Comments on Draft Final Proposal - Phase 1

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

Advanced Energy Economy[1] and the Advanced Energy Buyers Group[2] appreciate the opportunity to provide input on CAISO’s “Draft Final Proposal - Interconnection Process Enhancements 2021.” AEE and AEBG reiterate our comments on the Revised Straw Proposal with regard to the proposed changes to the Transmission Plan Deliverability (TPD) allocation process that would impact offtakers of power purchase agreements (PPAs) that do not have a Resource Adequacy (RA) obligation. As AEE and AEBG explained in our prior comments, offtakers that do not themselves have an RA obligation nevertheless face a clear financial incentive to ensure that the capacity value of their projects ultimately serves an entity that does have an RA obligation. Any distinction in the TPD allocation process between PPAs with offtakers that do have an RA obligation and PPAs with offtakers that do not have an RA obligation will not deliver any cost or reliability benefits to ratepayers. Instead, such distinction will only serve to disadvantage and disrupt the growing voluntary renewable energy market in California to the detriment of renewable energy deployment and greenhouse gas reduction in the state. We therefore maintain that PPAs with offtakers that do not have an RA obligation should not be deprioritized in the TPD allocation process relative to PPAs with offtakers that have an RA obligation.

Despite our strong view that projects with PPAs with offtakers that do not have an RA obligation should be treated equally for purposes of TPD allocation, AEE and AEBG nonetheless appreciate that CAISO has expressed willingness to create a process for such projects to be allocated deliverability if they demonstrate that the RA will be offered to an entity with an RA obligation. While CAISO’s Draft Final Proposal reflects an improvement in this regard, the proposed demonstration approach lacks detail, appears to be incompatible with how voluntary PPAs and the RA market operate in practice, and continues to put projects with PPAs with offtakers that do not have an RA obligation at a disadvantage relative to projects with LSE offtakers.

AEE and AEBG reiterate our request for CAISO to maintain equal treatment for projects with PPAs with offtakers that do not have an RA obligation in the TPD allocation process. In the alternative, we ask that CAISO develop a clear, flexible, and fair process for non-LSE offtakers to develop projects that are eligible for TPD allocation if the party ensures that the RA will be made available to an entity with an RA obligation. Such a process should take into account the practical constraints and timelines of the RA market and voluntary PPAs and must avoid putting PPAs with entities that do not have an RA obligation at a disadvantage with respect to TPD allocation.

[1] Advanced Energy Economy (AEE) is a national association of businesses that are making the energy we use secure, clean, and affordable. It works to accelerate the move to 100% clean energy and electrified transportation in the U.S. Advanced energy encompasses a broad range of products and services that constitute the best available technologies for meeting energy needs today and tomorrow. These include energy efficiency, demand response, energy storage, solar, wind, hydro, nuclear, electric vehicles, biofuels and smart grid. AEE represents more than 100 companies in the $238 billion U.S. advanced energy industry, which employs 3.2 million U.S. workers.

[2] The Advanced Energy Buyers Group (AEBG) represents the views of a coalition of large electricity customers, with member companies spanning the retail, manufacturing, and technology sectors. These companies are among the 76% of Fortune 100 companies and 60% of Fortune 500 companies that have established renewable and/or climate targets as part of our corporate sustainability commitments. AEBG members share a common interest in expanding our use of advanced energy, including renewable energy like wind, solar, geothermal, and hydropower; demand-side resources like energy efficiency, demand response, and energy storage; and onsite generation from solar, advanced natural gas turbines, and fuel cells.

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

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

AEE and AEBG explained in detail in our comments on the Revised Straw Proposal our opposition to CAISO’s proposal to change the TPD allocation process such that projects with PPAs with offtakers that do not have an RA obligation (i.e., non-LSE PPAs) would not be eligible for groups 1 or 2. This would put non-LSE PPAs at a disadvantage relative to projects with PPAs with offtakers that do have an RA obligation (i.e., LSE PPAs). We maintain that any measures that would distinguish between LSE PPAs and non-LSE PPAs for purposes of TPD allocation is both unfair and unnecessary. As we explained in our comments, entities that do not have an RA obligation nevertheless have a clear and strong incentive to ensure that the capacity of any PPAs to which they are party is sold to an entity that does have an RA obligation. In other words, restrictions on the allocation of TPD to non-LSE PPAs are not needed to achieve CAISO’s stated goal of ensuring that deliverability is “ultimately utilized by, or offered to, an entity with an RA obligation.” Rather than protecting ratepayers from adverse cost or reliability outcomes, such unequal treatment would reduce competition in the state’s renewable energy market and hamper the ability of voluntary renewable energy buyers to play a role in accelerating the state’s transition to a decarbonized grid.

For all of these reasons, and as explained in more detail in our prior comments, AEE and AEBG reiterate that CAISO should maintain equal treatment for projects with PPAs with offtakers that do not have an RA obligation in the TPD allocation process.

Despite our strong view that projects with PPAs with offtakers that do not have an RA obligation should be treated equally for purposes of TPD allocation, AEE and AEBG nonetheless appreciate that CAISO has acknowledged our concerns and expressed willingness to create a process for such projects to demonstrate that the RA will be sold to an entity with an RA obligation. Unfortunately, we do not think CAISO’s proposed demonstration requirements are workable as proposed. Specifically, CAISO states in the Draft Final Proposal:

The ISO is revising its proposal such that if a project has a PPA that is with an entity who does not have an RA obligation, but it can be demonstrated that the RA attributes of the project are under contract with an entity with a RA obligation for a term of five years or more, the project would be eligible for an allocation. The priority for allocating TPD to projects with such contracts will be after allocations are made to eligible projects whose PPAs are with an entity with an RA obligation. Financial incentives, the intent to sell capacity, or being shortlisted with an entity with an RA obligation are insufficient to meet this requirement.[1]

This approach is not viable for two primary reasons. First, it does not take into account the timeline of the TPD process, PPA arrangements, or the RA market. Making such a demonstration would require non-LSE offtakers to enter into RA arrangements with LSEs far in advance of a project’s in-service date, and would dictate a contract structure and term that is not compatible with the liquid nature of the RA market. Even if a non-LSE offtaker could meet these requirements, doing so would certainly put such an offtaker at a disadvantage relative to LSE offtakers that do not face such requirements. As proposed, this approach therefore fails to provide non-LSE offtakers with a viable path toward pursuing projects with RA value. Second, even if the demonstration requirements were revised and improved, the proposed approach maintains a priority for PPAs with an offtakers that have an RA obligation by putting such projects first in line for TPD allocation. As explained above, such preference is unjustified even in the absence of a demonstration or commitment by a non-LSE offtaker to ensure that the RA attributes of a project with which it has a PPA are made available to entities with an RA obligation. With such a demonstration, such preference is certainly unwarranted.

Should CAISO move forward with a requirement for non-LSE offtakers to make a demonstration that the RA of a project with which they have a PPA will be made available to an entity with an RA obligation, we ask that this process be developed collaboratively with stakeholders—particularly entities engaged in voluntary renewable energy contracting—to ensure that it is clear, flexible, and fair. Such a process should take into account the practical constraints and timelines of the RA market and voluntary PPAs and must avoid putting PPAs with entities that do not have an RA obligation at a disadvantage with respect to TPD allocation.

[1] Draft Final Proposal at 12.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

Amazon Energy LLC (“Amazon”) appreciates the opportunity to submit these comments on the CAISO’s Draft Final Proposal for Its 2021 Interconnection Process Enhancements initiative.  As it has in prior comments, Amazon focuses exclusively on section 3.2 and the changes the CAISO proposes to make to the TPD Allocation process.  This issue is very important to Amazon given its commitment to developing carbon-free deliverable capacity in California that can serve its substantial and growing load across the State.   

From the outset, Amazon has expressed its view that CAISO should remain neutral to the identity of the interconnection customer’s offtaker and treat all interconnection customers equally with regard to the allocation of deliverability. Further, Amazon continues to believe that prioritizing the TPD Allocation Process to advantage projects that have contracted with Load Serving Entities (“LSEs”) over projects that contract with non-LSE offtakers, including corporate offtakers like Amazon, who do not have resource adequacy (“RA”) obligations will not help California achieve its goal of cost effectively decarbonizing the power grid while maintaining system reliability. 

Amazon shares the view expressed by Advanced Energy Economy (“AEE”) and the Advanced Energy Buyers Group (“AEBG”) in their earlier comments that “the change CAISO proposes would unduly disadvantage renewable energy procurements by non-LSE buyers and harm the growing voluntary renewable energy market in California without any reliability or cost benefit to ratepayers,” and joins in AEE and AEBG’s concerns that this “distinction will only serve to disadvantage and disrupt the growing voluntary renewable energy market in California to the detriment of renewable energy deployment and greenhouse gas reduction in the state.”

As outlined in Amazon’s previous comments, if project developers that contract with corporate offtakers are effectively unable to obtain a TPD Allocation, which is the likely result of the CAISO’s current proposal,[1] the end result will be a reduction in the overall deployment of clean energy in the State.  It will also end up reducing the supply of RA-eligible resources being developed, as non-LSE offtakers will instead contract for energy-only resources.  The reduced supply of RA-eligible resources could lead to higher prices for RA and therefore higher prices to California consumers.

In earlier comments, Amazon highlighted that the RA from a project with a TPD allocation will invariably end up serving an entity with an RA obligation.  This is true regardless of whether the offtaker is a LSE or a non-LSE.  As detailed in those comments, simple economics compel this outcome.  If a corporate offtaker has uncommitted RA in its portfolio that it will not use to “self-supply”, it will re-sell or otherwise transfer that RA to a party that needs it, i.e., to a LSE.  For that reason, Amazon does not believe it is necessary to treat interconnection customers differently. 

Given California’s ambitious objective to decarbonize the power grid while maintaining system reliability, Amazon urges CAISO not to advance a new set of rules which will discourage the development of much needed resources.

[1] The Draft Final Proposal provides that “the PPAs of offtakers that do not have RA obligations will not be eligible for [TPD] groups 1 or 2.”  Draft Final Proposal at 12.  Given the expectation that there will be insufficient deliverabilty to ensure deliverability of all the projects seeking full or partial capacity deliverability status, this makes it quite unlikely that the projects outside of groups 1 or 2 will receive a TPD allocation.

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

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

In response to this question, Amazon focuses on the section of the Draft Final Proposal that would enable non-LSE offtakers to develop projects that are eligible for a TPD allocation if they commit to re-sell the RA to a LSE for a term of five years or more.  For projects that meet this requirement, the CAISO proposes to make such projects eligible for a Group 1 TPD Allocation though only after allocations have been made to eligible projects whose PPAs are with an entity with a RA obligation (LSEs).  The CAISO provides no rationale for this part of its proposal and few details about how this commitment would be evidenced. 

Further, the CAISO’s proposal does not go far enough to be practical and falls short in three ways.  First, it is too prescriptive.  The current proposal appears to contemplate a formal resale agreement by the offtaker of the RA to a LSE for a minimum of five years.  That would rule out the prospect of a corporate offtaker using its RA to “self-supply” its own RA.  Under such an arrangement, a corporate offtaker would transfer its own purchased RA to its LSE that would otherwise need to separately procure such RA to serve the corporate offtaker’s load.  In exchange, the LSE would likely provide a credit against or reduction in the retail charges it charges the corporate offtaker.  Under such an arrangement, the RA would end up in the LSE’s supply plan, meeting the CAISO’s concerns.

For a party like Amazon, this flexibility is necessary given the wide range of LSEs serving its load across the State.  Amazon’s energy demand is served by many different LSEs, including IOUs, CCAs, Munis, and ESPs. Amazon expects to enter into a variety of “self-supply” arrangements, where such arrangements are permissible and, then, if any uncommitted RA remains, re-sell that uncommitted RA to LSEs.  These sales would be typical RA sales of the sort that are routinely transacted between LSEs and non-LSEs all the time. The CAISO’s current proposal lacks the flexibility to credit this range of transactions that will be required to make it practical. 

Second, even if a corporate offtaker wished to enter into an agreement to re-sell its RA to an LSE, as proposed by the CAISO, it is unlikely that a corporate offtaker would find a willing LSE buyer ahead of the TPD Allocation process.  Because a project with a non-LSE offtaker would only be eligible for a TPD Allocation after it has contracted directly with a LSE, it seems unlikely that an LSE would speculate on an RA resale agreement when it can simply contract directly with a project eligible for a TPD Group 1 Allocation.  While the LSE may negotiate a transaction with the non-LSE offtaker contingent on the underlying project getting a subsequent TPD Allocation, this is much more complicated and riskier than just contracting with the developer directly.  Thus, the prospect of a corporate entity even being able to make use of what the CAISO proposes seems unlikely.

Finally it is not clear why the CAISO is focused exclusively on the offtaker as the key to solving the CAISO’s stated concerns.  The CAISO’s concerns can be better addressed by the interconnection customer directly.  The CAISO currently requires that interconnection customers demonstrate they have a PPA that requires deliverability in order to be eligible for a Group 1 TPD Allocation.  Instead of focusing on the identity of the offtaker, the CAISO should instead make eligibility for Group 1 require a PPA with a deliverability obligation and an obligation that the resulting RA go to a LSE (if the offtaker is not already an LSE). 

Such an obligation could be contractually enforced between the interconnection customer and its offtaker in many ways.  For example, the CAISO could require a “use it or lose it” provision in the PPA under which the offtaker is obliged to put the RA into a LSE’s portfolio or otherwise lose the right to re-sell that RA.  The right to sell it would then revert back to the interconnection customer who would have the obligation to sell it or otherwise put its project’s deliverability at risk.  This approach would meet the CAISO’s concern that the TPD capacity, built at ratepayer expense, be used by LSEs to meet their RA obligations.  And, it would do so without hindering project development by non-LSE corporate offtakers.  

