1.
Please provide your organization’s comments on section A. Transmission Service to eligible customers on Behalf of Large Loads.
a. Please provide comments on the definition of large loads.
b. Please provide comments on the large load application process and interconnection study procedures.
c. Please provide comments on the large load operational requirements.
d. Please provide your comments on the large load service agreements.
e. Please provide any other comments on this topic.
Pacific Gas and Electric Company (“PG&E”) respectfully submits these comments on the California Independent System Operator Corporation’s (“CAISO”) Large Load Enhancements Draft Final Proposal issued September 17, 2026 (“LLE Proposal”). PG&E submits these comments as both a Participating Transmission Owner (“PTO”) named as a respondent in the June 18, 2026 Order to Show Cause[1] issued by the Federal Energy Regulatory Commission (“FERC” or “Commission”) and a Utility Distribution Company (“UDC”) that serves as the primary interface for Large Loads seeking to interconnect within its PTO Service Territory.[2]
PG&E continues to generally support the LLE Proposal and to commend the CAISO for advancing a framework that responds to the Commission’s directives while maintaining the established division of responsibilities between the CAISO and the PTOs. PG&E recognizes the urgent need for solutions that enable Large Load interconnection while maintaining grid affordability and reliability. However, CAISO’s proposed definition of “Large Load” remains problematic. The CAISO’s final proposed definition fails to address the substantive concerns raised by PG&E in its comments on CAISO’s prior Straw Proposal. In doing so, CAISO proposes a final definition that is fundamentally inconsistent with the Order to Show Cause and will result in few, if any, large loads in the CAISO region meeting the definition. If the CAISO proposed definition is left unchanged, it could result in rejection by FERC and could result in FERC imposing a new definition that does not reflect the unique characteristics of the CAISO region, making it unworkable and causing significant disruption to the CAISO markets.
In Section I.A. of the LLE Proposal, the CAISO responds to the first set of concerns in the OSC—the definition of Large Load, the application process, study procedures, operational requirements, and Large Load service agreements. The LLE Proposal adopts a structure under which PTOs directly interact with Large Loads (i.e., End Users), as if such Large Load customers were “interconnection customers” of the PTO. This structure is fundamentally flawed and inconsistent with the actual intent and requirements of the OSC. CAISO’s proposed structure is founded on the erroneous view that Large Load customers today directly interconnect to the CAISO system and enter interconnection agreements with PTOs. It also assumes that the relationship between PTOs and End Use customers is the focus of the OSC. The OSC, however, is carefully and specifically directed at three entities—the CAISO, the PTOs in the CAISO, and Eligible Customers who provide transmission service to End Use Load, including Large Loads, in the CAISO Balancing Authority Area (“BAA”). All three entities are unquestionably regulated by FERC. And the OSC’s purpose is to require that CAISO and the PTOs have proper procedures in place for transmission service taken by Eligible Customers to serve Large Loads to ensure that service is safe and reliable and protects other customers from cost shifts. Thus, CAISO should clarify that any reference to “Large Load interconnections” in the LLE Proposal is referencing interconnections of Eligible Customers, who in CAISO are referred to as MSS and UDCs, providing interconnection and transmission service to a Large Load.[3]
Before addressing the CAISO’s specific topics, in light of the discussion above, PG&E emphasizes the importance of distinguishing among the various types of entities involved in providing transmission service in the long-standing CAISO structure, which the CAISO clearly does not want to alter.[4] The primary entities relevant to the OSC and thus to the CAISO’s LLE Proposal, aside from the CAISO, should be PTOs and the two sets of “Eligible Customers” in the CAISO BAA that are responsible for obtaining and paying the CAISO for in-BAA transmission service—UDCs and Metered Subsystems (“MSS”). UDCs/MSSs are responsible for interconnecting and providing transmission service to their retail customers, including Large Load retail customers in the BAA.[5]
According to the LLE Proposal, “[t]he CAISO tariff does not use Eligible Customer, and introducing it here could require other changes to the CAISO tariff.”[6] PG&E recognizes that CAISO has not traditionally used the term Eligible Customer in the same manner that the OSC uses the term.[7] PG&E thus has no objection to the CAISO using an alternate term for Eligible Customer (e.g., “UDC/MSS” or “TAC Customer”) in the CAISO Tariff, but it is crucial that CAISO ensure that its proposed definition of Large Load customers actually captures the intent and purpose of the OSC.
a. Please provide comments on the definition of Large Loads.
