Comments on Track 3 Consolidated revised straw proposal

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a) Allocation Groups

ACP-California greatly appreciates CAISO’s efforts to revise the proposed TPD allocation groups and TPD allocation process to better address a number of the concerns and concepts that were put forward during the working group meetings. ACP-California applauds CAISO’s proposal to incorporate “Conditional Deliverability” into the process going forward, and to do so in a manner that will be easier to administer than the original high-level concept put forward by ACP-California during the working group meetings. Given the full scope of the proposal, and simplified approach, ACP-California supports the Conditional Deliverability allocation group and approach, even though the deliverability allocated to this group would be counted as allocated when determining the 150% zonal limits for future clusters.

In general, ACP-California supports CAISO’s proposal for the TPD allocation groups for Cluster 15 and future clusters and is optimistic this will provide a reasonable path for projects to balance the TPD allocation process with the commercial development/contracting process. And, as CAISO stated in the stakeholder meeting, this approach will put the “bilateral procurement process in the driver’s seat” allowing for the procurement process to determine the value of projects competing for a PPA, while providing a “line of sight” to deliverability if the resource is contracted. Providing projects an opportunity to attain “Conditional Deliverability” and then seek a PPA, should provide some of the upfront assurances developers and offtakers need to make these processes work in tandem and able to support project development.

Allowing Conditional Deliverability to receive a deliverability allocation and then requiring a PPA to retain it appears to be a reasonable approach. However, ACP-California highlights that, if there are just 12-months from the time of a Conditional Deliverability allocation is received until a signed PPA must be demonstrated (as would generally be the case in most cycles), that is an incredibly tight timeline for both developers and offtakers to market projects, negotiate, and execute a PPA. We encourage the CAISO to offer some leeway for projects that are in the process of negotiating a PPA, but have not signed it yet. Providing some flexibility on this front will help ensure that: 1) developers and LSEs aren’t overly rushed to sign PPAs with problematic terms and conditions just to meet a short turnaround to retain the TPD allocation and 2) viable projects don’t lose their chance at a standard TPD allocation just because they couldn’t get the PPA fully executed in time to retain their deliverability allocation. ACP-California suggests that after receiving a Conditional Deliverability allocation, a project should have to demonstrate it is “actively negotiating PPA terms” through an affidavit from the resource developer and offtaker. This would be sufficient to retain the Conditional Deliverability allocation for one more TPD allocation cycle, but in the subsequent cycle, an executed PPA would be required.

We appreciate CAISO’s thoughtful and creative approach to the TPD allocation process and are optimistic that, with some adjustments, the proposed process could work well for CAISO, developers, and offtakers.

c) Opportunities to seek TPD

Providing three opportunities for Cluster 15 and future clusters to secure a deliverability allocation, while also providing a chance (or two, as discussed above) for the Conditional Deliverability group to secure a PPA appears to strike a reasonable balance of keeping projects moving through the process while also providing enough time for development activity to occur.

As discussed more in response to question #2, for Cluster 14 and earlier, we encourage CAISO to consider whether it would be prudent to offer a modified TPD deferral option for (long lead-time and other) resources with active interconnection requests in Cluster 14 or earlier.

d) Eligibility of Energy Only projects, including technology additions

As far as ACP-California can tell, the prohibition on Energy Only projects ever seeking a deliverability allocation was first discussed and outlined by CAISO in the IPE Track 2 Final Addendum. And it appears that this policy was not well discussed – or understood – by at least a number of stakeholders. While we appreciate the CAISO’s interest in ensuring that projects don’t undermine the interconnection queue through an Energy-Only interconnection application that later seeks deliverability, ACP-California respectfully requests that CAISO reconsider this prohibition for projects that achieve commercial operation. In other words, we request that CAISO revise the IPE Track 2 policy and tariff language to allow for Energy Only projects that have achieved commercial operation to request a TPD allocation. It is appropriate for the CAISO to revisit this policy decision in IPE Track 3, given that this track (not Track 2) should have addressed modifications to the TPD allocation process and many stakeholders were not aware of this change to deliverability allocation eligibility for Energy Only that was made as part of the broader Track 2 filing.

We also point out that allowing Energy Only to compete for a TPD allocation is appropriate, and should not be expected to create queue management issues, when used only for the Commercial Operation group. The availability of this option is highly unlikely to be used by any resource developer simply to gain entry into the queue because the barriers, costs, and risks to actually executing on this option would be so high. To be successful in this “strategy” a project would have to come online at significant risk and cost before it could even seek a deliverability allocation. This is highly unlikely to be used as a strategy by any resource developers and, if CAISO were to allow it,  allowing projects that are online to compete for a deliverability allocation would be expected to be used infrequently, if at all, but could offer significant benefits.

Thus, in evaluating this request to revisit the options for Energy Only projects to seek deliverability, CAISO should consider the implications of not allowing a project that is online to seek a TPD allocation. Imagine a situation, in the future, where there is an Energy Only project that has achieved commercial operation and there is a tight market for Resource Adequacy. And, in this example, assume that the existing, online Energy Only project could contribute additional capacity to the RA market, if it could just secure a TPD allocation. Under the current rules put in place in Track 2, CAISO would not allow this resource to compete for a deliverability allocation at all. And yet, a different project early in the development cycle, could apply to enter the queue and secure the same deliverability. But it would take many years for that other project to achieve commercial operation and actually be able to contribute to the RA requirements of LSE. And during those years, the Energy Only project would be available (and could have been contributing to RA requirements of LSEs). Thus, in this hypothetical example, as a result of CAISO’s policy, the RA market would be shorter than it needed to be (and than it would have been if the online, Energy Only could have sought a deliverability allocation). If this delay in securing additional RA resources results in an LSE being short on its RA requirements, there could also be penalties that would apply to the LSE. All-in-all, the policy of never permitting Energy Only resources to seek deliverability only serves to potentially increase costs for meeting RA needs and is not a reasonable approach. Instead, the CAISO should allow Energy Only projects to compete for deliverability through the Commercial Operation group for not only Cluster 14, but also for Cluster 15 and beyond. We urge CAISO to revisit this policy decision that was incorporated into IPE Track 2 with highly limited stakeholder engagement and discussion.

e) Modifications to the TPD Scoring Criteria

ACP-California is still considering whether the proposed TPD scoring criteria are appropriate or if they require revision under the revised TPD allocation approach included in the Consolidated Revised Straw Proposal.

At this time, we simply highlight that CAISO will need to identify sufficient milestones for projects from LSE affiliates that are competing for a TPD allocation. There should be a significant requirement for these entities to demonstrate that their project is, in fact, on a commercial trajectory similar to a project with a signed PPA. And we encourage CAISO to hold additional discussions on this topic and to collect input on what might be appropriate for projects of LSE affiliates to move forward with securing a TPD allocation. 

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

ACP-CA generally supports the proposal put forward by the CAISO for Special Considerations for Long Lead-Time, Location Constrained Resources. We appreciate the CAISO’s thoughtful approach to ensuring that all resource types have a viable pathway through the interconnection process culminating in allocations of deliverability. This proposal builds on CAISO’s Track 2 revisions which adopted scoring criteria specific to long lead-time (LLT) resources. It also reflects the energy agencies’ joint acknowledgement of the importance of resource diversity, including advancing procurement, transmission planning, and interconnection processes for LLT resources, like Offshore Wind (OSW), Out-of-State (OOS) wind and geothermal resources.

As CAISO is aware, many long lead-time resources will seek PPAs through the Department of Water Resources’ (DWR) Central Procurement program, and for some, this is the only viable pathway to procurement in the next decade. The central procurement program will offer discrete, limited opportunities for certain long lead-time resources to secure a PPA. Further, the timelines for central procurement are uncertain and may shift as the process evolves. Thus, it is imperative that CAISO develop a process for allocating deliverability to these resources that includes appropriate flexibility to recognize this unique set of circumstances. We appreciate CAISO’s efforts to incorporate this flexibility and we hope CAISO recognizes that, as more details become available and DWR firms up the solicitation schedule, there may be a need to further incorporate changes to the deliverability process to appropriately reflect the central procurement process.[1]

a) Eligibility

In the Consolidated Straw Proposal (page 32), CAISO puts forward four criteria which it expects that interconnection customers would need to meet “some or all” of in order to determine eligibility for the long lead-time treatment in the deliverability allocation process. ACP-California offers the following comments on the eligibility criteria.

First, we generally support the development of criteria where resources would need to meet “all” of the identified criteria in order to be eligible for the proposed long lead-time treatment in the deliverability allocation process. This requirement would provide more clarity to prospective customers and ensure the LLT TPD deferral option is utilized as intended by the CAISO. With that in mind, we offer the following recommendations for each of the draft eligibility criteria in the Consolidated Straw Proposal.

On the first bullet (on page 32 of the Consolidated Straw Proposal), which defines long lead-time technologies, ACP-California recommends that the terminology not be overly restrictive to very specific sub-technology types. In the examples, CAISO lists “Advanced Geothermal” and it is important to note that this terminology, to geothermal developers, is very specific to a sub-technology type and wouldn’t include other geothermal technologies like Enhanced Geothermal. We recommend simply listing “geothermal” and other resources generically so as to not overly restrict which resources can qualify for long lead-time treatment. We also highlight that if CAISO adopts a requirement for customers to meet “all” of these criteria, there is less need for the CAISO to define technologies very specifically.

ACP-California generally supports the second eligibility bullet which requires the resource technology to be “location constrained.” This criteria aligns with the CAISO’s approach to reserving policy-driven transmission for specific location-constrained resources.

On the third bullet, CAISO must make modifications to ensure – as CAISO did in IPE Track 2 eligibility for long lead-time points – that all long lead-time resources that have available transmission (whether approved or existing) can qualify. And, if CAISO makes these eligibility criteria that resources must meet all of, we further recommend against limiting the type of transmission that an otherwise qualifying long lead-time resource depends upon. ACP-California suggests the following language for the third eligibility criteria, which aligns with the IPE Track 2 tariff language for long lead-time point allocation:

“The resource corresponds to approved network upgrades in the CAISO’s transmission plan specifically designed to meet the long lead-time resource needs of the local regulatory authority or does not require additional transmission capacity to be built.”

This modification to the third bullet of eligibility requirements aligns with IPE Phase 2 (and CAISO’s existing tariff language) while also providing assurances that both central coast OSW projects seeking to utilize, in part, existing transmission capacity and out of state wind utilizing existing import capability can qualify for long lead-time resource treatment.

Additionally, on the fourth bullet, our understanding is that the quantity of a specified long lead-time resources in an LRA plan (e.g., the TPP base case) will serve as a gating mechanism for location constrained, long-lead time resources first through the zonal scoring process, and then in their request to elect a TPD deferral. For the latter, we would advocate that the quantity of deliverability that a long lead-time customer seeks should be defined based on quantities in LRA plans at the time of the affidavit for the upcoming TPD allocation process, after the customer has reinitiated the TPD allocation process post-deferral. This would align with the CAISO’s process of reserving TPD on an on-going basis according to quantities of LLT/location-constrained resources in each TPP.

b) Extension to seek TPD

ACP-California generally supports the proposed approach for long lead-time resources to defer their chances for a TPD allocation and looks forward to working with the CAISO on specifics. Regarding the deferral period, we would recommend that for OSW, long duration storage, and geothermal resources, customers can elect to defer until one (1) year after the latest CPUC-authorized solicitation for that resource is completed by the central procurement entity[2] or until three (3) years before their anticipated commercial operation date, whichever is later. For example, for OSW resources, the CPUC has currently authorized procurement of up to 7.6 GW of OSW through a series of solicitations beginning in 2027, though solicitation timelines are ultimately up to DWR as the central procurement entity. Thus, if DWR closes its last solicitation in accordance with this authorized procurement in 2032, a project entering the queue and electing deferral could reinitiate the TPD process by 2033.

CAISO has also requested input on the “triggers” for releasing TPD that has been reserved for long lead-time resources should the policy direction and/or portfolios change. The CAISO should only release TPD from the reservation process when there is certainty it is no longer required for the long lead-time resources which are expected to require it. This could include the conclusion of central procurement solicitations and subsequent revisions to CPUC (or other LRA) portfolios with reduced quantities of the long lead-time resources in question.

c) Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

As we consider the recent interconnection process changes through IPE Track 2 and Order 2023, and their impact to long lead-time resources, we note the CAISO may need to consider certain exceptions to the proposed “unavoidable time in queue” requirement of seven (7) years which adopted as part of the IPE Phase 2 proposal. It is likely that an “unavoidable” seven-year restriction on time spent in the queue may not provide sufficient flexibility to accommodate a longer deferral process as contemplated in the Phase 3 Consolidated Straw Proposal.

We appreciate the questions posed by CAISO related to additional needs for long lead-time resources and we encourage CAISO to continue developing specific exceptions to the current interconnection and deliverability allocation processes for these resources, as the Consolidated Straw proposal put forward.

At this time, we do not have specific recommendations for changes to the study process, commercial readiness, or GIA deposits for long lead-time resources but may consider these questions further in later stakeholder opportunities. ACP-CA would flag that following the state’s 1373 central procurement process timelines would be generally helpful for aligning timelines for allocation of deliverability for LLT resources.

We also ask the CAISO to consider whether it would be prudent to offer a modified TPD deferral option for resources with active interconnection requests in Cluster 14 or earlier (e.g. those in Group D currently). We note there are more than 2,000 MW of long lead-time OSW capacity with Group D allocations that face impending TPD retention requirements that will be difficult or impossible for them to meet, given their required development timelines. Similarly, there are non-LLT resources that may have C14 active requests that have been substantially delayed due to delays in, and long development timelines for, network upgrades they depend upon. For both these resource types, we recommend the CAISO offer a specific time-limited TPD retention deferral opportunity whereby projects can defer for a minimum of five (5) years and a maximum of ten (10) years.[3] This would limit the deferral option to only those projects that require significant extra time due to factors outside their control, rather than those projects that simply want additional opportunities to secure a PPA. It would also limit the deferral option in time so as not to keep C14 or earlier projects with active requests pending for an indefinite amount of time.

Finally, given the numerous design questions raised in these comments and the importance of aligning the long lead-time TPD deferral process with the development timeline for these resources, including those that will depend on the newly formed but to-be-implemented central procurement process, we agree that CAISO workshops on this topic would be an appropriate next step.

[1] The CPUC’s Decision 24-08-064 for Determining Need for Centralized Procurement of Long Lead-Time Resources, issued in R. 20-05-003, August 29, 2024, notes a potential DWR solicitation timeline for offshore wind with a first solicitation in late-2027, with contracts going to the CPUC for approval in mid-2028; a second solicitation in late 2029, with contracts going to the CPUC for approval in mid-2030; and a third solicitation in early 2030 with contracts seeking CPUC approval in late-2030.

[2] As authorized by the CPUC in accordance with AB 1373 (2023) requirements.

[3] With a longer potential timeline, if necessary, for projects dependent on the AB 1373 solicitation process.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

As with past iterations, ACP-California generally supports this proposal and encourages the CAISO to continue to provide additional details on the implementation process for intra-cluster prioritization. 

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comments at this time. 

5. Please provide any additional feedback:

No additional comments at this time. 

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a. Allocation Groups 

AES is not opposed to reducing the number of allocation groups to three, including the removal of the shortlisted group. However, AES opposes the Commercial Operation group if it excludes operational Energy Only projects. As discussed below, CAISO should clarify within the proposal whether operational Energy Only projects can seek transmission plan deliverability (TPD). While CAISO staff indicated during the stakeholder call that Energy Only projects may never seek TPD, the revised straw proposal states, “These projects will only be allowed to obtain TPD after going into commercial operation.”¹   

AES seeks clarification regarding priority group 1, which is similar to the existing PPA group.  AES seeks clarity if there are any retention requirements associated with group 1. For example, assume a PPA was executed with an offtaker for a project who then receives TPD under group 1. However, if the PPA was canceled, are there requirements for the project to retain its TPD allocation under group 1? In addition, are there restrictions with the size of LSE to the size of projects that can be contracted with? Finally, AES seeks clarity on whether the MWs contracted under the PPA must be congruent to the size of the project to qualify for group 1.  Similarly, if a project was allocated TPD in the conditional group 3, would the PPA required to retain its TPD by the following TPD cycle must have the entire project size contracted? 

AES seeks clarity on the treatment of projects that only receive partial TPD by the time their three attempts for TPD allocation have been reached. The CAISO should clarify whether projects would automatically or would require an MMA to downsize to the portion of the project receiving TPD. 

b. Multi-fuel projects receiving an allocation with PPAs 

AES recommends some flexibility for parties to transfer the received TPD from one fuel type to another fuel type should TPD only be awarded to one fuel type. PPA structures vary, and flexibility allows parties to identify the best pathway forward if only one portion of a multi-fuel project receives TPD.  In addition, the CAISO should also clarify whether the portion that doesn’t receive TPD can continue to try in the future allocation cycle to receive TPD. 

c. Opportunities to seek TPD 

1. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. 

AES is not necessarily opposed to the proposed three attempts to receive TPD allocation before being withdrawn from the queue, but is concerned that delayed long lead time DNUs and RNUs approved in the TPP may become the impediment for projects to receive TPD. The CAISO should continue to work for solutions to provide interim TPD for projects behind TPP-approved DNUs and RNUs so that they are not withdrawn before the three opportunities rule. 

The CAISO should preserve the opportunity for projects to seek an allocation during the TPD cycle of the interconnection facilities study through demonstration of a PPA as long as it does not eliminate one of the three opportunities to receive TPD. AES recommends aligning the affidavit due date to align with the completion of the interconnection facilities study. 

d. Eligibility of Energy Only projects, including technology additions  

1. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. 

AES seeks clarity on the CAISO’s proposal related to the Commercial Operation Group and Energy Only projects. The Revised Straw Proposal states that the CAISO proposes to reduce the allocation groups to three with the “2nd priority group as, “the Commercial Operation group (formerly group C) for eligible Energy Only projects that go into commercial operation.”² However at the November 15, 2024 stakeholder meeting, the CAISO verbally stated that Energy Only projects cannot seek TPD, even after reaching commercial operations. AES urges the CAISO to provide Energy Only projects the opportunity to seek a TPD allocation after reaching commercial operations. If the CAISO’s goal is to provide TPD to the most viable projects, Energy Only projects, by coming online, meet this goal. The opportunity to request TPD for operational Energy Only projects should be reserved. Similarly treated, pre-Cluster 15 projects should also be able to seek TPD through the commercial operation group after the 2025 TPD allocation cycle. Pre-Cluster 15 projects entered the queue with certain assumptions of TPD allocation policies that should not be changed. 

The CAISO should clarify the transferability of TPD as related to technology additions through the MMA process. The proposal currently states, “[a]ny technology additions (via MMA or Post-COD mod) will be added as EO and may only seek TPD through the Commercial Operation group.”³ The CAISO should clarify whether: (1) a project with the same queue position can transfer its TPD to the technology addition; and (2) a project from a different queue position can transfer TPD to the technology addition. 

e. Modifications to the TPD scoring criteria 

AES encourages the CAISO to consider the concern of early GIA commitments prior to being allocated TPD in a separate track. While AES understands that FERC Order 2023 requires GIA execution and commercial readiness deposits within a certain timeframe after the publication of the interconnection facilities studies, it is unclear to AES what the GIA will entail without a TPD allocation. Given the FERC Order 2023 timelines, a project must execute its GIA and pay a commercial readiness deposit of 20% Network Upgrades prior years before a project may be allocated TPD. The project will therefore be subject to immense financial risk without TPD certainty. This differs from today’s practice where projects do not typically execute GIAs until after TPD allocations. At minimum, the CAISO should clarify what the GIA will encompass and consider a deviation to Order 2023 given CAISO’s unique TPD procedures. 

¹ Revised Straw Proposal, p. 14. 

² Revised Straw Proposal, p. 17. 

