Comments on Issue paper and straw proposal

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

ACP-California understands the need, however unfortunate, to effectively delay the start of studies for Cluster 15. Given the significant size of the remaining Cluster 14 Phase II requests, and the anticipated size of Cluster 15, some accommodations are necessary. We recognize the difficult situation the CAISO is in, as well as the ramifications for accelerating the interconnection of new capacity and meeting procurement mandates.

We also appreciate that the CAISO had sought to consider informal feedback on how to address Cluster 15, given the present situation. There are certainly pros and cons to opening Cluster 15 on April 3, 2023, and then suspending it, versus delaying the opening of the Cluster window altogether.

We also understand that, after further consideration, the CAISO is planning to open the Cluster 15 window as scheduled on April 3^rd, and is no longer seeking comments on the option to delay Cluster 15 altogether. This is an unfortunate outcome, but understandable in the face of rapidly approaching deadlines. While ACP-California would have supported a full delay in opening Cluster 15 over what is planned, we understand CAISO’s position and look forward to working with CAISO to determine how to address Cluster 15 going forward.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

We commend CAISO for considering the negative impacts of delaying Cluster 15 on all resource types, including the potential impacts on long-lead time resources like Offshore Wind and Out-of-State Wind. While we agree with CAISO that there are unique considerations and risks to out-of-state and offshore resources (along with other resource types), our membership has divergent views on whether a separate Cluster process is feasible or appropriate at this juncture. Should CAISO go forward, however, we strongly recommend CAISO continue to focus on the unique attributes and challenges that these types of interconnections face rather than implement a Cluster study process segmented solely by resource type.

We also urge CAISO to reinvigorate its exploration of reserving capacity for these resource types when accompanied by relevant state policy direction, as was being considered in the Transmission Planning Process (TPP) Enhancements Initiative in 2022. Some of the negative impacts to OSW and OOS Wind from delaying Cluster 15 could be avoided through a combination of prioritizing approval of new network upgrades required for these resources in the 2023-24 TPP cycle and through implementation of the process for reserving capacity that was outlined in the TPP Enhancements initiative. CAISO is on solid footing to pursue this type of approach to provide the necessary process for ensuring that resources including, but not limited to, OSW and OOS Wind, have access to the transmission capacity that the state of California might seek to have approved to support them.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

ACP-California suggests an alternative approach (in the response to Question #7) for CAISO to limit the amount of interconnection requests and align them with procurement activities. Please see our response to Question #7 for more details on the alternative approach.

In general, while ACP-California is supportive of the concept of zonal planning in general, we strongly oppose use of this “element,” as described in the Issue Paper/Straw Proposal, as part of CAISO’s interconnection reforms. ACP-California is concerned that this proposed element is overly restrictive for both generators and offtakers, and that it is contrary to both open access and general interconnection principles.

Implementation of this element would – effectively – restrict the ability for procurement of new resources to take place outside of areas that are already deemed as necessary through the TPP and associated state processes. However, there may be a variety of reasons why procurement outside of these designated areas is warranted and the CAISO’s interconnection process should not inherently preclude resource procurement and development based on their location.  

Additionally, this approach would serve to preemptively restrict the evaluation of generator interconnection in many areas. If a generator seeks to interconnect, and is willing to pay for upgrades in a given area, there should be a process that enables this type of development. Indeed, under CAISO’s current tariff, generators must finance upgrades. This element of CAISO’s proposal would inherently restrict interconnections to predefined areas.

Overall, this approach would be too restrictive and may serve to restrict or eliminate interconnection requests that could be beneficial to the system in the long-run. It also runs counter to general open access principles by preemptively restricting the ability of resources to interconnect to the transmission system in certain locations. Thus, we recommend an alternative approach (in response to Question #7) which would serve to restrict the amount of definitive interconnection requests that are studied but would provide more flexibility on where those interconnection requests can be located on the grid.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

In the response to Question #7, ACP-California suggests an alternative approach to limiting definitive interconnection requests that are studied. Our alternative approach would serve to limit the number of interconnection requests that are submitted but would do so by providing offtakers (both Load Serving Entities and corporate offtakers) with a mechanism to indicate a preference for studying particular projects in the definitive interconnection queue. This suggestion is, in effect, to use a different type of screening criteria to limit the number of interconnection requests that must be studied. ACP-California is also open to discussing other readiness screening criteria such as site exclusivity (or deposits) and permitting progress, but opposes utilizing a strict MW limit for priority zones.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

In the response to Question #7, ACP-California suggests an alternative approach for CAISO to consider to better align definitive interconnection requests with resource procurement activities.

ACP-California understands the importance of incorporating some form of commercial readiness, or commercial interest, criteria to limit the number of interconnection requests that are received and, thus, a commercial element is an important component of interconnection queue reforms. However, the signing of a PPA or selection in a shortlist is too onerous to require at this stage in the development process. Additionally, there should be special considerations for long-lead time resources like OSW and OOS wind. In particular, for OSW there is no offtake mechanism yet in place, though central procurement has been proposed. Should a central procurement mechanism be adopted it would take time to implement and this dynamic needs to be considered. In addition to a PPA or shortlisting being too strong a commercial element to enter the queue, the unique circumstances of long-lead time resources needs to be evaluated. To help address this, ACP-California recommends an alternative strategy, in response to Question #7, as a mechanism for offtakers to indicate commercial interest while allowing the project to proceed through the interconnection study process without requiring a full blown PPA or short listing. This process, coupled with an informational interconnection study process, may serve to achieve many of the goals that CAISO has articulated for queue reform while not requiring offtakers to take binding commercial actions prior to having interconnection study results for a particular project.  As ACP noted in response to FERC’s 2022 interconnection NOPR, requiring demonstration of commercial readiness excessively early in the interconnection process is fundamentally incompatible with typical project development, which requires some indication of potential upgrade costs before a PPA can be negotiated. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

In response to Question #7, ACP-California suggests an alternative approach for queue reforms that should help achieve CAISO’s objectives but would not increase uncertainty by limiting the number of interconnection request windows. ACP-California does not support limiting the opening of an interconnection window to only times when it is “warranted.” Having a regularly scheduled interconnection queue is important to allow a variety of different procurement processes to proceed with some relative certainty, and without undue discrimination towards new projects. And we are concerned that by only opening a window when “warranted” there will inevitably be times when a window is warranted for some purpose but may not be sufficient for CAISO to deem it necessary, which could delay the interconnection of new resources even further. Moreover, to justify the investment in site/project investigation and development and getting projects “commercially ready” interconnection customers need certainty as to when they will be able to exercise their open access rights. We recommend CAISO further develop the necessary details to implement the proposal put forward in our response to Question #7.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

ACP-California understands and appreciates the need to better align the interconnection process with resource procurement and with transmission planning. Further, we understand that the number of interconnection requests that CAISO received in Cluster 14 and expected to receive for Cluster 15 is not sustainable and is leading to several challenges, from securing the staffing and resources to perform the studies, to producing studies with unrealistic results given the level of requests in each area. Thus, meaningful changes to the interconnection process are required to create a durable, sustainable, and predictable process going forward.

Below, we outline an initial concept for CAISO to consider in implementing queue reform, which we are referring to as the “Informational and Definitive (Indicative Commercial Interest) Queue Process.” ACP-California acknowledges that this proposal is not fully fleshed out at this early stage, but we believe the general concept is worthy of further exploration and development of key details as Track 2 of the IPE 2023 stakeholder process moves forward.

Our proposal involves creating two tiers of interconnection queues: one being purely Informational and another being Definitive (i.e. can lead to an Interconnection Agreement). The Definitive queue would require some preconditions for resources to enter, which could include deposits, site exclusivity and permitting requirements that vary by Phase of the process. But the most important precondition that ACP-California proposes, for those seeking Full Capacity Deliverability Status (FCDS) or Partial Capacity Deliverability Status (PCDS), is an indication of commercial interest from a potential offtaker. The proposal also includes a proposed limit on the amount of resources an offtaker can provide this indication of commercial interest indication for, incorporating any relevant statutory or regulatory procurement requirements. This proposal might be thought of as being somewhat similar to the “Resource Solicitation Cluster” that is utilized by some other Transmission Providers (most notably Public Service Company of Colorado) but has been modified to fit within the CAISO framework. It should also be noted that the proposal, described below, may not work well in other market constructs, such as those where the offtakers themselves are also resource developers and thus it is unlikely to be successful on a broader geographic scale than CAISO. But in the context of the CAISO market, where offtakers are generally not developing their own resources, this construct may be able to be implemented with fewer concerns associated with vertically integrated utilities limiting open access to the transmission system.”

The frameworks offered by ACP-California also offers several advantages over the different elements that CAISO proposed for consideration in the Straw Proposal, including:

• It would not limit interconnection requests to predefined areas
  • Thus, it would provide potential offtakers more flexibility in making resource procurement decisions, provide developers more flexibility in proposing unique projects, and would maintain open access principals
• It would limit definitive interconnection requests to a more reasonable number, but would not require offtakers to make a binding commitment to projects prior to obtaining definitive interconnection results

Given these benefits, we recommend that CAISO further explore this proposal during the upcoming stakeholder process for Track 2 of the 2023 IPE.

Summary of the Informational and Definitive (Indicative Commercial Interest) Queue Proposal

The first element of this proposed approach would be to implement a high-level, optional, and information-only interconnection process. This Informational Queue would be open to any potential interconnection requestor. The Informational Queue would serve to provide data and information on the feasibility of different interconnection points on the system. Additional details for this process would need to be developed, but the intention is that this screening level study should not create an undue burden on already strained resources available to perform this type of study work. Wherever possible, ACP-California recommends that CAISO automate the analysis needed for Informational Queue data, and publicly post that data in useable formats (including as a “heat map”).  The Informational Queue should provide a tool for interconnection customers to gain a high-level understanding of the interconnection impacts of their projects, which they can use in discussing their project with potential offtakers (and in seeking to secure the designation necessary to enter the Definitive Queue).  

The second element of the proposed approach would be a Definitive Interconnection Queue. The Definitive Queue would be the process used for projects to secure an Interconnection Agreement and interconnect to the grid. The Definitive Queue could include several screening criteria, that would differ based on whether the project is seeking to proceed as Energy-Only or if it is seeking FCDS or PCDS. In other words, interconnection requests seeking to secure any type of deliverability allocation would have a higher bar (including Indicative Commercial Interest, discussed below) to enter the Definitive Queue. Projects that elect to proceed as Energy-Only would be able to enter the Definitive Queue with fewer requirements/screening and would not require any level of commercial interest (thus continuing to provide a mechanism for merchant projects to interconnect to the CAISO grid).

Projects that are interested in securing FCDS or PCDS could have a number of screening criteria applied in order to enter the Definitive Queue but, most importantly, they would need to have a designation from a potential offtaker as having “Indicative Commercial Interest.” Indicative Commercial Interest designations would be limited (as discussed more below) to help reduce the number of interconnection requests that must be studied in the Definitive Queue by CAISO and the PTOs.

Indicative Commercial Interest allocations would be available to potential offtakers, including both Load Serving Entities and corporate offtakers. The allocations would be for a MW amount of deliverability and could be tied to the known procurement needs for LSEs and a process for corporate entities that would require documentation of clean energy procurement goals and the quantity of resources needed, within CAISO, to meet those goals. There may need to be a scaler or other factors that should be added to the quantified procurement need for each offtaker. But, ultimately, each offtaker would receive (for each Cluster window) a designated MW amount of deliverability status that they could use to identify projects they have an Indicative Commercial Interest in. The designation of having Indicative Commercial Interest would be a gatekeeper for resources to seeking a deliverability allocation through the Definitive Queue. This designation would allow the projects to enter the definitive queue and would require some level of commercial interest but would not require offtakers to have signed PPAs or have short listed the projects ahead of the interconnection study process. It would serve to limit interconnection results amounts in any given cluster, provide a tie to procurement interests, and provide flexibility on procurement to offtakers. And, thus, we believe it warrants further exploration within the CAISO.

Following the completion of Phase I studies for the Definitive Queue, offtakers would be able to review the interconnection study results and determine if they would like to continue forward with the project they designated as having Indicative Commercial Interest or not. If they do not proceed with that resource, the MW allocation allotted to the offtaker could be provided to a different resource for analysis in the upcoming cluster study cycle. But if the offtaker does choose to proceed with the resource, it would enter Phase II and that MW allocation for the offtaker would continue to be tied up and would not be reallocated back to the offtakers for use in the next cluster study.

As part of this process of re-envisioning the interconnection queue process, we recommend discussion on long-lead time resources. Notably, even under a central procurement mechanism, OSW – for instance – will likely not have a PPA in place at the beginning of Phase 2. Lack of a current offtake mechanisms for these resources should not adversely impact their queue treatment and we recommend additional discussion around these dynamics.

ACP-California recognizes that there are significant details and new processes that would need to be developed to implement this approach. We believe that the Informational and Definitive (Indicative Commercial Interest) Queue process provides significantly more flexibility to procurement entities and developers than the other elements that have been proposed in this stakeholder initiatives so far. And, at the same time, it achieves the goals that CAISO is seeking to achieve with its interconnection reforms, including providing a strong tie to procurement interests of offtakers. Thus, we recommend further exploration of this concept by CAISO and stakeholders in Track 2 of IPE 2023.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

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1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

AES Clean Energy appreciates the CAISO’s due diligence to accept interconnection requests for Cluster 15 during the April open request window.  AES Clean Energy understands that CAISO staff is under resource constraints to process the expected increased interconnection requests (IRs) for Cluster 15 and beyond, while studying each IR with the highest level of accuracy.  Understanding that Track 2 reforms will affect the treatment of Cluster 15 projects, AES Clean Energy urges the CAISO to allow interconnection customers (ICs) to make modifications to their IRs and withdraw penalty-free prior to resuming the scoping and validation meetings.  ICs should be given a month between the FERC approval date for Track 2 reforms to modify and/or withdraw projects as needed at minimal costs. ICs should also be allowed to modify the following: 

1.  Point of Interconnection (POI): ICs should be allowed to change their POI within one substation range from the IR’s applied substation or from the IR’s applied transmission line to the closest substation. 

2. Project Capacity: ICs should be allowed to increase or decrease the original IR’s capacity without a material modification request. 

3. Fuel Type Changes: ICs should be allowed to modify the fuel type of their project, including adding storage, and submit any updated data/models as needed to support this request without a material modification request, 

4. Transmission Line Layout Changes: ICs should be allowed to modify the layout of the interconnection request to connect generation to the substation. 

In addition, within the Track 2 stakeholder process, CAISO should also consider allowing a limited number of new applications for Cluster 15 after Track 2 reforms are finalized.  This small reopening window can occur during the same time that ICs can modify and/or withdraw their existing IRs that were submitted in April 2023. 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

AES Clean Energy has no substantive comments at this time.  AES Clean Energy is willing to work with CAISO on potential schedule changes to accommodate special studies but notes that long lead time projects, such as offshore and out-of-state wind, should not cause delays for in-state applications in the interconnection queue. 

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

AES Clean Energy appreciates CAISO’s efforts to align resource and transmission planning activities, interconnection processes, and resource procurement to provide developers with greater insight into the most optimal areas for interconnection.  However, AES Clean Energy has several concerns with this proposal including open access violation due to study limitations, potential increased cost of development, overreliance on CPUC’s IRP as a primary mechanism for interconnection, and lack of consideration for other optimal interconnection zones outside of CPUC resource portfolios.  AES Clean Energy’s comments discuss individual concerns and provide alternative considerations for each concern. 

1. Open Access Concern - AES Clean Energy is concerned that restricting the interconnection study to certain zones may undermine the long-held Open Access Principles established in FERC Order 888, which could undermine the CAISO’s reform efforts and ability to implement reforms that will be effective for Cluster 15.  

2. Increased project cost due to competition in zones:  AES Clean Energy is heavily concerned that the proposal limits development into priority zones that will unduly increase development costs, and by extension, ratepayer costs. The proposal will result in pre-identified priority zones with existing or planned transmission capacity that will increase competition for the same area of land.  This will likely increase project development cost and contract prices, resulting in negative ratepayer impacts. 

   • Alternative:  In the priority transmission zones, CAISO should provide greater cost certainty and transparency.  This would allow ICs to contract at a competitive rate in advance of final IC study results.  For example, MISO and SPP’s Joint Targeted Interconnection Queue (JTIQ) study proactively identifies and approves transmission lines along the seams of the two regions.  The JTIQ’s goal is to create timing and cost certainty for affected systems by providing ICs with an estimated range of affected system study costs ahead of time.1 CAISO can take principles from this JTIQ process and create an informational price map by priority zones that includes, but is not limited to:(1) price range per MW for interconnection for each substation, (2) potential network upgrade costs, (3) and potential affected system study costs. CAISO should also provide any other miscellaneous information pertinent to interconnection in these zones to help guide developers.  If developers had a posted price in each zone and more certainty on the timing of network upgrades, they would have a greater understanding of their costs. This would allow developers more opportunities to engage in more forward contracting. 

3. Overreliance on the Integrated Resource Plan (IRP) as the primary mechanism driving interconnection:   AES Clean Energy understands CAISO’s effort in aligning the interconnection process with the transmission planning process (TPP) and IRP. However, AES Clean Energy is concerned that this proposal may over-rely on the state’s resource planning without any margin for error. To date, the CPUC has authorized 11.5GW of new resources for midterm reliability procurement under the IRP and around 2,000 MW - 3,000 MW of new resources under the Summer Emergency Reliability Order Instituting Rulemaking.2  These procurements orders have been made to fill in capacity needs in the near to midterm based on capacity shortfalls. Despite existing procurement orders, projects have still been significantly delayed to reach their Commercial Operational Date (COD), putting IRP procurement goals at risk.3 Only relying on state planning processes to inform interconnection activities may result in “just in time” interconnections without a margin for planning errors. In addition, there continues to be differing assumptions in the resource adequacy and IRP programs that create larger resource planning uncertainty. AES Clean Energy cautions CAISO to only rely on the state planning processes to guide interconnection practices without a margin for error. 

   • Alternative:  The CAISO should consider an added margin on top of the IRP resource portfolios to consider planning errors and minimize “just in time” interconnections to meet state policy goals. 

4. Priority zones may not consider other optimal interconnection locations:  From AES Clean Energy’s experience, locations outside of the IRP resource portfolio zones can also be optimal for interconnection. These interconnections can also support reliability, such as by alleviating congestion between different zones or mitigating energy deficiency. 

   • Alternative: The CAISO should allow for interconnections outside of the pre-identified priority zones based off the IRP and TPP.  The CAISO should allow ICs to submit a 3rd party study supporting an alternative point of interconnection outside of the priority zones. This is a current practice in NYSERDA’s request for proposal process.4 

In circumstances where CAISO does not believe that an IR is submitted in an area with existing or planned capacity, the CAISO should provide developers an opportunity to conduct a 3rd party study and consult with CAISO to revisit the decision. Finally, AES Clean Energy seeks clarification on the treatment of energy-only resources under this proposal.,  

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

At this time, AES Clean Energy does not support limiting studied IRs based on existing or planning capacity. Instead, the CAISO should consider higher readiness criteria for entering into the interconnection queue which can be discussed during the stakeholder working groups. For example, additional readiness deposits to demonstrate the financial viability of the project as utilized in MISO and PJM should also be considered.  

AES Clean Energy would be open to further exploring the auction method to allocate interconnection rights.  However, this idea should be further explored in a stakeholder working group. The academic community should also be included to ensure the auction mechanism is based on reasonable economic principles. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

AES Clean Energy is concerned that the proposal will result in a degradation of value and certainty that PPAs currently provide.  From AES Clean Energy’s experience, phase 1 study results do not provide certainty for developers and offtakers to execute a PPA due to the lack of accurate details and the potential for significant changes from project withdrawals. Moreover, it is AES Clean Energy’s understanding that LSEs rely on more accurate total network upgrade costs after Phase 2 studies to conduct their least cost best fit analysis. Given the lack of cost and timing certainty, the proposal will likely cause PPAs to include more lenient exit clauses to give parties the ability to manage timing and risk.  In addition, LSEs may have greater uncertainty that the contracted projects will advance in construction, resulting in greater project financing uncertainty. LSEs may need to sign more PPAs than actually required to account for project attrition. As a result, requiring a project to have a PPA or be shortlisted for a PPA before entering phase 2 studies may dilute the current value of PPAs and increase the volume of lenient PPAs. 

AES Clean Energy provides two alternatives to the CAISO’s proposal. First, AES Clean Energy believes this proposal may be manageable if CAISO can provide greater price transparency of interconnection costs earlier in the process.  For example, CAISO should provide and update on a regular basis, a map of generic interconnection cost by zones.  This map can be used by developers prior to entering the interconnection queue.  The interconnection cost can then be further refined in Phase 1.  This will provide parties some cost certainty prior to executing a PPA. Second, the CAISO should require other readiness metrics, such as permit applications, to move onto Phase 2.  For example, CAISO can require CEQA applications to move onto Phase 2 studies. CEQA applications can still indicate development intent and PPA value can be maintained. 

If CAISO moves forward with this proposal, AES Clean Energy urges to allow deposits in lieu of having or being shortlisted of a PPA to maintain open access principles and pricing competition.  Many WECC entities, such as Public Service of Colorado and PacifiCorp allow interconnection customers to submit a deposit ($/MW) in lieu of an executed term sheet to demonstrate commercial readiness.  Allowing this option can help maintain the competitive nature of the resource adequacy market by giving LSEs more choices and time for contracting. The deposit in lieu of option also helps preserve Open Access. 

If CAISO moves forward with this proposal, AES Clean Energy also urges the CAISO to: (1) allow PPAs with non-LSEs to count toward this requirement; (2) engage with developers regarding the viability of the approach in addition to LSEs; and (3) maintain the transmission planning deliverability rules as is. 

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6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

AES Clean Energy strongly opposes the CAISO to eliminate the annual open request window and believes this proposal would violate Open Access principles.  The annual open request window gives developers the opportunity to adjust to new federal policies and/or state mandates (i.e., IRA tax incentives and updated CPUC procurement targets through IRP or Summer Emergency Reliability proceedings).  The certainty of cluster windows allows developers to coordinate strategic development activities such as land prospecting, financing, and procurement and submit the most ready projects in the interconnection queue. Moreover, AES Clean Energy encourages CAISO to provide sufficient notices, such as three months, regarding the status of the annual cluster window to give developers certainty of the next opening and duration. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

Please refer to AES Clean Energy’s recommendations throughout the comments. 

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

AES Clean Energy recognizes the strain the CAISO is experiencing with the unprecedented increase of IRs.  AES Clean Energy applauds CAISO for taking a proactive approach to reform the interconnection process prior to the Final FERC Order on the Interconnection NOPR.  AES Clean Energy is committed to being partners with CAISO and stakeholders during this policy development process to help the state meet its clean energy goals while maintaining a robust and competitive market. AES Clean Energy provides general comments regarding stakeholder engagement and FERC risk below. 

First, AES Clean Energy supports CAISO administering stakeholder working groups as suggested at the March 13 stakeholder meeting. Conducting a series of stakeholder working groups can expedite the policy development process and result in a greater chance of reaching consensus prior to the release of the Track 2 Straw Proposal. AES Clean Energy proposes weekly or bi-weekly working groups for a minimum of two months to allow stakeholders to vet and develop ideas.  These working groups could be forums to educate CAISO and stakeholders on the development and LSE procurement processes and allow stakeholders to present Element proposals for consideration.  Given the desire for radical change under a short timeframe, AES Clean Energy suggests the following schedule: 

• Early April 2023: CAISO to develop stakeholder working group schedule and tentative discussion topics, and take stakeholder nominations for any additional topics 

• End of April 2023 – June 2023: Stakeholder Working Group Meetings either weekly or biweekly 

• July 2023: Straw Proposal and Stakeholder Meeting 

• September 2023: Revised Proposal and Stakeholder Meeting 

• October 2023: Additional Stakeholder Working Group Meeting as needed to reach further consensus 

• November 2023: Draft Final Proposal, Draft Tariff Language, and Stakeholder Meeting 

• December 2023: CAISO Board of Governor’s Meeting 

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AES Clean Energy also urges CAISO to ensure all affected stakeholders are engaged with the CAISO.  Although AES Clean Energy is encouraged that CAISO intends to work with LSEs to better understand procurement needs, it is critical that CAISO provide the same level of engagement with developers.  Engagement on all fronts will ensure that the California bilateral market continues to be effective with these significant interconnections reforms for all parties affected in the procurement process. 

Finally, AES Clean Energy cautions the FERC risk with certain elements of the proposal, such as limiting development in certain areas and eliminating the annual open request window.  As proposed, these elements could jeopardize open access principles and may potentially face heavy scrutiny when filed at FERC.  This could result in a delayed timeline for implementation.  AES Clean Energy recommends CAISO be open to alternative stakeholder ideas to ensure the final proposals are viable and compliant with open access principles. 

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Avantus Position: Opposed

Avantus Proposal: Avantus Clean Energy LLC (Avantus CE) requests that CAISO reconsider delaying C15 request window opening by a year if resumption of validating requests would not take place until at least April 2024. Requiring Study and Site Exclusivity In-Lieu Deposits to sit for a year only ties up that considerable security.  Avantus CE also requests that the ISO hold off assessing the $500,000 Site Exclusivity In-Lieu Deposits until April 2024 when C15 is projected to resume.

Additional Comments: We kindly request CAISO to reconsider the 2021 IPE Phase 2 change to make the Site Exclusivity In-Lieu deposit fully refundable until after C15 Phase I study, considering we will not have complete C14 Phase II results and the 2023-2024 TPP results to truly inform our C15 submittal that are due to be deemed complete by April. By not delaying the C15 window open until after C14 Phase II is complete, we are working off limited data for site selection and it is likely to exacerbate the volume of requests.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Avantus Position: Opposed

Avantus Proposal: If the CAISO proceeds with this initiative, it should ensure any of the projects identified as Cluster 15(a) projects be required to contribute to any Network Upgrades identified in the future as part of the Cluster 15(b) study of projects that would not be participating in this group of special consideration projects rather than being exempt.  There also needs to be a pre-determined amount of Offshore and Out-of-State Wind that would be allowed from separate interconnection timelines, as to not incentivize LSEs from procuring solely from Offshore and Out-of-State Wind, rather than Solar or Energy Storage, based on the earlier potential study timeline.

Additionally, we urge the CAISO to impose stricter Site Exclusivity requirements for these projects to ensure that projects that are given special consideration are both in line for readiness and viability by requiring these projects to meet the Site Exclusivity requirements and eliminating the ability to post the “in lieu of” deposit for entry.

Additional Comments:  If CAISO offers a more expedited study format for Offshore and Out-of-State Wind, this could put other types of projects at a disadvantage. Because of this, it’s believed that before moving forward with this initiative, the CAISO should provide detailed rationalization to support this.  With the publication of the annual TPP upcoming, the findings from the report could indicate that this initiative is not needed due to the expected approved upgrades stemming from this study may already support these efforts.

On the other hand, as a part of the process in identifying upgrades to support long lead-time projects outlined in the IRP, rather than limiting approved upgrades that would solely benefit OSW & OOSW, it would identify those that benefit other technology types as well. This maintains the ISO’s principles to be non-discriminatory. Note also that the IRP has not been updated to include storage and other non-wind resources, further supporting the need for them to be considered.

Should the TPP not identify approved upgrades in support of OSW & OOSW, the ISO should examine whether these projects in turn should be given special consideration at all.

Regardless of whether upgrades are approved in support of OSW & OOSW, there still doesn’t seem to be substantive rationale to support “special treatment” of these resources. Transmission Planning should be attribute-based and not biased toward a specific technology.  We maintain that capacity should be available in a non-discriminatory manner to applicants of all technologies.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Avantus Position:  Opposed

Avantus Proposal: Avantus CE suggests postponing the Track 2 initiatives and instead, setup up a forum where industry stakeholders (CPUC, LSE’s & developers) can work in partnership to address CAISO’s concerns on these matters before putting forth this proposal.

However, if Element 1 proposal proceeds as written, Avantus CE recommend the ISO to make available existing and planned capacity information for multiple clusters at once (E.g., “ISO can accept X capacity in C16 and Y capacity in C17 according to TPP and Resource Plan.”), and not just the immediate cluster as to provide a more holistic and longer-term picture for development needs. This is critical for work-stream planning for the industry.

We believe that it is appropriate for the Generator Interconnection Process to advise Interconnection Customers to the location and volume of existing/planned capacity, as identified during the CPUC busbar mapping & Transmission Planning processes, however, we disagree with using these inputs to restrict or limit interconnection activities.

Additionally, if referenced capacity information was made available as part of the CAISO Data Transparency Effort that spun off from IPE 2021, we believe the projected queue volume would’ve significantly reduced.

Furthermore, to preserve a diverse and abundant resource pool for LSEs during the procurement process, it is important to continue enabling an interconnection queue volume larger than existing/planned capacity. The extent of the proposed limitation should be carefully considered.

Additional Comments: Limiting interconnection activities to where Transmission Capacity is available, constrains the Generator Interconnection process to be completely dependent on a Transmission Planning process that is undergoing improvements to properly meet the RPS.

While we recognize CAISO’s longer term planning effort and substantial portfolio of approved upgrades in the more recent TPP cycles, it is industry consensus that transmission capacity became scarce largely due to slow down in proactive interregional planning, (RE: FERC order 1000 comments in TP NOPR) exacerbated by interconnection activities that were not planned for.

Additionally, Element 1 as proposed like likely to eliminate projects that would otherwise trigger lesser scoped LDNUs entirely due to “deficient” capacity area. This also limit a project’s ability (however rare) to fund any ADNUs identified for a given study area. For the ISO to decide such projects from moving forward purely due to not being in the “desired areas”, is contradictory of what “Open Access” was designed to achieve.

Furthermore, there are notable historical examples of large transmission projects built specifically to utilize new resources (e.g., PNW->Hydro resources). With time, planning activities evolved to accommodate load growth, and presently a mix of both, vis-à-vis Offshore and Out-of-State Wind being given special consideration. We urge the ISO to continue refining their priorities in ways that achieve a balance between enabling the best projects to materialize and achieving the state’s objectives.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

Avantus Position: Opposed

Avantus Proposal: We request the CAISO provide more substantive details on how an auction format would work to determine which project can proceed. Without further details, our opinion is that an auction format would likely favor the largest developers with abundant capital backing.

Additional Comments: Limiting areas to where capacity is available could increase local land prices/competition, thus decreasing economic viability of said projects, and in turn affecting PPA pricing.

Element 1 and Element 2 combined are problematic in that they are restricting interconnection activities. Potential downstream effect includes 1) reduced option in solicitation pool, 2) less competitive pricing, 3) long term resource adequacy issues.

We urge the ISO to carefully consider and review how such restrictions affect long-term resource adequacy. Amidst a time when California regulatory bodies are working to extend Diablo Canyon Power Plant for meeting reliability needs, we urge the ISO to consider the proposal’s potential to exacerbate similar unintended consequences.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Avantus Position: Opposed

Avantus Proposal: Viability criteria such as permitting & site control should be considered in lieu of a PPA to satisfy this readiness requirement.

Assuming this is to align with a “First Ready, First Served” principle outlined in the FERC GI NOPR, Avantus CE views there should be more than one option aside from PPA as a screening criterion (e.g., Site Control, Permitting,).

If Element 3 proceed as written, Avantus CE recommend adding alternative options as a criterion and exclude requirements for PPA/Shortlisting to be tied to LSEs and/or RA obligations.

Additional Comments: Although merchant activities in the ISO footprint remain minimal at this point, the industry expects to see more merchant reaching commercial operation in the future. This is likely to be more relevant to stand alone storage projects, amidst an environment where Deliverability is scarce. By requiring a PPA to enter Phase II, merchant opportunities would be virtually eliminated. This is contradictory to the 2021 IPE Phase 2 changes which put merchant projects at a higher priority for TPD than projects proceeding without PPA.

To make Shortlist/PPA a viable criterion, the ISO will need to provide more certainty to Developers and LSEs on potential costs and schedule in the Phase I Study Results.  CAISO and LSEs would need to align their procurement timelines with the completion of the Phase I Studies.  Note this could also impact land or permitting negotiations when the counterparty requires to see specific interconnection milestones before entertaining offers.

Additionally, how does CPUC view PPA/shortlist from an approval/oversight perspective before studies are complete and costs are finalized? We recognize that coordination between resource planning and interconnection is memorialized in the MOU, however, without further details on the MOU and IPE proposal, the extent of stakeholder feedback is limited. Though the ISO stated desire for sequence of event to start with obtaining initial stakeholder feedback before further communication with regulatory bodies, please note that LSE procurement activities are entirely overseen by the CPUC. Their opinion for this topic is critical and should be the primary driver.

Furthermore, we urge the ISO to inquire with LSEs and report to stakeholders the quantity/volume (in aggregate) of PPAs that have been executed before all studies (Phase I, Phase II, and Deliverability) are completed and costs are finalized. Additional points to consider:

• Historically, CAISO projects in the queue are protected from phase II costs per Phase I Maximum Cost Responsibility (MCR).
• Since C14, Phase I MCR has become advisory only and we expect this to be applicable towards C15 and beyond.
• Using PPA as a screening metric at existing context is likely to disqualify more projects than intended, while simultaneously adding risks for offtake.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Avantus Position: Opposed

Avantus Proposal: If Element 4 proceeds as written, we recommend the study window opening notice be at least X years in advance as developers require time to prepare work spanning across land, permitting, and engineering. Although excessive number of interconnection requests are seen as “speculative”, each active interconnection queue is the product of significant hours of such up front work. Often, the missing piece to a viable queue position is Grid Data Transparency.

Additional Comments: Avantus CE do not recommend this proposal as an intermittent IR schedule would add to uncertainty in the interconnection process, affecting company resource, staffing, and strategic planning.  The CPUC in its recent white paper on procurement recognized the need to establish a predictable, methodical procurement trajectory to avoid capacity shortages like those that occurred in the past few years and meet the sizable system needs.  The CAISO should maintain a similarly predictable IR schedule so that companies can efficiently deploy resources to meet our common supply goals.

Additionally, the ISO should reconsider its time limit in queue policy that is now greatly affected by the longer timelines of upgrades requiring 5-9 years due to insufficient infrastructure.

Furthermore, while not identical in context, note that PJM had previously requested FERC to approve a four-year pause on accepting interconnection requests amidst severe backlog. FERC ruled that they are only allowed to delay processing the requests but maintained that they must continue to accept them. Element 4 proposal could trigger similar response from FERC as CAISO is proposing to keep the process closed until deemed necessary to open.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

Avantus CE proposes the following alternative elements to supplement the 2023 IPE effort.

Limited Operation Study Expansion

To avoid completely stifling interconnection activities, we recommend other bridge reforms that may help interconnection requests to materialize, a particular one being Limited Operation Study.

ISO staff have acknowledged that its Limited Operation Study Business Practice is limiting due to the timing a generator is able to initiate the request. Under current procedure, Generating Facilities can request an LOS “no earlier than 5 months prior to the Generating Facility’s Initial Synchronization”.

The Initial Synchronization date is guided by the In-Service Date which is dictated by the longest lead time upgrade established between studies and LGIA negotiations. If the longest lead time upgrade is 5 months longer than the next longest lead time upgrade, the LOS becomes impractical for accelerating commercial operation.

In other jurisdictions, Limited Operation Studies can be requested as soon as a queue position is established and meet required conditions (NVE), or the study would be provided as part of their System Impact Studies (SPP). The result provides the GF a glimpse of their ability to operate within the existing system at a given time requested, but with more realistic information because such results also include other established queue positions in the same cluster.

One example that’s particularly relevant are the amount of Short Circuit Duty (SCD) upgrades triggered by a large volume of interconnection requests in one study area. These upgrades extend construction duration from 36-48 months, to as long as 108 months, severely impacting ISDs. By knowing what MW level a GF can bring online without these upgrades, it signals which SCD upgrades are realistic, while also signaling what queue volume reduction would be needed to support a practical resource buildout.

We believe revising to expand and standardize the use of LOS should be considered as a tangential alternative to element 1 amidst long lead time transmission projects in the horizon. Rather than deliberately limiting interconnection study activity, perhaps a more informative approach by providing better insights, could achieve the same results, but in an open access manner.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

No additional comments. 

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

BayWa r.e. Solar Projects LLC (“BayWa r.e.”) is opposed to CAISO’s straw proposal with respect to the Cluster 15 request window (“C15 Window”).  Instead, BayWa r.e. requests that CAISO (1) proceed with the current filing deadline of 4/17 and (2) not collect the $500,000 Site Exclusivity In-Lieu Deposits until 2024, shortly before CAISO’s validation of the QC15 interconnection requests. 

Given that CAISO anticipates that the validation of requests submitted during the C15 Window will not resume until April 2024 at the earliest, a one-year delay on collecting the deposits would provide applicants additional time to satisfy CAISO requirements, thereby alleviating both the time pressure on applicants to satisfy such requirements and the burden on CAISO staff as applications will be more fully developed.  Additionally, requiring Study and Site Exclusivity In-Lieu Deposits to sit for a year only ties up that considerable security and does not provide meaningful benefits to any party. 

BayWa r.e. is in support of CAISO’s straw proposal with respect to allowing interconnection customers to “(a) refresh their interconnection request...and (b) withdraw for minimal or no cost at any time until study work begins.” A longer runway between the application deadline and start of the Phase 1 Study necessitates greater flexibility on CAISO’s part, as real estate and ISO-level transmission planning activities can impact developers’ strategies pertaining to project sizing and POI selection. Since the intention is for CAISO to wait until April 2024 to validate QC15 applications, there is no harm in CAISO accepting revised interconnection requests that reflect developers’ responses to changing market conditions. BayWa r.e. appreciates CAISO’s recognition of a need for a higher degree of flexibility in light of the IPE Straw Proposal. 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

BayWa r.e. is opposed to CAISO’s proposals with respect to the Other Issues for Consideration.  In particular, while BayWa r.e. notes that out-of-state wind and offshore wind are important resources to achieve California’s sustainability and renewable energy goals, the proposed preferential treatment with respect to these types of assets is discriminatory with respect to solar generation and in-state wind resources. 

In the event that CAISO proceeds with these initiatives, BayWa r.e. requests that CAISO make clear that solar and in-state wind resources which are delayed to a second phase of the C15 Window are not saddled with costs for the network upgrades identified for the projects preferentially examined in a first phase of the C15 Window, unless these second phase projects directly make use of such network upgrades.  Additionally, given the likely higher cost for network upgrades triggered by these first phase projects, BayWa r.e. further requests that second phase projects making use of such upgrades be allocated costs on a pro-rata basis using a methodology that accounts for the lesser impact in terms of network upgrades that the second phase projects would have triggered.  

Lastly, BayWa r.e. proposes a cap or other limitation on the out-of-state wind and offshore wind resources to be evaluated in a first phase of the C15 Window so as to not improperly incentive load serving entities to contract exclusively with such resources due to the increased timelines imposed on second phase projects as a result of the delay in their evaluation by CAISO.  Solar and in-state wind are also important resources for achieving California’s sustainability and renewable energy goals. 

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

BayWa r.e. concurs with the comments likely to be submitted by other organizations and trade groups that additional consideration should be given, and additional information is needed with respect, to these suggestions and that working groups or other forums bringing together subject matter experts would be beneficial to develop comprehensive proposals that fully account for all stakeholders and constituencies.  

