Comments on Preliminary issue paper and stakeholder workshop

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

ACP-California appreciates the opportunity to comment on the CAISO’s IPE issue paper and the discussion that took place at the October 19^th workshop.

There are a number of more minor interconnection process improvements, such as those proposed by LSA/SEIA and many of those outlined in Section 3.1, which should be implemented through this initiative to improve the process for generation developers and their offtakers. Additionally, there are additional pieces of information and improvements to data accessibility, as discussed by Gridwell, that can be provided to developers to help reduce the number of unviable interconnection requests and partially reduce the overheated nature of the CAISO’s interconnection queue.

While both of the aforementioned reforms are necessary, they are unlikely to be sufficient to address the large volume of interconnection requests that CAISO has received and is expected to continue to receive in future clusters. Thus, through IPE, it will be necessary for CAISO to impose additional requirements for projects to be “ready” and/or increase the capital at risk to move forward in the interconnection queue. In developing requirements for “ready” projects within IPE, it will be critical to develop a suite of criteria that recognize the different development processes and land requirements for different technologies. Providing open access to the transmission system can be achieved while also accommodating and recognizing the unique development process for different technology types, especially Offshore Wind (OWS) and stand-alone Battery Energy Storage Systems (BESS), which may not be as well suited for site control/exclusivity requirements that often apply to other technology types.

ACP-California applauds CAISO for thinking creatively about modifications that might help address interconnection and deliverability issues, including wholesale changes to the deliverability allocation process. However, we caution CAISO about transitioning the deliverability process to one in which LSEs are allocated deliverability. That approach appears as though it would be similar to the Maximum Import Capability (MIC) process, which has its own set of challenges and results in substantial transaction costs for LSEs and resource developers. Additionally, as CAISO considers potential modifications to the deliverability allocation procedures, it should be mindful that if the CPUC implements major structural changes to the RA construct, they may directly affect deliverability and necessitate reevaluation of the deliverability study processes and allocation procedures. CAISO may wish to wait until the new RA construct is finalized (or close to finalized) before undertaking substantive changes to the deliverability allocation process.

ACP-California supports CAISO’s efforts to improve how the interconnection process functions and to allow viable projects to proceed forward in a timely fashion. We also support CAISO providing additional, more accessible information to developers to help reduce the number of unviable interconnection requests that CAISO receives in the future. However, the provision of additional information and data, while necessary, are unlikely to be sufficient. CAISO should explore increasing requirements for readiness in order to advance in the interconnection queue and should ensure that readiness requirements appropriately recognize the differences between technology types.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

ACP-California generally supports providing additional clarity and documentation surrounding the interconnection process, as outlined in Section 3.1, including providing additional criteria around changing sites and POIs during the study process and creating processes for transferring WDAT projects into the CAISO queue. While ACP-California generally supports addressing the issues proposed by CAISO in this section, additional discussion around the impacts of the proposed clarification to Reliability Network Upgrades should be undertaken as part of the upcoming stakeholder process.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

Given the size of Cluster 14 and the need to move the interconnection process forward, it will likely be necessary to implement some form of “readiness” requirements for interconnection customers to proceed into Phase II. The Issue Paper specifically mentions potential site exclusivity or equipment requirements in order to proceed. As mentioned during the October 19^th stakeholder workshop, it will generally be too early in the development process to impose major equipment requirements in order to proceed to Phase II (and, especially, to impose these requirements in order to enter the queue). Additionally, site exclusivity requirements may be appropriate demonstrations of readiness for certain types of projects, but will not be appropriate or reasonably achievable for others. Notably, OSW and BESS may not be well suited to meet site exclusivity requirements.[1] Given the unique nature of these technologies (and perhaps others), ACP-California encourages CAISO to explore having different requirements for different technology types to advance in the interconnection process. While there appears to be some concern about maintaining open access principles while applying different readiness criteria to different technology types, ACP-California points out that, elsewhere in the country, differing criteria for different technologies already apply. For instance, several western transmission providers enforce site control requirements have different acres per MW requirements for different resource types, to reflect the relevant land use needs each resource. Thus, we are confident that CAISO and stakeholders can work collaboratively to come up with different readiness requirements for different technology types while adhering to the principles of open and non-discriminatory access. ACP-California encourages CAISO to consider the different development processes for different resource types as it develops a Straw Proposal and to work with stakeholders to better understand the development processes for different resource types.

[1] OSW may not be well suited for site exclusivity demonstrations because, unless and until lease auctions occur, OSW resources are not capable of demonstrating site exclusivity. And stand-alone BESS may not be well suited for site exclusivity demonstrations to demonstrate readiness because many BESS applications will likely be situated in urban areas and site exclusivity will come much later in the development process in these areas than it does for wind/solar development.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

The provision of additional, more accessible data, to interconnection customers should help to reduce the number of unviable requests that utilize the cluster study process as an information gathering exercise. But, even if substantial improvements to data accessibility and information access are achieved, they are unlikely to fully address the magnitude of the issue the interconnection queue is experiencing. Thus, as part of Phase 2 of this process, CAISO will need to implement other reforms that help to further reduce unviable interconnection requests in Cluster 15 and beyond. CAISO should consider higher fees, increased deposits (with more “at risk”) and implementation of other criteria to enter and advance in the interconnection process. Development of additional “capital at risk” requirements and/or “readiness” requirements, while being mindful of the need for different readiness criteria for different technology types, should be thorough explored as part of this initiative. ACP-California looks forward to additional discussion on the appropriate deposits, fees or criteria which could be implemented in order to discourage unviable interconnection requests from being submitted.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

In Section 4.2, CAISO outlines potential modifications to the TPD Allocation process and asks whether CAISO should consider a revised TPD Allocation process where TPD is allocated to LSEs who would then enter into a PPA with a specific project. ACP-California appreciates CAISO’s creative thinking on the TPD-related challenges that exists. While we do not have a strong position on this idea at this early stage in the process, we do urge caution on this type of a modification to the TPD Allocation process. The allocation of deliverability to LSEs would appear to be analogous to the current process for allocating deliverability for import RA (the Maximum Import Capability or “MIC” process). The MIC process has significant transaction costs and can be difficult to navigate as it requires imported RA resources to identify LSEs that have, or can obtain, a MIC allocation at a particular location where the imported resource can deliver. CAISO should be aware of these challenges, and the associated transaction costs, of allocating deliverability in this manner and should ensure any proposals that are put forward on deliverability in this initiative do not recreate those challenges for internal resources. Additionally, given the potential wholesale modifications to the CPUC RA paradigm and their potential direct impacts on deliverability, CAISO may wish to postpone any substantive deliverability modifications until there is more certainty on the CPUC’s new RA rules.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

In part, Gridwell’s presentation highlighted the need to improve data accessibility in order to provide developers with more information the viability of their interconnection requests which, in turn, would help reduce the number of unviable interconnection requests that are submitted and take up valuable study resources. ACP-California supports improving data accessibility and improving overall information provided to developers in order to reduce the volume of unviable interconnection requests that are submitted. While addressing data and information provision is necessary, it is unlikely to be sufficient to address the current magnitude of the interconnection queue challenges. Thus, in addition to the scope of issues recommended by Gridwell, CAISO should explore implementation of additional requirements to advance in the interconnection queue.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

ACP-California generally supports addressing the issues presented by LSA/SEIA, as they can help improve the interconnection and deliverability allocation processes and help solve challenges that have been identified. As discussed above, additional reforms will also be required in order to reduce the number of unviable interconnection requests that are submitted in future clusters.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on the Interconnection Process Enhancements 2021 (IPE 2021) preliminary issue paper and October 19, 2021 stakeholder workshop discussion. Although 2021 IPE is expected to address several issues related to enhancing the Generator Interconnection and Deliverability Allocation Procedures (GIDAP), and further adjustments to the Cluster 14 “supercluster” process, BAMx’s comments are limited to a subset of near-term enhancements that are expected to be implemented by Summer 2022.

[1] BAMx consists of City of Palo Alto Utilities and City of Santa Clara, Silicon Valley Power.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

BAMx supports CAISO’s clarification that any remedial action scheme (RAS) or other Reliability Network Upgrade (RNU) identified in a deliverability study will continue to be categorized as an RNU and will be subject to the RNU cost cap. This approach will be consistent with the past practice and continue to provide much-needed ratepayer protection that was envisioned at the inception of GIDAP in 2012.[1]

[1] CAISO Tariff Appendix DD Section 14.3.2.1(1).

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

 No comments at this time.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

 No comments at this time.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

BAMx understands that consistent with FERC policy, as an affected system, the CAISO would only be able to require developers to build RNUs on the CAISO system. However, that does not mean that CAISO ratepayers should reimburse a generator for network upgrades on the CAISO grid if those upgrades are required for a generating facility interconnecting in another balancing authority area (BAA). To BAMx’s knowledge, none of the neighboring affected systems fund upgrades triggered on their system by the generators seeking interconnection to the CAISO grid. Therefore, consistent with the reciprocity envisioned in the CAISO’s tariff regarding the affected systems, BAMx opposes any such reimbursement of network upgrades on the CAISO grid if those upgrades are required for a generating facility interconnecting in the neighboring BAA.

BAMx appreciates the CAISO’s plan to consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems[1] where the associated generation benefits more than, or other than, the customers within the service area of the Participating Transmission Owner (PTO) owning the facilities. The regional TAC is a “postage stamp rate” based on the aggregated transmission revenue requirements (TRR) of all PTOs for all regional facilities on the CAISO system. In contrast, the local TAC is PTO-specific, charged only to customers within the service area of the PTO owning the facilities. BAMx shares the concern that the current practice for local upgrades could unduly impact local ratepayers who are not the sole beneficiaries of the upgrades, but who solely bear their costs. BAMx requests the CAISO to provide a historical quantitative analysis to demonstrate the extent of this potential problem. In other words, the CAISO should identify the specific local Network Upgrades (NU) that have been identified along with their scope and cost, and how those local NUs provide benefits beyond the specific PTO area. BAMx would reserve its opinion on the consideration of this issue until such additional information is available.

[1] Network upgrades for 200 kV systems and above are considered regional, and upgrades below 200 kV are considered local.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

No comments at this time.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

No comments at this time.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

No comments at this time.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

No comments at this time.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

No comments at this time.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

No comments at this time.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

No comments at this time.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the IPE 2021 Preliminary Issue Paper and workshop discussion. This effort is timely given the amount of interconnection requests in the queue to support new resource build needed to meet system reliability needs and state policy goals. CalCCA responds to a limited set of questions raised by the California Independent System Operator (CAISO) for consideration in Phase 2. In summary:

• CalCCA requests clarification on the existing processes for reimbursing generators for network upgrades by other balancing authorities as affected systems and the number of requests the CAISO receives;
• CalCCA supports the CAISO considering an alternative cost allocation treatment for network upgrades to local systems (below 200 kV) where the associated generation benefits more than, or other than, the customers within the service area of the Participating Transmission Owner (PTO) owning the facilities; and
• CalCCA supports more transparent and digestible information about approved transmission build and viable cites for new resource build, but new financial incentives are not needed.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

CalCCA has no comments at this time.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

CalCCA has no comments at this time.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

CalCCA has no comments at this time.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

The CAISO asks whether California’s ratepayers should reimburse a generator for network upgrades on the CAISO grid as an affected system if those upgrades are required for generating facilities interconnecting in another balancing authority area. To answer this question, CalCCA requests the CAISO clarify if costs for network upgrades in California are reimbursed by other balancing authorities when they are affected systems. If another balancing authority provides reimbursement for network upgrades in California when they are an affected system, it may be reasonable for California to do the same, as both balancing authorities are sharing the costs of network improvements that benefit their customers. However, if such mutual arrangements are not in place, it may not be appropriate for California ratepayers to pay the costs of those network upgrades. Instead, customers in each balancing authority area could pay for upgrades for the generators that are designated to serve their own load. Additionally, CalCCA requests the CAISO provide the number of these requests and associated costs the CAISO typically receives to better assess the magnitude of this issue. This information on current practice and number of requests will help stakeholders form positions on this issue.

The CAISO also asks if it should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the PTO owning the facilities. CalCCA supports re-considering an alternative cost allocation for network upgrades to local systems when the benefits extend beyond just those within the PTO service area. On principle, CalCCA supports a cost allocation methodology that allocates costs to all those who receive benefits. The current practice allocates costs of local upgrades only to customers within the PTO’s service area where the upgrade is occurring. It is prudent to re-evaluate this allocation methodology for cases in which a broader set of customers benefit from those updates to ensure costs reflect the benefits received.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

The CAISO seeks stakeholder feedback on methodologies to align generation procurement more closely with the generation and transmission expansion processes of the California Public Utilities Commission (Commission) and CAISO respectively. Specifically, the CAISO asks if there should be incentives for load-serving entities (LSEs) to procure generation projects at locations where transmission capacity has been built or approved based on the Commission portfolios.

The CAISO indicates in the issue paper that many projects obtaining Power Purchase Agreements (PPAs) are located in areas that will require various network upgrades for the resource to be operational.[1] However, LSEs already have incentives to procure generation at sites where transmission capacity is available with no or little incremental cost. Additionally, LSEs have existing procurement obligations in place to bring new resources online in the coming years under specific timeframes. When making procurement decisions, LSEs weigh various factors when selecting a project, including viable project locations and available transmission to ensure they meet their obligations in a timely and cost-effective manner. Therefore, adding additional financial incentives to procure specific generation products is not needed. However, if information about where such capacity exists is inaccessible, the lack of information will be a barrier to getting resources to interconnect at those locations.

To reduce barriers to bringing resources online where existing transmission capacity exists, the CAISO should provide additional transparency and more digestible information to LSEs. Between the Commission’s resource portfolios in the Integrated Resource Planning process, transmission capability estimates in the Transmission Planning Process, and environmental and land use mapping performed by the California Energy Commission, information already exists to inform LSEs about where transmission currently exists and could expand in the future. This information could be enhanced to further inform LSEs to procure generation where transmission already exists. For example, within the Renewable Energy Transmission Initiative, Competitive Renewable Energy Zones (CREZ) were developed to identify areas with high densities of best-quality resource while minimizing new transmission facilitates necessary to access new renewables to meet state policy goals. These were used to rank locations for resource development on an economic and environmental basis.[2] This level of detail could be incorporated into the existing processes to provide further information to LSEs about the best locations to procure new resources to minimize unnecessary time and cost impacts of new interconnection upgrades.

[1]             Interconnection Process Enhancements Issue Paper at 9.
[2]             Collaborative Transmission Planning: California’s Renewable Energy Transmission Initiative: https://www.westerngrid.net/wp-content/uploads/2012/07/tste-olsen-2200111-x.pdf.  

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

CalCCA has no comments at this time.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

CalCCA has no comments at this time.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

CalCCA has no comments at this time.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

CalCCA has no comments at this time.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

CalCCA has no comments at this time.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

CalCCA has no comments at this time.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Please see the attached California Energy Commission Letter in Support of the Interconnection Process Enhancements 2021 Initiative.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

CESA is supportive of the CAISO’s launch of the 2021 IPE Initiative given the importance of timely interconnection and transmission upgrades to meet near- and long-term resource buildout needs. Understanding that this IPE Initiative is being launched within the context of the current Queue Cluster (QC) 14 supercluster and the Federal Energy Regulatory Commission (FERC) Advanced Notice of Proposed Rulemaking (ANOPR) on future transmission systems and planning, CESA underscores the importance and need for reforms to streamline the interconnection queue, conduct proactive transmission planning instead of reactive transmission buildout and cost allocation, and ensure timely identification and construction of upgrades to enhance near- and long-term reliability and decarbonization.

With this in mind, in the near term and for the current supercluster (i.e., IPE Phase 1), CESA recommends against any retroactive changes and instead urges focus on more transparent, accessible, and granular information to guide decisions on whether to advance to Phase 2 of the interconnection study process. Otherwise, there may be limited options for the CAISO to address in the IPE to bring on incremental capacity without deviating from existing tariff processes. Rather, CESA’s focus in this initiative will most likely center around forward-looking IPE Phase 2 issues, which not only focuses on improved granular information to guide project siting and reduce the use of the interconnection process to gather this information, but also on certain modifications to viability criteria, improved use of TPP policy-driven assessments to align transmission capabilities and needs with procurement interest, feasibility of “local” cluster or PTO timelines/processes to more efficiently advance energy storage projects, and PTO performance standards and reporting.

In addition to these IPE topics, CESA also requests that the CAISO launch a new deliverability assessment enhancements initiative focused on how methodologies can be modified to align deliverability studies with the CPUC’s direction toward RA reforms, which recognizes the intended operations of specific resources for particular slices of the day and thus redefines what the RA resource should be studied for in terms of, for example, net peak deliverability. Coordinating these changes will particularly support quicker and near-term deployment of energy storage accounting for existing supply conditions.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

For the various issues posed as necessary enhancements or adjustment in Section 3.1, CESA offers the following comments:

• Downsizing window and request requirements: CESA generally supports the consideration of these changes to afford greater flexibility in the process while helping ICs avoid unrealistic upgrades. However, given the fact that these requests only take effect until the next reassessment study, this additional flexibility may have limited impact in increasing the efficiency of the interconnection process. To this end, the CAISO should consider whether more frequent TPD allocation cycles could help realize the impact of this proposal.
• Process for changes to network upgrade requirements after the second IFS posting: CESA has no position at this time.
• Withdrawal option for projects impacted by new costs and/or delayed in-service date after initial posting: CESA generally supports this potential modification as a means to reduce the queue but notes that this may not necessarily address the large volume of IRs in future cycles. CESA requests that the CAISO specify the “end date” for the withdrawal option, if any.
• Clarify definition of Reliability Network Upgrades (RNUs): CESA is generally supportive of these clarifications.
• Transferring PTO WDAT projects into the CAISO queue: CESA is supportive of modifications to ensure IRs are entered into the right queues, but the CAISO should also consider providing clear upfront information to help ICs immediately identify the appropriate queue based on their requested POI. Given the unique nature of California’s electric grid, it is not immediately obvious that certain POIs would translate to…This information could be posted in advance to create less or no after-the-fact cleanup, but having such a process in place is still helpful nonetheless. 
• Changing sites and POIs during IR validation: CESA supports the clarity and flexibility in being able to change the generating facility’s location and their POIs during the cluster IR validation period. Having a specific timeline and criteria will support upfront clarity.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

For the various issues posed as further adjustments to the Cluster 14 supercluster process in Section 3.2, CESA offers the following comments:

• Site exclusivity requirements: CESA does not support the inclusion of site exclusivity requirements for QC14 and earlier clusters to enter into the Phase 2 study process, which would represent a retroactive change for projects that entered into the queue with one set of rules and requirements. This could be a potential IPE Phase 2 issue for consideration as a viability criterion to enter into the Phase 2 study process for future queue clusters.
• Equipment requirements: CESA does not support the setting of equipment requirements as a viability criterion or a prerequisite to enter the Phase 2 process. Typically, equipment supply agreements and procurement occurs closer to the COD of projects, which maximizes the economic efficiencies of technology developments and availability and allows developers to optimize costs with multiple suppliers. Given this reality, equipment requirements present an unreasonable viability criterion that would negatively impact all project development.
• Accelerated process for “ready” projects: CESA has no position at this time and looks forward to reviewing CAISO and stakeholder proposals for criteria to define readiness. At the same time, CESA also encourages the CAISO to explore how and where existing processes can accommodate ready projects to come online without impacting queue position, cost responsibility, and TPD deliverability allocations, such as in leveraging interim deliverability processes, or with the CPUC allowing for the procurement of energy-only or PCDS resources to meet near-term emergency reliability needs. It is important to recognize that a process to accelerate some projects is a major deviation from existing processes and could delay the interconnection and deliverability process for all other projects that benefiting from this fast-track process.
• Different requirements based on technology type or resources with siting flexibility: CESA has no position at this time and looks forward to reviewing CAISO and stakeholder proposals for criteria to define what types of resources and project types would be eligible. At the same time, CESA again encourages the CAISO to explore how and where existing processes can accommodate certain project types to come online without impacting queue position, cost responsibility, and TPD deliverability allocations. In addition, rather than addressing this item as potential refinements to the current supercluster, this may be a topic worth considering in Phase 2 of the initiative, as explained further below.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

CESA has no position at this time, but like with the proposal to accelerate “ready” projects, the CAISO should consider ways to leverage existing processes and/or pursue this in a way that does not harm other projects in taking up existing and available deliverability.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

For the various issues posed as necessary Phase 2 enhancements or adjustments to be addressed in Section 4.1, CESA offers the following comments:

• Higher fees, deposits, or other criteria: CESA supports the exploration of these criteria. On the one hand, such criteria could discourage multiple submissions from a single developers, reduce speculative requests, and/or incentivize developers to submit the most viable or high-potential projects; on the other hand, increasing the bar for entry into the interconnection process could discourage small developers and projects and only favor large ones that can defray these costs to a larger scale project or corporate balance sheet. As these criteria are considered, CESA recommends that a principle of proportionality be incorporated, such as making fees/deposits scale with the MW size of projects.
• Streamlined interconnection studies: CESA supports efforts to refine study timelines to balance efficiency with completion of study work. In particular, the CAISO should explore if there are specific study criteria that can be reserved for Phase 2 studies in order to provide more timely Phase 1 study results, upon which interconnection queues may be reduced. In addition, as submitted by CESA and CalWEA in a separate request for new initiative, CESA believes that the interconnection study timelines can be more streamlined if deliverability assessments of energy storage resources are modified to recognize the intended and rational operation of the resource, especially in light of the slice-of-day RA reforms being considered by the CPUC.
• Affected systems: CESA supports the clarification to policies on projects that request study of the CAISO as an affected system, which may require new policies on cost allocation and reimbursement. Given the high volume of IRs in the CAISO queue, an increasing number of storage developers are exploring non-CAISO interconnections to support California’s reliability and policy needs as imports.
• Alternative cost allocation treatment for network upgrades to local systems: CESA generally supports consideration of this issue in the Phase 2 long-term enhancements to better align beneficiaries with cost allocation.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

For the various issues posed as general Phase 2 interconnection issues to be addressed in Section 4.3, CESA offers the following comments:

• Incentives for LSEs to procure generation projects at locations where transmission capacity has been built/approved: CESA is open to the consideration of these issues as a potential discussion matter, but we are unclear on how it translates to specific requirements or modifications to the interconnection process. This may be a CPUC matter in ensuring procurement compliance and may be better resolved through better information transfers between the CPUC, CAISO, and LSEs. In addition, this may be addressed through the use of policy-driven studies in the TPP to determine and drive optimal buildout.
• TPD allocation process revision: CESA is open to the consideration of these issues to understand the various tradeoffs. On the one hand, the current TPD allocation process is in the hands of the CAISO as a neutral entity with upfront priority groups and formulas; by contrast, having the TPD allocation in the hands of the LSEs may result in the need for new processes and may result in “black-box” processes as to how they are allocated.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

For the various issues posed as broader Phase 2 issues as it relates to existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection in Section 4.3, CESA offers the following comments:

• Alignment of interconnection process and procurement interest: CESA supports this general objective and looks forward to developing ideas or proposals to this end.
• Alignment of interconnection process with transmission system capabilities and renewable generation portfolios: CESA supports this general objective and looks forward to developing ideas or proposals to this end.
• Different interconnection requirements for location constrained versus location flexible resources: While such changes in Phase 1 of the IPE would have been retroactive and problematic with QC14 already underway, CESA recommends that the CAISO revisit the idea of having different PTOs move forward at potential different timelines, and/or have “local” cluster study processes be allowed to occur on quicker timelines if processes allow. On a going-forward basis, knowing that quicker study completion and deliverability allocation can position projects for upcoming solicitations, this can be helpful to guide ICs to understand that cluster study processes could advance more expeditiously at locations with fewer IRs, and/or where upgrades may be less/minimal or locations. With battery storage having flexibility to site in different locations, this may support the intent of this idea/proposal and still maintain key principles of fairness, open access, transparency, and proactive rule/requirement changes, while advancing the prospect of new resources like energy storage in meeting near- and mid-term reliability needs.
• Solicitation model for some key locations and constraints not addressed in portfolio development: CESA supports CAISO consideration of this issue, but the CAISO should still take directions from the CPUC in terms of key areas of procurement interest that aligns with policy objectives. For example, in the CPUC’s consideration of the retirement or reduced reliance on Aliso Canyon, this type of solicitation model could be developed for that purpose upon such determination by the CPUC. In the meantime, LCR and TPP special studies may inform the CPUC’s determination.
• CAISO ability to terminate the GIA earlier than the seven-year period: CESA has no position at this time. 

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

CESA has no further comment beyond those expressed in our responses to Questions 2-7.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

CESA has no feedback at this time.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

Gridwell’s presentation aligns with CESA’s views on a number of topics, which includes the accessibility of CAISO interconnection and transmission constraint data. Data must be provided in accessible format (e.g., Excel) and facilitate analysis, including a data dictionary and more data categories (e.g., PCDS percentage, sub-areas, resource IDs, in-service date). CESA understands that the CAISO has been increasingly providing this data, such as through the transmission capability estimates, but further and more accessible data may help reduce the phishing for information through interconnection requests. Specifically, information could be provided on how projects up to a certain MW level could move forward through the interconnection process without upgrades or modest upgrades, signaling to LSEs and ICS the viability of projects for solicitation.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

CESA appreciates the thought put into the various ideas presented by LSA/SEIA at the workshop. In particular, CESA supports the proposal to re-stack of network upgrades to facilitate CODs without impacting cost responsibilities. This idea seems reasonable and should be explored further, as it could maintain fairness and achieve the same end result while shuffling the implementation process to accommodate feasible timelines for actual upgrades. In addition, CESA supports consideration of an additional TPD allocation and retention cycle, which could offer more flexibility in getting resources online and accommodate major changes incurred as a result of reassessment studies.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Beyond CAISO interconnection study processes, a key barrier to near- and mid-term resource deployments and buildout is the timely construction and completion of network upgrades by PTOs. While specific performance standards or incentives may not be an IPE matter, CAISO should consider if there is a role for it to play in reporting on transmission upgrade project status – as part of an effort for CAISO to more effectively implement its tariff and ensure standardized reporting to LSEs and developers.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

The Staff of the CPUC Energy Division (CPUC Staff) appreciates the CAISO’s efforts to improve and enhance the interconnection process.  We offer these comments regarding the scope of this initiative:

• Consider a process to enable certain location-specific resources to receive unique treatment within the interconnection process.  Should it be deemed appropriate, state policy goals should be a factor that shapes inteconnection policy and processes.  

• Consider the benefits, costs, and structure of a mechanism to allow storage to be added to existing sites on an expedited basis to meet pressing reliability needs.

• Review certain cost allocation issues, specifically whether California’s ratepayers should reimburse a generator for network upgrades on the CAISO grid if network upgrades are required on the CAISO grid for generating facilities interconnecting in another balancing authority area.

• Consider an alternative cost allocation treatment for network upgrades to local (below 200 kV) systems.
• Consider ways to encourage generation procurement at locations where transmission capacity has been built or approved.  Consider how projects in advanced levels of development, such as projects with power purchase agreements, might have different requirements that could expedite their interconnection.

• Consider enhancements to make the Transmission Plan Deliverability Allocation process nimbler, including possible ways to enable transferring deliverability rights between resource owners where it is feasible.

• CPUC Staff also encourages consideration of how synergies between the interconnection process and the transmission planning process can be further improved.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

Regarding whether different requirements and potentially different study processes should be considered based on project technology, CPUC Staff agree this issue should be in scope for this initiative. The questions posed by the CAISO “Would different requirements for different technologies to advance in the interconnection process be appropriate? Between location-specific resources versus more location-flexible?” are important questions that certainly need to be explored as part of this initiative.

Specifically, CPUC Staff supports consideration of a process to enable certain location-specific resources to receive unique treatment within the interconnection process, should that be deemed appropriate. State policy goals are an important factor to consider. For example, it would be useful to consider how certain preferred resource types which could provide GHG or reliability benefits, but which may subject to significant hurdles in their transmission development process (such as offshore wind or geothermal), might be prioritized in some manner within GIDAP.

We recognize there is a trade-off to be struck between pure market-driven use of the transmission system and societal benefit-driven use. It will be important for all participants of this process to understand better:

• What the unique treatment within GIDAP could potentially consist of?
• What would be the benefits but also the downsides of this treatment?
• What consequences would the unique treatment have on all resource types that do not qualify?

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

In this section “the CAISO is seeking stakeholder input on whether a one-time option should be adopted to allow resources such as storage to be added to existing sites on an expedited basis to meet pressing reliability needs despite the potential impacts on earlier-queued projects.”

To further develop on CPUC’s response to question #3, there are looming needs for reliability and GHG-free resources to come online to meet the California electric sector’s goals.  In the last two years, 14.8 GW of net qualifying capacity has been ordered online by 2026 by CPUC’s Integrated Resource Planning (IRP) proceeding (https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M389/K603/389603637.PDF),as well as additional megawatts ordered by the Summer Reliability proceeding (https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M319/K825/319825388.PDF) Meeting SB 100 goals for GHG reductions will also mean record buildout of GHG-free resources over the next couple of decades.  We believe having a responsive and flexible interconnection process is essential for realizing these goals. 

CPUC staff ask that CAISO also include in the next steps of this initiative more information on the potential consequences or impacts that this may have on earlier-queued projects. Would the earlier-queued projects have to be re-evaluated? May these projects then face delays?

