ACP-California
Submitted 01/22/2026, 10:10 am
Submitted on behalf of
ACP-California
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
ACP-California supports the proposed change to remove the requirement that non-LSEs attest that the resource allocated commercial interest would support their sustainability goals. As CAISO noted, there are a variety of reasons a non-LSE may seek to contract with a resource.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
N/A
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
N/A
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
ACP-California appreciates CAISO’s efforts through IPE 5.0 to make targeted refinements to the interconnection process and, in particular, appreciates CAISO’s responsiveness to stakeholder requests to create a pathway, albeit a narrow one, for operational Energy Only projects to obtain Transmission Plan Deliverability (TPD) allocations. Allowing all operational EO resources to seek deliverability recognizes the important role these resources can play in meeting reliability and Resource Adequacy (RA) needs and represents a meaningful step forward relative to prior policy.
CAISO has continued to propose a high bar for operational projects seeking a TPD allocation, with the Final Proposal requiring those projects to have an executed contract with an LSE for the project’s RA capacity at a duration of five years or longer. While it would be reasonable to have a lower bar for these operational projects to seek a TPD allocation, ACP-California appreciates that CAISO will waive this requirement for the 2027 TPD allocation cycle. We hope that the experience in the 2027 TPD allocation cycle might offer some other, reasonable alternatives to a fully executed PPA that CAISO could consider for allowing the 2028 TPD allocation cycle (and beyond) through a future IPE initiative.
ACP-California greatly appreciates CAISO’s willingness to work with stakeholders on a solution for operational Energy Only projects to seek a TPD allocation and believes this policy pathway may provide notable benefit in the future. At the same time, ACP-California is strongly concerned with CAISO’s position that, pursuant to the IPE 2023 Track 3, all projects in Commercial Operation will be allocated TPD behind the PPA group, regardless of whether the operational project already has a PPA or is otherwise well positioned to support near-term RA needs. CAISO has indicated that this treatment was approved by the Board in IPE 2023 and therefore is not subject to reconsideration in IPE 5.0. However, ACP-California does not believe this outcome was well understood by stakeholders during the IPE 2023 process. Given the associated tariff provisions have not yet been filed with FERC, we believe CAISO should consider additional modifications to this policy following further stakeholder discussion before initiating the FERC approval process. We believe there is no reasonable justification for allocating TPD to commercial operation projects after projects that are in development when both project types have PPAs. This could be determined to be discriminatory. Additionally, from a policy perspective, ACP-California is concerned that allocating TPD in this order -- to queued in-development projects with PPAs before commercially operational projects with PPAs -- may unnecessarily constrain deliverability access for resources that are available to serve load and contribute to LSE RA needs earlier. This approach risks limiting near-term RA availability and could create artificial scarcity by prioritizing projects that are still under development over resources that are already built, interconnected, and capable of providing reliability benefits today. ACP-California urges CAISO to reconsider this allocation framework to better align TPD outcomes with system reliability needs and the realities of procurement and resource availability. Given that this policy has not yet undergone FERC review, ACP-California strongly encourages CAISO to treat the allocation priority for operational EO projects as open for additional stakeholder consideration and to modify it to permit operational Energy Only projects with an eligible PPA to be included in the PPA group.
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
ACP-California appreciates the modifications CAISO has made to this portion of the proposal, to help provide some additional flexibility and accommodation for viable projects. In particular, we appreciate that CAISO – in response to ACP-California and other stakeholder concerns – has removed the three-year commercial operation date extension limit. This is critical to ensuring that projects that are making progress but run into challenges can continue to move towards commercial operation and aren’t unnecessarily removed from the queue. ACP-California also appreciates CAISO clarification that reforms to COD extension will only apply when requested by the interconnection customer and will not apply where PTO construction delays require longer timelines. CAISO may further consider clarifying that CVC requirements apply at the submittal of modification request and that CVC requirements be applied prospectively following FERC approval. We look forward to continuing to work with CAISO to ensure the existing queue is properly managed in a way that does not allow projects to stagnate but also does not remove projects that are viable.
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
N/A
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
N/A
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
N/A
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
N/A
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
N/A
California Community Choice Association
Submitted 01/21/2026, 12:58 pm
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
CalCCA has no comments at this time.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
CalCCA has no comments at this time.
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
CalCCA has no comments at this time.
