Comments on Draft Tariff Language

1. Please provide your organization's comments on the Track 3 draft tariff language

ACP-California appreciates CAISO’s draft tariff language for this portion of the IPE Track3 Final Proposal. As indicated in the attached comments on the tariff language, ACP-California does not believe that certain portions of the proposed tariff language are appropriate for the tariff because they do not affect the rates, terms and conditions of service by CAISO. Instead, we recommend including these components, which are primarily aimed at providing additional transparency on an existing CAISO process that is already in the tariff, into a Business Practice Manual. Additionally, ACP-California is concerned that the tariff language is in conflict with the IPE Track 3 Final Proposal by not providing an avenue for the reservation of capacity on the existing system, due to limiting reservations to the “lower of” the amount of deliverable long lead-time resources and the capacity created by Category 1 policy-driven solutions. The tariff language (which we recommend move to a BPM) needs to be adjusted to account for the reservation of capacity on the existing system, consistent with the Final Proposal. The Final Proposal (on page 52) included a footnote that clarifies that "the transmission capacity created by the transmission plan upgrades for the specific long lead-time public policy requirement" "may include the use of existing transmission and upgrades” and this should be included in the BPM.

1. Please provide your organization's comments on the Track 3 draft tariff language

Clearway appreciates the CAISO advancing tariff language for the new Reliability Network Upgrade Prioritization process. This is an important initiative that will help accelerate generator interconnection in the context of frequent delays and uncertainty in network upgrade timelines.

Clearway requests that the CAISO modify the tariff language or provide flexibility in interpretation of the tariff language related to LGIA execution, in light of severe delays in the LGIA tendering and execution process for Cluster 14 projects. Certain projects in Cluster 14 have requested PTOs to tender the LGIA and have been waiting for more than 8 months. For two of Clearway’s projects, the PTO has indicated that it will take more than a year from the initial request to tender the LGIA for execution. PTOs have explained these delays in tendering LGIAs by pointing to lack of adequate contracting resources. The extent of these LGIA execution delays was not known when the RNU prioritization concept was initially developed in IPE Track 3.

Had these LGIAs been tendered and negotiated on time, these Cluster 14 projects would by now be well-situated to execute the GIA and meet other posting status criteria described in Section 16.3 of the draft tariff language. Cluster 14 projects that have requested PTOs to tender LGIAs on time and yet not received draft LGIAs are now at risk of not being able to score points in the RNU prioritization process that they should qualify for, through no fault of the developers. Clearway strongly recommends CAISO modify the tariff language to provide the ability to claim certain GIA and posting status points to projects that have timely requested LGIAs and can commit to meeting the other criteria for points in this category as soon as an LGIA is tendered by the PTO.

Clearway proposes the following tariff revision to address this concern:

16.3 (3)(a)

The Interconnection Customer has an executed GIA, has provided the Participating TO a notice to proceed to construction, and has provided its final Interconnection Financial Security or equivalent financing to the Participating TO, as agreed in its GIA, [or the Interconnection Customer requested a GIA prior to September 1, 2024, that has not been tendered yet, and has provided its final Interconnection Financial Security or equivalent financing to the Participating TO.]

16.3(3)(c)

The Interconnection Customer has an executed GIA[, or requested a GIA prior to September 1, 2024, that has not been tendered yet,] or its GIA has been filed with FERC unexecuted and is still pending before or approved by FERC.

1. Please provide your organization's comments on the Track 3 draft tariff language

Please see attached marked up Draft Tariff Document.

1. Please provide your organization's comments on the Track 3 draft tariff language

Please see attached mark-up (LSA comments in green highlight).

1. Please provide your organization's comments on the Track 3 draft tariff language

Please find below NCPA's comments on seelct Track 3 draft tariff language:

Section 24.4.6.6 - Policy-Driven Transmission Solutions

Once the CAISO has identified reliability-driven solutions, LCRIF projects eligible for conditional or final approval, solutions needed to maintain long-term CRR feasibility, qualified Merchant Transmission Facilities, needed LGIP Network Upgrades as described in Section 24.4.6.5, and Subscriber Participating TO transmission facilities as well as generation facilities seeking to interconnect to the CAISO Controlled Grid on Subscriber Participating TO transmission facilities, the CAISO shall evaluate transmission solutions needed to meet state, municipal, county or federal policy requirements or directives as specified in the Study Plan pursuant to Section 24.3.2(i).  Policy-driven transmission solutions will be either Category 1 or Category 2 transmission solutions.  Category 1 transmission solutions are those which under the criteria of this section are found to be needed and are recommended for approval as part of the comprehensive Transmission Plan in the current cycle.  Category 2 transmission solutions are those that could be needed to achieve state, municipal, county or federal policy requirements or directives but have not been found to be needed in the current planning cycle based on the criteria set forth in this section.  The CAISO will determine the need for, and identify such policy-driven transmission solutions that efficiently and effectively meet applicable policies under alternative resource location and integration assumptions and scenarios, while mitigating the risk of stranded investment.  The CAISO will create a baseline scenario reflecting the assumptions about resource locations that are most likely to occur and one or more reasonable stress scenarios that will be compared to the baseline scenario.  Any transmission solutions that are in the baseline scenario and at least a significant percentage of the stress scenarios may be Category 1 transmission solutions.  Consistent with the state or federal, municipal or county requirements or directives underlying the Category 1 transmission solution, the Transmission Plan will specify the busbar location where the CAISO will reserve the transmission capacity created by a Category 1 transmission plan for certain long lead-time resources and the amount of any such reservation.  The Transmission Plan will specify criteria for eligible resources, including at a minimum, but without limitation: location, MW capacity, generating technology, and expected in-service date.  The CAISO will provide each Local Regulatory Authority the opportunity to review the proposed eligibility criteria for long lead-time resources and to provide the CAISO with a more explicit list of qualifying resources. Each Transmission Plan may modify these criteria for policy-driven transmission solutions as needed to meet state or federal, municipal or county requirements or directives.