Comments on Draft Final Proposal

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

ACP-California appreciates the CAISO’s proposal and the expansion to explicitly cover upgrades other than short-circuit mitigation in this proposal. This should help accelerate more resources to come online in a more timely fashion. And we appreciate the CAISO’s efforts to further narrow the restrictions on utilization of this process as compared to the last version of the proposal. However, we ask that CAISO further consider the restrictions that require Reliability Network Upgrades to have a greater than four-year construction timeline and delay of the in-service date of multiple generating projects by two years or more. These restrictions feel unnecessary in limiting the scope and application of a process that could be beneficial to a greater set of projects and result in more capacity and energy coming online earlier. We urge CAISO not to unnecessarily restrict eligibility for this process and to reduce or eliminate these timing restrictions in the Final Proposal.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

Need for additional time to secure an executed PPA: ACP-California generally supports the CAISO proposal to modify the TPD allocation process. Though we previously requested additional time to secure an executed PPA after a Conditional Deliverability allocation is received, we understand that CAISO is not willing to provide such an extension at this time. And we understand CAISO believes the proposed timeline will be sufficient. While we remain skeptical that there will be sufficient time to fully negotiate and execute PPAs to retain conditional deliverability allocations under this new process, we ask that CAISO commit to monitoring this as the IPE revisions are implemented. And we ask that CAISO consider implementing an extension if the current timeline proves to be too short and projects are losing allocations as they are close to having an executed PPA but are unable to fully execute the documents ahead of the new TPD deadlines.

Need for LSEs to provide more documentation to qualify for PPA points and RA points: Under the proposed TDP allocation scoring approach, entities must have an executed PPA as a minimum requirement for the 1^st priority group and can receive five extra points if the off-taker is procuring the capacity to meet its own RA obligation or the Interconnection Customer is a Load Serving Entity serving its own load. CAISO appears to offer projects developed by LSEs/their affiliates with a de facto qualification for both of these requirements, providing unduly preferential treatment to projects being developed by LSEs or their affiliates. CAISO must augment the Final Proposal to provide additional, specific requirements for LSEs to meet the qualifications of “having an executed PPA” and for using the project to meet their own RA need. Simply being an LSE with a project in the queue, and claiming to be using the project to serve load, is insufficient and will provide LSE self-build project with an undue advantage in the TPD allocation process, which will result in discrimination against project development by third-parties (IPPs) which will have to meet a much higher bar to qualify.

ACP-California urges CAISO to provide additional requirements that LSEs must meet to demonstrate that their projects are sufficiently advanced to be on a level-playing field with projects developed by third-parties that have executed PPAs. We recommend the following requirements for LSE projects:

LSE projects must demonstrate final, non-appealable approval of the project from the LRA in order to qualify as having an executed PPA.

LSE’s must attest that the project is being developed to meet their own RA needs to receive the extra points associated with providing RA to the offtaker.

The requirement for having a non-appealable approval of the project is consistent with the triggers for financing of third-party projects that are selling to California’s investor-owned utilities. Before those third-party projects are financed, the seller generally needs to demonstrate that the PPA has been approved by the CPUC and there have not been any applications for rehearing filed. ACP-California urges CAISO to add these requirements for projects sponsored by LSEs to qualify as having an executed PPA” to enter the 1^st priority TPD allocation group. If these additional requirements are not implemented, CAISO’s proposal will provide undue preference to LSE projects, which will have to do nothing more than “be developed by the LSE” to qualify as having met the high burden of having an executed PPA. This would be entirely inappropriate and could result in a significant advantage for LSE built projects, which could change the existing balance of LSE self-build and IPP projects in the region.

ACP-California strongly opposes the current very low bar for LSE projects and urges CAISO to provide additional requirements for these projects to meet, in line with our recommendations above.

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

ACP-California generally supports CAISO’s proposal and looks forward to continued discussions on other modifications that may be appropriate as CAISO and stakeholders work through the implementation of the IPE reforms and the modifications to the interconnection process that were made as part of Order 2023 compliance.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

ACP-California appreciates CAISO proposal on the treatment of Long Lead-Time resources in the IPE Track 3 Draft Final Proposal and generally supports the approach that CAISO has put forward.

a) Eligibility: We further appreciate CAISO’s clarifications and additional details on the process for determining Long Lead Time generation eligibility. The proposed process provides a level of transparency and due process that is important and will provide better assurances to all resources and users of the grid regarding the reservation of capacity and the resources that can qualify to compete for the TPD that has been reserved. ACP-California also greatly appreciates that CAISO has clarified that there may be cases where eligible Long lead-Time resource already have available transmission capacity and, in these cases, transmission capacity can still be reserved, subject to the process outlined in the Draft Final Proposal.

b) Opportunity to defer first attempt to seek TPD: As in the prior set of comments, ACP-California generally supports the use of an opportunity to defer the first attempt to seek TPD as a reasonable, and simple, solution to addressing the unique needs of Long Lead-Time resources. And ACP-California supports the CAISO proposal to require resource to begin seeking TPD no later than three years prior to their expected online date (according to the resource portfolio). This appears to offer a straightforward solution that may provide these resources with a workable framework for securing TPD. However, we continue to urge CAISO to evaluate whether any additional ties to the timing of procurements and rules surrounding California’s 1373 central procurement process are necessary or may be helpful with respect to the rules regarding TPD deferral or other components of the Long Lead-Time resource process. Continuing to align the rules for Long Lead-Time resources with the central procurement process, or other future procurement opportunities for long-lead time resources, will be imperative for some resource types and deserves further consideration going forward. On a related note, ACP-California reiterates our prior request for CAISO to extend the opportunity to defer a TDP allocation and defer retention requirements for Cluster 14 projects. We note there are more than 2,000 MW of long lead-time OSW capacity with Group D allocations that face impending TPD retention requirements that will be difficult or impossible for them to meet, given their required development timelines. Long Lead-Time projects in cluster 14 are facing a requirement to demonstrate an executed PPA by the 2027 TPD allocation cycle. Yet, the procurement processes for many Long Lead-Time resources under AB1373 will be just beginning. Furthermore, for some resources like OSW, central procurement will be the only current feasible avenue for obtaining a PPA. Thus, it is imperative that CAISO provide these Long Lead-Time resources in Cluster 14 an opportunity to defer their TPD allocations or they will, likely, be forced out of the queue and need to re-enter at a later date.

d) Triggers for releasing reserved TPD: Under the process CAISO has proposed, capacity for Long Lead-Time resources would be reserved once communicated to the CAISO by the LRA under the defined process. Such capacity would only be released in either:

1. The event of formal cancellation of an associated policy-driven transmission project or
2. If the resource is later removed from the LRA’s portfolio due to project failure, with formal written decision by the LRA.

These are appropriate triggers for releasing the capacity that is reserved into the generic RA deliverability pool and will ensure that reserved capacity is not inadvertently released via an error or slight modification to the LRA portfolio that was not intended to result in a change in the reservation of capacity for Long Lead-Time resources. This proposal also provides the CAISO the flexibility it needs to ensure that deliverability is not “stranded” or unused due to major changes in transmission and resource plans. Thus, ACP-California supports this approach.

5. Please provide any additional feedback:

N/A

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

?AES Clean Energy, “AES,” appreciates the opportunity to submit comments on the Draft Final Proposal of the Interconnection Process Enhancements Track 3.  

AES overall supports the intra-cluster prioritization of use of existing SCD/RNU headroom and appreciates the additional implementation details. The CAISO should identify and post on its website the affected RNUs as soon as possible and set the affidavit date to September 1, 2025, to align with the 2025 TPD allocation process. In addition, the CAISO should clarify that prioritization would be made on a cluster by cluster basis. The PTO ranking assessments should be made public. 

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

a. Allocation Groups and Energy Only Treatment: AES is not opposed to consolidating the allocation groups to three groups but is opposed to the application of the Commercial Operation Group. The CAISO proposes the Commercial Operation Group to only apply to technology additions or pre-cluster 15 energy only projects. While the CAISO states that the permanent status of Energy Only resources is already approved as part of the tariff for IPE Track 2, during the draft tariff discussion of IPE Track 2, stakeholders were presented with IPE Track 3 straw proposal that stated the following: 

“Energy Only projects are only eligible for an allocation through allocation Group C – in commercial operation, regardless of how they became Energy Only. This applies to all new and existing Energy Only projects in the queue.”¹ 

Having both processes running in parallel, AES is disappointed that the CAISO adjusted its Track 3 proposal to reflect the IPE Track 2 tariff when Track 3 discussions were ongoing. Continuing this approach would deflect from the CAISO’s purpose of allocating TPD to projects that are most commercially ready. AES recommends the CAISO to adjust the existing tariff to allow Energy Only projects, no matter how they became Energy Only, an option to seek TPD.  

In addition, AES continues to strongly oppose the proposal that storage added through the MMA process can only request TPD once they have achieved commercial operations. AES continues to believe this proposal would limit the deployment of storage, which has proven to be an incredibly valuable resource in times of extreme weather and providing grid flexibility.  Allowing resources like wind and solar to add storage to those site greatly increases the CAISO’s ability to move energy from time of overproduction to times of greatest need. Moreover, deliverability is crucial for storage development, and the lack of ability to request TPD before commercial operations would completely discourage storage deployment into the CAISO market. 

b.Modifications to the TPD scoring criteria: AES urges the CAISO to consider modifications to the GIA status component in a future IPE track. While the GIA milestones were adopted through FERC Order 2023, CAISO’s unique process of allocating TPD requires an additional review of the issue. At this time, projects are required to sign a GIA and submit deposits without certainty of whether TPD is allocated. AES recommends the CAISO consider adjusting the GIA requirements in light of CAISO’s unique TPD processes.  

c.Opportunities to seek TPD: AES is not opposed to the three allocation opportunities starting with the TPD window opened after the interconnection facilities studies. AES supports the additional opportunity to seek TPD during the interconnection facility study, and the tariff should clearly note that opportunity is optional and does not remove one of the three attempts in seeking deliverability

¹IPE Track 3B Straw Proposal, p. 12.

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

?AES is highly supportive of CAISO’s proposal to extend the second interconnection financial security posted for parked Cluster 14 projects to May 29, 2026. AES recommends the CAISO consider further adjusting the date if the 2025 TPD allocation results are delayed to ensure that developers have sufficient time to reconsider project viability before making the second posting.  

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

AES has no comment at this time.  

5. Please provide any additional feedback:

??AES seeks clarification on where TPD transfer is allowed for tech additions added through projects for FCDS-seeking resources. AES is opposed to additional restrictions on TPD transfer between queue clusters. At this time, CAISO proposes to only allow TPD transfer from Cluster 14 and earlier to Cluster 15; TPD transfers are prohibited from later queue clusters to earlier clusters. AES believes these are unnecessary additional restrictions because IPE Track 2 already added requirements for projects transferring TPD to either be withdrawn or demonstrate an EO PPA. Developers may have numerous reasons for transferring TPD from one project to another cluster to ensure project viability. AES believes that these are risks that the developers should consider and additional restrictions would not ensure that most commercially viable projects come online.  

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

The California Community Choice Association (CalCCA) appreciates the opportunity to provide comments on the California Independent System Operator’s (CAISO’s) Track 3 Draft Final Proposal. CalCCA supports the CAISO’s proposal to use its transmission plan deliverability (TPD) allocation process scoring methodology to allow generators to interconnect up to an amount that will not trigger the need for a long lead time (LLT) short circuit upgrade or other reliability network upgrades. This proposal will provide opportunities for projects to come online and obtain deliverability more quickly when there is headroom to do so, helping to alleviate the current interconnection capacity scarcity.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

The TPD allocation process is a critical part of project development because resources must obtain TPD to provide resource adequacy (RA). The CAISO proposes to redefine the TPD allocation groups as: (1) the power purchase agreement (PPA) group; (2) the commercial operation group; and (3) the conditional allocation group. The CAISO’s proposal would provide projects with three consecutive opportunities to seek a TPD allocation and retain a conditional TPD allocation. 

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

For the commercial operation group, the CAISO proposes to include energy-only (EO) projects that go into commercial operation in clusters 14 and prior. Under the CAISO’s IPE Phase 2, the CAISO developed and the Federal Energy Regulatory Commission (FERC) approved on September 30, 2024, CAISO Tariff Section KK, which states that “Interconnection Requests that proceed to the Cluster Study based on the criteria for Energy Only Interconnection Requests may not obtain Deliverability for that Generating Facility and any associated Generating Units thereafter, including without limitation through transfers, modifications, or the TP Deliverability allocation process.”[1] CalCCA understands that the CAISO interprets this language to mean that projects in cluster 15 and later that seek to interconnect as EO cannot in the future seek TPD, even by submitting a new interconnection request once the resource reaches commercial operation.[2]

CalCCA understands and supports the CAISO’s intent to prevent developers from utilizing the EO pathway to circumvent a competitive process for TPD allocation. However, there are legitimate reasons why projects may pursue interconnection via the EO process, such as, a willingness on the part of both developers and LSEs to contract for a period of time for EO deliveries. The CAISO should therefore not prevent EO projects from ever seeking deliverability. If a project enters the queue and comes online as EO, the project should be allowed to submit a new interconnection request and follow the intake and study process for obtaining deliverability.

This approach could help expand and expedite opportunities for developers to finance and construct projects without a TPD allocation while ensuring projects cannot circumvent the interconnection intake process, in which projects seeking deliverability and projects seeking EO are scored separately. Constructed and operational projects are more viable than earlier stage projects under development and should be allowed to compete against other projects in the interconnection intake process and TPD allocation process to contribute to the state’s RA requirements. To avoid an EO resource from unduly benefitting from its EO status, the new interconnection queue request for deliverability should follow all of the criteria that the CAISO has developed. In doing so, demonstration of a PPA would need to include that it is for the capacity element of the resource and not the existing EO contract that it had previously signed. For these reasons, CalCCA proposes that projects that have achieved commercial operation as EO be allowed to submit new interconnection requests, apply for TPD allocation, and be scored along with all projects.

[1]            See FERC Docket No. ER24-2671, Order on Tariff Revisions (Sept. 30, 2024), located at: https://www.caiso.com/documents/sep-30-2024-ferc-order-accepting-tariff-amendment-interconnection-process-enhancements-2023-er24-2671.pdf.

[2]            It is not clear that FERC’s intent was to never allow EO to later apply for and receive deliverability. FERC stated that “[f]inally, we decline to direct CAISO to clarify that an interconnection request that completes the interconnection study process and executes a GIA may change its status in a future cluster, without having to withdraw their initial interconnection position. . . We note that CAISO’s Tariff does, however, permit expansions of generating facilities with [EO] deliverability status to receive deliverability if their interconnection requests proceed to the cluster study based on the criteria for interconnection requests seeking deliverability. CAISO’s Tariff also permits an interconnection customer to submit a new interconnection request for its generating facility if it seeks to be studied for deliverability in the future.” Id. at 214 (footnotes omitted) (emphasis added).  

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

CalCCA has no comments at this time.  

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

CalCCA agrees with the CAISO that TPD will need to be allocated to LLT resources such as offshore wind, out-of-state wind, and geothermal, which currently have longer project development cycles, and that the timelines for development of these resources may not be compatible with the updated TPD allocation process outlined in Section 2 of these comments. The CAISO’s draft final proposal for allowing eligible resources an extension to seek TPD allocations could provide a reasonable path forward for ensuring these resources can compete for TPD when they are commercially ready. The CAISO and the California Public Utilities Commission should take care to not oversize TPD reservations for LLT resources such that other technologies are unable to obtain TPD even when commercially viable and able to support system portfolio needs. In other words, the CAISO should not reserve TPD in excess of the amount of TPD specifically resulting from an upgrade triggered by eligible LLT resources in LRA portfolios. This is necessary so that other non-LLT resources can utilize the TPD resulting from their inclusion in LRA portfolios without being held up by the TPD reservation process. The CAISO should also specify that this process is not specific to a certain procurement entity but applies generally to all procurement entities seeking to develop LLT resources. Moreover, the CAISO should confirm that once within the 3-year window for seeking deliverability LLT resources would need to follow the standard process for TPD allocation (i.e. the process established for all resources).

In addition, the CAISO’s proposal for releasing reserved TPD if specific LLT resources upon removal from the LRA portfolio or cancellation of their associated transmission upgrades is a crucial element of this proposal. Releasing unused TPD will be necessary to ensure, in the event LLT resources do not progress, projects that are ready for TPD allocations can obtain them.

5. Please provide any additional feedback:

CalCCA has no additional feedback at this time.

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

CPUC Staff commends CAISO for developing this creative path to accelerate interconnection for projects that otherwise would remain waiting for a transmission upgrade by making use of available transmission headroom in the meantime. 

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

CPUC Staff suggests that CAISO consider retaining this process for future Clusters beyond Cluster 14, should headroom be available in areas where resources may be subject to a delayed transmission upgrade.
 

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

CPUC Staff supports CAISO’s proposed changes to simplify and reduce the number of groups and clarify the priorities for deliverability allocation. We believe this proposal allows reasonable opportunity for projects to seek deliverability in a timeframe that generally matches the expected commercial operation date of the project. 

CPUC Staff also support CAISO’s proposal to allow no more than three opportunities for projects to receive a deliverability allocation, assuming that this entire Draft Final Proposal includes the reservation of deliverability for particular resource types identified by the CPUC and other local regulatory authorities. 

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

CPUC Staff has no comments at this time. 
 
 

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

CPUC Staff support this proposal to enable the reservation of capacity that can eventually enable the deliverability of particular “non-routine” or “long lead-time” resource types and amounts that are identified by the CPUC  or Local Regulatory Authorities (LRAs).

We note that the most recent Proposed Decision¹  in the CPUC’s integrated resource planning proceeding R.20-05-003 (issued January 10, 2025) along with related posted documents, which detail the CPUC’s proposed electricity resource portfolios to be utilized in CAISO’s 2025-2026 Transmission Planning Process, set the example for initiating the “clear and transparent process in coordination with the LRAs to identify and determine eligibility of the option to defer the first attempt to seek TPD.” ²  

This Proposed Decision (to be considered, at the earliest, at the Commission’s February 20, 2025 Business Meeting) is where the CPUC identifies the amount and location of specific resource types for which the Commission requests CAISO to reserve transmission capacity for long lead-time resource deliverability.

CPUC Staff urge CAISO to clarify in its Final Proposal for IPE Track 3 that reserved transmission capacity should only be released into the generic deliverability pool when the CPUC or LRA explicitly requests that CAISO stop reserving the specific capacity that had been previously requested for reservation.  We believe this clarification adds greater clarity and transparency to the process, as opposed to the language in the Draft Final Proposal stating that reserved TPD would be released “if specific long-lead-time resources or their associated transmission upgrades identified in the transmission plan do not materialize.”³ 

1. Proposed Decision Transmitting Electricity Resource Portfolios to the CAISO for 2025-2026 Transmission Planning Process, p.2, pp.53-55.

2. CAISO’s Draft Final Proposal for IPE Track 3, January 9, 2025, page 47

3. CAISO's Draft Final Proposal for IPE Track 3, January 9,2025, p.49

5. Please provide any additional feedback:

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

CalWEA generally supports the proposal for QC14, which allows more viable projects to move forward and use available existing system capacity.  We agree with the proposal to treat EO and FCDS projects with the same priority, everything else being equal.  However, when scoring for PPA status, EO projects should receive 10 points (rather than 7 points) if they have an EO PPA because these projects are matching their PPA requirement. In addition, to make this provision effective for the many projects awaiting RAS upgrades, all projects waiting for RAS upgrades should be allowed to start operations using congestion management (a technically sound option) until the RAS is implemented.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

CalWEA provides comments on four of these issues: 

(a) Allocation Groups - CalWEA continues to recommend that the highest priority be placed on operational projects, including those that entered the queue with an EO request (as opposed to current policy that prohibits EO projects from ever attaining FCD status).  Operating projects can provide RA to the market immediately, with no additional transmission costs (no additional DNUs are required), which provides ratepayer benefits by mitigating RA capacity costs.

(e) Eligibility of Energy Only projects to seek TPD – As noted above, granting TPD to operating EO projects would add RA resources to the market immediately with no additional transmission costs, serving reliability goals and ratepayer interests.  Therefore, any operational EO project in any cluster (and Fast Track for <5 MW projects) should be able to seek TPD and be prioritized. To address any CAISO concerns that such an approach could be used by project developers to game the process, we remind CAISO that a project developer will have to place tens, if not hundreds, of millions of dollars at risk in bringing an EO project to life. All that CAISO needs to do is make sure that such a project moves towards its COD according to its GIA. 

(f) Documentation - CAISO should provide some flexibility to offtakers of TPD-retention or TPD-seeking projects, enabling offtakers to obtain an additional month’s time beyond the affidavit submittal deadline by submitting a formal letter attesting that the offtaker is awaiting final execution of the PPA.

(g) Modifications to the TPD scoring criteria - CAISO clarified that transferring TPD from a later to an earlier cluster will no longer be allowed as of QC15. Previously, projects at same POI were allowed to transfer TPD from a project in a later to an earlier cluster. Ending that practice would deprive the market of RA capacity, since earlier-queued projects are likely to have an earlier COD.  Allowing such transfers will increase the viability of earlier-clustered projects and advance new resource development, which promotes reliability and ratepayer interests.  Therefore, we recommend that CAISO simply change the rule to allow a project to transfer TPD capacity to another project at the same POI that has an earlier or same-date COD.

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

CalWEA strongly supports the CAISO proposal to move the second IFS posting due date for QC 14 parked projects to May 29, 2026, which avoids projects having to put money at risk before TPD is allocated.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

CalWEA generally supports the proposal but requests several refinements and clarifications. 

(a) Eligibility

CAISO should more clearly define, and provide accompanying rationale for, its proposed criteria (p. 40-41) for the resource types and technologies that will be eligible for transmission capacity reservation.  The criteria should require resource types and technologies to be both “long lead-time” and “location-constrained,” with both terms defined and justified. CAISO should then identify the universe of resource types and technologies that satisfy the criteria, while still enabling that universe to be modified over time if needed to reflect technological advancements.  Finally, apart from the criteria, the process should provide that each LRA request, from among the universe of qualifying resources/technologies, a certain amount of capacity to be reserved for their desired resources/technologies within designated transmission zones.

Regarding the criteria, the term “long lead-time” is not described or defined in the document. The Final Draft Proposal provides only an incomplete list of examples. That list excludes some resource types and technologies that meet the criteria,[1] creating uncertainty.  The term should be defined to include resources whose development and permitting lead-times – apart from transmission -- are relatively longer than others (i.e., typically five years or longer).  In this context, it is critical that transmission be excluded from the development timeline because most new resources have been, and will continue to be, delayed by transmission planning and development lead-times; thus, including transmission lead-time would not distinguish among resources based on their own attributes.

The “location-constrained” criterion should be defined as resources and technology types that exist in limited locations and therefore cannot be developed to take advantage of available transmission capacity outside of those areas. CAISO can refer to its own queue to distinguish between resources for which interconnection requests are numerous and widespread and those that are not.  Projects that rely on resources that are widely dispersed and technologies that have substantial locational flexibility can be located to utilize transmission capacity where it exists or is planned to exist.  Thus, transmission that is planned for location-constrained resources must be protected from resource/technology types that have much greater locational flexibility and shorter lead-times and thus could use up the transmission needed for location-constrained resources. 

Again, CAISO should make clear that both criteria – long lead-time and location-constrained – must be met to be eligible for the transmission capacity reservation proposal.

CAISO should then identify the universe of resource types and technologies that satisfy both proposed criteria, while enabling that universe to be modified over time to reflect technology advancements.  That universe currently is wind (offshore and onshore, both in and out-of-state), geothermal, and long-duration storage types that are constrained to limited geological features. 

LRAs may then request that transmission be reserved for certain quantities of these eligible resources in particular transmission zones.

(b) Opportunity to defer first attempt to seek TPD

No comment.

(c) Amount of TPD requested and reserved

CAISO should reserve existing available capacity, and plan for additional transmission capacity as necessary, to accommodate the total amount of eligible resources requested by LRAs in each transmission zone.  CAISO should clarify the unclear statement on p. 47 (“the lower of (a) the MW quantity of long lead-time FCDS generation in the approved LRA portfolios submitted to the ISO in the most recent TPP and (b) the transmission capacity created by the transmission plan upgrades for the specific long lead-time public policy requirement”) accordingly.

CalWEA also recommends clarifying the statement on pp. 47-48 as follows: “To the extent that a resource seeks additional projects collectively seek deliverability beyond what is approved and reserved in the portfolio, the interconnection customers will have to compete for the excess based on the same scoring process used to prioritize projects the PPA group and the conditional group.”  Based on the subsequent sentence, this appears to be CAISO’s intent, which CalWEA supports.

(d) Triggers for releasing reserved TPD

CalWEA recommends clarifying the statement on p. 48 as follows:  “Reserved TPD should only be released in the event of formal cancellation of an associated policy-driven transmission project or if the generic resource (not specific projects) is later removed from the LRA’s portfolio due to project failure for any reason and is not added to another LRA’s portfolio in the same timeframe, with formal written decision(s) by the LRA(s).

(e) Need for additional detail and discussion

 No comment.

[1] Excluded are onshore CAISO-interconnected wind resources, all geothermal resources, and long-duration storage resources that are constrained to limited geological features.

5. Please provide any additional feedback:

No additional comment.

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

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

CESA supports providing a quicker pathway for projects to come online prior to completion of large reliability network upgrades (RNUs).

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

1. Allocation groups:  CESA supports consolidating short-list and group D into a single “conditional” group.
2. Multi-fuel projects receiving an allocation with PPAs: CESA supports the requirement that if FCDS is allocated to a portion of the multi-fuel project, the TPD must be accepted by that particular component.
3. Parking: CESA supports eliminating parking for Cluster 15 and beyond.
4. Opportunities to seek TPD: CESA does not oppose a three-year TPD allocation window but remains concerned that while directionally positive this could result in the window expiring before developers and load serving entities are able to enter into power purchase agreements if the earliest commercial operating dates for the projects are beyond the CPUC’s procurement requirements.  CAISO acknowledges that this is an issue for long lead-time resources but fails to recognize that the same logic applies to projects with long lead-time network upgrades.
5. Eligibility of Energy Only projects to seek TPD:  For Cluster 15 and beyond only technology additions for projects that were studied as FCDS or PCDS are eligible to seek TPD allocation though the commercial operation group.  This effectively creates two TPD groups: (1) has a PPA and (2) conditional seeking a PPA.
6. Documentation: Support.
7. Modifications to the TPD scoring criteria: Support.
8. Scoring for the commercial operation group: Support. 

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

Support. 

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

CESA reiterates its prior comments on long lead-time generation rules.  CESA’s believes the long lead-time generation rules warrant a revised draft final proposal since the proposal is ambiguous and as demonstrated at the stakeholder call may not represent the internal CAISO consensus design. 

5. Please provide any additional feedback:

 No additional comments.

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

Clearway appreciates CAISO’s efforts to move this proposal towards implementation. During the stakeholder workshop CAISO stated that this could apply to any cluster, however this begs the question of whether and how queue priority should be integrated into the proposal. Given the overall goal of moving to a “first ready, first served” model, Clearway recommends that a more ready C14 project should be allowed to come online before a less ready earlier queued project. Clearway also requests that the CAISO change the name of this initiative to “Prioritization of Use of Existing SCD/RNU Headroom” (removing the “intra-cluster” description) and clarify that this will be an annual process. Clearway also requests that the CAISO clarify that all RNUs that satisfy the prioritization criteria, regardless of the cluster during which they were triggered, shall be evaluated as part of this process.  

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

(e)  Eligibility of Energy Only projects to seek TPD

Clearway continues to see value in the ability for a project to have an opportunity to convert to EO for a limited time after failing to receive a TPD allocation. After a project fails to receive a TPD allocation by exhausting the three opportunities, the project should receive the opportunity to convert to an EO project. While imposing a strict three strikes policy (p. 23) for TPD allocation, the ISO should allow those projects to convert to EO resources and apply the same requirements as used in the CVC criteria to limit the duration EO resources could stay in the queue. The additional years as an EO resource would provide a pathway to test the market’s appetite for EO PPAs.

The ISO’s stated rationale for forced withdrawal is that EO projects in queue retain their RNUs and cause unnecessary RNUs to be required for later queued FCDS projects (p. 23). However, a proposal that forces withdrawal will inevitably result in queue churn. Resources that do not receive a TPD allocation after their third attempt have already demonstrated significant readiness, LSE interest, viability scoring, and capital at risk. It is likely that if they are forced to withdraw they will resubmit in a subsequent cluster and cause those same RNUs to keep popping up. Providing an opportunity to convert to EO would enable the resource to assess the market for EO PPAs and provide a clear timeline for removal of the resource from the queue. If five years pass following the resources facility study and it has not been able to demonstrate a EO PPA, then it will be removed and would be less likely to resubmit in a subsequent queue. This method would enable the ISO to find a clear path to removal of EO resources while also reducing the potential for queue churn.

In response to Clearway’s previous comments, the ISO argued that historically EO resources have been part of hybrid or co-located projects (p. 25). However, there will continue to be a role for EO projects in CAISO’s footprint, especially given the shrinking number of viable development sites suitable for PV+BESS. Although the ISO expresses doubt that EO resources are financially viable, they are already part of the resource mix and are essential to enabling California to reach its ambitious goals and reduce carbon emissions. CPUC resource portfolios continue to identify a need for EO resources (> 12 GW generic EO mapped in the draft 2025-2026 TPP portfolio for 2040; ~2 GW out of this is stand-alone EO). Clearway is currently completing construction of an EO project that has an EO PPA with an LSE under a contractual pairing structure created by the CPUC’s midterm reliability procurement order, and we believe there will be a continued role for EO resources in future CPUC-driven procurements.

Multi-year Interim Deliverability

Clearway appreciates the discussion on multi-year interim deliverability; however, we are disappointed that it has not been included in the Final Draft Proposal. Within the discussion, the ISO discusses the steps it took to allocate identified long-term interim deliverability stemming from the 2024 TPD Allocation Report (p. 16). Clearway agrees that this was a step in the right direction, but we would like to see CAISO formalize the process and commit to performing that level of analysis in each area with multiple upgrades on different timelines that enable TPD, if the same circumstances that led to the allocation of additional TPD from the 2024 report occur again.