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
The California Community Choice Association (CalCCA) appreciates the California Independent System Operator (CAISO) proposing a pathway for energy-only (EO) resources to obtain deliverability. For the reasons described in CalCCA’s August 25, 2025, comments in this initiative, including the need for development of new resources for reliability and clean energy objectives coupled with challenging market realities, a pathway for EO resources to obtain transmission plan deliverability (TPD) is crucial to ensure the viability and cost-effectiveness of new resources to meet capacity needs.[1]
However, CalCCA is concerned that the CAISO’s proposal will severely limit the ability for projects to use this pathway. This is because the CAISO’s proposal would leverage the commercial operations group, meaning EO projects seeking TPD through the commercial operations group would be allocated TPD only if there is existing deliverability to be allocated. Where there is not existing deliverability to be allocated, these EO resources would not be able to finance upgrades to increase deliverability, like projects seeking TPD from the outset can. This may significantly limit the usefulness of the CAISO’s proposal, as there is currently very limited existing TPD available for allocation without upgrades. CalCCA continues to advocate for revision of the current proposal as set forth in its November 3, 2025, comments,[2] allowing a limited amount of EO projects to finance upgrades if there is not existing TPD to allocate to them and the projects have RA contracts with LSEs. If the CAISO adopts its current proposal now it should also commit to continued exploration in a future interconnection process enhancements (IPE) initiative of future pathways for EO projects behind constraints to seek deliverability, particularly where projects have made commitments with LSEs or where projects are aligned with local regulatory authority policy needs.
During the stakeholder call, many stakeholders expressed concern with the CAISO’s proposed five-year RA contract requirement for projects to use this pathway. CalCCA does not take a position on this requirement under the context of the CAISO’s proposal, in which upgrades would not be triggered as a result of these projects seeking deliverability through the commercial allocation group.[3] If the CAISO retains this requirement, it should clarify that LSE-owned resources (e.g., utility-owned or joint-powers-owned projects) are eligible for the EO TPD pathway, as the current framing appears to require power purchase agreements rather than ownership structures
[1] CalCCA Comments on IPE 5.0 Straw Proposal (Aug. 25, 2025), https://stakeholdercenter.caiso.com/Comments/AllComments/9b0551da-cdeb-4413-8629-3801bb56231e#org-a1da5f2a-7e9a-4e52-a586-dc0d205462fa.
[2] CalCCA Comments on IPE 5.0 Straw Proposal (Nov. 3, 2025), https://stakeholdercenter.caiso.com/Comments/AllComments/544a61c0-5dc4-4bb8-9c2c-6bda69b8edb8#org-fc9c1544-097f-4c99-8546-1dbb144be18c.
[3] If the CAISO’s proposed pathway was modified to enable EO projects behind constraints to seek deliverability, the CAISO’s proposed 5-year requirement could make sense to ensure that investments in upgrades resulting from EO to deliverability conversions are focused on projects that are commercially viable and intend to provide reliability benefits to California through the RA program subject to a deliverability allocation.
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
CalCCA has no comments at this time.
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
CalCCA has no comments at this time.
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
CalCCA has no comments at this time.
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
CalCCA has no comments at this time.
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
CalCCA has no comments at this time.
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
Now that the interconnection queue intake process adopted in IPE 2023 has been implemented, the CAISO should reflect on the significant attrition following Cluster 15 Phase I, which exceeded 10 GW. While the IPE 2023 reforms appear to have successfully addressed speculative queue entry, the pendulum may have swung too far, risking an insufficient pipeline of resources to meet California’s policy targets. Understanding the root causes of this attrition should inform future reforms necessary to ensure enough new capacity can interconnect to support California’s ambitious policy goals.
California Wind Energy Association
Submitted 01/21/2026, 10:59 pm
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
No comment.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
No comment.
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
No comment.
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
CAISO should allow operational projects to obtain TPD capacity without a PPA
CalWEA continues to support CAISO’s proposal to allow Energy Only projects in Cluster 15 and later that have completed the interconnection process and are in commercial operation to seek deliverability (TPD) capacity. However, CAISO should allow operational projects to obtain TPD capacity without a PPA. At a minimum, as discussed below, operational projects with PPAs should receive highest priority for receiving TPD capacity.
In the Final Proposal, and reiterated on the stakeholder call, CAISO stated that the purpose of the PPA requirement is not to demonstrate commercial viability (even though, when competing for TPD capacity, projects score points for “commercial viability” by having a PPA). Rather, the purpose is to “demonstrate that an LSE actually finds value in the project’s ability to meet a specific resource adequacy need,” and therefore a PPA for that RA capacity is necessary. However, projects inherently carry their RA value even if they are not under contract to an LSE, because the capacity will immediately be available to CAISO to meet its system RA needs. Recognizing this capacity benefits ratepayers by reducing the need for RA supply. These benefits warrant awarding EO projects with TPD capacity regardless of PPA status.