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

Regarding the policy for CAISO as an affected system, CPUC Staff believes cost allocation for required upgrades should be scoped into this initiative -- in particular, the outstanding issue of whether California’s ratepayers should reimburse a generator for network upgrades on the CAISO grid if network upgrades are required on the CAISO grid for generating facilities interconnecting in another balancing authority area.

In addition, CAISO should indeed re-consider an alternative cost allocation treatment for network upgrades to local (below 200 kV) systems where the associated generation benefits more than, or other than, the customers within the service area of the PTO owning the facilities.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

In this section, the CAISO asks the following key question: “Should there be incentives for load serving entities to procure generation projects at locations where transmission capacity has been built/approved based on the California Public Utilities Commission (CPUC) portfolios?”

CPUC Staff supports the inclusion of this in the scope of this initiative but believe that before this initiative can answer this question it is important to define and understand the problem:

• To what degree are load serving entities currently not procuring generation projects at locations where available transmission capacity exists or will soon exist?
• If this is occurring at a concerning scale, why is it occurring? Is it a problem of load serving entities lacking information regarding areas that are “more suitable” for development because transmission is available? Is it a problem of incentives? Or is it a problem of perception of what areas are in fact “more suitable” for development? Do other barriers to development exist in the areas where transmission capacity is available that make those locations cost-prohibitive, or at a minimum not a “first pick” for project development?
• If this historically this has not been a problem, to what degree does CAISO believe this will become a problem in the future?

Should the need to cooperate at an organizational level arise in addressing the questions and issues listed above, CPUC looks forward to the opportunity to working with CAISO.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

CPUC Staff comments on four topics relevant for Phase 2:

• CPUC Staff favors consideration of how projects in advanced levels of development, such as projects with power purchase agreements, might have different requirements that could expedite their interconnection.

• We also support discussion on a potential framework to allow storage to be added to existing sites on an expedited basis to meet pressing reliability needs.

• CPUC Staff supports consideration of enhancements to make the Transmission Plan Deliverability Allocation process nimbler, including possible ways to enable transferring deliverability rights between resource owners where it is feasible.  This could provide some relief to the queue study process and enable transmission capacity to be used where it is most valued.  

• CPUC Staff also encourages consideration of how synergies between the interconnection process and the transmission planning process can be further improved.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

CPUC Staff looks forward to further definition of the scope of this worthy effort to improve the CAISO’s interconnection policy and processes. 

We commend the CAISO for its continued commitment toward aligning resource and transmission development in innovative and practical ways that that benefit California ratepayers.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

The following are comments from the Public Advocates Office at the California Public Utilities Commission (Cal Advocates).  Cal Advocates is an independent consumer advocate with a mandate to obtain the lowest possible rates for utility services, consistent with reliable and safe service levels, and the state’s environmental goals.[1]

Cal Advocates recommends changes to the CAISO’s existing generator interconnection policies to minimize ratepayer cost and ensure reliable service.  Specific recommendations are provided on the topics covered in the 2021 Interconnection Process Enhancements Preliminary Issue Paper (2021 IPE) issued on September 30, 2021, in the order provided.

[1] Cal. Pub. Util. Code § 309.5.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

In Section 3.1 of the 2021 IPE, enhancements that would impact ratepayers were not discussed, thus Cal Advocates does not have any recommendations on this section.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

In Section 3.2 of the 2021 IPE, the CAISO asks the following:

1. Should an accelerated process for “ready” projects be considered?
2. Would “different requirements for different technologies to advance in the interconnection process be appropriate”? “Between location-specific resources versus more location-flexible.”[1]

These questions are timely given the urgent need to bolster the California resource adequacy (RA) capacity fleet.  Governor Newsom declared a state of emergency on July 30, 2021, ordering state agencies to undertake a variety of extraordinary measures to achieve energy stability.[2]  The CAISO issued reliability must-run (RMR) designations to several resources seeking retirements to meet system-wide reliability needs.[3]  The CAISO  also identified local RA deficiencies in the San Diego Gas & Electric Company (SDG&E) and Pacific Gas and Electric Company (PG&E) service territories.[4]  These tight supply conditions are reflected in California’s RA market prices.[5]  

The CAISO initiated a 2021 IPE stakeholder initiative after receiving an unprecedented 373 interconnection requests in the Cluster 14 open window.[6]  Given the tight RA capacity market, Cal Advocates supports an expedited path for technologies with demonstrated evidence of reducing transmission or energy costs for ratepayers.  While Federal Energy Regulatory Commission (FERC) Order Nos. 888 and 2003 prohibit discriminatory treatment of interconnection requests,[7] the overlapping conditions of a tight RA capacity market, system-wide RMR designations by the CAISO, and local RA deficiencies compels swift action and a change in policy.  California is not alone in facing an overwhelmed interconnection queue.  For example, the Midcontinent Independent System Operator (MISO) has noted an unprecedented number of projects and gigawatts in its 2021 queue.[8] 

The CAISO should expedite the interconnection process for preferred resources that can cost-effectively address reliability needs and achieve operational status in a timely fashion.  To be eligible for expedited treatment, projects should either solve system reliability needs and reduce the need for RMR designations, or cure a specific need identified in the CAISO local capacity technical study.[9]  To address the time-sensitive and outstanding RMR designations, the CAISO should seek temporary interconnection queue expediting authority from the FERC through a CAISO tariff amendment in 2021.  For the long-term, the CAISO should also seek a permanent change to expedite interconnection queue requests to serve reliability needs in Phase 2 of the IPE initiative.

It is worth noting that FERC’s advance notice of a proposed (ANOPR) rulemaking entitled Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection issued July 2021, also asks whether FERC should allow “a fast-track for ‘ready’ interconnection requests.  FERC suggests that this fast-track policy could remove barriers to interconnection requests that meet certain readiness criteria that could include an executed power purchase agreement, utility selection through a request for proposal process or location at an existing interconnection facility.[10]

In response to this ANOPR, the California Public Utilities Commission and the MISO Transmission Owners stated interest in some form of fast-track mechanism for the interconnection process in their filed comments.[11],[12]  Specifically, the MISO Transmission Owners support fast-tracking generator interconnection requests that are planned specifically to serve native load and or reserve margin requirements (resource adequacy),[13]  which is in-line with Cal Advocates’ recommendation above.

[1] CAISO IPE 2021, p. 6.

[2] https://www.gov.ca.gov/wp-content/uploads/2021/07/Energy-Emergency-Proc-7-30-21.pdf

[3] The vast majority of RMR designations are intended to meet identified local RA needs.  The CAISO has also noted, “the current fleet of available internal resources does not meet either the 15% or the 17.5% margin, at the net peak hour, for the month of September 2021, let alone the load forecast increase for year 2022.” http://www.caiso.com/Documents/Decision-Conditional-Approval-Extend-RMR-Contracts-Memo-Sep-2021.pdf.

[4]http://www.caiso.com/Documents/EvaluationReportofLoadServingEntitiesCompliancewith2021ResourceAdequacyRequirements.pdf

[5] The highest RA capacity prices in 2019—two years ago—reached $15.25/kilowatt-month (compared to the 2018 maximum of $10.09 in 2018), and supply constraints have only worsened since that point, which strongly suggests that prices will remain elevated until adequate supply is available to promote price competition (Jonathan Lakey, et al., 2019 Resource Adequacy Report, CPUC Energy Division, March 2021, p. 22; Simone Brant, et al., 2018 Resource Adequacy Report, CPUC Energy Division, August 2019, p. 23). See also increases in the Commission-developed Market Price Benchmark (MPB) RA Adder prices at Table 2: MPB RA Adders (Public) from IOU ERRA Forecast filings ($/kW-month) in The Public Advocates Office Comments on Administrative Law Judge’s Ruling Seeking Feedback on Mid-Term Reliability Analysis and Proposed Procurement Requirements (Public Version), March 26, 2021, p. 9.

[6] CAISO IPE 2021, pp. 3-4.  Previously, the CAISO had received an average of 113 queue requests annually, and accommodating “supercluster” 14 has required extending the study process by an additional year, which could lead to delays for all resources involved (Neil Millar, Decision on Cluster 14 Interconnection Procedure [Memorandum to CAISO Board of Governors], July 7, 2021, http://www.caiso.com/Documents/Decision-Cluster-14-Interconnection-Procedures_Memo-July-2021.pdf.).

[7]  Federal Energy Regulatory Commission, July 24, 2001, RM02-01-000, Order No. 2003, p. 1. 

[8] MISO’s interconnection queue as of September 30, 2021, has 958 interconnection requests totaling 150.3 gigawatts of total new capacity, MISO, RM21-17-000, p. 90.

[9] The CAISO’s 2022 Local Capacity Technical Study identified local capacity deficits in the North Coast/North Bay (deficit listed on p. 41) and Kern (p. 112) Local areas.  These local areas are at risk of CAISO using its backstop authority to cure deficits absent new generation or transmission.  (CAISO, 2022 Local Capacity Technical Study Final Report and Study Results, April 30, 2021.)

[10] FERC ANOPR, item 157, p. 107.

[11] CPUC, RM21-17-000, October 12, 2021, p. 70.

[12] MISO Transmission Owners, RM21-17-000, p. 40.

[13] MISO Transmission Owners, RM21-17-000, p. 40.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

In Section 3.3 of the 2021 IPE, the CAISO asks whether or not it should develop a one-time framework to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impacts on earlier-queued projects, to meet pressing reliability needs?[1]

Cal Advocates supports the development of a framework to allow resources to be interconnected to the CAISO grid on an expedited basis if they will meet pressing reliability needs as stated in our response to question number 3. 

Additionally, if a transmission solution (such as the installation of storage at an impacted area on the grid) is identified as the lowest cost and best fit option in the CAISO Transmission Planning Process (TPP) to address a reliability issue that is already impacting ratepayers, then Cal Advocates supports expediting both the competitive solicitation and interconnection study analysis for the transmission solution project.  This would remedy the identified reliability issue and could expeditiously reduce ratepayer costs.

[1] CAISO  2021 IEP, p. 7.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

In Section 4.1 of the 2021 IPE, the CAISO proposes several enhancements as questions.  The following are Cal Advocates’ recommendations to these questions in the order that they are discussed in the 2021 IPE.

1.Should higher fees, deposits or other criteria be required for submitting an interconnection request?

Cal Advocates supports increasing the interconnection submittal fee for projects seeking an interconnection location point where there is limited or no available transmission capacity.  This would deter developers from installing generation where it would require new or upgraded transmission, therefore, keeping costs down for ratepayers.  This fee could be based on the estimated value of the project.  Cal Advocates also recommends maintaining the current interconnection submittal fee of $50,000 for developers that locate projects where there is existing transmission capacity. 

Cal Advocates also recommends the CAISO provide more user-friendly information regarding available transmission capacity on the CAISO grid per the recommendations provided in Gridwell’s October 19, 2021, workshop.[1]  In addition, the CAISO should update this information on a monthly or quarterly basis.  These changes will encourage developers to propose generation in locations where there is available transmission capacity.  Cal Advocates also recommends that the CAISO provide information on how many developers are proposing to use the same interconnection point so that new interconnection requestors can make more informed decisions on their selected point of interconnection.  As the CAISO states, “developers should be incentivized to find cost-efficient interconnection sites.”[2]

2. Should California ratepayers reimburse a generator for network upgrades on the CAISO grid if these network upgrades are required on the CAISO grid for generating facilities interconnecting in another balancing authority area.[3]

The CAISO should not unilaterally agree to expand inter-regional transmission capacity without assessing the benefits for each region along with the costs attributable to each region.  New transmission project proposals should be required to identify each affected region or Balancing Authority Area (BAA) that could be impacted for project review and assessment.  The CAISO should not unilaterally fund external project without proper review process as specified by FERC Order No. 1000.[4]  Cal Advocates recommends that the costs for new transmission to accommodate new resources outside of the CAISO grid should be handled under the inter-regional review mechanism put into place by FERC Order No. 1000.[5]  

3. Should the CAISO re-consider an alternative cost allocation treatment for network upgrades to low (below 200 kilovolts) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating Transmission Owning (PTO) facility?[6]

Cal Advocates requests that the CAISO evaluate and determine the likely benefits that network upgrades to low systems (below 200 kilovolts) could provide to other customers outside their PTO service area and to the CAISO grid.  This analysis could then be used to determine network upgrade cost allocation between the PTOs’ service areas and California’s regional transmission access charge.  As an example, in Southwest Power Pool (SPP), 67% of the costs for Network Upgrades between 100-300 kilovolts (kV) are allocated to the zone where the upgrades are constructed and 33% are allocated to the region.[7]  This cost allocation split is based on a study SPP conducted that demonstrated the benefits of higher voltage transmission lines to the region as well as the local area in which they are located.

[1] 2021 Interconnection Process Enhancements – Gridwell Consulting Proposed Issues (presentation), October 2021, slides 6-7.

[2] CAISO, FERC RM21-17-000, October 12, 2021, p. 104.

[3] CAISO 2021 IEP, p. 8.

[4] FERC Order 1000, Docket No. RM10-23-000, Sections 164 - 178, pp. 90 – 101.

[5] FERC Order 1000, Docket No. RM10-23-000, Sections 164 - 178, pp. 90 – 101.

[6] CAISO 2021 IPE, p. 8.

[7] Southwest Power Pool, FERC RM21-17-000, October 12, 2021, p. 17.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

In Section 4.2 of the 2021 IPE, the CAISO ask whether incentives should be considered for load serving entities (LSE) to procure generation projects at locations where transmission capacity has been built or approved based on the CPUC portfolios?

Cal Advocates does not support providing incentives to ensure that LSE procure projects in preferred areas.  Instead, Cal Advocates recommends that the CAISO provide more information on the available transmission capacity on its managed facilities including the number of developers that are seeking to use the same point of interconnection so that developers can make more informed decisions on where to locate their projects.  During the interconnection process enhancement meeting, a former CAISO interconnection policy staff and Gridwell representative also stated that “developers do not have sufficient data to evaluate potential project interconnection sites.”[1]  This former CAISO staff recommended that the CAISO increase data accessibility to address and to improve CAISO interconnection queue opportunities.[2]

It is important for project developers to know where the CAISO has available transmission capacity in order to plan for a speedy project development effort.  Project developers will be better served by the CAISO if they can complete a project in three to five years at a location that has available capacity versus a project that may take seven to ten years based on a renewable cluster analysis that leads to requiring new transmission upgrade(s).

[1] 2021 Interconnection Process Enhancements – Gridwell Consulting Proposed Issues (presentation), October 2021, slides 3.

[2] 2021 Interconnection Process Enhancements – Gridwell Consulting Proposed Issues (presentation), October 2021, slides 3-7.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

As discussed in responses to questions 2 and 3 above, Cal Advocates supports fast-track treatment for generation interconnection requests that could meet reliability needs identified in the CAISO TPP or resource adequacy requirements.  This recommendation is consistent with Cal Advocates’ prior recommendations on the CAISO’s 2018 IPE in which we supported measures to manage the queue “such as giving priority queue positions to resources that provide capacity or meet other energy services needs in the project area, and/or serve an identified CAISO controlled grid need.”[1]

In our response to questions 5 and 6 above, Cal Advocates also recommends that the CAISO provide better information on CAISO system conditions and available capacity, so that project developers could select the optimal locations for their projects. 

The CAISO may also consider a separate track for requests that do not require system upgrades as this will reduce costs for ratepayers, but this track should not take priority over projects to meet reliability needs.

[1] Cal Advocates Comments on the 2018 IPE – Issue paper, February 7, 2018, p. 8.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

Please refer to Cal Advocates’ responses to questions 3 through 6 above. 

Additionally, Cal Advocates recommends that the CAISO revisit the cost responsibility for network upgrades required to accommodate generator interconnection requests.  Specifically, Cal Advocates recommends that the CAISO revise its cost responsibility policy so that the cost of interconnection upgrades that are not needed for reliability are assigned to interconnection customers, not ratepayers.  This would be consistent with the interconnection cost responsibility policies in the MISO authority area.[1]

Currently in California, most interconnection customers do not fund network upgrade costs.  As the CAISO states, interconnection customers only finance network upgrade costs, and participating transmission owners refund their payments over a five-year period.[2]

[1] Midcontinent Independent System Operator Transmission Owners, FERC RM21-17-000, October 12, 2021, p. 35.

[2] CAISO, FERC RM21-17-000Comments, October 12, 2021, p. 90.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

Cal Advocates has no comment, at this time regarding the Southern California Edison presentation provided at the October 19, 2021, stakeholder workshop.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

As stated in our response to questions 5 and 6, Cal Advocates agrees with Gridwell’s recommendations to improve transmission capacity information.[1]  

Cal Advocates also requests that the CAISO review and either confirm or update Gridwell’s estimate that only one in 10 interconnection requests and 4% of proposed megawatts reach completion[2] with information on the estimated dropout rate in the CAISO interconnection queue.

[1] 2021 Interconnection Process Enhancements – Gridwell Consulting Proposed Issues (presentation), October 2021, slides 6-7.

[2] 2021 Interconnection Process Enhancements – Gridwell Consulting Proposed Issues (presentation), October 2021, slide 10.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

Cal Advocates supports the Large-Scale Solar Association (LSA) and Solar Energy Industries Association (SEIA) requests for greater transparency on interim deliverability further described in their presentation during the October 19, 2021, stakeholder workshop.[1]

[1] 2021 Interconnection Process Enhancements – LSA & SEIA Proposed Issues, Stakeholder Workshop, October 19, 2021, p. 6.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

 At this time, Cal Advocates has no additional comments on the CAISO’s 2021 IPE.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

CalWEA believes that a number of the items are ill-advised, and we encourage CAISO to move forward and focus on the following issues –

• Have a resilient interconnection process to deal with the issues caused by the over-crowded queue and keep it accessible to smaller developers.
• Honor queue integrity and provide better transparency. No special treatment should be given for technology, location, or other considerations unless circumstances clearly warrant. No queue jumping should be allowed.
• Focus on helping projects in the queue complete the interconnection study process and receive deliverability, thus creating a competitive procurement environment.
• Provide better opportunities for Energy Only resources to seek deliverability.
• Streamline the process to allow projects to interconnect before the GRNU that is triggered by a group of projects. Improve flexibility to deal with network upgrade construction delays.
• Strengthen the cost cap established by the lower ­­­of the Phase I and Phase II studies and minimize disruption from post-Phase II activities.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

CalWEA supports enhancement of the downsizing process, such as  allowing downsizing requests to be submitted at any time. Interconnection requests that do not share any network upgrade cost with other projects could be processed in an expedited manner, e.g., through the MMA process.

Errors or omissions identified after the second IFS posting should not increase an interconnection customer’s (IC) maximum cost responsibility and maximum cost exposure as the IC could have already made financial decisions and commitments based on the previous network upgrade assignment.

CalWEA supports full refund of IFS and un-used study deposits if the project withdraws after being notified of any new network upgrade requirements or delays in COD.

The ISO should, at a minimum, clarify in the BPM that, when congestion management is sufficient to maintain system reliability in lieu of a RAS, the RAS is not required for the generation project to interconnect and should not delay the COD. This is especially true for projects in the ISP where the ISP reliability assessment does not identify any need for a RAS, even if later deliverability assessment requires the RAS for FCDS.

CalWEA supports formalizing the process of transferring an IR between the ISO Queue and a PTO’s WDAT Queue, as well as establishing rules for changing sites and POI during IR validation. Regarding the latter, the rules should be based on geographic distance or electrical distance, whichever is further.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

CalWEA strongly opposes changes to the current site exclusivity requirement. A deposit in lieu of site exclusivity document should be allowed when submitting IRs.

The ISO should not introduce equipment requirements. There are many uncertainties associated with project development, many of which are out of the developer’s control. Also, technologies can evolve quickly. Requiring developers to make early commitments to specific equipment is unrealistic and will prevent developers from making the most efficient and effective equipment decisions that may benefit the grid and ratepayers.

An accelerated process for “Ready” projects could be beneficial. For example, “Ready” projects could skip the Phase I study and be put into a Phase II study directly as long as the projects are willing to forego Phase I cost protections and accept sole allocation of any new upgrade requirements. However, the coordination of the “ready” projects process with the main study process could be complicated and should be designed carefully so as not to delay the study process for other projects. Readiness criteria also should be developed to prevent abuse by the utilities intending to develop their own projects.

CalWEA opposes special treatment based on technology unless circumstances clearly warrant.  For example, if an EO project agrees to fund DNUs to obtain FCDS, CAISO should allow that.  Another example is to relax technical requirements for offshore wind in the early stage of the study process, given the long development lead time for these projects. A conceptual user-written model, instead of a site-specific model, should be allowed before the Phase II study.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

CalWEA strongly opposes queue-jumping. The ISO should play no role in favoring specific projects.  If desired, LRAs or LSEs can promote specific projects already in the queue by awarding PPAs or mandating certain types of resources, or CAISO can issue RMR contracts.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

CalWEA opposes higher fees and study deposits for entering the queue. Fees are sufficiently high and shouldn't become unaffordable to smaller developers.

The ISO clarified that it intends to reduce the study scope instead of expanding the study timeline. CalWEA is concerned about the cost implication of the reduced scope. Reducing study scope should not remove the cost protections in the Phase I study process and should not have the unintended consequence of PTOs inflating the Phase I cost to cover potentially missed network upgrade requirements.   

For generation projects interconnecting outside the ISO BAA, but impacting the ISO grid, the study of ISO as an affected system should use the latest available ISO cluster study base case, instead of waiting for the current cluster to complete its Phase I or Phase II study. The network upgrade costs identified in the study are reimbursable if the generator will export to the ISO.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

Incentives to align LSE procurement with CPUC portfolios already exists in the CAISO’s GIP and the CPUC’s IRP-TPP processes, and resources are available at the locations identified by the CPUC’s busbar mapping process. The ISO approves policy upgrades by studying the CPUC portfolios. The approved upgrades support generation in the queue to obtain deliverability. LSE procurement requires deliverability. This loop is already there and there is more than enough generation already in the queue. The ISO should focus on helping projects in the queue complete the interconnection study process and receive deliverability, thus creating a competitive procurement environment. The ISO should consider deliverability methodology refinements to make more deliverability available. CALWEA, together with the California Energy Storage Alliance, has submitted deliverability methodology reform into the CAISO’s policy initiatives catalog. 

TPD should be allocated directly to generators, not to LSEs. Allocating TPD to LSE would introduce inefficiencies and create the potential for market power for LSEs.

The ISO should consider enhancing opportunities for EO projects to receive deliverability.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

See comments above for 4.2 regarding aligning the interconnection process with procurement.

As for the proposal for the ISO to be able to terminate a GIA earlier than the 7-year period if a project cannot prove that it is moving forward towards permitting and construction, this is impractical and thus not worth pursuing. Projects can always show some progress towards obtaining a PPA or land-use permit.  Moreover, even after the 7-year period, the ISO tariff allows the ISO only to take away the full capacity or partial capacity deliverability status if the project fails the commercial viability test, not to terminate the GIA.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

No further comment at this time.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

Shared IRNUs should not be exempted from GIDAP 14.2.2 if the projects sharing upgrades have no affiliation with each other.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

The public queue could be enhanced by including more non-confidential information, especially for Partial Capacity Deliverability Status. Regarding the availability of transmission capacity, plenty of information is available and accessible on the ISO website although, given the complexity of the technical studies underlying such information, advanced technical skills are required to interpret the information.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

CalWEA generally supports enhancements to the TPD allocation to provide greater flexibility and accessibility to deliverability. TPD can be tradeable for projects at the same POI although it would not always be a MW-for-MW trade, depending on the ISO deliverability assessment methodology for different technologies. When increased scope and construction time are identified in the annual reassessment, impacted projects should be given an additional opportunity to meet TPD seeking/retention criteria. EO projects should be able to seek deliverability before they are operational. Furthermore, CalWEA urges that the ISO allow EO projects to fund LDNUs to obtain full capacity or partial capacity deliverability status. Prioritization of TPD groups should be revisited. CalWEA supports merging groups 1 and 4 and treating them the same, and the same for groups 2 and 5.

CalWEA agrees it is important to system reliability that a formal process is established to deal with battery performance degradation.

CalWEA supports more proactive actions by the ISO to help developers deal with high-cost upgrade requirements and significant delays of COD due to affected system studies performed by the neighboring utilities.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Although the ISO allows generators to interconnect before all the RNUs are in service through a limited operational study (LOS), the process is still missing pieces. The LOS is done 5 months ahead of the synchronization date. However, without knowing if the generator can interconnect, the IC can’t plan for the synchronization date. The process needs to be streamlined to allow generators to interconnect until the triggered GRNUs are actually needed and have policy on treating generators after the actual needs arise.

When a generator seeks interconnection to an old substation, the PTO may require the substation to be converted in accordance with current design standards. In such a situation, the PTO should not assign the full converting cost to the generator. The generator should only be assigned the cost for the facilities it uses to interconnect.

The ISP electrical independence test (EIT) should be re-examined by the ISO. Per EIT criteria, projects of any size with >= 5% shift factor on the selected transmission element fails the EIT. However, the flow impact of a small project is insignificant and non-material for a high voltage transmission facility. CalWEA recommends a flow impact consideration for projects with impacts, e.g., shift factor >= 5% and flow impact >=2%. Also with the super-cluster timeline, a requirement to perform the EIT using the current cluster results should be re-considered and revised.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Calpine appreciates the opportunity to comment and the CAISO's identification of a host of possible initiatives.  While the "horse may have already left the barn", the scale and scope of the queue, exemplified by Queue Cluster 14, has placed an unsustainable burden on transmission planners and forced them to design upgrades based on a fictional house-of-cards.  Calpine supports refinements that make it harder to join, and more expensive to stay in the queue. 

Our comments are limited to specific concerns or ideas, and we do not comment on all proposals.  

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

Calpine agrees that there must be limitations on the ability to "hunt" for a good POI during the IR validation process.  Indeed, with better information -- for example, the posting of preferred, minimal anticipate upgrade interconnection locations -- changes to POI might be substantially avoided.  

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

Calpine would support stronger screening criteria not just prior to Phase 2 studies, but with the submission of an interconnection request.  For example, and again with better information on preferred locations, the CAISO could require site exclusivity as a part of an I/R.

Demonstrations of "equipment commitments" could be helpful in some circumstances.  However, the combination of a rapidly evolving technology marketplace and the extended timeline for C14 (3-4 years) could force a developer to "commit" to equipment that could become obsolete, or outdated.  Placing more money at risk might create the same incentives (to stay or drop) without the potential for inefficient outcomes. 

Calpine suggests that the creation of an accelerated process for "ready" projects requires much more discussion.  If the CAISO pursues this idea, which is a significant departure from historic practice, it should address this issue in a workshop format.  

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

No Comment

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

Calpine would support stronger requirements for the submission of an interconnection request.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

Shortening and consolidating study timelines would be very helpful. In fact, the value of Phase 1 studies seems suspect, given the broad assumptions upon which they are built.  

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

Calpine opposes any proposal that would allocate TPD deliverability to LSEs as it would unreasonably encourage self-build options as well as reinforce buy-side market power. Such an allocation is perhaps, a very large departure from open access principles.  

Having solicitations that are based on development at preferred locations seems to interfere with pre-existing queue priorities. 

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

No Comment

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

No Comment

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

No Comment

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

No Comment

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

No Comment

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

CORD is a nonpartisan coalition of renewable energy developers, energy companies and transmission companies dedicated to advancing renewable energy development in the West with particular focus on solar, wind and geothermal development in the Southern Nevada region of the California Independent System Operator’s (CAISO) grid. CORD recognizes that the risks of 138kV upgrade costs being allocated to small PTOs like VEA creates a barrier to renewable buildout in high potential renewable areas such as Southern Nevada. CORD strongly encourages the CAISO to work with stakeholders in this process to address how to resolve this issue and minimize these development risks/costs.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Diamond Generating Corporation (“Diamond”) is pleased to provide comments on the California Independent System Operator’s (“CAISO’s”) Interconnection Process Enhancements 2021 Preliminary Issue Paper, dated September 30, 2021 (“Issue Paper”).  The Issue Paper indicates: 

The CAISO is seeking stakeholder input on whether a one-time option should be adopted to allow resources such as storage to be added to existing sites on [an] expedited basis to meet pressing reliability needs despite the potential impacts on earlier-queued projects.

Issue Paper at 7.  Diamond believes the CAISO should make this one-time option available immediately in response to the Governor’s Proclamation of a State of Emergency issued on July 30, 2021, (“Proclamation of Emergency”)  which permits the California Energy Commission (“CEC”) to issue permits for battery storage systems (“BSS”) of 20 MW or more that will deliver net peak energy by October 31, 2022.[1]

On September 8, 2021, the CEC issued Order No.: 21-0908-2 (“CEC Order”) which establishes a process for licensing new or expansions of battery storage systems of 20 MW or more and required that applications be filed by November 1, 2021.[2] 

On October 29, 2021, the CPUC issued a Proposed Decision in Docket No. 20-11-003, finding “The Commission has conducted an analysis of the need for new resources and found that a range of 2,000 to 3,000 megawatts of new supply and demand-side resources is needed  to address grid reliability in 2022 and 2023.”[3]  For supply side resources, the Proposed Decision  notes that resources with June 1, 2022 ,Commercial Online Dates are preferred but recognizes that resources that are operational by the following year, August 1, 2023,  should also be considered.[4] The Proposed Decision goes on to propose rules which require the investor-owned utilities to conduct the necessary procurement activities.