Background
The scope of the definition of Large Load is fundamental to whether CAISO will satisfy the requirements of the OSC and assist FERC in achieving its goals. If the definition remains limited, the result will be a set of CAISO Large Load enhancements that are inapplicable in scope. Indeed, as discussed below, if the current proposed definition is adopted, there are not and will never be Large Loads in a UDC Service Area. Thus, the CAISO definition is inconsistent with the objectives of the OSC and California state law. PG&E is also concerned the definition is unreasonable and will be rejected by FERC, will result in legal disputes, or both.
The CAISO proposed definition, which the CAISO portrays as non-final,[8] reads: “An End User located at a single site whose Point(s) of Interconnection is/are to the CAISO-Controlled Grid, and that has a peak load of 50 MW or greater.” There are two primary flaws in this definition. First, Large Loads, i.e., End Users, do not connect directly to the CAISO Controlled Grid at a Point of Interconnection but rather connect to intervening facilities that connect to Points of Withdrawal (Points of Delivery) at the CAISO Controlled Grid. Second, the CAISO interprets its definition to exclude Large Loads connected to a UDC’s or MSS’s local distribution facilities, which renders the LLE Proposal an incomplete approach to addressing FERC’s concerns.[9]
Although the CAISO claims to address PG&E’s point that Large Loads do not connect directly to the CAISO Controlled Grid, it demonstrates that PG&E is correct by redefining Interconnection Facilities in Appendix A to describe the intervening facilities. Nonetheless, the CAISO claims that PG&E’s definition “creates additional ambiguity because it seems to include intervening assets that may be first connected to the distribution system.” To be clear, PG&E’s proposed definition of Large Load would include Large Load connected to the CAISO Controlled Grid via intervening assets for the simple reason that such intervening assets always exist between the Large Load-owned facilities and the CAISO Controlled Grid. The OSC recognizes this fact by focusing on regulating “transmission service to Eligible Customers on behalf of Large Loads” rather than the interconnection of Large Loads directly to the transmission system.[10]
The CAISO’s concern with clarifying the fact that the Large Load connections are in fact “indirect” appears to be directly related to the second flaw in the definition. The CAISO believes it problematic that PG&E’s proposal would include within the scope of Large Load distribution-connected and non-PTO connected loads within the CAISO BAA. The CAISO argues that if such Large Loads cause network upgrades, they should be considered in the CAISO transmission planning process but not subject to the OSC.[11] This approach is unworkable. The focus of the OSC is addressing the lack of process and procedure in the CAISO and TO Tariffs for studying and providing transmission service for Eligible Customers on behalf of Large Loads.[12] Eligible Customers take transmission service on behalf of Large Loads even if the loads are attached to UDC distribution facilities. The OSC recognizes that states have jurisdiction over sales to end users and FERC has jurisdiction over transmission service taken by Eligible Customers to serve those end use customers. The transmission service taken by Eligible Customers on behalf of Large Loads plainly affects FERC-jurisdictional transmission and transmission rates. Under the CAISO’s interpretation, the CAISO would not be allowed to engage in transmission planning to serve the vast majority of (distribution connected) load in its BAA.
The OSC Does Not Focus On The Interconnection Of Large Load to FERC-Jurisdictional Transmission Facilities
A root cause of the CAISO’s refusal to acknowledge PG&E’s argument and the proper scope of the OSC requirements is CAISO’s flawed belief that the OSC is focused on and limited to the direct interconnections of Large Loads to transmission facilities. The CAISO claims that the OSC is premised on FERC’s duty to remedy the potential for undue discrimination in transmission access by regulating interconnections to the transmission system, not the distribution system, which the CAISO claims is left to the states. The CAISO states that the “CAISO may not assert substantial rules on distribution-connected loads for the same reason that FERC has not asserted rules on them: distribution-connected retail customers are not jurisdictional to FERC under the Federal Power Act.”[13] This is simply not true. The OSC requires CAISO and the PTOs to address PTOs interconnecting Eligible Customers so that they can take transmission service for Large Loads.