CAISO also indicated that EO projects should not “siphon off” available TPD for projects that have been in the queue. CAISO should consider that, while other projects have waited in the queue, highly viable projects have proceeded to secure financing and been constructed. Those projects provide system capacity that is going unrecognized; withholding recognition is unfair to developers who have taken substantial risks to bring their projects online.
Further, a representative from a load-serving entity (LSE) on the stakeholder call indicated that it is difficult to specifically address future RA capacity in a PPA, as the timeframe for its availability is unknown. There is no way for the LSE to know when TPD could be freed up for an EO project. Despite this difficulty, which may prevent EO projects from obtaining TPD capacity, CAISO responded that a specific PPA is necessary to avoid gaming. There is nothing to game (no unused FCDS to hoard), however, since the project has been built and deserves to have its RA capacity recognized.
Operating EO projects without PPAs should be treated similarly to queued projects
At a minimum, operating EO projects without PPAs should receive priority for receiving TPD capacity under the same terms that a queued project receives TPD capacity, i.e., contingent on obtaining a PPA within one year, however, operating projects should receive highest priority given their operational status.
Prioritization is appropriately addressed in IPE-5
CAISO stated on the call that TPD prioritization was addressed in IPE 2023 and therefore is not being addressed in IPE-5. However, prioritization for operating EO projects was not discussed in IPE 2023 because such projects were eliminated from consideration entirely. Here, CAISO proposes to enable operating EO projects to obtain deliverability, and therefore, it is entirely appropriate to consider all related issues, including prioritization and transferability.
CAISO should also amend the tariff to provide that an operating EO project may accept TPD capacity from a queued project at the same POI, subject to all conditions that made the transferring project deliverable. While the tariff doesn’t apply where both projects are operational, CAISO needs to address the situation in which the transferring project is in the queue because the tariff (Appendix KK) disallows deliverability transfers to EO projects.)
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
Generally, CalWEA supports CAISO’s clarification that CVC does not apply to WDAT projects, while TPD retention does. (WDAT projects will need to provide PPA status to keep the TPD allocation but will not have to go through CVC when they extend COD or make other changes.)
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
No comment.
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
No comment.
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
No comment.
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
No comment.
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
No comment.
Clearway Energy Group
Submitted 01/21/2026, 04:40 pm
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
None.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
None.
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
None.
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
Clearway continues to support CAISO’s proposal to enable operational EO projects to seek TPD through the Commercial Operation allocation group. However, we continue to be concerned with the inclusion of a PPA requirement. The application of the PPA requirement retroactively to C14 and prior clusters is inappropriate. Delaying the application of the requirement on C14 and prior clusters until 2028 does not address the retroactive application. An EO project reaching COD demonstrates that it has achieved economic and commercial viability. LSEs have a clear need for system RA resources; an EO resource that is operational carries no development risk. Enabling operational EO resources to seek a TPD allocation will carry value to an LSE that is different from other development projects. Additionally, requiring EO projects to show PPAs will create an additional administrative burden on LSEs, who would now need to negotiate PPAs with these projects without any certainty that the project will receive a TPD allocation.
In our previous comments, Clearway included a suggestion that would make the PPA showing requirement more palatable. It does not appear that the CAISO addressed our suggestion to expand the types of PPAs that could be shown to include non-LSE PPAs. CAISO should expand the types of PPAs that would be accepted to demonstrate that an EO resource is needed for resource adequacy. This change would make the PPA showing requirement more efficient and equitable, while still preserving the stated goal of demonstrating the value of an EO resource for its RA potential.
Additionally, Clearway remains concerned about the change to TPD allocation transfers. While CAISO’s latest change enables group D allocations to transfer TPD, the final proposal imposes a new prohibition of TPD transfers in the Conditional Allocation group. Instead of an outright prohibition on the Conditional Allocation group, CAISO should follow a similar approach to the TPD allocation transfer requirements on group D allocations. Under group D, for TPD allocations to be transferred, the project receiving the allocation must not have a COD later than the transferring project. Additionally, CAISO could require mandatory PPA showing to match CODs. These restrictions would alleviate the concern that the Conditional Allocation group is being used as a vehicle to acquire TPD and transfer it to other projects. This approach would impose strict requirements on the ability of the Conditional Allocation group but would not prohibit them from transferring TPD.
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
Clearway is supportive of and appreciates CAISO’s decision to remove the proposal to create a three-year limit on a project’s COD request extensions. This restriction would have been unduly restrictive on developing projects that face significant challenges and need flexibility to be completed.