Now it is the CAISO’s turn to take action.  The Proclamation of Emergency specifically provides:

14. The CAISO is requested to take all actions available and use best efforts, including seeking waivers to its existing tariff processes, to expedite the interconnection to the transmission grid of resources specified by the California Energy Commission for purposes of meeting the intent of this proclamation.

Proclamation of Emergency at ¶ 14.  

The Issue Paper is an excellent first step to meeting the Governor’s proclamation, but success in achieving the Governor’s objective requires the CAISO act with utmost speed.  As discussed in the further comments, Diamond intends to permit two BSS projects under the CEC Order, but the capital investments for these projects can only be made if the CAISO takes the steps necessary over the next two to three months to seek the necessary waivers ensuring a clear path for the BESS projects to interconnect by October 31, 2022.   Diamond has uploaded a fuller set of comments as an attachment  to this submission.

[1] A copy of the Proclamation of Emergency is available at https://www.gov.ca.gov/wp-content/uploads/2021/07/Energy-Emergency-Proc-7-30-21.pdf .  See Section 11 (“With respect to new, and expansions of, battery storage systems of 20 megawatts or more that the California Energy Commission determines are capable of discharging for at least two hours and will deliver net peak energy by October 31, 2022, the provisions of Public Resources Code, Division 13 (commencing with Section 21000) and regulations adopted pursuant to that Division, are suspended to the extent that the Energy Commission determines that such systems should be licensed. Public Resources Code section 25500 shall apply to the issuance of a license under this Paragraph (notwithstanding the 50-megawatt limitation in Public Resources Code section 25120). The California Energy Commission shall implement the provisions in this Paragraph in consultation with local jurisdictions and state agencies.”)

[2] The order is available at https://www.energy.ca.gov/sites/default/files/2021-09/Expedited%20Battery%20Licensing_Order_N0_21-0908-2_ADA.pdf .  The CEC has also prepared a “Battery Storage System (“BSS”) Application Checklist” available at   https://www.energy.ca.gov/media/6104.  The checklist requires “proof of interconnection authorization by October 31, 2022.” Checklist at 1.12.

[3] Proposed Decision, Docket No. 20-11-003, issued October 29, 2021 at 2, which is available at https://docs.cpuc.ca.gov/SearchRes.aspx?docformat=ALL&docid=418927517. 

[4] Id. Ordering paragraph 60 at 164.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

See attached Comments of Diamond Generation LLC 

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

See attached Comments of Diamond Generation LLC 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

EDF-R appreciates this opportunity to provide comments and suggestions for consideration as the CAISO develops the scope for the Interconnection process enhancements 2021 stakeholder initiative. EDF-R supports many of the reforms proposed during the Oct 19 stakeholder workshop with two notable exceptions:

• EDF-R does not support the CAISO’s proposal to provide interconnection customers a one-time opportunity to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impacts on earlier-queued projects.
• EDF-R does not support CAISO’s suggestion to initiate a new or different method to terminate generation interconnection agreements that have not yet passed the seven (7) year time-in-queue limit.

In addition to giving feedback on proposals in CAISO’s paper and at the Oct 19 workshop, EDF-R also proposes that the CAISO completely restructure its material modification assessment (MMA) process. The process as it exists today is onerous for interconnection customers, the CAISO’s own reports on the process prove that the process has little value, and the CAISO simply will not be able to provide reasonable response times given their already limited staff resources are devoted to the enormous task of reviewing Supercluster 14.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

 EDF-R supports simplifying the downsizing process.

EDF-R believes that CAISO should enact policy changes to protect interconnection customers from increased costs and in-service date delays caused by an error or omission discovered after the initial and the second postings have passed. In this circumstance these costs should be borne by the Participating Transmission Owner (PTO). This is particularly important if the newly discovered cost is for an interconnection item the interconnection will not receive reimbursement for. Furthermore, EDF-R believes that the PTO should be obligated to identify and fund interim solutions to remedy any delays to the earliest achievable in-service date if the interconnection customer can provide proof of PPA or shortlist for the project. This would create a more equitable responsibility balance in universe of energy contracts:

• LSEs are responsible for RA showings, and pay penalties when they are short
• Interconnection Customers are responsible to perform on their contract, and pay liquidated damages when they fail to perform, and
• PTOs should be obligated to remedy any harm caused by an error or omission discovered after two and a half years of study work

EDF-R supports easy offramps for projects impacted by new costs and/or delayed in-service date after initial posting.

EDF-R suggests that in addition to considering criteria for POI changes during the scoping meeting, the CAISO should improve transmission system data availability and accessibility. If developers had information such as Transmission Plan Deliverability availability, congestion, and the magnitude of upgrades needed to accommodate new supply in a particular area, the CAISO would not see as many speculatory interconnection requests. MISO’s POI Analysis tool is a good example of a high value scalable tool for this purpose. https://giqueue.misoenergy.org/PoiAnalysis/index.html

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

EDF-R suggests that it would be unfair to increase the requirements for interconnection requests (site exclusivity, equipment requirements, etc.) without simultaneously reducing the length of the study process.

• In EDF-R’s experience, landowners are not enthusiastic about extending long term exclusive options and the CAISO’s 2.5 year study process often consumes a large portion of the opportunity window developers have to act on those land options.
• EDF-R also sees requirements on equipment procurement as ill-suited as a queue-reduction technique.
• EDF-R suggests that certain studies should only be performed during Phase II (i.e short circuit, stability)
• EDF-R suggests that the CAISO should review if Appendix DD section 8.6 “Accelerated Phase II Interconnection Study Process” can be expanded to include a larger number of projects, and that if it is clear that interconnection capacity and Transmission Plan Deliverability in an area is sufficient to accommodate all projects in that area requesting it, then the projects should be offered the opportunity to skip Phase II and be grouped for TPD allocation with the next TPD group (I.e. a cluster 19 project that elects to skip Phase II would be grouped for TPD allocation with cluster 18) 
• EDF-R does not support an accelerated first ready process or the CAISO’s proposal for another one-time modification opportunity, it’s unclear what criteria would be used to identify ready projects, nor how the CAISO would ensure performance once the projects received their study results. EDF-R would prefer CAISO focus its resources streamlining its existing processes.
• EDF-R does support the creation of a non-refundable fee that is scaled with interconnection capacity MW to proceed into the Phase I study after the scoping meeting. Supercluster 14 has 14 projects seeking interconnection for 1,000 MW or more, and yet in its entire history no project larger than 800 MW has declared commercial operation. Projects of this size increase the volatility of study results and exacerbate an already bloated queue.  

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

EDF-R does not support a one-time opportunity to allow resources such as storage to be added to existing sites on expedited basis to meet pressing reliability needs despite the potential impacts on earlier-queued projects. CAISO MMA and BTM processes are already sufficient to accommodate such requests. EDF-R encourages CAISO to instead focus any resources that would be spent on a one-time effort to be used to reduce the turn time on MMAs.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

EDF-R support creation of a study process for CAISO as an affected system. EDF-R also supports the notion that network upgrades identified in this process that improve transmission or when resource is set to provide RA in CA should be eligible for reimbursement.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

EDF-R supports and highly encourages increased coordination between the Joint Agencies. On this topic EDF-R notes that if developers had information such as Transmission Plan Deliverability availability, congestion, and the magnitude of upgrades needed to accommodate new supply in a particular area, the CAISO would not see as many speculatory interconnection requests or interconnection requests being proposed in already difficult and saturated areas. MISO’s POI Analysis tool is a good example of a high value scalable tool for this purpose. https://giqueue.misoenergy.org/PoiAnalysis/index.html

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

EDF-R does not support CAISO’s suggestion to initiate a new or different method to terminate generation interconnection agreements that have not yet passed the seven (7) year time-in-queue limit. CAISO already has the ability to hold projects in breach for failure to perform on Appendix B milestones in the project’s executed GIAs. It would be more appropriate for the CAISO to focus its attention on the 83 projects cluster 11 and prior that are already at or beyond their 7 year time-in-queue limit.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

EDF-R proposes that the CAISO completely restructure its material modification assessment (MMA) process. The process as it exists today is onerous for interconnection customers, the CAISO’s own reports on the process prove that the process has little value, and the CAISO simply will not be able to provide reasonable response times given their already limited staff resources are devoted to the enormous task of reviewing Supercluster 14.

EDF-R is an experienced developer and has submitted dozens of modification requests since the process was formalized in the Interconnection Process Enhancements 2013 stakeholder initiative and memorized in the BPM for Queue Management[1]. In the seven (7) years since the CAISO has rarely denied a modification proposal. In CAISO’s data on the MMA process for 2017, 2018, and 2019 the CAISO reviewed 163 requests for modification. Of those 163 requests, one was denied outright, two were partially denied. The MMA process results in an approved modification 98% of the time.

Despite the fact modifications are approved 98% of the time, it can take 6 months to receive the CAISO’s modification approval letter. All the while development plans are in limbo, as interconnection customers are not assured their modifications will be approved. This timeframe is sure to get worse in the coming years as the CAISO’s already lean staff works to study Supercluster 14.  

EDF-R is not proposing the CAISO eliminate the process altogether. EDF-R acknowledges the CAISO needs the detailed technical data it collects during the modification process. However, it is not clear that the study work being undertaken by the CAISO and PTO are a required control for preventing issues, since 98% of modifications are approved. EDF-R proposes the CAISO shift the process to one where approval is automatic if the interconnection customer presents:

• a complete technical data package (as verified by the CAISO),
• agrees to abide by standard control mechanisms, and
• provides a one-time fee of $5,000 to cover the cost of validating technical information and memorializing the modification in a letter from the CAISO to be endorsed by the interconnection customer

[1] Now known as the BPM for Generator Management.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

EDF-R is supportive of the topics presented by Gridwell and more specifically the items regarding information sharing that would improve decision making. One example would be to improve the curtailment data the CAISO publishes by showing curtailment by specific planning sub-regions as well as curtailment as a percentage of renewable potential. The existing data that shows system wide curtailment on a MWh basis provides little to no value to interconnection customers.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

 EDF-R supports continuing the conversation on LSA/SEIA’s proposal to “Re-stack” LDNUs & RNUs triggered in the interconnection process, allowing later-queued projects w/earlier declare COD and reach FCDS.

EDF-R cautions the implementation of such a procedure without a tightening up of queue management procedure; if interconnection customers can cure material harm to other projects by allowing them to skip ahead of them in line, there would be no remaining cause to deny COD extension requests.  

EDF-R would also like to call attention to a similar program that was previously a part of SPP’s interconnection process. Staring in 2014, Attachment Z2 of the SPP tariff created revenue credits that stemmed from transmission service that could not have been provided “but for” the upgrade, and then upgrade sponsors would receive payments. On April 29, 2020, SPP submitted revisions to its tariff to eliminate these transmission revenue credits as an option for compensation Attachment Z2. SPP’s the Holistic Integrated Tariff Team (HITT)  concluded that the Attachment Z2 approach increased transmission service rates by roughly two percent on average and created additional directly assigned upgrade costs. Unraveling the program has been complicated by technical and legal issues, and California would do well to consider these if it decides to create a model where some interconnection requests effectively “sponsor” others.

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EDF-R appreciates LSA/ SEIA presenting on BESS degradation and encourages the CAISO to develop a procedure proactively to address BESS degradation concerns. This is a problem that will "snowball" quite quicky given the volume of BESS needed to meet near term supply needs. EDF-R can imagine two solution approaches:

Proposal 1

Energy storage customers may request preapproval for their maintenance plans. EDF-R envisions a process where, using the existing modification review framework (including required deposit and technical data), an interconnection customer could request and receive approval for post-maintenance configurations well in advance of the date the maintenance would be performed. For tracking purposes timeline and details of the post-maintenance facility configuration could be codified in the project’s GIA or a separate CAISO form (perhaps like the CAISO’s process for facilities to declare phased implementation[1]).

This proposal has multiple benefits:

• Improvement to cost and timing concerns
  • Interconnection customers receive CAISO results well in advance of critical dates
  • Less modification requests overall reduces costs and administrative burden for the interconnection customer and the CAISO
• Increase transparency regarding the interconnection customers operating characteristics for the CAISO
  • Potentially benefitting the transmission planning process and avoiding chaotic deliverability outcomes soon (explained in detail below)
• CAISO may be able to implement pre-approved maintenance plans without extensive stakeholder effort or tariff changes

Figure 1 Concept for Battery Energy Storage System Maintenance Schedule

Proposal 2

The CAISO adds Battery Energy Storage System Maintenance activities up to a certain level as a change that is allowable without a modification review in Section 6.2.1 of the BPM for Generator Management, “Modifications That Are Approved Without Material Modification Assessment.” It is well understood that acceptable maintenance activities may not be a facility betterment or replacement.  EDF-R proposes that the CAISO outline acceptable criteria under which interconnection customers can perform routine maintenance on non-degrading batteries. While this would be a divergence from the CAISO’s current practices, the treatment is appropriate and consistent with CAISO’s treatment of energy storage elsewhere in the BPM for Generator Management.

• This change approval process provides the CAISO and PTO opportunity to review and approve the technical details
• The cost, timing, and effort in this scenario is appropriately scaled to the potential impact the changes
  • Maintenance changes are insignificant at a macro level since typical degradation is between 2 and 5% annually
  • Modifications under section 6.2.1 are reviewed within 5 business days
• CAISO may be able to implement pre-approved maintenance plans without extensive stakeholder effort or tariff changes

[1] http://www.caiso.com/Documents/PhasedCommercialOperationImplementationPlanTemplate.doc

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

EDF-R appreciates this opportunity to provide comments and suggestions for consideration as the CAISO develops the scope for the Interconnection process enhancements 2021 stakeholder initiative. EDF-R supports many of the reforms proposed during the Oct 19 stakeholder workshop with two notable exceptions:

• EDF-R does not support the CAISO’s proposal to provide interconnection customers a one-time opportunity to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impacts on earlier-queued projects.
• EDF-R does not support CAISO’s suggestion to initiate a new or different method to terminate generation interconnection agreements that have not yet passed the seven (7) year time-in-queue limit.

In addition to giving feedback on proposals in CAISO’s paper and at the Oct 19 workshop, EDF-R also proposes that the CAISO completely restructure its material modification assessment (MMA) process. The process as it exists today is onerous for interconnection customers, the CAISO’s own reports on the process prove that the process has little value, and the CAISO simply will not be able to provide reasonable response times given their already limited staff resources are devoted to the enormous task of reviewing Supercluster 14.

EDF-R is an experienced developer and has submitted dozens of modification requests since the process was formalized in the Interconnection Process Enhancements 2013 stakeholder initiative and memorized in the BPM for Queue Management[1]. In the seven (7) years since the CAISO has rarely denied a modification proposal. In CAISO’s data on the MMA process for 2017, 2018, and 2019 the CAISO reviewed 163 requests for modification. Of those 163 requests, one was denied outright, two were partially denied. The MMA process results in an approved modification 98% of the time.

Despite the fact modifications are approved 98% of the time, it can take 6 months to receive the CAISO’s modification approval letter. All the while development plans are in limbo, as interconnection customers are not assured their modifications will be approved. This timeframe is sure to get worse in the coming years as the CAISO’s already lean staff works to study Supercluster 14.  

EDF-R is not proposing the CAISO eliminate the process altogether. EDF-R acknowledges the CAISO needs the detailed technical data it collects during the modification process. However, it is not clear that the study work being undertaken by the CAISO and PTO are a required control for preventing issues, since 98% of modifications are approved. EDF-R proposes the CAISO shift the process to one where approval is automatic if the interconnection customer presents:

• a complete technical data package (as verified by the CAISO),
• agrees to abide by standard control mechanisms, and
• provides a one-time fee of $5,000 to cover the cost of validating technical information and memorializing the modification in a letter from the CAISO to be endorsed by the interconnection customer

[1] Now known as the BPM for Generator Management.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

 EDF-R supports simplifying the downsizing process.

EDF-R believes that CAISO should enact policy changes to protect interconnection customers from increased costs and in-service date delays caused by an error or omission discovered after the initial and the second postings have passed. In this circumstance these costs should be borne by the Participating Transmission Owner (PTO). This is particularly important if the newly discovered cost is for an interconnection item the interconnection will not receive reimbursement for. Furthermore, EDF-R believes that the PTO should be obligated to identify and fund interim solutions to remedy any delays to the earliest achievable in-service date if the interconnection customer can provide proof of PPA or shortlist for the project. This would create a more equitable responsibility balance in universe of energy contracts:

• LSEs are responsible for RA showings, and pay penalties when they are short
• Interconnection Customers are responsible to perform on their contract, and pay liquidated damages when they fail to perform, and
• PTOs should be obligated to remedy any harm caused by an error or omission discovered after two and a half years of study work

EDF-R supports easy offramps for projects impacted by new costs and/or delayed in-service date after initial posting.

EDF-R suggests that in addition to considering criteria for POI changes during the scoping meeting, the CAISO should improve transmission system data availability and accessibility. If developers had information such as Transmission Plan Deliverability availability, congestion, and the magnitude of upgrades needed to accommodate new supply in a particular area, the CAISO would not see as many speculatory interconnection requests. MISO’s POI Analysis tool is a good example of a high value scalable tool for this purpose. https://giqueue.misoenergy.org/PoiAnalysis/index.html

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

EDF-R suggests that it would be unfair to increase the requirements for interconnection requests (site exclusivity, equipment requirements, etc.) without simultaneously reducing the length of the study process.

• In EDF-R’s experience, landowners are not enthusiastic about extending long term exclusive options and the CAISO’s 2.5 year study process often consumes a large portion of the opportunity window developers have to act on those land options.
• EDF-R also sees requirements on equipment procurement as ill-suited as a queue-reduction technique.
• EDF-R suggests that certain studies should only be performed during Phase II (i.e short circuit, stability)
• EDF-R suggests that the CAISO should review if Appendix DD section 8.6 “Accelerated Phase II Interconnection Study Process” can be expanded to include a larger number of projects, and that if it is clear that interconnection capacity and Transmission Plan Deliverability in an area is sufficient to accommodate all projects in that area requesting it, then the projects should be offered the opportunity to skip Phase II and be grouped for TPD allocation with the next TPD group (I.e. a cluster 19 project that elects to skip Phase II would be grouped for TPD allocation with cluster 18) 
• EDF-R does not support an accelerated first ready process or the CAISO’s proposal for another one-time modification opportunity, it’s unclear what criteria would be used to identify ready projects, nor how the CAISO would ensure performance once the projects received their study results. EDF-R would prefer CAISO focus its resources streamlining its existing processes.
• EDF-R does support the creation of a non-refundable fee that is scaled with interconnection capacity MW to proceed into the Phase I study after the scoping meeting. Supercluster 14 has 14 projects seeking interconnection for 1,000 MW or more, and yet in its entire history no project larger than 800 MW has declared commercial operation. Projects of this size increase the volatility of study results and exacerbate an already bloated queue.  

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

EDF-R does not support a one-time opportunity to allow resources such as storage to be added to existing sites on expedited basis to meet pressing reliability needs despite the potential impacts on earlier-queued projects. CAISO MMA and BTM processes are already sufficient to accommodate such requests. EDF-R encourages CAISO to instead focus any resources that would be spent on a one-time effort to be used to reduce the turn time on MMAs.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

EDF-R support creation of a study process for CAISO as an affected system. EDF-R also supports the notion that network upgrades identified in this process that improve transmission or when resource is set to provide RA in CA should be eligible for reimbursement.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

EDF-R supports and highly encourages increased coordination between the Joint Agencies. On this topic EDF-R notes that if developers had information such as Transmission Plan Deliverability availability, congestion, and the magnitude of upgrades needed to accommodate new supply in a particular area, the CAISO would not see as many speculatory interconnection requests or interconnection requests being proposed in already difficult and saturated areas. MISO’s POI Analysis tool is a good example of a high value scalable tool for this purpose. https://giqueue.misoenergy.org/PoiAnalysis/index.html

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

EDF-R does not support CAISO’s suggestion to initiate a new or different method to terminate generation interconnection agreements that have not yet passed the seven (7) year time-in-queue limit. CAISO already has the ability to hold projects in breach for failure to perform on Appendix B milestones in the project’s executed GIAs. It would be more appropriate for the CAISO to focus its attention on the 83 projects cluster 11 and prior that are already at or beyond their 7 year time-in-queue limit.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

EDF-R is supportive of the topics presented by Gridwell and more specifically the items regarding information sharing that would improve decision making. One example would be to improve the curtailment data the CAISO publishes by showing curtailment by specific planning sub-regions as well as curtailment as a percentage of renewable potential. The existing data that shows system wide curtailment on a MWh basis provides little to no value to interconnection customers.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

 EDF-R supports continuing the conversation on LSA/SEIA’s proposal to “Re-stack” LDNUs & RNUs triggered in the interconnection process, allowing later-queued projects w/earlier declare COD and reach FCDS.

EDF-R cautions the implementation of such a procedure without a tightening up of queue management procedure; if interconnection customers can cure material harm to other projects by allowing them to skip ahead of them in line, there would be no remaining cause to deny COD extension requests.  

EDF-R would also like to call attention to a similar program that was previously a part of SPP’s interconnection process. Staring in 2014, Attachment Z2 of the SPP tariff created revenue credits that stemmed from transmission service that could not have been provided “but for” the upgrade, and then upgrade Sponsors would receive payments. On April 29, 2020, SPP submitted revisions to its tariff to eliminate these transmission revenue credits as an option for compensation Attachment Z2. SPP’s the Holistic Integrated Tariff Team (HITT)  concluded that the Attachment Z2 approach increased transmission service rates by roughly two percent on average and created additional directly assigned upgrade costs. Unraveling the program has been complicated by technical and legal issues, and California would do well to consider these if it decides to create a model where some interconnection requests effectively “sponsor” others.

------

EDF-R appreciates LSA/ SEIA presenting on BESS degradation and encourages the CAISO to develop a procedure proactively to address BESS degradation concerns. EDF-R can imagine two solution approaches:

Proposal 1

Energy storage customers may request preapproval for their maintenance plans. EDF-R envisions a process where, using the existing modification review framework (including required deposit and technical data), an interconnection customer could request and receive approval for post-maintenance configurations well in advance of the date the maintenance would be performed. For tracking purposes timeline and details of the post-maintenance facility configuration could be codified in the project’s GIA or a separate CAISO form (perhaps like the CAISO’s process for facilities to declare phased implementation[1]).

This proposal has multiple benefits:

• Improvement to cost and timing concerns
  • Interconnection customers receive CAISO results well in advance of critical dates
  • Less modification requests overall reduces costs and administrative burden for the interconnection customer and the CAISO
• Increase transparency regarding the interconnection customers operating characteristics for the CAISO
  • Potentially benefitting the transmission planning process and avoiding chaotic deliverability outcomes soon (explained in detail below)
• CAISO may be able to implement pre-approved maintenance plans without extensive stakeholder effort or tariff changes

Figure 1 Concept for Battery Energy Storage System Maintenance Schedule

Proposal 2

The CAISO adds Battery Energy Storage System Maintenance activities up to a certain level as a change that is allowable without a modification review in Section 6.2.1 of the BPM for Generator Management, “Modifications That Are Approved Without Material Modification Assessment.” It is well understood that acceptable maintenance activities may not be a facility betterment or replacement.  EDF-R proposes that the CAISO outline acceptable criteria under which interconnection customers can perform routine maintenance on non-degrading batteries. While this would be a divergence from the CAISO’s current practices, the treatment is appropriate and consistent with CAISO’s treatment of energy storage elsewhere in the BPM for Generator Management.

• This change approval process provides the CAISO and PTO opportunity to review and approve the technical details
• The cost, timing, and effort in this scenario is appropriately scaled to the potential impact the changes
  • Maintenance changes are insignificant at a macro level since typical degradation is between 2 and 5% annually
  • Modifications under section 6.2.1 are reviewed within 5 business days
• CAISO may be able to implement pre-approved maintenance plans without extensive stakeholder effort or tariff changes

[1] http://www.caiso.com/Documents/PhasedCommercialOperationImplementationPlanTemplate.doc

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Golden State Clean Energy (“GSCE”) appreciates the opportunity to submit this comment on the Preliminary Issue Paper for the 2021 Interconnection Process Enhancements initiative. The reoccurring IPE stakeholder process and the California ISO’s responsiveness to an evolving interconnection landscape is a strong part of what makes the ISO’s interconnection process laudable and preferrable to many developers nation-wide.

GSCE provides its position below on the scope and substance of a number of the early-stage proposals provided in the Preliminary Issue Paper. Of those proposals, we highlight a few that we find most important to improving the interconnection process:

• GSCE strongly supports the ISO scoping the topic of reviewing when site exclusivity should be required, and we generally support significantly stronger site exclusivity requirements.
• GSCE strongly supports the ISO scoping the topic of the consideration of a one-time framework to add storage to existing sites on an expedited basis, but we think that the material modification assessment process should be largely sufficient and that instead the opportunity to seek additional deliverability is the bigger issue. We suggest the ISO accept affidavits seeking deliverability this year that are contingent on the approval of a pending MMA to add storage.
• GSCE strongly opposes the scope and substance of allocating deliverability to load serving entities rather than to interconnecting resources.

Site exclusivity timing and requirements

GSCE strongly supports the ISO reviewing when site exclusivity should be required, and we generally support stronger site exclusivity requirements, including the demonstration of site exclusivity. A project should not be able to advance in the study process or qualify for an allocation of deliverability unless it has demonstrated site specific exclusively such as a contractual option to acquire the site; actual ownership of the site location; or a long-term lease, easement or similar instrument.

GSCE supports proof of site exclusivity as a requirement prior to Phase I studies (after interconnection request validation), in line with that required by other ISOs and RTOs, or at the latest before Phase II studies. We are also generally in favor of ending the deposit alternative to site exclusivity. Providing the ability to pay a deposit in lieu of showing site exclusivity offers interconnection customers a low risk means of seeking information from the ISO via an interconnection request, which thus incentivizes these less serious, information-probing interconnection requests that create additional work for the ISO and PTOs in the study process and skew the study results for project developers focused on reaching commercial operation.

In addition to strengthening site exclusivity requirements for studies to progress, the ISO should also consider strengthening it as a requirement for seeking and maintaining deliverability. An interconnection customer should not be able to qualify for deliverability unless it has demonstrated site exclusivity. Site exclusivity is one major hurdle for project development, and it will be increasingly so as we see further land impacts en route to meeting SB 100 in 2045.[1]  With the ISO tightening requirements elsewhere to ensure that only commercially viable projects hold deliverability, site control requirements should also be strengthened as a condition of both qualifying for and retaining deliverability.

With the number of interconnection requests pending in the ISO queue, earlier and stronger site exclusivity requirements seem like a logical adjustment to the ISO’s current practice that may help cull projects that cannot demonstrate this specific and key commercial viability requirement. But GSCE also recognizes that some locationally constrained resources may be more burdened by this requirement than others in a manner that is not indicative of the resource’s commercial viability (e.g., offshore wind). GSCE believes that stronger site control requirements should generally be required, but it could be reasonable for exceptions to exist for constrained resources like offshore wind.

One-time framework to add storage and consideration of the MMA process

GSCE strongly supports the ISO scoping the topic of the consideration of a one-time framework to add storage to existing sites on an expedited basis, but we do not necessarily think a new process is needed for adding storage. Storage can be added with an MMA now, and it is unclear what other process is needed, although the ISO should examine accelerating MMA response times or possibly another batch MMA for storage additions akin to 2019.

Facilitating a process for interconnection customers who are adding storage to seek a deliverability allocation would be more important. Without deliverability the storage additions will not be able to provide resource adequacy and thus will fall short of expectations for relieving the supply constraint. Providing an opportunity for new storage additions to qualify for a deliverability allocation will allow online projects or those in later stages of the cluster study process to contribute to the solving the resource adequacy deficiency in California. 

GSCE proposes that the ISO accept affidavits seeking deliverability this year that are contingent on approval of a pending MMA to add storage, as this is a tangible way to get more RA resources on the grid in the near-term while using existing processes and tariff authority. The ISO could create another batch MMA process that aligns with its affidavit process, much like it did in 2019 in response to changes to variable energy resources’ deliverability assessment methodology. The CAISO tariff does not prevent it from accepting two sets of affidavits, one being the preferred affidavit that is contingent on the MMA to add storage being approved. The ISO would only need to provide a market notice that notifies stakeholders of the deadline to submit an MMA to add storage that can be pointed to in a provisional affidavit seeking deliverability for the storage resource. This deadline would be based on the time the ISO needs to approve the MMAs without holding up the deliverability allocation process.

With the deadline fast approach for projects to submit affidavits to seek additional deliverability, the ISO should consider what it can do within its existing tariff authority to address Governor Newsom’s July Emergency Proclamation and the related RA resource-deliverability needs. Other proposals in the 2021 IPE that address the Emergency Proclamation are worth continued consideration, but they may not have an impact until next year’s deliverability affidavit cycle.

Allocating deliverability to LSEs rather than to resources

GSCE strongly opposes the scope and substance of allocating deliverability to load serving entities rather than to interconnecting resources. We do not see this proposal as solving anything, and instead it will cause needless disruption and uncertainty to interconnection customers. Without knowing that a project has deliverability, the interconnection customer will not be able to make an informed decision about making additional postings and evaluating the economic viability of the project. This proposal would completely upend the existing framework under the CAISO tariff. We see other proposals, like strengthening site control requirements, as more important to queue management.