The CAISO’s desire to ensure that RA-qualifying resources go to entities with an RA obligation can be accomplished without the imposition of a prescriptive solution that interferes with important policy objectives.  Amazon is ready, willing, and able to work with the CAISO to address the CAISO’s concerns.  In so doing, it hopes the CAISO will adopt a policy that ensures the continued development of RA-eligible resources by corporate offtakers.  The need for new fully deliverable capacity in California has never been more urgent. 

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

Broad Reach Power LLC (BRP) appreciates the opportunity to comment on the CAISO’s Draft Final Proposal for IPE 2021 (Phase 1) posted on March 17. BRP is a leading utility-scale solar and storage developer in the United States. BRP has submitted comments in prior rounds of this stakeholder initiative.

BRP has comments on the CAISO’s latest proposal regarding TPD allocation Group 4. CAISO’s proposal for Group 4 represents progress but additional modifications or at least clarifications are required as noted below.  BRP also comments on how Site Exclusivity should be demonstrated by C14 projects in advance of First IFS, due in early 2023. In addition, BRP provides a beneficial proposal to increase transparency of queued project Site Exclusivity as a way to increase market efficiency and help clear the “overheated” C14 queue.

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

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

Although it does not fully address the need of merchant projects that require TPD to reliability serve CAISO load, BRP appreciates the forward progress made in the Draft Final Proposal by allowing Group 4 projects to secure TPD without a PPA, subject to the  requirement that the project subsequently secure a PPA. CAISO’s proposal needs further refinement and precision before final adoption. BRP recommends that a Group 4 project be allowed to retain TPD in the first year by executing a PPA. A requirement to demonstrate a PPA or shortlisting should only be required for the “second” retention (i.e., into year “3”).

Also, CAISO’s proposal requires further clarification. Currently, being shortlisted is not a recognized retention criterion—see CAISO’s posted “retaining TPD” affidavit form.  BRP understands that current Group 3 projects have shown PPA shortlisting as a way to secure TPD but to BRP’s understanding either the project was effectively restarting the “seeking TPD” process or CAISO was allowing projects to retain TPD in a manner inconsistent with its posted form.  In any event, CAISO needs to allow projects allocated TPD via Group 4 to:

• Retain TPD by showing, in a future year, its project was shortlisted even if the project could not otherwise have parked.
• As a shortlisted project, continue to retain TPD by showing a signed PPA.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

BRP’s prior comments stressed the importance of increasing project viability and commitment to the interconnection study process by requiring that a project demonstrate Site Exclusivity (“SE”) as a requirement to proceed to C14 Phase 2. BRP appreciates that CAISO Draft Final Proposal is now consistent w/ BRP’s comments.

The Draft Final Proposal needs to be more precise in how it details when SE is required in advance of First IFS. C14’s current schedule has Phase 1 reports being issued on 9/15/2022 and First IFS due on 1/13/2023. BRP proposes that demonstrations of SE “pre-First-IFS” be submitted by the developer and validated by CAISO by no later than 12/16/2022. This date is ~90 days after Phase 1 reports have been issued and would give developers enough time to submit required documentation and for CAISO to conduct a review before end of year holidays and closures. CAISO would notify the market that it will not process SE demonstrations between 12/17/2022 and when First IFS has been accepted. Thus, any project w/o SE established by 12/16/2022 will have its SE deposit at risk per the CAISO proposal.  Projects that do post First IFS and stay in the queue may demonstrate SE at a later time per the Draft Final Proposal.

Furthermore, BRP recommends that project  SE information be posted to the public queue during December 2022; similar to the way the queue currently shows project name, study phase, and interconnection agreement status, etc.   BRP’s proposal is easy to implement and will support efficient decisionmaking by giving developers information to know if other projects in an area of its project have site control before being required to post at-risk security. SE is a meaningful viability metric and a developer without SE may not choose to not move forward if it sees that many other developers have SE in a relevant area. This transparency will help to clear out the “overheated” C14 queue. Also, making such information public is also beneficial to Load Serving Entities as they are the buyers of new resources currently in the queue.

BRP recommends making SE status public for all projects in the CAISO queue. To the extent CAISO cannot make such a broad policy change in this “Phase 1” portion of IPE 2021 it should be at least adopted in Phase 1 for C14 and considered further in IPE 2021, Phase 2.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

CESA appreciates the ISO staff’s collaboration with stakeholders on the various proposals under consideration, particularly the responsiveness to stakeholder feedback and concern. CESA is mostly supportive of multiple proposals in the Draft Final Proposal, including the reasonable balance struck with the proposal around site exclusivity as described in Section 4.1. Furthermore, we welcome the modifications to the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in Section 3.2, which are directionally positive with the establishment of a new Allocation Group 4 and reduce the risk of hindering procurement efforts in the near term. However, the primary focus of our comments on the Draft Final Proposal are focused on revisions to the TPD allocation process, which require further refinement and clarification.

Importantly, the ISO should carefully consider incremental changes to the newly proposed Allocation Group 4 to create pathways for projects to be allocated deliverability and be able to come online without a PPA and to avoid situations where projects are forced to withdraw if projects have a viable Energy Only (EO) pathway. In addition, we seek specific clarifications around parking rules, the impact to Allocation Group 4 projects that only receive partial TPD, and the categorization of certain project types. Finally, while the one-time exception for Queue Cluster (QC) 14 projects is helpful, we seek clarification on the retention criteria for QC14 projects and continue to urge the ISO to reconsider its position on a 5-year minimum term length of PPAs for Allocation Group 1 or 2 projects.

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

CESA generally supports this proposal and appreciates the clarifications provided. We have no further comment at this time.

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

CESA greatly appreciates the CAISO’s responsiveness and receptivity to stakeholder feedback on the proposal related to the TPD allocation process. The modifications made represent significant improvements on the Revised Straw Proposal that would eliminate the current Allocation Group 3 (proceeding without PPA), which as proposed at the time would only serve to hinder project development and load-serving entity (LSE) procurement. Under this process, if a project has not attained TPD, it puts undue risk on the offtaker to engage in a contract, risk they are likely to pass on to the developer. By contrast, the changes to add a new Allocation Group 4 would afford projects some flexibility and a window to secure a PPA, thus providing opportunities in two TPD allocation cycles to market their projects to LSEs and secure a PPA.

Overall, CESA welcomes this change. Generally speaking, CESA shares the ISO’s goals of better aligning the various processes (procurement, transmission, and interconnection) and supporting the interconnection of new resources to meet near- and mid-term reliability needs. The ISO should be aware that projects are increasingly being built without PPAs when entering the TPD allocation process, likely in the hopes of securing a PPA at a later time (e.g., moving toward COD and operating as a merchant facility in the near term). As expressed previously, CESA also believes that a large interconnection queue in itself is not necessarily an undesirable outcome, so long as the projects in the queue are highly viable and create a more competitive marketplace of projects needed to meet reliability needs not only in the near and medium term but also in the long term. With pathways to have greater certainty of TPD as projects are being developed or come online, it will mitigate the burden of LSEs having to assess earlier or risker projects using only Phase I study results that bid into their Request for Proposals (RFPs) and competitive solicitations.

As such, while the changes in the Draft Final Proposal are directionally positive, the ISO should carefully consider incremental changes to the newly proposed Allocation Group 4 to create pathways for projects to be allocated deliverability and be able to come online without a PPA and to avoid situations where projects are forced to withdraw if projects have a viable EO pathway. Otherwise, the ISO’s current proposal as-is does not necessarily encourage more viable projects, leads to potential wasting of TPD allocation when projects are prone to greater failure risk, and closes out continued development markets for projects, especially considering the financial risks that developers face with land acquisition and construction. Notwithstanding our support for the directional change and our general comments on the issue at hand, we offer several areas of further comment and clarification.

First, CESA recommends a modification to the proposed withdrawal rules for Allocation Group 4. The ISO proposes to give projects two consecutive opportunities to seek, secure, and/or retain an allocation in Allocation Group 4, and if unsuccessful, be required to withdraw. CESA believes that the withdrawal requirements are disproportionate to the intent of enabling the development of new resource capacity that could be later positioned to secure a PPA. Rather than being forced to withdraw and lose queue position due to the inability to be allocated deliverability, the ISO should allow these projects to proceed with the interconnection and development process as EO projects, which in some cases could be sold to LSEs and have a PPA executed, thereby positioning it for Allocation Group 1 or 2 in future TPD cycles. Forcing a withdrawal does not support the continued project development of otherwise viable and good projects.

Second, CESA requests clarification on how the parking rules would apply for Allocation Group 4 projects. For example, if projects park in the first TPD cycle and does not obtain TPD in the second subsequent cycle, will the project be required to withdraw? As discussed above, projects should be allowed to convert to EO status instead of being forced to withdraw.

Third, CESA requests clarification on what the ISO proposes for projects that only receive partial TPD for the fully requested TPD amount. For example, if a 10-MW project receives 1 MW in the first TPD cycle and 2 MW in the second cycle, will the 8 MW of unallocated TPD be forced to withdraw? How would that work? Could the project just be deemed a Partial Capacity Deliverability Status (PCDS) project, with the 8 MW treated as EO? Again, as discussed above, projects should be allowed to convert to EO status instead of being forced to withdraw.

Fourth, CESA greatly appreciates the ISO making an exception to the 5-year minimum term length of PPAs for Allocation Group 1 or 2 projects in the 2022-2023 TPD cycle, which will avoid near-term disruptions. However, the ISO should also provide clarification on whether the exception to the PPA term length requirement will impact retention in future TPD allocation cycles, where presumably the 5-year term length will apply. Overall, rather than establishing two regimes, CESA urges the ISO to reassess its position on a qualifying PPA term length, which we have expressed in the past may not be the ISO’s role to make such determinations considering it is the domain of the California Public Utilities Commission (CPUC) to direct procurement and set Resource Adequacy (RA) obligations. At minimum, if the goal is to support RA obligations through the structure of TPD allocation priority groups, the qualifying PPA definition should align with the CPUC’s RA forward contracting requirements (i.e., qualifying PPAs based on a minimum contract length of one year). As discussed above, there are many advantages to increasing the marketplace of projects and to bringing more projects online with deliverability that could derisk the eventual long-term contracting for these projects in ongoing or future competitive solicitations. The ISO expressed the view that ratepayer-funded transmission investments are best utilized for projects that support long-term procurement needs and obligations, but again, projects that are able to secure and retain TPD on a short-term basis can still support these ends and support less risky long-term contracting of projects. While coming online with deliverability but without a PPA (i.e., merchant operations) can often be a viable short-term strategy, but at the end of the day, these projects will likely seek to monetize their deliverability through long-term RA contracts.

If the ISO moves forward with defining qualifying PPA terms, CESA seeks clarification on the following questions:

• What TPD Allocation Group would a project be eligible for if they have a PPA tied to RA that is less than 5 years? Would they be put into Allocation Group 4 and be subject to the same withdrawal requirements and restrictions?
• What TPD Allocation Group would a project be eligible for if they have a PPA but not tied to RA? Would they be put into Allocation Group 4 and be subject to the same withdrawal requirements and restrictions?

Finally, CESA understands that the ISO plans to make potential adjustments to the GIDAP BPM scoring weights during the BPM update process and after securing FERC approval of tariff changes. However, these scoring criteria may be a means to achieve some of the ISO’s ends by prioritizing more ready projects or favoring those that have longer-term agreements without making this a gating criterion for TPD allocation. If possible, CESA thus recommends that the ISO provide some directional proposals on the scoring weights in the next paper.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

CESA generally supports this proposal with clarifications related to guardrails, process, and parameters provided in the Draft Final Proposal, but we emphasize how emergency reliability needs can be mitigated in general through faster queue processes. As noted in our response in the “Additional Comments” question below, CESA also recommends the ISO more expansively consider whether and how operational solutions could support incremental capacity coming online sooner.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

CESA greatly appreciates and supports the ISO’s modifications to this proposal in the Draft Final Proposal that would not only require site exclusivity to move into the Phase II study process but also allow QC14 projects to utilize a site exclusivity deposit after making their initial interconnection financial security (IFS) posting, with the deposit not subject to refund if the interconnection customer (IC) withdraws without having demonstrated site exclusivity. For QC15 and beyond, the ISO proposes scenarios that would essentially put 50% of the site exclusivity deposit at risk of non-refundability, if the IC leverages the deposit in lieu of site exclusivity and depending on whether and when the IC withdraws.

Overall, CESA believes that the ISO’s modified proposal strikes the right balance in increasing the commercial viability criteria for progressing through the interconnection process and in providing optionality for meeting the site exclusivity requirement via higher non-refundable portions of these deposits. As a result, the ISO will be able to manage the overheated queue in general while accommodating projects of different technologies, locations, and lead times where site exclusivity requirements would pose barriers despite their overall viability. However, CESA reiterates our request that the ISO explicitly clarify the site exclusivity documentation due date, which was not specified in the Draft Final Proposal, where timelines are not detailed to the same degree as the Revised Straw Proposal. According to the adopted Supercluster Interconnection Procedures, the initial interconnection financial security (IFS) is due on January 13, 2023, but based on the Revised Straw Proposal to have site exclusivity paperwork due 10 business days before the initial IFS posting, this requirement will need to be met by December 29, 2022. Even with the changes made in the Draft Final Proposal, not only does this timeline fall within the holiday season, but the schedule to meet this requirement is also very compressed, such that the ISO should consider shifting the timeline to avoid the holiday season and push back the initial IFS posting date to the end of January.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

CESA generally supports this proposal and has no further comment at this time.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

CESA has no comments at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

CESA generally supports this proposal and appreciates the ISO’s commitment to work with PTOs to make information about facilities that are on the ISO-controlled transmission grid versus the PTO-controlled distribution grid, which will reduce confusion and reduce the need for transfer to the right queue in the first place.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

CESA generally supports this proposal and appreciates the clarifications provided. We have no further comment at this time.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

CESA supports the ISO’s Draft Final Proposal that expanded the type of requests to include downsizing.

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

CESA has no comments at this time.

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

CESA supports the ISO maintaining this proposal in the Draft Final Proposal.

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

CESA supports the ISO maintaining this proposal in the Draft Final Proposal.

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

CESA has no comments at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

CESA has no comments at this time.

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

CESA has no further comments at this time.

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

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

• CalWEA strongly opposes the element of the TPD allocation proposal wherein new Group 4 projects would be required to withdraw if they do not receive a TPD allocation after two attempts. Currently, converting to EO status is an option for all groups that do not receive a TPD allocation.  
• CalWEA generally supports the ISO’s proposal that site exclusivity be required to progress into the Phase II study process; however, we recommend that 50% of the site exclusivity deposit be made non-refundable only if the IC withdraws the interconnection request after the Phase 1 IFS posting deadline; otherwise, it should be fully refundable. 
• CalWEA asks the ISO to streamline the policy and process for interconnection of projects before their RNUs are implemented and include it as a long-term topic.  In this regard, CalWEA recommends that a fee-based, non-binding Limited Operation Study (LOS) be performed, as part of the annual reassessment to evaluate whether projects with executed GIAs can interconnect at the dates requested by the project developer.

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

CalWEA supports the ISO proposal. 

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

• CalWEA supports collapsing six groups (1, 2 and 4-7) into the new 4 groups (the originally proposed 3 groups and the new group 4).
• CalWEA strongly opposes the element of the proposal wherein new Group 4 projects would be required to withdraw if they do not receive TPD allocation after two attempts. Currently, converting to EO status is an option for all groups that do not receive a TPD allocation. The ISO should not deprive generating resources of the right to participate as EO resources when there is limited transmission capacity. 

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

CalWEA appreciates the clarification but continues to oppose. We believe the emergency process could be misused by PTOs via the PUC, upsetting a well-functioning competitive market. 

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

CalWEA supports with modification. We suggest that 50% of the site exclusivity deposit only become non-refundable if the IC withdraws the interconnection request after the site exclusivity deadline, i.e., 10 business days prior to the initial IFS posting. Otherwise, it should remain fully refundable.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

CalWEA supports the ISO proposal. 

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

CalWEA does not object to the proposal but believes that the achievable earliest COD of a resource should not be impacted by the RAS when congestion management is feasible in lieu of the deliverability study triggered RAS. 

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

CalWEA supports the ISO proposal.  

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

CalWEA supports the ISO proposal.  

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

CalWEA supports the ISO proposal.  

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

CalWEA supports the ISO proposal. CalWEA suggests the ISO reduce information required to what the PTO and ISO really need for the study in Appendix B.  For example, the requirement for a 7.5-minute quadrangle of the site is outdated and redundant to the kmz file of the site that is already required. Other information, such as physical dimensions, bus length, tower numbers, number of third-party easements, alternate source of auxiliary power, and PLC protocol are only known at the time of project implementation and are not needed for the Phase 2 study (or the Facility Study for ISP applications).

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

CalWEA supports the modifications to commercial viability criteria. However, CalWEA restates the previous recommendation that the ISO should streamline the policy and process for projects achieving ISD before all RNUs are implemented. There should be a mechanism for the developers to get an indication whether the project can interconnect before all their RNUs are in-service. Upon request by the project developer, a fee based non-binding Limited Operation Study (LOS), as part of the annual reassessment, should evaluate whether projects with executed GIAs can interconnect at dates requested by the project developer.  

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

CalWEA supports the ISO proposal. 

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

CalWEA is concerned with the letter of intent being required at the IR submission that documents the intent of the parties to negotiate the terms of the sharing agreement. We believe the letter should be required by the time that Appendix B is due and the executed agreement be required by GIA execution.  

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

CalWEA supports the ISO proposal. 

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

n/a

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

EDF-R supports the CAISO’s Interconnection Process Enhancements (IPE) Phase 1 proposal and notes that this proposal was substantially reshaped during the course of the policy development process. That reshaping is a testament to the CAISO’s Transmission Planning & Infrastructure Development staff’s responsiveness and commitment to robust policy outcomes. 

EDF-R appreciates and supports the CAISO’s decision to modify their TPD allocation methodology proposal and add the Group 4 ranking option, and seeks clarification on a few minor points below. 

EDF-R understands CAISO’s intent to only construct delivery network upgrades in support of the Resource Adequacy program, and asks that CAISO clarify that as long as a contract for RA exists to provide RA from a specific generator to an LSE, neither the underlying contractual relationships nor the legal entity selling the RA are relevant to the allocation process. EDF-R provide further detail and an example below. 

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

EDF-R supports this change. 

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

Transmission Plan Deliverability Group 4 Proposal 

EDF-R appreciates and supports the CAISO’s decision to modify their TPD allocation methodology proposal and add the Group 4 ranking option. Group 4 allows any interconnection to seek a TPD allocation regardless of PPA or shortlist status. This proposal is complimentary to the CAISO’s existing process and resolves many of EDF-R’s concerns with respect to marketing and data transparency. 

 EDF-R has the following clarifying questions about the CAISO’s TPD Allocation group 4 proposals, and asks that the CAISO address them in its final proposal: 

• If a project parks after its Phase II study in Year 1, seeks a TPD allocation in Year 2, and then does not receive an allocation in Year 2, is that project eligible to seek an allocation in Year 3? Or year 4, if it meets the criteria? 

• EDF-R requests that CAISO clarify the minimum amount of MW that could be allocated in the TPD process. Because projects that receive an allocation are required to accept the allocation or withdraw, it makes sense to ensure that the TPD process does not allocate TPD amounts that are untenable from a financing and development standpoint. For example, could a project receive an allocation 1 MW and be required to accept or withdraw? 5 MW? 15 MW? 

• If a project that entered the queue as FCDS or PCDS does not receive a TPD allocation in the allocation process and proceeds to declare commercial operation as Energy Only, is project eligible to seek an allocation in Group 3 after it declares COD? Is the project eligible to seek an allocation in Groups 1 or 2 if it meets the criteria? 

Clarifying requirement related to a PPA requiring deliverability 

In its IPE 2021 Draft Final Proposal the CAISO clarifies that a PPA used as eligibility for Group 1 or Group 2 “must be with an off-taker to fulfill its own RA obligation” because the “intent of constructing delivery network upgrades and allocating deliverability is to allow the facility to participate in the Resource Adequacy program (RA).”  

EDF-R does not understand why the CAISO would want to apply hurdles to or effectively restrict contractual arrangements that are very common commercially and do indeed support generation that is operating in and serving RA needs in the CAISO BAA. 

Interconnection customers are free to sell their energy product in whatever commercial arrangement best serves their needs. Here is an example: 

• Interconnection customer with a wind project executes a Power Purchase Agreement with ACME Corporation for the whole of the facility and all of its associated “products” [1]
• ACME uses the Renewable Energy Credits (RECs) and demonstrate to their shareholders that their product is produced with green energy
• Because ACME Corporation bought all “products“ associated with the generator it is also the holder of the facility’s RA value
• ACME Corporation competes in an RFO with a CAISO LSE, is selected to serve that LSE’s RA obligation, and executes a PPA to that end

The PPA between ACME Corporation and should be eligible for CAISO’s TPD Allocation Groups 1 or 2. This arrangement is distinct from the more common Interconnection Customer – LSE PPA arrangement, but there is no difference in the RA product supplied.

This concept was discussed at the March 24 stakeholder meeting and the CAISO indicated EDF-R and the CAISO indicated the possibility of creating a 1A and 1B allocation for corporate PPAs. EDF-R strongly believes there is no need to group a corporate PPA for RA with an LSE (ACME Corp + LSE) from a more traditional PPA arrangement (Interconnection Customer + LSE). EDF-R believes the CAISO should not be concerned with the details of the contractual arrangements, provided the RA is serving the LSE’s obligation.

[1] This can be called a financial PPA, virtual PPA, or synthetic PPA and allows companies to increase their green impact without requiring them to own and operate the generator.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

EDF-R requests the CAISO define explicitly when the emergency interconnection process would be followed, there was some discussion of this on the March 24 call, but no clear conclusion.  

Will the process be used when a state of emergency is formally declared by the Governor, or are there other possible circumstances? Specifically EDF-R requests clarification if a declaration from the CPUC (a state agency) would prompt CAISO to open this process? 

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

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

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

EDF-R appreciates the CAISO’s addition of PPA termination to the eligibility criteria for this proposal.  

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

No comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

No comment at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

No comment at this time.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

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

No comment at this time.

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

No comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

EDF-R supports the expansion of deliverability transfer opportunities. 

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

No comment at this time. 

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

No comment at this time. 

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

No comment at this time. 

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

Golden State Clean Energy (“GSCE”) appreciates the movement the California ISO has made on some topics in phase 1 of this initiative. Our comments focus on the following topics related to transmission plan deliverability allocation and site exclusivity (questions 3 and 5):

• Transmission plan deliverability (“TPD”) allocation
  • GSCE supports allocation Groups 1-3 with a caveat.
    • We urge CAISO to include in Group 3 projects that have provided their notice to proceed to construction. These projects are more likely to proceed to commercial operation than those that are shortlisted and could support system reliability sooner.
  • GSCE supports Group 4 with a caveat and requested clarification.
    • We find the deliverability terminology to be unclear and potentially confusing as to the effect of the rule. The next policy paper should more clearly describe which projects will qualify for Group 4 and provide examples that illustrate how the rules would apply to projects at different stages of development (i.e., immediately after Phase II studies, approaching seven years in the queue, and once the project is operational).
    • For allocations in fall of 2023 and thereafter, CAISO should explicitly address how Group 4 would treat a late-stage FCDS or PCDS project that wants to add storage in either a hybrid or co-located configuration and seek an allocation of deliverability for the storage addition.
      • These FCDS and PCDS resources should be able to add storage during later stages of development, seek deliverability (including for energy only co-located storage), and continue to their COD with the storage as an energy only component of the project even if the project fails to attain deliverability for the storage addition through two attempts at Group 4.
      • Co-located resources with one FCDS/PCDS component and one energy only component should be treated equal to PCDS hybrid resources so CAISO does not force one configuration over the other.
    • A project that has received TPD by any means other than a Group 4 allocation should be protected from Group 4 withdrawal requirements.
  • The new Group 4 seems designed to push energy only projects out of the queue if they are unsuccessful in obtaining a deliverability allocation. CAISO should commit to working with the CPUC to adjust assumptions about energy only projects used in their proceedings like the integrated resource planning proceeding.
• PPA minimum term length requirement
  • GSCE opposes a five-year minimum term as unsupported and disconnected from the need to only consider RA program needs. We urge CAISO to adopt a three-year minimum term requirement, which will better encourage new RA resources to reach commercial operation.
• Site exclusivity
  • GSCE supports the addition of site exclusivity-based readiness criteria for Cluster 14, although we believe that QC14 projects should not be allowed to proceed to Phase II without demonstrating site exclusivity.
  • We do not believe that QC14 is an anomaly. In fact, more clusters the size of QC14 will be needed to get sufficient resources connected and built to address California’s goals.
  • To illustrate our concern with the queue, we have provided an assessment of the historical success rate of CAISO’s queue and how that translates into meeting procurement and planning targets over the next decade.
  • GSCE believes that going forward site exclusivity must be a requirement to submit an interconnection request. We see projects with site exclusivity as much more likely to be able to proceed to commercial operation.
  • We suggest that CAISO address the site exclusivity policy for Cluster 15 and beyond in phase 2 of the initiative. This will allow for more dialogue about what steps can be taken to improve the viability of projects entering the queue.

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

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

TPD Allocation Groups 1-3

GSCE continues to support the proposal for Groups 1-3, but we urge CAISO to make projects that have provided their notice to proceed to construction eligible for Group 3. We view this as an important way to inject readiness criteria into the GIDAP and incentivize projects to proceed to commercial operation. This is in line with discussions surrounding FERC’s recent transmission and generation interconnection ANOPR where FERC is asking about, and seems to be moving towards, an interconnection process where the most ready projects are promoted.[1]

Expanding proposed Group 3 to include projects that have provided notice of intent to proceed to construction is reasonable because these projects are fully committed financially and have permits necessary to allow them to proceed to construction. These projects also bring a much higher degree of commercial certainty than projects that have been shortlisted. The notice to proceed provides a clear, bright-line requirement that is easy for CAISO to confirm.

TPD Allocation Group 4

GSCE supports the newly proposed allocation Group 4 with the following caveats and requested clarification: 

• The next policy paper should address stakeholder confusion by more clearly stating that all projects are eligible to seek TPD via Group 4 this fall regardless of TPD status.
  • The Draft Final Proposal describes Group 4 eligibility this fall as “[a]ny project that does not have an allocation of TPD,” which could be read to exclude PCDS projects and those that are FCDS and seeking an allocation for a new storage addition. During the March 24 stakeholder meeting, CAISO clarified that any project, regardless of deliverability status, may apply (i.e., FCDS, PCDS, and EO). CAISO should include this clarification in the next policy paper.
• For TPD allocations in fall of 2023 and beyond, CAISO should directly state that eligible projects include those that just completed Phase II, are coming out of parking, or have an allocation of TPD at the time of the allocation affidavit due date irrespective of any past energy only status.
  • Explicitly referencing projects that just completed Phase II or are coming out of parking clarifies the Draft Final Proposal reference to FCDS and PCDS.
  • In addition, during the March 24 stakeholder meeting it was mentioned that eligibility could be described as projects that have not been converted to energy only. However, a project that has been converted to energy only in the past should be eligible for Group 4 if it later receives TPD, so long as the project has some TPD when it applies to Group 4.
    • Defining eligibility as projects that have never been converted to energy only could be read to contradict the following from the Draft Final Proposal: “Beginning with the 2023-2024 TPD allocation cycle and thereafter, an Interconnection Customer may apply for a TPD allocation in Group 4 at any time if its deliverability status at the time of the allocation affidavit due date is FCDS, or PCDS.”[2]  
• Also considering allocations in fall of 2023 and beyond, projects that are either FCDS or PCDS should be able to add storage during later stages of development and qualify for an allocation of TPD.
  • These FCDS and PCDS resources should be able to add storage in later stages of development, seek deliverability (including for energy only co-located storage), and continue to their COD with the storage as an energy only component of the project even if the project fails to attain deliverability for the storage addition through two attempts at Group 4.
    • For example, Cluster 9 projects with deliverability should have the chance to add co-located energy only storage and seek TPD via Group 4, thereby creating new RA resources that can more quickly come online and support grid reliability. And co-located energy only storage that fails to receive TPD through Group 4 should not be forced to withdraw or downsize.
  • A co-located resource with one FCDS/PCDS component and one energy only component should be treated equal to a PCDS hybrid resource so CAISO does not force one configuration over the other. We see what CAISO is currently proposing as pushing resources to a hybrid configuration.
  • Even if all mixed fuel projects initially start in the queue as a single project (and thus are PCDS if they have some TPD), a co-located resource must eventually elect to have multiple resource IDs. If one resource ID is energy only, it then faces issues with CAISO’s current description of Group 4 eligibility and withdrawal.
    • CAISO should treat this case on par with how it is proposing to treat PCDS hybrids rather than a standalone energy only resource.
    • Elsewhere, CAISO has sought to promote co-located configurations over hybrids, so CAISO should not discourage co-location through these proposed rule changes.
    • In addition, same fuel-type projects can also create multiple resource IDs, and CAISO’s proposal appears to needlessly limit this as well.
  • Overall, the fact that a project can only apply to Group 4 in two consecutive years will still be a limiting factor that does not allow projects to linger in the queue, especially when combined with commercial viability criteria and time-in-queue limitations.
• CAISO should clarify that if an interconnection request with an allocation of deliverability is applying to Group 4 to seek additional TPD, the project will not be required to withdraw if it fails to receive any additional TPD via Group 4.
  • A project that has received an allocation of TPD by any means should be protected from Group 4 withdrawal requirements.  
  • CAISO is proposing to increase TPD transfer capabilities and is allowing PCDS to apply, so CAISO should generally support these projects and not limit opportunities to reach FCDS, as FCDS increases the chances of being financed and reaching commercial operation. 
• A project that applies to Group 4 once but forgoes the option to do so a second year should not be withdrawn.

Lastly, the proposed Group 4 has an important policy consequence beyond the interconnection process. CAISO is creating an allocation group that pushes projects out of the queue solely based on the absence of deliverability and the absence of a PPA that satisfies a certain minimum term requirement (i.e., only qualifies under Group 4 and twice fails to receive or retain TPD via Group 4). This speaks to the lack of commercial viability for energy only. However, it is inconsistent with the integrated resource planning proceeding’s assumption that a significant amount of energy only resources will become operational in the future. This is troublesome because the IRP’s assumptions then impact CAISO’s transmission studies because the resource portfolios studied in the TPP come from the IRP. CAISO should commit to working with the CPUC to adjust assumptions about energy only projects used in the IRP.

PPA term length requirement

GSCE supports three years as the minimum term length for contracts to be eligible to seek and retain TPD. In order to encourage resources, particularly storage, to be developed and qualify to support the resource gap in California, CAISO should consider that pure RA contracts are commonly for one to three-year terms. Given TPD is allocated to support the RA program, CAISO must consider RA-only contract term lengths, and three years is a material minimum for RA-only. In addition, once a resource is able to sell RA it will continue to do so because of the commercial value, which highlights that a TPD allocation based on a three-year contract will be a prudent investment in reliability by providing RA well beyond the three-year term.

Five years is a significant barrier that we do not support, and we find such a barrier inappropriate because CAISO does not have a clear policy solution it is trying to achieve with the proposed term length. Setting a five-year requirement does not appear linked to any real-world commercial length associated with RA contracting. CAISO’s only goal is to enshrine some form of minimum, so it should start with a more conservative term length.

CAISO should be focused on supporting new resources capable of delivering capacity and figuring out how these resources can qualify for deliverability rather than imposing new barriers. We urge CAISO to strengthen other measures to qualify for a deliverability allocation that signal a project’s ability to proceed to commercial operation (e.g., site control) rather than impose new requirements that will impede development of resources capable of supplying RA.

[1] See FERC docket RM21-17-000, 176 FERC ¶ 61,024, at ¶157, July 15, 2021; see also Utility Dive, 'I think we have a wake-up call right now' — FERC's Phillips touts transmission's reliability benefits, March 25, 2022, available at: https://www.utilitydive.com/news/i-think-we-have-a-wake-up-call-right-now-fercs-phillips-touts-transmis/621024/ (quoting FERC Commissioner Phillips as saying, "I think we need to start looking at what projects are actually ready to have shovels in the ground. And then we can incentivize properly the developers and everyone in the system to make sure that those projects get selected.").

[2] Interconnection process enhancements 2021 initiative, Draft Final Proposal, at 10, March 17, 2022.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

GSCE has supported CAISO’s proposals to tighten the site exclusivity requirements and believes CAISO should push further to require site exclusivity for Cluster 15 and beyond as a condition of entering the queue. In addition, we believe CAISO needs further reforms to encourage viable projects to seek interconnection and discourage speculative projects that take up precious time and resources.

Since its inception, CAISO has had a total of 1,912 generator interconnection requests representing 492,561 MW at the point of interconnection.^[1]  Only 4.8 percent of the megawatts that have entered the queue have achieved commercial operation. Obviously, with any statistical analysis there are multiple ways to look at the same numbers, but our analysis concludes that not only is the current queue unlikely to be sufficient to meet California’s long-term climate change objectives, but a significant amount of time, money, and precious human resources are currently focused on studying projects that will never become operational. We do not believe the current process will allow California to meet its GHG reduction goals or reliability needs given the historic success rate and the amount of renewable generation that must be built in the next several years. 

CAISO’s Draft Final Proposal states, “[t]he 605 projects totaling 236,225 MW, 164,153 net MW at the Point of Interconnection (POI), currently in the queue exceeds mid-term requirements by an order of magnitude.”^[2]  This is a true statement only if it is the case that all projects go on to achieve commercial operation, which is clearly not the case. Given that the historic success rate of queued projects that reach commercial operation is about 5 percent, the current queue will only produce about 8,200 MW of operational projects. This falls well short of what is needed for midterm reliability procurement and is only roughly 20 percent of the megawatts expected to be needed in 2032 according to the CPUC’s preferred system plan (“PSP”) that CAISO will be studying in this year’s transmission planning cycle.^[3]

Stated differently, to reach the estimated 40,551 MW required to be operational in 2032 (based upon the PSP), CAISO’s generator interconnection queue would need to have over 800,000 MW of pending projects (a 490 percent increase over the current queue) if the current success rate of projects in the queue holds. For the current queue to succeed at producing sufficient generation on the system by 2023, pending projects would need to achieve a commercial operation success rate of almost 25 percent. As a reference, only 5.2 percent of all projects in Clusters 1-7 have successfully reached commercial operation while approximately 92 percent of all megawatts have withdrawn.  For Clusters 8-10 the results are similar:  1.5 percent have reached commercial operation and 67.2 percent have already been withdrawn. While projects in more recent clusters are still in the development process, so it is too early to reach conclusions about their success rate, thus far fewer than 0.5 percent of the megawatts in Cluster 11-13 have reach commercial operation while 65 percent of the megawatts have been withdrawn from the queue.

The following chart summarizes the success and withdrawal rates of five historic periods since CAISO commenced operation:

Based on the historic success rate of approximately 5 percent, it is highly unlikely that 25 percent of all the projects currently in the queue will reach commercial operation. We believe that a 10 percent success rate should be seen as highly optimistic, given historic rates of success. Therefore, assuming that we are at or near the historic success rate moving forward, in order to meet the 2032 target, we need a queue of over 400,000 MW net POI, two and a half times more megawatts than are currently pending.  Another way to consider it is we need between four (optimistic) and eight (historical average) additional queue windows similar to Cluster 14 to hit the 2032 target, and this is assuming that the 2032 target does not increase. 

We believe all of this points to the need for more aggressive reforms to do two things: (1) strengthen the rules so projects that are just “prospecting” are discouraged from entering the queue; and (2) strengthen the process and ties between CAISO’s transmission planning and generator interconnection process, the CPUC’s integrated resource planning process, and the CEC’s forecasting and SB 100 processes. We urge CAISO to help lead a process to examine the steps needed to give California a fighting chance to achieve the 2032 target.

This should include strengthening site control requirements moving forward so that a deposit is no longer sufficient to enter the queue. This is in line with the practice of other ISOs and RTOs^[4] and would markedly improve the chances that developers are pursuing real projects when they enter CAISO’s interconnection queue.

Without immediate and meaningful reforms, this data shows that we remain on a path to come up short. We urge CAISO to take a further look at additional reforms in phase 2 of this initiative.

[1] This information is pulled from CAISO’s Public Generator Interconnection Queue information updated as of March 8, 2022.

[2] Interconnection process enhancements 2021 initiative, Draft Final Proposal, at 3, March 17, 2022.

[3] See 2022-2023 Transmission planning process, Draft Study Plan, at 24, Feb. 18, 2022, available at: http://www.caiso.com/InitiativeDocuments/DraftStudyPlan-2022-2023TransmissionPlanningProcess.pdf.

[4]  Interconnection process enhancements 2021 initiative, Revised Straw Proposal, at 25, Jan. 25, 2022 (referencing PJM and SPP).

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

Hanwha Q CELLS (or, Q CELLS, for short) appreciate the opportunity to provide continued feedback as part of CAISO’s Interconnection Process Enhancement 2021. Q CELLS is primarily concerned with two facets of the Phase 1 enhancements at this time -- TPD allocation and site exclusivity deposits. Our comments and feedback to those and other items are listed below.

About Hanwha Q CELLS

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

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

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

Q CELLS has no comment at this time.

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

Q CELLS appreciates CAISOs proposal of a new TPD allocation group 4 which will consist of projects without PPAs that hope to execute one with the TPD allocation.

Q CELLS generally supports the TPD allocation framework, but also needs to see transparency from CAISO regarding TPD methodology and allocation. In instances, for example, where a gap exists between allocation and capacity, developers need to see how these calculations are made, and what status is placed on unallocated capacity.

Q CELLS appreciates all the effort CAISO has put into this item, giving considerable weight to developer feedback. Q CELLS looks forward to CAISO’s additional work in this matter. 

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

Q CELLS has no comment at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

Q CELLS appreciates CAISO’s efforts in this matter and agrees with the overall framework. In-lieu deposits should be substantial, as is the case for withdrawal penalties.

However, Q CELLS is against 50% non-refundability at such an early stage (after scoping meeting). This represents a large financial risk that will have to be a consideration for, we assume, a majority of developers. Q CELLS, much like the rest of the developer community, wants to see sensible reduction in CAISO’s queue, especially when it comes to non-viable projects . Q CELLS believes the current remedy will have unintended consequences and will not aid in acheieving this goal. For example, due to the added risk, queued projects which are commercially viable may be withdrawn. Second, less viable projects may remain in the queue, as there is no consequence (starting at the scoping meeting site exclusivity deadline through the phase 2 study entry deadline) for doing so.

Q CELLS suggests a graduated approach, where 50% non-refundability represents a maximum amount. This maximum level would take place sometime around the Phase 2 study entry deadline. Q CELLS suggests a 10-20% non-refundability penalty at the proposed deadline (shortly after the scoping meeting).

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

Q CELLS has no comment at this time.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

Q CELLS has no comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

Q CELLS has no comment at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

Q CELLS has no comment at this time.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

Q CELLS has no comment at this time.

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

Q CELLS approves of this initiative and looks forward to the added clarity regarding deficiency curing timelines.

Q CELLS will review the tariff language for details about the added due dates and will reserve additional comment until that time.

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

Q CELLS has no comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

Q CELLS has no comment at this time.

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

Q CELLS has no comment at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

Q CELLS has no comment at this time.

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

Q CELLS has no comment at this time.

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

Hydrostor appreciates the work that the CAISO has undertaken within the Interconnection Process Enhancements Initiative including listening to feedback from stakeholders.  We look forward to continuing to engage with the CAISO in this initiative including Phase 2, where we hope further refinement of Deliverability assessments will be considered, as well as other CAISO stakeholder processes. 

In general, Hydrostor supports many aspects of the Phase 1: Near-Term Enhancements particularly process improvements that allow for a more streamlined, transparent and efficient interconnection process.  However, we do have some concerns regarding the newly proposed Allocation Group 4 within the TPD allocation process.  Specifically, the proposal requires that projects that do not receive Deliverability after two attempts via new Allocation Group 4 withdraw and we believe this requirement is overly onerous.  Projects should be given the option to convert to Energy Only after two unsuccessful attempts through Allocation Group 4 in lieu of being forced to withdraw.

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

Hydrostor supports the CAISO proposal.

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

 As noted in our answer to Question 1, Hydrostor has serious concerns regarding the requirement that projects that are unsuccessful after two attempts at securing Deliverability via Allocation Group 4 be forced to withdraw from the interconnection queue. These projects should be given the opportunity to convert to Energy Only.  Developers are spending significant time and resources in developing projects within the CAISO footprint and the proposed requirement to withdraw appears to be overly onerous when layered on top of monies put at risk in the interconnection process (e.g. site exclusivity deposit, Interconnection Financial Security postings). 

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

 Hydrostor has no comments on this topic at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

Hydrostor generally supports the revised site exclusivity requirements.  However, we believe that that the CAISO should consider moving the date after which the site exclusivity deposit is at risk until after the Phase I Results Meeting (vs. the Scoping Meeting as currently outlined in the Draft Final Proposal). 

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

 Hydrostor supports the CAISO proposal.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

Hydrostor has no comments at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

 Hydrostor supports the CAISO proposal.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

Hydrostor supports the CAISO proposal. 

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

Hydrostor supports the CAISO proposal.  

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

Hydrostor supports the CAISO proposal. To the extent that information requirements for Appendix B can be further streamlined as proposed by CalWEA, these should be considered by the CAISO.

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

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

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

 Hydrostor supports the CAISO proposal.

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

 Hydrostor has no comments at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

 Hydrostor supports the CAISO proposal.

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

Hydrostor looks forward to further engaging with the CAISO in this Interconnection Process Enhancement Initiative including Phase 2.  In particular, Hydrostor strongly encourages the CAISO to consider the modest modifications to its On Peak Deliverability Assessment methodology, as put forth by CalWEA and CESA, and included on pages 176 and 177 of the Future of RA Report issued by the CPUC, as part of Phase 2 of this initiative (or another near-term process).   Given the fundamental changes to the RA program being proposed – with a Decision by the CPUC in R.21-10-002 expected in summer 2022 – Phase 2 of the Interconnection Process Enhancements Initiative is an ideal avenue to consider these changes in parallel.  Adoption of these modest Deliverability study methodology changes will allow a greater array of resources to assist in meeting California’s urgent reliability needs while reducing the potential for the increased costs associated with a transmission over-build (which have far too often been delayed).

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

LSA continues to strongly support efforts to allow projects to move ahead without adverse impacts to other projects and supports many CAISO proposals here to facilitate that.  LSA very much appreciates the CAISO’s open-mindedness in welcoming stakeholder proposals for this initiative, including incorporation of several LSA-suggested topics.

LSA continues to support these proposals:

• Remove the downsizing window and simplifying downsizing request requirements, but with clarifications that could allow more requests to be approved in the Material Modification Assessment (MMA) process.

• Develop an emergency generation interconnection process.

• Expand the errors and omissions process.

• Clarify that “C&I” PPAs can qualify for Transmission-Plan Deliverability (TPD) awards by having a Resource Adequacy (RA) contract with a Load-Serving Entity (LSE)

• Transfer Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into the CAISO Queue.

• Allow sites and POI changes during IR validation, with certain clarifications.

• Allow parked projects to submit MMAs while parked.

• Modify Commercial Viability Criteria to exempt COD delays from PTO delays.

• Expand deliverability-transfer opportunities to allow transfers between projects connecting at the same substation and voltage level.

• Include all interconnection-related documents in RIMS for each project.

Likewise, LSA does not object generally to the revised Site Exclusivity (SE) proposal but offers several suggestions to address difficulties with obtaining SE on public lands and revised tariff or BPM language concerning the SE definition.

However, several CAISO proposals seem to be attempts to restrict and regulate market transactions, including agreements freely entered into by diverse market participants that increase market liquidity and efficiency.  Many proposals in this category do not clearly address any problem and/or provide very little justification or evidence to support proposed solutions.  These proposals are the following:

• Require a minimum 5-year term for “qualifying” PPAs in the Transmission Plan Deliverability (TPD) Allocation process.

• Imposing a lower TPD Allocation priority on “C&I” PPAs meeting the qualification requirements described above.

• Require that any IR that proposes to use a third party gen-tie provide documentation showing the owner has agreed, because it singles out only one detail of the many that could cause a project to fail.

Finally, LSA appreciates the CAISO’s response to recommendations from LSA and others to retain a form of the current TPD Allocation Group 3, through CAISO’s proposed new TPD Allocation Group 4.  However, LSA is concerned that the “come and get it” approach for eligibility, as well as the complex rules for retention and dire consequences for lack of it, are unnecessary and irrational, and will deplete the limited stock of RA deliverability at a time when the CAISO is concerned about deliverability availability for new technologies. 

Instead, LSA encourages the CAISO to adopt the more simplified and limited approach suggested by LSA in this area, retaining the current Group 3 provisions for the new Group 4 except for the addition of PPA milestones.  As the CAISO points out, the current Group 3 approach has proven its worth through years of experience as projects with those awards have obtained PPAs and then constructed operating facilities; there is no need to layer on the new proposed complexities in the new Group 4.

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

Support with clarifications

Among other things, the Proposal would remove the current downsizing application window, unique deposit, & agreement, allowing requests to be submitted at any time, and processed via the MMA process. Downsizing requests for projects with no Network Upgrades could be approved through the MMA process; downsizing requests for other project would be held and processed in the annual Reassessment process, as they are today.

LSA supports the concept of simplifying the downsizing process and making it more like the regular MMA request process (as it was before implementation of the formal and separate downsizing process). However, developer benefits would be limited to the extent that downsizing requests would continue to be processed in the annual Reassessment, so the CAISO should clarify whether the CAISO would consider processing a downsizing request through the MMA process in other simple situations.

Thus, LSA has asked in nearly every stakeholder meeting in this initiative if the CAISO would consider approving downsizing requests in the regular MMA process where the project has Network Upgrades but the CAISO/PTO could assess the impact without a study.  The CAISO has answered in the affirmative every time, and LSA has requested this clarification in every comment submittal but, for some reason, the CAISO did not include the clarification in the subsequent proposal.

Thus, LSA again requests that the CAISO include that clarification, in the Final Proposal.  With all due respect, this is simply the approach used in the current MMA process for all requests, i.e., if the CAISO/PTO can assess the request without a study it can be considered there, while requests that require a study would have to undergo a study. 

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

Support, but with the revisions and clarifications described below.

LSA continues to support the simplification of the current 7-group structure but strongly recommends the revisions below. 

• • Revise the proposed TPD Allocation Group 4 proposal to more closely follow LSA’s prior recommendation for a framework that more closely resembles the proven and simpler current Allocation Group 3 approach.

• • Withdraw its proposal to apply a lower TPD Allocation priority within Groups 1-2 (and perhaps Group 4) where the off-taker is not an LSE but has an actual (Group 1) or tentative (Group 2 and perhaps 4) contractual commitment to provide RA to an LSE.

• • Withdraw, or if not, shorten the proposed 5-year minimum term.

These recommendations are explained below in the remainder of this section.

Revise the Allocation Group 4 proposal

LSA greatly appreciates the CAISO’s responsiveness to strong stakeholder sentiment and new proposal for an Allocation Group 4.  LSA agrees with the CAISO’s earlier assessment that the current Group 3 was used successfully by projects to first obtain a TPD allocation, and then secure a PPA and build the project.

Thus, LSA was one of the parties recommending continuation of this approach.  Our proposal (dating back to the Workshop) was to retain the current Group 3 as a post-Phase II Study option, with the addition of retention milestones similar to Group 2, i.e.: (1) Shortlist/active negotiations the next year; (2) executed PPA the following year; and (3) regulatory approval of PPA the year after that.  Retention requirements would cease once the project reached Commercial Operation, as they do today.

The CAISO’s new Group 4 proposal features some of this framework, but it seems to create other problems and does not address complexities needed for a well-considered, complete proposal.  Among LSA’s many concerns are those described below.

First, while the current Group 3 election is limited to projects coming off the study process, the wide-open Group 4 eligibility criteria – essentially, no criteria at all – would allow any and all projects without a TPD Allocation, operating and still active in the queue, to apply. 

To start, this does not make sense for operating projects, since any of those could apply under the new Group 3 and would receive a higher allocation priority as a result.

Second, even limiting the criteria to projects active in the queue could produce a tremendous “gold rush” that (by the CAISO’s own admission) could exhaust the already-limited supply of TPD in many areas, thus leaving little or nothing for Cluster 14 or any new technologies (e.g., offshore wind).  The CAISO has gone from concerns that retaining the current Group 3 could absorb a large portion of remaining deliverability before Cluster 14 to throwing the doors wide open to any and all projects.  While some LSA members would welcome another “bite of the apple” for their EODS projects, even they, on balance, don’t consider this a wise policy move. 

This is especially true if the CAISO – as it has “telescoped” in more than one forum – is considering restrictions on TPD awards available from future-approved policy-driven upgrades for Phase 2 of this initiative.  Exhaustion of currently available TPD would only exacerbate the situation the CAISO might seek to address in such Phase 2 proposals.

Third, the Proposal does not explain why projects even requesting a Group 4 award become subject to the current Group 3 restrictions (e.g., suspension prohibition and COD extension restrictions) even if they do not receive such awards, or (as noted below) how that would work if the request was only for part of a project.

Fourth, restrictions in eligibility going forward – 2023-2024 allocation and beyond – to projects having FCDS/PCDS status before the allocation doesn’t really make sense.  Projects that fail to receive or retain TPD Allocations are converted to EODS and thus would be ineligible for Group 4.  Effectively, that means only projects coming off the Phase II Study process (plus those parked – see below) could elect Group 4, so why not just retain the current rules limiting this election to those coming off the study process, perhaps with the exception noted below?

Fifth, the parking rules seem strange and illogical.  It seems that projects failing to receive an award would be allowed to park once, and perhaps twice, and try again – unless they had parked before (which could have happened years earlier).  If a project had parked once before, it’s not clear whether they could park a second time under this proposal and, if so, whether that would be under the rules applying to first or second parking.  Moreover, it’s not clear what would happen if a project had parked only some of its capacity before, once or twice, and now was asking for another award.

Sixth, it’s not clear why a project must withdraw from the queue after failing to receive or retain a Group 4 award, instead of just being converted to EODS.  The CPUC TPD portfolios contain a large portion of EODS solar and other resources, and there is no reason to suspect that these projects as a whole could not be successfully developed as EODS projects, especially if LSE procurement processes eventually reflect the CPUC’s expectations.

If the CAISO is trying to use this option as a “queue clearing” mechanism, it is certainly a strange and contradictory way to do that.  Inviting large amounts of projects to apply for deliverability again, with no qualifying criteria, would tend to keep projects in the queue for at least another year or two, when perhaps they might have dropped out before that.

Finally, the Proposal does not consider more complicated situations, e.g., treatment of Mixed-Fuel Resources or PCDS projects.  For example:

• Would a project requesting a partial Group 4 allocation be precluded from requesting a COD extension for the capacity already possessing a TPD award?

• Would a project unable to retain a Group 4 award for part of its capacity have to completely withdraw, or downsize to remove the applicable capacity (even to the extent that, for example, an MFR resource might have to remove, e.g., the entire renewable component for which it was seeking deliverability)?

Clearly, this proposal is “not yet fully baked,” and the pieces just don’t seem to fit together.  This is a troubling conclusion for a topic in a Draft Final Proposal.  LSA strongly urges the CAISO to instead adopt its original, much simpler, and proven proposal framework, perhaps with a simple adjustment like making currently parked projects eligible. 

PPA requirements for “C&I” (non-LSE)_PPAs

LSA appreciates the CAISO adding the clarification that “C&I” PPAs would qualify for Group 1 and 2 TPD awards if the non-LSE off-taker has a contractual obligation to provide RA to an LSE third party (e.g., CCA).

However, this is a prime area where the CAISO appears to be proposing an unsupported solution that would unduly restrict contracting and related market activities, in order to respond to an unidentified problem.  The CAISO has not provided any data (e.g., from other jurisdictions where these kinds of contracts are more common) showing that any C&I (non-LSE) off-takers are withholding RA or capacity services. 

As Amazon Energy stated in earlier comments, non-LSE off-takers are strongly incented economically to make RA deliverability available to either their host LSEs or others seeking it in the market. Such off-takers have already paid for these all attributes, and unless the CAISO has some evidence otherwise, there is no reason to assume that they would withhold those attributes from the market.

In addition, the CAISO has offered no justification for giving C&I PPAs (even those with associated LSE RA contracts) lower priority for TPD Allocation awards than PPAs with LSEs (or LSEs building for their own loads).  The ultimate user of the RA attributes will be LSEs in any case, and the CAISO should not be interfering in the RA market by showing favoritism for certain contracting practices over others.

PPA requirements – minimum contract term

This is another area where the CAISO appears to be proposing an unsupported solution that would unduly restrict contracting and related market activities to respond to an unidentified problem.  Moreover, this proposal would create additional impediments to RA contracting and eventual project success. 

Again, the CAISO has provided no evidence at all that the lack of a minimum contract term for qualifying PPAs has led to any problems, and no evidence that a minimum term as long as 5 years is needed for any reason.  Several aspects of this issue are discussed below.

Operational projects:  Contract expiration after COD should be left to project owners to manage.  It is highly implausible that a project that has reached COD and is already operating, with an expired PPA but with valuable RA attributes, would withhold those attributes from the market and willingly forego the associated revenue stream.  The CAISO’s past actions unbundling and enabling separate contracts for RA have been highly effective, and there is no need for the CAISO to interfere in the vibrant market it has helped to create.

Needed flexibility:  While developers typically rely on long-term contracts to support project development, the PPA market is struggling with many issues that, if anything, are driving developers toward arrangements with more flexibility.  Among those are:

• • Regulatory uncertainty:  The CPUC is in the middle of an extensive and lengthy effort that could significantly revise the way RA resources are counted, among other things, through the new “slice of the day” approach or perhaps others.  The Mid-Term Procurement counting rules are not consistent with current rules, adding uncertainty. 

The CAISO itself has contributed to this uncertainty through its UCAP proposal.  That proposal, which has been public for a couple of years, has greatly complicated RA contracting, and it is unclear whether or when it might be imposed and what the eventual rules might be.

Contract flexibility will enable suppliers (and buyers) to adapt more easily to whatever rules are eventually adopted. 

• • Cost uncertainty:  Equipment markets – e.g., for batteries – have been especially hard hit by the combination of inflation and supply-chain shortages.  Equipment has been hard to come by in many areas, and equipment suppliers are quoting cost increases of 30% or more in some cases.  This situation could persist far into the future as renewables construction ramps up considerably, raising the possibility of higher operating costs after Commercial Operation as well.

This makes it extremely difficult for developers to quote the kinds of long-term firm prices that buyers have become accustomed to in long-term PPAs.  It is possible that some, or a significant number, of long-term contracts may simply fail, e.g., developers may have to cancel them if they are no longer economic.

If the CAISO mandates a high minimum term that undermines market need for flexibility, then parties will try other mechanisms to provide that flexibility, e.g., liberal termination or renegotiation provisions.  That could require the CAISO to assess the “bindingness” of bilateral PPAs, and LSA doubts that the CAISO would want to assume that role.

Discriminatory treatment:  The CAISO proposal will also disadvantage new projects compared to existing projects with expired shorter-term contracts.  These existing projects will be able to contract for any term agreeable with their off-takers, while new projects will be hobbled by any CAISO minimum-term requirements.

Conclusion:  The CAISO should not impose mandatory minimum contract terms on this already fraught situation without any demonstration of need.  The trade-offs between contract/revenue certainty and regulatory/cost risk should be left to free interaction between contracting parties and not dictated by the CAISO.  Sellers and buyers are having enough difficulty managing these problems in this market, and they don’t need interference by the CAISO that will only complicate matters.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

Support reformulated proposal for “emergency”-type authorization.

The proposal has been sufficiently limited and clarified – e.g., governmental emergency declaration required, three-year limit, Interim Deliverability only– to address LSA/SEIA’s concerns.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

Does not object to the Phase II Study proposal, as revised, but recommends changes to the Site Exclusivity definition proposal.

Phase II Study proposal:  The CAISO has proposed the following:

Starting with Cluster 14, a project can enter Phase II studies w/a Deposit in lieu of SE, and the deposit is refundable upon later SE demonstration.  However, the entire SE deposit is non-refundable if project withdraws after Initial IFS posting.

Starting with Cluster 15:

-  SE Deposits increase to $250K for projects <20MW & $500K for projects >20MW.

-  SE Deposits will remain refundable if a project in the queue later demonstrates SE

-  If project withdraws after submitting SE Deposit, deposit refundability is: (1) full, for withdrawals w/in 30 CDs of the Scoping Meeting; and (2) 50%, for withdrawals after that.

-  SE required (no deposits) to enter Phase II, by 10 BDs before the Initial IFS posting.  Project deemed withdrawn if fail to meet this requirement, SE Deposit 50% refundable.

LSA believes that, for the most part, the revised proposal strikes a reasonable balance, allowing Cluster 14 to proceed largely under current rules and reserving the more significant changes to project applying in the future.  However, assuming a more typical post-Cluster 14 schedule, LSA is concerned that obtaining SE on public lands sometimes cannot be complete by this early deadline, before the first posting. 

Thus, LSA suggests that some additional leeway be given in those situations where necessary.   Other jurisdictions with Site Exclusivity requirements recognize these difficulties in their tariffs.  As an example, LSA’s suggested language below is based on MISO tariff provisions (Attachment X GIP (Effective March 15, 2022)330116.pdf (misoenergy.org)) for similar situations.

An Interconnection Customer unable to demonstrate Site Exclusivity on public lands for its Generating Facility as a result of regulatory restrictions can enter Phase II by continuing its SE Deposit postings and making its SE demonstration once the process is complete.  To demonstrate such regulatory restrictions, the Interconnection Customer must submit: (i) a signed affidavit indicating that Site Exclusivity is unobtainable when required due to regulatory requirements; (ii) documentation sufficiently explaining the regulatory restrictions, including any conditions that must be met to satisfy the regulatory restrictions; and (iii) the time when the Interconnection Customer expects to satisfy the regulatory restrictions.

LSA would not oppose a complete forfeit of the SE Deposit for projects using this option that later withdraw from the queue.

SE definition proposal:  The CAISO proposes to do the following, for projects sited on public lands, to support off-shore wind applications:

• Replace current tariff definition with a broad requirement that IC must show it holds a “duly executed written contract or option to purchase, acquire an easement, a license or a leasehold interest in the real property for which new interconnection is sought, or that it has filed applications for required permits to site on federal or state property.”

• Include “current, known requirements for certain use cases” in BPMs.

LSA supports removal of case-specific language related to BLM applications from the Site Exclusivity definition.  However, the Proposal indicates that it would be replaced by a broad provision to meet Site Exclusivity that would include a filed application for required permits to site on federal or state property.

Such provision would still limit Site Exclusivity to public agencies, like the BLM, which allow interconnection customers to “apply” for site control. This definition would exclude interconnection customers working with public agencies that do not offer a BLM-like “application process.”  For public land that does not have a site control application process, LSA suggests that the Interconnection Customer be required to submit evidence of engagement with an appropriate public agency, with details in the BPMs.

Similarly, LSA supports CAISO’s proposal to include current, known requirements for certain use cases in the BPMs.  To that end, LSA recommends language added to the following language to the “current, known requirements” in the BPM, as an option to meet Site Exclusivity requirements:

For public land that does not have a site control application process, the interconnection customer shall be required to submit evidence of engagement with an appropriate public agency.

Evidence of engagement shall confirm that the interconnection customer is working with the agency to evaluate the suitability & availability of land for the project. This evidence of engagement could in the form of a signed attestation or an affidavit.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

Support.

The CAISO proposes that a project could accept changes, or withdraw and receive a full refund of IFS and any unused Study Deposit, if a PTO error or omission is discovered after the first or second IFS posting that: (1) increases aggregate project costs by more than the greater of 10% or $1 million; (2) delays the earliest achievable In-Service Date or in-service date for any DNUs needed for the project’s requested deliverability status; or (3) leads to project PPA cancellation. 

LSA supports this proposal and greatly appreciates the CAISO’s recognition of the potential damages caused by late-discovered and significant project changes from PTO errors and omissions.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

Oppose.

LSA’s position on this issue has not changed, for the reasons discussed below.

The CAISO states that deliverability-triggered RNUs are RASs, which are always RNUs, so it is justified to treat them as RNUs, i.e., they are needed for interconnection/operation and their costs count toward the RNU cost cap.

LSA does not believe that this rationale justifies this proposal.  These upgrades are triggered by DNUs and the cost is allocated like a DNU.  The fact that they are needed for project operation and “reliability” should not change the fact that they are related to DNUs and only exist because of DNUs, and the cost treatment should thus be consistent with that applied to DNUs.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

Support with clarifications.

LSA support this proposal, with the clarification that the CAISO will include the topic of public information about respective jurisdictions of lines and substations in the upcoming information transparency effort. That effort should focus on facilities where confusion is most likely to arise, i.e.: (1) facilities over 50kV on the PG&E and SDG&E systems  under PTO control; and (2) facilities under 200 kV on the SCE system under CAISO control.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

Support with clarifications.

As before, the CAISO is proposing that:

• Like today, the developer must confirm the project POI within 5 BDs after the Scoping Meeting.

• Any new requested POI must be within the same transmission study area as the originally requested POI.

• Site changes will only be permitted in conjunction with a permissible change in POI.  (The Proposal clarifies that this restriction applies only during the IR validation process, i.e., site changes will continue to be considered through the MMA request process.)

Likewise, LSA/SEIA continue to support the proposal as reasonable, subject to the CAISO’s commitment to provide additional information on the terms “study area” and “transmission study area,” with maps if possible.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

Support, with clarifications and additional modifications.

The CAISO has revised its original proposal to provide that:

• MMA requests would be allowed, but only for changes to fuel type, technology (e.g., wind to storage, solar to storage, etc.) and POI.  (Inverter changes can be made once the project exits parking.)
• Projects must make the second IFS posting when submitting the MMA request.

LSA appreciates the CAISO’s proposal revisions but request the clarifications and further modifications discussed below.

Clarifications

The CAISO should clarify the following:

• • Modifications not requiring MMA requests could be made by parked projects, without submittal of the second IFS posting. These changes are by definition minor and should not unduly burden the CAISO or PTO resources.  The BPM for Generator Management, Section 6.2.1 lists several changes projects can make without submitting an MMA request, such as:
• • • “De minimus” size reductions (5% or less)
    • Milestone delays due to PTO delays
    • Inverter changes, where technology and electrical characteristics are unchanged, including the number and size of inverters, and the PTO agrees that dynamic analysis is not required.  (While these changes can be made after the project exits parking, they may improve the project economics and capability to secure a contract and qualify for a higher allocation group after existing parking, so they should be allowed while parked.)
    • Conversions to lower deliverability status, including Energy Only.
  • Additions or subtractions of energy storage, without increasing POI capacity, qualify as “technology changes” and are allowed during parking, as discussed at the prior stakeholder meeting.

• • Permissible Technological Advancements (BPM for Generator Management Section 6.6) could be made by parked projects because, by definition, those changes “have little or no potential to affect other Interconnection Customers or Affected Systems, require a new Interconnection Request, or otherwise require a re-study or evaluation.”

Modifications

• The CAISO should adopt the sensible and practical SDG&E suggestion from the prior stakeholder meeting that projects be allowed to postpone their CODs when entering parking status. This is especially relevant for projects which have selected the “earliest possible ISD,” which could (but may not necessarily) change with the project parking.

• The CAISO should also allow deliverability transfers from other projects to parked projects during parking (assuming approval of the proposal for deliverability transfers between projects), especially projects parked because they did not receive a TPD Allocation. Such deliverability transfers could make the parked project more competitive, enable early exit from parking, and facilitate queue withdrawal of other, less-feasible projects. Also, DTRs are just math calculations, not requiring any technical studies, and thus are much less burdensome to PTO personnel than most MMA requests.

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

Oppose.

The Proposal retains the CAISO’s prior proposed requirement for all Appendix B deficiencies to be cured within 70 CDs of the Phase I Study issuance, saying that all projects will still have the 35 days for validation even though some will have more.  LSA continues to oppose this proposal because some projects will have more validation time than others, for reasons (e.g., scheduling of Results Meetings) beyond their control.

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

Support.

LSA appreciates the CAISO’s adoption of its workshop proposal that projects not be forced into having to meet CVC based on COD delays caused by PTO delays.

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

Strongly support.

LSA appreciates the CAISO’s adoption of its proposal in this area and continues to support this proposal. Deliverability impacts to the system of projects connecting to the same substation, at the same voltage, are the same. Thus, allowing TP Deliverability transfers between such projects, instead of limiting transfers to those between Generating Units of a single Generating Facility, would provide additional flexibility to developers without adversely impacting other projects either operating or under development.

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

Oppose.

This is another case of the CAISO offering a “solution” to a situation that has not been demonstrated to be a problem.  The CAISO has offered no evidence at all that lack of early gen-tie sharing agreements, in any form, has been a significant (or any) contributor of project failures.  There is no need for the CAISO to impose timing or other restrictions when the parties involved are already addressing these issues satisfactorily.

In addition, as stated earlier, LSA opposes proposals in this area because they focus on only one element of a project – indeed, only one element of gen-tie siting.

Finally, if any rules are imposed despite the lack of need for them, they should be no more stringent than Site Exclusivity rules. 

For Cluster 14, the CAISO has proposed that an LOI be provided to enter Phase II, and an agreement be required by the Second IFS posting.  Instead, the CAISO should provide an option allowing the project to elect to either:

• • Conform to these requirements; or

• • Include this element in its SE provisions, i.e., no LOI or agreement would be needed, but the SE Deposit would be forfeited if the project withdraws without meeting these requirements.

These same rules would apply to Cluster 15.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

Support.

The Proposal would add all communications, including MMA, Repowering, and Limited Operations study documents (requests, data files, study plans, study results, etc.) to RIMS.

As before, LSA supports this proposal. Incomplete records can cause confusion, and also a lack of continuity when CAISO and PTO personnel assigned to the project (and IC personnel as well) change over time.

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

No additional comments.

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

MRP supports most aspects of the CAISO’s Phase 1 Draft Final Proposal.  The exceptions, noted below, are:

• MRP requests clarification on which projects will be eligible to apply for TPD allocation in the 2022-2023 cycle.
• While MRP appreciates that the CAISO is adding emergency interconnection provisions to its tariff before they will be needed or used, and while MRP also appreciates the safeguards that the CAISO has proposed for this process, MRP remains concerned about how and whether those emergency provisions will be used in transparent and equitable ways. 
• MRP still holds that tying the deadline for finalizing Appendix B to the results meeting instead of the publication of the study report will help prevent Interconnection Customers whose results meetings are scheduled later in the process from getting squeezed.
• MRP still believes the errors and omissions thresholds are too high.
• Finally, while MRP appreciates the CAISO expanding the types of MMA changes for parked projects, MRP still believes the CAISO should allow parked projects to submit MMAs for inverter changes.  

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

MRP supports this aspect of the CAISO’s proposal and respectfully urges the CAISO to devote sufficient resources for this effort.   

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

MRP supports the CAISO creating a new Allocation Group 4 (“AG4”) instead of eliminating the existing Allocation Group 3 (“AG3”). 

That said, MRP has some concerns about the CAISO’s proposed AG4. 

• If an AG4 project does not receive deliverability in its first or second attempt or receives deliverability but is not able to retain it, it would be required to withdraw from the interconnection queue. (DFP at p. 11 – “If after two allocation cycles an allocation group 4 project has either never received an allocation or has received an allocation, but has not been able to retain it, the project will be required to withdraw.”)   MRP believes this requirement to be too punitive.  If an AG 4 project does not receive deliverability, it should be allowed to convert to Energy Only status.  Disallowing this option does not align with California’s soon-to-be-growing demand for energy.

• In the table on page 9, only Group 4 shows “see proposed criteria below” for its allocation requirement.  The first bullet under “Additional Criteria” on page 10 states projects must have completed all studies to be eligible for all allocation groups (emphasis added).  Please clarify if the CAISO intends for the first three bullets under “Additional Criteria” to apply to all proposed TPD allocation groups or just to AG4. 

• Additionally, with regards to the first bullet under “Additional Criteria” on page 10, MRP interprets that bullet to mean that projects would not be eligible for the 2022-2023 TPD allocation cycle unless their deliverability study has already been completed.  If that interpretation is correct, MRP struggles to align it with the first sentence under “Explanation of Allocation Group 4” on page 10, which states that “Any project that does not have an allocation of TPD may apply for an allocation during the 2022-2023 TPD allocation cycle.”  Furthermore, MRP believes projects that have a partial allocation should also qualify to apply for an allocation. MRP requests the CAISO clarify what projects may apply for a TPD allocation in the 2022-2023 cycle. 

• With regards to the statement on page 10 - “As with all allocation groups, only projects that have completed all studies, including deliverability, qualify for Group 4.” - while MRP understands the CAISO’s concerns about ISP projects “queue jumping” to obtain deliverability, in light of ongoing state efforts to secure new resources that can be deployed quickly, MRP respectfully urges the CAISO to consider allowing ISP projects that can be deployed quickly, are expansions of existing generating sites and would require no reliability network upgrades, to be studied for deliverability ahead of the next queue cluster. Normally, these ISP projects would have submitted their Interconnection Request ahead of the Cluster and have a COD that the subsequent Cluster would not support. MRP believes that a narrowly crafted exception that facilitates deploying additional needed generation quickly but would not prompt a tsunami of ISP requests warrants consideration

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

MRP is inherently suspicious that creating an emergency interconnection process may create the potential for a self-fulfilling prophecy that encourages “queue-jumping”.  MRP finds it plausible that, if the most expeditious way to interconnect new generation is through an emergency process, that will create a temptation for the state to declare an emergency if the non-emergency process is not perceived to be sufficiently expeditious.  Recent history supports this perception through the lens of resource procurement; for years, California added few generation resources focused on system reliability (instead focusing on RPS procurement) until the load shedding events in August 2020 prompted an emergency declaration that catalyzed the development of new reliability resources.  That said, MRP strongly supports establishing emergency interconnection procedures with strong guardrails and protections in advance of the need to use them.  As the Federal Energy Regulatory Commission noted, the CAISO should make every effort to avoid requests to waive CAISO Tariff provisions related to the emergency interconnection of generating resources in the future.[1]  While MRP appreciates the CAISO’s efforts to craft such procedures and protections in this proposal.  MRP remains concerned about how these emergency interconnection procedures will be applied transparently and fairly if and when they are used.  MRP also urges the CAISO to ensure Interim Deliverability is fairly allocated to projects in the queue when compared to emergency process projects.

[1] California Independent System Operator Corporation, 176 FERC ¶ 61,159 (2021) at P. 27.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

MRP supports this aspect of the CAISO’s proposal. 

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

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

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

MRP supports this aspect of the CAISO’s proposal. 

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

MRP supports this aspect of the CAISO’s proposal, provided that it prevents WDAT projects from jumping ahead of projects in the CAISO’s interconnection queue. 

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

MRP supports this aspect of the CAISO’s proposal. 

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

While MRP appreciates the CAISO expanding from the prior draft language the types of MMAs that can be submitted for parked projects, MRP remains disappointed that the CAISO is still not allowing the Interconnection Customer to submit an MMA for inverter changes to a parked project.  As MRP has offered in comment before, inverter changes can reduce short circuit current, which could obviate the need for network upgrades.  The CAISO’s interconnection process will function most effectively and efficiently if the CAISO has the most recent, most accurate information about projects in the queue. It is not clear to MRP how waiting until a project has left parking to change inverters accomplishes that goal, and MRP remains concerned it could lead to project delays as projects that are parked may still proceed with development and construction.  As result, the CAISO could end up in a situation where a project that is parked has achieved synchronization without being able to update its inverters due to design changes. For these reasons, MRP respectfully requests the CAISO reconsider its proposal to not allow MMAs for inverter changes for parked projects. 

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

MRP remains concerned that tying the deadline for curing Appendix B deficiencies to the issuance of the Phase I study report and not to the date of the results meeting could squeeze ICs whose results meetings are scheduled for later than those of other ICs.   MRP respectfully requests the CAISO reconsider tying the Appendix B due date to the date of the Phase I study report. 

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

MRP supports this aspect of the CAISO’s proposal. 

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

MRP supports this aspect of the CAISO’s proposal. 

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

MRP supports this aspect of the CAISO’s proposal. 

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

MRP supports this aspect of the CAISO’s proposal. 

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

MRP has no additional comments on the IPE Final Phase 1 Proposal.

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

PG&E appreciates the opportunity to provide comments on the draft IPE Final Proposal – Phase 1. Below please find PG&E’s comments and recommendations.

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

PG&E appreciates the CAISO’s collaboration and is supportive of this enhancement.

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

PG&E does not have any comments on the proposal at this time.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

PG&E appreciates the CAISO’s additional development of the emergency generation process. PG&E suggests that the emergency interconnection process only occur when an official proclamation or other equivalent executive order has been issued by the State of California. PG&E appreciates the CAISO’s collaboration with all stakeholders on this important issue.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

PG&E is supportive of the requirement of site exclusivity to progress into the Phase II study process but is concerned that the proposal as presented may result in a large amount of studies that is discarded as a result of site exclusivity.  Additionally, the lack of the gating function (site exclusivity) will result in a large number of mitigations from the unrealistic number of generation projects applying in the cluster.  When generation projects without site exclusivity drop out of the study process, a proportional number of mitigations will also no longer be necessary, resulting in Phase 2 studies that may have vastly different interconnection costs.  PG&E continues to urge the CAISO to move the requirement for site exclusivity to before the Phase 1 study process.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

PG&E is appreciative of the additional language surrounding the impacts of the error or omissions required to be refunded Interconnection Financial Securities and appreciates the CAISO’s collaboration on this enhancement.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

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

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

PG&E looks forward to working with the CAISO on this enhancement, and in the future to revise its WDT to include reciprocal language. PG&E appreciates the CAISO’s collaboration on this enhancement.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

PG&E appreciates the CAISO’s clarification of the existing limits of POI exploration by Interconnection Customers as well as the assertion that PTO and CAISO staff cannot provide technical advice on the design of an IC’s project. PG&E has no additional comments at this time and appreciates the CAISO’s collaboration on this enhancement.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

PG&E does not have any additional comments on the proposal at this time.

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

PG&E has no additional comments at this time but is supportive of this enhancement.

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

PG&E has no additional comments at this time but is supportive of this enhancement.

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

PG&E has no additional comments at this time but is supportive of this enhancement and appreciative of the CAISO’s collaboration through its development.`

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

PG&E has no other comments to add at this time but is supportive of this enhancement.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

PG&E does not have comment on this enhancement.

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

PG&E has no further comments. 

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

Recurrent Energy respectfully requests that CAISO clarify the following outstanding questions not currently specified in the DFP:

• For projects that choose to park for the TPD cycle immediately after Phase II study results posting, whether they are left with one cycle to seek TPD under Group 4 before being required to withdraw.

• If there are any option for FCDS projects to convert to EO before TPD cycle opportunities are exhausted. An example would be if a FCDS project can convert to EO after one cycle of seeking TPD under Group 4.  

• The appropriate TPD group (if not Group 4) for projects that secures a PPA tied to RA that’s less than 5 years or secures a PPA not tied to RA obligation, and the withdrawal requirement that comes with, if any.  
• Withdrawal requirements for any projects that obtains Partial Deliverability and have exhausted opportunities to seek TPD under Group 4.

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

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

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

REV Renewables (REV) overall supports CAISO’s draft final proposal for Phase 1, and appreciates CAISO’s revisions particularly on creating allocation group 4 for TPD allocation and the changes to site exclusivity requirements.

On REV’s proposed issue of the PTO/ISO start planning for all upgrades after NTP, REV is open to this being included in data transparency forum, but would appreciate CAISO considering this item for a Phase 2 topics should our concerns not get addressed through the forum discussion.

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

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

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

REV supports CAISO’s revisions in this draft final proposal and appreciates CAISO’s attention to stakeholder feedback in this important TPD issue. REV supports the creation of the new allocation group 4 and thinks this new group will help active projects achieve commercial operation.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

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

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

REV supports CAISO’s revised proposal for site exclusivity and thanks CAISO for its compromise in allowing cluster 14 projects to have a deposit in lieu of site exclusivity. REV also supports CAISO’s revised proposal for site exclusivity for cluster 15 and beyond.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

REV agrees with the CAISO proposal.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

REV has no comment at this time.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

REV has no comment at this time.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

REV has no comment at this time.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

REV has no comment at this time.

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

REV has no comment at this time.

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

REV has no comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

REV has no comment at this time.

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

REV has no comment at this time.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

REV has no comment at this time.

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

REV does not think item 6.8 in the Revised Straw Proposal (requesting the PTO/ISO should start planning for all upgrades after NTP that are required for a project to attain FCDS) is related to data transparency to be included in that forum discussion, though is willing to start conversations there. REV thinks resolution of this issue may trigger BPM or tariff changes, and therefore if not included in Phase 1 then should at least be included as a Phase 2 topic. If this issue is not addressed it could pose significant financial exposure to projects in operation.

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

RWE appreciates the continued opportunity to participate in the CAISO process and discussion.  As a developer of wind, solar, storage and offshore wind we, along with others, recognize the interconnection process is the defining piece for new generation projects to come online.  All the markets in the US are experiencing these issues and the focus here of finding the improvements needed for CAISO is appreciated.

RWE supports many areas of the proposal, some with minor adjustments.  RWE is also a member of several industry groups including LSA, SEIA and ACPCA.  We support many of comments provided by these entities but offer or emphasize certain ones here.

Some key areas of importance for projects are site control and deliverability assignment and PPA requirements for deliverability.

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

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

Support with LSA's comments

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

RWE generally supports the Site Exclusivity, particularly the compromise for C14 with the option to maintain the deposit in lieu.  In addition the Site Exclusivity requirements starting in C15 are generally acceptable.  However, there must be a provision for projects on public lands that cannot show Site Exclusivity at the start of Phase II.  RWE suggests the following which is pulled from the MISO process and an accepted/approved practice:

If the Interconnection Customer is unable to obtain Site Control on public lands for its proposed Generating Facility as a result of regulatory restrictions, the Interconnection Customer shall provide a cash deposit in lieu of Site Control. In order to demonstrate regulatory restrictions, Interconnection Customer must submit: (i) a signed affidavit indicating that Site Control is unobtainable due to regulatory requirements; (ii) documentation sufficiently describing and explaining the source of and effects of such regulatory restrictions, including a description of any conditions that must be met in order to satisfy the regulatory restrictions and the anticipated time by which the Interconnection Customer expects to satisfy the regulatory restrictions

As a developer of the several types of renewable resources we have experienced a variety of limitations at times, and now with the prospect of offshore in the CAISO market there needs to be opportunities for the projects to proceed while awaiting opportunity/process to obtain the Site Exclusivity.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

RWE opposes this item as all projects need to be provided with the same/equal opportunity to resolve, especially if the difference between two projects is out of their control (ie. schedule for results meetings).

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

• SDG&E commends the CAISO’s efforts in this 2021 IPE stakeholder initiative. SDG&E is thankful for the opportunity to provide its comments on the topics below.

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

• No comments.

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

• No comments.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

• No comments.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

• SDG&E supports this proposal.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

• SDG&E supports the proposal but asks CAISO to reconsider the specificity of the COD reference in the proposed language. There are many more times in which the COD will be adjusted other than the proposed language. In example, MMAs, PTO or IC Delay letters, Technical Reports, and Facilities Reassessment Report. SDG&E proposes two options for language below:
  • A) results in a delay to the schedule by which the Interconnection Customer can achieve Commercial Operation by more than one year, based on the COD in the latest issued report, MMA, IC delay, or PTO delay letter, or the GIA, as applicable.
  • B) “results in a delay to the schedule by which the Interconnection Customer can achieve Commercial Operation by more than one year, based on most recent COD as documented in the final Phase II Interconnection Study Report, Technical Report, Facilities Reassessment Report, the latest annual Reassessment Study Report, MMA, IC or PTO delay, MMA, or the GIA, as applicable;”

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

• No comments.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

• No comments.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

• SDG&E agrees with CAISO’s response to comments that it would not always be feasible to have advance communications with ICs.  SDG&E also agrees with PG&E’s comment that limiting alternative POIs during scoping meeting will improve the IR validation process.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

• SDG&E supports the CAISO proposal’s intent to limit the amount of MMAs and the process specifically for parked projects.  However, SDG&E believes the intent of the proposal is missed by including POI changes as a potential Modification.  For the PTO and CAISO to determine if criteria is met to “improve the costs and benefits (including reliability) of the interconnection” before the starting the MMA process puts undue burden on both entities, and should not be considered an allowable modification for parked projects.
• SDG&E asserts that since CAISO has already established the following, the POI change for parked MMAs should be omitted for the proposed tariff changes:
  • “the CAISO must be able to evaluate the change and find it acceptable without the need to undertake a re-study to meaningfully evaluate it. In general, one of the indications that signals whether a post Phase II modification request is material or not is whether a re-study is necessary. If so, then the requested change is material, and thus not permissible within the scope of the existing Interconnection Request.”  (GIDAP BPM Section 7.3.3.)
    • Any change of POI would require a re-study or at a minimum re-scoping by the PTO to determine the new POI feasibility.
  • “Any change to the Point of Interconnection, except for that specified by the CAISO in an Interconnection Study or otherwise allowed under GIDAP Section 6.7.2 and GIDAP BPM 7, shall constitute a Material Modification. The Interconnection Customer may then withdraw the proposed modification or proceed with a new Interconnection Request to accommodate such modification.”  (GIDAP BPM Section 7.2)
    • This should be applicable for Section 6.7.2. as an allowable modification from Phase I to Phase II.
• Additionally, SDG&E requests that CAISO make tariff revisions to GIDAP Section 6.7.2 to clarify the type of modifications that are allowable between Phase I and Phase II, versus modifications that can be made otherwise.  Since Section 6.7.2 is under Section 6.7 (Phase I Results Meeting) and Section 6 (Activities for Phase I of the Interconnection Study Process), the section for modifications should be clearly defined which apply only to this point in the process.  Every subsequent section and Appendix EE pro forma language refers to Appendix DD Section 6.7.2.
  • GIDAP BPM Section 6.2.5.4 makes this distinction and should be similarly reflected in Appendix DD.

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

•  SDG&E supports this proposal. 

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

•  SDG&E supports this proposal. 

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

• No comments.

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

• SDG&E supports this proposal and commends CAISO’s efforts to apply this for Cluster 14 Phase II.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

• SDG&E supports this proposal and looks forward to further discussion with CAISO and other stakeholders on this proposal.

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

• No comments.

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

SEIA appreciates CAISO’s effort on this proposal and largely supports the proposed Phase I provisions. SEIA offers more detailed comments, proposals, and requests for clarification on proposed enhancements to the TPD allocation process, site exclusivity, the expanded errors and omissions process, the coordination of the PTO WDAT and ISO interconnection processes, MMA submissions for parked projects, and due dates for curing technical data deficiencies. 

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

Support.

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

SEIA appreciates CAISO’s responsiveness to stakeholder comments regarding the importance of maintaining an allocation group for projects that do not currently have a PPA. SEIA supports the proposed revisions to the TPD allocation process, especially the new TPD allocation group 4. SEIA believes the group 4 criteria is fair and adequately balances the commercial interests of developers with the CAISO’s goal of efficiently and effectively allocated transmission deliverability to projects providing resource adequacy. SEIA would also like clarification that a project that fails to receive or retain a Group 4 allocation can convert to energy-only.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

Support with the understanding that this proposal is meant to codify an existing practice.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

SEIA appreciates the new proposal to provide the option for projects in Cluster 14 to proceed to Phase II with a financial deposit. SEIA supports this proposal as it accommodates projects currently in the queue in includes process enhancements that will allow for a more efficient interconnection process moving forward. SEIA proposes that the currently effective withdrawal reimbursement rules be applied to projects in Cluster 14 since these projects applied to interconnect with these expectations. Alternatively, SEIA suggests CAISO consider including safeguards against excessive interconnection cost increases resulting from Cluster 14 project withdrawals like SPP describes in Section 8.14 of its tariff.

SEIA believes the CAISO proposal is consistent with interconnection queue reform changes in other RTO/ISOs like the recently FERC-approved SPP provision that requires evidence of at least 50% of the tie-line mileage needed to interconnect the project or post financial security equal to $80,000 per line mile of right-of-way (SPP tariff Section 8.2(a)(2)). While FERC’s approval of the SPP site control provision does not guarantee approval of the CAISO proposal, it does suggest that FERC could find the CAISO proposal just and reasonable and not unduly discriminatory which, given the immediate need for an enhancement for projects in Cluster 14, is important. 

SEIA also appreciates CAISO’s proposal to broaden the site exclusivity projects siting on public land given the anticipated development of off-shore wind. SEIA notes that processes and timing for acquiring public land differs greatly from projects being built on private land and believes this should be reflected in the interconnection process. Given the overall effort of creating a more efficient interconnection process, SEIA believes CAISO can leverage language from the MISO interconnection process to accommodate projects facing public land acquisition issues without causing undue delays to the queue. More specifically, section 7.2.1.2 of Attachment X to MISO’s tariff allows interconnection customers to demonstrate regulatory restrictions that prevent the interconnection customer from obtaining site control with a signed affidavit and documentation describing the regulatory restriction and the timing and conditions needed to satisfy the regulatory restrictions.

Finally, SEIA would appreciate if CAISO shared draft public land site exclusivity BPM language prior to submitting the proposal to the Board of Governors to ensure the language has enough flexibility to allow public land projects to reasonably progress through the queue. 

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

SEIA supports this proposal overall but has some concerns regarding the substantial error or omission threshold criteria subsection (iii). Subsection (iii) requires the termination of the PPA be documented and signed by an authorized representative of the off-taker or buyer. SEIA is concerned that this requirement could expose interconnection customers to undue financial penalty if an error or omission leads to the termination of its PPA and the buyer or off-taker disagrees with the cause for termination or is unwilling to sign the necessary document. SEIA believes there should be some protection against this like a dispute resolution process or documentation from the PTO describing the error or omission that harmed the project.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

Support.

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

SEIA supports this proposal and appreciates CAISO’s commitment to working with the PTOs to develop more specific criteria. SEIA is particularly interested in improved transparency regarding facilities managed by CAISO or managed by the PTO.

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

Support.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

SEIA supports this proposal but would like confirmation from the CAISO that the proposal to allow parked projects to request fuel and technology type changes would not contradict the FERC Order 845 and Order 845-A definition of “permissible technological advancement” which explicitly precludes changes in generation technology or fuel type.

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

SEIA appreciates implementing a deadline to ensure this data is validated in a timely manner, but has concerns that this deadline could create additional timing issues, particularly for projects that are deficient. For example, as this proposal is written, it seems possible that CAISO could determine a project’s submitted data is deficient on day 70, giving the project 5 business days to cure that deficiency or else be removed from the queue. SEIA believes that this potential issue can be resolved by 1) standardizing communication processes between the CAISO, PTO, and interconnection customer to ensure that deficiencies are communicated and resolved in a timely manner and 2) affording interconnection customers additional opportunities to cure deficiencies when they attempt to correct the deficiency in a timely manner. As an example, SEIA proposes allowing for a second curing period of 5 business days if the project responds to the initial deficiency on time but is still deemed deficient. 

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

Support.

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

Support.

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

Support.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

SEIA supports this proposal. Utilizing RIMS should support communication between the CAISO and developer’s interconnection engineers. 

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

SCE commends the CAISO’s efforts to continue to improve the existing interconnection process and appreciates the opportunity to comment on the 2021 IPE Draft Final Proposal – Phase 1.

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

SCE reiterates its support of the CAISO’s proposal to remove the downsizing window and simplify the downsizing request requirements.  SCE appreciates the CAISO’s clarification that the downsizing requests will be implemented like all other material modification assessments (MMAs), using the existing process.  Also, if a Network Upgrade (NU) is still needed, the downsizing project maintains the cost responsibility.

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

 SCE has no comment. 

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

SCE appreciates the CAISO’s clarifications on the issues raised by SCE regarding certain aspects of the emergency generation interconnection process.

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

SCE supports the combined proposal regarding site exclusivity (SE) requirements and the deposit amounts in lieu of SE for Queue Cluster (QC) 14, and QC15 and beyond.

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

SCE reiterates its disagreement with the CAISO placing the cost responsibility on the PTO for a substantial error or omission after the IFS posting have been made.  However, SCE appreciates the CAISO responding to SCE’s comments by modifying what constitutes a substantial error or omission and developing the proposal for termination of a purchase power agreement (PPA) as a criterion for a refund of the IFS posting.

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

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

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

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

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

SCE reiterates its support of the CAISO’s proposal that the timing of the process for changing point of interconnections (POIs) whether in accordance with GIDAP section 6.7.2.1 or otherwise, remain consistent with current CAISO practice that interconnection customer(s) must confirm its POI within five (5) Business Days of the project’s scoping meeting pursuant to the CAISO’s GIDAP BPM v.28 section 6.2.2 and any change in POI will be limited to within the same transmission study area (e.g., within the same county, one transmission line, or one switchyard from the original) as the POI originally requested in its Interconnection Request.

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

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

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

SCE appreciates the CAISO agreeing that developers must continue to comply with the commercial viability criteria if the 7-year timeframe is breached.

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

SCE has no comment.

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

SCE supports the CAISO’s proposal that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie.

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

SCE supports the CAISO being consistent in using RIMS for all documents, details, etc. related to projects.

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

SCE has no additional comments.

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

See attached document.

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

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

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

Upstream appreciates the opportunity to comment and the effort that the CAISO has undertaken to develop equitable proposals to enhance the interconnection process for all parties.

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

Upstream supports the CAISO proposal.

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

Upstream appreciates the CAISO modifying its position and creating an Allocation Group 4 that will provide ICs with a bridge between obtaining deliverability and executing an off-take agreement.  This provides more certainty to the IC and load-serving entities that the project will achieve COD.  The CAISO notes in the Draft Final Proposal…  

“If after two allocation cycles an allocation group 4 project has either never received an allocation or has received an allocation, but has not been able to retain it, the project will be required to withdraw.” 

Upstream understands that CAISO is trying to disincentive developers from selecting Allocation Group 4, but forcing projects to withdraw from the queue is overly punitive and these projects should be converted to energy only.  Our concern is that the forcing projects to withdraw after the second allocation will incentivize developers to file new queue positions every other queue cluster for the same exact same project which will lead to a significant number of duplicate queue positions and future superclusters.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

Upstream supports the CAISO proposal with the clarification that the emergency process only be allowed if specifically designated by a state agency.   

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

Upstream does not support allowing QC14 IRs to continue into the Phase 2 Study without obtaining site exclusivity.  In lieu of securing a site and making option payments to a landowner, ICs will use CAISO, the PTOs, and the study process as a $250,000 “option.”  

Even making the $250,000 non-refundable will do nothing to limit the number of speculative projects in the queue because the $250,000 non-refundable deposit is cheaper than making option payments to a landowner – especially in areas like LA Basin where ICs used a “shotgun approach” in the hope that a project site becomes available adjacent or near one of their POIs.  

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

Upstream supports the CAISO proposal.   

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above:

1. Please provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) draft final proposal for Phase 1: Near-Term Enhancements:

WPTF appreciates the opportunity to submit comments on the CAISO’s Interconnection Process Enhancements 2021 draft final proposal. WPTF supports the addition of Transmission Plan Deliverability Allocation Group 4 in the CAISO’s draft final proposal.

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

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

 WPTF supports the addition of Transmission Plan Deliverability Allocation Group 4 in the CAISO’s draft final proposal. The addition of Allocation Group 4 provides information to developers and Load Serving Entities (LSEs) that is critical to the Resource Adequacy (RA) solicitation process and views the current proposal as supportive of a stable environment for interconnection and investment.

WPTF requests that CAISO confirm in its final proposal the minimum amount of TPD MW that can be allocated in the TPD allocation process. Given that projects that receive an allocation face serious consequences – to accept the allocation or withdraw entirely – there should be a TPD MW allocation floor to ensure that the minimum among of allocatable TPD is an amount that could reasonably be developed. WPTF suggests that the ideal way to identify this TPD MW floor is to survey its stakeholders and transmission planning engineers to make this determination. WPTF believes that a viable TPD MW amount should not be less than 15 MW, at least, consistent with the stakeholder discussion on the March 24 web conference.

4. Provide your organization’s comments on the ISO’s proposal for developing an emergency generation interconnection process, as described in section 3.3:

5. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.1:

6. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.1:

7. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.2:

8. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.3:

9. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.4:

10. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.5:

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

12. Provide your organization’s comments on the ISO’s proposal for modifications to commercial viability criteria, as described in section 6.2:

13. Provide your organization’s comments on the ISO’s proposal for expanding deliverability transfer opportunities, as described in section 6.3:

14. Provide your organization’s comments on the ISO’s proposal for recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

15. Provide your organization’s comments on the ISO’s proposal for recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.5:

16. Please provide additional comments on the IPE Final Proposal – Phase 1 not mentioned above: