Comments on Revised straw proposal

1. Please provide a summary of your organization’s comments on the revised straw proposal

ACP-California appreciates CAISO’s work on a difficult and complex topic which has many moving pieces. We offer our general support for the direction that CAISO is headed, so long as a few elements (discussed in these comments) are addressed ahead of the proposal being finalized. In these comments, we offer a number of comments and suggestions for improvements, which are summarized below. ACP-California’s key points include:

Related to Order 2023 Compliance

• ACP-California requests that CAISO retain an option for interconnection customers to request OPDS or for CAISO to provide “indicative” OPDS results such that this status can be maintained. This could be performed outside of the standard cluster studies and, thus, CAISO would still be able to comply with Order 2023 timelines.
• While ACP-California does not support application of Site Control requirements earlier in the process than would otherwise apply for Cluster 14 and earlier clusters, CAISO should provide clarity as soon as possible on its plans to apply Site Control requirements to Cluster 14 and earlier. Interconnection Customers without site control need to understand, as quickly as possible, what requirements they will need to comply with and when. To that end, CAISO should clarify the definition of Site Control (and any associated acreage requirements) in the near-term so that customers can make necessary preparations to comply with the requirements that CAISO will propose.

Related to interconnection request intake (the proposed Zonal approach and Option B process)

• ACP-California supports the general approach, though some modifications and additional details are required. Most notably, to maintain open access on the CAISO grid, it is imperative to ensure that there are ample opportunities for resources serving corporate offtakers to interconnect to the grid (both within and outside of the designated “zones”). We are concerned that the current provisions may severely hinder or entirely prevent corporate offtake arrangements and the underlying resources from interconnecting to the grid. The proposal needs to provide an opportunity for these resources, which are a substantial portion of the contracted clean energy resources in the country, to interconnect and, therefore, CAISO cannot rely entirely on LSE interest. CAISO must provide opportunities for corporate offtaker interest to be considered and, additionally, provide room from energy-only interconnections which are not requested by LSEs.
  • Resolving this concern could include allowing commercial offtakers to provide “interest” as part of the scoring process and/or providing opportunities for these resources to interconnect in designated zones on an energy-only basis (without needing any LSE interest or support).
• CAISO should remove the proposed 25% cap on a developer’s ability to submit interconnection requests in a given cluster application window. The restriction is arbitrary and unnecessary in light of the other proposed reforms.
• CAISO should monitor the option for non-CPUC jurisdictional entities to have their preferred resources automatically included in the interconnection queue and revisit this element of the reforms should these resources comprise a significant amount of the resources admitted under the Option A/zonal approach (e.g. 5% or greater which is still significantly than the load ratio share of non-CPUC jurisdictional entities currently participating in CAISO). This will help ensure there is not an undue competitive advantage provided to LSE projects over those proposed by independent power producers. Additionally, CAISO should expand the resources which will automatically advance in the interconnection study process to include resources which the CPUC has specified as needed “eligible energy resources” to be procured through the Department of Water Resources Central Procurement Entity (CPE) established through AB 1373 (2023) and for which existing transmission is available or where the CPUC has approved a TPP portfolio with the same eligible resource that will trigger transmission expansion. This will ensure these resources can enter the queue.
• CAISO should update the “indicators of readiness” scoring criteria to provide different levels of points to projects based on the quality of the demonstrated business partnership and Engineering Design Plans. Engineering standards exist for what documentation is required to demonstrate design progress at different stages of project development which can be adopted by CAISO. Engineering standards exist for what documentation is required to demonstrate design progress at different stages of project development which can be adopted by CAISO. And CAISO should add scoring criteria for projects which have site control for the gen-tie required for the project (since this was not part of Order 2023, those projects that can demonstrate site control for a gen-tie should receive higher points on their “readiness”).
  • Additionally, CAISO should modify the weighting of the individual readiness metrics to reduce the advantage currently given to projects that are expansions of existing facilities. As proposed, new projects, which will likely represent the majority of projects entering the queue, will only be eligible for 30 out of the 100 Project Viability points.  This could lead to little distinction between scores of new projects, defeating the purpose of the scoring criteria. 
• In addition to adding an option for resources procured by a CPE and part of a CPUC portfolio to enter the queue automatically, it is appropriate to retain the “Long-Lead time Resource” point allocation for long-lead time resources that meet the definition of “eligible resources” but that may not have been specifically identified by the CPUC for procurement through the CPE at the time of an interconnection request. Long-lead Time resources should be defined to align with the definition of “eligible resources” in AB 1373 (2023).
• ACP supports the modifications to the auction process, which will result in bids only being requested when necessary and after the viability scoring process has been completed.
• ACP supports the modifications to the Option B process to allow customers which fund an Option B ADNU that is ultimately required to support a CPUC portfolio to be relieved of the funding requirement and get refunded.
• Option B should also be further defined to allow for energy-only interconnections (as should Option A) in order to maintain open access to the CAISO grid and to provide optionality in project development structures.
• The TPD allocation modifications, which are forthcoming, will be critical. TPD allocation must be designed to ensure that Long-Lead Time Resources will be able to secure the TPD capacity that was approved to facilitate their interconnection.

Related to Contract and Queue Management

• CAISO should modify the timing requirements for the proposed Commercial Viability Criteria demonstration to better account for resources with commercial operation dates far in the future (including long-lead time resources) which may enter the queue and, though making development progress, not be able to demonstrate a PPA after 7-years in the queue, given their long development timelines.  

Additionally, more time should be provided to customers that have a PPA cancelled as a result of a PTO delay. While we appreciate the CAISO offering an option, 12 months is highly unlikely to be sufficient to renegotiate a PPA, especially if there is not an active procurement cycle ongoing.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

ACP-California appreciates CAISO’s continued efforts to improve data accessibility to support the zonal approach. And we appreciate CAISO’s willingness to consolidate disparate information sources that inform the zonal capacity availability to support ease of access for interconnection customers. While the process for assessing whether a project is in a designated zone with available capacity will be manual and challenging, the information that CAISO has provided has been useful and informative. We appreciate CAISO’s ongoing efforts to continue to improve information access for potential interconnection customers.

We also encourage CAISO to continue to evaluate and discuss with the CPUC how the transition to the zonal approach will change the data sources and availability of data sources that are relied upon in this process today. For instance, by transitioning to the zonal approach, the information used for the Transmission Capability Estimates may be more limited than it is today which will, in turn, make it more difficult for developers to understand whether projects will have available capacity. We understand that the CPUC and CAISO are considering these impacts and encourage ongoing discussion, as continued access to this information and data will be critical to the ultimate success of the zonal approach.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

ACP-California supports the general approach, though some modifications and additional details are required.

CAISO Must Ensure Open Access to the Grid, which Includes Maintaining Options for Projects Selling to Corporate Offtakers to Enter the Queue:

The current proposal on interconnection request intake from CAISO focuses on resources seeking deliverability status and provides two options to enter the queue: Option A (the zonal approach) and Option B. ACP-California greatly appreciates CAISO developing Option B (which applies in areas with no available/planned deliverability capacity) to help ensure open access on the CAISO grid. While Option B is a good start, we are concerned that the present proposal may unduly hinder or entirely prevent access to the grid for resources which are looking to serve a corporate offtaker and/or which are seeking an energy-only interconnection. The final proposal must provide a pathway for resources which are serving corporate offtakers and for resources which wish to be energy-only to interconnect to the grid. Reserving interconnection capacity (even in designated zones) entirely for projects that are contracted to LSEs conflicts with open access principles and could thwart certain (significant) types of development projects, including those serving corporate offtakers. Projects serving corporate offtakers are not a niche market. They represent a significant portion of the generation development across the country. In fact, according to ACP’s most recent quarterly report (Q3 2023), corporate offtakers are the buyers for nearly 20% of clean power capacity in development across the country. This is a significant portion of resource development which cannot be written off or ignored as CAISO reforms its interconnection processes.

To address this concern, we recommend two modifications to the zonal approach (and additional modifications to Option B, discussed later in these comments):

1. Within the scoring criteria, LSE interest should be expanded to include other offtakers, such that a corporate offtaker has an opportunity to express its interest in projects and support their entry into the queue.
   1. In comments early in this initiative, ACP-California suggested that, in addition to providing LSEs with a limited amount of MW in which to express interest, CAISO should develop a process for corporate entities which could “require documentation of clean energy procurement goals and the quantity of resources needed, within CAISO, to meet those goals.” This could be augmented with attestations from corporate representatives as to their level of interest in procurement within CAISO to arrive at a MW limit that an individual corporate offtaker could utilize under this element of the scoring criteria.
2. Develop a process for projects to interconnect within Option A (the zonal approach) on an energy-only basis, without requiring such projects to have interest expressed by an LSE. This would allow energy-only interconnection projects serving corporate offtakers or looking to connect on a merchant basis to enter the queue and would, therefore, help ensure open access across the entirety of the CAISO grid.

CAISO Should Remove the Proposed Cap on Interconnection Submissions from a Single Parent Company

ACP-California urges CAISO to remove the proposed 25% restriction on a developer’s ability to submit interconnection requests in a given cluster application window. Many developers and other stakeholders have previously raised concerns with this proposal, which is arbitrary and will be difficult to implement with different project structures, joint ventures, etc. ACP-California is further concerned that it could result in suboptimal projects moving forward in the interconnection process because superior projects are deemed ineligible due to this restriction. Furthermore, this restriction should be unnecessary given the use of the scoring criteria in the interconnection process. The scoring criteria should help to determine which projects can move forward and should help reduce the ability for any one developer to overwhelm the system with speculative interconnection requests. CAISO should implement the other reforms that are proposed and, if it still sees this to be an issue, revisit this proposal at that time.

CAISO Should Monitor the Option for Non-CPUC Jurisdictional Entities to Automatically Enter the Queue in a Zone

ACP-California understands the need to have an “automatic entry” process for certain categories of resources to enter the queue. While we have some concern about providing non-CPUC jurisdictional entities with an automatic in, given the potential for preferential treatment of utility-owned generation through such a process, we do not object to such a process at this time. However, we urge CAISO to build into the proposal and associated tariff language a trigger which would require CAISO to revisit this rule should non-CPUC jurisdictional preferred resources comprise a significant (e.g., 5%) amount of the capacity allowed to enter the queue through the zonal process. This will help provide certainty that there is a process to revisit the approach should it be utilized more than is currently anticipated.

CAISO Should Expand the Types of Resources Eligible to Automatically Advance to Include Resources Procured By a Central Procurement Entity for Which There Is Existing or Planned Transmission Capacity

ACP-California urges CAISO to create another category of resources which can automatically advance to the study phase in the queue. Specifically, resources which 1) meet the definition of “eligible energy resources” in AB 1373 (2023); 2) have been specifically identified by the CPUC as eligible resources to be procured through the Central Procurement entity (CPE); and 3) for which transmission capacity is available or has been planned for in accordance with a CPUC portfolio that identifies the same eligible resource. For example, if the CPUC identifies a quantity of offshore wind for procurement by the CPE, in accordance with the process established in AB 1373, and the CPUC has also advanced a portfolio with 1,000 MW of North Coast offshore wind in the base case of a TPP, then any North Coast offshore wind project in the queue should automatically advance, so long as they meet site control and other standard queue entry requirements. Similarly, if the CPUC identifies geothermal resources for procurement by the CPE and there is a combination of existing and planned transmission to access geothermal resources in the Salton Sea, geothermal interconnection requests within this resource zone should also automatically advance. This will provide a pathway for CPE resources to be entered into the queue and will also ensure the amount of CPE resources is in line with what the CPUC is planning for while allowing for sufficient competition. It will further align with the concepts CAISO has proposed to develop in later phases of IPE to preserve capacity upgrades driven by specific resources for those specific resources. Because of the restrictions on these types of resource getting automatically advanced in the queue, and the naturally limited universe of projects that will also meet basic site control and project viability criteria, a similar trigger or limit (as discussed above for non-CPUC jurisdictional resources) is not warranted. These CPE resources are already limited by the CPUC’s process for identifying specific eligible resources for the CPE as part of the cyclical IRP process. But this will provide a necessary level of certainty that these resources can enter the queue even if they are in an early stage of a long project development process, and unlikely to be awarded points by individual LSEs given their long-lead time and/or large-scale nature. Indeed, this suggested accommodation for CPE resources would be in keeping with the purpose and need for central procurement itself: filling a gap in planning and procurement processes to enable development of diverse, long-lead time resources not typically procured by individual LSEs or under widespread development, but necessary for portfolio diversity and long-term reliability. We suggest that the CAISO monitor the interconnection requests that advance through the queue as a result of a CPE resource automatic trigger, to consider if any modification to the request intake process is needed in the future. To ensure these resources are treated appropriately, we highlight that additional policy development will be necessary, as part of the TPD allocation changes in this initiative, to ensure that the TPD planned for these resources continues to be available for them. ACP-California looks forward to working with CAISO on this item in the next phase of IPE 2023.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

CAISO Should Provide a Pathway for Corporate Offtaker Interest to be Included in the Scoring Criteria

As discussed in response to question #3, CAISO must ensure that the combined set of queue reforms continue to provide open access to the grid and, therefore, opportunities for projects serving corporate offtakers to interconnect. ACP-California recommends that, within the scoring criteria, LSE interest should be expanded to include other offtakers, such that a corporate offtaker has an opportunity to express its interest in projects and support project entry into the queue.

In comments early in this initiative, ACP-California suggested that, in addition to providing LSEs with a limited amount of MW in which to express interest, CAISO should develop a process for corporate entities which could “require documentation of clean energy procurement goals and the quantity of resources needed, within CAISO, to meet those goals.” This could be augmented with attestations from corporate representatives as to their level of interest in procurement within CAISO to arrive at a MW limit that an individual corporate offtaker could utilize under this element of the scoring criteria.

CAISO Should Update the Indicators of Readiness Criteria to Provide a Range of Scores Based on the Quality of Engineering Design Plans and Business Partnerships

CAISO should update the “indicators of readiness” criteria to provide different levels of points to projects based on the quality of the demonstrated business partnership and Engineering Design Plans. While we understand CAISO is seeking to avoid subjective criteria, we believe that different scores for different percentages of completed engineering design studies would be appropriate and could be reasonably implemented based on existing industry standards.[1] 

Additionally, CAISO should add a new element in this category that provides additional points to projects which have site control for the gen-tie required for the facility. Because gen-tie site requirements were not part of Order 2023, projects achieving this metric would have an opportunity to differentiate themselves from other interconnection requests. We urge CAISO to add this scoring criteria as another metric to help indicate project readiness.

Finally, the current point weighting in this category, with 70 of the 100 available points being allocated to expansion at existing facilities, is unnecessarily high. Having so much weight on projects at existing facility locations could lead to a lot of ties amongst the “new” projects, which would be problematic. We suggest lowering the allocation to existing facilities to 30 or fewer points.

CAISO Should Define Long-Lead Time Resources Consistent with AB 1373

In addition to adding an option for resources procured by a CPE and part of a CPUC portfolio to enter the queue automatically (as discussed in response to question #3), there may still be Long-Lead Time resources that do not fit into that bucket. For example, there may be long-duration storage projects that are “eligible energy resources” as defined by AB 1373 (2023) but that have not yet been specifically identified by the CPUC for CPE procurement, or which may be sited in different zones across the state and therefore not linked to a specific TPP zone. To continue to encourage development of diverse resources, these projects should have a pathway to receive “points” even if not receiving the automatic qualification described above. Therefore, it is appropriate to retain the “Long-Lead Time Resource” point allocation metric in the scoring system. ACP-California also recommends CAISO define Long-Lead time resources consistent with the definition of “eligible resources” in AB 1373[2] The CPUC could further define which resources are to be considered in this category in the transmittal of resource portfolios for the TPP. In any event, the definition should be limited so that it cannot be interpreted as applying to all the resource type locations in the CPUC portfolios. Otherwise, its application will be rendered meaningless.

CAISO Should Develop an Open Access Approach for Energy-Only Resources

While the focus to date has been on resources entering the queue and securing deliverability, ACP-California reiterates that CAISO must develop a process for energy-only resources to enter the queue. This may require a scoring/ranking process for these resources in addition to the metrics that have been developed for those seeking deliverability in a given zone. But it is imperative that a process be developed for energy-only interconnections and that it not be entirely dependent on LSE interest in these resources.

[1] For example, the different cost estimation classes defined by AACEI can inform the level of engineering plan completion (see here: https://web.aacei.org/docs/default-source/toc/toc_18r-97.pdf?sfvrsn=4). And there may be standards from IEEE or other sources that could be utilized to inform the level of points provided for this criterion and help differentiate projects with more complete plans.

[2]PUC 454.52 (h) (1) Only a new energy resource that meets all of the following requirements is eligible to be procured by the Department of Water Resources pursuant to this section:

(A) The resource directly supports attainment of the goals specified in Section 454.53 without increasing the state’s dependence on any fossil fuel-based resources.

(B) The resource is determined by the commission to not be under contract at sufficient levels as shown in load-serving entities’ most recent individual integrated resource plans submitted to and reviewed by the commission pursuant to this section to achieve the goals specified in Section 454.53.

(C) The resource has a construction and development lead time of at least five years.

(D) The resource does not generate electricity using fossil fuels or fuels derived from fossil fuels.

(E) The resource does not use combustion to generate electricity, unless that combustion use is ancillary and necessary to facilitate geothermal electricity generation.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

ACP-California offers limited comments on the fulfillment of the 150% of available and planned capacity. We do, however, urge CAISO to provide additional details on how and when capacity levels will be determined. And, in calculating the available capacity for a given zone, we recommend that any TPD allocations to Group D projects not be “counted” as already utilized. Group D projects are less certain and their temporary allocation of TPD should not serve to restrict the amount of interconnection capacity requests that CAISO will permit into the queue.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

ACP supports the modifications to the auction process, which will result in bids only being requested when necessary and only after the viability scoring process has been completed. We appreciate CAISO’s responsiveness to our comments and the comments of other stakeholders on this issue.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

ACP-California supports the modification to Option B that CAISO proposed in the Revised Straw proposal to relieve Interconnection Customers of the ADNU funding requirement and get refunded should CAISO determine that an Option B project is required to support a future CPUC portfolio. This is a reasonable approach to address uncertainty in the timing of various network upgrades and is equitable to those projects which may have initially funded an upgrade that is later found to be beneficial to the system to support a CPUC portfolio.

Additionally, as with Option A, we encourage CAISO to better define how energy-only interconnections in Option B areas would be treated. It is imperative that energy-only interconnections (whether to support LSE interest, corporate offtake, or for a merchant project) be allowed to proceed across the CAISO grid, in both Option A and Option B locations.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

CAISO proposes to remove both the off-peak and operational deliverability assessments (and therefore the Off-Peak Deliverability Status “OPDS”) to support meeting Order 2023 study timelines. While ACP-California understands the need to simplify the study process, we have seen some potential benefit to OPDS under future iterations of the Slice of Day RA paradigm – specifically, in that it can illustrate deliverability in certain “slices” or hours of the day.

Therefore, ACP-California requests that CAISO retain an option for interconnection customers to request OPDS or to provide “indicative” OPDS results such that this status can be maintained and CAISO can comply with Order 2023 timelines

Additionally, while ACP-California does not support application of site control requirements beyond what is required to comply with Order 2023 , CAISO should provide clarity as soon as possible on its plans to apply Site Control requirements to Cluster 14 and earlier. Interconnection Customers without site control need to understand, as quickly as possible, what requirements they will need to comply with and when. To that end, CAISO should provide clarity on the definition of Site Control (and any associated acreage requirements) in the near-term so that customers can make necessary preparations to comply with the requirements that CAISO will propose.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

While recognizing the challenges of a free one-time withdrawal opportunity, ACP-California continues to support exploration of an opportunity to withdraw with less risk than currently exists. This may facilitate a significant reduction in the size of the current queue, and we encourage continued discussion on how to achieve this objective, even if the final proposal includes a cost obligation for those withdrawing.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

ACP-California continues to oppose CAISO’s proposed removal of suspension rights, as we have in the past. Please see past comments for additional details (here and here).

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

CAISO should modify the timing requirements for the proposed Commercial Viability Criteria demonstration to better account for resources with commercial operation dates far in the future (including long-lead time resources) which may enter the queue and, though making development progress, may not be able to demonstrate a PPA after 7-years in the queue given their long development timelines. We recommend considering a “later of rule” where resources must demonstrate Commercial Viability Criteria at the later of 7-years after entering the queue or three years prior to their initially submitted commercial online date.

Additionally, CAISO should provide more time to customers that have a PPA cancelled as a result of a PTO delay. While we appreciate CAISO offering an option, 12 months is highly unlikely to afford sufficient time for a project to renegotiate a new PPA, especially if there is not an active procurement cycle ongoing. We recommend that, in the event a PTO delay causes cancellation of a PPA, developers be provided with the greater of three years or the length of the PTO delay (e.g., four years if that is how long the PTO project is delayed).

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

AES Clean Energy, “AES”, appreciates the opportunity to submit comments on the CAISO’s IPE Revised Straw Proposal.  AES appreciates the stakeholder timeline extension to May Board of Governors given the complexity and substantial changes of the proposed revisions. AES provides a summary of the comments, with more details in the respective comments section.

AES supports the following with some/no modifications:

• Consolidated document of data required to enable the zonal approach if the CAISO includes a capacity number that will be studied in the following cluster for each interconnection zone. The CAISO should reconsider the queue window opening date to at least September to align with the Transmission Planning Process (TPP) and Transmission Plan Deliverability (TPD) allocation processes. The consolidated document provided in January 2024 will provide misleading transmission capability estimate information to interconnection customers because the 2023-2024 TPD allocation cycle will not conclude until May 2024.
• Data of the additional number of new gen-ties that can come into a substation without upgrades in addition to the expandability of the substations.
• Data of the short circuits at each CAISO bus.
• Inclusion of major electrical equipment purchase order and preliminary engineering design into the scoring criteria. The long lead time equipment definition must include transformers and generation set up.
• Utilizing DFAX level for tie-breakers project applications.
• Option B modifications if Option B is allowed as an option for projects unselected through the scoring criteria process.
• Removal of the off-peak and operational deliverability assessment.
• One time withdrawal opportunity for all existing projects in the queue.
• Requesting limited operation studies nine months prior to synchronization.
• Updating the GIA nine months prior to synchronization with the amended MMAs.
• Requiring PTOs to notify the interconnection customer and CAISO that network upgrade activities have begun within 30 days from the interconnection customer providing the Notice to Proceed and posts the 3rd IFS posting to minimize upgrade delays.

AES opposes the following:

• The justification of the developer cap has not met its burden of proof that developers submitting more applications lead to higher attrition rates. AES provides statistical analysis from Cluster 12 and 13, demonstrating that there isn’t any statistical significance in attrition rates between developers submitting more or less than three projects.
• Non-CPUC jurisdictional entities’ projects should not be automatically included within the 150% available transmission capacity study cap as it raises discriminatory treatment between utility-backed generation and IPPs. At minimum, non-CPUC jurisdictional entities’ projects should be studied above the 150% available transmission capacity.
• POIs within subzones should not “close” once it reaches its expandable capacity. The CAISO should study all capacity within the zone and provide an opportunity for customers to upgrade the POI if needed.
• Utilizing an auction methodology for tie-breaker project applications.
• Removal of suspension rights.
• Requiring projects transferring TPD to withdraw from the queue.

AES seeks clarity on the following:

• Treatment of Energy Only project applications. AES believes Energy Only projects should not be subject to study caps and be allowed as Option A and B.
• Preventing LSEs from self-awarding points to their own projects in the LSE scoring criteria.
• Phasor Angle Measuring Units sample number. Does CAISO mean to update the samples from 30 samples/second to 60 samples/second?

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

AES appreciates the CAISO’s willingness to consolidate existing information into one document.  AES supports including transmission constraints, single line diagrams of resources, single line diagrams of POIs behind constraints, transmission capability estimates, and list of substations within each interconnection area into the document. However, AES urges the CAISO to include a capacity number that will be studied in the following cluster cycle for each interconnection zone. While a heatmap will be made available to customers that identifies the available capacity at the POI level based on the latest cluster study and annual TPD allocation study, providing customers with concrete numbers of the studied capacity in each zone will minimize uncertainties of guessing what the studied capacity will be in each zone. Setting this studied capacity number up front will also provide administrative efficiencies down the line when CAISO must score and accept projects into the study process. This will reduce the likelihood of disputes or complaints at FERC because all parties will have a clearer picture upfront of how many potential MWs would be accepted in each zone. In addition, the CAISO needs to include physical data consideration into the report. AES recommends that the CAISO work with TOs to compile a list of the number of new gen-ties that can feasibly come into a substation without expansion and the substations’ expandability. AES also recommends the document to include published short circuits at each CAISO bus.

In addition, CAISO should clarify how reassessments and WDAT clusters would be incorporated into the document.

Continuously updating the document as new information becomes available has good intentions but will not provide stakeholders with certainty on what assumptions would be made in the following cluster cycle. For Cluster 16 and beyond, AES urges the CAISO to determine a cut-off date that will then identify the assumptions made for the following cycle.  For example, CAISO can utilize June 1 as the cut-off date for assumptions made in the next cycle. June 1 will allow other processes (e.g. TPP and TPD allocation) to take place that affect the following cluster cycle.  The document will include all the proposed data information that is most up-to-date, and identify the capacity that will be studied in each interconnection zone.  This document will allow interconnection customers to understand the cluster cycle assumptions and studied capacity. As the proposal stands, interconnection customers will essentially need to guess whether or not a zone has capacity or are behind any constraints given the timing misalignment with other important processes, such as the TPP and TPD allocation processes. Since CAISO’s TPD allocation methodology will allocate TPD to projects if additional TPD is available, only a small fraction of deliverability will remain available after each allocation cycle. This makes it difficult for developers to commit resources to projects until after TPD allocation process is complete.  To ensure timing alignment with other related processes, CAISO will need to reconsider changing the annual queue opening date from April to at least September of each year. This would allow interconnection customers time to process the updated information prior to being scored.

In the short term, the CAISO has indicated that a single document with all consolidated information will be provided to customers by the end of January.  AES appreciates the CAISO’s willingness to provide information as soon as possible, but is concerned with the timing misalignment between the report and the 2023-2024 TPD allocation cycle.  Specifically, AES is concerned that the January report will misinform interconnection customers with the available transmission capability estimates in each zone. The 2023-2024 TPD allocation report will not be released until May 2024, which may significantly decrease the actual transmission capability estimate given the total capacity of projects included in Cluster 14 that will be eligible for TPD allocation.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

AES continues to strongly oppose the implementation of a 25% developer cap as discussed in the Revised Straw Proposal. The CAISO has not met its burden of proof in demonstrating that developers submitting more projects have statistically significantly different dropout rates than developers submitting fewer projects.  The data provided in the Revised Straw Proposal identifies the number of projects submitted by companies and does not demonstrate that companies submitting more projects are correlated to higher attrition rates, which would indicate that parent companies that submit more projects are more speculative than those that submit fewer. In fact, AES has previously conducted a difference of proportion test for Clusters 12 and 13 from data provided in IPE 2021 to determine if the appearance of companies submitting more projects having a higher retention rate was statistically significant.[1] The difference of proportion test evaluates whether the difference in percentages across two groups is meaningful or if the differences are the product of random chance, and thus the apparent differences can’t be associated with the difference between the two groups, in this case, the number of applications submitted by a parent company per cluster leading to different retention rates. The results of the test can be shown in Table 1. For Clusters 12 and 13, there is not a statistically significant difference between these two groups because the alpha values are greater than 0.05.   The data does not support a significant difference in retention rates between companies submitting 3 or more projects than companies submitting less than 3 projects.[2]

Table 1.

In addition, the CAISO justifies using the auction mechanism for tie-breaker projects by agreeing with stakeholders that projects required to participate in an auction would advantage large, well-capitalized entities. The CAISO states this is not a poor outcome because generation development requires significant capitalization. Given this acknowledgment, developers with the resources to invest in projects with higher entry requirements should be able to submit their applications for consideration since they are the ones who bear all of the risks in the process.

The CAISO claims that the developer cap is also meant to reduce administrative burdens, however, this could be solved through outsourcing the validation of applications or legal review of supporting documentation, as PJM has recently done in their queue transition process. The scoring system is intended to be binary, so developers either have it or not. Therefore, the volume of projects to score should not matter, especially since CAISO requests customers to self-score some of the categories in our interconnection application.  AES believes that with the new FERC Order 2023 entry requirements in addition to the proposed scoring mechanism, CAISO will unlikely be receiving an influx of interconnection applications. Therefore, an additional developer cap may be redundant and require unnecessary administrative processes through the yet-to-be-defined determination of which projects belong to which “parent company”.

The CAISO also states that the developer cap intends to ensure that no one developer captures an inappropriate share of transmission capacity. AES continues to argue that the interconnection process is not the appropriate venue in assessing market power issues.  If market power were created, regulatory authorities would be the appropriate entities to assess via market power analysis.[3]  In fact, applying a blanket 25% developer cap on the available transmission capacity for clusters may result in project sizes that are uneconomical, with higher pricing, or may inhibit the local market. This will contribute to the market power concern that CAISO is attempting to address through the developer cap. Project sizes may become uneconomical because of the need to size projects to meet the developer cap given the uncertainty of the available TPD after the allocation cycle.

AES seeks clarity on how the CAISO intends to identify the parent company. Identifying the parent company can be complicated if there are joint ventures or companies that have interactions.  AES worries that the internal processes of ensuring that subsidiaries of the same parent company, who could be considered competitors, do not submit projects above the MW cap could violate NERC anti-trust rules.

AES seeks clarity on whether the developer cap would apply to LSEs in addition to IPPs.   AES believes that applying developer cap to only to IPPs would result in discriminatory treatment between LSEs and IPPs and would violate FERC principles.

[1]  AES Clean Energy Comments on Interconnection Process Enhancements 2021 Revised Straw Proposal, June 28, 2022.

[2]  AES Clean Energy Comments on Interconnection Process Enhancements 2021 Revised Straw Proposal, June 28, 2022.

[3] Horizontal Market Power | Federal Energy Regulatory Commission (ferc.gov)

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

 AES believes the scoring criteria need further refinement. Below are recommendations and questions on the revised scoring criteria:

• Regarding the LSE interest category, how will the CAISO prevent LSEs from only awarding points to their own projects?
• What information basis will the LSE have to make decisions on rewarding points to projects? 
• AES recommends a lower weighting in the LSE interest category to minimize the power from LSE in determining what interconnection applications are submitted into the studies.
• AES also urges CAISO to include non-LSE interest into the scoring criteria. Non-LSE interest can include a letter supporting a project that demonstrates carbon reduction.
• AES believes the project viability category weighting should increase to 40% from the proposed 30%.
• AES supports including long lead time equipment purchasing orders. AES does not believe that including a Master Service Agreement to demonstrate business partnerships for future supply of major equipment would create granularity in the scores as this can be easily met. However, including a purchase order for major long lead time equipment can create competition in the scoring criteria. The CAISO would need to define major generating equipment and include transformers and generation step up.
• AES believes a preliminary engineering design is a reasonable criterion to be included and recommends the following definition:
  • Long lead time equipment count
  • General arrangement with total system size and developer substation
  • Single line diagram showing metering and protection
  • Parcels/easements with site control highlighted
  • Site layout that indicates multiple gen-tie routes
• AES recommends the expansion of facilities’ weighting be lowered to lower the preference of existing generation owned by utilities.
• The CAISO should clarify how long lead time resources are defined. Given that limited resources (e.g. long duration storage and offshore wind) would qualify, this category weighting should be lowered. The CAISO should also consider creating a separate interconnection process for these long lead time resources, such as offshore wind. 
• The CAISO should clarify how Energy Only projects would be treated given that the 150% study capacity is based on full deliverability capacity studies, which Energy Only projects would not require. Energy-only projects should be allowed to continue as Option A. These projects should not be subject to the 150% available transmission cap nor the developer cap. Energy Only projects should only be responsible for interconnection costs, and not network upgrade costs.

AES supports utilizing DFAX levels as the first mechanism to break tie-breakers, selecting applications with the lowest DFAX. To best understand DFAX levels across the queue, AES recommends CAISO to publish DFAX values from the current queue prior to interconnection studies.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

 AES appreciates the CAISO’s additional details on how it intends to fulfill each zone’s 150% of available and planned capacity.  Within each zone, AES does not support the CAISO “closing” the POI once it reaches the maximum expandable capacity before an upgrade is needed. The expandability of the POI in each subzone largely depends on the CPUC’s busbar mapping process, which is not 100% accurate. AES believes all capacity at the POIs should be studied regardless of whether the nested constraints cause a network upgrade. If an upgrade is needed, interconnection customers triggering the upgrade should be given the option to fund it.

AES continues to oppose including non-CPUC jurisdictional entities automatically into the interconnection studies without scoring, inclusive of the 150% available transmission capacity study cap. AES continues to believe this raises discriminatory treatment between independent power producers and utility-back generation, in addition to between CPUC jurisdictional and non-jurisdictional entities. While CAISO staff has noted that non-CPUC jurisdictional entities make up a small portion of the CAISO footprint,[1] AES agrees with others on the December 19, 2023 stakeholder call that some municipal utilities are large and may potentially contribute to a higher footprint. AES recommends the CAISO to, at minimum, study non-CPUC jurisdictional LRAs studies outside of the 150% available transmission capacity cap.

Finally, annually after Cluster 17, the CAISO should reevaluate whether 150% of available transmission is the appropriate study cap that ensures competition, minimizes attrition, and meets state procurement goals.

[1] CAISO Interconnection Process Enhancements 2023  Track 2 Working Group Meeting, November 15, 2023.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

 AES continues to oppose auctions as an appropriate mechanism for tiebreakers. Bidding is not an appropriate mechanism to compare projects against one another. Projects selected through the auction will have different at-risk security than projects admitted through the scoring criteria. AES continues to believe this is discriminatory treatment given that the CAISO will withhold auction security that are subject to different refund rates compared to projects selected not through the auction mechanism.

Given that CAISO will break tie-breakers by selecting projects with the lowest DFAX levels, an auction mechanism is not necessary. If projects still exist after the DFAX screen, the CAISO should consider studying more projects, even if it exceed the 150% available transmission capacity cap.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

 AES appreciates the modifications made to the Option B process. AES continues to urge the CAISO to allow projects that are unselected through the scoring process (Option A) and “energy only” projects to be given the opportunity to continue as Option B. If companies are willing to self-fund network upgrades within the priority zones, the CAISO should allow this to occur. The additional network upgrade built by self-funded projects will provide additional grid benefits than just interconnecting the project. The CAISO stated that allowing Option B projects in priority zones would result in studying capacity in those zones potentially well above the 150% threshold and would be counterproductive to solving the issue identified in the problem statements of studying capacity levels so high that the study results lose accuracy, meaning, and utility. To prevent this issue, the CAISO can study Option A projects first, then study Option B projects to prevent the loss of study accuracy. Option B projects in the interconnection priority zones can help increase generation supply and help keep any potential market power in check by increasing competition. Option B projects could also provide cushion and more margin of error if the state’s resources planning process does not identify enough resources to cover increases in demand as they actually materialize in the future.

AES appreciates the CAISO publishing ADNU cost estimates but seeks clarity on where and when the CAISO will publish the ADNU estimates.  AES recommends publishing the ADNUs cost in the single document that is discussed in the data accessibility section. AES is concerned whether Option B will be a viable option given historical ADNUs estimates that may cost over $1 billion.  AES recommends the CAISO to identify methods for cost recovery for ADNUs, otherwise, this option may continue to be unviable.

AES supports the CAISO’s modification to allow customers to be relieved of funding ADNUs if the upgrade is approved in the Transmission Planning Process.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

 AES supports the CAISO’s proposal to remove the off-peak and operational deliverability assessments if it improves the study timelines.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

 AES continues to believe that the CAISO should allow a one-time withdrawal opportunity to clear out the existing queue. The most recent survey results indicated that existing projects would consider withdrawing if there was an opportunity.[1]  AES recommends the CAISO to explore additional sources of funding for the network upgrade costs associated with the withdrawals.

[1] Stakeholder Working Group Survey Results presented post working groups

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

 AES continues to support allowing interconnection customers to request limited operation studies at least 9 months prior to synchronization.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

AES does not support the removal of suspension rights as it does not allow the flexibility to accommodate delays out of the interconnection customer control, such as permitting.  At minimum, the CAISO will need to continue allowing customers to have a one-time delay in construction milestones based on existing practices if suspension rights are removed to allow some flexibility for interconnection customers to accommodate delays outside of their control.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

 AES continues to oppose requiring projects transferring TPD to withdraw from the queue unless an Energy Only PPA is provided at the time of transfer request. On the contrary, in the short run, AES believes the CAISO should maintain flexibility in TPD transfers to ensure that developers can contract to convert projects with assigned TPD into projects that can reach COD. Existing projects have already been studied, and the CAISO should make it as easy as possible to convert this sunk cost in terms of studies and TPD allocation into operational MWs. In the long run, the CAISO’s concern of having TPD as a tradable commodity will vanish because of the scoring criteria limiting studies to 150% of the available transmission capacity. In addition, providing an Energy Only PPA at the time of transfer request is not viable because the offtaker may not want to sign an offtake agreement until they are certain that the TPD has been transferred. At minimum, if CAISO moves forward with this proposal, it should allow a minimum of 90 days after the TPD transfer for transferring project to provide an Energy Only PPA.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

 AES understands the intent of the proposed commercial viability criteria (CVC) deadlines and GIA execution deadlines for all existing and future clusters. The CAISO should understand that network upgrade schedules may well exceed six years and therefore may inhibit the developer from meeting the CVC requirements. The CAISO should consider how longer network upgrade schedules would be incorporated into the CVC requirements.

For good merit, AES recommends that CAISO allow customers of existing queues to request a one-time timeline extension meeting the CVC requirements.  For Cluster 15 and beyond, the CAISO states that projects must meet the CVC no later than 7 years from the original interconnection request application.  AES urges the CAISO to require Cluster 15 projects to meet the CVC requirements 7 years from the date of validation given that the IPE 2023 stakeholder process will have taken over a year since Cluster 15 projects were originally submitted.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

AES supports requiring all parties to post for shared network upgrades within 60-90 days from the first customer’s posting. This will ensure network upgrades are built in time. AES seeks clarity on how and when the due dates for the payments will be communicated. In the event that a customer without an executed GIA withdraws, all other customers should not be financially responsible for the withdrawn customer’s pro rata cost responsibility and costs should be originally allocated such that interconnection customers do not bare the full cost of the shared upgrade.  AES also seeks clarity on how shared upgrades will be allocated to multiple projects (i.e. MW, total cost, # of projects).

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

AES supports updating the GIA nine months prior to synchronization with the amended MMAs. AES supports that the New Resource Implementation process qualifying criteria are revised to accept MMA approvals in lieu of updated GIAs.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

 AES strongly supports requiring PTOs to notify the interconnection customer and CAISO that network upgrade activities have begun within 30 days from the interconnection customer providing the Notice to Proceed and posts the 3rd IFS posting to minimize upgrade delays. AES also supports requiring the PTO to meet the Initial Synchronization Date in the GIA to allow interconnection customers to meet their PPA requirements.  

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

 AES is not opposed to including an implementation cost but requests the CAISO to publish periodic reports of resource development progress. The CAISO should also consider utilizing implementation deposits to hire additional resources to assist with resource implementation. Additional contractors hired should be published on the CAISO webpage, similar to utility practice. AES is not opposed to including an implementation cost, but requests the CAISO to publish periodic reports of resource development progress. The CAISO should also consider utilizing implementation deposits to hire additional resources to assist with resource implementation. Additional contractors hired should be published on the CAISO webpage, similar to utility practice.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

 AES seeks clarification on the CAISO’s proposal. The CAISO believes the current 30 samples per second of Phasor Angle Measuring Units is not granular enough to use for fault analysis, but recommends a revision of 16 samples per second. To have more granularity, the samples per second would need to be higher than 30.  AES is not opposed to increasing the Phasor Angle Measuring Unit, with a limit of 60 samples per second.

1. Please provide a summary of your organization’s comments on the revised straw proposal

Avantus remain highly concerned by proposed reforms unbacked by sufficient quantitative and qualitative data. At a high level, we view the following topics require additional data and/or consideration before moving forward:

• Developer Cap (Data Request) - See detailed response under 3. 
  • IR submittal and withdrawal rates after Scoping Meeting and Phase I study
  • This provides one data point differentiating entities submitting “unready” projects vs having a large portfolio.

• Scoring Criteria – See detailed response under 4.
  • Avantus requests CAISO to clarify that MWs to be assigned to CPUC jurisdictional LSEs to allocate can be applied toward their own projects.
    • If so, this enables LSEs to indirectly exclude competing projects from a study.
• 150% Capacity Limit (Data Request) - See detailed response under 5.
  • Proof of concept using previous queue entry data (C12 – C14 minimum) demonstrating how it would have shaped preceding clusters.
• Removal of Suspension Rights
  • With only 7 projects of many projects having requested suspension, this is not sufficient data to justify eliminating a long-standing pro forma LGIP tool.
• Potential exclusion of Energy Only Projects
  • CAISO clarified intentions at the 12/19 meeting to exclude EO projects unless requested by LSEs. Avantus urge the ISO to provide further guidance soon.
    • The intended outcome would exclude all projects intending to be merchant.
• Auction Tie-Break Mechanism
  • Between the proposed scoring criteria and DFAX tie-break, an auction tie-break is not necessary and would further burden relevant CAISO staff.
  • Avantus recommend deploying a bell-curve or pro rata mechanism to screen out capacity that can’t be accommodated in each cluster.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Avantus appreciates the separate workshop on 12/18 which provided a detailed overview and explanations of use and timing of data CAISO is working to consolidate. With various categories of data being available at different times, it appears challenging to obtain all necessary information at once. Regardless, we recommend CAISO to keep them in one document with a placeholder section and anticipated available date. Alternatively, these can be published under CAISO’s GI website as a standalone subsection accompanied by a master explainer document.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Zonal approach: Avantus appreciates CAISO's clarification on projects at POIs without capacity within a zone that has capacity would be excluded from study with no option to pursue Option B. In this case, Avantus is unsure why CAISO is approaching the IPE 2023 reform from a zonal perspective, rather than a simple, granular POI approach that is easier to follow.

We request that 1) CAISO provide further reasoning to support this intent, and 2) provide a demo of the mechanics outlined IPE presentation slide 21, which corresponds with section 2.5.1 page 41 of the revised proposal, using a set of IR requests and zone constraints, either from previous queue entry data or made up data, whichever is more convenient.

Developer Cap: Avantus strongly oppose an arbitrary developer cap until further data is provided on Figure 4 of page 31 of the revised proposal. Specifically, we request CAISO to produce subsequent withdrawal data as follow:

The withdrawal to submittal ratio (and vice versa), while not comprehensive, could provide one data point to differentiate whether an entity is submitting excessive unready projects vs. simply having a larger portfolio. Additional data points to consider include site control, median construction lead time and median $/MW upgrade cost. Additionally, we request CAISO for clarifications on how the developer cap would apply for joint ventures, jointly owned projects, and M&As that take places throughout the interconnection process.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

LSE Interest

Avantus appreciates CAISO removing previously concerning elements (e.g., permitting) from the scoring criteria; however, we are genuinely alarmed by the refined criteria which furthers LSEs' outsized influence on IR intake.

• We request clarification on whether the capacity amounts assigned to CPUC jurisdictional LSEs for scoring allocation can be applied toward their own projects.
• If yes, we urge both CAISO/LSEs to consider FERC's response to LSEs having indirect abilities to exclude competing resources in each study cycle.
  • We recognize there are several WECC region tariffs that already allow LSE owned projects or projects being developed for LSEs/large end users/C&I customers to bypass financial based commercial readiness requirements.
  • However, these are not considered unduly discriminatory as they do not bar other projects from entering the queue so long as they meet IR entry and readiness requirements.

Project Viability

Under project viability in the proposed scoring criteria, CAISO clarified in its proposal and at the 12/19 meeting that sub-category expansion of an existing facility (+gen-tie with capacity) would only include operational projects. Avantus views exclusion of phased projects typically spanning over several clusters as missed opportunities per the following:

• Existing operational facilities unassociated with other projects are unlikely to have appropriately sized gen-ties capable of accommodating additions.
• Modifying operational facilities to accommodate expansion would require logistics that PTOs may not entertain, and most certainly interrupt service, leading to lost revenue opportunities.
  • Additionally, operational facilities are assumed to have PPA obligations where they cannot go offline for extended periods (other than maintenance or unplanned outage) to accommodate expansion work.
• Phased projects are more efficiently planned/sequenced to maximize a given gen-tie/bay position capacity limit (1100MW), which translates to more comprehensive engineering, permitting, and procurement workflow prior to start of construction.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

Avantus continue to find the 150% proposal problematic per the following:

• The 150% figure is arbitrary, lacking quantitative and/or qualitative analysis which demonstrate enough capacity would be studied to ensure long-term Resource Adequacy.
• Future IR qualifiers being based on existing/planned transmission capacity, specifically deliverable capacity.
  • Most developers agree that after the 2024 TPD cycle, it is likely that no capacity will be left for C15 to qualify into.
  • This does not factor in anticipated late-stage withdrawals or longer term TPP projects that will open deliverable capacity downstream in successive years closer to project CODs.
  • This also does not consider future peak load amount or resource accreditation (We encourage the ISO to review AES Clean Energy’s comments on MISO’s proposed queue cap, starting page 5).
• CAISO did not conduct a proof-of-concept demo using previous queue entry data (at minimum C12, C13, and C14) as to how the proposal would have shaped the preceding clusters.
  • This serves to provide critical insight for determining functionality and reasonableness of the proposed mechanism.
• CAISO has not cleared any resources through Phase II study since C14 kicked off in 2021, closing in on 3 years of inactivity.
  • Paired with PTO delays, it is critical for CAISO to quantitatively and qualitatively verify that further restrictions from IPE '23 Track 2 will not lead to or exacerbate long term generation shortage. 

Additional unanswered question(s):

• What happens to the 50% of 150% admitted project MWs that do not receive TPD after completing a study cycle?
  • Will these MWs be required to withdraw or convert to Energy Only?

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

Avantus remain opposed to all auction mechanism per the following:

• There are close to no stakeholder support.
• A more reasonable second tie-breaking mechanism (DFAX) has been introduced.
• Order 2023 requirements will be sure to screen out a substantial amount of projects.

Should the ISO insist on implementing additional tie-breaking mechanisms, we recommend using a bell curve (after DFAX) or pro rata allocation to screen out capacity that can’t be accommodated in each cluster.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

Avantus reserves the right to comment on this proposal under future iterations.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

Avantus requests CAISO to 1) provide additional insight (e.g., Gantt chart showing the workflow) on why the two assessments would not be accommodatable under Order 2023 prescribed timelines and 2) reasoning on why this wouldn’t qualify for Independent Entity Variation, considering these assessments have been a long-standing part of CAISO’s GIDAP.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

Avantus views CAISO ceasing further considerations on the one-time withdrawal proposal before quantifying any benefits as missed opportunity to reduce queue sizes. Along with LSA, Avantus provided detailed recommendations to produce a least harm scenario by bucketizing priority withdrawals. Avantus’ proposal is as follow for re-consideration (partially incorporated into LSA’s proposal presented to CAISO in August 2023):

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

Avantus continues to advocate for a planning horizon LOS post LGIA execution, in addition to built-in LOS during study process based on IC requested COD akin to SPP’s process. Having the ability to bring a portion of a project online (pending long lead upgrades) is critical for fulfilling mid-term reliability needs.