CAISO also relies on a flawed analysis that the intervening facilities between a Large Load and the CAISO Controlled Grid are FERC-jurisdictional “Interconnection Facilities,” and can be treated the same as FERC-jurisdictional transmission facilities in the generation interconnection context. Indeed, for the CAISO to make its Large Load definition workable, it had to alter the definition of both “Point of Interconnection (‘POI’)” and “Interconnection Facilities.” The CAISO Tariff-defined term POI currently relates only to Generating Facilities.[14] The CAISO seeks to supplement this definition by adding that “[f]or a Large Load, the Point of Interconnection is the point at which the Large Load Interconnection Facilities connect to the CAISO Controlled Grid.”[15] Then, as already noted, the CAISO redefines “Interconnection Facilities” to include “all facilities and equipment between the … Large Load and the Point of Interconnection” and to exclude Distribution Upgrades. The CAISO facially is trying to turn “intervening facilities” into FERC-jurisdictional Interconnection Facilities to support its jurisdictional interpretation.
By using the newly defined term Interconnection Facilities, the CAISO is equating state/local-jurisdictional facilities between a Large Load and the CAISO Controlled Grid with the FERC-jurisdictional facilities between a Generator and the CAISO Controlled Grid. California Public Utilities Code § 399.2(d) defines “electric distribution grid” as “those facilities owned or operated by an electrical corporation that are not under the control of the [CAISO] and that are used to transmit, deliver, or furnish electricity for light, heat, or power.” The intervening facilities between a Large Load and the CAISO Controlled Grid are used only for retail transmission service. Therefore, if the CAISO is concerned that it has no jurisdiction with regard to Large Loads connected to distribution facilities, that same exact problem exists as to all Large Loads. For this reason, FERC’s assertion of jurisdiction in the OSC does not rest on Large Loads connecting directly to CAISO-controlled FERC-jurisdictional facilities, which they do not. Rather, FERC jurisdiction rests on the transmission service that the Eligible Customer is going to purchase at a Point of Withdrawal.
The OSC Rests Jurisdiction on Transmission Service Taken by Eligible Customers
The CAISO admits on page 58 that “transmission service will [] continue to be assumed through an interconnection request.” PG&E agrees with this notion that when a new retail Load seeks to interconnect or a load-serving distribution company seeks to expand its existing interconnection service in order to serve new retail Load, the customer is effectively requesting a bundled transmission/interconnection product. A request for a Load to interconnect, whether a retail load or wholesale load, is effectively a request for transmission service in CAISO. Separating the services for study purposes would lead to absurd results. Load interconnections are not studied by assuming the Load is not withdrawing power. And, given that the CAISO must ensure there are sufficient transmission facilities to serve all distribution-connected load within the CAISO BAA taking transmission service, it only makes sense that the nature of the facilities that the Load is interconnected to is irrelevant.
In the CAISO structure, UDCs/MSSs are the Eligible Customers for transmission service. Thus, any definition of Large Load must capture the “on behalf of” portion of FERC’s framing of jurisdiction in the OSC. Throughout the OSC, FERC states that it preliminarily finds the CAISO and TO Tariffs appear to be unjust and unreasonable because they lack clarity for “the provision of transmission service to Eligible Customers on behalf of large loads.”[16] FERC’s deliberate use of this phrase, and its focus on the Eligible Customer, reflects a jurisdictional reality: FERC’s intent to apply the OSC’s requirements (study processes, reliability oversight, and cost recovery) to all Large Load customers for whom the Eligible Customer takes transmission service. There is no question that FERC has jurisdiction over transmission service taken by Eligible Customers to serve load, including retail load. By anchoring its requirements to the Eligible Customer’s transmission service, FERC ensures its reach is legally sound while still enabling it to indirectly place requirements on Large Loads, as discussed immediately below.
