Affected System (A/S) interconnection customer once they are notified their project requires an ISO as an A/S study, among other identified requirements.

5. Please provide any additional comments on the draft final proposal or October 20 meeting discussion.

SCE curreently has no comment.