Comments on Draft Tariff Language

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

See attached document for comments regarding the need to change the tariff langauge to allow long lead-time resources on existing transmission capacity to qualify for long lead-time points and for a request for clarification on changes to the Point of Interconnection for Cluster 15+.

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

AES Clean Energy, “AES,” appreciates the opportunity to submit comments on the CAISO’s Interconnection Process Enhancement Draft Tariff. AES’s comments mainly request clarity on the tariff language. 

In the proposed definitions under Appendix A, AES recommends the CAISO insert a definition for “Sub-Zonal Constraint” given the Final Proposal’s focus on qualifying projects in the Deliverable Zones based on whether sub-zonal constraints exist. While the current Appendix A already includes definitions for Area Deliverability Constraint and Local Deliverability Constraint, the CAISO should insert a definition for sub-zonal constraints for the purposes of identifying valid interconnection requests for scoring.  

Under the proposed Section 3.5.2, the CAISO states, “The Scoping Meeting will be segregated by Transmission Zone and Cluster Study criteria.” AES seeks clarification if this would mean that there will be group scoping meetings for each Transmission Zone that is further divided by the different request types. For example, will each Transmission Zone have four scoping meetings: one for deliverable zones, one for merchant zones, one for reimbursable energy-only, and one for non-reimbursable energy-only? 

Under the proposed Section 4.1, AES seeks clarity on how the CAISO would treat projects behind constraints or not selected through scoring based on the 150% limit. The CAISO should specify what happens to projects that are not selected through scoring or are behind constraints. Under the proposed Section 4.1 (1), AES recommends the CAISO to add additional clarity on how deliverability will be determined at the Point of Interconnection (POI). For example, how would the constraints be considered in determining deliverability available at the POI?  

Under the proposed Section 4.4, AES recommends the CAISO to clarify what interconnection requests qualify for this study criteria. For example, will this include energy-only projects not in Transmission Zone the Local Regulatory Authority has designated a specific MW quantity of Energy Only capacity for procurement or unselected projects in Section 4.3?

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

Please see attached.  

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

Please clarify if POI changes are allowed during customer engagement window as proposed in initial discussions. The tariff language strikes off the change in POI clause under section 6.7.2.2. Please confirm if this is would be under consideration in Track 3, and if yes when would be the deadline for submission of POI change

Additionally, please clarify the treatment of out-of-state projects that wish to move their POI. According to CAISO queue reform discussions, a POI can be moved anywhere within the same study zone. In this case, projects located out of state would be clustered under which zone, and would they be allowed to modify their POI?

We currently have a project in QC15 (Project Name: Glyder, 1000MW IR) that is interconnected to the Cielo Azul 500 kV POI in Arizona. Can you please confirm the study zone for this project? Additionally, are we allowed to move the POI for this project, and if so, to which study zone?

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

• Section 3.6.4 (timing of TPD information release)
  • September 1st is too late in the application cycle to receive data regarding constraints and TPD availability, especially considering the requirement to show proof of 90% site control before the deadline (Oct 15 post-QC15). Intersect Power proposes that CAISO publish this information within a month of the previous cycle's TPD allocation.
• Section 4 (TPD transfers to EO projects)
  • CAISO's final proposal, and associated addendums, did not include provisions precluding TP Deliverability transfers to projects that pursue Energy Only Interconnection Requests. CAISO should remove this provision from the draft Tariff language.
• Section 4: (scoring data transparency)
  • It is critical to the integrity of the scoring process that CAISO publishes the list of IRs behind each constraint as well as each IR's corresponding scores. Without this level of transparency, developers have no way to discern project omission and have no means to independently validate the CAISO's conclusions.
• Section 4.1.1.1: (LSE full allocation option)
  • CAISO's final proposal, and associated addendums, did not include a provision for LSEs lacking sufficient points to match the capacity of one project to limited to utilizing the Full Allocation option for ICs with Interconnection Service Capacity only up to 150% of the LSE's most recent peak demand forecast. Given stakeholders did not have an opportunity to debate the merits of such a limitation, and the arbitrary selection of 150%, CAISO should remove this provision from the Tariff language, at a minimum for Cluster 15.
  • If some version of the full allocation option limitation remains, can an LSE still allocate its full points up to 150% of its most recent coincident peak demand forecast to a single project even if it wouldn't get the project to 100 sub-points (e.g. if 150% of coincident peak demand is 900MW and the project size is 1000MW, then would the project get 90 points)? If so, can the project still pursue the rest of its points from another LSE?
• Section 4.1.1.2: (engineering design plan points)
  • Please confirm that the maximum 50 subpoints correspond to a 50% design (not explicitly stated).
• Section 4.1.1.2: (expansion of existing generator points)
  • For the expansion of a Generating Facility that has an executed GIA, the requirement is to have issued notice to proceed and be under active construction. What is active construction? This will be problematic for CAISO to objectively verify because the definition of construction can adopt different perspectives, e.g., physical, tax, contractual, not to mention trying to define the degree to which construction has commenced under each of those perspectives. Intersect Power suggests removal of the "active construction" clause, and replacement with a third posting requirement. Thus, the requirement would become issuing notice to proceed and making the associated third posting under the GIA.
• Section 6.7.2.2 (change of POI)
  • For cluster 15 specifically, CAISO should permit changes to POI considering the magnitude of queue reform that has occurred and the amount of time that has elapsed since the submission of the original QC15 applications. Intersect Power suggests loosening these restrictions for QC15 to allow for POI changes that do not result in increasing the Interconnection Service Capacity from the original filings. 

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

LSA has comments in numerous places, from content (e.g., where the language goes beyond the Final Proposal) to editing (organization and phrasing suggestions.

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

Please find below NCPA's proposed edits to the draft Tariff language:

Section 3.6.4 (i) - Single-line diagrams of each Transmission Zone with the CPUC and LRA portfolio resources identified at the substations to which the CPUC has mapped resources in its busbar mapping process and those identified by LRAs, if any;

Section 4.1.1 (1) (Second Paragraph) - Load Serving Entities will provide the CAISO their point allocations consistent with Section 3.5.  The Interconnection Customers will receive up to 100 sub-points in the commercial interest category based on the ratio of its requested Interconnection Service Capacity at the Point of Interconnection to the number of points allocated to it from the Load Serving Entity.  If a Load Serving Entity lacks sufficient points to match the capacity of one project, it may indicate a full allocation to that project in lieu of using any of its allocated points in that Cluster Application Window.  A Load Serving Entity exercising this option can award its points to only select one Interconnection Request only in the Cluster Application Window, and the Interconnection Customer’s Interconnection Service Capacity may not exceed one hundred fifty percent (150%) of the Load Serving Entity’s most recent coincident peak demand forecast from the California Energy Commission; provided, however, that multiple Load Serving Entities exercising this option in mutual coordination can jointly award points to a single Interconnection Request in the Cluster Application Window, and the Interconnection Customer’s Interconnection Service Capacity may not exceed one hundred and fifty percent (150%) of the aggregate of the coordinating Load Serving Entities’ most recent collective peak demand forecast from the California Energy Commission.  An Interconnection Request with a full allocation will receive 100 sub-points in the commercial interest category.

Section 4.1.1.1 (Last Paragraph) - For each Cluster Application Window, a Load Serving Entity may allocate points to no more than three (3) Interconnection Requests from Affiliates, orand no more than twenty-five percent (25%) of its points to Interconnection Requests from Affiliates based on their requested Interconnection Service Capacity.

Section 4.3.1 (Last Paragraph) - For each Cluster Application Window, a Load Serving Entity may allocate points to no more than three (3) Interconnection Requests from Affiliates, orand no more than twenty-five percent (25%) of its points to Interconnection Requests from Affiliates based on their requested Interconnection Service Capacity.

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

Please see attached.

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

Q1. Whatis RIS?

Q2. (Appendix KK -Section 3.5.1.) Are commercial Readiness Deposits needed for all porjects or porjects connecting to merchant deliverability zones only. According to IPE track 2 final proposal this was a requirement only for Porjects connecting to merchant zones

Q3. (Appendix KK -Section 3.5.1.) Can CAISO confirm this is $10,000 per MW 

Q4. (Appendix KK -Section 3.5.2.) Is this section for C16 or C15? In one of the previous versions I think we were told the scoping meetings will be held Between May 1-31st, was this now changed to Juan 1st -March 31s?

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

San Diego Gas & Electric (SDG&E) is concerned that the draft Tariff language as written does not accurately represent the approved policy for limits on LSE owned projects. In the Interconnection Process Enhancements (IPE) Final Proposal, LSEs “may only award capacity to either three self built projects or 25% of the LSE’s capacity allocation per cycle, whichever is greater”.1 However, the language in the draft Tariff states that LSEs will be limited to no more than three interconnection requests from affiliates, and no more than 25% of its interconnection service capacity to self-build projects. We offer the following redlines to better align the draft Tariff language with the final Board of Governors-approved IPE policy proposal. This change will make it clear in the tariff that it is the greater of one or the other, rather than implying LSEs are limited to both conditions when awarding capacity to these projects.  

Section 4.1.1.1 and Section 4.3.1  

For each Cluster Application Window, a Load Serving Entity may allocate points to no more than three (3) Interconnection Requests from Affiliates, and or no more than twenty-five percent (25%) of its points to Interconnection Requests from Affiliates based on their requested Interconnection Service Capacity, whichever is greater. 

In addition, SDG&E requests clarification in the tariff that for Cluster 15 only, LSEs will be allowed 21 calendar days to submit their capacity allocation to the CAISO.  

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

Please see the attached redline of the CAISO's draft tariff language.

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

Please see SCE's proposed comment/edits, highlighted in yellow, to the CAISO's 2023 IPE Track 2 draft tariff language in the attached document. Thank you.

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

See attached comments and suggested revisions.