The OSC makes its intended reach explicit. FERC clarifies that the phrase “provision of transmission service to Eligible Customers on behalf of large loads” encompasses situations where an Eligible Customer requests a new or modified point of delivery to serve a Large Load, where a Large Load seeks a new or modified delivery point as an unbundled retail transmission service customer, or where Large Loads are otherwise included in an Eligible Customer’s reported load growth and that Eligible Customer is taking network transmission service.[17] This broad articulation makes clear that FERC intends its requirements to capture all Large Loads receiving transmission service through an Eligible Customer.
CAISO’s interpretation is too narrow and ignores FERC’s clear statement that “[t]he Commission has jurisdiction over the study process for transmission service to both Eligible Customers on behalf of large loads and unbundled retail transmission service to end-use large load customers where, pursuant to state law or a public utility’s voluntary offer of such service, the large load is an Eligible Customer under the transmission provider and/or transmission owner tariffs.”[18] As noted above, the focus of the OSC is on “the provision of transmission service to Eligible Customers on behalf of large loads.” Thus, to FERC, where the Large Load initially connects is irrelevant if it is ultimately connected to the transmission system and receiving transmission service from an Eligible Customer. For example, in Paragraph 45 of the OSC, FERC states that it has “the authority to ensure that tariffs include provisions that clearly and consistently address study process for the provision of transmission service to Eligible Customers on behalf of large loads.” The breadth of this authority—and the absence of any limiting language restricting coverage to loads that directly interconnect to the transmission system—indicates that FERC intends these requirements to apply comprehensively to all large loads regardless of where they ultimately connect.
We believe FERC will reject CAISO’s definition as too narrow because, rather than focusing on the transmission service the Eligible Customer takes to serve the large load, it focuses on how the Large Load customer physically connects to the CAISO Controlled Grid—missing the purpose and intent of the OSC. PG&E’s previous suggested revisions to the CAISO’s initial proposal were intended to make this relationship more explicit. PG&E modifies the proposed definition to make the scope and reach of the OSC’s requirements crystal clear.
PG&E’s Proposal Reflects the OSC
PG&E’s modified suggested definition of Large Load is: “An End User located at a single site behind one or more Point(s) of Withdrawal from the CAISO Controlled Grid and that has a peak load of 50 MW or greater.”[19] This definition uses the term “behind the Point of Withdrawal” which focuses on load deliverability rather than relying on the generator framework and trying to rewrite that process to apply to Large Load. Crucially, Point(s) of Withdrawal, when used in the transmission service context, is limited to the CAISO BAA.[20] PG&E also proposes to modify the definition of Point(s) of Withdrawal for clarification. Specifically, PG&E proposes to modify the definition as follows:
Point(s) within the ISO Balancing Authority Area, or for purposes of scheduling and operating the Day Ahead Market only, the EDAM Area where Energy and Ancillary Services are made available to a receiving party under this ISO Tariff, for purposes of scheduling and operating the Real-Time Market only, the EIM Area where Energy and Ancillary Services are made available to a receiving party under this ISO Tariff, or for purposes of the definition of Large Load only, the point(s) where a non-transmission facility that is used to withdraw Energy from the ISO Controlled Grid to serve an End User connects to the ISO Controlled Grid.”
PG&E’s view is supported by NERC’s proposed definition. In 2025, NERC defined Large Load as follows: “Any commercial or industrial individual load facility or aggregation of load facilities at a single site behind one or more point(s) of interconnection that can pose reliability risks to the [Bulk Power System] due to its demand, operational characteristics, or other factors. Examples include, but are not limited to, data centers, cryptocurrency mining facilities, hydrogen electrolyzers, manufacturing facilities, and arc furnaces.” NERC does not indicate that “behind one or more point(s) of interconnection” means the Large Load must be directly connected to the transmission system.
Other RTO and ISO definitions that have been filed or proposed to stakeholders are more consistent with PG&E’s interpretation and approach, explicitly recognizing that Large Load does not have to be interconnected to the transmission system directly and instead using the terms “Behind” or “Through” to appropriately capture the effects of any Large Load on the transmission system. MISO refers to large load “located at a single substation behind one or more Point(s) of Withdrawal from the Transmission System” where Point of Withdrawal is “[t]he point(s) where a non-transmission facility that is used to withdraw Energy from the Transmission System to serve Load connects to the Transmission System.” ISO-NE’s definition proposal includes large load that “connects to the transmission system either directly or through a system primarily designed to serve the customer.” SPP refers to a large load “connected through one or more shared Points of Interconnection (POIs) or delivery points.” NYISO’s proposal refers to large load “behind one or more POIs.” None of these definitions facially excludes distribution-connected Load and none requires that the Large Load directly connect to the Transmission System.