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

Please see the response to Question 3. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

BayWa r.e. is opposed to this proposal.  While the aim of this proposed requirement is admirable—to ensure that projects are sufficiently advanced to merit utilizing CAISO’s limited time and resources—from a practical perspective load serving entities will not contract for PPAs prior to developers having line of site to, or executed, interconnection agreements and confirmed deliverability.  And, in the event that load serving entities ultimately do agree to contract in advance, this puts extreme risk on developers and will have the unintended consequence of chilling the development and deployment of renewable resources in CAISO territory.  To the extent additional requirements are necessary, BayWa r.e. proposes focusing these on permitting and site control efforts, which can practically be achieved ahead of interconnection and deliverability confirmation.  

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

No comments at this time, though BayWa r.e. would note that this proposal merits further stakeholder consideration in the event CAISO decides to move forward with studying it further. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

No comments at this time, though BayWa r.e. would note that this proposal merits further stakeholder consideration in the event CAISO decides to move forward with studying it further. 

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Introduction

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the Interconnection Process Enhancements (IPE) 2023 Issue Paper and Straw Proposal. This important initiative reflects the fact that while the entire industry is moving as quickly as possible to get new clean resources online, policies and processes in place need to evolve to accommodate the unprecedented pace of procurement that will continue as the state progresses toward Senate Bill (SB) 100 goals. A successful IPE is key to reaching the objectives outlined in the memorandum of understanding between the California Independent System Operator (CAISO), California Public Utilities Commission (CPUC), and California Energy Commission (CEC), especially the aim “…to enhance coordination of resource planning and transmission planning to achieve state reliability and policy needs, and coordinate the timely development of resources, resource interconnections, and the needed transmission infrastructure.”[1]

Load-serving entities (LSEs) have procured new resources at record paces in the last several years and will continue to do so. The CPUC ordered procurement in years 2021-2028 through Decision (D.) 19-11-016, D.21-06-035, and D.23-02-040. These procurement orders total 18,800 megawatts (MW) of net qualifying capacity (NQC) or roughly 35 percent of the existing NQC on the system. This build-out far surpasses the pace of procurement at any other time in recent decades.[2] In fact, the build-out rate between 2022-2028 is two and a half times higher than the build rate following the post 2000-2001 energy crisis build-out from 2002-2008.

Just as LSEs are moving as quickly as possible to contract with new projects, the CAISO is moving as quickly as possible to get these projects through the queue. Getting projects through the queue in a timely manner is proving difficult after experiencing an unprecedented amount of requests in Cluster 14 and anticipating a similar volume in Cluster 15. While the number of requests in Cluster 14 has far surpassed the number of requests in any other cluster before it, we should not consider Cluster 14 unique. Instead, the volume of requests experienced in Cluster 14 should be considered indicative of what the CAISO will continue to experience in future clusters, because to meet California’s ambitious climate goals, the state will need to continue to develop new resources at a rapid pace for many years to come. Figure 1 shows the cumulative capacity additions necessary for the CEC’s SB 100 Core Scenario and 60 percent Renewable Portfolio Standard (RPS) reference scenario.[1] Under the SB 100 Core Scenario, the state will need to build roughly 175,000 MW between 2027 and 2045.

Figure 1

Figure 2 below shows the historical installed capacity since 2001[2] and future procurement that will be needed to meet the 175,000 MW from the SB 100 Core Scenario shown in Figure 1 above, assuming future procurement occurs in a straight line. From 2001 through 2021, the state has built new capacity at a rate of 1,308 MW per year. Under the SB 100 Core Scenario, the rate will need to increase to 7,292 MW per year from 2022 through 2045 (a 557 percent increase).

Figure 2

CalCCA Response

The CAISO proposes to accept Cluster 15 interconnection requests during the normal April 2023 window and delay validation, scoping meetings, and studies for Cluster 15 until April 2024, to give the CAISO additional time to complete Cluster 14 phase II studies. Given challenges the CAISO anticipates in addressing the projected size of the queue and the workload associated with both Cluster 15 Phase I and Cluster 14 Phase II studies, CalCCA understands the CAISO’s need to adjust the schedule for processing and studying Cluster 15. This delay could, however, impact LSEs’ abilities to comply with CPUC procurement orders as those orders require projects to be interconnected and deliverable to count towards LSE procurement obligations. While the delay of Cluster 15 may be necessary to complete studies already underway and not double down on the queue backlog, track two of this initiative will be critical in enhancing the interconnection process such that it can handle these volumes in the future without the need for further delays.

[1]             2021 SB 100 Joint Agency Report, Charting a path to a 100% Clean Energy Future, 19-SB-100 (Mar. 15, 2021, updated Sept. 03, 2021), at 10: https://www.energy.ca.gov/publications/2021/2021-sb-100-joint-agency-report-achieving-100-percent-clean-electricity.  

[2]             https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/electric-generation-capacity-and-energy.

[1]             Memorandum of Understanding between the California Public Utilities Commission and the California Energy Commission and the California Independent System Operator regarding Transmission and Resource Planning and Implementation at: http://www.caiso.com/Documents/ISO-CEC-and-CPUC-Memorandum-of-Understanding-Dec-2022.pdf (emphasis added).

[2]             https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/electric-generation-capacity-and-energy.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

CalCCA Response

The CAISO is considering conducting a separate study timeline for offshore and out-of-state wind study requests given state policies and CPUC planning activities that have identified a need for both resource types. Additionally, the CAISO indicates the Cluster 15 study delay may inhibit the development of these resources given that they face unique challenges in obtaining timely power purchase agreements (PPAs) (e.g., procurement responsibilities spread over many LSEs, massive supply chain and construction infrastructure needs). CalCCA generally supports a separate study process for offshore and out-of-state wind, as long as this process does not compromise the ongoing Cluster 14 study timeline or the proposed modified Cluster 15 study timeline that the CAISO would use for other projects. This special process should not negatively impact LSEs’ abilities to comply with CPUC procurement orders, particularly considering the CPUC has ordered LSEs to procure other types of long-lead-time resources as defined in D.21-06-035, including long-duration storage and clean firm resources.[1]

[1]             D.21-06-035, Decision Requiring Procurement to Address Mid-Term Reliability (2023-2026), R.20-05-003 (June 24, 2021), at 35-36: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M389/K603/389603637.PDF.  

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

CalCCA Response

The CAISO proposes to accept or process only interconnection requests where the transmission system has available or existing planned capacity. CalCCA supports the CAISO taking more proactive steps to inform stakeholders to locate projects where there is existing or planned transmission capacity. The CAISO’s proposal could improve the interconnection process by focusing project development on areas most ready for new resources and prioritizing the number of projects the CAISO studies to those that can interconnect with no or minimal additional transmission system upgrades.

For this proposal to successfully result in project development in preferred zones, the CAISO must publicize upfront where the zones are that have available existing or planned transmission, how the CAISO will prioritize each zone, and how much existing or planned transmission exists in those zones. This transparency is necessary to guide LSE procurement decisions and developer siting decisions.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

CalCCA Response

The CAISO proposes to further limit the number of interconnection requests that the CAISO studies in each zone based upon screening criteria the CAISO would use to filter down the number of requests it studies. CalCCA requires additional details on the criteria the CAISO would use in order to develop a position on this proposal. When developing the criteria, the CAISO should avoid criteria that could be used to pick winners and losers based upon specific resource technologies or operational capabilities instead of allowing the market to decide the most effective resources to meet state policy goals and reliability needs.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

CalCCA Response

As the CAISO correctly notes, whether or not to move forward on this element will depend on input from procurement experts. CalCCA requires additional time to consult with community choice aggregator procurement experts before providing a recommendation on this element.  

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

CalCCA Response

CalCCA does not support this element of the proposal. As described in Section 1, large study clusters should be considered the new normal. Only opening a new study request window “when warranted” could inhibit viable projects that can provide the grid with reliability and/or green-house gas-free benefits from getting studied and interconnecting to the CAISO system. Rather than retreating away from the annual cluster study process, the CAISO should instead focus on other proposed elements targeted at improving the efficiency of the cluster study process, incentivizing developers to streamline the number of requests they submit, and prioritizing the most viable projects to advance them through the queue more quickly.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

CalCCA Response

In addition to these enhancements, the CAISO should pursue adding new personnel to study interconnection requests or investing in automation or efficiency gains to accelerate the study process where possible. It would be worth exploring increases to the Grid Management Charge to accommodate these additions if it results in new resources coming online faster.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

CalCCA Response

CalCCA has no additional comments at this time.  

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

CESA appreciates the opportunity to submit comments on the 2023 Interconnection Process Enhancements (IPE) Issue Paper and Straw Proposal. With the large volume of projects remaining and proceeding to Phase II studies among the Queue Cluster (QC) 14 applications and the additional large volume of QC 15 applications expected in the April application submission window, CESA understands the difficult decision that the California Independent System Operator (CAISO or ISO) had to make regarding QC 15 applications. With the market notice on March 15, 2023, the ISO has made the decision to not delay the QC 15 window schedule and proceed with accepting QC 15 interconnection requests (IRs) as originally scheduled, yet not move forward with any further QC 15 application validation and Phase I study initiation.

Given the circumstances, the prioritization and focus on completing QC 14 Phase II studies is appropriate since those projects are likely aiming to provide capacity to meet identified mid-term reliability (MTR) and summer emergency reliability needs. As a result of the less-than-usual attrition rate of projects among QC 14 projects moving to Phase II studies, the ISO system will likely have sufficient capacity among the prospective projects for the near future, so CESA generally agrees that it is reasonable to complete the study processes of projects at hand rather than add to the problem and slow down the process for all. Especially given the limited transmission plan deliverability (TPD) available on the ISO system at this time, aiming to not further extend/delay the schedule for QC 14 Phase II study completion should be the priority goal.

However, CESA expects that the developer community will be divided on the ISO’s decision to proceed with accepting QC 15 interconnection requests during the normal April 3 through April 17 open window. On the one hand, CESA believes that it is important to have regularly-occurring cluster windows since interconnection customers (ICs) have invested significant time and resources into preparing interconnection applications (e.g., conducting due diligence, acquiring site control), which poses opportunity costs to developers who focused on developing projects in California with the expectation that the QC 15 window opening as originally scheduled. While accepting applications without advancing the QC 15 study process for a year or more would lock up study deposits and capital for a longer period of time than expected, many developers likely expected to do so to some degree given the recent track record of delayed and protracted cluster studies, not only in California but in many other ISOs/RTOs. Considering the CAISO has already signaled to the market the near-term expectation of superclusters and delays, absolute delay of the QC 15 acceptance window could create the unintended impact of even further pent-up demand and IRs, with the next window (QC 16) likely not expected to open for an even longer period of time, creating a “get in now or never get in for a long time” environment.

On the other hand, the same uncertainty and opportunity cost consideration factors into many developers (particularly smaller developers with more limited capital) holding the view that the CAISO should delay the normal QC 15 application acceptance window altogether, perhaps on the order of a few months (e.g., Summer 2023). Rather than having the CAISO sit on study deposits and capital that could be deployed elsewhere, an outright delay could also allow the Track 2 process to play out and provide greater certainty to developers on whether to enter QC 15, at what strategic locations, and with what configurations (e.g., fuel type). Especially if further guidance on locations or areas with TPD availability or priority zones are identified as part of the Track 2 process, the current range of QC 15 IRs may be inefficiently sited or designed. To this end, there may be some merit to delaying the QC 15 application submission window by a few months to afford some time to have line of sight into the Track 2 proposals and the details therein. If a delay on the submission window is not on the table, then CESA recommends several modifications and clarifications in the near term for adoption as Track 1 proposals.

Importantly, the CAISO should establish a window for QC 15 application withdrawals and study deposit refunds once the Track 2 stakeholder process and schedule is adopted. Depending on the nature of the Track 2 proposals, or even whether any of the major Track 2 reforms are adopted, the CAISO could be providing materially new information that was not available to the QC 15 ICs, leading to immediately known infeasibility or inefficiency of certain IRs and thereby only serving to waste time and resources for ICs, the CAISO, and participating transmission owners (PTOs) alike in the study process. With minimal time and resources taken to accept IRs in the April 3 through April 17 QC 15 window and the deferral of any scoping meetings, it should present minor administrative burden to process withdrawals and refunds in this proposed withdrawal window. For similar reasons (i.e., new information, preferences, criteria), this window should not only allow for withdrawals and refunds but also should affirm and clarify existing rules for modifications to existing QC 15 IRs that have already been accepted. In allowing for modifications, the CAISO should clarify the range of eligible modifications, such as fuel type (e.g., retrofitting storage) and certain types of point of interconnection (POI) changes (i.e., allow changes to POI within a substation but not allow a change in “areas”).

As such, a withdrawal/modification window should be established if major Track 2 proposals are adopted, potentially with a schedule known in advance (e.g., within 6 months of ISO Board approval of Track 2 proposals, or with a pre-determined window, such as February 2024).

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

The CAISO suggests that a separate study track could be established for offshore wind, out-of-state (OOS) wind, or other long lead-time (LLT) resources since it does not want to “negatively affect federal and state processes for specific resource development.” CESA is concerned with this suggestion since any technology-specific special treatment in the cluster study and generator deliverability process would be discriminatory in violation of Federal Energy Regulatory Commission (FERC) principles. With near- and mid-term reliability challenges, where many “routine” resources such as solar and storage are critically needed more urgently, CESA believes that pulling already-strained resources to these LLT projects would be inadvisable. Furthermore, such considerations need to be coordinated with the proposals raised in the CAISO’s Transmission Plan Enhancements (TPE) Initiative, which raised similar questions around retaining policy-driven transmission capacity for LLT resources but has yet to have issued a Final Proposal addressing the matter. Along these lines, the CAISO must also address the outdated nature of the IRP portfolios submitted to the Transmission Planning Process (TPP), where many of the same areas where, for example, offshore wind is mapped would also be where significant storage and other non-wind resources are seeking to interconnect. By putting offshore wind resources on a separate track, the CAISO would be favoring and allowing such projects to jump the queue over other non-wind resources that would otherwise be entering the queue at the same time. CESA addresses the potential issues created by misalignment of the generator interconnection queue with the IRP portfolios in subsequent sections.

At the same time, CESA believes that it is still worthwhile to have these discussions in the 2023 IPE Initiative. It would be premature to be adopted in Track 1, especially in the absence of a more specific proposal and how it would align with the TPE proposals and IRP portfolios, but it could be subject to further discussion in Track 2. In other words, a separate study track for LLT resources should not be adopted at this time in Track 1. As the CAISO tees up this issue for Track 2 of this initiative, CESA also urges the CAISO to broaden the consideration of LLT resources to not just offshore and OOS wind resources but also to long-duration energy storage (LDES) resources. Several LDES projects could also fall in this category of consideration, and LDES technologies should also be included in any discussion of LLT proposals in order to maintain technology neutrality and without violating broader non-discriminatory principles.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

CESA has many questions on the proposal at this time to only accept or process IRs in these “priority zones” (Element 1) where TPD is currently available or planned for several reasons.

First and foremost, CESA does not believe that such a proposal would pass open access rules where IRs can just simply not be accepted and processed. ICs should still be able to request study at any particular location, and denial of this pass would likely not be accepted by FERC. The only way such a proposal could be workable and consistent with open-access rules would be to establish a slower or generic process for IRs where they fall out of these priority zones, but any further consideration of such a structure would be more thoroughly and carefully developed in Track 2.

Yet, instead of this priority zone proposal, the CAISO should continue its efforts to improve data transparency to provide more dynamic and updated information on planned and available TPD, which is still lacking and is therefore contributing to the large volume of IRs. Whereas the 2021 IPE proposals established making competitor information publicly available, such as those around TPD allocations by project or queue status and milestone data of different projects, the information available to developers is still incomplete without improved information on planned and available TPD heading into cluster submission windows. Transmission capability estimates are made available by the CAISO but they are higher level and static snapshots of this information.

Second, CESA has concerns with establishing these priority zones when there is a significant mismatch in the timing of interconnection data used in the Integrated Resource Plan (IRP) portfolio busbar mapping process, which are then used in the TPP to study and approve policy-driven transmission upgrades. With the California Public Utilities Commission (CPUC) staff methodology prioritizing Phase II studies over Phase I projects in mapping storage projects along the commercial interest criteria, CESA has major questions as to how the establishment of priority zones would potentially forestall the acceptance and proceeding of the cluster study process where developers have shown commercial interest, informed by not only by potential TPD availability but also by strategic cost-effective project development (e.g., land costs, nodal/congestion pricing). See, for example, below the major shift in project development location for standalone energy storage, by county and by QC window. This information is based on the active CAISO queue as of March 2023 for standalone energy storage IRs.

As illustrated above, standalone energy storage project development locations have shifted in QC 14, where the use of or greater weight to QC 14 data would highlight the need for planned transmission capacity in different locations (i.e., Northern California). By only establishing priority zones where existing or planned TPD is available based on outdated data (i.e., QC 13 Phase II data) or with a prioritization on this older data (see Page 21 of Methodology for Resource-to-Busbar Mapping & Assumptions for The Annual TPP), it could create unreasonable barriers to project deployment where commercial interest has been clearly indicated. After all, the busbar mapping methodology continues to prioritize the commercial interest criteria for a reason, even though the CPUC expressed intent language to balance the various criteria in future methodology updates in the most recent CPUC Decision, D.23-02-040 (see Page 66 and Conclusion of Law 21). By only accepting and advancing IRs in the priority zones that work counter to the commercial interests based on the most up-to-date queue data, the CAISO would undercut the very intent of the busbar mapping methodology. Significantly, this raises the issue of addressing the timing of the IRP busbar mapping, which must be aligned to the most up-to-date queue data when adopted and transmitted to the CAISO for its TPP study process and be aligned to inform developers prior to cluster launch.

Third, the CAISO must be cognizant of the unintended impact of identifying these priority zones, which could only create a “gold rush” to these locations, raising land and development costs for all pursuing projects in these zones. Like with any proposal that increases the cost of entry to the queue, those higher costs translate to higher PPA prices, which are borne by ratepayers. Any Track 2 proposal, not just this one, should aim to mitigate such risks in appropriate and reasonable ways.

Fourth, in developing the Element 1 proposal, the CAISO should better define “available transmission” and how availability is determined (e.g., do earlier queued projects that have not achieved COD get included in studies to determine available transmission?).

In summary, the above concerns must be addressed with modifications to the proposal and the alignment of cross-agency processes. These topics should be discussed in the Track 2 proposal development and stakeholder meeting process.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

While similar to the Element 1 proposal in aiming to limit or focus the cluster study process to areas where transmission capacity is planned, CESA interprets the Element 2 proposal as an effort to further limit the queue cluster via auctions or screening criteria. Overall, CESA has many questions on the Element 2 proposal and the various “sub-elements” or related variants.

First, the use of auctions has some potential to efficiently identify projects to study, but this is a pretty big reform that requires much more discussion. Since such approaches are not used for queue management in other regions to our knowledge, the literature on auctions should be examined and discussed further, perhaps with experts and academics presenting potential proposals on how they could be applied to interconnection queues. In theory, CESA sees an auction as a potential means to allocate limited existing or planned TPD in ways that would align economic incentives to pursue interconnection studies and to not just hold TPD allocations but also to sell them. However, auctions would represent significant reforms that warrant deeper examination in Track 2 and may need to await a FERC Final Rule in RM22-14, which did not contemplate an auction-type structure. It may also need to be developed with an eye toward not necessarily just favoring the most well-resourced developers, putting smaller or less-capitalized developers at a disadvantage regardless of the quality of the project(s).

Second, the screening criteria approach could present some near-term solutions and incremental fixes, though it should not be coupled with limiting the IRs to these priority zones. Regardless of whether an IR falls within a priority zone, the CAISO could consider certain reasonable commercial readiness criteria to manage the queue, such as CEQA permitting approved or in process – all steps that reasonably fall within the bounds of prioritizing more commercially viable projects without establishing commercial viability criteria that are not aligned with the realities of project development milestones and timelines (e.g., PPA or shortlisting prior to Phase I or Phase II studies, battery purchase and procurement prior to Phase II).

Third, CESA views the use of generic studies as having some potential. It is unclear what form this would take and how helpful it could be to inform project development and procurement decisions, but the CAISO should keep this approach on the table and work with stakeholders with proposal development and refinement.

Finally, and importantly, CESA sees the potential of the use of either auctions, screening criteria, or generic studies in concept, without necessarily mirroring the Element 1 proposal by only applying these approaches to limited priority zones.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

CESA opposes the use of a power purchase agreement (PPA) or shortlisting (Element 3) as a requirement to proceed to Phase II studies. This proposal, or some semblance of it, has been raised in the CAISO’s 2021 IPE Initiative and FERC’s Notice of Proposed Rulemaking (NOPR) in RM22-14. By as explained then and reiterated here, these requirements represent an impossible standard in California since LSEs are unlikely or would never execute a binding term sheet or PPA, or possibly even shortlist, for a project with just Phase I study results and within the short window before interconnection financial security (IFS) deposits must be made prior to entering into the Phase II study process. Recognizing that Phase I study results are still indicative and not final, CESA sees a very low likelihood of LSEs shortlisting or contracting for projects without more definitive information on TPD availability and/or upgrade costs. Finally, the CAISO should not bias against the merchant generator development path, which could support projects coming online yet would be precluded from further study through this PPA or shortlisting requirement.

Should CAISO decide to proceed with prioritizing projects that have offtake agreements, CAISO should also prioritize projects that possess offtake agreements, either through a broker or directly established with a counterparty. Doing so will have similar effects on increasing the viability of projects requesting interconnection without discriminating against the nature of the offtake.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

CESA opposes the Element 4 proposal to establish ad hoc cluster window openings when warranted given the importance of regularly-occurring clusters. As discussed above, developers have opportunity costs (i.e., project development activities related to site control, due diligence, technology acquisition, assessment of transmission capability estimates, etc.) on whether to focus on CAISO versus other markets, which cannot be planned for without line of sight into when windows will open. While CESA sees the importance of regular annual cluster windows, we would be amenable to regular two-year windows if the CAISO can adhere to those timelines and not make ad hoc decisions on cluster study timelines. Firm certainty of window openings and study timelines may be more important to developers in weighing opportunity costs and planning sites and projects rather than having arbitrary, open-ended, and ad hoc shifts/changes in cluster window openings and interconnection study timelines.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

CESA recommends that the CAISO also consider modifications to the TPD allocation priority groups and process. Even though they were recently modified as part of the 2021 IPE Initiative, there may be yet more incremental changes that could support the goals identified at the start of Section 3 of the Issue Paper and Straw Proposal.

First, CESA recommends that the CAISO consider the development of a “conditional TPD” product that would help facilitate the type of PPA and shortlisting that would advance certain projects forward that address LSE procurement requirements. Notwithstanding the questions and potential modifications on the generator deliverability methodology, which is being teed up in a separate stakeholder initiative, a conditional TPD allocation would facilitate LSE contracting and would ensure that many developers do not abandon project development due the lack of TPD allocation. With conditional TPD in excess of actual TPD, this new category of projects would merely serve to facilitate transactions, and the actual TPD allocations would still adhere to what is physically available on the grid based on power flow studies. The conditional TPD allocation will be conditioned on the project entering into a PPA within a reasonable period of time, perhaps even after a Phase I study (Element 3 proposal) and accounting for LSE procurement schedules and durations. If projects fail to enter into a PPA after the allowed time period, then the conditional TPD allocation would be lost.

Second, CESA also recommends that the CAISO signal a potential pathway for projects to demonstrate commercial viability by actually pursuing and achieving commercial operations, even in the absence of a PPA or shortlisting. Other than a PPA, it should be self-evident that the ultimate sign of viability would be to have the project actually come online. Some developers have expressed an appetite to pursue such a project development path if there was a clearer line of sight to TPD allocations. One way such projects could be better signaled to pursue this path would be to consolidate Allocation Group B (PPA shortlisting) with Allocation Group C (commercial operations) into one allocation group, placing both on the same level playing field. Related to this, as indicated in our reply to question 4, CAISO could also increase commercial viability by requiring interconnection customers to demonstrate they have incurred material project costs to proceed past a certain point of the study process. Doing so will have the effect of raising the effective cost of interconnection requests, similar to auctions or other mechanisms, without imposing significant and unpredictable costs on interconnection customers.

Third, CESA stresses the importance of advancing the separate initiative focused on generator deliverability methodology revisions, which could play an important role in leveraging the existing TPD available in ways that ensure a safe and reliable system grid but also recognizes the unique characteristics of energy storage resources (e.g., energy limited), along with their interplay with the rest of the grid mix (e.g., complementary nature with solar and other renewables). While not the focus of the 2023 IPE Initiative, it is important to move that other process forward, which has not seen any next steps since the issuance of the Update Paper in December 2022.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

Beyond our comments to specific proposals in the IPE Issue Paper and Straw Proposal, CESA generally sees potential in some of the Track 2 proposal concepts but finds it hard to comment in detail on them until further fleshed out. Given the nature of the potential reforms, CESA recommends that Track 2 involve regular working groups and/or workshops to further develop details, have subject matter experts (SMEs) speak to alternative mechanisms, and offer parties a platform to present proposals. The use of such regular meetings and discussions is the only means by which the CAISO can expeditiously address the “supercluster” issue. Despite the large undertaking of developing and implementing such substantial reforms, CESA points to the Extended Day-Ahead Market (EDAM) Initiative as an example where the CAISO was able to achieve daunting and significant objectives within one year using frequent and regular working groups. Similar processes should be used in Track 2 of the 2023 IPE Initiative.

As the CAISO embarks on the Track 2 process, the CAISO must consider the question of applicability. Depending on the nature of the Track 2 proposals, CESA believes that a strong and reasonable case could be made that the reforms may need to apply to projects starting with QC 16 applications. For example, if the CAISO proceeds with establishing priority zones or screening criteria to QC 15 IRs despite applicants being unaware of them, it could be discriminatory and retroactive. It takes time to re-scope accepted IRs and/or to submit new IRs (in the case where new entry is allowed). In other words, it should not be a foregone conclusion that Track 2 reforms will apply to QC 15 projects, which would be placed on hold in accordance with the CAISO’s current Track 1 proposal. Since allowing new entry into QC 15 projects would not be equitable to existing QC 15 projects with capital held up despite new reforms and/or additional information provided in Track 2, CESA believes that applying the Track 2 reforms to QC 16 would be a clean and more elegant solution to these complex questions. Furthermore, CESA raises this question because QC 15 will be the first full cluster process where the 2021 IPE proposals will apply, and pushing the applicability of Track 2 reforms to QC 16 applications could better align with the pending issuance of a FERC Final Rule, which will tell CAISO what to do. On the latter point, the exact timing of a Final Rule is unknown, but FERC seems to be prioritizing the Generator Interconnection NOPR (RM22-14) over the Transmission NOPR (RM21-17). In light of the FERC rulemaking, as well as legislation on the table to transition CAISO into a regional transmission operator, there is a real risk that the Track 2 reforms are premature and could be for naught.

In addition to these process recommendations and applicability considerations, CESA also urges the CAISO to clarify and refine the key goals in developing the Track 2 proposals. Some of this was elaborated in Section 3 of the Issue Paper and Straw Proposal, which was interpreted as the CAISO setting a goal to reduce the number of applications, but CESA believes that these outlined principles warrant modification. In our view, the goal should not be to reduce the number of applications.

Rather, CESA believes that the focus should be on ensuring high-quality and viable applications, regardless of the number, as well as solutions to more quickly and efficiently process a high number of applications. To meet the state’s and nation’s decarbonization targets and reliability requirements, we must align on the fact that we are in a new world where there will be a large volume of new projects and infrastructure buildout, versus an old world where interconnection queues could only handle a handful of traditional generators. To this end, Track 2 should also continue the conversation on efforts to improve data transparency further and to consider approaches to streamline and expedite the processing of high volumes of IRs. In the short term, the CAISO could look to best practices of other ISOs/RTOs on how they are processing high volume of applications (e.g., automated IR validation, pre-study or feasibility study prior to Phase I, leveraging outside consultants and engineers such as those from the project developer to complete certain study steps).

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) is the state-appointed independent consumer advocate at the California Public Utilities Commission (CPUC).  Our goal is to ensure that all Californians have affordable, safe, and reliable utility services while advancing the state’s environmental goals. Our advocacy efforts to protect California customers span the areas of energy, water, and communications regulation.[1]

Cal Advocates commends the California Independent System Operator (CAISO) for launching its 2023 Interconnection Process Enhancements initiative and focusing on making significant and transformative improvements in the generation interconnection process.  The CAISO’s ongoing commitment to improve its process is critical given the urgency of the climate crisis and California’s efforts to both maintain reliability and transition its energy sector to zero-carbon resources. It’s critical to carefully monitor generation interconnection activities, analyze resource interconnection bottlenecks, and identify improvements in interconnection process workflow.

With 187,886 MWs currently in the CAISO Interconnection Queue, 205 applications remaining in the Cluster 14 Phase II process, and approximately 300 new applications expected to be received in the Cluster 15 application window, Cal Advocates agrees with CAISO that it is critical to make transformative improvements to the CAISO interconnection process.[2] 

Much of the proposed capacity in the queue is speculative and might not be built.  Lawrence Berkeley National Lab found that only 13% of the projects that have entered the CAISO queue from 2000-2016 have reached commercial operation.[3]  There should be approaches to distinguishing between “real” and “speculative” projects.  Cal Advocates also agrees with Gridwell that we cannot squander scarce time and human resources studying unviable interconnection requests.[4] 

There are many drivers to the problem with unviable interconnection requests clogging the CAISO interconnection queue, including [5]:

• Increased resource planning procurement authorization.
• Low threshold for entry; it costs the same amount to request interconnection for 30 megawatts (MW) as it does for 1000 MW.
• Projects have limited financial motivation to drop out of the process.
• Limited Information available to developers on regional curtailments, known transmission constraints, and known deliverability availability.

CAISO correctly points out that its previous refinements to the interconnection process have not sufficiently reduced the number or capacity of interconnection requests to a manageable or meaningful level.  CAISO also admits that the current strategy of introducing various incremental enhancements to the interconnection process, but excluding structural changes that would disrupt the current interconnection queue process and prioritization,  are not sufficient to address the logjam.[6]  As such, for the 2023 Interconnection Process Enhancements (IPE), CAISO should strive to design an interconnection process that:

• Adopts a First Ready, First Serve queue prioritization.
• Significantly raises the financial threshold for entry into the queue.
• Disincentivizes developers from hedging their risk with superfluous interconnection requests that are destined to fail.
• Provides the financial motivation for unviable projects to drop out of the process as early as possible.
• Provides sufficient data for developers to evaluate potential project interconnection sites
• Adopts interconnection reform best practices of other regional transmission organizations (RTOs).

CAISO also recognizes the shortcomings with the previous strategy in the 2021 IPE to limit the scope of process changes in order to avoid getting too far ahead of the FERC Notice of Proposed Rulemaking (NOPR) on Improvements to Generator Interconnection Procedures and Agreements that was published on June 16, 2022.[7]  To date, FERC has not published an order from this rulemaking.  The issues surrounding the interconnection process are too urgent to continue to wait for federal guidance, and FERC orders are likely to be “lowest common denominator” reforms palatable to the entire country and not suitable for CAISO.

Other RTOs, like PJM RTO,  are taking immediate action to make transformation changes.  PJM was able to successfully reform its generation interconnection process with the submission and approval by FERC (FERC docket ER22-2110-000 and -001 on PJM Interconnection Process Reform).  The FERC Order acknowledges that “the filing constitutes a comprehensive reform of the PJM interconnection process designed to more efficiently and timely process New Service Requests by transitioning from a serial first-come, first-served queue process to a first-ready, first-served clustered cycle approach.”[8]  CAISO should follow PJM’s lead and in the 2023 IPE adopt the PJM interconnection best practices that have already been approved by FERC.

Cal Advocates recommends that the CAISO adopt similar reforms first using PJM Interconnection Reforms as Best Practices since these are tried and true methods that FERC has already approved for PJM.  These issues include:

1. Interconnection Request (IR) Queue Priority Reform (First-Ready, First-Serve
2. Reduction of Excessive Interconnection Request Submissions.
3. Elimination of Unviable IRs that Clog the Interconnection Queue.

a.  Reform IR Queue Process Priority (First-Ready, First-Serve)

Cal Advocates recommends that the CAISO adopt, as PJM has, a First-Ready, First-Serve plus Cluster approach.  Currently, all CAISO interconnection requests are lumped into a massive cluster (e.g., Cluster 14 with 205 Interconnection Requests (IRs)) that will take nearly three years for an interconnection customer to get a signed Generation Interconnection Agreement.  As the CAISO points out, Cluster 15 submissions are projected to be around the same scale as Cluster 14 (~300 IRs).  CAISO should adopt a first-ready, first-serve interconnection queue priority approach, which would assign the interconnection customer an interconnection queue position according to when the interconnection customer executes a Phase I study, rather than when the interconnection customer entered queue.  Interconnection customers should also be given the option to expedite an IR Agreement following a Phase 1 or Phase 2 study, if no or minimal local upgrades or minimal local system network upgrades are required.

2. Reduce the Number of Excessive Interconnection Request Submissions

The CAISO continues to express its concern regarding the increased number of current submissions in Cluster 14 and the potential number of submissions in Cluster 15.  As the Gridwell study identified, one reason for the excessive number of IRs is due to the low cost for entering the CAISO queue. Cal Advocates recommends addressing this issue by implementing the PJM increased study deposits which were approved by FERC.  Specifically:

Increased Study Deposits

1. $75k:     20 MW
2. $200k:   20 MW to < 50 MW
3. $250k:   50 MW to < 100 MW
4. $300k: 100 MW to < 250 MW
5. $350k: 250 MW to 750 MW
6. $400k: > 750MW

c. Elimination of Unviable IRs that Clog the Interconnection Queue

The CAISO has numerous IRs that are clogging the interconnection queue.  Cal Advocates recommends the CAISO to regularly reassess IRs for viability using the same methods adopted by PJM and approved by FERC.  Specifically, IRs that are 6 months late for posting deposits and completing an IR agreement should be removed from the IR queue.

[1] Public Utilities Code Section 309.5.

[2] CAISO 2023 Interconnection Process Enhancements, Issue Paper and Straw Proposal, Mar 6, 2023 (2023 IPE) CAISO InitiativeDocuments/Issue-Paper-and-Straw-Proposal-Interconnecton-Process-Enhancements-2023-Mar132023.pdf

[3] “Queued Up: Characteristics of Power Plants Seeking Transmission Interconnection as of the End of 2021”, Lawrence Berkeley National Laboratory, April 2022, page 11. PowerPoint Presentation (lbl.gov)

[4] 2021 Interconnection Process Enhancements – Gridwell Consulting Proposed Issues Presentation, Gridwell Consulting, October 19, 2021, slide 5. PowerPoint Presentation

[5] id., slide 11.

[6] 2023 IPE, p.7.

[7] https://www.ferc.gov/media/rm22-14-000

[8] Federal Energy Regulatory Commission ORDER ACCEPTING TARIFF REVISIONS SUBJECT TO CONDITION, PJM Interconnection, L.L.C. Docket Nos. ER22-2110-000, ER22-2110-001, November 29, 2022.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Cal Advocates recommends that the Cluster 15 application window (April 3 – 17, 2023) should not be delayed.  Cal Advocates agrees with CAISO that it would be disruptive to industry to prohibit interconnection requests already developed for this April. Developers have spent significant time and money in developing projects for Cluster 15.

The process that the CAISO describes in its 2023 IPE Section 2 is a very serial process where Cluster 14 Phase 2 interconnection studies are scheduled to be completed in February 2024 and then the Cluster 15 applications review begins April 2024 (a year after the applications come in).  CAISO and the Participating Transmission Owners (PTOs) need to find ways to process the clusters in parallel or process the applications in a First-Ready, First-Serve priority.  Without making any significant reforms to the interconnection process, CAISO and the PTOs will continue to fall behind and delay interconnection of critical resources necessary to both maintain reliability and transition the State’s  energy sector to zero-carbon resources.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Cal Advocates supports reforms to provide greater transparency to the interconnection process, including identifying transmission system availability and capacity to inform both resource developers and load serving entities (LSEs).  The CAISO’s proposal to limit resource submissions is potentially unjust and discriminatory by restricting open access to market participants and reducing resource choices for LSEs. FERC Order 2003 requires that all generators should be treated on an equal basis to prohibit undue discrimination.  With open access rules, generation can propose to locate anywhere, whether an optimal location or not.  That said, CAISO can encourage smart resource siting by providing Transmission Capacity Availability maps, including stoplight coding (e.g., red, yellow, green) transmission lines to reflect the relative costs to interconnect at various locations on the transmission system.[1]

[1] Conceptual Transmission Capacity Availability maps coding:

red:  system level upgrades needed for connecting new generation resource to support full capability deliverability status (FCDS).

yellow:  minor local upgrades needed for connecting new generation resource up to the yellow capacity addition designation (e.g.  upgrades to local circuit breakers or increased transformer capacity).

green:  no local upgrades needed for connecting new generation resource up to the green capacity addition designation.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

Cal Advocates views the CAISO’s proposal to limit resource submissions to be potentially unjust and discriminatory by restricting access to market participants and reducing resource choices for LSEs.  See answer to Question 3 above.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Cal Advocates strongly supports the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase 2 studies.  This reform will focus the phase 2 study process on projects that are most viable and ready.  This will also help limit the required upgrades to what are truly needed and provide more precise construction timelines.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

CAISO proposes changing the frequency of how often the new IR window will be opened to new applications.  Previously, CAISO suspended new applications for two years.  Cal Advocates opposes future moratoriums on interconnection request applications as it only masks the extent of the problem and it’s also an ineffective way to prioritize interconnections and address California’s reliability and energy goals.  By allowing all eligible interconnection requests to be submitted without restrictions, CAISO and stakeholders can better understand the magnitude of demand for interconnection requests.  This will enable the development of a strategy to process and prioritize those requests and more efficiently achieve California’s transition to zero-carbon resources.

If CAISO intends to alter the process from taking applications on an annual basis, it should adopt the PJM interconnection reform (that was approved by FERC) which opens a new Interconnection Request window upon completion of the current Phase 2 cluster study (i.e., CAISO would open the next application window when the Cluster 14 Phase 2 study is complete (April 2024).

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

Cal Advocates has provided an Alternative Proposal in the summary section under Comment 1.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

Cal Advocates has provided an Alternative Proposal in the summary section under Comment 1.

In addition to the Alternative Proposal above, Cal Advocates recommends the following:

• Along with PTOs, assign additional staff to address the Interconnection Queue review process and execution of interconnection agreements;
• Develop a public dashboard of queue management performance metrics for decision makers and stakeholders;
• Require Transmission Owners to identify and implement improvements to facilitate approved generation interconnection construction and required network upgrades with high priority.  If Transmission Owners cannot complete interconnection request projects within 3 years, then the CAISO should take over project management and assemble external resources to have the project performed in a time critical manner;
• Qualify a list of third-party experts to perform study efforts;
• Require developers to perform their own self-study using a qualified third-party entity for local network upgrades;
• Provide Transmission Capacity Availability maps, including stoplight coding (e.g., red, yellow, green) transmission lines to reflect the relative costs to interconnect at various locations on the transmission system.