[1] Clean Air Task Force and Environmental Defense Fund, Building a Zero Carbon California Grid: Moving From Models to an Implementable Plan, Nov. 2, 2021, available at: https://ww2.arb.ca.gov/sites/default/files/2021-11/EDF-sp22-electricity-ws-11-02-21.pdf (presented at the Nov. 2 CARB AB 32 Scoping Plan workshop).

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

Of the topics addressed in section 3.1, GSCE provides the following support or opposition for the scope and specific policy direction of the topics:

1. GSCE supports the ISO scoping the topic of removing the downsizing window and simplifying downsizing requirements.
2. GSCE supports the ISO scoping the topic of study report errors after the second posting is made when the error impacts cost responsibility.
3. GSCE supports the ISO scoping the topic of offering a full-refund withdrawal option when in-service dates are delayed or significant new costs are added after the first or second posting, and we also preliminarily support adoption of such a policy.
   • Allowing projects to withdraw earlier with a lower or no penalty is fairer for interconnection customers when costs above a certain threshold are allocated to the IC or significant project timeline changes occur. A penalty-free withdrawal opportunity within a short window of time after a reassessment adds costs above a certain threshold is consistent with precedent in other ISOs and RTOs.
   • Allowing full refunds of posted interconnection financial security under these circumstances allows projects the opportunity to withdraw rather than linger without a meaningful opportunity to proceed to commercial operation. GSCE believes this will help address the issue of nonviable projects persisting in the ISO queue.
   • Similar benefits are provided related to the freeing of deliverability that is otherwise held by a project that does not plan to continue developing.
4. GSCE supports the ISO scoping the topic of reviewing the tariff criteria for the ability to change a project’s site or POI during the interconnection request validation process, and we generally support stronger site exclusivity and POI selection requirements.
   • GSCE agrees with the ISO’s statements at the stakeholder meeting that it expects projects to be further along in their project development when submitting an interconnection request than still sorting out the project location and POI.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

Of the topics addressed in section 3.2, GSCE provides the following support or opposition for the scope and specific policy direction of the topics:

1. GSCE strongly supports the ISO scoping the topic of reviewing when site exclusivity documentation should be required, and we generally support stronger site exclusivity requirements for all clusters, not just QC14.
   • GSCE supports proof of site exclusivity as a requirement prior to Phase I studies or at the latest before Phase II studies, because the ability to pay a deposit in lieu of showing site control provides interconnection customers a low risk means of seeking information from the ISO via an interconnection request.
   • In addition to strengthening site exclusivity requirements for studies to progress, a project should be required to demonstrate site exclusivity to qualify for deliverability. A project should not be able to rely on a deposit to obtain and retain a deliverability.
   • We also suggest the ISO consider stronger notions of site exclusivity and what is required to demonstrate site exclusivity, such as a contractual option to acquire the site; actual ownership of the site location; or a long-term lease, easement or similar instrument.
2. GSCE opposes the ISO scoping the topic of requirements for a commitment for various key equipment required for the project to timely move forward, and GSCE opposes the policy direction of this proposal.
   • Supply chain issues have recently arisen around the globe, and this fast-developing phenomena could unnecessarily prevent some projects from being studied that are otherwise commercially viable.
3. GSCE generally supports the ISO scoping the topic of an accelerated process for projects that could go to commercial operation quickly, i.e., “ready” projects, and we could support this proposal depending on the readiness criteria and if it diversifies existing study processes by being more focused on projects intended to support state policy.[1]
   • To better assess the overall intent of a “ready” study process, it would be helpful for the ISO and stakeholders to provide a comparative analysis of existing study processes, how quickly projects can come online under these processes, and what the shortfalls are of each process that may make it undesirable to take advantage of despite the timeline provided. Otherwise, it is unclear to GSCE what new process is needed to accelerate “ready” projects when there is already a Fast Track and Independent Study Process.
     • More insight into the shortfalls of the Fast Track and Independent Study Process will make it clearer to all stakeholders what gaps exist and what could be improved in the current processes without creating a new process.
     • Focusing the discussion on the shortfalls of existing accelerated study processes and the intent of a “ready” study process also helps clarify the type of eligibility criteria that should be considered if a “ready” process is adopted.
     • GSCE is concerned that certain readiness eligibility criteria for a new “ready” process could create a process that benefits some that already have a viable development path forward while causing delays for other projects in the queue and not clearly benefiting other long-term needs like state policy.
   • We do, however, have a general concern over the state’s ability to timely meet its SB 100 policy goals, and we therefore find it reasonable to develop a new accelerated study process that is more policy oriented.[2]
   • As an initial suggestion, GSCE believes that one way to look at an accelerated study process of “ready” projects that furthers state policy is to link the notion of a “ready” study process to a location-specific study process focused on least-regrets policy resource zones.
     • Given our locational-focused proposal, we think one readiness criterion should be site exclusivity, as that has a clear nexus to the overall policy intent of this proposal and it speaks to the viability of a project seeking to interconnect under this “ready” study process.
4. GSCE supports the ISO scoping the topic of technology-specific and location-specific study requirements and processes, but we suggest this proposal be tied to the topic of “ready” projects and that the locational consideration be broadened to align more fully with state policy and long-term planning locational considerations such as the 20-year transmission outlook.
   • Offshore wind is one resource type being considered in context of this issue, which GSCE supports, but we see parallels between the focus on offshore wind development zones and other policy resource zones, such as the least-regrets solar zones in the Central Valley that were highlighted in the CEC’s SB 100 report resource mapping exercise that informed the 20-year transmission outlook.
     • A number of resource zones involve a major build-out to meet the state’s decarbonization goals and are in areas that will require significant new transmission and long lead-time development. This makes it reasonable to target certain geographic locations and to develop a “ready” study process for certain resources.
     • There is also a need to consider the land impacts of all this development and ensure decarbonization policy aligns with other state policies that impact land use (e.g., SGMA, preferring environmentally disturbed areas like drainage impaired agricultural lands). The amount of solar coming online in California is so significant that we must start recognizing its potential land constraints.
   • Sufficiently broadening the technology and location considerations in this IPE will better ensure the 2021 IPE is developing a durable interconnection framework that will allow California to meet its policy goals over the next few decades.
     • Elsewhere in the Preliminary Issue Paper, the ISO has sought to manage misalignment with resource portfolios being studied in the TPP and procurement activities. We appreciate this concern, but there are many questions about the IRP (e.g., study horizon) and its control over TPP studies. Ultimately, the goal is to meet SB 100 and its 2045 deadline, and all processes must have an eye towards that goal. Thus, the 20-year outlook seems better to align the interconnection processes with as the 20-year outlook is more focused on longer-term needs and takes a more zonal approach to resource development.
     • Designated renewable energy or policy resource zones that have a well-defined history of environmental and land use planning support should be promoted from interconnection to transmission planning.
     • The ISO may not be able to affect procurement activities, but it can create processes that promote development that is smart from the start, which should then feed into project economics and procurement decisions. 
   • In addition, this locational consideration can be tied to other proposals in this initiative. We see the possibility for the ISO to take the desire of some stakeholders to provide more interconnection information upfront and pair that with a study process for “ready” projects that aims at policy resource zones (e.g., some form of a pre-study process for the resource that aligns with each policy zones).

GSCE would also note that although these topics are raised in the context of Cluster 14 and earlier clusters, some of the proposals related to these topics may not be able to be implemented in this timeframe. However, where there is the possibility to enhance the interconnection process, there is value to refining and implementing these proposals to apply to future clusters.

[1] See Cal. Energy Comm’n and Cal. Pub. Util. Comm’n, Senate Bill 100 Implementation, at 10-11, Nov. 2, 2021, available at: https://ww2.arb.ca.gov/sites/default/files/2021-11/SB100-CEC-CPUC-sp22-electricity-ws-11-02-21.pdf (This presentation from the Nov. 2 CARB AB 32 Scoping Plan workshop raises a number of issues and provides high-level recommendations that GSCE believes are addressed by our proposal relating to a policy-driven “ready” study process that is linked with locational considerations and long-term planning efforts.).

[2] Clean Air Task Force and Environmental Defense Fund, Building a Zero Carbon California Grid: Moving From Models to an Implementable Plan, at 4, 9-10, Nov. 2, 2021; Cal. Energy Comm’n and Cal. Pub. Util. Comm’n, Senate Bill 100 Implementation, at 4, Nov. 2, 2021 (“Resource buildout needs to occur at unprecedented pace and scale.”).

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

The only topic in section 3.3 is the consideration of a one-time framework to add storage to existing sites on an expedited basis. GSCE supports this topic being in scope, but we do not see the need for a new process for adding storage. Rather, addressing deliverability for storage additions is more of a concern and something that the ISO should address in response to tight supply conditions.

• Storage can be added with an MMA now, and it is unclear what other process is needed, although the ISO should examine accelerating MMA response times or possibly another batch MMA for storage additions akin to 2019.
• The bigger issue is providing an opportunity for additional deliverability to be requested and allocated to new storage, as this will allow online projects or those in later stages of the cluster study process to contribute to the solving the resource adequacy deficiency in California.  
• GSCE proposes that the ISO accept affidavits seeking TPD this year that are contingent on approval of a pending MMA to add storage, as this is a tangible way to get more RA resources on the grid in the near-term while using existing processes and tariff authority. The ISO could create another batch MMA process that aligns with its affidavit process, much like it did in 2019.
• Lastly, GSCE seeks clarification that the ISO intends to hold a deliverability affidavit cycle in 2022 where the ISO will allow eligible projects to seek an allocation of deliverability (we are seeking this clarification in light of the impact of the delays due to QC14).  Projects that would qualify for TPD allocation groups 4-7 should be able to seek deliverability in the fall of 2022.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

Of the topics addressed in section 4.1, GSCE provides the following support:

• GSCE supports CAISO scoping the topic of itself as an affected system, including determining the base case and how required upgrades are paid for.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

Of the topics addressed in section 4.2, GSCE provides the following support or opposition for the scope and specific policy direction of the topics:

1. GSCE supports the ISO scoping the topic of incentives for LSEs to procure generation at locations where transmission capacity has been built or approved, but GSCE has very strong concerns over the IRP-TPP study horizon and resource portfolios studied, and thus we oppose the proposal given its nexus to portfolios that have no clear link to where development is actually occurring or will likely occur.
   • It is unclear how the ISO could incentivize procurement within its jurisdictional authority, and market forces should render this incentive structure unnecessary if new transmission development sufficiently aligns with the state’s long-term needs. To the extent this issue is already proving problematic, it may suggest misalignment with the IRP-TPP resource portfolio study process.
     • The IRP has failed to promote development of clean energy resources in specific areas that aligns with state land use policies.
   • Looking towards the 20-year transmission outlook for resource locations to better incentivize may be more appropriate and fruitful given its longer-term, zonal view of future resource needs.
     • Also, no new transmission development will result from the 20-year outlook, meaning there is not an existing advantage to developing these areas that the ISO should be promoting development in.
2. GSCE strongly opposes the scope and substance of allocating deliverability to LSEs rather than to interconnecting resources.
   • We do not see this proposal as solving anything; it will instead cause needless disruption and uncertainty to interconnection customers.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

Please see our above comments.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

Please see our above comments.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

No comment at this time.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

No comment at this time.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

No comment at this time.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

No additional comments at this time.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Goldman Sachs Renewable Power, LLC (“GSRP”), a unit of Goldman Sachs Asset Management, is submitting comments in support of a concept in the Preliminary Issue Paper (Paper), Section 3.3 – specifically, allowing existing projects to add resources “such as storage” on an expedited basis to meet pressing reliability needs, despite potential impacts on earlier-queued projects.

Specifically, GSRP supports a one-time framework to allow new storage capacity to be added to existing sites on an expedited basis.  The details are described under our response to Question #4 below.

However, this approach requires other elements to be successful, and GSRP is concerned that separate CAISO consideration of the numerous proposed individual topics suggested for this initiative could fail to consider the synergies from combining them into integrated proposals such as this one.  For example, this proposal requires:

• An accelerated study process based on resource readiness (Paper, Section 3.2):  Possible new accelerated process for projects demonstrating advanced readiness to start operations before other projects. Includes readiness criteria, study process, & consequences for later project-caused delays.

• Transmission Plan Deliverability (TPD) allocation favoring additions to existing (operating or earlier-queued) projects (LSA/SEIA proposal): Recognizes that adding capacity sharing Interconnection Facilities (IFs) and Interconnection Reliability Network Upgrades (IRNUs) can be faster, more cost-effective, and less risky.

In addition, if the CAISO wishes to avoid harm to earlier-queued projects (which may already have contractual and other commitments), the CAISO should coordinate this initiative with consideration in the Transmission Planning Process (TPP) of the cost-effective deliverability-increase upgrades CAISO listed in the Day 2 presentation at the September stakeholder meetings in that process.

Generally, GSRP supports a more combined and integrated approach focused on feasible solutions – like this one – that will help the state meets its greenhouse-gas (GHG) and other emission-reduction goals while enhancing system reliability.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

In Section 3.3 of the Paper, the CAISO asks “Whether projects should be allowed to add resources “such as storage” on an expedited basis to meet pressing reliability needs, despite potential impacts on earlier-queued projects.”  GSRP’s answer is yes – the current and future supply situation in California justifies expedited actions in support of capacity additions that can be studied, contracted, and deployed on an expedited basis. However, mitigating actions, which are discussed further below, are recommended to limit the impact on earlier-queued projects.

GSRP has several existing solar sites, with operating projects, that could be retrofitted with 93 MW/372 MWh of storage capacity that could reach COD in approximately 2-3 years, if cluster-study timelines were not a significant barrier.  Other developers presumably have other sites that could deploy storage additions within that timeframe. 

This proposal would utilize existing Interconnection Service Capacity, IFs (both Interconnection Customer and PTO), and IRNUs.  This will allow for faster construction, lower costs, and less risk, since the facilities needed to accommodate operation of the new capacity are already in place.

The success of this approach requires several other elements, as indicated in our response to #1 above.  Specifically:

• The study process must be expedited.  The normal pre-Cluster 14 process of 2+ years clearly would not allow for construction and Commercial Operation of these capacity additions in the time required. 

• This capacity must receive TPD allocations.  Addition of storage through the Material Modification Assessment (MMA) process can be accomplished, but that process does not allow for additional TPD allocations, and there is no commercial procurement market or CPUC directive to support Energy Only storage additions. 

This second point raises the issue of impacts on earlier-queued projects.  This may not be a problem in the increasingly few areas where TPD is still available; in those areas, this approach would require preferential allocations of the remaining TPD to qualifying project additions.  However, in areas where no more TPD remains, TPD re-allocation from earlier-queued projects to the new capacity additions could be required. 

As indicated above, GSRP recognizes that these projects may have invested significant resources into project development, possibly including contractual commitments for equipment purchases and/or sales to off-takers.  Mitigation of these impacts would likely require CAISO adoption of the approach it has proposed in the TPP, i.e., consideration of upgrades beyond those triggered by the CPUC “base” portfolio that could provide considerable additional TPD within a reasonable timeframe.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

GLW responds to item 5 below regarding the CAISO’s reconsidering of the consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

GLW strongly encourages the CAISO to re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the PTO owning the facilities. GLW is aware of the large interest from renewable project developers for interconnection to the CAISO grid in the GLW/VEA footprint. GLW supports the CAISO’s reconsidering this policy to reduce barriers to efficient interconnections that would reduce costs for California LSEs and support California’s renewable goals. GLW looks forward to working with the CAISO and stakeholders on this issue.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Q CELLS has provided feedback, comments, and recommendations for issues listed and described in the 2021 Interconnection Process Enhancements Preliminary Issue Paper. 

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Hanwha Q Cells USA is located in Irvine, CA.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

1. Removing downsizing window and simplifying downsizing request requirements
   1. Q CELLS supports expanding the downsizing window.
2. Process for changes to network upgrade requirements after the second Interconnection Financial Security (IFS) posting
   1. No issues or comments
3. Withdrawal option for projects impacted by new costs and/or delayed in-service date (ISD) after initial posting
   1. Q CELLS supports withdrawal options for projects impacted by new costs and/or delayed in-service dates.
4. Clarify definition of Reliability Network Upgrade (RNU)
   1. Q Cells has no issues or comments regarding clarifications to RNU definitions.
5. Transferring Participating Transmission Owner (PTO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue
   1. Q CELLS supports this for enhanced communication through establishing a formal procedure that results in clearly stated party responsibilities to reduce confusion. Q Cells looks forward to reviewing this proposal.
6. Changing Sites and POIs During IR Validation
   1. Q CELLS is looking forward to reviewing this proposal. Q CELLS is concerned about too much restriction (pending the proposal details) and is seeking additional clarity on the subject. 

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

1. When should site exclusivity documentation be required?
   1. Q CELLS does not support changes to this section of the tariff. Q CELLS supports the current rules that site exclusivity is only required at LGIA.  The in-lieu deposits should also not change since the amounts in the current guidelines are reasonable and effective.
2. Should equipment requirements be introduced
   1. Q CELLS does not support the introduction of equipment requirements. Further, Q CELLS firmly believes this is not a reasonable modification since equipment selection often changes throughout the development process as costs change and as project details develop.  Lastly, Q CELLS does not support deposits in lieu of equipment requirements.
3. Should an accelerated process for "Ready" projects be considered
   1. Q CELLS generally supports the idea of projects that meet certain criteria being given quicker operation times. However, Q CELLS believes the criteria is important and looks forward to seeing a draft proposal of criteria.
4. Would different requirements for different technologies to advance in the interconnection process be appropriate? Between location-specific resources versus more location-flexible
   1. Q CELLS supports BESS having different requirements that would lead to LGIA faster, especially for location-specific generators.  Q Cells sees how allowing non-location specific resources that have shorter development timelines can help achieve 100% carbon free by 2045 more efficiently.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

1. Should a one-time framework be adopted to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impacts on earlier-queued projects, to meet pressing reliability needs
   1. Q CELLS is open to exploring this idea further.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

1. Should higher fees, deposits, or other criteria be required for submitting an IR
   1. Q CELLS does not object to higher fees or deposits for entrance to IR submission.  However, the cost should not be unattainable and Q CELLS supports staggering of fees as the process moves along.  Q CELLS also suggests a reasonably low application fee, with more money required after scoping but before further studies.
2. Streamline interconnection studies
   1. Q CELLS appreciates this question and would like to recommend increase resources/external consulting resources to manage interconnection workload so that interconnection studies are aligned with timelines outlined in the tariff.
3. Policy for CAISO as an Affected System – how is the base case determined and how are the required upgrades paid for
   1. Q CELLS fully supports memorializing specific procedures and base cases for affected systems. Furthermore, Affected Systems should be reimbursed as they are benefiting rate payers and other grid users in the affected region. The timelines for repayment should be shorter than a one-time cash payment at the end of 20 years per FERC rulings and should be provided as an option in a form other than Transmission Service Credits.
   2. Q CELLS would like CAISO to mediate with affected parties to find proactive solutions when affected system issues arise.
4. Should the CAISO re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the PTO owning the facilities
   1. Q CELLS generally supports pushing costs regionally so that local customers are not burdened, and communities do not push back on projects due to high local costs. Further, Q CELLS believes that interconnection customers should receive a fair treatment from a cost reimbursement standpoint if the generation addition provides grid benefits to ratepayers outside the local area of the PTO.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

1. Should there be incentives for load serving entities to procure generation projects at locations where transmission capacity has been built/approved based on the California Public Utilities Commission (CPUC) portfolios
   1. Q CELLS has no comment.
2. Should Transmission Plan Deliverability (TPD) Allocation process revisions be considered?
   1. Q CELLS has no comment.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

1. How can the interconnection process and incoming applications better align with procurement interest?
   1. Q CELLS believes the focus should be added efficiency to help achieve CA at 100% carbon free by 2045.
2. How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?
   1. Generation Interconnection can be a tool for grid reliability as CA is working to be carbon free by 2045.
3. Should interconnection application requirements differ for resources that are location constrained, versus resources like standalone batteries that can be located elsewhere on the grid?
   1. Please see Q CELLS response to #10a above.
4. Should a solicitation model be considered for some key locations and constraints not addressed in portfolio development, where commercial interest is the primary driver?
   1. Q CELLS would be open to understanding this topic further.
5. While the tariff currently allows a project to achieve its COD within seven (7) years if a project cannot prove that it is actually moving forward to permitting and construction, should the CAISO have the ability to terminate the GIA earlier than the seven-year period?
   1. Q CELLS recommends 5 years.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

Q CELLS has no additional comments at this time. Please see above for comments, organized by section.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

Q CELLS has no comment at this time.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

Q CELLS has no comment at this time.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

Q CELLS has no comment at this time.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Q CELLS has no comment at this time.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

There are several easy queue management and other processes that CAISO can implement in the near-term that will significantly improve the GIDAP process with the resulting benefits of a shorter interconnection timeline, a less resource intensive process, better planning information, and lower costs.  These include institiuting project viability based prioritization tiers, increasing transparency, and increasing study/application fees on the margin.  Given the long-standing policy interest in distributed resources (including BTM, FTM and micro-grids) CAISO should take steps to level the playing field for and prioritize DG in the interconnection process.  The current procedure for revisiting GIDAP process improvement every few years should be replaced with a dynamic and continual improvement process.  Finally, given the urgency of the problem CAISO should accelerate the implementation of improvements.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

These incremental adjustments are fine.  However, there is significant concern that CAISO's approach does not addressing the fundamental issue that has arisen since 2018.  California and the nation are in a period of urgent and rapid transition to renewable energy on a tight timeline.  We need to interconnect large volumes of renewable energy and storage resources over the next 10 years. The current GIDAP process is not in synch with this reality.  The predictable rapid increase in interconnection applications over the past 2 cycles resulted in a significant delay in the process to interconnect resources, frustrating all parties.  The primary focus of the enhancement process needs to address how CAISO can improve and shorten the process to interconnect resources to reach overarching policy goals.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

Our perspective is that the priority of the enhancement process needs to be fundamental reform of the process to put it in synch in an environment where large volumes of applications should be expected over the next 10 years given overarching renewable energy policy and targets.  The "supercluster" is not a one time anomaly rather a predictible expectation of the future.  The process needs to be changed to be able to process large volumes of applications within historic timeframes with a goal of actually shortening timelines rather than extending them.  If some or all of the following recommendations can be implemented as a part of Cluster 14, all the better:

• Project Viability Based Prioritization Tiers: an easy solution is to establish tiers based on project viability and other metrics.  For example, projects with site exclusivity should be ranked higher priority than projects proposing deposit in lieu of site exclusivity, projects that have permits or have started permitting process should be ranked higher than those that have not, near-term projects higher than longer term projects, etc.  Other prioritization metrics could be projects with locational benefits, distribution level projects, projects within approved renewable energy land use zones, and those in areas of lesser transmission constraints.  In a given cluster, CAISO would process as many application tiers as feasible to maintain historic process timeline.  In addition, CAISO should consider a shorter process for the highest priority projects.  Lower tier projects could be processed on a longer or delayed timeline.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

Again, our position is that fundamental change is necessary.  High volumes are already and will be the norm over the next 10 years.  One-time solutions do not address the challenge.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

The proposed bifurcation of near- and longer-term improvements and timeline for implementation does not align with the urgency of the problem in relation to the bigger picture goal of rapid transition to renewable energy.  A comprehensive package of improvements should be implemented as soon as possible:

Recommended Process Improvement Measures

• Project Viability Based Prioritization Tiers: an easy solution is to establish tiers based on project viability and other metrics.  For example, projects with site exclusivity should be ranked higher priority than projects proposing deposit in lieu of site exclusivity, projects that have permits or have started permitting process should be ranked higher than those that have not, near-term projects higher than longer term projects, etc.  Other prioritization metrics could be projects with locational benefits, distribution level projects, projects within approved renewable energy land use zones, and those in areas of lesser transmission constraints.  In a given cluster, CAISO would process as many application tiers as feasible to maintain historic process timeline.  In addition, CAISO should consider a shorter process for the highest priority projects.  Lower tier projects could be processed on a longer or delayed timeline.
• Transparency: as Gridwell noted in its presentation, lack of transparency contributes to a bloated queue, waste of resources, and bad planning information as developers hedge bets with multiple applications.  Online distribution system capacity (ICA) maps have been available now for many years in California and other states with good results.  Data and infrastructure security issues have been addressed.  CAISO should implement similar online maps for the transmission system and other transparency measures.  The benefits:
• Streamlining: a reduction of applications as developers will focus efforts on where projects are viable.  Fewer, more viable applications yield a higher quality and more manageable queue.
• Resource Efficiency: transparency means developers need not hire limited transmission engineering resources to obtain/interpret information, freeing these resources up to focus on transmission planning and implementation.
• Lower Costs: increasing the COD MW/application MW ratio decreases developer transaction costs, leading to lower project and energy costs to consumers.
• Increase Marginal Study Fees: the current fixed application/study fee structure incentivizes behavior that exacerbates the queue management problem.  Since application costs are fixed per project, there is incentive for developers to flood the market with applications and to oversize projects to corner available capacity.  Application/study fees should be structured to vary based on MW and to increase on the margin, that is at an increasing rate per MW as MW increase, both for individual projects and at an aggregated level per individual developer. 

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

These issues can be incorporated as factors in the prioritization tiers approach outlined in the answer to question 5.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

The recommended improvements outlined in response to question 5 - prioritization tiers based on project viability and other metrics, increased transparency, and increased marginal application/study fees.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

In addition to the recommendations outlined in the response to question 5, there are two additional recommendations:

Level the Playing Field for and Prioritize Distributed Resources: California has long had a policy interest in prioritizing distributed generation – both behind-the-meter and front-of-meter projects - as a preferred resource.  Resource adequacy is now typically a must have to make FTM DG projects and micro-grids financially viable.  The basic attributes of DG projects make them high viability: site exclusivity (as required by WDT), locational benefits, ease of permitting, and shorter implementation timelines.  Yet the current GIDAP process is stacked against distributed resources.  Per MW costs for utility WDT interconnection study plus CAISO FCDS study is prohibitively expensive and higher than for transmission level projects.  While CAISO does not control the WDT interconnection study fee structure, it should reduce the FCDS study fee for DG projects to reduce barriers to these preferred resources.  As a preferred resource with high viability attributes, DG projects should automatically be place in the highest prioritization tier.  As currently configured, the Deliverability for Distributed Generation (DGD) process, while helpful in the past when deliverability was a “nice to have” feature for DG projects, is not useful for projects that require deliverability because it provides no certainty and recent allocation has been minimal.

Establish Metrics and a Continual Improvement Process: The current procedure for revisiting GIDAP process improvement every few years should be replaced with a dynamic and continual improvement process.  CAISO should establish and make public key GIDAP performance metrics such as COD MW / Application MW and time to complete subprocesses, establish improvement goals, develop and implement improvement procedures, and track and make public its progress towards its targets.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

We agree that increased transparency is a key part of the improvement process as outlined in detail in the response to question 5.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Overview

LSA/SEIA appreciate this opportunity to comment on the CAISO’s Preliminary Issue Paper (Paper) in this initiative, comment on ideas suggested by others, and further explain their suggested additional ideas for the initiative scope.  LSA/SEIA support many of the process improvements suggested by the CAISO and others, as well as its own suggestions, and that support is reflected in our comments below.

However, LSA/SEIA are uncertain about some concepts in the Paper that would “expedite” certain “ready” projects or resource types.  All pre-Cluster 14 projects have completed Interconnection Studies or will soon do so, and most have been through at least one Transmission Plan Deliverability (TPD) allocation cycle.  Deliverability-retention rules require Cluster 4 projects with TPD awards to have or soon acquire Power Purchase Agreements (PPAs), or move expeditiously toward construction and development regardless (Group 3).

Thus, applying “expedited” treatment to projects in areas where TPD has run out could mean taking TPD from projects that already have PPAs and/or are otherwise moving forward in the development process.  In other areas where there are RNU constraints (e.g., circuit-breaker replacements), “expedited” treatment could mean delaying project Commercial Operation Dates (CODs) so other projects could move ahead. 

Such enormous disruption of projects under development must clear an extremely high threshold and include financial and other compensation.  That’s why LSA/SEIA topic suggestions include more-efficient use of the existing TPD that has already been awarded and not removing earlier TPD awards.  (However, LSA/SEIA do not object to consideration of viability reviews of projects without retention requirements, including those awarded TPD on the basis of Balance-Sheet Financing (BSF) affidavits.)

This initiative should consider revising the Interconnection Study and TPD Allocation processes.  However, that will have only a limited impact, i.e., apply to only to Cluster 14 (potentially) and to new projects entering the queue (or capacity added through Material Modification Assessment (MMA) requests), and it will not improve the situation in areas where TPD has simply run out.

Instead, in addition to the changes considered in this initiative, a complete plan to improve the current situation must include other actions, including:

• Helping projects now in the queue move toward completion.  Multiple transmission-construction delays (apparent in comparing the In-Service Dates in successive annual Transmission Plans), combined with late-discovered upgrade requirements (e.g., PG&E and SDG&E circuit-breaker replacements) have combined to add years to some project Commercial Operation Dates (CODs), seriously impairing project viability in the process. 

Other projects are delayed significantly by slow CAISO and PTO administrative procedures, e.g.:

• Slow processing of Material Modification Assessment (MMA) requests, where CAISO and PTO approvals can take months beyond the 45-90 Calendar Days (CDs) provided in the tariff;

• Slow turnaround for Generator Interconnection Agreement (GIA) negotiations, which can take up to a year; and

• Slow post-GIA execution PTO work initiation, where assembling and deploying project teams should take 4-6 months but often take longer, even where the developer has issued a Notice to Proceed.