³ Revised Straw Proposal Presentation, slide 12. 

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

AES has no comment. 

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

?AES supports the proposal’s intention to provide a quicker pathway for projects to come online sooner, prior to the completion of large Reliability Network Upgrades (RNUs). AES supports the 97% threshold for short circuit current to continue to require a limited operation study.  AES seeks clarity on implementation. Specifically, will this be evaluated on a cluster-by-cluster basis (e.g. RNUs associated with Cluster 14, RNUs associated with Cluster 15)? The CAISO should provide a schedule of: (1) when the considered RNUs would be posted on the CAISO website, (2) when the affidavit is due; (3) when results of the assessment are expected. The CAISO should also publicly post the study for stakeholders to reference. 

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

?AES urges the CAISO to identify opportunities for projects behind long lead time DNUs and RNUs to receive interim TPD prior to withdrawal after the three TPD allocation opportunities. 

? 

5. Please provide any additional feedback:

?The CAISO should grandfather parking for pre-Cluster 15 projects. Projects prior to cluster 15 entered the queue with an understanding of prior tariff rules and made business decisions around those rules. At minimum, pre-Cluster 15 projects should have one more opportunity to park prior to elimination. For Cluster 15 and beyond, AES is not opposed to removing parking. In addition, for existing parked projects, the CAISO should clarify the new posting due dates if the 2025 TPD allocation cycle’s affidavit due dates are pushed to September 2025. 

? 

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

AReM has no comments at this time. 

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

AReM appreciates CAISO’s continued transparency regarding the issue of transmission deliverability reservations for long lead-time (“LLT”) resources. AReM notes that long-duration energy storage is now considered an LLT resource per the latest straw proposal. Given the California Public Utilities Commission (“CPUC”) has used different definitions of what constitutes long-duration storage, AReM seeks more clarity regarding what types of storage are eligible. For instance, the CPUC ordered load-serving entities to procure 8-hour or longer duration storage, but the Department of Water Resources (“DWR”) was directed to procure 12-hour or longer duration storage. The straw proposal also lists location constraints as a consideration, but whereas pumped storage technologies have location constraints, battery storage would generally not. AReM seeks a better understanding of whether and under what conditions long-duration battery storage may qualify for transmission deliverability reservations.

CAISO also seeks feedback on time limits or triggers that would release capacity from the reservation process if generation or transmission failed to materialize. AReM certainly supports the need for rigor in this process such that a resource does not maintain deliverability reservations forever. Although AReM does not offer a specific proposal for a time limit or trigger, AReM supports the concept. The main point of the need to overhaul the interconnection process was to ensure CAISO can support the increased volume of procurement needed to meet state policy regarding green energy development. Allowing resources to sit in the queue indefinitely would undermine that process. AReM also seeks clarification regarding whether and how DWR procurement would be considered in that process. For instance, if DWR procured less than the amount of LLT capacity in the CPUC transmission planning process portfolio, would that trigger a reduction in the amount of capacity deliverability reserved by the CAISO for LLT resources?

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

AReM has no comments at this time.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

AReM has no comments at this time.

5. Please provide any additional feedback:

AReM has no additional feedback at this time.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

The California Community Choice Association (CalCCA) appreciates the opportunity to provide comments on the California Independent System Operator’s (CAISO) Track 3 Revised Straw Proposal. The transmission plan deliverability (TPD) allocation process is a critical part of project development because resources must obtain TPD to provide resource adequacy (RA). The CAISO proposes to redefine the TPD allocation groups as: (1) the power purchase agreement (PPA) group; (2) the commercial operation group; and (3) the conditional allocation group. The CAISO’s proposal would provide projects with three consecutive opportunities to seek a TPD allocation or retain a conditional TPD allocation, noting opportunities to seek and retain allocations of TPD are typically done on an annual basis but could be more than one year apart.[1]

CalCCA is still developing a position on this proposal and seeks clarification on the timing of the three opportunities to seek a TPD allocation for projects with and without conditional deliverability allocations after the first opportunity. The proposal states:

the first opportunity will be in the TPD allocation request window following the interconnection customer’s receipt of its interconnection facilities study report. After the third opportunity to seek an allocation, projects that have not received an allocation will be withdrawn. Projects that do receive an allocation through the Conditional group, but are unable to retain their allocation in the next request window by demonstrating an eligible PPA will be withdrawn.[2]

Applying the proposal to the Cluster 15 study timeline[3] appears to result in the following timeline:

• Facilities Study Report: November 2026
• Beginning of first opportunity / TPD Affidavits: March 2027
• For projects with conditional deliverability after first opportunity:
  • Deadline to show a PPA or withdraw: March 2028[4]
• For projects without conditional deliverability after first opportunity:
  • Beginning of second opportunity / TPD Affidavits: March 2028
• For projects with conditional deliverability after second opportunity:
  • Deadline to show a PPA or withdraw: March 2029
• For projects without conditional deliverability after second opportunity:
  • Beginning of third opportunity / TPD Affidavits: March 2029

Therefore, projects appear to have roughly one and half years after receiving the facilities study report to demonstrate a PPA or be withdrawn if a project receives a conditional deliverability allocation. If a project does not receive a conditional deliverability allocation, it will also have until March 2028 to either sign a PPA to get into the PPA group or seek conditional deliverability for its second opportunity. In the next iteration of the proposal, the CAISO should confirm or correct this understanding with a timeline or flow chart for the three opportunities using the Cluster 15 schedule, including the steps for projects that do and do not receive conditional allocations. This clarification will help stakeholders develop positions on the proposal.

CalCCA appreciates the CAISO’s responsiveness to stakeholder feedback in revising the PPA status points allocation criteria in Table 2 of the Straw Proposal. Categorizing projects based upon whether its PPA is with an off taker that has a RA obligation will result in a meaningful differentiation of projects that meet versus exceed the minimum requirement, because it bases its ranking on RA obligations which drive the need for TPD. It will also provide for uniform treatment of all PPAs with load-serving entities.

[1]            See Straw Proposal at 19.

[2]            Ibid.

[3]            https://www.caiso.com/documents/resource-interconnection-standards-interconnection-study-timeline.xlsx.

[4]            For this example, assume one year between successive opportunities to seek and retain an allocation of TPD for simplicity, although they may be more than one year apart in practice.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

CalCCA agrees with the CAISO that it will be necessary to allocate TPD to long-lead time (LLT) resources such as offshore wind, out-of-state wind, and geothermal that currently have longer project development cycles that may not be compatible with the updated TPD allocation process outlined in Section 2. The CAISO’s straw proposal for allowing eligible resources an extension to seek TPD allocations can efficiently and equitably meet this need with additional work to define the details around: (1) how much TPD can be reserved for this purpose; and (2) when TPD that is reserved for LLT resources would be released after a certain time if it goes unused.

The straw proposal recognizes the need to release reserved TPD after a certain time, stating:

The ISO will have to establish a deadline for specified projects to begin seeking TPD for each cluster, which should align with the timeframe for the resource coming online in portfolios. The ISO will also have to develop conditions or a trigger mechanism for releasing reserved TPD if generation or transmission does not materialize. Such conditions would need to be driven by the transmission planning process, such as changes to the policy scenarios or canceling transmission projects.[1]

As the CAISO further defines this process, it should avoid over-reserving for LLT, or maintaining reservations for projects that prove unviable, as TPD is “inherently finite.”[2] The process for allocating TPD to LLT resources should maintain the incentive for resources to seek a PPA as soon as practical so that LLT resources with reserved TPD do not retain it without a viable path to using it. The process for LLT resources with reserved TPD should maintain a clear deadline for projects without a PPA to be removed from the queue and the TPD released to make room for other projects to seek an allocation.

[1]            Straw Proposal at 32-33.

[2]            Straw Proposal at 25.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

CalCCA supports the CAISO’s proposal to allow generators to interconnect up to an amount that will not trigger the need for the LLT short circuit upgrade or other reliability network upgrades. This proposal will provide opportunities for projects to come online and obtain deliverability more quickly when there is headroom to do so, helping to alleviate the current crisis of interconnection capacity scarcity.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

CalCCA has no comments at this time.

5. Please provide any additional feedback:

CalCCA has no comments at this time.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

CPUC staff supports CAISO’s proposed changes to reduce the number of groups and clarify the priorities for deliverability allocation.  We favor prioritizing the awarding of deliverability to projects that have a signed PPA, which is consistent with this CAISO proposal, and giving priority within the Commercial Operation group to those projects that demonstrate having a Resource Adequacy contract, though we suggest clarifying how a project could have a RA contract without already establishing deliverability. Overall, we believe these sensible improvements to Cluster 15 and beyond will simplify and enhance the allocation process and more closely match LSE preferences.

We believe this CAISO proposal to simplify the prioritizing of projects offers reasonable opportunity for projects to seek deliverability in a timeframe that generally matches the expected commercial operation of the project. 

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

CPUC staff appreciate CAISO’s proposal for unique treatment of long lead-time resources that would allow extended time to seek a deliverability allocation.  CPUC staff strongly support the continued preservation and retention of deliverability for certain long lead-time resources as identified by the CPUC and other local regulatory authorities through their engagement with CAISO’s Transmission Planning Process. 

The specific resource types, locations, and the amounts eligible to utilize such deliverability, as well as when such reservations end, should be based on coordination with the CPUC and local regulatory authorities to ensure alignment with current policy and procurement needs. To enable that, CPUC staff suggest that the CPUC and local regulatory authorities could provide direct and updated guidance to the CAISO in their annual transmittal of portfolios and policy goals to the CAISO for the TPP or similarly appropriate venue. 

CPUC staff also note the potential need and benefits to have different eligibility requirements compared to those established for the interconnection scoring criteria. For example, a long lead-time resource that is fairly flexible in geographic siting locations should benefit from the interconnection scoring criteria and also the potential extensions for long lead-time resources; however, the preservation of deliverability may not necessarily be required.
 
CPUC staff generally support the goals of the proposed changes to enable long lead-time resources to extend their time in the queue. CPUC staff, however, are concerned about options for extensions on seeking TPD or postponements of commercial readiness deposits that encourage speculative queue applications that enable projects to enter well ahead of time and potentially monopolize reserved TPD. We are particularly concerned about the potential cost impacts to ratepayers if such scenarios were to occur, and encourage exploring ideas to mitigate this risk whilst still giving project developers visibility of the pathway to being allocated deliverability.

CPUC staff recognize that in waiting to award deliverability to projects with PPAs could potentially hinder the development and construction of upgrades historically viewed as interconnection-related upgrades and paid for by the interconnection customer that are larger or have long lead-times themselves. One potential option is that such upgrades be identified and developed through the policy-driven TPP study process. CPUC staff support additional discussions, if needed, to further develop this portion of the proposal.
 

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

CPUC staff generally support this proposal because it likely could enable some projects behind upgrades with long construction times to come online with some deliverability even before the upgrade is complete. We recognize that the cost responsibilities for these reliability network upgrades would not be affected, so this process could potentially reduce costs, if other projects behind the upgrade withdraw and the upgrade becomes no longer necessary.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

CPUC staff have no comment on this proposal to maintain the current priorities for interim deliverability allocation.

5. Please provide any additional feedback:

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a. Allocation Groups

For allocating TPD capacity, CAISO has proposed prioritizing projects as follows:

1. Those that meet existing PPA eligibility requirements
2. Eligible projects in commercial operation
3. Non-operational projects without PPAs (“conditional group projects”). 

CalWEA recommends that the highest priority be placed on operational projects, including those that entered the queue with an EO request (as opposed to current policy that prohibits such projects from ever attaining FCD status).  Second priority should be placed on projects meeting PPA eligibility requirements. Third priority should be placed on “conditional group projects,” however, among conditional group projects, those on procurement shortlists should be prioritized over other projects.

CalWEA’s proposed order of priority promotes timely attainment of reliability goals at the lowest cost to ratepayers.  Regarding EO resources, CAISO’s proposal that these resources never be given an opportunity to seek FCDS is at odds with the current lack of available substitute RA supply, concerns over the ability of the system to meet reliability criteria, and the tightening of available RA supply post-2028 due to the use of the UCAP methodology rather than ICAP.  FERC has held that RA revenues are an appropriate incentive for market participants to rely on for market entry and exit decisions.  And while CAISO and the CPUC intend that their coordinated transmission planning process will match RA needs, enabling operational EO resources to attain FCDS would nevertheless bolster the RA market, with benefits accruing to ratepayers, at a challenging and uncertain time. 

b. Multi-fuel projects receiving an allocation with PPAs.

No comments at this time.

c. Opportunities to seek TPD. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA.

CalWEA does not support creating an additional TPD opportunity during the facilities study for PPA group projects as it would create an opportunity for unfair competitive advantage for utility-owned projects. Utilities may have early access to facilities study results, providing an opportunity to favor utility-owned projects over the projects of independent power producers.

On a related topic, projects seeking TPD capacity should be allowed to convert to EO after any of the three cycles and continue towards completion if they have met all the requirements of the GIA.  If they decide to convert to EO, their postings for LDNUs should be released. 

d. Eligibility of Energy Only projects, including technology additions. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle.

All EO projects should be eligible to seek and receive TPD.

Requiring a developer to obtain a PPA to add EO storage to a project is impractical and puts developers at the mercy of LSEs.  An EO addition to an existing project should be able to remain in the queue if it meets the requirements of its amended GIA. 

e. Modifications to the TPD scoring criteria

As with the allocation groups, shortlisted projects should have higher priority within the conditional group.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

a. Eligibility

Eligibility should require "all" rather than "some or all" of the list of criteria.  However, criteria 1 and 2 – “long lead-time technology” and “location-constrained” – should be condensed as “location constrained,” which is more precise. 

In-state onshore wind and all geothermal energy resources should be included in the list of resources, and long-duration storage resources should be limited to location-constrained types.  The list can then serve as an exclusive list rather than a series of examples.  (Alternatively, regarding wind energy, the list can simply include “wind energy” rather than listing three locational types of wind energy.  If “in-state” is used, it should be defined as “CAISO-interconnected” wind energy.)

The third criterion should be restated as “Resources included in CPUC or LRAs’ portfolios at a specific busbar that are dependent on existing or TPP-approved transmission lines, with explicit guidance from the CPUC or LRAs regarding TPD capacity reservation.”  The policy should be busbar specific, consistent with CPUC/LRA portfolios. All new resources that are dependent on policy-approved transmission will be dependent also on portions of the existing transmission grid, which CAISO has recognized in its capacity reservation proposal.  Thus, there is no reason to exclude from this policy resources in LRA portfolios that are dependent solely on existing transmission capacity. 

Rather than requiring resources to “Enter the queue requesting appropriate amount of capacity per LRA's resource portfolio,” all location-constrained resources at specific busbars should be eligible until TPD allocation occurs at which time allocation can be based on scoring.

b. Extension to seek TPD

Financial security postings for LLT (better termed “location constrained”) resources should be tied to transmission development, aligning postings with actual transmission procurement and construction activities to assure financiers that construction will occur, thus reducing risk.  For example, postings could be required when orders for breakers are placed, and when actual construction activities commence. (This same policy should apply to non-location-constrained resources that are awaiting transmission.)

With its recommended changes, CalWEA does not see the need for a discrete interconnection process for location-constrained resources.

c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

No comments at this time.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

In addition to using TPD scoring criteria for the purpose of intra-cluster prioritization for the use of existing headroom, CalWEA recommends adding criteria related to a project’s development activities as follows:  

• 5 points should be offered to projects for having 90% of engineering design completed
• 10 points should be offered to projects for having a purchase order of resource equipment with project specificity
• 7 points should be offered to projects for having a purchase order of resource equipment without project specificity.

The criteria should require Interconnection Customers to demonstrate every six months that they continue to meet the criteria that their eligibility was based on.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No changes are being proposed, nor should changes to current practice be considered.

5. Please provide any additional feedback:

Regarding the affidavit for seeking or retaining TPD capacity, CAISO should add some flexibility, enabling the eligible project offtaker to provide a formal letter attesting that a PPA is awaiting final approvals and will be executed within a month of the affidavit submittal deadline.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

Opportunities to seek TPD

Calpine supports the proposal to allow at least three consecutive “allocation opportunities” for Cluster 15 and beyond, beginning when the Facilities Study is completed. However as discussed below, if the Facilities Study for any resource includes long-lead equipment, the Interconnection Customer (IC) should have the opportunity to defer the first of those three opportunities or have the option to preserve conditional deliverability beyond the third year to a time closer to the in-service date of the long lead equipment.

At the conclusion of the allocation window, Calpine supports forced-queue-withdrawal rather than conversion to Energy-Only deliverability status.  The queue currently contains approximately 10,000 MW of energy-only projects, many of which do not seem to be progressing – or even executing LGIAs. These projects likely are causing other more-viable projects to be exposed to the cost and construction delays of Reliability Network upgrades that will likely not be needed but for stalled EO projects.   

In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA.

Calpine does not support the proposal to allow an extraordinary opportunity to seek TPD prior to, or during the Facilities Study process. It creates an unjust priority within the same group of clustered Interconnection Customers.   

Eligibility of Energy Only projects, including technology additions.

Calpine strongly supports the proposal to allow all pre-C15 Energy-Only projects only one more opportunity to obtain TPD.  Based on the current queue, there are approximately 60 EO projects (100 if partial deliverability is included) representing over 10,000 MW (20,000 with PCDS).  Of those EO projects, only about one-third have executed LGIAs (20). 

Nonetheless, these EO projects could be forestalling the CODs of other, more viable projects because the stalled EO projects may require RNUs that, as described below, are significantly backordered – with delivery dates pushing CODs out 4-7 years.  Absent these RNU delays, other CPUC MTR projects may be able to move ahead more expeditiously.

The CAISO, in supporting this proposal, should review the extent to which RNUs (or other upgrades) associated with EO projects are delaying subsequently queued projects.    

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

Eligibility

First and foremost, Calpine asserts that any project that contributes to the State’s ambitious carbon reduction goals and requires long-lead time upgrades should be allowed special consideration. The description on page 32 of the Revised Straw Proposal (RSP) of the resources that qualify for special consideration is broad and somewhat ambiguous. Perhaps rather, the ISO should consider a simpler, yet transparent and non-discriminatory basis for special considerations that ties TPP planning to actual interconnection study results.   

For example, the CPUC mapping creates the roadmap for transmission investment. That investment takes the form of policy-driven upgrades which support the specific POIs of the resources that the CPUC maps.  If, in fact, deliverability is created by long-lead transmission investments, that deliverability should be identified in the TPP and preserved for any resource that meets the CPUC’s bus-bar mapping in the targeted area. Special considerations should apply to all targeted resources.  

Second, it appears, based on p24 of the RSP that the CAISO has preserved nearly 9000 MW of TPD for various out-of-state and off-shore wind projects. Indeed, while helpful now, this information should be transparently disclosed when it is reserved in the TPP /TPD process. That is, each time a policy-driven upgrade is approved, the CAISO should identify the deliverability that will be withheld, the POIs that will benefit from this deliverability and as discussed below, the conditions under which that capacity might be later released.    

Third, to our knowledge, the deliverability preservations – particularly to support out-of-state wind east of California – do not include transmission upgrades within the State. Calpine is unaware of any study that demonstrates that these incremental flows will not negatively impact the deliverability of existing resources inside the State.  This crucial matter should be discussed, and if necessary, studied in the next draft.

Finally, the tariff requires that MIC allocations be performed on an annual basis.  There are not provisions to allow a multi-decade allocation of MIC to new interconnecting transmission.  Perhaps more clarity on the CAISO’s envisioned allocation of intertie capacity could be included in the next draft.   

Extension to seek TPD

The RSP suggests that long-lead resources be given an “option” to take additional time to seek TPD.  Calpine does not object conceptually to giving any resource that triggers – or is dependent on – long-lead interconnection facilities some reasonable options.  For example, if a storage project at a CPUC mapped location is dependent on a TPP deliverability upgrade or a long-lead RNU, it should be given the option to preserve that deliverability or delay its application for TPD. 

Calpine also agrees that the CAISO and stakeholders will need to develop triggering mechanisms to allow the release of preserved deliverability.  For example, in the last TPP, the CAISO approved billions of dollars in investment to support off-shore wind in the Humboldt area.  As a result, the CAISO withheld roughly 1600 MW of deliverability in te latest TPD allocation.  Collectively, we should discuss the conditions under which that preserved deliverability, as well as the deliverability preserved for other aspirational resources, might be released  for future allocations. 

Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

Calpine suggests that a separate queue for long-lead resources seems to introduce the real possibility of unjust and inequal treatment.  Without more detail on what is proposed, we cannot comment substantively.

Calpine does not support extensions for commercial readiness or GIA deposits for long-lead resources.  However, if the supporting TPD upgrades are canceled beyond the reasonabe control of the Interconnection Customer, perhaps special consideration on refundability could be considered.  

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

Calpine supports the proposal to identify and allocate existing RNU headroom to the most viable and deliverable projects.

However, most importantly, Calpine believes that the CAISO should do what it can to stabilize, rather than disrupt, the PPA market.  As described below, commercial transactions may be facing strong headwinds due to changes in the Administration and supply chain delays. 

Above all, and for the foreseeable future, the CAISO should reconsider and perhaps, not move forward with its Track 2 “Queue Maintenance” proposal which places immutable deadlines on life-in-queue and the continuous need to demonstrate commercial viability.  Specifically, given the potential turmoil in the PPA market, projects that lose their PPA due to these headwinds should be granted a time-limited amnesty to renegotiate PPAs before losing their deliverability. 

As the CAISO weighs further changes to the Interconnection Process it should countenance  the real risk of delayed CODs and increasing costs.  Even without further IPE changes, these trends will create havoc in the PPA market, where delay damages could mount leading to possible breach or default.  Adding pressure, e.g. with immutable deliverability deadlines or unbending PPA requirements, will only add to the failure rate.  PPA failures will threaten MTR targets and progress toward the States goals. 

The first disruption is related to supply chain.  The delivery times for interconnection equipment necessary for any resource addition are growing.  Transformers, reactors, and breakers of all transmission voltages are currently experiencing 4-to-5-year delivery delays.  This, in combination with capital allocation decisions by LSEs that prioritized system hardening, undergrounding and other wildfire responses have resulted in deferring necessary upgrades (including overstressed breakers and other precursor network upgrades) and delaying CODs by as much as 6 to 7 years. 

The second disruption is the change in Administration and the real likelihood of increased costs for imported goods through the imposition of higher trade tariffs.  Unless panels, batteries, inverters, breakers and transformers are on ships steaming toward CA ports, prices are likely to rise, potentially substantially.  Domestic production is not poised to replace offshore orders – at least for several years. 

Adding pressure to PPAs as the unbending form of commercial viability will do nothing to accelerate accomplishment of the State’s carbon reduction goals.  Given these trends, it is more likely that revoking deliverability allocations upon PPA failure will merely shift these problems to a new group of resources that will face even more daunting delivery and pricing challenges.  As such, for resource that have been granted deliverability, upon failure of a PPA, the CAISO should consider at least a one deliverability-cycle amnesty period during which its allocation is preserved and the project is not withdrawn or converted to energy-only. 

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comment

5. Please provide any additional feedback:

No comment

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

The California Energy Storage Alliance (CESA) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 3 revised straw proposal.

1. Allocation groups:  CESA supports consolidating short-list and group D into a single “conditional” group.  Since CASIO has stated that very few energy only projects have reached commercial operation, the change effectively simplifies the TPD allocation process.  If a project has a power purchase agreement, it can receive and retain TPD.  If the project does not have a power purchase agreement within the three-year window, it cannot achieve deliverability and will convert to energy only or withdraw.
2. Multi-fuel projects: CESA supports the requirement that if FCDS is allocated to a portion of the multi-fuel project, the TPD must be accepted by that particular component.   CESA requests clarification on the example provided in the revised straw proposal.  If the project is still within the three-year TPD window, can the solar resource seek TPD in the next TPD allocation?
3. Opportunities to seek TPD: CESA does not oppose a three-year TPD allocation window but remains concerned that while directionally positive this could result in the window expiring before developers and load serving entities are able to enter into power purchase agreements if the earliest commercial operating dates for the projects are beyond the CPUC’s procurement requirements.  CAISO’s revised straw proposal states that the three-year TPD allocation window will begin after facilities studies are completed.  CAISO seeks feedback if an interconnection customer should be allowed to request TPD prior to the interconnection study being completed.  CESA requests CAISO clarify if this provides the interconnection customer with an additional TPD request prior to the start of its three-year window.  CAISO should evaluate if there is the ability to start the three-year window a year or two following the facilities study if the commercial operation date of the project based on phase 2 studies is greater than 5 years from the start of the three-year TPD allocation window.  This would provide projects with long-lead time network upgrades to seek a power purchase agreement during a timeframe load serving entities are procuring new resource adequacy capacity.  CESA also seeks clarity on the allocation of TPD and power purchase agreement retention criteria.  If a project does not receive a TPD allocation during the three-year window, is the project automatically withdrawn or converted to energy only?  If a project received TPD, but its power purchase agreement was cancelled after the three-year window, will the project be automatically withdrawn or converted to energy only?
4. Eligibility of energy only projects: CESA supports providing energy only projects in cluster 14 and earlier an additional opportunity to seek TPD through the power purchase agreement or short-list group in the 2025 TPD allocation process.  Then starting with the 2027 TPD allocation process, all energy only projects must seek TPD through the commercial operation group.  CESA seeks clarity if a project that entered the queue as energy only and those projects seeking full capacity deliverability status but were unsuccessful during the three-year TPD allocation window would equally be allowed to seek a TPD allocation through the commercial operation group.  Does CAISO need to make tariff changes to allow projects that entered the queue as energy only to seek deliverability through the commercial operation group?
5. Modifications to the TPD scoring criteria: CESA supports the additional scoring criteria within the commercial operation group.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

1. Eligibility: CESA supports defining eligibility consistent with the CPUC’s definition of long lead-time resources considered for central procurement.
2. Extension to seek TPD: CESA supports allowing long lead-time resources with an option to take additional time to seek TPD to better align with commercial milestones and procurement but notes this is the same issue as other technology-based projects encounter with long-lead time network upgrades.  CESA recommends the CAISO look at the issue less from the technology type but rather the time at which the transmission upgrades will be in place which is within the time window (5 years) in which a power purchase agreement for resource adequacy could be entered into between a load serving entity and the project.
3. Broader procedural changes: See respond (b) above.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

CESA supports the proposal’s intention to provide a quicker pathway for projects to come online sooner, prior to completion of large reliability network upgrades (RNUs). CESA supports the 97% threshold for short circuit current to continue to require a limited operation study.  CESA also supports using the same group and intra-group scoring criteria for TPD allocation to apply to intra-cluster prioritization. 

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

CESA supports not changing the current interim deliverability allocation process.  CESA should work with the CPUC to identify opportunities for projects to meet resource adequacy requirements prior to all network upgrades being completed by increasing the available quantity of interim deliverability. 

5. Please provide any additional feedback:

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a. Allocation Groups

Clearway supports the “conditional allocation” in concept but notes that the requirement to show a PPA in the next TPD allocation cycle may not be feasible for projects behind long-lead network upgrades. Clearway appreciates the CAISO’s acknowledgment of this timing issue in the Revised Straw Proposal (p. 8) and during stakeholder meetings. However, there is still no solution on the table to allow projects in this situation to move forward. Clearway hopes to see a procurement pathway created for projects behind long-lead-time network upgrades, but such a pathway does not exist yet. Today many of these “conditional allocation” projects will be in the same position as the formally designated “long lead time resources,” and will similarly need flexibility in when to begin seeking a TPD allocation.

d. Eligibility of Energy Only projects

The Revised Straw Proposal leaves some ambiguity about which Energy Only projects would be eligible to seek TPD after reaching commercial operation: pre-Cluster 15 projects only, both pre- and post-Cluster 15 projects, or none. Clearway’s position is that all EO projects that have reached commercial operation should be eligible to seek TPD. These projects have demonstrated that they are viable and should have a path to TPD.

Projects that do not receive TPD should be allowed to remain in the queue as Energy Only and should not be automatically withdrawn. California will need EO PV resources to meet its clean energy needs in the future, as demonstrated by the resource portfolios adopted by the CPUC. It is getting more difficult to find sites that are viable for PV+BESS (sites with both available TPD and available land), so PV development is likely to remain focused in more remote areas while energy storage resources can be located closer to load. This dynamic can be seen in the CPUC’s resource portfolios and reflects the reality of project development.

Instead of automatically withdrawing EO projects from the queue, CAISO should rely on the CVC criteria that requires a PPA after 7 years in the queue; this will force EO projects to show EO PPAs to remain in the queue. This 7-year period will show whether the project is desirable to the market without TPD, and if the project cannot obtain an EO PPA after 7 years, the CVC criteria will remove the project from the queue.

Technology additions

Clearway disagrees with the CAISO’s position that the system no longer has an “urgent need for new resources” (p. 15) that can be met with technology additions to existing resources. Energy storage retrofits to operating renewable resources are a uniquely efficient way to meet the evolving needs of the grid. The ISO has not justified its statement that “that need has been fulfilled.” Looking at the pace of new resource additions called for in the CPUC IRP portfolios, as well as the very long timelines for new projects to interconnect and receive FCDS, it is clear that there is still a need for shovel-ready projects that can be built quickly and provide RA. Specifically, increasing curtailment of renewable energy resources* shows the value in adding storage to operating standalone renewable generators.

* https://www.caiso.com/about/our-business/managing-the-evolving-grid

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

a. Eligibility

Given the potential impact of carveouts and reservations for LLT resources, there needs to be more clarity on what qualifies as a LLT resource. The criteria listed in the Revised Straw Proposal (p. 32) are not specifically defined. For example, all utility-scale PV and wind resources are “location-constrained,” but it is clear from context that the CAISO is not proposing to treat all PV and wind resources as LLT resources. Additionally, there is a lack of clarity as to which long-duration energy storage technologies are eligible. The CPUC has defined long-duration energy storage differently in different policy contexts. Decision 21-06-035, authorizing midterm reliability procurement, defines “long-duration storage” as any technology “providing 8 hours of storage or more,” but Decision 24-08-064, determining the need for central procurement of certain technologies, defines “long-duration energy storage” for purpose of that procurement as technologies other than lithium-ion batteries providing 12 hours of storage or more. The CAISO should provide more specific rules about which long-duration energy storage projects would qualify for LLT treatment in the TPD allocation process.

The CAISO should also clarify how many MW of TPD are reserved today and at what busbars; the Revised Straw Proposal references broader areas such as “Central Coast,” but the selection of a specific busbar will have an impact on interconnection studies and TPD availability for other projects in the queue. For future reservations of TPD, the CAISO should specify the busbar and number of MW.

Generally, Clearway is concerned about the potential disruption to the TPD allocation process that this reservation process could cause and encourages the CAISO to limit the amount of TPD reserved for LLT resources. The MW numbers listed in the Revised Straw Proposal (p. 24-25) suggest that the CAISO is planning to reserve large amounts of TPD for LLT resources and that the location of the reserved TPD may change substantially from one cycle to the next as the CPUC’s busbar mapping changes. Reserving significant amounts of TPD for long-lead-time resources at a single busbar can skew results in favor of resources that are inherently higher-risk and may not be able to move toward viability.

b. Extension to seek TPD

Clearway supports flexibility on timing to seek TPD for all resources with COD driven by long-lead RNUs, as well as designated LLT resources. As discussed in prior rounds of comments, these resources face the same challenge given the mismatch between their CODs and LSEs’ focus on near-term resource acquisitions. Flexibility on timing to seek TPD can allow both types of long-lead resources to better align with commercial milestones and procurement.

Clearway also supports the proposal to develop a mechanism for releasing reserved TPD if generation or transmission does not materialize. The CPUC’s decision recommending LLT resources for central procurement, Decision 24-08-064, was clear that procurement of any amount of these resources is subject to a determination that the costs are reasonable. These resources will need more time than others to go through permitting and construction, but they should not be exempt from the need to prove their viability and make progress toward commercial operation.

c. Broader procedural changes

Clearway does not support creating a separate interconnection process for LLT resources. Creating a separate IR process just for LLT resources would create biased opportunities for such resources. While LLT may need more time for permitting and construction, an extension to seek TPD should be enough for these resources to move towards viability without biasing the IR process in favor of these resources.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

Clearway previously requested that CAISO expedite this intra-cluster prioritization proposal. Clearway continues to recommend that CAISO move forward with this process as soon as the tariff change is approved, using existing studies. Projects need to know as early as possible whether earlier CODs will be feasible so that they can act to accelerate development and construction schedules to take advantage of the opportunity. If the CAISO waits to use the next TPD affidavits for this exercise (Sept 2025) that would mean Q1 2026 implementation – which would be too late for some projects to change construction schedules to take advantage of acceleration.

Clearway is supportive of the scoring matrix using similar metrics to the TPD allocation scoring matrix, but we recommend adding expansion points to the scoring matrix to ensure that this process is supporting projects that can be built first. While expansion points would be accounted for in queue entry scoring for Cluster 15+ projects, this scoring did not happen for pre-Cluster 15 projects.

Additionally, Clearway is supportive of expanding the scope of prioritization to include other long-lead RNUs beyond SCD upgrades. CAISO should expand the scope of this prioritization to include situations where multiple projects are collectively triggering an upgrade but only one project’s ISD is being delayed (for example, because other projects initially requested later ISDs).

There are some aspects of the proposal that need some further clarification:

• The CAISO should describe how funding costs for studies will be defined, since the value from this process for the generator will largely depend on how much it will cost the generator. The proposal indicates that current studies will be used to the extent possible, (p. 37) but it seems possible further studies could be needed.
• The scope should include pre-Cluster 15 projects that are behind precursor network upgrades and RNUs. If a pre-Cluster 15 project is waiting for two sets of upgrades that delay the project several years, then the project should also qualify for this prioritization.
• The CAISO should determine the length of delay that an upgrade is causing to a project’s in-service date based only on RNUs and interconnection facilities, not DNUs. The example provided in the Revised Straw Proposal suggests that DNUs would factor into the determination that an RNU is creating a three-year delay (see footnote 13 on p. 37). Clearway recommends that CAISO only look at RNUs and interconnection facilities and that DNUs not be used to assess whether the delay crosses the three-year mark, since a DNU does not prevent a project from being placed in service. The delay should be determined by the wait time for the longest-lead upgrade minus the next gating RNU or PTO interconnection facility, since these are the upgrades that determine the in-service date. However, as discussed further in our response to question 4, Clearway strongly supports extending the same “headroom” approach to DNUs to enable projects to achieve FCDS or Interim Deliverability status earlier.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

Clearway offers additional comments on the feasibility of multi-year interim deliverability, in response to the statement in the Revised Straw Proposal that the CAISO “does not think it is likely that there will be sufficient information to predict when allocated deliverability will go unused for multiple years” (p. 38).

Clearway continues to believe that interim deliverability enhancements are necessary to provide interconnection customers a reasonable means to identify, with sufficient outlook, interim deliverability available to projects that are reliant on numerous deliverability upgrades to provide for the level of interconnection service. Currently, there are earlier queued projects that have been materially delayed given the delay in deliverability upgrades. Third-party analysis has identified sufficient interim deliverability; however, the current rules require the project to be well under construction to initiate the annual interim deliverability analysis officially confirming what capacity is available to the project. This sequencing does not support the financing and contracting timelines for projects, therefore rendering this interim deliverability unutilized.

There have been more than $10 billion approved for upgrades that will enable TPD, but many projects rely on several different upgrades that move on different and disconnected timelines, and there is a history of these upgrades being delayed for several years. Additionally, not all prior queued projects will come online as planned, leaving more capacity available. This unused transmission capacity exists today, and without interim deliverability there is value being left on the table.

Clearway understands that it is not possible to say with certainty how much interim deliverability will be available and when, but this is not a reason to drop this proposal. We encourage the CAISO to implement a framework for multi-year interim deliverability, at least on a trial basis. If after multiple studies there is no interim deliverability available, then CAISO could eliminate this provision. Additionally, there is potential for the intra-cluster prioritization of SCD/RNU headroom to be more valuable if projects that are allowed to interconnect earlier have a path to accessing interim deliverability.

To increase transparency in the interim deliverability study and allocation process, Clearway also recommends including an interim deliverability assessment in the annual NQC study. Clearway recommends including details about specific dispatch, flow assumptions and any other modeling assumptions that will allow stakeholders to replicate the NQC studies. Clearway also recommends that NQC study cycle should be used to explore the multi-year interim deliverability studies. We believe this will help CAISO provide the pathway to deliverability for projects that are delayed because of long lead-time deliverability upgrades but can benefit from the intra-cluster prioritization of RNUs to achieve an earlier operation.

5. Please provide any additional feedback:

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

EDF Renewables (EDF-R) appreciates the opportunity to provide comments on CAISO’s IPE Track 3A consolidated revised straw proposal.  

b. Multi-fuel projects receiving an allocation with PPAs  and c. Opportunities to seek TPD 

Slice of Day and CPUC procedures encourage and sometime require market responsiveness that is not always aligned with the CAISO’s new IR request timelines – e.g. 4+ years in advance. Preserving agility in CAISO’s processes should be a priority. 

EDF-R strongly opposes CAISO’s limits on project technology changes. Provided a modification is not deemed material in CAISO’s MMA process, CAISO should remain neutral on the topic of an interconnection customer’s technology change. EDF-R requests CAISO preserve this agile policy and retain the option for projects to seek a technology change and transfer their TPD to the newly added technology. a prohibition would limit RA market competition, which is harmful to reliability and ratepayers. The CAISO has not demonstrated that its current policies that allow technology changes harm the interconnection queue, particularly in requests where project milestones are not also changed. 

EDF-R understands CAISO’s need to have projects indicate which fuel type should be allocated first in instances where TPD allocation amounts are less than 100%, procedurally speaking. EDF-R requests CAISO justify why interconnection customers should not have the ability to shift allocated deliverability within the project provided the allocation score for both fuel types was the same. This is an unnecessary prohibition, especially this early in the interconnection process. 

EDF-R also requests CAISO clarify two items: 

• If, when a project receives its requested TPD allocation for only one fuel type, the IC must accept or have the portion of project that was allocated TPD withdrawn from the queue, or can the IC decline the allocation in hopes of a full allocation in the next allocation cycle? 

• If the fuel type portion of the project is withdrawn, will the interconnection capacity change?  

EDF-R supports and appreciates CAISO’s proposal to allow projects with conditional TPD allocations to seek an allocation if the project is not able to retain its conditional allocation in allocation attempt one or two.  

EDF-R shares stakeholders concerns about the eligibility of Energy Only projects to seek TPD allocation under the commercial operation group and requests CAISO provide more clarity on the eligibility of Energy Only projects to seek TPD under the commercial operation group. 

Firstly, EDF-R notes that stakeholders were not provided an opportunity to provide comment or opinion on Appendix KK prior to its submission, despite requesting the opportunity and CAISO precedent for such review (see FERC Order 765, FERC Order 831, FERC Order 881, and FERC Order 1000.)  

EDF-R supports CAISO’s proposal to allow Energy Only projects to be eligible for an allocation through the Commercial Operation group, regardless of how they became Energy Only, as specified in the consolidated revised straw proposal page 14.  

However, CAISO’s slide 12 and discussion on the workshop call seems to indicate the opposite, that technology additions to projects that entered the queue Energy Only will not be eligible to seek TPD in the commercial operation group.  

CAISO stated on the call that Appendix KK was designed to reward interconnection customers that had the “foresight” to request a particular technology by prohibiting developers that change directions mid-stream from “queue jumping.”  This is not queue jumping, projects are still paying for their proportional shares of network upgrades, and the charges have been deemed non-material but CAISO and the PTO. EDF-R requests CAISO revise any language in Appendix KK that would disallow a project that has declared COD from seeking TPD for itself, or an Energy Only technology addition.  

As stated above, EDF-R strongly opposes CAISO’s proposed limits on project technology additions. Provided a modification is not deemed material in CAISO’s MMA process, CAISO should remain neutral on the topic of an interconnection customer’s technology change.  EDF-R requests CAISO preserve the existing agile process that allows projects to seek a technology change and seek a TPD allocation when that portion of the project has declared COD. Eliminating this policy removes developer’s ability to quickly respond to market signals (which are changing all the time, as evidenced in year over year change to CPUC’s TPP base case to the CAISO) and limits RA market competition, which is harmful to reliability and ratepayers. The CAISO has not demonstrated that its current policies that allow technology changes harm the interconnection queue, particularly in requests where project milestones are not also changed, and policies that declare commercial operation before seeking TPD have proven commercial viability and literally cannot clog the queue. 

Furthermore, EDF-R urges CAISO to reconsider the proposal to prohibit Energy Only projects with executed PPAs from providing a PPA that specifies an Energy Only product to extend its COD. This would eliminate the possibility for projects to come online Energy Only, declare COD, and then seek TPD. CAISO should require PPAs for RA for TPD retention, but should remain neutral if a PPA has an RA component when an Energy Only project receives a COD extension. 

In addition, the CAISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. As a general rule EDF-R is inclined to support additional opportunities to seek an allocation where it makes sense, however EDF-R questions if allowing projects to seeking an allocation during the facilities study (earlier than their cluster-peer-projects) is equitable, as it effectively allows a Cluster 20 project to seek allocation in the Custer 17, 18, and 19 project. This also creates the risk that there will be less available conditional TPD for projects that did not elect for this additional opportunity.  

d. Eligibility of Energy Only projects, including technology additions  

Consistent with comments above, EDF-R supports pre-cluster 15 EO projects being able to seek TPD through the Commercial Operation group if they have a PPA or if they achieve COD. This fosters an environment responsive to shifts in the RA market and incentivizes projects to move forward.  

e. Modifications to the TPD scoring criteria 

No comments at this time. 

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

a. Eligibility 

EDF-R agrees that CAISO appendix KK needs a policy for enabling Long Lead Time, Location Constrained Resources.  The ISO proposes that IRs that satisfy some or all of the following criteria be allowed to take additional time to seek TPD to better align with commercial milestones and procurement: 

• A long lead-time resource technology (e.g. offshore wind, out-of-state renewable resources on interregional transmission, long-duration energy storage, advanced geothermal resource).  

• Resource technologies that are location-constrained.  

• Resources dependent on policy-approved transmission with explicit guidance to treat the resource as a long lead-time resource from the CPUC or local regulatory authority.   

• These interconnection requests must enter the queue requesting amounts of capacity appropriate for the amounts specified for their resource in the LRA’s resource portfolio. 

EDF-R agrees with the CAISO’s proposed criteria and requests that when the CAISO addresses this issue in a future IPE track the CAISO expand proposal to include considerations for resources that are affected by long lead reliability network upgrades (RNUs.)  

CAISO rightly stated on the call that it has little influence on the existence of the long lead time RNUs and DNUs and their construction timelines, and that collectively we need to look outside the CAISO for solutions to this issue. However, in the meantime CAISO should augment its interconnection policies to enable reasonable deadlines for projects affected by these long lead times. In the process as it is currently designed PPAs are due for projects in queue longer than 7 years, no matter what, but minimum ISDs are far beyond the timelines that LSE contract for because the CPUC has not ordered long term procurement. Until CPUC directs this long-term procurement, CAISO should allow these projects to stay in queue until 3 years before minimum ISD. 

EDF-R does not believe separate interconnection request process is needed, but extensions for commercial readiness deposits, the Generator Interconnection Agreement deposit, and commercial viability criteria requirements will certainly be necessary. CAISO’s process should not have the effect of limiting the ability of developers to build long lead-time projects by requiring undue financial or withdrawal risk early on.  

EDF-R requests CAISO include in the next track for IPE policy development proposals for when and how LLR transmission should associated generation not come online in MW amounts planned.  

• Does the CAISO propose to reserve transmission for a particular resource type, or a specific queue position? If so, how can this reserved transmission option not be available for all resource types without appearing to be preferential towards a select few technologies? 

• What will be the requirements and timelines for retaining that reservation? 

• Will there be amended queue management requirements for GIA execution and commercial viability requirements for long-lead resources? 

• In the event a resource does not retain its long lead deliverability; how, when, and to whom will that deliverability be released? 

• How will transmission construction progress change these questions? For example, if construction has not started, deliverability could be released to “the pot” and upgrade changed as needed in restudy; vs when construction is underway and a resource loses deliverability, the capacity will still be in that specific study area or POI. Will CAISO allow interconnection customers to submit interconnection requests in that area for alternate resource types? 

b. Extension to seek TPD 

A separate interconnection request process specifically for long lead time resources;  

EDF-R does not believe separate interconnection request process is needed, but extensions for commercial readiness deposits, the Generator Interconnection Agreement deposit, and commercial viability criteria requirements will certainly be necessary EDF-R also requests that LLR generators be denoted as such in the public interconnection queue.  

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comments at this time 

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comments at this time 

5. Please provide any additional feedback:

No comments at this time 

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a) Allocation Groups

ENGIE North America (“ENGIE”) supports CAISO’s proposal to revise TPD allocation groups for Cluster 15 and beyond. Specifically, ENGIE appreciates and endorses the introduction of the Conditional Deliverability allocation group as a replacement for the existing Group D. This change addresses concerns raised by stakeholders in previous comments and working group meetings. ENGIE also supports the removal of current restrictions in Group D as part of the new Conditional Deliverability framework to streamline the process. By allowing projects to attain Conditional Deliverability and then pursue a PPA, this approach provides developers and off-takers with much-needed upfront assurances, helping align processes to support project development effectively.

The proposal to grant Conditional Deliverability a deliverability allocation, contingent upon obtaining a PPA, appears reasonable. However, ENGIE encourages CAISO to allow flexibility for projects actively negotiating a PPA but not yet finalized. For instance, the typical 12-month timeline between receiving a Conditional Deliverability allocation and demonstrating a signed PPA could end up a very tight timeline for negotiation with also consideration for  the need for some LSE’s to obtain regulatory approval. . Offering some leeway in this timeline would:

1.Prevent developers and off takers from rushing into PPAs with problematic terms solely to meet tight deadlines, and

2.Ensure that viable projects don’t lose their TPD allocation due to delays in executing a PPA.

ENGIE suggests that developers demonstrating active PPA negotiations should be allowed to retain Conditional Deliverability for one additional cycle, with the understanding that an executed PPA would be required in the subsequent cycle.

ENGIE is not opposed to CAISO’s proposal to eliminate the shortlist allocation group. While the Revised Straw Proposal suggests this change could address stakeholder concerns, ENGIE believes most concerns center on ensuring PPAs in the PPA TPD category qualify appropriately for TPD rather than issues related to shortlisting. Given the scarcity of TPD, CAISO must ensure that PPAs in the PPA category are viable, with CODs aligned to the deliverability timelines of the product being sold. For Cluster 14 projects, which often face long lead-time network upgrades, ENGIE has observed instances of TPD allocation to projects with infeasible CODs relative to where PPAs are being signed. This creates an uneven playing field, risking project failures and denying TPD to potentially more commercially viable projects that avoid infeasible agreements.  This also risks maintaining a competitive and robust procurement environment for off takers as developers that are not willing to knowingly obtain TPD allocation with infeasible CODs will be forced to abandon projects, leaving those projects that ultimately do get awarded TPD with infeasible CODs left to renegotiate contract terms with less competition left at the table.  Lastly, this practice potentially creates significant risk on California reaching its decarbonation goals as projects that are otherwise just as viable as those being awarded infeasible PPAs are forced to exit the market. As noted in comments below, allowing projects with longer-lead time transmission upgrades the ability to delay TPD allocation could help this issue.

For Cluster 14 and earlier projects, ENGIE requests that CAISO retain existing TPD allocation rules to avoid negative impacts. While CAISO proposes allowing currently parked projects one final opportunity to leverage Group D before requiring a PPA in the next allocation cycle, ENGIE recommends these projects be granted one more opportunity to shortlist, followed by demonstrating a PPA in the subsequent cycle, in alignment with the existing rules.

b) Multi-fuel projects:

ENGIE supports CAISO’s proposal to allocate TPD to each fuel type based on the interconnection customer’s desired ranking order. ENGIE also agrees that TPD must be accepted by the specific fuel component, and if not, that component should be removed from the project. However, we request clarification on whether portions of a project that do not initially attain TPD (e.g., if storage receives TPD but the solar component does not) can subsequently seek an allocation under the remaining two out of three options offered. If an allocation is given to one component of the project can it be swapped to the other component?

c) Opportunities to seek TPD

With the recommended changes above for projects negotiating a PPA, ENGIE supports CAISO’s proposal to provide three opportunities to secure a deliverability allocation. Nevertheless, we are concerned that this may still be insufficient for projects requiring long-lead-time transmission upgrades to obtain a PPA, potentially forcing viable projects out of the queue. To address this issue, ENGIE recommends that CAISO offer these projects the opportunity to delay TPD allocation until they are better positioned to obtain a PPA.

 d) Eligibility of Energy-Only Projects, Including Technology Additions

ENGIE is highly concerned about CAISO’s prohibition on Energy-Only (EO) projects ever seeking a deliverability allocation. This policy appears to have been introduced in the IPE Track 2 Final Addendum to the Final Proposal without prior inclusion in earlier proposals or adequate stakeholder discussion. Most stakeholders expected TPD-related policy changes to be deferred to Track 3. ENGIE requests that CAISO reconsider this policy in Track 3, which is the appropriate venue for this discussion..

CAISO’s concern appears to center on the potential for gaming by projects entering the queue as Energy Only (EO) but later securing a TPD allocation. However, this concern seems highly unlikely, particularly if the conditions for EO projects to secure TPD include: (1) achieving commercial operation (COD) and (2) relying on available deliverability without requiring the EO project to fund additional deliverability upgrades. Under these constraints, no developer would initiate an interconnection request for a project needing deliverability.

The primary beneficiary of allowing EO projects to secure TPD upon COD is the load, as it enables more resources to attain Full Capacity Deliverability Status more quickly. Discouraging these projects from pursuing TPD, even when it aligns with business or grid needs, is counterproductive. In situations where capacity is urgently needed, prioritizing already-operational projects for deliverability is far more efficient than waiting for new projects to enter the queue and navigate a lengthy interconnection process.

e) Modifications to the TPD Scoring Criteria

ENGIE generally supports CAISO’s proposed approach to TPD scoring criteria.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

Eligibility:

ENGIE supports defining eligibility for long-lead-time resources in alignment with the CPUC’s definition for central procurement.

Extension to Seek TPD: ENGIE advocates for extending the option to seek TPD not only to long-lead-time resources but also to other projects facing significant delays due to long-lead-time transmission upgrades. The challenges faced by these projects are similar, and granting this opportunity—albeit temporarily—could address these issues until network upgrade timelines are reduced to five years or less. This approach could prevent viable projects from exiting the queue prematurely due to factors beyond their control.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

ENGIE strongly supports CAISO’s proposal for intra-cluster prioritization and encourages the provision of further details on the implementation process.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

ENGIE supports retaining the current process for prioritizing the allocation of interim deliverability.

5. Please provide any additional feedback:

ENGIE has these additional comments>.During the November 15 stakeholder call, CAISO acknowledged the need to address the due date for second IFS for projects currently parked.  The due date is July 1 (original C14 due date plus one year) yet parked cluster 14 projects will not submit affidavits until September 1, 2025 and allocations of TPD to eligible parked projects will not occur until sometime in early Q2 2026.  Given this, it is unreasonable to require parked projects to post approximately 9 months before they know if they will receive a TPD allocation.  It is urgent CAISO to address this issue in a timely manner as CAISO will need to make a tariff change to move the due date for second IFS.  Engie supports a proposal that includes the following:

1. A project can post second IFS anytime before the due date and be allowed to initiate GIA negotiations. (Currently, parked projects cannot progress their IA while parked.)
2. Any second IFS due should exclude any LDNUs as LDNU security should only be required if the project receives a TPD allocation.   In other words, second IFS should be calculated for Interconnection Facilities, Interconnection Reliability Network Upgrades (IRNUs) and General Reliability Network Upgrades (GRNUs).

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

d. Eligibility of Energy Only projects: 

EAS welcomes CAISO's proposal to allocate available TPD capacity to post-COD Energy Only projects through the Commercial Operation group.

EAS recommends that once an Energy Only project acheives COD the method of study process entry selection (EO, PCDS, FCDS) should have no bearing on the eligibility for qualification to seek "available" TPD capacity that is not otherwise irrevocably allocated to other projects or reserved for Long Lead Time, Location Constrianed resources. 

All projects, upon acheiving Commercial Operations, should be eligible to seek available TPD capacity allocation to convert the Energy Only capacity to Deliverable Capacity. If the available TPD capacity is insufficient to convert the entire Energy Only capacity to Deliverable Capacity, then the project should be eligible and able to convert a portion of the Energy Only capacity to Deliverable Capacity by fully utilizing the available TPD capacity. If multiple post-COD Energy Only projects compete for the same contrained available TPD capacity, then there could be a prioritization based on the date COD is acheived or another method that could ensure equitable allocation of available TPD capacity. 

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

EAS broadly supports the need for a process carveout for Long Lead Time, Location Constrained Resources. At the same time, EAS urges caution with the proposal when it comes to TPD Reservation on existing transmission infrastructure for Long Lead Time, Location Constrained Resources. EAS supports further stakeholder deliberations to fully vet the impact of TPD Reservation on existing transmission facilities.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

EAS supports CAISO's proposal in this regard.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

EAS supports CAISO's proposal of maintaining the exiting priority framework while ensuring that all projects, upon acheiving Commercial Operations, should be eligible to seek available interim TPD capacity allocation to convert all or portion of the Energy Only capacity to interim Deliverable Capacity.

5. Please provide any additional feedback:

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

Three Strikes and You’re Out

Golden State Clean Energy (“GSCE”) opposes the forced withdrawal of a project that does not receive and retain deliverability after it has exhausted its three attempts to seek an allocation. Allowing the project to convert to energy only should be retained as an option. This requirement that a project be forced to withdraw if there is no deliverability allocation is overly punitive and unnecessary given CAISO’s existing framework for encouraging non-viable projects to withdraw from the queue, including the Commercial Readiness Deposit, the time-in-queue limit, and the requirement that all projects sharing a network upgrade post according to the earliest timeline need among those projects.

GSCE recommends that if a project does not receive and retain deliverability after it has exhausted its three attempts to seek deliverability, the project would then have to decide whether to pursue energy only or withdraw. This would alleviate the concern of projects continually seeking deliverability, which GSCE believes is the underlying issue. Projects have likely lingered in the past because they could continue to seek deliverability, but with CAISO foreclosing the option moving forward, it is unclear why a project would remain in the queue if it was not serious about developing as an energy only project. CAISO should not prohibit a project from electing conversion to energy only, especially considering the financial commitment a project would have made to that point. Most projects are likely to withdraw because energy only is uncommon and uneconomical for most technology types, but CAISO should let market forces drive this result instead of preemptively forcing it upon the project.

TPD Allocation Group B

GSCE believes it is important to retain Group B as a separate means for demonstrating eligibility for a deliverability allocation. Group B is beneficial because it allows more commercially ready projects to differentiate themselves from the current Group D, and maintaining this distinction between Group B and Group D is important and promotes commercial readiness. Often PPAs require lengthy negotiations, board approval, or are set on timelines that are driven by CPUC mandates. These outside influences make it challenging to secure a PPA in line with the deliverability allocation timelines, but they indicate significant commercial efforts to progress a project that should be recognized and rewarded. CAISO’s current proposal to remove Group B would ignore the lengthy PPA negotiation and approval process and leave a major gap between projects that have executed a PPA and projects that have not begun negotiating with offtakers.

GSCE acknowledges the working group discussions around what types of PPAs should be acceptable, but we are unaware of stakeholder concern regarding the process of representing active negotiations. If there is a concern, we suggest CAISO make clearer what that concern is so stakeholders can explore more precise solutions (and better address this for Cluster 14 and prior that will still have the option of selecting Group B in 2025).

In the spirit of readiness that now defines the interconnection process, GSCE views active PPA negotiations or shortlisting as an appropriate distinguishing factor. GSCE supports continuing to include this as the second highest priority group.

TPD Allocation Conditional Group

GSCE opposes the removal of the restrictions to Group D but supports requiring projects under this group to have an executed PPA to retain a deliverability allocation. A catchall group that allows for three attempts to seek a deliverability allocation without any qualifying criteria or a commitment to pursue its current development timeline is contrary to project readiness and inconsistent with the broader goals of this initiative. In contrast, requiring such a project to have a PPA to retain deliverability does support readiness and thus is appropriate.

GSCE raised a concern in its previous comment that retaining Group D would risk any given cluster absorbing all the available deliverability and blocking future projects from seeking interconnection. This would occur even though Group D essentially indicates that the project has done nothing above the minimum requirements to prove readiness and commercial viability, whereas the project that is unable to seek interconnection may be more viable and ready to contract. The only check on Group D is the restrictions provided in the tariff that prohibit a project from delaying its development timeline (at least until a project executes a PPA).

We appreciate that some stakeholders argued that Group D is critical because it is challenging to begin commercial negotiations or to execute a PPA prior to an allocation of deliverability. Group D allows for the allocation to occur first and for contracting to follow. Thus, we understand why CAISO has retained it. But removing the requirement to commit to existing timelines is at odds with readiness, and this proposal should be removed.

Energy Only Interconnection Requests

GSCE understands that an energy only interconnection request (whether the project seeks RNU reimbursement or not) is unable to seek deliverability during the study process. This is needed for there to be a meaningful distinction between the energy only and deliverability option tracks. However, it is unclear why a project that is already constructed and online cannot make use of deliverability provided by existing transmission facilities. GSCE believes that the COD Group for deliverability allocation should be broadly available to all. CAISO can manage this by making it the lowest priority group.

If CAISO does not expand the availability of the COD Group, GSCE suggests CAISO come up with a process for projects that have reached COD as energy only to re-enter the queue to seek deliverability. This would be similar to interconnection service capacity, where a project that overbuilds capacity behind the point of interconnection that wants to increase its injection right at the POI must submit a new interconnection request in order to increase the interconnection service capacity. Such a process for deliverability would avoid any queue jumping concerns while allowing developers to make more efficient use of existing infrastructure (generation, interconnection facilities, and the grid). GSCE believes it is risky and excessively prohibitive for CAISO to foreclose any possibility of existing generation seeking FCDS.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

No comment.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comment.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comment.

5. Please provide any additional feedback:

No comment.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

GridStor proposes that CAISO create fair competition among interconnection customers. Since the prior IPE Track 2 reforms have prioritized projects for study based on different project qualities, the selection for TPD allocations should minimize the additional inherent advantages of specific project types. To that end:

1. GridStor supports the creation of the conditional deliverability group, as it affords developers modest flexibility on the timing of contracting negotiations as they seek TPD allocation.
2. No comment.
3. GridStor opposes allowing projects to seek TPD allocation during the facilities study process. Doing so would create a significant competitive benefit for signing offtake contracts before final study results, with significant cost and schedule details, are clear. Effectively, CAISO would be asking developers to shoulder more risk for advantage over their competition and create a higher chance of contract failure. Instead, CAISO can better preserve fair competition by ensuring all projects compete for TPD allocation under the same study conditions.
4. GridStor strongly opposes allowing technology additions to projects to compete for TPD allocation. Doing so would allow projects to jump ahead of the line, so to speak, contrary to the fair competition principles CAISO is putting in place through the reformed TPD allocation process. This is particularly true for storage resources. Standalone storage resources would be inherently disadvantaged to hybrid storage resources added via a surplus interconnection route. CAISO has been correct to include this constraint in its proposal.
5. GridStor observes that CODs are dependent primarily on transmission owners’ timelines for network upgrades and interconnection facilities. Projects proceeding to TPD allocation will have offtaker interest or contracts that indicate value for those resources at the given COD. To the extent that tie-breakers for projects with the same score will select the project with the earlier COD, doing so could limit offtakers' interest in longer-lead procurements. This raises the question of whether a separate process for long lead-time network upgrades may be warranted -- please see our comments in Section 2.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

We ask that CAISO clarify if the list of several criteria for long lead-time resources must all be satisfied to enshrine a long lead-time resource, or whether just one of those criterion is sufficient.

GridStor observes that network upgrades are becoming longer, with some having timelines of 7+ years. This is reducing the distinction between long lead-time resources, where the facility construction will take many years, and long lead-time upgrades, where the transmission infrastructure construction will take many years; the effect on the grid and TPD allocation is similar. Therefore, GridStor proposes that CAISO incorporate a timeline criterion for long lead-time resources – such as 7+ years to proposed COD – separate from the other criteria. Doing so will create fairer competition for resources with long timelines that are only likely to come online if deliverability is reserved / timeline extensions for seeking TPD are permitted. Not doing so could create a preferential treatment among similarly situated resources for deliverability reservations.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comments.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comments.

5. Please provide any additional feedback:

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a. Intersect Power appreciates CAISO’s efforts to streamline the TPD allocation process and its creation of the Conditional Group. However, Intersect Power disagrees with the removal of the Shortlist Group (B). With the introduction of the new interconnection schedule for QC15 and future clusters, the period of time between the receipt of Interconnection Facility Study results and the 1st cycle’s TPD affidavit deadline is very limited (4-5 months) and in many cases is not long enough to negotiate and fully execute a PPA. Thus, Intersect Power supports the reinstatement of Group B, which provides a middle ground for developers that are in active negotiations of their PPA as compared to including them in the Conditional Group where all remaining projects are pooled together, regardless of their efforts to secure offtake.

b. Intersect Power supports CAISO's proposal to remove a certain fuel type capacity from the queue, should that project refuse a TPD allocation for that capacity, while being in a PPA group. 

c. i. Intersect Power supports the CAISO’s proposal to allow for a 4th opportunity to seek TPD ahead of the Interconnection Facilities study completion with a proof of PPA.

d. Intersect Power does not support CAISO’s proposal to completely restrict Energy Only projects’ ability to request TPD allocation (for both pre-C15 and C15+). Intersect Power agrees that Energy Only projects should not be able to request TPD during the development phase especially given the new intake scoring process, however, once operational, Energy Only projects should have the ability to request TPD, at least for pre-QC15 EO projects. This is, in fact, the fastest path for CAISO to procure a deliverable asset. 

e. Power Purchase Agreement status: 

Intersect Power strongly opposes the discrimination between LSE and non-LSE PPAs proposed by assigning 5 additional points to PPAs with “Off-takers procuring the capacity to meet their own RA obligation.” Over the past few years, non-LSE PPAs have become more and more disadvantaged due to a series of new rules set by the CAISO. Paraphrasing Amazon Energy’s comments to the 2021 IPE, circa June 2021, non-LSE PPAs also require developers to secure deliverability for their projects, which in turn have an incentive to put it to use by selling it to a party that needs the RA capacity (i.e., an LSE). Hence, the ability to re-sell RA capacity is crucial for non-LSE offtakers to secure their needed energy and RECs at competitive prices. The proposed discriminatory treatment of non-LSE PPAs undermines fair competition and stifles innovation, and will hinder deliverable capacity development in California.

 If the CAISO elects to proceed with this proposal, projects with non-LSE PPAs should at least be granted 3 points to reduce the competitive imbalance with LSEs.

GIA Status:

Intersect Power agrees with the current GIA scoring rubrics and proposes that CAISO qualifies projects that have executed an Engineering & Procurement agreement with their PTO to start funding their Network Upgrades, for the 3-points option, i.e. change the 3 points qualification to “has provided to the ISO the required GIA deposit or executed an Engineering & Procurement agreement to start funding NUs”.

Permitting Status:

Intersect Power also generally agrees with CAISO’s permitting status point allocation breakdown and proposes some additional updates listed below and summarized in the below table. These changes are essential now that this scoring methodology will also be used to assess the viability of more advanced projects participating in the intra-cluster prioritization, as well as better reflect the certainty of a project’s timeline to achieve commercial operation.

• 1 Point: Intersect Power proposes this be further clarified to reference the primary land use application, and not for a secondary or tertiary permit that may also be required.

• 3 points: Intersect Power does not agree that a project deemed “data adequate” represents a meaningful advancement toward obtaining eventual land use approvals and proposes the removal of the 3-point rubric, due to multiple reasons including but not limited to: (a) the BLM does not deem applications complete until a ROW Grant is issued, which is well after NEPA is complete and a decision record issued, (b) counties typically have a much lower standard of application completeness than an agency like the California Energy Commission under AB 205, creating a mismatch of standards projects are weighed against.

• 5 points: It is expected for every Draft EIR published in California to have at least one remaining significant impact that cannot be mitigated to a less-than-significant level. In fact, the only reason for a CEQA lead agency to pursue an EIR instead of a lower-level document like a Negative Declaration is because a significant impact is anticipated. While the CAISO has provided additional clarifications in the BPM section 6.2.9.4.2 that address these concerns, Intersect Power proposes that these changes be reflected directly in the point rubrics table by omitting the reference to “no significant impact that cannot be mitigated”.

• 7 points: Intersect Power believes that receipt of a Certified CEQA document and final land use permit represents significant advancement and project viability. We, however, disagree that obtaining a final governmental permit to construct (i.e., all building and grading permits) is a meaningful milestone for TPD allocation. Projects should not be advancing construction-ready designs and pre-construction plans and approvals without having some amount of certainty on deliverability for the project, especially given the fact that this would be an easy final step to achieve once capital is deployed for final design.

• 10 points: a significant differentiator for project viability is achieving Environmental Leadership Development Program (ELDP) certification, because it affords expedited judicial review, requiring all court decisions and appeal processes to be decided within 9 months of CEQA document certification. This truncates a process that can otherwise take 3-5 years.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

a. Intersect Power believes that CAISO should provide very specific eligibility criteria for reserved TPD for LLT resources. Only capacity opened up by transmission upgrades approved for a specific type of policy-driven LLT resource during the TPP should be reserved for such resources. This should be included in a very clear and transparent fashion in the TPP report.

b. Extension to seek TPD, if granted, should apply to LLT resources as defined by CAISO in this straw proposal, as well as to all resources requiring long-lead time RNUs that are not able to take advantage of available headroom via the intra-cluster prioritization. These resources should still be required to make any financial postings that they’re triggering and that other IRs may NTP.

c. Intersect Power supports CAISO’s proposal to include the LLT resource-specific process in a Track 4 where it can be further discussed without holding back the rest of the Track 3 proposed reforms.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

Intersect Power strongly supports the Intra-cluster prioritization of SCD/RNU headroom, as well as the proposal to extend this process to additional Network Upgrades including Precursor NUs. Further clarification on how the CAISO would apply such prioritization to broader types of NUs would also be helpful. 

Additionally, Intersect Power proposes that this process not be limited to upgrades with “an estimated time to construct of more than five years, and that serve as the sole reason for delaying the in-service date of multiple generation projects by more than three years” as proposed as an example for QC14, but rather include any Network Upgrades where potential headroom is available. A high-scoring project should be able to benefit from any available headroom across different NUs it triggers, as long as its COD is not held up by any other Network Upgrades with no available headroom or with available headroom that it’s unable to secure due to the prioritization of other higher-scoring projects.

Additionally, footnote 13 suggests that projects behind a Deliverability Network Upgrade delaying their deliverability allocation would not be able to benefit from RNU headroom. Intersect Power proposes that FCDS projects be allowed to participate in the Intra-Cluster prioritization to request RNU headroom if such a project is committing to go online as an Energy-only resource ahead of securing deliverability.

Intersect Power does not support CAISO’s suggestion to not allow projects benefiting from this process to suspend or request a COD extension through the modification process, due to the inherent uncertainties associated with the development of a project. Intersect Power suggests instead that the CAISO imposes a condition for any project delaying its COD beyond what is enabled by their secured headroom, to release that headroom, with the ability to participate in the next intra-cluster prioritization cycle, that would take into account its updated COD.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

Intersect Power strongly opposes the current prioritization for Interim Deliverability status, which favors a project’s queue cycle rather than its TPD allocation date. While some stakeholders opposed CAISO’s proposal to change the current prioritization approach due to previously-made business decisions, it is worth noting that Interim Deliverability status is not a guaranteed outcome. Under any prioritization approach, it remains an uncertain factor, making it at best an upside opportunity, and not a reliable basis for strategic planning (i.e., a business decision driver).

If CAISO still elects to maintain the prioritization status quo, and to maintain fairness to all projects involved, CAISO could consider running the Interim Deliverability prioritization process using both methods, and allocating Interim Deliverability to both lists of prioritized projects. Thus, CAISO takes the risk for any surplus Interim Deliverability allocated for the period of time where the Interim designation is necessary. 

Intersect Power also suggests that CAISO reconsiders the implementation of a multi-year interim deliverability concept, especially considering the high level of uncertainty imposed by long lead time Network Upgrades on projects that would otherwise be ready for deployment.

5. Please provide any additional feedback:

Intersect Power would like to express its concerns about the requirements to make very early non-refundable postings and commit to execute a GIA ahead of receiving TPD allocation certainty, with the risk of getting withdrawn if the project does not secure TPD within the 3 allowable tries.

To reduce some of this uncertainty, Intersect Power proposes the below:

• Knowing that the postings schedule is a FERC Order 2023 compliance requirement, does CAISO have any flexibility with regards to refundability timing of the GIA posting? In other words, can CAISO delay the non-refundability of the GIA posting until a project’s TPD allocation date? That said, Intersect Power would still suggest that any postings related to Network Upgrades that are shared with other projects become non-refundable as soon as any other projects NTP that NU.

• Allow FCDSR projects that did not secure TPD allocation by the 3rd opportunity to stay in the queue and get built as an Energy-only project that would be allowed to seek TPD allocation again once it becomes operational. This maintains fairness for ICs that would have invested many millions of dollars in their project at that point, and leaves them with the decision to either proceed as an Energy-Only project or withdraw from the queue.

• Finally, given QC15’s modified interconnection process schedule as compared to future clusters (i.e. Interconnection Facility Study start planned for May 2026 vs. February for future clusters, thus missing the 2026 TPD allocation cycle), QC15 projects will be required to sign a GIA and make its 3rd posting without having the opportunity to participate in any TPD allocation cycle. CAISO should thus consider allowing QC15 projects to participate in the 2026 TPD allocation cycle as soon as the Cluster Re-study is complete, as part of the PPA group. This provides an additional opportunity for projects to secure TPD ahead of the deadline to make the GIA posting. If projects are unable to show PPA negotiations progress by the beginning of the next queue cluster intake, they would have to forgo that TPD allocation and try again on the next TPD cycle. This proposal would require a 3-months forward shift for the 2026 TPD affidavit deadline to allow for QC15 to participate in the allocation cycle. 

Can CAISO also confirm the treatment of multi-fuel FCDSR projects that don’t get TPD allocation by the 3rd try: 

• Are both fuel types then removed from the queue? If so, are all  postings (likely 20% of NUs at that point) forfeited? 

• What about projects with a partial deliverability allocation, will the IC have to downsize their project to the TPD allocated capacity, or can it stick to a PCDSA status with the remaining capacity as EO?

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a. Allocation Groups:  No comments on this issue.

b. Multi-fuel projects receiving an allocation with PPAs:  No comment on this issue.

c. Opportunities to seek TPD:  No comments on this issue.

i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA.  No comments on this issue.

d. Eligibility of Energy Only projects, incl. technology additions:  No comments on this issue.

i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle.  No comments on this issue.

e. Modifications to the TPD scoring criteria.  No comments on this issue.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

a. Eligibility.  No comment on this issue.

b. Extension to seek TPD:  The CAISO has proposed allowing Cluster 15 and later LLT resources to postpone commencement of their “three strikes and you’re out” TPD allocation attempts.  Invenergy understands that LSA has proposed an alternative that would allow these resources to request their TPD awards on the same timeline as other resources and then postpone their retention deadlines.  As noted below, the LSA option may be preferable in certain limited circumstances.

c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources:  Invenergy appreciates the CAISO’s efforts to adopt new rules to accommodate LLT resources in LSE/LRA portfolios going forward (C15+). 

However, while longer-term changes for C15+ projects could perhaps be deferred to a “Track 4[1],” quicker action is needed (in advance of September 2025 TPD Allocation affidavit due date.  Without near-term changes, the CAISO proposals in this area would leave behind the LLT “early adopters” that have already entered the queue, under the prior rules, i.e., in Clusters 13 and 14.  For example, at least 4-5 offshore wind projects, with over 3,000MW of capacity, appear to have completed their interconnection studies and received TPD Allocations in those clusters, based on information that can be gleaned from the CAISO queue listings. 

These TPD Allocations were awarded under prior Group 3 or Group D – the only realistic TPD Allocation options available, given: (1) their very long development lead times; (2) the lack of LSE procurement activity to date for this technology; and (3) the very early status of the state’s AB1373 Central Procurement mechanism, where the Department of Water Resources (DWR) will run future centralized solicitations for offshore wind through mechanisms that have not yet been implemented.   These projects, particularly offshore wind, lack opportunities available to projects in other allocation groups to manage their development, due to restrictions on project suspension and COD extensions. 

More urgently, the more than 2,000 MW of offshore wind (OSW) LLT capacity with Group D allocations face impending TPD retention requirements that will be difficult or impossible for them to meet, given their required development timelines.   The state’s AB1373 CDWR procurement requirements for these resource types and associated timelines are still in progress, and it is highly unlikely that these resources will be able to secure PPA shortlist positions or executed PPAs in the short term, regardless of their long-term viability, state goals and policy directives, and other merits.

The CAISO has reserved capacity for these resource types.  It is essential to adopt policies that allow OSW LLT resources to retain their already assigned TPD.  Therefore, Invenergy recommends that the CAISO take actions to keep “early adopter” Group D LLT resources with TPD allocations on track.

There are several approaches that could achieve that objective, i.e., postponing TPD retention compliance until a more realistic timeframe:

• Adopt some parts of LSA’s proposed LLT alternative and apply it to LLT projects already holding TPD allocations.  This would allow LLT resources already awarded TPD allocations to defer their retention requirements (e.g., shortlist or PPA acquisition for recent C14 and other TPD award recipients), applicable to pre-C15 Group D LLT resources, postponing their compliance showings until 5-6 years before their project CODs.   LLT resources that are eligible to participate in the upcoming AB1373 DWR auctions should have additional flexibility to defer their retention requirements until the conclusion of the DWR auction process, as described further below. 

The CAISO is already making accommodations for pre-C15 project options in this initiative, e.g., allowing them a last pre-COD opportunity to request a new TPD Allocation, and under Group D if they qualify even though that group will be eliminated after that.  The “early adopter” LLT approach Invenergy is suggesting here is simply another reasonable accommodation given changing market structures and the evolution of state policy.

• Apply the CAISO’s existing “holdback” or reservation authority (GIDAP 8.9.1) to TPD retention in addition to TPD allocation “holdbacks.”  Section 8.9.1(c) allows the CAISO to identify “any other commitments having a basis in the Transmission Plan” that will utilize TPD.  The LLT OSW resources will be included in upcoming Transmission Plans in accordance with the CPUC’s recent confirmation that:  “[W]e confirm our intent to reflect the results of the [LLT OSW] need determination in this decision in our upcoming activities formulating recommendations for the CAISO for the next TPP”, and “we intend to address the OSW amounts in our upcoming TPP recommendations.”[2] 

Future Transmission Plans should reflect expected OSW authorized in the CPUC’s need determinations, and OSW resources holding TPD allocations should be accounted for in the existing reservation authority under Section 8.9.1(c).  If necessary, the CAISO’s authority to hold back TPD for LLT resources also could reasonably be extended to actions needed for the intended LLT resources to retain the allocations they have already received, to help implement this provision. 

• Develop alternative TPD retention requirements for Group D LLT resources eligible to participate in DWR AB1373 solicitations, to ensure that those resources retain TPD while undertaking the significant investments required to advance development. 

For example, CAISO should consider aligning the timelines for TPD retention showings to match DWR’s AB1373 solicitation process, which is currently under development.[3]  LLT resources that participate in the DWR solicitations should retain their TPD allocations until DWR contracts are awarded.  Alternatively, allowing active participation in the DWR 1373 process could be considered compliance with the retention requirements in lieu of a shortlist position or executed PPA in hand. 

[1] For example, Invenergy believes that there may be merit in a system that could prioritize LLT resources as a “Priority 0” and award TPD for that group up to the “holdback” amount, using an LLT-appropriate version of the intra-group scoring system.  However, this plan will need additional work, and the CAISO should prioritize the near-term LLT issues for projects that already have a TPD Allocation if developing the C15+ framework will postpone implementation of a solution for that more urgent issue.

[2] CPUC’s Decision Determining Need for Centralized Procurement of Long Lead-Time Resources, Decision 24-08-064 issued in R. 20-05-003, August 29, 2024, at 67-68.

[3] The CPUC’s Decision Determining Need for Centralized Procurement of Long Lead-Time Resources, Decision 24-08-064 issued in R. 20-05-003, August 29, 2024, indicates a first DWR solicitation for offshore wind in late-2027, with contracts going to the CPUC for approval in mid-2028; a second solicitation in late 2029, with CPUC contract approval in mid-2030; and a third solicitation in early 2030 with contracts seeking CPUC approval in late-2030. The COD for all solicitations is delivery by June 1, 2037. The decision notes that the DWR solicitation timing could vary: "Timing reality may deviate from these plans somewhat, but our staff will work closely with DWR to execute this plan."

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comments on this issue.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comments on this issue.

5. Please provide any additional feedback:

No comments on this issue.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

Lotus Infrastructure Partners supports and appreciates the ISO’s continued treatment of Pre-Cluster 15 projects in accordance with TPD allocation procedures established in ISO Tariff Appendix DD.[1] Consistent with the provisions under App. DD, Lotus asserts that Pre-Cluster 15 Energy Only projects should be eligible to seek TPD through the Commercial Operation group following the 2025 TPD allocation cycle. This is a reasonable approach as these were the rules under which these projects initially sought TPD. Further, the allocation of TPD to Pre-Cluster 15 Energy Only projects that have reached commercial operation will not impact allocations to commercially ready projects as TPD will always be allocated first to those projects with a PPA.

[1] Consolidated Revised Straw Proposal at 19.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

No comment.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comment.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comment.

5. Please provide any additional feedback:

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a. Allocation Groups:  LSA does not support the removal a shortlist/active-negotiations position from (1) the 2025 TPD Allocation Group D; or (2) the post-2025 TPD Allocation as a separate Shortlist Group (2^nd priority) or a feature of the new Conditional Group.  The reason this step was originally included in the allocation overall and in Group D was that the process of acquiring a PPA can be long and difficult, and the LSE solicitation and PPA execution dates may not line up with the CAISO’s affidavit submittal dates.  Developers need that interim step to move forward from a shortlist position to secure a PPA.

LSA understands the CAISO’s desire to simplify the allocation and tracking process, but eliminating an important step that projects need to move forward is not a productive way to do that.

b. Multi-fuel projects receiving an allocation with PPAs:  LSA supports the CAISO’s proposal for Interconnection Customers (ICs) requesting TPD allocations for Multi-Fuel Resources (MFRs) to clarify prioritization between different portions of their projects in a TPD Allocation request.  However, this might not be as simple as a prioritization between fuel types. 

Developers may need more flexibility than that, e.g., prioritizing some solar-storage pairs over others, depending on the project PPA structure.  For example, for a 100MW MFR with two 50MW solar-storage PPAs might need to prioritize the one with higher payments or cancellation penalties over the other.

Again, LSA understands the CAISO’s desire for simplicity, but the new structure should accommodate commercial project-development priorities as they exist in the market.

c. Opportunities to seek TPD:  LSA agrees with having the first of the three opportunities to seek TPD following completion of the Facility Study, as long as this timing is coordinated with the next affidavit due date.  The current posted C15 timeline has completion of the Facility Study in late November 2026, well before the expected March 2027 TPD Allocation affidavit due date; however, if the Facility Study time is extended (which is allowed by the tariff), then the CAISO should adjust the affidavit due date if needed to ensure sufficient time for C15 projects to prepare for the TPD Allocation process.

LSA also seeks clarification on the treatment of resources that have only received part of their requested deliverability by the end of its third opportunity. The CAISO should clarify if those resources would be required to downsize in order to remove the capacity for which they requested an allocation that did not receive one.

i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA.  LSA has no objection to this proposal, especially since it will likely be many months between the end of the Facility Study and the results of the next TPD Allocation; projects with PPAs should have the opportunity to proceed more quickly to meet their PPA requirements.  The CAISO should clarify in the next written proposal version its intent that this would constitute a fourth request opportunity for these projects.

d. Eligibility of Energy Only projects, including technology additions:  Since the next question below applies to pre-C15 EO projects, LSA assumes that this question applies to C15 and later projects (C15+ projects).

The question of whether C15+ projects should have the right to seek TPD after Commercial Operation is realistically a somewhat esoteric question, based on current contracting practices.  It is highly unlikely that developers will invest time and resources to build projects, or technology additions, with no assurance of a TPD Allocation, especially the common BESS additions where the TPD element is such a large part of the project value.

However, that unlikelihood does not justify removing the opportunity.  Clearly this capacity must be commercially viable, since it will already be built.  While the pre-C15 framework encouraged projects to request deliverability regardless of how critical it might be for them, the new framework strongly encourages projects that can be viable as Energy Only to enter the process that way.   

Once they reach Commercial Operation, if they do, the CAISO should allow them an opportunity to obtain a TPD Allocation.  To the extent that the award relies on existing transmission, these projects could then provide Resource Adequacy to the market right away, and not years later. 

Prohibiting operational Energy Only projects from seeking deliverability when it becomes available is thus contrary to the CAISO’s fundamental obligation to support the state’s aggressive reliability and climate goals.  The CPUC in its RESOLVE model uses Energy Only resources as a flexibility to minimize total cost to ratepayers, but it does not indicate that this status is intended to be permanently attached to individual resources.

During FERC’s September 10, 2024 technical conference on interconnection queue efficiencies, FERC encouraged interim Energy Only operations as a solution to timeline mismatches between transmission planning, transmission construction, generation construction, and resource adequacy procurement.  Energy Only resources that are not seeking to circumvent the competitive intake process should have a pathway to seek deliverability after they become commercially available.

FERC also indicated, in the approval of the CAISO’s IPE Track 2 reforms, that such a process does exist[1], and therefore the CAISO should clarify why Energy Only resources should not be allowed to pursue TPD after reaching COD. 

1. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle.  LSA has argued in the past that pre-C15 projects should not be limited to one more opportunity to acquire TPD, i.e., that the CAISO should not change the rules for such projects midstream.  LSA still believes that.  Consistent with that position, LSA believes that such projects should certainly have the opportunity to seek TPD after COD, and in whatever Allocation Group for which they qualify.

In addition, LSA believes that removal of this opportunity is unfair.  The CAISO seems to say that the prior rules (e.g., Group D restrictions) apply to pre-C15 projects in some cases, while changing the rules when they don’t fit neatly into the new paradigm.  Either the prior rules apply or they don’t.  In this case, pre-C15 rules allow TPD Allocation requests up to and after COD, and those rules should apply.

e. Modifications to the TPD scoring criteria.  LSA does not oppose the proposed scoring criteria.

[1] FERC stated “CAISO’s Tariff also permits an interconnection customer to submit a new interconnection request for its generating facility if it seeks to be studied for deliverability in the future.”  (p.214)  While FERC’s statement seems to reflect a misunderstanding of the CAISO tariff, which does not allow projects to re-enter the queue to be studied only for deliverability, it does show FERC’s expectation that the CAISO would provide a path for Energy Only projects to obtain deliverability after Commercial Operation.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

a. Eligibility.  The CAISO must better define which resource types would qualify, e.g., tying the qualifying resources to legislative or regulatory requirements and then stating the specific resource types.  (This is true for the Cluster 15 intake process as well, as there seems to be widespread confusion over which resource types qualify for the Long Lead Time (LLT) points.)

The category of “Location Constrained Resources” is particularly puzzling.  Nearly all resource types are locationally constrained in some way, including on-shore wind and large-scale solar (which have huge land requirements and are increasingly constrained by local and other permitting restrictions).  In fact, the CAISO’s earlier adoption of the “Location-Constrained Resource Interconnection Facility” concept was largely (though not solely) aimed at wind (and later solar) resources in places like the Techachapi area.  Also, location constraints do not necessarily equal long lead times, and it’s not clear why location constraints should warrant special treatment.

Thus, criteria related to “location constraints” are too vague and not limited to LLT resources.  LSA suggests instead that the sole criterion for “holdbacks” and separate TPD awards be additional upgrades approved in the TPP primarily for that LLT technology type, as defined by legislative or regulatory processes (i.e. projects that take longer to develop because of their technology type, not their location).  This will require the CAISO to identify such upgrades in the Transmission Plan, including the amount of capacity assumed for the identified technology types when those upgrades were triggered – i.e., the amount of the future “holdback” for these technologies. 

This approach would be consistent with the CAISO’s original proposal, which was characterized as “holding back capacity for the purpose for which it was approved.”  Approving upgrades for specific resources and then reserving that capacity for those resources does not impair deliverability for other projects; on the other hand, holding back capacity for technologies where no new upgrades have been approved just unfairly reduces the amount available to other projects.

Also, the CAISO’s proposals that Interconnection Requests for LLT resources be limited to the amounts in LRA portfolios seems impractical.  As LSA said at the November 15^th stakeholder meeting, no individual developer can know the plans of other developers in advance of the close of the application window.  It would make more sense to allow all LLT project IRs that would otherwise qualify to apply, and then have them compete with each other for the holdback capacity, using an appropriate scoring rubric or auction approach that reflects the expected long lead times.  Projects that don’t “make the cut” for the holdback amount could still compete to be accepted for study in the larger pool of Interconnection Requests, and qualify if they can based on their scores.

b. Extension to seek TPD:  The CAISO has proposed allowing LLT resources to postpone commencement of their “three strikes and you’re out” TPD allocation attempts.  This seems sensible (not only for “LLT” resources but also resources with long-lead-time upgrades – see Section 5 below).  However, there should be some limit to this delay, e.g., they should be required to initiate their TPD Allocation requests by something like 5-6 years before their In-Service Dates.

Another alternative that might be effective would be to allow these resources to request their TPD awards on the same timeline as other resources – negating the need for the CAISO to continue to reserve “phantom” resources for their technology types, and in line with the transmission-upgrade approvals for them – and simply postpone their retention deadlines. 

For example, C15 LLT projects could request a TPD allocation right after Facility Study completion like other projects in the same cluster, but not have to comply with any retention requirements (e.g., executed PPA) until ~5-6 years before their proposed In-Service Date.  This option would give them early certainty of receiving a TPD allocation (facilitating any PPA acquisition activities that could be performed so far in advance) but postpone their shortlist/PPA requirements until the more likely LSE contracting window for their project CODs.

c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources:  LSA believes that a separate effort – “Track 4” – is needed, because the proposals in this area are significantly less developed than the other Track 3 items.  As noted above, the eligibility requirements are not at all clear, and any wholesale changes to the process will take time to work out and mesh with the processes for the rest of the queue.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

LSA appreciates the CAISO’s efforts to move this proposal forward, as well as the clarifications provided in the stakeholder meeting.  LSA believes that the intra-group scoring rubric from the TPD Allocation process could be used for this purpose. 

However, LSA has three major concerns with the proposal as it now stands.

• Additional details:  The proposal badly needs additional details, e.g., the applicability process for Precursor Network Upgrades (PNUs) and justification for the proposed 97% loading level for short-circuit duty (SCD) analyses.

• Determination of RNUs to be included:  Though the focus here is on COD acceleration, the CAISO appears to be including DNUs in this determination.  The Proposal states at footnote 13: “For example, if a generation project has to wait four years for a transmission upgrade needed for deliverability and has to wait five years for a short circuit mitigation upgrade, then the short circuit mitigation upgrade is only creating a 1 year delay for that generation project.”

While projects should be able to align their CODs to match their DNUs, but if the developer should still have the option to use the “headroom” process to reach COD earlier and operate as Energy Only, with possible Interim Deliverability.  Thus, the CAISO should consider only PTO’s Interconnection Facilities and RNUs in its determination of eligible RNUs; developers wanting to keep a later COD in line with their DNU timelines could simply choose not to apply for the earlier COD.

• Implementation schedule:  Implementation of this procedure should be accelerated, so projects know well before the September 2025 TPD Allocation affidavit due date whether their CODs can be moved forward.

This knowledge would help them meet their TPD retention requirements (e.g., acquire PPAs) by the affidavit due date.  Otherwise, they would have to take steps like acquiring PPAs based on their current, extended due dates, if that is even possible, and then amend them later.  That would be an inefficient process and could result in unnecessary TPD allocation loss that would be avoidable with an earlier implementation of this procedure.

For this proposed accelerated process, the CAISO should provide a schedule of: (1) when the considered RNUs would be posted on the CAISO website, (2) when the affidavit is due; (3) when results of the assessment are expected. The CAISO should also publicly post the study for stakeholders to reference.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

LSA still believes that: (1) the situations described by the CAISO, where there could be issues with the current methodology, are rare; and (2) any change should include grandfathering of projects relying on the current methodology.  Without such grandfathering, LSA agrees that a change is not helpful or needed for these rare situations.

5. Please provide any additional feedback:

LSA has comments in several additional areas: 

(1) TPD transfer clarifications;

(2) Projects with long-lead-time upgrades;

(3) Cluster 15 intake numbers and LLT holdbacks;

(4) GIA requirements for projects without TPD Allocations; and

(5) Cluster 14 parking and related issues.

TPD Transfer clarifications

The Proposal, and November 15^th meeting discussion, is muddled at best in this area.  The CAISO’s proposal appears to be as follows:

• TPD transfers within queue positions will continue to be allowed.

• TPD transfers to PCDS projects, or to technologies/capacity added to FCDS or PCDS projects via MMA requests, will continue to be allowed, as long as: (1) the “to” and “from” projects are at the same POI and voltage level; and (2) the capacity at the “from” project must produce an Energy Only PPA or withdraw from the queue.

• TPD transfers to technology/capacity added to Energy Only projects via MMA requests will not be allowed.  However, technology/capacity additions to Energy Only projects that submit new FCDS Interconnection Requests can enter the queue and obtain TPD Allocations through the normal study and allocation process.

It would be helpful if the CAISO could clarify these proposals in the next Track 3 document.

Projects with long-lead-time upgrades

The CAISO seems to have given up on solutions – other than the “headroom” proposal above, which LSA supports – for situations where projects are struggling with long-lead-time upgrades, e.g., 98-month SCD mitigation upgrades. 

However, LSA believes that some of the solutions discussed above to help LLT resources obtain and retain TPD Allocations commensurate with their development timelines could also be solutions for these situations.  Both the CAISO proposal for LLT resources (allowed postponement of TPD Allocation request commencement) and LSA’s suggested alternative above (on-time TPD Allocation requests but allowed retention-requirement postponement) could also help non-LLT projects struggling with long-lead-time upgrades.

As LSA said in its last comments, we see little difference between LLT resources that need 7+ years to come on-line because of the need for long-lead-time technical or inter-state transmission upgrades and non-LLT resources that need 7+ years to come on-line because their intra-state transmission upgrades will take that long to build. 

Both project types have such long lead times that standard compliance with TPD Allocation retention timelines may be difficult or impossible, and there is no justification for discrimination based only on the nature of the upgrades needed.

Also, as we pointed out in our last comments, the recent PTO policy changes requiring full security postings many years in advance of CODs extended for this reason have exacerbated this situation.  However, if projects could postpone their TPD Allocation requests or retention requirements until more realistic dates (e.g., ~5-6 years before the In-Service Date), then they could be more comfortable committing security further in advance.

Cluster 15 intake numbers and LLT holdback

It was clear from the discussion at the stakeholder meeting that LSA’s concerns about the Cluster 15 process, described in our last comment submittal were not yet well understood by the CAISO.  We are taking another try here to explain further, as we understand the situation. 

• The Cluster 15 intake figures (in the POI constraint mapping table) were based on remaining TPD after the 2023-2024 TPD Allocation process (results issued in April 2024).

• That TPD Allocation process considered TPP upgrades approved only through the 2022-2023 TPP, when there was no offshore wind (OSW) included in the CPUC base portfolio, so no Network Upgrades (NUs) targeted at OSW were approved in that TPP cycle. 

• There was OSW in the CPUC base portfolio for the 2023-2024 TPP, and upgrades targeted at OSW were approved in that TPP cycle.  However, as noted above, those upgrades were not considered in the C15 POI mapping intake information.

• By holding back 1600MW of TPD for OSW in the C15 mapping process (which did not show up until the 2023-2024 TPP) but not including any capacity approved for OSW in the 2023-2024 TPP, the CAISO greatly (and unfairly) impaired the TPD remaining for other projects.  The CAISO should have either:

• Added in the upgrades approved for OSW in the 2023-2024 TPP, and then held back TPD for the 1,600MW in the CPUC portfolio in that cycle; or

• Kept the TPD from the 2023-2024 TPD Allocation cycle, which was based on the 2022-2023 TPP, and not held back any TPD for OSW (which was not in the portfolio for the 2022-2023 TPP cycle).

As we noted before, implementing the holdback without including the capacity additions for OSW is the equivalent of adding in earlier-queued projects in interconnection studies without adding in the new upgrades approved for those projects.

LSA would be happy to discuss this matter further with the CAISO.

GIA requirements for projects without TPD Allocations

The CAISO should better clarify the requirements for projects that do not receive a TPD Allocation on their first try. 

The CAISO’s Order 2023 compliance filing provides that projects in this situation must increase their Commercial Readiness deposits and execute a GIA.  LSA does not support these requirements but acknowledges that they reflect Order 2023 directives.

However, it is not clear how a project without a TPD Allocation but with two more tries over the following two years could: (1) execute a GIA with realistic milestone dates,; or (2) meet requirements like monthly invoice payments and Notice to Proceed deadlines with a looming “three strikes and you’re out” provision.  Any GIAs required to be executed under these provisions should be highly conditional and not require additional financial commitments while they are waiting to see if their projects can even remain in the queue and move forward to development.

Cluster 14 parking and related issues

The CAISO should propose tariff changes in this initiative to postpone the second financial-security posting for Cluster 14 projects coming out of parking for the next TPD Allocation cycle.  As discussed at the November 15^th stakeholder meeting, the tariff provides that parking delays the second posting only 12 months, i.e., until July 2025.  This tariff provision should be changed to restore the original intent that these projects delay that posting until they receive the TPD Allocation results and can make a reasonable financial decision about whether to proceed as Energy Only or withdraw from the queue.

The CAISO should also consider allowing these projects, and other C14 Energy Only projects, one more opportunity to request a TPD Allocation, in 2027.  These projects entered the queue under rules that would have allowed them to continue seeking TPD allocations every year, up to and after Commercial Operation, and made their business decisions around those rules.  If the CAISO removes that flexibility, then it should at least give them the same three opportunities to seek an allocation that C15+ projects will have.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

1. MN8 supports the CAISO’s proposal
2. No comment
3. CAISO should allow projects to start the three cycle TPD request window 3-4 years out from the in-service date of the longest lead time contingent NU. It is inefficient for projects to sign PPAs many years out from when they will achieve commercial operation. In order to have an advantage during TPD allocation, projects will be incentivized to sign PPAs with exit clauses or inefficient terms. Lead times for NUs are outside the interconnection customer’s (IC’s) control and should not disadvantage these customers when seeking a TPD allocation.

Projects that receive an allocation in the Conditional group will need to execute a PPA in order to retain their allocation. According to the generic timeline on the IPE webpage, there are 4.5 months between the completion of the TPD Allocation Study and the start of the TPD Affidavits window. While this may provide enough time for ICs in the Conditional group to negotiate and execute a PPA with a single counterparty, it would not provide enough time for ICs to negotiate with a second counterparty if efforts with the first were unsuccessful. A standard negotiation requires at least 90 days in exclusivity with a counterparty. If ICs only have ~135 days, that would not leave enough time to negotiate with multiple parties if needed, which would disadvantage suppliers. To counter this risk, projects in the Conditional group should have 6-8 months to demonstrate an executed PPA (i.e., 1-3 months before the start of the next TPD allocation study).

4. On p16, CAISO clarified that MMAs can be transferred deliverability allocations from projects that were “successful in the deliverability intake scoring process.” We request that CAISO clarify whether MMAs can also be transferred deliverability from projects that already have TPD allocations that did not have to go through the intake scoring process.
5. No comment

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

No comments at this time.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

MN8 supports CAISO’s proposal to assign in-service dates for the use of existing SCD headroom using intra-cluster prioritization. In addition, CAISO should consider allowing resources to come online before their in-service dates under provisional interconnection service.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

MN8 supports the removal of the proposed modifications to the priority for awarding interim deliverability. 

5. Please provide any additional feedback:

We remain concerned about the risk that projects will be admitted to the queue on the basis of TPD that will ultimately not be available when they are seeking an allocation. MN8 has raised this issue in previous rounds of comments, including in February 2024 and April 2024. We reiterate our concerns and offer the example below for further consideration.

Consider three clusters (Cluster X, Cluster Y, and Cluster Z) that are each one year apart with a 1.5 year study process. Projects in Cluster X will be admitted to the queue based on a certain amount of location-specific deliverability (TPD). Say that 1 GW of TPD was approved in the transmission plan immediately preceding intake for Cluster X—in that case, this 1 GW of TPD would not have been shown to any clusters prior to Cluster X. Cluster X would admit up to 1.5 GW of projects based on this TPD.

According to the generic study timeline that was posted to the IPE webpage in April 2024, there will be at least 2 additional clusters (Y and Z) admitted to the queue before Cluster X is able to receive a TPD allocation. If this same 1 GW of TPD is shown to Clusters Y and Z, then 1.5 GW in Cluster Y and 1.5 GW in Cluster Z would each also be admitted for study. By the time Clusters Y and Z are eligible for an allocation, assuming an attrition rate of 33% or less, projects in Cluster X would be expected to have consumed all of the 1 GW in question.

ICs in Clusters Y and Z will only remain in the queue if they believe that new transmission deliverability will be approved at the same locations as their projects in time for when those projects are eligible for a TPD allocation. This is a lot of uncertainty for projects in these clusters to manage, made more acute by higher spend on deposits, site control, and other development expenses.

CAISO should earmark TPD that is made available by the transmission planning process to specific clusters. In the previous example, the 1 GW of TPD should only be shown to Cluster X. This 1 GW of TPD should not be made available in the TPD study until Cluster X is up for TPD allocation. From this point on, this TPD should persist in the models and be shown to subsequent clusters.

If projects drop out of Cluster X prior to its TPD allocation, CAISO could consider showing some of the 1 GW of TPD to Clusters Y or Z.

To the extent that CAISO is concerned about project attrition resulting in insufficient TPD uptake, CAISO should increase the size of the caps above 150%.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

NextEra Energy Resources, LLC (“NextEra Resources”) appreciates the opportunity to comment on CAISO’s Interconnection Process Enhancements (“IPE”) – Track 3 consolidated revised straw proposal. NextEra Resources appreciates CAISO’s commitment to improving the Transmission Plan Deliverability (“TPD”) allocation process to ensure projects with commercial interest are prioritized. While some aspects of the Track 3 proposal meet this goal, others risk needlessly eliminating projects that do, indeed, have commercial interest and overly constricting Load Serving Entity’s (“LSE”) access to a supply of demonstrably viable energy projects that supports energy affordability. NextEra Resources supports the following proposals: [b] multi-fuel projects required to request a specific MW capacity and ranking for each fuel type, as well as the removal of the parking process.

NextEra Resources opposes CAISO’s proposal [a] to remove the shortlisted allocation group. Shortlisted projects and projects actively negotiating a PPA are substantively in different stages of development than projects having no commercial interest. Projects that have been shortlisted by an interested Load Serving Entity (“LSE”) have proven that they are actively out seeking a PPA and are commercially viable. LSEs often shortlist a project waiting for the project to be awarded TPD to advance. Yet, this proposal errantly lumps-in shortlisted projects and projects actively negotiating a PPA with projects having no commercial interest at all. CAISO should distinguish between the two and allow shortlisted projects or projects actively negotiating a PPA to have priority over projects with no commercial interest in the TPD allocation process. NextEra Resources recommends including projects that have been shortlisted into allocation group A or including shortlisted projects in a reinstated group B. At a minimum, being shortlisted needs to be on the TPD scoring criteria and prioritized against other group D projects. If shortlisted projects are not prioritized, CAISO risks awarding TPD to less ready projects with no commercial interest and artificially limiting LSE’s access to projects of commercial interest. 

NextEra Resources strongly opposes CAISO’s proposal [c] changes to the opportunities to seek TPD. Forcing projects to withdraw from the queue after three opportunities to seek TPD is not preferred. Projects already must meet a rigorous set of requirements to demonstrate commercial viability before they can enter the queue and then they must compete to be studied. Additionally, projects seeking TPD are only allowed to enter the queue at locations where sufficient deliverability exists. CAISO, therefore, already has a stringent vetting process prior to studying projects. Removing a qualified project from the queue years after it entered and posted non-reimbursable collateral (and has potentially executed a GIA) is unnecessary and punitive. Projects should be allowed to convert to EO if not awarded TPD. Not allowing projects to convert to Energy Only (“EO”) will lead to less competition for LSE procurement and could lead to more expensive project pricing with long-term consequences for energy affordability. Projects with commercial interest and a PPA could be withdrawn from the queue prematurely. NextEra Resources could support only allowing projects with commercial interest to convert to EO. CAISO could have a list of qualifying criteria (similar to commercial viability criteria) that allows some projects to convert to EO.

Furthermore, the proposal that "projects that do receive an allocation through the Conditional group but are unable to retain their allocation in the next request window by demonstrating an eligible PPA will be withdrawn" risks preventing projects from fully utilizing their three attempts at TPD allocation. If a project receives a conditional allocation but is prevented from securing a PPA due to commercial agreement delays, penalizing the entire project by withdrawing its interconnection request is excessively harsh. Instead, the project should lose the allocated deliverability for that cycle but be allowed to recompete and be re-evaluated in the next cycle under the appropriate priority group. This ensures fairness, particularly if the project secured TPD on its first attempt but fails to demonstrate a PPA shortly after. Allowing the project to remain in the interconnection queue and utilize the remaining two attempts preserves the intended opportunity structure and supports continued project viability based on applicable criteria.

Given the constraints on projects having only three attempts at TPD allocation, and the restriction that Cluster 15 and later EO projects can never seek TPD, it becomes evident that the current structure renders the 2nd priority group (Commercial Operation group) practically null. In actual practice, most interconnection timelines extend beyond six years from the initial request, making it impractical for projects to achieve COD within the first three TPD attempts.

To maintain relevancy and practical applicability, all projects should be allowed to convert to EO after exhausting their three TPD attempts without penalizing their ability to seek future allocations under the 2nd priority group. This approach ensures that the 2nd priority group remains functional and meaningful. Moreover, by allowing projects to convert to EO, we directly address the concerns raised by CAISO regarding bottlenecks and unnecessary deliverability capacity reservations. CAISO's revised straw proposal suggests that EO projects causing bottlenecks and the need for upgrades are a concern. However, converting projects to EO alleviates these issues by preventing stalled projects from holding up valuable transmission resources needed for more viable projects. It ensures all projects have a viable path to contributing to the grid, even if they initially fail to secure deliverability status, thereby enhancing grid efficiency and encouraging the timely development of renewable energy projects.

NextEra Resources strongly opposes CAISO’s proposal [d] that would not allow EO projects to seek TPD through the commercial operation group or through any group at all. CAISO should allow EO projects that entered the queue as FCDS to seek deliverability if the project has a PPA (even if contingent on TPD)?. NextEra Resources appreciates CAISO allowing EO projects one additional opportunity to seek an allocation during the 2025 TPD cycle, but it is unclear if the condition that EO projects cannot have a PPA with contingent language applies to the 2025 TPD cycle or future cycles starting in 2027. It is also unclear how projects that enter the queue as a Merchant option will be affected by these changes.

Guidance from CAISO on a series of questions that follow would be helpful in future proposals. If a Merchant project converts to EO, would it still be allowed to apply for TPD? Additionally, will EO projects in Cluster 14 and earlier will be eligible to seek TPD allocations in cycles beyond 2025, given that the 2025 allocation cycle is stated to be their last opportunity to seek TPD through either the PPA or Shortlist allocation groups? Specifically, are these EO projects still eligible to seek deliverability under all three new priority groups introduced in the proposal, namely, the 1st priority group for projects with a qualifying PPA, the 2nd priority group for projects that have achieved commercial operation, and the 3rd priority group for projects without a PPA, evaluated through a scoring process? Do these projects maintain their rights to three TPD allocation attempts, transitioning soundly under these new priority groups post-2025 as applicable based on the established criteria?

NextEra Resources supports allowing projects to seek an allocation during the interconnection facilities study by demonstrating they have a PPA as a prudent provision. It facilitates early identification of viable projects, promoting efficient resource allocation and minimizing delays. This approach ensures that projects with strong commercial backing are prioritized, thereby streamlining the allocation process.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

While NextEra Resources recognizes that offshore wind and out of state wind may be prioritized in the CPUC integrated resource portfolio, it is vital for CAISO to ensure that all viable and ready projects (regardless of resource type) are treated consistently. Given the numerous supply chain and installation challenges that some long-lead time resources must overcome to bring energy to demand centers, NextEra Resources notes that it is equally important that CAISO ensure that California’s ability to meet aggressive decarbonization goals isn’t unintentionally undermined by overlooking or disadvantaging resources that can reach earlier CODs.  To that end, simply having the authority to reserve TPD for certain long lead-time resources in the tariff does not mean that the CAISO must do so (proactively) in each successive TPD cycle. 

While NextEra Resources recognizes that an underlining objective of the CAISO is to ensure the generator interconnection process provides a pathway for resources prioritized in the CPUC’s resource portfolio to connect to the ISO controlled grid, the CAISO should also observe that the CPUC’s integrated resource portfolio does not include a comprehensive evaluation of known risks and complexities that could impede the development of these resource types. For example, while the CPUC has planned for 7.6 GW of offshore wind to be operational by 2035, this aspirational target does not account for conflicting analysis by the California Energy Commission (CEC) that has estimated that the work to upgrade California’s ports will cost $11 to $12 billion to meet a 2045 offshore wind planning goal. Moreover, the funding sources at the state, federal, and local levels have yet to be identified or secured, and the timing of these upgrades is notably incongruous to the CPUC’s 2035 procurement target. If the CAISO proactively carves out TPD for these resources before they are ready, it may inadvertently undermine California’s broader resource needs/goals by obstructing projects that could utilize that TPD on a shorter timeline with greater certainty. A more prudent approach would be to limit the opportunity for these resources to extend the amount of time to seek TPD to when they actually enter the queue. Otherwise, the CAISO is holding back TPD for a resource that may never materialize. 

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comment at this time.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comment at this time.

5. Please provide any additional feedback:

No comment at this time.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

Part a. (Allocation Groups): NCPA requests that the Proposal section found in Section 2.1 (TPD Allocation Process Modifications; page 17) of the 2023 Interconnection Process Enhancements Track 3 Consolidated Revised Straw Propsoal (or subsequent proposals) be revised to clarify that the "1st priority group" also includes "Interconnection Customers in the current Queue Cluster that are Load Serving Entities serving their own load."

With regard to questions concerning the process for allocation of deliverability to LSE’s with self-built projects serving their own load, NCPA notes that Appendix DD (Generator Interconnection and Deliverability Allocation Procedures) already provides for these allocations. Section 8.9.2 of Appendix DD clarifies that “Load Serving Entities serving their own Load” are part of the same group as interconnection customers that have executed power purchase agreements, and that load serving entities are eligible for all attestations as other interconnection customers are. There is no need for additional process.  This is also consistent with Section 8.9.2 of CAISO Tariff Appendix KK.

Part d. (Eligiblity of Energy Only projects, including technology additions): NCPA believes that the proposed changes to the process for Modification of existing generating facilities are reasonable, provided that this process is clearly distinguished from the project repowering process. CAISO should clarify that the proposal regarding “any technology addition” (Slide 12 of the presentation) does not impact the addition of new technology in the repowering of a resource provided that the change otherwise meets the existing tariff requirements for repowering projects.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

Part a. (Eligibility): NCPA appreciates CAISO’s recognition that non-CPUC LRAs can also designate policy-driven, long-lead time resources. NCPA generally agrees with the criteria that CAISO has laid out on p. 32 of the paper and Slide 19 of the presentation. However, NCPA requests clarification as to whether pumped storage hydro falls within the definition of long-duration energy storage or of long-lead time resources in general. It would seem to satisfy the criteria, and NCPA believes it should be included.

Part c. (Broader procedural changes to the interconnection process for long lead-time, location-constrained resources): NCPA requests CAISO to supplement or clarify in the 2023 Interconnection Process Enhancements Track 3 Consolidated Revised Straw Proposal (or any subsequent proposal) which Area Constraints are impacted by the North Coast and Central Coast Offshore Wind projects that may be eligible for a reservation of a TPD allocation.  This will help stakeholder better understand the impact long lead-time resource policies may have on the interconnection study process. 

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comments at this time.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No comments at this time.

5. Please provide any additional feedback:

No additional feedback at this time.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

See attached

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

See attached

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comments

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No Comments

5. Please provide any additional feedback:

See attached

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

TPD Allocation with Interconnection Facility  

PARS Energy appreciates the opportunity to provide its comment on this proposal. Most off-takers will not agree to signing a PPA before the Facility Study is complete. Off-takers normally want to be cerain that a Project is economically viable and has financing to to build before signing a PPA. Interconnection Facility Study (AKA System Impact Study) does not provide the ultimate project costs. Project costs are established only after Facility Study i(AKA Facility Requirements Study) is complete. Also financing can not be obtained until all project costs have been established. PARS Energy does not support TPD allocation at the interconnection Facility Study and views it as impractical..

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

California utilities have a large backlog of new construction. Some Cluster reports suggest waiting for 10  years or more. The construction of long lead time constrained resouces may be phased for better project economics. The phaasing of the project will be based on utility input such as no later than this dtate and no sooner than this other date. Any Special Considerations for such projects to get partial TPD is welcomed and PARS Energy supports it. 

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

PARS Energy supports intra Cluster prioritization based on SCD/RNU. It can accelerate project construction schedules and is a positive step. However, CAISO needs to develop an equitable process with details as to how it would be implemented. PARS Energy expects that prioritization of projects could be challenged by some developers.  

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

No Comment.

5. Please provide any additional feedback:

Cluster 14 and Prior Parked Projects

The straw proposal does not clearly state the status and options of of Cluster 14 and prior Parked projects. It is suggesed that CAISO add a short paragraph to state the options of Cluster 13 and 14 Parked projects. Issues such as remaining for the full year and exiting Parking status needs to  addressed.

Please revise this paragraph on page 19 of the Proposal. It is mixing TPD allocation with Parking projects.It is also recommended to refrain using words such as likely, possible etc.Instead clearly state the CAISO position.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

REV Renewables (REV) appreciates CAISO’s changes in the Track 3 revised straw proposal. REV is supportive of the direction of this proposal, and has a few clarification and modification requests below.  

1. Allocation Groups – REV supports the proposed allocation groups, including removing the Short List group and creating the Conditional group. The new Conditional group, as with Group D, is an important category that helps developers and LSEs have the critical piece of information on deliverability in the procurement process.
   1. REV requests clarification on pre-Cluster 15 projects that have Partial Capacity Deliverability Status (PCDS) portion of the project already online. REV requests that these partially online PCDS projects would be eligible to receive TPD allocation under the PPA group after 2025 for the remainder of its capacity to receive Full Capacity Deliverability Status (FCDS).
2. Multi-fuel projects receiving an allocation with PPAs – REV has no comment at this time.
3. Opportunities to seek TPD – REV supports with caveats CAISO moving to allow three consecutive opportunities to receive TPD allocation. This additional year will be important with the removal of the Short List category and will assist projects awaiting long lead time upgrades. However, it is not enough to alleviate the projects stuck behind long lead time upgrades, and REV suggests additional years considered for these projects (also see comments in #2 below).
4. Eligibility of Energy Only projects – REV agrees that Cluster 15 and beyond projects that enter as Energy Only should not be eligible to receive TPD, and if those projects want to have TPD they should enter the interconnection process in TPD or Merchant zones. REV supports giving pre-Cluster 15 Energy Only projects in Commercial Operation one more opportunity in 2025 to receive TPD.
5. Modifications to the TPD scoring criteria – REV is generally supportive of the TPD scoring criteria modifications, but continues to support adding criteria related to expansion of an existing facility, such as having an existing gen-tie line.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

REV requests that CAISO allow Cluster 14 projects behind long-lead time upgrades to be eligible in this proposal as well. These projects are similarly situated with having to await long-lead time transmission projects, and further these Cluster 14 projects have no control this timeline as it is dependent on PTO schedules. These projects should have the option (not be required) to choose to extend their next attempt to seek TPD to count against their three opportunities. While CAISO’s proposal to use existing headroom will also help these projects, it is unknown how much headroom is currently available for these projects, and certainly will leave many projects left waiting. Therefore, an additional option is needed to support these otherwise viable advanced-stage projects.

REV suggests that projects could enter the TPD allocation cycle 5 years before online date of the transmission project (or 4 years before for Cluster 14 projects that have already used one of their year opportunities). This would give sufficient time for the project to participate in procurement processes and receive a PPA ahead of their construction timeline.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

REV supports CAISO’s proposal for the Intra-cluster Prioritization of use of Existing SCD/RNU headroom. This opportunity is greatly welcome for projects stuck behind long-lead time upgrades. REV requests that this opportunity not be limited to SCD/RNU upgrades, but should be for any upgrades with a 6-10 year lead-time.  

For this Intra-Cluster Prioritization process, REV suggests that CAISO add TPD scoring criteria on expansion of projects, such as whether the gen-tie or substation facility is already built or at an advanced stage of development. These criteria show projects that are more likely to be ready to be built and online sooner, which should be a priority in this Intra-Cluster Prioritization process.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

REV has no comment at this time.

5. Please provide any additional feedback:

REV requests that CAISO provide information on how many megawatts of WDAT projects are in Cluster 15 and how it will impact other projects, including impact on available capacity and potential network upgrades.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

No comment.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

SDG&E looks forward to reviewing CAISO’s proposed separate interconnection process for long lead time resources. In this regard, SDG&E encourages CAISO to strive for streamlined and efficient processes that will allow PTOs to respond with quickly and accurately (with respect to study results). CAISO has achieved this so far in the generally successful IPE Track 2 and SDG&E hopes CAISO will continue in this manner with any potential new long lead time related processes.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

SDG&E supports this proposal as a necessary step to ensure grid reliability. The current SCD-driven reliability upgrades have long been a concern and may have prevented “first ready” projects from moving forward to interconnection as projects needed to wait for the upgrade when MW thresholds have not been reached. SDG&E supports utilizing available SCD headroom, so long that it does not cause additional reliability concerns. The utilization of headroom will be even more beneficial as resource portfolios increase over the coming years. The affidavit and ranking components of the proposal are necessary measures to ensure that the new SCD process is manageable by existing interconnection staffs. SDG&E encourages CAISO to implement the high level SCD/RNU headroom proposal as presented in IPE Track 3 and looks forward to the details of the procedure as they become available.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

None.

5. Please provide any additional feedback:

None.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

a. Allocation Groups

SEIA does not oppose the proposed TPD allocation group reforms but asks that CAISO provide more implementation details like eligibility criteria for allocation and retention in the PPA group and treatment of projects in the Commercial Operation group. To the latter point, SEIA believes it would be helpful if the CAISO provided more information on how projects will be treated if, for example, TPD is transferred. Would the transferring project be eligible for TPD allocation as an Energy Only project if it reaches commercial operation?

b. Multi-Fuel Projects Receiving an Allocation with PPAs

As noted above, SEIA asks that CAISO provide more detail on how transfers within or to a multi-fuel project would impact TPD allocation eligibility for the transferer and transferee. Following the example provided in the revised straw proposal, could the BESS asset transfer the allocated TPD to the solar asset and, if so, what would happen to the BESS?

c. Opportunities to Seek TPD

SEIA notes that the proposed changes to the TPD allocation methodology imposes significant risk on interconnection customers who will need to execute a GIA and post the required security without any certainty that they will be allocated deliverability. As such, it is imperative that the TPD allocation affidavit due date aligns with the issuance of Facility Study reports and the annual Transmission Plan so that interconnection customers have some sense of the transmission capacity that will likely be available for allocation over the three-cycle period. Further, given the likelihood that RNU and DNU build timelines will not be conducive to project development and the lack of flexibility under the three consecutive TPD allocation cycles approach, it is important that CAISO provide interconnection customers with additional opportunities for interim deliverability.

d. Eligibility of EO projects

As noted above, SEIA asks that CAISO clearly articulate the eligibility requirements for the Commercial Operation TPD allocation group. Further, SEIA encourages CAISO to continue to treat pre-Cluster 15 projects under Appendix DD of the tariff which would permit TPD allocations to Energy Only projects that reach commercial operation.

e. Modifications to the Scoring Criteria

No comment.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

No comment.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

SEIA appreciates and supports this proposal. We agree with parties who advocate for including other types of upgrades beyond short circuit mitigation, and support CAISO refining this proposal to identify other types of upgrades whose inclusion would be an effective use of engineering resources.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

SEIA supports the removal of the proposed modifications to the priority for awarding interim deliverability and reiterates its request that CAISO work with stakeholders to identify additional interim deliverability options to support resource development.

5. Please provide any additional feedback:

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

In general, the Six Cities continue to support the CAISO’s efforts to simplify its TPD Allocation process in Track 3 of this initiative.  In particular, with respect to section a, the Six Cities generally support the CAISO’s proposal to reduce the number of allocation groups to three.  However, the Six Cities request that the CAISO revise its proposal to specifically state that the 1^st priority group includes, in addition to projects that have executed Power Purchase Agreements (“PPA”), projects where the interconnection customer is a Load-Serving Entity (“LSE”) serving its own load.  This language is included in the CAISO’s definition of existing TPD allocation group A. The Six Cities request that it be added to the instant proposal as well to ensure that the current priority for LSEs that are interconnection customers with respect to projects that are intended to serve LSEs’ native load is included in the TPD allocation process on a going-forward basis.  Similarly, with respect to section e, the Six Cities do not oppose the CAISO’s proposed modifications to the TPD scoring criteria so long as LSEs serving their load are included with the PPA group for purposes of allocation priority ranking.

In addition, the Six Cities:

• Do not oppose the CAISO’s proposal on multi-fuel projects receiving an allocation with PPAs (section b).
• Support the CAISO’s proposal to discontinue the “parking” process and require that all projects must make any required increases to their Commercial Readiness Deposits following the completion of their required interconnection studies (section c).
• Continue to support the CAISO’s proposal to allow three consecutive opportunities for an allocation of TPD begin after the facilities study report has been published, keeping all cluster projects on the same schedule for seeking and retaining TPD (section c).  In particular, the Six Cities agree with the CAISO that three opportunities to retain a Conditional TPD allocation is sufficient for a project to demonstrate its viability for obtaining a PPA.
• Support the CAISO’s proposed approach on Energy Only projects (section d).

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

The Six Cities recognize and support the need for continued and enhanced transparency in the process used thus far in assigning deliverability to Long Lead Time (“LLT”) resources.  The Six Cities share the concerns articulated by other stakeholders in this initiative that the practices used to date may be detrimental to LSEs that are not subject to the jurisdiction of the California Public Utilities Commission (“CPUC”), to the extent that TPD is being reserved for projects that directly support CPUC resource plans and policies and consequently reducing the amount of deliverability that is available to other resources that are needed to meet the procurement requirements of non-CPUC jurisdictional entities. 

Further, the CAISO’s transmission and interconnection policies should accommodate the ability of non-CPUC Local Regulatory Authorities (“LRAs”) to identify LLT resources on a basis that is comparable to the CPUC’s ability to make such designations.  The CAISO should coordinate directly with non-CPUC LRAs (and their LSEs) to collect information about LLT resources to ensure the CAISO’s planning assumptions are accurate with respect to these types of projects.

The Six Cities generally support the CAISO’s proposed criteria for determining eligible interconnection requests with respect to LLT resources, as listed on page 32 of the CAISO’s consolidated revised straw proposal.  With respect to the location-constrained category of interconnection requests deemed eligible under the consolidated revised straw proposal, the Six Cities request that the CAISO clarify whether the meaning of the term as used in this context matches the meaning of the term “Location Constrained Resource Interconnection Generator” as defined in Appendix A of the CAISO tariff.  If so, then the definition of the term “Energy Resource Area (ERA)” in the CAISO tariff may need to be expanded to include geographic regions certified by non-CPUC LRAs.  More broadly, it would be helpful to understand the process currently anticipated to be used by the relevant agencies for purposes of designating such areas (if any).

The Six Cities’ September 18, 2024 comments in this initiative addressed concerns with the need to align the time period for constructing network upgrades needed for LLT resources to ensure that there is not a mismatch between when these resources are expected to reach commercial operation status under LRA programs, and when the associated upgrades needed to provide deliverability are completed.  For example, the Six Cities remain concerned with the possibility that a resource with commercial readiness to come online and begin providing energy and capacity in 2025 – and that is expected to do so based on terms included in the project PPA – could potentially be delayed in its ability to provide resource adequacy capacity because the necessary network upgrades will not be completed until months or years later.  The CAISO’s proposal to include an option to take additional time to seek TPD to better align with commercial milestones and procurement may help address the Six Cities’ concerns in this regard.  Accordingly, the Six Cities would support further exploration of this option.

Additionally, the CAISO has requested feedback concerning whether there is a need for a separate interconnection process specific to LLT resources.  The Six Cities acknowledge that there may be value in considering this approach, and the Six Cities therefore do not oppose the suggestion to engage in further discussions of such potential need.  However, the Six Cities urge that any separate process arising from these discussion should not be permitted to slow down the “regular” interconnection process for non-LLT resources.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

The Six Cities do not oppose the CAISO’s proposal on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

The Six Cities do not oppose the CAISO’s proposal on Modifications to the Priority for Awarding Interim Deliverability.

5. Please provide any additional feedback:

The Six Cities do not have any additional feedback at this time.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

SCE supports the CAISO’s latest proposal within the Track 3 Consolidated Revised Straw Proposal for the TPD allocation groups, with a proposed modification and clarification.

SCE agrees that until parties execute a PPA, the CAISO should not prioritize the allocation of deliverability and instead preserve deliverability for projects that have the highest likelihood of coming online. This proposal ensures that only a commercial commitment places a project in the highest allocation group. While shortlisting status does indicate commercial interests, it is a signal of commercial interest at a very early stage of a procurement process and should not be relied upon when allocating deliverability. Stated another way, deliverability should only be allocated to projects that the CAISO believes will come online.

SCE proposes a modification to bolster the likelihood that an interconnection customer with a PPA will achieve its commercial online date by stipulating that a PPA is valid only if the PPA contains a posting requirement of at least $40/kW. As a way for the CAISO to validate this requirement, the off taker, for example, could provide an attestation stating that such a posting has been made. Without a posting requirement, developers will have an inexpensive, or free, option to get in front of the deliverability allocation queue. Therefore, without a minimum deposit, the CAISO may be in a comparable position to the Shortlist allocation group wherein deliverability will be assigned to projects that do not have firm commitment between the off-taker and the developer; and without a firm commitment between the off-taker and the developer, the project’s viability remains uncertain.

Finally, SCE seeks clarification that the criteria to be considered in the PPA group as an LSE serving its own load is an executed agreement to build or purchase a project (e.g., EPC agreement, build own transfer agreement, or other relevant purchase agreement). Furthermore, because these projects will be serving the LSE’s own load, the project will receive an additional 5 points in the TPD allocation process(1).

[1] Table 2 on page 22 of CAISO’s Track 3 Consolidated Revised Straw Proposal

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

SCE agrees that the CAISO should align its view of long lead-time resources with the CPUC. SCE proposes the CAISO modify their proposal to either:

1. only consider projects where the entire interconnection request capacity is being utilized by CPUC defined long-lead time resource types or,  
2. Only assign deliverability through the long lead-time deliverability allocation process to the capacity of the project that truly meets the long lead-time requirements of the CPUC.

Either modification will prevent the potential for developers to game the long lead-time deliverability allocation process by circumventing the normal path of achieving deliverability. SCE recommends the CAISO adopt (1) because it eliminates any potential for gaming. In short, deliverability is an important commodity that should be fairly allocated to the best projects to serve customers.  It would be a poor outcome if deliverability that was intended for long lead-time resources is allocated to resources that are not truly long-lead time resources.

Also, while possibly beyond the scope of Track 3, SCE encourages the CAISO to examine if the queue intake process should be modified to ensure that similar gaming cannot also occur and lead to unintended outcomes in the deliverability allocation.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

SCE supports the CAISO’s proposal to allow generators to interconnect up to an amount that would not trigger the need for long lead-time short-circuit or other reliability network upgrades. SCE has made efforts to address this issue in the past, but having a formal CAISO process would address transparency, equity, funding, and allocation prioritization concerns. SCE also agrees that such a process should ensure there is adequate margin to accommodate the impacts of Rule 21 projects, Wholesale Distribution Access Tariff (WDAT) projects, and base case changes as well as require sufficient commitments from generation projects that partake in this process as suspensions or date extensions could cause the need for restudies. This effort should also address if GIAs would include both the original in-service dates due to the long construction-time upgrades and the new in-service date due to the Intra-cluster Prioritization effort and the resources required to modify GIAs. 

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

SCE has no comment.

5. Please provide any additional feedback:

SCE has no comment.

1. Please provide your organization’s questions or comments on the Modifications to TPD Allocations by these sections:

a. Allocation Groups b. Multi-fuel projects receiving an allocation with PPAs c. Opportunities to seek TPD i. In addition, the ISO seeks stakeholder input on whether a project should be able to seek an allocation during the interconnection facilities study by demonstrating they have a PPA. d. Eligibility of Energy Only projects, including technology additions i. The ISO seeks stakeholder input on whether pre-cluster 15 EO projects should be able seek TPD through the Commercial Operation group after the 2025 TPD allocation cycle. e. Modifications to the TPD scoring criteria

Terra-Gen, LLC (Terra-Gen) appreciates the opportunity to comment on CAISO’s IPE Track 3 Consolidated Straw Proposal.

a. Allocation Groups

Terra-Gen does not support the CAISO proposal to remove the option for shortlist/active-negotiations status to qualify under the 2025 TPD Allocation Group D and the post-2025 TPD Allocation as a separate Shortlist Group or a feature of the new Conditional Group. 

Commercial Interest from LSE’s as demonstrated by being short-listed or in active negotiations is an important marker for project viability. Furthermore, viable development projects require timing flexibility in their milestones to succeed and LSE solicitations and PPA execution dates often do not line up with the CAISO’s affidavit submittal dates and developers like Terra-Gen need that interim step to move forward from a shortlist position to secure a PPA once TPD has been allocated.

b. Multi-fuel projects receiving an allocation with PPAs

Terra-Gen supports CAISO’s proposal for allowing projects to request TPD allocations for Multi-Fuel Resources (MFRs) and detailing the requested prioritization between different fuel-types and/or specific portions in its TPD Allocation request. 

Terra-Gen also requests that CAISO consider augmenting its subsequent proposals for MFR TPD allocations for MFRs with specific technologies/fuel types that are given preference in the TPD allocation process, such as Long Duration Energy Storage (LDES), to designate the entire project capacity to be afforded priority status for TPD allocations. This additional prioritization is essential because such projects are likely only viable if the overall project capacity including all technology types are afforded the respective requested TPD allocations.

c. Opportunities to seek TPD 

Terra-Gen supports CAISO’s proposal to allow three opportunities to seek TPD with the caveat that the first opportunity should follow completion of the Facilities Study and align with the next TPD affidavit due date to allow future clusters to have enough time to facilitate participation in the TPD allocation process. Terra-Gen also supports the proposed option to seek TPD Allocation sooner if they can demonstrate a PPA has been executed.

d. Eligibility of Energy Only projects, including technology additions

Terra-Gen strongly recommends that CAISO retain the option for Interconnection Customers (IC) with C15+ Energy-Only (EO) projects to be eligible to seek TPD allocations post achieving Commercial Operation. Although it has been discussed that developers are unlikely to invest in projects without certainty regarding TPD allocations, particularly for projects heavily reliant on TPD, such as energy storage, there are some key reasons that these outcomes may still occur and could be a viable path to add needed resources in a timelier manner. Due to the details outlined below, Terra-Gen requests CAISO seriously consider keeping this option available for projects that have reached Commercial Operation.

By permitting EO projects to pursue TDP allocations after achieving Commercial Operation, CAISO can realize several benefits for the system, its markets, and ratepayers alike, including the following: Retaining this option can help to optimize grid operations by leveraging the operational flexibility of storage resource additions to MFR co-located and hybrid resource configurations, which can further enhance system reliability and efficiency. This option can also assist in encouraging investment in clean energy resource projects by facilitating the expansion of existing facilities that can reduce renewable curtailment and improve transmission system utilization, as well as providing additional reliability and resource adequacy capacity in a cost-effective manner. This also aligns with State policy goals by supporting California’s aggressive climate and reliability aspirations by maximizing the utilization of existing and future clean energy resources.

Restricting EO projects from seeking TDP allocations when they are operational and capable of providing valuable grid services would be contrary to CAISO’s fundamental obligation to support the state’s clean energy and reliability objectives. Furthermore, it would undermine the flexibility and efficiency of the CAISO market design. For these reasons, Terra-Gen recommends that CAISO maintain the eligibility of C15+ EO projects to seek TDP allocations post-Commercial Operation.

e. Modifications to the TPD scoring criteria

Terra-Gen generally supports the revised TPD scoring criteria. However, Terra-Gen only supports the inclusion of certain aspects of Generator Interconnection Agreement (GIA) status items with some additional caveat that CAISO should grant points in recognition that Participating Transmission Owners (PTO) processes and prioritization discretion may unfairly delay GIA status related progress. 

For instance, CAISO has proposed two items under the GIA Status category: IC has provided payment and security to the PTO – worth 10 points; and, PTO has received written authorization to proceed with construction from the IC – worth 7 points. While Terra-Gen acknowledges these GIA status milestones indicate some progression and advancement, these steps require some cooperation, collaboration, and concurrence from the PTOs on related aspects to advance the GIA execution process.

Such timing delays may be out of the control of developers that have proceeded in a timely manner with aspects under the ICs own control but may be delayed due only to PTO inaction, without any fault or delay due to the IC.  In our experience, Terra-Gen has experienced delays in moving forward with GIA execution progress, specifically in some instances being delayed over six months. These delays are completely outside of our control and due solely to PTO discretion and prioritization. Therefore, Terra-Gen requests that CAISO consider proposing to allow ICs to demonstrate progression of GIA status has been delayed by PTO and still be eligible for receiving either 7 or 10 points under the GIA status category in the TPD scoring criteria.

2. Please provide your organization’s questions or comments on Special Considerations for Long Lead Time, Location Constrained Resources, specifically:

a. Eligibility b. Extension to seek TPD c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

a. Eligibility

Terra-Gen avers that CAISO must refine its definition of Long Lead Time (LLT) resources to ensure clarity and fairness in the allocation of transmission capacity. The currently proposed classification / categorization as “Location Constrained Resources” is overly broad and ambiguous, as many resource types, including onshore wind and large-scale solar, are inherently locationally constrained.

To address this issue, Terra-Gen suggests a more targeted approach that focuses on resources with specific, technology-driven long lead times. CAISO should identify LLT resources based on legislative or regulatory requirements, such as those related to specific technologies like offshore wind or advanced nuclear.

Once these LLT resources are identified, Terra-Gen recommends that CAISO reserve a portion of transmission capacity in the Transmission Planning Process (TPP) for these projects. This “holdback” capacity should be directly tied to specific transmission upgrades approved in the TPP to accommodate the LLT resource. By adopting this approach, CAISO can ensure fairness in allocating transmission capacity to projects that truly require long lead times due to technological constraints, align transmission planning with long-term resource needs, and avoid unnecessary delays and costs.

Terra-Gen also recommends that CAISO reconsider its proposal to limit Interconnection Requests (IRs) for LLT resources to the amounts in LRA portfolios, as this approach is impractical and could hinder the development of LLT projects. Instead, the CAISO should allow all qualifying LLT IRs to compete for the available holdback capacity, using a transparent and objective scoring process.

Additionally, Terra-Gen has previously commented on the ongoing implementation of CAISO’s LLT allocation reservation process to suggest that CAISO must clarify its methodology for implementing LTT deliverability reservations, as highlighted above in part.  Terra-Gen also takes this opportunity to reiterate prior feedback, and include a request that CAISO make clearer and more transparent how specific LLT TPD reservation amounts were determined, what technology output factors (%) are applied, and the impact on available TPD for other non-LLT resources. Further, Terra-Gen continues to recommend that CAISO should also consider the potential impacts of these reservations on the ability of other traditional resources to achieve deliverability and ensure that policy-driven planning and deliverability reservations for LLT resources accurately account for existing/planned and future upgrades needed to provide adequate deliverability for LLT and other resource types.

By implementing these recommendations CAISO can ensure an efficient, fair, and equitable process for allocating TPD capacity to LLT resources without unfairly restricting other non-LLT from receiving TPD allocations, thereby supporting California’s clean energy goals.

b. Extension to seek TPD

No Comment.

c. Broader procedural changes to the interconnection process for long lead-time, location-constrained resources

See response to part (a) above – Terra-Gen also notes CAISO should consider the feedback provided above regarding the impact of LLT planning, development, and deliverability reservations on the overall queue and viability of near-term projects under later-stage development.  Additionally, Terra-Gen reiterates that the use of location-constrained as a classification or categorization is problematic without some well-designed guiding principles and clear criterion being established to support clear designations of specific resource types and locations that would achieve eligibility for certain proposed treatments. The CAISO proposals on LLT resources deserve more focus and refinement and should not be rushed, which is a good reason to consider opening an additional track of the IPE process to consider all LLT related aspects holistically.

3. Please provide your organization’s questions or comments on Intra-cluster Prioritization of Use of Existing SCD/RNU Headroom:

No comment.

4. Please provide your organization’s questions or comments on Modifications to the Priority for Awarding Interim Deliverability:

Terra-Gen reiterates prior feedback that CAISO has not pursued in its proposal development regarding further enhancements to extending and opening more opportunities for interim deliverability status. Terra-Gen recommends that CAISO should develop and implement a longer-term interim or conditional deliverability policy that provides the ability to provide Resource Adequacy sooner when appropriate and identified as low impact or low risk. Additionally, CAISO should develop a proposal to expand the use of interim deliverability, including multi-year durations.

Terra-Gen also recommends that CAISO propose to hold IC/PTO/stakeholder working groups on an ongoing basis as part of its TPP and TPD allocation cycles with a focus on identifying any short-term solutions or mitigations that can address interim deliverability needs prior to longer-term TPP upgrades to be developed and placed in-service.

5. Please provide any additional feedback:

TPD Transfer clarifications

CAISO’s proposal regarding TPD transfers is currently unclear. Terra-Gen suggests that CAISO must provide further clarification on the following points in the next Track 3 document:

• Transfers to PCDS Projects and MMA Additions: The specific conditions under which TPD transfers to PCDS projects or MMA additions to FCDS/PCDS projects will be permitted, particularly regarding POI, voltage level, and PPA requirements.
• Transfers to Energy Only Projects and MMA Additions: Whether TPD transfers to MMA additions to Energy Only projects will be strictly prohibited, or if there may be limited exceptions under certain circumstances.

Terra-Gen requests additional clarity on these points to ensure that market participants have a clear understanding of the rules governing TPD transfers and can make informed decisions regarding project development and operations.

Cluster 15 study limits and LLT reservation impacts

Terra-Gen believes that CAISO’s approach to the Cluster 15 intake process and LLT reservations for offshore wind (OSW) has created inconsistencies and unfairness in the allocation of transmission capacity.

Cluster 15 intake figures were reportedly based on remaining TPD after the 2023-2024 TPD Allocation process, which did not consider the OSW-related upgrades approved in the 2023-2024 TPP. Terra-Gen is concerned that by reserving ~1,600 MW of TPD for OSW without including the capacity additions for OSW in the 2023-2024 TPP, CAISO has unfairly impaired the TPD remaining for other projects.

Terra-Gen suggests that the CAISO should have either:

• Included the OSW-related upgrades approved in the 2023-2024 TPP and held back TPD for the 1,600MW in the CPUC portfolio for that cycle.
• Retained the TPD from the 2023-2024 TPD Allocation cycle, which was based on the 2022-2023 TPP, and not reserved any TPD for OSW.

Overall, it is simply not clear that CAISO has conducted the initial OSW LLT reservations in a fair and equitable manner, and the TPD allocation of transmission capacity for all projects, including later-stage development projects have likely been unfairly impacted by the lacking rollout by CAISO’s approach for LLT resources reservations.

Cluster 14 parking and posting requirement timing issues

Terra-Gen suggests that the CAISO should propose tariff changes to postpone the second financial security posting for Cluster 14 projects coming out of parking for the next TPD Allocation cycle. The current tariff provision, which delays the posting only 12 months, does not align with the original intent of allowing projects to delay the posting until they receive TPD Allocation results and can make informed decisions about their future. Additionally, Terra-Gen recommends that the CAISO consider allowing Cluster 14 Energy Only projects, including those coming out of parking, one more opportunity to request a TPD Allocation in 2027. These projects entered the queue under rules that provided multiple opportunities to seek TPD allocations and removing that flexibility without providing a comparable opportunity would be unfair.