• CAISO continually reassess queue applications to ensure projects continue to progress towards commercial operation and meet commercial viability and PPA requirements and issue Breach/Default notices as necessary.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

CalWEA strongly opposes the proposal to delay by nearly a year the processing of Cluster 15 (C15) applications after their initial acceptance on April 17, 2023, at which point Cluster 14 (C14) phase II studies and results meetings are expected to be completed (April 1, 2024).  CalWEA strongly recommends that, instead, CAISO delay the C15 application deadline to shortly before the C14 process is expected to be completed (e.g., as late as March 2024).  Delaying the C15 deadline will better promote the CAISO’s objective of reducing its workload by enabling more thoughtful applications and discouraging speculative ones.  That additional time will allow developers to consider a great deal of important new information that will enable better-informed decisions on submitting their interconnection applications.  The additional information that is expected includes:

• C14 Phase 2 study results;
• The short-circuit duty information on existing substations that CAISO plans to provide to the industry by the end of March 2023; 
• CAISO’s 2022-23 transmission plan as adopted in May of 2023, as well as preliminary 2023-24 transmission planning information; 
• a potential ruling following FERC’s interconnection NOPR[1];
• CAISO’s rule changes for C15 (which will be more developed, if not final, by the end of 2023); and
• the CPUC’s 2023 Preferred System Plan (which may reflect significant resource portfolio and busbar mapping changes[2]).

While the Issue Paper notes that CAISO anticipates implementing tariff revisions that will allow C15 interconnection customers to “refresh” their interconnection request (IR) in the year-long interim period, and to allow applications to be withdrawn for minimal or no cost at any time until study work begins in Q2, 2024, CAISO provides no indication of the extent to which changes will be allowed, nor is FERC approval of such changes certain.  In any case, there is no good outcome to this plan:  If extensive changes are allowed, such as changes in the point of interconnection and project size or COD, speculation and gaming will be invited. But if only minimal changes are allowed, developers will not be able to adjust for the legitimate factors noted above. And, either way, substantial site exclusivity in-lieu and study deposits will be held for a year.

By contrast, there is no downside to delaying the application deadline to next year.  CAISO staff can still focus on Cluster 14 applications, and discussions of rule changes for Cluster 15 can be held in parallel.

We also note that reforms following the CAISO’s new initiative on deliverability challenges could help to address the concerns that are at the heart of this year’s IPE: relieving CAISO’s C14 workload and increasing the project pool for LSE procurement.  In CalWEA’s January 4, 2023, comments on the CAISO’s Update Paper on Generator Deliverability Challenges, CalWEA explained that adopting the deliverability reforms we propose will immediately reduce the CAISO’s workload by, for example, eliminating a study scenario and eliminating a highly unlikely study condition. As importantly, our proposed reforms would immediately increase the resources in the market by recognizing the existing grid’s ability to reliably support far more deliverability capacity than is recognized under the current methodology.

[1] FERC Notice of Proposed Rulemaking on Improvements to Generator Interconnection Procedures and Agreements, published on June 16, 2022.

[2] Note, for example, that the CPUC is updating the decade-old assumptions that its California land-based wind resource map is based upon.  CalWEA expects that the 2023 resource plan will identify significantly more commercial-grade wind energy resources than previously recognized. 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

The Issue Paper suggests that CAISO could explore whether offshore and out-of-state wind resources should be studied separately, given potential impacts from delaying the C15 schedule.  CalWEA does not believe that special studies and processes are needed or appropriate for these resources; however, their needs would be served by delaying the C15 application deadline.  Further, this, and especially the next, IRP-TPP cycle should advance the transmission needed to support the IRP portfolio, which will include these resources.

In the case of offshore wind, CAISO appropriately identified the numerous challenges faced by offshore wind development, including spreading offtake responsibility across a multiplicity of load-serving entities, developing major infrastructure, and fostering a new supply chain.  These challenges and related uncertainties will benefit from time; thus, it once again makes sense to delay the C15 deadline. CalWEA previously explained why it would be technically difficult, if not impossible, and legally questionable to attempt to reserve transmission capacity for offshore wind resources.[1] Reserving transmission capacity would not guarantee offshore wind development, but it would tie it up for everyone, throughout the system.[2]  The best (and perhaps only) way to approach transmission planning for offshore wind is for the CPUC (or the state as a whole) to coordinate the process for offtake and to foster the issuance of power purchase agreements as quickly as possible. This will allow developers to apply for, and secure, interconnection agreements in the normal course.

Similarly, in the case of out-of-state wind, CalWEA does not support any unique process.  Existing processes can accommodate out-of-state resources, including resources that are dependent on subscriber-based out-of-state lines into California.  Again, to the extent that there are challenges to be addressed, delaying the C15 submission deadline and issuance of offtake agreements will help. 

Both offshore and out-of-state resources that are supported by offtake agreements will benefit from deliverability methodology reforms and interconnection process reforms that advance the most commercially viable projects.

[1] See CalWEA’s October 14, 2022, comments on CAISO’s Transmission Planning Process Enhancements.  Available at https://stakeholdercenter.caiso.com/Comments/AllComments/fe469961-883e-4454-9adb-44eb6098b450#org-7ce3b7cc-d38a-4404-8f94-e9fa1619642a.

[2] We also wish to comment on the Issue Paper’s statement that while “some level” of transmission capacity exists for offshore wind off the Central Coast, it would focus on studying the transmission to support material amounts of offshore resources in the North Coast.  CalWEA urges CAISO not to assume that there will be sufficient transmission for a full build-out of the Morro Bay offshore wind resource area (particularly absent deliverability methodology reform).  CalWEA expects that sophisticated developers to submit applications in Clusters 14 and 15 in an attempt to secure any available transmission in this area, as well as any capacity that might become available in planning transmission for the North Coast, underscoring again the need for offtake agreements to be issued for these resource areas.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

CalWEA strongly opposes this proposed reform because it is antithetical to open-access, would constrain competition and, in any case, is simply unworkable.  Therefore, it is not a promising strategy for accomplishing the CAISO’s goals of reducing the size of the queue and increasing the market availability of viable projects.  Instead, we urge CAISO to pursue more practical strategies aimed at fostering more informed Phase 1 applications and impeding premature projects from entering Phase II studies, as we discuss in response to Question 7, below.

Limiting IRs to locations where the transmission system has available or planned capacity, as identified in ISO transmission plans, would prejudge the market and give market power to companies that happen to have tied up land around certain substations.  It also presumes that the CPUC-CEC process of identifying preferred locations for development (in the resource portfolios given to the CAISO to support its planning) proves out in reality.  As a recent presentation of draft CEC land-use screens made clear, “The geospatial land-use screens inform high-level estimates of technical renewable resource potential for electric system planning and should not be used, on their own, to guide siting of generation projects nor assess project-level impacts.”[1] The ability to develop projects in particular areas at assumed costs may or may not pan out at the site-specific level or even zonal level.

Moreover, “available capacity” is interactive at the bus (not zone) level.  So, while, say, 1,000 MW of capacity may appear to be available at a certain substation and 2,000 MW may appear to be available at another, development at one location can easily diminish the available capacity at the other.

Thus, it is not a simple thing to determine where the system has capacity.  Currently, the CAISO allocates available transmission capacity through the Transmission Plan Deliverability (TPD) study at the end of the study process, based on indicators of project viability (e.g., site control and power purchase agreements).  Developers will not have this information upfront, and it is not reasonable to expect them to. 

Instead, as we discuss below, the same result of guiding developments towards desirable areas on the grid (which cannot be known in advance) can be accomplished by providing developers with accurate grid information upfront, and adding a criterion for advancing to Phase 2 studies that screens for high transmission costs per megawatt.  This is the appropriate order:  allow developers to identify and market what they have determined (based on site-specific assessments and other considerations) to be promising development sites and seek access to the grid, rather than limiting development opportunities at the get-go in the absence of complete information.

[1] Energy Commission Docket 21-SIT-01, “Workshop Overview and Land Use in Electric System Planning” (March 13, 2023). (Emphasis in original.)

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

This proposal raises the same problems as the previous one.  If there are more IRs than capacity in a particular area, how is CAISO going to select which ones move forward?  The notion of auctioning capacity is antithetical to open-access.  Decisions about which projects succeed should be made by landowners, investors, local siting officials, and in the competitive procurement marketplace. They should not be made, as the Issue Paper suggests, by PTOs or “the resource procurement community,” by allowing the highest (and most deep-pocketed) bidders to corner the market, or via “generic” studies that may not be accurate for the project at hand (although such studies could be used to inform prospective applicants in pre-application meetings, as noted in response to Question 7).  Ultimately, arbitrarily limiting IRs in this and other ways could lead to inadequate reliability resources.

Instead, CAISO should adopt the type of processes and objective criteria that we discuss in response to Question 7, below. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Again, this proposal is not workable.  Buyers will need cost information from the Phase 2 studies to make final procurement decisions. Most PPAs have “out” clauses pending actual transmission costs;  if the cost estimate turns out to be too high, the buyer will cancel the PPA. But currently, other opportunities will arise for the buyer from projects that did not have a PPA but got lower transmission cost estimates.  CAISO should resist temptations to make such advance determinations itself, or through some imagined coordinated effort among buyers as suggested.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Notions of abandoning the annual open access window, or worse -- halting new interconnection requests entirely until the queue diminishes to some predefined level, are extreme and would be particularly harmful to resources and technologies other than those that now dominate the queue (i.e., solar photovoltaics and battery storage).  Resources that are less common now, such as land-based and offshore wind, may become more attractive to developers due to technology advancements, regulatory or market signals, or policy preferences.  To close regular open access opportunities would undermine the ability for the market to evolve to changing circumstances, particularly since three or four years are required to go through the interconnection process.  (Unfortunately, by raising this draconian prospect, CAISO has likely prompted many more submissions into the C15 window.)

Eliminating a predictable schedule for open access is particularly problematic for wind energy developers and other types of more site-constrained resources.  Commercial-grade wind energy resources are much more site-specific than commercial solar opportunities, and dramatically more limited than battery storage siting opportunities. Obtaining siting approval for batteries is also comparatively much less difficult than siting wind energy projects.  Therefore, solar and battery project developers are more able to submit interconnection requests based on more ubiquitous opportunities and run with those that pan out.  Wind projects, on the other hand, are very limited and developers have no such opportunities to “cast a wide net.” 

If CAISO moves forward with any notions of eliminating open access opportunities, it should take into account the need for resource and technology diversity.  Very few wind energy projects exist in the entire queue, and it will be very unfortunate if these diverse resources were eliminated from the market as a result of the site control requirements adopted last year, which result in forfeiting a $250,000 deposit 30 days after the initial meeting.  CAISO should also reconsider this requirement for wind and other diverse resources and require deposit forfeiture only after Phase 1 study results are available. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

Rather than seeking to limit applications in the Phase 1 study process, CAISO should focus on providing developers with useful pre-application information and thoughtfully raising the bar for Phase 2 applications.

CAISO should institute pre-application meetings to provide developers with meaningful upfront information about upgrade costs and timelines for specific locations on the grid.  To inform these meetings, CAISO could average results for projects that have been studied in previous or current studies. Such information will mitigate the current shotgun approach that many developers have been taking.  In addition, it would be useful for CAISO to advise prospective interconnection customers of the location and volume of existing and planned capacity identified in the CPUC’s IRP busbar mapping and transmission planning processes.

CAISO should also continue to focus on ways of raising the bar for Phase 2 applications to discourage, and even impede, projects in early stages of development and promote those that are more advanced, taking care not to discourage small projects and developers focusing on a limited number of projects. For C15, CAISO has made site exclusivity compulsory for projects to proceed into Phase 2, which will help. FERC may, in its interconnection NOPR, approve of higher deposit requirements (we continue to advocate a sliding scale based on the number of applications submitted by a single company, or group of affiliated companies). Commercial viability requirements could also be added to enter phase 2 (e.g., commercial interest showings such as a letter of intent or position on a short list) and/or projects could be required to pass a threshold below some expected transmission cost per megawatt.  Out-of-state resources on a subscription transmission line could be required to show that the line is fully subscribed to the CAISO boundary. CAISO could establish criteria to limit the time that projects can remain in the queue if they do not demonstrate that the project is advancing.

Such ideas should be fully explored and tested before leaping to solutions that seem likely to violate FERC’s open access policies.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

While CalWEA understands that the workload associated with the interconnection queue has become overwhelming and unsustainable for the CAISO, CAISO must take great care not to curtail open access and limit market competition.  Labeling those infringements as a “proactive approach” to transmission planning or “a more nimble queue” cannot obscure the reality that CAISO is proposing to limit open access.  As the Paper states, the proposals get ahead – far ahead – of FERC’s 2022 Interconnection NOPR.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Calpine understands the challenges of managing the anticipated workload identified by the CAISO from Cluster 14, phase 2 studies as compounded by the work necessary to process a new Cluster 15.  The unprecedented rollover of C14 phase 1 to phase 2 – even without a new cluster 15 – will create a significant risk to timely completion of final phase 2 studies for the 200+ projects representing ~94,000 MW in C14 that await PPA negotiations, approvals, contracting and construction.   

The projects in C14 are entirely sufficient to meet the requirements of near-term regulatory and municipal needs.  Processing those projects in a timely manner and with  minimal restudies or adjustments should be the CAISO’s priority.  As such, Calpine  preferred that the CAISO simply defer Cluster 15 for a year and focus on the Phase 2 reports, just as it did with the supercluster, Cluster 14. 

Nonetheless, the CAISO appears to be poised to open Cluster 15 in April and anticipates as many as 300 projects complete with study deposits, site control deposits and full interconnection details.  However, the CAISO proposes to suspend all work on Cluster 15 (other than the data sufficiency evaluation) for approximately a full year. Calpine calculates that this suspension could strand as much as $195,000,000 for a full year with no interest and no progress, only compounding the cost of new resources and adding unnecessary risk. (300 projects times $150k per request plus $500k for site exclusivity deposits or lease / ownership costs.) 

If the CAISO moves forward with this proposal Calpine asks that the CAISO consider the following:

• As is current policy, initially require study deposits and site exclusivity assurances to demonstrate financial viability while applications are deemed complete.  However, subsequently allow parties to temporarily withdraw a substantial portion of those deposits (perhaps up to 50 percent) during the suspension period while no interconnection study work is being performed.  Require a subsequent re-deposit when the scoping meetings are set and work begins sometime in 2024.  Failure to redeposit would result in withdrawal.
• Alternatively, confirm that all Cluster 15 deposits will be held in an interest-bearing account and distribute the proceeds from that account during the suspension to the interconnection customers in proportion to their deposits. 
• During the suspension period allow interconnection customers to demonstrate site control (via lease or ownership) and upon such, return any in-lieu-of $500k deposits.
• During the suspension period, Calpine supports the CAISO proposal to allow for a “refresh” of the request to allow for minor changes to the interconnection details and accommodate the changing nature of technology (inverters, etc.)  More detail should be established on what qualifies as a “refresh” versus an entirely new request.
• Given that the suspension is targeted to end in April 2024 and would compress work on a future cluster, Calpine suggests that the CAISO announce, now, that Cluster 16 is being deferred for at least a year and avoid the brinkmanship that this proposal has invoked.  

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Calpine believes that all interconnection requests face “unique challenges” and does not support the CAISO’s discriminatory and unduly preferential proposal to advance work on some technologies in exclusion to others. The proposal to suspend work on Cluster 15, which we agree is necessary, is entirely inconsistent with the proposal to work on the intellectually and electrically complex work associated with offshore and out-of-state wind.  Doing so would distract CAISO/PTO/Contractor resources, frustrate the diligent efforts of other I/C submissions and relegate many requests to a new basecase -- a Cluster 15B.  The CAISO’s near-term mission should be to complete Cluster 14 Phase 2.  It should not deviate from that mission.   

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Calpine is concerned that the proposal is not currently supported by the degree of transparency required for implementation.  It seems the proposal would require the CAISO to publicly identify “available or planned capacity” in specific terms -- substations, lines or interconnection points -- in advance of queue submissions.  Obviously, given the proposal to open the window to Cluster 15 requests in 2 weeks, that horse is already out of the barn – closing the door now serves no purpose. Implementing this proposal for Cluster 15 would frustrate the diligent and costly efforts of many to propose competitive projects to the CAISO and load serving entities.

Additionally, implementing this proposal is inappropriately substituting the judgement of the CAISO as to what constitutes a reasonable project for the contractual and appropriately binding judgement of the load-serving entities. And finally, this proposal to reject or exclude and not study non-conforming requests seems to violate the foundational principles of open access.   

With more forewarning (e.g., Cluster 16), more transparency and some flexibility, Calpine could support the creation of non-exclusive development zones as suggested in the proposal.  This has the potential of more closely tying transmission planning and interconnection processes.  The CAISO would have to strike certain balances on specificity, so as to not favor those with current land rights or create land-ownership market power.  Additionally, Calpine would favor a proposal that allows for the redevelopment of existing interconnections as “available capacity”. 

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

If specific interconnection zones are identified, Calpine sees no value in limiting the creativity and innovation of developers to fight against others to secure interconnection rights.  However, if the CAISO does seek to limit the number of interconnection requests in an area, Calpine could support a market-based rationing system like the auction mechanism proposed.  Alterntively, entities could secure rights through a payment of some kind, or an agreement to not seek reimbursement of network upgrade costs. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Calpine does not view this proposal as viable.  First, we do not believe a load-serving entity would be willing to accept the risk of paying the maximum cost of network upgrades established in a Phase 1 study.  Rather, it would seem prudent, as is historic practice, for a load-serving entity to know and be able to compare with some degree of finality and confidence, the costs demonstrated in a phase 2 study.

Additionally, requiring a PPA (of shortlist) to “enter Phase 2” would significantly challenge the timing of queue processing and security deposits.  Phase 1 reports, normally distributed in the late fall, would be the minimum required by a reasonable contracting counterparty.  PPA negotiations – from RFP to execution – could, if possible at all, only occur after the release of phase 1 reports and can take 6 months to a year (approximately the same for a short-list).  That would mean that phase 2 deposits would have to be delayed by about a year and phase 2 study work would not begin until one year after phase 1.  This would permanently result in at least a 3-year study process.  

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Calpine supports the existing tariff conditions which require the CAISO to open interconnection requests every year.  Calpine could support, as with Cluster 15, a pre-announced suspension of the queue window.  Such a suspension should only be based on the ability of the CAISO to process current and expected requests.  The suspension should not be based on the CAISO’s unilateral evaluation of the sufficiency of the queue.  Doing so might prohibit technology and secular changes in the generation fleet that otherwise would be beneficial.   

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

Calpine would support higher non-refundable security deposits, limiting the number of queue requests (e.g., no more than 7) by closely-affiliated companies and the imposition of a site control requirement as a condition of queue window submission (eliminating the $500,000 in-lieu-of payment).

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

The Center for Energy Efficiency and Renewable Technologies (CEERT) is supportive of the CAISO’s efforts to implement needed reforms to the Generator Interconnection and Deliverability Allocation Procedures (GIDAP) and to tighten linkages between the Transmission Planning Process and the interconnection process.  Improvements to the GIDAP are urgently needed to accelerate the pace that new clean energy resources can be developed to meet California’s SB 100 goals.

CEERT believes that the CAISO proposal for managing Cluster 15 interconnection requests is reasonable given the enormous backlog of work needed to complete the Phase II studies for Cluster 14. We are convinced it is essential that the Cluster 14 studies be completed on schedule and support the prioritization of this work.  

Therefore, while not desirable, it is understandable that the Cluster 15 study process would need to be paused until 2024.  It is also reasonable that the CAISO consider tariff revisions that would allow interconnection customers to modify their initial Cluster 15 interconnection requests and allow for withdrawal at no cost before the study work begins in 2024.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

CEERT is supportive of the development of offshore and out-of-state wind projects that can provide diversity at reasonable costs to the evolving resource portfolio that will be required to meet California’s SB 100 goals. To that end, CEERT supports a no regrets approach to transmission expansion and the development of additional transmission deliverability both within the CAISO footprint and in coordination with other California balancing area authorities.

CEERT understands that the 2023-2024 Transmission Planning Process (TPP) will study the need for transmission to support offshore wind development in the Central Coast and North Coast regions of the state. CEERT believes that a no regrets strategy for increasing transmission deliverability from the Central Coast to both the greater Bay Area and the Los Angeles region is essential.  One crucial decision that will need to be made in the near future is whether offshore wind would interconnect at the Diablo Canyon substation or at a new substation to be developed at Morro Bay. We understand that the appropriate venue for this decision is within the 2023-2024 and subsequent TPPs rather than through the GIDAP.

At this point there is not sufficient information provided in the proposed GIDAP reform process to determine whether or not prioritization of some interconnection requests in Cluster 15 should be done.  As noted above it is essential that the Cluster 14 Phase II studies be completed on schedule.  Therefore, any possible prioritization of Cluster 15 Phase I studies should not be considered by the CAISO until after it is clear that the Cluster 14 work can be completed on time.

CEERT supports the CAISO’s work to develop a “subscriber participating transmission owner” model to connect out-of-state wind resources to the CAISO. The CAISO needs to focus in the 2023-2024 TPP on no-regrets, in-state network transmission upgrades to enable out-of-state imports together with other planned generating capacity to be delivered to California loads.  We are supportive of creating additional headroom on in-state transmission to enable the import of out-of-state wind but are concerned about prioritizing the use of that capacity for selected Cluster 15 projects to the detriment of other Cluster 15 projects.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

CEERT is supportive of developing a zonal approach to more closely link the TPP with future interconnection requests.   This tighter linkage should be on a forward-going basis in order to not be discriminatory to existing interconnection customers.  It will be important in the 2023-2024 TPP that the CAISO clearly defines which zones on the transmission system will have available capacity in the future to accommodate more interconnections of the generation and storage resources needed to meet SB 100 goals.

If possible, it would be very helpful for the soon-to-be-adopted 2022-2023 Transmission Plan to identify available nearer-term capacity by transmission zone recognizing that the amount of future generating capacity will greatly exceed the amount driven by the 38 MMT resource portfolio that was studied over the past year. If CAISO is unable to incorporate this type of information in the 2022-2023 Transmission Plan, it would be helpful to conceptually discuss early in this initiative how the CAISO would view the use of available transmission capacity for future interconnection requests based on the 2022-2023 Transmission Plan. This explanation will help illuminate the CAISO’s proposed zonal approach and inform stakeholder discussion around this topic by providing a concrete, meaningful example of using the proposed zonal approach to interconnection prioritization.

CEERT is concerned about the possibility that transmission expansion might be delayed because of uncertainties about the specific resource portfolios that will be implemented by the state’s load serving entities (LSEs).  The development of additional transmission capacity for specific zones can be informed to a significant degree by the CAISO’s analysis of commercial development interest as was done in the CAISO 20-Year Transmission Outlook report.   The CAISO should take the lead in the TPP in identifying available capacity by transmission zone rather than waiting for the CPUC to give additional advice to LSEs on the procurement activities. 

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

CEERT understands the CAISO concern that even with a focus on specific transmission zones there may still be the possibility of an excessive number of interconnection requests.  We, therefore, support the development of more prescriptive screening criteria that can be used to limit the list of projects that would receive detailed study.  However, we do not support the proposed use of an auction mechanism at this time because of the uncertainty it would insert into the interconnection process while there is a great imbalance between available transmission capacity and interest in interconnection.

Instead, we support the development of screening criteria that focus on the viability and readiness of projects to be built in a timely manner.  Project viability can be determined by examining a number of factors such as site control, progress in obtaining necessary project permits and initiating environmental review, procurement of major equipment necessary for project execution and execution of offtake agreements or financial hedges necessary for operation as a merchant power plant.  CEERT encourages the CAISO to work with resource developers to develop actionable screening criteria that will enable the timely completion of interconnection studies.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

CEERT opposes using the requirement of having an executed PPA as a condition to proceed to Phase II interconnection studies. Viable projects can be financed and developed using other forms of financial hedges than a PPA with a load serving entity.  Projects with “synthetic PPAs” or contracts for differences have been built in other balancing areas and are likely to be developed in California as technology costs decline. Project financial viability is a reasonable criterion to be used as part of the screening process for interconnect requests. However, being shortlisted by a load serving entity does not guarantee a project’s viability and could be used in a discriminatory manner.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

CEERT does not support this proposed reform regarding the timing of future Interconnection Request windows. Instead, CEERT encourages the CAISO to focus on guiding interconnection requests to transmission zones with future available capacity and the development of effective screening criteria to limit the number of interconnection requests.  Maintaining a regular, predictable interconnection process is consistent with encouraging innovation in the evolution of clean energy technologies and project development over the time horizon that will be required to meet SB 100 goals. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

The CAISO noted in its White Paper that at least one PTO expressed concerns about completing the Cluster 14 Phase II studies on schedule. The CAISO should consider, as part of the GIDAP reform, alternatives that would bring more technical resources to bear on completing the required interconnection studies in a timely manner. Likewise, the CAISO should consider proposals that would result in the withdrawal of projects in the interconnection queue that have been delayed beyond a reasonable amount of time.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Clearway supports the CAISO’s proposal to (1) allow Cluster 15 interconnection customers to “refresh” their interconnection requests with reasonable changes prior to the start of validation and scoping meetings, and (2) allow customers to withdraw at minimal or no cost in the same window. As proposed, the process will allow interconnection customers to submit projects that they have put significant effort into developing based on the current policy direction provided by the CAISO, while ensuring that developers are not penalized for changes in rules that will be developed and implemented after the application window has closed.

Given that Track 2 of the IPE 2023 initiative appears likely to make a project’s POI even more consequential than it is today – potentially affecting not just the cost of interconnection but the ability of a project to receive an LGIA at all – Clearway suggests that the CAISO allow changes in POI as part of the “refresh” process. This will help drive Cluster 15 projects to align as closely as possible with the most recent resource and transmission plans as of the time studies begin, supporting the CAISO’s goals for this initiative. Interconnection customers should also be allowed to reduce the MW capacity of their interconnection requests or change the fuel type, such as the balance between solar and storage for a hybrid project.

To ensure that changes during the “refresh” process are influenced only by new information that arises during project development or in the resource and transmission planning processes, Clearway suggests that the CAISO wait to publish any detailed information about Cluster 15 interconnection requests until after the window for changes has closed, so that developers cannot see where other developers have submitted projects. If it is not possible to keep queue information confidential, it would be better not to allow POI changes during the refresh process.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

In general, the CAISO should seek to minimize delays for all resources rather than prioritizing some projects in the queue over others. The out-of-state wind projects that are planning to connect to the grid via the Subscriber PTO model are in a unique situation in that the success of that model depends on aligning the timing for resource development and independent transmission development. However, the basic argument in the CAISO’s proposal also applies to other projects that are consistent with the IRP and TPP resource portfolios: it is important to keep the interconnection process on track so that projects can come online when the resource portfolios show that they will be needed.

While offshore wind does face a long and complex development process, the pre-Cluster 15 queue appears to have sufficient capacity to meet the offshore wind need that is currently anticipated in the 2035 timeframe, including the full capacity of the Morro Bay and Humboldt lease areas. Additional offshore wind projects proposed for interconnection in Cluster 15 would presumably be targeting leasing and procurement activities that are further in the future and should be able to be studied on the same timeline as the rest of the cluster.  

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Clearway supports the general policy direction of prioritizing interconnection requests in areas identified in the resource and transmission planning processes. However, as described in the issue paper, this proposal appears to be too limiting. The most recent resource portfolio adopted by the CPUC adds 86 GW of new resources by 2035. Building out this volume of new renewables will require resources to be built in many parts of the state and will require major transmission expansion, potentially including new policy-driven transmission in areas that have not yet been identified in today’s transmission plan.

This concept, as well as the related Element 2, should be further explored in workshops as the initiative continues.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

Clearway opposes this proposal as currently framed and encourages the CAISO to hold workshops to explore this issue further. As noted in response to the previous question, California should be working toward a buildout of 86 GW of new renewables in the next 12 years under the currently adopted CPUC resource portfolio. This suggests a change in perspective for the IPE 2023 initiative: rather than limiting the number of projects that can enter the interconnection process, this initiative should be geared toward developing an interconnection process that can successfully and efficiently advance a very large volume of projects to meet the 86 GW target. Measured against a target of 86 GW of new resources online by 2035, the current queue is not as oversubscribed as it might appear to be.

Clearway supports a change in the process to allow the CAISO to study a more realistic volume of resources proposed for interconnection at a particular location – similar to the approach currently taken for ADNUs. However, limiting the ability of developers to even propose a project for interconnection at a particular site would be going too far. Clearway instead supports building on the changes adopted in the IPE 2021 initiative to move toward a “first ready, first served” model, allowing projects to move forward more quickly if they can demonstrate that they are advancing in development.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Clearway opposes this proposal. While we support the principle of increasing alignment between the procurement and interconnection processes, it is not reasonable to expect offtakers to sign PPAs without meaningful information about deliverability and interconnection costs. Clearway instead encourages the CAISO to move toward a broader “first ready, first served” approach that allows projects to accelerate in the interconnection process by meeting readiness milestones including (but not limited to) signing a PPA (further described in section 7). We also encourage the CAISO to provide more upfront information on interconnection capacity and deliverability, which would make it feasible for projects to sign PPAs earlier in the interconnection process.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Clearway opposes this proposal. Given how long the interconnection process takes, it is not practical to wait until a specific resource need is identified before opening the window for interconnection requests. For example, most of the projects that are currently being procured to meet midterm reliability needs entered the queue years before the need for midterm reliability procurement was identified.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

In moving toward a “first ready, first served” approach, Clearway recommends that the CAISO build on the scoring process used in the TPD allocation process and replicate this model for use in allocating limited interconnection capacity. Clearway’s experience is that the TPD allocation process is working well and has avoided the delays experienced in the interconnection process, even with a large volume of projects in the queue. In addition to the readiness factors that are already considered in the TPD allocation process, such as shortlist/PPA status, Clearway recommends adding points for projects that are adding on to an existing queue position. Expansion projects are likely to have shorter interconnection timelines if they are leveraging infrastructure that is already built or planned for the existing queue position, as well as lower environmental impact if building on already disturbed land. This expansion of scoring criteria should be considered in allocations of both interconnection capacity and deliverability.

Additionally, Clearway supports LSA’s recommendation to provide a one-time opportunity for any current project in the queue to withdraw with full financial-security release. If a project has a fatal flaw that will make it impossible to build but does not have a deadline to withdraw and would face a financial penalty for withdrawing, the rational choice for the developer would be to leave the project stagnant in the queue. As CAISO is raising the bar for new projects to enter the queue and progress in the interconnection process, new projects will generally be more viable and “ready” than older projects. Providing owners of older projects with a no-cost route out of the queue will free up much-needed interconnection capacity for more viable new projects.

Clearway also supports LSA’s recommendation to publish information on the owners of projects that have been in the queue for longer than seven years, to facilitate the sale of any older projects that are viable but are not moving forward due to issues related to financing or developer capability.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

No comment at this time.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

We support a technology agnostic approach to resources but see a need for consideration of offshore wind, particularly for the transmission challenged North Coast.  Additional consideration should be given to a separate track to study offshore wind, given the long lead time and particular challenges associated with the North Coast.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

The interconnection process is an important tool to direct transmission and generation projects to support California's energy goals including prioritizing development in low environmental implications locations that increase project viability.  We are concerned that limiting interconnection requests to  where capacity is available would continue to direct generation to areas with high environmental conflict (e.g., Kramer, Round Mountain, and Coolwater) and divert proactive planning and investments for transmission needed to serve generation in low environmental implications areas (aka least-conflict) (e.g., Westlands Water District). 

Project viability is inherently tied to the ability to minimize time and costs related to land use and environmental permitting.  Projects located in areas with high environmental implications face lengthy permitting times, high mitigation costs, and are vulnerable to litigation.  (See Dashiell, S.; Buckley, M.; Mulvaney, D. Green Light Study: Economic and Conservation Benefits of Low-Impact Solar Siting in California, 2019.)  Transmission investment should be prioritized to serve areas with low environmental implications, as identified in the California Energy Commission (CEC) Land Use Screens for Electric System Planning and the California Public Utilities Commission's (CPUC) busbar mapping.  Directing investments and generation to areas with low environmental implications is fundamental to improving project viability and reducing costs.  

Should the ISO adopt Element 1, we recommend limiting interconnection requests accepted or processed to those in low environmental implications areas identified by the CEC's land use screens.  Projects in high environmental implications locations have less viability due to high costs, long approval timelines, and increased risk of litigation associated with choosing high conflict/high natural resource value lands and burden the interconnection queue.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

We recommend the ISO focus on project viability and readiness to limit interconnection requests to projects likely to succeed and meet California's policies.  We support the concept of screening criteria ­provided the criteria are based on land use screens such as the CEC's land use screen to identify and prioritize those projects that would be located in low environmental implications areas.  Additional criteria such as project readiness, as demonstrated by achieving project milestones for environmental review and permitting and land use permits, are valuable screening tools. 

A higher standard is needed to demonstrate site exclusivity for interconnection requests uniformly.  The ISO's February 23, 2023 Fifth Replacement FERC Electric Tariff (Tariff)  requires projects located on public lands to have "a permit, license, other right, or pending application prescribed by the relevant authority, to use the property for the purpose of generating electric power and in acreage reasonably necessary to accommodate the Generating Facility" to demonstrate site exclusivity.   However, per the Tariff, projects located on private land only need a lease option for a minimum of 50% of the acreage reasonably necessary to accommodate the Generating Facility to comply with the site exclusivity requirement.  This approach invites more speculative projects with questionable viability on private lands while requiring greater certainty of project viability on public lands.  Projects on private lands should be held to the same standards as those on public lands.  Interconnection requests for projects located on private lands should be required to have achieved "application deemed complete status" (CA Government Code 65943) to demonstrate site exclusivity.

In addition, the Site Exclusivity Deposit allowed under the GIP BPM should be equivalent to the cost of preparing and submitting an application to the BLM or local land use authority to deter speculative and premature interconnection requests.

Finally, should the ISO engage in auctions for space on the interconnection queue, it should require land use screens and project readiness criteria outlined above for auction participation, not just how much money a developer can pay for a queue position.  Without such land use screens and project readiness criteria, auctions would favor well-funded developers over developers who have viable projects.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

We strongly oppose the use of PPAs as criteria for project advancement.  The project screening and purchaser decision-making process varies wildly in the market and does not provide a consistent measure of project viability or readiness.  In our experience, the existence of a PPA for a project – in and of itself – does not indicate project viability.  We have seen projects with PPAs fail due to the developer's decision to choose a high conflict site (e.g., Walker Ridge).  Allowing PPAs to have weight in the interconnection process can result in "deadwood" projects taking space and resources while they struggle to acquire environmental and land use permits on high conflict project sites.  The CAISO should be designing its interconnection process to incentivize project developers to choose the most viable project locations, which must include choosing lower conflict sites.  This would be consistent with and promote the ongoing efforts of the CEC and CPUC to identify the best areas for renewable energy development to meet SB 100 goals. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

We support the ISO's concept of imposing a time limitation for projects in the queue and recommend utilizing land use screens to prioritize high environmental implications projects for "aging out" of the queue.  Projects with high environmental implications lingering on the queue are those more likely to fail and should be eliminated.  

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

Our recommended alternative elements are included in our responses to Questions 3 to 6.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

We support the ISO's goals to make the interconnection queue more manageable and meaningful and do not believe these efforts will reduce competition amongst high quality, viable projects.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

EDF-R appreciates the opportunity to comment on the 2023 Interconnection Process Enhancements issue paper and straw proposal. EDF-R appreciates that CAISO is taking steps to improve the efficiency of the interconnection queue process and agrees that this is needed effort at pivotal time for renewable development.

In Section 2 the CAISO proposes that for Cluster 15 it will:

1. Accept interconnection requests (IRs) during the normal April 3 – April 17 window,
2. Confirm that all IRs are complete (that they have submitted the required documents, technical files and moneys) by May 1, 2023.
3. Postpone the validation of Cluster 15 IRs and the project scoping meetings.

EDF-R believes that developers have already undertaken significant efforts to put together Cluster 15 IRs and the correct decision is for the CAISO to open the application window on April 3. EDF-R requests that with the final proposal the CAISO address the following items:

• Interconnection customers should be given the opportunity to update or withdraw their interconnection requests in the month before the CAISO plans to begin validation of the IRs
  
  EDF-R appreciates that the CAISO is offering interconnection customers the chance to “refresh” their interconnection request, this will eliminate the risk of studying a “false cluster” which would then see major changes to its composition between Phase I and Phase II. EDF-R also supports CAISO’s proposal to allow customers to withdraw for minimal or no cost at any time until study work begins.
  
  The procurement environment changes quickly; often during the power contract negotiations off takers request changes to the project design or composition. Given that somewhere between 12 and 18 months will have passed between when the IRs were submitted and when the IRs will be validated EDF-R anticipates that many developers will need to make changes before validation begins. Interconnection customers should have the opportunity to adjust their IRs and change number and type of inverters, downsize MW amount, POI changes within the same study area, interconnection facility details, and shift the MW amounts of fuel type for hybrid facilities.
   
• CAISO should publish Cluster 15 projects in the RIMS interconnection queue in May 2023 when the IRs are accepted
  
  Publishing Cluster 15 in the interconnection queue allows for transparency, equitable information access, and more precise analysis as CAISO and stakeholders consider IPE 2023 Track 2 items.
   
• CAISO should develop a pre-Phase I study to give preliminary information about interconnection and deliverability availability and areas that will require network upgrades that could exceed the reimbursement cap
  
  Regarding interconnection capacity EDF-R is interested in particular for the CAISO to work PTOs to identify substations that cannot accommodate more interconnections, substations where bay positions are already full and new interconnections would necessitate expensive expansions or the buildout of whole new substations.
   
• Before the start of the Phase 1 study CAISO should implement changes to the study process to reduce the throughput time for the Cluster 15 study work
  
  It is understandable that CAISO handled Supercluster 14 with a straightforward timeline delay – Cluster 14 was the first ever supercluster and at that time CAISO was navigating policy changes related to the August 2020 outages.  However, EDF-R does not believe this is the best procedure going forward. In addition to implementing changes CAISO from the most recent IPE effort, CAISO should focus on reducing the study time for Cluster 15 and for all future clusters. A 3-year study timeline (from IR submission to deliverability allocation) does not meet the needs of California’s rapidly accelerating supply needs.
  
  Currently the narrowing of the queue depends on the interconnection customers waiting to receive Phase 2 study results and self-elect to withdraw. This process requires CAISO and PTOs to do two rounds of complex study work. EDF-R proposes that a pre-Phase I study report (at the study group level) could accelerate the timeline for that decision making. Publishing a Pre-cluster-I report would give interconnection customers who submitted their requests as a proxy for information requests the opportunity to withdraw from the interconnection queue with no penalty. Pre-Phase-I report would provide meaningful information in advance of the delayed Cluster 15 Phase I study reports.
  
  EDF-R is very interested in discussing this and other possbilities for reworking the study process stakeholders and the CAISO may have, and requests CAISO hold an in person IPE workshop to discuss Track 2 proposals. 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

In Section 2 under the “Other Issues for Consideration” section, CAISO proposes to address offshore wind and out-of-state wind connecting to the subscriber PTO immediately via an accelerated queue process. EDF-R does not support the CASIO’s proposal to bifurcate the interconnection queue and allow offshore and out of state wind to receive interconnection and deliverability results before other Cluster 15 projects. EDF-R sympathizes with the challenge CAISO has dealing with the magnitude of the interconnection queue, and agrees procedure changes must be made to improve queue efficiency both in quantity of study work and schedule. Creating an accelerated and separate queue to support specific wind projects is not the right solution.