The CAISO and PTOs should expect the current high level of work to continue, especially given ambitious state greenhouse-gas policies and the consequent LSE procurement directives.  We know the CAISO found only limited outside help when Cluster 14 materialized, but the CAISO and PTOs need long-term resource-procurement strategies of their own (hiring, longer-term outside arrangements) to manage this elevated work level.  The many projects entering and continuing in the queue provide the funding needed for these activities – or, if that is not enough to cover these activities, that information should be considered in this initiative.

• Approving low-regrets, cost-effective transmission upgrades in the TPP to add deliverability expeditiously in areas with high commercial interest.  CPUC portfolios limited to the bare minimum amount of deliverable resources needed to meet reliability requirements are based on models that, at best, reflect educated guesses about which areas are best-suited for resource development.  Persistent resource Interconnection Requests (IRs) submitted in other areas, along with Load-Serving Entity PPA contracting with resources in those other areas even with the disadvantages to such resources under the Least-Cost, Best Fit (LCBF) approach, are indications that additional upgrades are cost-effective and needed in areas not selected in the current modeling efforts.

The CAISO itself said at the last TPP meeting that it is planning to look beyond the CPUC portfolios in this cycle at possible approval of such upgrades in this cycle.  LSA/SEIA strongly support that proposal and believe it will greatly facilitate development of highly viable additional resources in commercially attractive locations.

Comments on this initiative

Fundamentally, LSA/SEIA:

• Are open to considering interconnection-process changes that could allow resources demonstrating advanced “readiness” or needed to maintain system reliability to move ahead more quickly than others.  However, the justness and reasonableness of such an approach strongly depends on: (1) The criteria for such treatment, e.g., clear demonstration of legitimate reliability need; (2) the meaning of “move ahead” (see above); and (3) the impact on other projects – specifically, as noted below, these actions should not impair progress of other projects already under development. 

• Strongly support changing the current treatment of CODs, Full Commercial Deliverability Status (FCDS), and Interim Deliverability Status (IDS), in Interconnection Studies and GIAs.  As discussed further in Q11 below, not all projects in a study cluster require the RNUs triggered by the whole cluster together in order to reach COD, and/or require the DNUs triggered by the whole cluster together to achieve FCDS; however, the presence of such NUs in the Interconnection Studies will delay COD and/or FCDS for all projects in the cluster.  These impacts are particularly strong for upgrades triggered by smaller overloads, since most projects in the cluster can probably be accommodated with the upgrades.

LSA/SEIA strongly support CAISO provision of additional information, and differentiation of projects within study clusters.  For example, Interconnection Studies should contain information about how much of the cluster can reach their requested CODs without the RNUs triggered by the cluster as a whole.  This initiative should develop procedures that would allow achievement of key milestones for some projects without completion of all the upgrades triggered by the entire cluster.

Similarly, the CAISO should provide increased information about IDS, starting in the Phase II Study and updated annually, to support developer decisions regarding project CODs and project contracting.

• Strongly support CAISO provision of additional information.  CAISO has significant locational information that would be extremely useful to resource developers and LSEs, but much of that additional information is hard or impossible to find.  Gridwell’s suggestions are on point and should be considered in this initiative.

• Do not agree with changes to the interconnection process that would:

• Harm resources already under development.  Receipt and retention of TPD allocations under the GIDAP already require some form of viability demonstration – an executed PPA (Groups 1 & 4), shortlist position or active negotiations for a PPA and an executed PPA required the following year (Groups 2 & 5), are otherwise moving forward (Group 3) or have already been built (Groups 6 & 7). 

In particular, projects that have made serious commitments (PPAs, land acquisition, permitting, equipment procurement) should not be faced with COD delays or TPD allocation removal, which would seriously impair their project viability or progress, in the absence of serious and verified legitimate system reliability threats.

• Favor some technologies over others.   The CAISO tariff and associated rules are (to the extent reasonably possible) technology-neutral and based on open-access principles.  Set-asides and other special treatment not justified by reliability needs distorts efficient resource development and market operation.

• Go beyond appropriate CAISO authority.  Energy procurement decisions are made by state policy-makers and Local Regulatory Authorities (LRAs) like the CPUC.  Aside from the straightforward provision of factual information (e.g., about interconnection capacity and/or deliverability availability), the CAISO should not take actions on its own initiative to influence the location or resource mix procured by LSEs.  If LSEs are procuring resources through the “Least-Cost, Best Fit” (LCBF) approach in areas needing upgrades, then the CAISO should approve additional transmission to accommodate those choices, not incent or force development in other areas.

LSA/SEIA’s comments on the topics suggested by the CAISO and others, and their additional suggestions for inclusion in the scope of this initiative, are consistent with these principles. 

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

Downsizing/simplification:  Remove downsizing window & simplify downsizing request requirements.  This would allow requests to be submitted at any time (to simplify tariff language), though they would still all be analyzed in the next annual Reassessment.  Consider other simplifications to the application process.  

Comments:  While simplifying the application process would be welcome, the timing change would not be very helpful to developers if the CAISO will still analyze requests only once a year.  However, LSA/SEIA support inclusion of this issue in-scope if it includes the expansion discussed at the workshop, i.e., defining situations where downsizing requests could be approved: (1) without a study; or (2) with an expedited process or study.

NU cost increases from errors/omissions after initial and/or second security postings:  Clarify cost-increase responsibility in this situation, since the tariff doesn’t address that issue (especially after 2nd posting).

Comments:  LSA/SEIA support the inclusion of this issue in scope, in the expanded form recommended by SCE below.  CAISO should also explain why SDG&E’s recent identification of 24 new circuit breakers as needed for (and assigned to) Cluster 12 isn’t a “significant error/omission” requiring re-issuance for example, why the error was corrected in a Reassessment and not as a “substantial error or omission” pursuant to GIDAP Section 6.88 (which would require issuance of a Phase II Study Addendum and re-setting financial-security posting dates).

Withdrawal option for projects with new costs or later CODs after initial/second postings:  Projects could either accept changes & move forward or withdraw w/refund of all IFS & any unused study deposit       

Comments:  This situation could result from “significant errors or omissions” (GIDAP 6.88) or Reassessment Reports.  LSA-SEIA support project ability to either: (1) accept significant cost or COD changes; or (2) withdraw with full security release and refund of unused Study Deposit money.

Clarify RNU definition:  Clarify that RNUs identified in deliverability studies (“deliverability-related RNU”) count toward the RNU reimbursement cap.

Comments:  LSA/SEIA oppose this “clarification,” i.e., the scope of this item should be redefined to be whether such “deliverability-related RNUs” should count against the RNU reimbursement cap.  The CAISO seems to have decided this issue without even discussing it in a stakeholder process or otherwise. 

LSA/SEIA believe that these upgrades are more properly termed “reliability-related DNUs” instead of “deliverability-related RNUs”  They should be treated like DNUs for reimbursement purposes, regardless of what they are called, because they would only be needed in association with DNUs and are not needed without the DNUs.

Moving PTO WDAT Projects into CAISO Queue, & vice versa:  Clarify how IRs would be transferred between WDAT & CAISO queues when the request is submitted to the wrong entity.   

Comments:  LSA/SEIA agree there should be procedures for early identification of these application errors, and transfer to the correct jurisdiction.  However, the best way to help ensure that these errors don’t occur in the first place is to provide more-easily accessible data about which parts of the system are under CAISO/WDAT interconnection jurisdiction.

Changing Sites & POIs During IR Validation or after Scoping Meeting:  Develop specific tariff criteria for changing proposed project sites & POIs during these times.  Includes: (1) POI changes when originally requested POI is feasible; and (2) site location changes based on infeasible POI. Need to avoid changes without cause, to far-off locations elsewhere in the system.     

Comment:  LSA/SEIA do not oppose reasonable criteria. 

POI changes should always be allowed if the original location is infeasible, at least to the nearest feasible location without obvious cost or other disadvantages.  Reasonable deadlines can be set for submitting updated Interconnect Request data.

However, site-definition flexibility during and after IR submittal (e.g., through the MMA process) is needed due to typical land-acquisition needs, especially for large projects.  The CAISO should allow site-definition changes throughout the project study process (and afterward, if needed) as long as the Point of Interconnection (substation and voltage level) stays the same.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

Site Exclusivity requirement:  Whether it should be required (no in-lieu deposit) for IR submittal or Phase II.   

Comments:  LSA/SEIA do not object to including this topic in the initiative scope, to allow for further discussion.  There are serious concerns on both sides; LSA does not yet have a group consensus and may not agree with any proposal in this area.

Equipment requirement:  Whether a project should demonstrate “a commitment for various key equipment” at IR submittal or to enter Phase II to timely move forward            

Comments:  LSA/SEIA oppose this requirement, for either IR submittal or Phase II Study participation.  Developers would not typically order major equipment this early in the process, especially given: (1) rapid technological change; (2) more limited information available from Phase I Studies, which might continue beyond Cluster 14; and (3) uncertain TPD allocation results at this point.

Accelerated study process based on resource readiness:  Possible new accelerated process for projects demonstrating advanced readiness to start operations before other projects. Includes readiness criteria, study process, & consequences for later project-caused delays.

Comments:  LSA/SEIA support inclusion of this topic in-scope.  LSA/SEIA’s support of any eventual proposal would depend on the readiness criteria, the meaning of “starting operations,” and the impact on other projects. 

Different study processes based on technology/system needs & locational flexibility:  Whether different requirements, and potentially different study processes and paths, should apply based on project technology (e.g., based on system needs) or locational flexibility (since less-flexible resources like off-shore wind or geothermal may have longer development timelines).    

Comments:  This topic definition is unclear.  LSA/SEIA do not oppose some acceleration or other treatment, if based on verified and legitimate system reliability needs, or where it would not impair other projects.  Otherwise, giving preference to some technologies over others violates CAISO open-access rules and should not be allowed.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

Storage (other?) resource additions for reliability needs:  Whether projects should be allowed to add resources “such as storage” on an expedited basis to meet pressing reliability needs, despite potential impacts on earlier-queued projects.       

Comments:  This should be allowed only if needed for verified and legitimate reliability reasons, or where such additions would not impair earlier projects, i.e., LSA/SEIA do not agree that negative impacts on earlier-queued projects are otherwise justified.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

Interconnection Request submittal requirements:  Whether IR submittal requirements should be increased, e.g., higher fees or deposits, or other criteria.

Comments:  LSA/SEIA do not believe that increased fees or deposits will be effective in reducing the number of IRs.  We encourage the CAISO to investigate similar efforts in other jurisdictions, which did reduce somewhat IRs submitted by smaller entities but did not reduce the number of IR submittals overall.

Streamlined Interconnection Studies:  CAISO will be developing a proposal for refining the Phase I, Phase II, and annual reassessment study timelines to allow sufficient time to complete the study work and enhance efficiency.

Comments:  LSA/SEIA support streamlining of the Interconnection Study process, e.g., the reduced Phase I scope used for Cluster 14, but only if the normal timeline (in effect before Cluster 14) can be restored and is not lengthened.  This could also simplify the IR submittal process, since dynamic model submission could be delayed to a time prior to commencement of Phase II Studies.

Even if the process is streamlined, the CAISO and PTOs should develop long-term plans to augment their resources to handle larger clusters.  This need will persist into the future, as LSE procurement gears up to meet the state’s ambitious greenhouse-gas emissions goals.

CAISO as an Affected System:  Policy for how base cases are determined & how required upgrades are funded, e.g., whether the cost of CAISO-system Network Upgrades to enable interconnection of resources in other BAAs should be reimbursed.           

Comments:  The CAISO should include this issue in the scope for this initiative.  Projects connecting to other BAAs may serve CAISO load, and the Network Upgrades they finance are available to other users, like NUs financed by CAISO-area projects. 

Generally, LSA/SEIA believe that NU costs funded by projects connecting outside the CAISO should be treated like those for projects inside the CAISO.  The initiative should consider whether other criteria should apply, e.g., (1) demonstration that the project will serve CAISO-area load (Pseudo Ties to CAISO, or PPAs with CAISO-area LSEs during refund period); and/or (2) CAISO negotiation of reciprocity refund agreements with other BAAs.

NU cost treatment for resources connecting to local (<200 KV) systems serving load elsewhere:  These NUs are funded through the connecting PTO LVTAC (PTO customers), but the resource off-takers serve CAISO load elsewhere.  (Earlier attempt to do this for GLW was rejected by FERC.) 

Comments:  LSA/SEIA supported the CAISO’s earlier VEA/GLW proposal, with its narrowly focused approach, and we still do.  The initiative should also consider other options, e.g., systemwide uniform LVTAC rate (like the current HVTAC rate).

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

Alignment between LSE procurement and locations where transmission capacity and CPUC supply portfolios:  Whether there should be incentives for LSEs to procure projects where TPP transmission capacity was approved/built based on CPUC resource portfolios.

Significant queue capacity would need no NUs, or only a RAS.  Instead, LSEs have been procuring new resources where new NUs are required, delaying CODs & increasing costs. 

Comments:  The CAISO hasn’t approved “policy-driven” NUs based on CPUC portfolios through the TPP in many years, so LSA/SEIA are puzzled by the CAISO’s references in the Proposal to locations where TPP transmission capacity was approved and built “based on CPUC resource portfolios.”

LSA and SEIA believe it would be inappropriate for the CAISO to so directly insert itself into procurement decisions through offering or paying locational “incentives.”   Application of “Least-Cost, Best Fit” (LCBF) principles to those LSE procurement decisions ensures that resources are procured only where the price is attractive even considering the cost of any needed upgrades.  Thus, those upgrades are, by definition, cost-effective.  LRAs are aware of these consequences and can change their procurement directives to jurisdictional LSEs if warranted.

Moreover, developers already have financial incentives through LCBF to locate where few or no upgrades are needed.  The CAISO can best help channel development toward those areas, where cost-effective considering upgrade cost/timing and other factors, through provision of clear and easily accessible information about where they are.

Transmission Plan Deliverability (TPD) allocation process revisions:  Whether the current TPD allocation process should be revised and if so, how.  For example, CAISO could allocate TPD to LSEs with RA obligations, who could then assign it to their contracted resources, similar to the CAISO Distributed Generation Deliverability allocation process.     

Comments:  LSA/SEIA strongly oppose this change, because it would:

• Be unnecessary.  Most projects already must have or acquire PPAs with LSEs to receive or retain TPD allocations, and even Group 3 projects are unlikely to move forward without one.

• Give even more market power and negotiation leverage to LSEs, since today projects with deliverability can contract with any LSEs anyway within the CAISO, while this change would likely remove that flexibility.

• Be inefficient.  While TPD is very location-specific, LSEs can buy from projects located anywhere; without a complex allocation process like that used for Import RA, it’s not clear how to design a fair and feasible LSE allocation process for projects beyond their service areas. 

See below for LSA ideas about modifying the TPD Allocation Groups.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

Interconnection & procurement:  How they can be better aligned with each other.           

Comments:  See above.  The CAISO can best help ensure this alignment through clear and accessible information about locations where few or no upgrades are needed (e.g., where TPD is available).

Interconnection and procurement & transmission capability:  How they can be better aligned with transmission capabilities & renewable generation portfolios developed for planning purposes.     

Comment:  Same as above.

Interconnection Requirements:  Whether they should differ for location-flexible (e.g., batteries) vs. location-constrained resources

Comments:  LSA/SEIA generally oppose discrimination by technology type in the interconnection process. 

It’s not clear how locational “flexibility” should be considered in this process.  As noted above, the CAISO wants projects to include solid POI locations in their IRs, and usually the developer has specified a certain location for a good reason. 

Moreover, there are already tools (e.g., Local Capacity Requirements) to promote development in locations where needed for reliability.

Locational issues – competitive solicitation:  Whether a solicitation model should be considered for some key locations & constraints not addressed in portfolio development, where commercial interest is the primary driver.       

Comments:  This seems like an impractical idea.  It doesn’t seem helpful to add another competitive process to the competitive RFO processes for PPAs, and it’s not clear how the two competitive processes would be coordinated in the project-development process.

Earlier GIA termination:  Whether CAISO should be allowed to terminate a GIA in <7 years for projects not “moving forward to permitting and construction.”           

Comments:  The CAISO could consider requiring additional viability demonstrations for projects that received their deliverability: (1) before any viability demonstration was required (i.e., pre-Cluster 5); or (2) based on a Balance-Sheet Financing (BSF) Affidavit. 

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

Please see LSA/SEIA’s suggestions above and below. 

In addition, with respect to study methodology, LSA/SEIA urge the CAISO to switch to the new Converter Interfaced Model in ASPEN software in Phase I, Phase II, and Reassessment studies.  Use of this more accurate model should trigger fewer circuit breaker issues, e.g., the recent SD&E finding that 24 circuit breaker replacements are needed at Imperial Valley Substation (5-year construction time) might be different using the better modeling. 

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

SCE Phase 1 suggestions:  SCE suggested including detailed clarifications to GIDAP Section 6.8 in the scope of this initiative.  LSA/SEIA support SCE’s suggested clarifications.

SCE Phase 2 suggestions 

Delays starting Phase II:  Add due dates for curing deficiencies in post-Phase I Appendix B submittals.         

Comments:  LSA/SEIA support clear and reasonable due dates.

Scoping Meetings for projects that later drop:  The IR validation process should be complete before Scoping Meetings

Comments:  LSA/SEIA agree with stakeholder comments at the workshop that the Scoping Meeting can provide important information and clarifications that can help Interconnection Customers complete the validation process.  LSA/SEIA support the CalWEA compromise proposal from the workshop, where “basic” validation should be complete before the Scoping Meeting but remaining validation issues can be addressed at the meeting.

Treatment of shared Interconnection Reliability Network Upgrades (IRNUs) across clusters:  Clarify that when Projects in different clusters share a gen-tie, PTO Interconnection Facilities, or any related IRNUs (e.g., line position to terminate gen-tie), the shared IRNUs are not subject to GIDAP Section 14.2.2.

This means that the costs can be allocated to later-queued projects even if an earlier-queued project executes a GIA containing the upgrade, if those assigned the upgrade then drop out.  In other words, those shared IRNUs remain as CANUs for later-queued projects in this situation and never become Precursor NUs.

(Doesn’t apply if shared IRNU is Stand-Alone Network Upgrade (e.g., Loop-In Substation.)   

Comments:  LSA/SEIA oppose this proposal, which is not a “clarification” but a significant policy change. 

These IRNUs are often very costly (e.g., switching stations), and earlier-queued projects triggering them may not drop out until years later.  The effect is magnified if other projects in the same cluster also drop out, because unlike CANU-GRNUs – which are typically shared with others, and where a project could be liable only for its cost share – projects can be held responsible later for the entire CANU-IRNU cost.

SCE also did not explain why SANUs would warrant retention of the current treatment, i.e., are different from other IRNUs, other than to say that “CAISO Legal wouldn’t go along with that” – not a strong policy rationale.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

Gridwell Phase 1 suggestions:  Gridwell suggested that one reason for the “bloated” condition of the interconnection queue is that developers have insufficient information to assess the relative viability of potential project locations.  Gridwell proposed detailed suggestions for additional data the CAISO should make both available and accessible.

LSA/SEIA support generally the inclusion of additional information provision as an in-scope topic in this initiative, as well as many of Gridwell’s specific suggestions.

Gridwell Phase 2 suggestions:  Gridwell’s suggestions here are less well-defined, but it seems to suggest a closer examination of the factors driving the Supercluster phenomenon.  Gridwell states drivers such as increasing procurement requirements, low entry thresholds, Site-Exclusivity Deposit refundability, lack of curtailment and transmission-constraint information, and other factors.

LSA/SEIA agree that lack of in LSA/SEIA generally agree with much of Gridwell’s analysis, especially the lack of accessible information on curtailments, constraints, and deliverability availability.  For example, the annual TPD Allocation Reports include allocation statistics only for areas with major transmission constraints, but no allocation results (e.g., TPD remaining) for other areas or information on more local constraints.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

LSA/SEIA provides the modifications and clarified topic suggestions below, in response to the workshop discussion. 

LSA/SEIA Phase 1 suggestions:  LSA’s suggested topics here are generally the same, for the reasons discussed in its original comments and workshop presentation.  (In response to a question from the CAISO, we have clarified the “Expand TPD transfer capability” item by referencing Generating Facilities connecting at the same substation and voltage level – see language in red font.)

Proposals to speed up project development

Delays caused by new PTO standards (CRAS, BAAH/substation upgrades, etc.):  Implementation of new standards by PTOs (including CRAS, substation upgrades, BAAH conversions, new automation standards, new telecom requirements, etc.) can create significant delays, even though existing projects have been operating under the prior standards.

Proposal:  CAISO should allow temporary operation using existing equipment/standards and implement improvements later, and/or work with the PTOs to find ways to accelerate PTO implementation of the new standards (e.g., CRAS implementation in less than 2-4 years). 

(The Limited Operation Study (LOS) tool is not effective in this situation because it cannot be applied until a project is very close to its In-Service Date; by then, a project would have already delayed its COD based on information in the studies.) 

Better differentiation within clusters (new):  Recent discussions about the SDG&E circuit-breaker situation at Imperial Valley (IV) Substation have highlighted the flaws in the current approach.  Nearly all the SDG&E Cluster 12 projects can safely reach COD without these upgrades, but the “feasible” CODs of all are impacted in the study because all the generation in the cluster cannot, and no information has been provided to indicate how the CAISO or SDG&E will determine which projects can reach COD without the upgrades.   

Proposal:  The CAISO should consider: (1) Providing information in Interconnection Studies (especially Phase II Studies) on how much of the cluster could achieve COD without all the RNUs triggered, and how much of the cluster could achieve full deliverability without all the DNUs triggered; and (2) consider reflecting that information in GIAs, to allow projects to come on-line (and potentially receive FCDS) before all the upgrades for the cluster are complete.  This could enable more rapid deployment of many resources where, for example, a cluster triggers RNUs that will take 5 years to complete, but some projects with earlier requested CODs can be accommodated without them.

(As noted above, the Limited Operation Study (LOS) tool is not effective in this situation because it cannot be applied until a project is very close to its In-Service Date; by then, a project would have already delayed its COD based on information in the studies.) 

Similarly, DNUs may only be needed for some projects in a cluster group, i.e., while they are needed for the cluster as a whole, some or many projects may be able to achieve deliverability without them.  the CAISO should consider granting FCDS to projects that reach COD even if all the DNUs are not built, e.g., if all the DNUs are not needed to serve the first few projects in the cluster.

Interim Deliverability Status transparency:  Long-duration DNUs impede PPA contracting and incents COD delays, even though many or most projects in a cluster may be able to achieve full deliverability without those upgrades.

Proposal:  The CAISO should provide IDS information in the Phase II Study process, with regular annual updates in Reassessments, would allow developers to rationally decide whether to continue or delay development of their projects and greatly aid their PPA contracting.  For example, this information help developers determine whether to: 

-  Retain requested CODs or delay them to match the in-service date of the longest-duration DNU; or

-  Contract with off-takers despite the risk of “RA Shortfall” provisions.

Network Upgrade re-stack:  Some later-queued projects may be assigned NUs with longer durations preventing them from reaching their desired CODs or FCDS, while some earlier-queued projects with later CODs may be assigned shorter-duration upgrades they don’t need right away.

Proposal:  The CAISO should consider “re-stacking” NUs, to better match NU in-service dates to project CODs, assigning faster NUs to projects with earlier CODs (to speed COD and/or FCDS for those projects) without delaying COD/FCDS for projects with earlier CODs.  (No changes to cost allocation are suggested here.)

Proposals to make better use of existing TPD

Expanded TPD transferability:  Currently, the applicable tariff language (GIDAP Section 8.9.9) could be interpreted to allow only deliverability transfers between Generating Units within a single Generating Facility (i.e., under a single GIA).  However, the deliverability impact to the system of different projects connecting to the same substation and voltage level should be the same; moreover, in at least some situations, developers are contemplating attempting to combine projects under a single GIA for this purpose alone, a cumbersome and burdensome course of action for the CAISO, PTOs, and Interconnection Customers.

Proposal:  Expand TPD transferability to allow transfers between Generating Facilities interconnecting at the same substation (or other location, e.g., line tap) and voltage level, particularly if the “transfer from” capacity withdraws from queue.  This would allow TPD to be assigned to projects that can better use it, and allow less-viable projects to monetize their valuable TPD and then exit the queue.  (The CAISO could also pay projects to exit, if that would be cheaper than adding deliverability in the area.)

Reassessment accommodation for TPD acquisition or retention: Several recent Reassessment Reports have contained significant new information – some examples: (1) Circuit breaker upgrades delaying CODs by up to 2-5 years; and (2) Precursor DNUs previously shown with “TBD” in-service date now shown with ISD in 5 years.  This situation has been exacerbated by timing issues – Reassessment Reports are usually issued around July 31^st, but several recent reports were not issued until August 31^st or September 15^th. 

New information that close to the TPD Acquisition or Retention affidavit deadlines confounds compliance with allocation and/or retention requirements.  This can jeopardize PPA acquisition and retention, e.g.: (1) projects with already executed PPAs could lose them; and/or (2) projects about to execute PPAs could be prevented from doing so because modifications are needed to reflect the new information (or the project could lose the PPA entirely due to the new information and have to find and negotiate a different PPA to retain the allocation).

Proposal:  This initiative should include a provision for provisional TPD allocations or retentions if Reassessment Reports shows significant change, e.g., delays COD by >1 year or high cost increases, with additional time (e.g., another cycle) for compliance demonstrations.  The initiative could also consider criteria for a developer to demonstrate that the compliance issue was caused by the revised information.

Proposals to improve new TPD allocations – moved from Phase 2 in workshop presentation)

(starting in this coming allocation cycle if possible)

Energy-Only project qualifications for new TPD allocations, Part 1:  TPD allocation rules for Energy Only capacity currently require that the capacity be built before receiving a TPD allocation, even if the developer meets the same qualifications as a project that started out requesting deliverability.   This prevents quicker and more cost-effective project additions through the MMA process, because the added capacity can’t get PPAs without TPD allocations but can’t get TPD allocations without PPAs.           

Proposal:  The CAISO should allow EO capacity to qualify for Allocation Groups 4-5 if they get or are short-listed, respectively, for eligible PPAs.  There is no apparent reason why they should be considered in a lower priority group if they are equally qualified to other projects that requested FCDS but were converted to Energy Only.

Energy-Only project qualifications for new TPD allocations, Part 2:  Existing projects that lost FCDS are ranked below new ones for TPD allocation.  However, there is no apparent reason why, especially since these projects have been in the queue longer and may be ahead of newer projects in development.

Proposal:  The CAISO should consider merging Groups 1 & 4 into a new Group 1, and also 2 & 5 into a new Group 2, for new TPD allocations.

LSA/SEIA Phase 2 suggestions

Option B reform:  As CAISO has pointed out, current TPP practices may not result in approval of sufficient upgrades in areas with high commercial interest.  Option B offers one way for developers to finance such upgrades, but the rules are so punitive that it’s possible that none has ever been built under those provisions.       

Proposal:  This initiative should reconsider the punitive aspects of this option, to make it fairer and more viable.  Changes could include refund, cost cap, and/or financial security provisions.

Battery augmentation (revised from workshop presentation):   Batteries will begin to degrade once they become operational even though NQC is fixed for a year at a time.  Regular augmentation will be needed to maintain capability.  

This problem will become more acute with large amounts of storage expected to come on-line soon.  The CAISO could be faced with annual (or more frequent) MMA requests for each storage facility on the system when more streamlined procedures may be feasible.         

Proposal:  Consider this issue generally in this initiative.  Two potential approaches are:

• Allow expedited augmentation addition of batteries (no inverter additions or Interconnection Service Capacity increases) under the BPM for Generator Management, Section 6.2.1 - Modifications That Are Approved Without Material Modification Assessment.

• Allow multi-year MMA augmentation requests (e.g., “X” MW/year) if inverters will be added (no increase in Interconnection Service Capacity).

Affected Systems – study options:  Affected Systems continue to subject new projects to possible delays or cost increases late in the development process.  In particular, developers have little recourse or options if Affected Systems make unreasonable financial demands.

Proposal:  The CAISO should consider implementation of a new Optional CAISO study (upon request, applicant funding) of CAISO-system options to mitigate identified adverse Affected System impacts.

Note:  LSA is withdrawing its proposal to give TPD allocation priority to projects sharing Interconnection Facilities and IRNUs due to the need for further discussion within the group.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

• Removing downsizing window and simplifying downsizing request requirements:

MRP: MRP supports the CAISO’s proposal to transition from a single month-long window to allowing requests to be submitted at any time.

• Transferring Participating Transmission Owner (PTO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue:

MRP: MRP does not object to the CAISO moving forward with this aspect of the initiative but suggests that the CAISO keep its Transmission Registry up to date to help clarify what lines and stations are within the CAISO’s operational control. 

• Changing Sites and POIs During IR Validation:  

MRP: While MRP does not object to the CAISO developing criteria as to what site and POI changes are allowed and which aren’t, MRP is concerned that some criteria (e.g., allowing a Interconnection Customer (“IC”) to change only within a single study area) may incent ICs to submit projects in each study area. 