(Please refer to previous comments for comprehensive details)

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

Avantus reserves the right to comment on this proposal under future iterations.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

Avantus continue to oppose removing suspension rights as stated in previous comments. Per CAISO’s data in the straw proposal, only 7 projects of many have requested/used suspension, which demonstrates it’s a tool rarely used due to CAISO’s TPD process and unique RA structure. This is insufficient data to support the elimination of a long-standing tool included with the pro forma LGIP.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

Avantus opposes restricting TPD transfer and views the proposed requirement for EO PPA to remain in queue and Group C only TPD allocation to be counter intuitive. Splitting EO projects with PPA into two classes of TPD eligibility is sure to complicate matters while simultaneously creating additional burden for ISO staff.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

Avantus continue to disagree with 1) CVC criteria on EO projects and 2) PPA being part of that CVC criteria for EO projects per the following:

• This effectively require all CAISO projects to have an offtaker to stay in the queue.
  • We request CAISO to provide guidance on how projects can pursue the merchant path. (note: not referring to proposed option B merchant path, rather, a project that intend to reach COD as a fully merchant project)
    • This also moots and contradicts TPD allocation Group C, as no projects will be able to stay in the queue and reach COD without a PPA. If an EO project obtains a PPA, they will be sure to seek deliverability under Group A or Group B in the next nearest TPD cycle.

Additionally, Avantus questions the logic of a 7-yr in queue CVC or ISD/COD requirement given C14 Study Results, PTO delays, and newly identified SCD mitigation.

• The 7-yr limit was initially part of pro forma LGIP language to prevent IR from submitting a project with ISD/COD too far out of a 10-yr planning cycle, accounting for 3-yr suspension/EPC delay allowance (Section 3.4.1 of LGIP, page 25 before Order 2023).
• Additionally, CAISO and other RTOs have since evolved to include a voluntary 20-yr Transmission Planning outlook.
• Further, considering that final FERC ruling on TPP docket could make some of these extended outlooks more permanent, the ISO should reconsider whether 7-yr CVC is just to impose across all resources and all project schedules.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

Avantus requests clarification on whether CAISO is delaying Construction Sequencing 9 months before synchronization date or COD, considering that there is a wide span (6-11 months) between the two referenced dates itself. Nonetheless, CAISO has not thoroughly explained why it is proposing the change or demonstrated sufficient reasoning on how this would bring upon improvements.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

The requirements outlined in this section to execute E&P Agreements and GIA, appear to moot the purpose of parking allowance. Avantus requests CAISO to further clarify in the proposal how deliverability status would be reflected in GIA Appendix C section (g) with the project in parked status.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

Avantus reserves the right to comment on this proposal under future iterations.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

Avantus reserves the right to comment on this proposal under future iterations.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

Avantus requests CAISO to 1) tally unused non-refundable Interconnection Study Deposit amounts from the last few Clusters and 2) Consider updating the GIDAP section 7.6 to redirect Interconnection Study Deposit and Non-Refundable Site Exclusivity Deposits toward post LGIA admin cost before implementing additional fees at the time of LGIA execution.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

Avantus reserves the right to comment on this proposal under future iterations.

1. Please provide a summary of your organization’s comments on the revised straw proposal

Aypa Power appreciates the opportunity to provide feedback on CAISO’s 2023 Interconnection Process Enhancements Revised Straw Proposal. As provided in prior feedback to CAISO, Aypa believes that the Straw Proposal’s most sweeping reforms, while important and well-intentioned, have not been provided ample venues to better analyze and understand actual impacts to the queue. Reforms must enable meaningful reductions in the interconnection queue processing time, while ensuring that viable projects can make it through an administratively efficient process. Importantly, CAISO’s proposed reforms challenge existing precedent on open transmission access, while introducing new forms of limitations on the interconnection process that have not been previously considered by the Federal Energy Regulatory Commission (FERC). These changes significantly increase the likelihood that FERC will require additional compliance filings, which would further delay Cluster 15 (C15) and later clusters.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

We appreciate CAISO’s proposal and efforts to make additional data available and more accessible to developers so that they can make informed business decisions before and during the interconnection study process. The timeline to provide such information is problematic and does not allow developers sufficient time to use the information to meet CAISO’s intended goals. Aypa encourages CAISO to reconsider the time duration between publishing this information and when interconnection requests for C15 and beyond will be reviewed to maximize the value of this information. The goal should be to reduce the need to re-review revised requests and the likelihood of projects that may appear to meet all the criteria but may sacrifice other project due diligence if there is insufficient time to make use of the published information. This will also allow developers to focus resources only on the areas that CAISO will allow projects to develop, thus improving the overall efficiency of development and reducing portfolio development costs. We recommend that the interconnection request validation process begin 6 months after the zonal information is published.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

The Zonal approach CAISO has proposed will be ineffective because the information that is proposed to be used to screen projects on intake is decoupled from the information that will be used to award projects at the end of the study process. There are currently significantly more project MWs in Cluster 14 that are eligible to seek TPD allocations than there is planned capacity. The current 23-24 TPP process is not expected to result in any new Economic or Policy projects that expand deliverability service beyond the current planned capacity amounts. The 2024 TPD allocations are expected to occur before C15 requests are validated. Given this, it would be reasonable to expect that 0 MWs will be available in any transmission zone for C15. Even if exceptions are made (see feedback in other sections), in 2+ years when C15 would be evaluated for deliverability, the amount of deliverability is unknown at best and 0 at worst, as it depends on the performance of CPUC and TPP planning cycles that have yet to occur. It is unreasonable to restrict the ability for resources to apply to certain areas based on information that is certain to change and will result in 2 different standards that cannot be reconciled under the proposed process. At best, it will continue to encourage speculative interconnection applications that have a chance but are not guaranteed to fall into an area that will receive a future policy project. At worst, it will commit development and study resources to projects that do not have a viable path forward to TPD interconnection service.

Section 2.3 – Interconnection Request limitations

CAISO has failed to demonstrate that this proposal will meet the stated objectives of reducing queue sizes and ensuring that the most viable and ready projects complete the interconnection process efficiently. It is also unclear how CAISO intends to validate and enforce this proposed requirement and how it would apply to unique partnerships between development companies. We do not support this proposal.

We request that CAISO make an updated Figure 4 available that shows this information for C13 and C15 and includes the MWs (at the point of interconnection (POI)) submitted by each category of company. The proposal seeks to limit the MWs submitted, while the information reviewed to justify the proposal is based on the count of projects submitted for a single cluster. CAISO is also requested to make this information available for counts and MWs of projects with executed GIAs for all prior clusters. 

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

The scoring criteria continues to borrow too much of its framework from the TPD allocation process that it is based on.  With the recent changes in scoring and weighting, doing so significantly increases the likelihood for process manipulation via the LSE interest points. The points are intended to be used to sort the projects based on viability, but there is insufficient information available to LSEs at this stage of a project specifically, certainty on costs, timing, and TPD allocations, for those points to be used as a meaningful differentiator in the intake process. Further, there are no restrictions on LSEs that can self-develop their own resources, allowing utilities to easily preference their own resources, which are already afforded advantages outside of the proposed scoring methodology.

The Non-CPUC-jurisdictional LSEs should be excluded from any MW caps based on TPD availability as they are not part of the CPUC policy framework that creates such TPD MWs.

While we generally agree that an expansion of an existing GIA is more viable than a “greenfield” project, the scoring seems too heavily biased towards these resources and would allow for incumbent utility generation to “stack” benefits giving them unnecessary advantages. We would recommend lowering the weighting to: Supplier relationship: 25, Detailed Site plan 25, Expansion 20, Expansion on higher-queued gen-tie 30.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

While we understand the desire to limit the amount of MWs in each study cycle, Aypa believes that 150% is too restrictive and doesn’t allow for a meaningful level of competition during the study process to yield the most viable and cost-effective projects to receive GIAs. Aypa believes that such a restriction should not be included in the final proposal.

There are currently no policy or economic projects proposed in TPP 23-24 that would increase TPD capacity and there are more MWs that are eligible to seek from C14 in every TPD zone than there is available TPD capacity. Unless other exceptions are made for the determination of available/planned capacity, it does not appear that any projects will be allowed to continue in the C15 process as an “Option A” project. 

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

Aypa believes that an auction does not add value or differentiation to projects entering the queue process. Projects are being encouraged to include a cost-adder to ensure their projects are selected. This is counter to the offtake process, which expected the least-cost resources to be developed. We expect more meaningful changes elsewhere in the process to eliminate the need to include this in the final proposal. The CAISO has a flawed view that this will somehow reduce overall costs to ratepayers when an auction mechanism will actually increase the overall costs of developing projects without providing any direct benefits. This is just increasing and shifting costs that will eventually be passed on to ratepayers in a more obscure manner distributed by the same developer to other projects or through the elimination of smaller developers and overall cost competition.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

The Option B process as designed today is rarely, if ever, utilized due to the risk associated with it. Stakeholders had asked early in this IPE process that CAISO make changes to the Option B process so that it could at least be considered as a viable option for projects. The changes proposed thus far make this even more risky and speculative than it currently is, which further reduces the likelihood that any project would ever select this option.

The CAISO seeks to have projects elect to take on the risk of an ADNU, often $100M++, without understanding if the information on previously considered ADNUs is properly scoped for their size project, if other projects will share in this cost or not, or even if projects initially elect to share if they will get all of the way to NTP on those ADNUs to minimize the additional cost risk exposure to a project. CAISO asks projects seeking this option to put more cash at risk earlier in the process than is currently required.

CAISO has also proposed to restrict projects with POIs in areas with remaining TPD capacity from electing Option B, even though there is an expectation that constraints will limit the TPD capacity awarded to such group of projects to less than what enters the queue (Section 2.5.1). This is an unnecessary restriction. If projects want to fund ADNUs to enable deliverability once current study information is provided, they should be allowed to do so.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

We support the removal of this analysis. These studies did not convey any additional service into the GIA.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

While we appreciate the concerns raised by the PTOs with regards to cost shifting, if the expected volume of projects were to withdraw it should be expected to result in a reduced scope of network upgrades to deliver the overall portfolio of projects, thereby reducing the potential that upgrades are under-funded. Even if the upgrades remained unchanged, the PTOs have failed to recognize that encouraging the acceleration of the withdrawal of projects that would otherwise withdraw later would result in the same financial problem, but on a much shorter timeframe. Rather than allowing projects to die a slow death it would be much more efficient to encourage projects to withdraw immediately with some incentive rather than allowing them to utilize the maximum timeframes allowed under the previous iterations of the Tariff.

C14 projects do not share the same concerns with cost shifting and PNUs that that the PTOs have raised for earlier-queued projects. C14 Phase 1 also did not establish project MCE. C14 still has a significant amount of project MWs in it, the majority of which cannot receive TPD allocations due to the mismatch of available TPD capacity and projects seeking new allocations. It would be significantly more efficient to encourage C14 projects to withdraw before 2024 TPD allocations to ensure that only the most viable projects are considered first in this allocation. If C14 projects are not incentivized to withdraw early, it would be prudent for all projects to seek TPD allocations regardless of their viability in order to maximize the value of these projects either for offtake or sale. This could result in multiple years of projects losing allocations and getting re-allocated to other projects which results in greater uncertainty as to which projects are ultimately the most viable moving forward with TPD allocated. We propose that any C14 project that withdraws before the 2024 reassessment be provided a refund of their phase 1 security. This will accelerate the attrition of non-ready projects by providing an immediate withdrawal off ramp.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

We appreciate any improvements in bringing the timing for operational studies forward. We would encourage CAISO to consider the provisional service opportunities provided by other ISOs which allow for projects accelerate their projects based on the timing for interconnection facilities and subjecting them operational limitations until other network upgrades are placed into service. We propose that the Limited Operation Study be made available any time.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

We support this alignment between the SGIA and LGIA.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

We believe that the alternative process being proposed by CAISO provides less clarity as to the rights and ability of a project to delay an ISD and/or COD, especially for circumstances outside of their control. The PTOs in CAISO routinely impose delays that impact a project’s ISD and COD and interconnection customers should be afforded some flexibility to manage issues that arise during the Engineering and Construction phases of the project.

The existing suspension provisions already prohibit projects from suspending their obligations towards shared network upgrades so that a project’s decision to suspend does not interfere with other interconnect projects. CAISO already imposes several restrictions on the ability to seek milestone changes and suspensions and is not proposing the same unrestricted ability to extend milestones (outside of a suspension) that were referenced from PJM’s accepted changes. We do not support this proposal.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

Any projects that receive a transfer of TPD allocation should be subject to the current assignment and retention requirements, as this constitutes new service. The project that TPD is transferred from should not be required to withdraw but is converted to Energy Only and should be unable to seek TPD unless it first achieves commercial operation (like any other current resource). Similarly, the project transferring deliverability would be unable to modify or suspend beyond the 3-year timeframe from its original GIA COD without risking termination.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

Aypa agrees with most of the elements that are being proposed but would suggest some additional changes:

1. The CVC Criteria trigger date should be based on the COD, not the time in queue.
2. Provide 3^rd FS within 90 days of GIA execution
   1. Require GIAs be signed within 90 days of study completion (TPD allocations under current process)
3. 100% site control within 90 days of GIA execution.
4. COD date in GIA within 7 years of queue date OR align with long-term policy upgrades if needed for Deliverability
5. Limit suspensions or modifications to 3 years maximum from GIA COD date.
   1. Only exception would be day-for-day delays on PTO facilities and/or network upgrades the project is dependent on (for ER or TPD service)

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

Aypa does not think there needs to be special treatment for construction sequencing delays. The broader suspension rights that would require all capacity to be online within 3 years of the GIA COD date should be sufficient.

We encourage CAISO and the PTOs to continue exploring business process efficiencies with regards to the MMA process.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

Aypa supports this proposal. We also support requiring the 3^rd IFS within 90 days of GIA execution and requiring projects to execute GIAs within 90 days of completing the TPD allocation process.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

Aypa believes that this is a secondary issue and recommends that CAISO provide more information as to the nature of any project that requests more than 2 MMAs. MMAs are expected to be limited in nature and should primarily consist of updating technical information that changes between the interconnection study and procurement or alignments between construction schedules and the energization of interconnection facilities. A project with 3+ MMAs would likely be withdrawn if COD, suspension, and the CVCs policies are enforced.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

Aypa supports this proposal.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

Aypa requests additional information be provided to justify the proposed deposit and overall cost. This cost appears to be significantly higher than other ISOs and automation and other business process efficiencies should be considered prior to implementing a drastic new deposit/fee.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

Aypa requests clarification on this change as the proposal as written seeks to reduce the number of samples/resolution by half. A proposal to increase the number of samples/resolution would need to be larger than 30, not less.

1. Please provide a summary of your organization’s comments on the revised straw proposal

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) Interconnection Process Enhancements (IPE) 2023 Revised Straw Proposal. The Revised Straw Proposal makes a number of positive revisions that will support the growing number of interconnection requests the CAISO has received and will continue to receive while minimizing the interconnection queue backlog. CalCCA’s primary objective within IPE 2023 is to create a durable process that timely studies and interconnects projects that meet load-serving entities’ (LSE) procurement needs. LSEs, as the primary entities responsible for procuring new clean energy projects to support procurement mandates and state policy goals, should play an active role in informing the CAISO regarding which projects to study. The CAISO’s proposed zonal approach has good potential to meet this objective.

CalCCA supports many elements of the Revised Straw Proposal, including the intent to provide a single source of data to support the zonal approach, the weighting and point system for the LSE interest scoring criterion, including long-lead time (LLT) as a scoring criterion, and maintaining a cap on the number of requests a single developer can submit. To enhance the Revised Straw Proposal, the CAISO should adopt the following recommendations, which are described in detail in the sections that follow:

• The CAISO should provide as much data as early as possible in a single consolidated document to allow interconnection customers and LSEs to make the best use of the data needed to enable the zonal approach.
• The CAISO should adopt its scoring criteria weights and LSE interest point system as proposed in the Revised Straw Proposal.
• The CAISO should work with the California Public Utilities Commission (CPUC) to have the CPUC define LLT resources in each Preferred System Plan (PSP). The CAISO should then tie its definition of LLT for the scoring criteria to the CPUC’s definition of LLT.
• The CAISO should automatically include non-CPUC jurisdictional LSE projects only up to the LSE’s load ratio share of the 150 percent limit.
• To inform the cap on the amount of requests a single developer can submit, the CAISO should assess its total transmission capacity and the developer make-up of cluster 15 requests to determine what level to set the cap to obviate a pivotal supplier issue.
• The CAISO should increase the limitation on the number of projects studied in each zone from 150 percent to at least 200 percent of planned and existing transmission capacity.
• The CAISO should, instead of developing an auction, focus on developing scoring criteria robust enough to rank projects’ viability and minimize occurrences of equal viability scores among projects.
• The CAISO should allow Option B projects within transmission zones.
• The CAISO should adopt its time-in-queue requirements proposal to incentivize lingering projects to withdrawal or move forward in the development process. 

CalCCA thanks the CAISO for its efforts to make LSEs more active participants in determining which interconnection requests will be prioritized for study.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

The CAISO should provide as much data as possible to stakeholders to enable the zonal approach to interconnection. The existing datasets demonstrated in the workshop combined with the heat map the CAISO will develop to comply with the Federal Energy Regulatory Commission (FERC) Order 2023 should provide stakeholders with the information needed to best focus interconnection requests and procurement, subject to the recommendations described below:

First, the CAISO should aim to publish a draft of the data the CAISO will make accessible in the format it plans to use as early as possible prior to the forthcoming 2024 Generator Interconnection and Deliverability Allocation Procedures (GIDAP) process. The CAISO should clearly define the zones and calculate the existing and planned transmission capacity that will be used to limit the number of interconnection requests studied. The CAISO should publicize information about available interconnection capacity at the same granularity that the CAISO will use to set the 150 percent limit on the amount of capacity it will study. This will provide much-needed clarity on the format of data and calibrate the magnitude of interconnection capacity the CAISO will study within its proposed 150 percent threshold.

Second, the CAISO indicates that it will provide information for each interconnection area in a single consolidated document for ease of reference.[1] This is critical to allowing interconnection customers and LSEs to make the best use of the data by ensuring all the information needed is consistent and can be found in one place.

Finally, CalCCA thanks the CAISO for posting an updated presentation on existing projects in the queue available for near-term interconnection.[2] To aid in LSEs’ evaluation of projects in the interconnection queue, the CAISO should regularly update this presentation and post it for stakeholder review. This information can help guide LSEs toward projects that require no (or minimal) upgrades.

[1]             Revised Straw Proposal at 23.

[2]             https://www.caiso.com/Documents/Briefing-ResourcesAvailable-NearTermInterconnection.pdf.  

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

See responses in sections 4, 5, 6, and 7 below.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

The CAISO proposes a set of scoring criteria that it would use to rank interconnection requests based on their readiness to prioritize requests that the CAISO will study in each transmission zone. Criteria that would indicate readiness include LSE interest, project viability, and system need. The criteria proposed by CAISO will aid in narrowing down interconnection requests to a more manageable level by focusing on the ones that are most viable. CalCCA generally supports the CAISO’s proposed scoring criteria and offers the following four recommendations for improvement:

1. LSE Interest Criteria

CalCCA strongly supports the amount of weight put on the LSE interest scoring criterion, as it will be very important for LSEs to have a say in what projects are studied so that the study process provides LSEs with a sufficient collection of projects that reflect LSEs’ desired resource characteristics and diversity. While the zonal approach is important for identifying the most viable projects, it will limit the options LSEs have for procurement, given not all requests will be studied. To mitigate against unwanted projects taking up space in the queue, it is important that the scoring criteria properly reflect the characteristics LSEs desire as procuring entities. 

The CAISO’s proposed point system will meaningfully differentiate between projects with varying levels of interest and allow LSEs to provide input based upon their own IRPs and preferences. Community Choice Aggregators (CCA), as LSEs and procuring entities, have a good sense of what projects will meet their needs based on their own criteria including technology, location, and price, and such projects are subject to approval by the CCA’s board. Allowing CCAs to provide input into projects’ viability rating will ensure CCA resource planning and procurement activities are aligned with the CAISO interconnection study process.

2. LLT Resource Criteria

The CAISO proposes to give points to interconnection requests that will address system needs, including the need for LLT resources. In defining LLT resource for the purpose of assigning points, the CAISO should work with the CPUC to have the CPUC define LLT resources in each PSP. This definition should reflect actually needing a long period of time, such as five years or more, to construct from the initial proposal, not inclusive of the period spent in the CAISO interconnection queue.

In addition, this category should include priority for resource types that are needed, as defined by the CPUC in its IRP process, but underrepresented in the CAISO queue. The CPUC should determine the eligibility of this category by comparing the representation of technologies in the interconnection queue to the resource types identified in the PSP as necessary to meet state decarbonization and reliability targets. As an example, if the CPUC compared the megawatts of in-development and generic resources by technology in the most recent PSP to the megawatts of resources in the interconnection queue with a completed Phase II study, it would have found deficiencies in onshore wind, offshore wind, geothermal, and biomass. It could accordingly designate those technologies as LLT for the next queue with the aim of alleviating any deficiency. As with the rest of the PSP process, the designation of LLT resources should be part of a public process and incorporate comments from stakeholders.

The CAISO should then tie its definition of LLT for the scoring criteria directly to the CPUC’s definition of LLT. This will ensure LLT resources are prioritized consistent with the CPUC’s identified need and, by extension, LSEs’ procurement activities. The CAISO should assign LLT resource points to interconnection requests that fit the above definition regardless of the procuring entity, meaning LLT resources procured by a central procurement entity, by groups of LSEs, or by a single LSE would receive points.

3. Non-CPUC Jurisdictional LSEs

The CAISO proposes to “automatically include any project that a non-CPUC jurisdictional LSE demonstrates is a preferred resource in its resource plan that has been approved by its Local Regulatory Authority (or where no approval is required).”[1] This would allow projects that are identified in non-CPUC jurisdictional LSE plans to bypass the scoring criteria and automatically be included in the proposed 150 percent cap on capacity that the CAISO studies. CalCCA previously expressed concern with this approach, in part because it would allow non-CPUC jurisdictional LSEs’ projects to crowd out projects that have to go through the scoring criteria if they take up more than their share of the 150 percent limit on the amount of interconnection requests the CAISO would study.

 Recognizing that non-CPUC jurisdictional LSEs make up a relatively small amount of CAISO load, and that their projects typically have already progressed through the LSEs’ procurement processes at the time of the interconnection study, [2] CalCCA could support the CAISO’s proposal to automatically study non-CPUC jurisdictional LSEs’ projects with limitations. Specifically, the CAISO should automatically include non-CPUC jurisdictional LSE projects only up to its load ratio share of the 150 percent limit. This approach would allow non-CPUC jurisdictional LSEs’ projects to be studied while also preventing their projects from pushing out projects that have to go through the scoring criteria. The CAISO should also clarify that if non-CPUC jurisdictional LSEs receive auto-inclusion for their projects, they would not also participate in LSE interest scoring. This would ensure no LSE has more control over the queue than others.

4. Developer Cap

The CAISO proposes to limit the number of requests a developer may submit in a cluster window to 25 percent of available transmission capacity across the CAISO footprint. While developers continue to express concern with the 25 percent cap given its potential to restrict the amount of their requests studied, the CAISO needs a mechanism to ensure the pool of projects selected to be studied come from a diverse set of developers. CalCCA, therefore, supports the 25 percent cap for a single developer because it is intended to prevent one or a few developers from having the ability to exert market power when contracting with LSEs for capacity within the transmission zones.  

To balance the concerns of the developers on the restrictiveness of the proposal and the concerns of CalCCA and the CAISO regarding the potential ability for limited competition among developers selected to be studied, the CAISO should (1) set a cap on the number of interconnection requests that can be from a single developer and (2) adjust the cap after assessing its total transmission capacity (plus an adder that aligns with the amount of capacity the CAISO will study in the interconnection study process, e.g. 150 percent) and the developer make-up of cluster 15 requests to determine what level of cap would obviate a pivotal supplier issue. The right level to set the cap for individual developer requests will depend on the cap chosen for the number of interconnection requests to study relative to existing and planned transmission capacity. The CAISO may find that the 25 percent cap is necessary to prevent the potential for too few developers’ requests studied or it may find that the cap could be raised and still provide for adequate competition. Either way, CalCCA supports setting the cap at the right level to ensure adequate competition.

[1]             Revised Straw Proposal at 37.

[2]             Id.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

CalCCA supports a zonal approach where the CAISO selects the most viable projects to study within each zone. However, only studying 150 percent of the planned or existing transmission capacity, as the CAISO proposes, is too little, considering the transmission system is planned based upon projected resource portfolios that LSEs will procure. If the CAISO only studies 1.5X the amount of capacity needed to support reliability and policy goals, LSEs would experience significantly reduced bids in their request for offers (RFOs) relative to their procurement needs. Past experience also shows that many projects do not ultimately proceed in the development process and may drop out after they submit their interconnection requests but before the contracting process. While some projects may offer to multiple LSEs, multiple LSEs may have interest in the same project, too. The CAISO should increase the limitation on the number of projects studied in each zone from 150 percent to at least 200 percent.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

The CAISO proposes to conduct a market-clearing, sealed-bid auction for the right to be studied if excess proposed capacity exists after applying the viability criteria and projects are deemed equal in viability rating. In previous comments, CalCCA expressed various concerns with the auction mechanism. In particular, an auction could favor larger developers with deeper pockets and result in studying the highest bidding projects rather than the most ready projects.[1] The auction process also seems to introduce a significant amount of administrative burden that could be better spent on evaluating project viability. Given these concerns, the CAISO should, instead of developing an auction, focus on developing scoring criteria robust enough to rank projects’ viability and minimize occurrences of equal viability scores among projects. If projects do receive the same viability score, the CAISO should study all tied projects.

[1] https://stakeholdercenter.caiso.com/Comments/AllComments/1198f707-8b68-4560-bb9a-7dd64ea2b57d#org-d8462b15-4465-49d6-a464-9df1f71ab2ce.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

The CAISO proposes that only projects interconnecting in areas with no available or planned transmission plan deliverability capacity would be eligible to use Option B. Option B would not be available for projects that did not score enough to be studied in the transmission zones with planned or available capacity. The CAISO should modify this proposal to allow projects within transmission zones to elect to move forward as Option B.

If projects in transmission zones would like to fund their own area network upgrades rather than receive reimbursement, they should be able to do so. While the CAISO suggests that allowing projects in transmission zones to proceed under Option B would be counterproductive to solving the issue of studying capacity levels so high that the study results lose accuracy, it is not certain this would be the result. Option B is not used today under the current rules, and it is unclear whether the proposed changes to the Option B rules would result in an influx of Option B projects. If the CAISO does see an influx of Option B projects after implementation, it could consider requiring projects within transmission zones to elect Option B upfront (rather than waiting to see if they score high enough to be studied as Option A) or limiting Option B projects within transmission zones using the same scoring criteria to rank Option A projects.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

CalCCA has no comments at this time.  

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

CalCCA has no comments at this time.  

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

CalCCA has no comments at this time.  

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

CalCCA has no comments at this time.  

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

CalCCA has no comments at this time.  

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

CalCCA has no comments at this time.  

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

CalCCA agrees with the CAISO that “[a]dditional straightforward milestones, black-and-white requirements, and universal time-in-queue limitations will help manage older projects, provide clear and transparent rules, and prevent projects from stagnating.”[1] The CAISO should, therefore, adopt its proposal to enforce time-in-queue requirements for projects in the queue without executed generator interconnection agreements, including the revisions in the Revised Straw Proposal.

[1]             Revised Straw Proposal at 74.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

CalCCA has no comments at this time.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

CalCCA has no comments at this time.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

CalCCA has no comments at this time.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

CalCCA has no comments at this time.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

CalCCA has no comments at this time.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

CalCCA has no comments at this time.

1. Please provide a summary of your organization’s comments on the revised straw proposal

CPUC Staff appreciate the consideration and ongoing efforts of the ISO to improve the interconnection process through the robust stakeholder process and release of the 2023 Interconnection Process Enhancements Track 2 Revised Straw Proposal (Revised Straw Proposal).  

While we are supportive of many of the reforms ISO is considering that would expedite the interconnection process and reduce the currently excessive interconnection burden on ISO staff and the developers, CPUC staff urge the ISO to prioritize implementation of reforms that can ultimately lead to lower costs for ratepayers, albeit indirectly by changing the rules of interconnection for resources to interconnect to the grid. CPUC staff note that the Section 1.1.1. Principles part of the Interconnection Process Enhancements proposal may imply, but does not currently expressly identify, minimizing ratepayer costs for new generation and storage as an objective.  

CPUC staff generally support the revisions made and support the direction the ISO is going in with the zonal approach, proposed efforts to expedite the interconnection study process and clean the queue, and process limitations and requirements to streamline ISO review processes to be more manageable for staff. Priority should be given to the reforms that have the highest likelihood of decreasing overall project costs, by minimizing uncertainty, increasing transparency and fairness.  

Specifically, CPUC staff provides the following comments:  

• CPUC staff support the ISO efforts to improve data accessibility and provide more transparency to stakeholders to allow for developers to provide more informed and viable interconnection requests. 

• CPUC staff support the ISO’s proposed reforms to the interconnection request intake process. 

• CPUC staff support improved transparency and posting of the parent company behind each interconnection request (2.3).  

• CPUC staff support the zonal approach (2.1).  

• CPUC staff support the viability scoring criteria (2.4).  

• Due to high rates of project failures, which could persist, CPUC staff would also support raising the 150% to 200-250%. (2.5.1)  

• CPUC staff support the proposed zonal auction (2.5.2).  

• CPUC staff agree with the ISO’s concern of financial risk caused by a one-time withdrawal opportunity and support further analysis of this proposal in a “Track 3” of the IPE (3.1).  

• CPUC staff support the proposed limitations to Transmission Plan Deliverability (TPD) transferability (3.5). 

• CPUC staff support the time in queue and viability criteria requirements (3.6). 

• CPUC support the ISO’s proposal to reduce the volume of modification requests to a workable level for ISO staff (3.7).  

• CPUC staff support the proposed shared network upgrade postings and payments process (3.8). 

• CPUC staff support the proposed requirement for the PTO to start work once the Notice to Proceed (NTP) and 3rd IFS posting is received (3.10). 

• CPUC staff support the increased sampling rate proposed for Phase Angle Measurment Units (PMUs) (3.12).  

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

CPUC staff support the ISO efforts to improve data accessibility and increase transparency to stakeholders in order for interconnection customers to provide more informed and viable interconnection requests that.  

Further, as discussed in section 2.3, CPUC staff support more transparency in identifying the name of the applicant company, as well as the parent company, supporting each queue request. The LGIA is a public document filed at FERC and identifies the name of the applicant entity sponsoring the interconnection request queue, so this information is already publicly available and for increased transparency should be included in the interconnection queue report.   

Currently, though, the LGIA may only identify a project specific Limited Liability Corporation (LLC) as an applicant, and CPUC staff support identification of the parent company of the LLC, and further recommend that this includes a requirement to notify the CAISO when an applicant corporate entity changes ownership.  CPUC staff support the ISO requiring interconnection request project applicants (sponsors) to state the parent company identified on their publicly filed articles of incorporation. Typically, an LLC is legally required to be registered in the state in which it conducts business. This means that the State has a public record of who owns the Corporation, and therefore it should be straightforward for the ISO to require the LLC to self-identify (and be subject to verification) the legal parent company of an LLC. (See for example, State of California Secretary of State website: https://bizfileonline.sos.ca.gov/search/business). 

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

CPUC staff support the ISO’s proposed reforms to the interconnection request intake process. 

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

CPUC staff support the ISO’s proposed scoring criteria as well as the distribution factor (DFAX) as a tiebreaker when the selection process is near the 150% threshold and two or more projects are tied (see question 9 for CPUC staff comment on 150% threshold).  CPUC staff support proposed criteria made through the stakeholder process and using the auction process bids only after viability scores and DFAX are completed. CPUC staff support the auction process only being used for projects that are deemed equal in viability rating and cause the total MW for a zone to cross the 150% capacity limit for that zone will participate in the auction.    

The scoring criteria may add additional complexities for the ISO to implement and some flexibility for modifying the criteria should be built into the tariff for instances in which the ISO finds the review for each of these items too cumbersome. For example, CPUC staff has experience reviewing similar documentation to verify milestones for IRP compliance and know it can be challenging. 

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

CPUC staff support the ISO proposal to analyze individual transmission zones with sub-zonal constraints, filling each sub zone until an upgrade is triggered, and “freezing” any additional interconnection in that zone and for other projects seeking to interconnect in that area to be eligible to interconnect in the broader zone until 150% of the capacity is reached.  Due to high rates of project failures, which could persist, CPUC staff would also support raising the 150% to 200-250%. 

To ensure competition in each zone, CPUC staff also support a minimum number of parent companies per zone. For example, a minimum of 3 different parent companies are selected for every 1000 MW of transmission capacity per zone. If there is more than 1000 MW available, there should be at least 3 parent companies per 1000 MWs of incremental capacity available. 

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

CPUC staff support the ISO’s proposed zonal auction approach as a backup mechanism that is only conducted if there is excess proposed capacity after applying viability scoring criteria, and applicable only to projects that are deemed equal in viability rating and cause the total MW for a zone to cross the zone’s capacity limit. 

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

No comment at this time.  

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

No comment at this time.  

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

CPUC staff agree with the ISO’s concern regarding the potential financial risk that may be placed on PTOs due to the one-time withdrawal opportunity and returning the unused portion of their interconnection financial security postings and site-exclusivity deposits. CPUC staff would support a withdrawal opportunity and incentive that places less financial risk on PTOs and ratepayers. 

CPUC staff support the desire to reduce the existing queue volumes and eliminate stale and unnecessary network upgrades. In the interest of time, CPUC staff would support the ISO removing the one-time withdrawal option from the Revised Straw Proposal and moving it into the potential “Track 3” of the IPE as well as using a Track 3 to consider other incentive mechanisms to promote the reduction of volume of projects in the queue. Moving this to Track 3 of the IPE process would allow for more time to assess the scale of anticipated withdrawal requests, potentially through a Request for Information from developers and the CAISO sharing more information on the existing financing of potential at risk upgrades and help determine the scale of the financial risk that could result from this proposal. Without this information and funding secured for the triggered upgrades, it would be premature to approve a one-time withdrawal. CPUC staff understand the urgency for cleaning up the queue and would support an expedited timeline for its consideration in Track 3.  

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

No comment at this time.  

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

No comment at this time.  

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

CPUC staff support the proposed limitations to TPD transferability. The ISO’s proposal allows for the most viable projects to secure deliverability though transfers while ensuring the transfer process does not cause a high volume of projects to remain in the queue without deliverability and no path forward after the transfer process. CPUC staff support the transfer process not overriding the delivery retention requirements and in general support preventing any loopholes for timing constraints through the transfer process.  

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

CPUC staff support the unavoidable time-in-queue requirement and the requirement for projects to demonstrate commercial viability criteria and distinct progress on an annual basis if they are to remain in the queue beyond 7 years.  

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

CPUC staff support the ISO’s proposal to reduce the volume of modification requests to a workable level for ISO staff.  

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

CPUC staff support the ISO’s proposal to require that if one interconnection customer is ready to proceed with construction of a shared network upgrade, then all participants in that upgrade must post the needed security for and fully fund that upgrade as applicable, regardless of their deliverability status, whether they are parked, or whether they have executed a GIA. This process will help streamline the queue by expediting the start time for shared network upgrades and trigger the withdraw of stagnant projects.  

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

No comment at this time. 

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

CPUC staff support the Revised Straw Proposal’s requirement for an NTP to be included in the GIA, and the requirement that PTOs move forward with network upgrades once the NTP and 3rd IFS posting is received and meet the Initial Synchronization Date. CPUC staff support the requirement for the PTO to notify the interconnection customer and ISO when activity has begun on the network upgrade and interconnection facilities and requiring it to be within 30 business days after receiving the NTP and 3rd IFS posting. 

 CPUC staff support this proposed increase in transparency to the interconnection customer and enforced timelines to support interconnection customers to meet the dates in their PPA requirements.  

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

No comment at this time. 

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

CPUC staff support this refinement.  

1. Please provide a summary of your organization’s comments on the revised straw proposal

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) provides these comments on the California Independent System Operator’s (CAISO Interconnection Process Enhancements), 2023 Phase 2 Revised Straw Proposal.? Cal Advocates is an independent consumer advocate with a mandate to obtain the lowest possible rates for utility services, consistent with reliable and safe service levels, and the state’s environmental goals.[1]

Cal Advocates strongly supports the CAISO’s first principle, which bases interconnection reform on the transmission zonal approach.  The zonal approach prioritizes interconnection projects that seek to utilize available capacity and are located in transmission zones where there are planning transmission capacity additions approved in the CAISO Transmission Planning Process (TPP) and as established by state and local regulatory authority resource planning authorities.[2]  Given that the CAISO TPP proposes a zonal approach to planning for the resources in the portfolio provided by the California Public Utilities Commission (CPUC), it also makes sense to align the resource planning portfolios and interconnection process enhancements with the transmission zones.

[1] Public Utilities Code Section 309.5.

[2] CAISO Revised Straw-Proposal-Interconnection-Process-Enhancements 2023 Initiative - Track 2, Dec 12, 2023, p. 11, http://www.caiso.com/InitiativeDocuments/Revised-Straw-Proposal-Interconnection-Process-Enhancements-2023-Dec192023%20.pdf

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Cal Advocates supports the CAISO’s proposal to increase the accessibility of grid information by consolidating the available information, along with lists of substations and constraints in each transmission zone into a single user accessible data source,  .  Cal Advocates also supports the creation of Federal Energy Regulatory Commission (FERC) Order 2023 mandated Heat Maps visually showing generation interconnection transmission capacity availability.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Cal Advocates supports the CAISO’s proposed interconnection process enhancements that align with its proposal principles, while also addressing identified problems related to interconnection request intake and queue management[1].  Addressing these critical issues will more efficiently utilize CAISO staff resources so that staff do not need to review a large number of largely non-viable proposed resource projects seeking to interconnect to the grid.  Historically only 13% of projects in the CAISO interconnection queue reaches commercial operation. [2}

[1] CAISO Revised Straw-Proposal-Interconnection-Process-Enhancements 2023 Initiative - Track 2, Dec 12, 2023, pp. 11,12. 

[2] Lawerence Berkeley National Lab Report, “Queued Up: Characteristics of Power Plants Seeking Transmission Interconnection As of the End of 2022”, May 2023.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

No comment at this time.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

No comment at this time.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

No comment at this time.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

No comment at this time.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

No comment at this time.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

Cal Advocates generally supports the CAISO’s efforts to address projects in the interconnection queue that are not progressing towards completion in a timely manner. In particular,  Cal Advocates supports the one-time withdrawal opportunity proposal, since its adoption would reduce the number of non-viable projects that currently clog the queue.  Reducing the number of non-viable projects in the queue through the one-time withdrawal opportunity would allow more viable projects to move more quickly to a Commercial Operation Date.  Moreover, allowing non-viable projects to remain in the queue risks overbuilding the transmission grid in order to serve both non-viable projects and newer proposed projects.  Overbuilding the transmission grid leads to unnecessary and excessive ratepayer costs.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

No comment at this time.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comment at this time.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

No comment at this time.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

No comment at this time.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

Cal Advocates supports the CAISO’s implementation of FERC Order 2023 that implements strict commercial viability criteria and time-in-queue requirements for all projects in the queue.  By implementing this firm commercial viability criteria and addressing queue management issues, the CAISO could utilize its resources more efficiently by reducing staff resources review and analysis of non-viable projects, which in turn should lower costs to ratepayers.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

Cal Advocates supports the CAISO proposal to improve the efficiency of the Timing for Construction Sequencing Requests process.  Under the current Generation Interconnection Agreement and Procedures, a Resource Developer may submit Material Modifications for their proposed project to the CAISO interconnection queue.  Material Modification are those modifications that have a material impact on the cost or timing of any Interconnection Request.  Material Modifications may include a decrease of electrical output (MW) of the proposed project, a modification of the technical parameters associated with the Large Generating Facility technology, or a modification of the interconnection configuration.

The CAISO performs a Material Modification Assessment (MMA) along with the appropriate Participating Transmission Owner (PTO).  Currently, Resource Developers must pay a $10,000 deposit for the cost of performing the MMA. The CAISO notes that sometimes the deposit is insufficient.[1] In order to reduce the number of Material Modification requests submitted by Resource Developers, the CAISO proposes to increase the deposit fee for each MMA submission to $30,000. The CAISO also  proposes to improve the MMA process transparency by increasing communication between the CAISO, PTO and Resource Developer in order to reduce validation review times for project modification requests.

Adopting the CAISO’s proposal to address Construction Sequence Request issue should reduce staff resources spent implementing transmission interconnection projects that are being modified.  In addition by addressing this Construction Sequence Requests issue this should improve the Resource Developer’s ability to meet the project Commercial Operation Date.

[1] CAISO Revised Straw-Proposal-Interconnection-Process-Enhancements 2023 Initiative - Track 2, Dec 12, 2023, p. 82 

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

Cal Advocates supports the CAISO efforts to improve the Shared Network Upgrade Postings and Payments process. Resource Developers (Interconnection Customers) that have submitted interconnection requests have raised concerns that the PTOs are not meeting the network upgrade milestone dates, particularly with shared network upgrades. In some instances, the PTOs are waiting until all or the majority of the interconnection customers (parties) responsible for the shared network upgrade have provided their Notice to Proceed (NTP).  This means that a resource project otherwise ready to go is delayed because the PTO is waiting for the NTP for all parties, or the majority of the parties.  CAISO’s proposed is that if one interconnection customer is ready to proceed with construction of a shared network upgrade, then all participants (parties) in that upgrade must post the needed security for and fully fund that upgrade as applicable.  This should occur regardless of their deliverability status or whether the interconnection customer has executed a GIA.

In the Revised Draft Proposal, CAISO, in coordination with the PTO, proposes to officially notify all developers whose projects were allocated a pro-rata share of the same Shared Network Upgrade that they will be required to make the 3rd Interconnection Financial Security (IFS) posting for their pro-rata share of the shared network upgrade.  If the project is on hold, the developer would need to execute an engineering and procurement agreement for the shared network upgrades with the PTO within 90 days or the project would be withdrawn. If the Generation Interconnection Agreement (GIA) is not executed, the interconnection customer will have 90 days to execute the GIA or the project application will be withdrawn from the interconnection queue. As proposed, the IFS and first payment would be due at the time of execution and payments would commence. Failure to post payment is grounds for termination of the engineering and procurement agreement or GIA.  If the GIA is already executed, the interconnection customer would have 60 days from the date of notification to post the IFS for the shared network upgrade and make payments to the PTO.

Cal Advocates supports the share network upgrade proposal in the CAISO’s Revised Draft Proposal. Its adoption should help reduce CAISO resources spent implementing non-viable transmission interconnection projects that may not be able to fund the necessary network upgrades the project requires.  More efficient use of CAISO resources should lower costs to ratepayers.  In addition, improvements in this process should lead to more certainty in the completion of generation interconnection transmission grid upgrades and deliverability of new resources to support customer loads.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

Cal Advocates supports the CAISO efforts to improve the efficiency of the Timing of the GIA Amendments process.  The CAISO reports that the Generation Interconnection Agreement (GIA) must be changed each time an Interconnection Customer (Resource Developer) submits a Material Modification for a proposed project.  Continuous revisions to projects through the Material Modification Assessment (MMA) process then require that contract negotiators for the Interconnection Customer, CAISO, and Participating Transmission Owner (PTO) work together to update changes to the GIA.  PTOs and CAISO are required to continually amend the GIAs.  From 2021 to date, the CAISO and PTOs have processed 376 MMAs. To reduce this time-consuming effort,  CAISO’s Straw Proposal proposes that the MMA results report that incorporates any change to scope, schedule, or cost would be the binding document and would only be amended once.  By addressing the Timing of GIA Amendments issue, CAISO resources would be more efficiently utilized which in turn lowers costs to ratepayers.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

Cal Advocates supports the CAISO efforts to improve the Notification to Participating Transmission Owner (PTO) to Commence Network Upgrades with the First Notice to Proceed (NTP) process. The CAISO.s Revised Straw Proposal states that Interconnection Customers (Resource Developers who have submitted Interconnection Requests) are concerned that once a Notice to Proceed (NTP) is provided to the Participating Transmission Owner (PTO), it may be months before the PTO actually starts engineering, design, or project management of the network upgrade.  This can result in the network upgrade being delayed from the original online date in the GIA. Such an outcome could then impair the ability of the interconnection customer to meet the timeline in its Power Purchase Agreements (PPAs), and subject the Interconnection Customer to financial penalties.

The CAISO’s Revised Straw Proposal proposes that a specific date for the NTP must be included in the GIA.  If a Material Modification Assessment (MMA) modifies the NTP date then the new date will be included in the MMA report that is then an amendment to the GIA.  The CAISO proposes that the PTOs must move forward once the NTP and 3^rd Interconnection Financial Security (IFS) posting is received and to meet the Initial Synchronization Date in the GIA thereby allowing interconnection customers to meet their PPA requirements.  This will allow milestones to be specifically tracked.  The CAISO also proposes that a new milestone be added requiring the PTO to notify the interconnection customer and CAISO when activity has begun on the network upgrade and interconnection facilities. This notification should be within 30 business days after receiving the NTP and 3rd IFS posting.

Addressing the PTO starting work on NTPs issue, as the CAISO proposes, should improve  communication between the CAISO, the PTOs, and interconnection customer and should increase transparency, which should lead to more certainty in the completion of generation interconnection transmission grid upgrades and deliverability of new resources to support customer loads.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

Cal Advocates supports the CAISO efforts to add the Deposit for CAISO implementation of interconnection projects process which requires a $100,000 deposit by the resource project developer.  The CAISO notes that following the study process, a project starts the implementation process as it progresses to commercial operation.  Once the project commences engineering, design, procurement, construction, etc., the PTOs charge the Interconnection Customers for associated costs.  However, costs incurred by the CAISO are paid through the Grid Management Charge by Scheduling Coordinators and are not charged to interconnections customers consistent with cost causation. In addition, interconnection customers have noted that the CAISO has insufficient resources to respond to all the needs of the interconnection customers for project management, facilitating communications with the PTOs, and the New Resource Implementation process. The CAISO states that it requires that additional resource project-specific funds for post-GIA work to be charged to the Interconnection Customer (Resource Developer).  The CAISO is proposing that an up-front deposit be made at the time of execution of the GIA that would be drawn down based on the actual cost of working on the Interconnection Customer’s project.  The CAISO proposes that upon execution of the GIA, the Interconnection Customer will provide a $100,000 deposit to the CAISO to compensate the CAISO for the project management and new resource implementation processes for each project in the queue.

Addressing this resource project interconnection implementation deposit issue as the CAISO recommends would require Interconnection Customers to fund the CAISO resource costs required to implement generation interconnection projects and associated transmission grid upgrades.  This, in turn, should lower costs to ratepayers.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comment at this time.

1. Please provide a summary of your organization’s comments on the revised straw proposal

CalWEA continues to support its ”Proposal to Effectively Address the Queue Overload While Preserving Open Access, Competition, and Resource Diversity” as presented at the July 11, 2023, stakeholder meeting, with slight modifications, some of which are to conform to FERC’s Order 2023 framework.  In summary:

1. No artificial limit should be placed on the size or location of submitted interconnection applications.  However, limiting the number of applications submitted by each unaffiliated company is appropriate, as noted below under question 3.  CAISO's compliance with FERC Order 2023 (e.g., site control requirements) could prevent what FERC considers “frivolous” interconnection applications.
2. All projects entering a queue cluster should be eligible for a scoping meeting and receive needed preliminary information on their interconnection requirements so that they can determine whether it would make sense to withdraw from the queue before the Cluster Study begins. 
3. For its Cluster Study, CAISO (and its PTOs) should study a reasonable volume of generation interconnection capacity in each of the study zones in which interconnection applications have entered the study process, rather than studying all the queued generation. The study can heavily rely on previous studies. The deliverability assessment should focus on the interconnection requests not behind any known transmission constraints. The reliability assessment should focus on short circuit duty and substation evaluation. 
4. The Cluster Study should therefore produce reasonable interconnection requirements, including cost and timelines, for each generation pocket.  These costs and timelines should be assigned as a proxy to all projects in each gen pocket according to a formula to be developed.
5. The proxy interconnection requirements (cost and timeline) assigned by CAISO to projects included in the Cluster Study would be shared with all interested offtakers (e.g., LSEs) for consideration.  Offtakers would then be encouraged to directly, or via the project, share their interest in studied projects with CAISO.  CAISO would use such input as one of several measures to determine the commercial viability of projects included in the Cluster Study, based on the formula for scoring commercial viability.  This project viability scoring process would require that the time between the Cluster Study and the Cluster Restudy be extended beyond the FERC Order 2023 45-day period to potentially a 3-month period.
6. CAISO would allow projects with a commercial viability score higher than a certain threshold to enter the Cluster Restudy.  All location-constrained resources should be exempt from any scoring mechanism that involves project locations based on CAISO-selected study zones.
7. The projects that do not qualify to enter the Cluster Restudy based on their commercial viability score would be withdrawn from the queue unless they are willing to post a non-refundable IFS deposit based on their full proxy interconnection cost.
8. CAISO would perform the Cluster Restudy studies using its existing protocols based on the projects that enter the Cluster Restudy.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

CAISO clarified in the Dec 19th call that available transmission capacity is determined by constraints. CAISO termed the gen pockets behind constraints “sub-zones” and acknowledged that sub-zones could partially overlap with each other, and a sub-zone could cross multiple study zones. Thus, the use of "zone" or "area" in the proposal is very confusing as treatment of interconnection requests based on available transmission capacity at the zonal level is not possible. Available capacity will be POI-specific. CalWEA does not support the proposal but, if CAISO moves forward, we ask CAISO to establish the policy based on the POI and its transmission constraints as follows:

In any zones, the POIs fall into one of the three categories below:

• behind constraints without available capacity; these can move forward only as Option B or Energy Only.
• behind constraints with available capacity; projects filling up to 150% of available capacity will be studied as Option A.
• not behind any known constraints.

This clarification is consistent with CAISO’s Dec 19th presentation to study up to 150% of available capacity.

CAISO does not address how to set capacity limits for POIs that are not behind any known constraints. We suggest that all projects at such POIs be included in the study process.

CalWEA urges CAISO to allow Energy Only interconnection requests anywhere in its BAA. For example, since CAISO proposes that filling up 150% transmission capacity should not apply to EO projects, that means that all EO projects are eligible for study regardless of where they are located.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

ISO should limit the number of requests by any developer and its affiliates, and should not limit the amount of capacity requested, which would artificially curb project scale efficiencies. For example, no affiliated developers could have more than 10 IRs across the CAISO footprint and not more than 3 in a study area. 

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

CalWEA strongly believes that scoring projects absent transmission upgrade cost and timing estimates will not be meaningful. CalWEA continues to support scoring after the cluster study provides cost and time estimates for needed upgrades, per our proposal outlined under question 1, above.

Regarding the specifics of the scoring criteria, we have the following comments:

• Re “LSE Interest” – LSEs cannot meaningfully determine interest in projects without a reasonably accurate estimate of upgrade costs and timelines. 
• Re “Project viability / Demonstration of business partnership with future supply of major equipment” – this criterion does not necessarily indicate the viability of a particular site since major supply agreements with developers can be global and not site-specific.
• Re “Project viability / Engineering design plan” – As such design plans are only a matter of expense, this scoring criterion would only increase the cost of IR development without differentiating the viability of projects.
• Re “Project viability / Expansion of existing facilities and surplus gen-tie capacity” – This criterion appears to assume that the expansion is being done by the owner of the existing facility.  This should be clarified, as expansion of a site could conflict with the existing project or substation.  Further, more points should be awarded where surplus gen-tie capacity is available.  Thus, we suggest replacing the 30 and 40 points for these two sub-criteria with 20 and 50 points. If there is only a letter of intent between the existing facility and the expanded resource, the IR should receive 20 points, rather than 30.  If there is surplus gen-tie capacity and an executed gen-tie sharing agreement, 50 points should be awarded and otherwise 0 points.
• Re “System Need / Long-lead-time resources” – Resources included in the CPUC portfolio that do not require new transmission should also get 60 points.
• Re “Distribution Factor / lowest DFAX as tie-breaker” – Projects are generally situated behind multiple different constraints, and therefore assessing DFAX will be very complex and is not suitable for project scoring purposes. Instead, DFAX should be considered in TPD allocation where CAISO should develop an algorithm that prioritizes the highest RA value based on the available transmission capacity. 

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

The language in the Dec 19th presentation is completely different from the very confusing language in the revised straw proposal. CalWEA's comments therefore address the presentation material. However, the proposed approach will provide too rough an approximation of available transmission capacity because it will not evaluate various impacts on the constraints from different POIs. Also, CAISO does not address how it will set capacity limits for POIs that are not behind any known constraints. Please see comments under question 2 above.

Regarding 150% of the capacity, CalWEA continues to support a higher threshold, such as 200%, for these reasons:

1. The available transmission capacity published by CAISO is lagging the most recent TPD allocation (at least for QC15). The ICs will need to make judgements in a too-short period of time regarding whether to pursue certain IRs in the next cluster window.
2. The available transmission capacity is a rough estimate that doesn't account for different impacts from a different set of POIs.
3. Scoring projects in an early stage of development could lead to uneconomic projects being picked and to overlooking potentially viable projects. Keeping a larger volume of projects in the study process will allow for self-correction of the imperfect scoring approach and potentially greater competition.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

The auction approach will raise project development costs, favor deep-pocket developers, and reduce competition.

If CAISO proceeds with the proposed approach, CalWEA suggests that CAISO refund the auction financial security if the project doesn’t receive a TPD allocation and has to withdraw

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

Option B should be allowed at all POIs without available capacity. See comments to question 2 above.

Regarding ADNUs being approved in TPP, an Option B project should not be required to seek a TPD allocation for an ADNU that it has already posted a deposit for; it should get the TPD immediately under the condition that its posting be refunded only once the project is operational. 

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

Support. These studies provide little value to developers. 

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

CalWEA supports CAISO's previous proposal. Given that network upgrade costs are fully refundable, SCE's concerns are unfounded. At a minimum, projects without shared NU and without Assigned NU that are Potential NU for later projects should be given the one-time withdrawal opportunity.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

CAISO should allow non-binding LOS any time upon IC request and at the expense of the IC. 

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

CalWEA supports the requirements.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

No comment.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

CalWEA opposes this proposal. The remaining project may be reduced in size for commercial reasons, but it should be allowed to develop as an EO resource at the original size regardless of PPA status. 

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

No comment.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

Section 3.7 is “Project modification request policy updates.” CalWEA supports the policy updates. 

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

No comment.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

Support. The adoption of the approach could be PTO-specific, i.e., a PTO could amend the GIA sooner. 

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

Support.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

CAISO should request that FERC allow the use of the study deposit for this purpose instead of requiring a new deposit. If FERC rejects the request, the additional deposit should be $50,000k or less. 

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comment.  However, we note that CAISO may have intended to suggest a PMU resolution requirement of 60 samples per second.

1. Please provide a summary of your organization’s comments on the revised straw proposal

The California Energy Storage Alliance (CESA) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Revised Straw Proposal.  The CAISO proposal continues to discuss the zonal process in the abstract.  It is important that CAISO begin to discuss the actual zonal limits that will be imposed on Cluster 15 and when such limit information will be available to stakeholders.  Based on discussions at both the December 18^th and December 19^th workshops, absent significant policy drive transmission upgrades out of the 2023-2024 Transmission Plan, there may be extremely limited available capacity in the zones to accept Cluster 15 projects to be studied as Cluster 14 could consume the available deliverability.  The CAISO must communicate a timeline for Cluster 15 outlining when availability data and limits will be established and when final interconnection requests will be submitted, reviewed, and accepted by the CAISO. Lastly, CESA is concerned that the zonal approach is actually a far more granular, constraint-based limitation (see slide 21 of December 19^th presentation) which makes the need for CAISO to provide availability data more imperative.  Developers are investing significant funds to meet the site control requirements introduced by FERC Order No. 2023.  These investments would be in vain if CAISO subsequently rejects the interconnection request because the point of interconnection has no available transmission capability due to a binding transmission constraint.   

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

The CAISO should develop a timeline for when transmission data will be available for stakeholders to assess the potential viability of interconnection requests.  CESA understands that data which impacts the transmission capability becomes available throughout the transmission planning process and interconnection study process; however, the CAISO must clearly establish what data will set the transmission capability limits that will applied to upcoming interconnection requests and provide developers with sufficient lead time to evaluate if their projects have a chance of passing the scoring criteria and being accepted by the CAISO to be studied.

In developing the timeline, the CAISO should consider other related processes, including the TPP and TPD allocation, and reevaluate the interconnection process.  For example, a cutoff date can be determined (i.e. June 1) for assumptions made in the following cluster study once the TPP and TPD allocations are completed. The annual cluster window can then open in September after interconnection customers have time to assess the updated document. Creating a cutoff date for assumptions can also enable the CAISO to determine the MW capacity that will be studied in each zone, which is unknown based on the proposed data thus far.

While the data proposed by the CAISO is useful, the CAISO needs to include information on substation expandability and short circuit values at each CAISO bus to provide interconnection customers with the full picture of the electrical and physical capabilities of the zones.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

CESA continues to oppose the 25% developer cap as proposed.  As requested in prior comments, additional information on the objectives of the 25% developer cap, including underlying analysis of the necessity of such a cap, as well as further discussion on how the cap will be implemented and enforced – are all crucial steps before a transmission capacity cap of any size can be considered.  CESA further notes that the ISO was unable during the conference call to estimate the MW size of the cap.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

CESA supports adding the DFAX impact to differentiate projects with similar scoring criteria. 

CESA reiterates prior comments that additional indications of LSE interest provide little differentiation between the viability of projects given the CPUC portfolio must be achieved to meet state policy objectives and such interest will most likely be non-binding since costs and timing are uncertain.  At a minimum, the weighting provided to LSE interest is too high relative to other scoring criteria categories.  In addition, the process for an interconnection customer receiving LSE interest is unclear.  CESA is concerned that LSEs may bias utility-built projects over other potential interconnection requests.  Also, it is unclear how non-load serving entity interest would be considered in prioritizing projects.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

CESA is unclear as to what the available transmission capability the 150% limit is applied.  For example, if Cluster 14 projects received deliverability via Group D, are the projects removed for the available transmission capability to accept Cluster 15 projects?  It seems appropriate that if a Cluster 14 project has NOT entered into or is negotiating a power purchase agreement, that the available capacity should allow Cluster 15 projects to be studied. Also, how will earlier energy only projects impact the available transmission capability impact future cluster projects from being studied?

As stated in prior comments, the 150% limit should not be seen as a firm limit, but rather it should set the minimum quantity of projects that will be accepted for study.  In the event that there are projects with equal scoring criteria and DFAX which exceed the 150% baseline, all those projects should be studied.  In addition, since non-CPUC jurisdictional load serving entity projects were not considered in the 2022-2023 transmission plan, these projects should not reduce the quantity of projects which can be studied in Cluster 15.  CESA supports that going forward non-CPUC jurisdictional load serving entities will provide similar information as the CPUC portfolio which will be included in the transmission planning process.  Lastly, the 150% limit should be regularly reviewed by the CAISO to ensure the limit does not excessively reduce the number of interconnection requests that can be studied.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

CESA continues to oppose auctions as a tie breaker for projects which cross the transmission capability study threshold.  The benefit of an auction is to allocate scarce resources and provide price discovery of the value of the scarce resources.  This benefit is not applicable to breaking ties as the price formation ignores the willingness to pay of all resources seeking to submit an interconnection study request in the transmission zone.  Also, with the introduction of prioritizing interconnection requests with the same scoring criteria based upon the DFAX, the additional step of requiring additional at-risk study deposits is unnecessary if the 150% limit is not seen as a firm limit as discussed in question 5.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

CESA continues to believe the CAISO should allow projects that did not pass the scoring criteria to be included in a given zone’s TPD deliverability study (Option A) to elect to self-fund additional transmission upgrades to be included in the queue cluster as Option B.  It may be likely that there will be limited transmission capability to accept Cluster 15 interconnection requests, thus Option B may be the only available path for new projects.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

Support. 

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

CESA continues to support a one-time withdrawal opportunity but does recognize the concerns expressed by the participating transmission owners regarding cost responsibility.  However, if a non-viable project lingers in the queue doesn’t the risk expressed by the participating transmission owners still exist when the project withdraws from the queue later than the proposed one-time withdrawal opportunity?  Lastly, perhaps the CAISO could consider allowing withdrawal of Cluster 14 projects as the network upgrades are yet to commence.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

Support. 

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comment. 

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

CESA continues to not support the ISO’s proposal to remove suspension rights for all projects that execute an LGIA.  CESA supports proposing language to limit suspension rights to more specific circumstances or for more limited durations rather than removing them altogether.  

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

CESA continues to oppose TPD transfers to require the transferring project to withdraw.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

CESA believes that the viability criteria review should be triggered based upon planned COD following completion of network upgrades not when a project entered the queue.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

No comment.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

Support. 

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

No comment.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

Support. 

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

CESA requests the CAISO provide additional justification for the proposed change. 

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

CESA requests additional clarity because the proposal as written does not increase granularity, but rather reduces observations from 30 to 16.

1. Please provide a summary of your organization’s comments on the revised straw proposal

Clearway supports many of the changes made in the Revised Straw Proposal and appreciates the CAISO’s responses to input from stakeholders. However, several elements of the proposal require further changes or clarification to ensure the revised interconnection process will continue to support project development at the scale and pace that California requires, as summarized here and detailed in our comments below:

• Clearway appreciates the proposal to provide additional data to inform the zonal approach and requests that this expand to include more extensive information for POIs included in the CPUC’s busbar mapping, drawing from information already available in project study reports.
• Clearway opposes the proposed limit on interconnection requests by parent company, which could limit project development activity by the most experienced developers with the most viable projects.
• As described in the Revised Straw Proposal, entry to the interconnection study process would be determined primarily by LSE interest. However, without available information about the likely time and cost for a given project to interconnect, LSE interest at such an early stage of project development is not likely to be meaningful, and there is a clear conflict of interest for LSEs that are developing their own projects. We recommend adjusting the scoring criteria to place more weight on project viability and less on LSE interest, as well as further refinements to the scoring criteria as described in our comments.
• The Revised Straw Proposal anticipates that many projects will apply for interconnection at locations identified for future transmission upgrades and only a subset will be allowed to advance. However, the proposal is not clear on what would happen to projects that do not make the cutoff. Given the scale of California’s clean energy ambitions, it’s nearly certain that additional projects with site control at prime locations on the grid will be needed in the future; the only question is when. The CAISO should explain its view on the path forward for these projects.
• Clearway also requests that the CAISO clarify the treatment of Energy Only projects throughout the proposed application and scoring process. Although contracting for Energy Only projects has been limited in the past, both the IRP and CPUC RA policy frameworks are counting on Energy Only resources to play a greater role going forward. Clearway encourages the CAISO to leave options for Energy Only projects aligned with IRP/TPP resource portfolios to proceed.
• Clearway continues to support making Option B available for both projects outside identified transmission zones and projects above the 150% threshold capacity in an identified transmission zone.
• Clearway supports extending the timeline to request an LOS, and we encourage the CAISO to continue increasing this timeline to the greatest extent possible.
• Clearway requests reconsideration of proposals presented by numerous stakeholders for simplifying the MMA process.
• Clearway supports allowing a project from which TPD is being transferred to remain in the queue if it can demonstrate a PPA or shortlist within a set period of time.
• We support the updated proposal to require PTOs to commence work on network upgrades within 30 days of NTP being provided and the 3^rd IFS is posted. In Clearway’s view, this is one of the most impactful proposals in this initiative, as it puts the CAISO system on a path toward more predictable timelines for network upgrades and accountability for timely completion of work.

Clearway also supports the CAISO’s continued efforts to improve the deliverability allocation and retention process, including creating a pathway for multi-year interim deliverability allocation and resolving the previously identified timing issue for deliverability retention for Cluster 14 projects. We support keeping these issues in scope for either Track 2 or a near-term Track 3 of this initiative.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Clearway appreciates the CAISO responding to our proposal presented at the interconnection data workshop. Clearway supports the CAISO’s proposals to publish redacted versions of cluster study reports and individual interconnection reports to make more granular data available; this level of transparency is common in other markets.

The draft proposal mentions that CAISO will not be able to provide the capacity for each substation, price range per MW for interconnection, capacity, and constraints for each POI. It is not clear why CAISO is unable to provide this information when the same POIs have been studied several times over the last 14 clusters and CAISO has most of this information readily available in individual project study reports. Clearway again reiterates the request to provide the following for POIs included in the CPUC’s busbar mapping:

• Interconnection Feasibility at POIs identified in the CPUC portfolio
• Deliverability data at a granular level
• Cost guidance, estimates for RNUs
• Schedule guidance, timelines for RNUs

If all of this information cannot be provided before the Cluster 15 modification window opens, CAISO should prioritize providing the cost guidance and schedule for RNUs.

For future clusters, ideally this information would come from a new study of a representative portfolio conducted prior to the opening of the interconnection request window, as described in our comments on the initial Straw Proposal. However, if this is not feasible for Cluster 15, Clearway requests that the CAISO provide this information based on pre-existing studies.

Regarding the timeline for publishing data, Clearway and other developers understand that information published 6+ months prior to the interconnection request window opening will be fixed at that point in time and not represent the most up-to-date information. However, developing project proposals and securing site control takes time, and developers will have limited ability to make changes in response to data provided just a few weeks or months before the IR window. We still encourage the CAISO to provide a consolidated report 6+ months prior to the window opening (even with the risk of some stale data being included), in addition to releasing new information when available.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Clearway opposes the proposed limit on interconnection requests by parent company. The CAISO’s concern about the total volume of interconnection requests is already being addressed by the proposal to limit the number of projects accepted into the study process, as well as implementation of a 90% site control requirement at the interconnection request phase. The CAISO has not explained why, even after implementation of these changes, it would still be necessary or helpful to limit the total number of IRs from a single parent company. As the CAISO notes in the section discussing the auction proposal, developing utility-scale projects in California requires experience and resources, and it is primarily large, sophisticated developers who can successfully advance projects to completion. The CAISO has not provided a compelling reason for limiting these companies’ new project development activity.

Clearway also has significant concerns about how the parent company cap would be implemented, as explained in our comments on the first Straw Proposal. If this proposal is included in the Draft Final Proposal, we request that the CAISO provide details at that point about how the proposed limitation would be applied to companies or projects that are owned by multiple parent companies, so that stakeholders can provide input on the fairness and administrative feasibility of the proposal. As a starting point, Clearway proposes that the CAISO consider two Interconnection Customers to fall under a single parent company only if that parent company holds an equity interest of more than 50% in each IC.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

As currently proposed, entry to the interconnection study process would be determined primarily by LSE interest, since LSE interest is given the greatest weight among scoring criteria. However, LSE interest at such an early stage of project development is not likely to be meaningful – what LSEs are primarily interested in is a project’s interconnection cost and timeline to achieve deliverability, which will not be known until after the study process, as well as the project’s viability.

Clearway provides the following recommendations to better align the scoring criteria with system needs:

• The weights among categories should be readjusted to prioritize project viability. We suggest the following weights as a starting point, with additional adjustments to each category described below:
  • Project viability 50%
  • LSE interest 30%
  • Other policy priorities (“system need”) 20%
• Project viability
  • Clearway supports adding a screen for a developer’s experience successfully completing and operating projects of the same scale and technology type, with full points for projects in CAISO and partial points for projects in other markets.
  • Clearway supports the proposed point awards for major equipment procurement. However, we note that “demonstration of business partnerships” would apply at the developer level rather than the project level and would therefore be a proxy for developer size and experience, rather than providing a way to differentiate among projects. Demonstration of major equipment procurement for specific projects has been used for many years to qualify projects for federal tax credits, and the CAISO may want to modify this proposal to reference equipment procurement at the project level rather than at the company level.
  • Clearway opposes awarding points for submittal of an engineering design plan. The standard interconnection request package provides enough information to study a project, and even for a well-developed, viable project, the engineering design is virtually certain to change as the project progresses through development (as the CAISO knows from the number of MMAs submitted for design basis updates). Spending time and resources on fully designing projects prior to submitting an interconnection request would only serve to increase costs with no real benefit to the project or the CAISO system.
  • Clearway supports the proposal to award points for expansions of existing facilities. However, it is too limiting to award points only when the original facility is operational and no points if the original project is under construction or will soon be. Points should also be awarded in this category if the original project has already issued NTP for upgrades under the LGIA, posted the 2^nd financial security and executed the LGIA.
  • Clearway supports adding points in this category for projects that have been shortlisted or executed contracts for energy and/or RECs with a non-LSE entity (e.g., a large corporate customer). While these non-LSE customers do not fit neatly into the LSE points allocation mechanism in the Revised Straw Proposal, they play an important role in the market, and a project that has secured a revenue contract or shortlist with a non-LSE entity is more viable than one without.
• LSE interest
  • The Revised Straw Proposal does not address the concerns stakeholders have raised about the disparate treatment of CPUC-jurisdictional and non-CPUC-jurisdictional LSEs. Utility-scale projects selected by non-CPUC-jurisdictional LSEs should be subject to the same project viability scoring as other projects – otherwise there is a risk that limited transmission capacity will be allocated to less viable projects and block more viable projects from proceeding to the study process. Clearway agrees with LSA that, if the concern is primarily with small LSEs seeking to advance small projects of their own, a better solution would be to not count these projects toward the 150% limit.
  • For LSEs participating in the process of awarding points, Clearway requests more detail on what information the CAISO would be providing to the LSEs on projects in the queue. Clearway would not support providing confidential project information to LSEs, such as specific project and developer names. As a developer, it is important to Clearway that we retain control of the process of sharing information on our early-stage development projects and marketing projects to offtakers. At this early stage, LSEs should ideally be identifying preferred locations and technology types, rather than specific projects. As discussed above, if too much weight is placed on LSE interest in specific projects before meaningful interconnection information is available, the logical result is that the awarding of points will become transactional rather than based on the merits of each project, with LSEs requiring developers to agree to unfinanceable contract terms or provide payment in exchange for points in the scoring criteria.
  • Where LSEs are pursuing utility-owned generation and storage projects, there is an obvious conflict of interest in giving them the option to award these projects points to advance in the interconnection process. To address this conflict of interest, the CAISO should consider not allowing LSEs to award points to self-developed resources.
  • The proportional scoring mechanism seems likely to drive counterproductive outcomes and should be adjusted. If we correctly understand the proposal as currently described, a 100 MW project where all 100 MW are selected by an LSE would receive double the points of a 200 MW project where 100 MW has been selected. The 200 MW project would need to downsize to 100 MW to receive full points. This mechanism would systematically favor smaller projects over larger ones. However, larger projects can be more cost-effective because they benefit from economies of scale and are therefore more viable in the context of competitive procurement processes. Clearway’s experience is that large projects require multiple contracts that are often executed at different times – taking this approach does not reduce project viability and should not count against a project in the scoring criteria.
• System need
  • As an editorial note, Clearway notes that all of the projects in targeted transmission zones are meeting system need. The projects receiving points in this category are those serving additional policy purposes beyond system need, so it may be appropriate to rename this category.
  • Ability to provide Local RA: Clearway suggests that the MWs eligible for points in this category should be limited to the amount of demonstrated need for Local RA, following the same logic as the overall limitation on projects entering the study process by zone.
  • Long lead time resources for which the TPP has approved transmission projects: This proposal is very similar to the CAISO’s earlier proposal to reserve transmission capacity for the public policy-favored resources for which the transmission need was identified. Similarly to the Local RA points, Clearway suggests limiting the MWs eligible for points in this category to the quantity identified in the CPUC’s IRP portfolio, rather than all projects in a given technology category.  
• Distribution Factors
  • Clearway supports this proposal in concept but would like the CAISO to provide additional detail on how the analysis would be conducted. The analysis should include both DFAX and flow impact, as both are relevant to the project’s impact on the grid.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

Clearway supports the revised proposal to accept the entire capacity of the project that reaches the 150% threshold, rather than maintaining a strict MW cutoff. The selection of 150% as the cutoff was not an exact science, and some flexibility around that number is warranted.

The Revised Straw Proposal is not clear on what would happen to projects that are not accepted within the 150% limit. Given the scale of California’s clean energy ambitions, it’s nearly certain that additional projects with site control at locations identified for transmission upgrades will be needed in the future; the only question is when. The CAISO should explain its view on the path forward for these projects, including whether they may convert to Energy Only and proceed in the same cluster, whether they can wait in the queue, continue development and be scored again for the next study process, or whether they must withdraw and resubmit in the next application window.

Clearway also requests that the CAISO clarify whether interconnection applications for Energy Only resources would be allowed outside of the 150% limit and what the limit would be (if any) for Energy Only projects to be accepted into the study process.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

Clearway welcomes the change in the proposed auction process so that bidding would be triggered only if and when an auction is actually needed. Clearway also supports the CAISO’s proposal to allow each project that crosses the capacity threshold to be studied in its entirety. Both of these changes improve the implementability of the CAISO’s proposal.  

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

Clearway continues to support making Option B available for both projects outside identified transmission zones and projects above the 150% threshold capacity in an identified transmission zone. The rationale is the same in both cases – to allow developers to fund additional transmission upgrades beyond those identified in the TPP.

Clearway understands the CAISO’s desire to reduce the volume of projects in the study process to make the results more realistic. However, as the CAISO considers imposing limits on new interconnection requests, it is important that the limits are aligned with policy goals and the needs of the grid. If projects in transmission zones targeted for development are strictly limited to the 150% threshold, while projects outside the zones can proceed without limitation under Option B, this could lead to a portfolio of projects advancing that is out of balance with the IRP/TPP portfolio.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

Clearway agrees with ACP-California that it will be valuable to have the off-peak deliverability assessment available in the future, given that the Slice of Day RA counting regime will provide an opportunity to make use of off-peak deliverability.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

Clearway disagrees that our proposal to allow a customer to request an LOS in response to a network upgrade delay “describes the status quo.” This has not been Clearway’s experience: When we received notification of a network upgrade delay for a project complex under construction earlier this year, we were told that we could not request an LOS until 5 months out from the project’s original in-service date. Extending this timeline to 9 months is a helpful improvement, and we encourage the CAISO to increase this timeline to the greatest extent possible. In this real-world example, having the LOS initiated as soon as the project was notified of the upgrade delay would have been helpful to Clearway, as we needed to develop a revised plan for construction sequencing and commissioning informed by the LOS results. The ability to request the LOS and review the results as soon as an upgrade delay is known is also critical for adjusting the commercial arrangements with offtakers.

Clearway appreciates CAISO’s clarification on the interaction between MMA request and LOS. CAISO states that any modification request submitted simultaneously with an LOS that may impact the LOS must be deemed complete and valid prior to the ISO starting the LOS. Clearway requests more clarity on how CAISO would evaluate if an MMA request would interact with the outcome of an LOS. We request that the CAISO clarify if modification requests to change technical specifications (e.g. inverters, transformers, collector system design, gen-tie design, etc.) without changing the net output at the MW would be allowed to proceed in parallel with the LOS.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

Clearway opposes the proposal to require a project from which TPD is being transferred to have a PPA in place as an Energy-Only resource prior to requesting the transfer, and instead supports LSA’s proposal to allow these projects to remain in the queue if they can demonstrate a PPA or shortlist within a set period of time. Even if a developer has line of sight to a PPA for an Energy-Only project, it is not realistic to expect the PPA to be executed before the TPD transfer has been completed.  

Clearway recommends allowing Energy Only projects that are not operational to seek TPD under Group A and Group B. If actively queued EO projects are capable of receiving commercial interest from offtakers in the form of shortlist and PPAs, then CAISO should allow these projects to compete for TPD.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

Clearway supports LSA’s position that COD extensions should be allowed as early as 12 months before the current In-Service Date, and not to place limits on Construction Sequencing requests for COD accelerations.

Clearway appreciates and supports CAISO’s proposed enhancement to host modification calls between the ISO and PTO engineering teams.

Clearway requests reconsideration of several ideas proposed by numerous stakeholders for simplifying the MMA process. Although there was significant interest in this proposal initially, the Revised Straw Proposal seems to have eliminated any possibility of streamlining MMAs for modifications that are nearly always approved. Clearway would like to reiterate our request to identify such modifications and create a pre-approved list of modifications and/or equipment to simplify and expedite the MMA process.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

Clearway supports the updated proposal in connection with the requirement that PTOs commence work within 30 days of receiving NTP and third IFS posting.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

Clearway supports the updated proposal and wishes to highlight the importance of this measure within the many elements of the IPE initiative. Requiring PTOs to commence work as soon as NTP is issued and financial security is posted is an important step toward predictable timelines for network upgrades, which is critical if California is to meet its reliability and clean energy goals.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

Permit-ability is fundamental to project viability and should be considered for readiness for entry into the queue and must be an unavoidable criterion for remaining on the queue.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

We appreciate the shift to a zonal approach and request that ISO take this opportunity to standardize the ISO zones with the RESOLVE resource regions.  The lack of geographical alignment between these key planning models undermines efficient generation and transmission planning.  The transmission planning geographies used by the California Energy Commission, California Public Utilities Commission, and the CAISO should be consistent.  The attached slide from a recent CPUC workshop illustatates the issue.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

We appreciate ISO staff, partners, and stakeholders' efforts to re-evaluate and streamline queue operations. 

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

The lack of permitting milestones in the scoring criteria removes one of the simplest indicators of project viability readiness.  It matters not if a project has business partnerships for equipment or engineering design if the project is not progressing toward or cannot obtain the land use and environmental approvals necessary to be built.  The ISO can and should require interconnection customers to provide either documentation of a project's permitting status or a letter from the land use authority where the project would be located verifying that such a project could be developed with appropriate permits and a general timeline for obtaining those permits.  This is not an unusual request; commercial lenders make similar requirements as part of loan packages.

We recommend revising the Straw Proposal scoring system on page 39 to increase project viability, including permitting status to 40% and reducing LSE interest to 30%.  Again, if a project cannot be permitted to be built, then no amount of LSA interest will resolve the lack of viability.

We agree with other stakeholders that power purchase agreements should not be used as criteria.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

No comment at this time.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

No comment at this time.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

No comment at this time.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

No comment at this time.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

No comment at this time.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

No comment at this time.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comment at this time.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

No comment at this time.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

No comment at this time.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

We support an unavoidable viability criteria and time-in-queue requirements for all projects in the queue.  In particular, we support including permitting milestones in the scoring criteria as one of the simplest indicators of project viability.  If a project is lingering on the queue, then pointed questions must be asked about its progression and if it can obtain the necessary land use and environmental authorizations.  The list of permits and authorizations listed in F.2 on page 78 and B.2 on page 79 of the Straw Proposal needs to be expanded to include compliance with both the Endangered Species Act and the California Endangered Species Act and federal Rights-of-Way and National Environmental Policy Act for projects located on federal lands.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

No comment at this time.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

No comment at this time.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

No comment at this time.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

No comment at this time.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comment at this time.

1. Please provide a summary of your organization’s comments on the revised straw proposal

 EDF-R appreciates the opportunity to submit brief comments on the interconnection process enhancements 2023 revised straw proposal.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

EDF-R appreciates CAISO’s continued work developing the interconnection report with stakeholders, and strongly supports CAISO’s commitment to consolidate information for each of the interconnection areas into a single document for ease of reference.

In the revised proposal CAISO indicates that providing the updated report 6 months before the opening of the queue window will “result in out of date or stale data.” EDF-R understands the complexity of the interconnection reporting asks, but requests that the CAISO provide in the context of this IPE discussion an analysis of when the data will be available, and memorization of that timeline in the tariff. It is unreasonable to expect stakeholders to perform development analysis and ready interconnection requests on a compressed timeline – developer work is as complex and time consuming as CAISO’s work on the transmission system. EDF-R suggests that CAISO should commit to providing the report no less than 120 days prior to the opening of the queue window, and the tariff should require a day-for-day extension to the close of the queue window for any day less than the 120 days.

EDF-R also supports comments from ACP-CA and CESA on this item.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

CAISO should eliminate all sealed bid proposals
EDF-R agrees with CAISO’s decision to no longer propose to require interconnection customers to submit sealed bids for the potential zonal auction with interconnection requests. EDF-R urges CAISO to also eliminate the proposed sealed bid auction for differentiating projects scored equally in the IR process when there is not sufficient capacity available. EDF-R agrees with the general stakeholder position that bidding is not an appropriate mechanism to compare projects against one another and that the 150% MW study cap for a zone should be a flexible. The CAISO did not provide any empirical evidence, but only theoretical support, to support 150% as the cap, so it stands to reason it can be flexible. Alternatively offering pro rata shares of capacity is a perfectly reasonable option.

FERC order 2023 and Cluster 14 or Earlier Project 
EDF-R reuests CAISO clarify if entry fees and study deposits consistent with FERC Order No. 2023 will be retroactively applied to Cluster 14 or earlier projects.

Interconnection request limitations
CAISO proposes to limit interconnection request capacity to 25% of the total available transmission capacity for a particular cluster. EDF-R requests CAISO describe how it came to the 25% conclusion. EDF-R is opposed to this proposal and supports comments from LSA, ACP-CA, and CESA on this item. CAISO’s justification for the proposal is that a small number of ICs are submitting 10+ IRs, and then seeks to caps MW capacity to solve this problem when MW amount and number of interconnection requests is not necessarily related.

Additionally, if there is a small amount of available TPD in any given cluster study application window, the 25% limit can possibly impact most IPP Parent Companies in the that queue cycle. It appears the CAISO assumes there is and will continue to be abundant amount of available TPD going forward.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

 EDF-R is at this point reluctant to fully endorse the scoring criteria. Still yet to be perfected is LSE capacity allocation factor. As it is currently proposed EDF-R believes the proposal is too complicated, and is too heavily weighted in the scoring rubric. LSE interest should not have more weight than project viability or system need.

EDF-R is also concerned with the potential LSE scoring assignment being applied toward their own projects, which enables LSEs to indirectly exclude competing projects from a study cycle.

EDF-R supports CAISO’s proposal to use projects’ distribution factor (DFAX) as a tie-breaker when the selection process is near the threshold and two or more projects are tied.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

 As described above, EDF-R requests the CAISO to provide any empirical evidence, not theoretical support, to support 150% as the cap, so it stands to reason it can be flexible. Alternatively offering pro rata shares of capacity is a perfectly reasonable option. EDF-R request the CAISO to provide a proof-of-concept demo using cluster 14 queue entry data on how it would have shaped preceding clusters. EDF-R supports ACP-CA comments on the CAISO providing additional details on how and when capacity levels will be determined.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

 EDF-R does not believe an auction mechanism is a reasonable method for identifying more viable projects. CAISO should consider other decision making approaches such as DFAX contribution, flexibility on the 150% cap, and offering equally scored projects pro-rata shares.  

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

EDF-R generally supports the Option B proposal. Although, EDF-R does not support the proposal that if an ADNU is picked up by the TPP then projects would then be required to seek an allocation of TPD through the affidavit process to obtain an allocation of TPD. These projects that select Option B make financial postings and take on major financial obligations so should be provided priority treatment if an ADNU is identified down the line. They should be provided priority treatment if the ADNU is picked up by the TPP, especially if the ADNU construction has already started as a result of the Option B projects.  

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

EDF-R supports this proposal.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

 No comments at this time.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

EDF-R supports the LOS changes.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

EDF-R supports this proposal.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

No comments at this time.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

No comments at this time.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

 EDF-R is unclear about the CAISO’s new position that PTO construction delays can and should be limited in certain circumstances.

• If an LGIA has not been executed then there exists no contract for construction of network upgrades. Therefore until a GIA is executed, day for day slippage of milestones is a delay of the PTO schedule, not necessarily a delay attributable to PTO inaction. And if a GIA is not executed due to a customers failure to negotiate, Appendix DD section 13.2 allows for the PTO and CAISO to issue a “last and final” draft of the GIA and if negotiation is declared at an impasse the CAISO or PTO may force the customer to agree to submission of an unexecuted GIA, withdraw, or initiate formal dispute resolution.
• If a PTO’s construction schedule has been delayed for reasons not related to IC action (even if IC has lingered in queue), the IC is due a PTO delay, and as in independent system operator, CAISO should investigate all drivers of a delay, rather than waiting on PTOs to provide PTO delay assessment results at their discretion.
• The CAISO should implement a deadline by which a GIA needs to be tendered by the PTO in addition to the GIA execution process for Cluster 14 and earlier projects. PTO accountability for tendering draft GIAs to the IC within a certain timeframe is critical.
• EDF-R supports ACP-CA’s comments regarding CAISO providing more time to ICs that have a PPA cancelled as a result of a PTO delay. While EDF-R appreciates CAISO offering an option, 12 months is highly unlikely to afford sufficient time for a project to renegotiate a new PPA, especially if there is not an active procurement cycle ongoing. We recommend that, in the event a PTO delay causes cancellation of a PPA, developers be provided with the greater of three years or the length of the PTO delay (e.g., four years if that is how long the PTO project is delayed).
• EDF-R supports CESA’s comments that the viability criteria review should be triggered based upon planned COD following completion of network upgrades not when a project entered the queue.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

EDF-R supports CAISOs proposal for construction sequencing requests.

EDF-R appreciates CAISO’s discussion of MMA process changes and accepts CAISO’s justification for continuing some confidential communication between PTO and CAISO, as well as the complication created by a tiered system.

EDF-R emphatically requests CAISO consider EDF-R’s proposal to raising the deposit to only $15,000 so that costs are covered 80% of the time (or more).

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

 EDF-R believes the CAISO’s proposal may be acceptable but asks CAISO to work through 2 example scenarios to ensure the proposal is well understood by all.

EDF-R also asks what happens if the PTO does not initiate construction within 30 days. Will security be returned to interconnection customers and NTP considered void? EDF-R can imagine a situation where this procedure is initiated and then a project gets “re-prioritized” by the PTO, resulting in the IC having inappropriate levels of funds at risk.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

EDF-R supports this proposal.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

EDF-R supports this proposal.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

 EDF-R requests CAISO provide information on how it came to the $100k mark for this deposit.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comments at this time.

1. Please provide a summary of your organization’s comments on the revised straw proposal

ENGIE NA (“ENGIE”) appreciates the opportunity to submit comments and generally supports CAISO taking measures to enhance the interconnection process. ENGIE raises the following concerns with the current proposal.

Order 2023 Compliance

• It is difficult for interconnection customers to fully evaluate impacts of the CAISO’s interconnection enhancements proposal when it is still unclear how CAISO will interpret FERC Order 2023.  ENGIE supports comments made on the stakeholder call that requested CAISO to make at least an initial summary available for how CAISO interprets impacts of the FERC Order.
• ENGIE does not support application of FERC 2023 site control requirements to Cluster 14 and earlier clusters.  FERC Order 2023 does not require site control on all in queue projects.  Transitional rules (including rule requiring site control) is required only from TOs that currently do not conduct cluster studies as part of their interconnection procedures.  CAISO has long conducted cluster studies and in-queue projects have substantial security posted Thus, no changes pre-C15 are necessary. 
• If CAISO does propose to require site control pre-C14 interconnection customers need:

• Transparency: site control guidelines need to be finalized in the near-term so interconnection customers can prepare to meet requirements
• Adequate time to respond.

• Ability to withdraw without cost if site control cannot be obtained  

Off-Peak Deliverability Status

• CAISO should retain an option for OPDS or agree to reinitiate option if this becomes tangible as a design component of RA Slice of Day.

Energy Only Projects

• CAISO should not limit studying energy only projects due to perceived lack of commercial interest. Energy Only projects should be accommodated without restrictions and be allowed to follow the Option B path.

Zonal Scoring Criteria

• The zonal scoring criteria needs to be modified to accommodate corporate off takers
• Scoring should be more heavily weighted towards project attributes rather than LSE interest
• Option D projects should not count against zonal limits

Developer Cap

• ENGIE continues to oppose the application of a 25% developer cap 

Contract and Queue Management

• A one year extension is insufficient in cases where a PPA is cancelled due to a PTO delay.  

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

• Interconnection customers need a specific schedule from the CAISO for when transmission data will be available and which data (including upgrades approved in the current Transmission Planning Process) will be used to set the transmission capability limits.
• Developers need sufficient lead time to evaluate whether projects are viable for Custer 15 which needs to occur before any site control is required or scoring occurs.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

• ENGIE opposes the 25% developer cap. The CAISO has not demonstrated there is a problem to solve and it is unnecessary in light of other proposed provisions.
• A developer cap will artificially stifle competition and will limit commercially viable projects from entering the queue. There is no case to be made that one developer submitting a large number of projects results in more speculative projects entering the queue.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

• The CAISO needs a transparent methodology for allocating available capacity to scored projects which should reside in the tariff, not the BPM. 
• It is unclear how scoring will be traded off against TPD deliverability in sub zones or within  a single zone but where  projects have very different DFAX’s ’s on critical constraints.
• The weighting of LSE interest is too high at 50% and could give utility owned generation a competitive advantage over IPPs. Criteria needs to be developed for how and why projects would qualify in the LSE interest category. LSE interest at this early stage would not ensure a viable project and any interest would not be commercially binding.
• Scoring should be weighted towards project specific attributes rather than so heavily towards LSE interest.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

• ENGIE supports CESA’s recommendation that the 150% not be seen as a firm limit, but rather it should set the minimum quantity of projects that will be accepted for study.  In the event that there are projects with equal scoring criteria and DFAX which exceed the 150% baseline, all those projects should be studied. The CAISO may need to increase the 150% limit to meet the needs of different queue cycles and transmission availability.
• It is very important that the CAISO not decrease available capacity unnecessarily.  The CAISO should reduce available capacity only with projects that have secured TPD via Groups A-C and exclude Group D as they may very well not retain the capacity a year later.
• There may be little to no available capacity in many zones. If that is the case, the CAISO should consider a pause on the more complex interconnection enhancements until more TPP projects are approved. 150% of zero, still equals zero. 
• Overly restrictive modifications to interconnection rules paired with little to no deliverability could impede the clean energy transition and impair reliability.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

• ENGIE continues to support the CAISO considering an auction in a later phase of interconnection enhancements and only if necessary. If the CAISO approaches the 150% limit as a floor rather than a ceiling and paired with the DFAX approach to evaluate projects with equal scores, an auction is  unnecessary.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

• Energy only projects should be allowed without restrictions and be allowed to follow the Option B path regardless of LSE interest. There may be more commercial interest in these types of projects in the future and they do not require deliverability.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

• CAISO should retain an option for OPDS or agree to reinitiate the  option if this becomes tangible as a design component of RA Slice of Day.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

• ENGIE supports retaining the one-time withdrawal opportunity. PTOs can  determine potential impact and developers could exit at the lower of the security posted or impact on PTOs. Eliminating this option could encourage projects to stay in queue longer when they otherwise would have made an economic decision to withdraw.
• PTOs claimed allowing early withdraw would create harm but provided no supporting data.  The benefits from accelerating withdrawal from projects holding TPD (or valuable substation positions) would be very large.   
• Projects that exercise the 1x are  likely to withdraw later so any measure of “harm” must be netted against that effect.  Furthermore, PTOs have total ability to reallocate costs if a C14 project were to withdraw under a 1x opportunity.  In this case there can be no “harm” by any measure of the term.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

• ENGIE supports retaining suspension rights with modified limits if need be, rather than removing it all together.  Suspension is not used often but is one of the few elements of flexibility for developers to use in the interconnection process. 

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

• Interconnection customers need at least two years to negotiate and secure a PPA in the event a PPA is cancelled due to a PTO delay. A one year extension does not represent commercial reality.  
• Also if the PTO “delay” comes at the outset; i.e. the Phase 2 study necessarily results in a COD more than 7 years out, the start of any CVC should be moved out commensurate with that long-dated COD.  It is simply unreasonable to assume a project that has a COD 10 years out should be expected to show a PPA shortly after a GIA is signed, which is what is required under CAISO’s proposal.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

esVolta appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 2 Revised Straw Proposal.  esVolta develops, owns and operates utility-scale battery energy storage projects across North America. esVolta's portfolio of operational plus utility-contracted backlog projects totals nearly 1.5 GWh, and we are developing a pipeline approaching 20 GWh of further large project opportunities. esVolta has both operational battery storage projects in the ISO as well as requests in the ISO’s interconnection queue.  esVolta takes no position on the majority of CAISO’s Revised Straw Proposal, and instead focuses its comments here on issues that are of the most significant concern to esVolta’s interests. However, esVolta’s silence should not be construed as endorsement.

esVolta continues to oppose the viability scoring criteria points CAISO proposes to award to expansion projects, and in the alternative, to reduce the points awarded to expansion projects. esVolta continues to advocate for a switching option from Option B to Option A. Finally, esVolta renews its support for elimination of suspension rights.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

As it did in its initial comments, esVolta opposes scoring criteria points for expansion projects. In the Revised Straw Proposal, CAISO’s discussion of this issue is limited to this quote:

“The ISO understands that there may be several development advantages and cost savings associated with this type of expansion, including reduced permitting requirements, reduced costs, and the potential ability to avoid requiring a new position at a substation.” CAISO Revised Straw Proposal at 33.

However, the ISO’s “understanding” is supported only by conclusory statements without supporting evidence. The ISO presents no evidence, either anecdotal or statistical, to support the contention that expanded projects are more viable. In fact, there are several reasons why expansion projects may be less viable than greenfield development projects.

First, expansion projects necessitate an existing project, and the longer a project exists the more likely it is to cause concern or opposition from neighbors, local communities, and local elected officials or other decision-makers. Therefore, an expansion of an existing project is more likely to be opposed by neighbors or decision-makers, raising doubt as to whether it is truly more viable than a new project. Even if CAISO does not agree that the viability of expansion projects is questionable, it should nevertheless require that expansion projects must be fully permitted, as CAISO has discussed during the stakeholder workshops, in order to award those projects with additional viability scoring criteria points.

Second, there are cumulative effects experienced by neighbors and local communities from projects that can compound negative impacts, which are worsened by expansions. For example, noise, visual impacts, aesthetic impacts, construction dust/debris impacts, and fire safety considerations can be worsened by expansions, and those heightened impacts are felt by the same communities that already bore those impacts for the existing facility. This cumulative effect can endanger the social license of the project, and local jurisdictions are considering more difficult permitting regimes based on cumulative effects for energy projects. See e.g. Statement of Proceedings at 89, LA County Board of Supervisors (Dec. 19, 2023) (“Overconcentration of larger, primary use BESS projects as evaluated by existing infrastructure”).

Even if expansion projects are considered more viable, for which the ISO has not provided sufficient evidence, the ISO’s proposed site control requirements (i.e. consistent with FERC Order 2023) already reflect the project viability gained by having control over the land required to site incremental generating resources. Therefore, the points awarded to co-located or expansion resources provide no additional assurance of viability, and can only be awarded to incumbent resource owners.

Moreover, providing additional scoring criteria points to expansion generators may also have implications for open access beyond those allowed by FERC through the viability demonstrations required by Order 2023, since expansion resources would have to be developed by or in agreement with incumbent resource owners whereas no such preferences for incumbents were approved by FERC in Order 2023. By giving significantly more points to co-located resources in the viability criteria, CAISO is effectively reducing the number of projects and project owners that can compete for valuable ATC, thereby concentrating pricing power in a handful of existing resources to the detriment of California’s retail prices and reliability.

Despite all of these concerns, if CAISO nevertheless insists on awarding additional viability points to expansion resources, those points should only be awarded if the resource meets the MOU goals, i.e. has the operational characteristics and is located in the geographic locations consistent with state agency resource planning. Moreover, these resources should only be awarded additional viability points for expansions if they are located in zones with sufficient available ATC to accommodate the incremental interconnection capacity, or where upgrades planned by CAISO would make sufficient incremental ATC available before the resource’s COD. Finally, the points awarded should be significantly reduced from 30 or 40 points to 20 or 30 points. As currently tallied, the expansion points would dwarf and therefore make irrelevant the other Project Viability category points and thus should be revised downward so as to not become all-consuming.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

CAISO should modify its proposal to allow Interconnection Customers to switch from Option B to Option A at the time of receipt of the Cluster Study Report. In the Revised Straw Proposal, CAISO claims that doing so would “require a restudy or an additional study and the best way to handle these options would be in the next cluster study.” While it is true that either a restudy or additional study might be required in the switching scenario, it does not follow that the “best” way to address the additional study is in the next cluster. In the significant amount of time that will be required under the single-phase study process, it is reasonable and appropriate for circumstances to change enough for new interconnection capacity to become available. To require resources to wait months, or potentially over a year, to be studied for that capacity simply delays the beneficial use of that available capacity and thus unnecessarily defers investments in reliability and affordability to the detriment of California load-serving entities and ratepayers. Rather, in the event and when that capacity becomes available, it should be put to good use as soon as practicable. It is as imperative to add new resources to the ISO’s system to meet the state’s policy goals and reliability requirements as it is to add those resources without unnecessary delay.

As esVolta commented previously, if the ISO seeks to limit the ability to switch, the ability to switch to Option A could be made available only to requests that are located in zones where incremental ATC has been made available due to interim changes in underlying inputs since the submission of the request. By strictly limiting interconnection customers who proceed down the Option B route with no option to switch, CAISO may over incentivize new requests exclusively in the transmission zones showing the most current ATC availability, to the detriment of projects that might provide value in addressing future needs.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

esVolta supports the ISO’s proposal to eliminate suspension rights, although esVolta would also support elimination of suspension rights for projects with existing LGIAs in addition to LGIAs executed in the future. The CAISO is unique compared to other transmission providers insofar as its proposed maximum time-in-queue requirements, the existing ability to modify a project’s COD through the MMA process, and its requirement to fund shared network upgrades during suspension. These characteristics make suspension unnecessary or unwarranted in most instances unique to CAISO, and valuable ATC is tied up and withheld from projects seeking to move forward by projects that may not be viable.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

No comment.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

No comment.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

No comment.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

• Golden State Clean Energy (“GSCE”) proposes the following categories be added to the scoring criteria:
  • Gen-tie path site control, with points for 50%, 90%, and 100% control of the gen-tie pathway.
    • Having secured a path to interconnection directly addresses the readiness and viability of a project. Further, it is easily verifiable and thus aligns with CAISO’s stated goal for the readiness scoring criteria.
    • Securing a gen-tie pathway can be difficult and either delay a project or cause it to fail late in the study process. Projects that have secured a pathway to interconnection have met a significant hurdle that must be addressed at some point in project development.
    • This should not be deemed out of scope due to FERC Order 2023’s site control requirement because that requirement does not consider land needed for the gen-tie or other interconnection facilities. In fact, it is in line with Order 2023 because FERC has shown it views securing land for a project as an indicator of project viability. Order 2023 leaves room for CAISO to supplement the site control requirement, so CAISO is not preempted from further addressing site control, and CAISO should address it for the gen-tie pathway because the current scoring criteria needs additional categories to better distinguish projects.
  • Project footprint that aligns with the CEC land use screens.
    • Development on or in close proximity to preferred lands in the land use screens increases the project’s viability because development is occurring in an area where state planning has generally identified less environmental and land use obstacles.
    • Additionally, this category further connects the interconnection process with other state planning and policy efforts that do not require CAISO to engage in policymaking. As observed in the long lead-time resources category, the scoring criteria already acknowledges the need to show preference for development that aligns with state policy, irrespective of whether the point category speaks to project readiness.
    • From an administrative standpoint, this category can be easily verified by overlaying the project footprint onto the final CEC land use screens map. A generation resource with a footprint that has any overlap with the land use screens should be granted points, acknowledging that a project that is at least in close proximity to areas the CEC has identified as lower conflict lands will improve the chances of a project being developed while accounting for any imprecision in the land use screens.

• GSCE opposes removal of permitting from the scoring criteria.
  • This category would only involve a check on an additional form of readiness and not be a minimum requirement as many stakeholders seemed to assume in their arguments in opposition.
  • Nonetheless, GSCE believes permitting must continue to be considered at some stage of the interconnection request process, such as continuing to be a factor in the allocation of deliverability.

• GSCE offers additional comments on the following scoring criteria:
  • GSCE recommends that a demonstration of a business partnership for future supply of major equipment prior to COD require binding agreements with commitments to deliver to the specific project (such as a Work Order with a defined delivery address) and that this category receive less points.
    • This category does not distinguish many developers while further driving up the cost to interconnection.
    • Many may be able to game this through framework agreements that apply to a broad pipeline of projects, allowing a shuffling of equipment supply contracts that do not necessarily ensure the project specified in the interconnection request will have access to such equipment and thus does not necessarily address readiness.
    • If the contract does not require purchase of a minimum amount of equipment that is aligned with the project size, a delivery requirement to the project site, and upfront payments or penalties for cancelation of the contract, then the agreement could be merely for show, or be executed with the intent of later renegotiation, or be an order sufficient for one project but used to obtain points for multiple potential projects.   
    • If this category remains, it should be deemphasized by having less potential points.
  • GSCE recommends the Engineering Design Plan category require only a conceptual plan.
    • A conceptual design plan should be required to show (a) a conceptual layout of the project meeting the desired interconnection capacity, (b) the gen-tie line route to the proposed point of interconnection, and (c) lands under site control for both the generating resource and the gen-tie line. This allows CAISO to connect the dots with other requirements or point categories and be an additional validation tool for generation and gen-tie site control.
    • Requiring much beyond this amount of detail (e.g., a 30% Engineering Design Plan) is unproductive at the interconnection request submission phase, as projects will likely have to later revise the design plan during the interconnection study process (e.g., as technologies change). This calls into question the project readiness this category attempts to address.

• GSCE supports automatic inclusion of projects that a non-CPUC jurisdictional LSE demonstrates is a preferred resource in its resource plan that has been approved by its Local Regulatory Authority

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

• GSCE continues to believe that 150% does not sufficiently account for the historical rate of projects failing to reach commercial operation, nor allow for sufficient competition in commercial negotiation or consider corporate offtakers that are not accounted for in the planning processes that dictate available and planned transmission capacity.

• GSCE supports stakeholders like CalCCA[1] and agrees that 200% is more reasonable.
• GSCE believes the recent clarification that available capacity will be enforced by individual constraints, not only per zone, will further reduce interconnection requests and alleviate CAISO’s concern regarding the total volume of future interconnection requests.
• Although there is extensive capacity currently in the queue, this initiative has established that many stakeholders think a substantial amount of that capacity is not viable--lingering without incentive to withdraw. Thus, current capacity in the queue is likely providing a false indicator to CAISO of projects that will be available to deliver to LSEs and CAISO should not undervalue the need for new project proposals.

• In addition, although GSCE supports automatic inclusion of a project that a non-CPUC jurisdictional LSE demonstrates is a preferred resource in its resource plan, GSCE opposes these projects counting against the 150% available capacity that move forward to the study process.

• GSCE opposes a developer cap.  
  • This cap creates unnecessary complications.
  • It is unclear how this cap will be implemented and how different business structures would count toward the cap. The proposal makes reference to “any one parent company”; however, parent company is not defined and attempting to define it productively creates more problems than it would solve to include this criterion.

If parent company is defined broadly, it would pick up arrangements where a member of a joint venture qualifies as a parent company even if that legal entity only owns a small fraction of the ownership interests and has no day-to-day control. This type of joint venture is frequently used to support equipment supply arrangements or various types of financing. If minority interest holders are included in “parent company” then it would foreclose or further complicate equipment supply and other financing arrangements.
 

Further, it is unclear how far “up the ownership chain” this test would look. For example, would a shareholder in a public company be a “parent company”? If so, that would require developers that are publicly traded entities to disclose the identities of major shareholders, and then it would be necessary to aggregate positions held by those shareholders across different public company developers to determine the capacity attributable to that shareholder as a “parent company”. To the extent shareholders in a public company should not be treated as “parent companies,” it creates a relative disadvantage to developers that are not publicly traded if their private ownership would count as a “parent company” and could therefore establish a cap on potential interconnection requests but a similar ownership structure in a public company would not trigger the cap.

• • On the other hand, if only a holder of a majority of ownership interests (>50%) counts as “parent company,” developers will use joint ventures or invent novel ownership structures to avoid triggering this threshold. Finally, there are economies of scale and numerous synergies that come from a single developer intensely focusing its efforts on a given region. Having a developer who knows the local landscape or a region and has robust ties to the community in which they seek to develop projects is likely to facilitate a project’s success, while mechanisms such as those discussed elsewhere in this initiative and the reforms of FERC Order 2023 will help ensure requests are not submitted arbitrarily.

[1] CalCCA comments on Straw Proposal, response to Question 2, Oct. 12, 2023.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

No comment.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

No comment.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

GSCE would appreciate better understanding how much time savings can occur from removing the off-peak deliverability study. Although it is not currently providing much value, it could have a role in the future RA slice of day framework.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

No comment.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

No comment.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comment.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

No comment.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

No comment.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

No comment.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

No comment.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

GSCE is concerned that this proposal can require a significant financial commitment with insufficient notice. At the same time, we appreciate the intent behind this proposal.

GSCE supports more advanced notice be provided to help balance this proposal. Given that CAISO will be requiring the notice to proceed and third posting dates to be included in the GIA, the earliest notice to proceed date for a shared upgrade should be known by CAISO and the PTO (potentially well in advance of the 60-day notice currently proposed). GSCE recommends that CAISO or the PTO share with all interconnection customers of a shared network upgrade the earliest notice to proceed date included in an executed GIA as an informational notice (perhaps as part of the quarterly transmission development forums to account for the fact the earliest NTP date may move a bit earlier in the study process and create administrative burdens to track), and then again provide the official notice to each interconnection customer in the 60-90 window as is currently being proposed.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

No comment.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

No comment.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

No comment.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comment.

1. Please provide a summary of your organization’s comments on the revised straw proposal

GridStor primarily seeks further revision and refinement of the scoring criteria matrix. As presently offered, the rubric overweights LSE interest and will create a situation where transmission-owning entities’ discretion is determinative of the larger share of projects selected for study. In addition, while GridStor welcomes the ISO’s removal of a number of problematic criteria, it has not proposed many additional criteria; as a result the rubric creates a screening mechanism that will prioritize projects based on a couple of criteria at most.

GridStor also notes that the ISO’s revised proposal does not take into account any matters relating to the post-GIA process of interconnection completion. We recommend that the ISO include the topic of timelines for post-GIA interconnection completions—both informational transparency and compliance matters—in any future Track 3 or subsequent initiative. The recently enacted California legislation SB 410, which sets timelines for distribution interconnection and provides transparency into resourcing by responsible entities, serves as a potential model for the ISO to emulate that is within its authority.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

To ensure interconnection customers make informed siting decisions aligned with the ISO’s intent, CAISO has to provide sufficiently detailed information regarding zones well in advance of implementing new rules and opening request windows.

GridStor also notes that ever-changing data on priority zones poses a high risk that the available capacity at a given location published by the ISO will always lag the real numbers as they will change with every cluster during the interconnection process and the TPD process.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

GridStor believes it is critical that the limitation on acceptance of interconnection requests for study and/or the initial gating requirements for interconnection do not result in privileging a small handful of companies. One way to accomplish this goal is a limitation on the number of projects or amount of capacity from a single company (including its affiliates) in any single cluster study. For administrative ease and fairness to all offers, we recommend that any such cap be applied after all interconnection requests have been scored (including DFAX tie-breaking) but before the use of auctions for tie-breaking. The ISO would determine after its initial scoring screening whether any single developer’s projects selected on scoring alone exceeds the cap; if so, the ISO would confidentially approach the developer and request that the developer use its own discretion to rescind projects of number/amount of capacity that brings that developer back under the cap. This will also then potentially allow further projects in under the 150% threshold for each zone, and the ISO can iteratively determine after each withdrawal and backfilling whether any single developer exceeds the cap.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

Overall, GridStor recommends that scoring be changed to weight LSE interest to account for up to 20% of overall score, down from 40%. The two other areas of System Need and Project Viability should have equal weight (e.g., 40% apiece).

GridStor also notes that the relative dearth of criteria should be a warning sign that this prioritization approach may overindex projects to only one or a handful of criteria. GridStor has offered a number of potential criteria that have a public policy rationale and diversify the basis on which projects may be prioritized. The ISO has rejected all of these (as well as eliminated its initial proposal for projects in load pockets not needing ADNUs). In place of these proposals, there are not new criteria. While there may be valid reasons to reject proposed criteria, the absence of new criteria makes the rubric overly thin.

Fundamentally, the ISO would best be served in this exercise by seeking a diverse portfolio of projects through a portfolio approach, rather than a project-by-project screen. The ISO effectively accomplishes this by outsourcing the role of portfolio selection to (transmission-owning) LSEs. This creates opacity and deflects accountability for outcome. To be both more transparent and accountable to stakeholders, the ISO should instead make clear the portfolio diversity criteria it seeks to meet and then assemble those portfolios from a mix of pre-specified scoring criteria and diversity criteria—taking responsibility those decisions before FERC.

With respect to specific criteria--

1) GridStor recommends lowering the weighting of LSE Interest:

The criterion of LSE interest in the draft is too heavily weighted in overall scoring and presents a high risk that LSE interest will become the determinative criterion for which projects get studied. Given that LSEs are also transmission owners, this presents a flagrant violation of open access principles.

While the ISO indicates it is limiting the reach of LSE interest by only allocating points equivalent to 35% of available TPD to LSEs, the ability of each LSE assign points to projects that cover only a portion of a project’s capacity enable LSE interest to be determinative for a much larger share of interconnection requests. For example, if LSEs award points equal to 50% of each project’s nameplate, that means overall projects totaling 70% of available TPD will be awarded scoring weight from LSE interest. Because LSE interest is weighted 40%, more than any other factor, those partial scores (which in the example would be equal to 20% overall scoring weight) will also be the single greatest factor of any individual criterion (as the largest single criterion value is long-lead time resources, which can only account for 18% of overall scoring).

It also bears mentioning that many interconnection requests will meet few or no criteria in the proposed scoring criteria. As a result, the 40% weight for LSE interest actually understates the determinative impact of this criterion on project prioritization.

The ISO’s proposal risks running afoul of open access transmission principles established by FERC Order 888 and subsequent precedents. Most of the LSEs in CAISO are also transmission owners. If the ISO establishes a system of studying only projects that meet certain scoring criteria, and it turns out that LSE (i.e., TO) discretion is the single greatest factor determining which projects are studied for interconnection (i.e., market entry), then the ISO will have created a system that is unlikely to gain FERC approval.

To avoid this outcome, LSE interest should be weighted to not more than 20% of a project’s overall score. Doing so will be more likely to render LSE interest determinative only for a subset of projects, which provides an important balance between the ISO’s need to prioritize projects and its obligations to uphold open access to transmission.

2) GridStor recommends modifying “Expansion of an existing facility:”

The criterion of “expansion of an existing facility” in the draft should be modified to focus on sites adjacent to substations. As CAISO staff indicated on the September 28 IPE working group call, the purpose of this criterion is as a proxy for viability of an interconnection requests, based on an assumption that sites at or adjacent to existing electric facilities would be easier to permit and/or faster to construct. Yet the existence of an operating facility does not meaningfully correspond to either concept—particularly if significant network upgrades will be needed anyway to complete interconnection of that expansion. A feature that is most likely to speed interconnection is siting adjacent to substations where capacity already exists, and CAISO may accomplish similar goals by awarding points to this characteristic instead.

Modifying the criterion this way would also reduce the challenge to open access principles and potential for perverse incentives. The draft proposal would mean that CAISO privileges existing interconnection customers’ new requests over those of other interconnection customers. It is contrary to open access principles that a key determinant of an interconnection request’s acceptance could hinge on an interconnection customer’s control of already-interconnected resources, even where no spare capacity is otherwise available. Additionally, the draft proposal creates incentives that border on gaming, as the draft proposal may drive interconnection customers to propose small projects that can be built quickly and then serve as a basis for much larger subsequent expansion requests.

Alternatively, CAISO should recast this criterion to cover interconnection requests that use previously disturbed sites, not just sites that already host operating power system resources. Numerous large commercial & industrial sites feature similar characteristics as bulk electric power facilities, and they should be extended the same assumptions as bulk power facilities regarding ease of permitting and construction. In some instances, the permitting and construction may be faster than for sites hosting bulk electric supply resources, such as sites already zoned for industrial use without operating facilities, electric or otherwise.

Finally, CAISO should answer to clarifying questions about this criterion:

• Can an interconnection request receive points for this criterion if the proposed project is directly adjacent to an existing facility owned by a different interconnection customer? If not, why not?
• Does “existing facility” include projects that are connected at distribution and provide wholesale services in CAISO (i.e., WDAT projects)? If not, why not?
• Can an interconnection request receive points for this criterion if the “existing facility” has an announced retirement date?

3) GridStor recommends expanding on how the ISO will demonstrate need for local RA:

CAISO does not indicate clearly how it will assess demonstrated need for additional local RA in an LCRA. While the ISO references its annual local capacity technical study, it does not state clearly what figures it will base its assessment on. GridStor requests that method be clearly described.

Additionally, the ISO’s annual local capacity technical study does not capture all the LCRAs and sub-LCRAs where additional Local RA resources are needed. For example, a projected deficiency may not account for existing fossil generation that retires in order to lower ratepayer costs or meet state greenhouse gas targets. We agree with New Leaf Energy that CAISO should apply additional, administratively easy-to-implement methods using existing sources of published data to make need determinations, such as its Net Qualifying Capacity (“NQC”) report to properly account for future thermal generation retirement; the CPUC’s annual RA Report to identify where Local RA prices are significantly higher (e.g., 20%) than System RA prices; and/or whether an LSE or Central Procurement Entity has documented procurement challenges in an LCRA.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

GridStor requests clarification from the ISO as to whether the calculation of the project MWs that meet 150% available & planned capacity of a zone will be in any way impacted by the existence of WDAT projects that have also requested interconnection within a given zone.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

GridStor supports the ISO’s draft proposal.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

GridStor supports the draft proposal.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

IEPA seeks clarity on the terms used to identify organizations and resources, and more detail within the scoring criteria to differentiate projects’ viability from one another.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

IEPA has no comment on this section.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

IEPA opposes the 25% developer cap. However, if CAISO continues with this proposal, IEPA proposes a “developer” to be defined as an “interconnection customer or an aggregate owner of projects within the cluster.” IEPA believes this definition would provide the necessary limits on one company submitting projects over the limit by capturing the varying company structures that fund interconnection projects. The broad definition of “parent company” risks confusion and might allow for partial project owners to submit in aggregate.

IEPA also requests further justification for CAISO’s proposal to limit requests in zones to 150% of available capacity. Given the historical low success rate of projects in the queue achieving commercial operation, IEPA suggests that CAISO should increase the capacity limit to a more reasonable number.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

Summarily, IEPA hopes to see more detail within the scoring criteria that differentiates projects’ viability from one another. The current scoring criteria are weighted heavily towards LSE interest and policy related indicators rather than project specific.

LSE Interest: IEPA seeks guidance—a qualifying list—on what is a “non-CPUC jurisdictional entity.” IEPA wants to ensure non-LSEs do not receive automatic advancement without showing they have met the same standards as an LSE. Additionally, interest from corporations as offtakers of new projects should be assigned weight given how large of a segment this group entails. Corporate PPAs are not currently included in this Straw Proposal and would not earn points on this proposed scoring criteria system.

Project Viability: The point allocation under project viability categories should have a sliding scale within each category and weighted the same to ensure all types of projects that are viable can compete for scoring criteria.

“Engineering Design Plan” should be a sliding scale to promote competition and allow projects that are further along to score more points. For example, instead of a flat 15-point allocation for the aforementioned category, the points should be awarded on a sliding scale: 20%, 40%, and 60% engineering design should receive 5, 10, and 15 points, respectively. Having an “all or nothing” approach for all categories in this section will provide little distinction between projects that are further along in their engineering designs and business partnerships. There are industry standards for engineering and cost estimation detail levels, such those outlined by the Association for the Advancement of Cost Engineering,1 which can be used so that CAISO does not need to create subjective category distinctions.

Points allocated under “Expansion of an existing facility” and “Expansion of an existing facility where the existing Gen-Tie already has sufficient surplus capability to accommodate the additional resource” should be joined together where the former receives an allocation of points and the latter receives an additional set of points that are equal to or less than half the points given for “Expansion of an existing facility.” Providing 70 points to an existing facility with Gen-Ties does disadvantage many other projects that might be similarly situated in project readiness, but are not connected to an existing facility. IEPA recognizes the value of projects that are connected to existing facilities, including those with Gen-Tie surplus, and projects that are not connected but are low risk for project production, like Corporate PPAs.

This is another key reason why distinctions are needed in the engineering design and business partnership categories instead of “all of nothing”. CAISO should also reconsider inclusion previously proposed categories under Project Viability that make distinctions between new facilities, such as site control beyond the minimums required by FERC Order 2023 and permitting status.

System Need: IEPA requests clarity on the “long-lead time” definition. Is this definition based on the CPUC’s definition for long-lead time2 , or will a new definition be put forward? The current definition provided in the straw proposal is confusing and contains circular logic. The CPUC uses the CAISO queue as an indication of commercial interest for developing the Preferred System Plan that feeds the TPP analysis, but the proposed long-lead time definition would only assign points to projects that are already located where the TPP has approved transmission. A new project applying to get into the CAISO queue may be part of an LSE’s IRP plan that has yet to be studied by the TPP and thus would have no ability to obtain points under the current definition.

1. 96R-18: Cost Estimate Classification System – As Applied in Engineering, Procurement, and Construction for the Power Transmission Line Infrastructure Industries (aacei.org), https://web.aacei.org/docs/defaultsource/toc/toc_96r-18.pdf

2. D.20-03-028 and R.20-05-003 Assigned Commissioner’s Ruling and Scoping Memo September 24, 2020 https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M347/K608/347608446.PDF.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

IEPA has no comment on this section.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

IEPA has no comment on this section.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

IEPA has no comment on this section.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

IEPA has no comment on this section.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

IEPA has no comment on this section.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

IEPA has no comment on this section.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

IEPA has no comment on this section.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

IEPA has no comment on this section.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

IEPA has no comment on this section.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

IEPA has no comment on this section.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

IEPA has no comment on this section.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

IEPA has no comment on this section.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

IEPA has no comment on this section.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

IEPA has no comment on this section.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

IEPA has no comment on this section.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

IEPA has no comment on this section.

1. Please provide a summary of your organization’s comments on the revised straw proposal

Intersect Power supports (or does not object to) the CAISO changes in the Revised Straw Proposal, in these areas, with the changes and clarifications noted in the sections below: 

• Provision of consolidated data for each POI and transmission zone, updated after the upcoming TPD Allocation process
• Exemptions from the scoring rubric for Energy Only projects, and for projects seeking deliverability in zones without available capacity (clarification requested)
• Option B enhancements
• GIA execution deadlines
• Project viability criteria for Energy Only projects
• GIA amendment reduction
• Shared Network Upgrade third postings, NTPs, and payments
• PTO commencement of work on Network Upgrades once third postings and NPTs have been made, and monthly payments begin for those upgrades
• Delay in Construction Sequencing notification until projects start construction
• $100K deposit for ISO implementation of interconnection projects

Intersect Power opposes, or proposes substantive revisions to, Revised Straw Proposal elements in these areas:

• As stated in prior comments submitted by Intersect Power, we remain opposed to the establishment of capacity caps implemented on a zonal level and strongly encourage the CAISO to instead take a simpler approach by implementing a reasonable maximum total queue capacity and maximum number of projects for each Cluster.
• Developer cap on Interconnection Request submittals
• Several elements of the scoring rubric, including:
• Complete bypass of the rubric by resources in approved non-CPUC jurisdictional LSE resource plans, and counting of these resources against the 150% study limit;
• Inordinate 40% weighting of “LSE Interest” for the other projects, so early in the process
• Continued retention of the auction element as a tie-breaker, a mechanism supported by almost no stakeholders, instead of simpler tie-breaker mechanisms
• Delay in Construction Sequencing notification until 9 months before the In-Service Date, for COD accelerations or delays

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Intersect Power fully supports CAISO efforts to provide consistent, consolidated, usable data, by POI and zone.  However, it is not clear which separate and consolidated data types will be available when, particularly for Clusters 14 and 15.  At a minimum, any information provided in January must be updated for Cluster 15 once the results of the next TPD allocation process are complete.

It would be helpful if the CAISO could provide a timeline showing the available and updated data that will be available over the next few months, at least.

For Cluster 16 and beyond, the CAISO should set a cut-off date for the assumptions applicable to the next Interconnection Request window.  For example, if the IR submittal window will be in April, CAISO can use the prior June 1^st as the cut-off date for assumptions to be used for Intake processing.  That date would allow for completion of other processes (e.g. TPP and TPD allocation) that affect the following cluster cycle. 

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Intersect Power’s comments on most of the major Proposal elements are provided in the separate questions below.  However, the proposed developer cap on Interconnection Request submittals is not covered by any of those separate questions, and therefore it is addressed here. 

Developer cap on IR submittals

Intersect Power strongly agrees with Vistra that the Proposal does not meet its burden of proof to support this proposal.  Simply noting that some developers submit many Interconnection Requests is not the same as showing that those IRs are less likely to be viable, or more likely to be withdrawn, than those submitted by smaller developers submitting only one or two IRs. 

In fact, a credible argument can be made that experienced developers are likely to have more resources and skills to bring projects successfully to completion, having likely done so before.  (This is one reason Intersect Power suggests consideration of developer experience with project technology and size as one scoring rubric element – see below.)

At a minimum, the CAISO should clarify how it would identify “parent companies,” as well as joint ventures and other partial-ownership structures, as well as any differentiation between ownership and control of an entity. 

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

Applicability of scoring rubric:  As a starting point, CAISO should confirm in writing the applicability of the scoring rubric, based on the clarifications offered in the stakeholder meeting. 

Thus, the CAISO should confirm that the scoring rubric would apply only to projects submitting Interconnection Requests seeking deliverability in transmission zones with available capacity (and which are not included in non-CPUC jurisdictional LSE resource plans – see additional comments on that below).  That is, the scoring rubric would not apply to:

• Any Interconnection Requests in zones without available transmission capacity; or
• Energy Only Interconnection Requests in zones with available transmission capacity.

So, please clarify that IRs in either of the two categories above will be accepted regardless of readiness scores.  In addition, impacts of unrestricted acceptance of Energy Only IRs in zones with available transmission capacity should be discussed further.

LSE Interest scoring element – Non-CPUC jurisdictional LSE preferential treatment:  Intersect Power strongly objects to the proposal to allow all resources in an approved non-CPUC-jurisdictional LSE resource plans to evade the readiness scoring rubric applicable to other resources, thereby reducing the capacity available to those (possibly more ready) projects. Intersect Power objects on both those grounds, i.e., that: (1) those projects evade the scoring rubric; and (2) their acceptance counts against the capacity available to other resources with strong LSE interest.

Several reasons have been offered for this discriminatory and inequitable treatment, including these:

• These entities are small, so the overall impact would be small.  Some are small, but others (e.g., NCPA and some munis) are quite large. 
• These entities’ interests were not adequately considered in past TPP cycles.  That may or may not have been true, but their projects have the same opportunity to compete for study in the same locations as other LSEs, and this should not be the forum to rectify those perceived issues.

The harm caused by this undue preference is compounded by the fact that these projects will reduce the capacity that can be studied for other projects.  Moreover, the expressed preference of these entities in stakeholder meetings is to source their supply close to their load which, while understandable, could lead to shutting out more ready resources and/or resources preferred by other (smaller) LSEs in some key locations.

This proposal would be more acceptable only if modified as follows:

• Limited to small LSEs.  There is no reason to grant any preference to large, sophisticated entities that do not need such protection
• Expanded to other small LSEs.  The applicable regulatory authority has simply not been justified as grounds for differential treatment.
• Reduced in scope to limit the harmful impact to others, i.e., either: (1) Exempt these supposedly small capacity amounts from the 150% study limit; or (2) limit the preference to the respective LSE load shares for the applicable constraints.  This would give these entities preference only for a reasonable share of the available capacity, overall and in specific areas.

LSE Interest scoring element – more generally:  Intersect Power is very concerned about the impact of the substantial weighting of LSE preference at this very early stage of development –a complete bypass of the readiness scoring for non-CPUC jurisdictional LSEs, and a 40% weighting for CPUC-jurisdictional LSEs.  In both situations, the selection criteria may violate open-access principles by making the selection criteria less transparent and more subject to preferences for LSE self-builds.  At a minimum, the weighting should be reduced, perhaps to something like 20%.

In addition, the CAISO should include some provision for interest from non-LSE off-takers.  The CAISO has recently refined its definition of PPAs in the TPD allocation process to provide for such off-takers, and earlier proposal versions of this initiative included interest from “qualified” non-LSE off-taker entities. 

Project Viability scoring element - Demonstration of “business partnerships for future supply of major equipment prior to COD:  This element is vague, and Intersect Power suggests below some potential criteria that could be used to implement this concept. 

• Overall developer experience and success at bringing on-line and/or operating projects of the technology type and size of the proposed projects.  This criterion could be similar to the CPUC “RPS Project Viability Calculator” measure (https://www.cpuc.ca.gov/search#q=%22viability%20calculator%22&sort=relevancy).  That scoring measure counts by the CPUC for up to 25% of a project viability score, with “project development experience” weighted to 20% and “ownership/O&M experience” worth up to 5%. This broad experiential measure would capture, not only productive relationships with vendors, but also overall competent and experienced project construction skills and operating experience.
• Master Service Agreement for purchase of major equipment, such as transformers, inverters, solar modules, and/or key technology-specific equipment.
• Purchase order for such equipment by the LLC or other ownership entity, with extra points for a demonstration that the equipment is specific to the site or project.
• Increase the weighting for this item beyond 15 points to a minimum of 30 points, and increase the weight of project viability factors by reducing the weight of LSE interest. The items suggested above will have a high correlation to project success and timeliness.

Project Viability scoring element – Expansion of “existing facilities:”  This feature shows up in two line items:  (1) “Expansion of an existing facility” (binary, 0 or 30 points); and (2) “Expansion of an existing facility where the gen-tie has available capability for the additional resource” (binary, 0 or 40 points). The Proposal states that the “existing facilities” for these scoring items must have already reached COD when the IR is submitted – otherwise, they are just “speculative.”

Intersect Power respectfully disagrees.  First, using planned facilities more efficiently, to serve multiple projects, inherently makes both projects more viable, including the first project, which the developer has even more incentive to complete because more than one project is dependent on the facilities in question. 

Second, projects advanced in the interconnection process should be considered as “existing” for this purpose.  Thus, for example, a project with an executed GIA that has provided a second posting, or a third posting and NTP, should be able to serve as a basis for the shared facility scoring for an additional Generating Facility using the same equipment. 

At a minimum, a more granular scoring element would at least give some partial credit for advanced facilities not yet in operation.  For example, sharing facilities with a project that has an executed GIA could be worth half the points in each area, and sharing facilities with a project that has provide a third posting and NTP should be worth the entire points available.

Additionally, this item should not just be limited to shared gen-ties. This concept should be extended to projects relying upon an affiliate’s Stand-Alone Network Upgrades (SANU’s) that increase access for future generators to the transmission system, e.g., new switchyards constructed on transmission lines providing for future interconnection positions, should be treated similarly to project’s utilizing a shared gen-tie. At a minimum, IC’s should have an explicit ability to put forth an argument for the CAISO’s consideration for why their affiliate’s SANU’s should qualify it for readiness scoring criteria in the same manner as a shared gen-tie.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

Below is an excerpt from this section of the Proposal (bolding added):

In the study process for each zone, the ISO will add projects to various substations within each zone until network upgrades are triggered. In zones/interconnection areas/sub-zones with nested constraints, the sub-zone with the constraint will be filled up until it triggers an upgrade, and at that point the sub-zone will be ‘frozen,’ limiting any additional interconnections in that area. Other projects seeking to interconnect in that area will be eligible to interconnect in the broader zone until 150% of the capacity is reached.

The last sentence in this paragraph was removed in the stakeholder meeting presentation, without any clear explanation.

On its face, the deleted language seems to hold out the possibility that an otherwise viable project could still be accepted for study if there is another feasible Point of Interconnection within the zone.  Intersect Power believes that this language should be restored to the Proposal.

At best, developers will be working based on educated guesses about how much capacity is available at different POIs, but even then, they have no way to determine how many other projects will be proposed at those locations.  It seems reasonable for those projects that may not score well enough to locate at a constrained POI might be accepted for study if there is a feasible nearby alternative POI, ahead of a less-ready project proposed in the same zone.

More broadly, the CAISO should include some flexibility in this criterion.  For example, even if a Network Upgrade is triggered, it might be a very cost-effective investment given the additional capability it would enable, and in any case the projects triggering it should be given an opportunity to fund it under an Option B framework.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

The changes the CAISO has made to this element of the proposal – requiring only projects who must participate to submit bids, and making bid amounts refundable after COD – have made this proposal more acceptable.  However, Intersect Power still believes that this mechanism will be complicated and is unnecessary; should the scoring rubric and DFAX tiebreaker be insufficiently limiting, Intersect Power prefers simpler methods like pro rata awards and acceptance of all projects “on the margin.”

In addition, if the CAISO proceeds with an auction mechanism, the proceeds should be completely refundable at COD, with interest.  Phasing transmission-cost refunds over 5 years provides a phase-in of those costs into the respective PTO rate bases, but there is no corresponding justification for dragging out auction-bid refunds.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

Intersect Power appreciates the changes the CAISO has made to the Option B framework, specifically:

• Reduced up-front financial security requirements
• Clarifications that Option B projects would receive: 
  • FCDS/PCDS once the required upgrades are complete, i.e., they do not have to compete for TPD in the allocation process.  (The exception would be if the ADNU is later approved as needed in the Transmission Planning Process, where the project would be relieved of its cost responsibility but would then have to compete against other projects for their FCDS/PCDS status.  See comments below.)
  • Local Delivery Network Upgrade (LDNU) reimbursement after COD, like other projects. 
  • The benefit of any financial security posted by projects sharing the upgrade that withdraw, under Section 7.6 “Application of Non-Refundable Amountst.”   Presumably, this is a reference to Section 7.6(b) (“Calculation and Disbursement of Non-Refundable Interconnection Financial Security for Still-Needed Network Upgrades At or Above $100,000 Threshold”), which provides for a proportion of non-releasable security from withdrawing projects to be applied to the remaining cost of the upgrade, to mitigate the impact to remaining customers bearing the cost. 
• Clarification that Option B projects could self-build and negotiate third-party agreements for funding ADNUs, including any additional financial protections they agree to amongst themselves, under GIDAP Section 11.3.1.4.4 “Posting Related to Interconnection Customer’s Stand Alone Network Upgrades.”  That tariff section provides that the applicable IC cost responsibility (and, presumably, associated financial-security postings) would be released once the SANU and cost responsibilities are documented in executed GIAs.

Intersect Power’s comments are in two areas, where: 

• The proposed revisions should be expanded or otherwise enhanced; and
• Additional revisions should be made.

Expansions/enhancements of proposed Option B revisions

• If an Option B ADNU is approved in the TPP, each applicable developer should have a choice between: (1) the proposed cost-responsibility and security relief, with the need to compete for an FCDS/PCDS allocation; or (2) retaining the existing arrangement, with cost responsibility but a guaranteed FCDS/PCDS award.  In particular, projects that are far along in the development process, or those participating in a SANU self-build arrangement, may simply choose to retain their existing arrangements for the certainty they would provide.
• GIDAP Section 7.6 would have to be revised to allow the full benefit of forfeited ADNU security to go to remaining projects.  Specifically, if the CAISO is requiring additional up-front security for Option B customers to fund ADNUs, then this up-front amount should be added to any proportional allocation of other posted security.

Additional Option B revisions that should be made:  Intersect Power continues to believe that the CAISO should include these elements in its Option B reforms:

• Allow Option B elections for projects seeking deliverability in zones with available capacity that do not make the scoring cutoff, perhaps with the same up-front deposit required in areas without available transmission capacity.  Intersect Power fails to see the harm in having developers voluntarily agree to fund additional transmission in areas with high locational demand, even if that would require some additional analyses in the study process.
• Provide advance estimates of potential CRR revenue for the applicable ADNUs, upon request.  Otherwise, it will be difficult for project sponsors to estimate net cost of an ADNU.
• Allow reimbursement of Option B ADNU costs to the extent that sponsors can demonstrate system benefits.  As it is, these upgrades will be open for use by all as part of the CAISO’s transmission network, and cost reimbursement would be appropriate by the beneficiaries of such projects, as provided for under regional transmission-planning practices.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

With all due respect, Intersect Power notes that the CAISO has not yet even determined the content of the studies under Order 2023:  (1) Cluster Study (90 CDs); (2) Cluster Re-Study (150 CDs); and (3) Interconnection Facilities Study (90-180 CDs). 

In fact, the study process is completely unclear – it certainly does not look like a “single-study process,” and it certainly is not clear whether this information could continue to be provided in the 14-month total duration.  Moreover, as noted at the stakeholder meeting, this information may prove useful under the new Slice of Day framework.

Thus, Intersect Power suggests postponing a decision about this part of the proposal until the above issues have been clarified as part of the Order 2023 compliance effort.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

Intersect Power is extremely disappointed that the CAISO is once again backing away from this broadly supported concept, without even any sensitivity studies or further consideration of the net impact on either PTOs or ratepayers.  The Straw Proposal already greatly constrained this concept through retention of security to mitigate PTO impacts (again, considering only potential costs but not potential benefits), and the Revised Straw Proposal seems to be the “final nail in the coffin,” leaving vague and speculative outside funding sources the only possible path.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

Intersect Power continues to believe that LOS requests should be allowed more than 9 months in advance.  While Intersect Power appreciates the longer lead time compared to the current 5-month period, given the extremely high benefit from such earlier information, Intersect Power recommends continued consideration in the future of ways to offer a longer timeline of at least 2 years.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comment.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

Intersect Power continues to oppose this proposal.  As the CAISO has said, few projects use it, but the CAISO has not demonstrated any harm from retaining this option. 

The CAISO has not justified the need for this proposal.  The Proposal states (at p.70) that “suspension rights currently give customers too much unilateral power to remain stagnant in the queue,” but earlier proposal versions stated that few projects even use such rights.  Moreover, suspension rights are hardly “unilateral” given recent tariff changes requiring the equivalent of a modification request, limiting exercise to situations where no other projects would be adversely impacted, and limiting the duration where the full three-year period would cause the project to exceed 7 years time in queue.

In other words, there is no need for this proposal.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

Intersect Power continues to oppose restrictions to transferring TPD between projects, other than the current POI and voltage-level rules, including restrictions on the newly Energy-Only projects transferring deliverability to other projects.  The Proposal states that:

• Such projects can only remain in the queue if they provide Energy Only PPAs at the time the TPD transfer is requested.  As was obvious from the stakeholder meeting discussion, but developers and potential off-takers of the Energy Only projects would be reluctant to execute PPAs while the RA status of the “from” project is uncertain, i.e., without knowing whether the transfer will be approved.

Intersect Power suggests that the CAISO allow a set period – e.g., 1 year – for the “from” project to provide an Energy Only PPA in order to remain in the queue.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

Intersect Power has long supported measures to remove non-viable projects from the queue, and it does not object to the concepts of GIA execution deadlines and Energy Only project viability criteria.  However, Intersect Power has several comments to improve the Straw Proposal proposals in these areas.

GIA execution deadlines

Intersect Power continues to maintain that simply setting deadlines, without any other timeline or process structure, is simply not fair or workable.  These concerns were amplified by the discussion at the stakeholder meeting indicating that each project might separately have to request a draft GIA on its own.  Instead, the process would be much more transparent and effective if the CAISO would:

• Set uniform dates for PTO tender of draft GIAs for each “traunch” of contracts, without the need for each developer to request a draft separately.  Intersect Power suggests tender dates approximately 4 months in advance of the respective execution deadlines.
• Set uniform turnaround times for drafts applicable to each side, e.g., two weeks.

This timing would allow the draft agreements to be issued with enough advance timing and to progress forward at a reasonable pace, with ample time for conclusion and execution or, alternatively, filing of unexecuted agreements.  PTO turnaround-time delays would extend the execution deadlines, though developer turnaround-time delays would not.

Viability Criteria demonstrations

• Projects with deliverability:  The current CVC appear to be working well.  Absent some justification (which is not provided in the Proposal), there does not appear to be a need to disrupt that process, including the additional time allowed for an executed PPA to retain deliverability where a project meets the other applicable criteria.
• Projects without deliverability (including those which had it but no longer do):  Intersect Power does not object to the proposed criteria at 7 years time in queue, with the caveat that, similar to the current CVC for projects with deliverability, they should have a similar extension to produce an executed PPA.
• PTO delays:  The current CVC for projects with deliverability (and other selective restrictions on COD delays for Group 3/Group D projects) do not apply if the need for a COD extension is due to a PTO delay.  Intersect Power believes that the CAISO should allow for an extension to all Viability Criteria demonstration deadlines if the project COD has been significantly delayed by a PTO delay.  Such projects are already impaired by the PTO delay, and they should be given additional time to comply if their timelines are disrupted by PTO delays – for example, a project whose COD is delayed for years (e.g., due to SCD upgrades) should not have to provide a PPA years before that.

The CAISO also needs to clarify the definition of a qualifying PPA in the proposed viability demonstrations.  Many early projects received their TPD awards before the current 5-year minimum term was applied for new TPD awards; consistent with CAISO practice, the required PPA terms should be consistent with the required PPA terms when the TPD award was received (or, for projects receiving deliverability before establishment of the TPD award process, when the interconnection studies were complete).

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

Intersect Power does not object to the requirement that a project should begin construction before noticing the CAISO that is it invoking Construction Sequencing.  However, once construction starts, Intersect Power does not see how delaying this notice helps either PTOs or developers in scheduling the work.  Moreover, the proposal still does not address situations where developers seek to accelerate CODs.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

Intersect Power does not object to the CAISO’s proposal for all projects to provide third postings, NTPs, and (as a clarification from the stakeholder meeting) payment initiation for shared upgrades when the first sharing project moves forward.

Intersect Power considers the other parts of the proposal – separate posting/NTP/payment timing and PTO obligation to begin the upgrade – as integral to its support for this proposal.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

Intersect Power supports the proposal for more flexible GIA amendment timing.  As was described in Intersect Power’s previous comments, LGIA amendments resulting from MMA approvals are superfluous and they consume an unnecessarily large amount of CAISO, PTO, and IC resources. Intersect Power encourages CAISO to better formalize the understanding that MMA approvals are effective and enforceable within the Tariff and/or Pro Forma LGIA so that financing parties can confidently rely upon the final MMA approvals, in lieu of an amended LGIA, which should eliminate the push from Interconnection Customers to make the subsequent revisions to the LGIA.

However, we are concerned about SCE opposition to this proposal, even though CAISO cited as support for its proposal the high PTO burdens from continual GIA amendments.  We are especially concerned about SCE’s contention that it will need even more time than the proposed extensions to process MMA requests if the MMA reports must contain schedule and payment updates. 

CAISO needs to sit down with SCE and the PTOs to work out a consensus position on this issue.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

As noted above, Intersect Power considers the PTO obligation to begin the upgrade once third postings, NTPs, and payment initiations are received as integral to its support for this proposal.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

Intersect Power does not object to the CAISO’s proposal for a $100K deposit for administrative costs, but subject to audit rights for expenses incurred if developers have questions about billed expenses.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

Intersect Power reserves the right to comment later on this item, pending clarification from the CAISO.  As discussed at the stakeholder meeting, the Proposal states that the current requirement for asynchronous generators to provide phase angle measuring unit (PMU) data at a resolution of 30 samples per second (upon request from the CAISO or PTOs) is “not granular enough” and proposes revision the granularity to 16 samples per second.  However, that proposal would seem to reduce granularity, not increase it, so the CAISO should clarify this proposal before requesting feedback.

1. Please provide a summary of your organization’s comments on the revised straw proposal

LSA supports (or does not object to) the CAISO changes in the Revised Straw Proposal, in these areas, with the changes and clarifications noted in the sections below: 

• Provision of consolidated data for each POI and transmission zone, updated after the upcoming TPD Allocation process

• Option B enhancements, as far as they go

• GIA execution deadlines

• Project viability criteria for Energy Only projects

• GIA amendment reduction

• Shared Network Upgrade third postings, NTPs, and payments

• PTO commencement of work on Network Upgrades once third postings and NPTs have been made, and monthly payments begin for those upgrades

• Delay in Construction Sequencing notification until projects start construction

• $100K deposit for ISO implementation of interconnection projects

LSA opposes, or proposes substantive revisions to, Revised Straw Proposal elements in these areas:

• Developer cap on Interconnection Request submittals

• Several elements of the scoring rubric, including:

• Complete bypass of the rubric by resources in approved non-CPUC jurisdictional LSE resource plans, and counting of these resources against the 150% study limit

• Inordinate 40% weighting of “LSE Interest” for the other projects, so early in the process

• Continued retention of the auction element as a tie-breaker, a mechanism supported by almost no stakeholders, instead of simpler tie-breaker mechanisms

• Delay in Construction Sequencing notification until 9 months before the In-Service Date, for COD accelerations or delays

• Effective elimination of the One-Time Withdrawal opportunity from the proposed framework.

LSA requests additional information/clarification for the Revised Straw Proposal elements in these areas:

• Exemptions from the scoring rubric for Energy Only projects, and for projects seeking deliverability in zones without available capacity

• The 150% capacity study limit in zones with available capacity

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

LSA fully supports CAISO efforts to provide consistent, consolidated, usable data, by POI and zone.  However, it is not clear which separate and consolidated data types will be available when, particularly for Clusters 14 and 15.  At a minimum, any information provided in January must be updated for Cluster 15 once the results of the next TPD allocation process are complete.

It would be helpful if the CAISO could provide a timeline showing the available and updated data that will be available over the next few months, at least.

For Cluster 16 and beyond, the CAISO should set a cut-off date for the assumptions applicable to the next Interconnection Request window.  For example, if the IR submittal window will be in April, CAISO can use the prior June 1^st as the cut-off date for assumptions to be used for Intake processing.  That date would allow for completion of other processes (e.g. TPP and TPD allocation) that affect the following cluster cycle. 

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

LSAs’s comments on most of the major Proposal elements are provided in the separate questions below.  LSA provides input in two areas here:

• The proposed developer cap on Interconnection Request submittals, which is not addressed in the template; and 

• The CAISO’s earlier proposal about whether Energy Only projects should be able to seek TPD in Groups A or B in the annual TPD allocation process.

Developer cap on IR submittals

LSA strongly agrees with Vistra that the Proposal does not meet its burden of proof to support this proposal.  Simply noting that some developers submit many Interconnection Requests is not the same as showing that those IRs are less likely to be viable, or more likely to be withdrawn, than those submitted by smaller developers submitting only one or two IRs. 

In fact, a credible argument can be made that experienced developers – like experienced surgeons – are likely to have more resources and skills to bring projects successfully to completion, having likely done so before.  (This is one reason LSA suggests consideration of developer experience with project technology and size as one scoring rubric element – see below.)

One quick indication of submittal of “unready” projects might be provided by an examination of the number of C14 and earlier projects were withdrawn early in the process, e.g., after scoping meeting and after Phase I Studies.  

At a minimum, the CAISO should clarify how it would identify “parent companies,” as well as joint ventures and other partial-ownership structures, as well as any differentiation between ownership and control of an entity. 

Ability of Energy Only projects to request TPD in Groups A or B

LSA notes that the earlier proposal to limit Energy Only projects currently in the queue to TPD Allocation Group C is not included in the Proposal, and we are hoping that is because the CAISO has decided to drop this proposal.

LSA strongly believes that the CAISO has not provided reasonable rationale for this proposal for pre-Cluster 15 projects.  If these projects can meet the applicable milestones (e.g., they secure a qualified PPA), LSA sees no reason to exclude them.  

That was the concept behind removing the inferior treatment of EO projects only recently, in the last TPD Allocation process (e.g., combining earlier Groups 1 and 4 into Group A, and combining Groups 2 and 5 into Group B).  These projects have been in the queue longer and may score higher in many viability measures than those just coming off the study process.

There are also situations where projects thought to be dead were acquired by others and resurrected, and given the framework today, that could include EO requests for deliverability.

Moreover, later approvals of additional TPP upgrades or successful Option B projects could provide additional deliverability later, and these EO projects should be allowed to request it then.

Finally, these projects may have been proceeding assuming that they could come back and request a TPD allocation if they qualify, and the CAISO should not change applicable rules at this late date.

However, some LSA members believe the issue of TPD allocations to Energy Only projects in Cluster 15 and later should be discussed as part of the CAISO’s Draft Final Proposal for Track 2 or the limited Track 3 process.  For example, there may be unintended consequences if the scoring rubric is not applied to Energy Only projects in the Intake process, but those projects can later request Group A or B TPD allocations.  Other LSA members disagree that this situation would be problematic, but LSA does not object to consideration of this issue for C15 and later projects.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

Applicability of scoring rubric:  As a starting point, CAISO should confirm in writing the applicability of the scoring rubric, based on the clarifications offered in the stakeholder meeting. 

Thus, CAISO should confirm that the scoring rubric would apply only to projects submitting Interconnection Requests seeking deliverability in transmission zones with available capacity (and which are not included in non-CPUC jurisdictional LSE resource plans – see comments on that below).  Thus, the scoring rubric – or any resulting exclusion from study – would not apply to:

• Any Interconnection Requests in zones without available transmission capacity; or

• Energy Only Interconnection Requests in zones with available transmission capacity.

So, please clarify that IRs in either of the two categories above will be accepted regardless of readiness scores.  In addition, impacts of unrestricted acceptance of Energy Only IRs in zones with available transmission capacity should be discussed further.

LSE Interest scoring element – Non-CPUC jurisdictional LSE preferential treatment:  LSA continues to strongly object to the proposal to allow all resources in an approved non-CPUC-jurisdictional LSE resource plan to evade the readiness scoring rubric applicable to other resources, thereby reducing the capacity available to those (possibly more ready) projects.  LSA’s objects on both those grounds, i.e., that: (1) those projects evade the scoring rubric; and (2) their acceptance counts against the capacity available to other resources with strong LSE interest.

Several reasons have been offered for this discriminatory and inequitable treatment, including these:

• These entities are small, so the overall impact would be small.  Some are small, but others (e.g., NCPA and some munis) are quite large. 

• These entities’ interests were not adequately considered in past TPP cycles.  That may or may not have been true, but their projects have the same opportunity to compete for study in the same locations as other LSEs.

The harm caused by this undue preference is compounded by the fact that these projects will reduce the capacity that can be studied for other projects.  Moreover, the expressed preference of these entities in stakeholder meetings is to source their supply close to their load which, while understandable, could lead to shutting out more ready resources and/or resources preferred by other (smaller) LSEs in some key locations.

This proposal would be more acceptable only if modified as follows:

• Limited to small LSEs.  There is no reason to grant any preference to large, sophisticated entities that do not need such protection.

• Expanded to other small LSEs.  The applicable regulatory authority has simply not been justified as grounds for differential treatment.

• Reduced in scope to limit the harmful impact to others, i.e., either: (1) Exempt these supposedly small capacity amounts from the 150% study limit; or (2) limit the preference to the respective LSE load shares for the applicable constraints.  This would give these entities preference only for a reasonable share of the available capacity, overall and in specific areas.

(LSA understands that some other WECC region tariffs allow LSEs to bypass readiness criteria for their own projects, but they do not exclude competing parties wishing to provide readiness in-lieu to be included in a study cycle.)

LSE Interest scoring element – more generally: 

LSA is very concerned about the substantial influence of LSE preference at this very early stage – a complete bypass of readiness scoring for non-CPUC jurisdictional LSEs, and a 40% weighting for CPUC-jurisdictional LSEs.  In both situations, the selection criteria may violate open-access principles by making the selection criteria less transparent and more subject to preferences for LSE self-builds (i.e., LSEs can include their own resources in their resource plans (non-CPUC LSEs) or assign large numbers of their points to their own resources (CPUC LSEs).  At a minimum:

• The proposed preferential treatment for non-CPUC jurisdictional LSEs should be eliminated or mitigated (see above); and

• The weighting for CPUC jurisdictional LSEs should be reduced, to around 20% or less.

In addition, the CAISO should include some provision for interest from non-LSE off-takers.  The CAISO has recently refined its definition of PPAs in the TPD allocation process to provide for such off-takers, and earlier proposal versions of this initiative included interest from “qualified” non-LSE off-taker entities as a selection criterion.  LSA’s earlier comments on those proposals requested clarification about which non-LSE entities would be “qualified” or how they could become so, but this Proposal does not mention them at all.

Project Viability scoring element - Demonstration of “business partnerships for future supply of major equipment prior to COD:  This element is vague, and LSA suggests below some potential criteria that could be used to implement this concept. 

• Overall developer experience/success at bringing on-line and/or operating projects of the technology type and size of the proposed projects, similar to that element in the CPUC “RPS Project Viability Calculator” (https://www.cpuc.ca.gov/search#q=%22viability%20calculator%22&sort=relevancy).  That scoring measure counts by the CPUC for up to 25% of a project viability score, with “project development experience” weighted to 20% and “ownership/O&M experience” worth up to 5%.

This broad experiential measure would capture, not only productive relationships with vendors, but also overall competent and experienced project construction skills and operating experience.

• Master Service Agreement for purchase of major equipment, such as transformers, inverters, and/or key technology-specific equipment.

• Purchase order for such equipment by the LLC or other ownership entity, with extra points for a demonstration that the equipment is specific to the site or project.

Project Viability scoring element – Expansion of “existing facilities:”  This feature shows up in two line items:  (1) “Expansion of an existing facility” (binary, 0 or 30 points); and (2) “Expansion of an existing facility where the gen-tie has available capability for the additional resource” (binary, 0 or 40 points). The Proposal states that the “existing facilities” for these scoring items must have already reached COD when the IR is submitted – otherwise, they are just “speculative.”

LSA respectfully disagrees.  First, using planned facilities more efficiently, to serve multiple projects, inherently makes both projects more viable, including the first project, which the developer has even more incentive to complete because more than one project is dependent on the facilities in question. 

Second, projects advanced in the interconnection process should be considered as “existing” for this purpose.  Thus, for example, a project with an executed GIA that has provided a second posting, or a third posting and NTP, should be able to serve as a basis for the shared facility scoring for an additional Generating Facility using the same equipment. 

At a minimum, a more granular scoring element would at least give some partial credit for advanced facilities not yet in operation.  For example, sharing facilities with a project that has an executed GIA could be worth half the points in each area, and sharing facilities with a project that has provide a third posting and NTP should be worth the entire points available.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

LSA has comments on both the 150% limit itself and the proposed application of this concept to sub-zonal constraints.

150% capacity study limit

LSA understands the CAISO’s objective of relevant and reasonable limits to the amount of capacity studied relative to the capacity available, and that some element of judgment may be needed.  However, the CAISO has not provided any empirical support or explanation for the proposed 150% limit, and LSA supports the need for additional justification for this limit. 

LSA thus requests that the CAISO provide a “proof-of-concept” analysis using previous queue entry data to show how much capacity would have been accepted for study in each area for preceding clusters.

Application of this concept to sub-zonal constraints

Below is an excerpt from this section of the Proposal:

In the study process for each zone, the ISO will add projects to various substations within each zone until network upgrades are triggered. In zones/interconnection areas/sub-zones with nested constraints, the sub-zone with the constraint will be filled up until it triggers an upgrade, and at that point the sub-zone will be ‘frozen,’ limiting any additional interconnections in that area. Other projects seeking to interconnect in that area will be eligible to interconnect in the broader zone until 150% of the capacity is reached.

The last sentence in this paragraph was removed in the stakeholder meeting presentation, without any clear explanation.

On its face, the deleted language seems to hold out the possibility that an otherwise viable project could still be accepted for study if there is another feasible Point of Interconnection within the zone.  LSA believes that this language should be restored to the Proposal.

At best, developers will be working based on educated guesses about how much capacity is available at different POIs, but even then they have no way to determine how many other projects will be proposed at those locations.  It seems reasonable for those projects that may not score well enough to locate at a constrained POI might be accepted for study if there is a feasible nearby alternative POI, ahead of a less-ready project proposed in the same zone.

More broadly, the CAISO should include some flexibility in this criterion.  For example, even if a Network Upgrade is triggered, it might be a very cost-effective investment given the additional capability it would enable, and in any case the projects triggering it should be given an opportunity to fund it under an Option B framework.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

The changes the CAISO has made to this element of the proposal – requiring only projects who must participate to submit bids, and making bid amounts refundable after COD – have made this proposal more acceptable.  However, LSA still believes that this mechanism will be complicated and is unnecessary; should the scoring rubric and DFAX tiebreaker be insufficiently limiting, LSA prefers simpler methods like pro rata awards and acceptance of all projects “on the margin.”

In addition, if the CAISO proceeds with an auction mechanism, the proceeds should be completely refundable at COD, with interest.  Phasing transmission-cost refunds over 5 years provides a phase-in of those costs into the respective PTO rate bases, but there is no corresponding justification for dragging out auction-bid refunds.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

LSA appreciates the changes the CAISO has made to the Option B framework, specifically:

• Reduced up-front financial security requirements

• Clarifications that Option B projects would receive: 

• FCDS/PCDS once the required upgrades are complete, i.e., they do not have to compete for TPD in the allocation process.  (The exception would be if the ADNU is later approved as needed in the Transmission Planning Process, where the project would be relieved of its cost responsibility but would then have to compete against other projects for their FCDS/PCDS status.  See comments below.)

• Local Delivery Network Upgrade (LDNU) reimbursement after COD, like other projects. 

• The benefit of any financial security posted by projects sharing the upgrade that withdraw, under Section 7.6 “Application of Non-Refundable Amountst.”   Presumably, this is a reference to Section 7.6(b) (“Calculation and Disbursement of Non-Refundable Interconnection Financial Security for Still-Needed Network Upgrades At or Above $100,000 Threshold”), which provides for a proportion of non-releasable security from withdrawing projects to be applied to the remaining cost of the upgrade, to mitigate the impact to remaining customers bearing the cost. 

• Clarification that Option B projects could self-build and negotiate third-party agreements for funding ADNUs, including any additional financial protections they agree to amongst themselves, under GIDAP Section 11.3.1.4.4 “Posting Related to Interconnection Customer’s Stand Alone Network Upgrades.”  That tariff section provides that the applicable IC cost responsibility (and, presumably, associated financial-security postings) would be released once the SANU and cost responsibilities are documented in executed GIAs.

LSA’s comments are in two areas, where: 

• The proposed revisions should be expanded or otherwise enhanced; and

• Additional revisions should be made.

Expansions/enhancements of proposed Option B revisions

• If an Option B ADNU is approved in the TPP, each applicable developer should have a choice between: (1) the proposed cost-responsibility and security relief, with the need to compete for an FCDS/PCDS allocation; or (2) retaining the existing arrangement, with cost responsibility but a guaranteed FCDS/PCDS award.  In particular, projects that are far along in the development process, or those participating in a SANU self-build arrangement, may simply choose to retain their existing arrangements for the certainty they would provide.

• GIDAP Section 7.6 would have to be revised to allow the full benefit of forfeited ADNU security to go to remaining projects.  Specifically, if the CAISO is requiring additional up-front security for Option B customers to fund ADNUs, then this up-front amount should be added to any proportional allocation of other posted security.

Additional Option B revisions that should be made:  LSA continues to believe that the CAISO should include these elements in its Option B reforms:

• Allow Option B elections for projects seeking deliverability in zones with available capacity that do not make the scoring cutoff, perhaps with the same up-front deposit required in areas without available transmission capacity.  LSA fails to see the harm in having developers voluntarily agree to fund additional transmission in areas with high locational demand, even if that would require some additional analyses in the study process.

• Provide advance estimates of potential CRR revenue for the applicable ADNUs, upon request.  Otherwise, it will be difficult for project sponsors to estimate net cost of an ADNU.

• Allow reimbursement of Option B ADNU costs to the extent that sponsors can demonstrate system benefits.  As it is, these upgrades will be open for use by all as part of the CAISO’s transmission network, and cost reimbursement would be appropriate by the beneficiaries of such projects, as provided for under regional transmission-planning practices.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

With all due respect, LSA notes that the CAISO has not yet even determined the content of the studies under Order 2023:  (1) Cluster Study (90 CDs); (2) Cluster Re-Study (150 CDs); and (3) Interconnection Facilities Study (90-180 CDs). 

In fact, the study process is completely unclear – it certainly does not look like a “single-study process,” and it certainly is not clear whether this information could continue to be provided in the 14-month total duration.  Moreover, as noted at the stakeholder meeting, this information may prove useful under the new Slice of Day framework.

Thus, LSA suggests postponing a decision about this part of the proposal until the above issues have been clarified as part of the Order 2023 compliance effort.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

LSA is extremely disappointed that the CAISO is once again backing away from this broadly supported concept, without even any sensitivity studies or further consideration of the net impact on either PTOs or ratepayers.  The Straw Proposal already greatly constrained this concept through retention of security to mitigate PTO impacts (again, considering only potential costs but not potential benefits), and the Revised Straw Proposal seems to be the “final nail in the coffin,” leaving vague and speculative outside funding sources the only possible path.

Instead of once again refusing this proposal without further investigation, LSA suggests that the CAISO give further consideration to the concepts advocated by Avantus for “prioritizing” applicability of this concept to various groups.

First, the CAISO could offer the opportunity to Cluster 14 projects, since withdrawal of those projects would not adversely impact PTOs or other projects.

Second, the CAISO could restrict the opportunity to projects that have not yet provided Notice to Proceed under their GIAs.  Projects that have provided NTP (and the associated third posting) are likely moving forward and not likely to accept the offer anyway.

Third, the CAISO could offer the opportunity to projects where withdrawal would not adversely impact PTOs or other projects, e.g., those: (1) Without Network Upgrades; (2) without shared Network Upgrades; and (3) where withdrawal would remove the need for Network Upgrades that are not Precursor Network Upgrades (PNUs).

Fourth, the CAISO could offer the opportunity to projects where withdrawal would not adversely impact PTOs because costs would be borne by other projects, i.e., those with Interconnection Reliability Network Upgrades (IRNUs) or Conditionally Assigned Network Upgrades (CANUs).

This concept could be extended to other groups as well.  The point is that, with just a little more nuanced approach, the CAISO could offer this opportunity to many projects while avoiding the adverse outcomes feared by the PTOs without any supporting analysis or consideration of situations where such outcomes are unlikely or impossible.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

LSA continues to believe that LOS requests should be allowed more than 9 months in advance.  While LSA appreciates the longer lead time compared to the current 5-month period, given the extremely high benefit from such earlier information, LSA recommends continued consideration in the future of ways to offer a longer timeline of at least 2 years.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

LSA has no comments on this proposal.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

LSA continues to oppose this proposal.  As the CAISO has said, few projects use it, but the CAISO has not demonstrated any harm from retaining this option. 

The CAISO has not justified the need for this proposal.  The Proposal states (at p.70) that “suspension rights currently give customers too much unilateral power to remain stagnant in the queue,” but earlier proposal versions stated that few projects even use such rights.  Moreover, suspension rights are hardly “unilateral” given recent tariff changes requiring the equivalent of a modification request, limiting exercise to situations where no other projects would be adversely impacted, and limiting the duration where the full three-year period would cause the project to exceed 7 years time in queue.

In other words, there is no need for this proposal.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

LSA continues to oppose restrictions to transferring TPD between projects, other than the current POI and voltage-level rules, including restrictions on the newly Energy-Only projects transferring deliverability to other projects.  The Proposal states that:

• Such projects can only remain in the queue if they provide Energy Only PPAs at the time the TPD transfer is requested.  As was obvious from the stakeholder meeting discussion, but developers and potential off-takers of the Energy Only projects would be reluctant to execute PPAs while the RA status of the “from” project is uncertain, i.e., without knowing whether the transfer will be approved.

LSA suggests that the CAISO allow a set period – e.g., 1 year – for the “from” project to provide an Energy Only PPA in order to remain in the queue.

• Such projects could only seek a new TPD award under Group C, i.e., if the project reaches COD as Energy Only.  However, LSA sees no reason to impose this restriction.  If these projects manage to secure an executed PPA or shortlist position that requires RA, they should qualify to receive a new TPD award, just like any other similarly situated Energy Only project.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

LSA has long supported measures to remove non-viable projects from the queue, and it does not object to the concepts of GIA execution deadlines and Energy Only project viability criteria.  However, LSA has several comments to improve the Straw Proposal proposals in these areas.

GIA execution deadlines

LSA continues to maintain that simply setting deadlines, without any other timeline or process structure, is simply not fair or workable.  These concerns were amplified by the discussion at the stakeholder meeting indicating that each project might separately have to request a draft GIA on its own.  Instead, the process would be much more transparent and effective if the CAISO would:

• Set uniform dates for PTO tender of draft GIAs for each “traunch” of contracts, without the need for each developer to request a draft separately.  LSA suggests tender dates approximately 4 months in advance of the respective execution deadlines.

• Set uniform turnaround times for drafts applicable to each side, e.g., two weeks.

This timing would allow the draft agreements to be issued with enough advance timing and to progress forward at a reasonable pace, with ample time for conclusion and execution or, alternatively, filing of unexecuted agreements.  PTO turnaround-time delays would extend the execution deadlines, though developer turnaround-time delays would not.

Viability Criteria demonstrations

• Projects with deliverability:  The current CVC appear to be working well.  Absent some justification (which is not provided in the Proposal), there does not appear to be a need to disrupt that process, including the additional time allowed for an executed PPA to retain deliverability where a project meets the other applicable criteria.

• Projects without deliverability (including those which had it but no longer do):  LSA does not object to the proposed criteria at 7 years time in queue, except that, like the current CVC for projects with deliverability, they should have a similar extension for an executed PPA.

• PTO delays:  The current CVC for projects with deliverability (and other selective restrictions on COD delays for Group 3/Group D projects) do not apply if the need for a COD extension is due to a PTO delay.  LSA believes that the CAISO should allow for an extension to all Viability Criteria demonstration deadlines if the project COD has been significantly delayed by a PTO delay.  Such projects are already impaired by the PTO delay, and they should be given additional time to comply if their timelines are disrupted by PTO delays – for example, a project whose COD is delayed for years (e.g., due to SCD upgrades) should not have to provide a PPA years before that.

The CAISO also needs to clarify the definition of a qualifying PPA in the proposed viability demonstrations.  Many early projects received their TPD awards before the current 5-year minimum term was applied for new TPD awards; consistent with CAISO practice, the required PPA terms should be consistent with the required PPA terms when the TPD award was received (or, for projects receiving deliverability before establishment of the TPD award process, when the interconnection studies were complete).

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

LSA does not object to the requirement that a project should begin construction before noticing the CAISO that is it invoking Construction Sequencing.  However, once construction starts, LSA does not see how delaying this notice helps either PTOs or developers in scheduling the work.  Moreover, the proposal still does not address situations where developers seek to accelerate CODs.

As LSA suggested in its prior comments, a compromise position might be to allow Construction Sequencing requests for COD extensions to be allowed as early as 12 months before the current In-Service Date, and not to place limits on Construction Sequencing requests for COD accelerations. 

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

LSA does not object to the CAISO’s proposal for all projects to provide third postings, NTPs, and (as a clarification from the stakeholder meeting) payment initiation for shared upgrades when the first sharing project moves forward.

LSA considers the other parts of the proposal – separate posting/NTP/payment timing and PTO obligation to begin the upgrade – as integral to its support for this proposal.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

LSA supports the proposal for more flexible GIA amendment timing.  As the CAISO has acknowledged, some developers will want updated GIAs as they go, while others would be content to receive an updated version at the end of the development process.  We note that the Proposal says that an executed and amended GIA would no longer be required to enter the New Resource Implementation Process NRIP).

However, we are concerned about SCE opposition to this proposal, even though CAISO cited as support for its proposal the high PTO burdens from continual GIA amendments.  We are especially concerned about SCE’s contention that it will need even more time than the proposed extensions to process MMA requests if the MMA reports must contain schedule and payment updates. 

CAISO needs to sit down with SCE and the PTOs to work out a consensus position on this issue.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

As noted above, LSA considers the PTO obligation to begin the upgrade once third postings, NTPs, and payment initiations are received as integral to its support for this proposal.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

LSA does not object to the CAISO’s proposal for a $100K deposit for administrative costs, but subject to audit rights for expenses incurred if developers have questions about billed expenses.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

LSA reserves the right to comment later on this item, pending clarification from the CAISO.  As discussed at the stakeholder meeting, the Proposal states that the current requirement for asynchronous generators to provide phase angle measuring unit (PMU) data at a resolution of 30 samples per second (upon request from the CAISO or PTOs) is “not granular enough” and proposes revision the granularity to 16 samples per second.  However, that proposal would seem to reduce granularity, not increase it, so the CAISO should clarify this proposal before requesting feedback.

1. Please provide a summary of your organization’s comments on the revised straw proposal

Middle River Power LLC (“MRP”) provides the following comments on the December 12, 2023 Revised Straw Proposal (“RSP”).  

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

MRP strongly supports and appreciates the CAISO’s proposal for providing information for each zone consolidated into a single document. 

MRP encourages the CAISO to consider PJM’s Services Request Status information site (https://www.pjm.com/planning/service-requests/services-request-status) as a model for providing project interconnection information.  Selecting the “Phases & Agreements” tab for a given project enables one to download a copy of the Feasibility Analysis and the System Impact Study for that project.  The information available through these reports includes:

The information provided does not identify the project owner. 

MRP also appreciates the CAISO targeting the Order 2023 heat map, including substation-specific data, for publication in Q2 2024.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

MRP has no comment on this section.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

The restructuring of California’s electricity industry in 1998 introduced open, non-discriminatory access to the bulk power system and displaced the Investor-Owned Utilities as the primary developers of power generation in in the California market.   With a few exceptions (e.g., a handful of Utility Owned Generation projects, typically developed in response to a perceived crisis or unusual, transitory circumstances), this model has worked very well.  The CAISO’s proposal to reserve 40% of its proposed scoring criteria for load-serving entities (“LSEs”) to express their interest in or preference for certain projects is a reasonable compromise – MRP is pleased that only 40%, not 100%, of the scoring is set aside for this purpose – but MRP urges the CAISO to ensure that this 40% is not somehow leveraged to reinvigorate the “utility owned” generation development model. 

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

MRP has no comments on this aspect of the RSP. 

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

MRP requests the CAISO clarify how it will apply the DFAX tiebreaker and zonal auction process if both are necessary.   MRP also requests the CAISO discuss how likely it is that the zonal auction process will be used in conjunction with the DFAX tiebreaker.  While MRP appreciates that the CAISO has clarified that sealed bids will only be required if the zonal auction process will be necessary, MRP is not clear how often this complex process will be required and whether it is truly necessary. 

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

MRP has no comment on this topic.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

While MRP understands the CAISO’s rationale for eliminating the off-peak and operational deliverability assessments (insufficient time to perform these studies under the new Order 2023-mandated single phase study process),[1] eliminating these deliverability assessments seems inconsistent with the California Public Utilities Commission’s adoption of the “Slice of Day” (“SoD”) approach to Resource Adequacy, which requires that LSEs provide sufficient capacity – presumably, capacity that is fully deliverable to its load – in each hour of the day.  While MRP is sympathetic with regards to the collateral effects on the CAISO of the mandates imposed in Order 2023, MRP does not understand how a single snapshot deliverability analysis can effectively support reliability under the SoD RA framework. 

In Section 2.7, the RSP proposes keeping all Transmission Plan Deliverability (“TPD”) issues together in a holistic discussion that will be precipitated later in this process, perhaps following the Board of Governors’ consideration of the Track 1 issues slated for May, with a Track 2 paper, targeting a July 2024 Board meeting.  MRP appreciates the CAISO taking up all TPD issues holistically in a later track and encourages the CAISO to ensure sufficient time is devoted to the consideration of this topic, rather than targeting bringing this topic to a particular Board meeting, at this time. 

[1] RSP at page 59.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

MRP, along with other stakeholders, thought a one-time withdrawal opportunity could prove to be an effective way to relieve the CAISO’s overloaded interconnection queue.  The Participating Transmission Owners’ concern that they would have to upfront-fund network upgrades costs left from withdrawing projects is not unreasonable, but that concern seems somewhat incongruent with the reality that the PTOs will earn a risk-reduced, regulated rate of return on those network upgrades for a substantial period of time, which suggests there should be sufficient incentives for finding funding sources for those upgrades.   

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

MRP has no comment on this topic.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

MRP supports this aspect of the RSP. 

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

MRP does not object to the proposal to eliminate suspension rights as long as developers retain the reasonable ability to extend milestone deadlines to address circumstances beyond their control.    

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

MRP joins the numerous stakeholders[1] who question why the project that is transferring its deliverability to another project must downsize.  While the CAISO asserts that Energy Only (“EO”) projects rarely, if ever, achieve commercial operation, if a project wants to retain its original size, and seek EO status, with or without an accompanying Power Purchase Agreement, it’s not clear to MRP why this should not be permitted.  MRP agrees that TPD transfer should not be used to escape deliverability retention requirements.   

[1] RSP, page 71.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

MRP applauds CAISO for attempting to identify criteria it believes would demonstrate the viability of a particular project.  MRP is concerned, however, that several of the criteria (1) would either favor well-capitalized strategic investors or developers (e.g. “Demonstration of business partnerships for future supply of major equipment prior to COD”) or (2) imposes requirements that are too early in the development cycle (e.g. “Engineering Design Plan”) or are not well defined as to what is required (e.g. “Expansion of an existing facility”). MRP would propose that some of these criteria are better suited to be embodied as schedule milestones in the Generator Interconnection Agreement (i.e., equipment supply agreements and engineering designs), rather than to be used as screening criteria to determine the “Project Viability” before the IR is studied. MRP is not aware of any other ISO that attempts to determine a project’s viability at the beginning of an interconnection request process other than by establishing minimum acreage requirements for specific technologies and requiring study deposits.

With regards to the CAISO’s proposal for changes to the Material Modification Assessment (“MMA”) process – increasing the deposit to $30,000 and increasing the time to complete the engineering analysis and the Facility Reassessment Report (“FRR”) from 45 to 60 days – MRP does not object to this proposal, but MRP’s experience with the MMA process is that the CAISO and the PTOs are currently taking much longer to complete those steps, so MRP questions whether the proposed modest increase in the timelines is sufficient.   MRP encourages the CAISO to propose and enforce timelines that it can dependably meet. 

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

MRP has no comment on this topic. 

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

MRP has no comment on this topic. 

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

While MRP understands the value of including all the MMAs in an amended GIA, MRP’s concerns about this aspect of the RSP stem from the fact that the developer often has little or no control with regards to the timing of the MMA reports, and recent experience has demonstrated significant timeline overruns, even if those reports are intended to be binding as proposed in the RSP.  

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

MRP supports this aspect of the RSP. 

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

MRP supports this aspect of the RSP. 

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

MRP supports this aspect of the RSP. 

1. Please provide a summary of your organization’s comments on the revised straw proposal

-

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

CAISO uses remedial action schemes (RAS) and congestion management to more efficiently utilize the transmission system during reliability and deliverability assessments. This is a best practice and we support the continued use of these strategies during deliverability assessments and system operations. That said, the use of RAS and congestion management makes it more difficult for developers to conduct their own analyses of the transmission system. We request that CAISO make available more methodological details on how it uses RAS and congestion management in deliverability assessments.

While CAISO indicates when it uses RAS in the TPP and in IR studies, it does not publish information about RAS and congestion management in sufficient detail for developers to recreate these results in their own internal studies. In some cases, this makes it extremely challenging for developers to accurately model the deliverability of the system and anticipate which zones and POIs might be viable for their projects. CAISO has expressed in stakeholder meetings that it believes that accurate developer studies that guide project siting are an important step in interconnection and will lead to a more efficient process. Giving developers access to this information is critical to enabling these studies.

For each RAS in use, we request that CAISO share the data files that govern the RAS. Additionally, we request that CAISO make available written descriptions of the RAS that are updated periodically. These descriptions should explain (1) when and how RAS are implemented, (2) when generation is added into a RAS, and (3) how the limit of the RAS is determined. Our preference is that CAISO post this information publicly. If this is not possible, then we request that CAISO share these files directly with developers who request them under NDA.

In instances where CAISO uses congestion management strategies to alleviate deliverability constraints, CAISO should publish a written description of the logic or methodology governing the strategy. The written description could be included in publicly available documents like the TPP, or through privileged documents that market participants could access like the TPD allocation reports.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

 -

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

CAISO’s current rubric contains a narrow set of criteria that assess a limited range of project attributes and viability indicators. We fear that the current version of CAISO’s intake scoring rubric will tend to advance a limited set of resources biased toward certain characteristics that are not predictive of project viability. Many efforts have been made in good faith by the broad stakeholder body (including the developer community) to develop a comprehensive set of scoring criteria. However, the industry simply isn’t at a place where a comprehensive set of meaningful and easily verifiable criteria could easily be used to prioritize projects before they are studied for interconnection.

A competitive marketplace should be set up to place the burden of business decision-making on competitive suppliers, not on an administrative planning body. Recognizing that developers and not CAISO are best suited to assess project viability, we feel strongly that market-based mechanisms are the best way of determining who advances in the interconnection process, particularly at the early development stages that projects are in at the time of intake. We think that the high volume of IRs, which we understand to be one of the core issues that CAISO is trying to solve with their intake proposal, should be managed not with caps and scoring but with a combination of money-at-risk (i.e., deposits and fees) and common-sense development milestones (e.g., site control and the other requirements set forth in FERC Order 2023).

It is possible that it could make sense to add additional criteria to the “development milestones” bucket in future clusters. We recommend a phased approach in which CAISO first implements the FERC Order 2023 requirements for Cluster 15, and then returns to the stakeholder process as needed if there remain unsolved issues even after implementing pending regulations, as evidenced through how Cluster 15 unfolds.

If CAISO nevertheless insists on retaining caps and a scoring mechanism, then we offer the following feedback on the specific criteria in the revised straw proposal:

LSE-determined points

• The current proposal would give LSEs undue discretion to effectively determine which projects can ultimately interconnect to the CAISO system. This lacks transparency and would run counter to competitive market principles.
• While it is reasonable to prioritize more viable projects for study, given the inevitable uncertainty at the time of project intake, we recommend that CAISO broaden the amount of capacity that is studied so as to avoid premature, erroneous administrative project selection decisions and allow for more market-based selection, with the understanding that more precise prioritization can occur during TPD Allocation when projects are much closer to NTP and commercial readiness and other factors are more knowable.
• We echo this recommendation to increase the amount of IRs that advance to the study phase in our comments on Section 2.5.1 below.
• We recognize that it might be reasonable to apply commercial viability criteria, including LSE and offtaker interest, at TPD Allocation.

Long-lead time resources

• It is reasonable for CAISO to prioritize projects required by CPUC or LRA planning targets insofar as they are found to be needed under IRPs.
• Instead of prioritizing long lead time resources outright, CAISO should add back criteria for projects that match the needs of an IRP or procurement order.

Expansions on existing facilities

• CAISO is proposing to score projects for expansion of an existing facility on the basis that it means projects will have a better chance of being permitted.
• We agree that a better permitting position can contribute to lower attrition risk, as we discussed in our first round of comments.
• That said, many greenfield projects may also have a better chance of being permitted by dint of specific characteristics that they may have. We believe that a permit criterion is not unreasonable to include, but CAISO should apply this directly as a screen, and in the process, should award points to projects that can demonstrate a higher likelihood of permitting success, e.g. by passing a CEC land use screening.

Demonstration of business partnerships for equipment supply

• Procurements occur on a project-by-project basis and it is unreasonable to expect developers to have placed money down on orders for projects that may not even be studied.

Ability to provide Local RA

• We would support including this criterion on the condition that projects that provide additional reliability attributes, including system RA and flexible RA, are able to receive points as well.

Additional criterion: Site control

• We agree with CAISO’s proposal to not include additional site control criteria as minimum requirements beyond those set by FERC Order 2023.
• However, we think that it would be appropriate to award points to projects that have exceeded the FERC requirements and can demonstrate up to 100% site control at the generation facility and/or site control at the gen-tie.
• Projects with site control above and beyond the FERC requirements bear less project attrition risk, which therefore should be reflected in viability scoring.

Additional criterion: Points for projects that pass CEC land use screen 

• As mentioned above, projects that can demonstrate a higher likelihood of permitting success should be awarded points.
• We propose that projects that pass land use screens for critical habitat, cultural impacts, and wetlands impacts should be awarded points at intake.
• We believe this would be straightforward to administer. When validating site control, CAISO would simply verify the project location as being outside of the boundaries of the applicable CEC land use screen.
• A more detailed explanation of this proposal can be found in our September comments.

Additional criterion: Points for project attributes

• We believe that it is reasonable to award points for projects that meet the needs of an IRP (or equivalent for LRAs) or active procurement.

Additional criterion: Points for projects sited in an energy community

• Because this criterion is a reasonable and verifiable indicator of economic viability, we feel that it may be appropriate to include this in an expanded set of intake criteria.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

CAISO’s proposal implies that 66% of projects that progress to the study phase will ultimately come online even though historical data suggest a success rate closer to 10 percent. Retaining a cap at 150% of available and planned capacity will severely constrict the available supply mix that is studied for interconnection. A cap set at this level means that if more than a third of studied projects fail to progress, then there will be surplus deliverability in that zone left unused despite the fact that many of the projects that were not progressed to the study phase would likely have been viable. This is an inefficient use of the transmission system and is antithetical to the spirit of the MOU undertaken by the California planning entities.

CAISO’s proposal will create a planning regime in which projects will advance on the merits of administrative selection and not competitive market principles. While it is reasonable to prioritize more viable projects for study, given the inevitable uncertainty at the time of project intake, it is unlikely that the projects advanced to the study phase will be exactly those that would otherwise have been the most viable and competitive. Instead, we recommend that CAISO broaden the amount of capacity that is studied with the understanding that more precise prioritization can occur during TPD Allocation when projects are much closer to NTP and commercial readiness and other factors are more knowable.

For all of these reasons, we strongly encourage CAISO to increase the study cap to at least 250% of the available and planned capacity. As we wrote in our first round of comments, we believe that it might be reasonable to create a target of as close to 250% as possible coupled with a minimum threshold of 200%, under which CAISO would never go unless there were insufficient applications. If all resources at a particular score were “in” at 225%, and allowing the next tranche resulted in 500% intake, intake would be cut off at 225%. If these numbers were 175% and 500%, respectively, intake would be cut off at 500%, since 175% would not clear the minimum threshold.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

Please refer to our September comments for MN8's position on zonal auctions.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

 -

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

 -

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

 -

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

 -

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

 -

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

MN8 maintains its position that suspension rights are an important tool to help companies manage unforeseen delays in development.

That said, we recognize that there are additional tools that companies can use to manage these risks. In the absence of suspension rights, it is critical that these tools give developers means to manage exogenous risks that would threaten otherwise viable projects.

One such tool is an MMA request. CAISO should retain the status quo policy of accepting MMA requests that extend the COD beyond 7 years as long as the cause of delay is outside of the developer's control. It is reasonable for CAISO to require that MMAs demonstrate project maturity, but maturity criteria should be reviewed on a case-by-case basis. For example, we feel that if developers can show receipts for equipment purchases, advance permits, and/or place money down in other ways, then MMA requests to delay milestones for reasons outside of the developer’s control ought to be accepted.

CAISO should evaluate requests on a case-by-case basis. Procurement issues, offtake issues, and changes in law that are material to project economics should all be considered reasonable causes for delay.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

 -

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

 -

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

 -

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

 -

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

 -

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

 -

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

 -

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

 -

1. Please provide a summary of your organization’s comments on the revised straw proposal

Natural Resources Defense Council (NRDC) appreciates the opportunity to respond to the Interconnection Process Enhancements Revised Straw Proposal issued by the California Independent System Operator (CAISO) on December 19, 2023. We support the development of improvements to CAISO’s current processes in order to handle requests in a more effective way to make it easier and faster to add new reliable, affordable, and clean resources in a way that is aligned with transmission development.

We appreciate all of CAISO’s efforts to enhance the study and approval process for interconnection requests and develop additional queue management tools and align the interconnection processes with other foundational framework improvements coordinated through the December 2022 joint Memorandum of Understanding (MOU) among the CAISO, California Public Utilities Commission (CPUC), and the California Energy Commission (CEC).

We appreciate the transparency offered by the inclusion of sections of the Revised Straw Proposal that provide details regarding the requirements that will need to be met to comply with FERC Order No. 2023 since the CAISO has stated it does not open compliance filings to stakeholder feedback.

We have provided comments on Section 2.5.1 regarding fulfillment of 150% of available and planned capacity and have left the other sections blank – a blank section does not indicate full support for the content of the section.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

NRDC acknowledges that CAISO is proposing to study 150% of the available and planned transmission capacity for each transmission zone in order to scale the number of studies to create a reasonable and fair limit on the amount of new generation the CAISO can study on a timely basis. While we do not offer comments of support or concern for this cap, we rather recommend that CAISO record any projects that would exceed the 150% capacity limitation and both save the information and report it to the CPUC and CEC to be considered in future transmission planning and resource planning, in an effort to further pursue coordination outlined by the joint MOU, as it would serve as an indicator of where additional transmission capacity may be needed.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

New Leaf Energy, Inc. (“NLE”) supports the following elements of the revised straw proposal:

• Provision of clear and comprehensive data on available capacity within the zones;

• Exemptions from the scoring rubric for Energy Only and Option B projects;

• Inclusion of the Local Resource Adequacy (“RA”) criterion in the system need category;

• Improvements and clarifications to the Option B process, subject to several recommended modifications; and

• Elimination of the proposal to limit eligibility for Energy Only projects in the Transmission Planning Deliverability (“TPD”) allocation process to Group C.

NLE recommends rejection or modification of the following elements of the revised straw proposal:

• Modify the zonal data proposal to require publication of all relevant data and assumptions as early as possible before a cluster window opens;

• Reject the proposal to limit the capacity of interconnection requests that a developer may submit to 25 percent of the available capacity in a given cluster;

• Reject the proposal to automatically study any project that a non-California Public Utilities Commission (“CPUC”) jurisdictional load-serving entity (“LSE”) demonstrates is a preferred resource in its approved resource plan, as well as the proposal to reduce the capacity available to other projects to stay within the 150 percent capacity limit in each zone;

• Reject or modify the proposal to allocate 40 percent of overall points in the scoring rubric to projects preferred by CPUC-jurisdictional LSEs;

• Modify the project viability category by adjusting the points allocation and adding additional criteria;

• Modify the requirements for the Local RA criterion in the system need category;

• Modify the criterion concerning long-lead-time resources in the system need category;

• Modify the Option B process proposal; and

• Modify the proposal for a one-time withdrawal opportunity to allow for it without third-party funding for any affected network upgrades.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

NLE supports the CAISO’s proposal to provide clear and comprehensive data on available capacity within the zones. However, NLE is concerned that the data may not be actionable unless developers have sufficient lead time for the published data to inform prospecting. The CAISO agreed to release a report on available capacity for Cluster 15 in January 2024, but the report’s available zonal capacity estimates will be inaccurate because the estimates will likely change significantly following the results of the 2024 TPD allocation process, which is not scheduled to conclude until May 2024. Thus, the CAISO should commit to updating those estimates as soon as possible after the TPD allocation process concludes.

In the future, NLE respectfully urges the CAISO to provide all relevant data as early as possible before a cluster window opens. The CAISO should explicitly state the final date for new data and assumptions to be incorporated into the available capacity analysis. This cut-off date should be at least six months before the next cluster window opening in order to provide the market with enough time to react to the analysis. In the next iteration of the Interconnection Process Enhancements (“IPE”) proposal, it would also be useful for the CAISO to propose and for stakeholders to have the opportunity to comment on example timelines for Cluster 15 and beyond.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

NLE supports exempting Energy Only and Option B projects from the scoring rubric, but NLE seeks clarification on the study process for Energy Only projects. The CAISO should clarify that it will accept interconnection requests for Energy Only projects both within and outside of the zones with available capacity. 

NLE also provides comments on one element of interconnection request intake that is not covered in the prompts below: the proposal to limit the capacity of interconnection requests that a developer may submit to 25 percent of the available capacity in a given cluster. NLE strongly opposes this proposal. The revised straw proposal does not provide sufficient justification to adopt a cap. The CAISO has not shown that projects proposed by developers submitting interconnection requests for less capacity have higher value or increased viability, compared to projects proposed by developers submitting interconnection requests for more capacity. Rather than putting downward pressure on ratepayer costs, the proposed anti-competitive restriction would likely prevent a number of more cost-effective projects—submitted by larger developers with more experience—from entering the queue.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

a) LSE Interest Category

i) Non-CPUC Jurisdictional LSEs 

NLE strongly objects to the proposal for projects in approved non-CPUC jurisdictional LSE resource plans to bypass the scoring criteria and automatically be accepted for study. These projects should be subject to the same requirements as all other projects entering the queue in order to ensure that the CAISO studies only the most viable and ready projects. 

Additionally, when drafting their resource plans, non-CPUC jurisdictional LSEs—like other LSEs—do not have sufficient information to know which projects will be the most viable and valuable. Projects need to progress through the interconnection process in order to provide potential buyers with more accurate and reliable cost information. Selecting projects for study before interconnection cost information is available is not in the best interests of LSEs or their ratepayers. Further, LSEs will likely not have signed contracts with projects at this stage, which creates an opportunity for projects to game the process and be studied over more cost-effective and viable projects. 

Prioritizing interconnection studies for these LSEs, over CPUC-jurisdictional LSEs that may also have regulator-approved resource plans, constitutes undue discrimination and is not justified. However, if the CAISO nevertheless decides to move forward with this proposal, NLE recommends exempting these interconnection requests from the 150 percent available capacity limit. This would address some of the concerns with these projects preventing other more ready or viable projects from being studied.

ii) Points for LSE-Preferred Projects

NLE is concerned with the proposal to allocate 40 percent of overall points in the scoring rubric to projects preferred by CPUC-jurisdictional LSEs for the following reasons:

• First, prioritizing projects selected by LSEs for study creates open access issues under Federal Energy Regulatory Commission (“FERC”) Order 2003. 

• Second, if this scoring element is retained, the proposed allocation of 40 percent of total scoring rubric points provides too much weight for this category. This heavy weighting increases the chances that LSE interest will be the primary determinant of whether the CAISO accepts a project for study, even over other projects that score much higher under the other categories. 

• Third, as noted above, LSEs will not have sufficient information to select the most viable or valuable projects at this stage because interconnection cost information, which is the primary driver of project viability and value, will not be known before a project enters the queue. 

NLE recommends that, if this category is retained, at minimum the CAISO reduce the number of points available within this category to 10-20 percent of total available points.

b) Project Viability Category

NLE recommends that the CAISO modify the points allocation for the project viability category and add additional criteria within the category. Project viability should be the primary determinant of whether the CAISO studies a project, and adding more criteria to this category would help to further differentiate projects. The currently proposed criteria in this category would not likely serve this purpose, as many projects would receive the same or very similar scores. NLE therefore recommends creating the following additional criteria in this category:

• First, the CAISO should create a new criterion that allocates 15 points to projects that demonstrate site control above the 90 percent requirement in FERC Order 2023. 

• Second, the CAISO should create a new criterion that allocates 15 points to projects that demonstrate gen-tie site control.

Further, to recognize the importance of project viability in determining which projects to study, NLE respectfully urges the CAISO to increase the points allocation for this category to 40-60 percent of total available points.

c) System Need Category

i) Ability to Provide Local RA in a Local Capacity Resource Area (“LCRA”) with an Independent System Operator (“ISO”) Demonstrated Need for Additional Capacity in That Local Area

The revised staff proposal does not include a definition of “ISO-demonstrated need” for the Local RA criterion. During the stakeholder meeting on December 19, 2023, CAISO staff proposed using the annual local capacity technical studies to determine whether a need exists in an LCRA. For the need determination, NLE recommends that:

• Both LCRAs and sub-LCRAs showing deficiencies qualify.

• The CAISO include a buffer of a reasonable amount (e.g., 10 percent) on the reported LCRA deficiencies when performing the need determination, as the deficiencies reported in the study are only estimates that are based on load and available supply estimates. Some areas where the LCRA need and capacity available are quite close might, in fact, end up experiencing a deficiency. Applying this buffer would help ensure that sufficient resources are coming online to resolve potential deficiencies. 

• The CAISO clarify which reported deficiency years the CAISO will use in the need determination. The local capacity technical studies annually report deficiencies for one and five years into the future. For example, in the most recent local capacity technical studies, released on April 28, 2023, the CAISO examined system conditions in 2024 and 2028. Using the five-year projections—or perhaps new projections even further out—seems most reasonable due to development timelines. 

• The CAISO remove the proposed “requirement that sufficient capacity is available in the LCRA to charge any proposed new energy storage facilities without needed additional transmission as outlined in the annual local capacity technical study.”^[1] This additional restriction is unnecessary and unfair. The CAISO already examines charging capacity within the Transmission Planning Process (“TPP”), and the CAISO does not require batteries to demonstrate sufficient charging capacity in order to receive full capacity deliverability status. Batteries should therefore not be subject to this additional requirement during the points allocation.

If the CAISO nevertheless adopts this additional restriction, it should provide information—within the package of information on available zonal capacity—regarding specific restrictions for qualifying LCRAs and sub-LCRAs. The CAISO should also clarify that if a proposed battery’s capacity is less than the one-for-one replacement capacity for a four-hour battery reported in the local capacity technical study, the project should be eligible for points under the Local RA criterion. In other words, the CAISO should not withhold points from individual projects if the cumulative capacity of batteries applying for interconnection is greater than the identified one-for-one replacement capacity.

• Expand the eligibility for this criterion to include more LCRAs and sub-LCRAs using the three additional methods described below to define “ISO-demonstrated need.” All of the following proposals would be administratively easy to implement, as they use existing sources of published data. The CAISO should apply all of these need determinations together, along with its proposal, to identify additional qualifying areas under the Local RA criterion.

1. Fossil or other generation likely to retire in the applicable time horizon: The CAISO could use its Net Qualifying Capacity (“NQC”) List—supplemented with data from the CPUC’s Qualifying Capacity Rules Final Classification List—to determine if an LCRA contains a certain percent of thermal generation (e.g., 25 percent or more) and/or other generation likely to retire in the time period considered.^[2] This would ensure that projected deficiencies properly account for future retirements.
2. RA price premium: The CAISO could use the CPUC’s annual RA Report to examine whether there is a premium (e.g., of 20 percent or more) on Local versus System RA prices.^[3] This proposal would help identify LCRAs where supply for Local RA resources is tight.
3. LSE/Central Procurement Entity (“CPE”) procurement problems: The CAISO could examine whether an LSE or CPE has documented procurement challenges in an LCRA. For example, San Diego Community Power (“SDCP”) submitted an advice letter to the CPUC reporting that, despite good-faith efforts, it was unable to secure contracts that would satisfy its entire Local RA procurement obligation.^[4] This proposal would help identify LCRAs where there are insufficient Local RA resources needed to satisfy procuring entities’ Local RA requirements.

ii) Long-Lead-Time Resources

As NLE has stated in previous IPE comments, the CAISO should not reserve available capacity for long-lead-time resources unless the CPUC or the legislature has provided an explicit procurement mandate and an LSE has initiated processes to procure the resources.

^[1] CAISO, 2023 IPE Track 2 Revised Straw Proposal at 40 (Dec. 12, 2023), available at: http://www.caiso.com/InitiativeDocuments/Revised-Straw-Proposal-Interconnection-Process-Enhancements-2023-Dec192023.pdf/.

^[2] See CAISO, Reliability Requirements, https://www.caiso.com/planning/Pages/ReliabilityRequirements/Default.aspx/.

^[3] See CPUC, 2021 Resource Adequacy Report (Apr. 2023), available at: https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/resource-adequacy-homepage/2021_ra_report_040523.pdf/.  

^[4] SDCP, Advice Letter 15-E, “Request of San Diego Community Power for Waiver of 2024 and 2025 Local Procurement Obligations” (Oct. 31, 2023), available at: https://sdcommunitypower.org/wp-content/uploads/2023/11/SDCP-AL-15-E-YARA-Local-RA-Waiver-Request_Public.pdf/.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

NLE has no comments on this item.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

NLE has no comments on this item.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

NLE generally supports the Option B process reforms included in the revised straw proposal. However, NLE seeks clarification on how the proposal would interact with the TPD allocation process, and NLE proposes supplemental modifications and revisions to strengthen the Option B proposal.

Under NLE’s understanding of the proposal, there are potential issues with how Option B projects would interact with previously queued projects in cost assignments and deliverability allocations. For example, additional information is needed to explain how the TPD allocation rules would apply to Option B projects after a future TPP cycle approves a shared Area Delivery Network Upgrade (“ADNU”). 

NLE respectfully urges the CAISO to modify or clarify the Option B proposal in the following ways. 

• First, the CAISO should allow projects that do not make the scoring cutoff in zones with available capacity to elect Option B and obtain deliverability through the proposed Option B process. The revised straw proposal claims that allowing Option B projects to apply for interconnection in the proposed zones would require an additional study after the CAISO finishes studying Option A projects in a zone. However, the FERC Order 2023 interconnection reforms include a restudy process, which is similar to the CAISO’s current Phase II study. The CAISO could wait to study Option B projects proposed in the zones until the new FERC Order 2023 restudy phase.

• Second, if an upgrade for an Option B project is approved in a later round of the TPP, the Option B project should have to choice to either: 1) retain the proposed Option B arrangement, fund the upgrade under the agreement reached when the project entered the queue, and receive a guaranteed deliverability award; or 2) exit the previous funding agreement, receive applicable refunds, proceed with the funding arrangement for all other projects sharing the upgrade, and compete for deliverability in the next TPD allocation cycle. 

• Third, ADNUs identified for Option B projects should only have to relieve Area Deliverability Constraints for the capacity from Option B projects. There are two potential ways to implement this proposal. The cluster study could assume that all earlier-queued projects are online, as is done under current practice, and the CAISO could then gauge the impact of the Option B projects—and not the entire cluster—with respect to any Area Deliverability Constraints and needed mitigation. Alternatively, a part of the cluster study could ignore both the earlier-queued projects and the non-Option B projects and just gauge the impact and mitigation needed for the Option B projects alone. The first option would be easier to implement; however, the second option is more fair because none of the earlier-queued projects have agreed to mitigate the Area Deliverability Constraints and the CAISO should not require Option B projects to fund mitigations for them.

• Fourth, the CAISO should allow reimbursement of applicable ADNU costs for Option B projects to the extent a developer can demonstrate system benefits from the relevant ADNUs. Because these upgrades would be available for use within the CAISO’s entire transmission system, cost reimbursement would be justified for any projects benefiting from the upgrades. 

• Finally, the CAISO should provide rough estimates of potential Congestion Revenue Rights proceeds for any relevant ADNUs. These estimates need not be exact and would not require significant additional work to calculate, but they would provide developers with useful information on whether their projects are viable. 

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

NLE has no comments on this item.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

NLE is concerned with the proposal to reject the one-time withdrawal opportunity unless the CAISO identifies acceptable third-party funding for the affected network upgrades. This is especially discouraging, as the one-time withdrawal opportunity proposal—supported by many stakeholders—likely represents the most significant opportunity to relieve queue congestion and ensure that only the most viable projects remain in the queue. It is also the only proposal that would encourage developers to voluntarily withdraw nonviable projects. NLE encourages stakeholders and the CAISO to continue to explore potential options to create an effective withdrawal opportunity.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

NLE has no comments on this item.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

NLE has no comments on this item.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

NLE does not support the proposal to remove suspension rights as the CAISO has not demonstrated any harm that would result from retaining this process.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

NLE has no comments on this item. However, NLE respectfully urges the CAISO to begin considering modifications to the TPD allocation process as soon as possible.

In the first IPE straw proposal, the CAISO proposed to limit eligibility for Energy Only projects in the TPD allocation process to Group C (i.e., projects that have achieved commercial operation).^[1] NLE strongly opposed that significant change to the TPD allocation process and appreciates the CAISO removing it from the revised straw proposal.

Limiting deliverability allocations for Cluster 14 and previously queued Energy Only projects is unjust and would raise costs for ratepayers because it would prevent more mature projects from receiving deliverability awards. These projects have remained in the queue and continued to meet development milestones under the assumption that they could convert to Energy Only and later seek a deliverability award through TPD allocation Groups A and B.

Additionally, NLE seeks clarification from the CAISO on the timing for the 2025 TPD allocation cycle. Projects under development need this information in order to properly time their development activities to qualify for high-priority allocation groups.

Because any changes to the TPD allocation process will drastically affect development decisions, the CAISO should initiate the stakeholder process for TPD allocation reforms as soon as possible and ensure that any proposed modifications are included in the final IPE proposal that the CAISO Board is scheduled to consider in May.

^[1] CAISO, 2023 IPE Track 2 Straw Proposal at 39 (Sept. 21, 2023), available at: https://www.caiso.com/InitiativeDocuments/Straw-Proposal-Interconnecton-Process-Enhancements-2023-Sep212023.pdf/.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

NLE has no comments on this item.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

NLE has no comments on this item.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

NLE has no comments on this item.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

NLE has no comments on this item.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

NLE has no comments on this item.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

NLE has no comments on this item.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

NLE has no comments on this item.

1. Please provide a summary of your organization’s comments on the revised straw proposal

NextEra Energy Resources, LLC (‘NextEra Energy Resources’) values efforts by the California Independent System Operator (‘CAISO’) to further refine the interconnection queue through the Interconnection Process Enhancements (‘IPE’) Track 2. Aspects such as the zonal approach reform, scoring criteria, Option B path alterations, and updates to contract and queue management are universally supported.

However, two proposals – the developer cap and zonal auction – should be rejected because they may unduly prejudice market participants and disrupt the interconnection process. NextEra Energy Resources urges CAISO to retract these controversial proposals and instead opt for the existing and other mechanisms proposed in IPE Track 2 to manage the interconnection queue and verify the quality and viability of interconnection applications.

Developer cap.  The limit proposed by CAISO to interconnection request capacity, set at 25% of the total available transmission capacity for a specific cluster, is problematic for several reasons:

This proposal contravenes the open access and non-discrimination principles of the CAISO tariff. These principles oblige CAISO to provide interconnection services to all eligible customers on a 'first come, first served' basis, without considering the customer's identity, ownership, or affiliation.  And as the Federal Energy Regulatory Commission (FERC) stated in Order No. 2023 at P 1, revisions to the interconnection process are to “ensure that interconnection customers are able to interconnect to the transmission system in a reliable, efficient, transparent, and timely manner, and will prevent undue discrimination.” The developer cap does not meet CAISO’s existing standards and standards embedded in the Federal Power Act.

The proposal also would create significant additional requirements for developers who may have several projects across zones and who operate under business models, risk appetites, and contracting strategies. The proposal would unfairly penalize a subset of developers who have already made significant investments in site control, permitting, interconnection studies, and who can offer substantial project viability and readiness through the scoring criteria. CAISO has developed a methodology for calculating the available transmission capacity based on the transmission planning process upgrades. However, the exact number for Cluster 15 has yet to be determined, making it impossible for developers to know the MW target to plan to. Furthermore the 25% limit will vary from year to year, making it a moving target that is unknown until only a few months before the opening of the next cluster window. Sitting and project development starts several years in advance of making an interconnection request, and developers need to know the specific quantity of available interconnection resources to plan accordingly.

Given that CAISO already has mechanisms in place to manage the interconnection queue and to ensure the quality and viability of interconnection requests, such as through site control requirements, financial security postings, scoring criteria, and viability criteria, the developer cap is both unnecessary and ineffective.

Zonal auction.  The proposed zonal auction by CAISO, which involves a market-clearing, sealed-bid auction for the right to be studied in a specific zone, also raises several concerns:

This proposal increases the complexity of administrative processing and delays interconnection studies. The auction is a third and unnecessary step, as the CAISO already has other mechanisms proposed to prioritize and select interconnection requests for study, such as the scoring criteria, and the DFAX tiebreaker. The scoring criteria creates appropriate and transparent screening for projects that is dependent on project readiness. A developer bid in an auction does not demonstrate that a project is viable and ready.

Considering these issues, NextEra Energy Resources urges CAISO to reconsider the developer cap and zonal auction proposals. We remain committed to diligently engaging with CAISO and other stakeholders on the IPE Track 2 and appreciate CAISO's initiatives aimed at aligning the interconnection process with Order No. 2023. However, we firmly oppose the aforementioned proposals due to their unjustified, discriminatory, and damaging potential for the interconnection process and the market.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

Nightpeak appreciates the opportunity to submit comments for this IPE. We believe that the simplest and most effective way to lessen the number of projects and megawatts in the queue is to require that all projects, regardless of vintage, obtain site control to stay in the queue. This simple and easy to understand fix would also free up meaningful amounts of transmission and deliverability for projects that remain, helping the state reach both its reliability and renewables goals. In addition, we strongly urge CAISO to be sure any changes to the tariff do not favor older projects without site control over higher viability Cluster 15 projects with site control. Projects in Cluster 14 and prior which still have not obtained site control are by definition speculative. In fact, given new study timeline requirements mandated by FERC Order 2023, projects without site control may have longer and riskier development timelines than Cluster 15 projects with site control.

We believe this requirement would be consistent with approaches implemented by other FERC-jurisdictional Balancing Authorities and would not unduly dissuade investment within the CAISO footprint, especially if a transitional period were implemented for older projects to gain site control before being deemed withdrawn.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Nightpeak believes the data that has been provided through the Transmission Plan Deliverability Allocation Report, White Paper, Transmission Capability Estimates, Transmission Plan, and other materials has been sufficient, especially when analyzed in conjunction with materials provided by CPUC, CEC, and other sources.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Nightpeak requests clarification of how CAISO would treat a project selecting Energy Only ("EO") in its Interconnection Request ("IR") and whether it would be subject to the 150% transmission cap. For example, if a project selected EO in its IR and is located in a zone with no Transmission Plan Deliverability, would it advance to study in all cases since it doesn't request deliverability?

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

Nira conducts transmission planning studies to help inform developers of wind, solar, and storage projects about potential inhibiting constraints on the transmission system. This is a crucial exercise developers undertake to understand project viability at all stages of development - from green-fielding to signing a Generation Interconnection Agreement (GIA).

Nira is active in all US markets except CAISO. Nira has attempted to conduct studies in CAISO, however, Nira has been unable to complete these studies due to a lack in modeling transparency. Nira has concluded that two things are required to accurately perform studies:

1. Adequate modeling details around Remedial Action Schemes (RAS)
2. Adequate modeling details for “Congestion Management” methods

Nira kindly asks CAISO to improve transparency on the two aforementioned areas in order to facilitate the ability of third parties to undertake accurate transmissin planning studies to inform renewable generation development efforts.  

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Nira Energy is pleased to have the opportunity to provide comments regarding CAISO’s “Revised straw proposal Initiative: Interconnection process enhancements 2023” and would like to thank CAISO and all those involved in this proceeding for their important work.

Nira conducts transmission planning studies to help inform developers of wind, solar, and storage projects about potential inhibiting constraints on the transmission system. This is a crucial exercise developers undertake to understand project viability at all stages of development - from green-fielding to signing a Generation Interconnection Agreement (GIA).

Nira is active in all US markets except CAISO. Nira has attempted to conduct studies in CAISO, however, Nira has been unable to complete these studies due to a lack in modeling transparency. Nira has concluded that two things are required to accurately perform studies:

1. Adequate modeling details around Remedial Action Schemes (RAS)
2. Adequate modeling details for “Congestion Management” methods

Every developer has the question of “how much transmission capacity is available at Substation X before network upgrades are required”, or “how much transmission capacity is available before curtailment is required”.

Transmission Planning Engineers cannot answer these questions in CAISO without adequate details regarding Remedial Action Schemes (RAS) and Congestion Management.

1.  Request for Transparency on Remedial Action Scheme Details

There are numerous RASs on the California transmission system. The most common type of RAS could be categorized as a “generation runback scheme”. This means, if a contingency occurs, generation will automatically be curtailed to mitigate an overload. In order for a Transmission Planning Engineer (TPE) to conduct a study on the CAISO transmission system, it is imperative that they know the following for each RAS:

• The monitored facility or facilities
• The contingency or contingencies
• The set of generators already subscribed to the RAS

It’s assumed that CAISO has RAS definitions in a text file (e.g., *.ras) in order to correctly conduct studies correctly internally. Nira requests these RAS definitions be shared under CEII access.

2. Request for Transparency on Congestion Management Methodology

CAISO often uses “Congestion Management” to mitigate overloads. This seems to be a concept that is applied with internal discretion at CAISO, but the criteria under which CAISO applies this solution is not sufficiently detailed for TPEs to be able to reproduce study results. Questions TPEs are currently unable to answer are:

• What monitored facilities and contingencies qualify for Congestion Management?
• Is there a cap to the amount of Congestion Management?
• Is there a specific subset of generators that are eligible to be curtailed?

Nira requests CAISO provide adequate documentation in order for external TPEs to be able to replicate study results. This information could be shared under CEII access.

3. Maps and associated data are not sufficient alone

Nira is aware of the work the CPUC and CAISO have been doing to map available capacity on the bulk transmission system. This work seeks to identify zones within which prospective generators are encouraged to interconnect due to identification of sufficient transmission capacity to accept the addition of these new generators.

Additionally, Nira is aware of CAISO’s plans to comply with FERC Order 2023 and publish a heatmap that provides “information at the POI level of available capacity based upon the generation that was included in the latest cluster study and after the restudy.”

Publishing these maps and the associated network data is a great step forward, but ultimately falls short in enabling the broader Transmission Planning community to replicate CAISO study results.

A key example where the maps will fall short would be any sensitivity analysis on queue assumptions. Maps and their associated data will be based on a single set of assumptions, or perhaps multiple sets of assumptions. However, it’s impossible to study all the combinations a developer may be interested in. For these reasons, it is crucial that CAISO equip external Transmission Planners with sufficient modeling details in order to conduct a study correctly.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

Due to the overwhelming number of new generation interconnection requests that have been submitted into the CAISO’s interconnection process during the past few queue cycles, the CAISO interconnection process has become overrun. The result is an excruciatingly slow and expensive process that deprives new projects of the opportunity to achieve timely interconnection, or even to receive timely and accurate estimates of how much it will cost them to achieve interconnection should they have the resources to spend years in the process waiting. NCPA will not dwell on the evidence CAISO has produced detailing the extent of the problem. Suffice it to say that the current process is not producing good results for anyone, especially for ratepayers.

CAISO is to be commended for proposing creative solutions to improve its process. The stakeholder process developed principles and problem statements that emphasized the important underlying values that must be represented and balanced in its final proposal. These include accommodating the California resource transition, ensuring that load-serving entities (LSE) have access to the necessary resources to serve their loads reliably and to meet all regulatory requirements, inclusion of all load-serving entities, equity, efficiency and capturing the benefits of competition and open access. Some of these goals are in tension with each other.

NCPA believes that CAISO has put forward a proposal that makes appropriate trade-offs. A system that simply does not work serves no one. At rock bottom, the fundamental role of the interconnection process (or any other part of the CAISO Tariff) is to ensure that LSEs have the ability to develop and gain access to resources they need to serve their load reliably and at just and reasonable rates. A functional interconnection process that quickly advances the most viable and needed projects to interconnection is necessary to meet this fundamental need, and will be critically important in allowing the state to achieve its environmental goals.

CAISO’s proposal has evolved and improved significantly during the stakeholder process. CAISO’s goal, as originally stated, was to “tighten[] linkages among resource and transmission planning activities, interconnection processes and resource procurement” so that these processes are proactively aligned in ways to help the state meet its reliability and clean-energy policy goals.[1] This goal accords with the Memorandum of Understanding among the California Public Utilities Commission (CPUC), the California Energy Commission (CEC) and the CAISO. Coordinating state agency and CAISO processes with the California energy transition is a laudable goal that inherently subsumes the concept that resource development and selection may have to move beyond the concept of letting all projects into the study queue, without respect to viability or what is needed to meet regulatory requirements.

Yet, as originally stated, the goal left out a significant piece of the CAISO landscape, specifically the non-CPUC jurisdictional LSEs, which are not parties to the MOU, not subject to many of the CPUC and CEC requirements, and have not explicitly been included in the Transmission Planning Process (TPP), but who must satisfy requirements imposed by their own Local Regulatory Authorities (LRA) both in terms of serving load reliably and cost-effectively, and in terms of achieving environmental mandates that may not match those of the CPUC. Obviously, a proposal that left out a significant number of the LSEs in the CAISO footprint could never have been found just and reasonable.

NCPA appreciates the fact that CAISO recognized this deficit, and has now included elements which provide non-CPUC jurisdictional LSEs a place at the table in the CAISO planning process, and an avenue to advance projects adopted by these LRAs into the interconnection process. These provisions are discussed further below.

As currently structured, including the provisions focused on non-CPUC jurisdictional LSE resource planning and development, NCPA can support this interconnection process package as proposed by the CAISO.[2]

[1] CAISO, 2023 Interconnection Process Enhancements: Issue Paper and Straw Proposal at 3 (Mar. 6, 2023), http://www.caiso.com/InitiativeDocuments/Issue=Paper-and-Straw-Proposal-Interconnecton-Process-Enhancements-2023-Mar132023.pdf.

[2] NCPA’s stated support for the interconnection process package as currently proposed by the CAISO is subject to and may change pending any subsequent modification that may be made to the current proposal.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Provided that non-CPUC jurisdictional LSE resource plans are included in the development and identification of zones through the TPP, NCPA can support the zonal approach.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

NCPA appreciates and strongly supports the CAISO’s commitment to solicit resource plans of non-CPUC jurisdictional LSEs as part of the TPP. NCPA engages in active resource planning at the direction of, and in coordination with, its member utility LSEs and their respective LRAs. Non-CPUC jurisdictional LSEs are subject to many of the same reliability and environmental requirements as LSEs regulated by the CPUC, though each LRA also may impose individual requirements. Inclusion in the TPP that will establish the planning zones is a crucial first step in assuring that the interconnection reforms proposed herein work equitably for all CAISO LSEs. 

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

LSE Interest Scoring Criteria

NCPA supports the inclusion of scoring criteria allowing LSEs to award points to projects they wish to see included in the cluster study. The goal of tightening the linkages between the TPP, the resource procurement requirements imposed by the CPUC and the other LRAs, and the generator interconnection process can only be achieved if LSEs are able to influence the selection of projects for study to ensure that the types and number of resources that LSEs need to meet the requirements imposed upon them by their respective LRAs are actually built and available to them. Projects that meet declared LSE needs or have LSE backing are inherently more viable. FERC has recognized this. [1] Where CAISO cannot study all projects and still provide meaningful study results, projects with indicators of LSE interest viability should be prioritized in the study process.

CAISO has proposed a simplified version of a scoring system proposed by an LSE working group led by Southern California Edison (SCE), in which NCPA participated. Although CAISO did not adopt all aspects SCE proposal that NCPA supported (direct recognition of LSE developed projects), the CAISO’s proposal seems reasonable as part of the complete package put forward in the Revised Straw Proposal. NCPA remains concerned that the scoring proposal, by itself, may not provide sufficient points for small LSEs in years where the Transmission Plan Deliverability (TPD) is on the low side. However, other features in the Revised Straw Proposal mitigate this concern.

To illustrate, if there were 45,000 MW of TPD in a given year, NCPA believes that under this proposal, the combined load ratio share of NCPA’s member utilities (which represents slightly less than 2% of the CAISO’s overall load) would yield it approximately 315 points. As NCPA understands it, these points could be awarded to up to 315 MW of proposed project capacity. NCPA’s members are long established utilities (some have been in business for over 100 years) with significant existing resources and mature portfolios. Resource planning is focused on load growth and meeting future regulatory requirements. This number of points would likely be sufficient to meet evolving needs in most years. However, in a year when less TPD might be available, the lower number of points that could be allocated to small LSEs by load ratio share could be insufficient for their procurement needs, particularly taking into account the lumpiness of resource acquisition. It is difficult to draw a clean line between sufficient and insufficient, but in some years, small LSEs could wind up with too few points to designate needed resources. For the smallest non-CPUC jurisdictional LSEs, the scoring provision might be adjusted to provide that all LSEs receive their load ratio share of points or some minimum threshold, whichever is greater. NCPA is not wedded to a particular number, but suggests 20 points as a minimum.

This potential shortfall is mitigated in the current proposal by the CAISO’s separate provision for automatically including in the cluster study resources included in a non-CPUC jurisdictional LSE resource plan approved by its LRA (where required). Taken together, the scoring criteria and the provision for automatic inclusion address NCPA’s concerns. There may be circumstances where it is appropriate for CAISO to reduce the scoring criteria point allocation for LSEs using the automatic inclusion provision by the number of megawatts of the project(s) automatically included.

Automatic Study Inclusion

While NCPA greatly appreciates the inclusion of non-CPUC jurisdictional LSEs in the TPP, such inclusion does not assure that highly viable projects identified in the overall plan will be built. The automatic inclusion of such projects in the cluster study allows these relatively small projects to proceed and to be developed to meet the needs of non-CPUC jurisdictional LSEs and their ratepayers. These projects should still meet standard requirements for site exclusivity and pay all deposits and generally comply with all requirements to enter into and move forward in the study process.

NCPA maintains its strong support for the automatic inclusion of these projects included in LSE preferred resource plans approved by the LRA (or where LRA approval is not required). As noted above, the LSE interest scoring process, as currently proposed, may not always provide sufficient points for non-CPUC jurisdictional LSEs, often quite small, to designate needed projects. The CAISO has noted that not all of these LSEs may be able to participate in the TPP in a timely fashion. Indeed, the TPP beginning in 2024 is the first where CAISO has formally solicited participation from the non-CPUC jurisdictional LSEs, and it remains to be seen whether the results of this TPP will be available to inform the next cluster window to open (Cluster 16), the date of which remains uncertain.

With regard to entities that have opposed this provision, NCPA has previously expressed its preference that the relatively small number of megawatts likely to be studied under this provision in any particular year should not be counted against the 150% megawatt cap to be studied in each zone, as the numbers are likely to be de minimis. Concerns about future municipalizations seem speculative at within the time frame of this initiative.

The automatic inclusion of non-CPUC jurisdictional projects in the cluster study remains a necessary route for these entities to ensure that they can build or acquire the resources needed to reliably meet their loads and satisfy the regulatory requirements of the energy transition in a system that was not originally designed with them in mind, and where their relatively small projects otherwise can get lost in the noise of a much larger system.

[1] Arizona Public Service Company, 184 FERC ¶ 61,188, P40 (2023).

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

No comment at this time.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

No comment at this time.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

No comment at this time.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

No comment at this time.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

No comment at this time.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

No comment at this time.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comment at this time.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

No comment at this time.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

No comment at this time.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

No comment at this time.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

No comment at this time.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

No comment at this time.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

No comment at this time.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

No comment at this time.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

No comment at this time.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comment at this time.

1. Please provide a summary of your organization’s comments on the revised straw proposal

PG&E appreciates the opportunity to provide comments on the IPE Revised Straw Proposal. Below please find PG&E’s comments and recommendations.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

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

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

2.3 Interconnection Request Limitations

PG&E is generally supportive of CAISO taking steps to ensure there is no market dominance by a handful of developers and that competition exists among resource developers for LSEs to procure from. However, PG&E believes the proposal to impose a cap-based limitation falls short of meeting the desired outcome of ensuring robust competition so there is no market power by one or more individual companies, which causes a negative influence on customer rates.  Therefore, PG&E supports CAISO suggestion in the revised straw proposal that it continue to explore various mechanisms to achieve the desired outcome of no market dominance in the market for procurement of new resources.  PG&E recommends CAISO hold a working group meeting to see if we can identify any appropriate mechanism to ensure there will be no market dominance with the new paradigm of zonal caps and scoring criteria for selecting which projects proceed to study.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

LSE Interest Points

PG&E is generally supportive of the approach taken by the CAISO regarding the allocation of points to LSEs based on their load share. Having the ability to award these points to preferred projects will enable LSEs to ensure that projects that meet their unique CPUC portfolio requirements are ultimately studied and have an opportunity to receive TPD.

It is important that the methodology for how an LSE can award points to the projects that they prefer remains flexible and does not become more prescriptive. A more prescriptive approach will diminish the ability of the LSE to support projects that meet their portfolio requirements.

Project Viability Points

Project Viability is important and a score that could differentiate the most viable projects to be studied would be helpful, though the proposed scoring criteria may not achieve the desired outcome. The first two scoring criteria, demonstration of business partnerships for future supply of major equipment prior to COD and submittal of an Engineering Design Plan, only target project readiness and say nothing about whether a project is truly viable. In addition, as the ISO acknowledges, those two scoring criteria will be easily achievable and hence they are more like busy work to check a box in which every applicant will be able to complete.  PG&E recommends CAISO further assess what are other viability criteria could be included in the scoring criteria to provide a more granular assessment of project viability.   

The final two scoring criteria, expansion of an existing facility and expansion of an existing facility where the existing Gen-Tie already has sufficient surplus capability to accommodate the additional resource, do provide differentiating data points.  An existing facility may have less infrastructure that needs to be built and hence a lower cost to build.  An existing project with an existing Gen-Tie that can support the proposed Project would be a cost saver and would improve the Viability of the Project.  PG&E is supportive of these two scoring criteria.

System Need

PG&E believes if a proposed project has an identified benefit in the LCR area by CAISO to earn points, then the resulting reduction in the local resource adequacy requirements in the CAISO’s LCR technical studies should be included in the project approval process and future LCR study efforts.  In addition, within LCR areas there are sub-areas and while the addition of a resource in one sub-area may have benefit to the system, the placement of a resource in another sub-area would provide no net benefit to the LCR area.

Regarding the second proposed indicator of system need, long lead-time resources, PG&E requests that the CAISO clarify and define what is considered as long lead-time resources as there are differences between prior CPUC and CAISO definitions for this category.  In addition, PG&E requests the CAISO further describe what the following language from footnote 21 in the revised straw proposal means and how it would be applied: “or as specifically identified by the CPUC in the portfolio provided to the ISO for use in the transmission planning process.” 

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

PG&E recommends that CAISO do further analysis of this new proposal and pick an area with high expected wind penetration area like Humboldt, and test the 150% new generation limit. If the analysis results in a large number of megawatts being available for new interconnection applications, CAISO should consider lower limits for zones that have large number of active applications in the queue since any new available deliverability would be more accessible to projects that are already in the queue.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

PG&E appreciates the CAISO’s additional development of a points-based scoring system that utilizes DFAX as the first tiebreaker for projects deemed equal in viability rating and cause the total MW for a zone to cross the 150% MW capacity limit for a zone.  PG&E believes using a market-clearing, sealed-bid auction mechanism as a second order tiebreaker to ensure that no more than 150% MW capacity limit for each zone is studied in the cluster process is reasonable. 

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

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

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

PG&E agrees with the CAISO that the off-peak and operational deliverability assessments have limited value and supports the proposal to remove both assessments in order to meet FERC Order 2023 150-day study timeline.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

PG&E supports [emphasis added] the CAISO’s revised position on the one-time withdrawal opportunity.  While PG&E believes that cleaning up the queue has benefits, it should not be done on the back of the PTOs’ balance sheets and ultimately customers by the transfer of 85% of the financing burden and need for access to capital for the precursor network upgrades (PNUs) that would still be required but were previously assigned to interconnection customers due to their entry into the interconnection queue.  Instead, PG&E recommends CAISO’s take steps to enforce its existing queue management tariff provisions and adopt its new batch of proposed queue management reforms to clean up the queue to the extent possible for the Cluster 15 study process and subsequent clusters. 

PG&E also supports the CAISO looking at other funding avenues, such as the establishment of a funding pool by all interconnection customers that wish to withdraw and have PNU cost responsibility assigned to them, and not just from those withdrawing interconnection customers that triggered still-needed upgrades.  Such a funding pool would need be structured in a manner to create a sufficient pool of funds for PTOs to complete the still required PNUs without transferring the financing burden from the interconnection customers to PTOs.  PTOs would then refund the funds to the pool of withdrawing interconnection customers on a proportional basis over a five-year period once the upgrades are complete.  This funding avenue could be complimented by the pool of interconnection customers seeking low interest rate loans from the U.S. Department of Energy's loan program.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

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

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

PG&E has no concerns with the CAISO proposal.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

PG&E continues to support CAISO’s proposal of removal of suspension rights under LGIAs. This proposal provides that LGIAs and SGIAs are both prohibited from suspending so as to prevent projects from lingering in the queue for extended timeframes.  This will help ensure the CAISO queue is manageable and is comprised of viable projects that intend to move towards commercial operation or are withdrawn.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

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

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

PG&E continues to generally support CAISO’s proposal to enhance Commercial Viability Criteria (CVC) and Time in Queue review and enforcement in order to better manage the size of the queue and ensure projects move towards commercial operation. 

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

In general, PG&E supports the proposal to increase the deposit for MMAs/Post-COD modifications and expanding the time period to process the MMAs/Post-COD assessments by an additional 15 calendar days.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

PG&E supports the CAISO proposal to ensure that all interconnection customers dependent on a shared network upgrade provide timely postings and payments to ensure the project move towards implementation in an efficient manner with all necessary funding secured.  PG&E also supports CAISO’s proposal to withdraw the interconnection customers (or terminate a GIA) if an interconnection customer fails to meet the proposed timelines. 

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

PG&E generally supports this proposal to streamline the process of GIA amendments to capture more efficiency and effectiveness.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

PG&E supports the proposal as it establishes a milestone with a definitive Notice to Proceed to be issued by an interconnection customer, which should ensure that projects stay on the schedule that are indicated in the milestone table. PG&E understands the proposal to imply that if the date is not met, than the interconnection customer would be held in breach/default of the agreement, however PG&E’s requests CAISO clarify if the requirement on the interconnect customers and PTO is initial as the construction activities commence or is it ongoing and frequent reporting with a pre-determined cadence.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

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

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

PG&E uses a PMU sample rate of 60 samples per second, and recommends CAISO modify the proposal use this sample rate.  PG&E notes thought that PMU data is not the best platform for fault analysis; rather, fault recorders with a sample rate of 16 samples/cycle or greater is the appropriate device for fault analysis.

1. Please provide a summary of your organization’s comments on the revised straw proposal

PARS Energy appreciates CAISO's efforts to improve the Interconnection process hopes for the followings as the definition of success:    effort

1. Reduce the number of unviable interconnection requests
2. Guidance reasonably size the proposed capacities of interconnecion requests
3. A fair and equitable Auction process 
4. Minimize the number of participants entering the Auction process
5. Enhance access to critical data access and clarity

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Access to Data- Substations Under CAISO Control

CAISO control of the California power grid is by voltage class. For example, PG&E voltages of 60 kV and above are under CAISO control. SCE voltage of 230 kV and above are under CAISO control and SDG&E’s voltage 69 kV and above are under CAISO control. The problem is that there are exceptions. For example, some PG&E 115 kV voltages are not under CAISO control and some of SCE’s 115 kV voltages are under CAISO control. The Issue is that this information is not public and causes submission of interconnection applications to the incorrect jurisdiction.

Recommendation: It is suggested that CAISO provide the list of substations that are under its control and keeps it updated as some of this information changes from time to time.

Access to Data- Interconnection Forbidden Substations

Some California utilities no longer accept interconnection requests to their substations. PARS Energy expects that in the coming years, more utilities may decide that they no longer accept interconnection requests to specific substations. During Cluster 15, applications were submitted to interconnection Forbidden substations creating confusion and, redesign and resubmissions of interconnection requests.

Recommendation: It is suggested that CAISO create, maintain and continuously update a list of substations to which utilities no longer accept interconnection requests.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Capacity Limit

Currently, the total capacity of interconnection requests is several times of what CAISO needs in the foreseeable future. Under Track 2, CAISO proposes to limit interconnection request capacity that a developer may submit in any given cluster application window to 25% of the total available transmission capacity across the system for each cluster. 

PARS Energy believes that the amount of capacity across system cluster within the CAISO footprint will be a large number and therefore 25% of a large number will still be a very large number.  As observed in Clusters 14 and 15, some abused the interconnection process by submitting very large project beyond the capacity of the grid in an attempt to increase costs for smaller projects and make them economically unviable.

Recommendation:  PARS Energy suggests that the proposed projects and the amount of MWs per project should also have a size limit commensurate with the POI voltage class. The following limits are proposed based on PARS Energy’s professional experience:

-500 kV: 600 MWs and higher

-230 kV: Up to 600 MWs

-115 kV:  up to 250 MWs

- 60/66/69 kV:  up to 130 MWs

The above capacity limits require discussions with IOUs as each utility has its own design standards.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

Auction Size Reduction

Experience in other states have shown that use of auction for interconnection process and $/MW proposals can lead into disputes. In order to reduce the potential staffing CAISO staffing requirement, effort needs to be made to reduce the number of projects that enter into the auction process.

Recommendation:  Upon validation of all IRs, CAISO identifies that the amount of MWs proposed in each Zone that exceeds 150% of that Zone’s capacity. At that stage, all projects can be allowed a one -time opportunity to reduce their requested capacity pro rata of the amount of MWs that exceed 150%. The projects that do reduce capacity will not enter the auction process and will be studied automatically.  Only the projects that do not reduce their capacity will enter the Auction process. For example, if the amount that projects exceed the 150% limit by 300 MWs, and there are 100 proposed projects, each project will have to reduce its output by 3 MWs, or enter the auction process. The proposed process should reduce the number of interconnection requests that enter into the Auction process and therefore reduces the CAISO   staffing requirements to conduct the Auction process.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

PARS Energy supports the removal of  both the off-peak and operational deliverability. 

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

PARS Energy supports the one-time withdrawal opportunity and considers it to be a postitive change.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

PARS Energy supports extension of LOS to nine months and consideres it a positive change.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

1. Transfer of Deliverability

Historically, transfer of Deliverability was limited to the Repowering plants and under the circumstances that the transferor and recipient of Deliverability were at the same POI.  Now that the amount of deliverability is established for each zone and by bus, it may be possible to transfer it to other qualified parties within the same zone if they meet certain qualifications.

Recommendation: It is suggested that CAISO create a process to transfer Deliverability within each zone as long as DFAX parameters of the recipient of Deliverability is equal or better than the transferor. This helps many retiring plants with huge cleanup costs to transfer their deliverability toward development of renewable projects without impacting the constraints of that zone. Additionally, it provides projects that are currently in a zone (parked or otherwise) be provided with opportunities to obtain Deliverability.

2.    Deliverability to None-CAISO controlled Entities

Energy Only projects do not qualify to provide Resource Adequacy (RA) services to the California’s Investor-Owned Utilities. These projects are currently considered as black sheep of the industry and demand significantly lower price than projects with full deliverability. PARS Energy believes that most projects will not opt for Option B and instead opt for Energy Only resources. As a result, we expect a large pool of Energy Only resources can only develop into operation with an RA contract. While projects may not be deliverable to IOUs, they may be deliverable to non-CPUC Under jurisdictional entities outside CAISO control Area such as SMUD, LADWP etc.    

Recommendation: It is suggested that CAISO extend its deliverability Assessment to include non-CPUC jurisdictional entities that are not under currently established zones and are not under CAISO Control Area. Non- Jurisdictional entities generally comply with CPUC’s RA requirement. These resources if awarded deliverability status to entities that are not under PUC jurisdiction and not a member of California CAISO could be dynamically scheduled and act as resources within such entities. PARS Energy will be happy to participate in such discussions.
 

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

Project Viability Assessment

-Equipment Order and Master Services Agreement: Developers do not order any equipment and do not issue Purchase Orders until after execution of GIA and completion of environmental analysis and permits and receiving Notice-to-Proceed. Requiring Equipment Order and Master Services Agreement at the interconnection stage causes undue burden and creates financial risks as described below:

1. 1. Developers generally obtain financing after GIA execution and completion of environmental studies permitting. They simply do not have the funds to order equipment enter into any financial obligation.
   2. Even if a developer did have the funds, during the interconnection process, it may decide to reduce the capacity of its plant and may end up excess facilities and designs they cannot use.
   3. Inverter and solar panel and wind turbine manufacturers generally update their equipment to increase its capacity every six months or so with higher capacities and higher efficiencies. Ordering equipment two years prior to start of construction may lead into a situation that the equipment ordered may no longer be in production. Further, the plant may have to be re-deigned with higher capacity equipment.

Recommendation: The Equipment Order and Master services Agreement requirement is appropriate for CAISO’s NRI process and should not be included in Track 2 as it causes undue burden, financial risk and no benefits to CAISO, utilities or the developers at it does not demonstrate project viability.  

-Engineering Design : Design of a renewale plant is conducted in various stages typically in 10%, 30%, 60%, 90% and 100%. The cost of preparing these design at a minumum costs around $500k. Requiring an engineering designat the interconnection stage  is yet another undue financial burden on the developers and if the size of the plant or the project site changed, it will have to be redone.

Recommndation: The Engineering Design proposed requirement should not be included in Track 2, but is appropriate for CAISO’s NRI process.
 

Suggested Viability Assessment Parameters: PARS Energy suggests that CAISO consider the followings in assessing the commercial viability of a project:

1. Past history of project development in California;
2. Past history of project development using the technology proposed in the interconnection request;
3. Relationship and letter of interest from banks and financing organizations with specific credit rating requirement, and
4. Exclusive Letter of Interest from CAISO jurisdictional LSEs.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

Please revise the terminology to "Phasor Measuement Unit (PMU)" 

1. Please provide a summary of your organization’s comments on the revised straw proposal

While Qcells USA Corp (“Qcells”) appreciates the need find enhancements in the interconnection process, we find that CAISO’s IPE takes unnecessary steps beyond that which Order 2023 provides as improvements to the process. Although Qcells applauds CAISO for removing certain provisions from its scorecard, such as the PPA requirement, Qcells finds that its 25% cap, as well as its scoring criteria continues to create an uneven playing field that is unjust, unreasonable, and unduly discriminatory or preferential. Qcells opposes any process that prevents viable projects from entering the study process due to assumptions made about the preference of such project before it even has the chance to be studied.  

Although generally opposed to using scoring criteria to determine which projects are studied, Qcells supports CAISO’s decision to remove PPAs from its scoring. Also, Qcells supports the data and heat map CAISO proposes to provide to Interconnection Customers.  

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Qcells appreciates CAISO’s efforts to make data accessible to better inform its zonal approach. Qcells supports providing any-and-all data available to better assist developers in making project decisions within the zonal approach to include single line diagram resources, identification of transmission constraints, locations of POIs and resources behind those constraints, and a list of substations within identified interconnection areas. Further, Qcells supports CAISO’s targeting of its implementation of an Order 2023-compliant heat map in Q2 2024. 

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Qcells opposes CAISO’s proposal which limits the number of requests that a developer may submit in any given cluster application window to 25% of the available transmission MW capacity for that cluster. Qcells understands there is a risk that a single developer may submit many requests that may overwhelm the queue. However, Order 2023 provides new guardrails against these practices, such as new site control requirements, increased study deposits, commercial readiness deposits, and a strict withdrawal penalty structure. Rather than creating rules to dissuade developers from submitting projects, CAISO should allow Order 2023 to work. Further, CAISO’s approach to provide data so that developers can make informed business decisions will also reduce the risk of a single developer overwhelming the queue.  

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

Qcells appreciates CAISO’s removal of points associated with PPAs from its scoring criteria. However, Qcells opposes any scoring criteria that may prevent a project from entering the study process. CAISO states that its scoring criteria is “a key mechanism to ensure that the most ready projects advance to the study process.” However, the CAISO scoring criteria is likely to put a halt to viable projects that would have been proven “ready” if they were able to be studied. Likewise, projects that may be assumed to be “most ready” prior to study, may turn out to be infeasible once studied. Without a proper interconnection study, it will not be possible to fully realize interconnection costs or impacts to the grid. By moving some projects forward to study, and holding others back, CAISO will be creating winners and losers. The anti-competitive nature of this proposal is unjust, unreasonable, and unduly discriminatory or preferential. 

Rather than utilizing scoring criteria to determine which projects are most ready, CAISO should lean into FERC’s Order 2023, which strives to create a “first ready, first served” interconnection process. As stated above, the reforms in Order 2023 promote ready and viable projects, reducing the need for stringent scoring criteria, which will only create an uneven playing field. 

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

Qcells appreciates the need to be mindful of sub-zonal capacity constraints; however, rather than freezing interconnection access in an area, CAISO should focus its efforts on providing the most detailed information possible to would-be Interconnection Customers so that they can make informed decisions on projects. In this light, while opposing the proposed 150% limit, Qcells supports CAISO’s proposal to provide access to its analyses of individual transmission zones with sub-zonal constraints. 

Further, Qcells does not support the automatic inclusion of non-CPUC jurisdictional LSE preferred resources into the 150% capacity threshold. This runs the risk of a non-CPUC jurisdictional entity preferring its own resource over other viable resources, which on its face would be discriminatory. 

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

No comments at this time.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

Qcells opposes CAISO’s proposed disallowance of projects to proceed under Option B if they do not qualify for TPD under Option A. If CAISO proceeds with using scoring criteria as a cap, then those projects who are disqualified from Option A should have the option to self-fund any needed upgrades under Option B. 

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

No comments at this time.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

No comments at this time.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

No comments at this time.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comments at this time.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

No comments at this time.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

No comments at this time.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

No comments at this time.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

No comments at this time.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

No comments at this time.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

No comments at this time.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

No comments at this time.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

No comments at this time.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comments at this time.

1. Please provide a summary of your organization’s comments on the revised straw proposal

The Interconnection customer, Recurrent Energy (“IC”)  acknowledges the addition of new sections in the revised straw proposal, particularly under Sections 2 and 3, addressing transmission capacity and operational deliverability assessments. While we understand the need for these topics in Section 2, we seek further clarification regarding their inclusion in Section 3.

 We also comment on various aspects of data accessibility, interconnection request intake, scoring criteria, and zonal auctions, as well as modifications to the Merchant-Financing process and the removal of suspension rights. Our feedback includes queries and suggestions for improvements in data handling, communication, and process enhancements. We aim to contribute constructively to the proposal's evolution, ensuring it effectively addresses the dynamic needs of the energy sector.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Where can I find the ‘Constraint-Boundary-Substation-List’ for SCE and SDGE ? PGE published their Matrix as an appendix to T-capability white paper however SCE & SDGE Posted the area constraint images not the excel. I understand CAISO Plans to publish a more consolidated information someone time in Jan 2024, however if there is any MPP portal resource I can access to get this specific information will greatly appreciate if you can guide me to that.

Not all substations are included in the ‘Constraint-Boundary-Substation-List’ for PGE ? If our C15 project is connecting to a POI that is not in the list what can we do to determine the Transmission capability for the area that project belongs to ?

Is there some kind of mapping for The substation names in the Substation_Constraint Matrix and the substation names in Queue List published by CAISO? If not Can CAISO create something like this and share, I can take a stab but wanted to see if CAISO already had anything

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

See answers for Q 4 to Q 7

What is CAISO’s site control criteria (acre/MW or acre/MWh) for the standalone storage projects?

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

IC applauds CAISO’s decision to remove commercial and permitting criteria like PPAs or permitting from the scoring process.

As part of the Data accessibility exercise Will  CAISO be willing to share a list of substations and the LRAs/LCRAs they come under so that developers can assess if their\ porjects may really qualify for the system need requirement.

LSE Interest: it is not clear how LSE capacity allocation process will work. Is it going to be a centralized process controlled by CAISO or a process that should be managed by IC by contacting LSEs individually prior to the interconnection process? If it’s the latter, it could be problematic to LSEs because all the projects will be in very early stage. With only location and size information being available, the LSEs will have to select the project that they are willing to contract in the future. IC is not sure whether this system would be workable to LSEs in a practical sense.

Project Viability: Demonstration of business partnership for future supply of major equipment needs to be elaborated because getting a general partnership agreement from major equipment supplier will be very easy, and it will not likely be a deciding factor among the projects. Same for submittal of an engineering design plan. It will be very easy for ICs to put together a basic engineering design plan if the site control is completed. This will not be a differentiator among the projects.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

 Will CAISO be making available the information on sub-zones for every zone that the project will be assigned to based on the constraints it is behind? Or is the constraint the sub-zone ? For example, per the transmission capability white paper if a constraint (subzone1) has 1000MW capability left after what is allocated already and what will be taken up by C14 , then will the sub zone capacity be 1000 MW ?

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

How and when CAISO anticipates they will communicate to the projects that an auction bid requirement has been triggered and their projects will need to submit a seal-in bid?

Will there be a starting point or minimum bid value provided by CAISO for this option?

Is CAISO going to open the auction results, including the clearing price, to the public?

CAISO have a plan to introduce a cap on the unit size of the project based on the available transmission capacity in a zone? If, for some reason, a large size project has a very high viability score, it could take the entire transmission capacity in the zone, ultimately being selected and studied as the only project in the zone, which is not very favorable to the entire market.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

Can CAISO help IC understand why the repayments of ADNU funded under option B can only be done via CRR’s. I think the main concern with CRR from Developer’s perspective is in what amount and after how long that investment be fully repaid. With the Cash repayment option there is certainty on caps, at risk amount and Surety that withing 5 year of COD that amount will be paid back. The same may not be true for repayment in form of CRRs.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

No Comments

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

For option 1 Can CAISO help IC understand what they mean by ‘a willing funding entity to assume costs and financing obligation associated with these network upgrades’. IC understands when the Project withdraws their shared NU costs will need to be offset by another project or the PTO itself. To reduce burden on the porjects that remain and PTOs, CAISO wants a willing funding entity to handle this burden. But IC is unable to understand what will this funding entity/third party  look like ? How/why will they be ‘willing’ to fund the NU’s ?

IC  supported option 1 (which was the only option until last draft issued in August/September)  with a desire to understand better how the adjustment to the shared NU costs look like. This options certainly incentivized developers to  withdraw their project and help trim the queue.

There is not much information on option 2 to provide any kind of support or opposition to it. The only thing CAISO provides is, “the ISO proposes to drop the one-time refundable withdrawal opportunity in favor of other queue management proposals that will set clearer requirements for projects in the queue to either perform or withdraw.” Unless more information is shared on what this option might look like it’ll be hard to pick one option over the other.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

 Will CAISO be willing to implement this set up for porjects that are affecting the CAISO System ?

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

 No Comments

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

 While IC understands the rational of the ISO to remove suspension rights and has one request to allow moving back the milestones further by 3 years instead of one , or two 1 yr extensions in addition to the original request.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

 No Comments the proposal sounds reasonable

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

Requirements like procurement status must include some accountability/ status update from PTOs as well. It has been observed that majority of project delays are triggered by PTO procurement delays lately. Unless this provision is made porjects will continue to face multi year delays in their ISD due to PTO triggered delays and the whole point of the exercise will be defeated. Further, with CAISO and CPUC working on a solution to add some accountability on PTOs part in the matter, it makes sense/seems like a logical next step to add such a provision in This IPE cycle, to demonstrate a timely action item implementation on their part, waiting for another IPE process or Working Group  to resolve this issue might seem to procrastinate resolving the root cause of project delays. Happy to hear CAISO's thoughts.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

 No comments

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

 A provision to have  PTO to provide a concrete schedule for the NU /NTP Date that they plan to achieve along with this notification of payments for the Porjects must be added to this section.

The tariff language that this change will be reflected on must be modified such that the language on the timeline for PTO to act on the upgrade is enforced not optional, ‘once the PTO has received the NTP and 3rd IFS posting, it will have 30 BD to commence the upgrades.’

This proposal adds uncertainty on the timeline for the payment, which will become a challenge for developers who seek investor approvals before making high financial security and monthly payment posting. IF CAISO can add more predictability on the notification timeline/payment schedule front for upcoming payments in a year or quarter that might be helpful. The 90 day clock starts ticking once notification is received from CAISO , in addition to this notification if a yearly heads up on upgrades that may trigger payments due to IA’s getting closer to execution will be helpful.

Generally, developers make a calendar view of the payments that they expect to go out at-least an year in advance as part of the financial year planning. Any abrupt payments that were not accounted for are drawn from some reserve or emergency funds. If random payment notification becomes a norm, it will cause developers to over-draw from those emergency funds.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

No comments  

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

The language provided in this proposal stands if the PTOs meet the Date commitments that they make in the LGIAs . It will be crucial for the true realization of the proposal that PTOs are held accountable if they digress from the dates they commit to in the GIA , and are subjected to similar due diligence like IC's when they want to implement such delays.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

1. Can CAISO show some sort of backend calculation that went into coming up with $100,000 deposit and how it will help fix this problem .
2. IC is having a hard time understanding How will these additional fees help CAISO overcome staffing issues? I think the root cause is overworked staff with bandwidth limitation to cater t the growing interconnection supply and demand needs of system,
   1. IC feels additional fees won't solve that problem.
   2. On several occasions IC's have heard how over worked everyone is and how they are trying to make ends meet with the limited resources they have working over night or through Holidays.
3. CAISO needs to have a plan for hiring and training staff that is able to address time constraint and resource overload issues. CAISO has confessed in several platforms their workforce has not scaled according to the workload in the last few years. Taking an example from the ‘for profit world’, companies scale their staff when work increases , they  don’t reduce the work and keep staff the same. The fight for climate change is real, CA is on the forefront of several revolutionary changes in the energy transition space and CAISO has been the bearer of many of these changes. The Interconnection Process Enhancement will not be the end of the struggle here and it seems pertinent they seriously consider upscaling their staff and bring in more gen Z in the workforce that feel Passionate about the subject and add new perspectives/more efficient ways of operating.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

16 samples per second, have enough inverter manufacturers CAISO has in its Queue shown proof of operational feasibility of this requirement

1. Please provide a summary of your organization’s comments on the revised straw proposal

REV Renewables (REV) appreciates CAISO’s progress and changes made to the revised straw proposal. However, REV continues to oppose CAISO’s proposal on the Interconnection Request Intake process, particularly for the zonal and company caps, scoring criteria, and auction approach. Despite the many hours that REV and other stakeholders have spent trying to find solutions to provide more clarity and simplicity, the proposal is still not a workable solution and is an overly complicated process. REV continues to suggest that CAISO instead raise the baseline requirements (e.g. entry fees, deposits, withdrawal penalties) and allow projects to be studied that meet those requirements. This approach would allow a project at entry to know whether it will be studied and avoid wasting time and money on site control or permitting and chasing more points for a project that, while it may rank high and be very viable, may ultimately not pass through the filter if another project scores slightly higher. By raising the baseline requirements bar, CAISO can filter out speculative projects, and projects can prioritize resources more efficiently. CAISO could also add increasing requirements (e.g. additional financial postings) through the study process so that a project needs to prove it is viable along the way in order to proceed. Additionally, complying with FERC Order 2023’s site control requirements may be a significant filter on its own to reduce the number of projects entering the queue, without creating a more complex scoring mechanism. This baseline requirements approach would mean a zonal cap limit, scoring criteria, and auction would not be necessary and would greatly simplify the proposed intake process compared to the Revised Straw Proposal. However, REV offers the comments below in the case that CAISO does move forward with its currently proposed approach.

In addition, in section 1.2 on FERC Order 2023, CAISO notes that “as a transitional measure, all interconnection customers without site control or executed GIAs may be required to have them sooner than the GIDAP currently contemplates.” REV opposes this action as out of scope. CAISO is not implementing a transition cluster as contemplated in Order 2023 and therefore should not change existing rules to pre-Cluster 15 projects. CAISO’s current GIDAP Manual allows Cluster 14 projects to enter Phase II without documenting Site Exclusivity, and this should not require a change to comply with Order 2023. If CAISO still ends up enforcing site control requirements pre-Cluster 15, it should propose how much time the projects have to show site control and request stakeholder comments on this.

REV does support most of the proposals in the Contract and Queue Management and thinks these changes will help ensure that projects keep moving through the queue and non-viable projects to not linger unnecessarily.

REV is ok with delaying TPD allocation related issues to a later IPE paper and emphasizes the importance of finding a solution on this issue in order for projects to retain deliverability in 2025 TPD allocation process.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

REV appreciates CAISO’s additional information provided on data accessibility and changes made from the previous proposal. REV requests that CAISO share a sample workbook for stakeholders to review and better understand what information will be included and what may need to be added/changed to support development. REV also urges CAISO to release area constraints and map data in GIS format for developer access and informed decision-making.

REV opposes the Zonal cap of 150% of available and planned transmission capacity.

• REV requests further justification for CAISO’s proposed limit of 150% of available transmission capacity in the zone. CAISO has not provided any data analysis, such as on project success rate, to suggest that only studying 150% of available and planned capacity is sufficient. In previous clusters, projects have had a relatively low success rate of reaching commercial operation, which suggests that CAISO should study much more than 150% in order to reach even close to 100% of available and planned capacity.
• CAISO should also provide further clarity on how energy only projects will be included in the interconnection queue and whether they would be counted in some way against the 150%. Also, if a project enters as energy only, would they be prohibited from later applying for TPD? REV also encourages CAISO to provide some indication on the congestion related to these EO projects so that developers can gain some insights into optimally locating these projects as well in the zones.
• REV also requests that CAISO consider including in the 150% availability some portion of the deliverability allocated to TPD groups D. Those projects do not yet have offtake agreements and may not reach COD, so it should not be factored as 100% taken when CAISO determines its available capacity

REV also requests that CAISO consider changing the date of the queue window opening to accommodate the most up to date information and provide sufficient time (at minimum 90 days) to stakeholders to develop Interconnection Requests in response to zonal information. In particular, given the TPD allocation timing, an April queue window opening seems to no longer make sense since developers do not want to assume a given MW level is available only for it to be consumed by the TPD allocation shortly before/after the queue window opens, or the TPP plan approval that may make more MW available. CAISO should provide a timeline of data availability in relation to the queue window opening date to illustrate what information would be available and when.

REV does not support making individual project reports available on the market participant portal, since this would provide others with proprietary information that an individual company paid to receive. REV suggests that CAISO provide a summarized version of these reports in a compiled report instead of confidential individual reports.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

As stated above, while REV appreciates CAISO’s progress and changes made to the revised straw proposal, REV continues to oppose CAISO’s proposal on the Interconnection Request Intake process, particularly for the zonal and company caps, scoring criteria, and auction approach. Despite stakeholder and CAISO attempts to provide more clarity and simplicity, the proposal is still not a workable solution and is still an overly complicated process. REV continues to suggest CAISO instead raise the baseline requirements (e.g. entry fees, deposits, withdrawal penalties) and allow projects to be studied that meet those requirements.

REV opposes the proposal to limit parent company interconnection request capacity to 25% of the total available transmission capacity for a particular cluster. CAISO has not provided a proposed definition of parent company, which is a critical component of this proposal and presents complicated verification for CAISO given the varying corporate structures and ownership agreements that exist. This cap is prior to going through any scoring criteria filters and zonal limits, so even if a developer submits more than 25% it does not guarantee that they would be studied at that level. Additionally, this arbitrary limit could be excluding viable projects that could be beneficial to ratepayers, which is important as affordable energy is an increasing concern in the state. Additionally, CAISO stated that mergers and acquisitions are not factored into this 25% cap, which provides a significant opportunity for bypassing this requirement through other means. If CAISO does move forward with this proposal, it should clarify that the proposal also applies to LSEs, publish developer specific caps based on latest available transmission capacity and allow a  minimum number of MW per company (e.g. 1000 MW) given the potentially limited zonal capacity available in the future.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

REV appreciates the progress made on identifying more reasonable scoring criteria. However, REV remains concerned about the success of a scoring process to filter for viable projects, particularly given only 30% is actually related to project viability while the remainder is policy-related (30%) and subjectively up to LSE interest (40%). Developers are left with minimal opportunity to improve their score, even if that project has a high likelihood of ultimate success.

If CAISO moves forward with the scoring criteria, REV offers the following suggestions and comments:

• LSE Interest –
  • While REV is open to LSE inputs, REV doesn’t understand how LSEs will be able to provide project specific scoring at this early stage when interconnection cost and schedule are unknown. LSE interest is already incorporated into the process through the CPUC’s Integrated Resource Planning (IRP) Process, which is based on individual LSE procurement plans, and the resulting preferred system plan gets sent to CAISO for transmission planning. The CAISO’s annual Transmission Plan is using the zonal approach to identify new transmission needs to accommodate new resources. Therefore, REV submits that LSE interests on commercial procurement activities is already built into the transmission and interconnection process at an early stage with the IRP process and does need to also be an additional screen to interconnection applications. Interconnection customers are already using the IRP portfolios and Transmission Plan to identify viable project locations. Further efforts to incorporate LSE interest could inadvertently lead to creating winners and losers which could place an unnecessary burden on LSEs to justify their actions, taking away time from making progress to expedite the interconnection process. In addition, this will reduce overall supply and therefore increase rate payer cost. The interconnection process needs to remain neutral to offtakers and be more driven by transmission availability, viability of the project developer and the project.  
  • If CAISO sees a need for LSEs to weigh in on the interconnection requests beyond the inputs they already provide through the IRP process, REV suggests that the input from LSEs should not be project specific. Instead, LSE input should be more general such as input on desired resource attributes, desired zones where LSEs have resource needs, how many MWs needed per zone, and level of developer experience, financial capability desired. If CAISO includes this category, CAISO should allow consideration of alternative offtaker interest as well, such as Corporate Buyers, as they are also significant buyers of new resources. CAISO would then use this offtaker input to rank projects.
  • The LSE review process as proposed is not transparent and provides significant opportunity for perceived discrimination and unfair treatment and could lead to unintended consequences or legal claims which could slow down the process. If LSEs are only provided intake request information, then it seems LSEs would simply be basing their decision on resource type and location only. Project and interconnection cost is a significant component in any offtake agreement and a key factor in LSE RFP processes but since these costs will be unknown at the time new interconnection requests are filed, it is unclear how LSEs would be able to provide points to specific projects. If CAISO still believes LSEs should provide inputs on projects, LSEs should objectively define the evaluation criteria (a type of “RFP-lite” process), so developers know ahead of time what LSE scoring would be based on, and it will be unavoidable to not include an independent evaluator in this process to avoid speculation of mis-dealings and balancing rankings of independent developer projects vs. projects proposed by the development arm of LSEs.   
• Non-CPUC jurisdictional LSE –
  • REV opposes non-CPUC jurisdictional LSE projects automatically moving forward to be studied and counting towards the 150% limit as discriminatory to other projects. The Interconnection process should provide equal and open access, but particularly if these projects would count against the zonal limit then this creates preferential treatment.
• Project viability -
  • REV generally supports the indicators in this category, though offers the following clarification comments.
  • REV suggests that CAISO should add another indicator including developer experience in bringing projects to commercial operation (in California or other states).
  • Engineering design – REV suggests the level of detail at the intake stage for engineering design should be related to the early project stage. Design elements such as a single line diagram and general site plan are appropriate for this stage.
  • Expansion of an existing facility – REV requests that this includes expansions of projects with a signed LGIA and NTP, not limited to projects that are already operational. A project could be progressing well towards COD, though not necessarily operational, and an expansion or additional phase of the project would be able to benefit from the earlier project similar to an operational project (e.g. land, permitting, and interconnection facilities).
  • Expansion of an existing facility where the existing Gen-Tie already has sufficient surplus capability to accommodate the additional resource – REV requests that this also include existing Gen-Tie that need minor upgrades, not necessarily zero upgrades. For example, an existing Gen-Tie facility can be upgraded to higher capacity with relatively inexpensive and quick upgrades, and should be allowed to count for this indicator.
• System Need -
  • Long Lead-Time Resources - REV continues to oppose additional points for long lead-time resources and reserving capacity in the interconnection process. CAISO’s Interconnection Process should be technology neutral and not favor or prejudice any particular technology. Prioritizing certain technologies in the interconnection process would be discriminatory. If resources use ratepayer funded upgrades, then any technology that helps meet the state’s clean energy goals should be allowed to access that capacity. California has shown that policy upgrades that may have had certain technologies in mind, but allowed all technologies to access the capacity, have benefited ratepayers and advanced clean energy goals. For example, Tehachapi transmission line was built for wind and Sunrise Power Link was built for solar, but a diverse set of resources use the transmission and it has not inhibited development of wind and solar, respectively. If transmission needs to be reserved for specific technologies, then it should be done using a merchant or subscriber transmission model such as TransWest Express or Sunzia.
• DFAX tie –
  • REV requests clarification on what would happen if there is a tie for lowest DFAX and the projects still exceed the 150%. Would only those projects that tied for lowest DFAX go to auction? REV suggests that the auction could be discarded as unnecessary if the DFAX will already be a tie breaker and further limit the number of projects. In case of a tie, CAISO should allow all the tied lowest DFAX projects to be studied as long as the flow impact on the facility does not reach 5%.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

REV requests further clarification on how projects will be prioritized as CAISO allocates projects to specific sub-zones. REV lays out a few scenarios below for CAISO to consider and clarify the process.

• Will CAISO start with the highest scored projects and work down the list until 150% limit is reached? Or as noted in section 2.5.1 is it to add these scored projects until a network upgrade is triggered? Could there be a scenario where some of these highest scored projects get removed as the initial score-based filtering was an estimate and network upgrades get triggered at less than 150% estimate based limit? There could also be a scenario where a network upgrade is not triggered based on section 2.5.1 assessment, and some of the projects that were screened out based on 150% estimate can now be added back as network upgrades did not get triggered.
• Will projects that hit a sub-zone limit be allowed to change their interconnection point within the zone if the zonal limit is not yet reached? For example, a 200 MW project may score in the top 5 for the zone, and while the sub-zone is full there is still 1000 MW available in the broader zone. It seems only fair that a high score project be allowed to change POIs (e.g. within 5 business days) to another location within that zone or potentially be given an option to downsize in order to stay withing the sub-zone limits.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

Not withstanding REV’s opposition to the interconnection intake request proposal overall, REV thinks CAISO’s proposed approach to zonal auctions is reasonable.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

REV appreciates CAISO’s clarifications on the Option B process and mostly supports this proposal with a few caveats. REV agrees with CAISO’s clarification that developers can share the cost of upgrades and that customers have the option to self-build these upgrades. REV also supports decreasing the IFS posting required to 5%. REV supports CAISO’s proposal that if a future TPP determines an ADNU that an Option B project is funding is needed to support a CPUC portfolio, then any projects funding the ADNU will be released from their obligation to fund the ADNU and be refunded its posting for the ADNU once the approved project sponsor executes its agreement.

REV disagrees with CAISO that Option B projects in zones with available capacity would be counterproductive or lead to inaccurate results. If the Option B projects are self-funding any upgrades necessary, they are not taking away from the available capacity in the zone. CAISO could consider providing limitations on Option B projects in these zones, such as if it is in a constrained sub-zone with less than X MW. Accordingly, REV continues to request that Option B be available for projects to pursue if the customer does not make it through the scoring criteria screening or auction, as only projects with a high degree of confidence and likelihood of success would pursue this option.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

REV supports CAISO’s proposal to remove both the off-peak and operational deliverability assessments. 

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

While REV supports a one-time withdrawal opportunity and continues to think there are ways to reduce the cost-shift burden, REV is ok to drop this proposal and agrees that other queue management proposals may incentivize projects to withdraw from the queue. However, REV suggests CAISO consider the one-time withdrawal opportunity for Cluster 14 projects, since there would be no risk of stranded costs for still needed network upgrades given the stage of these projects, and this could help incentivize withdrawal of Cluster 14 projects.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

REV supports CAISO’s proposal on Limited Operation Study Updates, including increasing the Limited Operation Study from 6 to 9 months before synchronization.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

REV has no comment at this time.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

REV does not support the removal of suspension rights on the LGIA. However, REV appreciates the clarification that the MMA process can provide extensions to construction milestones. REV notes that given potentially long network upgrade timelines, there needs to be reasonable accommodations for projects to progress through (or stay in) the queue while waiting for the upgrades to be completed.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

REV has no comment at this time.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

REV generally supports the time-in-queue limit and Commercial Viability Criteria. However, it is not clear based on CAISO’s proposal on how this will apply to projects that are PCDS and some capacity of the project is already online. Does CAISO want the remaining EO portion to obtain an EO PPA to be commercially viable? Absent which, the EO portion will be withdrawn? REV requests CAISO not impose the PPA requirements for the EO portion of these types of projects since a portion is already online, and therefore commercially viable. EO portions of these projects should be treated separately compared to stand-alone EO projects because they are at an advanced stage of development. In most cases, this will translate to advanced design of gen-tie and permitting required for the entire capacity of the project (including the EO project which is waiting for a PPA).

REV also requests clarification on the requirement that, if an extension is required and a PPA is in place, the customer must execute an amendment to the PPA to explicitly align its updated Commercial Operation Date with the PPA. REV notes that a PPA amendment may require CPUC or LSE Board approval and therefore create an extra regulatory burden and timely process. Therefore, REV requests that an alternative/equivalent compliance method also be accepted, such as a letter agreement between the parties that acknowledges and accepts the new date.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

REV generally supports the proposed changes to the Modification process. However, REV still encourages CAISO to reconsider options such as a list of modifications that would not require a detailed formal review by CAISO and PTOs. REV understands the short circuit concerns raised by ISO in the stakeholder calls, but believes that there are still areas in CAISO where these issues are not that pertinent. For example, any inverter change MMA request in these areas could potentially be approved without a formal review. There could be other scenarios where CAISO could consider relaxing formal review requirements.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

REV supports CAISO’s proposal that if one interconnection customer is ready to proceed with construction of a shared network upgrade then all participants in that upgrade must post the needed security for and fully fund that upgrade as applicable. By requiring posting for shared network upgrades, this will provide a more equitable process for those projects ready to proceed and not hinder their commercial viability while waiting for other customers. 

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

REV supports CAISO’s proposal that the process of amending the GIA that will include all of the MMAs should start 9 months prior to synchronization of the first block or phase of the project to the grid.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

REV supports CAISO’s proposal to add a new milestone to the GIA requiring the PTO to notify the interconnection customer and ISO when activity has begun on the network upgrade and interconnection facilities within 30 days of receiving NTP and 3^rd IFS posting. As CAISO notes, this will provide transparency as to when the upgrades are started and allow greater certainty as to when projects can come online.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

REV requests clarification on when CAISO proposes to start implementing this new deposit. Will it be imposed only on GIAs after approval of this proposal or any previous projects as well? REV also requests clarification on what this new cost will cover and how it is not covered today. In the proposal, CAISO notes it is for project management and new resource implementation processes, but how is CAISO currently covering those costs? Through other GIA costs or general administration budget?

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

REV requests clarification on this proposal and whether there are any expected technical problems or unanticipated costs with achieving the desired granularity resolution.

1. Please provide a summary of your organization’s comments on the revised straw proposal

Please see comments below.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

SDG&E is generally supportive of the reasoning behind the scoring criteria but needs additional information before it can fully assess the potential impacts.  As a threshold matter, if LSEs are going to be providing a “gatekeeper” function by scoring potential projects, that information must be kept confidential.  And public release of that information could provide insight into the portfolio needs of the particular LSE and could potentially threaten relationships with developers if there was a sense that developers were “scored” unfairly.    

In addition, SDG&E would appreciate additional information on how data will be gathered from developers, shared with LSEs and the process for reviewing and submitting scoring criteria.  For example, will the LSEs be provided information on “Project Viability” and “System Need” in advance of providing their score or are these seen as completely separate categories and “LSE Interest” is meant to be based upon separate criteria.   

The Revised Proposal mentions “30 calendar days” for LSEs to review and provide their elections, depending upon when this window opens it may be insufficient depending upon other deliverables.    

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

SDG&E does not have any comments on the removal of off-peak and operational deliverability assessments, but rather on the larger study process proposal.  

Early in the IPE process, multiple stakeholders (including SDG&E) advocated for the use of generic models for initial studies in the process. This proposal was widely supported as it moved the need for the intensive model validation process to later in the interconnection process where the list of prospective interconnections is more mature. It allowed interconnection customers to see preliminary, non-binding upgrades that would likely be required for their interconnection point before embarking on intensive parts of the study process. Such results would be able to be provided early on and give Interconnection Customers the opportunity to withdraw without going through a full blown study.  

SDG&E is disappointed that this step seems to have dropped off the IPE proposal and encourages CAISO to explore ways to incorporate generic models given the potential for streamlining the process. For example, it may be possible to have the initial “cluster study” done using generic models and the restudy done using full models that have gone through the model validation process. This step will also help distinguish the two phases so that we are not essentially duplicating effort between the two phases. 

Relatedly, SDG&E requests CAISO to provide more details around the future study process. This would include what analyses are required for each study, what differentiates the cluster study, restudy, and Interconnection facilities study. It is preferable that these three studies do not rely on projects dropping out as a major differentiating feature.  

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

SDG&E is encouraged by the direction of the IPE proceeding thus far, as it entails some reforms that may streamline current interconnection processes. Due to the anticipated value of these reforms, SDG&E encourages CAISO to consider a more expedited implementation timeframe. Take further, CAISO should consider not commencing with Cluster 15 until the queue has been adequately streamlined. Of concern are CAISO’s CVC demonstration timelines below showing that Cluster 13 and 14 projects do not need to demonstrate CVC until 2027. This issue is exacerbated by Cluster 13 and 14 projects far outpacing the remaining queue in terms of magnitude. If implemented as proposed, the study process will continue to be bogged down and the results skewed by excessive amounts of generation for the next few years until these projects are required to demonstrate CVC. SDG&E encourages CAISO to consider a more immediate timeframe so that the coming studies can provide use and more meaningful results.  

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

While this proposal is a step in the right direction, it may not be sufficient to streamline the interconnection queue. SDG&E notes that CAISO’s proposal calls for third postings for Shared Upgrades deadlines to be scheduled in the GIA. This contrasts with SDG&E’s previously stated position that the entire third posting (not just those related to shared upgrades) should be due prior to execution of the GIA. Unfortunately the current proposal may encourage the execution of speculative GIAs and further inundate the study process with speculative generation absent the appropriate process sequence.  

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

SDG&E understands this proposal to entail incorporating all MMAs into an amendment that would be scheduled for no sooner than 9 months before synch. SDG&E supports this approach, as it gives PTOs the scheduling flexibility when finalizing amendments. SDG&E already incorporates this into our procedures and finds that it has many benefits that greatly streamlines the MMA process. SDG&E encourages CAISO to proceed with the proposal as written.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

SEIA appreciates the opportunity to comment on the revised Interconnection Process Enhancements 2023 (IPE) straw proposal and thanks CAISO for extending the IPE timeline to allow for additional stakeholder review and refinement.

SEIA continues to stress the importance of providing developers with clear and robust data to ensure interconnection customers have the visibility needed to propose competitive projects and engage in CAISO markets with confidence. As described below and in more detail by AES, SEIA believes the zonal approach necessitates a common set of inputs and assumptions made available to developers that will be used to develop and evaluate interconnection requests in an equitable manner. SEIA also believes the scoring criteria requires further refinement to ensure the scoring categories and criteria are defined in a way that does not make any one category determinative, but instead elevates the most competitive projects. More specifically, SEIA believes the project viability category should include additional criteria to better differentiate between projects.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

SEIA appreciates CAISO’s proposal to consolidate interconnection area and transmission capability information into a single document. SEIA supports including transmission constraints, single line diagrams of resources, single line diagrams of POIs behind constraints, transmission capability estimates, and list of substations within each interconnection area into the document. In addition to the information CAISO proposes to provide, SEIA also recommends that CAISO include information regarding substation expansion capability. Though CAISO states that it will not be able to provide such information, SEIA urges CAISO reconsider how it could obtain this information from transmission owners. Information about how a substation expansion can help interconnection customers differentiate between POIs with constraints that could be relatively low cost to fix versus POIs that should be avoided.

Additionally, SEIA recommends that, rather than continuously updating the data as it becomes available, CAISO should establish a cut-off date for updates and assumptions for each cycle. The cut-off date could be three months before the next cluster window opens. Even if the information is not the most up-to-date or accurate, it would allow for all developers to work off same set of assumptions. In addition, to minimize guessing on what the available capacity is, the CAISO should determine the studied capacity for each zone in the document based on the cutoff date.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

See below.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

LSE Interest
SEIA recommends that CAISO assign a lower weight towards the LSE Interest factor. As SEIA has stated throughout numerous interconnection proceedings at FERC, it is nearly impossible for Independent Power Producers to enter into offtake agreements early in the interconnection process without having an idea of to the full extent of their interconnection costs, which is only available part of the way through the interconnection queue. SEIA recommends that CAISO clarify that interest from commercial offtakers be included in this factor.

SEIA recommends that CAISO provide more transparency around how LSEs will award points. Specifically, SEIA is concerned that LSEs will favor their own projects in making these awards, resulting in discrimination against independent power producers.

Non CPUC-jurisdictional LSEs

SEIA opposes automatically including non-CPUC jurisdictional LSEs in the cap calculation.

Project Viability

SEIA supports removal of the PPA criteria, as it is nearly impossible for Independent Power Producers to enter into offtake agreements early in the interconnection process without having an idea of to the full extent of their interconnection costs.

SEIA supports adding more categories to demonstrate project viability including major long lead time equipment purchasing orders and submittal of preliminary engineering design into the scoring criteria, and environmental and cultural studies. Preliminary engineering design should include:

• Long lead time equipment count 

• General arrangement with total system size and developer substation 
• Single line diagram showing metering and protection 
• Parcels/easements with site control highlighted 
• Site layout that indicates multiple gen-tie routes 

Projects that include additional site control than what is required should also receive points towards determining project viability.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

SEIA appreciates CAISO detailing the planned approach for measuring the fulfillment of the 150% capacity limit, particularly with respect to the treatment of nested constraints or sub-zones. SEIA argues, however, that the approach for determining sub-zonal capacity should be used to communicate the available transmission capacity in that sub-zone, not to limit or freeze the interconnections in the area. Recognizing that one of the goals of the zonal approach is to shift larger network upgrades from the interconnection process to the transmission planning process, SEIA suggests allowing for network upgrades triggered in a sub-zone to be eligible for the Option B process.

SEIA also proposes that CAISO include in the area reports the MW value for the 150% cap in each transmission area and sub-zone. This information will be critical for developers making decisions on project siting and sizing.

Finally, SEIA opposes the proposal to automatically study non-CPUC jurisdictional LSE preferred resources and count that capacity against the 150% cap. This proposal will introduce undue discrimination among similarly situated market participants (i.e., customers seeking to interconnect to the bulk electric system).

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

SEIA continues to oppose the use of zonal auctions, suggesting instead that the scoring criteria be sufficiently granular to differentiate between interconnection requests and reduce the likelihood of projects tying. SEIA supports the proposal to use DFAX analysis as an initial tiebreaker and argues that the 150% cap should be adjusted for any areas that require additional evaluations beyond the DFAX analysis.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

SEIA supports the proposed revisions to the Option B process, particularly the commitment to provide ADNU cost estimates and the opportunity to release Option B projects from funding obligations if the ADNU is included in a transmission plan. SEIA continues to oppose the proposal to preclude projects not studied under Option A from proceeding under the Option B process. SEIA encourages CAISO to consider additional enhancements to Option B like a subscription-based funding model or opportunities, even if limited, for projects that fail to be studied under Option A to proceed under Option B.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

SEIA supports this proposal insofar as it is necessary to meet the interconnection study timelines prescribed in FERC Order 2023.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

SEIA continues to support the one-time withdrawal proposal to further reduce the number of projects in the queue.  

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

SEIA supports AES’ position on this item.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comment.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

SEIA continues to oppose this proposal.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

SEIA opposes this proposal and supports AES’ comments.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

No comment.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

No comment.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

SEIA supports AES’ comments on this item.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

SEIA supports AES’ comments on this item.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

SEIA supports AES’ comments on this item.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

No comment.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comment.

1. Please provide a summary of your organization’s comments on the revised straw proposal

Shell Energy North America (US), L.P. (“Shell Energy”), Shell New Energies US, LLC (“Shell New Energies US) (together, “Shell”), and Savion, LLC (“Savion”) (Shell Energy, Shell New Energies US and Savion, collectively, the “Shell Companies”) offer the following comments on CAISO’s Track 2 Revised Proposal published on December 12, 2023.  The Shell Companies believe that the Revised Proposal contains modifications which will improve the interconnection process for CAISO.  The proposal increases the probability that higher quality projects that can achieve commercial operation on a more-timely basis will receive priority in the study process and ultimately commence commercial operation.   In addition, CAISO’s decision to extend the IPE comment and review process by three months is a positive development as it allows the CAISO and stakeholder to thoroughly understand and consider the various proposals and how they will impact project development. 

The Shell Companies have concerns given the lack of information related to the way Cluster 14 will be processed at this point in time.  CAISO indicates that Order 2023 will not have a significant impact on Cluster 14.  However, it also indicates that there may be new timelines and site control requirements for Cluster 14 projects.  The Shell Companies request CAISO identify Order 2023 changes which will impact both Clusters 14 and 15 and hold a stakeholder call which clearly delineates the impacts to both clusters.   Any changes and dispositive outcomes related to Cluster 14 will have large impacts on available capacity and considerations for Cluster 15 projects.  To increase transparency, CAISO should summarize the potential impacts to Cluster 15 from changes made as a result of Order 2023 compliance to Cluster 14.   In addition, as we look at Cluster 15, it is hard to determine what the local electric system can support in relation to the CAISO administered transmission line capacity being reserved for Cluster 14.  Without a better understanding of the lower voltage system, it is hard to anticipate interconnection configurations that developers can efficiency access.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

The Shell Companies view the Zonal approach as a starting point for implementing rules which will make the interconnection queue manageable and more efficient.  After the completion of each cluster, the Shell Companies recommend a process for CAISO staff and stakeholders to consider improvements in the methods and processes used to define zones from a “lessons-learned” perspective.  In addition, there could be changes to system conditions and in FERC, CAISO, and CPUC rules as well as state and local laws that require updating the zonal process. One area of concern, however, is the relative lack of information as to which locations/substations are located in a zone.  The Shell Companies appreciate any additional information published in one location prominently on the CAISO’s webpage.  Another area of concern is the amount of time interconnection customers will have to consider the zonal data and corresponding models that CAISO makes available. The Shell Companies recommend that such information should be made available at least 60 days prior to any interconnection window opening.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

CAISO Staff proposes to limit any one parent company to no more than 25% available transmission capacity per cluster.  This is a difficult issue because it requires balancing of ensuring sufficient competition for interconnection positions with limiting potentially beneficial/economic projects.  The Shell Companies suggest that criteria be developed to balance these key considerations.  For example, if developers that report to the same parent company and have projects that would cover more than 50% of the queue then the readiness score of the second-place project must be significantly higher than the next best project for that project to remain in the queue for that cluster.  In other words, apply an approach that has a little more flexibility, but The Shell Companies agree with the underlying concern CAISO is attempting to address.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

The Shell Companies support the CAISO proposal of using scoring criteria to evaluate project readiness. We understand that CAISO is trying to account for all scenarios where there is an interest in adding resources via broad categories of LSE interest, project viability and system i.e., reliability need; however, there are issues.

The Shell Companies are concerned with the LSE interest section of the proposed scoring criteria.  First, SCE’s proposed 35% limit on TPD capacity eligible to receive points is too low, we suggest a number closer to 50%.  In addition, allocating the total capacity by LSE load share ratio is problematic when weighed against non-CPUC jurisdictional LSE’s will enjoy the ability to automatically advance such that a project is a preferred resource as adopted by an LRA.  While non-CPUC jurisdictional load is a small proportion of CAISO’s system, the Shell Companies believe some “check” on this bypass is warranted, especially as a CPUC-jurisdictional LSE’s total points will depend on the relative size of its load.  Additional discussion on this facet is warranted.  

Further, the scoring criteria raises issues about the extent to which the proposal respects open access considerations and complies with Order 2023 in terms of first ready, first serve.  Under this approach, a project could have all its permits, complete site control, have an opportunity to sell the output but has not fully executed a PPA, i.e., this project is the “most ready” but gets bumped from a cluster by a project that is less ready but meets the scoring criterion vis a vis a vague expression of LSE interest.  For example, a hypothetical project with ability to provide local RA might rank quite well despite potentially lacking in another criterion. 

The Shell Companies recognize the realities of the California market and reliability needs but this proposal could perpetually bump projects that are seeking access to the system. CAISO should change the relative weightings and/or place a soft limitation on the projects that receive a significant amount of viability points based on LSE allocations or other prescribed criteria. 

In addition, the validation criteria for LSE allocations must be defined precisely for all market participants to understand; criteria applied vaguely could damage the credibility of IPE.  

Finally, the Shell Companies propose developers which have significant site control for the project and related interconnection tie line be given extra credit, such as 25 points if it has greater than 90% control of the project site and real estate for the generation tie line.  Projects lacking this would not be penalized – just not eligible for the extra credit.  Based on the experience of The Shell Companies, possessing site control is a strong indicator of project reality and readiness—comprehensive site control often leads to PPAs with LSEs and other interested counterparties.   

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

The Shell Companies support the fulfillment of 150% available and planned transmission capacity in each zone with the caveat that modest flexibility be incorporated into the analysis so that optimal solutions are not lost because that triggered a 151% output.  CAISO states that projects that submit the highest bids and are either within or the first project that crosses the 150% MW transmission zone capacity will be accepted to be studied in their entirety for that transmission zone. How would CAISO treat a scenario whereby the project that crosses the 150% cap value is an extremely large project?  For example: If the 150% cap value represented only 500 MW but the project that crosses the 150% cap value is a 1200 MW facility, it seems the study results could be distorted and produce unintended consequences.  We recommend CAISO to investigate potential solutions to this issue.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

The Shell Companies continue to support the use of the auction concept as proposed by the CAISO.  Even though we proposed an auction concept consisting of wider utilization, the CAISO’s proposal represents a fit for purpose approach to the concept of rationing scarcity which offers a reasonable alternative with bids based on at-risk auction financial security when there is a readiness tie score, and the projects would exceed the 150% capacity limit for the zone.  The Shell Companies suggest that the CAISO implement the auction for projects competing for the last increment of capacity and whose readiness score are within 10% of each other in order to head off potential scoring ties and disputes arising from claims that some of the scoring criteria are being applied too subjectively.  Competition in the auction is a preferrable method to resolve the allocation of the remaining capacity when the readiness scores for several projects are very close.

To address concerns of the auction, The Shell Companies request that following each of the first three Clusters (15 , 16 and 17), CAISO staff prepare and submit a report to stakeholders discussing the application of the scoring criteria and in the event of an auction, include a post-auction report discussing the benefits and/or issues posed by the auction process.  Such a report would provide insights on applicability of the auction concept and inform the efficacy of the readiness scoring criteria for stakeholders. 

The Shell Companies agree while the auction concept is novel, it would effectively be the ‘spout’ of a narrowing funnel; the funnel is the widest at the beginning and gets progressively narrower given the layers of CAISO’s IPE proposal.  By the time an auction may be required – ideally the highest quality and most ready projects remain.   Therefore, this design satisfies the threshold problem of CAISO’s unmanageable queue.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

 A viable Option B is important to maintain open access given the transition to the zonal model under IPE.  However, given the high degree of uncertainty in system upgrades timelines and especially costs, Option B appears a more hypothetical pathway than realistic one. 

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

The Shell Companies request the CAISO advise on the feasibility to maintain both the off-peak and operational delivery assessments by publishing an indicative estimate rather than an exact figure and indicate if such an estimate would allow CAISO to meet the Order 2023 timelines. 

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

The CAISO should retain the ability for a one-time penalty-free withdrawal opportunity under IPE. 

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

No comment. 

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

No comment. 

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

Acknowledging unforeseen issues which arise during the resource development, the removal of suspension rights should be more nuanced.  The Shell Companies suggest the CAISO allow a short deferral period, instead of complete removal of suspension rights.  For example, allowing a developer to petition the CAISO for a limited and finite deferral window, with documented reason would allow the developer to address any unforeseen circumstances.  Should the developer fail to justify their deferral or run the clock out, the customer’s LGIA would be suspended.  A window of 9 to 12 months would strike a reasonable balance between allowing developers to address unforeseen circumstances and achieving queue finality.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

The Shell Companies would like to obtain further clarification on the TPD transfer between different technologies.  How is CAISO planning on dealing with potential transfer between technologies?  Is CAISO planning on revisit and update section 6.5.4.1 on BPM for Generator Management? 

How is the CAISO addressing transfer TPD for projects with different commercial operation dates?

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

The Shell Companies support the inclusion of viability criteria but continue to object to the weight given to PPAs with LSEs or LSE allocations.  Given this preference raises open access concerns, they should be precisely defined and applied on a transparent basis.  The Shell Companies recommend that the projects with this type of preference have contracts that are substantially complete with no material conditions precedent or if developed via a utility, they have a very high score with respect to other criteria.  In addition, there should be an absolute limitation on the number of these projects so that they do not end up monopolizing the queue.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

No comment. 

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

No comment. 

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

No comment. 

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

No comment. 

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

 The Shell Companies do not oppose a fixed, reasonable implementation deposit.

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

No comment. 

1. Please provide a summary of your organization’s comments on the revised straw proposal

The Six Cities support the proposed zonal approach as set forth in the Revised Straw Proposal, contingent upon the CAISO’s retention of commitments to coordinate with non-California Public Utilities Commission (“CPUC”) local regulatory authorities (“LRAs”) and their load-serving entities (“LSEs”) regarding their procurement plans.  The Six Cities also strongly support the CAISO’s proposal to include in the interconnection cluster studies projects that are authorized by non-CPUC jurisdictional LRAs, and endorse the idea of reflecting these projects on top of, rather than within, the proposed 150% cap on amounts of capacity to be studied within transmission zones. 

With respect to certain other elements of the Revised Straw Proposal, including proposals related to the use of zonal auctions, the modifications to the “Option B” process, and the proposed limitations on transfers of transmission planning deliverability, the Six Cities have questions and requested clarifications. 

As outlined below, the Six Cities support or do not oppose other elements of the CAISO’s Revised Straw Proposal. 

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

In general, the Six Cities continue to conceptually support the zonal approach as proposed by the CAISO in the Revised Straw Proposal.  The Six Cities understand that the CAISO’s analysis and determination of zones will necessarily include all portions of the CAISO system such that the entirety of the CAISO balancing authority area (“BAA”) will be within a zone, and loads that are interconnected to or within the CAISO-controlled grid will likewise be included in a zone.  Whether there is available or planned transmission capacity within a zone to provide deliverability for new interconnecting resources is a separate question, and the Six Cities therefore strongly support the CAISO’s efforts to enhance coordination with all LRAs in the CAISO as an integral element of the zonal approach.  Indeed, the Six Cities’ support for this element of the Revised Straw Proposal is contingent upon the CAISO’s commitment, as discussed on pages 26 and 29, to develop and implement a process for inclusion of resources identified by LSEs represented by LRAs other than the CPUC in the portfolios that are assessed in the Transmission Planning Process (“TPP”).  For example, the CAISO states that it will “engage with non-CPUC jurisdictional entities regarding [their] approved resource plans to be included in the ISO’s annual transmission planning process.  And the CAISO will consider these issues within the scoring criteria for prioritization within the study process.”  (Revised Straw Proposal at 26.)  Later, the CAISO reiterates that it will “coordinate with the LRAs and non-CPUC jurisdictional entities to determine their approved resources in their individual [Integrated Resource Plans] to include in the transmission planning analysis,” and discusses its intent to obtain information for purposes of the 2024-25 TPP.  (Id. at 29.)

The Six Cities appreciate the CAISO’s commitment to include the resource plans of non-CPUC jurisdictional LRAs on behalf of their LSEs in its transmission planning studies.  Reflecting the resource procurement plans of non-CPUC jurisdictional LSEs in the transmission planning studies will enhance the accuracy of the CAISO’s assessments of needed transmission.  The Six Cities request that the CAISO provide additional information and detail regarding how its intended coordination activities will be implemented, and the Six Cities will work with the CAISO and other non-CPUC jurisdictional entities to develop these processes.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Please refer to the comments on specific subsections of Section 2 as provided below. 

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

The Six Cities strongly support the CAISO’s proposal to include in the interconnection study cluster any projects that are preferred resources in the LRA-approved resource plans of non-CPUC jurisdictional LSEs.  (See Revised Straw Proposal at 37.)  It is critical that non-CPUC LRAs retain the discretion to establish and implement policy by providing procurement direction to their LSEs, and such LRA-approved projects must have a path to advance through the interconnection process.  The CAISO proposal provides comparable treatment to non-CPUC LRAs relative to the CPUC.  

The Six Cities would support one refinement to the implementation of this element of the Revised Straw Proposal.  Specifically, it may be reasonable for the CAISO to consider reflecting non-CPUC LRA-approved projects in addition to, rather than within, the proposed 150% cap on the capacity within a zone that the CAISO will study.  As representatives for non-CPUC jurisdictional entities have previously explained, given the amount of load within the CAISO represented by these entities at this time, it appears unlikely that non-CPUC jurisdictional LSE projects would materially inflate the amount of capacity to be studied within a zone in a way that is excessive or unsustainable.  Moreover, projects that are part of such LSEs’ preferred resource portfolios—whether the LSE is developing the resource directly, is participating in its development through a joint action agency or similar arrangement, or is undertaking procurement through contractual commitments with a private developer—the project is demonstrably viable and does not pose the same development risks as other projects that may not have been selected through an LRA procurement process. 

In terms of scoring criteria, the Six Cities remain open to LSE scoring criteria as an alternative to the CAISO’s proposal to include non-CPUC projects in the interconnection studies, but it is critical that any scoring mechanism provide a path forward for non-CPUC LRA-authorized projects on at least equal footing to CPUC procurement directives.  In particular, the Six Cities continue to be concerned by requests to limit non-CPUC projects to load ratio shares of available capacity in a zone or to allocate points for purposes of weighting LSE interest on a load ratio share basis.  Such approaches may not allow a non-CPUC jurisdictional project to advance through the interconnection process, because procurement needs in a given year may not align with a load ratio share of points or transmission capacity in a single zone.  If parties are concerned that non-CPUC jurisdictional projects may occupy an excess share of capacity in the interconnection queue—which no party has shown to have been the case historically—then a preferable approach may be to monitor the implementation of scoring criteria (with the CAISO’s proposal to include non-CPUC LRA-approved projects in the interconnection studies) and identify if these projects are in fact taking up a place in the interconnection queue while failing to advance toward commercial operation and impeding the development of other projects. 

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

Apart from the comments provided in response to question no. 4 above related to whether non-CPUC jurisdictional LSE projects should be included in the 150% threshold, the Six Cities do not have any comments on this element of the CAISO’s proposal.   

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

The Six Cities have previously stated their general opposition to the use of an auction to determine which projects are eligible to be studied for interconnection.  As discussed, the Six Cities are concerned that the use of an auction process will introduce unneeded procedural complexity and raise the cost of interconnection.  The Six Cities request confirmation that with the CAISO’s proposal to include non-CPUC jurisdictional LSE projects in the interconnection process if approved pursuant to an LRA-approved procurement action, such projects will not need to participate in the auction process.

More broadly, in the event that the CAISO elects to proceed with the auction approach, the next iteration of the CAISO’s proposal would benefit from additional detail and potentially examples of how the auction process will fit with other elements of the scoring criteria and with the proposal to use distribution factors (“DFAX”) as a tie-breaker.  If DFAX will be used as a tiebreaker, would the auction only be necessary for projects that have the same score on the “indicators of readiness” table AND the same DFAX?  Is it likely that there could be multiple projects with these attributes that would each push the capacity eligible to be studied above 150% of existing and planned transmission capacity? 

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

The Six Cities generally do not oppose the proposed revisions to the Option B process, but note an apparent internal inconsistency in the Revised Straw Proposal related to the treatment of non-CPUC jurisdictional LSE projects.  Specifically, on page 51, at footnote 24, the CAISO provides an exception to its proposed rule that projects electing to interconnect in zones where there is no transmission planning deliverability available may only proceed as Option B projects, which requires projects to undertake additional financing commitments related to network upgrades.  According to footnote 24, the “exception to this are projects that meet the criteria for non-CPUC jurisdictional LSEs.”  The Six Cities strongly support this carve-out, on the basis that the CAISO controlled grid has not historically been planned with consideration for non-CPUC jurisdictional procurement.  Moreover, municipal utilities, which are governed by their own LRAs, must have the ability to obtain interconnection for projects that are located within their own municipal service territories.

However, on page 56, the CAISO appears to walk back the exception it acknowledged on page 51, explaining that it believes a carve-out from the Option B rules for non-CPUC jurisdictional LSE projects would be difficult to implement, susceptible to gaming, and generally is not needed.  The Six Cities disagree with these assertions, which are not supported, and reiterate that a carve-out from the Option B criteria is both necessary and appropriate for non-CPUC jurisdictional LSE projects.  If the CAISO believes that its coordination process related to the TPP obviates the need for such a carve out, then the Six Cities request further explanation of why the CAISO believes this to be the case.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

The Six Cities have no comments on this section of the Revised Straw Proposal at this time, beyond agreeing with the CAISO that predicating the ability to provide a one-time withdrawal opportunity on the availability of funding for still-needed network upgrades on a “green bank” or government loan or grant seems unworkable. 

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

In general, the Six Cities support the proposed limitations on the transfer of deliverability as outlined in the Revised Straw Proposal and note that the exception to the CAISO’s proposed approach for projects with an energy only power purchase agreement appears to be reasonable.  The Six Cities question whether there are other narrowly-drawn exceptions to deliverability transfers that would likewise be reasonable to include.  As a general matter, the Six Cities agree that transfers for the purpose of avoiding deliverability retention requirements should be prohibited.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

The Six Cities share the CAISO’s concerns regarding projects remaining in the interconnection queue without achieving sufficient steps toward commercial operation, and therefore they support the CAISO’s proposals regarding viability and the time-in-queue limitations. 

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

The Six Cities have no comments on this section of the Revised Straw Proposal, but observe that the CAISO’s proposal to require payment of security and costs associated with network upgrades that are shared and to execute an interconnection agreement once the first project is ready to proceed appears to be reasonable. 

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

The Six Cities have no comments on this section of the Revised Straw Proposal at this time. 

1. Please provide a summary of your organization’s comments on the revised straw proposal

SCE commends the CAISO for its ongoing collaboration with industry stakeholders to dramatically refine the interconnection queuing, transmission planning, and resource procurement processes through the 2023 IPE initiative.  The CAISO’s Revised Straw proposal reflects the incremental stakeholder feedback on prior iterations, as the proposed policy positions continue to evolve. While CAISO’s Revised Straw proposal represents positive steps toward proposed process enhancements, SCE appreciates the opportunity to continue to provide input to help shape the direction of the 2023 IPE Track 2 topics and provides its comments below on the Revised Straw proposal.  As addressed in these Comments, SCE agrees with the CAISO on several of its proposals as further updated in the Revised Straw proposal but continues to express its reasoned concerns with several with which SCE disagrees and opposes.  SCE urges the CAISO to consider the following Comments and positions for the CAISO’s adoption in a final proposal.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

SCE continues to support the proposal to provide data to stakeholders to enable the zonal approach to interconnection. The data, including CPUC busbar mapping of resources in portfolios, CAISO’s transmission capability estimates for the CPUC’s resource planning process, CAISO’s annual Transmission Plan Deliverability allocation report, and heat maps will be critical and helpful with the intent to steer resource developers to locations where there is current or planned transmission capacity.  Such explicit signals regarding available capacity before the submittal of interconnection requests should make for a more effective and efficient interconnection request intake process.  

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

SCE supports the CAISO’s refinements to the information provided to stakeholders to implement the zonal approach and the process of selecting projects that can proceed to the study process with each Option A zone.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

SCE supports the proposed updated set of objective indicators for scoring criteria to address project readiness, including an LSE point allocation mechanism to incorporate LSE interest earlier in the process. The proposed narrowing of the scoring criteria from the initial six categories to three broad categories that include LSE Interest (40%), revised Project Viability (30%) and System Need (30%) categories should also help to simplify the process of evaluating project readiness.  SCE agrees with the CAISO’s removal of “Contracting Status” as a path to receive LSE interest points, especially excluding an executed term sheet or PPA because such information does not necessarily provide the most reliable and useful indication of project readiness at such an early juncture in the overall process of a project’s development.  SCE also supports using each project’s Distribution Factor (DFAX) as a tiebreaker (when the selection process is near the 150% threshold and two or more projects are tied) within the scoring system prior to proceeding with a sealed-bid market-clearing auction if there remains a tie or a negligible DFAX difference after applying the DFAX assessment. 

SCE continues to oppose the CAISO’s proposal to automatically include any project that a non-CPUC jurisdictional LSE demonstrates is a preferred resource in its resource plan that has been approved by its Local Regulatory Authority” (Track 2 Revised Straw Proposal, p. 37, & 39). This approach provides substantial preferential treatment to projects that meet these criteria by giving them different interconnection rules and in effect allowing them to bypass CAISO’s interconnection application study selection process. Furthermore, with no load size limit on the non-CPUC jurisdictional LSEs that are eligible to receive this exemption or other restrictions that would limit non-CPUC jurisdictional LSEs combining qualified projects under this framework, there is a risk that this automatic inclusion will push projects above the 150% threshold that would otherwise have qualified to be studied, but for this preferential treatment. The selection process as outlined by the CAISO would allow these LSE projects approved by their LSAs to leapfrog the CAISO scoring assessment and enter directly into the interconnection study process. SCE contends that these LSEs can compete fairly in the proposed CAISO scoring mechanism process and should be required to be ranked under the same scoring criteria method as all other projects. If the CAISO decides to retain this automatic inclusion for non-CPUC jurisdictional LSEs, at a minimum, CAISO should limit these participating LSEs based on load share and place a cap (as a % of MW available in each zone) on the projects that can be automatically studied. 

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

SCE believes establishing the study group for a particular queue cluster at 150% of available and planned transmission capacity strikes a fair balance of studying a sufficient volume of resources to fulfill the transmission system and policy needs while simultaneously not studying such a high volume of resources such that the existing issue of not studying a meaningful level, in terms of MW, remains unresolved.  

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

SCE supports CAISO’s latest proposal to embed within the scoring criteria system each project’s distribution factor (DFAX) as a primary tiebreaker when the project selection process is near the 150% threshold and two or more projects are tied. Relying on each project’s DFAX as a tiebreaker should help to further achieve the goal of incentivizing developers to site their projects at locations where interconnection will not trigger additional network upgrades. Only if the project ties still exist after the projects’ DFAX have been considered, should the zonal auctions be effectuated. Given the insertion of the projects’ DFAX as the initial screener in the overall scoring process, SCE also supports deferring the requirement to submit auction bids until after the viability scoring process has been completed. 

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

SCE supports the CAISO’s proposed incremental modifications to the merchant-financing “Option B” process. SCE agrees with the proposed IFS posting requirements, beyond the previously proposed modifications to the Option B process, SCE also supports the proposal to include allowing only projects seeking to interconnect in areas that have no available or planned TPD capacity to select Option B and not permitting Option B to be available to projects that were not selected to be studied in transmission zones that have available or planned transmission capacity.  SCE agrees that the minimum posting requirement of $500,000 and maximum requirement of $5M is a reasonable range for a project’s initial ADNU financial commitment.  SCE also agrees it would be appropriate to relieve ICs of their ADNU funding requirement and refund their posting if TPP determines an Option B ADNU is required to support the CPUC portfolio. 

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

SCE acknowledges that FERC Order 2023 has significantly compressed the timeline for completion of the cluster studies. Given the truncated cluster studies timeline, coupled with the reduced value of continuing to perform interconnection studies beyond FERC’s pro forma, SCE supports the CAISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the CAISO to meet Order 2023’s prescribed timelines. 

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

SCE appreciates the CAISO’s updated position that “the concerns raised by the Participating Transmission Owners (“PTOs”) are genuine cause for reconsideration”1 of the CAISO’s prior contemplation concerning a one-time withdrawal opportunity. SCE commends the CAISO for its validation regarding the unreasonable and unfair imposition of financial risks to the PTOs that would result from the one-time withdrawal opportunity proposal, especially given the interconnection customers’ insufficient Interconnection Financial Security (“IFS”) postings to enable the PTOs to assume total short-term financing and funding responsibility for Precursor Network Upgrades (“PNUs”). As a path forward, SCE will consider supporting the CAISO seeking additional sources of funding for network upgrade costs associated with withdrawals, either through a “green bank” or government grant or loan program contingent on, but not limited to, the following conditions: 1) that in combination with the IC(s) IFS forfeiture amount(s) and the balance financed by a third-party entity (i.e., green bank), will not place SCE as a PTO in a position to finance any portion of the still needed Network Upgrades, 2) on the assumption that SCE will need to refund both parties (IC(s) and the third-party) for the use of these funds, it will be in accordance with the existing tariff reimbursement requirements and pursuant to Articles 11.4.1.1, 11.4.1.2 & 11.4.1.3 of the GIA, 3) if these transactions are reclassified as a Contribution in Aid of Construction (“CIAC”) since there are intermediaries involved in the transfer of funds to be treated as a “loan” to the PTO or if there is a change in tax law within ten (10) years from placing the applicable Network Upgrades in-service, the IC(s) exercising this one-time withdrawal opportunity shall remain contractually and financially responsible to indemnify SCE/PTOs of any tax or subsequent tax liability resulting from the use of these funds. In the event the CAISO is unable to secure third-party funding alternative(s) with terms and conditions approved by SCE/PTOs, it is SCE’s position that the CAISO remove the one-time withdrawal opportunity option from the 2023 IPE initiative.  As a substitute mechanism to remove projects that are not demonstrating progress towards commercial operation in a timely manner, SCE supports the CAISO’s contract and queue management regarding project viability and time-in-queue, with the enforcement of GIA execution and commercial viability demonstration requirements.  

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

SCE reiterates its support for the CAISO’s proposal to increase time to submit a Limited Operation Study (“LOS”) request from 5 months to 9 months prior to the approved initial synchronization date.  The proposed time extension should allow additional time for processing the LOS request after receipt of the LOS deposit, drafting and issuing the study plan, an estimated forty-five (45) calendar days to complete the LOS once the study plan is approved, and providing ICs additional time to evaluate the results and make timely decisions.  SCE also agrees with the CAISO’s proposed update to its Generator Management Business Practice Manual (“BPM”) to clarify that: 1) a Material Modification Assessment (“MMA”) request submitted simultaneously with a LOS must be deemed complete and valid prior to the start of the LOS and 2) if an MMA is submitted after the completion of the LOS and impacts the LOS results, the IC may be required to submit a new LOS request.  

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

SCE reiterates its support of the CAISO’s proposal to revise Attachment 7 (SGIA) to be consistent with Appendix H (LGIA) to align the interconnection requirements for all asynchronous resources, irrespective of size. 

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

SCE reiterates its support for the CAISO’s proposal to remove suspension rights for all projects that have not executed a GIA and, as applicable, its companion agreement for an Affected PTO, such as an Upgrade Facilities Agreement (“UFA”) by the effective date of this proposal if adopted by FERC.  Under a “first-ready, first-served” model, there should be no reason for a developer to suspend its project unless it is a “not-ready” project. Under this paradigm, a developer upon receiving its final interconnection study should be ready to proceed towards commercial operation by executing a GIA, and, as applicable, its companion UFA, and post its IFS, irrespective of whether the project is allocated TP Deliverability (FCDS or PCDS) or designated as Energy-Only after two TPD allocation study cycles. 

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

SCE appreciates and supports the CAISO’s revised proposal that more properly factors the resource procurement perspective, as the CAISO considers withdrawing projects from the queue upon the approval of a corresponding Transmission Plan Deliverability (“TPD”) transfer. This balanced approach regarding enhancements to the interconnection process should result in LSEs having the opportunity to execute contracts from a pool of Energy-Only (“EO”) projects to achieve RPS and clean energy goals. SCE supports CAISO’s incremental proposal to forego such withdrawal of the transferring project if the transferring project provides an EO PPA at the time of such transfer request and with the clarification that TPD transfers will not be permitted to circumvent deliverability retention requirements. 

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

SCE reiterates its support regarding the CAISO proposal to require all projects in the queue to demonstrate commercial viability if they remain in queue beyond seven years, regardless of deliverability status. This approach is consistent with FERC Order 2023’s requirement to impose an unavoidable time-in-queue requirement for all projects without an executed GIA and/or UFA to execute an interconnection agreement, provide the Notice to Proceed, and the 3rd IFS posting in accordance with the terms and conditions of the GIA and/or UFA. SCE supports a project’s interconnection request being withdrawn or placed in breach of the interconnection agreement if a project is unable to meet the CVC by an unavoidable time-in-queue and annually.  SCE believes CAISO’s diligent enforcement of both its revamped commercial viability criteria and a project’s time-in-queue proposals, if adopted by FERC, can have a significant and positive impact in effectively managing/clearing the interconnection queue such that only viable projects ready to proceed towards commercial operation remain in the queue. As a result, future interconnection studies will be performed at more reasonable and meaningful levels.  

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

SCE supports the CAISO’s incremental proposal to update the BPM for Generator Management (Section 6.2.4) that projects must have started construction and be within nine (9) months of achieving their then-current approved initial synchronization or commercial operation dates to submit a construction sequencing delay request to the CAISO with a copy of the request to the PTO, Interconnecting PTO, and the Affected PTO, as applicable.  

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

Having addressed SCE’s prior concerns with this proposal, SCE supports CAISO’s revisions in its Revised Straw proposal with the understanding that (1) once the developer for the first project pursuant to the terms and conditions in its GIA issues the Notice to Proceed (“NTP”) with engineering, design, procurement, and construction of the shared network upgrade, (2) has made project payments toward the shared network upgrade, and (3) has made its 3rd IFS posting which covers the balance of its shared network upgrade cost, then the remaining developers whose projects were allocated a pro-rata share of the same shared network upgrade shall upon notification by the CAISO in coordination with the PTO and within the proposed prescribed timelines: 

1. Make the 3rd IFS posting for its allocated share of the same shared network upgrade irrespective if the project is parked. 

2. Execute a GIA if not parked or a Letter Agreement (“LA”) if parked in order to remit project payments to the PTO for its allocated share of the same network upgrade since SCE/PTOs will not upfront finance any portion of the shared network upgrade unless required to do so by tariff. 

Failure to post, execute a LA or GIA, and make payments toward the shared network upgrade shall cause any of the remaining project(s) to be withdrawn or have their respective agreement(s) terminated.  

SCE will commence engineering and design of the shared network upgrade within thirty (30) BDs on the condition that the first project pursuant to its executed GIA that remains in good standing has: 

1. Issued the NTP 

2. Made the 3rd IFS posting for the shared network upgrade 

3. Made project payments toward the shared network upgrade 

4. Completed all predecessor milestone(s) necessary for SCE to commence the upgrade  

SCE will commence procurement and construction of the shared network upgrade once all the remaining projects allocated a pro-rata share of the same network upgrade has executed a LA or GIA, made its 3rd IFS posting, and remitted its first project payment toward the same shared network upgrade.  

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

SCE reiterates its opposition to the CAISO’s proposal to amend a GIA and/or UFA that will include all approved modification changes over a span of year(s) to a project no earlier than nine (9) months prior to the approved synchronization date of the first block or phase of the project to the grid for the following reasons:  

1. The CAISO’s proposal does not effectively solve the concerns relative to efficiently addressing project scope changes as controlling through MMA submissions.  First, no practical efficiencies are gained by simply shifting attention towards review and approval of an MMA(s) because the resource efforts required to address the full terms and conditions affected by an MMA change must still be made whether it’s accomplished through approval of an MMA or a GIA (and/or UFA) amendment.  More importantly, the controlling document must be the GIA and/or UFA, as amended, because it addresses the full range of terms and conditions that also must be modified as affected by approved MMA changes. That cannot be done piece meal through individual MMA approval because they typically address only specific changes in part to a project.  Thus, an MMA cannot be the enforceable contract binding the IC and PTO relative to the entirety of the project. Rather, the GIA and/or UFA, as amended, must control with incorporation of all the approved project specific modifications over time that impact a project’s scope of work, costs, project payments, milestones, and overall schedule.    

2. It is impractical to wait years to amend the GIA and/or UFA to incorporate all approved MMAs.  The years’ delay would create confusion relative to the scope of work, schedule, and the project’s overall budget. 

1. SCE’s execution teams, which consist of up to twenty-five (25) personnel plus the Project Lead rely solely on the GIA and/or UFA, as the controlling document, not potentially multiple MMA reports over time capturing specific approved modifications plus 1, the existing GIA and/or UFA. 

1. This means that in addition to the existing GIA/UFA each subject matter expert will also need, copies of all approved MMA reports to keep track of any changes made to the project potentially over a span of years that impact their respective areas of responsibility.  

2. Under CAISO’s proposal, two, three, or more years can pass before the GIA and /or UFA are amended.  During this time, personnel changes are likely to occur that may result in the project’s history being lost or worse, confusion because of key personnel changes such as the Project Lead, Contract Negotiator, and/or Contract Administrator.  

3. There have been cases where subsequent modification requests have negated prior approved project modifications, which has caused tracking difficulties and has led to confusion during project implementation.  

3. Most approved modification requests trigger changes to scope, cost, and schedule or a combination thereof, which would require an immediate amendment to the GIA and/or UFA.  

4. SCE as a Participating TO opposes being required to finance cost associated with incremental scope changes triggered by a developer’s request to make modification(s) to its project.  Accordingly, SCE would oppose any delay in amending the GIA and/or UFA to collect additional project payments and financial security (ITCC and IFS) not included in an MMA/Facilities Reassessment Report.   

5. COD MMA extensions also trigger significant changes to the GIA and/or UFA that must be captured immediately in an amendment, such as deferment of project payments, updated costs, changes to financial security amounts (ITCC and IFS) and their due dates, and schedule (i.e., recalibration of milestone due dates based on the revised COD).  

6. Finally, CAISO should consider requiring the developer community to submit, when possible, multiple changes to a project in a single modification request, which would potentially limit the number of MMA submittals over a span of years by a developer and reduce the number of times a GIA and/or UFA would need to be amended.  

The CAISO is correct that certain MMA reports include changes to scope, cost, and schedule, but it’s extremely limited and certainly does not include the magnitude of changes proposed by the CAISO. These changes can be substantial including but not limited to (1) updated scope changes, (2) a revised payment schedule and cost table, (3) updated provisions to financial security (IFS & ITCC) and their due dates, and (4) a revised milestone table in each MMA report, as applicable. Addressing such changes as proposed will require significant time to negotiate and obtain consent from the IC and a CAISO Negotiator before they are memorialized in the MMA report. Not only will an MMA report begin to take the form of a Letter Agreement, but the revised deposit and timelines proposed under Section 3.7 – Project Modification Request Policy Updates will no longer be sufficient or acceptable.  

If would be more effective and prudent from an efficiency perspective to negotiate terms and conditions resulting from very specific approved MMA changes in an amendment to a GIA/UFA in lieu of multiple MMA reports that each will take the form of a Letter Agreement and only represent a piece of the overall project’s puzzle.   

Although SCE appreciates the CAISO’s clarification that the MMA Report will be expanded to include all of the information required to amend the GIA including any impact to scope, schedule, budget and payments, updates will still be needed to the MMA Report which will offset any potential work efficiency benefits from consolidating the timing of GIA and/or UFA amendments until 9 months prior to synchronization.  

As stated above, given the controlling document from a project implementation/execution perspective is the LGIA and/or UFA, which address the project’s scope of work, costs, project payments, milestones, and overall schedule, MMA updates should continue to be made directly to the GIA from a work efficiency and project control document standpoint.  

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

SCE reiterates its support for the CAISO’s proposal for the GIA and/or UFA to include specific dates for the developer to provide the NTP and the 3rd IFS posting. SCE already provides specific milestones and due dates in its GIA/UFA Appendix B, Milestone table regarding NTP for design, engineering, procurement, and construction of PTO Interconnection Facilities, Network Upgrades, and Distribution Upgrades, if applicable, in accordance with Article 5.5.2 of the GIA and/or UFA. 

However, it is SCE’s position that the commencement of activities associated with PTO Interconnection Facilities, Network Upgrades, and Distribution Upgrades, if applicable, are not only dependent on the PTO receiving the NTP and the 3rd IFS posting, but also predicated upon the IC ensuring: 

1. Agreement(s) (Letter Agreement, GIA, or both GIA/UFA) remain in good standing. 

2. Project payments are received by their respective due dates.   

3. All predecessor milestones are completed by the specific due dates reflected in Appendix B, Milestones of the agreement.  

If any of these conditions are not met, commencement of activities within thirty (30) BDs of receiving the NTP and the 3rd IFS posting will be impacted. 

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

SCE has no comment currently. 

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

SCE is extremely supportive of ensuring reliable IBR operation, adequate event analysis, and model validation. SCE commends CAISO for continuing to seek improvements in meeting these objectives, though does not agree that the existing 30 sample/second PMU data has not been helpful in any event analysis. SCE has found this data useful for activities such as determining the fault voltage at the metering location, whether a unit tripped or went into momentary cessation, or how the unit responded to a fault (e.g., voltage support or primary frequency response). However, SCE agrees with the need for recording more information, such as using a combination of Digital Fault Recorder (DFR) and PMU devices. The DFR provides event-triggered high speed three-phase data that can show additional detail over PMU measurements. 

SCE has included compliance with IEEE 2800-2022 in their Interconnection Handbook as of 2023, which includes a requirement for ≥60 times/second continuous output Dynamic Disturbance Recordings (and a minimum input sampling of 960 samples/second) and ≥128 samples/cycle triggered Digital Fault Recordings event data. According to the 2018 NERC IBR Performance Guideline, Dynamic Disturbance Recordings are typically provided from a device with PMU capability. SCE supports CAISO including requirements for increased high speed data recording capabilities to meet IEEE 2800. 

1. Please provide a summary of your organization’s comments on the revised straw proposal

Terra-Gen, LLC (Terra-Gen) provides the following summary of the key elements of its comments on the CAISO’s IPE 2023 Revised Straw Proposal:

• Terra-Gen continues to oppose the proposed 25% developer cap, stressing the lack of justification and analysis supporting CAISO’s proposal.
• Terra-Gen opposes CAISO’s proposed LSE interest scoring criteria element. Terra-Gen notes concerns with CAISO’s proposal to apply significant weighting of LSE preference in the early stages of project development. Terra-Gen suggests that if CAISO continues to propose this LSE interest scoring element, then it should reduce the weighting to a maximum of no more than 20% of the overall scoring elements and incorporate provisions for interest from non-LSE off-takers.
  • Terra-Gen also expresses concern that this aspect of the proposal undermines anti-competitive protections and open-access principles. In response to these concerns, Terra-Gen requests CAISO disallow LSEs from self-selecting LSE self-build projects as part of the LSE interest scoring element. LSEs should not be allowed to assign points to any LSE-sponsored projects or assign points to any LSE-affiliated entities to safeguard against the potential for anti-competitive or open access concerns.
• Terra-Gen continues to question the proposed 150% limit on zonal available transmission capability and reiterates its recommendation that CAISO should raise the proposed zonal cap to at least a minimum of 200% to account for zonal approximations, interactive effects, sub-zones with layered constraints, and other uncertainties.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

Opposing 25% Developer Cap:

Terra-Gen continues to oppose the proposed 25% developer cap, stressing the lack of justification and analysis supporting the proposal. Terra-Gen agrees with stakeholders that have previously expressed a need for additional information on the objective and underlying analysis supporting the need for this aspect of CAISO’s proposal. Terra-Gen contends that this aspect lacks sufficient evidence to justify such a developer cap on Interconnection Requests (IRs). Terra-Gen and other developers have argued the 25% figure is arbitrary and CAISO has not addressed this concern. Further, CAISO has been unwilling or unable to estimate the MW size of the cap that would have been set for previous cycles during prior discussions when requested. This emphasizes the necessity for more comprehensive supporting analysis to support this aspect of the proposal. Simply citing the frequency of IR submissions by certain developers is insufficient to establish comparably lower viability or higher withdrawal likelihood compared to smaller developers. CAISO should provide more robust data that gives further insights into differentiating entities submitting speculative projects versus simply having a larger portfolio under development to support its proposal. If CAISO cannot provide evidence this aspect is justified it should remove the proposed 25% developer cap from its proposal.

Terra-Gen also notes that FERC’s Order 2023 site control requirements for 90% site control demonstration will likely reduce the likelihood of most speculative IR submittals and make the 25% developer cap unnecessary. Terra-Gen agrees with stakeholder suggestions that CAISO should consider alternatives to the 25% developer cap, such as using developer experience with project technologies and size as a scoring criteria rubric element instead. Terra-Gen also agrees with other stakeholder recommendations that CAISO should provide clarification on its intended approach for identifying "parent companies," joint ventures, and other ownership structures if it continues to pursue the 25% developer cap concept.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

Opposing Proposed LSE Interest Scoring Element and Reiterating Related Concerns:

Terra-Gen generally opposes CAISO’s LSE interest scoring element. Terra-Gen is concerned with CAISO’s proposal to apply significant weighting of LSE preference in the early stages of project development. Terra-Gen suggests that if CAISO continues to propose this LSE interest scoring element, then it should reduce the weighting to no more than 20% of the overall scoring elements and incorporate provisions for interest from non-LSE off-takers. Terra-Gen also requests CAISO ensure that any LSE interest scoring element be fully transparent and that all LSE project scoring assignments be made public.

Terra-Gen believes that LSEs should not be allowed to self-select LSE self-build projects. i.e., CAISO should not allow LSEs to assign points to any LSE self-sponsored projects, or to assign points to any affiliated entities such as a developer-company arm that is owned or financed by the same parent company as the LSE. Allowing such options under this proposal will result in anti-competitive concerns and contravene open-access principles. In the past, developers including Terra-Gen have experienced targeted LSE opposition to certain projects advancing development in some LSE territories. CAISO’s proposed LSE interest scoring element could easily be used to inappropriately disadvantage third-party developers from advancing projects to the benefit of LSE-sponsored projects. Since this LSE interest scoring element presents a legitimate open-access and competitiveness concern regarding potential bias toward LSE self-builds, Terra-Gen recommends CAISO carefully consider these concerns and seek to provide adequate protections against them materializing, either intentionally or unintentionally. In addition to the above suggested restrictions against LSE self-selection of LSE self-build or affiliate projects, Terra-Gen also believes that limiting the overall scoring weighting of this LSE interest element to a maximum of 20% is an appropriate protection that should be included in CAISO’s subsequent proposals.

Terra-Gen reiterates its reasoning for opposition to the LSE interest scoring element. This aspect of the overall scoring criteria may not rely on appropriately robust project cost information to allow for effective evaluation and application of LSE interest scoring points to be allocated among different projects. Without adequate knowledge of related upgrade costs and project timelines the value of any LSE interest scoring element will be undermined. While the CAISO’s proposal explains that confidential developer project information would be shared with LSEs to better effectuate the proposed LSE interest scoring element, it is not clear that the CAISO will have developed adequate upgrade cost estimates available at this phase of the process to appropriately inform LSEs or differentiate projects. Additionally, Terra-Gen suggests that LSE interest is already reflected in CAISO transmission planning and CPUC resource portfolios and through LSE’s RFP processes that assign weighting factors to project locations. Assigning a significant weighting to LSE interest in the scoring criteria will give LSE interest an excessive impact in the overall process. For these reasons, Terra-Gen believes the CAISO’s currently proposed LSE interest scoring criteria places an overemphasis on LSE interest in the interconnection process.

Concerns Regarding Preferential Treatment for Non-CPUC Jurisdictional LSE Projects:

Terra-Gen also opposes CAISO’s proposal to allow projects included in approved non-CPUC-jurisdictional LSE resource plans to bypass the readiness scoring rubric, thus diminishing IR study capacity available for potentially more prepared projects. Terra-Gen’s concerns stem from the potential discriminatory nature of this treatment and its potential to limit capacity for other projects to be studied. Terra-Gen recommends a modification to reduce these concerns, CAISO should consider exempting non-CPUC jurisdictional LSE projects from counting against the proposed 150% zonal study limit.

Feedback Regarding Other Scoring Criteria Elements:

Terra-Gen notes that demonstration of “business partnerships for future supply of major equipment prior to COD” does not necessarily provide a useful indication regarding the viability of a particular project.  Similarly, having an engineering design plan in place this early in the process does not necessarily differentiate the viability of projects and likely increases the cost of the IR development.

Terra-Gen recommends that resources in CPUC resource portfolios that do not require new transmission should also receive 60 points in addition to the item for “Long-lead-time resources in the CPUC and TPP portfolio that have approved transmission projects to accommodate” being awarded 60 points.                                                                                                      

CAISO’s latest scoring criteria proposal explained that it will use each project’s distribution factor (DFAX) as a tiebreaker when the scoring criteria process exceeds the 150% threshold, and two or more projects are tied, and less capacity is needed to reach 150% than the sum of the tied project’s capacity. Terra-Gen expresses concerns that the concept of using DFAX as tiebreaker is more complex than it appears because projects may be behind multiple and different constraints, with different levels of DFAX impacts on each constraint. Therefore, Terra-Gen recommends that DFAX should not be used as a tiebreaker for project scoring. Terra-Gen believes that DFAX should instead be considered in the Transmission Plan Deliverability (TPD) allocation process where CAISO could prioritize the highest Resource Adequacy (RA) value based on the DFAX impact to available transmission capacity.

Terra-Gen also notes it continues to oppose any auction-based mechanism for tiebreaking as well, as noted below in response to Question 6.                   

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

Advocating for Increased Zonal Study Limit Threshold Minimum of 200%:

Terra-Gen continues to question the application of the CAISO proposed 150% limit on zonal available transmission capability. Terra-Gen agrees with stakeholders that have previously suggested the CAISO’s proposal is arbitrary and the 150% cap has not been supported with data and analysis. In this section of its proposal CAISO has noted the zonal limit concept is complicated by sub-zones with nested constraints, illustrating that a 150% cap may be overly limiting the number of projects eligible for study, especially in more complex nested sub-zones with overlapping or layered constraints. Terra-Gen reiterates its recommendation that CAISO should raise the proposed zonal cap to at least a minimum of 200% per zone to account for zonal approximations, interactive effects, sub-zones with layered constraints, and other uncertainties. The current estimate for available transmission capacity lacks precision in accounting for varied impacts from different constraints impacted by multiple Points of Interconnection (POIs). The inherent risk in selecting economically unsound projects at early stages underscores the importance of maintaining a robust project volume, fostering competition, and allowing for self-correction in the scoring criteria methodology and zonal study limit. 

Regular Review of Zonal Study Limit Threshold:

Terra-Gen believes the zonal limit should function as a baseline guidepost rather than an inflexible barrier and suggests CAISO should include a regular review of the zonal limit to be performed on a regular basis. A regular review of any zonal study limit is essential to prevent undue restrictions on IR studies.

Clarification on Updates to Fulfillment of 150% Zonal Study Limit Threshold:

CAISO has also included updates for this element noting that it plans to add projects to various substations within each zone until network upgrades are triggered in the study process for each zone. In zones/interconnection areas/sub-zones with nested constraints, the sub-zone with the constraint will be filled up until it triggers an upgrade, and at that point the sub-zone will be “frozen,” limiting any additional interconnections in that area. Other projects seeking to interconnect in that area will be eligible to interconnect in the broader zone until 150% of the capacity is reached. Terra-Gen requests clarification on this update to the proposal and CAISO should explain if projects located in “frozen” sub zones would be eligible to adjust its POI to other available locations within the zone or be excluded from study. Terra-Gen recommends that CAISO consider allowing high-scoring projects to be studied with adjustment to respective selected POIs if alternative POI selections are considered reasonable project modification options.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

Opposing Auction Mechanisms as Tiebreaker:

Terra-Gen reiterates it continues to oppose any auction as a tiebreaker mechanism zonal transmission availability cap scoring criteria ties. Terra-Gen recognizes CAISO’s attempt to improve the proposed auction mechanism by requiring only projects who must participate to submit bids and making bid amounts refundable. However, even with the updates CAISO has included, this approach still appears overly complex and burdensome for developers and CAISO staff to facilitate. Terra-Gen agrees with stakeholder suggestions recommending that CAISO allow all projects with tied scoring criteria to be studied regardless of surpassing the proposed zonal cap.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

1. Please provide a summary of your organization’s comments on the revised straw proposal

Vistra does not support a scoring method that unfairly allocates points for screening based on “policy votes”, which both the Load Serving Entity interest and the system need criteria are contributing to in the scoring proposal, resulting in preferencing utility developers’ projects. The CAISO’s proposal is to afford 70% of the possible points to “policy votes” and not project viability criteria for projects in CPUC areas and effectively 100% to non-CPUC areas.  Vistra does not support the proposal that unequivocally guarantees non-utility developer projects in a non-CPUC jurisdictional plan by proposing that these automatically be studied. Vistra also does not support the proposal for allocating 70% of possible scoring points to “policy votes” as it unduly preferences utility developers over non-utility developers. This undermines open access to the interconnection process and transmission system at the detriment of consumers.

Of the three categories of non-financial readiness indicators CAISO proposes, two of the three allocate points for criteria unrelated to an Interconnection Request’s unique commercial readiness and instead allocates points based on incumbent utility or regulatory agencies preferences. Vistra finds both the Load Serving Entity (LSE) interest section and the System Need section represent “policy votes” instead of unique commercial readiness factor of the Interconnection Request (IR). The Load Serving Entity (LSE) interest section affords 100% of possible points to non-California Public Utility Commission (non-CPUC) LSEs through the automatic advancement and 40% of possible points to CPUC LSEs based on LSE allocating points – a CAISO proposed policy decision to prioritize utility projects. The System Need category allocates up to 30 points for projects based on policy decisions that projects should be prioritized in local capacity areas or that the project has long lead-time for construction based on the CPUC portfolios – proposed policy decisions unrelated to project’s unique commercial readiness. Combined both of these “policy” decisions are yet untested at Federal Energy Regulatory Commission (FERC). The CAISO will need to support that allocating up to 70% of possible points for CPUC LSE and 100% for non-CPUC LSE based on “policy votes” as opposed to objective commercial readiness criteria is not counter to FERC open access requirements or the recent FERC Order 2023 decision on a commercial readiness framework.

In the policy process, Vistra indicated that we could live with “policy votes” included in the scoring metric for screening interconnection requests, even though this appears to stray from open access principles by allowing for inequitable treatment that discriminates against non-utility developers. However, we maintain that this concession would be based on the percent of possible points allocated being a minority share so that there is a limit to the discrimination against non-utility developers such that it does not result in undue discrimination. CAISO’s proposed allocation of possible points exceeds the limits needed to ensure undue discrimination does not occur. Vistra requests the CAISO take a step back and consider whether it wants to arrive to a consensus with stakeholders. If CAISO is interested in striving towards consensus, CAISO will need to provide a proposal that better balances the scale so that it does not unduly discriminate against non-utility developers.

Vistra finds the revised straw proposal on its face discriminatory as it will favor entrenched market participants (utility developers) and specific projects that have state or local preference. Certainly, states, local entities, and joint action agencies can have preferences when looking at potential future resource portfolios. However, those preferences cannot result in restricting open access to the transmission system through limiting the requests that can be studied. CAISO’s proposal contemplates that the scoring metric will automatically advance projects in non-CPUC area’s utility plan and allocate up to 70% of all possible points to project in non-CPUC area based on entrenched market participants’ preferences.

CAISO’s revised straw proposal will provide preferential access to the interconnection queue and the transmission system to utility projects over non-utility projects. The CAISO has failed to provide any assurance that independent power producers and non-utility developers will have equal access to the transmission system through access to the interconnection queue compared to utility developers. We fear this proposal is contrary to FERC open access rules and contrary to the IPE 2023 principle that the proposal must “continue to ensure open access and avoid unduly discriminatory or preferential treatment”.[1] Instead of waiting for the FERC process and force FERC to struggle with the fundamental open access issue, Vistra requests the CAISO revise its proposal to provide assurance that IPP and non-utility developers will have equal or near equal access to the interconnection process under any scoring used for screening projects. Vistra hopes to work with CAISO and other stakeholders to reach a compromise that appropriately balances the desire to limit projects studied to viable projects against the need to ensure utility and non-utility developers are participating on an equal playing field.

[1] CAISO's Revised Straw Proposal at Page 11.

2. Provide your organization’s comments on data accessibility to inform and support the zonal approach

Vistra requests the CAISO provide the discussed data as soon as the additional information is available. We believe increased transparency into the zonal approach through publishing the points of interconnection mapped to each zone and the aggregate zonal transmission capacity values are essential to understanding the CAISO’s zonal approach proposal in its revised straw proposal. We request the CAISO provide the mapping and estimated aggregate transmission capacity by zone in the next iteration of the paper. This will significantly aid our ability to provide meaningful feedback.

Vistra also believes it is essential that all of the data is accessible to Interconnection Customers including the above mentioned information as well as the FERC Order 2023 required heat maps is held by Interconnection Customers for at least six months prior to having to make decisions on its Cluster 15 projects. There is uncertainty on what the Cluster 15 dates associated with withdrawing projects under Section 17.1(c) should be given this efforts’ delay. See below requests to include in the proposal the dates that the important Cluster 15 unique procedure section clauses will be moving to allow us to provide feedback on when the information needs to be accessible to ensure maximum ability that it can inform withdrawals or updates to C15 projects. This will mean thinking through the below dates in more detail given when data can be made available to inform the decisions.

Vistra requests the next iteration of the paper include proposed changes:

• Section 17.1(c): What date will the withdrawal of Cluster 15 projects with full refund by allowed now that this effort is not planned to be complete until after April 1, 2024 date in the Tariff.[1]^,[2]
• Section 17.1(b): Interconnection Request (IR) customers can modify their requests between what two dates now that the effort will not be taken to the Board until after May 1, 2024 and validation will not be complete by September 26, 2024?
• Section 17.1(a): Cluster 15 validation will be delayed from September 26, 2024 to what date?

[1] Vistra requests this date be moved out with the delay to begin validation. For example, if the CAISO moves validation beginning by three months from May 1, 2024 (per Section 17.1(b) date ranges) to August 1, 2024 then logic would follow that the date in Section 17.1(c) should move to July 1, 2024.

[2] Vistra believes for maximum information on the projects for C15 that the data would be accessible for six months prior to making the withdrawal decision, however that would be February 1, 2024 if Section 17.1(c) moves to July 1^st. Vistra urges the CAISO to release data as quickly as it can given its limitations. Ideally, developers should have 90 days to analyze the provided data to inform withdrawal decisions.

3. Provide your organization’s comments on updates made throughout Section 2 Interconnection Request Intake

None at this time.

4. Provide you organization’s comment on section 2.4 – Scoring Criteria

See Vistra’s response to question number one for our concerns with the scoring approach. A workable path forward could be to include the suggested financial viability criteria and to reduce the share of “policy votes” to a minority share of the total points. Generally, Vistra believes financial viability and project viability collectively should account for 75% of the possible points with 40% to financial viability for making the non-refundable fee and up to 35% for project viability.

If the CAISO is open to considering more revisions to the scoring proposal, Vistra would like to clarify our thinking for financial viability criteria in a scoring metric, since CAISO’s revised straw proposal appeared to inaccurately summarize the group of developers thinking on including financial viability criteria. Vistra is one of the generation developers that recommended revising the proposed approach for supporting financial viability of a project, however Vistra would not have characterized the idea that we put forward in the small group as “increased financial deposits to be used as initial requirements to submit an interconnection request”.[1] Through the viability criteria small working groups, Vistra put forward and was developing with stakeholders the idea of including in the viability scoring metric a category for “financial viability” that would result in points in the scoring metric for meeting financial viability. A project would receive ~40% of possible points at the time that a project is moving from scoping meeting into study process for paying a non-refundable interconnection financial security fee ($/MW) that would be non-refundable if withdrawing and would apply to project costs once an Interconnection Agreement is executed.

Vistra proposed that an equitable fee structure to start negotiating among stakeholders could be:

The logic behind these values as a starting place is that it would result in roughly around $2,000/MW costs for projects ranging from small to large projects so that small versus large projects would not be unfairly impacted after taking into consideration the study deposits due pursuant to FERC Order 2023, and the proposed non-refundable fee prior to entering the studies that would be cost-offsetting for successful projects. See below an example of the combined exposure to support financial viability.

Vistra continues to believe that financial viability criteria should be included in the scoring metric and assigned points at the point the CAISO is proposing to apply the scoring metric for screening out requests. A non-refundable fee used to offset project costs is aligned with the FERC Order 2023 financial commercial readiness deposit requirements and would work with those requirements by adding a commercial readiness deposit at the time of entering the cluster study process and assign points to that financial commercial readiness objective criteria.

Finally, Vistra and other developers had been working through more details on the type of project viability criteria would be reasonable to use to apply points at the IR screening stage and the potential supporting documentation.  Vistra respectfully asks the CAISO to continue working with developers on this criteria and appropriate supporting documentation and revise these criteria based on that work in the next iteration. While the subgroup work has stalled since the proposal was issued given lack of clarity on whether continued work to refine these will occur, Vistra hopes if CAISO commits to continuing to work on the criteria and invites the subgroups to keep developing this criteria the work may continue. We request CAISO coordinate with subgroups continued work on the project viability criteria.

[1] Interconnection Process Enhancements Track 2, Revised Straw Proposal, California ISO, Page 31.

5. Provide your organization’s comment on Section 2.5.1 - Fulfillment of 150% of available and planned capacity

As previously mentioned, Vistra is concerned this proposal lacks sufficient details and request the CAISO be clear on whether capacity is only full capacity or if it will include energy only capacity headroom or interim full capacity deliverability headroom. Further, CAISO needs to be clearer about how partial capacity and energy only capacity projects are proposed to be screened within this cap.

6. Provide you organization’s comment on section 2.5.2 – Zonal Auctions

None at this time.

7. Provide you organization’s comment on section 2.5.3 – Modifications to the Merchant-Financing “Option B” Process

Vistra does not believe the CAISO’s option B proposal allows for sufficient option B flexibility. Option B should be available to projects that were not selected to be studied in transmission zones that have available or planned capacity. Vistra does not support CAISO’s restrictions on ability to self-fund interconnection in transmission zones with insufficient headroom to facilitate the interconnection of a project willing to fund an upgrade to accommodate its full capacity interconnection. We respectfully request CAISO revise its proposal to ensure a fair access to projects a path to self-fund its interconnection for full capacity deliverability status regardless of where it is seeking to interconnect.

8. Provide you organization’s comment on the ISO’s proposal to remove both the off-peak and operational deliverability assessments to enable the ISO to meet Order No. 2023’s prescribed timelines (section 2.6.1)

None at this time.

9. Provide your organization’s comments on updates made to Section 3.1 - One-time Withdrawal Opportunity

None at this time.

10. Provide your organization’s comments on updates made to Section 3.2 - Limited Operation Study Updates

None at this time.

11. Provide your organization’s comments on updates made to Section 3.3 - Requirements for Asynchronous generating facilities

None at this time.

12. Provide your organization’s comments on updates made to Section 3.4 - Removal of suspension rights

Vistra requests the CAISO retain suspension rights in IPE 2023 Track 2 proposals, and allow for further analysis of how Order 2023 compliance and the other queue management proposals impact the lingering queue projects. In a future IPE, suspension right removal can be taken up again if the CAISO can better support that it needs to remove these rights as they cause harm or inefficiencies from being maintained. We believe at this point, CAISO has failed to support there is harm associated with maintaining status quo or that there is expected to be a significant benefit of the change. Given this, we request deferring this item to a future phase.

13. Provide your organization’s comments on updates made to Section 3.5 – Limitations to TPD

None at this time.

14. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue

Vistra recommends CAISO consider adopting a GIA execution no later than a date tied to when Cluster 14’s second Interconnection Financial Security payment is due pursuant to Appendix DD, Section 16.1(i) – July 1, 2024. Vistra recommends that allowing three years to execute the Generator Interconnection Agreement would be more reasonable, which would result in the GIA needing to be executed no later than July 1, 2027. Similarly, we would ask the CAISO to do the same for the Commercial Viability Criteria demonstration to July 1, 2029. Conceptually, this request is tied to the fact that the timeline for C14 has been delayed longer than the prior clusters using a more standard timeline and as such a slightly longer time in queue is warranted to reflect the more than a year delay.

15. Provide your organization’s comments on updates made to Section 3.7 – Timing for Construction Sequencing Requests

None at this time.

16. Provide your organization’s comments on updates made to Section 3.8 – Shared Network Upgrade Postings and Payments

None at this time.

17. Provide your organization’s comments on updates made to Section 3.9 – Timing of GIA Amendments

None at this time.

18. Provide your organization’s comments on updates made to Section 3.10 – PTO starting work on NTPs

Vistra supports this proposal to require additional milestones for PTO starting work in the agreement.

19. Provide your organization’s comments on Section 3.11 - Deposit for ISO implementation of interconnection projects

Vistra requests the CAISO specify how the $100,000 deposit will be used. As an organization required to be revenue neutral, CAISO will need to use the $100,000 deposits fees directly. Please explain whether this will be used to fund new hires, used as bonuses for CAISO staff, etc. Conceptually, Vistra can understand the desire add a deposit for CAISO staff time spent on projects if those funds go towards compensating the team members performing the work rather than into CAISO’s general funds as a revenue addition. We appreciate more details and assurance the funding would directly benefit the staff members working on the project management or new resource implementation. 

20. Provide your organization’s comments on Section 3.12 - Update to the Phase Angle Measuring Units data

None at this time.