• CAISO’s proposal will give wind projects unfair deliverability access
  
  CAISO indicated on the call that the Cluster 15 wind projects would proceed to deliverability allocation when their Phase II studies are complete, presumably a year or more before the rest of Cluster 15 is eligible for deliverability allocation. This is discriminatory. CAISO proposes that this concern is also resolved by the unique circumstances for the out of state and offshore wind.
  
  In the Transmission Planning Process Enhancements[1] stakeholder initiative CAISO proposes that the CASO be able to earmark transmission plan deliverability when projects are in areas where the CPUC IRP indicates specific resource types are preferred. CAISO’s response presupposes the outcome of the Transmission Planning Process Enhancement stakeholder initiatives, which has been on hold since Summer of 2022. CAISO does not have uniform stakeholder support for that proposal; many stakeholders believe the proposal may violate the no undue discrimination requirements of the Federal Power Act and the FERC has not granted CAISO the tariff authority to do this. Furthermore, during that initiative EDF-R requested CAISO provide specific evidence of the problem and show how much “policy tagged transmission” has been used by interconnection requests. In response CAISO provided hypothetical examples of how such a thing could occur, not that it actually has occurred. Understanding the magnitude of the problem is necessary when evaluating such a major change to interconnection procedures.[2] It is EDF-R’s view that CAISO cannot move forward with this proposal without finalizing the deliverability reservation topic in the Transmission Planning Enhancements initiative. Perhaps by taking both the deliverability element and the Track 1 proposal elements to the FERC at the same time.
   
• CAISO’s proposal to reserve deliverability is inappropriate without CPUC-ordered location and type specific procurement
  
  The CAISO’s proposal to accelerate the interconnection process for wind projects will have an inappropriate ripple effect, transforming what are currently CPUC preferences into CPUC orders.
  
  Projects that receive study results and deliverability allocation results before others have an obvious and undeniable advantage in the procurement environment. While it is clear the CPUC would like to see wind in certain areas, they have not gone as far as to order LSEs to procure it. Small amounts of storage were ordered in Decision 13-10-040 and Decision 21-06-035. However, the wind procurement is not currently in the authorization piece of IRP and the decision making for the central procurement of 4.7 GW of offshore wind between Morro Bay and Humboldt is still ongoing. CAISO’s reservation of deliverability would only be appropriate in the event there were specific wind procurement directives from CPUC and other entities. Deliverability reservation should not exceed the specific amounts ordered.
   
• The creation of a bifurcated accelerated queue and deliverability reservation system will quickly become complex, burdensome, and require reform or elimination
  
  CAISO must treat future situations samely. Should there be future procurement efforts that order procurement of specific fuel types and new transmission, the CAISO would also need to make specific accommodations for those efforts, each with its own unique timelines and procedures for fuel types. This is likely to quickly become burdensome and complicated.

For these reasons, EDF-R does not support an accelerated queue for offshore and out of state wind projects, and encourages the CAISO to focus on reform efforts that reduce the throughput time for Cluster 15 study work and the study timelines for all future clusters.

[1] http://www.caiso.com/InitiativeDocuments/StrawProposal-TransmissionPlanningProcessEnhancements.pdf

[2] http://www.caiso.com/InitiativeDocuments/StrawProposal-TransmissionPlanningProcessEnhancements.pdf page 9

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

EDF-R opposes this proposal. EDF-R believes a competitive open design is best and that CAISO should not impede or limit access to the transmission system in this way. EDF-R believes earlier deliverability information and greater insight into available and planned transmission capacity will achieve the desired outcome without limiting competition. EDF-is concerned about the transparency of some elements of the CPUC busbar process and if commercial interest input has enough weight in that process. Also the amount of Energy Only generation planned for in the base case far exceeds the amount of Energy Only generation online or planned. Here again we believe barring interconnection requests in a specific area could only be appropriately implemented in the event that the state, county, or city permitting authority has explicitly banned generation development[1].

CAISO’s proposal also effectively bans development outside of specific zones, ignoring the benefits that that generation can bring such as congestion relief.

If CAISO elects to explore this item further, EDF-R requests CAISO and CPUC work together to present an analysis of how this would have effected Cluster 14, had it been in place in April of 2021.

[1] For example, Los Angeles, San Bernardino and San Diego, have passed restrictions discouraging or banning development of large-scale commercial wind farms.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

EDF-R acknowledges the obvious challenges that exist on all sides when CAISO’s procedures obligate them to study every interconnection request in a queue that 5 or 7 times bigger than the transmission system can support. The “catch” here is, if CAISO limits the amount of IRs how will available interconnection capacity be allotted to interested developers? The CAISO suggests an auction mechanism, and EDF-R requests CAISO provide more information about their proposed mechanism so that stakeholders can provide informed feedback. For example would the auction mechanism be strictly to the highest bidder? Or would the CAISO implement a scoring matrix to take other factors into account? What would happen in the event that a developer who wins an auction does not meet the expectations upon which the auction victory was based? The idea is worthy of exploration, and EDF-R requests CAISO hold an IPE workshop in person to encourage open discussion among stakeholders.

In Section 2 CAISO asks, “Could projects not selected be studied in a slower, lower priority process?” and while that seems reasonable in theory a deprioritized queue would not be a net benefit to CAISO’s interconnection procedures and could take so long to study it would become stale.

There are two ways to reduce throughput in the interconnection process: reducing the number of interconnection projects (complex and potentially discriminatory) and changing the amount of study work the CAISO does each project, and when that work is done. CAISO’s solution should do only the work needed to get developers the information they need to estimate their interconnection costs and deliverability likelihood, and proceed to detailed study work after deliverability allocation.

Regarding study area information and available capacity, is CAISO able to develop that data for screening (specifically how much interconnection and deliverability each area or sub area can accommodate.) Historically CAISO has stated that such information is difficult to produce because of the dynamic nature of the transmission system. If such an analysis is available EDF-R requests that CAISO develop that resource and provide it for transparency no matter the outcome of this initiative.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

EDF-R sees this pathway only as potentially viable only if CAISO can provide TPD allocation information and allocation earlier in the process. It is not an improvement of the procurement environment on the whole if developers and LSEs are negation PPAs without actionable information on the project’s deliverability status. CAISO’s procedure changes should not have the effect of shifting risk to LSEs and developers or administrative burden to PPA negotiations.

EDF-R also encourages CAISO to consider if it appropriate to eliminate the merchant build option altogether, which an the effect this proposal may have. This proposal would also prohibit Energy Only generation from proceeding to Phase II, which is contrary to the amount of Energy Only generation in the CPUC base case.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

EDF-R opposes the CAISO’s proposal to open the interconnection queue “when warranted.” EDF-R does not believe that there will ever be agreement among affected parties on what circumstances would open the interconnection queue.

Secondly, given that 1 in 10 interconnection projects reach commercial operation, the root of interconnection queue issues is not an excess of viable projects. The goal of queue reform should be to encourage a leaner queue compromised of viable projects. Less window openings will not prevent nonviable projects from entering queue, nor will it disincentivize future superclusters, as the limited supply of opportunities to submit an interconnection requests will increase demand.

Finally, a predictable cluster study application window allows interconnection customers to make timely decisions about site procurement, submit proposed projects as procurement needs and technology possibilities change, and allows interconnection customers to wait submit their projects when the projects are as mature as possible.

Beyond the policy concerns expressed above, EDF-R is unsure if this is a viable path, given FERC’s new directive on cluster study methodology. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

EDF-R is unsure if this is a viable path, given FERC’s new directive on cluster study methodology.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

In the paper introduction CAISO makes the statement that “Clearly, refinements to the GIDAP in IPE 2021 have not sufficiently reduced the number or capacity of interconnection requests to a manageable or meaningful level to support the pace of new resource development that must be sustained in the years ahead.” And EDF-R wishes only to express that the effects of the IPE 2021 effects have not yet been realized, as the tariff is not yet in place, some of those policies only apply to Cluster 15 and beyond, and the proposals do not trigger until Phase II. They could yet net positiive effect. 

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

     Fervo Energy (Fervo) appreciates the opportunity to provide comment in this proceeding, and commends CAISO and the other MOU signatories for their progress towards synchronizing resource procurement and transmission planning. 

     As noted in the straw proposal, amendments to the GIDAP undertaken through the 2021 Interconnection Process Enhancements proceeding have not yielded a manageable queue. Problems with the interconnection process must be rectified to allow California to bring on the amount of new generation required to meet future load while achieving its policy goals. The massive resource buildout required by CPUC procurement planning will require similar levels of transmission buildout, indicating that CAISO will need to dramatically increase its capacity to study and process interconnection requests in the immediate future. 

     The approaches outlined in the straw proposal for tracks 1 and 2, on the other hand, effectively increase the barriers inherent to the interconnection process and penalize all forms of resources, not just those that are non-viable or speculative in nature. These approaches are of questionable utility when considering the ultimate goal of advancing the clean energy transition. 

     The Track 1 straw proposal for immediate adjustments to the Cluster 15 schedule is unacceptable. The proposal to open the queue, with associated required study deposits, and then simply sit on those requests for a year without taking action, is nonsensical and worse than simply delaying the cluster outright. In fact, it discriminates against developers with limited capital that cannot afford to have deposits held up in a queue that is not proceeding.

     In general, Fervo urges CAISO to abide by the principle of not biting off more than it can chew: in this case, opening a new cluster when CAISO doesn’t have the capacity to do the requisite work is ill-advised. The approach is worse when considering the discriminatory effect of such an action, as it is unfair to developers who cannot afford to have study deposits tied up for a year without progress. 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

     While offshore and out-of-state wind warrant consideration, Fervo urges CAISO to widen the scope of this inquiry to include the unique characteristics of geothermal energy that also call for additional consideration. Geothermal is also a long lead-time resource and, similar to offshore and out-of-state wind, somewhat locationally specific.

     Similarly to the noted offshore and out-of-state wind, impairment of geothermal development would be contrary to California’s policy objectives.  Specifically, ALJ Decision 21-06-035 in the 2021 IRP cycle (Rulemaking 20-05-003), Decision Requiring Procurement to Address Mid-Term Reliability (2023-2026), calls for 1,000MW of new, non-weather-dependent resources with a greater than 80% capacity factor to be procured by 2026 (this deadline was later amended to 2028). CAISO must make transmission resources available that will allow this procurement to proceed.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

     Fervo opposes this proposed reform. Limiting interconnection requests to those areas where development of transmission capacity is already planned would create a cycle that would ultimately stymie development of new generation and transmission resources. Interconnection requests are an important input to transmission planning that would be lost by implementing the proposed reform, creating a top-down resource development approach that is constrained by the transmission planning process, rather than a bottom-up approach that promotes technological and geographic resource diversification.

     The proposed reform has a discriminatory effect on resource technologies that face restricted siting flexibility, either by their resource availability or zoning and permitting conditions. Areas with the best subsurface thermal resources and potential may not be those in which transmission capacity is being planned; this would lead to a less than ideal outcome where a suboptimal resource was developed simply because transmission capacity was already planned in that area. 

     Additionally, enabling new generation only around currently planned transmission lines will concentrate resources in a few areas and reduce grid resilience.. Geographically dispersed resources distribute risk and exposure to various hazards, such as wildfires, extreme flooding, earthquakes, and other weather conditions that may be exacerbated by climate impacts. Artificially limiting development to certain areas will concentrate the system’s risk exposure, ultimately proving counterproductive to the supply of clean, safe and reliable energy to meet the state’s policy goals.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

     Fervo supports efforts that would focus interconnection queues on desired resource characteristics. In doing so, CAISO would need to avoid taking action that could be seen as discriminatory. However, by carefully specifying the desired attributes of new resources, such as increasing grid reliability while furthering decarbonization, the interconnection queue could become another pathway to achieve desired policy outcomes. For example, ALJ Decision 21-06-035 calls for the procurement of 1,000MW of new, non-weather-dependent resources with a greater than 80% capacity factor. Specifying a preference for resources that meet these characteristics would be following CPUC guidance and would also serve to reduce the number of interconnection requests.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

     Requiring a PPA or shortlisting to proceed to phase II creates a barrier to entry that will surely stymie development. Without a commercial operation date (COD), a product of phase II studies, PPAs can’t be executed. CAISO should consider more stringent site control requirements or other alternative readiness requirements to proceed to phase II studies.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

     As stated above in the response to question 1, Fervo believes it is of limited utility and verging on discriminatory to open a queue without any intention to process the associated requests. Until CAISO is able to process the requests already submitted, it should not open the window for a new cluster. 

     With that said, and as also stated above, Fervo believes reforms are needed that will increase CAISO’s capacity to process interconnection requests and facilitate projects moving through the queue. The proposed approach to delay clusters and increase barriers to entering those clusters seem counterintuitive and counterproductive to increasing access to transmission and interconnection to further California’s clean energy goals. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

     CAISO’s approach to an overloaded queue is to create and increase barriers to entry. This approach risks discriminating against developers who cannot meet those requirements, be they geographic or financial in nature. The proposed reforms would have a dampening effect on development in California, precisely the opposite of what’s needed to meet the state’s energy needs. 

     In reality, an overloaded queue is the result of the need to add significant quantities of new resources – generation and transmission – to the grid to meet load and policy requirements. A better approach would be for CAISO to support an accelerated energy transition through an expanded transmission system and interconnection process that is scaled to meet, not delay, California’s energy future.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

CAISO’s announcement that it will undertake significant queue reform weeks before interconnection requests are due even though it will not begin the initial study process for about a year creates a lot of uncertainty for interconnection customers. To help manage the uncertainty, Golden State Clean Energy (“GSCE”) supports the proposal to allow Cluster 15 interconnection customers to “refresh” or modify their interconnection requests or withdraw for minimal or no cost at any time until study work begins. Given the delay anticipated before study work will begin, we believe these accommodations are reasonable. 

Allowing projects to modify their original interconnection request should help improve their responsiveness to the market and the needs of the grid. Projects should be allowed to move their point of interconnection within the same study area (or zone as defined in Track 2), given the grid topography could change over the course of a year. In addition, projects should be permitted to right size their capacity (increase or decrease) within a certain percentage range. This allows interconnection requests to be better informed by Cluster 14 Phase II studies, the 2022-23 Transmission Plan, and other developments that will occur before the study process begins for Cluster 15.  

The penalty free withdrawal option will allow CAISO to better manage Cluster 15 while easing uncertainty concerns for interconnection customers. Queue management will be improved by incentivizing projects to withdraw for any reason over the next year. At the same time, offering a penalty free withdrawal option is not likely to drive a flood of interconnection requests given there will be little or no time to develop new Cluster 15 interconnection requests in response to this option. 

Finally, to better inform the Track 2 discussion on the schedule for Cluster 15, we seek feedback on whether CAISO anticipates needing additional measures for Cluster 15 similar to the supercluster procedures imposed on Cluster 14 (e.g., extend the Phase I and II study timelines, in addition to delaying the start of the study process). 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Golden State Clean Energy does not oppose a special process for out-of-state and offshore wind but we do request more information. We see the main long lead-time development issue being transmission coming out of the TPP and not generation or network upgrade development.  

Although we appreciate the tight deadline for Track 1 of this initiative, there is currently not enough detail provided to allow stakeholders to compare this special process to a process where the entirety of Cluster 15 is delayed. GSCE would likely not support a process that risks further delaying Cluster 15 projects that are not part of the special process, and there seems to be a substantial risk of this occurring. It is also unclear how CAISO could ensure network upgrades costs are fairly shared among different tranches of Cluster 15. The Track 1 timeline may ultimately prohibit consideration of this special process. 

GSCE generally supports a technology agnostic view of resources. We acknowledge the lengthy and nascent development process for offshore wind but are not supportive of extending special treatment to out-of-state wind. We see the main issue with out-of-state wind being trunk line transmission, which is a TPP issue. 

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Golden State Clean Energy supports CAISO’s proposal to limit the study process to zones on the transmission system that have available capacity. Although we do not support a strict MW limit on the projects that can apply to areas with available transmission capacity (as discussed in question 4), a zonal focus is a reasonable approach to ensuring transmission planning and generator interconnection are more closely coordinated.  We support transmission planning that unlocks scalable clean energy development on least-conflict lands and a generator interconnection process that is tied to new transmission development so state planning efforts to target least-conflict lands have a more holistic impact on resource development. 

To help stakeholders better understand how this zonal approach will work, we request more clarity in Track 2 on what is meant by available transmission and how CAISO would look to define zones. 

GSCE supports more proactive transmission planning and pairing this with limits on future interconnection requests so interconnection studies focus on zones of least regrets resource areas. The CEC has done important work to assess where future resource development should take place, and this planning needs to guide both future transmission planning and generator interconnection. The CEC’s upcoming update to its land use screens that will further improve these proactive planning efforts. 

However, we have had serious concerns with the historical resource portfolios that have been provided to CAISO in the TPP because the overall capacity has been insufficient to allow the state to meet its SB 100 goals, and busbar mapping has resulted in too much capacity being studied in areas that are often misaligned with least regrets land use planning. If these issues continue to exist in a future where interconnection requests can only be submitted in zones of available transmission, in-state resource development will be completely disrupted. The most recent resource portfolios put California on a much better track as far as overall resource capacity, but there is still a need to ensure the busbar mapping process does not inhibit the type of transmission development that is needed or re-direct development to existing infrastructure in areas the state is trying to shift away from. GSCE is encouraged by the collaborative efforts of the CEC and CPUC to refine the busbar mapping process for this upcoming IRP cycle, and we will continue to work with the state agencies to ensure the land use intent captured in the land use screens is carried through the IRP process and into CAISO’s TPP so that new transmission and resource development is concentrated in areas of least-conflict lands. Improved busbar mapping will be crucial to the success of CAISO’s proposed zonal approach. 

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

Golden State Clean Energy supports some form of additional screening (above the zonal restrictions), but CAISO should look to inject impactful readiness criteria instead of setting a strict MW limit on interconnection requests or employing an auction mechanism. Site exclusivity, permitting, and major equipment purchases are all important indicators of commercial viability during the development process and should be readiness criteria used to screen projects early in the study process. 

We appreciate the difficulty of acting on queue reform while FERC’s generator interconnection NOPR has yet to be finalized. However, broadly speaking, readiness requirements seem to be the direction FERC is heading. Proposed elements 2 and 3 of Track 2 should center around commercial readiness and viability rather than some administrative auction mechanism that risks placing undue limits on interconnection requests while introducing a whole new dynamic in the interconnection process. In tandem, we oppose setting a MW limit on the interconnection requests accepted during a window. Instead, reasonable but firm readiness criteria should be used to naturally reduce the number of interconnection requests and manage the queue. 

We created a white paper in 2022 that speaks to our view of commercial readiness (which we provided in comments on the 2021 IPE initiative), and we continue to advocate for the ideas expressed in that paper for better managing queue size. Land-based developmental steps like site exclusivity and permitting have a clear nexus to the zonal approach CAISO is examining and are reasonable requirements at the stages we propose. We also propose other readiness considerations like procurement of major equipment because this, as well as land-based developmental steps, provide much clearer indicators of a project’s seriousness and ability to be constructed. A project cannot be developed without permitted land and the necessary equipment (in contrast to a PPA), so they are reasonable requirements at certain points in the interconnection process. The following summarizes our white paper proposal: 

• Phase I study readiness should include site exclusivity or a substantial at-risk readiness deposit (far above the current deposit amount and with a significant portion at risk).
• Phase II study readiness should include actual site exclusivity (which CAISO has recently enacted) and having initiated environmental review under CEQA/NEPA.
• Deliverability allocation should be slightly broadened given project screening should be happening more aggressively but upfront, and ordering major equipment is a development step we see as reasonable for CAISO to assess for readiness by including as a deliverability allocation group. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Golden State Clean Energy opposes element 3 of CAISO’s Track 2 proposal. The readiness requirements we discuss in response to question 4 (and possibly other readiness requirements) should be sufficient to screen projects. CAISO already has a mid-study readiness check that is focused on securing a PPA, which is deliverability allocation, so we do not see this proposal adding much. 

Readiness requirements are important, but basing them solely on contracting status does not work and is misguided for the following reasons:

• First, it does not focus on early-stage developmental steps that drive project viability and indicate true commercial readiness. A project could meet a PPA requirement but no other major development milestone, which indicates a PPA can be a misleading when assessing what projects will actually be built. 
• Second, it provides incentives for project developers who have not taken concrete steps toward project readiness to bid low in competitive solicitations, creating fictional ‘contracted’ capacity in the pipeline that may never prove viable (a real occurrence in today’s marketplace).
• Third, the contracting landscape is evolving, and long-term contracting is no longer required for successful project financing or the emerging realities of capital markets. In fact, across the country with the inflationary environment, long-term contracts may currently be harder to finance than short-term contracts.
• Finally, a narrow focus on contracting forces commercial negotiations to occur before projects are fully studied and have sufficient cost certainty or development timeline assurances.

GSCE supports more readiness requirements that can come before the Phase I studies, which better addresses CAISO’s desire for Phase I to be a meaningful study that leads into Phase II. PPAs or shortlisting do not make sense pre-Phase I, so other readiness measures that are reasonable pre-Phase I should be examined. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Golden State Clean Energy opposes holding periodic interconnection request windows rather than the current process that creates certainty as to when projects may apply. CAISO’s proposal would create too much uncertainty when there is a need to ensure that renewable and storage development steadily occurs throughout the next couple of decades. A known and workable timeframe is also required to address an entire suite of externalities such as equipment supply chains and workforce development.

If CAISO limits interconnection requests to zones of available transmission and screens projects for commercial readiness, this proposal is unnecessary. The other proposals will limit future interconnection requests, but beyond those limits it does not seem that CAISO should further determine when a new interconnection request window is “warranted.” If there are no zones with available transmission capacity, then projects will not be eligible to seek interconnection. It is not clear that any additional benefit comes from this proposal, but it creates a lot of uncertainty that can harm development efforts. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

Overall, Golden State Clean Energy believes that CAISO is on the right track in the 2023 IPE in setting out significant queue reform. We applaud this effort and believe the following are the key areas for CAISO to focus its queue reform:

• Develop a zonal focus with additional screening based on commercial readiness to help create a more reasonable queue size. 
  • Screen early in the interconnection process so Phase I study results are meaningful and include additional readiness checkmarks later in the process.  
  • Site exclusivity, permitting, and major equipment purchases are all important indicators of commercial viability during the development process and should be readiness criteria used to screen projects.
  • Use commercial viability and readiness measures to limit and shape the queue, not artificial restrictions and strict adherence to modeling assumptions. If CAISO limits the queue to a set MW and auction without other screening mechanisms, it will have less projects and still have a high failure rate, which risks severely impeding the development needed to achieve state policy. 
• Develop proposals targeted at removing projects that are lingering in the queue and not commercially viable.
  • We support the Public Advocates Office’s comment made during the March 13 stakeholder meeting that CAISO needs to be more critical of projects in the queue and deem projects withdrawn.
  • CAISO should have the authority to deem significantly delayed projects withdrawn regardless of deliverability status. 
• The Tehachapi Renewable Transmission Project provides a model for the benefits that a master-planning process can provide, and we support further master-planning efforts on least-conflict lands and other areas that align with state land use policies. 

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

GreenGen supports CAISO’s proposal to postpone opening the window for Cluster 15 project requests until all Cluster 14 projects have been evaluated and Track 2 GIDAP criteria has been established.

GreenGenStorage, LLC (GreenGen) appreciates the opportunity to submit its initial comments to CAISO’s 2023 Interconnection Process Enhancements (IPE) initiative and March 13, 2023 stakeholder meeting.

GreenGen is a California-based pumped storage development company that is permitting a pumped storage project in parts of Amador and Calaveras Counties, California. The Mokelumne Pumped Storage Project is an eight-hour, 400 megawatt pumped storage project that will store 3,200 megawatt-hours per day of clean, reliable, and dispatchable energy. The Project is anticipated to be online by 2030, thereby helping California meet its energy and emissions goals by providing reliable, long duration, carbon-free energy storage. The Project minimizes land and water impacts by taking advantage of existing infrastructure, including reservoirs and transmission facilities. As this Project is a long-lead time resource, GreenGen has been working collaboratively with stakeholders in the proposed Project vicinity, including resource agencies, Tribes, non-governmental organizations, and interested members of the public since 2018. Application to the CAISO Large Generator Interconnection Agreement (LGIA) process is expected in the 2026-27 timeframe to support the 2030 online date. Based on the proposed changes to Cluster 15 timing and the Generator Interconnection and Deliverability Allocation Procedures (GIDAP) track 2 changes, GreenGen has a significant stake in the outcomes of Track 1 and 2.

In CAISO’s March 13 Straw proposal[1], the Cluster 15 window for submission of projects is April 3-17, 2023. CAISO proposes that projects submitted into Cluster 15 will be reviewed for completeness, but analysis of the projects will not start until the evaluation of the Cluster 14 projects is complete, and the updated evaluation criteria for the Track 2 GIDAP process are finalized. The Track 2 GIDAP evaluation criteria will be applied to Cluster 15 projects. 

GreenGen agrees with CAISO’s option to delay opening the window for submission of Cluster 15 projects for the following reasons:

• Opening the Cluster 15 window without the Track 2 evaluation criteria in place would disadvantage project developers, as they have no guidance on which projects, locations, or technology will be prioritized in the Track 2 evaluation. 

• Opening the project submission window in April 2023 and then delaying project evaluation until 2024 creates significant financial hardship for project developers due to incurrence of additional development costs associated with submittal into the Cluster evaluation process.  In addition to submission fees, project developers are required to show site control and incur costs associated with the project site, technology reservations and other project costs, without a timeline or any Track 2 evaluation criteria.

• During the Stakeholder call, CAISO staff indicated that preferred locations or zones would be identified for technologies to interconnect with the CAISO transmission grid.  These zones are expected to be included in the draft 2022-2023 TPP report due in late March 2023.  Developers of projects for Cluster 15 would have a limited ability to make adjustments to projects based on the identified preferred zones for interconnection if the Cluster 15 window is opened from April 3-17, 2023.

• The Straw proposal suggests that opening the Cluster 15 window now, will reduce an even greater number of projects applying, than if the Cluster window were to be delayed. If CAISO postpones opening Cluster 15, the projects that apply to Cluster 15 will know if they are well positioned to be analyzed in accordance with the Track 2 evaluation criteria or not. GreenGen believes that the Track 2 evaluation criteria will likely create a regulating force on the number of projects that will apply. Postponing opening the window for Cluster 15 could even result in fewer projects applying for interconnection because the yet to be determined Track 2 criteria will purportedly focus on locations/areas that are most beneficial to the grid and load-serving entities.

[1] Issue=Paper-and-Straw-Proposal-Interconnecton-Process-Enhancements-2023-Mar132023.pdf (caiso.com)

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Long lead time resources like Pumped storage should be part of any special consideration in Cluster 15 Interconnection and the TPP process.

Additional long lead time resources, like pumped storage, merit special consideration in Cluster 15. The Straw Proposal identified offshore and out-of-state wind as technologies that required special consideration in Cluster 15. During the CAISO Stakeholder Call, CAISO staff indicated that both out-of-state and offshore wind technologies need special consideration due to supply chain challenges and the long lead time nature of the technology.

Commenters aptly noted that other technologies fall into that category including pumped storage hydro. CAISO should include pumped storage technology as part of any special consideration in interconnection and the Transmission Planning Process (TPP).[1] 

As part of the CAISO’s 2021-2022 TPP evaluation, the California Public Utilities Commission (CPUC) issued Decision 21-02-008 that identified pumped storage as a technology needed to achieve California’s policy objectives. More specifically, the CPUC’s decision adopted a reliability and policy-driven base portfolio and two sensitivity portfolios with updated assumptions from the CEC’s 2019 Integrated Energy Policy Report (IEPR) as detailed in Attachment A[2] of the order for study in the CAISO 2021-2022 TPP: (a) A reliability and policy-driven base-case portfolio that meets the 46 million metric ton GHG target by 2031 (Base Portfolio)[3]; (b) A portfolio that meets a 38 million metric ton GHG target by 2031 as a policy-driven sensitivity (Sensitivity 1 Portfolio)[4]; (c) A portfolio to test transmission needs associated with offshore wind (OSW) and a 30 million metric ton GHG emissions target by 2031 (Sensitivity 2 Portfolio)[5].

Pumped storage technology faces the same supply chain and long lead time issues for equipment and permitting as do offshore and out-of-state wind projects. For these reasons, pumped storage should be given the same consideration and treatment as offshore wind and out-of-state wind, i.e., as a technology that requires special consideration in the TPP process, Cluster 15, and subsequent Cluster evaluations.

[1] CAISO Straw Proposal for GIDAP, Other Issues for Consideration, page 10.

[2] ftp://ftp.cpuc.ca.gov/energy/modeling/Modeling_Assumptions_2021_22_TPP_Final.pdf  

[3] The CPUC Base Case Portfolio 46 MMT with 2019 IEPR (2031) results identified 747 MW of pumped storage technology. 

[4] The CPUC Policy Driven Sensitivity Portfolio #1, 38 MMT with 2019 IEPR (2031), identified 1,700MW of pumped storage.

[5] The CPUC Policy Driven Sensitivity Portfolio #2 the “Offshore Wind Sensitivity Portfolio”, identified 1,076 MW of pumped storage.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Additional clarification is needed on how regions, where the system is deemed to have available or planned capacity, will be defined. There is a risk that preferred resources will not be considered even if their value to the system may warrant an incremental transmission upgrade.

As an initial consideration, GreenGen seeks clarification on how the CAISO will define regions where the system is deemed to have available or planned capacity. For example, GreenGen’s planned pumped storage project is located in an area of PG&E’s service territory that is not “behind” any known transmission constraints as they are defined in the CPUC’s IRP process. The CAISO should clarify whether it intends to use published transmission capability information to define such system boundaries.

Generally, a full prohibition could result in preferred resources not being considered despite the possibility that their value to the system may warrant an incremental transmission upgrade. Rather than a full rejection of interconnection requests in certain areas, a specification for only accepting interconnection requests from resources with preferred characteristics (e.g., long-duration storage, base-load renewable, etc.) would be preferred to an absolute prohibition of all interconnection requests in certain areas.

If the TPP process is intended to evaluate the CPUC’s preferred resource portfolio to identify zones for interconnection, the CAISO should describe the process they will use to evaluate the transmission requirements used to identify preferred zones for each technology.  Changes to the TPP process should also be included as part of this overall process.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

To the extent CAISO wishes to reduce the total MW submissions in a particular region, GreenGen recommends applying limits based on certain characteristics of resources seeking interconnection.

Consistent with the theme recommended by the CAISO for Track 1, should CAISO wish to reduce the total MW submissions in a particular region it would be best to apply limits based on certain characteristics of resources seeking interconnection. Resources with preferred characteristics such as long-duration energy storage and baseload renewable generation for example should be given priority over resources with declining reliability and renewable benefits to the system.

With respect to an auction, it is unclear to whom the rights to interconnect would be auctioned or what entity would be best suited to hold an auction. Would they be auctioned, for example, to load-serving buyers? Would they instead be auctioned to developers? Using an auction mechanism would seem to create a risk of significant distortion based on only the financial ability for a participant to bid for such capability. Ultimately the cost of an auction would likely act to increase the cost of reliability and carbon reduction for California buyers.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Requiring long lead time resources to have an early stage PPA executed prior to submitting an interconnection request will likely inhibit the development of preferred resources.

Preferred resources may by their nature not be candidates for early-stage PPA execution. CAISO should not create policies that further inhibit the rollout of preferred resources by, for example, requiring a PPA before such resources are able to submit interconnection requests. This is especially true of long-lead time resources, such as pumped storage.  Further, requiring a PPA of such resources would require a developer to escalate PPA prices to cover risks of possible transmission upgrades – even limited upgrades – required of the project.  To the extent the PPA does not include the transmission upgrade costs, it may expose customers to higher transmission costs if a project needs significant upgrades. If the CAISO continues to propose a PPA for entering the queue, such a requirement should not be applied to long lead time resources such as pumped storage. In addition, the cost of transmission associated with pumped storage should mirror that of offshore and out of state wind, and should not be treated as part of the project cost.

In addition, most if not all RFOs reviewed by GreenGen require that in order to be considered in the RFO, the project must have already submitted an interconnection application and/or have completed an interconnection study. The CAISO’s proposal would create an untenable chicken and egg problem.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Eliminating regular Interconnection Request windows would negatively impact the integration of needed preferred resources.

Uncertainty regarding Interconnection Request windows will create a significant commercial impediment to developing and contracting for resources. With respect to preferred resources, such a policy would significantly hamper the deployment of beneficial technological and creative renewable and grid solutions. While the existing queue may have depth with respect to total size, eliminating regular queue windows would not allow for integration of such highly needed long duration resources. From a contracting perspective, it will be challenging to negotiate a PPA without understanding when an LGIA window would be available. Technologies such as longer-duration storage and advanced geothermal generation, for example, would not have a mechanism to participate in the interconnection process, while conventional renewable resources, which are over time becoming less valuable to the grid, do.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

At this point in time, GreenGen has no comments on this issue.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Any adopted proposal should consider implications to FERC open access tariff requirements.

Green agrees with the CAISO and other stakeholders that proposals must consider Open Access and updates to the FERC Tariff. CAISO should strive for a process that is technology/resource agnostic that also focuses on preferred resource characteristics. Preferred resources have certain attributes beyond what traditionally has been considered in the CAISO interconnection process. Such resources may be beneficial in reducing the overall IRP capital buildout costs and/or they may provide adjunct grid or operational benefits. Thus, declaring that only one subset of preferred resources will be considered in any given queue process risks significantly limiting the benefits available to California from other long-lead time and preferred resources and would be discriminatory.

2. A more focused effort is needed to capture the transmission benefits and value of pumped storage.

Lastly, in response to the CAISO’s comment regarding the difficulty of disaggregating pumped storage’s transmission attributes from its generation attributes, noting that the more intertwined the attributes are, the harder it is for the CAISO to assess, GreenGen refers the CAISO to FERC’s 2017 policy statement that allows pumped storage and other energy storage assets to provide both regulated transmission and competitive market functions. While we understand the implementation challenges, GreenGen is willing to engage in this process to ensure the transmission benefits and value provided by pumped storage to the grid are understood and provided. For example, the addition of the Mokelumne Project to the CAISO system will provide benefits in the form of production cost savings, avoided CO2 emissions, avoided curtailment, and decreased thermal unit cycling. The Project is being designed to support California's climate and renewable energy goals and will respond to grid needs with a high level of flexibility and variability. A typical daily operation is expected to include pumping during the late morning into the early afternoon to support high levels of solar output and then generate in the late afternoon and evening to support very steep ramp rates and high load. During the overnight hours the Project is expected to pump, again supporting renewable generation from wind resources and other base load facilities, and then turn around and generate to support the morning ramp.

3. Conclusion

GreenGen respects the CAISO’s perspective that more fundamental changes to the GIDAP may be needed to make the GIDAP a viable process in light of the state’s vastly accelerated new resource procurement targets. GreenGen is similarly committed to reaching our collective goals and appreciates the importance of the ongoing alignment to ensure preferred resources are able to timely come online and to also consider the special permitting and construction needs of long-lead time resources like pumped storage.

A summary of GreenGen’s comments and recommendations:

• GreenGen supports CAISO postponing the opening the window for submission of projects into Cluster 15 until all Cluster 14 projects have been evaluated and the Track 2 GIDAP criteria have been established.

• Pumped storage technology is a long lead time resource and should be part of any special consideration in the interconnection and TPP processes. Pumped storage’s long lead time equipment and permitting issues mirror those of offshore and out-of-state wind projects.

• Uncertainty regarding Interconnection Request windows will create a significant commercial impediment to developing and contracting for resources. It is unclear as to when the process for LGIA interconnections will resume after Cluster 15. 

GreenGen thanks CAISO for the opportunity to submit comments. We look forward to learning from and contributing to the Track 2 process as it unfolds.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Q CELLS appreciate the time and effort CAISO has invested into developing proposals for the 2023 Interconnection Process Enhancements.

Q CELLS understands the challenges CAISO faces when looking at processing interconnection queue requests.

Q CELLS is not in favor of delaying the C15 cluster window or delaying C15 studies. Q CELLS prefers CAISO consider additional resources to expedite the processing of C14 study; delaying C15 as a last resort.

Q CELLS believes further discussion is needed concerning Track 2 proposals. CAISO expressed a desire to have reforms in place for a December board approval. Q CELLS disagrees with CAISO’s assessment regarding the amount of time needed to finalize decisions and details.

Q CELLS is generally against track 2 proposal for multiple reasons. We interpret track 2 as a series of solutions to be implemented together. That said, we have open access concerns with limited requests, concerns with cost certainty for PPAs, and development concerns regarding ad-hoc interconnection windows.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Q CELLS does not agree with providing preferential treatment to developers, especially those from out-of-state, based on technology type.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Q CELLS does not support accepting IRs only where the transmission system has available or planned capacity.

Q CELLS believes developers should not be penalized for project submissions not in CPUC's or TPP’s identified zones. By prioritizing specific zones, Q CELLS believes CAISO is pushing increasing queue problems to the local level, which Q CELLS does not believe helps CAISO 2023 IPE goals.

Q CELLS encourages CAISO to periodically notify developers where development is encouraged/discouraged – heatmaps, reports, POI validation (by request), etc..

Q CELLS supports larger readiness deposits as a way of limiting the interconnection queue.

Q CELLS is open to discussions about what increased deposits could look like.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

Q CELLS does not support a hard ceiling to the number of projects studied in a given area, considering (and not) proposals in section 3.1.

Q CELLS has concerns that a hard ceiling for IRs based on project output will lead to CAISO giving preferential treatment to larger projects.

CAISO has put forth interesting ways of implementing its proposal from section 3.2 – auctions, screening criteria, study routes, and options for ‘rejected’ developers. Q CELLS is awaiting more clarity and information before making specific recommendations or comments on these implementations.

Q CELLS supports larger readiness deposits as a way of limiting requests in future interconnection queues.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Q CELLS does not support the proposal to require PPAs or shortlisted status to proceed to phase 2 studies.

Q CELLS does not believe there’s enough cost certainty or time after phase 1 studies to execute a PPA.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Q CELLS does not support an as-needed interconnection request window as currently presented by CAISO.

Currently, the annual planning cycle provides clear guidelines that align with project development timelines.

Q CELLS, for this reason, supports continuing the cycle of annual queues. That said, Q CELLS supports further discussion around scheduling of future interconnection queues.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

Q CELLS supports the lowest withdrawal penalties possible to Cluster 15 since the rules are scheduled to change so drastically within this cluster. 

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

Q CELLS is generally against Track 2 reforms.

As stated in a previous response – Q CELLS has open access concerns with limiting requests by geography and by placing hard ceilings on studies performed. Those include concerns with cost certainty / timeliness for obtaining PPAs, and development concerns regarding ad-hoc interconnection windows.

Q CELLS feels that the proposals laid out in Track 2 will inadvertently harm otherwise viable projects.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

As the Issue Paper suggests, if CAISO intends to apply interconnection reforms retroactively to Cluster 15, it will be important to allow applicants to easily modify or withdraw requests once the final interconnection process reforms have been adopted by the Board. While IEP understands CAISO’s desire to reduce the number of applications submitted or progressing to phase II in Cluster 15, CAISO should also consider only applying the interconnection reforms prospectively to Cluster 16 and beyond.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

IEP has no response at this time.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

This approach may be feasible, but CAISO would need to clearly state the existing or planned capacity in each zone well before the opening of each cluster application window. CAISO would also need to provide detailed information on what constitutes a “zone.” For example, would prospective project locations be limited to those within X kilometers of an existing or planned transmission line to qualify? Or will CAISO issue specific GIS coordinates or other geographic designations?