Although several of these definitions employ “point of interconnection” terminology that may appear superficially similar to CAISO’s proposal, they are in fact materially different, and it would be a mistake to treat CAISO’s proposal as aligned with all of the other RTOs. CAISO proposes to define a Large Load as “[a]n End User located at a single site whose Point(s) of Interconnection is/are to the CAISO-Controlled Grid, and that has a peak load of 50 MW or greater.” Unlike the other RTO formulations, CAISO’s definition does not use key qualifiers such as “Behind” or “Through” the point of interconnection, nor does it use “delivery point.” Instead, it keys the definition to an End User whose own Point(s) of Interconnection are directly to the CAISO-Controlled Grid. The distinction is not merely one of capitalization or drafting style. SPP captures load “connected through one or more shared Points of Interconnection (POIs) or delivery points;” NYISO captures load “behind one or more POIs;” and PJM captures end-use customer load “behind one or more points of interconnection.” CAISO's language, by contrast, reaches only an End User whose point of interconnection is at the CAISO-Controlled Grid—i.e., load that is directly interconnected. As a result, CAISO's proposal is narrower than each of the other definitions and risks excluding large loads that are served through dedicated downstream or other non-transmission facilities but that nonetheless rely on, and materially affect, the transmission system. In sum, CAISO’s proposed definition of large load is too narrow and will result in a definition that fails to meet the requirements of the OSC and produces a null set.
b. Please provide comments on the large load application process and interconnection study procedures.
See PG&E’s September 2, 2026 Comments regarding roles and responsibilities of the PTOs and the CAISO.
Application Process
PG&E continues to generally support the proposed updates to CAISO’s application process but identifies a few areas of needed clarification. The CAISO continues to propose that the PTOs accept applications and notes that it is proposing enhanced and ongoing coordination with the PTOs on the Load and resource interconnection processes and expects the PTOs to align their Load application processes with the CAISO’s resource interconnection process.[21] This statement is unclear as to whether the CAISO is expecting the CAISO Cluster Window for new Resources to be aligned with applications from Eligible Customers for Large Load and/or how the FERC 90-day timeline would apply. PG&E agrees with CAISO that certain Eligible Customer for Large Load applications are going to prove that the Large Load is electrically dependent and will need to be studied in a Cluster for results to be meaningful.
The CAISO suggests that the PTOs develop a consistent application process.[22] PG&E expects each PTO’s application processes to be relatively similar, but given the abbreviated time frame to prepare filings, is not expecting uniformity. PG&E is still developing its proposed application process to respond to the requirements of the OSC. PG&E anticipates developing a separate application process for Eligible Customers seeking an interconnection to serve Large Load (as properly defined by PG&E). PG&E anticipates that the process will largely follow the application process under its existing Section 10 of its Transmission Owner Tariff (“TO Tariff”). Thus, PG&E anticipates the process will require submission of a standardized interconnection application that provides the technical information PG&E and CAISO need to understand the characteristics of the Large Load, together with documentation demonstrating that the project is not speculative and can move forward. PG&E anticipates reviewing each application for completeness within a defined timeframe and will process applications on a rolling basis consistent with the requirements of the OSC. Like CAISO, PG&E also intends to evaluate applications to determine whether Large Loads are electrically independent or electrically dependent.
Study Process
PG&E generally supports the CAISO proposal to coordinate with the PTOs on Eligible Customer for Large Load interconnections through Section 24 (Comprehensive Transmission Planning Process (“TPP”)) of the CAISO Tariff. The CAISO indicates that it does not propose changing the allocation of rights and responsibilities for studying Large Load interconnection requests from the framework in place today: the PTOs will continue to manage the bulk of the study responsibilities.[23] The CAISO encourages the PTOs to align their Large Load interconnection study procedures among themselves and with the CAISO resource interconnection standards and TPP for enhanced clarity and consistency for customers.
Historically, as noted by the CAISO, the PTOs submit certain types of upgrades for the CAISO’s concurrence in the TPP. This concurrence process for Load interconnections considers the transmission component of the Load interconnection (i.e., the network upgrades). The CAISO reviews and provides concurrence that the Load interconnection and potential network upgrades to interconnect the load meet the transmission reliability requirements and are consistent with the long-term transmission plans in the area.
The CAISO suggests that the PTOs develop a consistent study process.[24] Again, at this time, PG&E is uncertain of the degree of consistency that will exist across PTO filings. As noted above, PG&E continues to develop its process for studying requests by Eligible Customers seeking to interconnect Large Loads. However, it anticipates that any process developed will follow closely the existing study process for interconnection of loads under Section 10 of the TO Tariff. Like CAISO, PG&E anticipates treating electrically dependent and electrically independent Large Loads differently. PG&E anticipates a study process for both types of load that identifies the facilities and upgrades needed to serve the large load, accounts for the load characteristics provided in the interconnection applications, relies on existing transmission planning studies to the extent reasonably practicable, and evaluates alternative transmission technologies as potential solutions before selecting traditional network upgrades.
c. Please provide comments on the large load operational requirements.
See PG&E’s September 2, 2026 Comments regarding large load operational requirements.
The LLE Proposal summarizes the work of the Large Load Technical Requirements Working Group to develop consistent technical requirements for the reliable interconnection and operation of large data center loads. PG&E understands that certain requirements will be imposed through the CAISO Tariff, presumably on PTOs, although the level of granularity of information the PTO is expected to provide to the CAISO, and which entities the CAISO expects the PTOs to directly interact with, remain somewhat unclear. For example, the CAISO Tariff will “establish ramp-rate requirements,” but are those ramp rate requirements applied to individual Large Loads or to Eligible Customers for all their load? Similarly, “frequency and voltage ride-through requirements” would seemingly apply to Large Loads directly and it is unclear whether the CAISO is requiring the PTO in turn to impose such requirements directly on a Large Load, even if the PTO is not also the Eligible Customer and may not be in a position to establish a contract directly with the Large Load.
Separately, the CAISO proposes that a set of requirements be addressed through the TO Tariffs include the installation of phasor measurement units, requirements for control technologies and/or protection systems, when necessary, to limit Large Load withdrawals from the transmission system. Again, it remains unclear who actually imposes the requirements on whom, such that the Large Load customer installs what is necessary.
The CAISO expects that static information about Large Loads will come from the PTOs near the end of the interconnection process (similar to the new resource implementation process for generators) while day-ahead and real-time information will come from the (load-serving entity) Scheduling Coordinator responsible for the Large Load’s demand.[25] PG&E does not object to the extensive list of static information required, but the CAISO does not address how PTOs will collect such information if the PTO does not have a direct relationship with the Large Load customer. Once again, the fallacy that the PTO is directly interconnecting with the retail customer appears to be the basis for the requirement; i.e., the CAISO clearly believes that the CAISO and a PTO can directly impose requirements on such retail load. PG&E assumes that it can require instead that the listed information be provided by the Eligible Customer at the conclusion of the PTO process and that the Eligible Customer will need to update the PTO, as needed, who will update the CAISO. That said, where the Eligible Customer and PTO are one and the same entity, direct communication between the Large Load and the PTO may be more efficient.
PG&E understands that there will be an upcoming working group to develop requirements for Scheduling Coordinators in relation to Large Load. This will require many systems to be developed, which currently do not exist. PG&E is committed to cooperating in that upcoming process, including properly determining the scope of responsibilities for Scheduling Coordinators.
d. Please provide your comments on the large load service agreements.
See PG&E’s September 2, 2026 Comments regarding “Large Load Agreement(s).” As already noted, any pro forma TO Tariff agreements largely will likely focus on the PTO/Eligible Customer relationship, although in some circumstances, for efficiency reasons, or with the agreement of all the parties, the Large Load customer would be a party to some such agreements.
Again, meeting the CAISO’s expectations as to consistency among PTOs is a valid goal, but initial conformity may not be achievable. PG&E continues to develop the necessary service agreement that will govern requests for interconnection by Eligible Customers interconnecting Large Load. PG&E anticipates that it will develop a separate pro forma agreement to govern such service requests and that such an agreement will need to be executed by each Eligible Customer seeking interconnection service for Large Load customers. PG&E also anticipates that its pro forma agreement will include attachments that address the necessary cost recovery requirements of the OSC and flexible interconnection service requirements of the OSC.
e. Please provide any other comments on this topic.
None.
[1] California Indep. Sys. Operator Corp., et al., 195 FERC ¶ 61,214 (2026) (“OSC”).
[2] Capitalized terms not otherwise defined in these comments have the meaning assigned to them in the California Independent System Operator Corporation Fifth Replacement FERC Electric Tariff.
[3] PG&E recognizes that CAISO does not prefer use of the term Eligible Customer in this context. The use of the term Eligible Customer in the OSC reflects the fact that Eligible Customer is a defined term in Order No. 888 and the pro forma Open Access Transmission Tariff. PG&E does not object to use of different language that CAISO believes is more appropriate for the CAISO region, such as UDC and MSS, but the language must address what the OSC refers to as Eligible Customers taking transmission service to serve Large Loads.
[4] The CAISO repeatedly refers to maintaining existing roles and responsibilities. See e.g., LLE Proposal at 10 (“the CAISO does not propose significant changes to the roles and responsibilities associated with large load interconnection applications or studies”); id. at 12 (“the CAISO reiterates that the PTOs are much more familiar with the current load interconnection processes and responsibilities than the CAISO and are therefore in a better position to negotiate a process that clarifies roles and responsibilities”); id. at 25, 28.
[5] Scheduling Coordinators for Load outside the CAISO BAA may purchase wheeling transmission service for Eligible Customers, but Load situated outside the CAISO BAA is irrelevant to the LLE Proposal and the OSC. The OSC did not mandate that the CAISO and PTOs address situations in which Large Loads located in non-CAISO BAAs impact the CAISO Controlled Grid or require its expansion. The CAISO and PTOs can address that issue in the future.
[6] LLE Proposal at 16. A word search shows the term appearing 32 times in the CAISO Tariff.
[7] Generally, the term is used in the CAISO Tariff to describe the entity that a Scheduling Coordinator is representing for market/scheduling purposes.
[8] LLE Proposal at 16.
[9] See e.g., OSC at P 39 (“we use the phrase ‘the provision of transmission service to Eligible Customers on behalf of large loads’ to encompass the provision of new, modified or additional transmission service to Eligible Customers on behalf of large loads.”).
[10] Id.
[11] LLE Proposal at 13.
[12] OSC at P 3.
[13] LLE Proposal at 15.
[14] POI is currently defined in relevant part: “The point, as set forth in Appendix A to the Large Generator Interconnection Agreement or Attachment 3 to the Small Generator Interconnection Agreement, where the Interconnection Facilities connect to the CAISO Controlled Grid. For Generating Facilities connected to the Distribution System, the Point of Interconnection is the point at which the Generating Facility connects to the CAISO Controlled Grid.”
[15] At least in this definition, the CAISO admits there are intervening facilities between the Large Load and the CAISO Controlled Grid.
[16] See, e.g., OSC at P 38 (emphasis added).
[17] Id. at P 39.
[18] Id. at P 43.
[19] While PG&E proposes a 50 MW threshold for the definition, it also recognizes, based on its experience, that this threshold may be too high in practice and continues to evaluate it.
[20] In other contexts, a Point of Withdrawal can be outside the CAISO BAA. Point(s) of Withdrawal are “Point(s) within the CAISO Balancing Authority Area, or for purposes of scheduling and operating the Day-Ahead Market only, the EDAM Area where Energy and Ancillary Services are made available to a receiving party under this CAISO Tariff, or, for purposes of scheduling and operating the Real-Time Market only, the EIM Area where Energy and Ancillary Services are made available to a receiving party under this CAISO Tariff.” This Large Load process has nothing to do with scheduling and operating in energy or ancillary service markets.
[21] LLE Proposal at 19.
[22] Id.
[23] LLE Proposal at 25.
[24] Id. at 20.
[25] LLE Proposal at 37.
