Comments on Final proposal and draft Tariff language

1. Please share your organization’s overall position on the final proposal:

ACP-California appreciates CAISO’s efforts to address Cluster 15, given the present unsustainable situation with the interconnection queue. While the delay in Cluster 15 is not an ideal situation for any party, we understand the need to adjust the schedule for processing and studying Cluster 15 interconnection requests. And, as a general matter, ACP-California agrees that the ISO cluster study process is in need of significant reform to support the accelerated pace of resource development and we look forward to continued engagement with the CAISO on Track 2 reforms. We urge CAISO to review the proposal that ACP-California put forward in comments on the Straw Proposal (comments located here). Specifically, in response to question #7, ACP-California outlined a process for Track 2 which we believe could achieve the goals CAISO has identified for reforming the interconnection process while still maintaining some flexibility in procurement and interconnection requests.

With respect to the Final Proposal for Track 1 of IPE 2023, ACP-California looks forward to the provision of additional details on the potential paths and treatment for TransWest going forward. In the proposal, CAISO recognizes that TransWest Express is in a unique circumstance where it is being studied through transmission planning processes and offers that it would “explore addressing TransWest Express’s transition from a transmission planning process project as needed, but without a separate GIDAP process at this time”. It is our understanding that CAISO is not proposing a separate study process at this time, and that any proposal that might come forward would come through a future stakeholder initiative. We would appreciate CAISO’s clarification of the potential approach for considering TransWest Express. 

In addition, ACP-California urges CAISO to ensure that Track 2 moves forward as expeditiously as possible, such that modifications are in place when the Cluster 15 studies resume and the future reforms can be applied to the Cluster 15 applications that have already been submitted. Given that Cluster 15 is comprised of an extremely large number of interconnection requests, it will be extremely important that the reforms enacted in Track 2 can be applied to manage the anticipated volume of applications in Cluster 15.

ACP-California thanks CAISO for their work on this initiative, and supports the continued, proactive management of the interconnection queue to help bring resources online in a timely manner.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

On the draft Tariff language, ACP-California suggests providing some flexibility in the opening of Cluster 16 (addressed in Section 17.1.e). While CAISO may not currently believe that it will be feasible or necessary to open the Cluster 16 window in 2024, it should provide a path forward to opening that window in the event it is deemed necessary and appropriate. It is important to provide this option within the tariff language, as no one currently knows where the IPE 2023 Track 2 reforms will land and there is a possibility that unforeseen circumstances may result in the need to open the Cluster 16 window in 2024. Therefore, we suggest the following language for section 17.1.e:

The CAISO will not open the Queue Cluster 16 Cluster Application Window in 2024, unless it determines doing so is feasible, in which case CAISO will provide at least 60 days’ notice prior to the opening of Cluster 16.

1. Please share your organization’s overall position on the final proposal:

AES Clean Energy appreciates the opportunity to submit comments on the 2023 Interconnection Process Enhancements Track 1 Final Proposal (Final Proposal). Overall, AES Clean Energy supports the Final Proposal and looks forward to collaborating with the CAISO on Track 2 reforms that would ultimately apply to Cluster 15 projects and beyond. 

AES Clean Energy appreciates the Final Proposal’s flexible treatment to Cluster 15 projects that are submitted between April 3, 2023 – April 17, 2023 understanding that Track 2 reforms are still under discussion.  AES Clean Energy support the one-time opportunities for Cluster 15 interconnection customers modify their original interconnection requests (IRs) without material modification assessments once the Cluster 15 studies resume on April 1, 2024.  Specifically, AES Clean Energy supports the modifications including: (1) changes to technology type; (2) changes to the MW capacity amounts of the original IR as long as the interconnection service capacity does not increase; (3) adding or increase storage components to the original IR as long as the interconnection service capacity does not increase; (4) changes to the point of interconnection and project site within the study area; and (5) updated IR packages to support the requested modifications.  In addition to the modifications, AES Clean Energy supports the Final Proposal allowing withdrawals with full refunds prior to April 1, 2024.  AES Clean Energy agrees with the Final Proposal’s conclusion that tariff amendments are not needed to allow for the modifications and withdrawals since these changes are generally possible prior to conducting Phase 1 studies. 

AES Clean Energy supports the Final Proposal’s conclusion to not create a separate study process for out-of-state wind resources at this time.  AES Clean Energy agrees with stakeholder concerns that a separate interconnection study process for out-of-state wind may potentially cause further study delays for in-state projects. 

AES Clean Energy looks forward to further discussion regarding the Track 2 reforms that will apply to Cluster 15 projects and beyond. AES Clean Energy appreciates CAISO’s effort to present the Track 2 Final Proposal to the Board of Governors by December 2023 to implement the process changes for Cluster 15.  However, AES Clean Energy continues to urge the CAISO to incorporate stakeholder working groups into the schedule for Track 2.  Stakeholder working groups provide opportunities for the industry to propose interconnection reforms proposals that could more quickly achieve consensus prior to CAISO staff publishing a draft final proposal.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

AES Clean Energy has no comments on the draft Tariff language. 

1. Please share your organization’s overall position on the final proposal:

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California Independent System Operator’s (ISO) Interconnection Process Enhancements 2023 Final Proposal. This initiative is coming at a critical time when the entire industry is moving as quickly as possible to get new clean resources online. CalCCA’s comments on the Issue Paper/Straw Proposal highlight the urgent need to interconnect resources at an unprecedented pace to meet California’s ambitious climate goals.[1]

Track One focuses on near-term schedule changes delaying the study of new interconnection requests. While it is unfortunate to delay the interconnection process at a time when the need for new resource interconnection is at its highest, CalCCA understands the ISO’s need to delay the study of Cluster 15 interconnection requests, given the record amount of requests moving from Phase I to Phase II. CalCCA anticipates that Track Two of this initiative will bring about the “significant and transformative improvements”[2] the ISO seeks. In Track Two, the ISO must consider policies that will allow the ISO to support the number of requests the ISO has experienced in Cluster 14 and anticipates in Cluster 15 going forward. The amount of build-out projected by the California Energy Commission in its Senate Bill (SB) 100 scenarios and planned for in the ISO’s Transmission Plan will necessitate efficient queue management that supports the magnitude of requests in Cluster 14 without further delays and supports fluctuating queue sizes year over year.

The following Track One proposals appear reasonable given the delay between when Cluster 15 interconnection requests were submitted (April 2023) and when the ISO will begin validating those requests (April 2024):

• Allowing interconnection customers that withdraw prior to April 1, 2024 to receive a refund of any portion of the interconnection customer’s study deposit that exceeds costs that the ISO, Participating Transmission Owners, and third parties have incurred on the interconnection customer’s behalf (which the ISO expects to be minimal); and
• Allowing the interconnection customer to make certain modifications to their request, including changing the technology type, changing the megawatt amounts of the various generator technologies or adding battery storage as long as the original interconnection capacity in the request does not increase, or changing the point of interconnection within the same study area, before their request is validated (by Sept. 2024).

CalCCA also supports the ISO’s determination to not provide a special schedule for offshore and out-of-state wind. Offshore and out-of-state wind resources can play important roles in meeting state policy goals. As stated in CalCCA’s opening comments, however, CalCCA would be concerned with using a special study schedule for offshore and out-of-state wind if it would impact the study schedule of Cluster 15, and therefore, delay the interconnection of other projects needed to meet procurement orders. CalCCA agrees with the ISO that because policy-driven transmission projects for offshore wind and out-of-state wind are expected to be included in the 2023-2024 Transmission Planning Process cycle, studying offshore wind and out-of-state wind in Cluster 15 with the other projects makes the most sense.

[1]             CalCCA Comments on the Issue Paper Straw Proposal: “From 2001 through 2021, the state has built new capacity at a rate of 1,308 MW per year. Under the SB 100 Core Scenario, the rate will need to increase to 7,292 MW per year from 2022 through 2045 (a 557 percent increase).” https://stakeholdercenter.caiso.com/Comments/AllComments/b6ed131c-ecaa-460d-8316-e0e0dcd0373f#org-7f69761d-1e42-4add-9794-d8d20a05431d.

[2]             Final Proposal at 1.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

CalCCA has no comments on the draft tariff language at this time. The language appears consistent with the policy in the Final Proposal.

1. Please share your organization’s overall position on the final proposal:

The California Energy Storage Alliance (CESA) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) Interconnection Process Enhancement (IPE) 2023 Track 1 Final Proposal and draft tariff language. CESA appreciates CAISO’s efforts to implement improvements to the interconnection process needed to accommodate the growing demand for grid integration and ensure timely and cost-effective interconnection of projects in the queue.

As highlighted in the IPE Track 1 Final Proposal, the immediate adjustments proposed to the schedule for processing and studying QC 15 IRs is in the interest of allowing adequate time for completing QC 14 Phase II studies before starting the heavy workload of the QC 15 process. That said, CESA reiterates that, while the delay to QC 15 is not ideal, adjusting the schedule to QC 15 in order to prioritize QC 14 Phase II studies is appropriate.

However, the CAISO should consider further clarifying certain aspects of the Final Proposal to prevent further uncertainty for QC 15 interconnection customers (IC). Specifically, the CAISO should clarify whether there were modifications to the timing and types of refunds that are available to withdrawing customers in QC 15. The Track 1 Final Proposal highlighted that several stakeholders requested some level of relief from the CAISO holding deposits without any significant progress being made on IRs until April 2024 (e.g., refund IC study deposits or site exclusivity deposits). However, the CAISO contends that this is not a viable option, given that some ICs provided site exclusivity deposits in-lieu of demonstrating site control, and would not be able to refund ICs that made financial commitments to acquire site control, unlike ICs that provide a site exclusivity deposit. Yet, the CAISO also stated in the Final Proposal that the proposed refunds are already allowed “on or before 30 calendar days following the scoping meeting”, and that the ISO does not propose to alter existing deposit refund provisions. However, given the increased uncertainty QC 15 ICs are facing with the delay to QC 15, changes to other timelines in the process, and potential reforms that will impact their QC 15 IRs, the CAISO should clarify whether there were modifications to the timing and types of refunds that are available to withdrawing customers in QC 15. Providing further clarifications on the refunds allowed will reduce the amount of uncertainty ICs are facing navigating the various proposed changes to previous, current, and future QC timelines. Specifically, to avoid any confusion, there should be a clear indication of whether the deadline for withdrawing an IR and receiving a refund on all deposits is April 1, 2024, on or before 30 calendar days following the scoping meeting, or if the timing could potentially be impacted by the completion of QC 14 Phase II studies, considering the changes in timelines have been driven by the prioritization of QC 14. Above all, CESA urges the CAISO to further clarify in detail the exact changes, if any, to the timing and the types of refunds available to QC 15 ICs.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

In the Track 1 Final Proposal and draft tariff language, the CAISO proposed revising the deadline for TOs to publish QC 14 Phase II study reports, given that Pacific Gas and Electric Company (PG&E) needs more time to complete studies since the majority of IRs in QC 14 are in PG&E territory. Considering PG&E’s need for additional time to complete QC 14 studies, the CAISO proposed revising the deadline for publishing QC 14 Phase II study reports for all TOs including PG&E by a couple of months (i.e., from November 24, 2023, to January 31, 2024). CESA believes that this is appropriate, considering the need to prioritize QC 14 Phase II studies.

1. Please share your organization’s overall position on the final proposal:

CalWEA is very disappointed that CAISO proceeded with its plan to preserve the Cluster 15 (C15) deadline while anticipating nearly a year-long delay before those applications will be processed.  As we explained in our March comments, we believe that delaying the deadline would have been a much more productive and efficient approach with no downside.  Instead, we believe that CAISO’s initial statement in the straw proposal that C15 applications may be “refreshed” before studies commence, combined with the suggestion that the next Interconnection Request (IR) window might not be opened until “warranted,” drove developers to submit as many applications as they could, many likely very speculative.  Thus, it is not a surprise that CAISO received nearly 550 applications.  Worse, CAISO changed the IR rules just two business days before applications were due, preventing applicants from making any necessary changes to conform to the new rules, and presumably leading to the rejection of numerous applications.  This totally chaotic process created havoc in the market, was difficult for developers, and was contrary to CAISO’s tariff. CalWEA therefore continues to oppose these elements of the proposed tariff changes.

As for the balance of the proposal addressing the implementation of C15, additional clarity is needed, and we urge CAISO to reconsider the proposal to delay Independent Study proposals, as discussed below. 

2. Please provide a summary of your organization’s comments on the draft Tariff language.

Needed clarifications:

• Please clarify when CAISO will publish the study timeline for C15.

• ISO proposes that when it resumes processing C15 interconnection requests, interconnection customers that submitted complete requests will have an opportunity to revise their interconnection request by making modifications without submitting material modification assessment requests, stating that “Any modifications made to an interconnection request must be received between May 1, 2024 and September 26, 2024 and must be determined to be complete based on all required information being supplied specific to the interconnection request prior to any validation work or scoping meeting for the project.”  Please explain the underlined portion of the statement, as it is unclear and not in the draft tariff language. 

• CAISO proposes to allow various changes to IRs, including technology and capacity changes and storage additions if the original Interconnection Service Capacity is maintained.  Please add detail regarding the process for submitting such modifications.  

Independent Study Process:

In the proposed tariff changes (although not mentioned in the proposal narrative), CAISO proposes not to accept/process Independent Study Process Interconnection Requests until Cluster 15 Phase I Interconnection Studies are completed, which, under the proposed schedule, is likely to be late 2025 or early 2026.  While this is consistent with the current tariff, CAISO should propose tariff modifications to allow ISP projects to be studied based on C14 Phase 1 or Phase 2 studies.  Since CAISO is taking the unusual step of pausing C15 studies for a year, contrary to its current tariff, it is only fair to allow ISP projects to move forward in the interim C15 period based on C14 studies.

1. Please share your organization’s overall position on the final proposal:

EDF-R generally supports the CAISO's Interconnection Process 2023 Enhancments Track 1 proposal, in particular the CAISO's willingness to accept modifications to Cluster 15 Interconnection Requests and the decision to not propose a separate study process for offshore and out of state wind. 

The most recent paper was specifically tailored to address Track 1 proposals, but we notice that two elements were included in the draft tariff language that were not included in the final paper:

1) The CAISO will not open the Queue Cluster 16 Cluster Application Window in 2024.

2) The CAISO will not accept Independent Study Process (ISP)  Interconnection Requests pursuant to Section 4 until Cluster 15 has received its Phase I Interconnection Study results.

EDF-R requests that at the CAISO provide explanation at the May 1 meeting, as well as in a brief addendum to the Final Proposal, as to the justification for these proposal elements. The ISP process was not mentioned in any of the IPE 2023 documents, and the deferment of Cluster 16 seems to be at least a partial implementation of Element 4 of the issue paper, which was billed as out of scope for Track 1 of this effort. 

EDF-R also notes that the draft tariff language extends the Cluster 14 TP Deliverability allocation process date to no later than May 31, 2024 and the second Interconnection Financial Security date to no later than July 1, 2024. These are logical extensions based on CAISO's proposal to extend the Phase II interconnection studies date, but EDF-R encourages CAISO to confirm that these schedule changes are necessary and confirm that further milestones will not be affected (such as the annual reassessment date.) 

2. Please provide a summary of your organization’s comments on the draft Tariff language.

1. Please share your organization’s overall position on the final proposal:

We do not have a position on the final proposal except those reflected in the attached comments.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

1.  Given the postponement of the Cluster 15 interconnection requests validation by a whole year, we believe that all Cluster 15 interconnection requests should be afforded 5 Business Days of completeness cure period, not just those submitted more than five Business Days before April 17.

2.  Given the postponement of the Cluster 15 processing by more than one year, the existing rules pertaining the LGIP may not apply.  We believe CAISO should publish clear rules specifically applicable to Cluster 15 interconnection requests.

1. Please share your organization’s overall position on the final proposal:

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

QCells appreciates CAISO did not delay the C15 application window but is disappointed that CAISO is moving forward with firm delays to C14 and C15 studies.

QCells supports annual cluster windows and does not support delaying the C16 opening. Further, QCells is disappointed that a date for C16 has not been announced.

QCells supports CAISO not giving special consideration to offshore wind projects.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

 QCells supports the following language regarding C15 withdrawals:

“C15 interconnection customers that withdraw prior to 4/1/24 will receive a refund of any portion of the interconnection customer's study deposit, including interest earned, that exceed costs that the ISO, Participating TOs, and third parties have incurred on the interconnection customer's behalf, and a full refund of any site exclusivity deposit, including interest earned.”

QCells supports CAISO allowing Changing the POI and project site within the same subject area between 5/1/24 and 9/26/24, without requiring a Material Modification Assessment request.

QCells supports CAISO not allowing increases in project size without a material modification assessment request.

1. Please share your organization’s overall position on the final proposal:

LSA’s comments cover these three main points:

• Cluster 14 (C14) participation in 2023-2024 TPD Allocation process:  The CAISO should provide changes or clarifications stating that the 2023-2024 TPD allocation process will be delayed, so that C14 projects can participate, despite the delayed Phase II Study.

• Independent Study Process (ISP) treatment:  The CAISO should reconsider its statement in the draft tariff language prohibiting all ISP applications until after the Cluster 15 Phase I Studies are complete, and either remove this proposal or modify it to reflect other tariff provisions and CAISO market needs.

• Cluster 15 (C15) information release:  The CAISO should clarify its intent regarding information release for C15 Interconnection Requests (IRs), e.g., address this issue in Track 2.

Since this template requests “proposal” comments in this section and “tariff” comments in Section 2 below, LSA’s comments on the first and third point are addressed in this section, and those related to the ISP process (which CAISO included in only the draft tariff language but not the proposal document) are addressed under #2 below.

Cluster 14 participation in 2023-2024 TPD Allocation process

The written Proposal and draft tariff language would delay C14 Phase II Studies for about two months, until January 31^st, 2024.  LSA understands the need for this delay, but it raises questions about Cl4 participation in the 2023-2024 TPD Allocation process.

Typically, affidavits are due for the annual process in early December, about 2 weeks after issuance of the Phase II Study for the current study cluster.  This allows Interconnection Customers (ICs) time to examine their studies, finalize any PPAs, secure any shortlist status, and take other actions related to affidavit submittal.

The draft tariff language also says release of 2023-2024 TPD Allocation results will be postponed from March 31^st, 2024 to May 30^th, 2024.  This delay implies that the affidavit due date could also be postponed about two months, e.g., to early February 2024 – or, it could mean that CAISO plans to maintain the usual early-December affidavit due date and needs more time for the allocation process.

ICs with C14 projects need assurance that the former is the situation, i.e., that they will be able to participate in the next TPD Allocation cycle, and LSA believes this is the CAISO’s intent.  Thus, while the affidavit due date is not in the tariff (i.e., is included in a CAISO Market Notice, usually around late October-early November), the CAISO should clarify as part of the proposal that it intends to delay the due date to early February 2024.

Cluster 15 information release:  LSA’s comments on the last CAISO proposal version urged the CAISO to keep C15 queue information confidential until the window for changes (now defined as May-September 2024) has closed.

This position reflected a belief that POI changes should be based on analysis of new market information (e.g., 2022-2023 Transmission Plan, and additional locational information from the CAISO’s data-transparency efforts) instead of “speculation based on the actions of other customers.” 

LSA members holding this position believe that it would limit the volume of requested changes and protect initial C15 positions.  They note that CAISO typically does not add projects to the Generator Interconnection Queue until after IRs are validated; given the CAISO’s offer for a one-time C15 change, they don’t believe information pertaining to competing project locations, sizing, and configuration should be motivating factors for those changes.

However, this position is not unanimous within LSA.  Other members favor increased transparency, noting that the CAISO did release C14 application information (separate from the queue listings) before validation was complete.  They believe that speculative POI and other changes will occur regardless given new information, but in a less informed manner if C15 project information was withheld for a full year. 

Therefore, at a minimum, LSA urges the CAISO to clarify its intent on C15 information transparency and, if possible, provide stakeholders with an opportunity to respond and discuss this issue further, since it was not addressed at all in the Final Proposal or proposed tariff language.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

ISP application acceptance

The proposed tariff language would prohibit submittal of any ISP Interconnection Requests (IRs) until after C15 Phase I Studies are issued – perhaps two or more years into the future.  LSA believes that the CAISO should revise this proposal because:

• The proposal was not raised at all during the stakeholder process, and it should not be proposed for the first time through draft tariff language.  Stakeholders have had no opportunity to comment or raise related issues.

• The proposal is contrary to the ISP tariff language and CAISO market needs.  GIDAP Section 4.1.5 states as follows (emphasis added):

The CAISO will inform an Interconnection Customer whether it has satisfied the requirements set forth in Sections 4.1.3 within thirty (30) calendar days of receiving the data necessary to determine whether the Interconnection Customer has satisfied such requirements. For a proposed Generating Facility in a study area with active Interconnection Requests in the current Queue Cluster or the Independent Study Process, such 30-calendar day period will commence when the Phase I Interconnection Study results are available for the current Queue Cluster and all system impact studies (or combined system impact and facilities studies) have been completed for all earlier-queued Independent Study Process Interconnection Requests in the same study area.

Two issues are raised by this tariff language:

• Projects in study areas without active Interconnection Requests:  There is no need to cease acceptance of ISP IRs in such areas, since they would not impact or be impacted by any Cl5 studies, and the tariff does not provide for such treatment.

The BPM for GIDAP, Section 6.2 states that:

An Interconnection Request submittal for the Independent Study Process (ISP) can occur any time during the year.

The ISP will have its electrical independence tested against the study results of projects in the most recently completed studies of the latest cluster as well as earlier ISP projects in the CAISO queue.  If the results of the CAISO and Participating TOs determination of a project’s electrical independence is not completed prior to the close of any given open Cluster Application Window the customer’s ISP project will have to wait for the studies of the recently closed Cluster Application Window to be far enough along to be able to determine its electrical independence against the projects in that latest cluster. 

This language is clearly intended to apply only to ISP applications in areas where IRs were received in the Cluster Application Window.  GIDAP Section 4.1.5 does not require any wait for ISP applications in areas where there are no “active” Interconnection Requests, so regardless of the meaning of the term “active” (see below), the BPM language concerning the application window cannot not apply to those projects.

As a practical matter, the CAISO should clarify which areas do not contain any active IRs, so developers will not waste their time preparing IRs for those areas.

• Projects that should be considered “active:”  There is a legitimate question about whether this BPM language accurately reflects the applicable tariff language in GIDAP Section 4.1.5, i.e., whether IRs received in a cluster window should be considered “active” before they are even validated.  For example, projects are typically not added to the CAISO’s Generator Interconnection Queue until they pass validation, and some (perhaps many) may not ultimately pass.  Projects that may not have valid IRs should not be considered “active,” and thus should not impede processing of ISP applications. 

The very lengthy C15 process contemplated in Track 1 will simply compound the harm from the ISP prohibition, since ISP applications (which by definition have timelines that cannot endure the long Cluster Study process) will likely be delayed by over two years, as noted above.  For example, ISP applications may be needed for repowering applications, Net Energy Metering applications including large generators, conversions to CAISO market LGIAs where project changes may impact the electrical characteristics of the projects, or other projects that simply do not need deliverability.  These needed market changes would likewise be delayed.

In conclusion, LSA urges the CAISO to:

• Remove this provision from the draft tariff language and leave the existing ISP language in place (and modify the associated BPM language accordingly).

• Modify the language in GIDAP BPM Section 6.2 to:

• Clarify that the language referring to ISP processing delays due to the close of the cluster-study window would only apply to ISP applications in areas where cluster IRs were received, to make it consistent with the applicable tariff language in GIDAP 4.1.5.

• Provide that processing delays for ISP applications would not apply for cluster-study IRs in the same area until those cluster-study IRs are validated, i.e., that IRs are not “active” until they are validated.

• At a minimum, provide that ISP applications in areas where no cluster-study IRs pass validation would continue to be processed per the normal ISP timelines and need not wait until the next Phase I Study is complete.

1. Please share your organization’s overall position on the final proposal:

New Leaf Energy, Inc. (“New Leaf Energy”), an independent developer of solar and energy storage, thanks the California Independent System Operator’s (“CAISO”) for the opportunity to comment on the 2023 Interconnection Process Enhancements Track 1 Final Proposal (“Track 1 Final Proposal”) and Draft Tariff Language, dated April 13, 2023. New Leaf Energy appreciates the responsiveness of CAISO staff to stakeholder comments on the 2023 Interconnection Process Enhancements Issue Paper and Straw Proposal from March 13, 2023.

New Leaf Energy makes the following recommendations regarding the Track 1 Final Proposal and Draft Tariff Language:

1. The CAISO should clarify that the proposed two-month delay of the release of Cluster 14 Phase II results will be accompanied by a similar delay in the annual deadline for Interconnection Customers (“ICs”) to submit transmission plan deliverability (“TPD”) affidavits.
2. In this stakeholder initiative, a specific date or specific trigger criteria and timelines for the opening of Cluster 16 must be established.
3. If the CAISO moves forward with its current plan to allow ICs to modify the Points of Interconnection (“POIs”) in their Cluster 15 Interconnection Requests (“IRs”), it must incorporate additional safeguards against potential anticompetitive behavior.

Each recommendation is discussed further below.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

I. The Transmission Plan Deliverability Allocation Process Must Follow the Release of Cluster 14 Phase II Study Results

In Section 16.1(f) and (h) of the Draft Tariff Language, the CAISO proposes to postpone the publication of the Cluster 14 Phase II study reports from November 24, 2023 to January 31, 2024 and to postpone the publication of TPD allocation results from March 23, 2024 to May 31, 2024. New Leaf Energy does not object to these modifications, provided that the TPD affidavit submission deadline is likewise extended.

Typically, affidavits are due for the annual TPD process in early December, approximately two weeks after the issuance of the Phase II Study for the current cluster. Given the confusion and uncertainty associated with many changes to the current process, New Leaf requests that CAISO clarify in writing that it will modify the TPD affidavit deadline to ensure that Cluster 14 ICs have access to their Phase II results before TPD affidavits are due.

The Track 1 Final Proposal acknowledges that Cluster 14 is needed to “provide load-serving entities with a large pool of projects for procurement.”[1] This enlargement requires giving Cluster 14 projects the opportunity to seek TPD this cycle, which will also allow them to be far more de-risked when they enter solicitations.

New Leaf Energy infers from the proposal that the CAISO intends to adjust all deadlines associated with the TPD allocation, as failing to delay the TPD affidavit submission date would unnecessarily limit the number of mature projects that LSEs can consider in their solicitations, but written confirmation of this planned change would reduce any lingering uncertainty.

II. Ambiguity Regarding the Timing of the Cluster 16 Application Window Creates Unnecessary Market Uncertainty and Violates Open Access Principles

Section 17.1(e) of the Draft Tariff Language states, “The CAISO will not open the Queue Cluster 16 Cluster Application Window in 2024.” New Leaf Energy understands that the “supercluster” volume of IRs that the CAISO has received for Cluster 15 necessitates a delay in the annual application window, just as the high volume of Cluster 14 IRs received in 2021 led to a one-year delay in the Cluster 15 application window. However, far more specificity is needed, either in Track 1 or Track 2 of this initiative, on the exact timing of Cluster 16.

The development activities that take place leading up to an IR submission are time-consuming and costly. Developers need visibility into a submission deadline far before the window for submission opens. Such ambiguity will create unnecessary and costly market uncertainty and would appear to violate open access principles. A new IR window must be triggered on a defined cadence, at a date certain, or when the prior Cluster reaches a specific, transparent study milestone. New Leaf Energy urges the CAISO to establish a Cluster 16 Application Window date and/or specific trigger criteria and timelines by the end of this year.

III. CAISO Should Limit Permissible POI Changes for Cluster 15 IRs

The Track 1 Final Proposal would create a window from May 1, 2024 to September 26, 2024 in which Cluster 15 IRs could make certain modifications, including “[c]hanging the point of interconnection and project site, within the limitations provided in the tariff, namely within the same study area.”[2] New Leaf Energy appreciates the CAISO’s desire to offer flexibility to ICs in light of forthcoming Track 2 changes, but recommends adopting additional guardrails to protect against anticompetitive behavior and to minimize the harm to project developers that invested in analysis ahead of the 2023 Cluster 15 IR window.

First, New Leaf Energy notes that the Track 1 Final Proposal contemplates limiting POI changes to “within the same study area.”[3] However, Section 17.1(b) of the Draft Tariff Language references Tariff Appendix DD Section 6.7.2.2(a) – (h), which contains no such restriction. In order to ensure that the tariff reflects the intention of the CAISO, this restriction should be added into the Draft Tariff Language. New Leaf Energy is supportive of any efforts the CAISO can take to limit excessive shifting of POIs. New Leaf Energy suggests it may be more appropriate to limit POI changes to only an adjacent POI, as a study area is quite large geographically (encompassing multiple counties) and POI changes at this scale would have differential impacts on Reliability Network Upgrades. If the CAISO adopts an overly permissive approach to IR modifications, ICs will approach their current IRs as “placeholders” and will seek to modify them to the extent allowed by the tariff. This flexibility could counteract other actions proposed by CAISO in this initiative that intend to reduce the quantity of IR submissions and could lead to additional delays.

Second, New Leaf Energy is concerned about potential anti-competitive behavior that could result if the CAISO published any Cluster 15 queue information before the May 1, 2024 to September 26, 2024 modification window closes. If the CAISO releases information about Cluster 15 IRs prior to September 26, 2024, then 2024 POI changes could be driven by developers seeing where other applications (e.g. their competitors) had previously submitted IRs. Therefore, New Leaf Energy proposes that the CAISO keep queue information confidential until the 2024 modification window has closed.

Finally, New Leaf Energy worries that the CAISO has unintentionally set up incentives whereby project developers that invested in analysis ahead of the 2023 Cluster 15 IR window to identify POIs that are particularly promising will have the value of that work voided if those POIs are later swamped with modified IRs with whom they would now be studied concurrently. The CAISO could prohibit relocations to POIs that already have Cluster 15 IRs, or alternatively, the CAISO could devise a process by which those original Cluster 15 IRs have seniority in the study process at their POIs over those who come later.

IV. Conclusion

New Leaf Energy thanks the CAISO for the opportunity to provide input on these important issues and for its consideration of these comments.

[1] Track 1 Final Proposal, p. 4.

[2] Track 1 Final Proposal, p. 8.

[3] Track 1 Final Proposal, p. 8.

1. Please share your organization’s overall position on the final proposal:

PG&E appreciates the opportunity to provide comments on the final proposal and draft language.  PG&E supports the CAISO’s proposal for immediate adjustments to the Cluster 15 schedule.  Specifically, PG&E agrees with CAISO’s determination to postpone the target date publishing the Cluster 14 Phase II interconnection study reports until January 31, 2024, and postponing until April 1, 2024, commencement of the validation and project scoping meetings for Cluster 15 interconnection requests.  As the final proposal notes, there are 205 projects to be studied in the Cluster 14 phase II study process, over half of which (i.e., 105 projects) are seeking interconnection in PG&E’s service territory.  It is imperative for PG&E to finish all Cluster 14 study deliverables without overlap of Cluster 15 Phase I Interconnection Requests review and scoping meetings.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

1. Please share your organization’s overall position on the final proposal:

Power Company of Wyoming LLC (“PCW”) appreciates the opportunity to submit these comments on the California Independent System Operator’s (the “ISO”) Track 1 Final Proposal to the 2023 Interconnection Process Enhancements (“Final Proposal”).

In PCW’s comments on the straw proposal, PCW suggested that the ISO consider the interplay between the interconnection process and PCW’s ability to meet the requirements of offtakers in contracts for out-of-state wind. In order to ensure that critical long-lead time resources come online in time to meet the State’s planning objectives, PCW advocated for a separate track for out-of-state wind to proceed through Cluster 15. The CPUC’s comments echoed this request. 

Though the Final Proposal declines to adopt a separate study process for out-of-state wind, it recognizes PCW’s unique circumstances, where reliability, deliverability network upgrades, and interconnection facilities must be studied through both the generator and transmission interconnection processes. As outlined in the Final Proposal, PCW’s transmission provider, TransWest Express LLC, is engaged with the ISO, Participating Transmission Owners (“PTOs”), and other Transmission Owners (“TOs”) conducting transmission interconnection studies, including WECC Path Rating studies and System Impact Studies. To date, these studies have focused on ensuring that the design and operation of the TransWest Express Transmission Project (“TWE Project”) will meet required reliability standards and guidelines. These transmission studies do not address the generator interconnection study process and the issues outlined above.

It is essential that PCW be allowed to move expeditiously and without delay through the Cluster 15 interconnection process. Without clear line of sight on interconnection costs, deliverability status, and timing, PCW cannot finalize offtake agreements with California LSEs. Without offtake agreements, PCW cannot provide support for its obligations under its Transmission Service Agreement with TransWest. This would, in turn, negatively impact TransWest’s ability to secure financing for these new transmission facilities. Therefore, PCW supports the ISO’s call to continue exploring how to address PCW’s transition from transmission planning to interconnection without a separate GIDAP process at this time. PCW is committed to and looks forward to continuing to work with the ISO along with other PTOs and developers on this transition ahead of the impending Cluster 15 studies.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

No comment.

1. Please share your organization’s overall position on the final proposal:

REV Renewables (REV) supports the final proposal for Track 1 of the 2023 Interconnection Process Enhancements (IPE) initiative.

For Cluster 14 Phase II studies, it seems that the delay to January 31, 2024 is to allow PG&E specifically more time to complete the studies. REV requests that, if SCE and SDG&E are done with Phase II studies on time (or before January 31, 2024), then they should publish those reports when completed to allow customers more time to review the results.

REV also requests that CAISO publish the list of Cluster 15 applications after they are deemed complete. While REV understands the queue is usually published after the applications are validated, given the lengthy delay, CAISO should publish at least a simplified queue list. For example, it could include the point of interconnection (POI), MW, and technology type, but not specific resource names or queue numbers, or at minimum could be provided at a POI summary level.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

REV supports the draft Tariff language for Track 1, except for Section 17.1(f). REV opposes CAISO placing the Independent Study Process Interconnection Requests on hold until Cluster 15 has received its Phase I Interconnection Study results. By definition, these requests are independent of the cluster process and therefore should not impact or be impacted by the results or timing of Cluster 15. CAISO should proceed with the Independent Study Process per current requirements.

1. Please share your organization’s overall position on the final proposal:

SEIA appreciates the opportunity to comment on the Interconnection Process Enhancements Track 1 final proposal and draft tariff language. SEIA is thankful for the CAISO’s responsiveness to stakeholder feedback, particularly regarding the permissible modifications to Cluster 15 interconnection requests prior to the commencement of Cluster 15 Phase I studies and the decision not to establish a separate study process for long-lead resources. SEIA believes the final proposal achieves CAISO’s goal for Track 1 to carve out adequate time to complete Cluster 14 Phase II studies and study meetings without introducing additional unnecessary delays to the Cluster 15 study timeline. SEIA also agrees with CAISO’s determination that the permissible modifications discussed in the final paper are currently permissible before Phase I studies and therefore do not require tariff revisions.

SEIA is largely supportive of the proposal but recommends CAISO extend the TPD affidavit submission deadline together with the proposed delay to the release of the Cluster 14 Phase II studies so as not to disadvantage Cluster 14 interconnection customers affected by the delay.

SEIA also requests that the timing of the Cluster 16 open window be discussed under Track 2 of the IPE. It is important that market participants have certainty around the Cluster 16 open window and the expected Cluster 16 timeline, as well as the timelines for future clusters.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

See above.

1. Please share your organization’s overall position on the final proposal:

Vistra appreciates the CAISO reviewing our comments on the Issue Paper and Straw Proposal.[1]  As we mentioned in our comments, Vistra is supportive of the CAISO’s proposal that would delay the start of Cluster 15 to April 2024, especailly if CAISO can commit to maintaining the cadence of milestones once begun to roughly two-year process. As Vistra states below, there are three proposed Tariff changes that were not included in the Final Proposal Section 2 on immediate adjustments to the Tariff milestones, see below for feedback. Going forward, if CAISO could include a complete set of proposed milestone changes in their policy papers and hold stakeholder discussions on them, we would better be able to evaluate those proposals.

[1] Vistra Comments on 2023 Interconnection Process Enhancements Issue Paper and Straw Proposal, March 27, 2023, https://stakeholdercenter.caiso.com/Comments/AllComments/b6ed131c-ecaa-460d-8316-e0e0dcd0373f#org-f7caf464-840c-441b-8083-690896480d7c.

2. Please provide a summary of your organization’s comments on the draft Tariff language.

Vistra is generally supportive of CAISO allowing for delays to the Transmission Plan Deliverability (TPD) allocation results deadline in 16.1(h) beyond March 2024. While Vistra understands practically that TPD allocation results will likely need to be published after end of March, Vistra is concerned about a delay that pushes the TPD allocation results and the TPD allocation report near April 1, 2024. On April 1, 2024, the CAISO is also proposing to commence Cluster 15 validation and to allow Cluster 15 interconnection request withdrawals without penalty. For the latter, interconnection customers would ideally have the Cluster 14 TPD allocation report to review and consider prior to deciding to withdraw for a full refund by April 1, 2024. Vistra asks the CAISO to consider this interaction more carefully, and if it remains committed to delaying the Cluster 14 TPD allocation results, and applicable report, to end of May 2024, then perhaps the withdrawal deadline should be shifted to require a decision in five business days after the TPD allocation report is available. Please clarify whether the CAISO is proposing one-time changes or moving the deadlines to May and July respectively for future clusters.

Vistra is generally supportive of CAISO delaying the second Interconnection Financial Security deadline in 16.1(i) beyond May 4, 2024.

Vistra is also generally supportive of the CAISO adding clarity to how it will be assessing Independent Study Process (ISP) requests going forward, however we would have greatly preferred the CAISO had included the proposal to cease accepting ISPs until Cluster 15 has received its Phase I Interconnection Study results. Assuming, CAISO can commit to maintaining the normal cadence once it begins validation of Cluster 15 on April 1, 2024, this would mean that no ISP can be requested until approximately the end of 2024.