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

In Section 3.2, the Issue Paper proposes a few strategies for limiting or discouraging projects from entering the queue. IEP is not necessarily opposed to the use of more stringent screening criteria to reduce the number of applications, but since the Issue Paper does not suggest specific criteria, it is difficult to take a position until more detailed proposals are under consideration.

Section 3.2 also suggests that auctioning capacity in each zone might help to reduce the number of applications to more manageable levels. While this would limit the number of applications, IEP is concerned that this approach may only serve to put larger, better capitalized developers at an advantage without necessarily incentivizing the development of the most productive or cost-effective projects.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

If adopted, this approach is likely to sharply reduce the number of projects advancing to phase II studies since, as a prerequisite, projects would need to be shortlisted or have already obtained a PPA. This would limit projects to roughly the amount load-serving entities need to meet near- to mid-term procurement requirements. Reaching this stage of negotiations with a load-service entity is a robust indicator of commercial viability and would eliminate more speculative projects from diverting resources in the phase II study process. However, requiring an executed PPA may be excessive and infeasible under current CAISO processes because load-serving entities will not generally execute a PPA with a project that does not have deliverable capacity assigned. To work, this approach would need to be coordinated with some form of conditional deliverability allocation in Phase I. Without a change in CAISO’s Phase I processes, projects would be stuck in a Catch-22 between contradictory CAISO and load-serving entity requirements.

Another concern regarding this proposal is that it would foreclose the possibility of developing merchant projects in the CAISO territory. Although such projects may be rare, interconnection requirements should not completely eliminate opportunities for projects to commence operations on a merchant basis. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

An interconnection window as open-ended as the process proposed in Section 3.4 would add significant additional uncertainty to project development timelines. Project developers need firm targets to plan around and conduct preliminary project development activities. It would be preferable to conduct request windows with more stringent screening criteria that nonetheless occur on a regular basis than to subject developers to the possibility that they may have no opportunity to submit requests for an unknowable number of years in the future.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

IEP has no response at this time.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

IEP has no response at this time.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Proposed Schedule:  LSA generally does not oppose CAISO’s proposed Cluster 15 schedule.  LSA acknowledges the significant amount of work associated with processing the recent volume of interconnection requests and appreciates CAISO’s efforts to maintain the current Cluster 14 schedule. 

However, LSA suggests that CAISO resume Cluster 15 validation efforts the earlier of March 2024 (expected completion of Cluster 14 Results Meetings) or actual completion of the Cluster 14 Results meetings, instead of April 2024.  Since the validation process is time-consuming for CAISO, the PTOs, and Interconnection Customers, it should commence as soon as possible, especially given the potential for project revisions at that point under the CAISO’s proposal.  An extra month could ease the administrative burden by allowing more time to complete the process before scoping meetings begin.

LSA’s Proposed Adjustments to the Cluster 15 Timeline:

Accommodations for the Delay:  In the year or more between application submittal and scoping meetings, CAISO and other entities could provide new information that changes the commercial viability of potential projects.  New information on aspects like available positions at substations should help developers refine their potential projects.

CAISO proposes that Cluster 15 customers may withdraw for minimal cost at any time until study work begins, or “refresh” their projects once validation resumes.  LSA offers the following feedback on these proposals.

1. Free Withdrawals:  LSA supports CAISO’s proposal that customers should be able to withdraw for any reason before studies begin without forfeiting their study deposit.  This proposal accommodates developers who submit an interconnection request in good faith but find that rules developed in Track 2 of this initiative make their request less viable. 

LSA believes that the decision on whether to proceed should belong to Interconnection Customers.  LSA does not believe that CAISO should eliminate projects that the CAISO believes have become less viable because of changes developed in Track 2.  These projects should be allowed to continue through the Cluster process if the Interconnection Customers so choose, because of their initial good faith effort and inability to foresee changes that would impact their request. 

If CAISO nevertheless does decide to eliminate such requests from the study process, it should allow impacted Interconnection Customers to submit evidence proving their project’s viability to remain part of Cluster 15.

CAISO should also allow projects from earlier clusters (Clusters 14 and earlier) a one-time chance to withdraw from the queue without forfeiting their financial-security postings.  This will help remove non-viable projects from the existing queue, as discussed further in response to question 7 below.

2. Refreshed Requests:  The types of changes that qualify as a “refresh” should include:
   1. Limited Changes to Point of Interconnection (“POI”):  If CAISO allows Cluster 15 customers to change their POIs to “prime” locations revealed after the Cluster 15 window closes, there will be a “run” on those locations, potentially perpetuating inaccurate study results.  CAISO should consider the following proposals to reduce this risk.
      1. Allow only limited POI changes based on geography or electrical boundaries.  Given the uncertainty associated with the rule changes CAISO will develop in Track 2, this “limited change to POI” proposal is a middle ground between allowing full flexibility to change the POI and sufficient flexibility to deal with new Track 2 rules.
      2. Implement “barriers to entry” for these attractive zones.  For example, projects should provide proof of site exclusivity or increased security deposits to shift to a new POI to demonstrate project viability at the new location.
      3. Keep queue information confidential until the window for changes has closed so Interconnection Customers can decide whether to change a project’s POI based on analysis of new information instead of speculation based on the actions of other customers.
      4. If CAISO does allow unrestricted POI changes, the projects that were originally aligned with “prime” locations revealed after submittal should maintain some advantage/seniority over new projects moving to the same POI or area, to reward Interconnection Customers who performed accurate up-front due diligence.
   2. Change in installed capacity (MW), including storage additions or deletions, but no increase in Interconnection Service Capacity.
   3. Change in fuel type.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Special Treatment for Offshore and Out-of-State (“OOS”) Wind:

1. CAISO should better justify the need for this special treatment, specifically and in more than the general terms in the proposal.  If these resources are not expected to come on-line for many years, there may be sufficient time to simply study these projects with the rest of the cluster.  CAISO should also consider whether other solutions, like increasing the length of time these projects can remain in the queue, would resolve the mismatch between their interconnection request timelines and their development timelines.  For offshore wind, there are already projects in the queue advancing towards their expected commercial operation dates without special treatment, which raises questions about why later projects should require such treatment.
2. CAISO should reserve judgment on this issue until the volume of offshore and OOS wind Interconnection Requests is clear.  If the volume is very large relative to the need identified in the relevant TPP portfolio – including prior queued projects of the same resource type – then: (1) project dropouts would not be undesirable, and in fact would be expected; and (2) it would be unfair and unnecessary to sequence more than the required amount before the rest of the cluster.
3. CAISO should reserve judgement on this issue until it releases the 2022-23 Transmission Plan.  If this TPP cycle already includes upgrades required to support off-shore and OOS wind, then CAISO should not need to prioritize interconnection requests for these resources.  Also, stakeholders will be able to provide more informed opinions on this element of the proposal once they have seen the upgrades CAISO intends to approve.  On the other hand, if CAISO does not approve any upgrades designed to support offshore or OOS wind in this year’s TPP, it would be difficult to justify providing special treatment for these resources in Cluster 15.
4. If CAISO does move forward with providing priority treatment to offshore and OOS wind projects, it should require such projects to provide Site Exclusivity (no in-lieu deposit) to qualify, so that only the most viable projects proceed.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Workshops Needed: For Track 2 proposals, LSA encourages CAISO to hold workshops to vet each element more thoroughly and seek additional stakeholder input before issuing an official proposal.  In particular, LSA encourages CAISO to work closely with developers in addition to Load Serving Entities (LSEs) and CPUC staff to develop workable solutions.  Workshops held between April – June of 2023 would still give CAISO enough time to seek approval at its December meeting.

Preliminary LSA Feedback:  LSA urges the CAISO to consider this proposal more thoroughly in workshops before issuing a formal proposal but offers the following initial feedback.  Based upon preliminary results from the CPUC’s most recent busbar mapping process, it appears that CAISO will need to build new transmission in many of the existing transmission zones, diluting the impact of this proposal.  This element on its own does not seem like a useful step.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

Preliminary LSA Feedback:  LSA urges CAISO to consider this element further in workshops before issuing a formal proposal.  There is an assumption being made that there are enough projects in the queue to meet the state’s requirements, but the attrition rate is unknown at this point.  These workshops must include presentations describing historical viability and attrition rates in Clusters 13 and earlier, and analysis of the potential attrition rates for more recent Cluster 14 and 15 projects.  CAISO and stakeholders need a clear view of the volume of existing viable projects v. the state’s reliability and climate goals before they can decide how to appropriately limit future interconnection applications. 

In addition, the workshops must include presentations from developers about the due diligence involved with preparing viable interconnection requests.  CAISO and stakeholders must understand how developers make these decisions in order to develop credible policies aimed at steering them in a different direction.

If CAISO proceeds with this proposal, the following implementation questions would need to be addressed:

1. What happens if projects in the queue drop out?  CAISO will need a method to determine which project is next in line to backfill failed projects. 
2. If CAISO studies only the volume of projects planned for in the IRP, the projects selected for study then become hyper-critical to each LSE’s ability to comply with IRP procurement mandates, creating a risk of market-power and inflated pricing. 
3. Since LSEs typically shortlist more than the minimum procurement obligation to account for project failures, shouldn’t CAISO also study more than the minimum volume included in the IRP plan?
4. If interconnection requests are limited based on currently planned transmission buildout, how will the CPUC and CAISO determine where there is commercial interest in in areas where Interconnection Requests are not allowed for future IRP/TPP planning cycles?  Without commercial interest signals, the CPUC and CAISO will be missing a significant piece of data needed for transmission planning.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Preliminary LSA Feedback:  LSA does not support CAISO considering this element.  Many LSAs require completed Phase II studies before executing PPAs.  Some require completed Phase II studies as a prerequisite to bid.  Such a proposal does not reflect the way the procurement process relies on interconnection status to assess project viability.  Immediate questions/issues that arise include:

1. If developers must submit projects to LSEs without Phase II study data, how will they provide accurate pricing?
2. If LSEs must shortlist projects without interconnection cost data, how will they determine which projects are most viable?
3. Without Phase II cost/viability data, LSEs will have to negotiate many more PPAs contingent on Phase II study results.  Signing PPAs with so many offramps is not a good proxy for viability and could continue to lead to bloated interconnection queues.  Viability criteria other than interconnection costs would become critical (e.g., Site Exclusivity and permitting), and PPA security deposits would have to be reconsidered. 
4. What is the definition of a PPA?  Is there a minimum term?  A PPA for partial output?  A fuel hedge? A PPA between affiliates? 
5. Marchant projects could not comply with this requirement.  Infrequent as they may be, CAISO should not preclude them from advancing through the study process. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

LSA suggests that stakeholders discuss this question in workshops after the proposal for limiting applications has become clearer and CAISO has provided more information about prime locations and attrition rates.  LSA’s initial feedback, however, is that the market needs a predictable cadence for interconnection requests and allowing CAISO to have discretion about when to open cluster windows could violate open access principles.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

The Proposal seems to ignore the “elephant in the room,” i.e., how to manage the 200+ GW already in the queue.  Though most of this capacity may never be built, it is contributing significantly to the unrealistic study results that the CAISO (and developers) are concerned about. 

LSA has suggested in the past the addition of interim progress milestones (including those related to Site Exclusivity), as well as financial-security forfeit forgiveness and more liberal deliverability transfer rules that could encourage non-viable projects to leave the queue. 

This effort should include consideration of these kinds of measures to eliminate non-viable projects from the existing queue, including the following:

1. One-time Free Withdrawal

CAISO should allow a one-time “free withdrawal” for any project in the queue, with full financial-security release.

2. Increase “Skin In the Game” As Projects Advance

CAISO could consider increasing the dollar amount of deposits Interconnection Customers must provide in lieu of Site Exclusivity after Phase I, or other types of increased commitment as projects advance through CAISO milestones. 

LSA’s support of any increased security obligations is predicated upon CAISO’s ability to provide more transparent and user-friendly information about substations with sufficient transmission/deliverability, and number of available bays at each substation.

3. Add Milestone Requirements

LSA recommends CAISO consider requiring Interconnection Customers with Transmission Plan Deliverability (“TPD”) allocations to achieve development milestones, including Site Exclusivity, to stay in the queue and/or retain their allocations. 

Aside from Site Exclusivity, these additional milestones could include, for example, milestones related to project permitting and commitment for major equipment purchases, as well as start of construction. The workshops recommended above could be used to set realistic, general milestones that projects would be expected to meet.  This would give CAISO the ability to remove projects that are not moving forward and ensure that the limited amount of available deliverability and available bay positions are allocated to projects that are ready and able to use it.

4. Require Site Exclusivity Before Executing an Interconnection Agreement

CAISO should consider requiring pre-Cluster 15 Interconnection Customers to have Site Exclusivity before executing a GIA.  These projects entered the queue without a robust Site Exclusivity requirement but, because of unprecedented volumes of applicants, should not be allowed to continue without it.

5. Expand Opportunities for Transferring Deliverability

CAISO should consider increasing opportunities for projects with deliverability allocations to transfer it to more viable projects.  Interconnection Customers can currently transfer deliverability between projects at the same substation and voltage.  LSA recommends that CAISO also allow limited transfers between projects.  Interconnection Customers could apply for transfer, with those applications assessed in the annual Reassessment process to ensure that the transfer would not trigger new upgrades.  If none, CAISO should allow this transfer to occur.

6. Apply a Viability Assessment to Short-Circuit Triggered Upgrades

Cluster 13 and 14 studies have shown that several long-duration (72+ months) short-circuit upgrades across the CAISO BAA are now being triggered. These are mainly driven by commercial interest that far exceeds the projected portfolio needs.

Therefore, it is safe to assume that most of these short-circuit duty upgrades will not be required to support a realistic resource buildout. LSA recommends that CAISO explore a framework to evaluate which short-circuit duty upgrades are ‘real’ and which ones are ‘phantom’ (similar to how Area Deliverability Network Upgrades are handled by integrating TPP and GIDAP).

7. Publish Ownership Information for Older Projects

It is possible that some older projects are languishing in the queue because of financing or other challenges that could be addressed by selling the project. However, because the queue does not identify the project owner, it is difficult for potential buyers and sellers to find each other. The CAISO should consider publishing ownership information for all projects that have been in the queue longer than 7 years, or at least allow projects to release ownership information on a voluntary basis.  This additional queue data could facilitate project sales that may make some of these projects viable.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

 LSA has no further comments at this time.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

At this time, MCE is not opposed to the CAISO’s Track 1 proposal to accept Cluster 15 interconnection requests during the normal April 2023 window, but delay further Cluster 15 processes until April 2024. MCE understands and appreciates the practical utility of delaying the Cluster 15 process given the anticipated size of the cluster and the workload associated with the studies for Cluster 15 Phase I and Cluster 14 Phase II. MCE cautions, however, that this approach must be implemented in a way that does not unnecessarily limit the number of interconnected and deliverable projects that Load Serving Entities’ (LSE) can procure to meet procurement orders and Resource Adequacy requirements. Given the size of Cluster 14, MCE is optimistic that CAISO’s efforts to resolve the Cluster 14 queue will result in an unprecedented amount of capacity to support LSEs’ procurement needs and encourage sufficient market competition. That said, delays are a short-term fix to a long-term issue. MCE commends the CAISO for proposing a second and critical track for this initiative that will focus on more comprehensive enhancements to the interconnection process to ensure regulatory processes will be able to accommodate anticipated future interconnection requests for capacity needed to meet the state’s reliability and climate goals.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

At this time, MCE does not oppose CAISO’s proposal as part of Track 1 to implement a separate study timeline for offshore and out-of-state wind study requests. This approach is reasonable given state policies and the California Public Utilities Commission’s resource planning activities that indicate a need for both resource types to supplement the aggressive build-out of in-state resources. This separate track may also be important given the unique planning and development characteristics of out-of-state wind and off-shore wind.

However, it is critical that the CAISO take as holistic an approach as possible in pursuing this path. CAISO must ensure that this does not result in prioritization of out-of-state wind and off-shore wind

that would come at the expense or delay of in-state resource studies and development. As with many of CAISO’s proposals in this stakeholder initiative, the CAISO should prioritize enhancements that maximize and accelerate the interconnection process for all viable interconnection requests.

Doing so will reduce LSE risk and incentivize expeditious execution of PPAs that will bring needed projects to fruition.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

At this time, MCE sees merit in CAISO’s proposal to accept or process only interconnection requests where the transmission system has available or existing planned capacity. This enhancement could focus project development in areas most ready for new resources and prioritize the number of projects the CAISO studies to include those that can interconnect with no or minimal additional transmission system upgrades. That said, MCE requests the CAISO also accept or process interconnection requests related to currently interconnected projects that need interconnection upgrades to accommodate added battery storage. Processing these requests could efficiently bring additional capacity onto the system by taking advantage of existing renewable generation that might otherwise be curtailed without interconnection upgrades.

For the benefit of LSEs and developers, it is important for CAISO to be as transparent as possible, as early as possible, about the location of existing or planned transmission, how the CAISO will prioritize zones, and how much existing or planned transmission exists in those zones. This transparency is necessary to guide developers’ siting efforts and inform LSE procurement decisions

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

MCE is not opposed to this enhancement at this time, but requires additional detail from CAISO to be able to evaluate the proposal more thoroughly. To the extent this proposal is advanced, care must be taken to ensure efficient, equitable, and non-discriminatory effects.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

MCE has concerns with the CAISO’s proposal that would require projects to have a signed PPA with an LSE to be shortlisted to proceed to Phase II studies. MCE cautions that this proposal may have unintended consequences that would be disruptive to both LSEs and developers. From MCE’s perspective, requiring such an early-stage PPA under the current circumstances would unreasonably increase LSE risk and costs beyond current levels given the uncertainty around the interconnection process that a project will not ultimately prove viable. As an LSE, MCE relies on a developer to present a project for consideration in MCE’s annual Open Season procurement process. During this process, MCE prioritizes those projects that are farthest along in the interconnection process (i.e. those projects that have the highest probability of meeting MCE’s energy and capacity needs). This prioritization is especially critical given the interconnection and deliverability attributes needed to support near-, mid- and long-term reliability requirements. The interconnection process

enhancements should prioritize all projects that show well in the Phase 1 study. Such an approach will respect the project investments by developers, not drive LSEs to enter into premature and higher-risk PPAs for projects that may not come to fruition, and will also incentivize investment in projects that have the highest probability of succeeding.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

MCE does not have specific comments relevant to this prompt except to emphasize that the CAISO’s approach must prioritize efficient processing of as many viable interconnection requests as possible given the expectation that LSEs will continue to procure aggressively over the mid- and long-term to meet the state’s reliability and emissions goals

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

MCE has no comments responsive to this prompt at this time.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

MCE has no comments responsive to this prompt at this time.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

MRP respectfully urges the CAISO to open the Cluster 15 Interconnection Request (“IR”) window on April 3 and close it on April 17.  Developers have worked and incurred expenses to have projects ready to submit in this upcoming window and delaying the Cluster 15 window would negatively affect and disadvantage them.

MRP also supports the CAISO’s proposal to assess and validate the completeness of IRs submitted in this window by May 1, 2023.  MRP does not support delaying the validation of Cluster 15 projects to 2024.  In any case, delaying project validation to 2024 and then reopening Cluster 15 in early 2024 would effectively amount to keeping the Cluster 15 window open through 2023.

Finally, MRP does not support the CAISO’s proposal to restart the Cluster 15 process on April 1, 2024.  Reopening Cluster 15 at that time seems a recipe for realizing yet another overloaded “supercluster” of projects that will propagate process and interconnection delays to later clusters.   

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

The Issue Paper and Straw Proposal (“IPSP") notes California’s policy preference for off-shore wind (“OSW”) and out-of-state wind (“OOSW”) to diversify California’s solar-heavy and storage-heavy resource mix.  The IPSP also offers that any delays in the Cluster 15 schedule may adversely affect the development of these diversifying resources.  Consequently, the IPSP posits the possibility of studying OSW and OOSW separately from the upcoming Cluster 15 study process.  While it may be prudent and appropriate to diversify the resource mix, separate interconnection and transmission planning processes dedicated only to certain resources do not align with the principle of non-discriminatory access to the transmission system that is the CAISO’s core raison d’etre.[1] 

[1] See, e.g., FERC Order 888, 75 FERC ¶61,080 (1996), at page 50 (“Non-discriminatory open access to transmission services is critical to the full development of competitive wholesale generation markets and the lower consumer prices achievable through such competition.”)

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

MRP does not support this proposal. Such a process is not in keeping with FERC’s Order 888 in which FERC states “…in the event the [transmission] system is constrained, based on duration of the underlying firm service request; customers may choose the "firmness" of service they want by electing to take non-firm service, or by reserving and paying for firm service”[1] (emphasis added). FERC goes on later to state “utilities are free to propose and fully support different reservation priority provisions for firm service in subsequent rate filings as long as those provisions are not unduly discriminatory”[2] (emphasis added). As per FERC’s Order 888, the “customer” is the party that decides what type of service it is requesting. If the transmission system does not have any available or planned capacity, the “customer” could select to submit an Energy Only interconnection request that would not require additional transmission capacity. Restricting the ability of a “customer” to submit an interconnection request even when there is no transmission capacity available prohibits the ”customer” from choosing to submit an Energy Only interconnection request, or to if it is willing to pay for the transmission capacity required for its interconnection request. The only right that FERC has granted to “utilities” is the right of determining how it prioritizes such requests on a non-discriminatory basis.     

[1] FERC Order 888 at page 329.

[2] Id.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

As noted in the previous answer, MRP would not support such a proposal.  Moreover, under such a proposal, if there are IRs seeking more interconnection and network capacity than existed in or was planned for that area, the CAISO would have to develop and apply some non-discriminatory way to decide which IRs are accepted and which are not.  MRP envisions that developing that process would be a difficult and contentious.process.  

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

MRP supports this proposal. In general, MRP supports proposals that would require more stringent requirements to demonstrate project viability, both commercial and site control viability, even before allowing an IR to be submitted.  MRP believes this practice, which parallels requirements in other ISOs, would help cool off the CAISO’s over-heated interconnection queue. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

MRP does not support this proposal.  It is reasonable to expect that the CAISO and PTOs will be flooded with IRs once the IR window is reopened after being closed for a period, creating yet another supercluster of projects that will be difficult to process and work through.   Moreover, setting the threshold at which the CAISO would begin accepting IRs again is likely to be a contentious and somewhat arbitrary process, and may not align with the realities of the time to either i) develop the generation resources and/or ii) develop the necessary interconnection facilities and network upgrades to support the generation resources.  It is also unclear to MRP how this limit would apply to and affect the project modification process in cases where a Modification Request was found to be material. Projects should still retain the ability to submit a Cluster IR each year to address modification related needs.  Finally, this restriction would diminish incentives to the CAISO and PTOs to hire additional staff to facilitate a well-functioning, non-discriminatory interconnection process.  

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

MRP respectfully urges the CAISO to consider the following:

1. An interconnection process that includes:
   1. An initial “feasibility study” or “screening study” process that is run prior to any Queue Cluster interconnection process.  This screening study would include power-flow and transfer studies and would be based on the expected in-service year of the proposed generation resource in order to provide meaningful information to generation developers so that they can make the determination whether to submit a formal Queue Cluster interconnection request.  This study would also identify any potential generation dispatch limitations based on the site proposed by the interconnection customer.
      1. The results of the “feasibility” or “screening” study would indicate the level at which the proposed generation could expect to operate simultaneously with other known generation in the area before significant transmission additions or enhancements may be required.
      2. The “customer” would then be given a period to consider whether It should submit an Interconnection Request during the next Queue Cluster Open Window.
2. An ERCOT-style approach in which the transmission needed to connect resources in designated renewables energy zones is socialized across CAISO demand; and
3. A change in the transmission upgrade cost allocation in which generation developers are responsible only for the interconnection facilities costs for their projects, and all network upgrade costs are allocated to load via the CAISO Transmission Access Charge.   

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

MRP observes that the factors contributing to the current untenable interconnection situation are (1) the different timelines applicable to transmission and generation development, with generation development timelines a quarter to a third of transmission development timelines; (2) California’s inability, analogous to the recent chronic inability to timely develop generating resources that spawned three recent ad hoc procurement directives, to develop transmission resources sufficient to accommodate the resource buildout that was predictably required to accomplish state policy goals; (3) the lack of CAISO and PTO staff or outside consultant services sufficient to handle the surge in IRs; and (4) an interconnection process that does not provide sufficient information, screens and incentives to limit IRs to only viable and efficient generation projects.   As a result, the CAISO appears to be poised to move away from non-discriminatory interconnection processes towards processes that favor certain resources in certain locations.  MRP hopes that this outcome is not inevitable, and the CAISO and stakeholders can retain a timely-functioning non-discriminatory interconnection process at the same time they address the problems with the current process.  

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

New Leaf Energy, Inc. (“New Leaf Energy”), an independent developer of solar and energy storage that was recently spun out of solar and storage developer Borrego, thanks the CAISO for the opportunity to provide these comments. New Leaf Energy intends to be an active participant in this Interconnection Process Enhancements 2023 stakeholder initiative.

Section 2 of the 2023 Interconnection Process Enhancements Issue Paper and Straw Proposal issued on March 6, 2023 (“Issue Paper”) proposes a series of changes to the timing of Cluster 15. New Leaf Energy supports these proposals and provides additional feedback.

A. Proposed Cluster 15 Timing is Well-Justified

New Leaf Energy supports the CAISO’s approach to the timing of Cluster 15, as described in the Issue Paper and as adopted in the CAISO’s March 15, 2023 Notice.[1] New Leaf Energy agrees that the CAISO has laid out the best path forward: to accept Cluster 15 Interconnection Requests (“IRs”) during the anticipated April 3-17, 2023 window; to conduct the completeness review prior to May 1, 2023; and then to pause further activity on Cluster 15 until the Cluster 14 Phase II studies and results meetings have been completed. This will ensure that the results of Cluster 14 are reflected in the Cluster 15 studies and that CAISO resources, for the next year, are appropriately focused on ensuring that Cluster 14 projects continue to advance. New Leaf Energy supports the CAISO’s decision to prioritize advancing the Cluster 14 study process and appreciates the determination that no changes should be made to the existing timeline or rules governing Cluster 14.

B. Cluster 15 IRs Must Face Few Barriers to Withdrawal

The CAISO suggests that Cluster 15 IRs will have the opportunity to withdraw “for minimal or no cost  at any time until study work begins.”[2] Given the magnitude of changes that Track 2 of this initiative contemplates, New Leaf Energy agrees that no or low barriers to IR withdrawal are essential. The cost to withdrawing prior to Cluster 15 project validation should be no more than the costs associated with the completeness review. This will ensure that developers are not penalized for having submitted IRs that are out of alignment with the as-yet-to-be-determined rules governing Cluster 15. It will also help the CAISO to see a reduced volume of Cluster 15 IRs that choose to enter the study process.

C. Queue Withdrawal Opportunity Should Not Be Limited to Cluster 15

The Issue Paper makes evident that the CAISO is facing an unprecedented quantity of new IRs while also managing a substantial number of IRs in earlier Clusters that have completed the study process, including those that have received Transmission Plan Deliverability (“TPD”) and have yet to come online. While many of these projects are making good faith progress, others may be non-viable. New Leaf Energy suggests that the CAISO create a one-time window in early 2024 in which certain projects, such as those with executed Generator Interconnection Agreements (“GIAs”), or potentially all projects in the queue – along with IRs that have entered Cluster 15 – would be afforded a low- or no-cost opportunity to withdraw from the queue. This will ensure that future studies reflect a more accurate view of what is already on the system. It will also encourage developers to focus their efforts only on their most promising projects.

New Leaf Energy acknowledges that the CAISO risks creating moral hazard if the interconnection process requirements and deposits are seen as flexible, but believes that the benefits of a one-time exit window at this moment in time exceed the risks. New Leaf Energy encourages further discussion of what parameters would ensure that this does not inadvertently incentivize more speculative IRs in the future.

D. Opportunities to “Refresh” Cluster 15 IRs Must Be Limited

In addition to low- or no-cost withdrawal, the CAISO proposes to allow Cluster 15 projects to “refresh” their IRs by “making certain modifications,” which are unspecified.[3] New Leaf Energy appreciates the flexibility that the CAISO seeks to offer to developers but encourages the CAISO to limit the scope of allowable modifications. Project developers that did their homework ahead of the 2023 Cluster 15 IR window should not be effectively penalized if the promising POI locations they selected are later “goldrushed” by “refreshed” IRs in 2024.

For example, if a Cluster 15 IR reflects months of analysis of the transmission system to select a POI that then shows up in the mapping that may be published during the course of the Track 2 reforms, one can expect dozens of other IRs to “refresh” to that POI if allowed. Suddenly, the developer whose initial Cluster 15 IR better reflected system needs finds its application swamped by a surge of latecomers.

In short, any limitless ability change POI will create a free-for-all that does not serve the CAISO’s goal of encouraging targeted project development and will materially increase the CAISO’s workload. At minimum, the CAISO should prohibit POI “refreshes” to POIs where there are already Cluster 15 IRs or give those original IRs seniority in the study process.

For the same reasons, New Leaf Energy believes the only permissible size change during the 2024 “refresh” period should be a size decrease. It would be unreasonable to, for example, allow an IR for a 100 MW solar project in Fresno County to “refresh” itself to become a 500 MW project in San Diego County.

[1] CAISO Notice (March 15, 2023), available at: http://www.caiso.com/Documents/interconnection-process-enhancements-2023-issue-paper-straw-proposal-stakeholder-comment-template-posted.html.

[2] Issue Paper, p. 9.

[3] Issue Paper, p. 9.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

In Section 2, under “Other Issues for Consideration,” the CAISO suggests that offshore and out-of-state wind projects, which have long lead times and are identified in state planning portfolios, may merit their own study sequenced ahead of other IRs. Effectively, this would create a first-round “Cluster 15A” study for offshore and out-of-state wind and a later “Cluster 15B” study process for all other resources.

New Leaf Energy strongly opposes any proposal to advantage IRs of one technology and location over others submitted concurrently. The CAISO should approach such a proposal with utmost caution given that, as stated on the March 13, 2023 stakeholder call, it has never before taken such a step. And rightfully so – creating carveouts or preferences for specific kinds of projects entering its study process would violate open access principles.[1]

Moreover, New Leaf Energy questions whether such a move would actually help long lead-time projects advance. After all, long lead-time resources are characterized as such given their long development and construction timelines and, as the CAISO has stated, the reasons for those long timelines go well beyond interconnection issues. Thus, it is not clear why they would need to have their studies conducted ahead of other Cluster 15 IRs. It could be more impactful to find a fairly structured way to afford these projects more than the standard seven years to interconnect, rather than give them special status at the very beginning of the process.

Further, the CAISO has not made the case that reliability depends on implementing such a significant deviation from longstanding best practice.

Finally, New Leaf Energy notes that offshore wind projects are advancing through the East Coast RTOs’ standard study processes – and, indeed, through the CAISO queue itself – without special advantages or carveouts. For example, there are four offshore wind projects totaling 3.9 GW in ISO-New England that have executed interconnection agreements using the same study process as all other resources.[2]

[1] It is a core principle of the Federal Power Act that the Commission must ensure all rates to be just and reasonable and that “no public utility…with respect to any transmission or sale…subject any person to any undue prejudice or disadvantage” or “maintain any unreasonable difference in rates, charges, service, facilities, or in any other respect, either as between localities or as between classes of service.” See 16 U.S.C. §§ 824d(a)-(b); see also S. Carolina Pub. Serv. Auth. v. FERC, 762 F.3d 41, 49 (D.C. Cir. 2014). Rates or practices are unduly discriminatory when they treat similarly-situated customers differently. Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services, 119 FERC ¶ 61,295 at P 963 (2007) (“The standard for judging undue discrimination…has always been: disparate rates or service for similarly situated customers”); Elec. Consumers Res. Council v. FERC, 747 F.2d 1511, 1515 (D.C. Cir. 1984) (“If a rate design has different effects on charges for similar service to similar customers, the utility bears the burden of justifying these different effects”).

[2] ISO-New England Interconnection Request Queue (accessed March 22, 2023), available at: https://www.iso-ne.com/system-planning/interconnection-service/interconnection-request-queue/.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

New Leaf Energy understands the CAISO’s desire to ensure that its study process hews as closely as possible to the state’s resource planning process. However, there are a number of concerns with the approach identified in Section 3.1, in which the CAISO would only accept or process IRs in certain areas identified in the CPUC’s Integrated Resource Planning (“IRP”) process.

A. Open Access Principles Must Be Upheld

By precluding certain IRs from even entering the study process, the CAISO risks violating open access principles.[1] Open access to the bulk energy system is foundational to the existence of any ISO/RTO, and New Leaf Energy urges CAISO to continue its long-standing adherence to those principles.

B. The Process Must Enable Merchant and Energy-Only Projects to Advance

New Leaf Energy appreciates the CAISO’s desire to ensure that resources being developed for the Resource Adequacy (“RA”) program (and therefore requiring deliverability) should be targeted at areas where deliverability is anticipated to become available. However, not every project entering the CAISO’s study process is seeking an RA contract or even a PPA. Though infrequent to date, the CAISO cannot exclude fully merchant resources from entering and advancing through its study process.

C. CAISO Must Establish an Appeals Process

If the CAISO decides to move ahead with limiting IRs to certain areas of the system, it must establish a process by which developers can appeal a determination that their projects were excluded from the study process. There must be a way for developers to demonstrate to the CAISO that while a project may not be geographically within a certain area, it is electrically positioned to succeed based on current and planned transmission infrastructure.

D. CAISO Should Convene Stakeholder Workshops

Finally, as a general matter, New Leaf Energy recommends the CAISO convene focused stakeholder workshops during Track 2 of this initiative, as it has done before in complex and high-profile stakeholder processes (e.g. the Extended Day-Ahead Market [“EDAM”]). Track 2 will substantially remake the process of developing and interconnecting renewable resources in California. New Leaf Energy believes that a series of workshops during Track 2, each focused on one of the four elements contemplated in the Issue Paper, would ensure that a variety of viewpoints are heard and that proposals are sufficiently vetted.

[1] The principles of open access require “non-discriminatory treatment for all eligible users of the transmission system.” Calif. Indep. Sys. Operator Corp., 168 FERC ¶ 61,105 at P 13 (2019). The concept of fair, non-discriminatory and open access to transmission service was one of the core rationales behind the Commission’s creation of the Open Access Transmission Tariff (“OATT”) with Order No. 888 and maintaining open and non-discriminatory treatment has been the justification for nearly all subsequent rulemakings on the OATT, including those pertaining to interconnection service. See Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission on Servs. by Pub. Utils; Recovery of Stranded Costs by Pub. Utils. & Transmitting Utils., Order No. 888, 61 FR 21540 (May 10, 1996), FERC Stats. & Regs. ¶ 31,036 (1996), on reh’g, Order No. 888-A, FERC Stats. & Regs. ¶ 61,048, on reh’g, Order No. 888-B, 81 FERC ¶ 61,248 (1997), on reh’g, Order No. 888-C, 82 FERC ¶ 61,046 (1998), aff’d sub nom. New York v. FERC, 535 U.S. 1 (2002); Standardization of Large Generator Interconnection Agreements & Proc, Order No. 2003, 68 FR 49845 (Aug. 19, 2003), 104 FERC ¶ 61,103 at P 9 (2003) (stating that interconnection “is a critical component of open access transmission service and thus is subject to the requirement that utilities offer comparable service under the OATT”) citing Tenn. Power Co., 90 FERC ¶ 61,238 (2002); see also Improvements to Generator Interconnection Procedures and Agreements, Notice of Proposed Rulemaking, 179 FERC ¶ 61,194 at P 22 (2022) (proposing changes to the pro forma LGIP, LGIA, SGIP and SGIA to ensure “interconnection customers are able to interconnect to the transmission system in a reliable, efficient, transparent, and timely manner, thereby ensuring that rates, terms, and conditions for Commission-jurisdictional services remain just and reasonable and not unduly discriminatory or preferential”).

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

In Section 3.2 of the Issue Paper, CAISO expresses concern about the volume of IRs it is receiving, including those that are sufficiently targeted to ideal areas of project development.

A. CAISO Must Account for Project Attrition

The Issue Paper seems to contemplate that the CAISO would study only the quantity of MWs in a given area that have been identified in the CPUC’s IRP process. However, this fails to account for the historical project attrition rate.

In a white paper attached to its January 4, 2023 comments in the CAISO’s Generation Deliverability Methodology Review Initiative, Golden State Clean Energy reports that, prior to Cluster 14, only 6.3% of all IR capacity that CAISO has studied ultimately reached commercial operation.[1] If one were to apply this historical attrition rate to the queue, the CAISO would need to allow 15.8 times the quantity of MWs shown in the IRP for a particular zone.

Even if we assume that much – even most – of the IR capacity that fails to reach commercial operation is due to failure to obtain deliverability through the CAISO’s interconnection process, there is also a great proportion of projects that fail to reach commercial operation due to challenges with permitting and other project development challenges. For example. the opposition of neighbors and local communities to new energy infrastructure ( “NIMBYism”) is a major impediment to project development. This does not mean that the developers failed to invest in their pre-IR work, had shoddy development hypotheses, or otherwise failed to approach their projects with the rigor that CAISO expects. Rather, it reflects the complexity and multitude of obstacles that even projects that are otherwise desirable from an economic and transmission perspective encounter in trying to reach completion. Thus, New Leaf Energy concludes that it will be difficult for the CAISO to be quite so surgical in applying the CPUC’s IRP outputs to its queue process. In determining the quantity of capacity that is permitted to enter the queue in a given area, perhaps the multiplier doesn’t need to be 15.8x, but it will need to be something substantially higher than 1.0x.

B. CAISO May Inadvertently Create Market Power Risk

If CAISO limits the capacity entering the study process for a given area to just the quantity of MWs shown in the busbar mapping process, the owners of those projects will be well aware of the critical role they play in the LSEs’ own planning processes. These projects will have a significant amount of market power in negotiations with LSEs, to the detriment of ratepayers.   

C. CAISO Will Still Have to Artificially Limit the Volume of IRs

It is likely that once certain areas of the grid are identified as most desirable, the market will respond and project development efforts in those regions will be robust. In that case, the CAISO will need to set up a mechanism to determine which projects get studied. For example, if a given area is identified as ideal for 1,000 MW of solar plus storage and 5,000 MW of projects show up, which ones will get into the study cluster?

[1] Golden State Clean Energy, “White Paper: Reliably Meeting California’s Policy Goals – Building for the Future,” p. 5, (September 2022), available at: https://stakeholdercenter.caiso.com/Common/DownloadFile/b1a689a2-b57f-415e-8dee-1ec17cd49b23.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

New Leaf Energy opposes the proposal in Section 3.3 that projects would be required to have a PPA or be shortlisted to enter the Phase II Study.

A. Requiring PPAs Too Early Will Inadvertently Render Those PPAs Worthless

The costs and timelines associated with interconnection are critical ingredients in a PPA. With only Phase I study results in hand, project developers will not have sufficient information to bid accurately sign PPAs, unless the contracts contain so many offramps that the PPAs themselves will no longer be the meaningful milestones that the CAISO hopes they will be.

B. The Process Must Enable Merchant Projects to Advance

As stated above, New Leaf Energy cautions that not every project entering the CAISO’s study process is seeking a PPA, at least at the outset. Though they might be infrequent now, the CAISO cannot exclude fully merchant projects from advancing through its study process.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

In Section 3.4 of the Issue Paper, the CAISO considers whether, after Cluster 15, it should only open future IR windows “when warranted” and seeks feedback on what criteria should trigger a new Cluster.