 MRP believes that the CAISO publishing in advance of the interconnection request (“IR”) window reliable information as to the locations where interconnection capacity and deliverability are available will help steer ICs toward the right locations to begin with and reduce the need to change POIs and sites.  Information already provided by the utilities (e.g., SCE’s DRPEP ARCGIS system (https://ltmdrpep.sce.com/drpep/)) for their distribution systems but expanded to include this same level of detail for the transmission systems, could serve as the template for such a system. 

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

• When should site exclusivity documentation be required?

MRP: MRP believes that site exclusivity should be required earlier in the interconnection process and supports requiring site exclusivity before moving into the Phase II study process. 

• Should equipment requirements be introduced?

MRP: MRP urges caution with this approach.  Equipment requirements can unduly favor the developers who are also manufacturers or who can order and carry equipment without having defined projects.  MRP believes that ICs will want to see their Phase I results and what their permitting challenges may be before having to commit to equipment.  If equipment requirements are introduced, they should be introduced only during later stages of the interconnection process.  Requiring an affidavit from ICs that they have secured equipment at a given stage of the interconnection process could be another approach.  Yet another approach might be to establish phased, increasing non-refundable security deposits if an IC wishes to proceed into the later stages of the interconnection process without having secured equipment.

• Should an accelerated process for "Ready" projects be considered?

MRP: While MRP is aware that some ISOs and RTOs have adopted this approach, MRP is not sure if this practice has meaningfully improved their interconnection processes.  MRP is concerned that an accelerated process for “ready” projects will require detailed criteria as to what constitutes a “ready project” and could lead to “parallel interconnection queues”.  MRP notes the CAISO already has provisions in place to accelerate projects, however, recent experience in utilizing this accelerated process has not resulted in an accelerated schedule. MRP encourages CAISO to better define, and enforce, how its accelerated process is implemented.

• Would different requirements for different technologies to advance in the interconnection process be appropriate? Between location-specific resources versus more location-flexible?

MRP: The CAISO’s intent regarding these questions is unclear. MRP requests that the CAISO rephrase these questions. 

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

• Should a one-time framework be adopted to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impacts on earlier-queued projects, to meet pressing reliability needs?

The CAISO asks a difficult question.  It is difficult to portray allowing or even encouraging the expedited development of projects that affect earlier-queued projects as anything other than sanctioned queue-jumping.  Where the “pressing reliability need” stems from some unlikely event – for example, the catastrophic failure of a generator or transmission line – allowing the expedited development of replacement resources seems prudent.  Where the “pressing reliability need” stems from a failure to reasonably plan and construct new network or generator resources, however, sanctioned queue-jumping is a more difficult remedy to accept.  The former situation calls for the CAISO to implement emergency interconnection procedures in its Tariff; the latter calls out for better long-term reliability planning, procurement and development.. 

All things considered, MRP supports the CAISO creating a one-time framework to add storage at existing sites, provided that the CAISO also modifies its Tariff in parallel to this effort to include the ability to address future emergency interconnection needs.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

MRP has no response for this section.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

• Should there be incentives for load serving entities to procure generation projects at locations where transmission capacity has been built/approved based on the California Public Utilities Commission (CPUC) portfolios?

MRP: MRP does not understand why having transmission capacity available at certain locations does not serve as sufficient incentive for project developers.  Perhaps the issue is better addressed by providing the information on available transmission capacity to potential developers? 

• Should Transmission Plan Deliverability (TPD) Allocation process revisions be considered?

• • Should a TPD allocation process similar to the Distributed Generation Deliverability allocation process be considered where TPD is allocated to LSEs who have resource adequacy obligations and would assign TPD to specific projects they enter into a PPA with?

MRP: Would such a process provide LSEs with the ability to unfairly award TPD to projects developed by their affiliated generation companies?  If so, MRP would oppose it. 

MRP suggests that the CAISO should instead work on mechanisms to periodically share TPD availability (versus projects requesting) information by substation.  Information posted should be updated quarterly or more frequently (to reflect withdrawals, downsizing, ISPs/clusters).

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

• How can the interconnection process and incoming applications better align with procurement interest?

MRP: MRP suggests that each LSE post on the CAISO website links to LSE web pages detailing the state of their procurement efforts.  In addition, the CAISO should regularly communicate with LSEs on their procurement efforts to help educate the LSEs’ procurement staff on the IR process. Moreover, the CAISO should consider how to shorten the overall interconnection request process, including the typical timelines to design, procure and install interconnection facilities and network upgrades. Aside from the Super Cluster 14 timeline (which is even longer), the interconnection request process typically takes more than two-and-a-half years to complete, and if any interconnection facilities are required, the typical timeline adds another 27 months, which translates to request-to-COD time frame of over five years. The current procurement processes do not consider these timelines.

• How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?

MRP: Many network upgrades get delayed for years.  More needs to be done to resolve the issues causing the delays.  The delays compound the ability to complete projects that rely on prior queued projects’ upgrades, causing problems with ICs meeting CODs.

• Should interconnection application requirements differ for resources that are location constrained, versus resources like standalone batteries that can be located elsewhere on the grid?

MRP: MRP’s initial reaction to this question is that having two different sets of interconnection application requirements, which gives rise to the need to define precise criteria as to which set applies to which resources, may not be effective or workable.

• Should a solicitation model be considered for some key locations and constraints not addressed in portfolio development, where commercial interest is the primary driver?

MRP has no reply to this question.

• While the tariff currently allows a project to achieve its COD within seven (7) years if a project cannot prove that it is actually moving forward to permitting and construction, should the CAISO have the ability to terminate the GIA earlier than the seven-year period?

MRP:  MRP is open to discussing the possibility of giving the CAISO authority to terminate projects that are not materially advancing toward COD.  Exceptions – for example, for long delays resulting from PTO delays in constructing network upgrades – would have to be allowed. 

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

For the sake of completeness, MRP re-submits here the topics it originally submitted by e-mail on October 8:

1. The CAISO should review the information that it requests Interconnection Customers (“ICs”) submit in their Interconnection Requests (“IRs”) to better ensure that the information requested is necessary.  Further, the CAISO should revise the timelines in the interconnection process at which the information is required so that ICs are not required to submit information until that information is needed in the process.
    
2. To prevent data validation problems resulting from mismatches between the information requested in Generating Facility Data-Attachment A to Appendix 1, the CAISO should adopt a standard level of decimal place precision – MRP suggests two (2) decimal places to match the precision used in GE’s PSLF model – in that form. 

3. To ensure that ICs have the time to work with equipment manufacturers to obtain the information needed by the CAISO, the CAISO should finalize and publish Generating Facility Data-Attachment A to Appendix 1 templates at least four months in advance of the opening of the IR window. 

4. The CAISO should immediately schedule and hold scoping meetings after the close of the IR window.   This will prevent the CAISO and ICs from spending time validating IRs for Points of Interconnection (POIs) that are not viable. 

5. The CAISO should consider adopting other ISOs’ practice of requiring site exclusivity at the time the IR is submitted.

6. The CAISO should retain Allocation Group 3 but make it more difficult for projects to sit in the queue indefinitely (e.g., make the upgrade costs for such projects non-refundable, or adopt PJM’s practice of having separate Construction Services and Interconnection Agreements).  

7. The CAISO should, well in advance of the opening of the IR window, publish information that would better allow prospective ICs to understand which interconnection locations have available deliverability and which ones do not. 

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

MRP supports SCE’s proposal to re-examine how errors and omissions are treated. 

With regards to SCE’s proposal to add due dates for curing deficiencies in Appendix Bs, MRP suggests instead that the CAISO should define the point at which the project will be studied “as is” if deficiencies are not cured.  Further, it is critical that the CAISO and PTO adhere to their timelines for identifying deficiencies. 

With regards to SCE’s proposal to having the IR validation process deemed complete prior to holding Scoping Meetings, MRP prefers its proposal to hold the Scoping Meetings immediately after the IR window closes.  MRP does not believe it is productive to subject the CAISO, PTO and IC to data validation processes for projects that have no hope of proceeding.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

MRP supports Gridwell’s proposals to:

• Provide additional information in the Interconnection Queue report; and
• Create a transmission project tracking report.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

MRP supports LSA/SEIA’s proposals to

• Accelerate PTO work completion to prevent delays caused by the implementation of new standards;
• Provide regularly-updated information about potential interim deliverability through non-binding multi-year forecasts, starting with the Phase II studies and updated during the annual reassessments.
• Allow an additional TPD allocation/retention cycle for compliance with acquisition/retention requirements disrupted by new information coming from the annual Reassessments;
• Require systematic and more formal processes for addressing battery degradation and augmentation; and
• Provide for an optional CAISO study (to be funded by the IC) of CAISO-system options to mitigate identified adverse Affected System impacts. 

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

 MRP has no additional comments. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

NextEra Energy Resources, LLC (NextEra) is submitting these comments early under item 4 (see attached) to highlight that the proposed scope in the case of COMA, and timeline in the case of this IPE 2021, fail to support accelerated deployment of resources that could otherwise contribute to energy stability and mitigate potential capacity shortages for the summer of 2023.  The critical element within the CAISO’s control that must be immediately addressed is ensuring transmission deliverability is allocated to resources capable of achieving commercial operation for summer 2023 through one-time, limit changes to the 2022 Transmission Plan Deliverability Allocation process.   

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

See attached comments. 

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

PG&E appreciates the opportunity to provide its perspectives on the preliminary issue paper and looks forward to working with the CAISO and other stakeholders through the IPE process.  As discussed below, our preliminary comments raise more questions than answers.  Based on the last super cluster 14, PG&E recognizes the CAISO needs to adopt stricter tariff rules on new projects that can enter the Queue, such as site exclusivity requirements, speculative applications and simplify the interconnection process.  PG&E understands the goal of accelerating “ready” projects but asks if that issue can be better aligned with procurement activities and transmission planning.  

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

Removing downsizing window and simplifying downsizing request requirements

PG&E is supportive of the simplification of the downsizing process and believes that the continuous application window is reasonable. Currently downsizing assumptions are captured as part of the Annual Reassessment. If the downsizing window is removed, will the changes still be incorporated as part of the next reassessment? PG&E is interested in the perspective of developers that navigate the interconnection process since this change is most likely to affect their projects positively or negatively.

Process for changes to network upgrade requirements after the second Interconnection Financial Security (IFS)posting

PG&E is supportive of including the process for changes to network upgrade requirements after the second financial security posting.  Although this issue is not Germaine to every generation project, it is an issue that should have clear tariff direction to allow developers of generation projects clear insight into the costs and in-service dates of all Reliability and Deliverability Network Upgrades associated with their projects.

Process for changes to network upgrade requirements after the second Interconnection Financial Security (IFS)posting

PG&E invites discussion and development on the process by which Wholesale Distribution Tariff projects that are incorrectly received by PTOs are transferred into the CAISO queue. Tariff language will improve the process for the PTOs, interconnection customers, and CAISO.

Changing Sites and POIs During IR Validation

PG&E agrees that criteria should be developed for the extent to which project sites and points of interconnection can be changed during Interconnection Request validation.  When a project applies to the CAISO, it should be a project of sufficient maturity.  PG&E has observed in the past that some projects have not achieved sufficient maturity, which makes the process of identifying any point of interconnection difficult because the project is not tied to any location, point of interconnection, and in some cases, capacity. Uncertainties in project sites and changes to point of interconnection during the Interconnection Request validation process can jeopardize PTOs ability to meet CAISO Tariff timelines especially during a “supercluster”.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

PG&E is generally supportive of identifying pathways for the accelerated interconnection of “ready” projects as well as ways to limit future “super clusters” and a healthy queue. PG&E is interested in understanding the perspectives of the generation developer community on these topics, as they benefit from a healthy queue but might also be tasked with additional requirements for generation interconnection applications resulting from this stakeholder initiative.

When should site exclusivity documentation be required?

PG&E is supportive of the inclusion of site exclusivity requirements for projects applying to the CAISO for generation interconnection.  It appears that the lack site exclusivity encourages project speculation which is a direct cause of the “supercluster.”

Should an accelerated process for "Ready" projects be considered?

PG&E would ask that stakeholders consider whether an accelerated process is necessary to interconnect “ready” projects, or whether the level of project development required for applying to the queue has historically been too low?  Would increasing the level of readiness for projects to apply to the CAISO queue be another way to achieve the same goal?  PG&E can see unique cases where an accelerated process for generation projects to interconnect would be useful.  The current paradigm of available generation in California may be one such case.

Would different requirements for different technologies to advance in the interconnection process be appropriate? Between location-specific resources versus more location-flexible?

PG&E currently has no position on this topic but is interested in the position of other stakeholders on this topic – especially the position of generation developers.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

Should a one-time framework be adopted to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impacts on earlier-queued projects, to meet pressing reliability needs?

PG&E is generally supportive of changes that enable the interconnection of resources that support grid stability.  As such, PG&E is generally supportive of a process to help interconnect additional storage to address load at net peak. Careful consideration should be taken to ensure that one-time framework for addition of storage at existing sites does not exacerbate or cause new Reliability Upgrades impact existing queued generation’s in-service date. That being said, whatever the framework is, CAISO and CPUC requirements for interconnection and power purchase agreements should be made abundantly clear to RFO participants.  PG&E has observed that a number of the projects that underwent the one-time storage addition to existing generation projects have struggled with an understanding of their project requirements, timelines, and in some cases, a clear understanding of resource adequacy.

Regardless of the pathway to addressing this issue, PG&E invites the CAISO and load serving entities (LSEs) to coordinate procurement initiatives with interconnection procedures in this venue, should it move forward.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

Should higher fees, deposits, or other criteria be required for submitting an IR?

PG&E is generally supportive of additional administrative or project milestone related requirements as they should increase the quality of applications and potentially the number of applications.  PG&E is concerned that using the interconnection application fee as the way to reduce the number of interconnection applications as it will affect smaller developers unjustly in comparison with larger developers without necessarily improving the quality of application.

Streamline interconnection studies

PG&E shares the CAISO’s concerns regarding the increased scope and complexity of interconnection studies and looks forward to reviewing the CAISO’s proposal for refining the GIDAP timelines to allow sufficient time to complete study work and enhance efficiency. If dependencies exist with ongoing complex clusters or “superclusters”, PG&E requests to have provisions to extend tariff timeline for study process like ISP, Repowering and Post-Cod Modification.

PG&E suggests that in-service dates associated with PNU’s and CANU’s be considered when determining the generation project’s in-service date.  This inclusion should not affect the financial postings of a project.

Policy for CAISO as an Affected System –how is the base case determined and how are the required upgrades paid for.

PG&E has concern with the scenario under which there is no reciprocity on the treatment of reimbursements associated with network upgrades.  PG&E is supportive of a paradigm where there is reciprocity between neighboring BA’s in the treatment of reimbursements of network upgrades triggered by generators outside of the CAISO BA.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

Should there be incentives for load serving entities to procure generation projects at locations where transmission capacity has been built/approved based on the California Public Utilities Commission (CPUC)portfolios?

PG&E believes that there should be incentives for LSEs  to procure generation projects in geographic locations identified by the CPUC.  PG&E is interested in understanding what incentives the CAISO could provide in this space? Would it be simpler to implement these incentives through CPUC RFO?

Should Transmission Plan Deliverability (TPD)Allocation process revisions be considered?

PG&E believes that the way TPD allocation is applied to Wholesale Distribution Tariff projects should be updated to allow those projects to pay for deliverability network upgrades and potentially participate in wholesale markets.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

How can the interconnection process and incoming applications better align with procurement interest?

PG&E believes that procurement interest should be aligned with the interconnection process, not the other way around.  The CAISO’s interconnection process has clear timelines and opportunities for acceleration or project termination that include the required reliability and deliverability studies. Procurement activities should take these schedules into account. That being said, studies should clearly include a summary of all upgrades needed for projects to achieve commercial operation and full deliverability to enable procurement staff to understand the actual likelihoods of achieving the operational dates included in those studies.

How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?

PG&E has observed both the Tehachapi and CREZ initiatives in California and Texas have been successful in aligning transmission development, renewable generation portfolios, and generation interconnection in the past.  It is important to note that simply identifying the locations may lead to another supercluster; it will be important to address speculative projects if this path is chosen by stakeholders.

Should interconnection application requirements differ for resources that are location constrained, versus resources like standalone batteries that can be located elsewhere on the grid?

PG&E does not currently have a position on this issue, but notes that the addition of more study processes or pathways to interconnection will likely overcomplicate the interconnection process and expand the number of studies needed – which the CAISO is working to address in section 4.1.

While the tariff currently allows a project to achieve its COD within seven (7) years if a project cannot prove that it is actually moving forward to permitting and construction, should the CAISO have the ability to terminate the GIA earlier than the seven year period?

PG&E is supportive of actions that can be taken to improve the health of the CAISO interconnection queue.  PG&E is generally supportive of the CAISO’s suggestion of removing inactive generation projects from the queue, but is also interested in the perspective of the generation development community’s perspective on this issue, and if they have any specific suggestions on how to address the issue of “queue squatting”.  PG&E will note that a queue filled with “ready” projects would improve our ability to interconnect generation projects in a timely and cost effective manner.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

A number of questions included in the IPE issue paper address the topic of project readiness.  PG&E believes that these questions could be combined to address the deeper issue – what level of readiness are projects applying to the CAISO queue expected to have?  How does the CAISO envision the process of generation projects navigating the interconnection process?  Establishing alignment across stakeholders on these questions would make “cleaning up the queue” much easier, as the chosen tactics (e.g. application fees or site exclusivity) could be used to incentivize the agreed upon goal.  PG&E is interested in understanding the perspective of generation developers in answering these questions and establishing a unified vision of how the interconnection process is expected to function.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

Issue: Error and Omissions language in Section 6.8 (in addition to CAISO change contemplated in Section 3.1 of the Preliminary Issue Paper)

As PG&E mentioned in question 3.1, we are supportive of this issue’s inclusion in the IPE.

Proposed issues to include in Phase 2:

PG&E is supportive of SCE’s suggestions to have the IR validation process complete prior to holding scoping meetings and making it explicit when interconnection customers agree to share generation tie-line, PTO Interconnection Facilities, and any related Interconnection Reliability Network Upgrades across clusters, and ensuring IRNU’s are not subject to backstop by the PTOs (Section 14.2.2).

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

PG&E is supportive of Gridwell’s request for data transparency in order to reduce the number of speculative projects in the queue.  PG&E agrees that although data may be available, it may not be accessible.  PG&E is interested in understanding the perspective of the generation community on what data is needed and what steps can be taken to avoid future superclusters.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

In general, PG&E is neutral on the scope of issues presented by LSA/SEIA and is interested to see how other members of the developer community react to the presentation.  PG&E is concerned by the issue “Delays caused by new standards,” as this does not appear to be a common issue. Standards development is by no means a fast-moving arena, so the idea that customers should pay for accelerations to avoid meeting new standards seems unjust.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

PG&E has identified concerns on timely construction of shared network upgrades that have cross cluster dependencies like Conditionally Assigned Network upgrades (CANU) and Precursor Network Upgrades (PNU).  As it is now, the triggering project must post 100% of the estimated upgrade cost in financial security for PG&E to kickoff construction activities for these upgrades which are not required at the time of IA execution.  As a result, downstream queued projects are on the hook for the completion of upgrades that have typically not began in a timely basis.  This may result in queued project’s in-service dates being jeopardized by a delay in financial security postings. If the triggering project is required to post 3^rd financial security posting at the time of IA execution, this delay/ risk in online date would be eliminated.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

REV Renewables (REV) appreciates CAISO launching the IPE initiative to explore options to improve and streamline the interconnection process.

In Phase 1, REV supports including most items listed in the issue paper in the scope of this initiative, except issues that would retroactively change Cluster 14 or earlier process rules or issues that would allow queue jumping. For example, as noted below, REV does not support changing requirements for site exclusivity documentation, creating equipment requirements, or creating an accelerated process for “ready” projects. If CAISO and stakeholders want to explore those issues they should be included in Phase 2.

In Phase 2, REV supports issues that will help streamline the interconnection process and align with system needs. For example, REV requests CAISO consider updating the deliverability study process to assign more weight on the Highest System Need scenario to account for resources needed to meet the net demand peak period. REV suggests that any Phase 2 issues maintain that the interconnection process is technology and location neutral.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

• Removing downsizing window and simplifying downsizing request requirements
  • REV supports including this issue to provide more flexibility for developers to downsize and maintain real project in the CAISO queue. REV also supports CAISO considering the release of reports prior to next reassessment on a case-to-case basis e.g., for projects that do not have any network upgrades.
• Process for changes to network upgrade requirements after the second Interconnection Financial Security (IFS) posting
  • REV supports CAISO including this issue to clarify who bears cost responsibility if an error or omission is discovered after second posting. In evaluating this issue, REV suggests CAISO ensure that cost caps for network upgrades should still be protected to provide stability for interconnectors. In general, REV suggests that the party that is responsible for the error or omission should bear extra cost responsibility.
• Withdrawal option for projects impacted by new costs and/or delayed in-service date (ISD) after initial posting
  • REV supports CAISO considering this issue.
• Clarify definition of Reliability Network Upgrade (RNU)
  • REV supports including this issue in scope as it is important to clarify the definition of RNU. RAS schemes identified in deliverability studies should not hamper the projects ability to come online and these RAS should not count towards RNU cost cap. In addition, CAISO should clarify this specific categorization in the study reports so that there is no confusion later in the process for project to come online.
• Transferring Participating Transmission Owner (PTO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue
  • REV supports clarifying this issue and suggests CAISO publish a list of WDAT/CAISO POIs to help the stakeholders submit requests to the appropriate entity.
• Changing Sites and POIs During IR Validation
  • REV supports clarifying this issue with more specific criteria. The criteria should not limit IC’s flexibility to explore POIs within the general study area of the original requested POI.

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

• When should site exclusivity documentation be required?
  • CAISO should not change the current rules on site exclusivity documentation for Cluster 14 or earlier clusters. Any such change would be an unfair change to the process under which the request was submitted. If CAISO and stakeholders want to explore changes to site exclusivity it should be done in Phase 2 for future clusters.
• Should equipment requirements be introduced?
  • CAISO should not change the current rules on equipment requirements for Cluster 14 or earlier clusters. Any such change would be an unfair change to the process under which the request was submitted. Additionally, requiring certain equipment commitments at an early stage would be a significant departure and disruption to current development protocols and supply chain processes. If CAISO and stakeholders want to explore changes to equipment requirements should be done in Phase 2 for future clusters.
• Should an accelerated process for "Ready" projects be considered?
  • REV does not oppose CAISO considering an accelerated process for “ready” projects, but CAISO and stakeholders should consider equity concerns for other projects in the queue and harm that could result from queue jumping. This would be a more appropriate issue for Phase 2 if stakeholders want to consider this further.
• Would different requirements for different technologies to advance in the interconnection process be appropriate? Between location-specific resources versus more location-flexible?
  • CAISO should not consider different requirements for different technologies. The Interconnection Process should be technology neutral and not favor or prejudice any particular technology. If stakeholders want to explore this issue further it could be considered in Phase 2.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

• Should a one-time framework be adopted to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impacts on earlier-queued projects, to meet pressing reliability needs?
  • Interconnectors are already allowed to add resources such as storage to existing sites as long as it does not increase the maximum megawatt amount at the POI. If the interconnector requests an increase to the megawatt amount at the POI then it should not be given preferential treatment, it should go through the normal interconnection request process. REV does not support queue jumping that would result from an increase in megawatts allowed ahead of earlier-queued projects.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

• Should higher fees, deposits, or other criteria be required for submitting an IR?
  • CAISO fees and deposits are already sufficiently high, but if CAISO decides to increase the amounts REV could support that, however REV recommends that CAISO ensure that the site control deposit is still fully refundable (once customer submits evidence of site). Flexibility on site control is needed because going through the interconnection process is the only way for developers to know whether it is a viable location and developers could be financially burdened by costs for unviable project sites. REV does not support setting a limit on the number of projects a single developer can submit for the interconnection requests.
• Streamline interconnection studies
  • REV supports CAISO considering options to streamline the interconnection study process and timeline.
• Policy for CAISO as an Affected System – how is the base case determined and how are the required upgrades paid for
  • REV suggests that the base case used for generators in other BAs should be the same base case as generators within CAISO. REV agrees with the idea of a policy for CAISO as an affected system. Applying the current ISO study constructs, it will make sense to perform a study similar to reliability studies that ISO performs in its current study processes. It might be more efficient to use the readily available reliability base cases from the latest studies already finished by ISO. REV also supports considering how required upgrades are paid for.
• Should the CAISO re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the PTO owning the facilities
  • REV supports CAISO re-considering an alternative cost allocation treatment for local (below 200kV systems). California has a growing need for renewables and storage, and should not unduly burden local ratepayers for projects that have regional benefits. Additionally, CAISO should consider whether to lower or eliminate the voltage threshold for Order 1000 eligible projects to make <200kV projects eligible for competition, which can reduce the project cost to benefit transmission customers.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

• Should there be incentives for load serving entities to procure generation projects at locations where transmission capacity has been built/approved based on the California Public Utilities Commission (CPUC) portfolios?
  • This issue is more directly related to resource procurement issues and is the jurisdiction of the CPUC, not CAISO. CAISO should focus on interconnection requests and resulting upgrade needs, and should be unbiased in its assessment of project technologies or locations in this process. CPUC resource considerations can be factored into network upgrades in the Transmission Planning Process through the portfolios submitted to CAISO by the CPUC. Additionally, many LSEs consider transmission capacity in procurement processes by asking for network upgrade costs as part of submissions and using that as an evaluation criteria.
• Should Transmission Plan Deliverability (TPD) Allocation process revisions be considered?
  • No, REV does not support CAISO considering to revise TPD allocation to be allocated to LSEs. Developers provide the financial investment in the interconnection and development process, along with the financial and development risk. Therefore TPD should continue to be allocated to the project and developer who bears the risk and interconnection cost.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

• How can the interconnection process and incoming applications better align with procurement interest?
  • California’s need for resources during the highest system need (HSN) is growing. Resources such as energy storage that could generally charge during off-peak and discharge during highest system are adequately poised to meet these system needs. REV suggests that CAISO’s deliverability constructs should capture this and, for example, assign more weight on the HSN scenario for the deliverability. REV encourages CAISO to address this in the current deliverability framework and align it with similar sort of developments in the RA proceeding at the CPUC such as PG&E’s slice-of-day proposal. These changes could help align LSE procurement needs with grid system needs for resources in the net peak demand period.
• How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?
  • REV suggests that for out-of-state wind that are in CPUC renewable generation portfolios, the projects should be evaluated at their points of interconnection in BAs outside CAISO rather than at the CAISO boundary injection points. This evaluation would allow CAISO to better determine transmission needs to deliver the out-of-state renewable generation from source to load.
• Should interconnection application requirements differ for resources that are location constrained, versus resources like standalone batteries that can be located elsewhere on the grid?
  • CAISO should not consider different requirements for different technologies. The Interconnection Process should be technology neutral and not favor or prejudice any particular technology.
• Should a solicitation model be considered for some key locations and constraints not addressed in portfolio development, where commercial interest is the primary driver?
  • CAISO could consider a solicitation model for transmission solutions to resolve constraints at key generation constraints. CAISO could leverage its policy study framework and Order 1000 process to build transmission network upgrades for key renewable energy zones. However, if CAISO is referring to solicitation for generation, then REV does not support because that is the jurisdiction of CPUC and LSEs.
• While the tariff currently allows a project to achieve its COD within seven (7) years if a project cannot prove that it is actually moving forward to permitting and construction, should the CAISO have the ability to terminate the GIA earlier than the seven year period?
  • No, REV does not support CAISO terminating a GIA earlier than the seven year period. Many projects have legitimate reasons for long project timelines and should retain the right to stay in the interconnection queue. Additionally, Cluster 14 projects may take more than seven years to come online given delays in the study process and TO time to perform studies and construct network upgrades. If CAISO decides to pursue this issue, REV suggests that CAISO develop clear criteria on when/how to terminate a GIA and have a process for the developer to the termination.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

As stated in question 7, REV recommends CAISO consider providing a deliverability status for HSN period. California’s need for resources during the HSN is growing. Resources such as energy storage that could generally charge during off-peak and discharge during highest system are adequately poised to meet these system needs. REV suggests that CAISO’s deliverability constructs should capture this and, for example, assign more weight on the HSN scenario for the deliverability. REV encourages CAISO to address this in the current deliverability framework and align it with similar sort of developments in the RA proceeding at the CPUC such as PG&E’s slice-of-day proposal. These changes could help align LSE procurement needs with grid system needs for resources in the net peak demand period.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

• Additional thoughts on Errors and Omissions language to remove ambiguity in Section 6.8
  • As stated in question 2, REV supports CAISO including this issue to clarify who bears cost responsibility if an error or omission is discovered after second posting. In evaluating this issue, REV suggests CAISO ensure that cost caps for network upgrades should still be protected to provide stability for interconnectors. In general, REV suggests that the party that is responsible for the error or omission should bear extra cost responsibility.
• Adding due dates for curing deficiencies in Appendix Bs, to avoid delays in starting Phase II studies
  • REV agrees that CAISO could add due dates for curing deficiencies to avoid delays in starting Phase II studies.
• Seek to have the IR Validation process and “deemed complete” prior to holding Scoping Meetings (regular cluster, not supercluster procedures)
  • REV does not support a requirement to have the IR validated prior to holding Scoping Meetings. As long as the IC is working with the ISO and PTO to resolve the deficiencies, the IC should be allowed to participate in the scoping meetings. Additionally, in some instances, ICs change the POI after the scoping meeting which will again invalidate the IR but could be necessary to have a viable project.
  • REV also suggests that CAISO simplify and standardize the Interconnection application review process across different PTOs. This should help reduce the timeline and align with SCE suggestion to have the IR validation process “deemed complete” prior to the scoping meeting.
• Making it explicit that when ICs agree to share a Generation TieLine, PTO Interconnection Facilities, and any related IRNUs at the substation (e.g., line position to terminate the shared gen-tie) across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2. And such shared IRNUs will be treated as CANUs for later-queued generation and not PNUs. This exclusion does not apply in the case where the shared IRNU is a Stand-Alone Network Upgrade (e.g., Loop-In Substation).
  • REV has no comment at this time.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

• REV has no comment at this time. 