With new information now available about delays to DNUs, it is becoming clear that there will be multiple years of interim deliverability available for some Cluster 14 and earlier queued projects. In the Transmission Development Forum, PTOs are routinely reporting that upgrades enabling deliverability (DNUs and TPP upgrades) are being delayed by more than a year. Clearway is aware of several projects that have seen their expected FCDS timelines extended by more than 3 years because of these upgrade delays. Recently introduced uncertainty regarding federal permitting processes may also exacerbate delays associated with certain transmission upgrades enabling deliverability. These circumstances – multi-year delays to certain upgrades but not others – will create an environment where interim deliverability is available for some projects. Clearway encourages the CAISO to revisit this proposal in light of this updated view of network upgrade timelines. Any improvement to the timing for interim deliverability would make it easier for projects to sign PPAs and for projects with PPAs to stay on schedule.

Clearway appreciates CAISO’s willingness to implement prioritization of use of existing SCD/RNU headroom process and urges CAISO to include DNUs as part of this extremely useful framework. Since CAISO is already going to evaluate and score “more ready” projects as part of this prioritization, Clearway suggests that DNUs and TPP upgrades that are delayed or with a lead-time of more than 5 years be included in this prioritization of headroom.

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

Clearway is supportive of the adjustment to the 2nd interconnection financial security posting for C14 parked projects.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

a) Eligibility

Clearway appreciates the ISO’s attempts to provide clarity about eligibility for LLT generation and storage resources, however, there remain areas that are unclear that require further discussion. Specifically, the Draft Final Proposal indicates that the ISO will specify what resources qualify for each TPP cycle’s LLT resource pool; then LRAs can review and provide a more specific list (p. 48). This proposed eligibility leaves many specific details about eligibility to future stakeholder processes. It is unclear what the relationship would be between the criteria listed on page 48 of the Draft Final Proposal and any future legal standard for long-lead-time resources in a future TPP.

The criteria on page 48 are also not clearly defined. As discussed in Clearway’s comments on the Revised Straw Proposal, CAISO should provide more specific criteria upfront on which long-duration energy storage technologies are eligible to qualify for LLT treatment in the TPD allocation process. Clearway also urges the CAISO to remove the term “location-constrained” from the criteria, as nearly all resources are location-constrained, particularly resources such as utility-scale solar that require a large land area meeting specific physical criteria. Additionally, if out-of-state wind is eligible for LLT resource treatment because of the length of time to construct transmission, the same argument would also apply to many intra-CAISO resources depending on long-lead-time transmission projects.

Clearway appreciates the ISO’s commitment to provide more transparency into the TPD reservation locations and quantities. Clearway reiterates that future reservations of TPD should clearly specify the busbar and number of MW reserved.

b) Opportunity to defer first attempt to seek TPD

Clearway is supportive of the extension for LLT generation resources to seek TPD (p. 49) provided this extension is also offered to other resources that have long lead-time upgrades. The Final Draft Proposal allows flexibility on a project's timing to seek TPD and allows LLT resources to better align with commercial readiness milestones and procurement timelines. However, Clearway continues to argue that if a LLT resource is eligible to sit in a queue without being required to move through a TPD allocation cycle, the same logic and reasoning should apply to projects affected by LLT transmission upgrades.

The discussion of LLT resources in the Draft Final Proposal does not justify the extent of the special treatment they are receiving, compared to other projects with similar CODs. It is important that there is balance between LLT resources and other queued projects, including those with LLT transmission upgrades, as reservations of TPD and the ability for LLT resources to delay seeking TPD may skew the process and result in too much TPD being reserved for resources that have yet to prove their viability.

d) Releasing reserved TPD

Clearway is supportive of the ISO’s proposal to establish clear criteria for releasing reserved TPD. The ISO indicated that a reservation would be released if a specific LLT resource or its associated transmission upgrades identified in a TPP does not materialize (p. 49). The language in the Draft Final Proposal is important to ensure TPD is not reserved indefinitely. However, the proposal should incorporate an additional sensitivity to ensure that reserved TPD that will not be used is released as soon as possible. For example, reserving TPD capacity for five-plus years only to see the LLT resource drop out would be a loss to ratepayers and inappropriately delay the release of TPD to other queued projects. Accordingly, Clearway encourages the ISO to modify the criteria for reserved TPD to require that the LLT resource provide regular updates demonstrating progress towards commercialization. That modification would ensure the ISO takes a least-regret planning approach and releases reserved TPD within a reasonable timeframe.

5. Please provide any additional feedback:

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

EDF-R supports CAISO’s proposal for intra-cluster prioritization as a reasonable and structured approach to utilizing existing reliability network upgrade (RNU) headroom before all upgrades are completed. This proposal ensures that projects receiving deliverability allocation are not also occupying space in other upgrade queues, thereby enhancing efficiency in the allocation of available capacity. The structured scoring mechanism for prioritization effectively balances project viability and readiness while promoting competition among the most advanced projects. We believe this approach will facilitate the timely interconnection of viable projects without unnecessary delays or redundant network upgrade dependencies.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

a) Allocation Groups

EDF-R is supportive of this proposal, except for components of the Commercial Operation group as discussed below in these comments.

b) Multi-fuel projects receiving an allocation with PPAs

EDF-R is supportive of this proposal.

c) Parking

d) Opportunities to seek TPD

EDF-R supports CAISO’s proposal and appreciates the inclusion of the tables for illustrative purposes.

e) Eligibility of Energy Only projects to seek TPD

We oppose the proposal to prohibit certain Energy Only project types from applying for transmission plan deliverability (TPD). While CAISO argues that this restriction ensures fair competition, we believe that projects that have declared commercial operation should be considered inherently competitive. Restricting projects that have declared commercial operation from applying for deliverability unnecessarily limits market flexibility and prevents proven, viable projects from contributing to grid reliability. Given how few projects will be willing to declare commercial operation energy only (per CAISO’s analysis), CAISO should allow all EO COD projects to seek TPD, and revisit the policy if material impacts to later queued projects manifest. The benefits for making good use of all generation and transmission that is online as soon as possible outweigh the minor hypothetical risks.

EDF-R appreciates CAISO’s willingness to discuss this issue during this IPE process, and requests CAISO provide some slightly more detailed information on the projects that are eligible for the Commercial Operation deliverability group:

f) Documentation

EDF-R supports this procedure as long as documentation requirements clear and specified early enough for documents to be acquired.

g) Modifications to the TPD scoring criteria.

EDF-R is supportive of this proposal.

h) Scoring for the Commercial Operation group

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

We support CAISO’s proposal to adjust the second IFS posting due date for Cluster 14 projects that opted to park, extending the deadline to May 29, 2026. This adjustment aligns the due date with approximately sixty days after the TPD allocation results are published, providing interconnection customers with additional time to assess their allocation status before making significant financial commitments. This change improves financial planning and reduces unnecessary project risk.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

a) Eligibility

b) Opportunity to defer first attempt to seek TPD

EDF-R supports the proposal to allow LLRs to delay seeking TPD, and recommends developing a more detailed proposal for when LLR should seek TPD in the next iteration of IPE. It seems that there can and should be some sort of limit, such as a first attempt to seek no late than 5 years before transmission project completion.

c) Amount of TPD requested and reserved

 EDF-R is supportive of this proposal.

d) Triggers for releasing reserved TPD

EDF-R supports the CAISO’s proposal and recommends requiring a discussion of transmission and generation project progress and viability in each Transmission Plan. Given these generation projects are receiving special consideration in the CAISO process it is reasonable and rational to require those developers to submit information on project progress to be shared in the transmission plan. 

e) Need for additional detail and discussion

 EDF-R is supportive of this proposal.

5. Please provide any additional feedback:

 EDF-R requests the CAISO immediately consider modifications to commercial viability criteria for projects that are affected by extremely long lead network upgrades, CAISO should allow these projects to defer the requirement to present the CAISO with an executed PPA.

CAISO’s most recent study results are identifying network upgrades that will not be in service until the mid-2030s. CPUC directives and LSE procurement do not occur for dates that far into the future. Here is a list of examples of recent procurement activities:

CAISO knows the specific projects that are affected by extremely long lead network upgrades, and the timing and dates of procurement. Even though the CPUC planning horizon is 10 to 15 years, LSEs address these requirements in their Integrated Resource Plans (IRPs) with generic resource plans and do not perform specific procurement until showing dates are closer at hand. Projects that literally cannot provide energy or RA by LSE required showing dates cannot meet CAISO’s requirements. CAISO can collect information from PPAs developers have have provided, as well as survey LSEs for details on their procurement patterns generally. With this information CAISO can 1) identify projects who cannot reasonably obtain PPAS with such long lead time network upgrades, and 2) identify reasonable timelines for when those projects could participate in procurement. For example, if we were to base the policy on the data above projects with network upgrades completing in 2035 likely cannot reasonably be expected to participate in procurement RFOs until 2029.

It is EDF-Rs understanding that this policy is necessary because the CAISO’s policy is that even projects who have PTO delays taking their earliest achievable operation and FCDS dates to dates beyond the 7-year limit must still provide commercial viability evidence. Alternatively, if CAISO allowed projects with these extremely long-term network upgrades and associated PTO delays to be exempt from commercial viability checks, this policy change would not be needed.

Similar consideration will eventually be needed for projects with extremely long lead time network upgrades processed through the RIS, and EDF-R requests consideration of that item in the next IPE process.

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

ENGIE NA (“Engie”) supports  CAISO’s proposal and the expansion to cover upgrades beyond short-circuit mitigation. We appreciate CAISO relaxing the gating mechanisms that would allow projects to compete to come one-line early. However, we request the CAISO consider further relaxing the restrictions as that require Reliability Network Upgrades to have a greater than four-year construction timeline and delay of the in-service date of multiple generating projects by two years or more. These restrictions, while an improvement from the prior proposal, will still exclude a lot of projects. Even if a project can pull in an in service date by one-year that would go a long way towards bringing more capacity and energy online sooner.

The CAISO proposes that “PTOs could perform an assessment to allow the highest ranking projects to come online prior to completion of the upgrade” ENGIE requests that PTOs provide details on methodology for transparency.

Engie notes that SCE provided some helpful information as part of C14P2 and request that all PTOs provide this data.  SCE prepared a document “Additional SCD Information …” (excerpt pasted below) that provided information needed by the interconnection customer to assess likelihood of securing an earlier online date. In particular, the table shows in Kiloamps (kA)"

1. available margin
2. CB Rating
3. pre and post loadings of substation breakers as a result of interconnecting all C14 project

This information is helpful because substations with available margins that are relatively high compared to existing ratings can accommodate at least some C14 projects ahead of the upgrade triggered by C14. Furthermore, the difference between pre- and post-loadings indicates the totality of C14's impact. Engie is appreciative that SCE provided such information and requests that SCE and other PTOs be required to update that document to (1) reflect the recent 2024 reassessment and (2) change the operational year case to the year for which they will do the evaluation (most likely, 2027 as that's the earliest most projects seeking intra-cluster prioritization could get online).

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

Engie remains concerned that the three-year window  to seek TPD still does not align with the fact that many projects face long-lead time transmission upgrades and have CODs that extend beyond LSE procurement timelines.  This challenge is recognized by the CAISO for long-lead time resources, like offshore wind but not for other project types that face similar challenges. In our prior comments, ENGIE recommended that delayed projects be able to defer their TPD allocation similar to what is being proposed for long-lead time resources. This could be a temporary measure until transmission upgrades fall back into reasonable timelines. We request the CAISO to further consider this option as it seems it is better in the long run to provide some flexibility to projects already in the queue that have made significant investments versus  throwing the baby out with the bathwater and relying on a new set of interconnection requests.

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

Engie strongly supports CAISO proposal to defer the Adjusted 2^nd Interconnection Financial Security Posting.  This will allow interconnections customers to make a decision to withdraw or make a second posting after reviewing the next TPD allocation cycle results expected to be published on 3/31/2026.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

5. Please provide any additional feedback:

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

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

The Independent Energy Producers Association (IEP) represents the interests of independent, non-utility developers and owners of generation and energy storage facilities.  IEP is concerned that the scoring methodology for allocation of Transmission Plan Deliverability could have unintended effects on the market for Resource Adequacy (RA) capacity.

The proposed scoring methodology for prioritizing projects seeking TPD when there is insufficient TPD for the whole group (see Table 5 on p. 37 of the Draft Final Proposal) and for establishing intra-cluster priority (see Table 1 on p. 14 of the Draft Final Proposal) gives equal weight to projects with Power Purchase Agreements (PPAs) where (1) the off-taker is procuring the capacity to meet its own RA obligation or (2) the Interconnection Customer is a Load-Serving Entity (LSE) serving its own load.  Independent owners of generation and energy storage facilities could qualify for the indicated score only as sellers under PPAs that have off-takers that are procuring capacity to meet their own RA obligation.  Because of uncertainty that the seller’s project will actually receive the TPD needed for the RA capacity product, however, commercially reasonable PPAs for these transactions will necessarily include off-ramps or similar provisions so that the seller is not contractually obligated to provide a product that for reasons beyond its control it will not be able to provide as scheduled.  Without these off-ramps or similar provisions, the risk that seller will be locked-in to a situation that could result in a default would make these agreements commercially untenable.

In these circumstances, IEP is concerned about the statement in the Draft Final Proposal that “[t]he ISO will do all it can to ensure that sham or conditional PPAs are not used to try to obtain an allocation inappropriately.”  (Draft Final Proposal, p. 24.)  As described above, PPAs with independent generators and storage providers as sellers are very likely to require conditions that allow the seller to terminate the PPA without excessive penalties if the project does not receive a TPD allocation needed to create the RA capacity called for under the PPA.  The ISO should recognize that PPAs with these types of conditions are not “sham” PPAs but are rational and commercially reasonable responses to the current market conditions and the existing and proposed allocation of TPD.  In the absence of an ability to protect against the risk of not receiving a TPD allocation, very few independent generation and storage projects will be able to compete in the market for RA capacity, resulting in a distorted market dominated by LSE-owned projects.

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

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

5. Please provide any additional feedback:

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

1. Lack of Clarity for RNU Consideration

The CAISO's proposed Intra-Cluster Prioritization process for Reliability Network Upgrades (RNUs) suffers from a lack of clarity regarding eligibility criteria. Specifically, it remains unclear which generator upgrades will be considered, particularly for generators dependent on multiple upgrades with varying durations. This ambiguity hinders stakeholders' ability to assess the potential benefits of the process and provide meaningful feedback.

To address this, the CAISO should provide concrete examples illustrating the application of the proposed criteria. These examples should depict generators with multiple upgrades of varying durations, clearly demonstrating which upgrades, and generators, would and would not qualify for Intra-Cluster Prioritization. This will enable stakeholders to better understand the implications of the proposal and provide more constructive feedback.

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

Intersect Power supports CAISO's inclusion of the Deliverability Upgrade Status column in the intra-cluster scoring criteria. However, we believe the current scoring unfairly prioritizes Energy Only Deliverability Status (EODS) projects over Full Capacity Deliverability Status (FCDS) projects awaiting transmission upgrades.

Current Scoring Bias

EODS projects receive 10 points, while FCDS projects awaiting upgrades receive only 3 points.

Why This is Problematic

• Incentivizes Suboptimal Choices: Many interconnection customers are incentivized to bring projects online as Energy Only to meet deadlines such as the California solar property tax exemption (sunsets in 2026), even if it means sacrificing Resource Adequacy revenues. This trend is likely to increase if developers believe they can secure Interim Deliverability Status (IDS) for all or a portion of the time between COD and achievement of FCDS.

• Creates an Unlevel Playing Field: If an FCDS project chooses to operate as Energy Only while awaiting transmission upgrades, it should not be penalized in the scoring compared to a project that was initially designed as Energy Only.

Proposed Solution

Equal Scoring: Intersect Power proposes assigning 5 points to both EODS and FCDS projects operating as Energy Only while awaiting transmission upgrades. This would ensure a fair evaluation based on actual energy delivery, regardless of the project's ultimate intended operational status.

Below is Intersect Power’s proposed scoring breakdown for the Deliverability Status criterion:

3. Flawed Inter-Cluster Prioritization in the Proposed Process

While Intersect Power supports the concept of intra-cluster prioritization based on project viability, we strongly object to CAISO's stated intention to prioritize older queue cluster projects over newer ones, regardless of their scores. This policy creates an arbitrary and unfair advantage for older projects, undermines the entire purpose of the scoring system, and could have serious consequences for the efficient development of the grid.

• Arbitrary and Unfair: Prioritizing projects solely based on when they entered the queue is arbitrary and disadvantages newer projects that may offer superior technology, greater grid benefits, or more efficient use of resources. This creates an uneven playing field and discourages innovation.
• Inconsistent with Stated Goals: CAISO's own scoring criteria are designed to identify and prioritize the most viable projects. However, their inter-cluster prioritization approach completely disregards these criteria, favoring queue position over project merit. This inconsistency is fundamentally flawed.

Proposed Solution

Intersect Power urges CAISO to adopt a consistent prioritization approach across all clusters. The scoring criteria should be applied equally to all projects, regardless of their queue cluster. This will ensure that the most viable projects are prioritized, maximizing grid efficiency and reliability.

4. Limited Operation Study (LOS)

Intersect Power proposes that the CAISO explicitly states in the Final Proposal, that until a project with a reserved headroom (but requiring a LOS) reaches the 9-month earliest date to submit their Limited Operation request, the CAISO will reserve, to the extent possible, its headroom allocation and prioritize its headroom over other projects requesting a Limited Operation Study and that do not have such an allocation.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

a) Allocation Groups

Intersect Power appreciates the CAISO’s efforts to streamline the TPD allocation process and simplify the allocation groups, but continues to disagree with the removal of Shortlist Group (B). In fact, the period of time between the receipt of Interconnection Facility Study results and the 1st cycle’s TPD affidavit deadline is very limited and in many cases is not long enough to negotiate and fully execute a PPA. This is particularly relevant for QC15 where the Facility study is not expected to be completed before November 2026 (that is, assuming no delays to the process) and where TPD allocation affidavits are due by March 2027, leaving a mere 4 months to negotiate and fully execute a PPA. Projects actively negotiating a PPA should be distinguished from the Conditional Group where all remaining projects are pooled together, regardless of their efforts to secure offtake.

b) Multi-Fuel Projects Receiving an Allocation with PPAs

Intersect Power supports the CAISO’s proposal for projects to provide their preferred TPD allocation prioritization per fuel type. 

Separately, Intersect Power requests that the CAISO provides additional guidance on their proposed approach to move an allocation from one fuel to another, knowing that deliverability for different fuels is modeled differently (e.g. 100MW of BESS deliverability is not equivalent to 100MW of PV or wind deliverability).

c) Parking

Intersect Power supports the CAISO’s proposal to discontinue Parking.

d) Opportunities to seek TPD

Intersect Power supports the CAISO’s proposal for a fourth TPD allocation opportunity during the Facility Study. 

QC15 Timing Issue: However, it is important to flag that given QC15’s modified interconnection process schedule as compared to future clusters and the CAISO’s decision to cancel the 2026 TPD allocation cycle, the QC15 projects will not have an opportunity to seek TPD allocation ahead of their GIA execution (i.e. the CAISO’s QC15 schedule shows the QC15 Interconnection Facility Study start planned for June 2026 vs. February for future clusters, and GIA execution in April 2027, prior to when the 2027 TPD allocation results are published). Consequently, QC15 projects that are willing to sign a PPA and participate in the 4th earlier TPD allocation cycle will be required to sign a GIA and commit significant funds without having the opportunity to participate in any TPD allocation cycles. While Intersect Power appreciates the CAISO’s efforts to ensure the QC15 projects get an equal number of TPD allocation opportunities as future clusters, as shown in Table 3 on page 30 of the Draft Final Proposal, the first of the four TPD allocation opportunities would still be occurring post-GIA execution.  

Proposed Solution: Intersect Power thus proposes that the CAISO holds a 2026 TPD allocation cycle that’s aligned with the QC15 study cycle to grant this cluster its fourth TPD allocation opportunity ahead of the GIA execution and posting milestone.

e) Eligibility of Energy Only projects to seek TPD

Intersect Power supports the CAISO’s change to allow pre-QC15 EO projects to seek TPD allocation during operation.

f) Documentation

Intersect Power does not have any comments on this section.

g) Modifications to the TPD scoring criteria

Intersect Power generally does not object to this proposal. However, the following items should be addressed/clarified:

• GIA Status: How will the GIA Status criteria be assessed for projects with an executed Engineering and Procurement Agreement? This would seem to only impact the optional allocation window during the Facilities Study prior to GIA execution. 

• Permitting: It is expected for every Draft EIR published in California to have at least one remaining significant impact that cannot be mitigated to a less-than-significant level. In fact, the only reason for a CEQA lead agency to pursue an EIR instead of a lower-level document like a Negative Declaration is because a significant impact is anticipated. While the CAISO has provided additional clarifications in the BPM section 6.2.9.4.2 that address these concerns, Intersect Power proposes that these changes be reflected directly in the point rubrics table by omitting the reference to “no significant impact that cannot be mitigated”.

h) Scoring for the Commercial Operation Group

Intersect Power does not object to this proposal.

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

No comment.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

a) Eligibility

Long Lead Time (LLT) treatment should only be allowed to LLT resources designated by the LRAs as requiring such treatment based on their technology type.

b) Opportunity to defer first attempt to seek TPD

Intersect Power does not oppose the CAISO’s proposal to allow LLT resources to defer their first attempt to seek TPD. However, Intersect Power is concerned with allowing LLT Interconnection Requests to remain in the queue regardless of their potential viability towards eventual operation, especially in instances where they’re triggering upgrades they’re sharing with non-LLT resources. If LLT resources are to defer their first attempt to seek TPD, the CAISO should ensure that they are still on the hook to fund Network Upgrades they’re sharing with other non-LLT resources as soon as these faster-paced resources start funding them.

Intersect Power recommends that the CAISO require such LLT resources to start participating in the TPD allocation cycles 5-6 years (rather than 3 years, to allow them to go through 3 cycles of TPD allocation) before the planned COD shown in the LRAs’ resource plan to align with their procurement timeline for such LLT resources. Such resources should still be withdrawn should they not receive allocation after the 3rd shot. Additionally, LLT resources should be denied the option to defer their first attempt to seek TPD once the reserved TPD capacity is fully allocated.  

c) Amount of TPD requested and reserved

Intersect Power strongly opposes the CAISO’s proposal to reserve existing transmission deliverability and recommends that only TPD created by new transmission upgrades and approved for a specific LLT type of resource be reserved for that specific type of LLT resource. Previously approved upgrades and existing transmission were approved for a mixed portfolio of resources that did not envision any sort of capacity reservation for a specific type of resources. Limiting the TPD available for non-LLT resources would limit the advancement of non-LLT resources that may otherwise be able to advance to operations and guarantee additional Resource Adequacy to the grid years before any LLT resource would go online. That would also risk the reliability of the grid should the LLT resources not materialize as expected, and hold away deliverability that would have otherwise been available immediately without needing to wait for deliverability network upgrades.

d) Triggers for releasing reserved TPD

The CAISO should release reserved TPD when changes in LRA portfolios indicate that it is no longer needed.

e) Need for additional detail and discussion

Intersect Power recommends that the Long Lead Time resources topic be addressed in a separate track 4 to allow it to be better fleshed out and to capture all important details of the process, especially given the large number of open questions remaining. 

5. Please provide any additional feedback:

Need to Reform Interim Deliverability Status (IDS) Prioritization

Intersect Power remains deeply concerned about the current IDS prioritization process, which favors a project's queue cycle over its Transmission Plan Deliverability (TPD) allocation date. This approach is arbitrary, inequitable, and undermines the principles of fair competition and efficient grid development.

Flawed Rationale for the Status Quo

• Unreliable Basis for Planning: IDS is not guaranteed. Prioritizing projects based on queue cycle creates an artificial advantage that cannot be relied upon for strategic planning. 

• Perpetuating Inequity: The current system allows projects from older clusters to leapfrog newer projects for IDS, even if they entered the TPD process later. This is fundamentally unfair and creates an uneven playing field.

• Disregarding Merit: Prioritizing queue position over TPD allocation date disregards the merit-based nature of the TPD process. A project from an earlier queue cycle is not inherently better/more viable/more deserving, than a later queued project that received a TPD allocation in the same cycle. In fact, the resource receiving a TPD allocation for the earlier queued project is effectively a completely separate and new resource than the original resource from which it is receiving the prioritization benefit, further highlighting the arbitrary nature of this practice. 

CAISO's Arguments are Insufficient

• Temporary Nature: CAISO's claims that this issue is temporary and that changing the process would create complexity are inadequate justifications for perpetuating an inequitable system.

• Uncertain Future: CAISO cannot predict the future with certainty, and failing to address this issue now could lead to similar problems down the line.

Addressing “Prior Business Decisions”

• Claims that business decisions have been made based on the current IDS prioritization are misleading and potentially disingenuous. Numerous factors outside a generator's control (e.g., other generator advancement, deliverability upgrade advancement, and CAISO’s own deliverability methodologies) influence IDS awards. Responsible developers would have accounted for the uncertainty of IDS when making business decisions.

Proposed Solution

To ensure fairness and transparency, Intersect Power urges CAISO to immediately remove the queue cycle from the IDS prioritization factors and replace it with the TPD allocation date. This will ensure all projects of the same TPD allocation vintage have equal opportunity to receive an IDS allocation.

Unlocking Additional IDS via an Optimization Algorithm / Process

Intersect Power also recommends that the CAISO re-establishes a more robust optimization process, such as the Weighted Least Squares (WLS) algorithm that was previously utilized. The WLS algorithm, or similar, should provide more accurate, equitable, and justifiable results due to the below rationale:

• Over-Simpification: The approach currently used by the CAISO takes a very simplified view of the grid and only analyzes the available interim deliverability behind a single constraint in each area, whereas the WLS algorithm, can consider all constraints and allows for a more optimized analysis that should reduce arbitrary and discretionary assumptions and thus equitably distribute interim deliverability and also ensure a full distribution of available interim deliverability.

• Larger Projects Disadvantaged: CAISO’s current approach allocates interim deliverability based on the lowest total flow impact of each generator on the constraint, significantly disadvantaging larger project sizes (e.g. if a 100MW and another 150MW projects, located at the same POI, having the same DFAX, participated in the CAISO’s current interim deliverability process, the 100MW project would receive the entire available interim deliverability capacity, leaving the 150MW project with none). Alternatively, the WLS algorithm would allocate similar contributions to projects that have similar DFAX, weighting projects’ contributions based on their DFAX contribution (e.g. the 100MW and 150MW projects would each get half of the available interim deliverability).

• Queue Cycle vs. TPD Allocation Date: The CAISO’s current approach also prioritizes the interim deliverability allocation based on queue cluster, which as mentioned above, should instead be based on the TPD allocation date to avoid the prioritization of more recently added capacities via MMA, over older vintage projects that received their TPD allocation much earlier than these more recent MWs.

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

No comments at this time.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

No comments at this time.

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

No comments at this time.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

Invenergy’s comments are focused on “early adopters,” the handful of pioneer long-lead-time (LLT) projects already in the queue.  Invenergy asks the CAISO to reconsider its earlier rejection of provisions to help these projects and include such provisions, as needed, in the Final Proposal.

These off-shore wind projects – accounting for several thousand MWs of a technology clearly identified under state policy as unique and needed, based on their resource-diversity benefits and other attributes warranting special treatment – took action to enter the queue and request TPD Allocations using the only tools available to them at the time, including Group 3 and Group D. 

The CAISO is designing a separate intake, TPD reservation, and TPD Allocation framework for future LLT resources, applicable to Cluster 15+ projects, even though those projects are still unidentified and not yet in the queue.  There is some concern that these resources may not develop, and the CAISO has included proposals for possible release of reserved TPD if that happens. 

However, without further action in Track 3 or otherwise, the CAISO proposal would effectively strand the actual LLT projects already in the queue with unrealistic TPD retention requirements, instead of folding them into the new LLT framework with some small adjustments. 

The Draft Final Proposal summarily dismisses Invenergy’s earlier proposals:

Invenergy and LSA highlighted the challenges certain projects face in meeting TPD retention requirements, and suggested that the ISO either change retention requirements or allow LLT resources that have already received TPD allocations to defer their retention requirements. The ISO considered this proposal but is reluctant to change the rules for some resources in the queue, while leaving rules in place for other resources in the queue. Further, to create a level playing field among long lead-time resources, a simpler and more-timely solution would be for early adopters to exit the queue and re-enter the queue at a time that better aligns with commercial development.

This dismissal ignores the fact that LLT projects in the queue have invested considerable resources to acquire site-development rights and design their projects, and also have posted millions of dollars of financial security subject to sizeable forfeits if they withdraw.  There is no need to impose such penalties on projects the state clearly wants, or require them to start the entire process over again.  Instead, CAISO should support these projects by enabling their continued progress toward COD.

The Track 3 proposal, as well as Tracks 1 and 2 before it and other reform efforts before that, is aimed in part at “changing the rules for some resources in the queue, while leaving rules in place for other resources in the queue.”  The CAISO has changed tariff rules for Cluster 14 projects all along the way, including lengthening/modifying study process, Site Exclusivity, and cost-cap rules, as well as revising the TPD Allocation groups.  It seems disingenuous at best to say that the CAISO can’t make well-justified changes, consistent with state policy, where amply justified.

In fact, tariff changes are only one approach to accomplish state objectives here, though the CAISO should certainly not shy away from such changes in Track 3 if it deems them needed.  The CAISO has interpreted language in GIDAP Section 8.9.1(c) (“The CAISO will identify the following commitments that will utilize MW quantities of TP Deliverability:… (c) any other commitments having a basis in the Transmission Plan”) as providing the authority to reserve TPD for identified LLT resource types in the TPD Allocation process.  Extending that approach to TPD retention is entirely consistent with the CAISO’s interpretation of this tariff provision, and its intent. 

Invenergy’s proposals for early-adopter LLTs are described in the sections below.  They are aimed at folding in these projects intothe LLT framework, and “creating a level playing field” for all the LLT resources in the queue, which are similarly situated with respect to their development timelines, and unique from other projects in the queue by technology and state policy.  The presence of these projects in the queue adds certainty to the proposed LLT framework; for example, to the extent that they already have TPD Allocations, the CAISO can reduce the TPD reserved for unidentified future, more speculative LLT projects.

Invenergy asks the CAISO to reconsider its position on helping these projects, instead of implementing an inconsistent framework that would help only future projects but allow current, needed projects to fail.

