Comments on Queue Management Draft Tariff Language

1. Please submit your organization's comments on the Interconnection Process Enhancements 2023 Track 2 Queue Management Draft Tariff Language

Comments and markups have been included in the attached file, and summarized briefly below:

Section 11.3.2.6

1. IC's triggering commencment of Shared NUs should be able to do so via an executed GIA or E&P Agreement. Pursuant to the stakeholder calls (see dialogue starting at 5:36:20 of the April 4, 2024 IPE Track 2: Final Proposal call), CAISO indicated that their intention is to trigger as soon as work commences on a Shared NU. Considering work can commence under either an E&P Agreement or a GIA this language should be adjusted accordingly.
2. The CAISO's Final Proposal contemplated ninety (90) days from notification that the third posting for a Shared NU is required to execution of the E&P Agreement / GIA and third posting submission. However, the proposed Tariff language reflects one hundred twenty (120) days, and should be revised back down to the ninety (90) days as proposed.

1. Please submit your organization's comments on the Interconnection Process Enhancements 2023 Track 2 Queue Management Draft Tariff Language

Please the attached redline with LSA's comments.

1. Please submit your organization's comments on the Interconnection Process Enhancements 2023 Track 2 Queue Management Draft Tariff Language

Please see attached.

1. Please submit your organization's comments on the Interconnection Process Enhancements 2023 Track 2 Queue Management Draft Tariff Language

SDG&E views CAISO's final IPE proposal as a positive development that would help streamline our interconnection process. It was the culmination of years of work and stakeholder collaboration. Therefore, SDG&E encourages CAISO to implement the final IPE proposal for Track 2 in its entirety, without veering from those requirements. This proposal was approved by the CAISO board and reviewed by FERC as an attachment in CAISO's Track 2 filing. For example the Time in Queue requirements, Shared Network Upgrades, LOS and other provisions all received the extensive review summarized above and SDG&E encourages CAISO not to diminish the body of work by implementing a different set of requirements.

1. Please submit your organization's comments on the Interconnection Process Enhancements 2023 Track 2 Queue Management Draft Tariff Language

Please see the attached file. SCE has provided comments directly on the CAISO's draft tariff language document.