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

• Phase 1
  • Speed up new resource implementation
    • Delays caused by new standards
      • REV has no comment at this time.
    • Lack of transparency about Interim Deliverability
      • REV agrees it would be helpful to have best available information about Interim Deliverability early and updated regularly.
  • Use existing TPD more efficiently
    • Network Upgrade (NU) re-stack
      • REV does not support this issue if it allows projects to jump ahead of others in the queue.
    • TPD transferability
      • REV agrees that TPD transfers between projects at the same POI should be an option through e.g., selling TPD to others.
  • Reassessment accommodation
    • REV supports considering this issue.
• Phase 2
  • Improve TPD allocation processes (by next TPD allocation – otherwise, move to Phase 1)
    • REV is neutral on whether CAISO should consider these issues, but cautions on revisions that could be considered queue jumping for projects.
  • Option B reform
    • REV has no comment at this time.
  • Battery storage degradation management
    • REV supports considering augmentation issues, such as augmentation without an MMA process. These are issues on the customer side and developers should not be required to pay MMA study deposits for these augmentation requests.
  • Affected Systems issues
    • CAISO Network Upgrade refunds
      • As discussed in Question 5, REV supports considering this issue.
    • Study options
      • REV supports an optional CAISO study (upon request, applicant funding) to mitigate identified adverse Affected System impacts.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

REV suggests that when a developer issues NTP to the PTO, PTO/CAISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects. Sometimes there are upgrades such as new Remedial Action Schemes that are triggered by a group of projects, and not by individual projects themselves, and CAISO/PTOs wait to start planning for these upgrades until enough projects achieve commercial operations. This can cause material risk to the first project which stays under an Interim Deliverability status until the required upgrade is built. The deliverability status of this project is tested every year under the annual process which is conducted around middle of the year and if enough deliverability is available this project is allowed to be full capacity for the upcoming year. The concern with this approach is if the annual deliverability process does not show enough deliverability, CAISO and PTO may then decide to build the required upgrade but this may be too late for this project to sell full capacity RA for the upcoming year. Six months is typically not enough lead time for the upgrade to be completed and hence the project may not be able to meet its RA obligations for the upcoming year. In addition, this could cause a reliability risk for CAISO if supply conditions for this upcoming year were constrained. Therefore, REV proposes that when a developer issues NTP to the PTO, PTO/CAISO should either a) start planning for all upgrades required for FCDS status, including upgrades triggered by a group of projects or b) allow the project that is ready to achieve COD to proceed as FCDS if CAISO/PTO make a determination that the network upgrade doesn’t get triggered if only this project proceeded forward.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

1. “Clarify definition of Reliability Network Upgrade (RNU)”

If the intent is for there to be clarity around cost recovery mechanisms, then SDG&E agrees that RAS should be considered the same as RNU.  However, it is SDG&E’s understanding that CAISO has determined RAS needing implementation before they are needed to address reliability concerns and are ONLY needed to ensure deliverability for certain generators.  In instances like this, it is SDG&E’s position that RAS should be identified as Delivery Network Upgrades, but could still have cost recovery mechanisms of RNUs.

2. “Changing Sites and POIs During IR Validation”

SDG&E’s position is that ICs should be able to change their POI within the same study and it should be restricted to a set number of buses or electrical distance from the original POI.  The current mechanism to confirm POI within 5 business days of the scoping meeting is inadequate for ICs and also restrictive on the PTO.  Between the scoping meeting and the end of the IR validation window, there is very little time to start the IR validation process over again with a new POI and site location.  SDG&E recommends further discussion with stakeholders on how to provide POI feasibility information at some point during the IR validation, without waiting for scoping meetings to allow for more time to both IC and PTO.   

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

1. “Should an accelerated process for "Ready" projects be considered?”

An accelerated process may be especially useful for projects contributing to the reliability of the system. This will allow California to reach its short-term resource goals by removing certain roadblocks, as applicable. SDG&E encourages the exploration of allowing more “interconnection ready” projects to quickly move forward during emergency procurement situations identified by the CPUC, the CEC, or the CAISO. SDG&E also recommends that if a “Ready” project framework is established, the CAISO provide specific guidelines to address what would be the re-allocation of network upgrades.

2. “Would different requirements for different technologies to advance in the interconnection process be appropriate? Between location-specific resources versus more location-flexible?”

As mentioned above, SDG&E supports a mechanism to advance projects in the queue that are “interconnection ready” during emergency situations identified by the CPUC, the CEC, or the CAISO. This might allow for improved reliability by expediting viable interconnections.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

1. “Should a one-time framework be adopted to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impacts on earlier-queued projects, to meet pressing reliability needs?”  

SDG&E would also like to reiterate the comments above regarding a provision for queue jumping for “interconnection ready” projects that also meet California’s future energy goals.

Should an emergency reliability need be identified per study or analyses, it may be prudent to explore modifying interconnection processes. However, it may also be prudent to further explore opportunities for streamlining the interconnection process as necessary. For example, if a storage project is added as an existing site without increasing the site POI output, there would be less risk to the reliability of the transmission system. Furthermore, there are currently a lot of speculative projects in the CAISO queue that has been in the queue for years and that are not moving forward. A more comprehensive review of these projects might allow newer projects that are more viable to move forward.

SDG&E recommends specific electrical configurations of where the BESS might be sited.  A gen-tie sharing configuration that shares the Main Step-Up Transformer or, at a minimum, shares the high side breaker with the existing generator should be required.  SDG&E has found multiple issues and challenges around communications and protection for gen-tie sharing with tapped gen-ties and those would require higher costs and longer lead times.  Additionally, if the addition of the BESS to an existing generator was to be DC coupled with existing generator would avoid concerns of adding additional short circuit fault duty to the CAISO controlled grid.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

1. 1. Policy for CAISO as an Affected System – how is the base case determined and how are the required upgrades paid for”

SDG&E supports including this item for discussion in the Issue Paper.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

1. Should there be incentives for load serving entities to procure generation projects at locations where transmission capacity has been built/approved based on the California Public Utilities Commission (CPUC) portfolios?”

SDG&E does not see the necessity in the incentives mentioned and encourages synergy with CPUC procurement orders. The size of clusters 13 and 14 suggest that building projects closer to transmission capacity may be a matter of greater awareness and visibility around CAISO’s whitepaper on Transmission Capability Estimates. 

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

1. “How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?”

There should be close interaction between the TPP and GI processes so that ideally deliverability can be built through the TPP before bottlenecks can occur in the GI processes. It should also be noted that if the TPP only considers resource portfolios 10 years out and generators are submitting interconnection requests based on 2045 state goals or local government (e.g., Cities’ 2030 100% goals), there may be a mismatch and associated logistical issues. For this reason, it may be appropriate to start building transmission based on the results of the 20-year outlook analysis in the TPP.

2.  “Should a solicitation model be considered for some key locations and constraints not addressed in portfolio development, where commercial interest is the primary driver?”

SDG&E supports exploring how commercial interest could help transmission planning and procurement.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

SDG&E recommends improving the process of removing inactive (stalled) interconnection requests in the queue.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

SDG&E supports including a discussion of “IRNU reallocations” in Phase 2 of the Issue Paper. In example, Stranded Cost Responsibility for IRNU Switchyards (Phase I): If an IC proposes to connect to a switchyard of an earlier queued projects that has executed a LGIA, the new IC is does not have any cost responsibility or cost exposure related to the switchyard.  If the earlier queued project(s) terminates the LGIA, then the PTO is responsible for funding the switchyard.  SDG&E recommends a mechanism for IRNU reallocations with associated cost responsibility and cost exposure assigned to later queued project(s).

SDG&E also recommends providing clarity on projects assigned CANUs converting into PNUs.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

SDG&E has no feedback at this time but reserves the right to provide comments at a later date.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

SDG&E supports including an “Option B reform” discussion in Phase 2 of the Issue Paper to make it more feasible

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. SDGE recommends the following additions to the scope of issues:
   • • Charging Study (Phase I): CAISO study plan includes a section on charging study for each cluster, but the results are informational only.  With the extreme increase of Battery Energy Storage Systems in the queue (~83% of C14 applications in SDG&E study area).  CAISO should provide more guidance on how charging should be performed and include tariff language to how upgrades can be assessed and allocated to project to overloads/issued introduced by charging overloads.
     • Gen-Tie Sharing (Phase I):  Interconnection Customers (IC) are allowed to indicate Gen-Tie Sharing with an existing or proposed project with gen-tie to existing PTO substation, or to a proposed switchyard for earlier queued project, without being required to have approval to use that gen-tie by the existing gen-tie owner (GO).  There should be a requirement that IC’s obtain approval as part of their Interconnection Request (IR).  Additionally, existing generator(s)  should be notified of future interconnection requests that impact their project(s) or gen-tie configuration.  SDG&E experienced a situation where two proposed loop-ins to an existing gen-tie were proposed and went through both phases of the interconnection study before the GO was aware of any changes.
     • Stranded Cost Responsibility for IRNU Switchyards (Phase I): If an IC proposes to connect to a switchyard of an earlier queued project(s) that has executed a LGIA, the new IC does not have any cost responsibility or cost exposure related to the switchyard.  If the earlier queued project(s) terminates the LGIA, then the PTO is responsible for funding the switchyard.  There should be a mechanism for IRNU reallocations with associated cost responsibility and cost exposure assigned to later queued project(s).
     • RIMS Document Management (Phase I or Phase II): During IR validation period, RIMS is heavily used for files to be share between IC, CAISO and PTO.  The system does not categorize, group, version or organize the documents well.  RIMS needs enhancements or (if not already) use of more features to streamline the IR validation process.  After IR validation, ISO should be consistent in using RIMS for all documents, details, etc. related to the project.  Currently MMA requests, letters, etc. are not uploaded to RIMS.  CAISO, in efforts with CPUC, is seeking to be the central repository of all interconnection queue information.  If RIMS is supposed to be the system of use, then modifications are needed.
     • IR Validation Forms (Phase I):  Multiple items within the spreadsheet and Word doc need to be updated:  Primary Frequency response (static or dynamic), MW value at High Side Main Step-Up Transformer, updated to IR Validation tab for which items PTO is supposed to verify (remove Site Exclusivity, Signatory document), removal of ISD/COD achievable question from IR review. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

The Six Cities appreciate the comprehensive listing of potential issues identified by the CAISO in its Preliminary Issue Paper in this initiative and look forward to engaging with the CAISO and stakeholders on these topics as this stakeholder process moves forward.  At this time, the Six Cities’ comments are limited to several “Phase 2” items, although the Six Cities expect to provide comments on additional elements of this initiative as proposals become more definitive. 

The comments set forth below express the following preliminary positions:

• The CAISO should avoid adopting changes to its existing rules regarding reimbursement of network upgrades on the CAISO system that are needed because the CAISO is “affected” by generation that is interconnecting within a neighboring system, unless neighboring systems agree to provide reciprocal treatment.  (See generally Prelim. Issue Paper at § 4.1.)
• The Six Cities have concerns regarding the proposal to adopt an alternative cost allocation for network upgrades to a Participating Transmission Owner’s local (or low voltage) transmission system and do not support moving forward with consideration of changes at this time.  (Id.)
• To the extent that the CAISO engages in further stakeholder discussions or proceeds with development of proposals to address potential incentives for load-serving entities (“LSEs”) to engage in procurement of generation projects in areas where transmission has been built or is approved based on resource portfolios, the Six Cities reiterate that such incentives must not be limited to California Public Utilities Commission (“CPUC”) portfolios, but should be equally applicable to procurement by non-CPUC jurisdictional LSEs that are governed by other local regulatory authorities (“LRAs”). 

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

The Six Cities do not have comments on this section of the Preliminary Issue Paper. 

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

The Six Cities do not have comments on this section of the Preliminary Issue Paper. 

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

The Six Cities do not have comments on this section of the Preliminary Issue Paper. 

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

As described by the CAISO, it is receiving increasing numbers of requests to evaluate affected system impacts resulting from interconnecting resources on neighboring systems.  (See Prelim. Issue Paper at 8.)  In the event that affected system studies show that mitigations on the CAISO system are required, the CAISO asks whether CAISO ratepayers should reimburse the generator for the costs of network upgrades on the CAISO grid.

Based on information previously provided by the CAISO, neighboring systems do not provide reimbursement to resources interconnecting within the CAISO system for mitigation associated with addressing affected system impacts to their transmission systems.  (See 2021 Contract Management Enhancements Initiative, Issue Paper/Straw Proposal (Aug. 10, 2021) at 6 (explaining that “the CAISO proposes that Participating TOs will not reimburse external interconnection customers for network upgrades.  This practice is consistent with neighboring utilities’ practices for CAISO interconnection customers.) (emphasis added).)  The Six Cities are concerned that, if the CAISO revises its policy to provide for such reimbursements, CAISO ratepayers would be providing benefits to resources on neighboring systems that are not reciprocated by neighboring transmission providers.  It may be reasonable for the CAISO to consider changing its current policy to provide network upgrade reimbursement to such resources, but only if this policy change is likewise implemented by neighboring systems.  If the CAISO believes that a change in reimbursement policy is worth considering further, then the Six Cities urge the CAISO to work with neighbors to evaluate whether they are willing to make counter-part changes to their reimbursement policies. 

Second, the CAISO queries if its cost allocation for network upgrades to the local (or low voltage) transmission system should be revised so that reliability and local delivery network upgrades associated with generator interconnections that are deemed not to benefit the local Participating Transmission Owner would be recoverable via the regional (or “high voltage”) Transmission Access Charge (“TAC”).  (See Prelim. Issue Paper at 8.) 

As an initial matter, the Six Cities question how widespread the concern about the existing cost allocation really is.  (See id., asserting “ongoing concern” about this issue.)  More fundamentally, however, the Six Cities do not support singling out individual projects or network upgrades for broader cost allocation.  Doing so is likely to raise potentially complex and contentious questions about other segments of the low voltage transmission system and whether portions of the low voltage grid that may provide some benefits to customers taking service on high voltage facilities or that otherwise may support the high voltage system should also be eligible for a revised cost allocation.  It likewise raises questions about whether costs associated with portions of the existing low voltage system that are associated with existing resources should be subject to a revised allocation.  Finally, there also are legitimate considerations regarding the potential for cost shifts among customers in the various TAC areas.  For these reasons, the Six Cities do not support including this issue in this initiative.   

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

The CAISO asks whether it should incent LSE procurement in areas where transmission projects either have been developed or are approved based on CPUC resource portfolios.  (See Prelim. Issue Paper at 9.)  The CAISO explains that LSEs appear not to be procuring resources from the areas assumed in CPUC portfolios.  (Id.) 

The Six Cities acknowledge the CAISO’s concern and urge the CAISO to work with the CPUC to assess the reasons that resources are not being developed in accordance with the portfolio assumptions by the CPUC.  This discrepancy may imply a need for better alignment between portfolios that the CPUC adopts and the procurement processes by CPUC-jurisdictional LSEs over which the CPUC has oversight. 

As non-CPUC jurisdictional LSEs, however, the Six Cities reiterate that their procurement activities, like those of other municipal utilities in the CAISO, are not governed by CPUC procurement directives or portfolio decisions.  The Cities’ procurement policies are governed by their LRAs, including their City Councils.  As such, if the CAISO moves forward with its proposal to develop incentives for procurement that aligns with CPUC portfolios, it will be critical for the CAISO to ensure that it does not create incentives that are available only to CPUC-jurisdictional LSEs.  It also will be critical to ensure that the incentive structure does not undermine the independence and authority of other LRAs by attempting to shape non-CPUC jurisdictional LSEs’ procurement to more closely align with CPUC portfolios.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

The Six Cities do not have comments on this section of the Preliminary Issue Paper. 

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

The Six Cities do not have comments on this topic at this time. 

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

With respect to its Phase 1 proposals, SCE’s proposal to clarify responsibilities for increased costs due to errors/omissions is reasonable.  In circumstances where errors/omissions are attributable to interconnection customers, the Six Cities’ view is that transmission ratepayers should not indemnify interconnection customers for such errors/omissions, as could occur if the effects of interconnection customer-originated errors and omissions are not included in the Current Cost Responsibility, Maximum Cost Responsibility and/or Maximum Cost Exposure, as appropriate.   

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

The Six Cities concur with the Gridwell Consulting assertions that the existing interconnection queue is substantially oversubscribed.  There is value in assessing the proposals by Gridwell for improved data transparency and availability to inform the longer term proposals in this initiative, which should be geared around improvements to ensure that viable projects are able to move forward through the interconnection process expeditiously. 

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

The Six Cities do not have comments on the issues addressed in the LSA/SEIA presentation at this time. 

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

The Six Cities do not have additional comments at this time. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

Specifically and isolated to the QC14 “super cluster” if it is CAISO’s desire to weed out applications which are weak in foundation have the applicants require site control/ site exclusivity from the onset and remove the site control in-lieu of deposit option for all application for this cluster immediately or by YE 2021. This would result in a substantial amount of attrition in QC14 and will allow CAISO to reset it’s QC15 schedule by accepting applications again in April 2022 raSpecifically and isolated to the QC14 “super cluster” if it is CAISO’s desire to weed out applications which are weak in foundation have the applicants require site control/ site exclusivity from the onset and remove the site control in-lieu of deposit option for all application for this cluster immediately or by YE 2021. This would result in a substantial amount of attrition in QC14 and will allow CAISO to reset it’s QC15 schedule by accepting applications again in April 2022 rather than delaying QC15 another year.    

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

Arevia recognizes that the risks of 138kV upgrade costs being allocated to small PTOs like VEA creates a barrier to renewable buildout in good renewable areas such as Southern Nevada. Arevia strongly encourages the CAISO to work with stakeholders in this process to address how to resolve this issue and minimize these development risks/costs.

Arevia Power is one of the most active greenfield utility-scale renewable energy developers in Western U.S. with an active project pipeline in California, Nevada, Idaho, Utah and Arizona. In addition to Arevia’s experience in CAISO most notably and recently Arevia developed the largest solar and battery project in the country, the Gemini Solar Project which is a 690MW PV + 380MW BESS project located in Southern Nevada.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

SCE (Southern California Edison) appreciates the CAISO undertaking a further review of its interconnection process to identify potential enhancement opportunities and submits the comments below for the CAISO’s consideration in IPE 2021.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

• Removing downsizing window and simplifying downsizing request requirements

SCE generally supports removing the downsizing window and allowing downsizing requests to be submitted at any time, with the downsizing request evaluated via a Material Modification Analysis at that time.  Downsizing requests found to be “not material” would be reflected in future amendments.  Downsizing requests found to be “material” would not be permitted.  The impact of the downsizing requests evaluated throughout the year should be held by the CAISO for evaluation during the next reassessment study.

• Process for changes to network upgrade requirements after the second IFS posting

SCE supports addressing the topic of who the responsibility for increased interconnection costs falls to when an error or omission is discovered after the initial and the second postings have been made.  Beyond what is being contemplated in the Preliminary Issue Paper regarding Appendix DD Section 6.8, during the stakeholder webinar, SCE presented a proposal to overhaul the entire Section 6.8 to improve clarity.  SCE believes that Section 6.8 would benefit from a decision tree structure, as there are several paths a project can take, and these paths are not well described in the current Tariff. Among the items to be included in this “decision tree” structure are as follows:

•Is an error/omission that has been discovered considered “substantial”? (What happens if yes, what happens if no, etc.)

•What is the timing of the error/omission? Before or after IFS posted? (What happens if before, what happens if after, etc.)

•Does the error/omission require a change to CCR, MCR, and/or MCE and IFS posting?

•Does the error/omission require a revised study be issued?

•Does the error/omission reset the clock for the next IFS posting?

•Which party is ultimately responsible for the cost of upgrades as a result of the error/omission?

• Withdrawal option for projects impacted by new costs and/or delayed in-service date after initial posting

SCE supports the proposal to give a project which has received a new required upgrade or significantly modified upgrade after having made either its initial or second IFS posting that significantly increases the cost for the project to interconnect or significantly pushes back its earliest achievable in-service date, the option to either accept and move forward with the changes or withdraw and receive a full refund for its IFS and a refund of any unused study deposit.  SCE views this issue as having a direct relationship with the immediately preceding topic, as an “offramp” is one of the possible paths in the decision tree mentioned above.

• Clarify definition of Reliability Network Upgrade

SCE supports the CAISO providing additional clarity that any remedial action scheme (RAS) or other RNU that is identified in a deliverability study is categorized as an RNU and will impact the total RNU cost calculation for the RNU cost cap.

• Transferring PTO WDAT projects into CAISO queue

SCE supports the CAISO exploring how to transfer IRs between the WDAT and CAISO queues during the IR submittal process via a formalized process to be included in the CAISO Tariff. SCE acknowledges that in each cluster application window, CAISO receives a few projects that after further examination should have applied under WDAT (and vice versa).  SCE agrees that procedures need to be developed regarding appropriate communication and sharing of documents to make the overall intake of projects process more efficient.

• Changing sites and POIs during interconnection request validation

SCE supports the development of specific tariff criteria for changing proposed generating facility locations and their POIs during the cluster IR validation period.  This has seemingly been an area of abuse of process, if not outright gaming in the past.  SCE agrees that the development of criteria will improve transparency.  Beyond the threshold issue of whether a generating facility’s change in location and POI should be permitted, defining the scope of allowable changes to location and POI would be beneficial.  

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

•  Further adjustments to the QC 14 “supercluster” process for QC 14 and earlier clusters
  • When should site exclusivity documentation be required?

SCE supports requiring resource developers to demonstrate site exclusivity (no longer a deposit in lieu) to proceed into the Phase II study process.  SCE has experienced instances where different interconnection customers have projects on the same site, and this results in unrealistic studies.

• • Should equipment requirements be introduced?

SCE is ambivalent about establishing such a requirement.  However, requiring the project supplier demonstrate that the developer has a commitment for various key equipment required for the project to timely move forward, either at the IR stage or to enter Phase II, may potentially be a criterion to consider for deeming a “Ready” project (see next item).

• • Should an accelerated process for “Ready” projects be considered?

SCE believes prior to considering whether an accelerated process for “Ready” projects should be considered, there is a fundamental need to establish criteria to determine what constitutes readiness. SCE suggested during the stakeholder webinar that a smaller working group could be needed here to fully develop the “Ready” concept, with representation from the developer community, CAISO, and both the interconnection and procurement arms of the PTOs. Such an effort is needed because of the dramatic change from current rules/process, and high stakes given the resiliency/capacity needs for more generation and storage on the transmission system. 

From a technical perspective, “Ready” would have to at least mean there are no identified Short Circuit Duty issues and the “Ready” project would be the only project connecting to a particular system, with no needed RAS or CRASs or RNUs.  As an example, the concept of “Ready” would apply to sites with existing generation projects where minimal construction would be required.

• • Would different requirements for different technologies to advance in the interconnection process be appropriate?  Between location-specific resources versus more location-flexible?

SCE continues to support open access principles and as such, does not see a path forward to allow different requirements for different technologies in the interconnection process.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

• Should a one-time framework be adopted to allow resources such as storage to be added to existing sites on an expedited basis, despite potential impact on earlier-queued projects, to meet pressing reliability needs?

Rather than adopting yet another “one-time” framework, SCE’s preference would be to allow resources such as storage to be added through the MMA process on an ad hoc basis (this process already exists today). SCE would rather see the “Ready” concept be implemented ahead of giving preference to certain types of technology or locations of projects. The market continually changes, as do the costs of technology/equipment.  What might be “fast” today, might not be in the future. 

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

• Should higher fees, deposits, or other criteria be required for submitting an interconnection request

The bar for entry into the interconnection process should be raised to discourage numerous IR submissions by a single developer. It is clear to SCE that the current fee/deposit structure is insufficient to discourage outright speculative projects.

• Streamline interconnection studies

SCE agrees that due to the increased scope and complexity of the interconnection studies, the current timeline is not sufficient. SCE supports the CAISO developing a proposal for refining the Phase I, Phase II, and annual reassessment study timelines to allow sufficient time to complete the study work and enhance efficiency.  Additionally, SCE proposes the CAISO extend the application review timelines, and response time to the CAISO, for Cluster, ISP, and MMA applications from three business days to five business days.

• Policy for CAISO as an Affected System
  • How is the base case determined?

SCE supports the proposal to include additional tariff requirements around CAISO as an affected system studies to ensure consistency and minimize possible disruptions to customers in queue. The highest criticality is to ensure that these studies are being requested of the CAISO and that customers from other BAs provide the requisite project data that is already defined in the tariff and with adequate confidentiality provisions.

• • • How are the required upgrades paid?

SCE opposes the idea that California transmission ratepayers would provide network upgrades credits for projects interconnecting outside of the CAISO balancing authority that trigger upgrades to the CAISO system.  SCE agrees with the CAISO’s proposal regarding Affected Systems in its Contract Management “COMA” Enhancements Initiative Issue Paper / Straw Proposal issued August 10, 2021, that “Participating TOs will not reimburse external interconnection customers for network upgrades.  This practice is consistent with neighboring utilities’ practices for CAISO interconnection customers.” 

• Should the CAISO re-consider an alternative cost allocation treatment for network upgrades to local (below 200 kV) systems where the associated generation benefits more than, or other than, the customers within the service area of the PTO owning the facilities?

CAISO should not reconsider an alternative cost allocation treatment for network upgrades to local systems.  SCE does not believe that the current cost allocation recovery mechanism for generator interconnection driven upgrades in the CAISO’s Tariff is materially flawed but rather it has functioned, and continues to function, in a just and reasonable manner.  It would be inappropriate to shift costs from a transmission owner to other customers by allocating the costs of network upgrades to systems below 200 kV to the High Voltage TAC.

The 200 kV demarcation between high-voltage and low-voltage transmission facilities has been preserved in the CAISO Tariff and the TAC since CAISO proposed the two-tiered rate structure over two decades ago, after extensive stakeholder negotiation and compromise.  FERC endorsed this two-tiered rate structure as reasonable at that time[1].  Further, in its compliance filing for FERC Order 1000, the CAISO explained that its “existing transmission planning and cost allocation tariff provisions largely comply with the requirements of Order No. 1000”. 

As FERC stated in its Order Rejecting Tariff Amendments, issued September 1, 2017, in Docket Nos. ER17-1432-000 and ER17-1432-001, par. 33, “in the past, CAISO has justified its cost allocation methodology by explaining, with supporting evidence, that low-voltage facilities generally support local service and that the high-voltage transmission facilities perform a backbone function that supports regional flows of bulk energy”. SCE believes this continues to be the case. 

[1] California Independent System Operator Corporation, 91 FERC Par.61,205 at 61,722, 2000.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

• Should there be incentives for LSEs to procure generation projects at locations where the transmission capacity has been built /approved based on the CPUC portfolios?

SCE does not believe there is a need for additional incentives at this time for LSEs to procure generation projects at locations where the transmission capacity has been built/approved based on the CPUC portfolios.  Ease and cost of interconnection are largely already reflected in the bids that developers submit to LSEs’ solicitations.  Projects in areas where transmission capacity has already been built/approved will generally have lower bids than projects that require transmission upgrades and will thus already be selected through the competitive process.

 

• Should Transmission Plan Deliverability (TPD) allocation process revisions be considered?

SCE has no comment.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

Rather than pursue incorporating LSE decisions into the CAISO’s interconnection or transmission planning process, SCE recommends that the CAISO focus on providing timely information to developers and continuing to improve coordination with the CPUC and other state agencies in the IEPR, IRP, and TPP. The CAISO has an important role to play in resource planning by providing information regarding existing transmission capability and identifying policy-driven transmission projects based on the CPUC provided resource portfolios.

The eventual approval of policy-driven projects in the TPP will help reduce the volume and backlog of generation interconnection requests and contribute to system reliability by ensuring needed resources are built in a timely manner.  

SCE supports CAISO’s new 20-Year Transmission Outlook initiative and believes planning horizons must be expanded considering the current 10-plus year transmission development cycle.  Findings from this initiative must then inform the TPP to ensure long-term needs are considered in tandem with specific project approvals.  Specifically, SCE recommends that CAISO develop its transmission plan based on multiple scenarios (including the policy-driven sensitivity portfolios provided by the CPUC and the 20-year outlook) and focus on approving a least-regrets portfolio of projects that can spur the development of generation facilities and remove barriers to integrating renewable generation.
 

• • How can the interconnection process and incoming applications better align with procurement interest?

Procurement choices are typically driven by three items, whether the product procured is in line with regulator/customer expectations, project cost, and project online date. If developers know their costs and expected online dates, the procurement process should be able to choose those best fitting the need.

• How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?
  