New Leaf Energy opposes leaving the determination entirely to the CAISO’s discretion. This would appear to violate open access principles.[1] Moreover, it could be inadvertently anti-competitive, preventing robust competition from newer resources from pushing older, less efficient generators out of the market.

Instead, a new IR window should be triggered on a defined cadence, at a date certain, or when the prior Cluster reaches a specific, transparent study milestone. New Leaf Energy suggests that stakeholders could present models that have proven successful in other RTOs in a workshop. For example, PJM recently adopted a new framework for its interconnection process in which a new Cluster (called a “cycle”) is triggered at the conclusion of Phase I of the prior Cluster/cycle. At that point, the application deadline will be at least 180 days later.[2] This framework is less predictable than an annual date, but may be sufficiently transparent and ensures that the results from one Cluster study would get into the models for the next one.

[1] See Footnote 1 for Question 3.

[2] “PJM Interconnection Process Reform” (April 27, 2022), p. 21, available at: https://pjm.com/-/media/committees-groups/committees/mrc/2022/20220427/20220427-item-02a-interconnection-process-reform-presentation.ashx. “Application deadline of the subsequent cycle will be announced 180 days in advance at the conclusion of Phase 1 - IC D1 of the most recent cycle.”

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

While New Leaf Energy has expressed concern about many of the ideas floated in the Issue Paper, it has also identified reasonable measures that the CAISO could adopt to improve accountability throughout the development cycle.

For example, site exclusivity demonstrates continued intent to reach commercial operation. The CAISO requires that a project sited on private property have site exclusivity or provide a security deposit in lieu of site exclusivity. However, demonstration of site exclusivity requires a right to build on only “50% of the acreage reasonably necessary to accommodate the Generating Facility.”[1] For projects choosing the site exclusivity pathway, New Leaf Energy notes that 50% is one of the lowest thresholds in the country. By increasing the site exclusivity requirement to 80%, the CAISO would ensure that more project development work was done on the front end of the process in a way that is still fair and reasonable.

Additionally, the CAISO should consider requiring projects that entered the queue prior to Cluster 15 to demonstrate a similar level of site exclusivity – with sufficient duration – before executing a GIA (with sufficient advance notice afforded to them of this new requirement).

[1] CAISO Tariff, Appendix A

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

New Leaf Energy understands the scale of the workload that is facing the CAISO in Cluster 14 and is anticipated in Cluster 15. It appreciates that the reforms offered in the Issue Paper and those that will be discussed throughout this initiative are intended to ensure that the CAISO’s resources are used wisely in pursuit of the state’s reliability, affordability, and greenhouse gas reduction objectives. New Leaf Energy supports these goals and increased attention to minimizing speculative IRs. New Leaf Energy applauds the CAISO for continuing to execute high-quality work in the face of mounting pressures.

Although it is a severe and unprecedented challenge, New Leaf Energy encourages the CAISO to prepare for this new reality. As project developers across multiple industries respond to market and regulatory signals, it seems unlikely that the quantity of IRs in Cluster 14 and those anticipated in Cluster 15 are an aberration. After all, the CPUC’s recommended base case portfolio for the 2023-2024 TPP includes 86 gigawatts (“GW”) of new resources by 2035[1]  – some of which are undoubtedly in prior Clusters, but many of which may not be.

The CPUC states, “This is more than a doubling of nameplate capacity on the system within 12 years.”[2] This communicates a high level of demand in California for new clean transmission-connected resources will be robust over the next decade or so. The 2022 enactment of the federal Inflation Reduction Act (“IRA”) has brought new investment and attention to project development. Each of the renewable energy industries is diverse and competitive, meaning that there are dozens of companies competing to bring the best projects forward for California.

New Leaf Energy suggests that these market and regulatory signals are unlikely to diminish in the near future. Thus, in addition to pursuing enhancements to its interconnection process enhancements, New Leaf Energy encourages the CAISO to continue its preparations to achieve the level of staffing, consultant capacity, and technical expertise that will be needed for a future where heightened interest in developing new large-scale renewable resources is the norm and even the likely outcome of the market signals that the state and federal government are sending. New Leaf Energy recognizes that the CAISO is already making its best efforts to hire and retain the requisite workforce at this unprecedented time in the energy industry. New Leaf Energy is committed to working with the CAISO to elevate awareness of this challenge to relevant stakeholders and to exploring ideas for workforce development programs and other potential solutions to this challenge.

In conclusion, New Leaf Energy thanks the CAISO for its thoughtful engagement on these important issues and for its consideration of these comments. New Leaf Energy looks forward to participating in this important stakeholder process.

[1] CPUC Decision 23-02-040 (issued February 28, 2023), p. 48, available at: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M502/K956/502956567.PDF.

[2] Id., p. 47.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

NextEra Energy Resources, LLC (NextEra) appreciates the opportunity to provide comments on the CAISO 2023 Interconnection Process Enhancements (“IPE”) issue paper and straw proposal. While Cluster 14 studies continue, three modifications to the interconnection request timeline for Cluster 15 are proposed:

1. Accept Cluster 15 interconnection requests during April 3 – April 17 open window
2. Perform the interconnection request completeness review by May 1, 2023
3. Postpone validation of Cluster 15 interconnections and project scoping meetings – restarting the review and study process on April 1, 2024

NextEra generally supports these three modifications for Cluster 15 interconnection submissions along with a few additions. CAISO should provide additional information about how withdrawals, refunds, and project modifications will be handled between now and April 1, 2024. This will require CAISO to establish withdrawal windows, deposit refund procedures, and project modification request processes. The inclusion of these procedures is especially important since delays in the start of the study process often impact the version of equipment used (e.g., inverters, wind turbines, and other generation technologies).

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

NextEra supports identifying long-lead time network upgrades required as CAISO expands its footprint but requests further clarification on which projects/ technologies (i.e., offshore wind and out-of-state wind) will be included in special studies, as well as the timeline and process for such studies. NextEra also recommends that CAISO review the impact, if any, of special studies on the interconnection queue study process.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

NextEra supports CAISO’s identification of areas and zones where the transmission system has available existing or planned capacity.  CAISO should not, however, limit or confine interconnection requests to these areas. Developers attempt to site projects in locations with proximity to transmission, but nevertheless face other project constraints such as land use restrictions, land costs, wind/solar resource quality, environmental limitations, etc. Focusing on certain CAISO areas or zones for Phase 1 studies further risks ignoring commercial opportunities for incremental generation projects that the CAISO did not forecast due to timing or lack of data at the time of the CAISO study.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

NextEra supports the establishment of screening criteria, but requests that CAISO provide information and provide an opportunity for stakeholder comment on suggested screening criteria and how the auction would operate.  Screening criteria could include a score based on success of previous interconnection projects, number of projects and/or megawatts a developer has operating within the CAISO region, financial strength, operational experience, and ability to provide site exclusivity. The auction could award additional points based on these criteria in addition to the price offered to secure the available capacity.

Projects not selected based on the screening criteria or auction should not be rejected and forced to restart the process. Instead, those projects should have the opportunity to post an additional study deposit or financial security to remain in the queue.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

NextEra understands CAISO’s desire to focus on the most commercially advanced projects for prioritization. Because Phase 1 studies are an unreliable indication of the extent of upgrade requirements, cost, and timing, responsible developers typically do not or should not bid projects until Phase 2 study results are known. Requiring a PPA with only a Phase 1 study result would subject the interconnection customer and the LSE to unknown risks, and such added risk would ultimately result in increased costs for customers. Furthermore, since Full Capacity Deliverability Status (“FCDS”) is not known until after Phase 2, commercial terms surrounding resource adequacy eligibility make participating in competitive solicitations challenging. For these reasons, NextEra does not recommend requiring a PPA or shortlist before Phase 2.

While NextEra opposes a shortlist and PPA requirement after Phase 1 studies, it supports the concept of demonstration of a commercial interest 6-months after issuance of Phase 2 studies. This demonstration should apply both on a going forward basis and retroactively to Cluster 14 projects since Phase 2 studies are not yet released giving developers ample notice of forthcoming regulatory requirements.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

CAISO should not limit opening the Interconnection Request window only when warranted. It takes a significant amount of time and advanced planning to develop interconnection requests. The Interconnection Request window ought not be a guessing game. Only opening the next window when warranted fails to provide developers information necessary to advance projects and could lead to customers that are left without the generation projects or PPAs they desire.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

NextEra suggests an alternative element that includes improving the efficiency of the interconnection process through automation and standardization of studies. Several aspects of the study can be automated, which would reduce the overall study time and relieve the demand on Participating Transmission Owners (PTO) and CAISO staff. Other RTOs are currently implementing automation tools and software for validation early in the interconnection process. Additional work will be performed by Amazon Web Services (AWS) on automating the interconnection model building process and using cloud computing to execute studies in each phase of the interconnection study process.  Further, automation and standardization also provide certainty of cost and schedule to the interconnection.[1]

NextEra also suggests an additional element that involves increasing the cost of entry into the queue process as well as increasing the amount of financial security posted through Phase 1 of the study process. The number of projects currently in the queue attests to the problem that the hurdle to entry is too low. Furthermore, the CAISO study deposit posting constitutes a small fraction of total project development costs; therefore, the most effective solution is to establish deposit levels that escalate throughout the interconnection process providing developers the incentive to withdraw early if their commercial prospects are poor, permitting is troubled, or the upgrade cost and timeline do not support project development.  

Increased study deposits ought to be similar to what is being proposed in the FERC Notice of Proposed Rulemaking – Improvements to Generator Interconnection Procedures and Agreements[2] and what is currently implemented in both MISO and SPP. Recently, FERC approved SPP’s updates to its Generation Interconnection Procedures[3] to increase the study deposit for entry based on the size of the project that becomes more non-refundable as the project proceeds through the study process. CAISO should increase study deposits based on project MW size.  The financial security and the non-refundable amount also should increase as the project proceeds through the stages of the interconnection process. In addition to adopting higher financial security requirements, CAISO should consider a one-time ability of project developers to exit the current queue for any reason, cost free.

Similarly, NextEra recommends accelerating the timeline for when network upgrade payments are required. Paying for network upgrades earlier in the process would incentivize developers to assess project viability sooner and make decisions as to proceed or withdraw. CAISO also should evaluate increasing the security posting amounts to a higher percentage of network upgrade cost after each of the study phases, and increasing the amount at risk, including up to a complete loss if the project does not come online.

Finally, CAISO should implement stronger site exclusivity requirements based on the generation technology and site control requirements for generation-tie lines and substations (with an in lieu of financial security deposit as an alternative).

[1] ACORE comments on interconnection process improvements - https://acore.org/acore-submits-comments-to-ferc-on-proposed-interconnection-reforms/ and ACORE 2022 Grid Forum Presentation on Interconnection Improvements - https://acore.org/acore-grid-forum-2022/

[2] https://www.ferc.gov/media/rm22-14-000

[3] SPP Generation Interconnection Procedures - https://opsportal.spp.org/documents/studies/SPP%20Tariff%20Attachment%20V%20Generator%20Interconnection%20Procedures.pdf

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

CAISO suggested that working groups could be used in this initiative. NextEra supports the use of working groups for Track 2; however, the use of working groups should not delay the process past the April 1, 2024 restart date.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

While we understand the need to devote more resources to completing Phase II of Cluster 14, we believe that simply delaying the kickoff of the Cluster 15 study process another year is unfair, uncompetitive, and effectively uses a hammer to solve what could be fixed with a scalpel. We’d ask that CAISO consider the following impacts on the proposed handling of Cluster 15 interconnection requests:

• Delaying Cluster 15 will prohibit a more diverse and competitive resource mix form entering the queue, therefore limiting the types of resources LSEs can procure to projects that were conceived prior to major macroeconomic and technological changes since the start of Cluster 14 in 2021. For example, the Inflation Reduction Act (“IRA”) became law in 2022, and it was impossible for Cluster 14 and earlier projects to be planned and sited to account for geographical, technological, and other benefits provided by the law. A delay to Cluster 15 will effectively deny most California ratepayers the timely benefits of well-sited projects which take advantage of maximized IRA subsidies making California’s energy transition significantly more costly for ratepayers. In addition, the IRA has unlocked a clear commercialization path for new generation fuels and technologies, such as green hydrogen, which can provide more grid reliability benefits than wind and solar. Delaying Cluster 15 would jeopardize an opportunity to quickly deploy green hydrogen-fueled generation, which provides firm greenhouse gas-free dispatchable power.
• Delaying Cluster 15 risks making greenfield development in the CAISO footprint significantly riskier and more expensive for future clusters. A proposed delay to Cluster 15 so close to the Cluster 15 application window sends a signal that the CAISO development market at any time could become “closed for business” and making it challenging for developers to dedicate resources to this market. Given the immense forecasted load growth due to the electrification of the transportation and building sectors, this dynamic could pose a serious threat to future grid reliability given massive new resources that will be needed to be “at the ready” in the queue to interconnect and meet this market need. Fewer projects than required will be able to navigate this challenging environment and those assets will require a scarcity premium which adds costs to ratepayers.
• Delaying Cluster 15 weeks prior to the already scheduled opening severely disadvantages new entrants in the market and will result in significant economic damage to market participants who made strategic investments and business decisions utilizing the CAISO’s planned Cluster 15 schedule. All successful Cluster 15 projects will need to bear the additional costs of any delay, which will result in less competitive and economic projects and will ultimately be borne by ratepayers years down the road.

We recognize the difficulty of this situation and suggest the following modifications to the proposed delay of Cluster 15:

• Keep the original Cluster 15 timeline, but expedite the Phase I studies for projects that fall within a Local Capacity Region (“LCR”) and are needed to maintain reliability. This also promotes resource competition in the LCR areas, which should help reduce the cost of capacity in these areas of critical need.
• If the start of Phase I studies are delayed, ensure that study and in-lieu of site control deposits are fully refundable until the Phase I studies for Cluster 15 commence.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Like offshore and out-of-state wind, Nightpeak believes that green hydrogen fueled power generation is also a long-lead time resource and faces many similar development and technological promises and challenges while providing superior reliability benefits. Just like offshore wind, massive new infrastructure, such as fuel pipelines and manufacturing facilities, will also be needed to support green hydrogen power plants- something that’s a key focus and high priority at the state level as evidenced through official working groups (ARCHES) and recent CPUC orders. New hydrogen power plants need interconnection timeline and cost certainty now so that fueling infrastructure can be planned and built out to achieve SB100 goals while maintaining grid reliability. In addition, commercialization of green hydrogen for power generation has only recently been enabled by the Inflation Reduction Act (IRA) of 2022, which is why Cluster 15 will be the first cluster to have a meaningful amount of serious green hydrogen apply for interconnection. It would be a mistake to delay or impair the development of this key, and recently economic, reliable dispatchable greenhouse gas-free technology.

Should CAISO study different resources on different timelines, Nightpeak proposes that CAISO adopt a two-pronged schedule for Cluster 15 (i.e. Cluster 15a and Cluster 15b), but suggests that CAISO slightly modify its criterion for resources to qualify for Cluster 15a to include green hydrogen fueled generation. This modification should be made to align with the CPUC’s stated procurement goals for different types of long lead-time resources. Our suggested pathway to modify Section 2’s Other Issues for Consideration is:

• Include other generation technologies besides just offshore and out-of-state wind to qualify for Cluster 15a, except if the primary fuel or generation technology for that resource is already represented in the current interconnection queue above a certain percent threshold (i.e. stand-alone battery, solar, in-state wind would not qualify since it’s well represented in the queue)
• Qualify resources for Cluster 15a that meet the criteria of a “long lead-time” per the CPUC’s definition in D. 21-06-035. Nightpeak concedes that this approach would likely lead to a large number of applications from stand-alone batteries that could qualify as long-duration storage by simply adding more duration to similar battery project. We therefore further propose that CAISO limit the technologies that can qualify under this expedited provision to those who meet the criteria in section (b) of the long lead-time definition: “generation capacity that has no on-site emissions or is eligible under the requirements of the renewables portfolio standard program, and has at least an 80 percent capacity factor. The resource must not be use limited or weather dependent. No storage projects shall qualify under this provision.” We believe that green hydrogen fueled generation fits the criteria.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

We are generally supportive of a priority approach to study resources in areas identified by transmission plans, but not an all-out exclusion for those requesting to interconnect outside of the planning areas. Closing off certain geographies from development could run the risk of under-investment in areas of the CAISO grid that may have a future need, or which are disproportionately subsidized by the Inflation Reduction Act.

If projects can only interconnect in areas with TPP approved transmission capacity, then projects shouldn’t be required to finance nor fund network upgrades since the TPP will fund network upgrades directly.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

If implemented, this should only be applicable for projects that request FCDS. Projects should only be able to request FCDS if there’s deliverability in the location where they want to interconnect, thus avoiding triggering costly interconnection customer-driven ADNUs that are not likely to be built. However, CAISO should not deny access to the transmission system for new projects which do not request deliverability since those projects already have a mechanism fund local RNUs to operate safely without massive or numerous area upgrades which impact study results for other interconnection customers. Recent area study results seem to show lots of large ADNUs and relatively fewer RNUs in most if not all study regions, so CAISO should guide new interconnection customers seeking FCDS to areas where there is deliverability- but not limit where other interconnection customers can request interconnection.

To the extent more MWs enter the queue requesting FCDS than there is deliverability available in that location, all projects without a deliverability allocation should be automatically converted to PCDS at an equal proportion. For example, if there’s 500MW of new projects that apply for FCDS in an area with 250MW of deliverability, each generator would automatically convert to PCDS and only half of their capacity would be deliverable (250/500=50%). This would disincentivize numerous applications from the same developer in a single area along with over-applying for scarce deliverable MWs. Coupled with the ability for a project to downsize its MW capacity, this would also allow developers to right-size projects if FCDS is required.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

CAISO should not make obtaining an offtake agreement a sole condition to staying in the queue. Instead, before projects begin their Phase II study, they should meet one of the following three criteria: 1) prove they have a PPA or some sort of commercial arrangement to support further development of the project; 2) post a financial security in-lieu-of a PPA; or 3) have the ability to park for a year.

Having the ability to post a financial security in-lieu of obtaining a PPA is needed because only recently have operating generation resources (most notably batteries) without PPAs or deliverability made commercial sense in CAISO due to 1) falling capital costs to build projects; 2) transferable ITC as put into law in August 2022 which drastically increases the ability for project sponsors to take certain types of operational and market risks; and 3) consistent and predictable intra-day price volatility and ramping needs which are only getting more dramatic over time.

We believe the reason the CAISO has not observed many non-PPA batteries until now is because these many market developments are relatively new and many new generator resources (most notably batteries) haven’t been able to make it through the queue in time to come online to take advantage of this new reality; this is evidenced by the non-PPA battery fleet build-out in ERCOT which has a much quicker interconnection process.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Similar to our comment to question #5, CAISO should not deny access to the transmission grid, and thus CAISO-managed wholesale power markets, based on the depth and availability of the PPA market. Obtaining a PPA is one of many ways generators can earn revenue, and relying solely on PPAs as a barrier for projects to come online undermines a core purpose of an open wholesale LMP-based energy market. While we note that for the past decade or so, new as-available renewable energy resources have relied on offtaker-scheduled PPAs for financing to come online, we don’t believe that PPAs are as critical for project success today since Congress passed the Inflation Reduction Act in August 2022 which enabled ITC transfers.

If CAISO requires projects to obtain a PPA to continue in the study process, that unduly forces projects to be PPA price and commercial term takers, which dramatically increases and institutionalizes offtaker market power- increasing the risk that projects are abandoned after all other areas of development have been de-risked.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

No comment

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

No comment

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

NCPA understands and appreciates the resource shortages and the overwhelming number of requests that prompted CAISO to propose deferring action on Cluster 15 until stage two of the Cluster 14 analyses are complete. NCPA can support the deferral of Cluster 15, provided that the opening of the window is delayed to accommodate entities who may wish to submit.

NCPA counts itself among the stakeholders that may wish to submit projects in Cluster 15. Prior to CAISO’s proposal, entities anticipated the annual opening of each cluster as currently provided in the tariff. By delaying action on Cluster 15 until 2024, the schedule would implicitly delay future clusters by at least a year, if they open at all. Entities that were targeting a Cluster 16 submission date must now recognize that Cluster 15 is the only project train scheduled to leave the station in the next couple of years. NCPA is likely not the only entity that may accelerate its plans given the new proposed schedule.

Additional time would also allow CAISO to complete Phase 2 of this stakeholder process, allowing entities to better align their project proposals with whatever tariff changes arise from it. NCPA would support delaying the submission window for Cluster 15 until April 30, 2024.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

As NCPA understands it, CAISO’s proposal is to incorporate the loads and resource portfolios developed and approved by the CPUC for its jurisdictional entities in the CAISO’s annual Transmission Planning Process (TPP), and to somehow prioritize generator interconnection requests that align with those priorities in the interconnection process. This would be done in accordance with the MOU among the CPUC, CEC and CAISO.[1]

Whether or not this approach satisfied open access requirements as a general matter, NCPA believes that it could be found to be unjust, unreasonable and unduly discriminatory if it does not provide a path for a non-CPUC-jurisdictional LSE, such as NCPA, to have its portfolio procurement needs considered in the TPP. NCPA is not a party to the CPUC/CEC/CAISO MOU, and it does not govern their procurement needs. CAISO cannot, consistent with the requirements of open access and avoidance of undue discrimination, fail to provide a path for all LSEs operating within its footprint to obtain transmission access for their procurement and development needs. CAISO should expand the proposal to allow for procurement input from non-CPUC-jurisdictional LSEs into the TPP for them to make the requests necessary for their own resource procurement.

CAISO also requested comment on proposals such as a special process for offshore wind or for out-of-state wind using the Subscriber PTO model.

NCPA would suggest that focusing overmuch on type of generation is an invitation for claims of undue discrimination and endless angling to expand favorable treatment to other types of generation. CAISO should strive to apply rules of general applicability.

For example, generators using the Subscriber PTO model might qualify to move ahead more quickly on a “first-ready, first-move” principle, regardless of what type of generation has been subscribed over the line. Public policy transmission improvements selected in the TPP to enable offshore wind could move ahead (and could be available for temporary use by others until the public policy generation materializes). General rules tightening site control requirements or increasing deposits could help winnow the queue.

[1] http://www.caiso.com/Documents/ISO-CEC-and-CPUC-Memorandum-of-Understanding-Dec-2022.pdf

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

See response to question 2. This would only be appropriate if the procurement plans and needs of non-CPUC-jurisdictional LSEs are also considered.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

See response to question 2.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

NCPA could live with a requirement that projects have a PPA, be shortlisted for a PPA, or that are proposed to be developed by a Load Serving Entity.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

See response to question 2. Non-CPUC-jurisdictional LSEs must have their needs incorporated in the process to the same extent as those of CPUC-jurisdictional entities.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

No comment at this time.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

NCPA appreciates the opportunity to comment on CAISO’s proposals for IPE 2023, and it acknowledges the magnitude of the problems CAISO is attempting to address through this initiative.

NCPA approaches these proposals from the point of view of a non-CPUC-jurisdictional LSE serving load in the CAISO footprint. In order to satisfy the statutory requirements and FERC open access precedent that remain applicable,[1] the CAISO framework must consider the needs and projects of entities such as NCPA in its processes.

[1] E.g. Orders 888, 889, 890 and 2003 and Sections 210-212 of the Federal Power Act.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

PG&E appreciates the opportunity to provide its perspectives on the IPE 2023 issue paper and straw proposal issue and looks forward to working with the CAISO and other stakeholders through this vital initiative.  

PG&E strongly supports the CAISO not beginning the Cluster 15 validation and scoping meeting processes until Spring 2024, after the Cluster 14 Phase II studies and results meetings are complete.  PG&E has a large number of active projects in the Cluster 14 Phase II study process and has requested the CAISO amend the Cluster 14 Phase II study timeline to January 31, 2024 (from November 24, 2023) in order for PG&E to be able to complete all study deliverables.  Extending the Cluster 15 Phase I timeline will prevent the overlap of key Cluster 14 Phase II deliverables and Cluster 15 Phase I Interconnection Requests review and scoping meetings. Furthermore, extending Cluster 15 to spring of 2024 is important to allow the entire Cluster 14 Phase II process to finish and understand its influence on Cluster 15.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

PG&E is still evaluating the proposal described in Section 2, and to help stakeholders make an informed decision, recommends CAISO provide additional information of how this separate process in Cluster 15 will work.  PG&E seeks more information on the following questions:

• What are the criteria for CAISO to accept non-speculative projects for a potential separate study timeline or process for Cluster 15 than the rest of the interconnection requests that will only begin scoping meetings in Spring 2024? 
• Would other long-lead time technologies, beside out-of-state wind and offshore wind, be eligible for inclusion in the separate study process?
• Will the projects in Cluster 15 Phase 1 Group A study process have interconnection priority over the other projects in Cluster 15 Phase 1 Group B?
• How will network upgrade costs be shared between the technologies in the separate study process and the rest of projects in Cluster 15?
• Since Cluster 14 phase 2 study timelines have been extended, how does CAISO plan to include studies for Cluster 15 Phase 1 Group A in the same timeline as cluster 14 phase 2 studies.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

PG&E is still evaluating the proposal described in Section 3.1 and reserves the right to provide further comments on any concerns in the future.  In our preliminary review of the proposed reform, we have identified that information asymmetry between the CPUC, resource developers, and the CAISO of available or planned capacity at substations would create challenges for successful implementation.  Thus, the CAISO will need to provide data on available or planned capacity to entities either through the annual Transmission Planning Process or some other medium.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

In concept, PG&E supports limiting the number of interconnection requests in a study area based on the transmission capacity being planned for that area, predicated on resource developers having adequate information on where there is available and planned capacity.  The CAISO should continue its efforts to improve how it educates resource developers on how to make the most informed decision on where to seek interconnection.  A contingency amount would need to be included to account for withdrawals from the interconnection process. 

PG&E is still evaluating the four methods proposed in Section 3.2 to limit the number of interconnection requests, but believes that improvements to the interconnection application process can help ensure that truly viable projects proceed and speculative projects do not “clog-up” the interconnection study process.  One improvement that PG&E previously recommended is requiring that projects submitting an application have site exclusivity, and not be able to provide a deposit in lieu of demonstrating site exclusivity. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

Similar to the other Track 2 proposed reforms, PG&E is still evaluating the proposal described in Section 3.3 and reserves the right to provide further comments on any concerns in the future.  Notwithstanding PG&E not taking a position at this time on this proposed reform, if this proposal moves forward, PG&E believes for it to be viable in ensuring load-serving entities meet their procurement targets, the CAISO will need to provide information to LSEs after Phase I of the network upgrades required for the interconnection requests to achieve Full Capacity Deliverability Status (FCDS).  Understanding which projects going through the interconnection process can meet their in-service dates and count as FCDS, which often time is dependent on the network upgrades required, is important for procurement efforts.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

PG&E is still evaluating the proposal described in Section 3.4 and reserves the right to provide further comments on any concerns in the future.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

PG&E is still evaluating the proposed reforms described in Section 3 and reserves the right to provide comments on alternative elements in the future.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

PG&E provides the below thoughts for CAISO’s consideration as it scopes out issues for consideration in Track 2 and how it will implement any adopted reforms:

• It is unclear if implementing Track 2 proposed reforms for Cluster 15 will provide interconnection customers sufficient time to meet the new requirements.  There may need to be a phased-in approach for any of the proposed reforms under Track 2 to give resource developers time to adjust to the new requirements.  At the same time, PG&E appreciates CAISO trying to reduce the cluster sizes by looking at fundamental changes.
• PG&E suggests CAISO examine if the existing Cluster process can be divided into two queues, near-term and long term.  The "near-term queue" would prioritize projects that have site exclusivity, ISD and FCDS that can be achieved in the 2-to-5-year horizon helping to meet near- and medium-term Reliability, Local Capacity Requirements and Resource Adequacy goals. The "long term queue" projects would interconnect at locations with planned capacity upgrades from CAISO’s 20-year plan, off-shore wind integration, long term 500 kV Policy Projects (with ISD in the next 7-10 years). This will allow sufficient time to study the impacts of generation with input from WECC, Neighboring Utilities, and Affected Systems. The pros and cons of such an approach should be explored.
• PG&E recommends CAISO reconsider from the prior IPE initiative if limiting the time that projects can remain in the queue if not meeting criteria that demonstrate a project is advancing in its development.  As CAISO noted in its proposal, this could help manage the queue size, maintain study schedules, and prioritize projects already well underway.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Power Applications and Research Systems appreciate the opportunity to comment on 2023 IPE. 

As noted in Section 2, developers have already spent significant amount funds in signing site control contracts, performing environmental and permitting analyses, designing power plants etc. It is simply too late in the game to make major changes to Cluster 15 application submission window. Therefore we support  the alternative that Cluster 15 applications be accepted, validated and Scoping meetings be conducted. Scoping Meetings do provide an opportunity for developers to withdraw projects that may require significant interconnection costs. This can off-load projects that are not economically viable.  It is more acceptable that Cluster 15 Phase I studies to take longer to complete than making any other changes.   

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Power Applications and Research Systems (PARS) appreciate the opportunity to comment on 2023 IPE. 

Off-shore wind power plants are very capital intensive take many years to complete. Off-shore wind resources are only economically viable in very large sizes such as 1000 MWs or more.  Interconnection of such large size power plants can greatly influence the CAISO interconnection Queue in the coastal areas by hoarding interconnection capacity and thus creating an uneven playing field for the smaller coastal projects. PARS suggests that CAISO conduct analyses and determine the readiness and timeline for the California power grid to integrate 4,600 MWs of off-shore wind.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Power Applications and Research Systems (PARS) appreciate the opportunity to comment on 2023 IPE. 

PARS suggests that CAISO develop an annual study report which may be called, “Renewable and Storage Integration Plan” or a “Renewable and Storage Interconnection Plan” or RSIP for both. This plan should utilize the CAISO’s existing Transmission Plan findings and upcoming upgrades and regulatory changes to identify zones and areas with lower exposure to excessive interconnection costs etc.  As an example, President Biden’s Inflation Reduction ACT (IRA) providing tax incentives for renewables to locate in specific geographical areas can be used to identify specific sub areas which have existing or planned interconnection capacity.  

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

 No comments at this time.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Power Company of Wyoming LLC (“PCW”) submits these comments in support of the CAISO’s proposal to establish a separate track in Cluster 15 for interconnecting customers seeking to connect out-of-state (“OOS”) wind resources on new transmission facilities to be interconnected to the CAISO grid. 

California state policy and planning has repeatedly identified procurement of OOS wind resources as a core element of the state’s plan to increase the integration of new renewable resources while also maintaining system reliability.  However, as the CAISO’s straw proposal explains, these large wind resources require new transmission solutions that cannot be developed as quickly as other renewable options (e.g., solar+storage resources interconnected to the existing CAISO grid).  To keep these much-needed OOS wind resources on track for commercial operation in the 2027-2028 timeframe, it is imperative that Cluster 15 interconnection proceed on a timely basis for these resources and not be delayed until 2024 or beyond.

PCW has developed the 3,500 MW Chokecherry and Sierra Madre Wind Energy Project (“CCSM Project”) in Wyoming.  The CCSM project is a large-scale resource with all site control secured, all required permits secured, and the Project is under construction.  The CCSM Project’s high net capacity factors and complementary production profile will provide operational characteristics and geographic diversity consistent with planning conducted by the California Energy Commission (“CEC”), the California Public Utility Commission (“CPUC”), and the CAISO’s transmission planning.

Under a FERC approved open solicitation, PCW has secured the required transmission capacity from Wyoming to the CAISO Controlled Grid from TransWest Express LLC (TransWest).  For over a decade, TransWest has been developing a multi-billion dollar transmission solution to deliver highly valuable OOS wind resources from Wyoming to serve California load.  The CAISO is working with TransWest to implement the related Subscriber Participating Transmission Owner model (“SPTO Model”).  Under the SPTO model, the CAISO will also take control of these transmission facilities, which will provide the entire CAISO system with significant benefits from a reliability and operational perspective.  In addition, this new interregional bulk transmission will facilitate the exchange of energy under the EIM, EDAM and ultimately a broader western RTO.

The California legislature has mandated a diverse and balanced portfolio of resources to ensure a reliable electricity supply that provides optimal integration of renewable energy in a cost-effective manner.[1]  As part of that mandate, the CAISO has been tasked with enabling access to OOS resources that will allow California to meet its resource adequacy requirements in an economically efficient manner.  Access to Wyoming wind in particular will bring a geographic diversity that complements CAISO load shapes and the existing California renewable resource base.

Interconnecting OOS wind is crucial to meeting the objectives at the center of each of the CPUC’s core programs: Integrated Resource Planning (“IRP”), Resource Adequacy (“RA”), and Renewables Portfolio Standard (“RPS”).  For example:

• Through the IRP proceeding, the CPUC has ordered that load-serving entities (“LSEs”) procure 15.5 GW of September Net Qualifying Capacity by 2028. At the same time, the CPUC has asked the CAISO to study 4,828 MW of new OOS wind resources on new OOS transmission as the base case for the planning year 2033 in the 2023-2024 Transmission Planning Process. Specifically, the CPUC has identified 1,500 MW of Wyoming wind interconnecting at Harry Allen or El Dorado 500 kV substations (TransWest’s planned point interconnection lies between these two substations).[2]
• In the RA proceeding, the CPUC’s Energy Division has studied the effective load carrying capability of OOS wind and determined average monthly values for Wyoming and Idaho wind comparable to those of offshore wind.[3] This assessment illustrates the high resource adequacy value of OOS wind.
• In connection with the RPS program, the State legislature has recently continued to accelerate California’s climate goals. SB 1020 (September 2022) requires renewable energy and zero-carbon resources to supply 90% of all retail electricity sales by 2035, 95% of all retail electricity sales by 2040, and 100% of all electricity serving state agencies by 2035.  The diverse profile of Wyoming wind, especially given its strong nighttime generation, will significantly contribute to the advancement of these climate goals.

OOS wind from Wyoming will be RPS Category 1 resources and will provide RA benefits to the state (benefits which may become even more pronounced as California moves to reform its RA program).  However, as the CAISO correctly points out, OOS wind resources face unique challenges warranting special consideration.

PCW is discussing offtake contracts for this wind resource with California LSEs. These discussions contemplate that the costs of both the wind energy and transmission services will be included in the pricing for these offtake contracts (thereby allocating the costs associated with OOS wind directly to the benefiting LSE customers).  Because the costs of PCW’s transmission service agreement (“TSA”) with TransWest will be recovered through PPA revenues, it is essential that PCW be allowed to move expeditiously through the Cluster 15 interconnection process.  Without clear line of sight on interconnection costs, deliverability status, and timing, PCW cannot finalize offtake agreements with California LSEs.  Without offtake agreements, PCW cannot provide support for its obligations under its TSA with TransWest.  This would, in turn, negatively impact TransWest’s ability to secure financing for these new transmission facilities. 

By providing a separate track for OOS wind to proceed through Cluster 15, the CAISO can help solve this chicken-or-egg problem.  In so doing, the CAISO will help keep this critical long lead-time development on track for adding new resources that are consistent with the state’s planning objectives while simultaneously adding bulk transmission that improves reliability and the operational efficiency of the larger western grid.

In sum, PCW acknowledges the considerable task that the CAISO faces with respect to the Cluster 14 Supercluster and the impending Cluster 15.  We appreciate the CAISO’s consideration of how the proposed delays to the Cluster 15 interconnection process may interfere with meeting the State’s policy objectives related to supply diversity and reliability.  We strongly support the CAISO processing interconnection requests from subscribing generators of long lead-time resources that will further state policy on an accelerated basis.

[1] See California Public Utilities Code Section 399.11 (“The Legislature finds and declares all of the following: … Achieving the renewables portfolio standard through the procurement of various electricity products from eligible renewable energy resources is intended to provide unique benefits to California, including all of the following, each of which independently justifies the program: (1) Displacing fossil fuel consumption within the state.  (2) Adding new electrical generating facilities in the transmission network within the WECC service area. (3) Reducing air pollution, particularly criteria pollutant emissions and toxic air contaminants, in the state. (4) Meeting the state's climate change goals by reducing emissions of greenhouse gases associated with electrical generation. (5) Promoting stable retail rates for electric service. (6) Meeting the state's need for a diversified and balanced energy generation portfolio. (7) Assisting with meeting the state's resource adequacy requirements. (8) Contributing to the safe and reliable operation of the electrical grid, including providing predictable electrical supply, voltage support, lower line losses, and congestion relief. (9) Implementing the state's transmission and land use planning activities related to development of eligible renewable energy resources.”) (emphasis added).

[2] CPUC Staff Report, Modeling Assumptions for the 2023-2024 Transmission Planning Process (February 2023), https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/integrated-resource-plan-and-long-term-procurement-plan-irp-ltpp/2023-irp-cycle-events-and-materials/modeling_assumptions_2023-24tpp_v02-23-23.pdf

[3] Energy Division Study for Proceeding R.21-10-002, Regional Wind Effective Load Carrying Capability Study Results for 2024 (June 1, 2022), https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M482/K148/482148586.PDF

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

 No comments at this time.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

 No comments at this time.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

 No comments at this time.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

 No comments at this time.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

 No comments at this time.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

 No comments at this time.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

CPUC staff support ISO’s proposal for closing the Cluster 15 window on April 17, 2023 performing a completeness review, finalizing the Interconnection Request list by May 1, 2023, and postponing validation of Cluster 15 until the Cluster 14 Phase 2 Studies are completed, given the “Other Issues for Consideration” addressed in question 3 below are addressed.  CPUC Staff support closing the Cluster 15 window on the original intended end date, despite delaying review, to allow projects that have been developed for Cluster 15 to enter the queue. CPUC staff believe that leaving the Cluster 15 window open could overwhelm the volume of Cluster 15 requests.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

CPUC staff support advancing Cluster 15 Interconnection Requests for long lead time (LLT) resources such as out-of-state wind, geothermal, and offshore wind (OSW) on separate expedited timelines.  This would help to support transmission planning for these resources due to the complex timeline challenges that are unique to these resources compared to the majority of Interconnection Requests. As stated in the IPE Issue Paper, since Cluster 14, the US Bureau of Ocean Energy Management conducted the first OSW lease area auction for the Pacific region, which resulted in bids from five companies totaling $757.1 million in five areas that could produce more than 4.6 GW of OSW power. The ISO is currently analyzing transmission to support substantial amounts of OSW resources. CPUC Staff support a separate expedited timeline for LLT resource types to ensure development of these resources are in sync with transmission planning and development.   

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

CPUC staff recognizes the ISO’s efforts and support the general approach of prioritizing Interconnection Requests where the transmission system has available, existing, or planned capacity based on ISO transmission plans, in concept. CPUC staff look forward to further conversations with CAISO staff to better understand the details of the proposal and explore possibilities, including how resources that are identified as needed but are in areas without existing or planned capacity could still advance through the interconnection process

Relevant to Element 1 and other proposed elements, CPUC staff note that CPUC Integrated Resource Planning (IRP) portfolio modeling and busbar mapping rely on transmission capability and upgrade assumptions currently derived from GIDAP study results. These proposed reforms would limit interconnection studies’ ability to provide such transmission assumption information for CPUC IRP portfolio development. With several of these possible reform elements, CPUC staff note that an alternative method for developing such assumptions would likely be needed.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

CPUC is neutral on this proposal and would need more clarity on proposed mechanisms for limiting interconnections.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

 CPUC staff support a way to prioritize Interconnection Requests for projects with PPAs or projects that are shortlisted. The Issue Paper notes in Section 3.3 several benefits of this potential reform including better aligning the Transmission Plan Deliverability (TPD) allocation process with LSE procurement and focusing transmission upgrades. CPUC staff agree with the potential concerns noted in the Issue Paper and note an additional concern around the deliverability uncertainty, including necessary transmission upgrade costs and timelines of projects that have only completed Phase 1.