1. Eligibility.  The CAISO’s proposal to “provide a legal standard” defining eligibility at some future time is not quite a definitive proposal.  However, Invenergy believes that the CAISO should expand the concept of eligibility to early adopter LLT resources, with respect to actions needed to provide LLT resources with reasonable TPD retention opportunities. 

2. Extension to seek TPD:  Invenergy suggests broadening this topic to “Extension to seek and retain TPD.” 

The CAISO has proposed allowing C15+ LLT resources to postpone commencement of their three TPD allocation attempts until three years before their on-line dates in LRA portfolios.  Invenergy supports this proposal.

Invenergy also supports folding in early-adopter LLT projects under this framework by allowing them to delay PPA requirements for TPD retention under the same timeframe – three years before their on-line dates.  This is a reasonable accommodation that will still put early-adopter projects ahead of C15+ projects that make their first TPD Allocation requests three years before their on-line dates, since the C15+ projects would not have to produce a PPA for retention purposes until the year after they receive an allocation (i.e., two years before their on-line date).

Alternatively, the CAISO could set a realistic PPA compliance deadline consistent with the 1373 central procurement process for all LLT resources, including early adopters.  The state is establishing that process to enable PPA acquisition for LLT resources, and the CAISO should support this important state policy by letting early adopters retain their allocations until the process is implemented.

3. Amount of TPD requested and reserved:  Invenergy supports the CAISO’s proposal:

The ISO will continue to reserve transmission capacity commensurate with the lower of (a) the MW quantity of long lead-time FCDS generation in the approved LRA portfolios submitted to the ISO in the most recent TPP and (b) the transmission capacity created by the transmission plan upgrades for the specific long lead-time public policy requirement.

Footnotes clarify that the CAISO will use the lower of (a) and (b) because some of the reserved capacity may come from “use of existing transmission and upgrades” and/or capacity freed up by, for example, retirement of other resources.

Invenergy proposes folding in early adopters under the proposed LLT framework by counting them against the LLT transmission that otherwise would be reserved under GIDAP 8.9.1(c).  These are identified LLT resources, and there is no reason to reserve capacity when TPD allocation and retention for them serves the same purpose.

4.  Triggers for releasing reserved TPD:  The Proposal says “Reserved TPD should only be released in the event of formal cancellation of an associated policy-driven transmission project or if the resource is later removed from the LRA’s portfolio due to project failure, with formal written decision by the LRA.”  This proposal seems reasonable; TPD Allocations for early adopters can be later folded back into the LLT transmission reservation if they do not progress.

5. Need for additional detail and discussion:  A separate effort – “Track 4” – may be needed to work out the details for C15+ projects, e.g., TPD Allocation of MWs in the LLT reserve – but the CAISO should act now to provide reasonable relief for the early adopters in the queue.  They will need CAISO action before the September 1^st affidavit due date for the next TPD Allocation cycle, and the CAISO should implement the suggestions here – through tariff interpretation or tariff change – in time to be effective before that deadline.    

5. Please provide any additional feedback:

No additional comments at this time.

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

As a preliminary matter, LSA requests that the CAISO change the title of this proposal to something like “COD acceleration” or “RNU headroom prioritization.”  It is clear from the discussion that projects from more than one cluster depending on a particular covered RNU may participate, even though earlier-queued projects would have priority over later-queued project (more on that below).

LSA appreciates the CAISO’s efforts to move this proposal forward, as well as the clarifications provided in the stakeholder meeting, including the statement that this process could cover any RNU (not just circuit-breaker upgrades) and any cluster (not just Cluster 14).  LSA has the following additional suggestions:

• Queue position consideration:  Clarify (perhaps through addition of a column to the scoring table) that queue position is the first determinant of which project(s) will receive a “headroom allocation,” and that the scoring will be used only within each cluster. 

• Or not:  However, consider removing this same rule, so that later-queue projects that are more ready to proceed (i.e., score higher) have the ability to receive a headroom allocation before earlier-queued projects that are less ready to proceed (score lower).

• DNU consideration:  The CAISO should remove the additional consideration of whether or not a project is waiting for a DNU.  Projects are able to align their CODs to match their DNUs, but developers should still have the option to use the headroom allocation process to reach COD earlier and operate as Energy Only, with possible Interim Deliverability.  Developers that are not willing to take the Interim Deliverability Status (IDS) risk simply need not apply for the RNU headroom allocation.

• LOS:  Reconsider the proposal to require a Limited Operation Study (LOS) where the “margin” is less than 3%.  It makes no sense for projects to accelerate their CODs by several years only to find out at practically the “last minute” that they have to wait for the RNU anyway.

If this proposal is retained, then clarify in writing the discussion on this point from the recent stakeholder meeting.  Specifically, the CAISO should state in the Final Proposal that it will “reserve room” for projects with a headroom allocation in situations where headroom is available as a project is headed toward operation, but projects without such allocations submit LOS requests before those with the allocations reach the 9-month earliest date to submit their LOS requests.

• Implementation schedule:  The CAISO should: (1) provide a schedule of when the considered RNUs would be posted on the CAISO website; (2) clarify that the affidavit due dates and results will be the same as the TPD Allocation process; and (3) post the details of how it determined which RNUs are included, for stakeholder reference and overall transparency.

• Expansion of the concept to DNUs:  LSA supports expansion of this excellent concept to DNUs.  There are many projects struggling with large, multi-year differences between their achievable CODs and the likely award of their FCDS/PCDS status. 

The CAISO has decided not to proceed with a longer-term Interim Deliverability Status (IDS) option, but this proposed RNU framework for providing earlier CODs to some projects could be used to provide earlier deliverability status to some projects.  The principles for the two upgrade types are exactly the same. 

As with the RNU proposal, projects wanting to keep their CODs, or delay them less, can apply for the available DNU headroom in conjunction with the TPD Allocation process schedule.  Those that are willing to wait for their deliverability status, or to delay their CODs to match DNU construction upgrade timelines, simply need not apply.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

1. Allocation Groups:  LSA continues to oppose the removal a shortlist/active-negotiations position from (1) the 2025 TPD Allocation Group D; or (2) the post-2025 TPD Allocation as a separate Shortlist Group (2^nd priority) or a feature of the new Conditional Group.

The problem with the CAISO’s “schedule” showing that it is possible for projects to acquire PPAs without an interim shortlist position is that the procurement solicitations themselves are a function of CPUC and other LRA proceedings, and LSE follow-up actions.  These do not have a regular schedule, and there is no indication that these processes will align with the CAISO’s scheduling in the future any more than they have in the past.  The interim step provides flexibility to help developers manage these disparities, and removing it will further complicate an already difficult process. 

2. Multi-fuel projects receiving an allocation with PPAs:  LSA supports CAISO’s proposal for Interconnection Customers (ICs) requesting TPD allocations for Multi-Fuel Resources (MFRs) to clarify prioritization between different portions of their projects in a TPD Allocation request.   

LSA appreciates CAISO’s clarification at the recent stakeholder meeting that developers can submit multiple priorities for their TPD Allocation and are not limited to one priority level per fuel type.  For example, for a 100MW MFR with two 50MW solar-storage PPAs might need to prioritize solar/storage capacity for the one with higher payments over the other.

However, the ability to prioritize TPD Allocations should not be limited to projects with executed PPAs.  For example, projects with PPAs still under negotiation may need this prioritization to conclude their negotiations and finalize the PPAs.  Even projects without PPAs under negotiation yet may believe that allocating available TPD to one portion of the project over another will make the project more marketable, and they should also have that opportunity.

3. Parking:  The CAISO said at the recent stakeholder meeting that there still may be some C14 projects that qualify for a second year of parking, and that those projects could still elect Group D in the 2027 TPD Allocation process.  This treatment should be stated in the Final Proposal.

4. Opportunities to seek TPD:  LSA agrees with having the first of the three opportunities to seek TPD following completion of the Facility Study, as long as this timing is coordinated with the next affidavit due date. 

LSA again requests clarification on the treatment of resources that have only received part of their requested deliverability by the end of their third opportunity. The CAISO should clarify if those resources would be required to downsize in order to remove the capacity for which they requested an allocation but did not receive one.

LSA also supports the proposal for C15+ projects to make an initial TPD Allocation request during the Facility Study, especially since it will likely be many months between the end of the Facility Study and the results of the next TPD Allocation; projects with PPAs should have the opportunity to proceed more quickly to meet their PPA requirements.  The tariff language should clarify that this would be a fourth request opportunity for these projects.

5. Eligibility of Energy Only projects to seek TPD:  There are two aspect of this question:  (1) Pre-C15 projects; and (2) C15+ projects.

Pre-C15 projects

LSA is troubled at CAISO’s inconsistency about whether and when rules should be changed. 

For example, the CAISO has argued that, even though the Conditional Group for C15+ projects would not have the same restrictions as Group D, Group D projects knowingly committed to those restrictions, and changing them to be compatible with Conditional Group rules would be unfair to projects that lost their TPD Allocations under Group D rules, as well as projects that chose to forego an allocation request rather than assume the Group D restrictions.

However, the CAISO does not seem to be overly troubled by changing the rules when they would impair, and not benefit, projects.   Proposed rule changes would remove options for: (1) Group D projects to request another pre-COD allocation after 2025 if they lose it; (2) Energy Only projects in the queue to request a pre-COD allocation after 2025 if they get a PPA or are shortlisted later, they could request a new allocation; and (3) C14 projects that parked rather than seek an allocation to access a Group D allocation with two more years to get a PPA. 

In general, LSA still opposes removing later opportunities for pre-C15 EO projects (and technology additions to those projects via MMA requests) to acquire a pre-COD TPD Allocation after 2025.  However, the CAISO appreciates the CAISO’s change to allow such projects (and technology additions to them via MMA requests) to request a TPD Allocation after COD.

C15+ projects

LSA understands that the “permanent” Energy Only status of projects that enter the C15+ process as EO is already an approved part of the tariff.  However, LSA continues to believe that projects (or additions to project through an MMA request) demonstrating viability by reaching COD should be entitled to request a TPD allocation for that capacity. 

This is not a question of “jumping the queue” or going around the rules.  It would be risky indeed for a developer to apply under EO rules, incur considerable financial obligations, and then build the entire project just to take a chance on getting a TPD Allocation after COD.

Instead, once they reach COD under applicable interconnect rules, they are clearly viable as EO and should have an opportunity to obtain a TPD Allocation if sufficient capacity exists.  These projects could then provide Resource Adequacy to the market right away (given sufficient existing transmission, or upgrades completed in the near future), and not years later. 

As LSA argued before, prohibiting operational Energy Only projects from seeking deliverability when it becomes available is contrary to the CAISO’s fundamental obligation to support the state’s aggressive reliability and climate goals.  The CPUC in its RESOLVE model uses Energy Only resources as a flexibility to minimize total cost to ratepayers, but it does not indicate that this status is intended to be permanently attached to individual resources.

FERC indicated, in the approval of the Track 2 reforms, that a process for EO projects to obtain TPD Allocations post-COD should exist.  As we said in our prior comments, FERC stated, “CAISO’s Tariff also permits an interconnection customer to submit a new interconnection request for its generating facility if it seeks to be studied for deliverability in the future.”  (p.214) While FERC’s statement seems to reflect a misunderstanding of the CAISO tariff, which does not allow projects to re-enter the queue to be studied only for deliverability, FERC’s intent was clear, and the CAISO should comply with that intent.

6. Documentation:  LSA does not understand this request for comment.  Documentation of what?

7. Modifications to the TPD scoring criteria.  LSA does not oppose the proposed scoring criteria.

8. Scoring for the Commercial Operation Group:  LSA does not object to this proposal, except that the CAISO should clarify that: (1) any projects reaching CODs without executed PPAs, while having a lower priority than those with executed PPAs, can still qualify for a Commercial Group allocation; and (2) within that category, DFAX (lowest first) will also be used as a tiebreaker.

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

LSA strongly supports the proposed tariff changes to postpone the second financial-security posting for Cluster 14 projects coming out of parking for the next TPD Allocation cycle, until after the allocation results are published.  This proposal would restore the original intent that these projects delay that posting until they receive the TPD Allocation results and can make a reasonable financial decision about whether to proceed as Energy Only or withdraw from the queue. 

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

LSA offers some introductory remarks here before addressing the individual topics .

LSA cannot support the CAISO’s LLT proposals as they are now written, as they are unduly discriminatory, unnecessary, and simply not yet “fully baked.”    

First, it is not at all clear to LSA that some or all the proposed LLT special provisions for long-lead-time (are warranted.  In particular, the CAISO has in place already tools that, together with Local Reliability Authority (LRA) procurement guidance for LSE PPA execution, will ensure that deliverability is highly likely to be available for LLT resources by the time they need it.  These mechanics are described further under (c) below.

Second, where the LLT proposals do make sense, limiting them to LLT resources is unduly discriminatory.  For example, as LSA explains further under (b) below, the additional timing flexibility for requesting TPD Allocations is needed, not only for LLT resources, but for all resources with CODs many years into the future.  All these resources are similarly situated with respect to theirn inability to acquire PPAs many years before their CODs, which are beyond the procurement horizon for most LSEs.

Third, as LSA explains further under (e) below, there are many aspects of the LLT proposal that are simply unclear, including provisions applicable to individual projects vs. resource types and how TPD from any reserved capacity will be allocated to LLT resources. 

Finally, there is no reason to rush any decisions on LLT resources at this time.  The only decision in the near term that must be made is for any generic reservation in the 2025 TPD Allocation.  There are few or no LLT resources in Cluster 15 and the next TPD Allocation process won’t happen before 2027.  This leaves plenty of time to work through the open issues, including which proposals are or are not needed, before they become relevant to Cluster 16 and later projects.

1. Eligibility.  The CAISO’s proposal to “provide a legal standard” defining eligibility at some future time is not exactly a proposal.  LSA understands the CAISO’s interpretation of GIDAP Section 8.9.1 to support its past and proposed reservation of TPD for LLT resources. 

The CAISO’s list of “criteria” for what it may consider in its “legal standard” includes the nebulous “location-constrained” criterion.  LSA objects to consideration of “location constraints,” aside from LRA guidance or other legal requirements, in setting TPD reservations.

CAISO TPD reservations for resources that are or could claim that label (off-shore wind, on-shore wind, out-of-sate wind, geothermal, pumped storage or other hydro, and even large-scale solar) could potentially segregate significant portions of the scarce TPD otherwise available to other critical resources, namely solar and storage (as well as the limited amount of new natural gas resources that may be allowed).  This is especially concerning given the proposal to wall off large amounts of existing TPD from transmission not even approved for those favored resources, as noted below. 

LLT treatment should be limited to LLT resources identified by LRAs and/or legislative mandates as needing such special treatment to develop.  The sole eligibility criterion for “holdbacks” and separate TPD awards should be identification of those resource types as requiring such treatment because of their technology type, and not more than that due to “location constraints.”

2. Extension to seek TPD:  The CAISO has proposed allowing LLT resources to postpone commencement of their three TPD allocation attempts.  This seems sensible (not only for “LLT” resources but also resources with long-lead-time upgrades – see Question 5 below). 

However, the CAISO proposal would allow LLT resources to delay initial TPD Allocation requests up to 3 years before they are expected to come on-line in “the portfolio.”  This proposal is highly impractical, for two reasons:

• This is simply too late.  These resources will get the same three chances to acquire a TPD allocation as other resources, and those not receiving an allocation until the second or third try will likely not have sufficient time to actually build the resource.  Even those getting an allocation on their first try may have problems meeting the on-line targets, given the newness complexities of many of these technologies.

• Which “portfolio” targets would apply to which resources?  There may be multiple LRAs with the same resource type in their LSE portfolios, and even individual LRAs may have multiple years targeted for LLT on-line dates for the same technologies.

Instead, the CAISO should require that: (1) the initial TPD Allocation request be made by 5-6 years before the on-line date; and (2) the applicable on-line date be the specific resource COD, which presumably will be consistent with the dates that LRAs expect them to be operational. 

LSA is very concerned that allowing LLT projects to linger in the queue for many years without any proof of viability before TPD request submittal, while withholding reserved TPD and thereby impairing progress of viable other project types, would be a highly inefficient use of expensive transmission capacity needed for reliable nearer-term service to load.  In addition to the earlier TPD request requirement proposed above, there should be some viability requirements for projects waiting to submit their first TPD Allocation request – perhaps an LSE or LRA interest designation, demonstration of permitting application/progress, or on-shore substation development or gen-tie progress.

In addition, as LSA suggested before, a simpler and equally effective alternative would be to allow these resources, at their option, to request their TPD awards on the same timeline as other resources – negating the need for the CAISO to continue to reserve “phantom” resources for their technology types, and in line with the transmission-upgrade approvals for them – and simply postpone their retention deadlines (other than a basic viability demonstration, as noted above). 

For example, C15 LLT projects could request a TPD allocation right after Facility Study completion like other projects in the same cluster, but not have to comply with any retention requirements (e.g., executed PPA) until ~5-6 years before their proposed COD.  This option would give them early certainty of receiving a TPD allocation (facilitating any PPA acquisition activities that could be performed so far in advance) but postpone their PPA requirements until the more likely LSE contracting window for their project CODs, retaining the allocation in the meantime with only the lesser viability/progress demonstrations discussed above.

The CAISO did not respond to this alternative proposal in the Draft Final Proposal, and LSA requests that the CAISO consider and respond in the Final Proposal.

3. Amount of TPD requested and reserved: 

LSA is not convinced that TPD reservations are necessary to ensure that deliverability will be available for LLT resources.  LSA questions this need for the following reasons:

• No other resources have needed this special treatment to date.  The CAISO has not granted such treatment even to LLT resources like pumped-storage hydro and geothermal projects.

• As the CAISO has pointed out, virtually no resources are built without executed PPAs. 

• Most resources now in the queue will not be able to retain their TPD Allocations without executed PPAs.  Many resources in the queue with TPD Allocations hold them under restrictive Group C or Group D rules, which will not allow them to change their CODs, or even retain their allocations, without executed PPAs.  Others will fail the Commercial Viability Criteria (CVC) when they need COD extensions beyond 7 years in queue and will lose their TPD Allocations that way.

• The same is true for future resources entering the queue.  Many will start out with Conditional Group allocations that they will be unable to retain without PPA execution.

• Thus, as LSEs execute PPAs collectively for the different resource types reflected in LRA resource portfolios, project types in excess of those levels without PPAs will likely drop out over time (or at least lose their deliverability), freeing up that deliverability for later LLT and other diverse resources, about when they will need it.

In other words, as the CAISO has taken to pointing out, some problems will be addressed in the procurement process, e.g., the deliverability needed for LLT resources will likely be available to them when needed even if it is initially taken by other resources.  Thus, it is not clear that unduly discriminatory treatment like TPD reservations for favored resource types is really needed. 

To the extend that the CAISO nevertheless persists in promoting TPD reservations for LLT resources, LSA strongly objects to TPD reservations in excess of deliverability capability provided by new transmission approved explicitly for that purpose.  The Proposal says:

The ISO will continue to reserve transmission capacity commensurate with the lower of (a) the MW quantity of long lead-time FCDS generation in the approved LRA portfolios submitted to the ISO in the most recent TPP and (b) the transmission capacity created by the transmission plan upgrades for the specific long lead-time public policy requirement.

Footnotes clarify that the CAISO will use the lower of (a) and (b) because some of the reserved capacity may come from “use of existing transmission and upgrades” and/or capacity freed up by, for example, retirement of other resources.

Existing and previously approved transmission, by definition, was approved for other, non-LLT resources, including those expected to be on-line, and providing needed Resource Adequacy to load, well before LLT resources.  Confiscating and holding it in reserve for generic LLT resources simply removes it from use by non-LLT resources that could use it to provide system reliability years before any LLT resources can come on-line.  Effectively, the CAISO would be undermining its own principles (reserving capacity for the purpose it was approved previously) to give favored treatment to LLT resources that may or may not ever develop.

In other words, the CAISO would be providing a serious mismatch between:

• LLT TPD reservations from existing and already-approved transmission, for resources with expected CODs 8-10 years or more into the future many years, which could otherwise allow non-LLT resources to provide RA to load; and

• Non-LLTs with much shorter development times, which must nevertheless wait over a decade for new transmission approved in the future or just drop out of the queue.

Approving new transmission for specific resources and then reserving that TPD for those resources does not impair deliverability for other projects.  Holding back TPD for technologies where no new upgrades are approved just unfairly reduces the amount available to other projects.  Non-LLT resources proposed for LLT areas are particularly subject to harm, as TPD reserved in those areas for LLT resources will simply not be available to them.

In other words, TPD reservations should be limited to the additional TPD provided by new approved transmission identified in the TPP, and TPD from existing and already-approved transmission should be available for nearer-term, non-LLT resources.  This would be consistent with the original CAISO proposal, characterized as “holding back capacity for the purpose for which it was approved,” and would avoid depriving non-LLT resources of capacity approved earlier for their use. 

4. Triggers for releasing reserved TPD:  This proposal requires more clarification.  Assuming that the CAISO decides to proceed with LLT TPD reservations, the main focus should be release of reserved TPD for LLT resources in time for other resources to make use of it, and LSA is not sure that the proposal here would accomplish that important objective.

The Proposal says “Reserved TPD should only be released in the event of formal cancellation of an associated policy-driven transmission project or if the resource is later removed from the LRA’s portfolio due to project failure, with formal written decision by the LRA.”  This is really not clear.  The reservation is “generic,” for projects that have not yet entered the queue and/or requested a TPD Allocation, while the reference here is to specific project failure.  Is the term “resource” here intended to be specific projects (which may not yet have entered the queue or otherwise been identified) or to the resource type?

The CAISO should simply release generic reserved TPD when changes in LRA portfolios indicate that it is no longer needed.  If an LLT project receives a TPD Allocation and then fails, it would make sense for that project’s allocation (no longer a “reservation” once it was allocated) goes back into the generic reservation for the resource type/location.  However, the reserved (and unallocated) amount should be released for allocation to non-LLT projects with a reduction or elimination of that resource type/location from LRA directives to their jurisdictional LSEs.

5. Need for additional detail and discussion:  As explained in the preamble above, LSA believes that a separate effort – “Track 4” – is needed, because the proposals in this area are significantly less developed than the other Track 3 items.  Aside from LSA’s contention that LLT TPD reservations are not needed:

• The CAISO uses the terms “resource” and “resources” in ways that make it unclear whether the reference is to a specific project or a resource type.  The CAISO’s intentions in each aspect of the proposal should be clarified.

• The specifics of the TPD Allocation process need considerable additional work.  For example, the meeting slides said that “to the extent that a [LLT] resource seeks additional deliverability beyond what is in the portfolio, they will have to compete for non-reserved available capacity.”  However, there did not appear to be consensus within the CAISO about how that would work.

Consider an example where two 1,500MW off-shore wind projects (3,000MW total) are competing for a 1,000MW TPD reservation in the same area. 

The answers given by one CAISO speaker at the recent stakeholder meeting indicated that the projects would compete with each other, the 1,000MW of TPD would be awarded based on the intra-group scoring system and the other 2,000MW must compete against other projects for unreserved TPD.

Another CAISO speaker disagreed, giving answers indicating that each project could only offer 1,000MW (2,000MW total) to compete for the reservation, and the other 1,000MW from the two projects would compete against non-LLT projects for unreserved TPD.  The 1,000MW of reserved TPD would be awarded based on the intra-group scoring system, and the other 1,000MW competing for reserved TPD would simply not receive an allocation.

• The CPUC is currently considering similar issues in the Integrated Resource Planning proceeding, and the two entities should coordinate to ensure consistency.  The CPUC issued a “Proposed Decision Transmitting Electricity Resource Portfolios to the California Independent System Operator for the 2025-26 Planning Process on January 10, 2025” (PD).  The PD includes a discussion on how to define LLT resources and which technologies should qualify. 

Stakeholders will provide comments on January 30^th and reply comments on February 4^th.  These comments will likely include additional stakeholder feedback and ideas about any TPD reservation should work.  Ideally, both the CPUC and CAISO would participate in both discussions and coordinate on establishing the best approach.  This would require additional time up front but would likely eliminate mismatched approaches going forward that could cause delays and confusion for the market and CAISO.

• LLT resources would be subject to the same problem as other resources under the new framework, where they would presumably have to increase their Commercial Readiness deposits and execute GIAs soon after their Facility Studies, and begin making monthly invoice payments (see more below).  So, deferring their initial TPD Allocation requests would be of limited usefulness if they must otherwise proceed with significant financial commitments otherwise.

5. Please provide any additional feedback:

 LSA has comments in several additional areas: 

(1) TPD transfer clarifications;

(2) Projects with long-lead-time upgrades;

(3) Cluster 15 intake numbers and LLT holdbacks; and

(4) GIA requirements for C15+ projects without TPD Allocations.

TPD Transfer clarifications

As LSA mentioned in its last comments, the CAISO’s pronouncements in this area continue to be confusing.  The CAISO’s proposal appears to be as follows:

• TPD transfers within queue positions: Will continue to be allowed.

• TPD transfers to PCDS projects, or to technologies/capacity added to those projects via MMA requests:  Will continue to be allowed, as long as the “to” and “from” projects are at the same POI and voltage level.

• TPD transfers to pre-C15 EO projects, or capacity added to those projects via MMA requests:  Will continue to be allowed, as long as the “to” and “from” projects are at the same POI and voltage level.

• TPD transfers to technology/capacity added to C15+ EO projects:  Not allowed to these projects, or to technology/capacity additions via MMA requests.  However, technology/capacity additions submitted under new FCDS Interconnection Requests can enter the queue and obtain TPD Allocations through either the normal study and allocation process or TPD transfers from other projects at the same POI and voltage level.

Generally speaking, in this area, it would be helpful for the CAISO to distinguish in the Final Proposal between: (1) technology and other capacity additions added to C15+ EO projects via MMA request, where TPD Allocations and transfers are prohibited; and (2) capacity additions added to such projects via new IR submitted as seeking FCDS, where TPD Allocations and transfers are allowed.

Projects with long-lead-time upgrades

The CAISO’s response in the Draft Final Proposal to LSA’s proposal to allow projects waiting for long-lead-time transmission upgrades to have the same ability to delay their initial TPD Allocation requests as LLT resources was that such treatment was unnecessary, because:

• The timeline for long-lead-time RNUs will be factored in to the project’s GIA milestones.

• PTO delays are already accounted for in contract and queue management procedures.

These statements are accurate but beside the point.  LLT resources have these same tools but still will receive special treatment the CAISO deems needed for longer development timelines.

The issue is that these non-LLT resources are subject to the same market limitations as LLT resources with respect to PPA acquisition, namely that LSE procurement time horizons simply are not long enough for them to acquire the PPAs needed to gain and retain TPD Allocations so many years in advance of their CODs.  The problem is the time horizon, not the technology type, and the Draft Final Proposal response does not address this issue.

As LSA said in its last comments, there is no practical difference with respect to PPA acquisition between: (1) LLT resources that need 7+ years to come on-line because of the need for long-lead-time technical issues or inter-state transmission upgrades; and (2) non-LLT resources that need 7+ years to come on-line because their intra-state transmission upgrades will take that long to build. 

In fact, if thee non-LLT projects could postpone their TPD Allocation requests or (as LSA has proposed) retention requirements until more realistic dates (e.g., ~5-6 years before the In-Service Date), then they could be more comfortable committing security further in advance, as the PTOs have insisted.

Cluster 15 intake numbers and LLT holdback

The Draft Final Proposal does not address LSA’s concerns, stated several times, about the Cluster 15 process.  The CAISO has yet to even explain how it determined the amount of TPD holdbacks in the last TPD Allocation process.

LSA requests that the CAISO address these serious questions in the Final Proposal or some other appropriate forum.  In summary:

• The Cluster 15 intake figures (in the POI constraint mapping table) were based on remaining TPD after the 2023-2024 TPD Allocation process (results issued in April 2024).

• That TPD Allocation process considered TPP upgrades approved only through the 2022-2023 TPP, when there was no offshore wind (OSW) included in the CPUC base portfolio, so no Network Upgrades (NUs) targeted at OSW were approved in that TPP cycle. 

• There was OSW in the CPUC base portfolio for the 2023-2024 TPP, and upgrades targeted at OSW were approved in that TPP cycle.  However, as noted above, those upgrades were not considered in the C15 POI mapping intake information.

• By holding back 1600MW of TPD for OSW in the C15 mapping process (which did not show up until the 2023-2024 TPP) but not including any capacity approved for OSW in the 2023-2024 TPP, the CAISO greatly (and unfairly) impaired the TPD remaining for other projects.  The CAISO should have either:

• Added in the upgrades approved for OSW in the 2023-2024 TPP, and then held back TPD for the 1,600MW in the CPUC portfolio in that cycle; or

• Kept the TPD from the 2023-2024 TPD Allocation cycle, which was based on the 2022-2023 TPP, and not held back any TPD for OSW (which was not in the portfolio for the 2022-2023 TPP cycle).

As we noted before, implementing the holdback without including the capacity additions for OSW is the equivalent of adding in earlier-queued projects in interconnection studies without adding in the new upgrades approved for those projects.

This important issue should not be ignored just because the C15 intake process has commenced. 

GIA requirements for C15+ projects without TPD Allocations

The CAISO should better clarify the requirements for projects that do not receive a TPD Allocation on their first try. 

The CAISO’s Order 2023 compliance filing provides that projects in this situation must increase their Commercial Readiness deposits and execute a GIA.  LSA does not support these requirements but acknowledges that they reflect Order 2023 directives.

However, it is not clear how a project without a TPD Allocation but with two more tries over the following two years could: (1) execute a GIA with realistic milestone dates; or (2) meet requirements like monthly invoice payments and Notice to Proceed deadlines with a looming “three strikes and you’re out” provision.  Any GIAs required to be executed under these provisions should be highly conditional and not require additional financial commitments while the projects are waiting to see if their projects can even remain in the queue and move forward to development.

LSA notes that this problem will apply to LLT resources under the Draft Final Proposal, since they would be subject to the same security and GIA execution requirements.

The CAISO has said that it may address this issue for Cluster 16, but that does not help Cluster 15.  There is plenty of time to implement changes in time to help C15 projects.  These projects have already suffered through a greatly delayed timeline and a completely overhauled interconnection framework mid-stream; there is no reason to subject them to additional impediments through more uncoordinated transitional procedures.

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

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

1. We request that CAISO clarify that projects with a PPA for resource adequacy that is conditioned upon receiving an allocation (i.e., if the project does not receive an allocation, then the PPA is terminated) are acceptable.

4. Opportunities to seek TPD

We appreciate that CAISO has taken seriously our proposal to earmark TPD for specific clusters. Our support for this proposal is driven by our concern that if CAISO does not earmark TPD, then it will introduce significant risk that projects that are admitted for study ultimately will not receive TPD due to a procedural misalignment. Our proposal attempts to correct this by ensuring that all IRs have a fair shot at competing for TPD.

IRs face this risk because, under CAISO’s current proposal, new TPD that is shown to a given cluster at intake will also be offered to earlier clusters during TPD allocations before the intake cluster has finished the study process and has a chance to compete.

Referencing Table 4 in the draft final proposal—if new TPD is added (e.g., via the TPP) in late 2026 after C16 intake, projects in C17 will be admitted to the queue on the basis of this TPD. Projects in C15 and C16 will be able to compete for this TPD multiple times before C17 projects have completed the study process. C15 will have three “bites at the apple” and C16 will have one before C17 is eligible to compete for TPD. Thus, C17 projects will face increased risk that they will not receive a TPD allocation because they won’t be competing for their TPD on a level playing field with C15 and C16 projects.

The consequences of not receiving TPD for an interconnection request are even more acute in a regime where the costs to submit an IR are significantly higher due to factors like 1) increased deposits mandated by Order 2023, 2) deposits that LSEs are requiring for commercial viability points, 3) dollars spent on site control, and 4) dollars spent to de-risk IRs up front to be competitive in CAISO’s intake process.

CAISO can solve this by identifying all incremental TPD that was added after C16 intake and before C17 intake, and not offering this TPD until C17 is scheduled for TPD allocation. Further, CAISO should not show this incremental TPD to any subsequent clusters until it has been offered in TPD allocation. If CAISO is concerned that by not showing this incremental C17 TPD to subsequent clusters, then it will not be utilized due to attrition from C17, then CAISO should increase the volume of projects it accepts in C17 at intake, e.g., to 250% of available TPD. As CAISO points out, it is important to have projects competing for TPD, and we feel that this would lead to more effective competition because more projects would be competing for TPD at the same time.

Once TPD is shown during TPD allocation, CAISO should follow its current practice of including it at both future intake and TPD allocation cycles. To help projects at intake better understand the risks of not getting a TPD allocation, CAISO should identify earmarked TPD and non-earmarked TPD.

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

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

3. Amount of TPD requested and reserved

We are concerned that CAISO may be reserving more TPD than is optimal for offshore wind resources. According to the 2024-2025 TPP Final Study Plan, offshore wind is studied at 83% of its maximum output in the high system need case. However, an ELCC study posted on the CPUC’s website estimated the capacity value of offshore wind at 48%. While it is true that any increase to the deliverability study level will allow more capacity value from a given variable output resource (like offshore wind), the returns on incremental capacity value diminish with each additional percentage studied in the HSN scenario, and we believe that 83% may be a sub-optimally high reservation value that pulls headroom off of the system that could be more economically utilized by another resource (e.g., complimentary BESS).

CAISO should ensure that it is studying resource deliverability to balance the incremental capacity value against the cost of reserving TPD for these resources.

5. Please provide any additional feedback:

MN8 thanks the CAISO for its consideration of our comments

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

No comment at this time.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

No comment at this time.

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

No comment at this time.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

Regarding Special Consideration for Long Lead Time Generation and Storage Resources, NCPA requests the following clarifications be considered and added to the current draft proposal:

1. NCPA generally agrees with the eligibility criteria for long lead time resources laid out by CAISO and agrees with keeping the criteria flexible to allow for new technological developments. NCPA looks forward to discussions with CAISO regarding LRA implementation.

2. Establishment of clear rules and requirements to determine when a proposed Long Lead Time Generation or Storage Resource is no longer viable.  In the current political environment there is considerable risk faced by resource developers, with particular focus on Off-Shore Wind development.  While NCPA does not object to the concept of allowing an opportunity for a developer of a Long Lead Time Generation and Storage Resource to defer a first attempt to seek TPD, there should be clear rules and requirements to allow CAISO to make an ultimate determination of when a resource is no longer feasible for development and, if such determination is made, to release any reserved TPD to the market for the purpose of interconnecting alternative projects.  Whether such rules and requirements are based on defined timelines (e.g., if the project is delayed beyond an expected COD), or tied to key regulatory changes that result in the project no longer being viable, it will be necessary to develop such criteria to ensure that infeasible projects do not linger in the queue holding valuable TPD that could be used by other interconnection customers.

3. NCPA continues to request that CAISO include more detail in the final proposal than is presented in the current draft proposal regarding internal transmission constraints that are impacted by the proposed Off Shore Wind Project (both North Coast and Central Coast).  Transparency regarding this information will be important to assist planning and development opportunities for alternative technologies and resources.  If the CAISO is “reserving” TPD for these type of Long Lead Time Resources, it would be appropriate for CAISO to specifically identify what TPD is being reserved for such purpose down to the specific busbars.  This will help stakeholders better understand the near term and long term impacts of the current policy focused on reserving this capacity for projects that may never materialize. In addition, CAISO should make this information consistently available to stakeholders in future transmission planning and interconnection cycles.

4. NCPA also reiterates its request for clarification as to whether pumped storage hydro falls within the definition of long-duration energy storage      or of long-lead time resources in general. It would seem to satisfy the criteria, and NCPA believes it should be included.

5. Please provide any additional feedback:

No additional comments at this time.

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

PG&E appreciates the opportunity to provide questions and comments to the Draft Final Proposal of the Interconnection Enhancement Process, Track 3. 

1A. PG&E seeks clarification from CAISO regarding the timeline for this process and the scope of work for PTOs.  

In the draft proposal, CAISO had indicated that the study will commence in September 2025, with reports expected to be submitted in the first quarter of 2026, as mentioned during the stakeholder meeting held on January 15. PG&E prefers to work with CAISO to develop a PTO-specific study plan, which includes base case assumptions and dispatch scenario to determine headroom for different types of upgrades.   

According to the RIS timeline posted by CAISO in September 2024 for Cluster 15 study, QC15 reports are due on October 29, 2025, and the reassessment study will commence on October 30, with reports due on April 30, 2026. The QC15 study has a stringent 150-day timeline for QC15. 

PG&E seeks to understand how this study will be conducted concurrently with QC15 Study and the first reassessment study in accordance with the new FERC Order 2023 requirements.  According to the RIS timeline posted by CAISO in September 2024, QC15 reports are due on October 29, 2025, and the Reassessment study will commence on October 30, with reports due on April 30, 2026. The addition of another study which would be performed concurrently with the already stringent 150-day timeline for QC15 and reassessment is suboptimal. PG&E respectfully requests that CAISO take this into consideration when establishing the timeline for the new study. 

1B. PG&E requests CAISO to clarify if a project would be permitted to come online in phases if there isn’t sufficient headroom for an entire project to be accommodated. Evaluation of phases to ensure they can be accommodated can be complicated based on how the project is phased. PG&E prefers a Limited Operations Study to be used for approving phasing of projects. 

1C. PG&E recommends the Limited Operation Study not be waived for POIs at 500 kV stations or if the Short-Circuit Duty (SCD) mitigation is at a project’s Point of Interconnection (POI).  

PG&E has observed that several large multi-fuel projects’ Short-circuit Duty (SCD) contribution exceed 3% margin (for maximum circuit breaker ratings in PG&E territory) at the project’s point of interconnection (POI) resulting in our recommendation.  

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

During the stakeholder call on January 15, PG&E and other stakeholders indicated a lack of support for CAISO proposal for projects that haven’t received TPD after three cycles. 

CAISO offered the following reasoning to support its proposal:  

• Prevent stalled projects from reserving reliability related capacity and causing more viable projects to require costly and long lead-time RNUs that will likely never be needed.   

• Sanctity of the commercial process. 

• Preserving TPD for later cluster projects that apply for TPD. 

• Experience shows that developers will not use this option.  

In an effort to resolve the outstanding issue, PG&E restates our previous recommendations from December 3, 2024, in which we indicated that these projects should be given the option to continue as Energy Only projects if they meet all financial commitments to the Participating Transmission Owners (PTO). PG&E proposes these projects enter the queue seeking to be studied for deliverability be allowed to seek a TPD allocation after they come online in either group 1 or 2 allocation. 

PG&E offers the following bullets in response to the CAISO's reasons for supporting the proposal: 

• PG&E’s proposal would only apply to projects that are not stalled or lingering.  

• PG&E proposes FCDS-seeking projects be eligible to continue as EO if the IC has posted 100% of their cost responsibility (to ensure only projects which can be commercially viable as EO move forward) and are current in their obligations.  

• Indications that projects aren’t stalled, or lingering, include: 

• Projects that are seeking TPD have had substantial investment already.  

• These projects will have met FERC Order 2023 requirements to enter the cluster and will have received sufficient points to be studied.  

• By the time the TPD allocations occur, projects will have signed their LGIAs per FERC Order 2023 and may have advanced permitting to get more points for the TPD allocation process.  

• These projects will still be subject to the seven-year time in queue restrictions, much of which will already be over through the three TPD cycles.  

• PG&E does not believe our proposal interferes with the commercial process or points allocation process developed in IPE track 2. The proposal only applies to projects that sought TPD, so may have received points.  

• The CAISO has suggested that if a project does not get a PPA to get TPD after three cycles, it may not be a commercially viable project. However, while a PPA moves a project into the first category, it does not guarantee that TPD is available, meaning that the project could be commercially viable. Additionally, PG&E has found that when projects have a COD that is far off, even if they have deliverability, developers are not able to easily price the product and seek more complicated contractual terms, like indexing. Both these examples support that highly viable projects could be positioned to get EO PPAs.  By the time the three TPD cycles have passed, the COD may be closer, increasing viability.  These projects could be more viable than comparable EO projects just starting off their development process in a cluster that is three to four years newer than the cluster of the original projects.   

• Regarding reservation of TPD for projects that seek TPD allocation, this subset of projects did originally seek TPD. 

• While PG&E understands that past EO projects have not come online, IPE track 2 and FERC Order 2023 have changed the processes to come online, and past data may not be reflective of the future results. Projects that continue to meet development milestones are not “lingering” if they are current on all GIA obligations. 

PG&E’s concern is that forcing withdrawal may engender system inefficiencies, that ultimately represent a cost to the customers. While, in many cases, PG&E hopes that three years will provide ample time to price the project and obtain a PPA, there are developers who may want to develop their projects at their own risk and are willing to move forward. PG&E is concerned that, given recently updated load forecasts within the CEC’s 2023 Integrated Energy Policy Report (IEPR), forcing projects to withdraw to defer to later queue projects will delay ability to meet load. Rather than force withdrawal, PG&E would like to see guardrails to prevent lingering and allow projects that are not lingering to proceed.  

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

The CAISO proposes to adjust the due date for the second Interconnection Financial Security (IFS) posting for cluster 14 projects that opted to park following the publication of the 2024 TPD allocation results. 

PG&E requests CAISO to confirm that this extension of the second financial security posting does not interfere with commercial viability concerns or extend the "time in queue" limits that will be put in place with Cluster Queue 14. 

If it will not extend those times in queue limits or otherwise interfere with Commercial Viability concerns, then PG&E supports this proposal. 

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

PG&E supports the CAISO’s efforts to increase transparency associated with reserving TPD for long lead time resources. PG&E further recommends using the CPUC Integrated Resource Plan (IRP) Busbar Mapping (or similar non-CPUC jurisdictional Bus Bar Mapping) to further designate where the TPD should be reserved. 

Aligning the TPD to the CAISOs LLT resources reserved to date for offshore wind (OSW) and out of state wind to the broader categories for which the CPUC now recommends reserving TPD in its Proposed Decision on the IRP portfolio for the TPP: geothermal, biomass, OSW, non-battery LDES resources, in addition to portions of the OOS wind and in-state wind resources. PG&Es recommendation about Bus Bar Mapping should help achieve this alignment.  

TPD reservations only to “policy-approved transmission” can be restricting and asks CAISO to consider expanding where the reservations may be identified. Given TPP upgrades needed for reliability, it may be that the upgrades needed for a particular LLT project are identified in a different portion of the TPP and may not be called out as specific TPP policy projects. PG&E seeks clarification on how a project like the Helms expansion or geothermal projects which do not have explicit policy-approved transmission projects would avail of the reservation.  

To be eligible to receive the deliverability, PG&E agrees that resources which have reserved TPD must be locationally constrained and proposes that the projects must meet certain development milestones. PG&E also recommends that this policy be tested during the 2024-2025 TPP and revisited afterwards or after the next TPD allocation cycle to evaluate implementation and unanticipated ramifications. PG&E also agrees that there needs to be a process to release reserved TPD.  

5. Please provide any additional feedback:

PG&E supports having data of what projects (at least queue positions) are behind what RNUs and DNUs be released in a searchable form, like an excel spreadsheet. While data is available in various sources, it is not often readily searchable. Given the market and CAISO processes will require procurement with a faster turn around, LSEs need better, more digestible knowledge of the queues earlier on. While PG&E appreciates that there have been concerns about confidentiality previously, the new emphasis of expediting procurement necessitates changes. PG&E would appreciate a dialogue on how to make data accessible and suggests, at a minimum, that the tables of queue positions behind constraints from the TPD allocation report be released in a searchable, excel format.

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

REV Renewables (REV) appreciates CAISO’s continued refinements in the Track 3 proposal. REV generally supports the Draft Final Proposal and offers a few points for clarification below.

REV supports the Intra-Cluster Prioritization process. REV requests clarification on Table 1 GIA Status column. The footnotes and language indicate that these are based on the new Appendix LL and KK. However, these are applicable for Cluster 15 and beyond, and this intra-cluster prioritization process is for Cluster 14 projects that are still using Appendix DD. REV requests edits or clarification on how to translate these requirements for Cluster 14 projects.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

REV supports the proposals in this section.

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

 REV supports this proposal.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

REV requests additional detail on how this reservation would work, as it is currently unclear what would occur in the TPP process versus the Interconnection process. A few examples may help clarify.

5. Please provide any additional feedback:

 REV has no further comments at this time.

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

SDG&E supports the general concepts related to SCD/RNU headroom laid out in CAISO’s presentation. SDG&E recommends that CAISO, in the next draft, develops a detailed procedure similar to the deliverability allocation procedure. Such a document should include inputs from the PTOs, who have experience performing these studies and can advise best practices.  

While SDG&E acknowledges that ranking projects for study through the affidavit process provides necessary certainty around ISDs, it still has concerns about delayed projects retaining the allotted headroom. Projects experiencing COD delays after executing LGIA should be required to establish new milestone dates via an MMA/PTA process to retain the allotted short-circuit headroom. This will appropriately disincentivize delayed ISDs, particularly if long-duration upgrades are required to be constructed for later queued projects. Furthermore, just like deliverability, if a project does not move forward or is found to not be viable anymore, the short circuit headroom of such project should be reallocated to another more viable project. 

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

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

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

SDG&E supports CAISO’s proposal regarding the treatment of Long Lead Time resources, which attempts to afford more time to Long Lead Time resources that are included California’s resource plan. Working collaboratively with the CPUC on identifying specific Long Lead Time resources early will help the transmission development process and ensure that transmission capacity is there when needed. 

5. Please provide any additional feedback:

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

SB Energy is supportive of this proposal with the following comments. 

1. Can CAISO please consider reducing the minimum threshold for Network Upgrades for this process to three years. Permitting and construction of projects can take anywhere between 2-3 years at a minimum and therefore any network upgrades that have a duration of longer than 36 months can cause unnecessary delay in the commercialization of projects.

2. CAISO is requested to please only consider the duration of network upgrades when determining which network upgrades are going to eligible for the Intra-Cluster prioritization. Projects may have different kinds of delays (such as delays due to Deliverability upgrades coming into service after the project has achieved ISD/COD and is reliant on interfim deliverability, or delays due to Network Upgrades taking longer than it takes a project to complete permiting, engineering and construction, or delays due to PTOs). 

3. CAISO is also requested to consider making this an annual process independent of the TPD allocation process. The status and progress of projects change continuously and making this an annual process with provide chances for projects to obtain earlier allowable In-Service dates which are seen very favorably in the procurement of PPAs and financing of projects. 

4. CAISO is also requested to consider starting the first run of this process much sooner than the 2025 TPD Allocation process in September 2025. There are many Cluster 14 and earlier queued projects that will be relying on these decisions to spearhead the procurement of PPAs, engineering, construction and financing. Aigning the timing of the SCD Headroom allocation process with the 2025 TPD Allocation process and providing results in early 2026 will cause delays to such projects that achieve commercial readiness earlier based on the outcome of the SCD Headroom allocation process. 

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

SB Energy is supportive of all provisions under this proposal except e). Energy Only projects from C15 and beyond that achieve commercialization should be allowed to seek TPD allocations in the future. Not every project that has been allocated deliverability commercializes soon after and in some cases, projects with full or partial deliverability are also also considerably delayed. There is no gaurantee that such projects would be able to derisk the challenges causing the delays. At the same time, Energy Only projects that are able to commercialize on the basis of Energy Only PPAs would have undertaken significant financial risk to find a path to commercial viability. Should such projects be deliverable and achieve commercialization, these projects should be allowed for a chance at seeking deliverability in the future even if they had entered the cluster study process and Energy Only Requested project. Not many projects are expected to follow this path and CAISO is requested to consider allowing such projects to have another chance at seeking deliverability which is consistent with the eligibility of EO projects from Cluster 14 and earlier. 

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

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

5. Please provide any additional feedback:

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

The Six Cities do not oppose the CAISO’s proposal on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

Consistent with the Six Cities’ December 3, 2024 comments regarding section a (Allocation groups) and section g (Modifications to the TPD scoring criteria), the group receiving first priority for TPD allocation should explicitly include projects where the interconnection customer is a Load-Serving Entity (“LSE”) serving its own load.  The “Background” section of the CAISO’s Draft Final Proposal discusses this concept and acknowledges that the CAISO’s current policy is to include such LSE projects along with projects that have executed a power purchase agreement (“PPA”) in the highest priority group.  See Draft Final Proposal at 18-19.  Further, the “Proposal” section of the CAISO’s Draft Final Proposal incorporates updated language that appears to reflect this same concept—that an LSE serving its own load is included in the highest priority group, equivalent to projects that have executed a PPA.  See id. at 28 and Table 5.  Based on the updated language and discussion during the January 15, 2025 stakeholder meeting, the Six Cities understand that the CAISO is not seeking to change the current TPD allocation priority for LSEs serving their own load via this proposal.  However, for the avoidance of doubt, the Six Cities again request that the CAISO explicitly include such LSE projects in the applicable language defining the first priority allocation group, as reflected in the current definition of priority group A.  While the Six Cities generally support the CAISO’s proposals regarding modifications to the allocation groups and the TPD scoring criteria, the Six Cities reiterate and emphasize that such support is contingent on the CAISO’s explicit inclusion of projects where the interconnection customer is a LSE serving its own load within the highest priority group.

The Six Cities also reiterate their support and/or non-opposition regarding the proposals referenced in sections b through h, as noted in their December 3, 2024 comments.

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

The Six Cities continue to support the CAISO’s proposal to discontinue the “parking” process and require that all projects in Cluster 15 and beyond must make any required increases to their Commercial Readiness Deposits following the completion of their required interconnection studies.  With respect to pre-Cluster 15 projects, the Six Cities do not oppose the CAISO’s proposal on Adjusted 2nd Interconnection Financial Security Posting for Cluster 14 Parked Projects.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

In general, the Six Cities continue to believe that the CAISO’s proposal on Special Consideration for Long Lead Time Generation and Storage Resources would benefit from additional discussion and refinement in a future track of this initiative.  The Six Cities support thorough, studied consideration of these issues, including the need to ensure that the procurement requirements of non-CPUC jurisdictional LSEs are addressed for purposes of assigning deliverability to long lead-time resources.  However, the Six Cities caution against immediate implementation of proposed process modifications that may be underdeveloped or, at minimum, would benefit from further stakeholder input.

5. Please provide any additional feedback:

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

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

SCE supports the CAISO’s proposal to allow generators to interconnect up to an amount that would not trigger the need for long lead-time short-circuit or other reliability network upgrades. SCE appreciates that a formal CAISO process would address transparency, equity, funding, and allocation prioritization concerns. SCE also agrees that such a process should ensure there is adequate margin to accommodate the impacts of Rule 21 projects, Wholesale Distribution Access Tariff (WDAT) projects, and base case changes as well as require sufficient commitments from generation projects that partake in this process as suspensions or date extensions could cause the need for restudies.

SCE seeks confirmation that the 3% margin should be considered as an initial guideline for PTOs. Based on engineering analysis, PTOs would then determine the minimum acceptable margin, which may be less than 3%. 

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

SCE supports the proposed modifications to the TPD Allocation Process. In stakeholder discussions, there seemingly is alignment on how LSE Owned projects would qualify for a TPD allocation, however SCE is concerned that the language may not be clear on the scoring and ranking of LSE Owned projects.

Regarding the scoring of LSE Owned projects, the Draft Final Proposal states on page 36, “the points associated with the PPA group will only be available to projects that have a qualified PPA”.  SCE requests the CAISO clarify that points associated with the PPA group also apply to LSE Owned projects under development. Further, SCE requests the CAISO modify the above-referenced statement (and similar statements) to indicate, “the points associated with the PPA group will only be available to projects that have a qualified PPA or have a contract under which a Load Serving Entity would ultimately own and operate the facility.”

Concerning the “Power Purchase Agreement Status” column in Table 5 (page 38 of Draft Final Proposal), further clarifying language is warranted.  The “0 (Min. Req.)” category, in addition to “has an executed PPA”, should also include language on LSE Owned projects like what is proposed by SCE above. For the “5 points” category, SCE proposes the following language instead, as it is simpler but still captures the description of the resource:

“Capacity is to be utilized by a Load Serving Entity to meet its own RA obligation.”

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

SCE does not object to delaying the 2^nd IFS posting from 7/1/2025 to 5/29/2026 for QC14 projects that were eligible to park to align with the 2025 – 2027 TPD Allocation Study cycles as long this proposal does not: 1) preclude the PTOs from enforcing GIDAP Section 11.3.2.6 -  Shared Network Upgrades, where a parked project will be required to execute an E&P Letter Agreement with the PTO and make the 3^rd IFS Posting along with project payments toward its allocated share of the Shared Network Upgrade and 2) demonstrate all Commercial Viability Criteria no later than April 30, 2028 per Section 3.4  - Viability Criteria and Time in Queue of CAISO’s final 2023 IPE Track 2 proposal dated March 28, 2024.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

SCE appreciates the challenge of ensuring Long Lead-Time Generation and Storage Resources are provided appropriate opportunity to obtain deliverability. While SCE does not have any issues with the methodology as provided in the Draft Final Proposal, SCE notes  there are a number of complicated facets to the proposal that may warrant further discussion – e.g., coordination between the ISO/LRAs to determine what resources qualify for this category (and when) – including when resources are no longer designated long lead time and capacity is released, how “deferral” of seeking capacity would work, and how all of this dovetails with potential LSE procurement/contracting activities. As such SCE recommends additional stakeholder discussions to vet some of these details prior to adoption of a final proposal.

In addition, SCE suggests the CAISO explore whether it would be appropriate to not only determine what technologies qualify in what areas, but also create carveouts for certain technologies that match LRA suggested portfolios. Also, some resource types are arguably more “long lead time” than others, and as an inflection point, the CAISO should consider instituting a development timeline of greater than roughly 5 years when determining what is “long lead time”.

5. Please provide any additional feedback:

SCE has no additional comments currently.

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

Terra-Gen submits these comments on CAISO’s 2023 Interconnection Process Enhancements Track 3 Draft Final Proposal.

CAISO has proposed a mechanism to expedite the start of operations for energy projects by allowing them to connect to the grid before all necessary grid upgrades are complete. Terra-Gen supports this effort to streamline the interconnection process and believes it can accelerate project timelines.

Terra-Gen recommends refining the criteria used to determine which projects receive priority for this expedited process. While the project’s queue position is relevant, it shouldn't be the only factor. Projects with higher readiness scores, indicating a greater likelihood of timely completion, should be prioritized regardless of their initial queue position. Alternatively, the CAISO could eliminate queue position as a primary factor entirely.

Terra-Gen supports expanding the concept of accelerated grid connection to Deliverability Network Upgrades (DNU) since many projects face significant delays between their achievable Commercial Operation Dates (CODs) and the expected award of deliverability.  Since CAISO has not included any proposal for addressing the need for a longer-term interim deliverability status, the framework proposed for accelerating grid connection through Reliability Network Upgrades (RNU) could be adapted to provide earlier deliverability status for some projects. The principles for both upgrade types are essentially the same. Similar to the RNU proposal, projects seeking to maintain their current CODs or minimize delays can apply for available DNU headroom within the existing Transmission Planning Deliverability (TPD) Allocation process timeline. Projects willing to align their CODs with DNU construction timelines can opt out of applying for accelerated deliverability status.

Terra-Gen believes that CAISO's proposal should not consider whether a project is awaiting a DNU when deciding on expedited grid connection. Project developers should have the option to accelerate their start of operations and operate as energy-only resources, potentially with interim deliverability, regardless of their DNU status.

To enhance transparency and facilitate stakeholder understanding, CAISO should publicly disclose the schedule for posting the list of grid upgrades being considered on its website. CAISO should also clarify that the deadlines for submitting affidavits and receiving results will align with the Transmission Planning Deliverability (TPD) Allocation process. Finally, CAISO should publicly disclose the methodology used to select the grid upgrades included in this expedited connection process.

2. Please provide your organization’s questions or comments on the Modifications to the TPD Allocation Process, by these sections:

a) Allocation Groups b) Multi-fuel projects receiving an allocation with PPAs c) Parking d) Opportunities to seek TPD e) Eligibility of Energy Only projects to seek TPD f) Documentation g) Modifications to the TPD scoring criteria. H) Scoring for the Commercial Operation group

b) Multi-fuel projects receiving an allocation with PPAs – Terra-Gen supports CAISO’s proposal for Interconnection Customers (IC) requesting TPD allocations for Multi-Fuel Resources (MFR) to clarify prioritization between different portions of their projects in the TPD Allocation request process.   

d) Opportunities to seek TPD – Terra-Gen supports the proposal to allow the first opportunity to seek TPD allocation following the completion of the Facility Study, provided this timing is coordinated with the next affidavit due date. CAISO should clarify whether resources that have only received a portion of their requested deliverability by the end of their third TPD allocation opportunity will be required to downsize their capacity to reflect the actual allocation received. Terra-Gen supports the proposal allowing Cluster 15+ projects to submit an initial TPD Allocation request during the Facility Study. Given the potential for significant delays between the end of the Facility Study and the results of the next TPD Allocation, this early request will enable projects with Power Purchase Agreements (PPAs) to progress more efficiently and meet their contractual obligations.

e) Eligibility of Energy Only projects to seek TPD – Terra-Gen opposes removing future opportunities for pre-Cluster 15 (C15) EO projects (and technology additions through MMAs) to acquire pre-COD TPD Allocations after 2025. However, Terra-Gen acknowledges CAISO's decision to allow such projects to request TPD Allocations after COD. Regarding C15 and beyond projects, Terra-Gen recognizes that the "permanent" EO status for these later projects is an established tariff provision. However, Terra-Gen believes that projects (or additions through Material Modification Assessment (MMA) requests) that have demonstrated viability by reaching COD should be entitled to request a TPD Allocation for their operating capacity. This is useful for providing a pathway for viable EO projects to contribute to grid reliability and support the state's energy goals. Prohibiting operational EO projects from seeking deliverability when it becomes available would undermine the state's reliability and climate objectives. While the CPUC's RESOLVE model utilizes EO resources for locational flexibility and reducing transmission costs, it is not necessarily intended to permanently restrict their ability to access deliverability.

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

Terra-Gen supports the proposed tariff changes that would postpone the second financial security posting for Cluster 14 projects coming out of parking until after the publication of the next TPD Allocation results.

4. Please provide your organization’s questions or comments on Special Consideration for Long Lead Time Generation and Storage Resources, specifically:

a) Eligibility b) Opportunity to defer first attempt to seek TPD c) Amount of TPD requested and reserved d) Triggers for releasing reserved TPD e) Need for additional detail and discussion

Terra-Gen reiterates its previous concerns regarding the ambiguity and potential lack of internal CAISO consensus surrounding the proposed long lead-time generation rules.

Terra-Gen is concerned that allowing Long Lead-Time (LLT) projects to remain in the queue for extended periods without demonstrating viability could hinder the progress of other viable projects and inefficiently utilize valuable transmission capacity. To address this, Terra-Gen recommends CAISO incorporate viability requirements for projects awaiting their first TPD Allocation request, such as LSE or LRA interest designations, evidence of permitting progress, or on-shore substation/gen-tie development progress.

Terra-Gen notes general support for LSA’s recommendation that CAISO allow LLT projects to request TPD awards on the same timeline as other projects while postponing their retention deadlines (e.g., executed PPAs) until closer to their expected CODs, contingent on basic viability demonstrations. This approach would provide early certainty regarding TPD allocations while minimizing the need for CAISO to reserve capacity for potentially non-viable projects. CAISO did not address this alternative proposal in the Draft Final Proposal, and Terra-Gen requests that CAISO consider and respond to this proposal.

Regarding TPD reservations, Terra-Gen strongly objects to reserving transmission capacity beyond the capacity specifically created for LLT projects through new transmission upgrades. Utilizing existing and previously approved transmission for long lead-time projects while withholding it from nearer-term, non-LLT projects that require it for immediate grid reliability needs is an inefficient use of transmission assets.

TPD reservations should be limited to the additional capacity provided by newly approved transmission upgrades identified in the Transmission Plan. Existing and previously approved transmission should remain available for non-LLT projects. This approach would align with CAISO's principle of reserving capacity for the purpose for which it was originally approved.

Terra-Gen is concerned with this overall LLT topic and CAISO’s proposal lacks clarity regarding the triggers for releasing reserved TPD. CAISO should clearly define the criteria for releasing reserved TPD, such as changes in LRA portfolios indicating that the reserved capacity is no longer needed for long lead-time generation projects. Terra-Gen recommends that CAISO issue an additional proposal iteration prior to finalizing its Track 3 Final Proposal or consider deferring this aspect of the Track 3 into a separate track to allow for more robust development and discussion that can fully address the complexities of LLT generation rules. This separate track would allow for more in-depth discussion and development of these rules, given their significant impact on the interconnection process. 

5. Please provide any additional feedback: