Comments on Draft Final Proposal and Draft Tariff Language

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 draft final proposal and draft tariff language:

The comments of LSA and SEIA are summarized in the table below, and then explained in more detail in the subsequent sections.

2. Provide your organization’s overall position on the draft final proposal and draft tariff language:

LSA and SEIA support most of the proposals but request clarification in a few areas.

3. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

LSA and SEIA support the project schedule.

4. Provide your organization’s comments on the initiative scope, as described in section 3:

LSA and SEIA support the project scope, including: (1) Deferral to the 2021 IPE initiative of the Network Upgrade compensation issue for projects connecting to non-CAISO BAAs where the CAISO is an Affected System; and (2) deferral of the proposal to revise frequency response deadband & governor droop requirements (“Market Quality” proposal).

5. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

LSA and SEIA have no objection to the CAISO’s proposal, including the deferral to the 2021 IPE initiative of the Network Upgrade compensation issue for projects connecting to non-CAISO BAAs where the CAISO is an Affected System.

6. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

LSA and SEIA support the CAISO’s approach, providing the same three-year timeline for initiating a replacement project as is used for deliverability retention.  Specifically: 

Start of the three-year timeframe:  We support the same initiation point for the three-year timeframe as for deliverability retention, as stated in the BPM for Generator Management Section 12, p.74:

The effective date of Deliverability retention is the last day the Generating Unit was capable of operating. This date is the earliest [of]:

1. 1. 1. 1. the Generating Unit was forced out and not able to return to service, or
         2. the Generating Unit was removed from service and not able to return to service, or
         3. the SC disassociated from the Generating Unit in CAISO Masterfile, or
         4. the Generating Unit requested retirement by notice to Regulatory Contracts.)

End of the three-year timeframe:  We support the same initiation point for the three-year timeframe as for deliverability retention, as stated in the BPM for Generator Management, p.74: 

At the end of the 3 year period, the replacement project(s) must demonstrate that it is actively engaged in the construction of the replacement generation to be connected at the bus associated with the Deliverability priority and meets the commercial viability criteria to retain such priority.  (emphasis added)

However, we have one request related to this topic.  The CAISO explained at the last stakeholder meeting that the “construction” activity that must be initiated by the end of the three-year period (for both deliverability and interconnection retention) is different, depending on the process for the project replacement.  The CAISO explanations are summarized below.

• Replacement via a new Interconnection Request:  Submittal of the IR is sufficient, i.e., the project will qualify for retention if it enters the queue or submits an Independent Study Process (ISP) application by the end of the three-year period, even if the study period is ongoing and actual construction has not yet begun. 

• Replacement via Repowering provisions:  These projects are entitled to a faster study process, to determine whether the electrical characteristics are “substantially unchanged” and any new/upgraded facilities needed. 

The use of the term “construction” here means, according to the CAISO, “shovels in the ground,” i.e., the developer cannot just “wait around” but must commence actual construction by the end of the three-year period, to begin removing the existing facilities (if necessary) and building the new facilities.

At the meeting, LSA suggested that the CAISO explicitly explain these different standards for the different processes as part of the implementing BPM revisions for this initiative.  The CAISO asked that specific suggestions about that approach be offered in written comments, and we respond here by suggesting that the CAISO add the language in the bullet points above to its BPM revisions.

(LSA and SEIA also support SDG&E’s request at the meeting that the CAISO better define in the tariff or BPM the meaning of the “substantially unchanged” Repowering criterion.

7. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

LSA and SEIA appreciate and support the CAISO’s acceptance of their earlier suggestion to: (1) Start the process timeline when the repowering application is deemed complete and validated; and (2) require a Study Plan from the PTO 30 calendar days after that.

8. Provide your organization’s comments on the Clarify Repower language in Section 25 topic, as described in section 5.3:

LSA and SEIA have no objection to the CAISO’s proposal.

9. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

LSA and SEIA strongly support the CAISO’s proposal to allow Allocation Group 3 projects receiving a TPD allocation and later acquiring a PPA to modify their GIA CODs to reflect their PPA CODs.  (We refer to that GIA COD adjustment as “Alignment” here.)  However, we do have a comment and clarification request about one element of the current and proposed Alignment framework.

The Draft Final Proposal states that an MMA request would be needed for the Group 3 project Alignment, stating that as the current practice for similar requests from other projects, and COD delays more generally.   However, LSA and SEIA are concerned that the tariff language for Alignments reflects a slightly different intent.  GIDAP Section 6.7.5 states:

An Interconnection Customer with an executed GIA and an executed, regulator-approved power purchase agreement may request to automatically extend the GIA Commercial Operation Date to align with its power purchase agreement for that Generating Facility, including any extension or amendment…Requests to align the Commercial Operation Date with power purchase agreements are not exempt from the commercial viability criteria provisions in Section 6.7.4, where applicable.) (emphasis added).

The “automatic” language in this tariff provision is not included in any description of other allowed modifications, including other COD changes, indicating that this type of COD change would be treated different from others.

GIA COD alignment with PPA COD is not listed in BPM for Generator Management Section 6.2.1 as a modification “Approved Without Material Modification Assessment.”  Instead, it is shown under Section 6.5 (Types of Modifications) – specifically, Section 6.5.2.3 (COD Alignment with PPA(s),” which includes the same language about “automatic” GIA COD extensions.

That leaves the issue as ambiguous at best – the BPM formatting indicates that an MMA request might be needed, but the tariff and BPM language about “automatic” COD extensions indicates that perhaps it is not.  Since that terminology is in the tariff, that should supersede any format implications in the BPM.

However, BPM for Generator Management Section 6.5.2.3 goes on to say “Please note COD alignment with PPA(s) change CODs only, requests to move in-service date or other GIA milestones will require an MMA.” 

That language removes most “automatic” Alignment benefits, since it’s not clear how a extending the COD but not the related milestones would actually help a project (Group 3 or otherwise).  Thus, additional clarifications are needed.

In conclusion, the CAISO should:

• Explain and apply the different treatment for Alignments indicated by the “automatic” language, compared to other COD changes; and

• Clarify that Group 3 projects would also have the right to request modification of other project milestones to reflect Alignment, and not just the COD.

10. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

LSA and SEIA do not oppose the CAISO proposal.

11. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

LSA and SEIA do not oppose the CAISO proposal.

12. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

LSA and SEIA do not oppose the CAISO proposal.

13. Provide your organization’s concerns on deleting the Market Quality updates, as described in section 7:

LSA and SEIA strongly support removal of this proposal from the initiative scope.

14. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

LSA and SEIA do not oppose the CAISO proposal.

15. Provide your organization’s comments on Appendix A:

LSA and SEIA have no comments on the Affected Systems Study Agreement.

16. Additional comments on the COMA Enhancements 2021 draft final proposal and draft tariff language:

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 draft final proposal and draft tariff language:

NextEra Energy Resources, LLC (NextEra) is commenting on a scope item omitted from COMA, but requires urgent CAISO action.  NextEra submits these comments in the Contract Management Enhancements (COMA) and Interconnection Process Enhancements 2021 (IPE 2021) initiatives to emphasize that the proposed scope in the case of COMA, and timeline in the case of IPE 2021, fail to support accelerated deployment of resources that could otherwise contribute to energy stability and mitigate potential capacity shortages for the summer of 2023.  The critical element within the CAISO’s control that must be immediately addressed is ensuring transmission deliverability is allocated to resources capable of achieving commercial operation for summer 2023.  A proposed limited, one-time modification to the CAISO's existing process for the upcoming Transmission Plan Deliverability Allocation process is set forth in the attached comments. Please see attached submission.  

2. Provide your organization’s overall position on the draft final proposal and draft tariff language:

Generally support. 

3. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

4. Provide your organization’s comments on the initiative scope, as described in section 3:

5. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

6. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

7. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

8. Provide your organization’s comments on the Clarify Repower language in Section 25 topic, as described in section 5.3:

9. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

10. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

11. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

12. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

13. Provide your organization’s concerns on deleting the Market Quality updates, as described in section 7:

14. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

15. Provide your organization’s comments on Appendix A:

16. Additional comments on the COMA Enhancements 2021 draft final proposal and draft tariff language:

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 draft final proposal and draft tariff language:

The Six Cities generally do not oppose the CAISO's proposals in this initiative and acknowledge the CAISO's response to their earlier comments, including their response to Question No. 5 of the comments template, relating to the Issue Paper/Straw Proposal's discussion of the alignment between deliverability retention and interconnection service retention. 

The Six Cities do wish to clarify, in contrast to the CAISO's characterization of the Six Cities' position on network upgrade reimbursement under the "Affected System" topic, as described on slide 7 of the CAISO's October 7th stakeholder presentation and on pages 6-7 of the Draft Final Proposal, that the Six Cities' prior comments in this initiative explained that "[t]he Six Cities relatedly support the CAISO's proposal that Participating Transmission Owners in the CAISO will not provide reimbursement for network upgrades that are needed in connection with Affected System mitigation."  See Six Cities' Comments on Issue Paper/Straw Proposal at Question No. 4, emphasis added.  Thus, the Six Cities' position on network upgrade reimbursement is aligned with the position articulated by Southern California Edison Company.  

Additionally, it appears that the Six Cities' redlined version of the draft pro forma "CAISO as an Affected System Study Agreement" ("CASSA"), included with their comments on the Issue Paper/Straw Proposal, is not posted.  Thus, the Six Cities are re-providing their suggested revisions, which include proposed changes that are largely ministerial or intended to clarify the responsibilities of the Generation Project Owner under the CASSA.  

2. Provide your organization’s overall position on the draft final proposal and draft tariff language:

Please refer to the comments provided above.

3. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

Please refer to the comments provided above.

4. Provide your organization’s comments on the initiative scope, as described in section 3:

Please refer to the comments provided above.

5. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

Please refer to the comments provided above.

6. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

Please refer to the comments provided above.

7. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

Please refer to the comments provided above.

8. Provide your organization’s comments on the Clarify Repower language in Section 25 topic, as described in section 5.3:

Please refer to the comments provided above.

9. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

Please refer to the comments provided above.  

10. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

Please refer to the comments provided above.

11. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

Please refer to the comments provided above.

12. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

Please refer to the comments provided above.

13. Provide your organization’s concerns on deleting the Market Quality updates, as described in section 7:

Please refer to the comments provided above.

14. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

Please refer to the comments provided above.

15. Provide your organization’s comments on Appendix A:

Please refer to the comments provided above and the attached redline.

16. Additional comments on the COMA Enhancements 2021 draft final proposal and draft tariff language:

The Six Cities have no additional comments at this time.  

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 draft final proposal and draft tariff language:

Vistra appreciates the CAISO’s consideration of stakeholder comments on the Issue Paper and Straw Proposal. We support the CAISO proposals in the Draft Final Proposal, and we strongly support the CAISO decision to defer the Market Quality frequency response updates to another initiative. On the proposals in this paper, Vistra suggests two refinements to ensure that the intent of the proposals is more clearly adopted:

1. Request the CAISO add some language on the study plan timing requirements for Repowers topic to provide protections for Interconnection Customers against unnecessarily long validation periods since the proposed language begins the clock only after the validation period is complete.
2. Request the CAISO add language in the whole project conversions to storage topic that captures the full or 100% conversion proposal directly in the Tariff, perhaps as “up to full” conversion, and that specifies the full conversion is across all resources within a single facility.

We appreciate the opportunity to provide some additional suggestions to the Draft Final Proposal.

2. Provide your organization’s overall position on the draft final proposal and draft tariff language:

Vistra provides some additional suggested clarifications below.

3. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

None currently.

4. Provide your organization’s comments on the initiative scope, as described in section 3:

None currently.

5. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

Vistra supports this item.

6. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

Vistra supports this item.

7. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

Vistra appreciates the CAISO thoughtfully considering stakeholder suggestions. We can support the CAISO extending its timelines to 30 calendar days from the current 10 business days to allow for more time to validate the requests, but Vistra is concerned that there is no boundary or commitment to timely validate the repowering request packages within the new proposed language.

We can support the CAISO revising its proposal to extend to a 30 Calendar Day timeline to publish a draft study plan after a request is deemed valid and ready to be studied, however we request the CAISO also put forward some language that protects Interconnection Customers against the risk of extended validation periods. Please commit to responding to validation within 10 business days after submission identifying any deficiencies or issues. If there are two rounds of deficiencies, please commit to holding a meeting between Interconnection Customer, CAISO, and PTO to resolve any open issues or misunderstandings of the requirements needed to complete the validation of the repower request package.

8. Provide your organization’s comments on the Clarify Repower language in Section 25 topic, as described in section 5.3:

None currently.

9. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

None currently.

10. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

Vistra supports this item including the clarification that this conversion flexibility is only for synchronous (e.g., fossil-fuel) resources to convert to 100% storage via MMA, Post-COD Modification, or Repower request. In addition to the proposed Tariff language, Vistra suggests that it is prudent to include in the Tariff revisions that the conversion can be for a full facility even if the facility has multiple resources that make up that single facility. Specifically, including text that refers to allowing up to full conversion or 100% conversion at the facility-level would be useful. It would be unfortunate if the language was interpreted to be applied at a resource-level for facilities that have multiple resources where it could be interpreted to only allow a single resource to fully convert to storage. We believe the intent is to allow each resource in a synchronous facility to fully convert to storage such that the entire facility can fully convert to storage, consequently we encourage the CAISO to ensure this is captured in the revisions.

11. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

Vistra supports this clarification to the rules.

12. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

Vistra supports this clarification to the rules.

13. Provide your organization’s concerns on deleting the Market Quality updates, as described in section 7:

Vistra strongly supports the CAISO removing this topic from the COMA initiative and thanks the CAISO for considering stakeholder feedback on this topic. Vistra recommends this issue be addressed in the Frequency Response Measures initiative currently under planned initiatives in Section 6.15 of the 2022 Policy Catalogue[1] scheduled for 2022 with a 2023 implementation timeline.

[1] http://www.caiso.com/InitiativeDocuments/Draft2022PolicyInitiativesCatalog.pdf

14. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

Vistra supports this item.

15. Provide your organization’s comments on Appendix A:

None currently.

16. Additional comments on the COMA Enhancements 2021 draft final proposal and draft tariff language:

None currently.