CPUC is closely monitoring the pace of resource development and will continue consulting with LSEs to stay apprised of their progress and challenges in meeting procurement orders. 

One additional potential benefit of not limiting projects that can enter Phase 1 studies is that the GIDAP study results could still serve as a pertinent source of transmission information for IRP portfolio development and mapping for transmission planning as noted in comments for Question 4.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Depending on the frequency of new studies, CPUC staff believe a new process for developing transmission capability and upgrade assumptions for IRP portfolio development and busbar mapping would be needed, as noted response to Question 4.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

No comment at this time.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

No comment at this time.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Recurrent Energy (“Interconnection Customer” or “IC”) understands the rational put forth by CAISO (“ISO”) and Transmission Owners ( “PTO”) to delay the Cluster 15 processing to 2024 and appreciates CAISO’s efforts to streamline the study process by initiating QC15 studies after QC14 Phase II studies are completed.

IC recommends the ISO consider the option of delaying the site in lieu deposit submittal timeline as an exception for C15. This could relieve the concern around significant cash getting locked in until April 2024 when the work for QC15 is expected to begin. The ISO can delay the site in lieu deposit to February-March window in 2024 when the PH II Results meeting get over or whenever may be a more convenient for the ISO/PTO .

IC supports completeness review of interconnection requests by May 1st and would request the ISO to add ‘10 BDs of deficiency cure period’ to this language if it does not apply already.

IC would like the ISO to clarify what ‘minor’ modifications will be allowed to the IRs between April 2023 and March 2024 in the March 31^st, 2023 draft Tariff Language .

In light of the timeline associated with issuance of critical system data (SC Rating, TPP  23-24 plan, Transmission Capacity per sub/zone etc.) that may play a key role in assessing optimal locations per the track 2 provision IC would like to request the ISO to allow changes to the project size , project POI and kV levels within same POI until the validation work kicks off.  

Finally, IC requests ISO/PTOs ensure they meet current PHII Schedule in light of such drastic restrictions put on C15. It will be unfair to the developers if the PTO/ISO are unable to meet the PHII timelines and end up pushing the Cluster 15 processing any further.

IC understands the rationale to do something about the long lead time Network Upgrades required for integrating Offshore Wind (OSW) & Out-of-State Wind (OOS) wind into the CAISO System. IC feels this issue would be better taken care of under the Transmission Planning Process (TPP) enhancement initiative with a consideration for accelerating approval of Network Upgrades needed to build capacity for these resources.

IC opposes the proposal of a separate cluster process for C15, or any future clusters based on resource type. IC would prefer the ISO and PTOs to invest their time & energy in completing the PH II studies on schedule and kick off Cluster 15 window for all technology & resource types alike.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

 IC has the following concerns regarding this approach and feels this should be kept open to discussion as part of the track 2 initiative. :

• It does not align with FERC’s requirement of Open access to transmission.
• It will leave developers with very limited options in terms of site control, not to mention the competition amongst several candidates for limited buildable parcels nearby Point of Interconnects & subsequent long bidding wars on prices leading very high lease or purchase prices which will be transferred to the PPA prices, and eventually to the ratepayers.
  • This is also leaning towards a conflicts with the IPE 2022 tariff modification that puts 50% Site in lieu deposit at risk soon after the scoping call.
• It will curb the most optimal use of buildable land near transmission infrastructure.  

IC feels the ISO/PTOs may want to reconsider their goal of "limiting number of IRs" to "incentivize real/tangible IRs in areas where capacity is available" because:

a. “Limit" doesn't align with the overall objective of fair and open access

b. projects are willing to carry heavy ADNUs and thereby increasing capacity in areas which previously did not have any.

There can be several others ways to limit the IRs, one that will likely show its effectiveness post C15 scoping call is the 50% Site deposit at risk. We should be considering similar approaches that will encourage more procurable projects to move ahead.  

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

 IC has the following concerns regarding this approach and feels this should be kept open to discussion as part of the track 2 initiative. :

• It does not align with FERC’s requirement of Open access to transmission.
• It will leave developers with very limited options in terms of site control, not to mention the competition amongst several candidates for limited buildable parcels nearby Point of Interconnects & subsequent long bidding wars on prices leading very high lease or purchase prices which will be transferred to the PPA prices, and eventually to the ratepayers.
  • This is also leaning towards a conflicts with the IPE 2022 tariff modification that puts 50% Site in lieu deposit at risk soon after the scoping call.
• It will curb the most optimal use of buildable land near transmission infrastructure.  

IC feels the ISO/PTOs may want to reconsider their goal of "limiting number of IRs" to "incentivize real/tangible IRs in areas where capacity is available" because:

•  “Limit" doesn't align with the overall objective of fair and open access
• projects are willing to carry heavy ADNUs and thereby increasing capacity in areas which previously did not have any.

There can be several others ways to limit the IRs, one that will likely show its effectiveness post C15 scoping call is the 50% Site deposit at risk. We should be considering similar approaches that will encourage more procurable projects to move ahead.  

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

IC would like more clarity about what the ISO/PTOs are referring to when they say ‘available’ or ‘planned’ capacity. This could be the product of CPUC Bus Bar mapping and Planned TPP capacity however it will be best for the PTOs or ISO to publish this data in terms of capacity available per substation (for different technologies) for a clear idea of what they are referring to . Additionally, it will be important to understand how they are calculating the capacity for each substation and how they plan to restrict IRs at a substation based on that capacity.

IC also requests ISO/PTOs to provide this data in the next few weeks/months for C15 and well in advance of future cluster windows on a regular basis.

One more suggestion would be to make more data available to ICs in a bid to incentivize development in areas with available capacity (e.g., Make redacted versions of Phase 1 and Phase 2 studies available to all ICs)

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

IC requests clarity on what constitutes a valid PPA and PPA shortlist. Would CCAs be eligible?

IC understands the rationale to incorporate commercial readiness at a critical stage such as pre PH II for cluster 15 however, having a PPA or be shortlisted for one seems impractical and IC opposes this reform.

It is almost impossible for the ICs to have a PPA or be shortlisted before Phase 2 studies because there is too much uncertainty about the interconnection costs and timeline. Neither developers nor LSEs (off-takers) will be able to take such risks. Also, there will be more and more merchant projects in the market.

The procurement process does not align with the Interconnection Study process. Project developers have no visibility on when study results will be issued (delays in study reports across Markets) and when RFPs are issued by LSEs.

IC also wants to state that the limited deliverability in CAISO system has inherently pushed and will continue to push future Stand Alone Energy Storage projects to become merchant projects. This approach will essentially kill those merchant projects. The ISO should consider an approach where the merchant projects can be studied.

IC suggests that CAISO consider other forms of ‘commercial readiness requirements’ as accepted in some regulated markets – Ordering major equipment, In-lieu deposit for readiness etc.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

IC opposes this reform because it introduces a lot of uncertainty around planning of commercially viable opportunities and possess stress on the manpower (at Developer, ISO, PTO) involved in developing and studying those opportunities.  IC feels this reform is far-fetched at this stage and there is not enough information available to determine the need and its specifications. IC feels this reform should be assessed at later stages of track 2 or near PH I study results of Cluster 15 whichever is later. More information is needed to make any further comments on this.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

IC has a few thoughts/queries on the elements proposed in section 3:

1. IC requests CAISO to elaborate the plan of auction for IRs per substation, how they intend to do this and what will be the outcome of it.
2. IC requests alignment between the procurement and the interconnection study process. In terms of shortlisting and study issue dates, accounting for any delays in either process.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

Regarding the proposed handling of Cluster 15 interconnection requests, the IC is supportive of delaying the processing of Cluster 15 to 2024.  IC supports completeness review of interconnection requests by May 1st and would like to add ‘10 BDs of deficiency cure period’ to this language.

The IC suggests CAISO to make a few exceptions to C15 projects:

1. Delaying the site in lieu deposit submittal until Q1 2024
2. Allowing changes to the project size, project POI, and kV levels within the same POI until the C15 validation work kicks off.

IC opposes the ISO’s approach to only consider or process interconnection requests where the transmission system has ‘available’ or ‘planned’ capacity. IC suggests considering approaches that will encourage more procurable projects to move ahead without stymying healthy competition and reasonable avenues to secure buildable land near transmission infrastructure.

IC would like to suggest a few more items to CAISO/PTOs on the proposal discussion:

• Clarify what ‘minor’ modifications will be allowed to the IRs between April 2023 and March 2024 in the March 31^st, 2023 draft Tariff Language .

• Ensure Cluster 14 PHII schedule is met and no further delays in cluster 15 processing are proposed between now & April 2024
• Provide more clarity on what they mean by ‘available’ and ’planned’ capacity in terms of Integrable MWs per substation technology wise.
• Publish the Capacity data per substation in the next few weeks/months. Further, provide a timeline in the march 31^st tariff language when they plan to publish this.
• Make more data available to ICs in a bid to incentivize development in areas with available capacity (e.g. Make redacted versions of Phase 1 and Phase 2 studies available to all ICs)
• Elaborate on the plan of auction for IRs per substation to limit MWs to be studied, how they intend to do this and what will be the outcome of it.
• IC requests alignment between the procurement and the interconnection study process. In terms of shortlisting and study issue dates, accounting for any delays in either processes.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

REV Renewables (REV) understands the need for CAISO to change handling Cluster 15. Given the uncertainty this proposed change will cause for Developers, REV supports CAISO allowing customers to “refresh” their interconnection request (IR), though suggests CAISO clarify that this refresh will follow current rules as to what aspects can be changed after the scoping meetings.

However, REV strongly recommends that Track 2 changes should only apply to Cluster 16 and beyond. While it is possible that some Track 2 changes could be implemented for Cluster 15, CAISO’s current proposals are such that it could void otherwise valid interconnection requests that were submitted in good faith based on the current tariff. CAISO should be clear that Track 2 proposals will not invalidate Cluster 15 IRs.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

REV opposes special consideration for certain types of resources in Cluster 15 as it would impose undue discrimination against all other resources and preferential treatment of those specified resources. While some resources may have longer lead times and special transmission needs, CAISO must maintain its open access, technology neutral, and non-discriminatory principles in its interconnection process. CAISO should not create a special process that would put certain resources ahead of others to get transmission deliverability. Transmission network upgrades have been funded by ratepayers and should be available in a non-discriminatory manner to any resource that meets the state’s clean energy goals. Furthermore, most of the issues raised by CAISO for offshore wind and out-of-state wind resources are more directly related to transmission planning processes, which are outside of the scope of the Interconnection Process Enhancements initiative.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

REV does not agree with CAISO’s proposal to selectively accept IR where transmission system has available or planned capacity. It is crucial that several steps are taken before stakeholders can provide feedback on the effectiveness of this approach. For instance, one step is to update the transmission capability estimates that were last updated in 2021. This puts into question the 2022-23 Transmission Planning Portfolio that CAISO is working on and projects that may be approved in the current cycle. CAISO should update these estimates and work with CPUC to quantify the impacts on the portfolio before even considering limiting IRs based on available and planned transmission. In addition, CAISO should provide details on whether the currently available option for generation projects to build ADNUs would remain. While no customer has chosen this ADNU build option in the interconnection process so far, this could change.

While REV understands the desire to have developers focus on zones with available or planned capacity, there may be other reasons a developer chooses a project location. The interconnection process should allow projects that customers deem feasible to submit an interconnection request. Additionally, if CAISO creates tailored zones for interconnection requests, it is likely to create a flood of IRs to those zones and unrealistic Phase 1 study results. Developers respond to a variety of market signals in deciding where to locate a project, and transmission capacity, while important, is only one factor.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

REV opposes CAISO proposals to limit the number of interconnection requests that would go against open access principles and be unduly discriminatory. Furthermore, REV disagrees that limiting the number of IRs should be a primary goal of this initiative. While REV understands the work load impact that results from a high number of IRs, given the significant amount of new resources California needs to meet its 100% clean energy by 2045 goal and the challenges of developing a project in California that contribute to a small percentage of projects actually coming online, CAISO should not be inhibiting development by limiting IRs. The reality is that many good faith initial interconnection requests do not come to fruition (for a variety of reasons). Limiting the amount for each zone presupposes a certain success rate for projects, which is unknown. REV is also skeptical on how an auction would work in the interconnection process while maintaining open access to customers. Transmission capacity that is paid for by ratepayers should be available to any interconnection customer, and not be subject to auction. It is also unclear what would be done with the auction revenues.

REV defers further comments on this topic until specific criteria are proposed.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

REV posits that this proposal is unworkable given the current transmission plan deliverability (TPD) allocation and LSE procurement processes. While CAISO acknowledges the TPD allocation process would need to be moved to between Phase I and II, this would provide a very short window for LSEs to conduct a procurement process. Phase II results are also important for developers to help determine whether a project is truly feasible and to provide more cost certainty. This information is necessary for submitting quality bids to LSEs and flows into cost caps in procurement contracts. Unless CAISO is also able to increase the certainty of cost and upgrade information in Phase I results, this proposal is likely to result in more risk and burden on LSEs and developers to conduct procurement processes for projects that turn out to not be viable and/or exceed cost caps. Additionally, CPUC would need to authorize and LSEs would need to procure resources further out than they normally do, since cluster 15 projects would likely have a delivery year of 2030 or later (currently the vast majority of solicitations are only through 2028 due to the recent CPUC order).

This proposal would also exclude merchant generation projects from proceeding through the interconnection process. While most projects today are receiving PPAs, market conditions may change in the coming years and CAISO should not close the door on merchant generation.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

REV opposes this proposal, given the caution against presupposing a project success rate as discussed in #4 above. If CAISO does open a new window “only when warranted,” it should ensure that there is a clear trigger to provide sufficient notice to stakeholders ahead of the open window. It is important for developers to have a clear timeline to work towards in order to create quality IRs and CAISO should be provide as much advance notice as possible. For example, when the queue reaches a certain level, then the window will open in 12 months. REV would prefer CAISO more permanently extend the current interconnection process schedule (e.g. open window every 18 months) instead of an unclear timeline.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

REV suggests that CAISO more clearly define its goal(s) in IPE Track 2. CAISO’s principles seem aimed at reducing the number of interconnection requests as a primary goal, while others are aimed at shaping the criteria/quality/location of the IRs, or staying within CPUC portfolio planning. If there is disagreement among stakeholders on these principles and goals, it is likely to lead to disagreement throughout the process. REV recommends as a first step that CAISO have a workshop to discuss the redesign parameters, objectives, and goals of Track 2. Agreement on these principles could lead to better proposals, outcomes, and discussions among stakeholders.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

REV has no further comments at this time.  

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

RWE is a member of several industry groups and generally support the proposals presented by LSA(Large-scale Solar Association) and ACP-CA if submitted. 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

RWE appreciate that CAISO’s recognition of the unique challenges that offshore wind resources is facing.

As a winner of one of the first offshore wind leases in Humboldt, RWE has been diligently working towards development activities in California’s north coast region. Here we want to share some unique timing challenges we foresee in delivering offshore wind on a timescale that enables California to meet its clean energy goals.

As noted by CPUC, the Humboldt offshore wind resource area will likely require longer development timelines compared to the central coast due to the lack of transmission capacity along California’s north .  The transmission planning process alone takes several years to complete the cycle of modelling the options, selection of the optimal solution, and allocation of cost.  Then the permitting process is notoriously challenging and time consuming, especially through a region of sensitive habitats and Tribal Nation interests. Lastly, construction of the upgrades can be technically challenging.  Added all in, we believe that realizing the transmission in the north coast will very likely be a rate limiting milestone in the overall program of delivering the first tranche of offshore wind projects in the Humboldt region such as the 1.6GW offshore wind identified in CAISO’s 2023-24 transmission planning base case portfolio for year 2035.

It is precisely the challenging and time consuming risks of deliver north coast transmission needed for offshore wind that we are glad to see CAISO recognizing the need to prioritize studies relating to long lead time resources such as offshore wind.  We very much encourage CAISO to not delay cluster 15 studies relating these resources.  It is critical to have the cluster 15 offshore interconnection applications get studied hand in hand with CAISO 2023-2024 TPP to identify the initial long-lead transmission network upgrades.  The TPP studies results together with Cluster 15 Phase 1 study will provide clear guidance on how to interconnect the Humboldt offshore wind, cost estimates and approximate timeline so that developers can plan and facilitate the development effort accordingly. 

RWE appreciates the CAISO’s consideration of the timing challenges that offshore wind faces. We strongly support that offshore wind in cluster 15 warrant additional consideration and being studied without delay in normal timeline in parallel with CAISO 2023-2024 transmission planning process.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

RWE is a member of several industry groups and generally support the proposals presented by LSA(Large-scale Solar Association) and ACP-CA if submitted. 

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

RWE is a member of several industry groups and generally support the proposals presented by LSA(Large-scale Solar Association) and ACP-CA if submitted. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

RWE is a member of several industry groups and generally support the proposals presented by LSA(Large-scale Solar Association) and ACP-CA if submitted. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

RWE is a member of several industry groups and generally support the proposals presented by LSA(Large-scale Solar Association) and ACP-CA if submitted. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

RWE is a member of several industry groups and generally support the proposals presented by LSA(Large-scale Solar Association) and ACP-CA if submitted. 

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

In the Straw proposal[1] issued by CAISO on March 13, the Cluster 15 window for submission of projects is proposed to be April 3-17, 2023.  CAISO states that projects submitted into Cluster 15 will be reviewed for completeness, but analysis of the projects will not start until the evaluation of the Cluster 14 projects is complete and the updated evaluation criterion for the Track 2 Generator Interconnection and Deliverability Allocation Procedures (GIDAP) process is finalized.  CAISO states that the Track 2 GIDAP evaluation criterion will be applied to the evaluation of the Cluster 15 projects. 

CAISO should delay opening the window for submission of projects into Cluster 15 until all Cluster 14 projects have been evaluated and the Track 2 GIDAP criterion have been established. CAISO should delay opening the window for submission of Cluster 15 projects for the following reasons.

1. In the Straw proposal, the CAISO states that opening the Cluster 15 window now will reduce an even greater number of projects applying if the Cluster window is delayed.  In fact, the CAISO has proposed to use the Track 2 results to identify locations and technologies that will be applied to Cluster 15. If CAISO delays opening Cluster 15, the projects that apply to Cluster 15 will know if they are well positioned to be analyzed in accordance with the Track 2 evaluation criterion or not. The Track 2 evaluation criterion will create a regulating force on the number of projects that will apply.  Delaying opening the window for Cluster 15 should result in fewer projects applying for interconnection and those that do should be in areas that are most beneficial to the grid and load-serving entities.
2. Opening the Cluster 15 window without the Track 2 evaluation criterion in place would be discriminatory to project developers as they have no guidance on what projects, locations, or technology will be prioritized in the Track 2 evaluation. 
3. Opening the project submission window in April 2023 and then delaying project evaluation until 2024 creates significant hardship for project developers for costs associated with developing a project for submittal into the Cluster evaluation process.  In addition to submission fees, project developers are required to show site control and incur costs associated with the project site, technology reservations, and other project costs without a timeline or clear evaluation requirements from CAISO.
4. During the Stakeholder call CAISO staff indicated that preferred locations or zones would be identified for technologies to interconnect with the CAISO transmission grid.  These zones are expected to be included in the draft 2022-2023 TPP report due in late March 2023.  Developers of projects for Cluster 15 would have no ability to make adjustments to projects based on the identified preferred zones for interconnection if the Cluster 15 window is opened as currently proposed from April 3-17, 2023.

[1] Issue=Paper-and-Straw-Proposal-Interconnecton-Process-Enhancements-2023-Mar132023.pdf (caiso.com) (http://www.caiso.com/InitiativeDocuments/Issue=Paper-and-Straw-Proposal-Interconnecton-Process-Enhancements-2023-Mar132023.pdf)

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

The Straw Proposal identified offshore and out-of-state wind as a technology that required special consideration in Cluster 15.  CAISO should include pumped storage technology as part of any special consideration in interconnection and the TPP process[1].  During the stakeholder call held by CAISO on March 13, 2023, CAISO staff indicated that both out-of-state and offshore wind technologies need special consideration due to supply chain challenges and the long lead time nature of the technology.  Several commenters noted that other technologies also fall into that category including pumped storage hydropower.  As part of the 2021-2022 TPP evaluation by the CAISO, the CPUC issued Decision 21-02-008114 on February 17, 2021. The CPUC’s decision adopted the following reliability and policy-driven base portfolio and two sensitivity portfolios with updated assumptions from the CEC’s 2019 Integrated Energy Policy Report as detailed in Attachment A[2] of the order for study in the CAISO 2021-2022 transmission planning process:

(a) A reliability and policy-driven base-case portfolio that meets the 46 million metric ton GHG target by 2031 (Base Portfolio)[3];

(b) A portfolio that meets a 38 million metric ton GHG target by 2031 as a policy-driven sensitivity (Sensitivity 1 Portfolio)[4];

(c) A portfolio to test transmission needs associated with offshore wind (OSW) and a 30 million metric ton GHG emissions target by 2031 (Sensitivity 2 Portfolio)[5].

In all three portfolios provided by the CPUC, pumped storage is identified as a technology that is needed to achieve California’s policy objectives.  Because pumped storage technology is subject to similar supply chain disruptions and long lead time for equipment and permitting as offshore and out-of-state wind projects, new pumped storage projects should be given the same consideration as offshore wind and out-of-state wind as a technology that requires special consideration in both the TPP process and in Cluster 15, and subsequent Cluster evaluations.

[1] CAISO Straw Proposal for GIDAP, Other Issues for Consideration, page 10.

[2] ftp://ftp.cpuc.ca.gov/energy/modeling/Modeling_Assumptions_2021_22_TPP_Final.pdf  

[3] The CPUC Base Case Portfolio 46 MMT with 2019 IEPER (2031) results identified 747 MW of pumped storage technology. 

[4] The CPUC Policy Driven Sensitivity Portfolio #1, 38 MMT with 2019 IEPER (2031),  identified 1,700MW of pumped storage.

[5] The CPUC Policy Driven Sensitivity Portfolio #2 the “Offshore Wind Sensitivity Portfolio”, identified 1,076 MW of pumped storage.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

SDG&E supports CAISO’s proposal to postpone Cluster 15 requests. This will help improve the CAISO Generation Interconnection and Deliverability Allocation Process (GIDAP) as well as the quality and accuracy of study results. These changes represent a first step to ensure that study processes are producing meaningful results that are more actionable and useful than those available through today’s processes. Furthermore, SDG&E supports CAISO’s efforts to make “significant and transformative improvements” to the interconnection process before any new cluster window is open in the future. Failing to significantly transform the interconnection process now and manage the queue to a reasonable size will continue to delay future cluster projects, the development of non-speculative projects, and the efficient use of interconnection personnel.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

No Comment

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

SDG&E generally support CAISO’s proposal to limit Interconnection Requests (IR) and studies to areas where there is available transmission capacity and where local state policies have set actionable procurement targets for resources that are seeking Full Capacity Deliverability Status (FCDS). This will ensure that there is a better linkage between the State’s resource planning process and the FERC-approved CAISO GIDAP. However, SDG&E notes that some projects might want to interconnect to the grid and be Energy Only (EO). The recent IRP portfolio calls for a significant amount (~ 20 GW) of EO resources based on information available in CAISO 2023-2024 Transmission Planning Process (TPP) Draft Study Plan. It is SDG&E’s understanding that FCDS and EO resources will need to be developed in tandem to achieve the State’s policy goals. It is also SDG&E’s understanding that EO resources could be developed anywhere they choose, irrespective of available transmission capacity. 

Therefore, in order to further prioritize IRs and support FERC Open Access Transmission Tariff, SDG&E recommends that CAISO develops: 1) a strong and time-based set of commercial viability criteria for Energy Only (EO) projects that may desire to interconnect regardless of deliverability available in certain areas 2) A higher non-refundable deposit or withdrawal penalties, 3) bus-level charging capability due to the amount of Energy Storage in the IRP (and subsequently the interconnection queue). SDG&E notes a lack of conversation around charging capability, or lack thereof, and hopes that CAISO might lead efforts to quantify it at the bus or zonal level. It may then be possible to prioritize Interconnection Requests for Energy Storage (FCDS and EO) that have sufficient charging capability. 

SDG&E recognizes that there may be a diverse set of views on potential commercial viability criteria. These reforms would be best resolved in workshop settings where stakeholders and CAISO can deliberate on the optimal solution. 

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

SDG&E generally supports the proposal put forth in section 3.2 and looks forward to exploring the implementation details of the proposals. If implemented correctly, preliminary PTO screening (including for the study process), interconnection position auctions, and use of generic results (such as previous cluster and TPP study results) can be very beneficial in streamlining the interconnection process. SDG&E also recommends that the CAISO reviews how long projects can remain in the queue and the use of non-refundable deposits for projects that win the auction to ensure that non-speculative projects move forward. Lastly, SDG&E notes that over the past clusters there have been instances where the same entity have submitted multiple applications around the same location. SDG&E would appreciate if as part of the IPE process a solution could be found on how many interconnection requests an entity can submit around the same location. This will also help level the playing field and avoid that in one area one entity, with more funds than others, wins all the auctions. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

SDG&E maintains that more stringent requirements for commercial viability should be used for Phase II entry. SDG&E encourages a collaborative workshop to determine reasonable commercial viability criteria for advancement to Phase II. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

SDG&E supports CAISO’s proposal of only opening a new interconnection request window when warranted. In addition to considering the size of the queue with respect to the number of IR that have executed agreements, SDG&E recommends considering 1) the forecasted transmission capacity or load in an area, 2) the size and type of the CPUC IRP portfolio within the next 7 years. The 7-year timeframe could be used since it matches how long, based on the CAISO tariff today, that projects are expected to remain in the queue before they lose their deliverability allocation. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

The proposals in section 3 represent positive steps towards managing the interconnection queue and in the long run will benefit all parties involved in the interconnection process. SDG&E agrees with CAISO’s statement that “the immediate and long-term need for new resources is not served by studying thousands of megawatts above the current and future capacity on the ISO grid at levels not supported by CPUC portfolios.” SDG&E looks forward to exploring these in more detail, while recognizing there may be open access concerns with elements of section 3.  

There may be secondary concerns with enabling generation portfolios to serve load during all hours of the day, as noted in section 3 of these comments. Again, SDG&E encourages CAISO to consider addressing hyper localized transmission constraints that may limit the ability of Energy Storage facilities to fully charge. 

 SDG&E provides high-level alternative proposals below in section 8 of these comments. These proposals draw heavily on existing processes and timelines while streamlining current workflows and reducing demand on resources across all stakeholders.   

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

SDG&E recognizes that significant work will be necessary to achieve the goals of the IPE initiative. Either supplementing the current stakeholder engagement process or having working group sessions should be considered to achieve the “significant and transformative improvements” that are needed.  Alternatively, it may be beneficial to consider supplementing the web conference service with Audience Response Platform and holding a technical conference to work through interconnection process challenges.  

SDG&E provides the following high-level overview of proposed reforms to the Interconnection Process. The goal of SDG&E’s proposal is to reduce the impact on resources across all stakeholders, reduce the preparation work for early-stage studies to provide results more quickly, and apply commercial viability criteria or some form of controls between each step of the process. Taken together, SDG&E believes the proposed changes will make better use of resources while allowing projects to come to market in a more efficient and timely manner to support regional reliability and policy goals. 

  Key Elements of Reformed Interconnection Process: 

1. Simplify and standardize IR data to reduce resource impact of technical validation in during initial IR. 

2. Expand Scoping to provide more information up front while allowing queue position and queue priority retention.  

3. Require IFS posting for PTOs IF and IRNUs to proceed to Phase I and/or Commercial Viability demonstration Reduce scope and level of detail for Phase I to provide results more quickly 

4. Require demonstration of Commercial Viability to enter Phase II study 

5. Reduce scope of level of detail for Phase II, incremental changes from Phase I due to withdrawals. 

6. New Cost Estimates, Cost Responsibility and Cost Caps not set until Phase II. 

7. Replace Reassessment and part of Phase II with Annual Operational Studies for all projects but require demonstration of Commercial Viability to be included, results required for GIA. 

8. Require Commercial Viability demonstration to be eligible for draft/tender of GIA. 

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

SEIA appreciates the opportunity to comment on the 2023 Interconnection Process Enhancements (IPE) straw proposal. SEIA understands the many challenges facing both CAISO and developers as the Cluster 15 open window approaches. Given the delays and overall uncertainty with Cluster 15, SEIA recommends CAISO afford Cluster 15 interconnection customers (IC) additional flexibility to modify or withdrawal Cluster 15 interconnection requests (IR) with limited penalties. SEIA proposes the following reforms to the treatment of Cluster 15 ICs. SEIA proposes discussing these reforms in the IPE stakeholder process to the extent CAISO has concerns with potential impacts on existing interconnection requests.

1. Make Cluster 15 in lieu site exclusivity deposits fully refundable until after the Cluster 15 Phase I study. This will afford Cluster 15 ICs more time, information, and flexibility to identify and secure suitable sites given the delays to Cluster 14 and Cluster 15 and the uncertainty around Cluster 15 reforms.
2. Allow for ICs to modify project capacity (increase or decrease), fuel type (i.e., add storage), and/or point of interconnection (within one substation range of the IR POI). CAISO should accept these modifications until at least 30 days following FERC issuance of an order accepting Track 2 changes to provide ICs with sufficient time to understand the new rules and adjust their IRs as needed.
3. Allow for withdrawals at little to no cost to ICs up until Cluster 15 Phase I studies.

SEIA proposes that Track 2 of the 2023 IPE include consideration of a second limited interconnection request window for Cluster 15 following the FERC order accepting Track 2 changes. A second limited window would provide ICs the opportunity to submit interconnection requests that are better aligned with the design components contemplated under Track 2.

Finally, SEIA thanks the CAISO for its decisions to prioritize continued progress on the Cluster 14 study process and to not make further changes to the rules and timelines for Cluster 14.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

SEIA believes this element of the Track 1 proposal raises open access concerns by limiting access to a separate expedited interconnection process to certain resource types. To the extent CAISO sees the need for a separate interconnection process (“Cluster 15a”), the expedited track should be technology neutral. For example, the separate interconnection process can be open to any resources identified in a CPUC resource plan.

SEIA asks that CAISO provide more information on the need for special consideration for certain resource types, the criteria CAISO will employ to determine eligibility for Cluster 15a, and the expected interaction with Cluster 15b timing and costs since it is unavoidable that administering a separate, higher-priority interconnection process for certain resources only will have a negative effect on the remainder of Cluster 15. 

SEIA questions whether priority in the study process is what is needed to give long-lead time resources sufficient time to reach commercial operation. Rather, SEIA suspects that the longer development and construction timelines of these resources could be better served by providing more time at the end of the GIDAP rather than at the front end. 

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

SEIA appreciates CAISO’s interest in resource development in areas with commercial interest and transmission capacity but believes this is best achieved through competitive market design rather than prescriptive policies that limit or preclude access to the CAISO transmission system and markets. SEIA believes the combination of increased data transparency, specifically greater insight into available and planned transmission capacity, and the application of readiness requirements will achieve the desired outcome without limiting competition.

The instant proposal introduces open access concerns and relies on several administrative solutions that will introduce uncertainties that further complicate resource development and stifle competition. For example, identifying priority zones ahead of an open interconnection request window will focus the existing levels of hyper-competition in the interconnection queue to select areas which will translate to higher land prices in those areas, which will lead to increased costs for developers and, ultimately, higher rates for ratepayers. Further, prioritizing certain areas ignores benefits to the system in “lower priority” areas like reductions to congestion. CAISO should not prevent or deprioritize IRs that do not align with the IRP. Instead, CAISO should provide developers with more data, like expected interconnection costs, and implement readiness requirements that incentivizes more mature or competitive IRs. 

It is important to note that the busbar mapping that will likely be used to identify high priority areas was designed for system planning, not resource siting. SEIA is concerned that prioritizing resources based on busbar maps introduces circular logic that could impact future development. The “commercial interest” captured by busbar mapping is largely informed by the CAISO interconnection queue, so future busbar maps will reflect the IRs submitted which reflects the busbar maps, and so on. SEIA supports the use of commercial interest as criteria to inform the transmission planning process and is concerned that changes proposed under Track 2 could undermine the interconnection process and skew the commercial interest data which could ultimately undermine appropriate transmission planning.

Additionally, prior to the CAISO moving forward with approval of this element, since the IRP is directly governed by the CPUC, we urge the CAISO to include them and/or seek input throughout the stakeholder process for the Track 2 changes moving forward.

Finally, if the CAISO chooses to adopt this proposal, SEIA urges the CAISO to establish a process by which ICs can dispute their exclusion from the study process.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

As stated above, SEIA believes limiting the number of IRs in a study area violates FERC’s open access principles. Any attempt to limit the capacity studied in each of these zones will likely be based on an administratively determined level of attrition which will lead to regular over- or under-procurement. SEIA recommends that CAISO adopt readiness requirements like higher site control requirements to achieve the same effect without hindering competition.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

SEIA opposes this element of the Track 2 proposal. Requiring a PPA or shortlist effectively dilutes the value of the PPA with respect to commercial readiness and project viability. Phase I studies do not provide sufficient information to execute a PPA without baking in additional optionality to account for project uncertainty and risk. SEIA believes that there are more appropriate tools to ensure that projects are maturing as they move through the interconnection process, like permitting and site control requirements, which do not squeeze out merchant generation like a PPA requirement or undermine the value of the PPA itself.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

The interconnection request window timeline must be predictable and transparent. It should not be left to the CAISO’s discretion. SEIA asks that any replacement of the current annual process have a clearly defined date, cadence, or “trigger” to open a new window and provide sufficient time for developers to conduct the steps needed to assemble a competitive interconnection request. Without clearly defined timelines and criteria, removing the annual open window will likely lead to more speculative or immature interconnection requests which would conflict with the goals of the IPE.

Additionally, inability to accurately forecast queue window openings severely impacts the much needed alignment between the CPUC’s IRP Process, the CAISO’s TPP and the amount of available generation resources available to adequately assess the needs for future planning efforts. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

As mentioned in Section 3, SEIA supports the application of readiness requirements that prioritizes more mature projects while respecting project development timelines and activities. Readiness criteria like the PPA requirement contemplated in Section 5 do not align with project development timelines for independent power producers (IPP) as they cannot reasonably execute a PPA when the interconnection costs are unknown. This makes IPPs less competitive, necessitates high-priced contracts to account for cost uncertainty, and dilutes the value of PPAs as described above.

SEIA supports alternative forms of limited commercial readiness that more effectively reflect the viability of a project. For example, providing ICs the opportunity to demonstrate due diligence beyond the readiness criteria like site control and permitting. This not only weeds out half-baked projects but incentivizes well-researched interconnection requests. CAISO can also tie commercial readiness deposits to estimated network upgrade costs. This incentivizes both careful consideration of the costs and risks for the ICs and network upgrade cost estimate accuracy by transmission providers.

SEIA believes readiness requirements like the examples provided above will assist in managing the number and quality of interconnection requests submitted. By design, criteria like these will incentivize project development in the commercially viable zones, consistent with the goals of this initiative.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

SEIA fully supports CAISO’s proposal to establish working groups to develop the policies considered under Track 2 and looks forward to working with CAISO on these issues.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Silicon Valley Clean Energy (SVCE) is a Load Serving Entity (LSE) providing renewable energy to thirteen communities in Santa Clara County, California. SVCE appreciates the opportunity to comment on the Issue Paper and Straw Proposal for the 2023 Interconnection Process Enhancements. CAISO’s interconnection request process drives generation development timelines and CAISO is the authority on project interconnection and deliverability costs and timelines. Changes to CAISO process will have direct effect on SVCE’s procurement, and SVCE supports CAISO’s goal of making significant and transformative improvements regarding coordination of resource planning, transmission planning, interconnection queuing and power procurement to achieve state reliability and policy needs.  

At this time SVCE has no comment on CAISO’s Track 1 proposal to delay the study work for Cluster 15 interconnection requests for a year or more, except to request that CAISO continue its work making interconnection request and transmission data clear and accessible for LSEs to consider as procurement decisions are made. It is clear that unique accommodations will be needed for the upcoming cluster, and SVCE requests that immediately after closing the Cluster   window the CAISO publish the Cluster 15 project information to the public facing RIMS interconnection queue and produce a report that discusses how Cluster 15 aligns with known transmission capacity limitations and minimum feasible timelines for Cluster 15 projects to achieve COD by region, to the extent there are known precursor network upgrades needed in those areas, or network upgrades that are expected to be triggered because the area is effectively “at capacity.” This information will help LSEs understand the circumstances for projects being considered that indicated Cluster 15 as their interconnection pathway, and will provide data to support analysis of CAISO’s Track 2 proposals.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

At this time SVCE has no comment on CAISO’s Track 1 proposal to give priority treatment to out of state and offshore wind projects. Similar to the comments above, SCVE request that CAISO synergize the most recent known information about interconnection for these wind projects and produce a document that summarizes the following information:

• What transmission capacity currently exists for these projects,
• What new transmission has been approved to increase capacity, and
• What may yet still be needed to meet state renewable goals .

This information would help LSEs to understand the scope and minimum timelines needed to put this transmission into service and will aid LSEs as they consider these projects for procurement. Even in the event that this policy does not go forward, producing and providing the information publicly gives LSEs the opportunity to take it into consideration.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Currently SVCE has no comment on CAISO’s Track 2 proposal to apply restrictions to interconnection requests in zones with existing or planned transmission. In any policy outcome it is critical that the CAISO work with the CPUC to ensure busbar mapping accurately reflects development potential and CAISO should focus on providing developers with useful pre-application information. A policy like this would benefit from detailed collaboration in a workshop format to identify mismatches between the interconnection process and busbar mapping process. Busbar mapping was designed for system planning rather than land availability for resource siting or commercial interest.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

Regardless of the outcome of CAISO’s proposal to limit the number of IRs studied in each zone based on existing and planned transmission capacity, SCVE requests CAISO provide this very useful and valuable information for developers to consider and LSEs to reference. SVCE suggests that although it requires a binary rule or a mandatory screen to control IR submission, CAISO can have great influence on IR submission and procurement environment by providing easy-to-understand and sufficiently detailed date data for stakeholder and LSE use.

Regarding the idea of deprioritized queues, SVCE notes that separate queues are likely to be chaotic to understand for LSEs and developers.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

In Section 3.3 the CAISO asks LSEs to share the viability of requiring projects to have a PPA before entering Phase II. One of CAISO’s concerns is whether enough time could be allocated between the Phase I and Phase II studies to accommodate the time needed for LSEs to perform the procurement processes. Procurement could feasibly be done within the timeframe between Phase I and Phase II but the true answer to this question is more complex, and would require a detailed analysis as there are there are many considerations that go into when to undertake procurement.

LSEs are ordered to do procurements in tranches with specific online dates. So in order to perform an efficient procurement cycle Phase I reports would have to be sufficiently detailed and accurate for developers or LSEs to rely on when undertaking negotiations. CAISO has made clear that due to the quantity of projects staying in queue throughout the whole study process, Phase I results are not very accurate.

Equally important, LSE’s need clear and unbiased information about project deliverability before shortlisting a project; every seller is understandably optimistic about their project and about their chances. Deliverability allocation information comes in the form documentation provided by sellers that the CAISO has allocated them deliverability via the Transmission Plan Deliverability (TPD) process. SVCE also understands from sellers that negotiating PPAs that contain with “deliverability offramp clauses” makes project financing difficult.

Regardless of the outcome of this proposal the sooner the CAISO can provide interconnection customers deliverability certainty as soon as possible in the study process – that could mean a rearrangement of the study activities, or an expansion of staffing capabilities. Interconnection is the foundation of procurement, and California’s supply needs are only projected to grow, increased staff ability can only help as CAISO moves forward.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

Currently SVCE has no comment

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

 Currently SVCE has no comment

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

In addition to transparency items referenced in these comments SVCE would like to request CAISO provide Visibility on ACC constraints. This information is of interest to LSEs but are not clearly identified in study reports, interconnection agreements, or on CAISO.com.

Finally, this recent level of projects requesting interconnection is a new phenomenon, but to meet California’s goals of a GHG emission free grid this level on request is likely to remain for some time.  In fact, some cluster sizes could even grow beyond what we are currently seeing.  CAISO should consider more than process improvement but leveraging some sort of combination of consulting services and additional engineers to speed up throughput in the 5–10-year time horizon

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

The Six Cities take no position on the proposal for addressing Cluster 15, including the proposal to retain the current timing for opening the request window but deferring validation and scoping meetings until April 1, 2024.  It seems clear that proceeding on the existing timeline for Cluster 15 while also continuing to manage the workload associated with Cluster 14 is untenable. 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

The CAISO is seeking input on whether certain “long lead time” resources, such as offshore wind and out-of-state wind projects, that may be submitted during the Cluster 15 request window next month, should be advanced for interconnection study purposes ahead of other, more conventional resource types in Cluster 15.  At this time, the Six Cities take no firm position on this issue, but offer comments for the CAISO’s consideration. 

In the Six Cities’ view, it is preferable for the CAISO’s interconnection processes to remain technology neutral and not include procedures to advance the study of certain projects, or certain types of projects, ahead of procurement processes by local regulatory authorities (“LRAs”), such as the CPUC and publicly-owned utilities such as the Cities.  With that said, the unique complexities cited by the CAISO associated with development of offshore wind projects might provide a justification for accelerating—or, rather, not deferring—the study timeline for interconnection of these resources as compared with conventional resource types if these projects are supported by LRA procurement and can be evaluated on an expedited basis without disadvantaging earlier queued projects.  It is less apparent that the same lead-time considerations are applicable for out-of-state wind.  Irrespective of technology type, the Six Cities support prioritizing projects with offtakers that are supported through power purchase agreements (“PPAs”) (or that are shortlisted for PPAs) or are being developed by load-serving entities (“LSEs”) seeking to meet their own loads over other projects that do not reflect LRA-authorized procurement. 

The CAISO’s discussion of how the in-state transmission system will be evaluated to accommodate both offshore wind and out-of-state wind would benefit from clarification.  (See generally Issue Paper at 11.)  As noted by the CAISO, upgrades to the existing grid associated with offshore wind and out-of-state wind are being assessed as policy projects under the CAISO’s TPP, consistent with CPUC resource plans.  (Id.)  Additionally, the CAISO states as a “point of emphasis” that intra-state transmission capacity needed to accommodate offshore wind and out-of-state wind should be “above and beyond unused existing and planned capacity that has already been allocated to other projects earlier in the queue.”  (Id.)  The Six Cities understand this to mean that existing and planned capacity that is already dedicated to other, previously-queued resources will not be taken away from these resources in order to accommodate either offshore or out-of-state wind projects.  The Six Cities generally support this approach, but the CAISO should clarify what it means here.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

In general, limiting interconnection requests to locations where transmission capacity is available appears to be a reasonable approach that will avoid interconnection requests that are for facilities in unsuitable locations.  With that said, the Six Cities note that the CAISO will identify such locations based upon its transmission plans predicated on CPUC planning portfolios.  How will the CAISO address interconnection requests associated with projects developed or procured by non-CPUC jurisdictional LSEs?  The Six Cities do not support de-prioritization of such projects, particularly where the interconnection customer is an LSE seeking to serve its own load or the project is otherwise supported by a PPA with a non-CPUC jurisdictional LSE. 

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

The Six Cities support measures to limit the number and MWs of projects that are studied, including through the use of some of the measures that the CAISO highlights in the Issue Paper/Straw Proposal (i.e., screening criteria, availability of “generic” study results, etc.) and, potentially others, such as a revised deposit structure and/or changes to deposit amount, timing, or refundability criteria.  For example, the CAISO could consider implementation of an additional deposit associated with maintaining a position in the interconnection queue (above and beyond the existing deposit requirements) that would be refundable when a project enters service.  With respect to the proposal for an auction of interconnection queuing position or study priority, the Six Cities are concerned that this type of process may result in increased costs that would be difficult to predict and likely reflected in PPA prices.  The Six Cities do not take a firm position at this time on the various options that may be available to manage the volume of interconnection requests, but look forward to evaluating proposed approaches during this initiative. 

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

The Six Cities are open to considering this proposed modification, particularly given the CAISO’s statement that it may have the benefit of more closely aligning the interconnection process with the process for obtaining transmission planning deliverability (“TPD”) allocations.  In the Six Cities’ experience, it is challenging from a procurement practice and risk management perspective to finalize terms for PPAs with resources when there is not also high confidence that a resource will obtain TPD.  The Six Cities strongly support measures to better synchronize the interconnection and TPD allocation processes. 

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

The Six Cities do not have a position on this proposal at this time. 

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

As discussed in their response to question #5 above, the Six Cities support measures that will streamline and synchronize the interconnection process and the TPD allocation process.  It is not efficient to allow resources to move through the interconnection process when there is a low probability that these resources will obtain TPD allocations.  Without TPD, it is significantly less likely that resources are financially viable and able to proceed to development.  While the Six Cities support the CAISO in its efforts to manage the interconnection queue, the Six Cities also note that issues of interconnection and deliverability are closely related.  Therefore, it will be critical to ensure that any changes to interconnection procedures adopted in this initiative and any changes to the deliverability assessment methodology (and, presumably, the resulting TPD allocation process) that are considered in the Generation Deliverability Methodology Review initiative are appropriately aligned.  

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

The Six Cities do not have any additional comments at this time. 

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

SCE is currently on track to maintain the existing tariff schedule for QC14 Phase II, including publication of Phase II reports by November 2023.  SCE supports the CAISO's proposal to accept QC15 interconnection requests (IR) during the normal April 3-17 open window.  Subsequently, the IR completeness review of IRs received during the open window and the final list of adequate IRs should be completed by May 1, 2023. SCE agrees with the postponement of the validation of QC15 IR, project scoping meetings and studies until after completion of the QC14 Phase II studies.  Restarting the QC15 process in April 2024 should allow enough time for the 2023 IPE Phase 2 topics to be developed and in effect prior to focusing on QC15 and maintains the crucial close alignment between the GIDAP and TPP.

SCE seeks clarification on the timing regarding when the CAISO plans to release the Transmission Owner (TO) IRs and supporting documentation to the TOs.   If the release of the IRs and supporting documentation does not happen until the actual validation process begins, April 1, 2024, will these TO projects be assigned a queue position once the CAISO deems their IR package submittal complete, meaning they have satisfied the requirements set forth in GIDAP Section 3.5.1, or will the CAISO assign queue positions after the IC’s IRs have been deemed valid?

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

SCE does not have information to justify the need for a separate study timeline at this time.  SCE is open to further discussions with additional references. While the Issue Paper identifies offshore wind and out-of-state wind, there may be other generation resources with similar permitting hurdles or long-lead-time construction, such as compressed air energy storage.  SCE is concerned with the prospect of establishing a separate study timeline or process for certain potential QC15 IRs, including offshore wind. The existing GIDAP is technology agnostic and does not favor a certain technology at the expense of discriminating against another from a study timeline and/or process perspective.    The precedent of establishing a separate study timeline and/or process for offshore wind may become problematic when dealing with future innovative generation resource technologies in terms of what criteria would be used to create a new study process. Such a process could raise open access non-discriminatory and comparability concerns.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

SCE generally supports the CAISO’s proposal to only accept or process IRs where the transmission system has available or planned capacity identified in the TPP. It is inefficient and costly to continue to dedicate a significant amount of time and resources to study a large volume of projects in an area without transmission capacity with no further planned expansion. These studies will continue to identify the need for costly Area Deliverability Network Upgrades (ADNUs), which developers have not historically elected to pay for and construct, and would not be included in the TPP when they are not in the resource plan.  This outcome highlights the crucial coordination of the CPUC’s resource portfolios as the baseline in the TPP to identify ADNU’s in a timely manner to increase the available capacity in constrained segments of the grid.  Alternatively, the CAISO may consider limiting IRs under the “full” capacity scenario to Energy Only projects.  However, the CAISO should still evaluate special circumstances, such as a repower of an existing facility.

SCE has concerns about the potentially detrimental impacts of restricting the areas in which IRs may be accepted or processed.  Specifically, procurement may likely be negatively affected in multiple areas. More details need to be provided regarding the impact of this proposal on competition. Also, if developers are competing for the same land locations, this will likely increase land costs in selected areas resulting in higher contracting prices given a higher number of developers bidding for the same land areas.  Finally, SCE is concerned about potential discrimination against certain types of resources/developers if the CAISO only studies projects in certain zones.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

A challenge to limiting the number of interconnection requests in an area is that a study is needed to determine the number/location/size/technology of projects that are relatively straightforward to interconnect. While the details and the process would need significant further stress-testing and consideration, it seems reasonable to use the results of the Phase I study to align the most commercially viable interconnection requests with the most technically viable interconnection locations. This assumes that it is possible to determine commercial viability at this stage of the project development and study, which would likely span a wide range of issues such as site control, generation tie-line routing, permitting, procurement, financial support, and PPA terms. This topic should be discussed further between developers, LSEs, and CAISO or an entity that may be responsible for making such a determination.  SCE cautions that the CAISO should be careful in making these determinations to avoid the appearance of “picking winners.”

A project that is deemed difficult to interconnect according to this process could be required to participate in a new upgrade, such as an Area Delivery Network Upgrade or a new substation to accommodate physical space. Alternatively, they could be waitlisted using generic results and only become active when another project withdraws. Generic results could be challenging to the developers, given a lack of concrete information, and to PTOs, given the high risk to shift future queue cluster cost/timeline responsibility. SCE is open to a discussion on either possible remedy for this uncertainty or a stakeholder discussion to determine that it is still less impactful than the uncertainty created by a super cluster methodology.

SCE remains supportive of some of the proposals from IPE 2021 to move toward “first ready, first served.”  To facilitate interconnection of projects that are commercially viable for QC15 and beyond, SCE urges the CAISO to reconsider its position on allowing interconnection customers to post a deposit in lieu of demonstration of site exclusivity.  Requiring site exclusivity would be consistent with FERC’s Generator Interconnection NOPR, which would require interconnection customers to demonstrate 100% site control when they submit their respective IR.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

SCE appreciates the CAISO’s proposal to require projects to have a PPA or be shortlisted to proceed to Phase II studies, from the standpoint of increasing efficiency in the interconnection process.  However, from a procurement perspective, SCE has more clarifying questions than actual policy position(s) at this time on what is being contemplated and does not support the PPA criteria for entering Phase II studies. The executed PPA option for entering the Phase II study could have an unintended consequence by encouraging LSEs to sign contracts that lack commercial certainty from a cost and timing perspective.  Any PPA based on a bid without such information has the potential to create sham contracts solely for the purposes of holding a queue position.  Such a structure also places the IOUs at a contracting disadvantage to non-IOU LSEs who are not subject to CPUC oversight of their contracting activities and do not receive this additional scrutiny.  SCE may be able to support a structure that takes into account shortlisting, however, additional discussion on how this mechanism would work is needed.

From a procurement perspective, currently knowing a counterparty has requested Full Capacity Deliverability Status (FCDS) and that they are further along in the signing of their LGIA is a determining factor for SCE in shortlisting and prioritizing a project.  In large part, because of the additional certainty around the price in the PPA and the expected on-line date of the resource.  Thus, requiring developers to have a PPA or be shortlisted is in reverse order of the current contracting process.

Other unintended consequences of requiring a PPA or being shortlisted before moving to Phase II include:

1. Increased project or PPA failure risk.  Executing a PPA or project shortlisting without important decision-making information such as viability assessments, online dates, and interconnection costs will increase the risks that PPAs fail and could ultimately increase the cost to meet the State’s procurement goals through over procurement needed to account for project failure.
2. Increased costs for SCE customers:
   1. Increased O&M: Will require additional resources to manage the additional workload due to this new process that will require an LSE to select more shortlisted counterparties and sign more PPAs (to account for shortlisted counterparty to drop out and PPA failures). Shortlisting procurement activities (conform & compliance review, valuation, negotiations, etc.) and PPA contract management (management of disputes, delays & default associated with signed PPAs that fail) will require additional resources for LSEs.
   2. Increased contracting costs due to lack of interconnection cost information and increased risk of PPA failure.

• Do the detailed and individualized results of the current Phase 1 and Phase 2 study process provide truly useful information to those procurement functions given how local network upgrades (NUs) evolve as the queue “shakes out” to projects ultimately moving to construction?
  • Yes, the detailed and individualized results of the current Phase 1 and Phase 2 process provide information for SCE procurement to assess viability and timeframes for online dates.  Detailed studies provide costs that will ultimately be borne by SCE customers. 
  • Projects that are shortlisted or PPAs executed prior to receiving meaningful indicators for viability, online dates, and costs have a much higher risk of failing, which could jeopardize system reliability.
• Alternatively, would more timely and actionable results based on a more generic study process better meet their needs, especially considering the bulk of NU costs are ultimately refunded to ICs and recovered through transmission rates and capacity contracts?
  • In concept yes, however, it would depend on the quality of the generic studies and the type of information that the generic studies would provide.  Specifically, SCE would want to assess overall project viability, project online dates, and costs.
  • SCE seeks clarification from the CAISO on what type of generic study would replace the Phase 1 and Phase 2 studies and what information would be provided as a result of conducting the generic studies to help inform the LSEs in their procurement decisions.  SCE also seeks clarification on the timeframes that the generic studies would be conducted and completed.  SCE is concerned that if generic studies do not yield sufficiently detailed information and an LSE nonetheless still executes a PPA with such impacted developers, this may ultimately lead to the misidentification of economically viable projects with increased risks of subsequent project failures and increased costs for SCE’s customers.
  • SCE requests that the CAISO explain how much earlier in the process it would be able to provide TPD.
  • CAISO should also consider rate making differences between IOU and non-IOU LSEs.  Affordability is an important issue for all LSEs.  However, non-IOU LSEs are not impacted by T&D rates in maintaining affordability for their customers. Thus, these entities do not need to consider the cost of network upgrades when making procurement decisions, which could result in low contract prices (gen rate of the non-IOU LSE) but high network upgrade costs (T&D rate of the IOU).  SCE considers both rates and the impact of affordability on its customers.  As such, when making procurement decisions, SCE takes into consideration transmission upgrade costs. Any changes in the study process must consider this difference between the LSE types.

• SCE suggests that the CAISO initiate stakeholder workshops to discuss project viability and/or commercial viability screening criteria (other than a signed a PPA or being shortlisted).

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

SCE is concerned with the CAISO’s proposal that would essentially preclude submitting IRs for an indefinite period. Since we cannot rule out IRs pursuant to the Independent Study Process, it is not clear what avenue these projects would have to interconnect if they fail the electrical independence test and find themselves unable to proceed under the cluster process if there is no window to submit their respective IRs.  Some projects may be built for other purposes and generate electricity as a by-product. Other new IRs could leverage existing facilities, such as adding new resources to an existing generation tie line.  The trigger to open a new window should not be based on capacity or number of projects in the queue, as SCE has seen some projects linger for long periods of time or start and stop to avoid getting kicked out.  Any proposal should consider the need for additional resources and commercial viability requirements.  Also, SCE requests that the CAISO explain how and why it believes the proposal to open a new Interconnection Request window when warranted does not contravene open access requirements.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

SCE has no comment at this time.  However, the CAISO should remain open to other possible solutions.  It is critical that any new process must be able to meet the needs of the transmission study process as well as the procurement processes of LSEs.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

The CAISO should consider taking steps to clear the existing queue. Projects that have received a Phase II report and have not timely executed a LGIA should be removed from the queue.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

TNC does not submit a comment on the handling of Cluster 15 interconnection requests. 

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

TNC agrees that it is “important that our process be optimized for transmission upgrades California knows it will need for longer-term resource development, such as out-of-state and offshore wind.” Additional consideration should be given to a separate track to study these long lead-time resources. TNC’s Power of Place West report identifies the need for both resources to achieve West-wide decarbonization targets. 

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

TNC supports the ISO’s proposed prioritization of areas of existing transmission and “planned capacity,” where “planned capacity” is informed by least conflict and low impact-driven planning, as reflected in the California Energy Commission (CEC) Land Use Screens for Electric System Planning. 

Regarding existing transmission - TNC agrees that “decisions about resource procurement and the interconnection queue should be effectively shaped and informed to take advantage of transmission and interconnection capacity that exists or is already planned and under development.” The findings from TNC’s recent, techno-economic and geospatial Power of Place West study (published in the January 2023 edition of the Proceedings of the National Academy of Sciences) support prioritizing interconnection to and near existing transmission. TNC’s research found that more than half of the additional transmission capacity needed for the West’s transmission network to support net-zero in the West can be achieved by targeting grid upgrades and co-locating additional capacity within 6,700 to 7,600 miles of existing electrical utility rights-of-way. Thus, prioritization that considers alignment to existing transmission infrastructure stands to both reduce barriers associated with permitting and unlock meaningful amounts of new resources. 

Regarding planned capacity - TNC urges the ISO to further align identification of “planned capacity” to our State land use planning investments and resources, such as the Desert Renewable Energy Conservation Plan, “A Path Forward” solar planning for the San Joaquin Valley, and the CEC Land Use Screens for Electric System Planning. TNC agrees with other stakeholders who have noted that directing investments and generation to areas with low environmental impacts improves project viability and reduces costs. Projects in high environmental impact locations burden the interconnection queue. Priority transmission zones should also be carefully scoped to best reflect land use screens results and not risk being too broad to be useful.

An approach that prioritizes both: 1) low impact, low conflict, commercially viable planned capacity and 2) existing transmission will help the State accelerate important capacity expansion to meet SB 100 in a timely and affordable way. 

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

TNC supports the concept of a screening criteria, ­provided the criteria are informed by land use screens to identify and prioritize requests located in low impact and low conflict areas or zones, such as the CEC Land Use Screens. Such an approach serves as a preliminary indicator of whether a project is more or less likely to be in conflict with communities, highly productive agricultural land, biodiversity, and important water systems and, therefore, whether it is likely to succeed. Proposed updates to the CEC Land Use Screens, including new screens that consider climate resilience, are especially relevant to transmission planning, as fire, for example, poses a present and growing threat to grid reliability and the State’s transmission corridors.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

TNC does not submit a comment on the proposal for projects to have a PPA to be shortlisted.  

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

TNC does not submit a comment on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

 TNC’s recommended alternative elements are included in our responses to Questions 3 to 6.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

TNC commends the California Independent Service Operator’s (ISO) efforts, along with the California Public Utilities Commission (CPUC) and the California Energy Commission (CEC),  to “[tighten] linkages among resource and transmission planning activities, interconnection processes, and resource procurement” and, related, the ISO’s intention, reflected in the recent “2023 Interconnection Process Enhancements” issue paper, to “[re-imagine] the interconnections process” to address the growing queue of interconnection requests in support of achieving the state’s accelerated pace of new resource requiring grid interconnection. A queue that results in a more accurate reflection of transmission needs, potential resources that factor in land use conflicts, and procurement needs is critical for timely and focused coordination among agency,  planning, community, developer, and NGO stakeholders and, thus, for reaching California’s clean energy goals.TNC supports ISO’s work to improve the interconnection process and urges the ISO to continue to improve the links between the land-use planning processes and the transmission planning process.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

Vistra appreciates CAISO for acknowledging the tradeoffs involved in determining an appropriate path forward that balances the interest of developers, CAISO, and Participating Transmission Owners during this time of unprecedented, continued congestion in the interconnection process.

While we understand that determining a proposed timeline for Cluster 15 is an imminent and pressing need, we want to see a plan for both Cluster 15 and Cluster 16 that will allow us to return to annual cluster studies that the CAISO can complete without any delays due to parking at around two years from the cluster window close to the second Interconnection Financial Security due date.

Vistra would like to see the queue timelines be managed between now and through opening Cluster 16 such that the CAISO processes can return to a more predictable, recurring interconnection process with the timelines we saw prior to Cluster 14. Vistra proposes the plan should be developed with first principles, such as the CAISO should:

• Focus on completing study process for Cluster 14 and prior clusters before beginning the validation of Cluster 15 projects.
• Adopt a timeline for Cluster 16 that would begin no sooner than one year after the Cluster 15 requests begin their validation process to allow focus on Cluster 15 projects.
• Adopt pre-Cluster 14 timelines for Cluster 15 and Cluster 16 to be able to complete process in roughly two years (~765 days) from when the Interconnection Requests are complete and begin validation to submitting second Interconnection Financial Security payment, assuming no parking.
• Align timeline for beginning validation of new Interconnection Requests in Cluster 15 and Cluster 16 to April 15^th to work toward future cluster timelines returning to pre-C14 sequence.

Consistent with these principles, Vistra supports the CAISO’s Track 1 timeline proposal with the following modification in underlined:

• Accept Cluster 15 interconnection requests during the normal April 3 – April 17 open window.
• Perform the interconnection request completeness review of interconnection requests received during the open window, and finalize the list of interconnection requests that are deemed complete by May 1, 2023.
• Complete Cluster 14 Phase II studies and results meeting by February 22, 2024.
• Begin validating Cluster 15 requests on April 15, 2024.[1]
• Establish a schedule for the major milestones to be included in CAISO’s Tariff Appendix DD that would allow for the Cluster 15 requests to meet the pre-Cluster 14 timelines once the validation begins, such as:
  • Cluster 15 Phase I Study results published by approximately September 15, 2025[2]
  • Initial Interconnection Financial Security due by approximately January 13, 2026
  • Phase II Study results published by approximately November 24, 2026
  • Transmission Plan Deliverability Affidavits due by approximately December 1, 2026
  • Transmission Plan Deliverability results published by approximately March 24, 2027
  • Second Interconnection Financial Security due by approximately May 5, 2027
  • Reassessment by approximately August 21, 2027
• Delay the opening of Cluster 16 application window and Interconnection Request submission deadline to March 1, 2025 and April 15, 2025 respectively.
• Begin validating C16 requests on April 15, 2025.[3]

Implicit in the above is also a recommendation that these steps be taken along with the more holistic policy items in 2023 Interconnection Process Enhancements (IPE) Track 2 and the Federal Energy Regulatory Commission (FERC) Notice of Proposed Rulemaking on Improvements to Generator Interconnection Procedures and Agreements in Docket No. RM22-14 to be ruthless in prioritizing cooling down the queue so that Cluster 15 and Cluster 16 can return to pre-Cluster 14 normal operations. Consequently, we will support the CAISO efforts to achieve the end so that Cluster 16 interconnection requests are due by April 15, 2025 that it could feasibly result in a second Interconnection Financial Security due in May 2028.

Additionally, Vistra requests the CAISO clarify in Track 1 how Interconnection Customers should understand the out-of-cycle Transmission Plan Deliverability allocation process still held annually even though the clusters are delayed. With the delay of Cluster 14, it is our experience that it is unclear whether these are additional opportunities for TPD allocations or if they count towards the projects attempts for TPD. Please clarify in Track 1 final proposal how the TPD allocation procedures should be understood for years in-between (i.e. out-of-cycle) cycles.

[1] Similarly to CAISO, Vistra believes that the validation should begin after Cluster 14 Phase II Studies and Results Meetings are complete roughly around February but where this goal allows a couple extra months to complete by April 15 to account for timeline slipping.

[2] Vistra requests the CAISO clarify that its intent is to also not include system-level stability analyses in the Cluster 15 Phase I Study or if this level of detail will be addressed in a future stakeholder effort leading up to April 2024.

[3] Vistra requests the CAISO clarify that the intent of delaying the validation of Cluster 15 will similarly delay Cluster 16 window close to April 15, 2025. To ensure that Cluster 15 requests can be efficiently studied once begun in April 15, 2024 we believe this is necessary. CAISO proposal should include the Cluster 16 window dates as well.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Vistra sympathizes with the CAISO’s intent in its suggestion to consider whether certain potential Cluster 15 off-shore wind or out-of-state wind should require a separate timeline given their long-lead time for construction after achieving deliverability and executing Interconnection Agreements. Vistra does not support the CAISO proposing to study a subset of C15 resources in a separate timeline under the interconnection rules. Vistra supports allowing the transmission provider to use:

• Sub-regional cluster studies when the sub-regions are sufficiently electrically independent.

Vistra supports giving transmission providers the flexibility to conduct sub-regional cluster studies when the sub-regions are sufficiently electrically independent.  Doing so may allow a relatively less constrained region’s study to proceed quickly even if the studies for more constrained regions proceed based on the newly proposed binding study timeline. Vistra can support a Track 1 proposal that would contemplate expanding the ISP process to sub-regions that are electrically independent if all projects in that region are studied in the sub-regional cluster.

• Independent study processes for individual interconnection requests when the interconnection request is sufficiently electrically independent.

CAISO should only fast track resources that can meet the Independent Study Project requirements or Fast Track process. If the long lead time resources can meet ISP requirements, then the CAISO should facilitate projects that are in the queue or are submitted into the cluster that can be processed as an ISP to be treated in this way. The CAISO should defer any prioritization beyond this that could appear like “queue jumping” until a robust effort has completed to ensure that long lead time projects can be processed timely in a way that does not interfere or jump ahead of other queue projects.

As was evidenced by the discussion during the stakeholder call, this is a very complex issue. The CAISO has been striving to explore various options to address this concern in the Transmission Planning Enhancements efforts that would allow for the reservation of transmission deliverability resulting from the enhancements to the grid associated with the policy portfolios driving those upgrades. While Vistra believes the details are incredibly important, we agree with the CAISO’s previous instinct that this issue is more a transmission planning issue than an interconnection issue. Where it dovetails with interconnection is in how the increased deliverability from these policy upgrades are allocated to projects the state is expecting to see achieve commercial operations.

To illustrate exactly how complex this issue is, we provide the following example. CAISO identified in its issue paper and straw proposal that the Bureau of Ocean Energy Management (BOEM) awarded in its first offshore wind energy auction for the Pacific region five leases covering 373,268 total acres off central and northern California with the potential to support up to 4.6 GW of new capacity. Three of these five leases are located off of the Central Coast and anticipated to interconnect at Morro Bay. At the Morro Bay substation, Vistra is developing 600 MW / 2,400 MWh battery energy storage facility at the Morro Bay 230 kV point of interconnection to support the integration of these off-shore wind projects.[1] While these projects are not “long lead times” they should be prioritized simultaneously with the off-shore wind planning to connect in this area to ensure the wind and the storage assets have sufficient deliverability to connect. Storage interconnecting near the off-shore wind can provide wind balancing to increase effectiveness of the off-shore wind, transforming off-shore wind from a variable energy resource to a balanced around-the-clock resource better supporting grid needs. Given this integrated view of the wind and storage development at or near the Morro Bay substation, Vistra does not believe it is prudent to only study wind projects because this could leave the storage planned for integrating that wind behind.

In the past, Vistra has proposed an open season for transmission projects where Interconnection Customers could subscribe to the project and receive a deliverability allocation commensurate with its investment into the project as a viable way to address this issue. We are open to exploring this and other options further with CAISO. We do not think this should be rushed. If the Independent Study Process can be leveraged to facilitate either an individual long-lead time project or a sub-regional cluster that would study the area with the interconnecting long-lead time resources as proposed above, we are supportive. If not, these important questions should be tackled in Transmission Planning Enhancements and any interconnection specific elements in Track 2 of 2023 IPE effort.

[1] CEQA, SCH Number 2022060083, 600-MW Morro Bay Battery Energy Storage System Project, https://ceqanet.opr.ca.gov/2022060083.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

Vistra believes it is too soon to provide substantive comments on the concepts provided by the CAISO in 2023 IPE Track 2. We request the CAISO hold stakeholder workshops to to develop robust, detailed proposals in Track 2 to improve the interconnection process to allow for CAISO, Participating Transmission Owners, and Interconnection Customers to return to a more predictable, recurring interconnection process with the roughly two year timeline used prior to Cluster 14. Vistra requests the opportunity to present and discuss its proposals that it has submitted to CAISO for review in these stakeholder workshops. See response to #7 below for a reminder of Vistra’s proposals, which we will update for the future workshops based on lessons learned.

Ideally, Vistra believes the workshop should be joint workshops between the California Energy Commission, California Public Utility Commission, and the California ISO to jointly discuss a prudent way to move forward to support the goal of recurring, predictable cluster studies to support the transition of the California fleet towards a 100% clean energy and a carbon neutral fleet by 2045 consistent with SB 100 goal. If there is going to be greater reliance on the state’s integrated resource planning modeling and procurement directives, it will be important to start with a strong showing of coordination through joint workshops where stakeholders and regulators can align on first principles and explore options together.

Vistra also notes that several elements of 2023 IPE Track 2 are addressed in FERC’s interconnection reform NOPR.  Vistra is concerned that CAISO may get ahead of reforms required by FERC or expressly rejected by FERC.  The ability to consider reforms that are consistent with a FERC final rule on interconnection reforms is an additional benefit of stakeholder workshops.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

See above response to #3.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

See above response to #3.  Vistra notes that we and numerous other commenters to FERC’s interconnection reform NOPR expressed concerns about the requirement to have a PPA to advance in the interconnection process.

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

See above response to #3. Vistra notes this is inconsistent with our first principles as described in response to #1 to manage through the existing clusters to allow us to return to a more predictable, recurring interconnection process with the timelines we saw prior to Cluster 14 beginning with Cluster 15 validation through Cluster 16 and beyond.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

Vistra provides these comments from its perspective as a developer and owner of non-utility generation facilities.  Our comments reflect our experience and investment in finding solutions that will support a transition of our generation fleet in line with Vistra’s carbon emission reduction goals to support California’s environmental and reliability goals. To accomplish these goals, we need interconnection policies that facilitate timely interconnections while maintaining a level playing field among all potential participants in a competitive solicitation.

Through our Vistra Zero initiative, we currently have approximately 3,300 MW of zero carbon generation in operation, which we plan to grow to 7,300 MW by 2026.  One element of this program is utilization of existing generation sites to develop zero carbon resources. For example, Vistra will have successfully replaced 750 MW of retired generation at its Moss Landing 500 kV site by summer 2023 and continues to develop 600 MW / 2,400 MWh lithium-ion storage resources at our existing mothballed Morro Bay site to support wind integration in the Central Coast.

Vistra has submitted proposals into the CAISO policy efforts over the last couple of years as the CAISO and stakeholders have been striving towards how to address these increasing large clusters. On May 28, 2021, Vistra submitted comments on the Generator Interconnection: Cluster 14 Revised Study Process and Timeline Issue Paper and Draft Final Proposal posted on May 14, 2021 asking the CAISO to propose changes to its study process to separate the cluster into a first-ready cluster and a common cluster.[1] In our comments on the CAISO 2021 Interconnection Process Enhancements issue paper and stakeholder workshop, Vistra outlined a more detailed proposal for a  “first ready, first served” framework.[2]

In addition, we have also proposed a complementary transmission proposal for the CAISO to consider holding open seasons, could similarly be called an auction or subscription mechanism, for policy-driven or commercial-interest driven transmission projects to facilitate interconnections through allocating deliverability to Interconnection Customers, or funding entities such as the state, based on their investment into the transmission projects needed to facilitate their interconnection.[3] We believe a subscription mechanism to fund network upgrades to ensure deliverability “upfront” to the interconnection process can add a lot of value towards identifying those “first ready” projects to “first serve” in the above proposal.

Vistra respectfully requests the CAISO hold workshops to discussing potential Track 2 proposals from stakeholders in addition to those included in this issue paper. We would appreciate the opportunity to revise our previous proposals based on the evolving discussions and to put these ideas forward for stakeholder discussion.

[1] See Vistra’s comments on CAISO’s Generator Interconnection: Cluster 14 Revised Study Process and Timeline Issue Paper and Draft Final Proposal, http://www.caiso.com/Documents/VistraComments-SuperclusterInterconnectionProcedures-IssuePaper-DraftFinalProposal.pdf.

[2] See Vistra’s response to question #3 on the CAISO 2021 Interconnection Process Enhancements issue paper and stakeholder workshop, https://stakeholdercenter.caiso.com/Comments/AllComments/93e0040c-4e2e-4d37-8b2c-7eb0e7c55aa9#org-f382caf5-b32a-43e5-a759-fe484ea5d2c2.

[3] See Vistra’s comments on Transmission Planning Enhancements

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

None at this time.

1. Provide your organization’s comments on the proposed handling of Cluster 15 interconnection requests following the closure of the interconnection request submission window, as described in Section 2.

The proposed CAISO 2023 IPE presents the uncertainty of the due-process timelines for Clusters 14 and 15; it also leaves in doubt when or if a future Cluster 16 open window will occur.   The Cluster 14 Phase 2 Study Process, including developer-confirmed acceptance, will have been delayed by over a year if now forecasted to occur in February 2024.   The proposed and “preferred” commencement of the Cluster 15 Phase 1 study process, described in CAISO’s March 13^th Presentation, will have a start date of April or May 2024 with an opportunity for applicants to update their originally submitted data as needed.   Based upon CAISO’s traditional Interconnection Process timelines this would translate to the start of Cluster 15 Phase 2 studies in November/December of 2025.  It would seem appropriate for CAISO to consider postponing the Cluster 15  application window at least until the Track 1 and Track 2 related Tariff revisions are approved by FERC.  It is requested that CAISO consider offering guidance and Tariff revisions that would promote the submittal of due-diligent and system-knowledgeable Generator Interconnection Requests; this to promote a reduction in the number of speculative Cluster applications and to restore predictability to the scheduling for Clusters 16 and beyond.

2. Provide your organization's comments on the Other Issues for Consideration, as described in Section 2.

Among the resources facing unique challenges are long-term development for pumped storage hydro projects.  It is requested that CAISO consider:

1. Providing special considerations for the long-term development of pumped storage hydro projects at the same priority level presently being considered for Off-Shore Wind and out-of-state Renewable Energy projects.
2. Providing the opportunity for an Independent Study option for long-term projects requiring special considerations.   The existing CAISO acceptability criteria for Independent Study is not consistent with long-term project timelines, equipment procurement, construction duration and magnitude of associated network upgrades.

3. Provide your organization’s comments on the proposed Interconnection Process reform to only accept or process Interconnection Requests where the transmission system has available or planned capacity identified in the ISO transmission plans, as described in Section 3.1.

It would seem appropriate for CAISO to consider offering guidance and Tariff provisions that would promote the submittal of due-diligent and system-knowledgeable Generator Interconnection Requests as a means to reduce the number of speculative Cluster applications and to restore the CAISO Interconnection Process to its traditional predictable scheduling for Clusters 16 and beyond.  System knowledge being exercised by developer applicants would likely both decrease the number of Projects in Cluster 15 and increase the Distributed Generation applications presented to the Participating Transmission Owners for the low-priority transmission study areas.

4. Provide your organization’s comments on the proposed Interconnection Process reform to limit the number of interconnection request in a study area based on the transmission capacity being planned for that area, as described in Section 3.2.

It is suggested that CAISO consider the dissemination of “Hosting Capacity” maps and lists specifically identifying transmission lines and substations that are constrained and associated with curtailment.  This would be similar to the information that the Participating Transmission Owners are investigating to guide developers’ efforts in Distributed Generation.  It would seem appropriate for CAISO to consider offering guidance and Tariff provisions that would promote the submittal of due-diligent and system-knowledgeable Generator Interconnection Requests as a means to reduce the number of speculative Cluster applications and alert developers of the transmission study areas that would benefit from the installation of Distributed Generation in lieu of Large Generation on the Transmission System.

5. Provide your organization’s comments on the proposed Interconnection Process reform to require projects to have a PPA or be shortlisted to proceed to phase II studies, as described in Section 3.3.

The constraint of having an executed or short-listed PPA for a project’s full capacity allocation and progression to Phase 2 Studies is strong indication of “first-ready” for renewable projects comprising the bulk of Cluster membership.  It seems that the feasibility of this requirement will be based upon the coordination described by the December 2022 MOU between CAISO, CPUC, and CEC; the provision of advance notification to Load Serving Entities of scheduling requirements for off-take procurements in future years.   CAISO’s PPA constraints for long-term development projects should  be coordinated with the CPUC and the CEC to provide an Independent Study option that promotes a developer’s optimal project scheduling and the Participating Transmission Owner’s scheduling of Interconnection facilities and Network Upgrades.  

6. Provide your organization’s comments on the proposed Interconnection Process reform to only open a new Interconnection Request window when warranted, as described in Section 3.4.

The present Cluster 14 backlog, the constraints in progressing Cluster 15, the impending Tariff revisions, the impact of FERC’s Final Ruling on Interconnection Process Reform, the uncertainty of  “if or when” future Cluster windows will open, and CAISO’s present PPA constraints to full capacity allocation are daunting, to say the least.   These complex issues, however, seem out-of-context with the fundamental necessities of executing a long-term permitting, engineering, procurement, and construction project that has not been directly supported by State processes since CAISO’s inception and deregulation in 1996.   It is suggested that CAISO focus its efforts on restoring predictability to the Generation Interconnection Process that serves the full range of project profiles.

7. Please provide your organization’s comments on alternative elements to those described in Section 3. Any alternatives provided must align with the principles described in the IPE 2023 Issue Paper & Straw Proposal and the discussion at the beginning of Section 3.

It is suggested that CAISO modify its present criteria for accepting a project for Independent Study as the alternative to Cluster process for long-term projects worthy of CAISO, CPUC, and CEC special considerations.

8. Provide any additional comments on the IPE 2023 March 13, 2023 stakeholder call discussion.

The CAISO 2023 IPE Proposal represents uncertainty in the due-process timelines for Clusters 14 and 15; it also leaves in doubt when or if a future Cluster 16 open window will occur.   The Cluster 14 Phase 2 Study Process, including confirmed developer-acceptance,  will have been delayed by over a year if it occurs in February 2024.   CAISO’s “preferred” commencement of Cluster 15 Phase 1 studies, described in CAISO’s March 13^th Presentation, will occur in April or May 2024 with an opportunity for applicants to update their original application data as needed immediately prior.   Based upon original Interconnection Process timelines this would translate to the start of Cluster 15 Phase 2 studies in November/December of 2025.  It would seem appropriate for CAISO to consider postponing the Cluster 15  application window, at least until the envisioned Tariff revisions are approved by FERC.  It is suggested that CAISO consider offering guidance and Tariff provisions that would promote developers’ submittal of due-diligent and system-knowledgeable Generator Interconnection Requests as a means to reduce the number of speculative Cluster applications and focus on providing specific lists of constrained transmission lines and substations to encourage the installation of distributed generation.