  Recent procurement efforts have necessarily focused on new projects that could come online quickly because procurement authorizations by the CPUC have been issued on an emergency basis (e.g., D.19-11-016 for 2021-2023 procurement and D.21-06-035 for 2024-2026 procurement).  As such, projects must be far along in their development before they can realistically be contracted by an LSE.  The planning, interconnection, and procurement process could be significantly improved by:
  • Expanding the planning horizon and scope to identify transmission capacity that can either be approved as a policy-driven upgrade or on an expedited basis;
  • Increasing transparency to the planning process, expected timelines, and existing or expected transmission capability;
  • Development of a “first ready” construct in the interconnection process (but with reservations expressed elsewhere herein about how this “ready” concept is to be implemented).

• • Should interconnection application requirements differ for resources that are location constrained, versus resources like standalone batteries that can be located elsewhere on the grid?

No, interconnection application requirements should not differ for resources that are location constrained, versus resources like standalone batteries that can be located elsewhere on the grid.  Sufficient land in proximity to transmission is just as much a constraint on battery projects as PV or wind. 

• • Should a solicitation model be considered for some key locations and constraints not addressed in portfolio development, where commercial interest is the primary driver?

SCE does not support the concept of a solicitation model for transmission interconnection at this time.

• • While the tariff currently allows a project to achieve COD within 7 years if a project cannot prove that it is actually moving forward to permitting and construction, should the CAISO have the ability to terminate the GIA earlier than the 7-year period?

SCE supports the CAISO pursuing changes that would provide for termination of a GIA prior to a project achieving COD within seven years.  SCE has experienced projects remaining in the queue due to many reasons, sometimes to the detriment of delaying projects that are later in the queue but more viable (e.g., have a PPAs or are further along with permitting and/or financing).  CAISO should consider developing criteria to remove delayed projects from the queue in less than seven years, with an exception if the delay is due to an event not reasonably within the developer’s control (e.g., natural disaster or delays in permitting) and/or is subject to delays that would be experienced by any project seeking to build in the same jurisdiction.

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

SCE has no comment. 

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

In addition to the expansion/rework of Section 6.8 discussed in item #2 above, during the stakeholder webinar, SCE recommended three additional issues be addressed during this year’s IPE.

The three items include:

1, Seeking to add due dates for curing deficiencies in Appendix Bs, to avoid delays in starting Phase II studies

2. Seek to have the IR Validation process and “deemed complete” prior to holding Scoping Meetings (regular cluster, not supercluster procedures)

3. Addressing a real-world issue that came up with projects that share PTO Interconnection Facilities and related IRNUs across queue clusters, and how such sharing relates to the backstop financing requirements in Section 14.2.2 of the GIDAP.

SCE recommends making it explicit that if ICs agree to share a Generation Tie-Line, PTO Interconnection Facilities, and any related IRNUs (“shared IRNUs”) at the substation (e.g., line position to terminate the shared gen-tie) are shared with projects in a different queue cluster, and that any such “shared IRNUs” are included in an executed GIA, that is later withdrawn or terminated 1) that the backstop financing requirement in Section 14.2.2 will not apply to such “shared IRNUs” with the result that PTOs will not be required to backstop finance such “shared IRNUs” that are required for later-queued projects. The “shared IRNUs” will be treated as CANUs for later-queued projects and will not be treated as PNUs. In the case where the “shared IRNU” is a Stand-Alone Network Upgrade (e.g., Loop-In Substation), the backstop financing requirement in Section 14.2.2 will still apply.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

SCE supports Gridwell Consulting’s proposal to include the issue of increasing CAISO data “accessibility” for developers to have sufficient data to evaluate potential project interconnection sites.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

SCE supports the concept of seeking to avoid delays caused by PTOs implementing new or revised standards.  SCE supports discussing it within the IPE, because standards are usually surrounding maintaining the safety and reliability of the grid, therefore, there may be examples of upgrades that can be addressed following PTO (as suggested by LSA/SEIA) but others that cannot be postponed due to reliability concerns.  Hence, a discussion of all the issues by stakeholders would be beneficial to address SCE’s concerns in this area.

SCE understands LSA/SEIA concern about interim deliverability, but since that is a developer issue, SCE has no comment about whether interim deliverability needs to be addressed in IPE 2021.

SCE believes that the Network Upgrade “restacking” has been potential problem since the commencement of the cluster study process.  SCE sees this issue as an extension to the “first ready” concepts that CAISO wishes to develop.  This would be the case whenever later-queued, but “ready” resources are delayed by upgrades triggered by earlier-queued projects.  As such, SCE supports discussion about this issue in IPE 2021.

SCE believes that transferability of TPD is long overdue for further discussion by stakeholders.  Supports including this issue in IPE 2021.

SCE has no comment on the reassessment accommodation issue.

SCE has stated earlier in these comments about its concerns about shared IRNUs and the backstop financing requirement in Section 14.2.2 of the GIDAP.  LSA/SEIA seems to be advocating for more sharing of PTO Interconnection Facilities and IRNUs, which SCE supports due to its environmental and time-saving benefits.  Whatever becomes of this issue in IPE, SCE sees the potential for more projects sharing facilities in the future and thus wishes to reiterate here its recommendation on Section 14.2.2 in relation to such shared facilities.

SCE has no comment on the allocation barriers issue or the unfair allocation scheme issue, as these are largely developer issues.

SCE agrees with LSA/SEIA that Option B should be re-examined, because of the reluctance of developers to choose Option B, SCE wonders if it is really an option at all. 

SCE has no comment on the battery degradation issue, as it is a developer issue.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

SCE has no further comments.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

Changing Sites and POIs during IR Validation

Upstream supports allowing Interconnection Customers to modify their POI during the validation window but no later than five business days after the Scoping Meeting.  Doing so will minimize the number of speculative interconnection requests that are filed because Interconnection Customers will have the opportunity to modify their POI based on physical and deliverability feedback received from the CAISO and PTOs.  The current BPM provision of “one transmission line, county, etc..” is too loose of a physical boundary and the CAISO should only allow POI changes that are within the same PTO Study Area (for example, a project that files in the SCE Northern Study Area should only be allowed to move to another POI that is also within SCE Northern Study Area.  

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

When Should Site Exclusivity Documentation be Required?

Upstream supports requiring site exclusivity prior to the end of the queue cluster validation window to limit the number of speculative projects that enter the queue.  Unfortunately, raising the cost of the study deposit or other “barriers to entry” that have been discussed will likely have little impact on reducing the number of speculative projects.  Requiring that Interconnection Customers provide site exclusivity prior to the start of the Phase 1 Study is consistent with the current practice of MISO and other RTOs and prevents deep-pocketed developers from flooding the queue.

Should Equipment Requirements be Introduced?

Upstream opposes any form of equipment requirement at the IR stage or to enter Phase 2.  This unduly benefits large developers who enter into master supply agreements with equipment vendors and developers who are owned by an equipment manufacturer who will simply “point” to a purchase order or manufacturing slot to meet this requirement.  If provisions in the tariff aren’t black or white, then past experience has proven that developers will use these “grey” areas of interpretation to benefit their projects.
 

Should an Accelerated Process for “Ready” Projects be Considered?

Upstream opposes any new form of accelerated process for the following reasons…

1. The CAISO tariff already has two accelerated processes – the independent study process and the accelerated Phase 2 study.  Why does the CAISO need to introduce a third?
2. What would prevent developers from declaring their projects “Ready” which would essentially create a mini queue cluster of projects to be studied in parallel with the traditional queue cluster?  
3. The study process is typically not the long-lead item in terms of getting projects online – the build out of TPIF and RNU are the long lead items. 

Furthermore, how would the CAISO ensure that prior queued projects are not harmed by this “Ready” process which could potentially allow these projects to execute a GIA prior to QC13, QC14, and projects currently under study through ISP and Fast Track?

Would Different Requirements for Different Technologies to Advance in the Interconnection Process be Appropriate?

Upstream understands that the CAISO is trying to support new technologies such as offshore wind that have been impacted by existing generation like Diablo Canyon.  Rather than pick and choose winners and losers with respect to technology, the CAISO should explore removing Diablo Canyon from the reliability base case and providing results to QC14+ with the caveat that the results are conditioned on Diablo Canyon retiring on the dates currently filed.  The MCE and MCR amounts and the earliest achievable COD would be subject to change if the Diablo Canyon retirement dates were to change.

Upstream opposes any attempt to discriminate against one technology over another on a broad basis.  Developers should be allowed to deploy capital to development projects as they see fit.  This benefits the ratepayer because LSEs are presented with a number of different technologies when making procurement decisions.  

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

Should a One-Time Framework be Adopted to Allow Resources to be Added to Existing Site on an Expedited Basis?

Upstream strongly opposes a one-time framework that would allow anyone with an “existing site” to queue jump.  This unduly discriminates against earlier queued projects both with respect to reliability network upgrades and the allocation of deliverability.  

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

Should Higher Fees, Deposits, or Other Criteria be Required for Submitting an IR?

Unfortunately, higher fees or deposits will not deter interconnection customers from filing in the queue.  The CAISO should look to other RTOs like MISO who have solved their Supercluster issues by requiring site exclusivity prior to the start of the interconnection study. 

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Valley Electric Association, Inc. (“VEA”) appreciates the opportunity to comment on the Preliminary Issue Paper.  The CAISO Tariff currently allocates the costs of network upgrades for carbon free generators interconnecting with some low-voltage transmission facilities in a manner that violates FERC’s cost causation principles and causes inequitable results.  VEA requests that the CAISO implement a solution to this problem as part of this initiative.  VEA proposes several potential solutions which are detailed in the attached comments.    

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

The CAISO should address the cost allocation of network upgrades required to interconnect renewable and carbon free resources to low-voltage systems of Participating Transmission Owners (“PTOs”) who do not have a need for either the output of the renewable resources or the upgrades to the local network.  VEA provides a detailed discussion of this issue and potential solutions in the attached comments. 

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion:

Vistra appreciates the CAISO launching the Interconnection Process Enhancements effort to explore refinements that can be implemented by summer 2022 and facilitate timely exit from Cluster 14 as well as longer-term refinements that would apply starting in Cluster 15 and beyond. In the Issue Paper, the CAISO has floated a great deal of “issues”, that appear to be solutions, and questions that explore potential solutions. We encourage the CAISO to remain mindful of the specific issues that need to be addressed in this initiative, which should help the CAISO narrow in on which potential solutions it explored in this paper or new recommendations made through comments might be in its straw proposal.

Vistra recommends the CAISO include elements that address the following issues:

• Ensure interconnection requests needed to support near-term and mid-term reliability in CAISO BAA are not unnecessarily delayed due to the size of the queue.
• Ensure sufficient disincentives to mediate the number of speculative requests that developers submit to ensure that scarce CAISO and Participating Transmission Owner staffing resources are not unfairly employed on projects that have little to no intention to achieve commercial operations.
• Better serve developers that are trying to determine where to develop prospective projects so that they can identify feasible locations for these projects without clogging the common cluster.
• Support symmetry of information across Interconnection Customers and procurement arms of Load Serving Entities or the Central Procurement Entities by making the transmission and interconnection data more accessible so it can be better operationalized in development or procurement decisions.
• Ensure that existing sites that need to make enhancements to continue to sustain its operations at committed levels are not limited in doing so.
• Ensure that projects that are most ready to be developed at the time of the deliverability allocation are being appropriately allocated that deliverability.

In the remainder of our comments, Vistra responds to the items that the CAISO and other presenters raised for proposed enhancements. We appreciate the CAISO considering our feedback currently and we look forward to supporting these efforts as they progress.

2. Provide your organization’s comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 1, as described in section 3.1:

Vistra provides the following feedback on the elements the CAISO proposed in this section:

3. Provide your organization’s comments on further adjustments to the Cluster 14 “supercluster” process for Cluster 14 and earlier clusters, as described in section 3.2:

Vistra thanks the CAISO for bringing the question forwarded in Phase 1 of this effort that asks, “how can the CAISO better ensure interconnection requests needed to support near-term and mid-term reliability in CAISO BAA are not unnecessarily delayed due to the size of the queue”. Explore whether a “first ready, first served” framework should be adopted in the CAISO processes is a positive step and we encourage the CAISO to adopt this approach.

When Vistra proposes a “first ready, first served” framework this comes from our understanding of other markets providing a service that helps to provide the desired service to developers that submit speculative requests looking for the best location to site their project in a way that does not bog down or delay the study process for projects that intend to develop. Conceptually, these markets provide a “speculative study”. As we mentioned previously to CAISO, FERC approved transition of SPP to a “first-ready, first-served” approach in Southwest Power Pool, Inc., 128 FERC ¶ 61,114 (2009), where this approach would allow projects closer to development to proceed on a priority basis while still providing less-developed (more speculative) projects to receive results to inform its feasibility. It is our view that the benefit of this process is that the speculative projects can seek a service where the ISO/RTO performs a simplified study to provide indicative information to inform development decisions. In SPP’s framework, they provide two queues prior to the definitive queue that is the first required stage in its interconnection process best analogous to the CAISO’s existing processes. There is a feasibility queue and a preliminary queue.

The SPP FERC Order states, “optional feasibility study will provide information useful to determine whether it is economically and operationally feasible for a project to proceed…the optional preliminary system impact study—which is essentially the same in scope as the system impact study in the current interconnection procedures— serves as a tool to refine interconnection requests prior to entering the definitive queue.”[1] As far as timing goes, these optional queues that can provide the information to developers that indicate the best fit areas for development take in this process are completed within 90 and 180 days respectively after a queue window is closed. The definitive queue as SPP calls it, which can also be called the common or “first ready” queue, completes a system impact study within 120 days and a facilities study in an additional 90 days to be complete within 210 days. The definitive queue is studied in parallel because the first study is the same as that performed for the preliminary queue but only this queue proceeds to the facilities study. Vistra believes this framework is one that can be leveraged and refined to develop a CAISO-specific proposal.

We recommend the CAISO incorporate the following when it considers how to provide these indicative queue study processes that would be used for more speculative projects:

• Onus is on the Interconnection Customer to identify which queue and applicable study process that it wants to be studied under – an opt in approach.
  • Requests that are speculative in nature can request to only be studied in optional feasibility study.
  • Requests that are farther along than speculative but not ready for higher commitment can opt into the optional preliminary queue to perform the equivalent of today’s Phase 1 study results.
  • Requests that are ready for commercial development can proceed to the common queue and today’s study process bypassing the optional feasibility and preliminary queues.
• Provide incentives for more speculative projects to self-select its participation in the queue in the feasibility or preliminary study equivalents by introducing incentives such as lower fees or deposits to perform the indicative studies where the feasibility equivalent study would require the least investment, preliminary equivalent study would require medium investment, and the definitive equivalent study would require the highest level of investment.
• Queue positions are tiered by the choice selected by the Interconnection Customers where the projects receive positions chronologically within the tiers by:
  • Feasibility queue positions are subordinate to preliminary and definitive positions
  • Preliminary queue positions are above feasibility but below definitive positions
  • Definitive positions are afforded highest queue position tier
• Leverages the existing GIDAP timelines as basis for proposing timelines that:
  • Complete the common, SPP called definitive, queue sub-cluster interconnection procedures within today’s standard timelines for Phase II studies.
  • Complete the preliminary queue’s system impact study equivalent within today’s standard timeline Phase 1 studies.
  • Complete the feasibility queue’s simplified study equivalent within today’s standard timeline for no later than Phase 1 studies, but process wise the CAISO should publish these results as soon as practical to developers.
• TP Deliverability allocation procedures and reassessment would only apply to the definitive equivalent queue sub-cluster after Phase II studies are complete as done today.
• TP Deliverability allocation should prioritize allocations to projects based on project readiness factors for permitting and land access at least as high as the contract factors to ensure TP deliverability is being allocated to the most commercially viable projects.

[1] ORDER CONDITIONALLY ACCEPTING TARIFF REVISIONS ADDRESSING INTERCONNECTION QUEUE REFORM, Southwest Power Pool, Inc., 128 FERC ¶ 61,114 (2009), Paragraph 19.

4. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, as described in section 3.3:

Vistra raised questions on the CAISO stakeholder call that this effort sounds like an effort attempting to allow a one-time emergency generation interconnection fast track process to support California’s Emergency Reliability procurement directives to meet near-term reliability or to respond to the Governor’s July 30^th proclamation encouraging additional storage to brought online by summer 2022. We request the CAISO explicitly state that this is their intent.

While Vistra sympathizes with the CAISO desire to hold some type of process to help state preferred projects supporting near term reliability interconnect at existing sites in front of earlier queued projects, this would neither support open access and anti-queue-jumping rules nor is it in the best interest of California’s state goals. California has multiple reliability concerns that span not only the near-term for summer 2022 and summer 2023 but also out through 2025-2026 considering Diablo Canyon and non-compliant Once-through-Cooling retirements occur. Vistra cautions the CAISO against trying to fix the near-term 2022/2023 problem at the detriment of enabling California’s mid-term 2025/2026 problem. To potentially delay projects that are needed to support grid reliability in the mid-term horizon by allowing other projects to jump the queue is not prudent. Vistra recommends the CAISO focus its efforts in this project to minimize the risks of significant delays for Cluster 14 projects as a whole. This avoids any concerns with discriminatory or preferential treatment while furthering California’s near-term and mid-term goals simultaneously.

Further, Vistra also notes that in a parallel project, Contract Management Enhancements, CAISO is proposing to allow 100% storage conversion at existing sites. We believe these reforms will largely achieve through an existing Tariff mechanism the goal of allowing repowering or Material Modification of existing sites with battery energy storage while avoiding any question of inappropriate queue jumping.

5. Provide your organization's comments on the necessary enhancements or adjustments the ISO has become aware of since the 2018 IPE initiative that need to be addressed in Phase 2, as described in section 4.1:

CAISO Question: Should higher fees, deposits, or other criteria be required for submitting an IR?

Vistra generally supports scope items that are designed to disincentivize speculative interconnection requests absent of a separate study process for speculative requests under a “first ready, first served” framework. Even under a “first ready, first served” framework it is possible that additional disincentives might still be needed. We encourage the CAISO to benchmark the fees, deposits, and refunds provided under interconnection procedures in other markets, including focus on which organized markets have a “first ready, first served” approach or not. This information may better help stakeholders evaluate whether any changes are needed especially if a “first ready, first served” framework is developed. Our sense is that the most effective changes to consider will be refinements to the CAISO’s refund policies.

CAISO Question: Should it streamline interconnection studies?

Vistra supports streamlining and increasing efficiency of the study process if these enhancements continue to allow the CAISO to process normal cluster projects within the standard two-year cycle.

CAISO Question: Policy for CAISO as an Affected System – how is the base case determined and how are the required upgrades paid for?

Vistra supports this issue being included in scope of this effort but does not provide a recommendation. We reserve the right to do so after the straw proposal if this scope is included.

CAISO Question: Should the CAISO re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the PTO owning the facilities?

Vistra sympathizes with the problem statement. Some of the sticky policy questions that should inform this issue are being addressed in the Federal Energy Regulatory Commission’s Advanced Notice of Proposed Rulemaking. The FERC is asking questions about how to appropriately identify and allocate transmission costs so that costs are allocated to beneficiaries in a manner that aligned with estimated benefits. However, identifying who benefits from local transmission generation is a difficult question and slippery slope since one could start to argue that all local generation supports system reliability so the entire system should pay a share of the costs. However, generally the local generation is being built for local reliability purposes to serve the local needs on that system. Vistra encourages the CAISO to keep this issue in scope of Phase 2 but wait to explore potential solutions until the federal policy discussions that may help to highlight how the cost-benefit and cost-allocation principles will evolve for transmission upgrades is firmed up to avoid uncertainty with dual policy efforts.

6. Provide your organization’s comments on the General interconnection issues to be addressed in Phase 2, as described in section 4.2:

CAISO Question: Should there be incentives for load serving entities to procure generation projects at locations where transmission capacity has been built/approved based on the California Public Utilities Commission (CPUC) portfolios?

Vistra appreciates the concern being raised by the CAISO that it is observing interconnection requests being submitted into the interconnection process that are at substations with insufficient available transmission capacity instead of at substations with unlocked transmission headroom through previously approved transmission upgrades. The CAISO poses the question on whether there should be additional incentives for Load Serving Entities to procure projects at locations that transmission capacity is already available.

Vistra strongly believes the incentives for the Interconnection Customer to site its project at substations with available transmission is already present, because by doing so this makes our project more cost competitive in any Load Serving Entity’s competitive solicitations. We also think the incentives are largely there for the Load Serving Entities as well to attempt to procure set of generation that is best fit for its ratepayers. It is possible that a project’s costs are cost competitive even with the expected upgrade costs included in the offer and in that case, the Load Serving Entity selecting the offer to execute a contract with is rationale.

We believe the CAISO should be asking a different set of questions:

• How does the CAISO mitigate the risk that Interconnection Customers submit interconnection requests at locations on the system that would trigger significant upgrade costs?
• How does the CAISO better ensure that Load Serving Entity’s understand the implication of the offers potential impact to the transmission system when it evaluates offers in its competitive solicitation process?

We believe the answer is the same – more transparent and accessible data be provided.

While the CAISO Transmission Capability Estimate report is interesting especially for entities that closely follow the transmission system development through the Transmission Planning Process, it does not seem especially operationalizable for Load Serving Entities’ procurement arms. For this information to be accessible and easily used, Vistra suggests the CAISO provide an additional table that maps each transmission constraint to the specific substations with estimated Full Capacity Deliverability Study amounts.

Further, Vistra encourages the CAISO to file in the next portfolio development phase of the Integrated Resource Planning process asking the California Public Utility Commission to require the Load Serving Entities’ competitive solicitation process include estimated Full Capacity Deliverability amounts per substations available as a qualitative factor. We suggest this is best as a qualitative factor because as we provided an example above, it is possible that in aggregate across quantitative and qualitative factors that a project at a substation other than one of those identified by the CAISO may provide greater net value even with additional upgrade costs. By including as a qualitative factor, the explicit consideration of this data can be ensured providing more certainty that its consideration is being incorporated in procurement value assessments.

CAISO Question: Should Transmission Plan Deliverability (TPD) Allocation process revisions be considered?

On the CAISO’s other question on changes to Transmission Plan Deliverability allocation, Vistra does not support the CAISO allocating this deliverability to Load Serving Entities. This could introduce a great deal of confusion commercially if the deliverability is tied to a specific contract owned by the counterparty instead of the resource. A resource owner would potentially be restricted in options to toll or sell its resource if it is not the owner and holder of the deliverability associated with the project. We do not think this will pass the due no harm test and believe this would be likely to raise unjust and unreasonable concerns.

Vistra does believe the general question of whether TPD allocation rules should be revisited is a valid one. We believe that project readiness criteria for permitting progress, land access, and ability to use underutilized transmission elements are equally as important to the allocation of deliverability as the project’s contract status. By stopping the practice of providing deliverability allocation priority to projects with contracts and considering the other important readiness factors, we believe the CAISO may also be able to achieve some of its goals to explore how to better inform procurement decisions to reflect existing or planned transmission capacity. Vistra proposes that these factors points should apply first in addition to the points associated with contract status:

• Project location at a substation/Point of Interconnection with available headroom that the CAISO has identified as supporting state procurement portfolios,
• Progress on permitting approvals, and importantly
• Demonstration of site exclusivity.

A more effective process would weight these factors based on importance and determine a weighted score for each project and then allocate deliverability in order of highest weighted score to lowest weighted score.

7. Provide your organization’s comments on the broader issues that warrant discussion given existing supply conditions and the need to accelerate and sustain the pace of resource procurement and interconnection, the ISO is seeking stakeholder input on, as described in section 4.3:

CAISO Question: How can the interconnection process and incoming applications better align with procurement interest?

Vistra requests additional information from the CAISO on how the interconnection process and requests are misaligned with procurement interest. Our perspective is that the magnitude of interconnection requests is not inconsistent with the incremental generation, including battery energy storage, needs to meet near-term and mid-term reliability.

CAISO Question: How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?

See Vistra’s response to the same, or similar, question above to Section 4.2’s questions on whether there should be incentives for load serving entities to procure generation projects at locations identified by the CAISO as having available transmission capacity.

CAISO Question: Should interconnection application requirements differ for resources that are location constrained, versus resources like standalone batteries that can be located elsewhere on the grid?

No. See Vistra’s response to the same, or similar, question above to Section 3.2.

CAISO Question: Should a solicitation model be considered for some key locations and constraints not addressed in portfolio development, where commercial interest is the primary driver?

Vistra asks the CAISO to clarify whether it is suggesting the CAISO administer its own long-term competitive solicitation process. There is a historical precedent for the CAISO administering solicitations through the Local Area Reliability Services annual solicitation but that was prior to local Resource Adequacy requirements that negated the need for the CAISO solicitation. Vistra requests the CAISO provide a great deal more information on the specific types of constraints that it believes are introducing reliability risks by using the approved Transmission Planning Process proposals? It might be that a more effective solution will be to ensure the constraint or driver is being more fully considered in developing these portfolios rather than a CAISO run solicitation process.

To the extent CAISO is considering an open season for interconnection capacity, Vistra believes such a reform has promise if developed appropriately. In our comments to FERC’s ANOPR on transmission and interconnection reforms, Vistra suggested FERC consider using an open season process to develop transmission to areas of high commercial interest. At a high-level, such a process could be modeled on the open seasons used by merchant transmission developers. FERC has provided a set of criteria by which open seasons for merchant transmission could be conducted that can be adapted to support transmission developments needed to support new interconnections.^[1] CAISO or a transmission developer could identify a project or set of projects that would support new interconnections in a particular area. If a transmission developer had the lead time to identify projects, CAISO could support the identification of areas of high commercial interest.  CAISO or the transmission developer could then hold an open season in which new interconnection customers would express an interest. If the transmission project were under-subscribed, CAISO or the transmission developer could consider downsizing the project. If the transmission project is over-subscribed, CAISO or the transmission developer could consider up-sizing the project. Priority access would be based on criteria similar to those articulated in the Merchant Transmission Policy Statement, including willingness to pay, commercial readiness, and financial strength. Non-discriminatory, transparent selection criteria would provide greater certainty of priority to the projects most likely to reach commercial operation.

CAISO Question: While the tariff currently allows a project to achieve its COD within seven (7) years if a project cannot prove that it is actually moving forward to permitting and construction, should the CAISO have the ability to terminate the GIA earlier than the seven year period?

Vistra sympathizes with the nature of this question posed by the CAISO. However, we believe additional analysis is needed. This timeline is intended to ensure that the Interconnection Customer is moving expeditiously towards commercial operations. Our concern is that the development timelines for projects that add additional years after executing a Generator Interconnection Agreement largely are the result of the extended lead times needed for the Participating Transmission Owners to complete the necessary work prior to its interconnection. We request the CAISO further analyze whether our hypothesis is accurate or whether the question is designed to get at a specific behavior pattern in Interconnection Customers and provide that detail in its next iteration.

[1]      Allocation of Capacity on New Merchant Transmission Projects and New Cost-Based, Participant-Funded Transmission Projects; Priority Rights to New Participant-Funded Transmission, Final Policy Statement, 142 FERC ¶ 61,038 (2013) (“Merchant Transmission Policy Statement”).

8. Provide your organization’s comments on specific changes that are needed to any of the above mentioned topics, including specific recommendations or proposals on new or revised methodology:

None currently.

9. Provide your organization’s feedback on the scope of issues presented by Southern California Edison during the October 19, 2021 stakeholder workshop:

Vistra supports SCE’s request to also explore how errors and omissions discovered before initial and second interconnection financial security posting impact cost responsibility on Interconnection Customer or Participating Transmission Owner. Our initial impression is that the other scope items proposed appear straight forward and narrow in scope, which could be addressed in Phase 1 rather than Phase 2. We also support these proposed issues be explored with a target for Phase 1 completion.

10. Provide your organization’s feedback on the scope of issues presented by Gridwell Consulting during the October 19, 2021 stakeholder workshop:

Vistra strongly supports Gridwell’s proposal asking the CAISO to increase data accessibility. We further ask that the concept of a primary key be adopted across the CAISO, CPUC, and CEC for all transmission and interconnection data tables. We request the CAISO focus on improving access to its data accessibility for now and then pursue long term enhancements to ensure transmission and interconnection data being published across agencies is compatible and accessible.

11. Provide your organization’s feedback on the scope of issues presented by LSA/SEIA during the October 19, 2021 stakeholder workshop:

Vistra supports some of the issues brought forward by LSA/SEIA especially:

• Ensure that existing battery energy storage is not delayed in augmenting its site to ensure it maintains its contracted obligation by allowing it to be approved without treating it as a material modification assessment or at a minimum requiring a Tariff deadline for approving any Material Modification Assessment.
• Delays caused by new standards should not unnecessarily delay ready projects.
• Upgrade durations assigned to earlier or later queued projects are not optimal to effectively support successful exit from the queue to achieve the target commercial operations date.
• Addressing a concern that projects less able to achieve commercial operations are holding onto their TPD allocation, restricting viable projects from more quickly exiting the queue.
• Allowing an additional TPD allocation/retention cycle where the reassessment results include significant changes.
• Capacity sharing Interconnection Facilities (IFs) and IRNUs with existing projects should be a factor in the TPD allocation.
• New projects should not get priority for TPD allocations over projects already in the queue, even when both are similarly situated and qualified.
• Explore additional options to Option A and Option B that might provide way to fund new ADNUs in areas of high commercial interest that are less punitive.

12. Additional comments on the IPE 2021 preliminary issue paper and October 19, 2021 stakeholder workshop discussion: