Comments on Revised straw proposal

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

ACP-California appreciates CAISO’s continued efforts on IPE and its desire to improve the interconnection process and ensure it can move forward on a timely and efficient basis. ACP-California continues to hope that CAISO’s complete package of changes can achieve an appropriate balance of modifications that assist in reducing the number of non-viable interconnection request, while also providing flexibility to developers and allowing viable projects to move forward. Our comments focus on concerns with the modifications to the Transmission Plan Deliverability (TPD) allocation process and on recommended modifications to the definitions for Site Exclusivity for Offshore Wind resources and for projects that are sited on public lands. We look forward to continuing to work with CAISO to adjust the IPE Phase 1 (and Phase 2) modifications to provide for modifications CAISO sees as necessary while also allowing viable projects to move forward.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

N/A

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

ACP-California supports streamlining of the TPD allocation process, but has significant concerns with elements of CAISO’s proposal for modifying the TPD allocation process. Namely, as discussed more below, we have significant concerns around the elimination of TPD allocation group 3, especially if done before CAISO has worked with stakeholders to finalize improved transparency and information provision on deliverability availability. Additionally, the modification to the requirements for a PPA to qualify for a TPD allocation are concerning and will unfairly disadvantage viable, and sometimes mature projects, that may be available to provide clean energy capacity and energy to the CAISO grid, but have a PPA with a commercial/industrial offtaker.

Impacts of Eliminating TPD Allocation Group 3 will be Substantial and Will Negatively Impact the Commercial Development Process for Generators AND LSEs

CAISO has proposed to remove TPD allocation group 3 as part of the revisions to the TPD allocation process. ACP-California continues to oppose the complete elimination of this group and urges CAISO to heed comments from various stakeholders that have explained the commercial value and current use of the TPD allocation group 3. Completely eliminating this option will create a new set of commercial issues and TPD allocation problems and may delay the commercialization of new projects which are needed to meet reliability and procurement needs.  

TPD allocation group 3 is currently a valuable tool that can be used by generators to demonstrate to potential offtakers their path to a deliverability allocation. And thus, Group 3 is an important component of securing a PPA. Thus, it is a critical component of the development/procurement processes. Eliminating group 3 will create a new set of problems which may be worse than the problem that CAISO is trying to solve. This modification will place significant burdens on LSEs to determine whether a project they are considering contracting with has a reasonable path to a TPD allocation. LSEs may begin executing PPAs to test projects deliverability potential and, if a project cannot secure a TPD allocation, terminating those PPAs. This will delay the commercialization of new resources in CAISO and create a host of other problems.

We understand that CAISO will be creating a working group and developing additional information and transparency around deliverability allocation availability. However, it is not sufficient to hope that this process will lead to the right type of information for LSEs to operate effectively under the new paradigm CAISO is proposing (which would no longer include TPD allocation group 3). At a minimum, CAISO needs to complete the work on transparency and information provisions around deliverability prior to elimination of Group 3.

While completion of the transparency process is necessary, at a minimum, ACP-California continues to support retention of a TPD allocation group that does not require execution/negotiation of a PPA or short list selection. It is critical that some flexibility be retained for projects that are viable but may not fit precisely into the development process that CAISO has outlined for TPD allocations. While retaining an option to proceed without a PPA is important to the development/procurement process, we also recognize, given the volume of the queue, the need to streamline the TPD allocation process and to increase the barriers/requirements for TPD allocations. Thus, we again recommend that CAISO retain a modified option to compete for a TPD allocation without a PPA, but incorporate higher deposit and capital-at-risk provisions for projects that choose to proceed in this manner.

Eliminating PPAs that Indirectly Provide RA Benefits to LSEs will Hinder Development and may Negatively Impact Very Mature Projects

Given the various development models that exist, and which are supporting achievement of California’s clean energy goals, and supporting reliability needs, CAISO should not seek to create an exceedingly narrow definition of a PPA that qualifies for a TPD allocation and, as Amazon pointed out, CAISO should remain neutral on the identity of the interconnection customer’s direct offtaker, as those that cannot directly utilize RA are economically incentivized to sell that RA to an entity that has an RA need. Without this option available for generators selling to commercial/industrial customers, it is likely that the supply of RA-eligible resources being developed in the state will decrease which may increase RA prices and negatively affect ratepayers. Additionally, in order to provide non-discriminatory access to the grid and deliverability, CAISO must leave open options for PPAs that are not directly with an LSE to meet its RA obligation to qualify for an TPD allocation. ACP-California therefore, urges CAISO to not narrow and restrict the definition of a qualifying PPA for deliverability allocation purposes, but rather to allow contracts that do provide RA value to an LSE, even if through an intermediary, to count.

Additionally, CAISO’s proposal would implement this change in Phase 1 of the IPE, with it first applying to the 2022-23 TPD allocation process. While this clearly would affect Cluster 14 projects, it also appears as though it could impact projects in much earlier clusters which may be part of the 2022-23 TPD allocation. If that is the case, very mature projects with PPAs not directly with an LSE may become unviable at the eleventh hour due to this change by CAISO, which would reduce capacity that may be available to the grid in the near-term. At a minimum, CAISO should ensure this does not happen and that PPAs which have previously qualified for a TPD allocation in a prior TPD allocation cycle will continue to be eligible in the 2022-23 TPD allocation.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

N/A

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

CAISO has proposed to implement a Site Exclusivity requirement for projects to progress into the Phase II study process. ACP-California has previously expressed concerns about implementing this requirement retroactively for Cluster 14 and has recommended that Cluster 14 be provided some flexibility on Site Exclusivity demonstrations, such as a higher capital at risk deposit to proceed without Site Exclusivity. We continue to recommend CAISO consider such flexibility for Cluster 14. We also recommend modifications to the definition of Site Exclusivity for projects on public lands and for offshore wind projects sited in federal waters.

Site Exclusivity Definition for Projects on Public Lands Requires Modification

For projects on public lands, securing a final, non-appealable permit, license, or other right to use the property generally takes substantially longer than is necessary for a project to obtain Site Exclusivity as defined for private land. In order for any project on public lands that is part of Cluster 14 to be capable of achieving Site Exclusivity and move into the Phase II study process, modifications to the current definition of Site Exclusivity will be required. Absent modification, it is likely that all Cluster 14 projects on public lands will be removed from the queue. Other Transmission Providers in the West have recognized the need for alternative Site Exclusivity (or Site Control) definitions for projects located on public lands. In a recent filing to FERC (Docket ER22-834-000), PacifiCorp proposed modifications to its Site control definition which state:

For purposes of lands managed by a governmental entity (such as BLM), a Preliminary Plan of Development (PPOD) or equivalent government-issued documentation, shall be sufficient for demonstrating Site Control as to such government-managed land.

We recommend that CAISO include similar language in its definition of Site Exclusivity to accommodate projects on public lands. Additional discussions around “equivalent government-issued documentation” for state lands may be necessary and we would be happy to work with

CAISO and other stakeholder on this. To the extent CAISO has concerns that this definition is not sufficient to reduce the number of unviable projects in the queue, we recommend that (for projects on public lands) the above Site Exclusivity definition be used but an additional capital-at-risk component could be included for projects that utilize this definition.

Recommended Changes to Site Exclusivity Definition for Offshore Wind Projects in Federal Waters

CAISO has proposed new language for Site Exclusivity for offshore wind. After reviewing and discussing this language, we recommend the following change for offshore wind projects in federal waters:

For offshore wind to be sited in federal waters, a lease, permit or exclusive right to lease sea-space as awarded by the Bureau of Ocean Energy Management (BOEM) following a BOEM administered lease auction in a designated federal Wind Energy Area

For projects sited in federal waters, this language is preferable to the definition proposed in the Revised Straw Proposal because in the BOEM process there is a lag (~6 months) between the time when a bidder wins a lease auction and when it officially become the lease holder. This definition recommended above would allow projects that have won a lease auction to qualify as having Site Exclusivity and to proceed to Phase II studies.

ACP-California also suggests that, if the CAISO does implement a Site Exclusivity requirement, the CAISO should provide an extension on Site Exclusivity requirements to OSW projects in Cluster 14 in the event there is a delay in the BOEM auction process (currently planned for the end of 2022) which would prevent those projects from satisfying this requirement ahead of the pre-Phase II study deadline. 

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

N/A

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

N/A

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

N/A

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

N/A

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

N/A

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

N/A

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

N/A

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

N/A

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

N/A

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

N/A

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

N/A

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

N/A

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

See comments attached

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

N/A

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

See comments attached

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

N/A

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

N/A

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

N/A

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

N/A

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

N/A

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

N/A

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

N/A

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

N/A

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

N/A

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

N/A

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

N/A

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

N/A

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

N/A

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

N/A

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Amazon Energy LLC (“Amazon”) appreciates the opportunity to submit these comments on CAISO’s Revised Straw Proposal for Its 2021 Interconnection Process Enhancements initiative.  As was the case with Amazon’s earlier comments on the Issue Paper and Straw Proposal (“Issue Paper”), these comments focus on Question 3 regarding the proposed revisions to the Transmission Plan Deliverability (“TPD”) Allocation Process.

In its initial comments, Amazon described its efforts to power its operations with 100% renewable energy by 2025 and its strategy of procuring renewable energy and storage that will enable it to self-supply resource adequacy (“RA”).

Amazon supports California’s ambitious objective to decarbonize the power grid while maintaining system reliability. This goal is best served by increasing the number of renewable projects that can achieve deliverability.  To that end, Amazon supports the comments of Advance Energy Economy (“AEE”) and the concerns that CAISO’s proposed approach will reduce the supply of RA-eligible resources being developed, potentially drive up the price of RA and diminish the amount of capital available for future much needed investment. 

Amazon requests that the CAISO consider these comments and those of others, like AEE (as well as the twelve of eighteen previous commenters that raised concerns about this provision in the initial Straw Proposal), and reverse course in its approach to TPD Allocation.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

Amazon has no comments with respect to this issue.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Amazon believes that the CAISO’s proposal to limit TPD Allocation only to projects that have contracted with LSEs would be detrimental.  As noted above, Amazon joins in the comments of AEE. AEE identifies certain weaknesses of the CAISO’s rationale for limiting TPD Allocation to projects that contract with LSEs.  As AEE notes, there is no reason to doubt that RA capacity developed by corporate offtakers will be acquired by LSEs due to the existing economic incentives that are in place. 

If the CAISO continues with its proposal to limit TPD Allocation only to projects that have contracted with LSEs, Amazon urges it to consider including in the forthcoming Draft Final Proposal reasonable means by which non-LSE offtakers can still pursue the development of RA-eligible resources so long as they commit to making the capacity available to LSEs.  Amazon would welcome the opportunity to work with the CAISO on this initiative.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

Amazon has no comments with respect to this issue.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

Amazon has no comments with respect to this issue.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

Amazon has no comments with respect to this issue.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Amazon has no comments with respect to this issue.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Amazon has no comments with respect to this issue.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Amazon has no comments with respect to this issue.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

Amazon has no comments with respect to this issue.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Amazon has no comments with respect to this issue.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

Amazon has no comments with respect to this issue.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

Amazon has no comments with respect to this issue.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

Amazon has no comments with respect to this issue.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

Amazon has no comments with respect to this issue.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

Amazon has no comments with respect to this issue.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

Amazon has no comments with respect to this issue.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Avangrid Renewables appreciates the CAISO’s efforts in the Interconnection Process Enhancements proposal to efficiently and fairly accommodate cluster 14 requests while establishing reforms to properly manage future study clusters.

In these comments, we offer feedback on proposals to facilitate offshore wind in the IPE, express concern with some of the proposed revisions to Transmission Plan Deliverability allocations, and ask for clarifications regarding the downsizing window and POI change processes.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

Avangrid Renewables supports CAISO’s proposal to remove the downsizing request window and simplify downsizing request requirements. This will help move projects through the interconnection expeditiously, without the constraints of the existing downsizing request window and requirements. While Avangrid Renewables is supportive of this improvement, we also want to make sure that the proposal does not create undue delays in the current MMA process. We would like the ISO to clarify how this proposal will impact the current MMA review timeline.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Avangrid Renewables supports the CAISO’s suggestion to narrow down the TPD allocation groups. However, we do not support removing the “proceed without a PPA option.” As ACP-California, CESA, RWE and other parties discussed in their initial IPE straw proposal comments, the CAISO should include a TPD allocation group that allows an applicant to put a higher amount of capital at risk in lieu of verifying a PPA award, short-list or “in-negotiation” contract status. Providing this limited flexibility would avoid a no-win, circular scenario in which an IPP developer is required to have a TPD allocation to move forward in an LSE solicitation while also needing PPA status to proceed into TPD allocation with the CAISO. Given that only IPP projects would face this failing scenario, the CAISO should provide flexibility in the interest of fair competition.

We also object to the proposal that FCDS allocations would only be awarded to projects with contracts for LSEs that have RA obligations. Third-party power purchasers including C&I customers are an essential component of the market that will contribute to the large investments in renewables and energy storage needed to achieve the state’s clean energy transition. As Amazon Energy LLC, CESA, Golden State Energy, and NextERA explain, these types of transactions do not limit the deliverability or RA resources available to LSEs with RA obligations and can in fact facilitate development of new capacity. Ultimately, RA capacity is monetized through sale to an LSE. Contracting structures that provide additional private investment to bring clean resources online will accelerate state-wide procurement of capacity. The CAISO should preserve fair and open access to transmission deliverability rather than restrict the type of customers and transactions which could receive TPD allocations.

If the CAISO does elect to proceed with limiting deliverability allocation according to contract type as in the original and revised straw proposal, the CAISO should postpone implementation until phase 2 so as not to disrupt contracting already underway.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

No comment at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

Avangrid Renewables supports the CAISO’s proposal for requiring site exclusivity to proceed into the Phase II study process, beginning in Cluster 14.

Specific to offshore wind site exclusivity, Avangrid Renewables recommends that the CAISO adopt the following definition:

 For offshore wind to be sited in federal waters, a lease, permit or exclusive right to lease sea-space as awarded by the Bureau of Ocean Energy Management (BOEM) following a BOEM administered lease auction in a designated federal Wind Energy Area, and for offshore wind to be sited in waters under the jurisdiction of any state or other country, a lease, permit or exclusive right to lease sea-space from that jurisdiction.

This definition aligns with the site exclusivity language in the current ISO Tariff for projects to be sited on public land under management of the BLM which qualifies site exclusivity as the “exclusive right to use public land.”

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

No comment at this time.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

No comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

No comment at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Avangrid Renewables supports CAISO’s proposal for the timing of the process for changing POIs to remain consistent with the current practice. However, we would like the ISO to clarify the current process and the number of alternative POIs allowed under the current process, as well as to clearly define how many alternative POIs will be allowed going forward. As stakeholders commented previously, CAISO should clearly define what a “transmission study area” is, and if possible, illustrate these “transmission study areas” on the CAISO system map. We are supportive of RWE Renewables comments that some of the uncertainty regarding POI selection could be avoided by providing transparent data to Interconnection customers.

Additionally, Avangrid Renewables would like the ISO to clarify how, in the study process, it would treat (1) an IR with multiple alternative POIs and (2) multiple IRs (with different POIs) submitted by the same Developer for a single project.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

No comment at this time.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

No comment at this time.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

No comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

No comment at this time.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

No comment at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

No comment at this time.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

No comment at this time.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

Avangrid Renewables shares the concern the CAISO articulated in the revised straw proposal Section 3.3 regarding the “lack of coordination among the transmission planning process—and policy-driven transmission in particular—the interconnection process, and load serving entities’ procurement processes [which] continue to create the opportunity for transmission to be utilized by resources not envisioned in the original policy direction but earlier-positioned in the queue, resulting in challenges in meeting state resource policy goals.” Although the CAISO does not plan to advance a specific proposal to address this issue currently, we look forward to participating in future stakeholder processes as envisioned.

The CAISO’s recently released draft 20-year outlook takes a critical first step in identifying potential transmission solutions that would align transmission planning and investment in the state with the procurement needed to develop a cost-effective, SB 100-compliant state energy portfolio. The CAISO should begin proactively incorporating the policy-driven solutions identified in this outlook into the TPP process in a manner that could ultimately lead to the authorization of new transmission investments. Studies and sensitivities are a starting point, not a mechanism on their own.

Avangrid Renewables also notes two relevant CPUC and CAISO findings related to offshore wind. First, the CAISO’s 20-year outlook identified a solution for interconnecting up to 6 GW of offshore wind from the Morro Bay area at an estimated cost of $110 Million. This is a remarkably affordable option for bringing on substantial quantities of offshore wind. We expect that offshore wind developers who win leases in the BOEM auction anticipated for this fall for the first ~3,000 MW of offshore wind in the central coast will enter the interconnection queue in spring 2023 if they have not already received a queue position. However, the CAISO and the CPUC may need to consider a policy-directed approach to preserving the remaining ~3,000 MW of interconnection capacity in the central coast necessary to achieve full economies of scale for offshore wind at the 10GW+ level identified in the SB 100 portfolio.

Second, amid the uncertainty regarding how PG&E will utilize its transmission assets associated with Diablo Canyon retirement, the CPUC raised the issue of preserving capacity in the Diablo Canyon area for offshore wind in the current IRP process. In the Integrated Resource Planning Decision adopted on February 11, the CPUC stated, “In this decision we make clear our policy interest in ensuring that at least a portion of the central coast transmission capacity can be utilized for offshore wind development.” (p. 145) The Commission also stated its interest in the CAISO IPE process providing “an opportunity to explore ways that the state could acquire and exercise authority within the CAISO’s interconnection process, in a manner consistent with both FERC rules and state policy.” (p. 146) Avangrid Renewables appreciates this policy direction provided by the CPUC and encourages the CAISO and CPUC to continue their shared efforts to ensure sufficient transmission capacity is available to bring online valuable and highly location-specific clean energy resources, like offshore wind, essential to the state’s long-term clean energy portfolio. We recommend including this topic in Phase 2 of the IPE scope.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Aypa Power appreciates the opportunity to provide feedback on the Cluster 14 Supercluster Interconnection Procedures issue paper. Aypa understands the magnitude of the problem CAISO is experiencing and appreciates the effort put forward by CAISO to process the C14 supercluster in a timely and reliable manner. Following is a summary of Aypa’s comments on the IPE 2021 revised straw proposal –

• Aypa is supportive of the proposal to transition from an annual month-long downsizing window to a process that allows for downsizing requests to be submitted at any time and be processed through the existing MMA process.
• Aypa is not supportive of the proposal to eliminate Group three- proceeding without a PPA. Aypa is also not supportive of the proposal to eliminate all TPD retention criteria for projects outside of group 2 allocation. Procurement processes are not timely aligned with interconnection schedule and having group 3 provides flexibility for the project to align with procurement timelines. The GIA and FCDS allocation timelines can be a long lead process and eliminating group 3 along with the elimination of the TPD retention criteria would eliminate flexibility in the Interconnecting process.
• Aypa supports the ISO’s philosophy around the need for an emergency interconnection process but cautions developing a process that provide for queue jumping and impacts to already queued projects. Aypa also agrees with stakeholders that the ISO should address faster queue throughput than create shortcuts for certain projects. The timing and schedule of both the interconnection study process and the EPC of interconnection facilities and network upgrades needs to be accelerated to provide for any immediate procurement needs.  
• Aypa strongly disagrees with the Site Exclusivity requirements proposal by the ISO. The interconnection study process is a long lead process taking multiple years followed by an even longer Interconnection facilities and Network upgrade construction timeline. Requiring SE as an entry into Phase 2 is forcing the interconnection customer to acquire expensive real estate option without certainty on the cost and timing of interconnection. Especially, provided the phase 1 results in the supercluster are provided as “advisory” only, the SE proposal burdens the IC by raising the developing costs without a clear path to interconnection. Aypa supports a higher capital at risk option as an alternative to discourage non ready projects. Informed ICs have selected sites based on numerous factors, two of which are lack of competition at POI location and sufficiency of real estate availability for the requested MW at that location, i.e. lack of secured site control does not necessarily suggest a lack of viability, but rather prudent spend control to manage a long lead interconnection process.
• Aypa supports the ISOs proposal on the cost responsibility associated with errors or omissions for network upgrade requirements.
• Aypa agrees with the ISOs proposal on the RNU clarifying language
• Aypa agrees with the ISOs proposal on changing sites and POIs during validation phase.
• Aypa supports the ISOs proposal on expanding deliverability transfer opportunities.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

Aypa is supportive of the proposal to transition from an annual month-long downsizing window to a process that allows for downsizing requests to be submitted at any time and be processed through the existing MMA process.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Aypa is not supportive of the proposal to eliminate Group three- proceeding without a PPA. Aypa is also not supportive of the proposal to eliminate all TPD retention criteria for projects outside of group 2 allocation. Procurement processes are not timely aligned with interconnection schedule and having group 3 provides flexibility for the project to align with procurement timelines. The GIA and FCDS allocation timelines can be a long lead process and eliminating group 3 along with the elimination of the TPD retention criteria would eliminate flexibility in the Interconnecting process.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

Aypa supports the ISO’s philosophy around the need for an emergency interconnection process but cautions developing a process that provide for queue jumping and impacts to already queued projects. Aypa also agrees with stakeholders that the ISO should address faster queue throughput than create shortcuts for certain projects. The timing and schedule of both the interconnection study process and the EPC of interconnection facilities and network upgrades needs to be accelerated to provide for any immediate procurement needs.  

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

Aypa strongly disagrees with the Site Exclusivity requirements proposal by the ISO. The interconnection study process is a long lead process taking multiple years followed by an even longer Interconnection facilities and Network upgrade construction timeline. Requiring SE as an entry into Phase 2 is forcing the interconnection customer to acquire expensive real estate option without certainty on the cost and timing of interconnection. Especially, provided the phase 1 results in the supercluster are provided as “advisory” only, the SE proposal burdens the IC by raising the developing costs without a clear path to interconnection. Aypa supports a higher capital at risk option as an alternative to discourage non ready projects. Informed ICs have selected sites based on numerous factors, two of which are lack of competition at POI location and sufficiency of real estate availability for the requested MW at that location, i.e. lack of secured site control does not necessarily suggest a lack of viability, but rather prudent spend control to manage a long lead interconnection process.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

• Aypa supports the ISOs proposal on the cost responsibility associated with errors or omissions for network upgrade requirements.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

• Aypa agrees with the ISOs proposal on the RNU clarifying language

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Aypa agees with the ISO proposal of not making any changes to this process. 

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

• Aypa agrees with the ISOs proposal on changing sites and POIs during validation phase.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

Aypa is supportive of the ISO proposal language

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Aypa agrees with the CAISO proposed language

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

Aypa does not wish to comment on this subject at this moment. 

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

Aypa agrees with CAISOs proposed language

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

Aypa supports the ISOs proposal on expanding deliverability transfer opportunities.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

Aypa supports this milestone to be required at phase 2 and not at IR applicaiton. 

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

Aypa agrees with CAISO's proposal on all communicaiton being handled through RIMS.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

We commend CAISO’s efforts in balancing risk, certainty and exposure to all customers and stakeholders involved in the queue process and appreciate the opportunity to provide comments

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

CESA continues to support the intent of this initiative and appreciates the ISO’s responsiveness to stakeholder comments and requests. We understand that the goal of this initiative is to streamline the interconnection process, identify ways to manage time and resources of ISO staff, and better align interconnection applications with procurement needs and processes. In some ways, these goals are met, but in one critical way, CESA believes that the ISO may do more harm than good. That is, the current proposal to revise the Transmission Plan Deliverability (TPD) allocation process could actually have the effect of hindering project development and load-serving entity (LSE) procurement efforts. In light of these concerns, CESA recommends that the ISO either identify workable modifications to the current Allocation Group 3 (proceeding without PPA), or to adjust their current proposal to afford flexibility for projects to secure TPD in order to facilitate transactions that could result in power purchase agreements (PPAs), though the end-all, be-all should not necessarily establish PPAs as the primary criteria for allocating deliverability. There is value in merchant generation and the ISO should not play the role of being the arbiter of whether and when merchant generation warrants TPD allocation. In addition to our major concerns with the TPD allocation proposal, the ISO should modify the PPA definition, clarify TPD retention criteria, accelerate grid transparency efforts, and clarify and adjust timelines for the site exclusivity documentation due date.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

CESA has no further comment at this time. As expressed in previous comments, CESA is supportive of the proposal to remove the downsizing window and simplify the downsizing request requirements.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

CESA opposes the current proposal as hindering both project development and LSE procurement efforts, as well as for being incomplete and warranting further development. There is a chicken-or-the-egg problem at hand: the ISO is proposing to not allocate deliverability unless the project is contracted or shortlisted for a PPA with an LSE, while the LSE will not contract or shortlist a project unless the project has secured deliverability. At its core, without TPD, developers cannot sell RA to LSEs since showing TPD is an efficient means to finalize a PPA contract. At the February 1, 2022 stakeholder call, however, the ISO expressed its perspective that LSEs could simply shortlist more projects to qualify for TPD allocation in Group 2 and secure deliverability. CESA has major concerns with this proposal and the ISO’s view on the matter.

First, there is no evidence or statement from LSEs at this time that they plan to adjust their procurement and evaluation criteria accordingly to implement proposals for Issue 3.2 in time for the 2022-2023 TPD allocation cycle. As a result, the ISO’s proposal may only serve to frustrate and/or stall the procurement process, with a greater burden now being put on the LSE to determine which projects to shortlist with less certain or complete information and to conduct some of the analysis themselves, which is likely better placed on developers who have incentives to strategically and cost-effectively site and develop projects.  The LSE would also face risks potentially executing a PPA prior to the project signing a generator interconnection agreement (GIA) and receiving notice to proceed (NTP). On the flip side, developers would also have to provide development securities to LSEs without knowing whether the project will be allocated TPD and qualify for RA. Such a process is untenable and will only slow down or deter procurement needed in the near and medium term. While the ISO stated that they want to minimize their role in commercial transactions, the use of a contracted or shortlisted PPA as the primary criteria to qualify for TPD only appears to be digging the ISO deeper into this space. To meet the state’s decarbonization goals and reliability objectives, the ISO must modify this proposal to create pathways to secure greater certainty of TPD, which would lead to more signed PPAs and greater RA assurance for the ISO’s grid.

Second, CESA believes that the current proposal is incomplete because the ISO does not detail the specific revisions that will be made to the scoring criteria in the GIDAP Business Practice Manual (BPM). With PPAs serving as the primary criteria for TPD allocation, this is an important consideration that is absent in the current proposal. In fact, there may be ways to use the scoring criteria to more granularly score projects that proceed without a PPA for the purposes of TPD allocation, which should be further explored.

Third, there is ambiguity as to whether the current proposal would only apply to QC14 or to all projects, including those in earlier clusters. Applying these new rules to previous clusters raise concerns with retroactive policymaking on the one hand, while creating concerns about discrimination and open access by narrowly applying these new rules only to QC14 on the other hand. These potential dichotomous rules need further consideration and could be readily avoided by maintaining the current Allocation Group 3 (proceeding without PPA) with certain modifications.

Fourth, the proposal to eliminate the current Allocation Group 3 (proceeding without PPA) and define qualifying PPAs as those with off-takers who will use the RA to fulfill its own RA obligation closes the door on merchant generation. While the ISO pointed to the lack of merchant generation as a potential reason to make these changes, it should not be in the position to determine whether there should be any merchant generation as part of the TPD allocation process, which would violate FERC open access rules and non-discriminatory principles. Increased supply resources should be viewed as a good thing, and something that is particularly necessary in today’s tight supply market, but the ISO would be closing that door for projects that require 3-4 years to come online but cannot secure deliverability in advance. CESA does not envision any projects coming online without knowing whether they will secure deliverability. In addition, the ISO should allow the market to evolve to allow developers to provide more flexible products to LSEs and not deter the development of deliverable projects to non-LSE parties who have valid reasons to do so (e.g., reduce RA obligations to LSEs, pursue 24x7 carbon-free goals).

Given the above concerns, CESA requests that the ISO modify the current proposal in either of two ways:

• Maintain the current Group 3 (proceeding without a PPA) with some to-be-determined adjustments to scoring weights and criteria in the GIDAP Business Practice Manual (BPM), coupled with the other proposals around commercial viability (e.g., site exclusivity) that will help manage the current supercluster; or
• Modify the currently-proposed Group 3 to allow projects without a PPA to receive TPD allocations and fund/build deliverability network upgrades with the ability to park or maintain TPD deliverability for some period of time.

For the latter, it would afford projects some flexibility and a window to secure a PPA, thus demonstrating before the end of some (to be determined) defined window its status as a Group 1 or 2 project in future TPD cycles.

While appreciative of the ISO adding a definition to a qualifying PPA at the request of CESA and other stakeholders, CESA does not support the ISO’s current proposal to define the qualifying minimum contract length at five years. If the goal is to support RA obligations through the structure of TPD allocation priority groups, the qualifying PPA definition should align with the CPUC’s RA forward contracting requirements. With System RA contracts typically ranging from a few months or a year at minimum and Local RA contracts requiring at least three years in length, CESA proposes that the ISO define qualifying PPAs based on a minimum contract length of one year. A one-year RA contract with a resource would still support LSE RA obligations, and the ISO should avoid narrowly defining qualifying PPA terms, which may only serve to constrict the RA supply. For various reasons, a new deliverable storage project may contract for RA on a short-term basis or as a bridge until a long-term offtake opportunity is secured.

Furthermore, CESA requests explicit clarification from the ISO on how the PPA eligibility and requirement would apply to the TPD retention process. During the February 1, 2022 stakeholder call, the ISO explained that the TPD allocation groups and PPA eligibility and requirements would take effect for the upcoming 2022-2023 TPD allocation cycle, but it did not yet have a position on how these changes would impact projects in previous clusters that have already been allocated deliverability. To this end, CESA recommends that the ISO not subject projects in earlier clusters to the currently-proposed 5-year PPA term requirement to retain previously-allocated deliverability, thus applying the broader Phase I changes on a going-forward basis and avoiding disruptive impacts. However, as discussed previously, CESA has concerns with different rules that apply to QC14 projects versus earlier QC projects, such that the ISO should align the rules as much as possible by retaining the current TPD Allocation Group 3 (proceeding without PPA), not requiring the PPA offtaker have an RA obligation, and lowering the minimum contract term for PPAs to one year. At minimum, if the ISO moves forward with some or all elements of its current proposal, the ISO should not move the goal posts. For example, if TPD allocation is given on a PPA, then executing that PPA within the one-year window must provide retention.

Finally, regardless of whether this proposal moves forward in full or in part, or with modifications, CESA urges the ISO to prioritize the efforts to provide further transparency on where deliverable transmission is available since developers would be interconnecting and developing projects without much certainty regarding whether the project will ever be eligible to provide RA, have an executed generation interconnection agreement (GIA), and be provided written notice to proceed (NTP) on network upgrades needed to interconnect the project. Especially if this proposal moves forward, despite strong stakeholder opposition, the ISO must accelerate solutions to Issue 6.3 to improve grid data transparency.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

CESA generally supports the ISO’s proposal to develop an emergency generation interconnection process, which puts reasonable guardrails and upfront processes in place, thereby mitigating the need to use tariff exemptions or out-of-ordinary processes and the risk of negative queue impacts. CESA, however, adds that the interconnection service should be limited to the emergency period, as established by the order or authorization from a state agency, yet no more than three years (as proposed by the ISO). In doing so, any use of the emergency generation interconnection process does not extend beyond what is necessary. Furthermore, alternatives should be explored from projects in the queue (e.g., ISP) that can take advantage of available interim deliverability.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

CESA neither supports nor opposes the ISO’s proposal to require site exclusivity to progress into the Phase II study process. Without repeating all the comments made previously to the ISO’s Issue Paper and Straw Proposal, CESA expressed how this requirement could impact projects of different technologies and locations, where some portion of the projects opting for a deposit in lieu of site exclusivity can be considered viable, and how a potential alternative solution could be to have higher non-refundable portions of these deposits.

Notwithstanding these considerations, if the ISO moves forward with this proposal, CESA recommends several clarifications and modifications. Specifically, the CAISO should explicitly clarify the site exclusivity documentation due date. According to the adopted Supercluster Interconnection Procedures, the initial interconnection financial security (IFS) is due on January 13, 2023;[1] based on the proposal to have site exclusivity paperwork due 10 business days before the initial IFS posting, this requirement will need to be met by December 29, 2022. Not only does this timeline fall within the holiday season, but the schedule to meet this requirement is also very compressed, such that the ISO should consider shifting the timeline to avoid the holiday season and push back the initial IFS posting date to the end of January, thus providing some additional time to secure site exclusivity for projects that require it.   

[1] Supercluster Interconnection Procedure Final Proposal at 7. http://www.caiso.com/Documents/FinalProposal-SuperclusterInterconnectionProcedures.pdf

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

CESA generally supports the proposal to establish the options and refund policies depending on the party at fault of an error or omission, including the full refund option if an error or omission on the part of the PTO results in PPA termination.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

CESA has no comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

As expressed previously in comments, CESA is supportive of this proposal, which appears to be unchanged from the Issue Paper and Straw Proposal.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

As expressed previously in comments, CESA is supportive of this proposal, which appears to be unchanged from the Issue Paper and Straw Proposal.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

CESA has no comment at this time.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

CESA has no comment at this time.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

CESA has no comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

CESA is generally supportive of these modifications and clarifications, which better aligns processes in accordance with the source (either IC or PTO) of any delays.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

CESA has no comment at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

CESA has no comment at this time.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

CESA has no comment at this time.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

The ISO discussed in the Revised Straw Proposal that a range of issues have been deferred to Phase 2 and will be considered in a future and updated version of a proposal. Some of these issues include the alignment of interconnection applications with procurement interest and policy objectives, various modifications to commercial viability and bars to entry (e.g., fees, deposits), cost allocation methodologies, and various process and queue management changes. Given the substantive nature the issues and proposals, and the target date of November 2022 for ISO Board approval, CESA recommends a timely and quick turnaround to begin discussing and considering these issues upon finalizing Phase 1 proposals. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

• The Staff of the California Public Utilities Commission (“CPUC Staff”) appreciates this opportunity to provide comments on the IPE 2021 revised straw proposal.
• CPUC Staff shares the concerns raised by multiple stakeholders that the proposed revision to the transmission plan deliverability (TPD) allocation process in Section 3.2 has the potential to delay and potentially reduce the availability of deliverability information that LSEs use in their procurement decision to sign PPAs with projects that can qualify for resource adequacy. Staff believes the CAISO should seek to work with stakeholders to address these concerns either through the TPD allocation process or other efforts that will increase communication and transparency of TPD availability at an earlier time.
• The CAISO should consider both state and federal processes that are involved in the development of offshore wind resources.  Without adding delay in the GIDAP process, the CAISO could consider ways to include state agency approvals in determining site exclusivity for an interconnection project, and not establish a criteria that is determined solely by the results of a Bureau of Ocean Management (BOEM) auction.
• Three comments in reference to Section 3.3: “How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?”
  • A) CPUC Staff would like to learn more about the separate stakeholder working group through which this important and urgent issue will be addressed. We encourage the CAISO to share with stakeholders as soon as possible details such as specific questions that will be explored next. This will provide stakeholders with time to prepare thoughtful proposals and allow the working group to more methodically work through options.
  • B)  CPUC Staff encourages the CAISO to use the 20-year Transmission Outlook results to inform identification of least regret policy-driven transmission in the future.
  • C) CPUC Staff encourages the CAISO to revisit the nature of policy-driven transmission approvals within the context of other planning processes.  It is important to ensure that policy-driven transmission capacity is available to achieve the policy goals. CPUC staff encourages CAISO to re-evaluate the time-consuming and uncertain process of waiting for projects in the queue to determine their willingness to pay allocated transmission costs, which creates a need for potential revisions to planned transmission projects.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

No comment at this time.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

CPUC staff appreciate CAISO staff’s efforts to address the difficult challenge of coordinating deliverability allocation with procurement and recognize the CAISO’s concerns regarding the development of a complex scoring system to assess all projects seeking to move forward without a PPA and reasons for maintaining the proposed categories. However, CPUC staff also acknowledge and share the concerns raised by multiple parties that these proposed adjustments potentially remove a key path via which project deliverability information is made available, particularly for LSEs seeking to procure resources. The current group 3, which allows projects to progress and receive deliverability allocation without a PPA, has created a pool of projects with known deliverability status that LSEs can consider when procuring. Under the simplified groups proposals, LSEs may be forced to take risks and procure resources without knowing if that project will receive deliverability and would be able to count for resource adequacy. It is important that any revisions still ensure sufficient deliverability information on potential projects is available before a PPA has been signed to enable LSEs to have this information when assessing projects for procurement. There needs to be increased transparency on where transmission deliverability is available and an effective method to assess if projects would be likely to receive deliverability to assist LSEs in the procurement process. To that end, CPUC Staff supports continued discussion amongst the CAISO and stakeholders to ensure transmission deliverability information is available for both LSEs and developers either through further adjustments to these proposed transmission plan deliverability allocation revisions or through the development of separate efforts to increase the communication and transparency of information regarding the location and availability of transmission deliverability.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

No comment at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

In identifying the nature of “site exclusivity” for offshore wind projects, the CAISO should consider the unique aspects for development of offshore wind resources -- in particular, multiple regulatory processes and the considerable amount of coordination that is required among federal and state agencies. Simply acquiring a BOEM lease for specific area of offshore wind development may not be the only important criteria for site exclusivity within the interconnection process.  If there are ways to consider processes conducted by state agencies (such as environmental, cultural and tribal impacts) as well in determining whether an interconnection project has achieved site exclusivity, without adding an unreasonable amount of time to the process, then CAISO may want to recognize and incorporate these checks within the criteria for site exclusivity.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

No comment at this time.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

No comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

No comment at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

No comment at this time.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

No comment at this time.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

No comment at this time.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

No comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

No comment at this time.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

No comment at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

No comment at this time.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

No comment at this time.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

The three comments below (A-C) are all in reference to Section 3.3: “How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?”

A) CPUC Staff would like to learn more about the separate stakeholder working group through which this important and urgent issue will be addressed. We encourage the CAISO to share with stakeholders as soon as possible details such as specific questions that will be explored next. This will provide stakeholders with time to prepare thoughtful proposals and allow the working group to more methodically work through options.

According to the responses CAISO staff provided during the stakeholder meeting, our understanding is that the working group process will run in parallel to Phase 2 but may begin slightly earlier. With recent procurement orders including long lead time resource types and an increased need for policy-driven transmission upgrades, alignment of these activities needs to be prioritized, particularly considering that this specific issue may require a more substantive solution such as a restructuring of existing processes or development of a new process. CPUC Staff agrees with stakeholders such as EDF R who emphasize that band-aid solutions are insufficient to address this issue. With that in mind, CPUC Staff notes that Phase 2 of this IPE Initiative, like Phase 1 is currently scheduled to be extremely fast paced. Within approximately 7 weeks the CAISO plans to go from a draft proposal to tariff language. This schedule may not provide sufficient time to properly develop solutions without having to exclude more comprehensive yet complex solutions simply due to time constraints.

B)  CPUC Staff encourages the CAISO to use the 20-year Transmission Outlook results to inform identification of least regret policy-driven transmission in the future.

GSCE had an interesting suggestion on how this can be accomplished. “CAISO could look to transmission projects in the 20-year outlook as policy projects... CAISO could refine its interconnection process or create a separate study track that is policy-zone oriented, focusing on specific zones that can proactively unlock resources for policy needs that meet certain eligibility criteria to apply.” CPUC Staff believes this idea is worth further exploring.

C) CPUC Staff encourages the CAISO to revisit the nature of policy-driven transmission approvals within the context of other planning processes.

This effort focusing on “How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes?” is an excellent opportunity to further explore two questions:

1. How should commercial interest inform resource and transmission planning processes?
2. Should there be a mechanism for ensuring that policy-driven transmission capacity is reserved for achieving policy objectives?

As stakeholders note, there may be an opportunity to further consider to what extent commercial interest should inform policy-driven transmission approvals. Currently commercial interest informs transmission upgrades via two routes:

1. By commercial interest in busbar mapping which is used to identify TPP policy-driven transmission approvals
2. By the interconnection queue requests which lead to upgrades paid for up-front by project developers if they choose to proceed with their project

This IPE enhancement is an important potential area for improvement that directly relates to the CPUC’s role in the resource planning process. CPUC Staff acknowledge that commercial interest may not accurately capture true expected project development nor the best locations for grid upgrades to meet policy objectives considering the current overheated queue. For this reason, commercial interest is only one of multiple factors that is considered in the busbar mapping process. Additionally, the more granular busbar mapping process being applied in the 2022-23 TPP aims to improve some of the coordination issues stakeholders noted in prior TPPs. To continue to improve this coordination going forward, it is important to define how these two processes could be better aligned and consider the implications of different approaches to doing so.

One option is to try to reduce how many transmission upgrades are identified as necessary by the interconnection process, and instead frontload the identification and development of even more transmission upgrades through the TPP policy-driven assessment or a similar process. For example, the CAISO, in coordination with the CPUC and CEC planning processes, could establish the size and location of transmission projects that would be beneficial for achieving the states’ policy objectives. This could utilize a variety of information sources, such as the 20-year Transmission Outlook.

This approach may speed development in some areas by bypassing certain challenges of allocating larger transmission costs among projects in the queue, then waiting to see if the projects remain in the queue to confirm their willingness to pay the allocated transmissions cost, and finally revising the planned transmission project (and costs) to downscale to the size of requests from remaining projects in the queue.  We encourage considering this, or some other alternative process, that will avoid project delays or cancellation and uncertainty regarding transmission upgrades.

CPUC Staff is committed to collaborating with the CAISO on improving alignment within the context of interconnection process enhancements.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

EDF-R appreciates the opportunity to provide comments on the Interconnection Process Enhancements 2021 Phase 1 revised straw proposal. EDF-R supports the CAISO’s decision to postpone some of the substantial policy discussions to Phase 2 of the initiative. EDF-R agrees that the CAISO should take sufficient time to consider the effectiveness and possible outcomes for major GIDAP process changes. To that end, EDF-R requests the CAISO postpone finalizing the proposal to remove Transmission Plan Deliverability (TPD) allocation group 3 and continue the discussion of this topic into Phase 2 of the initiative.

EDF-R and many other stakeholders strongly oppose the removal of TPD allocation group 3. It is EDF-Rs perception that the CAISO considers the removal of the opportunity for projects without a power purchase agreement (PPA) to receive a TPD allocation as a minor change, but this is not the case. This change will have far reaching impacts on development and solicitation processes by reducing transparency and introducing new risks into the solicitation process. EDF-R requests that the CAISO postpone its decision to move forward with removal of TPD allocation group 3 in IPE Phase 1 and continue to discuss the topic in Phase 2 of the initiative in tandem with proposals of similar magnitude, and in the context of considering the major holistic changes needed to meet the interconnection demands driven by the state’s goal of serving load with 100% renewables.

In the event CAISO moves forward with this policy change, EDF-R strongly urges the CAISO to deliver the results of the Transmission Grid Data Transparency effort before formalizing the removal of allocation group 3 policy in a FERC filing.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

EDF-R continues to support this proposal.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

EDF-R opposes the CAISO’s proposal to remove eliminate TPD allocation group 3 and limit TPD allocation to projects that either have an executed RA contract or are on a shortlist.

The CAISO’s IPE proposal already introduces policies that are likely to narrow the number of interconnection requests eligible for TPD allocation. For example, the CAISO is proposing that, for cluster 14 and beyond, the CAISO will require actual site control (rather than a deposit) to proceed to the Phase II study. This control alone reduces the number of TPD eligible candidates by 68%.[1] The CAISO can continue to refine the process with the additional hurdles to entry that are set to be discussed in IPE Phase 2.

The CAISO’s proposal to eliminate TPD allocation group 3 introduces more difficulty and uncertainty into the already-complex task of developing and marketing new interconnection requests. In this scenario developers would have to compete in RFOs without knowing if the project will ever be eligible to provide RA, before the project has executed a GIA, and before the project has provided written notice to proceed on network upgrades needed to interconnect the project (meaning PTO construction schedules and achievable commercial operation dates are still very much in flux).

In the event CAISO moves forward with this policy change, EDF-R strongly urges CAISO to deliver the results of the Transmission Grid Data Transparency effort before formalizing the removal of allocation group 3 policy in a FERC filing. The provision of unambiguous and accessible information about the interconnection and deliverability availability on the CAISO system is the most efficient way to meaningfully reduce the amount of complexity this policy will introduce into the RA solicitation process.

EDF-R also requests CAISO revise the proposal to allow for energy only projects that have not yet declared commercial operation to be able seek a TPD allocation in groups 1 or 2 if they otherwise qualify. The current proposal paradigm, which would require a project to declare commercial operation as a merchant facility before competing to a TPD allocation will likely prove ineffective given that fewer than 1% of projects that declare commercial operation are energy only.

[1] http://www.caiso.com/InitiativeDocuments/RevisedStrawProposal-InterconnectionProcessEnhancements2021.pdf page 23

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

EDF-R requests clarification on how the CAISO enforce the 3-year operation limit -- will the generator be disconnected promptly, or will the GIA have a firm termination date?

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

EDF-R supports the proposal to require site exclusivity for an interconnection request to be studied in Phase II.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

a. General comments on errors and omissions topic

EDF-R supports the proposal and agrees that any cost responsibility increases associated with an error or omission on the part of the Participating TO that is discovered after a project’s due date for its second IFS posting should be the responsibility of the Participating TO.

b. comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered.

EDF-R supports the inclusion of this provision. Delivery of product (energy or RA) on an agreed time schedule is the primary obligation of the seller under the PPA. If an error or omission by the PTO delays the projects earliest achievable COD (and thus its energy or RA delivery date), the developer should qualify for the refund.

i. What specific documentation of a project’s PPA termination should be required? 

Similar to Generator Interconnection Agreement terminations, RA contract termination documentation will vary from project to project. The CAISO can reasonably expect to see contract documentation or communication that validates that the milestones were jeopardized, and to see correspondence between the Seller and the Buyer that verifies the contract was terminated.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

No comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

No comment at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

 EDF-R supports this proposal.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

EDF-R supports the CAISO’s proposal to allow only fuel-type, technology and POI changes, by the Interconnection Customer.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

No comment at this time.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

No comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

No comment at this time.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

EDF-R supports the expansion of deliverability transfer opportunities.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

 No comment at this time.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

EDF-R supports this proposal.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Thank you for the opportunity to comment on the Interconnection Process Enhancements proposal.  EDP Renewables N.A. supports the comments submitted by SEIA and ACP-CA and focuses these comments on one particularly concerning aspect of the Revised Straw Proposal in Section 3.2 that has immediate commercial impacts and is time sensitive.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

See answer to question #1 above.  

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

EDP Renewables is currently developing several large co-located solar and storage projects in the ISO’s footprint.  These projects are in various phases of development, including pre-construction today, and range from Cluster 8 to Cluster 14. 

EDP Renewables is concerned with the following language in the Revised Straw Proposal:

“The ISO proposes to revise the tariff to clarify that beginning with the 2022-23 TPD allocation cycle, a PPA must be with an off-taker to fulfill its own RA obligation. In other words, the PPAs of off-takers that do not have RA obligations will not be eligible for groups 1 or 2. Furthermore, the PPA must procure the deliverable capacity for a minimum of five years to be eligible.”

EDP Renewables interprets this proposal to mean that PPAs with a large C&I customer for energy and Resource Adequacy would no longer qualify for retaining Resource Adequacy, even if that C&I customer can show an obligation with its host Load Serving Entity (LSE) to be responsible for their portion of the LSE’s RA obligation.  Our understanding of the status quo is that such C&I PPAs do qualify today, as long as the ultimate RA obligation to an LSE can be demonstrated. 

EDP Renewables opposes the concept of requiring PPAs for RA to be with off-takers that are fulfilling their own RA obligation.  Doing so would unnecessarily constrain the Resource Adequacy market and would cause inefficient use of Deliverability Network Upgrades funded by ratepayers.  C&I customers are significant purchasers of clean energy and Resource Adequacy today, but this aspect of the Revised Straw Proposal would force them to only contract for the energy going forward.

EDP Renewables is particularly concerned with the potential application of this proposal to the 2022-23 TPD allocation cycle.  Doing so would impact projects as far back as Cluster 8 and effectively changes the rules for these projects retroactively.  If, as currently planned, the ISO finalizes this proposal during the May Board of Governors meeting, interconnection customers as far back as Cluster 8 would have roughly six months before Deliverability Affidavits are due to change their commercial negotiations and find new off-takers for their Resource Adequacy.   This scenario creates the real possibility that Deliverability Upgrades already being funded by ratepayers ultimately go underutilized. 

In order address these retroactive impacts to customers, and to support the timely contracting and construction of mature projects with deliverability that could bring Resource Adequacy to the market in 2023, the ISO should—as soon as possible—retract the application of this proposal to the 2022-23 allocation cycle.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

See answer to question #1 above.  

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

See answer to question #1 above.  

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

See answer to question #1 above.  

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

See answer to question #1 above.  

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

See answer to question #1 above.  

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

See answer to question #1 above.  

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

See answer to question #1 above.  

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

See answer to question #1 above.  

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

See answer to question #1 above.  

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

See answer to question #1 above.  

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

See answer to question #1 above.  

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

See answer to question #1 above.  

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

See answer to question #1 above.  

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

See answer to question #1 above.  

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Golden State Clean Energy (“GSCE”) appreciates the opportunity to submit this comment.  GSCE is generally supportive of the direction of many CAISO proposals in this initiative, including the working group process that will separate out some topics previously scoped for phase two. However, we are frustrated with the lack of response to stakeholders on the issue of requirements for a PPA to qualify to seek transmission plan deliverability.  We continue to believe that this proposal will be harmful for resource development in the state and that it is not supportable for any policy reason. As CAISO knows, several parties opposed CAISO’s proposal to exclude PPAs with offtakers that do not have RA obligations from being eligible for deliverability allocation groups 1 or 2.  At the same time, CAISO received little stakeholder support for its proposal.  The proposed compromise approach, where a corporate PPA could count if the RA is demonstrated to be sold to an entity with an RA obligation, would be administratively burdensome and is at odds with practical commercial realities.  

In addition, GSCE is concerned about setting a minimum term for contracts to qualify for an allocation of deliverability.  While most PPAs requiring deliverability will be long-term PPAs for energy and capacity (which renders a new minimum term rule unnecessary), if CAISO really wants to encourage resources, particularly storage, to be developed and qualify to support the resource gap in California, CAISO should consider that pure RA contracts are commonly for one to three-year terms.  Once a resource is able to sell RA, it will continue to do so because of the commercial value.  It is not clear to us what CAISO is expecting to achieve with this proposal or why it believes the proposal improves things.  Setting a five-year requirement does not appear linked to any real-world commercial length associated with RA contracting.  Even a three-year minimum term could represent a significant impediment.  We urge CAISO to strengthen other measures to qualify for a deliverability allocation that signal a project’s ability to proceed to commercial operation (e.g., site control) rather than impose new requirements that will impede development of resources capable of supplying RA.

Lastly, we appreciate CAISO providing the numerical breakdown of Cluster 14 interconnection requests that provided site exclusivity documentation versus those that provided an in-lieu site exclusivity deposit.  In this initiative, GSCE has supported stronger site exclusivity requirements throughout the interconnection and deliverability allocation process.  The number of Cluster 14 interconnection requests that provided site exclusivity documentation roughly comports with a more typical cluster size, and this provides a compelling case for CAISO to reconsider its proposal regarding site exclusivity and require site exclusivity in an interconnection request.  Such a proposal would represent a more serious attempt to control the size of future clusters without the risk of unreasonably restricting interconnection requests, as proven by the Cluster 14 IR data.

Below we provide additional comments on a limited set of questions posed by CAISO. Our comments address the following topics:

• Question 3 regarding the TPD allocation process and qualifying PPAs;
• Question 5 regarding site exclusivity;
• Question 6 regarding errors and omissions impacts on financial postings;
• Question 14 regarding deliverability transfers;
• Question 16 regarding RIMS documentation;
• Question 17 regarding phase 2 of the initiative.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

GSCE does not comment on this proposal at this time. 

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

GSCE is supportive of CAISO’s decision to streamline the TPD allocation categories. However, we remain concerned that full elimination of an option to proceed without a PPA is problematic.  CAISO should consider adding a means for late-stage projects capable of delivering capacity to qualify for deliverability.  We offer the following recommended refinements to CAISO’s proposal regarding the allocation groups:

• Expand proposed allocation group 3 (currently proposed for projects that have reached commercial operation) to also include projects that have provided the PTO with notice to proceed to construction.  These projects are fully committed financially and have permits necessary to allow them to proceed to construction.  Projects that have provided their notice to proceed are much more likely to reach commercial operation than projects that are shortlisted for a PPA. Expanding group 3 to projects that have provided a notice to proceed may slightly alleviate some of the concerns around eliminating current group 3 and the limitations that move imposes on commercially viable projects attempting to qualify for a deliverability allocation.
• Flip the allocation order of proposed group 2 and 3 (making projects that reached commercial operation or that provided a notice to proceed the new group 2).  This will get deliverability to projects that are most likely to benefit the RA program because the uncertainty of reaching commercial operation is significantly reduced, making them more deserving of deliverability than projects that are shortlisted and may not be the successful entity to receive a PPA.  Projects that have reached commercial operation or that have provided a notice to proceed can also provide the most immediate source of new RA capacity. Arguably these projects should be group 1 since they can deliver RA fastest and best ensure use of the existing transmission system.
• Consider allowing later stage “ready” projects to apply for a group 4 (defined by full site control, completed interconnection facilities, or other relevant elements).  These are objective measures for CAISO to consider that are well within CAISO’s institutional competency to assess.

Regarding the proposed requirements for a PPA to qualify to seek TPD, we continue to oppose CAISO’s proposal to exclude PPAs that require RA but were executed with corporate entities.  Our previous comment offered reasoned support for why CAISO’s proposal to exclude corporate PPAs ignores the commercial reality that these RA resources will eventually end up on an LSE’s RA plan, resulting in DNUs being funded for the benefit of ratepayers as envisioned by CAISO.  CAISO failed to address these comments all together and has not made a case for excluding commercial PPAs. We urge CAISO to reconsider its proposal.  At the very least, CAISO should grandfather existing corporate PPAs.  Otherwise, certain resources contracted for RA will be discriminated against in a manner that harms their deliverability eligibility simply due to the identity of the offtaker.  We do not see this distinction as justifiable under the Federal Power Act.

GSCE is also concerned about creating a minimum term requirement for PPAs to be eligible for an allocation of deliverability, and we do not support a five-year minimum requirement. We do not see this proposed term as aligned with pure RA contract terms, and it is not clear to us what problem CAISO’s proposal is trying to fix. CAISO should be focused on supporting new resources capable of delivering capacity and figuring out how these resources can qualify for deliverability rather than imposing new barriers.  

Finally, GSCE requests that CAISO elaborate on why energy only projects in the queue that are seeking TPD cannot trigger DNUs.  This seems to extrapolate current tariff requirements for allocation groups 4-7 onto the new groups 1-3, but it is unclear to us the policy rationale for not allowing certain projects in the queue to trigger and fund DNUs.  Moreover, we are concerned about preventing some projects from triggering DNUs when CAISO’s proposal will already make it harder to qualify for deliverability, thus likely resulting in more projects first becoming energy only until they can qualify with a PPA or by being shortlisted.  

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

GSCE does not comment on this proposal at this time. 

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

GSCE only comments on (a), general comments, and not (b), consideration of offshore wind in the definition of site exclusivity.

GSCE agrees with CAISO’s valuation of site exclusivity as an indicator of readiness for an interconnection request to advance through the study process.  Increasingly, land use issues will be harder to navigate as more local siting restrictions appear.  Discussions surrounding FERC’s recent transmission and generation interconnection ANOPR[1] have often circled around a readiness study process, and site exclusivity is a sensible readiness criterion that CAISO can inject into its existing queue cluster study process.

CAISO should take this even further – requiring interconnection customers to provide site exclusivity in an interconnection request would provide a significant impact to the GIDAP without upending the process.  This is a needed balance, as the queue size is highly problematic and nothing CAISO has proposed in this initiative will meaningfully restrict new interconnections requests going forward.

The Revised Straw Proposal provides good insight into the impact of requiring site exclusivity in an interconnection request.  For Cluster 14, 119 of the 372 interconnection requests provided site exclusivity documentation, which is roughly comparable to past IR window sizes. CAISO has argued this figure shows it is reasonable to require site exclusivity prior to Phase II, but GSCE finds this supportive of the reasonableness of requiring site exclusivity in the interconnection request.

[1] FERC docket RM21-17-000.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

GSCE supports this proposal.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

GSCE does not comment on this proposal at this time. 

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

GSCE does not comment on this proposal at this time. 

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

GSCE does not comment on this proposal at this time. 

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

GSCE does not comment on this proposal at this time. 

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

GSCE does not comment on this proposal at this time. 

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

GSCE does not comment on this proposal at this time. 

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

GSCE does not comment on this proposal at this time. 

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

GSCE appreciates CAISO providing initial draft tariff language for this proposal. We have one concern about how the draft tariff language is currently constructed – the change in the second paragraph could be read as eliminating the ability of an interconnection customer to reallocate deliverability among its Generating Units. Thus, we recommend that CAISO make the following modification to the second paragraph so the proposed additional ability to transfer deliverability does not incidentally impact the current tariff rules:

An Interconnection Customer may request to reallocate its Deliverability as provided in this Section 8.9.9 pursuant to Section 6.7.2.2 of this GIDAP, Article 5.19 of the LGIA, and Article 3.4.5 of the SGIA, as applicable. A repowering Interconnection Customer may transfer Deliverability as part of the repowering process pursuant to Section 25.1.2 of the CAISO Tariff. An Interconnection Customer expanding its capacity behind-the-meter pursuant to Section 4.2.1.2 also may transfer Deliverability as part of that process, or subsequently under the other processes in this Section.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

GSCE does not comment on this proposal at this time. 

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

GSCE supports this proposal.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

GSCE requests that the proposed workshop process that will parallel phase 2 be noticed in this initiative in addition to any general market notices.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Q CELLS appreciate the opportunity to provide continued feedback as part of CAISO’s Interconnection Process Enhancement 2021.

Q CELLS is primarily concerned with three items: TPD Allocation Groups, Application Costs and Site Exclusivity. Our responses to each point are provided below. Other responses are similar to previous submissions.

About Hanwha Q CELLS

Q CELLS is a total energy solution provider worldwide. Our business scope ranges from the midstream of cells and modules to downstream solar solutions for residential, commercial, and industrial buildings, as well as for large solar power plants.

Since our entry into the solar energy business in 2010, the Hanwha Group has transformed Hanwha Q CELLS into the world’s leading producer of solar cells and modules. Our current production networks span across China, Malaysia, South Korea, and the US. Bolstered by strong revenue and driven to stay ahead of the growing worldwide demand, we’ve continued to invest in R&D and manufacturing innovations. Our Malaysia plant alone was able to produce more than 1GW of Q.ANTUM cells annually in 2015, the first of its kind in the industry. In Q1 2019, we penetrated the US market and began our acceleration to expand into the country by building a 1.7GW capacity module plant in the US state of Georgia.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

Q CELLS continues to support the removal of the downsizing window, allowing developers to make changes more dynamically to their project parameters. Q CELLS believe this simplification will be a benefit to the entire interconnection process.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Q CELLS does not support the current 1/25/22 straw proposal of Allocation Group 3 (projects that are online as merchant generation where output/capacity is not contracted by a LSE). 

Q CELLS supports Allocation Group 3 to have the ability to obtain/park transmission plan deliverability (TPD) while awaiting final PPA confirmations since:

1. While a developer is in the PPA solicitation process, it is best to show TPD to ultimately finalize the PPA contract.
2. Without the TPD, one could not sell Resource Adequacy (RA) to load-serving entities (LSEs). 
3. In order for CA to be 100% renewable and zero-carbon by 2045, CAISO needs to provide this adjustment in the straw proposal so that more projects can be implemented by means of certainty of TPD which would lead to more signed PPAs & RA assurance for the State of California. 

Q CELLS is open to a proposal that includes a 4th group just for merchant generation.  This still results in efficiencies by going from 7 groups down to 4 groups.

Q CELLS supports CAISO to provide further transparency on where deliverable transmission is available since developers are marking projects without having the following items that create an environment of project certainty:

1. If the project will ever be eligible to provide RA.
2. Have a executed generation interconnection agreement
3. Provided written notice to proceed on network upgrades needed to interconnect the project.

Q CELLS also supports a more flexible approach other than PPA must be with an offtaker to fulfill its own RA obligation since then it will be unlikely that non-LSE parties will advance the development of deliverable energy projects and the market should be allowed to evolve to allow entities to provide more flexible products to LSEs. 

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

Q CELLS supports this proposal and has no further comments at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

Q CELLS supports this proposal that allows for partial site control to progress to phase 2 studies. Q CELLS remains opposed to in-lieu deposits, especially increases of those deposits, to proceed to phase 2; since site control / site exclusivity is appropriate at this stage.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

Q CELLS has no comment. 

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Q CELLS has no comment. 

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Q CELLS has no comment. 

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Q CELLS has no comment. 

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

Q CELLS has no comment. 

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Q CELLS has no comment. 

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

Q CELLS has no comment. 

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

Q CELLS has no comment. 

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

Q CELLS has no comment. 

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

Q CELLS has no comment. 

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

Q CELLS has no comment. 

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

Q CELLS has no comment. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Hydrostor appreciates the efforts put in by the CAISO on the Interconnection Process Enhancements (“IPE”) 2021 initiative.  We believe that the stated goal of aligning interconnection processes; transmission and resource planning; procurement initiatives; and state policy objectives is critically important.  Only when these activities are aligned will the state be able to achieve its environmental (including decarbonization), reliability and cost-effectiveness objectives including the deployment of valuable grid resources such as long duration energy storage (“LDES”). 

In general, Hydrostor supports efforts to simplify the interconnection processes as further described in the specific answers to the questions below. This includes elimination of the TPD retention criteria.

Hydrostor notes that a number of important issues have been deferred by the CAISO to Phase 2: Long-Term Enhancements or to separate stakeholder processes.  We urge the CAISO to address these issues in an expeditious manner.  Specific issues for consideration that are highly relevant to LDES include:

Section 3.3: How can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios for planning purposes? 

The CPUC supported more discussion regarding withholding and reservation of transmission capacity for projects that achieve policy goals and that the “ISO prioritize withholding transmission capacity for long-lead time and location constrained resources”.  As LDES is often a long-lead time resource, it should also be considered for any transmission capacity that may be withheld in a future process.

Hydrostor shares the CAISO’s concerns that there is a “lack of coordination among the transmission planning process—and policy-driven transmission in particular—the interconnection process, and load serving entities’ procurement processes continue to create the opportunity for transmission to be utilized by resources not envisioned in the original policy direction but earlier-positioned in the queue, resulting in challenges in meeting state resource policy goals.”  In the revised straw proposal, the CAISO defers further discussion of this to a separate stakeholder working group.  Further details need to be provided on this separate stakeholder working group.

Section 3.4: Should a solicitation model be considered for some key locations and constraints not addressed in portfolio development, where commercial interest is the primary driver?

The concepts proposed here warrant further consideration by the CAISO and may wish to consider it alongside the concepts proposed in Section 3.3.  In areas of the grid where there is commercial interest and limited transmission capacity, consideration of alignment with state policy objectives (including the need for LDES) may be warranted.

Again, the CAISO defers further discussion of this to a separate stakeholder working group.  Further details need to be provided on this separate stakeholder working group.

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Long duration energy storage has a valuable role to play in the future CAISO grid and we remain concerned that interconnection and Deliverability challenges may hinder its timely development. 

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

Hydrostor is supportive of removing the downsizing window and simplifying the downsizing request requirements.  

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Hydrostor echoes the comments from the CPUC (noted in the revised straw proposal) that greater efforts are needed to “support state policy and procurement goals” which could include the deployment of LDES in the state. 

While Hydrostor notes the CAISO’s comment that retention of Allocation Group three could “result in all remaining TPD to be allocated in the next cycle” has merit, further consideration of proposals by various stakeholders of ways to potentially modify Allocation Group three is warranted before its elimination.  This could include having the Interconnection Customer (“IC”) secure a PPA within a fixed period of time. 

 Hydrostor supports the removal of the TPD retention criteria as proposed by the CAISO.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

 Hydrostor has no comments at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

 Hydrostor has no comments at this time.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

Hydrostor supports the CAISO proposal and specifically supports the inclusion of PPA termination due to errors and omissions of a PTO within the eligibility criteria for project withdrawal and receiving a full refund of the IFS and unused study deposit.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Hydrostor has no comments at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Hydrostor supports the CAISO proposal and support the request from LSA/SEIA and RWE Renewables that the CAISO provide public information about the operational control of substations and lines to diminish this being a problem.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Hydrostor supports the CAISO proposal but notes that more information needs to be made available publicly such as clear study area boundaries (among other items).   

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

 Hydrostor has no comments at this time.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Hydrostor supports greater clarity on timelines as long as it is presented in a transparent manner to all parties.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

Hydrostor has no comments at this time.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

Hydrostor supports the CAISO proposal. However, Hydrostor believes that further consideration should be given to CalWEA’s suggestion regarding a Limited Operation Study more than 5 months before the Initial Synchronization Date and it warrants further review.  This may be particularly helpful for projects that seeking to assist in meeting the state’s Mid-Term Reliability needs.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

Hydrostor supports the CAISO proposal.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

 Hydrostor has no comments at this time.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

Hydrostor supports the CAISO proposal.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

Please see our answer to Question 1.  As noted in our answer to Question 1, there are a number of very important issues which the CAISO has deferred to Phase 2 or to other stakeholder processes.  We believe that these should be advanced in earnest – particularly issues where there needs to be greater alignment of transmission planning processes, interconnection process, procurements and state policy objectives.

Long duration energy storage has a valuable role to play in the future CAISO grid and we remain concerned that interconnection and Deliverability challenges may hinder its timely development. 

Further, Hydrostor strongly supports greater grid data transparency and would be interested in participating in the offline discussion proposed by the CAISO.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Leeward Renewable Energy (“Leeward”) is a wind, solar, and storage developer and long-term asset owner and operator with a significant footprint in the CAISO market.  Leeward has 88 MW of operating wind in California, 474 MW of solar coupled with 108 MW of battery storage currently under construction and/or contracted, and an additional 2.7 GW of solar and 3.1 GW of battery storage in the CAISO interconnection queue. 

Leeward supports sustainable queue reform that identifies and prioritizes the most viable projects to move forward, ensuring the interconnection of resource adequacy capacity for Calfornia’s near-term needs.  As part of that effort, Leeward strongly recommends the CAISO take two additional steps in Phase I of IPE: 

1. Modify the Site Exclusivity requirement for projects sited on public land, ensuring those projects are treated equitably and not disenfranchised relative to projects on private land; and, 

2. Allow projects to fully securitize their network upgrades in order to move forward into Phase II studies, in lieu of site control. 

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

Leeward has no comments at this time.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Leeward has no comments at this time.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

Leeward has no comments at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

Leeward appreciates the position that CAISO finds itself in and supports the concept of creating more stringent requirements to move forward to Phase II studies.  However, establishing site exclusivity as the sole arbiter of whether or not a project is worthy of being prioritized creates an unintended bias in the process.  QC14 projects that are sited on public land will be disenfranchised due to no other reason than public land procedural processes, which can take many years to complete, and do not easily fit within CAISO’s narrow definition of site control.  The CAISO’s proposal, whether intentional or accidental, unjustly preferences projects sited on private land, where site control can be bilaterally negotiated.   

Separate and distinct requirements related to site exclusivity are not uncommon in the Western Interconnection, where significant swaths of land are held by government agencies at the state, federal, and tribal levels.  PacifiCorp recently filed revisions to its Generator Interconnection Procedures at FERC (docket ER22-834) that created an alternative threshold for public land projects to meet.  In that filing, PacifiCorp stated that “[f]or Interconnection Customers seeking to develop projects on property managed by governmental agencies, such as the Bureau of Land Management (“BLM”), demonstrating actual site control at the facilities study stage may be difficult, given the permitting and other administrative processing considerations involved.”  PacifiCorp has proposed that, for lands managed by a governmental entity, a Preliminary Plan of Development (“PPOD”) or equivalent government-issued documentation would satisfy their site control requirement to move forward.  As pointed out by PacifiCorp, this language is consistent with FERC-approved language in NV Energy’s tariff.  In NV Energy’s LGIP, Site Control is articulated separately for private, BLM, and Tribal and other lands.   

Leeward recognizes that CAISO’s existing tariff distinguishes between public and private land in its Site Exclusivity definition; however, CAISO’s public land requirement, particularly for moving into a Phase II study, is demonstrably stricter than other large transmission operators in the Western Interconnection.  Projects entering QC14 that leverage public lands would essentially have the goal line shifted dramatically under CAISO’s proposal and would potentially face an immediate and arbitrary halt to otherwise highly viable projects. 

Leeward proposes that CAISO shift its Site Exclusivity requirement in the IPE to better account for the idiosyncrasies of siting projects on public land.  We recommend: (1) projects on Federal land meet the requirement through the submission of a PPOD; and, (2) projects on State land meet the requirement by showing documentation indicating confirmation of priority bidder status for land auctions or similar activities.  This approach better allows for public land projects to be treated fairly as CAISO addresses its queue backlog and prevents unjust treatment relative to projects sited on private land. 

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

Leeward has no comments at this time.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Leeward has no comments at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Leeward has no comments at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Leeward has no comments at this time.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

Leeward has no comments at this time.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Leeward has no comments at this time.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

Leeward has no comments at this time.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

Leeward has no comments at this time.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

Leeward has no comments at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

Leeward has no comments at this time.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

Leeward has no comments at this time.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

The overarching goal for CAISO in streamlining the queue process should be ensuring that highly viable and “shovel ready” projects are capable of moving forward quickly, while “phantom” projects that are simply fishing for information are deprioritized.  While it may be prudent for CAISO to hold off on requiring higher fees and deposits at this time, allowing for further consideration in Phase II of the IPE, Leeward encourages CAISO to consider an option for projects that do not otherwise qualify the option to fully securitize network upgrade costs and move into the Phase II study process.  Such an option would ensure that projects truly committed to coming online have an avenue with which to continue in the process.  Given the resource adequacy needs of the California system in the next several years, it is imperative that CAISO not unintentionally exclude viable projects from moving forward. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Please see our comments in the attachment.  We have found this method to be the most expedious and effective, due to the limited ability to cut and paste into the template while retaining formats (requiring considerable reformatting in the template), the limiting formatting tools in the template, and the occasional tendency of the template to delete all content seemingly randomly (usually once everything has been cut-and-pasted in, and re-formatted).

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

See attachment.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

See attachment.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

See attachment.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

See attachment.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

See attachment.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

See attachment.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

See attachment.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

See attachment.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

See attachment.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

See attachment.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

See attachment.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

See attachment.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

See attachment.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

See attachment.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

See attachment.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

See attachment.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

MRP continues to support many aspects of the CAISO’s proposed Phase 1 modifications, such as (1) offering a continuous downsizing process and (2) requiring Site Exclusivity (“SE”) to proceed to Phase II of the study process.  Conversely, MRP continues to oppose other aspects of the CAISO's Revised Straw Proposal, for example, the proposals to (1) eliminate Transmission Plan Deliverability (“TPD”) Allocation Group 3 and (2) tie the deadline for Schedule B submittals to the issuance of the study report and not the date of the results meeting.  MRP also encourages the CAISO to consider re-examining and fixing the Independent Study Process (“ISP”) in lieu of creating a new, separate emergency interconnection process (though, if the CAISO insists on moving forward with the emergency interconnection process, that the CAISO work with stakeholders to develop and codify that process in the CAISO Tariff well in advance of it being used.)  

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

MRP supports the CAISO’s proposal.  MRP reiterates that the success of this proposal depends on the CAISO’s willingness to devote sufficient staff resources to it. 

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

As with several other parties that commented on this topic during the February 1 call (Gridwell, LSA/SEIA, CalWEA, Vistra), MRP continues to oppose the CAISO’s plan to revise the TPD allocation process to eliminate Allocation Group 3.  Group 3 developers face restrictions that other developers do not face and face risks by proceeding without a PPA.  MRP is not aware that Group 3 projects have taken up deliverability or lingered in the queue, and therefore does not understand or appreciate what problem the CAISO is trying to solve by proposing to eliminate this allocation group.

MRP offers an additional comment with regards to a related issue that was discussed in this section of the RSP.  Upstream Energy’s proposal allows ISP projects the ability to seek an allocation of deliverability as soon as their System Impact Studies and Facility Studies are complete.  The CAISO responded that doing so would constitute queue jumping.  MRP observes that the CAISO offers the ISP expressly for situations in which the CAISO’s interconnection cluster process cannot accommodate the project’s desired Commercial Operations Date (“COD”).  Studying ISP projects submitted in early 2022 as part of a much later cluster deliverability allocation process negates the ISP’s purported purpose of offering projects a timing that cannot be offered by the cluster process.  To allow the ISP to function as it was intended, MRP respectfully urges the CAISO to reconsider and adopt Upstream Energy’s proposal. 

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

In prior comments, MRP supported the CAISO developing an emergency interconnection process as long as (1) that process was developed and codified in the Tariff prior to it being needed, and (2) that WDAT projects, especially utility-owned WDAT projects, could not use the proposed emergency interconnection process to bypass the CAISO’s interconnection process. 

Upon further consideration, MRP’s strong preference would be for California to develop and implement a rational, regular procurement process that would completely obviate the urgent, but avoidable, need to periodically deploy new generation on an emergency basis when system conditions tighten after years of procurement inaction. 

While MRP believes that a Tariff-codified emergency interconnection process that specifies safeguards and restrictions would be preferable to interconnecting generators on an emergency basis without any such defined process, MRP remains skeptical that the proposed emergency process could be applied fairly and equitably. 

If the CAISO moves forward with this proposal, MRP proposes that the CAISO commit to prioritizing the allocation of interim deliverability to already-queued projects over allocating interim deliverability to emergency projects.  In addition, MRP would appreciate the CAISO providing specific details on (1) how projects interconnecting under this proposed emergency process won’t impact other queued projects and (2) how the CAISO will keep projects owned by the PTOs from “having a leg up” on third-party projects submitted by Interconnection Customers ("ICs") that don’t have the same intimate and detailed knowledge of the PTO’s transmission system.   

Finally, MRP urges the CAISO to re-evaluate and, as needed, fix the existing ISP process instead of creating this emergency interconnection process. 

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

MRP supports the CAISO’s proposal to require SE to proceed to the Phase II study process. 

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

MRP notes that liquidated damages associated with delays in power purchase agreements caused by a PTO error or omission could be very significant (e.g., $75/kW-month).  Should PTO errors or omissions lead to delays of cost increases that result in the termination of the PPA, MRP strongly agrees that in that case the IC should be allowed to withdraw and receive a full refund of its study and interconnection security deposits. 

MRP believes that the CAISO’s thresholds for allowing an interconnection customer to withdraw with no penalty following the discovery of a Participating Transmission Owner error or omission that increases cost by 10% or delays the project by 12 months to be too high.   MRP reiterates that it believes the threshold criteria should be (1) a six-month delay or (2) a five percent increase in cost. 

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

MRP has no comment. 

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

MRP has no comment.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

MRP supports the CAISO’s proposal.   

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

While MRP appreciates the CAISO’s willingness to allow some types of MMAs for parked projects, MRP respectfully urges the CAISO to expand the list of MMAs that it allows for parked projects.  As an example – as MRP understands the CAISO’s proposal, an IC would not be allowed to submit an MMA to change inverters on a parked project.   Changing inverters, however, could reduce the short circuit contribution of that project and, conceivably, could eliminate or reduce Reliability Network Upgrades associated with that parked project.  While MRP understands the CAISO’s desire to avoid having to invest a large amount of staff time on processing parked project MMAs, and while MRP appreciates the CAISO’s willingness to allow some types of MMAs for parked projects, MRP respectfully encourages the CAISO to consider additional MMA types that would be allowed for such projects. 

If the CAISO is not willing to expand the types of MMAs that parked projects could submit, MRP urges the CAISO to consider also implementing a mechanism that would prevent an MMA that cannot be submitted while a project is parked from delaying the project once the MMA is submitted after the project has left parking.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

To prevent ICs from being time-squeezed by a later-held study results meeting, MRP supports LSA/SEIA’s proposal for setting Appendix B due dates that are tied to (i.e., held some reasonable number of days after) the study meeting, not tied to the date of the Phase 1 Study Report.   

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

MRP has no comment.   

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

MRP supports the CAISO’s proposal. 

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

MRP’s supports the CAISO’s proposed clarification.   

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

MRP supports the CAISO’s proposal.   

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

MRP supports the CAISO’s proposal.   

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

MRP has no further comment.  

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

CalWEA supports the proposal on many of the near-term topics, but still has concerns as follows:

CalWEA urges the ISO to bring back the existing TPD Allocation Group 3, which is reserved for actively queued projects to request TPD Capacity based on “Proceeding to Commercial Operation without a PPA.”. Eliminating this group would deprive merchant generators of the opportunity to seek deliverability before they are operational because projects will typically not obtain a PPA or be built without deliverability. A compromise, such as requiring a PPA in the subsequent year to retain the TPD allocation, could be made to keep the allocation group viable.

With regard to the ISO’s proposal on the emergency generation interconnection process, CalWEA urges the ISO to focus on helping projects already in the queue to complete development on time instead of creating new processes.  If the proposal moves forward, CalWEA strongly urges the ISO to ensure the transparency of the process and prevent transmission owners from jumping the queue in a non-transparent way favoring their projects.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

CalWEA supports the ISO proposal. 

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

CalWEA supports collapsing six groups (1, 2 and 4-7) into the new 3 groups. As stated in the previous comments, CalWEA strongly recommends that the existing TPD Allocation Group 3 (reserved for actively queued projects to request TPD Capacity based on “Proceeding to Commercial Operation without a PPA”) be maintained. In addition to several practical reasons, merchant generators should not be deprived of the opportunity to seek deliverability before they are operational because projects will typically not obtain a PPA or be built without deliverability. However, as a compromise, CalWEA proposes that the existing group 3 become the new group 4 with additional requirements such as requiring that the IC to have a PPA within a year to retain the allocation.  The new group 4 would be any active interconnection request in the current queue cluster with a completed Phase II Interconnection Study that has not parked and elects to proceed without a power purchase agreement.

CalWEA also recommends that resources with PPAs shorter than 5 years should be able to get interim deliverability given that the shorter PPA does not qualify the resource for TPD allocation.

ISO clarified at the stakeholder call that ISP projects requesting FCDS could not seek TPD as EO before it completes the cluster deliverability assessment. CalWEA asks the ISO to reconsider this policy. Seeking TPD as EO does not constitute queue-jumping because the EOs seeking TPD are checked against the current queue to ensure they are not contributing to any local delivery constraints. ISPs that elect EO are currently allowed to seek TPD and that is not considered queue-jumping. There is no difference in the case of ISPs that elect FC and those seeking TPD as EO.  

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

CalWEA opposes this queue-jumping exercise. Rather than creating this non-transparent process that favors PTOs, ISO should accelerate interconnection of ready projects already in the queue. If this proposal moves forward, the new process should not be allowed to be used by PTOs to develop their own projects. The criteria should require both NU and distribution upgrades to meet the cost threshold. The process should be transparent regarding the qualification of the eligible interconnection requests and how impacts of the emergency interconnection on the queued generation interconnection requests are determined.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

CalWEA supports the site exclusivity standard for offshore wind projects in federal waters governed by BOEM, but the standard should differ for projects in state waters.  In the case of BOEM projects, the lease is issued first to the winning bidder, an EIR is then conducted, and then approval of a Construction and Operation Plan is considered.  In State waters, a project submits an Application for Lease of State Lands to the State Lands Commission.  After deeming the application complete, the Commission first conducts CEQA review on the proposed project and then determines whether to approve the lease application. (See State Lands Commission’s Application Guidelines, available at  https://www.slc.ca.gov/wp-content/uploads/2018/07/Lease_App_Guidelines_2011.pdf.)  Therefore, CAISO should consider an application-deemed-complete as site exclusivity for state waters projects.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

CalWEA supports the ISO proposal. CalWEA supports inclusion of PPA termination due to errors and omissions of a PTO within the eligibility criteria for project withdrawal and receiving a full refund of the IFS and unused study deposit.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

CalWEA has no objection to the clarification. 

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

CalWEA supports the ISO proposal. 

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

CalWEA supports the ISO proposal provided that the study area boundary is defined and available publicly.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

CalWEA supports the ISO proposal with modification. CalWEA recommends allowing downsizing while a project is parked. 

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

CalWEA has no objection to the ISO proposal but asks ISO to clean up Appendix B to remove unnecessary data requirements. 

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

CalWEA believes that shared IRNUs should not be exempted from GIDAP 14.2.2 if the projects sharing upgrades have no affiliation with each other. There is enough protection for the PTO to keep the cost responsibility with the Interconnection Customers for shared IRNUs. No special treatment should be given for IRNU as PNU if the sharing parties are non-affiliated.   

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

CalWEA supports the modifications to commercial viability criteria. However, the ISO proposal does not address the concern CalWEA raised regarding interconnection before RNU. Timing of the limited operational study (5 months before the Initial Synchronization Date) does not leave enough time for project development.  There should be a mechanism for the developers to get an indication whether the project can interconnect within two years. A non-binding LOS, as part of the Phase II operational study or annual reassessment, should evaluate if the projects with executed GIA can interconnect as requested by relying on market operation in lieu of some reliability upgrades. This analysis, including the assumptions, limitations, and conclusions, should be published and updated annually. 

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

CalWEA supports the ISO proposal. 

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

CalWEA supports the ISO proposal that only a Letter of Intent is required at the time of IR submission, as stated in the January 25, 2022, Revised Straw Proposal.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

CalWEA supports the ISO proposal.  

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

CalWEA asks the ISO to reconsider the previously proposed changes to the Independent Study Process. The concern that the ISO has regarding accumulated impacts if relaxing Electrical Independence Test (EIT) is addressed by the overall ISP design. First, there are ISP eligibility criteria. Not all requests can meet the criteria. Second, performing the EIT requires the study results from the current cluster study or previous ISP study. Therefore, an ISP request can only be processed after the previous ISP study is completed. Third, the EIT also includes aggregated flow impact test. As the ISO tariff states, “the aggregate power flow test shall require that the aggregated power flow of the Generating Facility being tested, plus the flow of all earlier queued Generating Facilities currently being studied under the Independent Study Process that were tested against the transmission facilities described in the previous sentence, must be five (5) percent or less of those transmission facilities’ capacity.” Based on these factors, accumulated impact from many ISP requests should not be of concern.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

PG&E is generally supportive of the enhancements proposed in the Interconnection Process Enhancements 2021 revised straw proposal. PG&E has concerns with some aspects of the proposed emergency generation interconnection process and disagrees that parked projects should be able to submit MMAs while they are parked. PG&E appreciates the very hard work the CAISO has done in the development of these enhancements.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

PG&E is supportive of the changes to the downsizing window but has concern at the increased volume of MMA’s the CAISO and PG&E would have to field. PG&E is supportive of a clear rule on which projects are eligible for consideration of immediate downsizing approval and believes this rule should be that any projects with network upgrades will have their review delayed until consideration during the reassessment. 

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

PG&E appreciates the efforts the CAISO has gone through in the development of this enhancements.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

PG&E is concerned with the impacts the emergency generation process will have on the PTO’s and on generation projects interconnecting through the queue. The lack of timeline to complete initial analysis, study, and execute the work is likely to cause adverse impacts on staffing, existing study processes, and as a result, existing generation projects. PG&E urges the CAISO to take into account the adverse impacts of injecting new studies and work into the already stout interconnection queue and Cluster 14.  PG&E requests that the CAISO take special care when defining which projects can participate in the emergency generation interconnection process, as there may be projects which appear to meet the network upgrade cost and upgrade timelines may not actually be able to meet the emergency needs of the state.  For example, small upgrades that require clearances that are unavailable might appear to fulfil the emergency needs of the state but in reality would not be.  PG&E proposes that screening process similar to fast track or independent study process could be developed.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

PG&E is supportive of the addition of site exclusivity to the interconnection study process. Could the CAISO elaborate as to its reasoning why site exclusivity should not be required with the submission of an interconnection request?  

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

PG&E is generally supportive of this enhancement, but has concern that the proposal does not address the increased costs, project delays, and cost shifts between interconnection customers and the PTO when an error or omission is triggered by a delayed or cancelled TPP project or a new deliverability upgrade identified in subsequent annual reassessments. This proposal also does not address delays from the interconnection customers side which suspend or park their project which can affect study results based on other active projects who are moving forward without delays.  

PG&E suggests that when a project’s PPA is terminated due to errors and omissions caused by the PTO, the termination letter from the offtaker citing the specific delay or project cost increase be required to trigger the withdrawal and refund of financial security postings.  ? 

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

PG&E is supportive of the CAISO’s proposal and agrees that a RAS is considered a Reliability Network Upgrade. 

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

PG&E is supportive of this proposal and looks forward to working with the CAISO on the development of tariff language as well as the reciprocal tariff changes to PG&E’s WDT to receive transfers from the CAISO. 

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

PG&E appreciates the CAISO’s structure for POI changes and agrees that these changes will improve the efficiency of IR validation for all participants.  PG&E requests that in addition to the requirements the CAISO has already outlined, that a limit of 2 alternative POI’s be allowed during the scoping meeting. Additionally, PG&E requests that the proposal include language making it clear that PTO and CAISO staff cannot provide technical advice on the design of the interconnection customer’s project. 

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

PG&E does not agree that a parked project should be allowed to submit MMAs at all. Any MMAs needed by the project can be submitted when the project comes out of park. That being said, if parked projects are allowed to submit MMA’s, then PG&E agrees with the required submission of second financial security postings when submitting the MMA.  

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

PG&E supports the proposal and agrees that the addition of due dates for curing deficiencies associated with Appendix B with enable the Phase 2 study process to begin without delays. 

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

PG&E is supportive of this proposal as it prevents unexpected PTO backstop of facilities that were agreed to be provided by interconnection customers. 

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

PG&E generally agrees with the proposed modification to commercial viability criteria.  Interconnection customers 7-year timeline should not be consumed by PTO delays.  

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

PG&E is supportive of this change and believes it will enable the development of more efficient interconnections using existing deliverability. 

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

?PG&E supports the CAISO’s proposed requirements for when an interconnection request proposes to utilize a third-party gen-tie or substation to interconnect. PG&E appreciates that the requirements advance as the project studies advance and also that the CAISO has required that the MMA study process not begin until after the executed gen-tie sharing agreement has been received.? 

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

PG&E does not have comment on this proposed enhancement.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

PG&E does not have comment on this proposed enhancement.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Recurrent energy does not support the CAISO’s proposed change to the TPD Allocation process.

• CAISO Phase 2 studies provide projects with a firm outlook of upgrade costs, timelines, and milestones. The current proposal constraint projects from entering the market after the Phase II study reports are issued. A project is expected to be shortlisted in an RFP or secure a PPA, prior to the TPD allocation affidavit filing deadline in December, which is an unrealistic timeline.

• The CAISO proposal burdens projects to make significant financial deposits as part of the RFP requirements before knowing the results of the allocation study.
• The proposal provides an unfair advantage to prior queued projects that did enter the TPD allocation process without a PPA/shortlist and used the additional time to meet the criteria as is currently proposed.
• There are existing restrictions for projects that opted for Group 3 under the existing framework (prior to IPE 2021) – no suspension

Recurrent Energy proposes:

• CAISO not eliminate Group 3 altogether but consider changes to the Group 3 framework like timeline for projects to secure PPA/be shortlisted in an RFP
• Co-ordination with LSE’s to align with any changes to the TPD allocation process
• More input to the points system as part of the affidavit for TPD allocation/retention

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

NA

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Recurrent energy does not support the CAISO’s proposed change to the TPD Allocation process.

• CAISO Phase 2 studies provide projects with a firm outlook of upgrade costs, timelines, and milestones. The current proposal constraint projects from entering the market after the Phase II study reports are issued. A project is expected to be shortlisted in an RFP or secure a PPA, prior to the TPD allocation affidavit filing deadline in December, which is an unrealistic timeline.

• The CAISO proposal burdens projects to make significant financial deposits as part of the RFP requirements before knowing the results of the allocation study.
• The proposal provides an unfair advantage to prior queued projects that did enter the TPD allocation process without a PPA/shortlist and used the additional time to meet the criteria as is currently proposed.
• There are existing restrictions for projects that opted for Group 3 under the existing framework (prior to IPE 2021) – no suspension

Recurrent Energy proposes:

• CAISO not eliminate Group 3 altogether but consider changes to the Group 3 framework like timeline for projects to secure PPA/be shortlisted in an RFP
• Co-ordination with LSE’s to align with any changes to the TPD allocation process
  • More input to the points system as part of the affidavit for TPD allocation/retention

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

NA

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

Recurrent Energy asks CAISO to clarify in its proposal that the Cluster 14 Site Exclusivity documentation are due on December 29^th, 2022, 10 Business Days before the initial IFS posting per page 7 of the Supercluster Interconnection Procedures.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

NA

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

NA

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

NA

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

NA

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

NA

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

NA

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

NA

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

NA

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

NA

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

NA

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

NA

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

NA

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

REV Renewables (REV) continues to be concerned about two issues in CAISO’s IPE proposal and recommends more conversation before advancing the proposals as is.

• First, REV does not support CAISO’s proposal to revise site exclusivity rules for Cluster 14 as that would be a retroactive change to the rules, this proposal should instead be considered in Phase II for future clusters. REV suggests a compromise position can be higher deposits and/or capital-at risk in lieu of site exclusivity to move into Phase II.
• Second, REV recommends further revisions are needed on CAISO’s TPD allocation process proposal, particularly the proposed Allocation Group 3. REV suggests that projects that meet certain readiness criteria but without PPAs could be in Allocation Group 2 to receive TPD deliverability for a limited time period, such as up to two years. If the project does not have a PPA at the end of that deadline then it could be moved to Allocation Group 3. REV also recommends CAISO revise its definition of PPA to allow non-LSE PPAs to qualify for deliverability; this can avoid non-LSEs left procuring energy-only projects and being forced to lean on LSEs for reliability.

REV disagrees with item 6.8 (requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS) being included in the transmission grid data transparency topic, and suggests items that will be helpful to understand the PTO process for these upgrade.

REV appreciates CAISO’s work on streamlining and enhancing the interconnection process and looks forward to discussing revised proposals for Phase I and Phase II. Further, REV agrees with CAISO’s decision to not move forward with its identified issues at this time.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

REV supports this proposal to simplify downsizing requirements for projects with no network upgrades.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

REV continues to oppose the current proposal and suggests it needs more discussion among stakeholders. REV disagrees with the allocation requirements for Group 3 of having achieved commercial operation. This is an unreasonably high bar, even for a project that intends to be merchant, to require the project to come online before it knows whether it is able to receive full or partial capacity deliverability status. This sequence puts significant risk on the developer, who essentially has to assume it may have energy-only status and be limited in its market participation. We believe that current group 3 allocation group and its associated requirements (COD cannot be delayed beyond the date proposed in the original IR etc.) has  served well for providing certainty to both LSEs and developers to get the projects online. Elimination of this group results in uncertainty and potentially increased reliance on the proposed group 2 (shortlisted for or negotiating a PPA) by the developers. This also creates more risk to both LSEs and developers to enter into a PPA without knowing deliverability status, which might be an unintended consequence here on CAISO’s part. In addition, the current proposal could result in a timing misalignment with TPD Allocation which takes place after the phase 2 study process. It will generally work better for the projects to have the phase 2 study information available prior to entering in to the solicitation/PPA negotiation process. Further, we believe that projects should be allowed to receive TPD deliverability on a merchant basis.

REV suggests that projects that meet certain readiness criteria but without PPAs could be in Allocation Group 2 to receive TPD deliverability for a limited time period, such as up to two years. If the project does not have a PPA at the end of that deadline then it could be moved to Allocation Group 3.

We appreciate CAISO removing the November 30^th deadline to submit an executed PPA for projects that received TPD in new group 2. However, CAISO should clarify whether it now wants these Group 2 projects to have an executed PPA by next year retention affidavit due date.

We further encourage CAISO to reconsider our suggestion to let projects interconnecting in areas with no ADNUs to proceed without a PPA in the TPD allocation process. Similar to the goal of reducing burden for TPD retention, this should further help with ISO’s goal of reducing administrative burden.

REV disagrees with CAISO’s proposed definition of what qualifies as a PPA to those entities with their own Resource Adequacy obligations. REV suggests that non-LSE PPAs also be allowed to qualify for deliverability. If non-LSEs are left to procure energy-only capacity that may result in less firm capacity being built and that entity could be forced to lean on LSEs during stressed grid conditions, thus exacerbating issues in times where deliverable capacity is needed most. CAISO should be encouraging all entities, not just LSEs, to procure deliverable capacity.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

REV supports CAISO’s proposal for developing an emergency generation interconnection process.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

REV continues to oppose CAISO’s proposal to revise site exclusivity rules for Cluster 14, particularly because this would be a significant retroactive change to the rules in the middle of the process. CAISO showed that Cluster 14 has 32% of projects with site exclusivity as a justification for this being a reasonable proposal; however, viewed from a different angle the vast majority of projects (68%) do not have site exclusivity. Even at an early stage, these projects are already substantial investments, and now this mid-process change will pose significant commercial risk for the interconnection customers and lead to higher costs for consumers.

The late-stage introduction of a binary risk that customers without site exclusivity would not be able to advance to Phase II would cause customers to negotiate site control agreements from a weak negotiating position, likely increasing project costs. Customers would be incentivized to pay more for real estate or accept less valuable land positions in order to keep a project in queue, ultimately raising the cost of the project and by extension, raising the price these projects can bid to load-serving entities in future procurements. In extreme cases, multiple customers with queue positions at a single substation may find themselves in bidding wars with one another over limited land options, where they otherwise may not do so with enough time for planning and negotiations.

Given the vast majority of C14 projects do not currently have site control, it is not unreasonable to think that these increased project costs will occur across the entire C14 queue and ultimately be passed along to consumers.

REV agrees with stakeholders suggesting increasing deposits and/or have a higher amount of “capital-at-risk” option for Cluster 14 projects without site exclusivity as a reasonable compromise. This structure allows customers to negotiate land positions with care and, given this capital would not represent an increase in a project’s total interconnection cost if the project is successful, could do so without increasing total project costs.

REV supports revising site exclusivity rules for Cluster 15 and beyond as those rules would then be clear and transparent when entering into the queue. Accordingly, REV suggests this issue be moved to Phase II longer term modifications.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

REV agrees with the CAISO proposal.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

REV has no comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

REV has no comment at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

REV has no comment at this time.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

REV has no comment at this time.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

REV agrees with the CAISO proposal.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

As CAISO develops a proposal for this issue, REV reiterates its caution to avoid shifting the costs of the PNUs to the generators and increased the MCE for the project. REV does not support this as any proposed changes to the MCE of the project pose a significant risk, among others, to the commercial viability of the projects.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

REV has no comment at this time. 

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

REV agrees with the CAISO proposal.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

REV has no comment at this time. 

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

REV agrees with the CAISO proposal.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

On item 6.8 in the Revised Straw Proposal to requesting the PTO/ISO 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, REV appreciates CAISO’s effort in providing a transmission platform to provide a status of all planned TPP and GIP upgrades. However, the Transmission Forum does not address REV’s concerns regarding the examination of the issues when a developer issues a notice to proceed to the PTO. The Transmission Forum, while helpful, is more for general updates and not project-specific issues. REV encourages CAISO to provide more clarity on the PTO decision making process to build these shared transmission upgrades after the NTP is issued by interconnection customer.

Some of the items that will be helpful to understand the PTO process for these upgrade could be:

• Prioritization, if any, to upgrades coming out of study processes, such as TPP and GIP.
• Considerations to the cost of the shared upgrade. For example, posting amounts received by PTO or number of project level thresholds, if any, that the PTOs use to decide to build the shared upgrades, and whether these thresholds are consistent among different PTOs.

In addition, it will be helpful to further discuss issues related to deliverability status if the project achieves COD and does not trigger the need of shared upgrade itself. In this instance, REV strongly believes that giving FCDS status to projects creates financial incentive to bring the project online in a timely manner and reduces development risks for projects.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

RWE supports the CAISO initiative to improve the interconnection process and appreciates the opportunity to continue to participate and provide comments.  It is important that CAISO does not unduley impact one group over another and moves forward with the most fair and just options possible.  We look forward to the continued conversation for finding the best process.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

RWE supports a projects ability to downsize.  If an NU is still needed, an increase in allocation to other projects could be considered material unless there is a cost cap to ensure no negative impacts to other projects.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

RWE disagrees with the elimination of group 3 as proposed but would support some additional requirement sto be in group 3.  While CAISO did not intend for group 3 to be used to obtain an agreement with an entity seeking RA capabilities, how can a project negotiate or be shortlisted for that kind of discussion without knowing their allocation?

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

Support as modified

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

a) Requiring site exclusivity is okay for C15 and beyond.  The rules should not be modified for the active clusters as companies are working on and processing based on the current rules.  For state or Federal lands the timing to obtain site exclusivity may be impacted, in these scenarios a in-lieu deposit should still be accepted - similiar to other ISOs.

b) The definition is fine, however, the opportunity to obtain the leases is limited to times which are released by the Federal government.  As such, an in-lieu deposit should be acceptable.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

Support, see LSA comments

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Oppose, see LSA comments

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Support but continue to request ISO and PTOs provide public information about the operational control of substations and lines in an effort to diminishing this being a problem.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Support but restate that these issues could be avoided by providing transparent data to IR customers which can, in turn, help when selecting POIs. RWE would also like the ISO to clarify what “Same Transmission Study Area” means in the proposal.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

Support

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Support if all parties are also provided the same amount of time and there is a due date.  One party should not have extra time or an advantage when their results meeting is held earlier than others.  A minimum amount of cure time also needs to be maintained, technical deficiencies can be more complex to evaluate.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

The proposal notes this is a Phase 2 item and should be reintroduced at that time.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

Support not impacting the CVC criteria if a PTO delay puts a project beyond the 7 years, only if change is by IC

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

Support

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

RWE would support a intent to negotiate at start of Phase II but an agreement should not be required until IA signing.  Prior to phase II it can be assumed an individual gen-tie.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

Support.  One note, the projects hsould be automatically added to the RIMS account when new, the IC should not need to add them manually.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

No new comments, however regarding study deposits, the focus needs to be on the project basis, not parent company.  This is a clarification as it appears RWE's comments were not clear.  RWE will strongly oppose any method that penalizes a company's ability to develop multiple projects.  And deposit variotions should be individual to each project only, and RWE will support a sliding scale - this can be seen in other ISOs.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

SDG&E commends the CAISO for exploring potential interconnection process enhancements to move interconnection resources through the interconnection queue more efficiently and to manage the overheated queue through this 2021 IPE stakeholder initiative. SDG&E is thankful for the opportunity to provide its comments on the topics below.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

SDG&E has no comments.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

SDG&E has no commrents.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

SDG&E supports and provides the following for the CAISO’s consideration in developing requirements for this process:

1. The complexity should not be underestimated, since studies, cost estimates, and reports all have to be prepared the same as other cluster study projects in the queue or those that enter through more expedited processes (Fast Track, ISP, etc.).  

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

SDG&E supports CAISO’s proposal of including this requirement, especially for Cluster 14.  Additionally, ICs should provide site exclusivity for land sufficient for both the project site and the loop-in switchyard (for those proposing to loop-in existing transmission lines).

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

SDG&E supports this proposal.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

SDG&E does not support CAISO’s proposal. SDG&E believes that if the RAS is for deliverability, then CAISO should label the RAS as a deliverability upgrade. If a RAS that’s needed for deliverability is not implemented, congestion management cannot be used in lieu of the RAS. This is different from a reliability-study-driven RAS. Congestion management could be used instead without affecting local and system resource adequacy. This approach is consistent with the way the CAISO treats non-RAS upgrades as part of the interconnection process.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

SDG&E request clarification on the definition of “transferring”.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

SDG&E proposes additional communications between the PTO and IC for POI availability in advance of Scoping Meetings.  There is limited time, typically, between scoping meetings and when IRs must be deemed valid.  If the information is available earlier from the PTO, ICs should change POI then and update technical data accordingly.  There are concerns of POI “fishing expeditions” but SDG&E believes that providing bay availability within one (1) bus or line away from the IC’s proposed POI represents reasonable effort from the PTO and is consistent with the CAISO’s BPM. Confirmation of POI should remain at 5BD after Scoping Meetings

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

SDG&E supports CAISO’s proposal to limit the type of MMAs that ICs can submit while parked, and SDG&E provides additional recommendations in response to item seventeen (17) below.  There is inconsistency between CAISO’s proposal to include POI changes in allowable MMA types and BPM section 7 on modifications and GIDAP section 6.7.2.1.  Parking can only occur after the completion of the Phase II study and allowable changes for POI references in BPM and GIDAP are under activities of the Phase I study.  BPM states “Any change to the Point of Interconnection, except for that specified by the CAISO in an Interconnection Study or otherwise allowed under GIDAP Section 6.7.2 and GIDAP BPM 7, shall constitute a Material Modification.” (BPM for GIDAP, Section 7.2).  SDG&E asserts that POI changes should not be an allowable type of MMA for parked projects.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

SDG&E supports this proposal, and re-states other stakeholders’ proposals that the reference point for due dates should be based on the results meetings, not the issuance of Phase I study reports.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

SDG&E commends and supports CAISO’s proposal for unique treatment of IRNUs and to treat IRNUs as CANUs until both GIA execution and 3^rd IFS posting for the first project that required the upgrades.  SDG&E would request further consideration for the case of IRNUs that qualify as SANUs (i.e. switchyards) regarding the adjustment of IFS postings as described in GIDAP section 11.3.1.4.4.  If the first project that requires the SANU desires to self-build the SANU, minimal IFS posting will be required.  If any subsequent project(s) intends to utilize the SANU, SDG&E proposes that the SANU remain as a CANU (and therefore would be included in the MCE for any later-queued project(s) requiring the SANU) until the SANU is constructed (regardless if the first project that required the SANU executed a GIA or made 3^rd IFS posting).  By maintaining the SANU as a CANU (and not changing it to a PNU), ratepayers will be protected if the first project terminates its GIA and the subsequent projects require the SANU.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

SDG&E has no comments.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

SDG&E has no comments.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

SDG&E supports the proposal but would like CAISO to consider implementing this requirement for Cluster 14.  SDG&E believes it would be better for this to be applied for C14 Phase II and aligns with CAISO’s goal of managing the overheated queue

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

SDG&E supports and looks forward to the discussion with CAISO to understand the full features and capabilities of RIMS.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

1. SDG&E recommends an additional section be added to the Deliverability Allocation Customer Options Form, that would require parked projects to update their ISD, TOD, and COD, similar to the section in Appendix B “Please provide achievable schedule dates”.  ICs would then calculate, based on the Phase II study report tables for earliest achievable dates with a reference starting point of “Project concludes their parking” as March 1^st or 15^th of the next calendar year, when they might accept allocation, or no longer be eligible for parking.  CAISO and PTO would confirm those dates based on Phase II study. This would ensure that project dates in the queue more accurately reflect achievable dates, reduce the number of MMAs to update dates, and make both operational deliverability and reliability study (that are required to use queue dates) results more accurate.
2. SDG&E also recommends that projects in the construction phase that want to delay their in-service date on record by more than a year, submit an MMA to do so at least 6 months before the in-service date on record. This requirement will help ensure that if delays are expected by a Project, the PTO is made aware of it in a timely fashion and can redirect and reprioritize its resources on projects that are moving forward to achieve their in-service date. This will also help ensure that the overheated queue has accurate information regarding projects in-service date. This change is extremely important in light of the ambitious State’s goals to reach SB 100. Based on the CPUC IRP work, PTOs expect that the pace of interconnections will only increase requiring PTOs to be efficient and nimble with their engineering and construction resources. An option, to incent projects to submit MMAs when they expect their in-service date on record to be delayed by more than a year, could be for the CAISO to increase the MMA fee for these projects if they notify the CAISO and the PTO less than 6 months in advance. SDG&E is open to other proposals to help address this challenge which will only grow in the upcoming years.
3. Finally, SDG&E is concerned that storage projects today qualify for Resource Adequacy as part of the TPD allocation process even if they have charging restrictions. Storage charging requirements and their effects on the surrounding transmission system should be considered appropriately. The timing/coordination of battery resources without causing transmission overloads or interfering with load demand needs to be managed.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

SDG&E commends the CAISO for exploring potential interconnection process enhancements to move interconnection resources through the interconnection queue more efficiently and to manage the overheated queue through this 2021 IPE stakeholder initiative. SDG&E is thankful for the opportunity to provide its comments on the topics below.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

SDG&E has no comment.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

SDG&E has no comment.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

 SDG&E supports and provides the following for the CAISO’s consideration in developing requirements for this process:

1. The complexity should not be underestimated, since studies, cost estimates, and reports all have to be prepared the same as other cluster study projects in the queue or those that enter through more expedited processes (Fast Track, ISP, etc.).  

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

SDG&E supports CAISO’s proposal of including this requirement, especially for Cluster 14.  Additionally, ICs should provide site exclusivity for land sufficient for both the project site and the loop-in switchyard (for those proposing to loop-in existing transmission lines).

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

SDG&E supports the proposal

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

SDG&E does not support CAISO’s proposal. SDG&E believes that if the RAS is for deliverability, then CAISO should label the RAS as a deliverability upgrade. If a RAS that’s needed for deliverability is not implemented, congestion management cannot be used in lieu of the RAS. This is different from a reliability-study-driven RAS. Congestion management could be used instead without affecting local and system resource adequacy. This approach is consistent with the way the CAISO treats non-RAS upgrades as part of the interconnection process.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

SDG&E request clarification on the definition of “transferring”.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

SDG&E proposes additional communications between the PTO and IC for POI availability in advance of Scoping Meetings.  There is limited time, typically, between scoping meetings and when IRs must be deemed valid.  If the information is available earlier from the PTO, ICs should change POI then and update technical data accordingly.  There are concerns of POI “fishing expeditions” but SDG&E believes that providing bay availability within one (1) bus or line away from the IC’s proposed POI represents reasonable effort from the PTO and is consistent with the CAISO’s BPM. Confirmation of POI should remain at 5BD after Scoping Meetings.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

SDG&E supports CAISO’s proposal to limit the type of MMAs that ICs can submit while parked, and SDG&E provides additional recommendations in response to item seventeen (17) below.  There is inconsistency between CAISO’s proposal to include POI changes in allowable MMA types and BPM section 7 on modifications and GIDAP section 6.7.2.1.  Parking can only occur after the completion of the Phase II study and allowable changes for POI references in BPM and GIDAP are under activities of the Phase I study.  BPM states “Any change to the Point of Interconnection, except for that specified by the CAISO in an Interconnection Study or otherwise allowed under GIDAP Section 6.7.2 and GIDAP BPM 7, shall constitute a Material Modification.” (BPM for GIDAP, Section 7.2).  SDG&E asserts that POI changes should not be an allowable type of MMA for parked projects.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

SDG&E supports this proposal, and re-states other stakeholders’ proposals that the reference point for due dates should be based on the results meetings, not the issuance of Phase I study reports.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

SDG&E commends and supports CAISO’s proposal for unique treatment of IRNUs and to treat IRNUs as CANUs until both GIA execution and 3^rd IFS posting for the first project that required the upgrades.  SDG&E would request further consideration for the case of IRNUs that qualify as SANUs (i.e. switchyards) regarding the adjustment of IFS postings as described in GIDAP section 11.3.1.4.4.  If the first project that requires the SANU desires to self-build the SANU, minimal IFS posting will be required.  If any subsequent project(s) intends to utilize the SANU, SDG&E proposes that the SANU remain as a CANU (and therefore would be included in the MCE for any later-queued project(s) requiring the SANU) until the SANU is constructed (regardless if the first project that required the SANU executed a GIA or made 3^rd IFS posting).  By maintaining the SANU as a CANU (and not changing it to a PNU), ratepayers will be protected if the first project terminates its GIA and the subsequent projects require the SANU.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

SDG&E has no comments.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

SDG&E has no comments.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

SDG&E supports the proposal but would like CAISO to consider implementing this requirement for Cluster 14.  SDG&E believes it would be better for this to be applied for C14 Phase II and aligns with CAISO’s goal of managing the overheated queue.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

SDG&E supports and looks forward to the discussion with CAISO to understand the full features and capabilities of RIMS.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

1. SDG&E recommends an additional section be added to the Deliverability Allocation Customer Options Form, that would require parked projects to update their ISD, TOD, and COD, similar to the section in Appendix B “Please provide achievable schedule dates”.  ICs would then calculate, based on the Phase II study report tables for earliest achievable dates with a reference starting point of “Project concludes their parking” as March 1^st or 15^th of the next calendar year, when they might accept allocation, or no longer be eligible for parking.  CAISO and PTO would confirm those dates based on Phase II study. This would ensure that project dates in the queue more accurately reflect achievable dates, reduce the number of MMAs to update dates, and make both operational deliverability and reliability study (that are required to use queue dates) results more accurate.
2. SDG&E also recommends that projects in the construction phase that want to delay their in-service date on record by more than a year, submit an MMA to do so at least 6 months before the in-service date on record. This requirement will help ensure that if delays are expected by a Project, the PTO is made aware of it in a timely fashion and can redirect and reprioritize its resources on projects that are moving forward to achieve their in-service date. This will also help ensure that the overheated queue has accurate information regarding projects in-service date. This change is extremely important in light of the ambitious State’s goals to reach SB 100. Based on the CPUC IRP work, PTOs expect that the pace of interconnections will only increase requiring PTOs to be efficient and nimble with their engineering and construction resources. An option, to incent projects to submit MMAs when they expect their in-service date on record to be delayed by more than a year, could be for the CAISO to increase the MMA fee for these projects if they notify the CAISO and the PTO less than 6 months in advance. SDG&E is open to other proposals to help address this challenge which will only grow in the upcoming years.
3. Finally, SDG&E is concerned that storage projects today qualify for Resource Adequacy as part of the TPD allocation process even if they have charging restrictions. Storage charging requirements and their effects on the surrounding transmission system should be considered appropriately. The timing/coordination of battery resources without causing transmission overloads or interfering with load demand needs to be managed.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

SCE appreciates the opportunity to provide comments on the CAISO’s 2021 IPE Revised Straw Proposal.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

SCE reiterates its support of the CAISO’s proposal to remove the downsizing window and simplify the downsizing request requirements.  However, SCE has several questions about how downsizing requests will be implemented going forward. 

For example, the statement: “Once the downsizing request is received by the ISO the project would be deemed downsized to the requested capacity.”  SCE supposes from this statement that the IC for Project X with one or more network upgrades submits the request to downsize its project from 500 MW to 250 MW along with the technical package and $10,000.00 deposit several months after its Phase II Results Meeting, say June 1, 2022 or after the current Reassessment Study cycle is underway.  Per the statement, Project X would thenceforth be deemed having a capacity of 250 MW instead of 500 MW upon CAISO’s receipt of its request.  What do PTOs do with this information? Does this mean that CAISO and PTOs are not going to technically evaluate the downsizing request until the 2023 Reassessment Study cycle?  How would this benefit the IC unless it’s a given (a formality) that its downsizing request would be officially approved a year later?   Is the PTOs approval required since it is not explicitly stated in the straw proposal? Do we charge our time to the MMA WO that was opened and released almost a year ago per the MMA process or do we charge our time to the Reassessment WO#?  Is Project X placed on hold since it would not make sense for the PTO to tender a GIA until after the 2023 Reassessment is complete and an MMA approval response letter is issued to the IC?

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

SCE has no comment.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

SCE sees much ambiguity being introduced with this idea of an emergency generation interconnection process. SCE seeks clarification on the following issues:

1. Where will the parameters of this emergency generation interconnection process reside?  Will it be outlined in detail in GIDAP and/or BPM?
2. Will these projects be treated similarly to Cluster and ISP IRs with respect to the following?
   1. Will a Study Agreement be required?
   2. IR and technical package will be validated and deemed complete?
   3. Study timeline clearly delineated in the BPM and/GIDAP?
   4. Study report issued and Results Meeting held?
   5. Letter Agreement, GIA, or amended GIA will be executed? This step can take 2 – 4 months to complete
   6. Agreement may need to be filed w/FERC, initial payment and financial security received, and WO#s opened and released, resources assign to Project. This step can take 2 – 3 months to complete

Section 2 (a) – (f) could take up to twelve (12) months to complete before a kick-off meeting is held with the IC

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

SCE reiterates its support regarding the proposal that site exclusivity will be required to move into the Phase II study process.   Concerning the appropriate definition for demonstration of site exclusivity for offshore wind projects, SCE would expect the applicant to demonstrate site exclusivity equal to the control we would expect for other projects – for the parts of the project on public land, SCE would require a final, non-appealable permit, license, right-of-way grant, lease, or other right to use the property for generation purposes from the appropriate governmental agency.  If any part of the project is sited on private land, SCE would require a fee or leasehold interest in the land or an option to acquire such interests. 

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

SCE disagrees with the CAISO’s proposed cost increase threshold of 5% and a minimum of a 12-month delay in the earliest achievable ISD as follows:

1. The current tariff provision defines a substantial error or omission to be more than five (5) percent or one million dollars (whichever is greater) or.
2. Results in a delay to the schedule by which the IC can achieve Commercial Operation, based on the results of the final Interconnection Study, by more than one year

If the CAISO insist on placing the cost responsibility on the PTO for a substantial error or omission after the IFS posting have been made, then at a minimum, the definition and terms in GIDAP Section 6.8.1 should remain the same other than revising “COD based on the results of the final Phase II Study.” One million dollars or more is substantial, any amount less than one million dollars is not. The project’s ISD and COD should be adjusted after the Phase II Results Meeting and reflected in the Phase II meeting minutes based on GIDAP Section 13.2.1. The ISD and COD is adjusted based on when the GIA is tendered, either thirty (30) CDs from the Phase II Results Meeting or May 1, after TPD Allocation Study results are issued and affidavits received. In most cases, the ISD and COD is based on tendering the draft GIA by May 1 if the IC does not park or withdraw its project from the queue based on their TPD Allocation Study results.

If a project parks or executes a GIA and then subsequently invokes Article 5.16 – Suspension, the IC’s project should not be eligible for one hundred percent of its IFS posting for Network Upgrades. The IC can either accept the error or omission impact to cost and/or schedule to its project or withdraw its IR or terminate its GIA without receiving one hundred percent of its Network Upgrade IFS posting.

If the consensus is to support issuing a full IFS refund due to a termination of a PPA, then the party terminating the PPA must be the Buyer or Off-taker (e.g., SCE), not the IC. With respect to documentation, a notarized letter on company letterhead signed by an Off-takers’ or Buyers authorized representative stipulating that they terminated the PPA because of the IC being unable to meet its performance obligations pursuant to the terms and conditions in the PPA specifically due to the schedule impact associated with the error or omission.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

SCE reiterates its support of the CAISO’s proposal to clarify its existing policy that a RAS is always considered an RNU, regardless of the study that identified the need for the RNU.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

SCE reiterates its support of the CAISO’s proposal to move forward with developing tariff language for allowing the CAISO to accept interconnection request (IR) transfers from the PTO’s WDAT queue to the ISO queue.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

SCE reiterates its support of the CAISO’s proposal that the timing of the process for changing POIs whether in accordance with GIDAP section 6.7.2.1 or otherwise, remain consistent with current CAISO practice that interconnection customer(s) must confirm its POI within five business days of the project’s scoping meeting pursuant to the CAISO’s GIDAP BPM v.27 section 6.2.2 and any change in POI will be limited to within the same transmission study area (e.g., within the same county, one transmission line, or one switchyard from the original) as the POI originally requested in its Interconnection Request.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

SCE supports the ISO’s latest proposal to permit developers to submit a modification request for a “parked” project, contingent upon the modification request being limited to fuel-type, technology-type, and POI changes and the 2^nd IFS posting requirement has been met before submitting an MMA request to the CAISO.  

Approving an acceptable form of collateral instrument or an amendment to an existing collateral instrument for the 2^nd IFS Posting can take up to thirty (30) Calendar Days when SCE is the Participating TO.  In those circumstances where SCE is the Affected Participating TO, SCE would not have line-of-sight when the 2^nd IFS Posting requirement has been made to the Interconnecting Participating TO in accordance with GIDAP Section 14.4.1.  It is SCEs position that when a developer submits an MMA for a parked project to the CAISO, as part of its MMA submittal, the developer must include an email from the PTO, Interconnecting PTO, and/or Affected Participating TO that the developer has met is 2^nd IFS Posting requirement. If a developer does not include the email confirming that the 2^nd IFS Posting requirement has been met as part of its MMA submittal, the MMA request will be denied.

SCE will support a POI modification request if any change to the POI will be limited to within the same transmission study area as the POI originally requested by the developer in its IR and the request satisfies GIDAP Section 6.7.2.1, improve the costs and benefits (including reliability) of the interconnection. From SCE’s perspective, both conditions must be satisfied for a POI modification request to proceed.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

SCE reiterates its appreciation of the CAISO’s inclusion of this SCE-recommended topic in the 2021 IPE. SCE supports the CAISO’s proposal to add a deadline for the validation of Appendix Bs, where all Appendix Bs and any associated technical data must be submitted within ten (10) Business Days following the Phase I Interconnection Study Results Meeting and be deemed valid by the PTO and CAISO no later than seventy (70) Calendar Days after the date of the original Phase I Interconnection Study Report. Projects with invalid Appendix Bs by the due date will be withdrawn from the interconnection queue pursuant to GIDAP Section 3.8.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

SCE does not support the CAISO’s proposal to extend the current treatment of cost responsibility for shared IRNUs within a cluster to cases where the IRNU is shared across clusters. Under the CAISO’s proposal, GIDAP Section 14.2.2 would require SCE and other PTO’s to back-stop finance the shared IRNU upon the Interconnection Customer of the earlier-queued project making its 3^rd IFS Posting since the shared IRNU would at that point be considered and reclassified as a PNU. If the Interconnection Customer of the earlier-queued project terminates its GIA, the non-refundable portion of its Network Upgrade IFS posting that the CAISO proposes would be subject to Appendix DD Section 7.6 Application of Non-Refundable Amounts will not make SCE or any other PTO whole.

SCE’s position is if the Interconnection Customer of the earlier-queued project terminates its GIA, the interconnection customer of the later-queued project remains jointly and severally liable for up to one hunderd percent (100%) of the shared IRNU costs, IFS, and ITCC, if applicable.

SCE agreed to work with the developer community on this issue since the request to share a Generation Tie-Line with an earlier-queued project by default leads to sharing certain PTO Interconnection Facilities and IRNUs and saves the interconnection customer of the later-queued project significant time and money. SCE has articulated its position to the developer community and the CAISO going back to Queue Cluster 8 that GIDAP Section 14.2.2 will have to be waived by the IC (a condition precedent), SCE will not back-stop finance the shared IRNUs if the interconnection customer for the earlier-queue project terminates its GIA. The developer community agreed, and as a result, SCE has executed a significant number of GIAs with the support of the CAISO and filed them with FERC requesitng the waiver. FERC accepted all the GIAs without comment or requesting clarification.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

SCE believes that developers that 1) submit multiple COD MMAs, 2) park their projects for two-years pursuant to GIDAP Section 8.9.4, or 3) invoke Article 5.16 – Suspension of the GIA for two or three years and then are further impacted by a PTO Delay (e.g., change in Standards), must continue to comply with the commercial viability criteria if the seven (7) year timeframe is breached.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

SCE has no comment.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

SCE supports the CAISO’s revised proposal to require a letter of intent between the non-PTO owned or third-party gen-tie or substation and the project seeking to share the gen-tie or substation.  SCE also seeks clarification concerning which party (CAISO, SCE, or both) approves, if required at all, the terms and conditions in the Letter of Intent (LOI) and subsequent gen-tie sharing agreements before it is executed. 

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

SCE supports the CAISO being consistent in using RIMS for all documents, details, etc. related to projects.  The CAISO should also grant SCE personnel access to all documents and files (IR, Phase I/II Studies, Meeting Minutes, Appendix B Submittals, Reassessments, MMAs, TPD Allocation Study results and affidavits, etc.,) to a project proposing to interconnect to a neighboring PTO (e.g, GridLiance West or Valley Electric Association) when SCE is the Affected Participating TO.

Documents posted to RIMS should include Notice to Operate in Parallel Letters to the IC and CAISO System Operator/NRI.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

SCE has no further comment.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Upstream appreciates the effort undertaken by the ISO to improve the Generator Interconnection Process – especially in light of the CPUC’s 2032 GHG emissions target and the need to interconnect 40GWs of new resources by 2032.  

Upstream supports most of the enhancements put forth by CAISO, but is concerned that several proposals with significant commercial implications are counterproductive and will create future reliability issues that would then require emergency procurement at an increased cost to the ratepayer.  

• Developers have relied on “Allocation Group 3 – Proceeding to Commercial Operation Without a PPA” to obtain deliverability which “de-risks” a project enough that the developer can than enter into an off-take agreement with a load serving entity (“LSE”).  Multiple stakeholders have raised an important point that has not been addressed adequately – load serving entities lack insight into deliverability and are likely to contract projects in deliverability constrained areas due to least-cost best-fit methodology.  Allocation Group 3 enhances reliability because many of the projects that are coming online in 2023 and 2024 selected Allocation Group 3 and were able to come online quickly.  What will happen in the future if the ISO eliminates Allocation Group 3 and LSEs contract with thousands of MWs of projects located behind deliverability constraints and these projects don’t get deliverability?  This will lead to significant reliability issues when these projects ultimately fail and LSEs are forced into emergency shortfall procurement.
• The CAISO is proposing to introduce a new emergency generation interconnection process rather than enhance existing accelerated interconnection processes with proven guardrails that prevent “queue flooding” and negative impacts to other projects in the queue.  Upstream strongly encourages the ISO to ensure that any new interconnection process is i) transparent, ii) doesn’t require the ISO to adjudicate which projects qualify and which don’t through the use of predefined engineering metrics, and iii) doesn’t unfairly benefit transmission owners over third-party developers.  

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

Upstream supports the ISO proposal.  

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Upstream strongly opposes the elimination of Allocation Group 3 for the following reasons that have also been raised by a significant number of stakeholders.  

• Under the current allocation methodology, developers can obtain deliverability through Allocation Group 3 and then execute a contract with a load-serving entity.  Eliminating Allocation Group 3 would require developers to obtain a contract and then try to obtain deliverability where no deliverability is available to be allocated.  The timing and reliability issues this presents are illustrated as follows…  

Q1 2022 – Developer executes PPA with LSE for 100MW with Q2 2025 COD.  

Q1 2023 – Developer submits TP Affidavit and does not obtain FCDS.  Project parks.

Q1 2024 – Developer submits TP Affidavit and does not obtain FCDS.  Project becomes EO.  

Q2 2024 – Developer notifies LSE that project did not obtain FCDS and defaults on PPA.  Developer forfeits development security deposit in the amount of $9.5 million.  LSE has approximately one year to replace 100MW resource that defaulted on PPA (impossible).  CAISO is notified that 100MW resource in NQC Report under “2022 Other” tab is no longer coming online. 

• Many of the storage projects that are coming online in 2023 and 2024 selected Allocation Group 3.  How would the current reliability emergency be exacerbated if these projects weren’t available to come online and were required to submit a TP Affidavit in the next window?  Would these projects have been financed, or would they have to wait until the next TPD Allocation in March 2023 before being financed?  This timeline wouldn’t support a Q2 2024 COD.   

As a compromise, Upstream proposes that i) the existing Allocation Group 3 become a new Allocation Group 4, ii) projects that are not subject to a deliverability constraint that is binding for the TPD Allocation automatically receive FCDS, and iii) projects proceeding through an accelerated interconnection study process be allowed to submit a TPD Affidavit as Allocation Group 1 or 2.    

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

Upstream reiterates our support for enhancing grid reliability, but strongly opposes a new accelerated interconnection process that is not transparent and continues to incentivize “last minute” procurement that ultimately harms the ratepayer via higher costs.    

• The ISO notes in the Revised Straw Proposal “the interconnection cannot negatively impact the cost or timing of any queued project…” but does not elaborate on what engineering metrics will be used to confirm this.  Will CAISO or PTO engineers simply be able to use engineering judgement or will a metric like the Electrical Independence Test be used?  If engineering judgement is used, how will the ISO ensure that this process is uniform across PTOs and study areas?
• Interim deliverability is a finite commodity – allocating it to new emergency generation projects may reduce interim deliverability available for other projects (as we’ve seen in Fresno study area).  Will the ISO allocate IDS to these new emergency generation projects after IDS has been assigned to all existing projects?
• How would CAISO handle modification requests (“MR”) where storage is added to existing renewable generation?  Would these qualify for this process and then be able to proceed through the MR?  When would they be eligible for the TPA?
• On the stakeholder call, the ISO expressed concerns that the Independent Study Process would be flooded with new interconnection requests.  How does the ISO intend to prevent this new process from being flooded with new requests?  Will the ISO treat all of these requests equally, or will the ISO be required to “agree that the interconnection is warranted to potentially maintain reliability”?

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

Upstream supports the ISO proposal.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

Upstream supports the ISO proposal and supports the inclusion of PPA termination due to errors and omissions of a PTO within the eligibility criteria.  

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Upstream supports the clarification.   

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Upstream supports the ISO proposal.  

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Upstream supports the ISO proposal and requests that the study areas be clearly defined and made public prior to the queue cluster window opening on April 1^st.   

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

Upstream supports the ISO proposal.  

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Upstream supports the proposal put forth by SCE.   

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

Upstream supports the proposal.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

Upstream supports the ISO proposal and supports the comment previously made by CalWEA regarding the timing of the limited operational study.  The current tariff stipulates that the limited operational study can only be completed six months prior to commercial operation.  This does not work in practice because a developer cannot finance a project under the stipulation that a limited operational study may show that the project can come online prior to a RNU.  This study need to be completed prior to a developer issuing Notice to Proceed.    

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

Upstream supports the ISO proposal.  

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

Upstream supports the ISO proposal.  

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

Upstream supports the ISO proposal.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

Upstream respectfully requests that the ISO reconsider suggestions made by multiple stakeholders to improve the Independent Study Process.  

• The ISO expressed concern on the stakeholder call that the ISP may see a future “mini cluster,” but this shouldn’t be a concern.  The CAISO has or is currently processing 2,192 interconnection requests and only 18 of these have been studied under the Independent Study Process.  The site exclusivity requirement and fact that only a single ISP can be processed within a study area at any given time provides sufficient guardrails to prevent a “mini cluster”.  
• The ISO also expressed concern on the stakeholder call that ISPs tend to get filed prior to the queue cluster window and that these projects are simply trying to queue jump.  This is not true – there is a small window after completion of the prior queue cluster studies when projects can complete the Electrical Independent Test.  The design and timing of the ISP should not be misconstrued with queue jumping.
• The Independent Study Process is designed to be an accelerated study process.  Why does the ISO want to introduce a new accelerated study process when an existing accelerated study process already exists and can be improved?
• The ISO noted on the stakeholder call that projects studied through the independent study process are studied for reliability only.  Why should a project that queues ahead of other projects and has no impact on other projects in the queue be required to wait for the next queue cluster as an Allocation Group 1 or 2 project?             

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Please see attached.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

Please see attached.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Please see attached.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

Please see attached.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

Please see attached.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

Please see attached.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Please see attached.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Please see attached.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Please see attached.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

Please see attached.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Please see attached.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

Please see attached.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

Please see attached.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

Please see attached.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

Please see attached.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

Please see attached.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

Please see attached.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

Western Area Power Administration-Sierra Nevada Region (WASN) appreciates the opportunity to comment on the CAISO’s IPE 2021 revised straw proposal and supports the CAISO’s ongoing efforts to work with its stakeholders to improve the CAISO generation interconnection process.  In addition, WASN would like to acknowledge the progress made in the CAISO’s efforts to work with neighboring systems to resolve concerns that are driven by CAISO queue generation.   

The need for additional resources within the CAISO footprint is understood and the proposed changes within the 2021 IPE will better equip the CAISO’s GIDAP to accommodate that need.  WASN supports this effort and will continue to work with the CAISO to resolve concerns that appear on the WASN system due to CAISO queue generation.   To fully take advantage of the improved processes gained through the 2021 IPE, and to avoid unnecessary delays related to potentially Affected Systems, WASN has the following suggestions:

Early notification for potentially Affected systems

This will allow Affected systems to remain aware of projects that might potentially impact their system and raise concerns early on that might be addressed in the CAISO study process.  If those concerns can not be addressed, and a separate Affected system study is required, the advance notification will allow Affected systems the adequately plan and dedicate resources so that any additional studies required by the Affected systems can be completed quickly and not result in unnecessary delays for the CAISO process.  

Posting of up-to-date study cases

With the implementation of the 2021 IPE, it is expected that project changes will occur more often during future Cluster study cycles. With the extension of the Cluster 14 study cycle , these changes are expected to be amplified in the near-term with an increased number of projects added to the queue and studied through the Independent Study Process, Fast Track Process or the proposed emergency generation interconnection process.  As these changes in generation will affect the results of related studies, posting up-to-date cases will be necessary for Affected systems to continue to effectively work with the CAISO to resolve concerns during the CAISO study process.

 Coordination and Communication

To improve effective coordination and communication between CAISO and Affected system engineering staff, related contact information should be made more easily available.  This would improve the ability for Affected system to work with the CAISO more effectively in resolving technical matters that might otherwise cause delays for the either the CAISO or the Affected system as they perform their internal review.  In addition, further efficiency might also be gained in the Affected system review process if the Appendix A CAISO project customer reports and meeting minutes are made available through the CAISO RIMS website.

As mentioned, there has been a lot of progress in the CAISO’s efforts to work with neighboring systems regarding CAISO queue generation studies.  Most of the items listed above are a part of the existing CAISO GIDAP practices.  However, with the expected accelerated pace of the CAISO generation interconnection process, they will become even more important for the ability of Affected systems to work with the CAISO to avoid any unnecessary delays.  

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

No Comment

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

No Comment

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

No Comment

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

No Comment

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

No Comment

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

No Comment

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

No Comment

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

No Comment

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

No Comment

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

No Comment

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

No Comment

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

No Comment

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

No Comment

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

No Comment

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

No Comment

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

No additional comments at this time.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 revised straw proposal:

WPTF appreciates the opportunity to submit comments on the CAISO’s Interconnection Process Enhancements 2021 revised straw proposal. WPTF recognizes that the system needs have changed since the original Transmission Plan Deliverability (TPD) methodology was implemented and supports the CAISO’s efforts to better align the assessment of deliverability with actual system needs. WPTF acknowledges the CAISO never intended for allocation group 3 to be used the way it historically has been – allowing developers to secure TPD without having an executed RA contract or being on a shortlist for one. However, the silver lining outcome of this unintended consequence is that CAISO has avoided problems that severely limiting allocation eligibility is sure to create: increasing RA contract delivery risks, further complicating the RA contract solicitation process, reducing overall transparency, and increasing transaction costs.

WPTF is still unclear if and how this proposal achieves the stated goal of this effort to align the allocation process with the planning and procurement process. Furthermore, WPTF is concerned that the CAISO’s proposal for TPD allocation and removing group 3 will increase uncertainty and risk in the contracting process, which in turn will increase transaction costs. Lastly, as discussed in more detail below, we also encourage the CAISO to consider a measurable permitting metric that can take permitting status into consideration.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1:

No comment at this time.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.2:

Fundamentally the CAISO is the administrator for interconnection and deliverability within the bounds of its balancing authority area (BAA) to ensure fair treatment for interconnection requests across its footprint and create a stable environment for interconnection and investment. CAISO’s proposal states a developer must have an RA contract or be on the shortlist for one prior to receiving TPD. This proposal will result in decreased stability because the proposal asks developers and load serving entities (LSE’s) to perform their solicitation and contracting activities together (1) without the CAISO’s input, (2) without knowing if the project will ever be eligible to provide RA, (3) before the project has executed a GIA, and (4) before the project has provided written notice to proceed on network upgrades needed to interconnect the project (meaning PTO construction schedules and achievable commercial operation dates are still very much in flux). This decreased stability will increase transaction costs. This is an incredible amount of uncertainty introduced to the contracting equation. Very basically, what if a project receives an RA contract but does not end up receiving the commensurate TPD allocation from CAISO? The RA contract will be in default, and this risk will inevitably be included into contracting prices up front.

Additionally, WPTF is not convinced eliminating group 3 (proceeding without a PPA) achieves the goal CAISO states of aligning the allocation process with the planning and procurement process. Consider that LSEs will likely choose to include the risk of projects not getting TPD allocation in their contracting processes and choose to make their shortlist longer. LSEs including more projects on a shortlist and waiting to see what gets TPD allocation effectively puts CAISO back in the same position it states it does not want to be in- designing an elaborate scoring methodology and scoring projects based on a number of inputs. Additionally, there’s no insurance a project on an LSE shortlist will get a PPA so there is still the possibility of TPD being allocated to projects without a PPA. However, under this construct overall contracting is more expensive because these risks are included in PPA prices upfront, including in the prices of PPAs executed from the shortlist.

Permitting and site control are equally critical indicators for a project’s readiness and viability and the CAISO’s current process does not take either factor into consideration for allocation in group 3. CAISO is already proposing a control measure to ensure for the site control item by only allowing projects with actual site control (rather than a deposit) to proceed to the Phase II study. WPTF believes that CAISO, in coordination with IPE stakeholders, could create a clear and measurable permitting metric to take permitting status into consideration and encourages the CAISO to do as much in the next iteration of the IPE Phase 1 paper.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.5:

No comment at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2: a) General comments on site exclusivity topic. b) Provide your comments on the appropriate definition for demonstration of site exclusivity for offshore wind projects to be included in the ISO Tariff Appendix A.

No comment at this time.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3: a. General comments on errors and omissions topic. b. Provide your comments on including the termination of the project’s PPA within the eligibility criteria for allowing projects to withdraw and receiving a full refund of its IFS and any unused study deposit when an error or omission is discovered. i. What specific documentation of a project’s PPA termination should be required?

No comment at this time.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

No comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

No comment at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

No comment at this time.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8:

No comment at this time.

11. Provide your organization’s comments on the ISO’s proposal for adding due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

No comment at this time.

12. Provide your organization’s comments on making it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.2:

No comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.4:

No comment at this time.

14. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.6:

No comment at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.9:

No comment at this time.

16. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.10:

No comment at this time.

17. Additional comments on the IPE 2021 revised straw proposal and February 1, 2022 stakeholder workshop discussion particularly focused on any Phase 2 issues. (Please do not re-submit comments on phase 2 issues unless they are new or provide additional clarity. Comments submitted on the Issue Paper and Straw Proposal phase 2 issues will be addressed and considered in the next Phase 2 issues proposals):

No comment at this time.