Comments on Draft Final Proposal

1. Please provide your organization's comments on the Interconnection Service Capacity and Deliverability Retention for Non-Operating Generating Facilities Draft Final Proposal and May 18 meeting discussion

PG&E appreciates the opportunity to comment on the Draft Final Proposal.  First, we reiterate our support for the initiative and thank CAISO for the clarification offered with regard to the notification timeline for units that are currently on an extended outage.  PG&E understands that the notification timeline for such resources will commence upon the effective date of the new tariff and is not retroactive to the date of the outage.

Additionally, there are two further cases that PG&E would like to comment on, specific to the hydro faciltiies, where the proposed timelines may be inadequate to support other regulatory requirements. One is the case in which PG&E elects to sell one or more of its Utility Owned Generation (UOG) hydro facilities, and the other is the case in which PG&E elects to decommission one or more of its UOG facilities that are regulated under a FERC Hydro License.

In the first case, when selling a UOG hydro facility, it is assumed that the purchaser will repair the off-line facility and therefore it is necessary to maintain the interconnection rights and preferable to retain the deliverability rights. The time it takes to sell a UOG facility and for the new owner to repair the facility and return it to service is typically 5-6 years from the time it goes off-line. This includes 1 year to analyze the technical requirements and economics of a repair and, upon the decision to sell, to prepare for the sale of the facility; 1 year to select a buyer and negotiate a purchase and sale agreement; 1.5-2 years to obtain CPUC approval of the sale of the UOG facility (concurrent with any FERC Hydro License transfer approval, if applicable); 3-6 months to close the sale; and finally, about 1 year for the new owner to repair the facility and return it to service.

In the second case, when decommissioning a UOG hydro facility that is operated under a FERC Hydro License, there are steps in the process during which FERC has the authority to trigger the Orphan Process and/or order the generator owner to attempt to sell the facility prior to commencing the decommissioning path. The Orphan Process is initiated by FERC after a generator owner communicates that it intends to surrender its FERC hydro license. FERC solicits interested parties to submit a notice of intent to assume the license and then ultimately submit a final license application. The Orphan Process typically takes 2-3 years. If an entity submits a final license application, it will take FERC another 2-5 years to review it and issue a new license to the new owner. In both the Orphan Process and a FERC ordered sale process, it is assumed that a new owner would repair the facility and return it to service.

For both unique cases, PG&E would prefer to use the Mothball Repair in Progress scenario and then communicate schedule milestones, along with status reports, to keep CAISO informed of the progress, ultimately retaining the interconnection and deliverability rights so that the facility can be returned to service.  PG&E recommends allowing for flexibility in the Mothball Repair in Progress scenario, like the Repower scenario where a facility has up to seven years or more, with meeting commercial viability criteria, to implement the repower and return to service. If this retirement scenario is not acceptable, PG&E requests CAISO accommodate these unique cases with an alternate retirement scenario that enables timeline alignment with other regulatory processes and timelines. 
 

1. Please provide your organization's comments on the Interconnection Service Capacity and Deliverability Retention for Non-Operating Generating Facilities Draft Final Proposal and May 18 meeting discussion

Yuba County Water Agency (Yuba Water) appreciates the opportunity to comment on the CAISO’s Interconnection Service Capacity and Deliverability Retention for Non-Operating Generating Facilities Draft Final Proposal (Draft Final Proposal). Yuba Water supports the CAISO’s underlying objective in this initiative which aims to ensure that capacity and deliverability are not indefinitely held by generating facilities that are permanently retired or have no imminent prospect of returning to service. As such, requiring Generating Facilities that cease operations to submit a retirement affidavit and a subsequent repowering request, and return to service within three years, will ensure prudent use of existing capacity and incentivize timely repowers.

Interest of Yuba Water

Yuba Water does not regularly participate in CAISO stakeholder processes and would like to provide some background to CAISO and stakeholders. Yuba Water was established in 1959 to reduce flood risk and provide a sustainable water supply for the people of Yuba County. Yuba County has historically endured devastating floods, due in part to Gold Rush-era hydraulic mining practices that washed millions of cubic yards of debris into the Yuba River, raising the riverbed and increasing the flood risk.  In 1961, the Yuba River Development Project was approved, which includes the New Bullards Bar Dam, as well as power production facilities including the New Colgate, Narrows 2, and New Bullards Bar minimum instream flow powerhouses. 

On February 13, 2026, Yuba Water experienced a major rupture of its 14-foot-diameter penstock pipe above New Colgate Powerhouse along the North Yuba River in Dobbins, California, about 45 minutes east of Marysville. The rupture released approximately 400-acre feet of water down the hillside, causing erosion and significant damage to Yuba Water’s New Colgate Powerhouse and associated switchyards. The New Colgate Powerhouse represents 350 MW of zero-carbon power, and is also located in the Sierra Local Reliability Area. Yuba Water has publicly stated its commitment to repair the damage, restore service, and return New Colgate to operation, subject to engineering, environmental, permitting, regulatory, and safety requirements which could take a considerable time to complete. Indeed, it is too soon after the incident to give an estimate of a date for return to service with any certainty. 

Yuba Water appreciates the CAISO’s inclusion of a “Repair in Progress” (RIP) category within the mothball scenario under which facilities that have filed a retirement affidavit may retain deliverability beyond the 36-month window upon reasonable demonstration of need due to ongoing repairs, and after reaching an agreement with the CAISO. The RIP category allows a facility owner to preserve existing deliverability where there is clear, documented intent and a reasonable path to return the resource to service, while still advancing the CAISO’s objective of preventing indefinitely mothballed or effectively retired resources from occupying scarce capacity and deliverability.

As such, Yuba Water believes the CAISO’s RIP category is essential to ensuring that facilities that experience extraordinary, unplanned infrastructure failures within the deliverability assessment process, are not forced into premature retirement solely due to the time needed to complete complex repair, reconstruction, and regulatory processes. Yuba Water recognizes the CAISO’s efforts to accommodate these types of outages, and would appreciate confirmation from CAISO that Yuba’s understanding of the RIP category would cover the process for the New Colgate facilities described above.