Clearway continues to support the application of Commercial Viability Criteria to EO resources. However, the application of the CVC to EO resources should mirror their application to other queued projects. EO projects should be allowed to utilize the existing CVC exception that the PPA is due at the later of one year after the COD extension request or 8 years in queue. While CAISO is concerned that the exception will be used to cause intentional delays, it ignores the difficulty projects face as they move through the development process. If projects are limited to only a one-year waiver, once per queue position, it will significantly impede a project's ability to respond to delays that are outside their control, like permitting delays or a network upgrade delay on an affected system.
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
None.
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
None.
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
Clearway has some concerns about discontinuing the pre-application process. While the data received through pre-application reports may rapidly become stale, it still provided developers with information they could not readily access elsewhere. While much of the data has been made available, there remains some information that CAISO has not made available. The Pre-Application Process required PTOs to provide all the information the PTO had on hand. PTOs should have substation access and physical interconnection feasibility data (for example, the availability of breaker position) on hand. However, this information was not provided by CAISO as part of the data made available for C15 entry. For companies making significant investments to secure site control, information about which breaker positions are available or expandable is of tantamount importance at queue entry.
Clearway recommends that CAISO consolidate and make Network Upgrade data searchable, reinstating and committing to providing data on substation access and physical interconnection feasibility. As CAISO works to finalize the removal of the preapplication process, it is imperative that CAISO, with support of the PTOs, enhances the availability of substation access data. While this data may require some upfront work from CAISO, it would be extremely valuable to understand which substations have open bays for interconnection and which do not. Subsequent updates could delve deeper into substation data, such as which substations could be expanded within the current footprints, or which substations have potential land nearby to expand.
Without access to this information, Clearway would be opposed to discontinuing the Pre-Application?Process.
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
None.
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
Clearway previously commented on the need for changes to GIA execution under C15. While these comments were not addressed in the final proposal, Clearway reiterates the need for CAISO intervention either in IPE 5.0, the subsequent IPE initiative, or through engagement with PTOs on GIA posting requirements at execution.
Clearway respectfully recommends that CAISO allow projects in Cluster 15 to execute GIAs after completion of the first TPD allocation cycle. The concerns that deferring that GIA execution until after TPD allocation could delay progress on shared NU is flawed. Based on the latest C15 schedule, TPD affidavits are due in March 2027 and LGIA execution is expected in April 2027. TPD allocation results should be available by August 2027. Extending the LGIA execution milestone to September 2027 would have a minimal schedule impact (six months or less) on any project that is ready to fund shared NUs. This should address CAISO’s concern about unreasonably delaying any ready projects that want to proceed with construction of upgrades. If a PTO demonstrates that it is ready to proceed with a shared NU, developers could execute E&P agreements to allow that work to proceed on time. CAISO has already required existing C14 'parked' projects to secure shared NU via E&P agreements, demonstrating the effectiveness of this mechanism without impacting other IC timelines reliant on a shared NU.
Clearway’s principal concern regarding the current LGIA execution deadline relates to the linkage between LGIA execution and posting requirements for NU costs. Cluster 15 study results are now being released, and the study reports for some TPD zones are showing significant upgrade costs: Upgrades for one TPD zone were estimated at approximately $100 million. Clearway does not take issue with the initial posting due this year, which is only 5% of the total network upgrade cost. However, looking ahead, the current schedule will force these projects to post security for 100% of the network upgrade costs, fully at-risk, before their first TPD allocation cycle is complete. While the posting requirement upon LGIA execution is only 20% of NU costs under CAISO’s tariff, PTOs have a practice of requiring 100% posting within 120 days of LGIA execution, fully at-risk. There is potential for this to be addressed outside of the CAISO tariff, but it would necessitate CAISO discussions with PTOs to ensure that projects are not required to make 100% security postings prior to receiving information about TPD allocations, which could cause tens of millions of dollars to become stranded assets on withdrawal.
Since queue entry in C15 was based on 150% of available TPD, interconnection customers understand that not all projects entering the first TPD cycle will receive an allocation, even with high commercial readiness. The consequences of the TPD allocation have become more significant given that projects failing to obtain TPD will be required to withdraw from the cluster. Requiring tens of millions of dollars in fully at-risk security postings before interconnection customers have any visibility into their likelihood of receiving deliverability is neither reasonable nor aligned with the principles of fair and nondiscriminatory access. It is critical that this timing issue be addressed in advance of posting requirements increasing beyond the current 5% threshold next year.
LSA
Submitted 01/21/2026, 05:12 pm
Submitted on behalf of
Large-scale Solar Association
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
LSA suggested earlier that the attestation concerning compliance with corporate sustainability goals be removed from the non-LSE CI points affidavit, and we support that proposal here.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
LSA appreciates the CAISO’s illustrative table showing the application of the proposed new methodology. While LSA is concerned that the information on which the proposal is based is not public – preventing wider verification of the accuracy of the points allocation – we are generally supportive of the change, especially in light of the purported support of small LSEs.
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
LSA supports the CAISO’s proposal for distribution-level projects to participate in the cluster-study process, including the competitive intake process, on the same basis as transmission-level projects. LSA also supports the proposal for eligibility determination based on distribution-level tariffs.
However, LSA still believes that the CAISO should clarify in the final Proposal version that distribution-level projects can qualify for post-COD Commercial Operation Group TPD Allocations. If they must follow the same rules as transmission-level projects, they should have the ability to participate in this part of the process also. LSA requested this important clarification in its last comments and repeats that request here.
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
LSA has supported an opportunity for Cluster 15 and later Energy Only projects to seek a post-COD TPD Allocation and appreciates the CAISO adopting this approach. However, LSA has two specific concerns about the proposal as stated:
(1) The PPA requirement for Commercial Operation Group TPD Allocation requests should be eliminated, especially for C14 and earlier projects; and
(2) CAISO should clarify that TPD can be transferred to C15 and later Energy Only projects after Commercial Operation, given its policy change to allow such projects to request new TPD Allocations, since it makes sense to have the same rules for both.
Both of these concerns are described in more detail below.
PPA requirement for Commercial Operation TPD Allocation requests
LSA has three significant concerns with the requirement for an executed LSE PPA to submit a Commercial Operation Group TPD Allocation request.
- Executed PPA requirement generally: There are at least three reasons why this requirement should be removed.
- Harm to the market: As LSA noted in the January 7th call, and stated in its earlier comments, there is a serious need for more flexibility in RA trading, and it is counterproductive to require all RA to be tied up under 5-year contracts. While the CAISO stated that its policy change allowing operational C15+ projects to seek TPD Allocations was driven by consideration of LSE portfolio needs, this flexibility need is driven strongly by resource needs, caused largely by CAISO rules.
Resources already in operation with available RA that is not already tied up under 5+-year agreements could provide some of this needed short-term/flexible RA, specifically:
- RA substitution for Planned Maintenance Outages: Resource owners (not LSEs) must secure short-term RA capacity to gain CAISO approval for PMOs. The initiative leading to CAISO adoption of this requirement was supposed to have a second phase, where the CAISO would consider establishment of an “outage pool” to either assist resource owners in security substitute capacity, or that the CAISO itself could draw on for that purpose. That second phase was never initiated.
In other words, the CAISO established this significant obligation but never took the next step to help resources comply more easily.
- RAAIM substitution: Similarly, resources seeking protection against RAAIM penalties must search out substitute RA capacity on their own, and these uncontracted resources could provide such services.
- RA shortfall protection: Most PPAs allow Sellers to provide substitute RA when their projects have difficulties (short- or long-term) meeting the committed level of RA, including when their deliverability-related upgrades are not completed on time and Interim Deliverability is not available, or less is available than needed. Shorter-term RA attributes can allow them to bridge that gap.
In sum, the CAISO should consider the needs of suppliers here, as well as LSEs.
- LSE interest: The CAISO said at the stakeholder meeting that it wanted the scarce RA directed to projects with “LSE interest.” That may make sense for PPAs needed to demonstrate project viability (since projects provide a mix of attributes that may meet various LSE needs), but the CAISO said that is not the purpose of these PPAs.
With respect to RA, CAISO success at creating the RA “Standard Capacity Product” has established a tradeable RA attribute that can be provided by any project with deliverability. In fact, as noted above, most PPAs allow suppliers to provide substitute from other projects to meet their RA obligations under those contracts, since RA from one project can meet an LSE’s needs as well as RA from another. (The same is true of Local RA, as long as the substitute resource is in the same Local Capacity Area.)
- Inconsistency with other RA provisions: For projects with PPAs with non-LSEs seeking TPD allocations (starting with awards in the 2023-2024 TPD Allocation cycle), a deposit is required for the highest-priority allocation group, refundable at the earlier of project COD or demonstration of at least a 1-year LSE RA contract.
Similarly, projects subject to Commercial Viability Criteria have annual PPA demonstrations only through COD.
In other words, the obligation to show an LSE contract terminates at COD. This is consistent with statements from Amazon Energy (a non-LSE) in that earlier IPE initiative that, having rights to a valuable RA attribute, of course they would offer it in the market. This is true for any project reaching COD. The higher the market need, the higher the market price, and the stronger the incentive to offer the product.
- Unnecessary term length: The 5-year minimum term requirement was originally introduced to ensure that PPAs were legitimate bases for project financing and other viability proof. Projects that have reached COD have already demonstrated their viability, as noted above, and there is nothing wrong with such projects deciding to sell their RA on a short-term or seasonal basis.
- Executed PPA requirement for Cluster 14 and earlier projects: The Proposal says that “consistency” is the reason for imposing this requirement on these projects, i.e., it proposes to require a PPA for Cluster 14 and earlier projects because it is requiring a PPA for Cluster 15 and later-queued projects. In addition, the Proposal says that, since CAISO has not yet filed the 2023 IPE Track 3 TPD Allocation changes, it feels free to modify them in this initiative and the change is not really “retroactive.” LSA has two responses to these statements.
First, “consistency” is not sufficient justification for imposing a new restriction on exercise of this already greatly limited opportunity. The CAISO retained the Commercial Group for these projects in order to minimize retroactive rule changes. These projects have already lost the right to unlimited pre-COD TPD Allocation requests, and it is not onerous to track the queue positions of these projects and exempt them from these additional one-time TPD Allocation requirements.
Second, the 2023 IPE T3 rules were thoroughly vetted and discussed in that extensive stakeholder process, while this latest restriction was first proposed here in the Draft Final Proposal. The CAISO chose not to file these proposals before, even though they were “decided” a long time ago, and it is unfair to subject projects proceeding all this time since then based on the earlier CAISO decisions to what really is another retroactive change.
TPD transfers for C15+ projects reaching Commercial Operation
LSA thanks the CAISO for considering stakeholder input and allowing C15+ projects to request new TPD Allocations under the Commercial Operation Group. The Final Proposal further clarifies that these allocations can be transferred to other projects that have also reached Commercial Operation.
However, the Proposal does not mention TPD Allocation transfers to C15+ projects reaching Commercial Operation. There is no apparent reason that C15+ projects reaching Commercial Operation should be able to request brand new TPD Allocations but should be unable to accept TPD transfers from other projects, subject to the same restrictions applicable to TPD transfers generally. Unless the CAISO has some rationale for distinguishing between new and transferred allocations for this purpose, C15+ projects should qualify for both.
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
LSA thanks the CAISO for considering stakeholder input and withdrawing its earlier proposal to impose a 3-year COD extension limit.
LSA has supported CVC applicability to EO projects and supports this proposal generally. However, we have two serious concerns with the latest description of the proposal, and “clarifications” or changes at the stakeholder meeting. Those concerns relate to:
- The proposed restriction of the PPA time extension under the CVC to a one-time exercise, including application of this new restriction to FCDS/PCDS projects; and
- The proposed withdrawal from the queue of FCDS/PCDS projects seeking COD extensions that do not meet the CVC.
These concerns are explained further below. LSA believes that the CAISO should withdraw the one-time restriction for the PPA extension (at least for projects with deliverability) and modify the proposed withdrawal of projects with deliverability that fail to meet the CVC.
PPA extension limitation: This issue concerns the current ability of projects seeking COD extensions beyond 7 years in queue to delay provision of an executed PPA supporting the new COD until the later of 1 year after the request submittal or 8 years in queue.
LSA has both process and substance concerns here.
With respect to the substance, there was a legitimate reason for this allowance. In practice, it is difficult to secure a PPA supporting the later requested COD only documentation showing an infeasible COD. In other words, most off-takers want to see a feasible COD before taking the time and energy to negotiate and execute a PPA.
This is true the first time a project might need to meet CVC, but it is no less true if the project must request an additional COD extension under the CVC. LSA understands that the CAISO does not want to keep non-viable projects in the queue, and we don’t either. However, unfortunately, even a viable project might need more than one extension.
For example, projects receiving a widely circulated letter from the federal Bureau of Land Management will likely suffer delays in their permitting activities, and they will simply have to guess at the extent of those delays. If they guess wrong, they may will have to submit additional request for milestone extensions.
The difference here is only a few months anyway. A project requesting a second extension subject to CVC is likely already past 8 years in queue, so it will only have a short time after to acquire the executed PPA, and continuing this reasonable practice makes sense.
With respect to the process, LSA strenuously objects to the CAISO’s “clarification” in the Final Proposal that this restriction on the PPA time extension would revise the CVC applicable to FCDS/PCDS projects. There was no indication in any of the prior proposal versions that the CAISO intended to modify the CVC applicable to FCDS/PCDS projects, and no justification for this change to those CVC.
Queue withdrawal for FCDS/PCDS projects: Currently, FCDS/PCDS projects that request COD extensions but fail CVC are simply converted to Energy Only. The CAISO said at the stakeholder meeting that, instead of conversion to EO, these projects would be withdrawn.
Again, LSA has both process and substance concerns about this proposal.
With respect to the substance, there is some merit to CAISO’s argument at the meeting that if an FCDS/PCDS project is converted to EO, it would also fail the new EO CVC and be withdrawn from the queue anyway. However, consistent with the treatment of FCDS/PCDS projects that transfer their TPD to other projects, it would make sense to give these projects the opportunity to produce an EO PPA at that time to avoid withdrawal from the queue.
With respect to the process, again LSA objects to the last-minute inclusion of this proposal, not even in the written Final Proposal, but through a “clarification” at the stakeholder meeting. Again, there was no indication that the CAISO was contemplating changes to FCDS/PCDS CVC provisions; LSA would have made the above suggestion earlier had we known the CAISO was proposing this change, and we hope the CAISO will give it serious consideration for the final version.
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
LSA supports the CAISO’s revision sequencing projects subject to this process after any clusters then under study. LSA further recommends, consistent with the stakeholder meeting discussion, that the CAISO clarify that this means that the Affected System studies can commence once the Cluster Studies for the cluster under study is complete, i.e., they do not have to wait until after the Facility Studies are complete.
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
LSA supports this sensible proposal.
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
LSA continues to believe that the CAISO should facilitate publication of additional information on limitations connecting to different substations. As we have said before, this information is critical for projects to secure the high level of Site Control needed under the new interconnection process. We are happy to see some recent progress in this area with respect to PG&E.
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
LSA supports this proposal generally but still believes that a direct report to an absent named Vice President, not involved in the original dispute, should be an option.
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
Pacific Gas & Electric
Submitted 01/21/2026, 03:55 pm
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
PG&E has some concerns about the 500 MW cap for project size. PG&E previously appreciated that this proposal was intended to aid small LSEs in giving points for projects greater than their load share of points would allow. PG&E did not appreciate the limit on points given to a single project and appreciates the CAISO’s inclusion of the table, which illuminates this point. Many CCGTs, nuclear facilities, and pumped hydro facilities are larger than 500 MW. While these facilities were not in Cluster 15, it does not make sense to inhibit a large LSE’s ability to use their points on a preferred, larger project, if one were to arise in the future. PG&E would appreciate if the CAISO would reconsider the use of this cap.
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
PG&E supports the CAISO’s desire to align giving TPD to Energy Only projects that have a long term commitment with an LSE. PG&E cautions against requiring too much specificity in how long the Resource Adequacy has to be procured in the contract term, since it may be that a possible RA delivery period is shorter than the underlying contract. For example, if PG&E has an off-take agreement for an EO solar project for 5 years that applies for TPD after it becomes operational, then the RA offtake period will be less than 5 years. PG&E also supports making the language explicit that LSE-owned generation does not need to show a contract.
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
PG&E supports the proposal and requests CAISO confirm that there will be no delay penalties mandated by FERC Order 2023 due to affected system study delays caused by ongoing studies in the same study area.
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
During the January 7 stakeholder meeting, several questions were raised with regard to how the cluster scoring process would apply to distribution interconnection project applications that fall under a PTO’s Wholesale Distribution Access Tariff (WDAT). PG&E, like the other PTOs, maintains its own WDAT interconnection study process, which in general conforms to the parameters and timelines of the CAISO process and allows CAISO to study both sets of projects within its cluster deliverability studies. As CAISO evolves the rules as proposed in the IPE final proposal, modifications may need to be made in certain elements of the PTO WDATs, for example, to align study timelines and avoid unnecessary delays. PG&E looks forward to further conversation with CAISO to understand what WDAT changes are envisioned and how best to implement them.
Rev Renewables
Submitted 01/21/2026, 02:31 pm
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
REV Renewables (REV) supports this proposal.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
REV supports this proposal.
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
REV supports this proposal.
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
REV supports this proposal, and the limitation to allow only operational EO projects to be eligible for this deliverability allocation. It is important to not allow a bypass around the 150% study limit in the new interconnection intake process. However, if an EO project becomes operational, it has proven commercial viability and should be allowed to compete for deliverability.
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
REV appreciates CAISO’s decision to eliminate the three-year COD extension limit in the latest proposal. However, REV was surprised to find a new restriction that limits the one-year exception to a single instance per interconnection request. This is a significant change, and REV does not support including it at this late stage of the final proposal.
REV is unclear why this flexibility should be restricted to a single instance rather than tied to existing demonstrated commercial viability criteria, as currently exists in CAISO’s tariff. To address this, CAISO should provide concrete examples or scenarios that illustrate how and when this one-time limit is intended to apply. This substantial departure from current rules warrants further scrutiny before inclusion in the final proposal. REV believes this element requires broader stakeholder discussion and suggest that CAISO address it in a subsequent IPE effort, providing clear examples to ensure all stakeholders understand and are on the same page.
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
REV supports this proposal.
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
REV supports this proposal.
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
REV supports this proposal.
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
REV supports this proposal.
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
San Diego Gas & Electric
Submitted 01/21/2026, 04:03 pm
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
Overall, SDG&E is confident that these measures will support CAISO’s goal of streamlining the queue. Although the proposal is favorable, SDG&E requests clarification from CAISO regarding the handling of projects that have stalled in the queue, particularly those that have exceeded their CODs. For these projects, there would not be a provision to mandate an extension of the COD, and consequently, no process to initiate the CVC demonstration requirements outlined in the proposal.
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
Southern California Edison
Submitted 01/21/2026, 04:04 pm
1.
Please provide your organization’s comments on Section 2.1 Non-LSE commercial interest process.
No comment.
2.
Please provide your organization’s comments on Section 2.2. Cap on the full allocation election.
SCE does not object to utilizing LSE forecasted load share as a determinant of project size for the full allocation election. Whether based on LSE forecasted load share or the current methodology of TPD allocation amount, it makes sense the factor should be based on LSE size. However, restricting to either the lesser of this outcome or 500 MW is not substantiated and seems arbitrary.
SCE understands that the full allocation election capability is a specific function that not all LSEs may choose to use. However, LSE’s procurement targets are almost always proportional to some function of load size, as such it would seem appropriate that the ability to procure or attract projects to meet those requirements should also be proportional without any other restrictions.
3.
Please provide your organization’s comments on Section 2.3. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes.
SCE appreciates the CAISO providing additional information on how the coordinated process between the CAISO and PTOs with WDATs will work. Below, SCE is resurfacing issues previously raised by SCE, seeking further clarification or explanation from the CAISO.
- In response to SCE asking for an explanation regarding why distribution-level projects are not eligible to participate in the merchant process, CAISO stated: “In response, the similar Option (B) process in the GIDAP approved by FERC in 2013, distributed projects were not eligible to select Option (B), and the ISO proposes to continue with that policy.” However, SCE’s WDAT does permit Interconnection Customers to select the Option B process. Given this fact, SCE requests the CAISO explain why distributed projects are not eligible for the merchant process.
- CAISO has indicated the eligibility of a distributed project to be studied in a cluster study for FCDS will be governed by the Participating TO’s WDAT or other interconnection tariffs that allow or prohibit a project to seek FCDS or PCDS under the ISO tariff. ISO and distributed Fast Track (FT) projects will not be eligible for the cluster deliverability studies.
Currently, SCE’s WDAT Fast Track projects, which are studied as Energy Only, may seek a deliverability allocation via the WDAT, which references Section 8.9.2 of Appendix KK. SCE requests the CAISO confirm whether a WDAT FT is not eligible for the “cluster deliverability studies” but remains eligible for the process under Appendix KK Section 8.9.2.
4.
Please provide your organization’s comments on Section 3.1. Allowing Operational Energy Only Projects to Seek Deliverability.
No comment.
5.
Please provide your organization’s comments on Section 4.1. Application of Commercial Viability Criteria to all projects in the queue.
Previously, SCE commented on “4.1 Manage the accumulation of stagnant projects in the queue.” SCE asked if/when ISO intends to add the GIDAP Shared Network Upgrades requirements (Section 11.3.2.6) to the RIS as part of the IPE 5.0 filing. SCE also asked if ISO anticipated revising 11.3.2.6 to change “construction activities” to pre-construction activities.” CAISO did not directly respond to these issues in the Final Proposal. SCE requests the CAISO provide responses to these topics.
In the Final Proposal, Section 4.1. is titled “Application of Commercial Viability Criteria to all projects in the queue.” SCE supports application of Commercial Viability Criteria.
6.
Please provide your organization’s comments on Section 4.2. ISO as an Affected System process modifications.
No comment.
7.
Please provide your organization’s comments on Section 4.3. Modify the commercial readiness deposit due date.
SCE supports the proposal to modify the commercial readiness deposit due date.
8.
Please provide your organization’s comments on Section 4.4. Discontinue the Pre-Application process.
No comment.
9.
Please provide your organization’s comments on Section 4.5. Modifications to the GIDAP Executive Dispute Committee.
No comment.
10.
Please provide any additional comments on the Final Proposal or January 7 meeting discussion.
No comment.
