Comments on Issue paper and straw proposal

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

ACP-California appreciates the opportunity to comment on the CAISO’s IPE Straw Proposal. We applaud CAISO for thinking creatively about modifications that might help address interconnection and deliverability issues and create a more workable process going forward. We offer some comments on specific proposals in the following comments. Overall, it will be important to ensure that the final set of proposals that move forward in IPE achieve a balance between two things:

1. Modifications are sufficient to reduce the number of non-viable interconnection requests, such that the interconnection and deliverability processes become workable on reasonable timelines and are no longer clogged with requests that are unlikely to move forward
2. Allowing flexibility for unique/non-standard, but viable, projects to proceed and successfully complete the interconnection process and receive a deliverability allocation.

In some areas we provide specific recommendations to help achieve these two goals and facilitate additional clean energy resource coming online in a more timely fashion. We also look forward to working with CAISO on modifications to various processes that would allow, in unique instances like that for Offshore Wind, the reservation of transmission capacity on the system for public policy directives and to the opportunities to incorporate solicitation models going forward.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

CAISO proposes to revise the TPD Allocation process, including simplifying the allocation groups to three and removing the option to proceed without a PPA. CAISO clarified during the stakeholder meeting that this item is intended to be part of Phase 1 of IPE, such that it could be implemented during the 2022-23 TPD Allocation cycle where Cluster 14 customers could seek a deliverability allocation.

ACP-California generally supports the streamlining of the TPD allocation process, with modifications (as discussed below), and recognizes the need to make changes to ensure that projects receiving deliverability allocations are ready to move to operation. We also recognize the importance of implementing this change for Cluster 14 to help address the large magnitude of projects and capacity in Cluster 14, but we recommend modifications to CAISO’s proposal to strike a balance between addressing the magnitude of the queue and providing flexibility to developers and market participants to enable project success. Additionally, CAISO should provide specificity around the requirements it will implement to demonstrate a “qualified” PPA under this new process and should modify its proposal to include a path whereby there is an option (albeit with higher requirements) to proceed for a TPD allocation without a PPA.

While ACP-California generally supports the streamlining of the TPD Allocation process, we have concerns about the amount of upfront development risk that may need to be undertaken to secure a PPA or be shortlisted/actively negotiating a PPA without a clear line of sight to a deliverability allocation. Thus, we urge CAISO to include a modified option (with higher deposits and capital at risk) for projects to compete for a TPD allocation without being shortlisted/actively negotiating or having secured a PPA. Many projects that initially do not have a PPA later acquire one and use the current “Group 3” to do so. In fact, these projects use the “Group 3” process to demonstrate their path to a deliverability allocation to potential offtakers in order to secure a PPAs. Thus, it is critical to the development/procurement processes that CAISO’s new TPD allocation process include an option for developers to proceed without a PPA. While retaining an option to proceed without a PPA is important to the development/procurement process, we also recognize, given the volume of the queue, the need to streamline the TPD allocation process and to increase the barriers/requirements for TPD allocations. Thus, the modified option to compete for a TPD allocation without a PPA should incorporate higher deposit and capital-at-risk provisions for projects that choose to proceed in this manner. ACP-California will support the application of the change to the TPD allocation groups for Cluster 14 (the 2022-23 TPD allocation cycle) if CAISO includes an option to move forward without a PPA,  but with higher requirements, as discussed above. 

If CAISO continues to propose a process that does not incorporate an option to proceed to a TPD allocation without a PPA, it will be crucial, at a minimum, for CAISO to continue the work it is doing (and which Gridwell supported) to provide additional information and transparency around likely deliverability capacity at different interconnection points on the grid. This type of information will be crucial for developers as well as LSEs and, without it, it may be very challenging for LSEs to determine which resources to shortlist/procure because they are likely to be capable of securing deliverability, which could undermine the intent of these modifications. We urge CAISO to continue its information and transparency efforts on deliverability availability and to commit to working with LSEs to provide digestible information on deliverability on the system.  Furthermore, if the process is going to require or slant toward shortlisted projects or projects with PPAs, procurement opportunities need to be regular and predictable to make sure the timelines line up for both assessing development risk and making sure meeting COD is possible. The CPUC acknowledged this in a recent proposed decision adopting the Preferred System Plan: Section 7.3.2 talks about the CPUC’s recognition of the need for more predictable procurement and assignment of procurement to LSEs from the IRP process as compared to previous years.[1] Thus, CAISO should work with the CPUC to promote transparency on suitable locations and work to better align procurement and interconnection timeframes.

We also urge CAISO to use caution in implementing specific requirements for PPAs to qualify for the TPD Allocation process. There are many different (and sometimes unique) contracting structures being used in today’s market that should be able to secure a deliverability allocation under the rules CAISO ultimately implements. For instance, during the stakeholder call there was discussion about PPAs with commercial/industrial offtakers where the energy/renewable attributes may be sold to the commercial offtaker while the RA value is sold to a Load Serving Entity (LSE) with an RA obligation. There are also storage contracts which may include the sale of RA attributes but not the energy/arbitrage, among similar arrangements for hybrids and other resource types. It will be critical that these types of arrangements, and other unique structures that ultimately benefit LSEs with RA obligations are able to proceed through the deliverability allocation process. Thus, CAISO should provide more specificity on what requirements may be in place to demonstrate that the PPA that has been executed or is under negotiation is with an offtaker to fulfill its own RA obligation, so that projects under development can ensure that their contracts are appropriately structured to meet this requirement. 

Additionally, under the current interconnection and deliverability processes, renewable energy developers already assume considerable risk; however, transmission owners are not held accountable for completing upgrades in a timely manner, and CAISO does not provide sufficient detail regarding the availability of interim deliverability. CAISO should provide more advanced transparency regarding interim deliverability to developers. Transmission owners should also be held accountable to complete upgrades in time to ensure that developers are able to meet milestones and requirements. Project developers should not be forced to assume additional risk without both additional clarity and accountability around the deliverability allocations.

[1] California Public Utilities Commission Proposed Decision Adopting a Preferred System Plan.  https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M434/K547/434547053.PDF. p. 149.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

CAISO should consider making modifications to the transmission planning process and/or IPE to ensure that sufficient transmission is built to meet future needs of the system, as the delays in transmission approval, permitting and construction are exacerbating reliability challenges on the system. CAISO’s 20-Year Transmission Outlook should be a helpful data point in understanding the magnitude of future system needs and may inform what types of changes should be considered to better align the interconnection process, procurement activity and the transmission planning process. Ultimately, the CAISO and CPUC long-term planning processes should serve to build out the “backbone” transmission system and to inform the interconnection process, similar to what has been done in MISO. We encourage CAISO to leave this item on aligning interconnection, procurement and transmission planning “in scope” for Phase 2 of this initiative and to explore it in more depth after the release of the 20-Year Transmission Outlook as part of the 2021-22 TPP.

CAISO also asked for stakeholder input on withholding transmission capacity specifically for policy-driven processes for which it was planned rather than relying on interconnection requests to allocate transmission capacity on the system. This type of “withholding” or “reserving” of transmission capacity for policy-driven needs is unlikely to work on a broad scale for all resources seeking to interconnect to the CAISO system, especially because virtually all resources currently looking to interconnect will be supporting policy-driven processes and it is unclear how CAISO could pick “winners and losers” between similar resources. However, this type of an approach should be utilized in limited areas of the CAISO grid where there are unique public policy needs and where resources have limited interconnection options. For instance, this type of approach seems to be well suited to ensuring that the transmission capacity in the Diablo area is utilized for Offshore Wind (OSW) resources. This area of the system warrants unique policy-driven attention given that 1) offshore wind development in the Morro Bay Wind Energy Area represents the only opportunity to bring commercial-scale offshore wind online in the Central and South Coast of California within the next decade; 2) there is significant transmission capacity available today and in the future when the Diablo Canyon Nuclear Power Plant retires (5-6 GW); and 3) offshore wind is a high capacity factor resource, which will provide system reliability and total resource cost benefits in California’s future electric system. Unlike many other resource types, OSW is highly limited in its interconnection options. The CPUC recently indicated policy support for including offshore wind in the December 2021 Proposed Decision Adopting a Preferred System Plan, stating “The State of California has a policy interest in ensuring that at least a portion of the central cost transmission capacity associated with Diablo Canyon can be utilized for offshore wind development.“[1]  The CPUC also notes “…the state has a significant interest in fostering the development and deliverability of the resources needed to achieve our clean energy goals. Therefore, in this decision we make clear our policy interest in ensuring that at least a portion of the central coast transmission capacity can be utilized for offshore wind development.[2]

ACP-California supports implementing modifications to the transmission planning and deliverability allocation process that would allow for CAISO to receive public policy direction from the CPUC to “reserve” capacity for certain resource types, such as offshore wind or geothermal, both of which are highly locationally constrained in their interconnection options and are part of the state’s long-term resource plans. It will be critical to get these types of reforms in place ahead of the opening of Cluster 15, such that the appropriate transmission capacity can be reserved through this process and new interconnection requests do not enter the queue and use up some of the capacity that would be reserved through a process of this nature.

[1] California Public Utilities Commission Proposed Decision Adopting a Preferred System Plan.  https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M434/K547/434547053.PDF. Finding of Fact 22.

[2] California Public Utilities Commission Proposed Decision Adopting a Preferred System Plan.  https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M434/K547/434547053.PDF. P. 141.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

Solicitation models should be further explored in this stakeholder process over the coming months and especially once there is additional certainty on the “Phase 1” proposal. Both solicitation model options that CAISO has outlined could be helpful in addressing the overheated queue and in helping CAISO (and the CPUC) understand the development interest in certain areas and, thus, we encourage additional dialog on these options in the coming months.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

Under this topic area, CAISO has dropped consideration of an accelerated process for “ready” projects in general and is, instead, proposing to implement a framework for emergency, interim, reliability-driven interconnection service. The CAISO proposal would, seemingly, memorialize the process that was used in summer 2021 in response to the Governor’s emergency proclamation. While we appreciate the CAISO’s interest in developing and memorializing a process for emergency interconnection service, we are concerned that doing so may serve to normalize this type of process. Emergency procurement to address capacity shortfalls is not the method California should be relying upon to address its energy and capacity needs. Despite these concerns, having a process in place that clearly defines how such a process should work and is designed to ensure that emergency capacity shortfall resources are not able to “queue jump” will likely be beneficial and will add transparency to the process, should it be needed in the future.    

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

CAISO has proposed higher study deposits, as well as tiered study deposits that increase with the number of interconnection requests submitted by projects owned by the same parent company. These modifications will lead to more “capital at risk” for project developers and therefore should be met with increased transparency of information and increased accountability of the transmission owners, as discussed above. While we understand the CAISO’s objective of reducing the number of unviable interconnection requests submitted, we caution that experience in other regions has shown that increasing study deposits alone has not proven to be sufficient to address overheated queues. However, implementing additional capital at risk requirements can be helpful if coupled with other proposals, such as some sort of “readiness” requirement implemented at some point during the interconnection process.  

CAISO’s proposal to increase study deposits for multiple projects with a common owner is discriminatory and should be rejected, as the CAISO has not provided evidence that an individual IR submitted by a large developer places a greater burden on the study process or is less likely to be viable than an IR submitted by a smaller developer. We recognize that, in proposing these changes, CAISO is seeking to reduce the volume of interconnection requests that are received in a cluster window to a more management amount such that future queue processing can be timelier and more effective. To achieve this, we recommend that CAISO consider higher capital at risk requirements and increase transparency and provide information to interconnection customers on the high-level likely viability of their requests earlier in the queue process.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

CAISO has proposed to require site exclusivity for projects to progress into the Phase II study process.  Site exclusivity is one factor in project “readiness” and implementing a requirement to demonstrate site exclusivity during the interconnection process is intended to weed out unviable interconnection requests. ACP-California supports implementing some form of readiness requirement during the interconnection process, as these requirements are likely to be necessary to mitigate the overheated nature of the queue; however, ACP-California recommends providing some additional flexibility for Cluster 14, given the advisory nature of Cluster 14’s Phase I studies and the fact that the cluster is already in process and achieving site exclusivity by the Phase II date may be highly challenging, even for the most “viable” projects.

For clusters 15 and beyond, the implementation of a site exclusivity requirement may be a good “gate” for proceeding to the Phase II study process (though there may be special considerations or details required for offshore wind, as discussed more below). However, for Cluster 14, the imposition of a site exclusivity requirement to proceed to the Phase II study may be problematic. Cluster 14’s Phase I study results will be deemed “advisory” and acquisition of site control may be extremely expensive to secure. It may also be very difficult to obtain site exclusivity by the time it would be required to proceed to the Phase II study process. Thus, Cluster 14 should be provided some flexibility on this proposal. To help reduce the number of unviable interconnection requests in Cluster 14 that proceed into the Phase II study process, ACP-California recommends that CAISO implement a higher deposit and “capital-at-risk” option for Cluster 14 projects that cannot demonstrate site control but still wish to proceed to Phase II.

With respect to offshore wind ACP-California recommends additional discussions on the definition of site exclusivity for these resources and whether there are special timing considerations (such as the timing of the BOEM lease auctions) that need to be taken into account going forward.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

CAISO’s proposed solution for an alternative cost allocation treatment for network upgrades to local systems is problematic in that it fails to properly allocate costs to beneficiaries and could have unintended consequences. Thus, we recommend CAISO consider alternative approaches for this item. CAISO’s proposed solution, which would address situations like those faced by Valley Electric Association (VEA), is to establish a 15% transmission revenue requirement threshold for each PTO. And, under CAISO’s proposal, when low-voltage interconnection costs exceed that 15% threshold, future interconnection customers would be responsible for all incremental low voltage interconnection costs in that area (without reimbursement). This solution is highly problematic. It would likely serve to inhibit generation that interconnects to the VEA area, by making generation above a certain level in this region more expensive to LSEs than generation in other regions (due to the direct inclusion of low-voltage interconnection costs in the cost of the generating facility itself). It also does not reasonably allocate costs to beneficiaries and may be unduly discriminatory for generators interconnecting to VEA (as compared to generators interconnecting to other PTOs that have not met this threshold). Additionally, there may be unintended consequences if a current (or future) PTO hit this threshold at some future date. Unintended consequences could include pushing interconnections onto the higher voltage system of the PTO (which may or may not be beneficial depending on the specific circumstances) and/or creating disincentives to interconnect to certain PTO areas.

ACP-California recommends that CAISO further consider implementation of alternative “a”, “c”, or “d” as submitted in VEA’s prior comments (here). These options would allow low-voltage interconnection costs to generally be included in the regional TAC (alternative “a”) or create a targeted exception for carbon-free resources developed outside California to serve California LSE needs (alternative “c”) or create a targeted exception for policy-driven resources in an area identified as desirable for development by the CEC/CPUC (alternative “d”). While FERC rejected CAISO’s prior proposal to create a unique low-voltage interconnection cost allocation approach for a “Certified Small PTO”, each of these alternatives is different than the prior approach and warrants further review, as each would be preferable to the approach currently proposed by CAISO.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

ACP-California supports CAISO’s proposal for an expanded errors and omissions process. With respect to the thresholds that CAISO has proposed for the application of errors/omission process, we recommend adding language that acknowledges that the deliverability start date is also critical to commercial viability. Under this approach, the process would apply when an error or omission is discovered after either the first of second IFS posting that increases aggregate interconnection costs by more than 5% or pushes back the earliest in-service date or FCDS/PCDS effective date by more than12 months.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Amazon Energy LLC (“Amazon”) appreciates the opportunity to comment on CAISO’s “Interconnection Process Enhancements 2021 Issue Paper and Straw Proposal,” dated December 6, 2021 (“Issue Paper”). 

In 2019, Amazon co-founded The Climate Pledge, a commitment to be net-zero carbon across its business by 2040, 10 years ahead of the Paris Agreement.  In the process, Amazon has become the world's largest corporate purchaser of renewable energy and is on a path to powering operations with 100% renewable energy by 2025, five years ahead of its original goal. Amazon recognizes the widespread benefits that can be achieved by a more expeditious transition to a sustainable, decarbonized electric system. 

California is one of Amazon’s largest markets for consumer goods, groceries and data centers in North America. Amazon has invested over $81 billion in California since 2010, including its infrastructure and total compensation to employees. As of last year, Amazon employed over 153,000 Californians in either full or part-time positions, and over 220,000 small and medium California-based businesses were growing via Amazon.  Given Amazon’s Climate Pledge Goals, clean and reliable electric power in California is essential.

Because of its substantial operations in California, Amazon has already executed multiple Power Purchase Agreements (“PPAs”) for projects in California and intends to enter into more. Amazon plans to use its PPAs to cover the resource adequacy (“RA”) obligation of the load serving entities (“LSEs”) that provide electric service to Amazon’s operations. 

In the Issue Paper, CAISO proposes to allocate deliverability in a manner that will make it unlikely for non-LSE future PPA counterparties to attain full capacity deliverability status (“FCDS”), and thereby provide RA benefits, even though these parties might be obliged to do so under a PPA.  This change would not help California achieve its goal of cost effectively decarbonizing the power grid while maintaining system reliability, as explained in more detail below.     

CAISO should remain neutral to the identity of the interconnection customer’s offtaker and treat all interconnection customers equally with regard to the allocation of deliverability.  As discussed in response to Question 3, projects that seek FCDS do so because their offtakers require deliverability.  In Amazon’s case, it acquires deliverability in order to self-supply the RA otherwise required by its LSEs under direct access arrangements.  To the extent corporate offtakers cannot make use of the RA, they are economically incentivized to sell any uncommitted capacity to parties that have an unfilled need, i.e., to LSEs.  That is what LSEs currently do when they have over-procured RA and non-LSE offtakers would have the same incentives.      

If, as proposed, CAISO distinguishes between offtakers and does not allocate deliverability to projects with non-LSE offtakers, developers will prefer LSEs as counterparties given the greater likelihood their projects will receive deliverability.  This will impede the development of corporate renewable procurement in California, reducing the overall deployment of clean energy in the State.  It will also reduce the supply of RA-eligible resources being developed, as non-LSE offtakers will contract for energy-only resources.  The reduced supply of RA-eligible resources could lead to higher prices for RA and therefore higher prices to Californian consumers.  Given the significant and immediate need for new deliverable capacity in California, CAISO should reconsider its proposed change to deliverability allocation.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

Section 3.3 of the Issue Paper, entitled “Should Transmission Plan Deliverability (TPD) Allocation process revisions be considered?” addresses, among other topics, how deliverability should be allocated amongst different types of interconnection customers.  To that end, the Issue Paper proposes to prioritize TPD to interconnection customers that have PPAs which require FCDS but only so long as such PPAs are with LSEs seeking to fulfill their own RA obligation.  In particular, the Issue Paper provides:

The intent of constructing delivery network upgrades and allocating deliverability is to allow the facility to participate in the Resource Adequacy program (RA). Although the tariff requires the PPA to require deliverability, it is ambiguous the deliverability required by a PPA is ultimately utilized by, or offered to, an entity with an RA obligation. For the December 6, 2021 affidavit/allocation cycle, the ISO will deem eligible any project’s affidavit that demonstrates it has an executed or shortlisted PPA that requires deliverability without requiring the offtaker demonstrate they have an RA obligation; however, the ISO proposes to revise the tariff to clarify that in the future, a PPA must be with an offtaker to fulfill its own RA obligation. In other words, the PPAs of offtakers that do not have RA obligations will not be eligible for groups 1 or 2.

Issue Paper at 13 (emphasis added).  This proposed change means that projects which have executed PPAs with non-LSE offtakers would be placed in Group 3 and allocated deliverability, if at all, on that basis. Unlike Groups 1 or 2, Group 3 is for Energy Only projects and, in all likelihood, means interconnection customers with non-LSE offtakers are unlikely to receive any deliverability for their projects and then only receive deliverability if no delivery network upgrades (“DNUs”) are required.   

Amazon supports California’s ambitious objective to decarbonize the power grid while maintaining system reliability.  This objective is best met by ensuring there is sufficient RA capacity to maintain reliability.  The proposed rule to prioritize PPAs with LSEs, and therefore limit deliverability to other projects, will not advance the State’s efforts to bring online additional, cost-effective RA capacity.  As a result, the proposed tariff change will make it unlikely that non-LSE parties will advance the development of deliverable energy projects.  Non-LSE entities will no longer be able to require FCDS in their PPAs because it will no longer be something their counterparties can realistically commit to providing. This will create an unneeded barrier to non-LSEs self-supplying for their own RA needs.

It is important to better understand CAISO’s rationale for prioritizing deliverability for projects that contract with LSEs before proceeding with such a change. One potential concern is allocating deliverability to project offtakers that lack RA obligations might result in that capacity being withheld from LSEs, which could result in unnecessary DNUs that could raise the utility bills paid by ratepayers.  However, that concern does not appear to have sufficient support or precedent.  Any offtaker with uncommitted deliverable capacity is economically incentivized to sell that capacity to an LSE that needs it.  Said differently, an offtaker will seek to recoup the value of its investment by selling the excess deliverable capacity to parties that need it.  That is what LSEs do today, i.e., sell any excess RA in their portfolios to other LSEs.

California’s goal to cost effectively decarbonize the power grid while maintaining system reliability is best served by increasing the number of renewable projects that can achieve deliverability.  To help with that goal, Amazon believes the CAISO should treat all interconnection customers equally in the allocation of TPD and not give priority to those signing PPAs with LSEs.  Amazon looks forward to further engagement with the CAISO and stakeholders regarding this important issue.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Balanced Rock Power develops, invests in, and operates renewable energy and energy storage assets throughout North America. As an active developer in the CAISO interconnection queue, we appreciate the CAISO undertaking this effort to improve the interconnection process.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

BRP has no comment on this issue.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

BRP does not support eliminating the current Allocation Group 3.  As we’re experiencing with the current capacity shortfall in CAISO, regulatory-driven procurement often lags market need and eliminating Allocation Group 3 would eliminate a significant number of “shovel ready” projects in a future emergency procurement scenario.  A significant amount of generation that is coming online in 2022 and 2023 was originally awarded deliverability as Allocation Group 3 which allowed these projects to proceed with outlaying development capital in order to achieve an earlier COD.  Eliminating the current Allocation Group 3 would further exacerbate future emergency procurement because developers would be forced to sit in queue, obtain a contract, and then obtain deliverability to the extent that deliverability is available.  This would require developers to post a significant amount of development security in the hope that deliverability could be obtained from a future TP Allocation.  

BRP supports retaining the current Allocation Group 3 as is, or moving the current Allocation Group 3 to a proposed Allocation Group 4. 

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

BRP supports the CAISO decision to abandon the “ready” concept but opposes the proposal to allow PTOs to interconnect their UOS for a period of three years or less as this essentially permits “queue jumping” and bridges the period of time between calling the UOS a “distribution asset” and the time the PTO can file an interconnection request under its Wholesale Distribution Tariff.  

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

BRP supports the CAISO proposal.     

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

BRP supports the CAISO proposal to require site exclusivity to move into the Phase II Study and making this applicable to Cluster 14.  

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

BRP has no comments on this issue.   

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

BRP supports the CAISO’s proposal.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

BRP supports the CAISO proposal 

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

BRP supports the CAISO proposal 

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

 BRP has no comments on this issue at this time.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

BRP supports the SCE proposal.   

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

BRP supports the SCE proposal.   

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

BRP is supportive of making more information available to interconnection customers, but a lot of information is already made available on the Market Participant Portal through prior cluster Area Reports. The timeline for QC14 was extended due to workload and asking the PTOs to make additional information available will only add to the workload.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

BRP has no comments at this time.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

BRP does not support “re-stacking NUs” without a reallocation of costs to the earlier project.  

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

BRP opposes treating deliverability like a commodity and allowing developers to sell or transfer deliverability at the same POI.    

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

BRP supports revising and updating the Electrical Independence Test.  The current Electrical Independence Test is out of date and provisions in the tariff already protect later queued projects (like an ISP) from impacting earlier queue cluster projects.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

BRP has no comments.

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

BRP has no comments on this issue.

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

BRP has no comments.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Broad Reach Power LLC (BRP) appreciates the opportunity to comment on the CAISO’s IPE 2021 Issue Paper and Straw Proposal (“Straw Proposal”). BRP is a leading utility-scale solar and storage developer in the United States. BRP owns a 21 GW portfolio of utility-scale solar and energy storage power projects that will operate in multiple U.S. power markets.   BRP projects are helping to ensure the grid’s reliability and to meet the demand for lower cost and emission-free generation resources. Within the CAISO footprint, BRP is actively developing a portfolio of projects from early stage (recent CAISO queue clusters, ISPs, and WDATs) to ones under construction.

Although BRP’s comments at this time are limited to a selected number of topics, BRP reserves the right to comment on all IPE 2021 proposals included in CAISO’s revised straw proposal, which is expected to be circulated in the next month. In brief summary, BRP:

1. Opposes the elimination of (or further restrictions placed on TPD Allocation Group 3) unless the Interconnection Customer (IC) is afforded other feasible ways to maintain Full Capacity status for a reasonable period of time during the interconnection/development process. If such alternative pathways cannot be created in the limited time afforded to Phase 1 of IPE 2021, CAISO should move this topic to Phase 2 of IPE 2021. See further comments in Section 3, below.
2. Opposes increasing study deposits or other fees that specifically target entities submitting multiple projects in a single cluster study window. See further comments in Section 7, below.
3. Supports making site exclusivity a requirement for projects to enter into Phase II (or otherwise increase the financial commitment of the IC) for an IC to proceed to Phase II. This change should be made in IPE 2021 Phase 1, so it is effective in time for C14 and subsequent clusters. See further comments in Section 8, below.
4. Opposes the proposal to eliminate the ability to pursue MMAs during parked years. Instead, CAISO should increase options for the IC progress project development during parked years, including pursing GIA negotiations. See further comments in Section 16, below.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

CAISO proposes that this topic be addressed in “Phase 1” of this stakeholder process. However, the likelihood of finding new TPD allocation processes within the Phase 1 timeline is low and for this reason BRP recommends that CAISO move this topic to Phase 2 of this stakeholder process. More time may be required as TPD allocation policies are a core component of CAISO’s interconnection process and any proposal to eliminate TPD Allocation Group 3 must create other feasible ways for the IC to maintain Full Capacity status for a reasonable period of time during the interconnection/development process. 

A project active in the interconnection queue (including C14) has its first TPD allocation opportunity based on an affidavit due within days of receiving the project’s Phase II study report. It is simply not reasonable to expect a project with a viable or attractive Phase II result to have a PPA or be shortlisted by that date. CAISO rules allow for a year of parking but even that length of time can be insufficient. First, it can take 6 months to a year to negotiate a generator interconnection agreement (GIA) and many LSE off takers are reluctant to enter into PPAs with projects that have not received a GIA. Second, and perhaps more important, PTO timelines to achieve COD can be 3 years in duration or more (PTO timelines typically require at least 2.75 years for In Service and assume 9 months from issuance of a Phase II report to GIA execution. This leads to an In Service date of at least 3.5 years from issuance of the Phase II report.)  Parked projects will see a year added to this timeline as they cannot progress the GIA while parked. As applied to C14, the question becomes why an LSE would want to contract with a resource for RA (or RA + energy) by November 2024 (the date a 1-year-parked C14 affidavit will be due) if the earliest COD is late 2027 (= March 2024 [date of TPD allocation for parked project] + 42 months)?   For these reasons, if CAISO were to consider eliminating or restricting Group 3, it must also consider ways to:

• Scrutinize PTO posted timelines for various upgrades that make interconnection In Service so protracted. Relatedly, can the PTOs identify POIs that would have short In Service timelines as part of improvements to transparency?
• Allow parked projects to progress on GIAs during parked years and, for projects that sign a GIA, initiate engineering on all upgrades other than any allocated delivery network upgrades (LDNUs and OPNUs). Alternatively, the CAISO and PTOs should significantly streamline ability of Interconnection Customers to enter into an E&P option so projects can continue to progress during parked years. See related comments in Section 16, below.
• Allow projects to park without restriction for at least two years. Currently, projects can park 1 year with only a very limited ability to park a second year.
• Create a viable “Option B” deliverability path, where projects can secure deliverability without participating in the TPD allocation process. The current Option B is demonstrably unworkable. CAISO is mistaken to think that FERC will agree that Option B, in its current form, represents a just and reasonable way to provide open access Full Capacity interconnections to merchant developers without also having Group 3 as an option. For that reason, CAISO should reconsider its decision to exclude Option B reform as a topic in IPE 2021.

Furthermore, other issues that must be considered before Group 3 is eliminated or significantly restricted:

• Because of declining costs, siting flexibility, and continued energy price volatility, the prospect of merchant battery projects is becoming a real possibility. Self-financed storage projects will be beneficial to the grid and, once a resource is deemed deliverable, it is reasonable to assume it will sell its RA capacity to LSEs that has RA obligations. Why does CAISO want to thwart this potential improvement to the market by closing the door to self-financed projects?
• Projects in Group 3 still have cost responsibility for LDNUs and OPNUs. If they are forced to become Energy Only or withdraw (which is the consequence of eliminating Group 3), then they can no longer fund these upgrades. How does this serve the needs of interconnection customers and further California’s resource planning goals?
• If active queued projects are forced to become Energy Only, they need to be provided a viable path to securing deliverability before COD. CAISO’s proposal does not contain address this distinct outcome

If CAISO does not make necessary adjustments in conjunction with the elimination of or additional restrictions placed on Group 3, it will fail to improve the efficient progress of project into the queue to meet its requirements for open access and California’s resource planning goals.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

A large number of interconnection requests submitted in a queue cluster window is not inherently bad. Instead, it should be viewed as an indication of high demand for an essential service that CAISO has a duty to address through its open access tariff. To the extent that CAISO believes some developers submit requests on a “speculative” basis, then it should first give a hard look at what information it provides in advance so that prospective applications are better informed. (In this regard, BRP supports IPE 2021 efforts to improve transparency.) CAISO should consider other measures to plan for “large” clusters, such as receiving deposits earlier (with a nonrefundable component) to allow it to tap external resources, define service standards, and manage demand.  

BRP opposes CAISO’s specific proposal to increase fees when multiple projects are submitted by the same parent company. CAISO’s specific proposal is that for the first two projects submitted by a parent company/entity, the study deposit would be $250K per request; for projects 3-5, the study deposit would be $500K per request; and for any more than 5 projects, the study deposit would be $1M per request. BRP notes that CAISO has provided no evidence that multiple requests submitted by a single party were, on average, of a lesser quality or “less serious” than single, double, or triple requests submitted by a single entity. Furthermore, CAISO did not provide any evidence that the cost of processing multiple requests was any higher. In the absence of factual information, CAISO’s proposal is unduly discriminatory. BRP notes that over half of the interconnection requests submitted in C14 were made by entities that made 3 or more requests. Thus, promoting developer diversity will not be served by CAISO’s proposal. Lastly, there is no basis for CAISO’s proposal here with any other FERC-approved interconnection process. CAISO should not waste its time on proposals that will not be deemed just and reasonable and not unduly discriminatory by FERC.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

BRP concurs with CAISO’s position that this topic should be addressed in Phase 1.

BRP supports making site exclusivity to be a requirement for projects to enter into Phase II for C14 and subsequent clusters.

As of January 4, 2022, CAISO C14 still incudes 340 projects active in Custer 14, representing approximately 101 GW. (These statistics exclude ISPs and C14 WDAT projects that will also be studied for deliverability by CAISO in C14.) During May 2021, CAISO indicated that the initial number of C14 projects was 373; thus, the number of project withdrawals that have occurred up to this point, i.e., as a result of the IR validation and scoping process, has been only about 9%. For California to meet its resource planning and decarbonization goals, it is crucial that C14 be a success. CAISO has already indicated that Phase 1 results will be in many ways an “approximation.” Reasonable measures to identify viable projects should be implemented in time for the start of Phase II. If steps are not taken to be implemented before C14P2, the Phase II results will be inaccurate and generally inflated. Only after inevitable withdrawals that will come later (and only reflected in reassessment studies), will the results be more realistic. This path will undermine the state’s resource planning goals and distort outcomes in future queue cluster studies.

CAISO should give careful thought as to when site exclusivity needs to be demonstrated. Developers need a reasonable amount of time between receipt of a Phase 1 study and any site exclusivity deadline. BRP suggests that any site exclusivity demonstration be provided no later than 30 days before First IFS is due. That should provide sufficient time for CAISO to validate submitted site exclusivity documents.

As much as any stakeholder, BRP recognizes the difficulty of securing site exclusivity, particularly in the urban areas where battery storage projects are located, BRP would therefore also support, as an alternative to the demonstration of site exclusivity, an increase in the financial commitment of the IC (such as making the site exclusivity deposit nonrefundable) as a requirement to entering into Phase II. This financial requirement would be additive to what is currently required under First IFS. Note also that any nonrefundable component of a site exclusivity deposit should become refundable when a project later provides of evidence site exclusivity before reaching COD or otherwise leaving the active queue.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

BRP opposes this proposal. At the very least, CAISO should provide evidence that it cannot meet the demands of ICs requiring MMAs or consider ways to streamline the change management process that MMAs are intended to address.

Instead of placing more restrictions on parked projects, CAISO should allow parked projects to proceed on GIAs during parked years. CAISO could require Second IFS from the IC (less the IFS required for delivery network upgrades, if any) for projects that want to progress their projects during a parked year. The need for this change is heightened if CAISO eliminates or restricts TPD Allocation Group 3. See related comments in Section 3, above.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

California Community Choice Association (CalCCA) supports an alternative cost allocation treatment for network upgrades to local systems (below 200 kV) where the associated generation benefits more than, or other than, the customers within the service area of the Participating Transmission Owner (PTO) owning the facilities, as described in Section 9 below.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

No comments at this time.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

No comments at this time.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

No comments at this time.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

No comments at this time.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

No comments at this time.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

No comments at this time.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

No comments at this time.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

CalCCA supports a cost allocation methodology that allocates costs to all those who receive benefits. As such, CalCCA supports re-considering an alternative cost allocation for network upgrades to local systems when the benefits extend beyond just those within the PTO service area in this initiative. To mitigate the risk that interconnection-related local network upgrades may create disproportionate impacts on a single set of ratepayers, the California Independent System Operator (CAISO) proposes to cap the percentage of interconnection-related network upgrade costs within each PTO’s local transmission revenue requirement (LTRR). For any network upgrades that exceed the PTOs aggregate cap, interconnection customers would finance any network upgrades without reimbursement or move their generator interconnection to the high voltage system.[1] The CAISO’s proposal to cap the percentage of interconnection-related network upgrade costs in each PTO’s LTRR improves the current structure with respect to protecting local ratepayers from the cost impact of network upgrades that benefit all customers. However, the CAISO should describe how the proposal will treat upgrades that benefit all customers if they fall under the proposed cap. If the purpose of the network upgrades is for generation projects to be deliverable anywhere on the grid, then all customers benefit and should share the costs.

[1]             Interconnection Process Enhancements Issue Paper and Straw Proposal at 32-33.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

No comments at this time.

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

No comments at this time.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

No comments at this time.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

No comments at this time.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

No comments at this time.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

No comments at this time.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

No comments at this time.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

No comments at this time.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

No comments at this time.

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

No comments at this time.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

No comments at this time.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

No comments at this time.

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

No comments at this time.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

No comments at this time.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

No comments at this time.

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

No comments at this time.

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

No comments at this time.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

No comments at this time.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

CESA appreciates the CAISO’s IPE Issue Paper and Straw Proposal and is mostly supportive of the CAISO’s proposal and scope of issues. We underscore the importance of avoiding any retroactive changes to the existing queue where reasonable and apply many of the key reforms to prioritize and align the interconnection and transmission planning process with reliability and procurement needs, as well as to reasonably increase the commercial viability criteria to manage the interconnection queue and mitigate the risk of future superclusters. In the near term, there are reasonable changes that could be made to ensure timely network upgrades and flexibility to advance through the interconnection process.

CESA also wishes to express the sentiment that avoiding superclusters as an end or goal should not be what the CAISO strives for. High volumes of interconnection applications in itself could be a sign of significant commercial interest in developing renewable and energy storage projects to meet procurement obligations and market needs in support the state’s decarbonization goals and reliability objectives. Combined with increased and/or refined commercial viability criteria to screen out less viable or speculative projects, the CAISO’s focus should be weighted toward improving streamlined study processes, increasing staff resources (e.g., comprehensive staffing plan), and investing/implementing automation tools to ultimately decrease study times and push the interconnection process “down the cost curve”. Reasonable measures to incrementally increase the cost of entry and cost to stay in the interconnection queue is one lever in streamlining the process, but the CAISO should also do everything it can in terms of resourcing and automation to more expeditiously advance commercially-viable projects toward execution of generator interconnection agreements (GIAs) and facilitate the significant resource build needed to advance the state’s energy transition.

Overall, some of the main areas of reform in the IPE Issue Paper and Straw Proposal are focused on modifying the commercial viability criteria, but in doing so, CESA generally recommends that these changes must be reflective of procurement cycles and varying development practices by technology and location. To this end, CESA also generally supports the CAISO’s express intent to increase upfront data availability on transmission system capabilities and align processes across reliability, transmission, and supply capacity planning as part of Phase 2 reforms of this initiative, thus aiming to tackle some of the chicken-and-egg situations where resource development is not necessarily aligned with transmission capacity availability. Additionally, while likely outside of the direct scope of the CAISO and its interconnection process, the CAISO should coordinate with the CPUC to ensure that participating transmission owners (PTOs) adhere to timely (and potentially expedite) construction timelines for interconnection facilities and network upgrades. Greater transparency and accountability on these timelines is a necessary initial step in this regard.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

CESA supports this proposal for out-of-cycle downsizing requests as a reasonable means to reduce the MW in the interconnection queue.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

The CAISO proposes to revise the TPD allocation process and consolidate the Allocation Groups, focusing primarily on projects that have an off-taker agreement, have been shortlisted in a solicitation, and/or demonstrate that they are in active negotiations with a load-serving entity (LSE). While not opposing revisions to the TPD allocation groups, CESA believes that the CAISO’s proposal requires further discussion and refinement as an IPE Phase 2 item to ensure that the Allocation Groups are defined in ways that: (1) do not force viable projects to become Energy Only (EO) projects (i.e., CAISO’s proposed new Group 3) if the generator is willing and able to fund deliverability upgrades if needed; and (2) allow EO projects that are operational could be classified as a Group 1 or 2 if it has secured an off-taker agreement or is in the process of doing so (shortlist, active negotiations).

In the first case, CESA believes that these situations must be accommodated in the TPD allocation process since the timing of TPD allocations do not always align with securing a power purchase agreement (PPA), nor does the history of deliverability upgrade delays. The CAISO's proposed Group 2 seemingly covers situations where a commercially-viable project may be in the interconnection queue and in advanced stages of negotiating and securing a PPA, but it would deprioritize and force projects without a secured PPA or actively shortlisted/negotiated PPA to be EO projects and only have deliverability allocated where it is available on the existing system, even though, as a practical matter, projects could be built and fund the deliverability upgrades if allocated deliverability in the TPD allocation process. Otherwise, if forced to be EO and not able to secure deliverability and fund/build the associated upgrades, these projects would need to “claw back” deliverability in future TPD cycles. Rather, a path should be established for projects without PPA agreements, shortlisting, or negotiation to positioning itself for future reliability needs or procurement obligations that is more realistic with the timing of the completion of deliverability upgrades. For example, if a project’s deliverability upgrades are not scheduled to be online until 2028, it does not seem reasonable to require a PPA demonstration until closer to that date, especially considering the history of PTO upgrade delays. Importantly, PPAs are also typically secured after a TPD allocation.

Instead, CESA recommends that either: (1) the current Group 3 (proceeding without a PPA) could be maintained, not eliminated; or (2) the newly proposed Group 3 could be modified to allow projects without a PPA to receive TPD allocations and fund/build deliverability network upgrades with the ability to park or maintain TPD deliverability for some period of time. For the latter, it would afford projects some flexibility and a window to secure a PPA, thus demonstrating before the end of some (to be determined) defined window its status as a Group 1 or 2 project in future TPD cycles.

More broadly speaking, CESA has concerns with tying deliverability allocation priority groups solely based on a PPA itself. The CAISO indicates that a PPA is the ultimate sign of commercial viability, but a qualifying PPA has not been defined, such as around contract term length. Would short-term contracts (e.g., less than a year, a few years) qualify? Rather than seeking to define the terms of a qualifying PPA, CESA urges against using a PPA as the sole means to define commercial viability and consider our comments above on how projects without PPA agreements or shortlisting/negotiations be included in the TPD allocation process without being forced to be EO projects.  

In the second case where an EO project is operational and could be in the process of or having already secured a PPA, the ability to be classified as Group 1 or 2 in the TPD allocation process would support the same ends that projects are prioritized for those that fulfill an LSE’s RA obligations. During the stakeholder call, the CAISO noted the rarity of such situations, but it should not foreclose those possibilities. CESA recommends a more flexible definition regarding whether deliverability could be prioritized for projects that may not meet immediate RA obligation needs but could also be used to meet reliability needs pursuant to an “effective” planning reserve margin, which the CAISO is undoubtedly aware the CPUC has directed the investor-owned utilities (IOUs) to procure for Summer 2022/2023 emergency reliability needs. While not meeting RA obligations per se, securing deliverability for these projects remain a high priority since they could also be used to meet future procurement and RA obligations.  

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

CESA agrees with the CAISO’s broader goal to improve coordination of planning and procurement activities, but we have general concerns about resource-specific development (e.g., offshore wind) and withholding such capacity. Given unique considerations of long lead-time resources, CESA supports further exploration of this issue in a technology-neutral way but also aligns with longer outlooks of the CAISO’s 20-year Transmission Outlook Initiative and the Joint Agency’s SB 100 Study process and supports their identified resource development.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

In addition to greater transmission data transparency, CESA is generally supportive of exploring the development of a solicitation model. In locations where there is limited existing transmission availability relative to the interconnection requests, the CAISO’s solicitation model concept could be considered, albeit with further development on the process and criteria. At that stage, higher commercial viability criteria, fees, and/or deposits could be applied as screening and scoring criteria. In this way, the barriers to entry will not be unnecessarily increased across the board.

However, CESA has major reservations about using the solicitation model to favor selected projects with a pre-existing right to interconnect. While it could be used as a process by which to manage and reduce the interconnection queue, reserving interconnection rights represents an overreach of the CAISO’s role as a non-discriminatory and competitive system operator. Existing processes are already in place to secure interconnection rights and deliverability in a non-discriminatory way.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

CESA is supportive of moving this issue into Phase 2 of this initiative since criteria would need to be further defined and processes would need to be developed to verify readiness. In particular, CESA directionally supports the narrowing of the scope to support temporary emergency interconnection service to address near-term reliability needs, but the CAISO must develop criteria around how it defines “temporary” to ensure that it does not impact other projects seeking “permanent” interconnection in the normal queue process, or more than is necessary. In addition, there must be criteria established to define “emergency” to demonstrate that existing or expected resources truly cannot meet near- or immediate-term reliability, such that expedited interim interconnection of temporary generators could be allowed. At the stakeholder meeting, the CAISO shared how it may require an emergency proclamation from the Governor and orders from a state agency to determine the need for emergency generators to meet the shortfall, which is a start but requires further refinement. Finally, CESA shares the perspectives of other stakeholders that there may not be a need for such separate “ready” criteria if commercial viability criteria are refined and interconnection study processes are streamlined, leading to the development of temporary emergency interconnection service to be a last-resort measure that the CAISO could exercise without separate FERC tariff waivers.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

CESA is open to the CAISO’s proposal in general for higher fees, deposits, or other proxies to minimize speculative projects or flooding the queue with applications. In particular, CESA appreciates the CAISO’s nuanced consideration of a proposal that would not raise the price to entry for all projects; however, the specific amounts proposed represent significant increases that are not tied to the actual study costs and may not necessarily increase the quality of applications. A large developer who submits 10 projects could very well be submitting 10 high-quality and commercially-viable projects but may be deterred by the significant fees and deposit requirements.

CESA thus recommends against imposing escalating fees and deposits based on multiple interconnection applications by a single developer. Escalating fees and deposits based on the number of projects may penalize high-quality, viable projects simply as a result of being from the same developer, who may be submitting multiple interconnection applications as a result of understanding the transmission system and market/procurement landscape, not because of a scattershot approach. At the stakeholder meeting, the CAISO stated that they were not basing this proposal on any quantitative or qualitative analysis on whether the number of projects submitted by a single entity correlated with poor-quality or speculative projects. Absent such analysis, this proposal should not be pursued. Moreover, CESA also has questions regarding the administrative complexity of tying interconnection applications to a single parent company when each project is typically owned and developed by separate legal entities.

CESA, however, is open to considering some increase in the study fee that is tied to actual study costs or historical precedent (e.g., $250,000) as a means to reduce the queue, reasonably and incrementally increase the bar to entry, and support greater resourcing and infrastructure to handle the volume of interconnection applications.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

CESA does not have a position at this time on adding a site exclusivity requirement for QC14 projects to move toward Phase II study processes. Regardless of whether the CAISO adopts a site exclusivity requirement for QC14 projects, CESA recommends that the CAISO consider how this requirement could impact projects of different technologies and locations. For example, projects developed in or near urban areas may face different conditions when it comes to securing land and site control, which can be higher and time consuming than those in rural areas, even though these projects may be otherwise commercially viable. Projects in such locations are located in extremely expensive commercial markets where landowners are not accustomed to multi-year options, except at very high lease options. If projects will not be deliverable with the necessary deliverability network upgrades until further out in the future, then projects in expensive urban markets will be economically disadvantaged in the interconnection study process, even though they may be some of the most-needed capacity to support reliability needs. Moreover, such projects may still be highly viable since smart developers will have accounted for a number of factors, such as the availability of existing transmission capability, the lack of competition at the point of interconnection (POI), and sufficiency of real estate availability at the POI.

Since many developers planned their projects with the existing tariff rules in mind, CESA recommends that the CAISO also ensure that sufficiently forward notice be provided to all market participants in advance of issuing Phase I reports by September 15, 2022 (per the CAISO’s Supercluster Final Proposal). Prior to making any changes, CESA also requests that the CAISO provide data and analysis on some of the following:

• How many QC14 projects have deposits in lieu of site exclusivity?
• Has CAISO quantified the impact this change might have in terms of both application review timelines or upgrade construction timelines?
• Has CAISO evaluated what staffing level would be required to review the current Queue without a change in review or construction timelines?

In addition to the aforementioned considerations, CESA also notes that the timing between receiving the Phase I study results reports (by September 15, 2022 per the CAISO’s Supercluster Final Proposal schedule) and making a decision to move into the Phase II study process is likely too short to allow projects without site control to obtain it in time to advance. Even with the CAISO setting a goal to have the Phase 1 final proposal and tariff changes approved by the Board of Governors in May 2022, certain developers would face risk in beginning the process to acquire site control without receiving their Phase I study results.

However, CESA is open to considering proposals to have higher non-refundable portions of securities and deposits for interconnection requests that drop out of the queue as a condition of advancing to the Phase II study process in QC14, coincident with the Phase II deposit deadline. In considering such an approach, the CAISO should take into account the combination of proposals for higher fees/deposits and non-refundable portions to ensure that the securities do not put unreasonable levels of funds at risk for each project, which may otherwise be commercially viable and necessary to support economic project development as well as procurement needs.

On a going forward basis for QC15 and beyond, CESA is open to considering whether to require site exclusivity as a condition to advance to the Phase II study process. Overall, CESA will need more time to develop positions or proposals on reasonable commercial viability criteria for future clusters.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

CESA has no comment or position at this time.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

CESA has no comment or position at this time.

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

CESA has no comment or position at this time.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

CESA has no comment or position at this time.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

CESA is supportive of this proposal for consideration in Phase 1. We look forward to reviewing the specific criteria regarding requirements for projects that need to be transferred to the Wholesale Distribution Access Tariff (WDAT).

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

CESA has no comment or position at this time.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

CESA has no comment or position at this time.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

CESA disagrees with the CAISO’s proposal to not allow parked projects to submit MMAs. Projects may be parked for multiple reasons, even due to offtake reasons, and doing an MMA to update something like inverters or change capacity while finalizing offtake negotiations, may save time in the long run and make a project more viable.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

CESA is generally supportive of this scoping item. As explained in the Issue Paper and Straw Proposal, it is important to establish reasonable and clear upfront curing periods so that the entire queue is not held up due to delays of interconnection studies with deficiencies.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

CESA has no comment or position at this time.

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

CESA is strongly supportive of this scoping item since improved data access, transparency, and accessibility will support not only the developer community in identifying viable and cost-effective project sites but also LSEs in more smartly assessing projects and vetting achievable commercial online dates and overall project costs

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

CESA has no comment or position at this time.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

CESA supports the continued inclusion of this issue for further discussion and believes it could be developed in a way that supports practical implementation timelines while avoiding any line jumping of fair interconnection and deliverability rules.

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

CESA is supportive of this scoping item as a means to help manage the overheated queue and potentially consolidate around the most viable projects.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

CESA does not have a specific proposal at this time, but we support an examination to clarify the process and study criteria for the electrical independence test.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

CESA is supportive of this scoping item and agrees with REV Renewables that delays in upgrade construction unnecessarily creates a reliance on year-by-year interim deliverability and causes the potential for the loss of deliverability on any given year if interim deliverability no longer exists, yet deliverability-related upgrades are not constructed in time. Broadly, like the network re-stack issue above, how work plans for network upgrades are prioritized and initiated merit deeper discussion.

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

CESA has no comment or position at this time.

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

CESA has no comment or position at this time.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

CESA appreciates the CAISO’s inclusion of the Grid Strategies white paper, which offers helpful context from the FERC ANOPR as well as key observations on how the current process can be improved. As noted throughout the white paper and in the CAISO’s proposals, there is misalignment in planning and interconnection processes, where Phase 2 of this initiative will play a critical role in facilitating the development of these proposals.

Due to the timing of the issuance of the Issue Paper and the Straw Proposal and the intervening end-of-year holiday break, the above comments are limited in scope since member feedback has been limited and/or consensus recommendations have been harder to reach as an organization. However, we look forward to further engagement in this initiative.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Clearway Energy Group (“Clearway”) appreciates the opportunity to comment on the IPE 2021 Issue Paper and Straw Proposal. Clearway supports the comments submitted by the Large-scale Solar Association (“LSA”) on the full scope of issues within the Issue Paper and Straw Proposal. We are providing a more specific response on the issue of accelerating interconnection for “ready” projects.

Clearway supports developing a process to accelerate interconnection and deliverability for projects that can be brought online quickly to meet urgent system reliability needs, in a way that minimizes any negative impact on earlier queued projects that face a longer development timeline. The mixed feedback at the Preliminary Issue Paper stage reflects that this is an issue where it is difficult to identify a “win-win” solution that benefits all stakeholders, in the context of an already crowded queue with a diverse set of projects and developers. In this case where some tradeoffs are unavoidable, the overriding priority must be improving system reliability and reversing the trend of increasing delays in the interconnection process.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

Clearway supports the CAISO’s proposal for urgent reliability-driven interconnection service for interim interconnection. Furthermore, Clearway strongly supports the idea of proactively offering interim deliverable service to operating projects with existing interconnection service that can accommodate additional firm (near-perfect) capacity such as co-located battery storage. These firm capacity resources could be added to operating projects similar to the existing MMA process, but with certainty regarding the underlying capacity value associated with these additions. In circumstances where interim deliverability capacity is not available, the CAISO should consider attributing additional reliability value to these otherwise Energy Only capacity additions. Clearway also seeks a clarification that while the capacity allocation would be provided on an interim basis, the interconnection would not be on a temporary basis, but rather, a project that receives interim deliverability service would continue to maintain its interconnection service rights while it seeks Full or Partial Capacity Deliverability Status by entering the annual TPD allocation process under a dedicated allocation group.  

Beyond the proposal for emergency authorization on a temporary basis, the CAISO should continue to explore additional options to accelerate interconnection. There are many projects in the queue today that can be brought online quickly to meet urgent system reliability needs and would not have a significant negative impact on other queued projects but cannot move forward because of delays and inefficiencies in the interconnection process. The “Resolving Interconnection Queue Logjams” report highlights the potential benefit of a “first ready, first served” approach, and Clearway believes additional incremental steps in that direction are needed.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

Given the urgent need to bring additional megawatts online to meet near-term and mid-term reliability needs, Clearway urges the CAISO to consider ways to prioritize the work of CAISO staff and Transmission Owners (“TOs”) to ensure that advanced-stage projects are able to meet or accelerate their planned in-service dates. As noted in the Issue Paper, in recent years developers have experienced more and more delays in the interconnection process, pushing out in-service dates and deliverability for projects that should have been able to meet near-term reliability needs. Clearway greatly appreciates the CAISO’s ongoing efforts to troubleshoot interconnection delays with developers and TOs and hopes that that process can be used to identify additional needed improvements to the interconnection process. In addition, the CAISO should consider options to accelerate the processing of filed MMAs (design basis updates, deliverability transfers) to ensure financing and construction can proceed without delays.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

EDF-R deeply appreciates the scope, effort, and precision that the CAISO has allowed for this IPE initiative, and offers the comments herein in the spirit of robust and thorough discussion of each proposal’s merits and potential impacts.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

EDF-R generally supports the proposal inasmuch as it facilitates the downsizing process without posing any negative effects to non-downsizing interconnection customers.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

EDF-R is in agreement with the majority of stakeholders that Transmission Plan Deliverability allocation should not be a Load Serving Entity’s responsibility and supports the CAISO’s decision to drop the proposal.

EDF-R takes no position on the removal of Allocation Group 3 at this time, in general EDF-R is concerned that this process change introduces more uncertainty into the already-complex task of developing new interconnection requests. In the event CAISO moves forward with this policy change, EDF-R strongly urges CAISO to deliver the results of the Transmission Grid

Data Transparency effort before formalizing the removal of Allocation Group 3 policy in a FERC filing. The provision of unambiguous and accessible information about the interconnection and deliverability availability on the CAISO system is the most efficient way to meaningfully reduce the amount of complexity this policy will introduce into the RA solicitation process.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

In the Grid Strategies memo published on the CAISO website on December 13, 2021, Grid Strategies LLC presented clear actionable steps for how improve the Joint agencies (CPUC, CAISO, CEC) coordination on resource adequacy, transmission planning and generator.

The preliminary IPE paper was published before the Grid Strategies Report. As a next step EDF-R encourages the CAISO consider if and how CAISO’s IPE proposals address changes needed as identified by the report. EDF-F suggests that items in the report that are particularly prudent for consideration by the CAISO are:

• Apply Grid-Enhancing Technologies where appropriate in the interconnection process to enable faster and cheaper integration
• Conduct more pro-active transmission planning that optimize energy, capacity, and transmission and consider a broader set of benefits beyond production cost alone, such as resilience and capacity reserve sharing in transmission benefit-cost assessments.
•  Develop more stable interconnection costs by electrical zone to reduce uncertainty on developers and procurement entities. Spreading this risk across ratepayers will likely reduce their costs in the long run.

The final point about developing more stable costs is of particular interest to EDF-R as a discussion point. Each time there is a suggestion for a first-ready first-served model, or for reducing the time and scope of interconnection studies, the CAISO accurately points out that these options are incompatible with Cluster Study process timing, its financial milestones, and the joint agencies alignment plan. However, it seems quite clear from stakeholder comments and the Grid Strategies report that Band-Aid solutions such as higher costs and harder requirements will only temporarily tourniquet the current interconnection issues, and that the true solve for CAISO’s interconnection issues is in a holistic restructuring that includes a more agile and time-efficient approach to generator interconnection and transmission planning.

This suggestion is also consistent with FERC ANOPR RM21-017 which targets better identification of cost and responsibility for regional transmission facilities and interconnection-related network upgrades and suggests a more forward-looking approach to the regional transmission planning process that plans for anticipated future generation. CAISO’s current transmission processes are focused on right sizing and economics, rather than a least-regrets approach.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

EDF-R believes that solicitation model proposals need to be sufficiently detailed before their merit can be evaluated.

With respect to proposal (1) a solicitation model to identify which projects should be carried forward into the interconnection process conducted in conjunction with load serving entity procurement processes, EDF-R respectfully requests that any coordination CAISO does with LSEs as a part of the LSE’s RA solicitation efforts be completely transparent to the interconnection customer. EDF-R does not support the notion that the CAISO would provide LSE information about or assessments of interconnection requests that the interconnection customer cannot see and respond to.

EDF-R also suggests that if the CAISO eliminates Allocation Group 3 and delivers unambiguous and accessible information in its Transmission Grid Data Transparency, such a solicitation model may not be necessary.

EDF-R enthusiastically supports further discission on proposal (2) a solicitation model confirm interest in an area in which transmission capacity may be expanded with commitments from the resources helping support the transmission development.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

EDF-R is initially reluctant to support such a measure given there are ambiguities that may be inherent to any urgent interconnection process. For example:

• Which state agencies could direct the activation of this urgent interconnection process? Only the Governors Office? Or others?
• How will the CAISO enforce the 3-year operation limit? Will the generator be disconnected promptly? Will the GIA have a firm termination date?
• Will these same operating limitations imposed on the 2021 summer emergency procurement be imposed on projects interconnecting under the new urgent interconnection process?
• In what circumstances will these projects be included in the base case, and if they are included in the base case, what control measures will be in place to ensure emergency generation seeking to move to traditional generation are assigned their appropriate costs?

EDF-R suggests that this approach is not the most equitable and independent approach to solve the stated problem that a “framework for urgent reliability-driven interconnection service” is needed, and instead the CAISO should focus on a holistic restructuring that includes a more agile and time-efficient approach to generator interconnection studies and transmission planning. EDF-R provided more detail on this element in section 4 of these comments.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

CAISO’s proposal for higher interconnection study deposits presupposes the outcome of FERC ANOPR RM21-17 which seeks to identify how to determine a just and reasonable limit to the number of interconnection requests.

As procedural items, EDF-R requests that CAISO separate what amounts are the “study deposit” (currently $150k) and what are “scaling non-refundable fee” (all the newly proposed costs). EDF-R also requests that CAISO clearly identify by what process it will identify affiliated interconnection customers as they apply to the scaling costs. EDF-R also requests CAISO provide its proposal in a visual matrix format in the next proposal iteration to facilitate clarity on what costs are applicable when.

As a process item EDF-R requests that the CAISO continue to require the $150k with the interconnection request, but should hold on the “scaling non-refundable fees” until after the scoping meetings are complete. In tandem with this change, EDF-R also suggests that the current proposal does not represent an equitable “service level agreement” between the CAISO and the interconnection customer. If the CAISO proceeds with creating these additional interconnection process checkpoints and financial hurdles, the CAISO should provide reciprocal clarity to stakeholders in the form of a standard amount of information provided at the scoping meeting. CAISO should provide basic information on feasibility at these meetings, and include a summary of the area’s history including historical queue drop out information (which indicates that Points of Interconnection is not viable), Transmission Plan Deliverability availability, congestion, and the magnitude of upgrades needed to accommodate new supply.  To put it plainly, EDF-R believes that for a $150k upfront study deposit interconnection customers should get the opportunity to meet with the CAISO on their specific project.

 EDF-R is supportive of the CalWEA and LSA/SEIA compromise proposal where “basic” validation should be complete before the scoping meeting but remaining validation issues can be addressed at the meeting.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

EDF-R supports further discussion on this topic, and requests the CAISO create visual timelines to illustrate how long site exclusivity would need to be held in various scenarios. It is EDF-R’s experience that landowners are reluctant to sign exclusive options for long periods of time, or if they will, the cost upends an otherwise economic proposal. 

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

No comment at this time

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

No comment at this time

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

EDF-R supports the CAISO’s proposal that an error or omission discovered after a project makes its second IFS posting should be the responsibility of the party that made the error or omission. EDF-R also supports the idea of easy-offramps for projects that receive an aggregate cost increase or a significant ISD delay.

Specific to the ISD delay, EDF-R requests that the CAISO define a significant ISD delay as “pushing the earliest achievable ISD by 1 year or a delay that results in the interconnection customer breaching its executed PPA” to account for a scenario where the earliest achievable ISD and PPA ISD were previously closely matched

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

No comment at this time

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

No comment at this time

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

No comment at this time

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

EDF-R has managed many interconnection requests and has submitted dozens of quarterly status reports to the CAISO. This requirement is not burdensome, and EDF-R is comfortable supporting a proposal where a project’s failure to provide quarterly status reports is considered a material breach to the GIA and the primary driver for holding a project in breach. EDF-R requests CAISO explicitly confirm in this initiative that upon notice of this breach the interconnection customer will have 30 days to cure the breach, and submitting a completed Queue Management Status Report is sufficient to cure this breach.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

Given CAISO’s reporting indicates that 99% of MMA’s are approved, EDF_R suggests that CAISO could provide a letter response to the parked project requesting the modification proposal is expected to be approved based on engineering judgement and historical MMA trends.

This “it’s probably ok, let’s confirm fore sure later” response provides parked projects reasonable assurance that their request to modify their project will be approved. This enables projects to respond to procurement trends and use parking time productively to enhance their ability to get shortlisted and receive a TPD allocation under the CAISO’s proposal in this IPE, while saving the CAISO from study work while the project is parked. EDF-R is also supportive of the proposal to limit change types to changes reasonably expected to impact project marketability (fuel type changes, technology changes, or POI changes) and decline to process MMAs of other types (inverter changes, for example.)  

EDF-R does not support CAISO’s suggestion on the call that interconnection customers should be required provide the second posting in order to request an MMA while parked.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

EDF-R is concerned that this proposal adds additional pressure to an already tight timeline, especially for projects whose study results meetings fell toward the end of the cluster group. EDF-R suggests that a nuanced approach could provide some relief to these customers. For example, the due date for curing an Appendix B sufficiency would be the later of 70 days or 35 days after the projects Phase I Interconnection Study Results Meeting.

As described elsewhere in these comments, EDF-R does not support IRs being “deemed complete” before the scoping meeting, given the dramatic financial consequences CAISO is proposing with respect to scaling nonrefundable interconnection fees.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

No comment at this time

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

EDF-R supports CAISO’s proposal for Transmission Grid Data Transparency and requests that the next proposal iteration include specific descriptions of that the CAISO is committing to provide, including data fields and their definitions.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

No comment at this time

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

No comment at this time

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

EDF-R supports the expansion of deliverability transfer opportunities.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

No comment at this time

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

EDF-R enthusiastically supports the notion that when a developer issues a notice to proceed to the Participating TO, Participating TO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects.

This is logical, will likely reduce the number of PTO triggered ISD delays, and may have the long term benefit of reducing the need for Limited Operations Studies or projects coming online with IDF instead of FCDS. All of these items are evidence that transmission sometimes trails generation.  

Here EDF-R notes that specific interconnection customers that have experienced these effects may not be present in this initiative for whatever reason, and a failure to receive CAISO’s requested information should not be taken an indication that no such issue exists.

EDF-R also sees CESA’s proposal for added transparency and new performance standards regarding the timely construction and completion of network upgrades by Participating TOs as a complimentary to this issue. EDF-R appreciates CAISO’s including it in the Transmission Grid Data Transparency item.

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

No comment at this time

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

EDF-R supports the improvement of RIMS to capture a projects complete document set, including MMA work.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Golden State Clean Energy (“GSCE”) appreciates the opportunity to submit this comment. Our comment addresses the following topics:

• Question 3 regarding the revisions to the deliverability allocation process
• Question 4 regarding generator interconnection-procurement-transmission and resource planning alignment
• Question 8 regarding site exclusivity
• Question 22 regarding deliverability transfers
• Question 26 regarding documents to be provided on RIMS

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

GSCE appreciates CAISO’s examination of the current TP deliverability allocation groups and process, and we generally support the proposed revisions to the allocation groups that would simplify allocation eligibility. However, we believe that CAISO should provide for an additional allocation group that recognizes commercial viability with criteria other than shortlisting or a PPA. In addition, we strongly oppose the proposal to restrict the PPAs that are eligible for an allocation of deliverability to PPAs with offtakers seeking to fulfill their own RA obligation. We believe that corporate entities provide much needed capital for adding to the resource fleet and in doing so add liquidity to the RA market while also helping the state achieve its GHG reduction goals. Given that these corporate entities are supplying facilities in California and paying the TAC charges, there is no policy reason to establish a preference for PPAs with LSEs as qualifying for deliverability while excluding PPAs with commercial entities where the PPA requires RA.

The proposed allocation groups are an improvement, but an additional group may be needed

CAISO is proposing to reduce the number of TPD allocation groups to three, which includes eliminating the ability to seek deliverability by proceeding without a PPA. GSCE is supportive of these three new allocation groups and their proposed order. Collapsing the groups into three straightforward groups will simplify the process and allow the current mechanism to continue to drive deliverability allocation with minimal disruption.

However, there is a gap that could be filled by a fourth category that recognizes commercial viability in alternative ways. More projects are considering merchant options for development. PPAs are no longer essential for a project to be commercially viable. In addition, where projects seek to add storage, there is value to the grid to have the storage additions be deliverable as soon as they are operational. The fourth group could be opened to later stage “ready” projects (defined by full site control, completed interconnection facilities, or other relevant elements), and to storage additions.  This would help address the “chicken and egg” problem that exists for projects seeking to supply LSEs with RA where they do not yet have an allocation of deliverability. Projects in this category, in demonstrating strong commercial viability, could also offer their PPA counterparties more certainty that they will be successful in achieving commercial operation.

Corporate PPAs should qualify for TPD allocations

GSCE opposes CAISO’s proposal to only allocate deliverability to the proposed groups one and two when the PPA contemplated is with an LSE with an RA obligation. At the very least, CAISO should grandfather in all PPAs that require RA and are executed by the time of the effective date sought from FERC for this eventual tariff filing. But we believe that these PPAs should continue to be eligible to support deliverability allocation and retention going forward. Grid reliability, GHG reduction goals and ratepayers all benefit from more financial resources supporting new construction in California and the market liquidity created by additional supply.

If an offtaker is willing to pay the premium for RA and require deliverability of a resource, whether it is an entity with its own RA obligations or not, the value is only realized if that entity markets the RA. We believe the commercial realities dictate that any resource capable of supplying RA would be offered into the RA market, and any concern that CAISO may have that deliverability would not be used to support RA is misplaced.

Corporate offtakers are growing as active participants in the PPA market as corporations strive to support policy goals by encouraging GHG-free supply. CAISO should develop rules to support development of resources that meet reliability and policy goals, not discourage them. By limiting the ability for corporate offtakers to participate in the RA market, CAISO may drive them to sign PPAs for energy-only renewable resources that do not require storage, adding to the solar curtailment problem and to the challenges with managing a grid with high penetration of renewables.

There is no policy reason to deprive corporate offtaker PPAs of the opportunity to qualify for deliverability. Corporate entities as ratepayers pay their share of the TAC when using the transmission grid, whereas LSEs only fund it as a pass-through to their ratepayers. In addition to the ratepayer, policy and reliability benefits provided by retaining the ability of corporate offtaker PPAs to qualify for an allocation of deliverability, CAISO’s existing tariff framework does not require the LSE-RA obligation link for entities to qualify for deliverability, and CAISO’s proposal is at odds with longstanding FERC-approved precedent. A project can currently receive deliverability by proceeding without a PPA and reach commercial operation without a PPA but still have deliverability. All grandfathered projects relying on balance sheet financing fall under this category, as do projects that elected to proceed without a PPA under the current group 3.

A stakeholder participating in the December 13, 2021, stakeholder call asked whether CAISO would consider a corporate PPA if it was shown that the PPA had been re-sold to an LSE with an RA obligation; CAISO noted it had not ruled this out. We do not believe this is a viable option. It would add a needless level of administrative burden on CAISO and the contracting parties, and again is at odds with the current tariff framework.

In sum, commercial customers who are greening their portfolios by entering into long-term PPAs for renewable energy that require deliverability support state policy and GHG reduction goals and should continue to qualify for a deliverability allocation, deliverability retention, and to satisfy commercial viability criteria required after seven years in the queue.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

CAISO expressed concern over the lack of coordination between the GIDAP and TPP, especially the role of the TPP’s policy-driven studies. GSCE appreciates this concern, and we support further examination of GIDAP-TPP linkage. Part of the issue we see with the current GIDAP-TPP linkage relates to the significant influence the CPUC’s resource portfolios and busbar mapping have over transmission planning. Busbar mapping looks to the current queue, in part, to inform commercial interest. However, the queue is not intended to be representative of where transmission development needs to occur. We believe this reliance on the current queue, along with a resource mapping process that intends to reduce grid expenditures by avoiding new transmission infrastructure investments, leaves California without a means to proactively drive policy-driven development through planning. This, in turn, is creating issues for resource development.

Thus, as CAISO considers “not only developing transmission capacity for planning purposes,”[1] we support examining how planning can spur needed transmission investments to facilitate smarter development of renewable resources.

CAISO also indicates it is considering a reservation system within the policy-driven process as a means of ensuring the intended resources are allocated deliverability. We do not support this suggestion at this time because we think this consideration fails to address the current impediments to planning for new infrastructure. We are also not sure how the concept of a reservation system gets reconciled with CAISO’s historic position that deliverability is not a right conferred on interconnection customers. However, despite these concerns, we would support further examination of this concept in a stakeholder process.

As an alternative to a reservation system or as a supplemental proposal to consider for addressing GIDAP-TPP linkage, we point to our comment on the Preliminary Issue Paper.[2]  There, we called for further assessment of an interconnection process that focuses on locational considerations and least-regrets policy resource zones. Among existing CAISO and California planning processes, we see a potential framework to build from in CAISO’s 20-year transmission outlook and the zonal assessment supported by the CEC and the SB 100 report. This could move away from use of the current queue for driving resource locations used in the TPP, away from a mapping process that seeks to neatly place resources in areas that avoid transmission upgrades in a nearer-term horizon, and towards a process that is focused on building new transmission to zones where state policy supports development of resources that are needed to meet SB 100. We also see parallels to a zonal process and the Tehachapi initiative, which CAISO highlighted in PG&E’s comment that called Tehachapi a success story.[3] 

CAISO noted that planning, interconnection, and procurement could be improved by expanding the transmission planning horizon.[4]  GSCE strongly agrees with this – CAISO’s generation interconnection and transmission planning processes must work in tandem to develop the necessary resources needed to reliably meet California’s SB 100 goals. Incorporating the 20-year outlook into more CAISO processes could bring about the improvements CAISO seeks, and it also helps address the need to allow the 20-year outlook to go beyond a mere planning exercise.

Lastly, to the extent that policy development requires changes to the TPP, we believe that CAISO should embrace this in a new initiative sufficiently scoped to address changes to the IPE and TPP in tandem. Issues found out-of-scope in this IPE that relate to the TPP would likely not be within the scope of any currently active initiatives, and CAISO should ensure needed policy reform does not fall through the cracks.

[1] CAISO sought feedback on this consideration in the first question posed in section 3.4. 2021 IPE, Issue Paper and Straw Proposal, at 15, Dec. 6, 2021.

[2] Stakeholder comments on the Preliminary Issue Paper are available on the 2021 IPE webpage: https://stakeholdercenter.caiso.com/Comments/AllComments/93e0040c-4e2e-4d37-8b2c-7eb0e7c55aa9.

As an example of our zonal proposal supplementing a reservation system, CAISO could look to transmission projects in the 20-year outlook as policy projects that it begins withholding deliverability for and soliciting. As an example of using a zonal process instead of a reservation process, CAISO could refine its interconnection process or create a separate study track that is policy-zone oriented, focusing on specific zones that can proactively unlock resources for policy needs that meet certain eligibility criteria to apply (e.g., site exclusivity in the policy zone).

[3] 2021 IPE, Issue Paper and Straw Proposal, at 14, Dec. 6, 2021.

[4] 2021 IPE, Issue Paper and Straw Proposal, at 14, Dec. 6, 2021.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

GSCE continues to support stronger site exclusivity requirements throughout the interconnection and deliverability allocation process. CAISO’s proposal to require site exclusivity for projects to move on to Phase II studies is reasonable, particularly with the size of current clusters. We support CAISO’s proposal and its inclusion in phase one of the initiative so it can become effective in 2022.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

GSCE supports this proposal.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

GSCE supports increasing the functionality of RIMS to include more documentation.  All communication handled now exclusively via email, including deliverability allocation results, financial security posting requests, and MMA documentation and results, should be provided on RIMS in addition to being communicated via email and other written correspondence.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

CalWEA’s primary concerns are as follows.

CalWEA urges the ISO to moderate some of its proposed actions, which are in response to the large size of Cluster 14, to avoid harming smaller developers.  In response to question 7, we urge the ISO to focus on developers that submit an inordinate number of applications – the study deposit and the site exclusivity deposit should remain at the current level for a developer’s first five interconnection requests, so as not to penalize developers with limited requests.  In addition, forfeitures should only be considered for 30 days after the Phase I results meeting.

With regard to the ISO’s proposal to require that interconnection customers finance network upgrade costs to local (below 200 KV) systems exceeding the funding cap (response to question 9), CalWEA strongly opposes this and advise that treatment of network upgrade costs should not differ simply due to a different interconnection voltage level. 

Finally, CalWEA urges the ISO to focus on helping projects already in the queue to complete development on time.  As a primary example, CAISO should require PTOs to build needed upgrades in a timely fashion; currently, PTOs often take an inordinate amount of time to complete upgrades. CAISO should address this fundamental problem rather than creating shortcuts around the current processes or a new solicitation model. Also, the timing of the limited operational study (5 months before the Initial Synchronization Date) is too late to help with the project development of such projects.  CAISO should allow an early LOS a – as early as 24 months before the Initial Synchronization Date.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

CalWEA supports the proposal and suggests that the ISO make it clear in the draft final proposal that if the downsizing project has any network upgrades, the proposed MMA-like process will determine if the request has to be assessed in the annual reassessment.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

CalWEA supports the proposal with modifications. Groups 1 and 2 should include all active IR or operational resources (rather than only active IRs). CalWEA strongly recommends that the existing TPD Allocation Group 3 that is reserved for actively queued projects to request TPD Capacity based on “Proceeding to Commercial Operation without a PPA” be maintained. Among several practical reasons, we believe that merchant generators should not be deprived of the opportunity to seek deliverability before they are operational.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

The current process could work if, rather than avoiding transmission upgrades as part of the integrated IRP/TPP process, the CPUC would optimize the portfolio in a realistic way that does not seek to avoid transmission upgrades. CalWEA believes these topics should be addressed by the CPUC in the IRP process.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

The overheated areas and the cost of transmission in these areas are already known to the public. Transmission capacity in many of the overheated areas are already fully allocated to the projects in the queue. Instead of creating a new solicitation model, ISO should focus on helping the projects already in the queue to complete development on time.  As a primary example, the ISO should require PTOs to build needed upgrades in a timely fashion; currently, PTOs often take an inordinate amount of time to complete upgrades. CPUC should optimize the IRP portfolios in a more realistic way that could require transmission upgrades.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

Rather than creating short-cuts around the GIDAP process, deliverability allocation process, and limited operational study process, the ISO should focus on expediting the completion of upgrades that are delaying many projects in the queue from becoming operational. The ISO should address this fundamental problem rather than create shortcuts that CalWEA believes will mostly benefit PTO projects.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

CalWEA opposes higher fees and study deposits that could be a barrier for smaller developers and thus impede competition. Measures to pare down the queue should be aimed at developers that submit an inordinate number of applications. CalWEA recommends keeping study deposits and the site exclusivity deposit for the first five IRs at the current level, so as not to penalize developers with limited requests. In addition, forfeiture of 50% of the site exclusivity deposit upon project withdrawal after the IR is deemed complete is too stringent. At the earliest, such forfeiture could be considered 30 days after the Phase I results meeting.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

CalWEA has no objection to this ISO proposal. 

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

CalWEA strongly opposes requiring that interconnection customers finance network upgrade costs exceeding the funding cap. Treatment of network upgrade costs should not differ simply due to a different interconnection voltage level. 

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

CalWEA has no objection to this ISO proposal. 

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

CalWEA does not object to this ISO proposal but asks ISO to clarify the different processes for PTO/ISO error and omission vs. IC error and omission. According to the ISO during the stakeholder call, an IC must give up maximum cost responsibility (MCR) and maximum cost exposure (MCE) protections in order to correct an IC-responsible error or omission. ISO should describe how the MCR and MCE would be re-established.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

CalWEA has concerns about the limited operational study to allow interconnection prior to completion of RNUs. Please see comments below in response to question 20.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

CalWEA supports this ISO proposal.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

CalWEA supports this ISO proposal and requests that the ISO and PTOs clearly define the study area boundaries and make the definitions available to the public. 

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

CalWEA doesn’t see any harm in EO projects remaining in the queue except that it could contribute to the need for short circuit duty mitigation. An EO IR could be terminated if it contributes to critical short circuit duty needs and has made no progress towards COD beyond the 7-year period. 

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

CalWEA supports verbal comments by Phoenix Consulting that there should be a middle ground to allow parked projects to submit certain MMAs and at the same time meet their second IFS posting requirements. 

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

CalWEA has no objection to the ISO proposal but asks ISO to clean up Appendix B to remove unnecessary data requirements.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

CalWEA believes that shared IRNUs should not be exempted from GIDAP 14.2.2 if the projects sharing upgrades have no affiliation with each other

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

CalWEA supports the ISO proposal. ISO should enhance the quality of interconnection reports. For example, ISO should define the study area boundary in the area reports. 

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

CalWEA supports the ISO proposed modifications to commercial viability criteria. But the proposal does not address the concern CalWEA has raised regarding project interconnection before all its RNUs are in service. Timing of the limited operational study (LOS) (5 months before the Initial Synchronization Date) is too late to help with the development of such projects.  ISO should allow an early LOS – as early as 24 months before the Initial Synchronization Date.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

CalWEA does not see any basis to assign NU to projects with earlier COD if such NUs are not needed by these projects. PTOs will be pressed to construct NUs in a timely manner to meet generator COD needs.

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

CalWEA supports this ISO proposal. 

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

The current flow test for independence is based on the flow caused by the Generating Facility being tested divided by the lesser of the Generating Facility’s size or the transmission facility capacity. If the result is five percent (5%) or less, the Generating Facility would pass the flow impact test. This means both shift factor and flow impact must be less than 5% to pass the test. CalWEA suggests that ISO modify the criteria such that small projects with close to 0 flow impact can pass the test even if they are electrically close to the transmission facility being tested – their shift factor is higher than 5%:

The Generating Facility passes the flow impact test if one of the following is true: 1) flow divided by the Generating Facility's size is 5% or less, or 2) flow divided by the transmission facility capacity is 2% or less.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

The ISO requests stakeholder feedback on whether FCDS should be provided to an Interconnection Customer that has achieved commercial operation, provided the Interconnection Customer agrees to pay the cost of the upgrade(s) that have not yet been built and agrees to defer repayment of Network Upgrades until all upgrades are built or a reassessment study determines that the Network Upgrade(s) is no longer required. CalWEA believes that FCDS should only be granted after the required upgrades are in service unless the ISO changes the NQC reduction methodology. Currently, resources get Interim Deliverability Status (IDS) while waiting for the upgrades, then achieve FCDS after all required upgrades are in service. If there isn’t sufficient transmission to support deliverability of all the resources due to upgrades not in service yet, NQC is reduced among IDS resources first. If NQC reduction among IDS is not enough, further NQC reduction is spread among all FCDS resources contributing to the transmission constraints. Therefore, if a resource is designated FCDS before the needed upgrades, the NQC reduction is unfairly spread to other FCDS resources that do not require the upgrades.

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

CalWEA does not agree with the ISO proposal and suggests the agreement be required by the time that Appendix B is due. If the IC does not have an agreement from the third-party before the Phase I study, the Phase I study can assume a dedicated gen-tie for the purpose of establishing MCR. 

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

CalWEA supports the ISO proposal to include all documents in RIMS.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

CalWEA has no additional comments.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Q CELLS appreciate the opportunity to provide continued feedback as part of CAISO’s Interconnection Process Enhancement 2021.

Q CELLS is primarily concerned with three items: TPD Allocation Groups, Application Costs and Site Exclusivity. Our responses to each point are provided below. Other responses are similar to previous submissions.

About Hanwha Q Cells

Q CELLS is a total energy solution provider worldwide. Our business scope ranges from the midstream of cells and modules to downstream solar solutions for residential, commercial, and industrial buildings, as well as for large solar power plants.

Since our entry into the solar energy business in 2010, the Hanwha Group has transformed Hanwha Q CELLS into the world’s leading producer of solar cells and modules. Our current production networks span across China, Malaysia, South Korea, and the US. Bolstered by strong revenue and driven to stay ahead of the growing worldwide demand, we’ve continued to invest in R&D and manufacturing innovations. Our Malaysia plant alone was able to produce more than 1GW of Q.ANTUM cells annually in 2015, the first of its kind in the industry. In Q1 2019, we penetrated the US market and began our acceleration to expand into the country by building a 1.7GW capacity module plant in the US state of Georgia.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

Q CELLS supports expanding the downsizing window and removing re-assessment hold for final decisions as described above.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

Q CELLS is open to either current Group 3 (proceeding without a PPA) remain as is or modify the proposed Group 3 to allow projects without a PPA to receive TPD allocations and fund/build deliverability network upgrades with the ability to park or maintain the deliverability some period of time.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

Q CELLS believes the focus should be added efficiency to help achieve CA at 100% carbon free by 2045

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

Q CELLS has no comment.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

Q CELLS has no comment.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

Q CELLS remains open to higher fees, especially those required for studies. However, we do not agree with the fee structure, which appears excessive. Q CELLS recommends a reduction in single-project applicants to $200K, as well as a max rate of $500K per project once five (5) projects have been submitted.

For clarification, Q CELLS proposes that all projects submitted by a single developer in a single cluster up to and including the fifth (5) project will incur a $200k/project application fee, while all additional projects [six (6) or greater] in that same cluster will be charged $500k/project.

Q CELLS remains open to increased study fees.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

Q CELLS would accept site control requirements being implemented prior to entering Phase 2 studies if the site control requirements were limited to a portion of the generation site/project-based land requirements, ideally 60%, and there was no site control requirement for the generation interconnection tie line (0%). This modification will provide some flexibility for developers in the land negotiation process while still proving the project has obtained real commercial potential.

Q CELLS also does not support in-lieu deposits at this phase of the IP. Q CELLS believes that Phase 2 is an appropriate stage to have majority site control.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

Q CELLS generally supports pushing costs regionally so that local customers are not burdened, and communities do not push back on projects due to high local costs. Further, Q CELLS believes that interconnection customers should receive a fair treatment from a cost reimbursement standpoint if the generation addition provides grid benefits to ratepayers outside the local area of the PTO.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

Q CELLS fully supports memorializing specific procedures and base cases for affected systems. Furthermore, Affected Systems should be reimbursed as they are benefiting rate payers and other grid users in the affected region. The timelines for repayment should be shorter than a one-time cash payment at the end of 20 years per FERC rulings and should be provided as an option in a form other than Transmission Service Credits.

Q CELLS would like CAISO to mediate with affected parties to find proactive solutions when affected system issues arise.

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

Q CELLS has no comment.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Q CELLS has no comment.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Q CELLS supports this for enhanced communication through establishing a formal procedure that results in clearly stated party responsibilities to reduce confusion.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Q CELLS has no comment.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

 Q CELLS has no comment and looks forward to further discussion.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

Q CELLS has no comment.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Q CELLS has no comment.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

Q CELLS has no comment.

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

Q CELLS has no comment.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

Q CELLS has no comment.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

Q CELLS has no comment.

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

Q CELLS has no comment.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

Q CELLS has no comment.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

Q CELLS has no comment.

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

Q CELLS has no comment.

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

Q CELLS has no comment.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

Q CELLS has no comment.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

LSA/SEIA are open to considering interconnection-process changes that could allow resources demonstrating advanced “readiness,” or needed to maintain system reliability, to move ahead more quickly than others, as long as these actions do not impair progress of other projects already under development. 

To that end, LSA/SEIA strongly support efforts that would allow such projects to move ahead without adverse impacts to other projects, including:

• Reforming deliverability-transfer rules to allow transfers between projects connecting at the same substation and voltage level, to improve the viability of projects ready to move forward and facilitate withdrawal from the queue of those that are not;

• Better differentiating between projects in a cluster where some longer lead-time upgrades are not needed for the entire cluster, allowing some projects to reach Commercial Operation Dates (CODs) and/or receive deliverability status (Full Capacity or Partial Capacity Deliverability Status (FCDS or PCDS) before others in the same cluster;

• Performing a Network Upgrade (NU) “re-stack,” to see if it could enable projects desiring earlier CODs to move faster and/or receive deliverability status quicker without any adverse impacts on other projects (i.e., no cost-allocation or construction-schedule changes); and

• Retaining a reformed Transmission Plan (TP) Deliverability Allocation Group 3 option, but with changes to require progress acquiring PPAs, to improve competitiveness of projects otherwise ready to move forward.

LSA/SEIA also strongly support CAISO provision of additional information about where, and how much, TP Deliverability remains in the system, to aid developers in their locational decisions, along the lines of proposals from Gridwell.

On the other hand, LSA/SEIA do not support changes that would:

• Harm resources already under development.  Receipt and retention of TPD allocations under the GIDAP already require some form of viability demonstration – an executed PPA (Groups 1 & 4), shortlist position or active negotiations (Groups 2 & 5), or prompt movement forward under stringent rules (Group 3).

In particular, projects that have made serious commitments (PPAs, land acquisition, permitting, equipment procurement) should not be faced with COD delays, or deliverability removal or delays, which would seriously impair their project viability or progress, in the absence of serious and verified legitimate system reliability threats.

• Favor some technologies over others.   The CAISO tariff and associated rules are (to the extent reasonably possible) technology-neutral and based on open-access principles.  Set-asides and other special treatment not justified by reliability needs distorts efficient resource development and market operation.

• Go beyond appropriate CAISO authority.  Energy procurement decisions are made by state policy-makers and Local Regulatory Authorities (LRAs) like the CPUC.  Aside from the straightforward provision of factual information (e.g., about interconnection capacity and/or deliverability availability) and the above interconnection-related actions to allow quicker development of ready resources, the CAISO should not take actions on its own initiative to influence the location or resource mix procured by LSEs.  If LSEs are procuring resources through the “Least-Cost, Best Fit” (LCBF) approach in areas needing upgrades, then the CAISO should approve additional transmission to accommodate those choices, not incent or force development in other areas.

LSA/SEIA’s comments below are consistent with these principles. 

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

Support with clarifications

Among other things, the Proposal would remove the current downsizing application window, unique deposit, & agreement, allowing requests to be submitted at any time, and processed via an “MMA-like” process. 

• Projects with no Network Upgrades could be approved through the MMA process. 

• The CAISO clarified at the stakeholder meeting thatrequests for projects with Network Upgrades could also be approved in the MMA process (e.g., if all NUs are 100% assigned to the project); if not, they would be included in the annual Reassessment (like today).  This determination would be made on a “case-by-case” basis.

LSA/SEIA support the concept of simplifying the downsizing process and making it more like the regular MMA request process (as it was before implementation of the formal and separate downsizing process).  However, developer benefits would be limited to the extent that downsizing requests would continue to be processed in the annual Reassessment, and the CAISO appears already to be overwhelmed by the current MMA request workload (as evidenced by the lengthening timelines LSA/SEIA members have seen for processing such requests).  Thus, CAISO should clarify:

• Whether the “MMA-like” process proposed is actually the regular MMA request process, e.g., whether the MMA processing target timelines would apply; if not, the CAISO should clarify any process differences and explain why they would be necessary.

• The criteria CAISO will use for “case-by-case” determinations of whether requests for projects with Network Upgrades could be processed through the new, expedited procedure or must be held for the Reassessment process.

• How CAISO will manage these additional MMA-type requests when it is already short of resources to handle the current MMA request workload.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

Support, but with the revisions and clarifications described below.

Revisions: 

• Retain Allocation Group 3 (before proposed Group 3, which would become Group 4)

LSA supported elimination of the predecessor to Group 3 – the Balance-Sheet Financing (BSF) affidavit – because it allowed projects to linger in the queue for years while retaining valuable deliverability.  LSA agrees with the CAISO conclusion that few projects are actually built without a PPA under this option.

However, Group 3 has evolved into a different type of tool since its establishment.  Essentially, it allows projects to obtain deliverability in order to be more competitive in procurement solicitations to obtain a PPA and then be constructed.  Moreover, restricting TPD awards to projects acquiring or being shortlisted for a PPA with an LSE having an RA obligation is essentially the same as the proposal the CAISO is discarding for lack of support, i.e., giving LSEs the ability to allocate deliverability.

The CAISO has not presented any evidence that Group 3 projects are lingering in the queue or that they are less likely to be successfully contracted and built than, say, projects electing Group 2.  In fact, the CAISO’s contention that projects are using Group 3 allocations to acquire PPAs (and then, presumably, be constructed) demonstrates that a Group 3 allocation has become a new path to successful development.

For those reasons, LSA/SEIA propose that CAISO retain Group 3, but with reforms that recognize its transitional nature by:

• Keeping the current restrictions (e.g., no suspension rights); and

• Requiring projects to progress toward a PPA, similar to Group 2.  Projects selecting the new Group 3 must:

• Be shortlisted or in active negotiations for a qualifying PPA by the next cycle;
• Have executed a qualifying PPA by the next cycle after that; and
• Obtained any regulatory approval by the cycle after that.

This reform would retain the benefits of Group 3 while preventing projects from retaining deliverability if they fail to progress toward PPA acquisition and eventual construction.

• Remove the “active IRs” restriction, since the CAISO would allow operating EO projects to acquire deliverability, and technically they are no longer “active.”

Clarifications

• Confirm that EO projects that are not yet operational can qualify for Groups 1 or 2 if they otherwise qualify.  

• Explain why EO capacity requesting deliverability must be studied to “ensure the project is not behind a deliverability constraint,” when the intent here is to allow EO projects to compete for TPD behind a deliverability constraint.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

Oppose. 

Despite some CAISO protests to the contrary during the stakeholder meeting discussion, this is clearly a proposal aimed at new offshore/imported wind and geothermal resources.  LSA/SEIA do not agree with policies that favor some technologies over others, unless there is a legitimate reliability need and higher-queued projects (which may have made financial and schedule commitments) are not impaired as a result.  

The CAISO tariff and associated rules are (to the extent reasonably possible) technology-neutral and based on open-access principles.  Set-asides and other special treatment not justified by reliability needs distorts efficient resource development and market operation.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

May support, depending on the details. 

LSA/SEIA are open to considering such a model, as long as the opportunities to offer such “clarity” or “interest expressions or commitments” are technology-neutral and do not impair higher-queued projects.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

Support reformulated proposal, for “emergency”-type authorization, but with clarifications. 

Specifically, CAISO should make the clarifications from the stakeholder call, i.e., that:

• The resource would use only Interim Deliverability, if available, and not receive a “permanent” deliverability award through this path; and

• Continued resource operation after 3 years would require submission of regular IR via one of the other established tracks, without any advantage over other projects submitting IRs in those processes.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

STUDY DEPOSIT:  Neutral on the proposed increase to $250K, but strongly opposed to the proposed increasing scale with multiple Interconnection Request (IR) submittals. 

LSA/SEIA oppose the proposal to raise the Study Deposit as high as $1 million per project for multiple “parent company” submittals because, as CAISO confirmed on the stakeholder call:

• The higher fees have no relation to actual study costs.  “Calling them something else,” as was suggested by the CAISO during the discussion, does not make them any fairer.

• The proposal is based on “anecdotal evidence from Scoping Meeting discussions” (not actual evidence) that large developers submit “numerous [IRs] requests to see which work out,” instead of “a small number of well-developed, viable projects.”  While submitters of multiple IRS may submit a large portion of total IRs, CAISO offered no evidence that those IRs are any less solid or less successful than projects submitted by submitters of low numbers of IRs. 

For example, one could theorize, with equal credibility, that larger developers have many more resources, more experience, a broader view of the market, and more financial resources to support project analysis and ultimate development, so perhaps their projects are more likely to be successful even where they are submitting multiple IRs.

LSA/SEIA offer the following additional feedback:

• The IC is typically a project LLC, not the “parent company.”  It’s not clear how CAISO will determine the parent company for those IRs, or legally how CAISO can penalize a project LLC (a separate legal entity) for unrelated actions (i.e., submittal of separate IRs for other project LLCs) of the parent company.

• The CAISO have to determine criteria for which project(s) would be subject to the penalty if multiple project companies with a common parent submitted IRs at the same time.  

• The CAISO have to determine how this policy would be applied to more complex project ownership structures, like joint ventures or other shared ownership models. 

SITE EXCLUSIVITY DEPOSIT CHANGES:  Do not oppose.

LSA/SEIA do not object to giving the proposed small advantage for projects that do have Site Exclusivity this early.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

Oppose.

As LSA/SEIA stated in our last comments, a project would not typically have achieved that milestone before entering Phase II. 

LSA/SEIA object in particular to imposing this requirement on Cluster 14 projects.  Commercial decisions were made, and capital allocated to these projects, based on the current rules; changing the rules halfway through the process would be unjust and unreasonable, and it could result in significant opportunity costs.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

Oppose, but could support with changes. 

Though the Proposal does not explicitly so state, of course this proposal is another CAISO try to mitigate VEA-area ratepayer impacts from new development in that resource-rich area.

LSA/SEIA support this goal; we supported the CAISO’s earlier VEA proposal, with its narrowly focused approach, and we still do.  However, we oppose this proposal because it is unjust and unreasonable to impose different and discriminatory refundability rules in different CAISO-area locations. 

Moreover, the proposal is flawed logistically. 

• There is no way for a project to know its cost liability until it gets an Interconnection Study.  Even after the cap is reached, for example, there may still be “room” for new capacity, depending on the location, and/or upgrades needed may not be expensive. 

• Moving the POI to a higher-voltage point would sacrifice any Network Upgrade cost-cap protection, so that suggestion is not realistic under the current rules.  (If this suggestion is implemented, POI changes for this reason should be allowed, with retention of cost-cap protection.)

Certainly, any such significant rule changes should not be applied for projects already in the queue.  Going forward, the impact will be to greatly reduce or cease IR submittals on the VEA system, regardless of the quality of the resource or the amounts in the CPUC resource portfolios. 

Instead of imposing discriminatory refundability rules based on generator/storage location, this initiative should consider other options, e.g., :

  - Addressing FERC’s problems with the earlier proposal;

  - Systemwide uniform LVTAC rate (like the current HVTAC rate);

  - Systemwide LVTAC adder to fund interconnection-related upgrades (cost-causation being that LSEs can contract in any area to meet their RPS and RA requirements);

  - Allocation of “excess” costs to other PTO LVTAC rates based on contracting of projects in the VEA area by LSEs in other PTO areas

  - Approaches recommended by VEA that would recover LVTAC costs in the HVTAC when the "host" PTO is already fully conracted.. 

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

Support.

LSA/SEIA fully support the CAISO’s proposed policy, including refunds for CAISO-area Network Upgrades funded by resources interconnecting in other BAAs.  LSA/SEIA continue to urge the CAISO to seek reciprocal arrangements with other jurisdictions, so that CAISO-area projects can receive similar treatment from those other jurisdictions.

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

Support, with modifications.

The Proposal is balanced and reasonable generally, as far as it goes, recognizing that cost and COD timing are critical elements for project viability and PPA commitments. 

However, the Proposal does not recognize one other critical element – project deliverability.

The “FCDS Guarantee Date,” “RA Start Date,” and similar deadlines are typical PPA milestones.  Significant deliverability delays due to errors or omissions can cause the loss of the PPA and/or significant financial damage liability, just like ISD delays, and they can thus seriously undermine the commercial viability of a project.

The CAISO tariff recognizes the importance of deliverability by allowing COD postponements generally if the PTO is late for any Network Upgrade in-service date, not just Reliability Network Upgrades needed for COD.

Thus, LSA/SEIA recommend the change below, to add deliverability to the conditions activating this provision, i.e. adding the underlined language below:

When an error/omission is discovered after the either the first or second IFS posting that increases aggregate interconnection costs (refundable or not) by >5%, or pushes back the earliest achievable ISD or the FCDS/PCDS effective date by >12 months…

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Oppose. 

There are two issues here.  The discussions on this point have been confusing, and further CAISO explanation would be very helpful in developing a reasonable solution.

The first issue, raised in the CAISO’s original proposal, is cost/reimbursement treatment.  A RAS identified in a Deliverability Assessment should be considered deliverability-related and should count as a DNU for reimbursement purposes.  If the RAS would not have been triggered if all projects in the cluster were Energy Only, then it is functionally a DNU and should be treated as such.

The second issue, added in the Proposal, is whether a RAS identified in a Deliverability Assessment must be completed for reliability reasons before a project comes on-line.  If A RAS is needed for a project to reliably connect, even as an Energy Only project, then LSA/SEIA do not oppose a requirement that it be completed before COD.  However, if the RAS is triggered by construction and operation of a DNU, then: (1) Energy Only projects should not require the RAS for interconnection and operation; and (2) FCDS/PCDS projects should not require the RAS for interconnection and operation until the triggering DNU(s) go into service.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Support with modifications. 

It would be helpful to have some more process structure when a developer submits an IR to the wrong jurisdiction, and LSA/SEIA understand that the CAISO has jurisdiction over only its own tariff (i.e., CAISO procedures and not those of PTOs) – the reason why the Proposal only covers situations where an IR is erroneously submitted to the CAISO and not the other way around. 

However, as LSA/SEIA suggested before, it would be much better if the problem could be avoided.  To help ensure that, the CAISO and PTOs should provide public information about the operational control of substations and lines, so that the jurisdiction is clear before IRs are submitted.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Support with clarifications.

The Proposal is reasonable, but CAISO should provide the clarifications listed below.

• Define the term “transmission study area.”

• Clearly state that site changes are allowed later, through the MMA request process, as long as the POI (substation and voltage level) stays the same.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

LSA/SEIA’s responses to the CAISO’s very interesting questions are given below.

1) Should EO projects be allowed to stay in the queue forever?

No, but BPM for Generator Management, Section 6.5.2.1 states that “projects requesting to remain in the queue” beyond the applicable limit “clearly demonstrate that:” (1) engineering/permitting/construction will take longer than that; (2) the delay is beyond the IC’s control; and (3) “the requested COD is achievable in light of any engineering, permitting and/or construction impediments.”

This language does not seem like a license to stay in the queue “forever.”  However, LSA/SEIA do not object to consideration of reasonable EO viability criteria or time limits.

2) Should there be a time limit for project to reply to information queries before a GIA default is declared?

Yes.  LSA/SEIA do not oppose a reasonable time limit for response, e.g., 30 CDs. 

3) If a project needs an MMA (e.g., has missed COD or other major milestone but will not initiate the process), how long should CAISO wait before declaring a GIA default?

LSA/SEIA do not oppose CAISO issuance of a default notice, and appropriate deficiency remediation timeline (e.g., 30 CDs – see above), when a major milestone is missed.

4) Should CAISO take action if project is not moving to permitting, procurement, and construction of Interconnection Facilities or the generating facility but does not miss any GIA milestones?

No.  It seems beyond the scope of CAISO authority, and very burdensome to the CAISO, to decide when an IC “should” be taking actions when a GIA milestone has not been missed, and besides the project would not be in violation of the GIA at that point. 

However, LSA/SEIA have long supported development of a uniform GIA Appendix B milestone table template (and other GIA Appendix formats and content), and that uniform templats could contain standard and appropriate milestones to ensure that a project is not languishing.

5) Any other stakeholder suggestions about moving stalled projects through the queue to completion or withdrawal are welcome.

LSA/SEIA continue to support exploration of voluntary incentives for queue withdrawals, e.g., refundability of security before the 7-year time limit is reached.  (LSA/SEIA note that its proposal for enhanced TP Deliverability transfers below is one such proposal, since it would allow projects with deliverability that are not progressing to monetize the value of that deliverability and then withdraw from the queue.)

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

Oppose, but could support with modifications.

LSA/SEIA oppose this proposal, because projects might need to make modifications while parked in order to improve their competitiveness, and thus their ability to become shortlisted or acquire a PPA in the next TPD Allocation process.  For example, feedback from failures to make LSE shortlists could inform project changes to enable better performance in upcoming RFOs (and/or projects failing to receive a TPD allocation could seek deliverability transfers from nearby less-feasible projects, if LSA/SEIAs proposal allowing such transfers is approved).

However, per the discussion at the stakeholder meeting, LSA/SEIA are open to working with CAISO and stakeholders to develop a narrower group of allowable MMA request changes that could be submitted for a parked project, i.e., those aimed at improving project competitiveness, instead of open-ended changes.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Oppose, but could support with modifications.

The proposed 70 CD deadline leaves too little validation time for projects with Scoping Meetings late in the process.  Since Scoping Meetings can be as late as 60 CDs after the study is issued, this proposal could leave as little as 10 CDs for both re-submittal of Appendix B and complete re-validation. 

However, LSA/SEIA could support a more reasonable deadline, e.g., that validation must occur within a set time (e.g., 45 CDs) after the Results Meeting, with a time limit after re-submittal for CAISO and the PTO to identify any deficiencies.  This proposal would spread the CAISO/PTO validation workload throughout the Scoping Meeting timeline, leaving re-submittals for just a few projects at the end of the meeting timeline with later validation deadlines.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

Strongly oppose.

Normally, Network Upgrades assigned to earlier-queued projects are considered CANUs for later-queued projects depending on those upgrades.  Once one project assigned the NU executes a GIA, the CANU becomes a PNU for the later-queued projects, i.e., the later-queued projects still need the NU but do not bear cost responsibility for it.

This proposal would treat an IRNU assigned to one or more earlier-queued projects as a CANU for later-queued projects needing that upgrade, even after GIA execution by an earlier-queued project assigned that upgrade, i.e., treat IRNUs different from other NUs in this respect. 

Neither SCE nor the CAISO have presented any evidence that this is even a problem, much less one that justifies an exception to current inter-cluster allocation practices.  The CAISO and PTOs should at least provide information about how frequently this issue occurs and whether PTOs have incurred any net costs (including consideration of forfeited security) from such occurrences.

LSA/SEIA very much doubt that this could be a significant problem, for the reasons stated below.

• The issue is limited to projects that drop out after executing GIAs, which is likely a small subset of drop-outs overall.  Again, some data from the CAISO and PTOs would help inform this discussion.

• The issue is further limited to the (usually narrow) window between GIA execution by the earlier-queued project(s) and the third posting, which provides the PTO full coverage of IRNU costs.  Once the third posting is made, there is no justification for imposing IRNU costs on later-queued projects.  The most costly IRNUs – switching stations – have significant lead times, so the third posting for those upgrades would typically be due soon after GIA execution even where the third posting is phased, because other upgrades have shorter lead times.

• The issue is mitigated even during that narrow window by earlier security postings, because the second posting would likely be due before (or very shortly after) GIA execution.  This protection would be greatly increased for shared IRNUs, where (based on earlier reforms) each project sharing the IRNU must post as though they will bear 100% of the costs until the third posting is made. 

So, for example, two projects sharing a switching station must each post 30% of the cost for the second posting (60% coverage total), and so the PTO would have 30% cost coverage (assuming half the posting is refundable) if both projects drop out after GIA execution but before the third posting.

If this is demonstrated to be a significant problem, and if the CAISO decides to proceed ith this proposal, then the following conditions should be considered:

• The security posted for the IRNU but forfeited by the earlier-queued project(s) should be subtracted from the IRNU cost imposed on later-queued customers, and the amount subject to RNU reimbursement limits, since ratepayers would already have received the rest of the IRNU cost without paying reimbursement.

• The later-queued projects subject to imposition of these costs should be informed of the status of security postings by earlier-queued projects, so it is aware of the remaining risk.  Once the earlier-queued project(s) have made their third posting for the IRNU, the upgrade should become a PNU for the later-queued projects.

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

SUPPORT.

LSA/SEIA have two main comment areas for this item, related to:

• LSA/SEIA’s earlier-suggested issue “Better Differentiation Within Clusters,” which CAISO said would be covered in this topic; and

• Additional information that should be made publicly available – primarily, deliverability-related information.

Better Differentiation Within Clusters

Many times, upgrades are triggered by small overloads for the cluster as a whole, and one or more (and in some cases, many or most) projects could connect safely without those upgrades.  The CAISO practice for this situation should:

• Be both uniform (between PTOs) and clear, and it is currently neither.

• Allow project CODs and GIAs to reflect the earlier connection times before the upgrades are triggered (with notice to ICs that projects can lose that “place in line” if CODs are delayed later), without the need for an LOS.

• Allow projects to reach COD or FCDS if the upgrades needed for their interconnection or FCDS are complete, even if all the upgrades identified for the cluster as a whole are not yet complete.

Additional public information desired

LSA/SEIA would like the CAISO to provide the information listed below, in addition to considering the items listed by Gridwell.

• Available TP Deliverability:  In addition to the regular transmission status reporting that CAISO is initiating, LSA/SEIA would like to see more information provided about areas where TP Deliverability is still available, and how much.  The annual TPD Allocation Reports contain useful information about areas where deliverability has run out but relatively little information about where, and much, deliverability remains.

• ADNUs/other upgrades:  This TPP cycle has included a useful discussion about use of the CAISO’s Transmission Capability report to identify potential cost-effective transmission upgrades to provide additional TP Deliverability in areas of high commercial interest.  LSA/SEIA would like the CAISO to refine this information to make it useful in identifying “low-regrets” transmission upgrades, for policy purposes.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

Support

The CAISO already allows project COD delays due to late PTO upgrade construction.  LSA/SEIA believe that, consistent with that principle, CVCs should apply only if the IC submits the modification request to move past the 7-year deadline, and not if the project is delayed past that point due to PTO delays. 

The CVC were implemented (with strong support from LSA/SEIA) to help ensure that infeasible projects do not linger in the queue and “hoard” TP Deliverability.  However, developers cannot control PTO timelines (in fact, PTOs themselves may not be able to do so in some situations), and it would be unfair to impose adverse consequences of such delays (in addition to the consequences of the delay itself) on impacted new generation/storage project.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

Strongly support; additional clarification provided below.

LSA/SEIA appreciate the CAISO’s decision to include this concept in the scope of this initiative.  We believe that it has the potential to accelerate the CODs and deliverability status of projects in later clusters with earlier desired CODs without harming earlier-queued projects with later CODs.

To clarify:  This proposal would impact neither cost allocation nor PTO work sequencing and scheduling. Instead, it would simply align the interconnection and deliverability enabled under existing PTO work sequencing and scheduling for already-planned upgrades with the CODs of projects in the queue.  

Thus, with all due respect, the Proposal statements concerning CAISO’s ability to affect PTO construction schedules are not relevant to this concept. 

With respect to “prioritizing the various upgrades versus project CODs,” LSA/SEIA suggest focusing on Reliability Network Upgrades (RNUs) in areas with the longest lead times first, where Interim Deliverability is expected to be available.

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

Strongly support.

The deliverability impacts to the system of projects connecting to the same substation, at the same voltage level, are exactly the same.  Thus, allowing TP Deliverability transfers between such projects, instead of limiting such transfers to those between Generating Units of a single Generating Facility, would provide additional flexibility to developers without adversely impacting other projects that are either operating or under development. 

As the CAISO notes, this change would also:

• Provide “queue-clearing” opportunities, where an infeasible project can transfer deliverability to a more feasible project, freeing up that deliverability before the 7-year time limit is reached, and then potentially withdraw from the queue.   

• Remove perverse incentives to combine projects into a single GIA – a time-consuming and otherwise useless process – just to enable such transfers.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

Support.

CalWEA explained on the stakeholder call that ISP impact assessments are based on both location (flow impact/shift factor) and MW size.  However, for example, a very small project would have a very small impact even with a high shift factor.  So, while current criteria can trigger an ISP eligibility violation from either location or size, violations should be based on combinations of location and size.

LSA/SEIA agree that this is a reasonable proposal that should be considered further by the CAISO.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

Strongly support.

LSA/SEIA believe that the PTO should begin work on all upgrades once the GIA is executed and the Interconnection Customer provides a Notice to Proceed, for the reasons listed below.

• Given the estimated duration, immediate commencement is needed for the PTO to meet its committed milestones in GIA Appendix B.

• The initial work on a significant upgrade – design, engineering, and permitting – typically consists of relatively low-cost, low-regrets activities, so the project could be readily cancelled if enough projects drop out that the upgrade(s) is not needed. 

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

Oppose.

LSA/SEIA oppose this proposal because it singles out this one element for scrutiny.  The CAISO doesn’t screen other gen-tie feasibility aspects, and we see no reason to single out this arrangement.  The Interconnection Customer bears the consequences if gen-tie arrangements, like this one, become infeasible, e.g., if an agreement with the gen-tie owner can’t be reached and the gen-tie set-up must be revised (like any proposed gen-tie route).

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

Support.

The Proposal requests feedback on whether MMA, Repowering, and Limited Operations study documents (including requests, data files, study plans, study results & other files) should be added to RIMS.  LSA/SEIA believe that the answer is yes.  Incomplete records can cause confusion, and also a lack of continuity when CAISO and PTO personnel assigned to the project (and IC personnel as well) change over time. 

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

Select LSA/SEIA ideas not included in the Proposal

LSA/SEIA request CAISO re-consideration of the two issues discussed below for inclusion as in-scope for this initiative, in light of the discussion at the stakeholder meeting.  We understand that there are many other issues included but believe that these two are sufficiently important that they should be reconsidered.

• Reassessment accommodation for TPD acquisition or retention:  At the meeting, LSA/SEIA argued again for some forbearance in the TPD acquisition/retention process where significant project impacts come in Reassessment studies, especially if they are late and thus too near the TPD Affidavit submittal deadline for the project to adjust.  The CAISO acknowledged that several Reassessment studies were late this year, partly due to Cluster 14 impacts, and said that hopefully wouldn’t happen again going forward. 

With all due respect, the CAISO cannot be sure that this will not happen again; for example, while the CAISO may more closely monitor the circuit-breaker issues responsible for many late and impactful Reassessment reports in 2021, other issues can arise in the future with the same types of impacts.  Even if Reassessment reports are issued on time (around July 31^st), that still leaves less than 4 months for a project to make the significant contractual or other adjustments that may be needed to acquire/obtain a TPD award. 

Instead, criteria CAISO is already proposing for errors or omissions could be used to develop fair and reasonable criteria for treatment of significant Reassessment revisions.  Specifically:

• The applicable criteria would be a Reassessment report that that increases aggregate interconnection costs (refundable or not) by more than 5%, or pushes back the earliest achievable In-Service Date by more than 12 months.

• Demonstration (including confirmation by the potential off-taker) that:

• For new Group 1 allocations:  But for the change, the project would have had an executed PPA.  Such projects could receive a provisional Group 1 TPD allocation but must show an executed PPA by the following cycle.

• For new Group 2 allocations:  If the project was short-listed before the changes, that short-list position could be used as the basis for a Group 2 request even though a new COD may be inconsistent with the RFO/shortlist criteria. 

• Option B reform:  At the stakeholder meeting, CAISO said that Option B was “intended to be used not fairly frequently” and acknowledged that no upgrades have ever been constructed pursuant to Option B, but it asserted that the TPP was the best venue for approval of large transmission upgrades. 

With all due respect, “not fairly frequently” probably wasn’t intended to mean “never.”  The fact that it has meant “never” for over a decade is a solid indication that reform is needed.

There are simple, fair, and reasonable reforms the CAISO should consider that could help improve the viability of this option.  For example:

• If projects are sharing an Option B upgrade and one withdraws from the queue, then the security posting should be given to the other projects, which must now bear the previously shared costs. 

• If costs are not capped, then Option B project sponsors should have the option to reverse their sponsorship decision should costs escalate, i.e., revert to Option A.

• Sponsors of Option B transmission projects should receive compensation to the extent that the upgrade provides: (1) ratepayer benefits, as measured using the TEAM methodology; and (2) deliverability benefits to other new generation/storage projects. 

These are only some of the reforms that could help make this option more viable.  The CAISO should consider them for the scope of this initiative, instead of retaining an obviously unviable “option” that is really no option at all. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Please see MRP’s comments below.   

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

MRP supports the CAISO’s proposal.   From MRP’s recent experience with the Material Modification Assessment (“MMA”) process and the post-COD modification review process, MRP respectfully urges the CAISO to devote sufficient resources to supporting a continuous downsizing process. 

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

MRP does not support the CAISO’s initial proposal to revise the TPD allocation process. 

First, MRP expects that the Federal Energy Regulatory Commission (“FERC”) will not find the proposal to eliminate Allocation Group 3 (projects proceeding on a merchant basis) to be just and reasonable. 

Second, TPD retention criteria should not be eliminated.  They help ensure that only viable projects moving forward continue to retain TPD.

Third, consolidating the number of allocation groups from seven to just three may result in more projects receiving partial rather than full allocations due to multiple projects falling into the same group.  Furthermore, providing projects with two opportunities to obtain deliverability through the TP Allocation Process and then automatically converting them to energy only with a limited ability to obtain deliverability in the future effectively forces queue attrition.  MRP is concerned that allowing energy only projects to linger in the queue for seven years or more will result in a bloated queue and a significant increase in the number of special protection schemes required for later-queued projects that are likely to be more commercially viable. 

For all these reasons, MRP respectfully recommends the CAISO retain the current TPD allocation process. 

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

MRP is skeptical of a process within the CAISO’s transmission planning process that would both develop transmission capability targeted at developing specific “policy-driven” resources and reserve that transmission capability solely for resources that fit within that “policy-driven” definition.  Given the long-lead time for transmission development, and the potential for new technologies to emerge within that long-lead time, such a process has the potential to strand significant transmission investment.  MRP strongly prefers a model, described in the response to item 5, in which the CAISO conducts an open season to solicit, and ultimately, obtain commitments from, resources to expand transmission capability.   MRP finds dubious the idea that, in the face of significant uncertainty, long-forward central planning can produce a better outcome than arming the market with the right information and allowing the market to optimize the outcome. 

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

The IPSP says this (at page 17): 

Based [on] stakeholder feedback, there are two concepts the ISO seeks further feedback on: (1) a solicitation model to seek clarity in an overheated area as to which projects should be carried forward into the interconnection process which could be focused solely on transmission capacity or could be conducted in conjunction with load serving entity procurement processes, and (2) a solicitation model to test and confirm interest in an area in which transmission capacity may be expanded in the planning process via mechanisms like the Location Constrained Resource Interconnection Facility, with commitments from the resources helping support the transmission development. The ISO expects these resources would then have a pre-existing right to interconnect ahead of other projects in queue.

Based on this, MRP interprets the phrase “solicitation model” to mean either (1) some kind of competitive process in which projects in an overheated area would submit economic offers that would determine which limited set of projects should be allowed to proceed, or (2) an “open season” process to assess interest in expanding the interconnection capability to allow more projects than could be accommodated by the current limited amount of interconnection capacity to proceed.   

MRP does not fully grasp what kind of process the CAISO might have in mind for (1) and requests that the CAISO better explain what kind of process this might be.  Additional clarification on such a process is warranted, especially given the CAISO’s observation that such a process would provide winning resources with the right to interconnect ahead of other projects in the queue. (IPSP at page 17)

With regards to (2), MRP strongly supports the CAISO conducting an “open season” process to gauge interest in expanding interconnection capability.  Natural gas pipeline providers and other electric transmission providers have successfully used such a process to support the development of new capacity. 

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

MRP supports the CAISO implementing new tariff provisions that govern the interconnection of resources under pre-defined emergency conditions.   These tariff provisions should be developed through a stakeholder initiative well in advance of their use so that the reasonableness of these provisions is neither argued nor assessed under stressed conditions.  Finally, no project that was first interconnected under the WDAT process should be allowed to use these new emergency tariff provisions to interconnect under the CAISO tariff. 

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

MRP supports creating incentives that encourage ICs to submit “real”, not speculative projects, and to encourage projects that have little chance to move forward to exit the queue.  MRP does not take a position on whether the CAISO should increase the costs associated with submitting an interconnection request (IR).   However, MRP supports the CAISO (1) increasing the deposits required in lieu of Site Exclusivity (SE) and (2) making changes to put more of the IR and SE deposits at risk (i.e., non-refundable) the longer a project remains in the queue. 

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

MRP supports the CAISO’s proposal to require SE to move into the Phase II study process.  MRP would also support the CAISO making the requirement to demonstrate SE even more stringent. 

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

MRP has no comment on this issue now.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

MRP supports the CAISO’s proposal. 

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

MRP supports the CAISO’s proposal that the responsibility for any cost increases associated with an error or omission discovered after the second interconnection financial security (“IFS”) posting belongs to the party that made the error or omission, and that Maximum Cost Responsibility (MCR) and Minimum Cost Exposure (MCE) cannot increase due to an error or omission discovered after the second IFS posting has been made. 

Some errors or omissions do not require a study to correct.  Those that can be fixed without a study should not wait for the annual reassessment and should be corrected immediately. 

In MRP’s experience, most errors and omissions were made by the CAISO or the PTO. MRP agrees that delays and cost increases can significantly affect a project’s ability to obtain an offtake agreement.  In that light, the CAISO’s proposal for a cost increase threshold of 5% should be increased to 10%, and its proposal for a minimum increase in the in-service date of 12 months should be cut in half, to six months.  The threshold should be higher to help incentivize greater accuracy in the reports during their initial development and to provide greater cost certainty to ICs.

MRP also proposes that, regardless of who made the error, the IC may withdraw after the error has been discovered and receive the appropriate refunds.

Finally, normally the MCR and MCE cannot increase after the second IFS posting. If the IC is at fault for the error or omission, the IC should be allowed to waive the MCR/MCE caps to move forward.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

MRP has no comment on this issue now.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

MRP has no comment on this issue now.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

MRP supports the CAISO’s proposal.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

In MRP’s opinion, projects – even energy-only projects - should not be allowed to remain in the queue forever.  While energy-only projects may not be taking up deliverability, they may be tying up network upgrades that affect later-queued projects.  If a project is not making measurable progress towards its in-service date, or not providing information requested by the CAISO, the CAISO should declare a default and initiate the process to remove the project from the interconnection queue.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

While the CAISO has proposed to not allow ICs to submit MMAs for parked projects, MRP supports allowing ICs to submit MMAs for parked projects.  To the extent an MMA is intended to make the project even more likely to be successful, ICs should be allowed to submit those MMAs even if the project is parked. 

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

With regards to SCE’s proposal to have the IR validation process “deemed complete” prior to holding scoping meetings, MRP reiterates its recommendation from its initial comments: The CAISO should immediately schedule and hold scoping meetings after the close of the IR window.  This will prevent the CAISO and ICs from spending time validating IRs for Points of Interconnection (POIs) that are not viable. 

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

MRP has no comment on this issue now.

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

MRP supports this proposal.  

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

MRP agrees that the CAISO should re-align the commercial viability timeline if PTO-caused delays cause a project’s COD to extend beyond the seven-year maximum time in the queue and to assess the commercial viability of a project only if the project sponsor submits an MMA, not if PTO delays cause a modification. 

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

MRP seeks clarification on what “re-stacking” NUs means.  MRP interprets “re-stacking” to mean re-arranging NU construction priorities and NU in-service dates so the NU in-service dates better align with the proposed in-service dates for queued generator projects.  If that understanding is correct, MRP supports this proposal.  If that understanding is incorrect. MRP requests the CAISO more explicitly define what “re-stacking” means. 

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

MRP has no comment on this issue now.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

MRP believes that CalWEA’s proposal to re-examine the ISP electrical independence test (“EIT”) should be further considered within this initiative.  A significant number of revisions have been made to the tariff since the original EIT language was drafted that now protect earlier-queued projects.  The EIT should be as its name describes – a test to determine if a project filed after a queue cluster clears planning is electrically independent of other projects in the queue.  The current EIT, along with the flow impact test and short circuit test, need to be revised.       

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

MRP supports REV’s proposal to provide FCDS to a project where that project that has achieved commercial operation provided the Interconnection Customer agrees to pay the cost of the upgrade(s) that have not yet been built and agrees to defer repayment of Network Upgrades until all upgrades are built or a reassessment study determines that the Network Upgrade(s) is no longer required.

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

MRP supports the SDGE proposal.  MRP also recommends that this requirement be applied to IRs proposing to interconnect both to customer-owned facilities in general and PTO-owned facilities where the surrounding land is completely controlled by a third-party generator. 

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

MRP supports this proposal and encourages the CAISO to investigate and report back to stakeholders on the feasibility of modifying RIMS to allow ICs to submit all materials via RIMS. 

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

With regards to CalWEA’s second proposal (not allowing the Participating TO to assign all the costs of upgrading a substitution to bring it into compliance with design standards to the IC), MRP strongly supports the proposal that the IC should only be assigned the upgrade costs associated with its interconnection facilities.  While the CAISO’s position is that this is a matter between the IC and the PTO, the CAISO also supports ongoing conversations on this matter.   If this issue is not included in the Phase 2 scope of this initiative, MRP is unclear as to what will catalyze, and provide the fairness guidance for, those needed ongoing conversations. 

MRP also proposes that projects studied under the CAISO or WDAT Independent Study Process be allowed to enter the TPD Allocation Process immediately following receipt of the System Impact Study and Facilities Study.  Projects that file through ISP are essentially “ready” projects that are highly viable and can achieve commercial operation quickly.  Tying the deliverability study for these projects to the deliverability analysis conducted for the subsequent queue cluster unnecessarily delays these projects obtaining deliverability.  These projects would be studied through the Energy-Only Deliverability Study but would be eligible for Allocation Groups 1-7. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

PG&E is generally supportive of the enhancements which have been identified for near-term and long-term discussion. PG&E has some concern that the processes resulting from some of the enhancements may cause issues in the timelines and workloads of PG&E and CAISO staff working on interconnection projects.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

PG&E supports the inclusion of the downsizing proposal as a near-term issue and agrees that the structure of the current process can cause delays for the development of generation projects and/or generation related network upgrades. That said, PG&E does have concern that the MMA-like process would add to the significant number of Material Modification Assessments that PG&E and the CAISO are already receiving. With the number of requests in mind, PG&E suggests that the analysis for the downsizing timeline include some level of variability to allow for the seasonal variability of workload associated with the generation interconnection procedures. As the proposal develops, PG&E asks that an appropriate document capture the changes and reasoning for changes to upgrades potentially outside of the reassessment process.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

PG&E agrees that simplification is needed, and that this enhancement should be considered during the long-term phase of the IPE. Additionally, PG&E has observed scenarios where inactive earlier queued projects are responsible for upgrades that later queued projects require to achieve full capacity deliverability status (FCDS). This results in scenarios where those later queued projects must wait for the progress of the inactive earlier queued project to achieve FCDS. Along with this enhancement, PG&E recommends for CAISO to develop a mechanism for allowing the later queued projects to assume some cost responsibility for the earlier queued upgrades to enable their advancement.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

PG&E is supportive of the inclusion of transmission capacity development as it aligns with state procurement goals. PG&E agrees that the enhancement should be included in the long-term phase of the IPE. Since policy projects are often large in scope and difficult to implement, PG&E requests that the CAISO require that solutions developed via the TPP require some work with the relevant load serving entities to identify the best and most feasible solutions. Such joint work will allow CAISO and PTOs to identify feasible, timely and cost-effective solutions that will enable procurement goals. At times, this upfront work will result in smaller capacity projects instead which would support achieving the procurement mandates and goals.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

PG&E is generally supportive of the CAISO’s objective to remove transmission constraints in overheated areas of the grid and agrees that the enhancement should be addressed in the long-term phase of the IPE. PG&E is interested in the perspective of the development community on the two solicitation models to identify projects which should be carried forward into the interconnection process and to identify interest in the development of transmission capacity where commercial interests would fund the transmission development in exchange for rights to interconnect ahead of projects in the queue.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

PG&E has concern with the development of a separate process for urgent reliability-driven projects since the same resources that would support these projects support other work needed to interconnect projects and complete their upgrades. PG&E agrees that this enhancement should be addressed in the long-term phase of the IPE. PG&E has observed that accelerated projects are often incapable of achieving the dictated schedule and that the acceleration can result in time-consuming mistakes in the interconnection process. Lastly, the creation of emergency projects can delay work that would allow for the timely completion of work needed by other soon to interconnect generation projects to achieve commercial operation status or FCDS.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

PG&E is supportive of the CAISO’s enhancements to discourage the number of IRs that are being submitted annually and agrees that the enhancement should be addressed in the long-term phase of the IPE. PG&E suggests that in addition to the increase in application costs, there also be a cap on the number of projects a company and its affiliates can submit in total, and also at any given point of interconnection, to discourage the submission of speculative interconnection requests. As part of the stakeholder discussions on this enhancement, PG&E requests that the “Small Generators” be discussed and clearly defined.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

PG&E is strongly supportive of this enhancement and agrees it should be addressed in the near-term phase of the IPE.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

PG&E is strongly supportive of this enhancement and agrees it should be addressed in the near-term phase of the IPE. PG&E is also interested in whether the CAISO or other stakeholders have identified other options to achieve the same intended result.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

PG&E supports the inclusion of this enhancement in the IPE and agrees that it should be addressed in the long-term phase of the IPE. PG&E looks forward to further discussions with the CAISO and other stakeholders on this enhancement and how it would affect the timelines of studies and cost reimbursement.

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

PG&E is supportive of this enhancement’s inclusion in the IPE and agrees that it should be addressed in the long-term phase of the IPE. PG&E is concerned that the proposal does not address the increased costs, project delays, and cost shifts between interconnection customers and the PTO when an error or omission is triggered by a delayed or cancelled TPP project or a new deliverability upgrade identified in subsequent annual reassessments. This proposal also does not address delays from the interconnection customers side which suspend or park their project which can affect study results based on other active projects who are moving forward without delays. PG&E believes that the requirement should shift from 2nd posting to 3rd posting which triggers construction activities.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

PG&E supports the CAISO’s clarification on the policy that a RAS is an RNU and that this issue be covered during the near-term phase of the IPE.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

PG&E supports the CAISO’s proposal to move forward with the development of tariff language to allow the CAISO to accept interconnection request transfers from PTO WDAT queues to the CAISO queue. PG&E supports that this enhancement be addressed during the near-term phase of the IPE.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

PG&E is supportive of this enhancement’s inclusion in the IPE and agrees that it should be addressed in the near-term phase of the IPE. PG&E is supportive of the CAISO’s proposal, and would add that the interconnection customer should be limited to 1 or 2 alternative POI discussions during the scoping meeting and should follow the requirements the CAISO has identified for location. PG&E requests that the proposal also include language to make it clear that PTO and CAISO staff are not allowed or able to provide technical advice to the interconnection customer and that the scoping meeting is not intended to identify points of interconnection for theoretical generation projects.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

PG&E is supportive of this enhancement’s inclusion in the IPE and agrees that it should be addressed in the long-term phase of the IPE. In scenarios where a customer accepts their study, but ceases advancement and communication for over 1 year, the project should be terminated. The continued participation of these inactive projects has a negative effect on the advancement of other generation projects.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

PG&E is supportive of this enhancement’s inclusion in the IPE and agrees that it should be addressed in the near-term phase of the IPE. PG&E agrees that parked projects should not be allowed to submit MMA’s while the project is parked.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

PG&E is supportive of this enhancement’s inclusion in the IPE. PG&E agrees that ensuring that Phase 2 studies begin without delay is an integral requirement for the continued interconnection of generation projects.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

PG&E is supportive of this enhancement’s inclusion in the IPE. PG&E agrees that the PTO should not be responsible for funding IRNU’s when interconnection customers agree to share these facilities across clusters.

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

PG&E is supportive of this enhancement’s inclusion in the near-term phase of the IPE. PG&E requests that the criteria for what constitutes a PTO delay versus what constitutes an interconnection customer delay should be clearly discussed and agreed to by stakeholders.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

REV Renewables (REV) generally supports CAISO’s grouping of Phase I and II issues, and on not advancing all of the issues initially proposed. REV appreciates CAISO’s efforts to streamline and refine the Interconnection Process, but cautions against retroactive changes to existing queue clusters and on enabling queue jumping of projects.

REV opposes two items in particular. REV opposes the increase in fees based on the number of requests as discriminatory to large developers, it should instead be increased across the board or based on other transparently developed criteria such as technical documents, site control, and increasing deposits at risk. REV also does not support CAISO’s proposal to revise site exclusivity rules for Cluster 14 as that would be a retroactive change to the rules, this proposal should instead be considered in Phase II for future clusters. Further comments on specific issues are below.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

REV supports this proposal to simplify downsizing requirements for projects with no network upgrades.

For projects with one or more network upgrades, REV requests clarification on when and how the downsizing request will be approved/denied and what would be the impact on the reassessment studies. CAISO’s proposal seems to be that once the downsizing request is put in then the project’s capacity will be assumed downsized for the reassessment studies. CAISO will then look at the reassessment study results to determine if the downsize request is approved through a MMA type process. However, it is not clear whether the downsizing request can be denied and what would be the impact on the reassessment studies.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

REV does not support the current proposal and suggests it needs more discussion among stakeholders. The current proposal could result in a timing misalignment with TPD Allocation which takes place after the phase 2 study process. It will generally work better for the projects to have the phase 2 study information available prior to entering in to the solicitation/PPA negotiation process. Projects should be allowed to receive TPD deliverability on a merchant basis, which the current proposal denies. One alternative could be to allow projects without PPAs to be in Allocation Group 1 or 2 to receive TPD deliverability for up to two years, and if the project does not have a PPA at the end of that deadline then it could be moved to Allocation Group 3. In line with our comment above, REV also encourages CAISO to expand the timeline for the projects that received an allocation in the new Group 2 and are required to submit an executed PPA by November 30 to retain deliverability.

REV also suggests that projects interconnecting in areas with no ADNUs should have an option to proceed without a PPA in the TPD allocation process. Similar to the goal of reducing burden for TPD retention, this should further help with ISO’s goal of reducing administrative burden.

REV requests clarification on what qualifies as a PPA. Is there a specific contract duration required? For example, would a short-term Resource Adequacy contract (e.g. two years) qualify as a PPA to receive deliverability?

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

In general, REV suggests that CAISO work with CPUC and other state agencies to determine whether refinements to the resource procurement process are needed to better align with the CAISO TPP process. CAISO’s interconnection queue and transmission capacity development should be technology neutral and CAISO should not withhold any capacity for any projects studied in any process.  

CAISO requested feedback on two concepts:

• 1. The concept of not only developing transmission capacity for planning purposes associated with achieving specific resource development;
  •  REV suggests that for out-of-state wind that are in CPUC renewable generation portfolios, the projects should be evaluated at their points of interconnection in BAs outside CAISO rather than at the CAISO boundary injection points. This evaluation would allow CAISO to better determine transmission needs to deliver the out-of-state renewable generation from source to load.
• 2. As a further step, withholding that capacity specifically for the policy-driven processes for which it was planned rather than relying on it for any and all interconnection requests received through the request windows.
  • REV suggests that this concept needs further discussion and examples to clarify CAISO’s position.  It is unclear what CAISO means by withholding capacity specifically for policy-driven processes. For example, does this mean capacity would be reserved for specific projects? Or specific resource types and/or locations? In general, REV suggests that the interconnection process should be unbiased in its assessment of project technologies or locations.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

CAISO seeks further feedback on:

• (1) a solicitation model to seek clarity in an overheated area as to which projects should be carried forward into the interconnection process which could be focused solely on transmission capacity or could be conducted in conjunction with load serving entity procurement processes,
  • REV generally supports the concept of a solicitation model and requests more details and examples of how this concept would work. REV does not support CAISO choosing specific projects to move forward even if in conjunction with an LSE. CAISO’s interconnection queue should remain project neutral. However, an overheated area could, for example, result in higher commercial viability criteria, fees, or deposits in order to move forward. Any such criteria should be developed in a transparent manner.
• (2) a solicitation model to test and confirm interest in an area in which transmission capacity may be expanded in the planning process via mechanisms like the Location Constrained Resource Interconnection Facility, with commitments from the resources helping support the transmission development. The ISO expects these resources would then have a pre-existing right to interconnect ahead of other projects in queue.
  • REV generally supports the concept of a solicitation model and requests more details and examples of how this concept would work. This process and criteria would need to be transparently developed, with clear fees, deposits, and commitment milestones. If a project gets a pre-existing right to interconnect, CAISO should ensure that this does not result in a back door way to jump the interconnection queue.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

REV supports CAISO’s approach of limiting its proposal for accelerating “Ready Projects” due to ambiguity and the potential issue of jumping queue. Any framework for urgent reliability-driven interconnection service should be aligned with the principle of avoiding queue jumping. REV requests CAISO to provide rationale for proposing to provide a maximum of three years of interim deliverability. REV also requests clarification on issues such as how this framework will work for an area where there are no local or interconnection network upgrades needed, but ADNUs have limited the deliverability of projects in the regular Queue process.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

While REV supports higher fees, deposits, and criteria in general to limit IRs and increase commercial viability of projects, REV does not support CAISO’s current tiered proposal. CAISO’s proposal is discriminatory to large developers that are penalized with $1 million per request for more than 5 projects, though that amount is not tied to any increase in costs to conduct the study nor to project viability criteria. Large developers could genuinely have several viable projects, and given the resource needs in the state to meet its policy goals, projects should not be so severely discouraged.  The increase in fees should not be based on the number of requests, it should instead be based on other transparently developed criteria such as technical documents, site control, and increasing deposits at risk. CAISO has proposed an increase in study deposit fee from $150k to $250k. REV supports the increase and could support further increase beyond $250k, but only on a per project basis. The higher deposit should be implemented regardless of how many projects a developer is filing. A sliding scale approach as currently proposed should not be adopted.

REV supports CAISO’s proposal to increase the site exclusivity. However, REV suggests moving the determination of losing 50% of the in-lieu site exclusivity deposit after IR is deemed complete to after the completion of PTO-ISO scoping meeting. REV suggests that this minor change will align with the IC having better information on whether to continue in the interconnection process.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

REV does not support CAISO’s proposal to revise site exclusivity rules for Cluster 14, and in general opposes retroactive changes to rules. The changing of site exclusivity rules in the middle of cluster process will pose significant commercial risk for the interconnection customers, particularly given the timing that may be needed to obtain site exclusivity which may extend beyond the deadline to advance into Phase II.   

REV supports revising site exclusivity rules for Cluster 15 and beyond as those rules would then be clear and transparent when entering into the queue. Accordingly, REV suggests this issue be moved to Phase II longer term modifications.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

CAISO should reconsider the cost allocation rules in broad context of the FERC Advanced Notice of Proposed Rulemaking: Building for the Future through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection - Docket No. RM21-17-000  (“ANOPR”). Given the overwhelming comments received on the ANOPR, reforms to the transmission planning, cost allocation, and interconnection processes are imminent in order to support transformation of the electricity sector. The definition of “local” vs “regional” was one of the most discussed topics in this proceeding. The California Public Utilities Commission’s comments on the ANOPR, for example, provide several references to and examples of the CAISO processes, questioning whether the definition of “local” should be redefined to include facilities lower than 200 kV. Additionally, whether these lower voltage facilities should be competitively built, which could reduce overall upgrade costs. As CAISO considers revising cost allocation treatment for network upgrades to local systems, CAISO should keep in mind the industry developments that, in near future, could alter the fundamental premise upon which the current cost allocation rules exist.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

REV has no comment at this time.

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

REV agrees with the CAISO proposal.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

REV has no comment at this time.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

REV has no comment at this time.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

REV has no comment at this time.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

REV has no comment at this time.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

REV has no comment at this time.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

 REV supports CAISO’s proposal to include in scope the item from SCE on adding due dates for curing deficiencies.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

CAISO should carefully consider these items of SCE’s /SDGE’s proposal as it directly shifts the costs of the PNUs to the generators and increased the MCE for the project. REV does not support this as any proposed changes to the MCE of the project pose a significant risk, among others, to the commercial viability of the projects.

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

REV has no comment at this time.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

REV has no comment at this time.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

REV supports further consideration of this issue but cautions that it should not enable projects to jump queue based on the requested COD of the projects.

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

REV supports this scoping item.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

REV has no comments at this time.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

REV thanks CAISO for including this item and supports further consideration in Phase I.  

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

REV has no comment at this time.

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

REV supports SDGE’s proposal on this item.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

REV has no further comments at this time.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

RWE appreciates the opportunity to provide feedback on the CAISO’s 2021 Issue Paper and Straw Proposal. RWE is a global leader in renewables technology and operates assets in all major technologies like Standalone Solar/Storage/Wind, Hybrid (Wind – Battery, PV- Battery) and offshore (Floating PV, and Wind). As a renewable developer and operator RWE is directly impacted by any changes to interconnection rules and procedure and has an inherent interest in an improved process.

RWE is a member of several trade organizations and generally also supports comments filed by LSA/SEIA, ACP-CA, and CESA.  In areas where there may be differences, RWE submits its comments.  RWE’s views are developed based on years of experience in the industry, participating in many interconnection process reforms and interconnecting our more than 5GW of renewable energy across the US.

RWE strongly supports these changes as listed in the straw proposal – Downsizing, Data Transparency, FCDS Upgrades Sequencing, and RIMS for all documents.

RWE strongly opposes these changes as listed in the straw proposal – Site Exclusivity for C14, and TDP Group 3 Changes.

RWE in general either supports with modifications or doesn’t oppose other mentioned initiatives in the straw proposal.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

Support

RWE supports the initiative as it tries to simplify the downsizing process and moves it to a more MMA-like request. This will help the IC to request a downsize based on when it's required rather than when the downsizing window opens. It’ll also help the projects without network upgrades be proceed sooner.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

Strongly Oppose

RWE agrees with CAISO that projects without a PPA have a higher risk of not being constructed than those with PPAs.  However, this allocation group is used by RWE and many others as means to obtain PPAs and be competitive. Allowing projects to get TDP allocation only when they’ve PPA or shortlisted for a PPAs is similar to giving LSEs the ability to allocate the deliverability.

During the presentation, CAISO justified this by mentioning that the Group 3 projects are lingering in the queue and wouldn’t be contracted and thus never be operational. RWE uses the allocation from Group 3 to showcase project merits for RFP and PPA negotiations and signing contracts which lead to commissioning the projects.

CAISO could possibly look at other modifications to the TDP allocation process without removing Group 3 which potentially help with the lingering issue seen by CAISO in the cluster.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

Neutral

RWE is a developer of several technologies and could have projects impacted either way with this proposal.  Generally, interconnection processes are to be technology agnostic.  It would be expected that there would be several planning scenarios that would include specific public policy expectations and requirements and thus develop appropriate transmission plans for those future scenarios as not all system improvements should come from the interconnection process. RWE feels this warrants further discussion and coordination with transmission planning.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

Neutral:

RWE apricates the opportunity to provide feedback on this topic but would like to get more information on how the solicitation model would work.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

Support with Modifications:

The proposal should only be applied under emergency type authorization and shouldn’t adversely impact higher queued projects.  RWE would really appreciate it if CAISO could define in detail how a “Ready” project would be identified and what save guards (like interim based or till new resources can replace the capacity) would it implement that these projects don’t adversely impact higher queued projects.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

Supports with Modifications: Higher IR FEEs

RWE supports the proposal of raising the study deposit or other cost as seems appropriate by CAISO but with the following modifications.

CAISO cannot make a determination on if a specific company has the resources to develop the projects submitted.  RWE, as an example, has development teams for all technology types with many members of each and thus has the resources to develop multiple projects at once.  It is absolutely true that not all projects will be successful in a process but that is an inherent piece of the puzzle as it is evaluated.

RWE would recommend that there can be a project cost scale or $/MW study deposit.  Both of these are used successfully in other markets and do not discriminate against a party working on several projects at once.  With that, RWE would like further discussion on this topic and what would potentially be at risk from a study deposit aside from actual study costs, and when those dollars would be at risk.  There are sufficient examples in other areas that could easily be utilized.

Support with modifications: Higher deposit in-lieu of  Site Exclusivity

RWE has been a strong advocate of site exclusivity in interconnection process reform but we also recognize that certain areas of the country may pose different scenarios.  First, there needs to be an alternative when the site is on federal/state/tribal lands as there is a different process compared to private land.  In addition, with the California land market, we would like to have clear definitions of what CAISO would consider site exclusivity.  Finally, there should be a financial alternative.  Today’s $250k with no risk may be too lenient, however, an increased site deposit (possibly $500k) with a certain amount that is “at risk” at the site exclusivity deadline if not demonstrated otherwise would be a potential alternative.  If site control was later received the “at risk” portion would be returned, however, if the project later dropped from the interconnection queue that “at risk” money can be placed toward any additional studies needed for impacted projects

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

Strongly Oppose

RWE strongly opposes imposing this requirement to C14 projects.  CAISO has indicated that Phase I studies will be advisory and not impact the cost cap.  Why should projects in mid-process have a pretty significant requirement placed on them and in addition not even receive information that can be relied on for decisions.  Any change should only be on C15 and later and should take into account RWE's previous comments on site exclusivity.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

Neutral

RWE appreciates the opportunity to provide feedback on this topic, RWE has a neutral stance on this proposal.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

Neutral

RWE appreciates the opportunity to provide feedback on this topic, RWE has a neutral stance on this proposal but would definitely ask CAISO to make sure that the same is reciprocated by the affected system i.e. CAISO projects would receive a similar repayment mechanism from the affected system

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

Support

RWE appreciates the opportunity to provide feedback on this topic, RWE supports the proposal as it is a balanced approach to tough situations. By giving the ICs the option to exist without loss of IFS posting is a balanced approach in instances where a major change to IF cost or construction timeline was discovered. 

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Oppose 

RWE opposes this proposal as a different discussion with CAISO hasn’t provided any clarity on this proposal

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Support 

RWE believes that the best way to prevent the issue is to provide transparent data which shows all substations/lines and their jurisdictions but in the meantime, any proposal to streamline the process is highly appreciated.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Support with clarifications

RWE supports the proposal but would again like to mention that these issues could be avoided by providing transparent data to IR customers which can, in turn, help their selecting of POIs. 

RWE would like CAISO to clarify what does “Same Transmission Study Area” means in the proposal.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

1. Should EO Projects be allowed to stay in the queue forever? NO
2. Should there be a time limit for the project to reply to information queries before GIA default is declared? Yes, a response time limit to response would be acceptable (30 days).
3. If a project needs an MMA (e.g., has missed COD or other major milestone but will not initiate the process), how long should CAISO wait before declaring a GIA default? A default notice should be issued and then some grace period is given for the IC to respond, the response time needs to be reasonable based on the required information.  Certain instances may require 30+ days but the IC should be in open communication with CAISO
4. Should CAISO take action if the project is not moving to permit, procurement, and construction of Interconnection Facilities or the generating facility but does not miss any GIA milestones? No, CAISO is not the developer. Each company has its own process and timelines.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

Neutral

RWE appreciates the opportunity to provide feedback on this topic, RWE has a neutral stance on this proposal

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Support with modifications

The 70 CDs deadline will leave no time for projects with late results meeting to resubmit appendix B and cure deficiencies. RWE would like CAISO to consider when the results meeting was scheduled and then come up with deadlines for IC to cure deficiencies.  Depending on the nature of the deficiencies different time to respond is required but there should be a minimum time guaranteed (at least 15 CDs) and response time if CAISO asks additional questions.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

Oppose

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

Support

RWE strongly supports this initiative as outlined by Gridwell. Transmission Grid data and other information related to deliverability will make a selection of interconnection POIs much smoother, potentially reduce some of the back-and-forth, and facilitate more successful IRs.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

Support

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

Support

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

Support

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

Neutral

RWE appreciates the opportunity to provide feedback on this topic, RWE has a neutral stance on this proposal.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

Support

RWE believes that once the interconnection customer executes the GIA and gives the NTP the PTO should begin work on all upgrades, especially on significant upgrades. There is an inherent risk in the event a project drops but generation projects CODs are being impacted by upgrade construction schedules currently. 

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

Oppose

RWE appreciates the opportunity to provide feedback on this topic, RWE opposes this proposal.

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

Support

RWE supports the idea of moving all applications that require email-based submission to a more central system-based submission like RIMS or equivalent as it provides more clarity on tracking changes, approvals, or deficiencies.  This also help ICs to maintain continuity when resources are assigned to project change.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

RWE appreciates that CAISO is moving forward with the reform of the interconnection process.  There are still many areas for discussion to reach a consensus for all the stakeholders.  RWE suggests that CAISO not rush too quickly in the stakeholder process as the greater consensus that can be found here will we will all find benefit with a smoother approval process later.

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

The comments provided below specifically address items 9, 10, and 15.  As to these topics, the Six Cities

• Neither support nor oppose at this time the proposal related to low voltage network upgrade cost allocation, but seek additional information.  (See the response to question 9.) 
• Question the basis for providing reimbursement to resources on neighboring systems associated with “affected system” mitigation on the CAISO network.  (See the response to question 10.) 
• Articulate support and provide comments on the CAISO’s proposal to adopt measures to establish remedies for inactive projects.  (See the response to question 15.) 

As discussed further below, the Six Cities either support, do not oppose, or take no position on other elements of the CAISO’s Straw Proposal.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

The Six Cities do not oppose the CAISO’s proposals regarding the downsizing process. 

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

The Six Cities do not oppose the CAISO’s proposals regarding the Transmission Plan Deliverability Allocation process. 

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

The Six Cities understand the CAISO’s desire to better synchronize the transmission and interconnection study processes with procurement determinations and agree that this topic merits additional consideration in Phase 2.  It would be constructive to explore why discrepancies arise, and whether this is driven by a need for improved coordination with local regulatory authorities or for other reasons. 

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

The Six Cities do not have extensive comments on this topic at this time.  While not opposed conceptually to either of the CAISO’s suggested approaches – i.e., using a solicitation model to identify projects within particular areas that should be carried forward into the interconnection process or using a solicitation model to test and confirm interest in within particular areas – more details are needed in order to fully evaluate how these options might work.  The Six Cities expect to assess and provide comments on specific proposals if developed by the CAISO. 

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

The Six Cities support development by the CAISO of tariff provisions addressing interconnections associated with emergency generation procurement.  In terms of the earlier proposal to advance “ready” projects, which the CAISO has stated in the Issue Paper/Straw Proposal that it does not intend to pursue, the Six Cities concur in the CAISO’s determination that permitting such projects to advance ahead of earlier queued interconnection requests would be challenging and contentious, and CAISO and stakeholder resources may be better allocated to other elements of the Issue Paper/Straw Proposal. 

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

The Six Cities do not oppose the CAISO’s proposals regarding fees and deposits. 

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

The Six Cities do not oppose the CAISO’s proposal to require documentation of site exclusivity from interconnection customers as a prerequisite to move into Phase II studies. 

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

As noted in the Issue Paper/Straw Proposal, the Six Cities had previously identified concerns regarding the CAISO’s proposal to devise an alternative cost allocation scheme for low voltage network upgrades and did not support including this issue within the scope of this initiative.  The Six Cities remain convinced that the current transmission access charge (“TAC”) structure and delineation between high and low voltage facilities is not in need of revision. 

In the event that the CAISO proceeds with consideration of its proposal to cap the cost of low voltage network upgrades at 15% of each Participating TO’s transmission revenue requirement (“TRR”), or, more specifically, the net investment included in the TRR that is associated with low voltage network upgrades, Six Cities’ concerns with the transfer of costs from the low voltage TRR to the high voltage TRR appear to be addressed through the proposal to require interconnection customers to up-front fund, without reimbursement, costs for low voltage network upgrades once the threshold is reached.  It would be useful for the CAISO to provide examples of how the proposed threshold would apply to different Participating TOs’ low voltage TRRs, and for the next version of the proposal in this initiative to include amounts of aggregate net investment for all low voltage network upgrades in each Participating TO’s TRR currently.  It is also unclear how the cap would apply for Participating TOs that do not have low voltage TRRs at this time.

In light of the foregoing questions, the Six Cities neither support nor oppose the CAISO’s proposal, but look forward to the CAISO providing more details in a subsequent paper. 

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

The Six Cities take no position on the CAISO’s proposal regarding the applicable study case to use in assessing affected system impacts to the CAISO system.

The Six Cities are not convinced that the CAISO’s proposal to provide reimbursement to interconnection customers in neighboring areas for network upgrade costs on the CAISO system to mitigate affected system impacts is reasonable or appropriate.  Is the CAISO’s position that FERC policy has specifically dictated that network upgrade costs due to affected system impacts must be reimbursed?  Or only that FERC’s general policy provides for network upgrade cost reimbursement, and since network upgrades may be identified at a result of affected system studies, affected system upgrades should be subsumed within that policy? 

In the Six Cities’ view, the concept of providing reimbursement has less to do with the jurisdictional status of neighboring entities and whether or not their policies provide for reimbursement of network upgrades at all, and has more to do with fairness and reciprocity.  In the absence of clear direction from FERC that reimbursement is required for network upgrades to mitigate affected system impacts, the Six Cities do not support a change in CAISO policy at this time. 

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

The Six Cities do not oppose the CAISO’s proposals for addressing errors and omissions. 

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

The Six Cities do not oppose the CAISO’s proposal to classify a remedial action scheme as a reliability network upgrade. 

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

The Six Cities take no position on the proposal to develop tariff language to address transfer requests between queues. 

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

The Six Cities take no position on the timing for changing sites and points of interconnection. 

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

The Six Cities agree with the CAISO’s concerns that interconnection customers that are occupying space in the interconnection queue without taking meaningful steps to advance their projects should not be entitled to remain in the queue indefinitely.  There is no valid policy reason to permit non-active projects that lack viability and are unlikely to advance to commercial operation to occupy a queue position on a long-term basis, to the detriment of both projects taking good faith steps to advance their development and load serving entities looking to procure resources to meet state and local policy goals.  The Six Cities therefore support the CAISO’s proposal to adopt stricter requirements for retention of queue positions by projects that do not, according to the examples cited by the CAISO at pages 43-44 of the Issue Paper/Straw Proposal, respond to information requests, initiate necessary material modification assessments, and/or otherwise move expeditiously to permitting, procurement, and construction.  The Six Cities agree that it is necessary to provide improved clarity in the tariff and in interconnection-related agreements regarding expectations of project advancement, and to provide the CAISO with a remedy – namely, termination of the interconnection agreement and removal from the queue – when projects do not sufficiently advance and/or appear to be inactive as a result of failures to respond to information requests or submit material modification requests when needed. 

The Six Cities also question if seven years remains the appropriate duration for interconnection customers to remain in the queue.  Does the CAISO have information about the average length of time in queue for projects that have entered commercial operation?  Is there data showing that a different period might be appropriate?  If so, revisiting the seven year period could be warranted as a way to remove inactive projects. 

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

The Six Cities do not oppose the CAISO’s proposal to prohibit submittal of MMAs by parked projects, which appears to be a way for the CAISO to manage resources efficiently and avoid studying non-ripe projects. 

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

The Six Cities take no position on this topic at this time. 

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

 The Six Cities take no position on this topic at this time. 

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

 The Six Cities take no position on this topic at this time. 

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

 The Six Cities take no position on this topic at this time. 

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

The Six Cities take no position on this topic at this time and look forward to evaluating the positions of other stakeholders and the CAISO regarding network upgrade restacking.   

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

 The Six Cities take no position on this topic at this time. 

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

 The Six Cities take no position on this topic at this time. 

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

 The Six Cities take no position on this topic at this time. 

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

 SDG&E’s proposal appears to be reasonable, and the Six Cities do not oppose it. 

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

 The Six Cities take no position on this topic at this time. 

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

 The Six Cities have no additional comments at this time. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

SCE commends the CAISO for exploring through this 2021 IPE stakeholder initiative potential interconnection process enhancements to move interconnection resources through the interconnection queue more efficiently and to manage the overheated queue. SCE is grateful for the opportunity to provide its comments on the identified topics. 

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

SCE supports the CAISO’s proposal to simplify the downsizing process. The CAISO proposes to remove the downsizing application window, the unique downsizing deposit, and the downsizing agreement (Appendix HH), among other simplifications. Instead, the downsizing process will be modified to allow downsizing requests to be submitted at any time and be processed through an MMA-like process.  Once the downsizing request is received by the CAISO the project would be deemed downsized to the requested capacity. 

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

SCE has no comment.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

As noted in SCE’s comments on the 2021 IPE Preliminary Issue Paper, SCE supports the development of policy-driven transmission capacity based on needs and direction provided in the CPUC’s IRP process.? SCE also notes that the IRP process already includes a detailed “resource-to-busbar mapping” that ensures the portfolios used in the Transmission Planning Process (TPP) considers the level of commercial interest in particular geographic areas¹.? This information (along with additional scenarios described in SCE’s comments on the 2021 IPE Preliminary Issue Paper) can be used to identify a least-regrets portfolio of projects that should be approved as policy-driven upgrades.? However, SCE does not support “withholding” capacity for any specific resources as that would violate open access principles. 

**[1] CPUC D.21-02-008 at OP3, which states “[i]n mapping electric resources to busbars to identify geographic locations to support the [CAISO’s TPP], Commission staff shall prioritize commercial interest, followed by locations in disadvantaged communities and local air quality non-attainment areas, especially for locating battery storage.  The mapping process shall also be informed by the CAISO’s most recent methodology associated with hybrid or co-located storage and generation resources.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

SCE has no comment. 

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

SCE’s position on “first ready” is that it’s a dramatic departure from decades of use of the successful “first come, first served” approach.  That’s not to say that “first come, first served” is flawless, but it is an undeniably fair process and synchs well with the Open Access concept at FERC.  SCE is certainly interested to explore and examine other options to “first come, first served”, but in order to support such a radical departure from this “tried and true” construct will take time and much discussion with all parties to the interconnection process.  SCE would be willing to participate in such discussions, perhaps held offline from any other IPE discussions in order to not slow down needed IPE reform efforts.  But such discussions will be needed if the “first ready” concept will ever get off the ground.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

SCE supports increasing application fees or deposits.  SCE supports the CAISO’s proposal to increase the study deposit from $150K to $250K per interconnection request. SCE further supports the CAISO’s remaining proposed provisions on this topic: (1) to further increase the study deposit for a parent company/entity that submits more than two interconnection requests in a cluster window; and (2) for the first two projects submitted by a parent company/entity the study deposit would be $250K per request, for projects 3-5 the study deposit would be $500K per request, and for any more than 5 projects, the study deposit would be $1M per request. The same percentages will be at risk as currently defined in the tariff.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

SCE supports incorporating stronger screening criteria, which includes Site Exclusivity, before projects can move into the Phase II Interconnection Study process thereby discouraging the number of speculative projects that enter the interconnection queue. SCE agrees with CAISOs proposal to require interconnection customers to demonstrate Site Exclusivity no later than seventy (70) Calendar Days from the date of the original Phase I Interconnection Study report before their projects are permitted to move into the Phase II Interconnection Study process. SCE supports applying this requirement to Cluster 14 and future clusters. 

Pursuant to GIDAP section 3.5.1 or GIDAP BPM section 5.3 requires an interconnection customer to demonstrate Site Exclusivity, at a minimum through the Generating Facility’s proposed Commercial Operation Date (COD). It is SCE’s position that an interconnection customer adjusting its Generating Facility’s proposed COD post Phase II or post GIA or UFA (extending the COD during the Phase II Results Meeting, requesting a COD MMA, parking, or suspending a project) must continue to demonstrate Site Exclusivity up to the revised COD, in accordance with the modification process (GIDAP section 6.7.2) before a revised COD is approved by the CAISO in coordination with the PTO.  In addition, a revised COD must comply with GIDAP section 13.2.1 and GIDAP BPM section 10.3, project milestone dates must be feasible.  

A PTO Delay or construction sequencing will require an interconnection customer to demonstrate Site Exclusivity up to the revised COD.  

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

SCE is pleased the CAISO “agrees with SCE that the current cost allocation is not flawed and it would be inappropriate to shift costs on network upgrades to systems below 200 kV to the High Voltage TAC.”  SCE does not oppose the CAISO’s proposal to cap the percentage of interconnection-related network upgrade costs within each PTO’s local transmission revenue requirement.  Interconnection customers would finance any network upgrade costs that exceed the PTO’s aggregate funding cap without cash reimbursement or move their generator interconnection to the high voltage system.  The net result would be generator interconnection network upgrade costs shall not exceed 15% of a PTO’s total all low-voltage upgrades.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

SCE supports the CAISO’s proposal that the base case assumptions for the study be based on previously queued projects as of the affected system study agreement execution date.  

SCE reiterates its opposition to the idea that California transmission ratepayers would provide network upgrades credits for projects interconnecting outside of the CAISO balancing authority that trigger upgrades to the CAISO system.  SCE agrees with the CAISO’s proposal regarding Affected Systems in its Contract Management “COMA” Enhancements Initiative Issue Paper / Straw Proposal issued August 10, 2021, that “Participating TOs will not reimburse external interconnection customers for network upgrades.  This practice is consistent with neighboring utilities’ practices for CAISO interconnection customers.”   

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

SCE opposes CAISO’s current position of placing cost responsibility on PTOs in those rare instances (low probability) were a substantial error or omission for Network Upgrades above the Interconnection Customer’s maximum cost responsibility (MCR) is discovered after the Interconnection Customer has made its initial and second IFS posting. In addition, requiring PTO’s to be the backstop financier akin to GIDAP section 14.2.2 contradicts, in our opinion, CAISOs prior position regarding the errors and omissions provision filed, approved, and accepted by the Commission under Docket No. ER12-502 and ER16-693: 1) an error or omission can affect a project’s MCR and financial security requirements; and 2) revisions can be issued after an Interconnection Customer makes its initial and second IFS posting. In addition, GIDAP section 6.8.3 does not limit when the CAISO in coordination with the PTO can issue a revised study report to the Interconnection Customer.  

SCE recognizes the importance of the interconnection study process providing Interconnection Customer’s with some level of cost certainty; however, the CAISO stated in ER16-693 that the definition of substantial error or omission is designed such that “study revisions for substantial errors or omissions are rare.” Because an error or omission satisfies this narrow definition, GIDAP requires the CAISO to issue a revised study report even if the revisions impact the Interconnection Customer’s MCR. As a result, it is SCE’s position, supported in our opinion by CAISOs filings, that an Interconnection Customer bears the cost responsibility of incremental Network Upgrade costs that are the result of a rare error or omission discovered after the second IFS posting but before the execution of an interconnection agreement.  

SCE acknowledges that under these rare  instances that can lead to cost and IFS posting increases and potentially schedule delays, SCE can support giving an Interconnection Customer the option to accept these changes or withdraw its project from the queue and receive a full refund of its current Network Upgrade IFS posting despite the impact this may have to GIDAP Section 7.6 – Application of Non-Refundable Amounts for Still-Needed Network Upgrades and a refund of any unused study deposit. On the condition that the Interconnection Customer bears the cost responsibility for an error or omission, we find the release of the Interconnection Customer’s current IFS posting for Network Upgrades and any unused study deposit just and reasonable.  

SCE is not aware of any provision in the applicable CAISO tariffs and BPMs that requires a PTO to finance an increase to an Interconnection Customer’s Network Upgrade costs above the MCR because of a substantial error or omission and opposes this position in this stakeholder process. In addition, SCE reserves the right to intervene in the pending filing with FERC. 

SCE reiterates its suggestion from its comments on the preliminary issue paper (and during the Stakeholder webinar), that Appendix DD Section 6.8 is not well structured currently and could benefit from added clarity of using a decision-tree construct.  To reiterate what SCE said during those efforts (that appears to have been discarded in the recent issue paper), would be something akin to: 

  Is an error/omission that has been discovered considered “substantial”? (What happens if yes, what happens if no, etc.) 

•What is the timing of the error/omission? Before or after IFS posted? (What happens if before, what happens if after, etc.) 

•Does the error/omission require a change to CCR, MCR, and/or MCE and IFS posting? 

•Does the error/omission require a revised study be issued? 

•Does the error/omission reset the clock for the next IFS posting? 

•Which party is ultimately responsible for the cost of upgrades as a result of the error/omission? 

 One other point in relation to errors & omissions.  SCE notes in the Issue Paper that the proposed threshold for an increase in cost due to errors & omission is now 5%, and/or a 12-month impact to overall project schedule.  SCE agrees on the duration aspect (12-months), but SCE’s position is that a 5% increase in overall cost of facilities/upgrades is too low a threshold.  While SCE recognizes cost increases after IFS posting are disruptive and a source of risk to ICs, 5% is quite a deminimus amount (equating to $50,000 on a base cost of $1 million) which seems could be quite easily triggered by small changes in cost estimates.  SCE believes that the 25% amount proposed in the Supercluster proposal reflects the magnitude of likely errors/omissions that could prove disruptive to an IC yet remain in the “rare/large” side of the equation to qualify for full refund of IFS posting amounts.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

SCE supports the CAISO’s proposal to clarify its existing policy that a RAS is always considered an RNU, regardless of the study that identified the need for the RNU.  Because RASs are RNUs, they are included, and will continue to be included, in the RNU reimbursement calculation as described in GIDAP section 14.3.2. 

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

SCE supports the CAISO’s proposal to move forward with developing tariff language for allowing the CAISO to accept interconnection request (IR) transfers from the PTO’s WDAT queue to the ISO queue. The CAISO will work with the PTOs to develop any criteria necessary to ensure that the transfer occurs, and the validation of the IR and technical package are deemed valid and complete within an appropriate window of time, but before the start of the Interconnection Studies (System Impact Study or Phase I Cluster Study). 

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

SCE supports the CAISO’s proposal that the timing of the process for changing POIs whether in accordance with GIDAP section 6.7.2.1 or otherwise, remain consistent with current CAISO practice that interconnection customer(s) must confirm its POI within five business days of the project’s scoping meeting pursuant to the CAISO’s GIDAP BPM v.27 section 6.2.2 and any change in POI will be limited to within the same transmission study area (e.g., within the same county, one transmission line, or one switchyard from the original) as the POI originally requested in its Interconnection Request.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

SCE does not support allowing any project (Energy-only or otherwise) to remain in the interconnection process indefinitely.  Such “squatting” projects consume resources that ought to be used for viable projects that are moving forward towards commercialization.   

SCE supports the CAISO developing criteria in Phase 2 of the IPE that grants the CAISO and PTO(s) the ability to remove project(s) allocated partial or full deliverability or are energy-only from the queue that fail to advance towards commercial operation in less than seven years by terminating its GIA or UFA, unless interconnection customer(s) can demonstrate that the delay is due to an event not reasonably within its control.  

Post GIA or UFA, SCE supports limiting the number of modification requests [with the number of MMA requests allowed to be discussed with stakeholders] in order to extend a project’s COD.  It appears to SCE that in many cases interconnection customers are using the MMA process to dramatically lengthen the execution/construction phase of the interconnection process (post GIA).  There may be legitimate reasons for doing so, but it appears that at times the ICs are using MMAs as a defacto suspension, without “using up” its suspension rights.  Certainly, delays can occur for many reasons, and PTOs can also encounter delays in the execution/construction phase.  The problem with execution/construction phase delays is the impact on scarce resources, such as those resources required to engineer, design, and construct the required interconnection facilities and network upgrades on behalf of ICs.  With so many projects seeking to come online to meet commercial goals, these resources are scarce and precious.  CAISO and PTOs need to be able to use these scarce resources for “real and ready” projects, allowing those to move forward to in-service and commercial operations, while avoiding expending these resources on projects that are not moving forward (for various reasons) and appear to be “queue squatting”.  

  Unless an interconnection customer can demonstrate that an extension is required to secure tax credits, or a PPA, (if GIDAP section 8.9.2.2 does not apply) or to secure the necessary permits to advance a project towards commercial operation, it should not be allowed to make an unlimited number of MMA requests. If the IC cannot demonstrate to CAISO and PTO’s satisfaction, that the delays are reasonable, then interconnection customer(s) should be required to suspend its project by submitting a modification request pursuant to Article 5.16 – Suspension of the GIA or UFA. In accordance with the Generator Management BPM section 10 - Suspension, interconnection customer(s) must demonstrate to the CAISO and PTO(s) how they plan to advance project(s) towards commercial operation prior to coming out of suspension. If interconnection customers fail to do so, the CAISO and SCE should have the ability to terminate interconnection customers GIAs or UFAs that are not advancing towards commercial operation. 

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

SCE supports the CAISO’s proposed position not to allow interconnection customer(s) to submit an MMA while project(s) are parked for up to two years.  

However, if permitted then: 1) the type of MMA requested must be limited and must satisfy a set of criteria to be developed and supported by the CAISO and PTO(s) that will advance a project towards commercial operation once a project is unparked, 2) interconnection customer(s) will be required to make the second IFS posting for PTO IFs and NUs if the modification request is made in Year 1 or Year 2.  The CAISO and PTO(s) will evaluate interconnection customer(s) MMA request(s) after the second IFS posting has been received and approved by the PTO(s). If interconnection customer(s) subsequently withdraw its project(s) from the interconnection queue, GIDAP section 11.4.2 will apply, as applicable. Modification requests submitted post Phase II shall comply with GIDAP Section 6.7.2.3. In accordance with GIDAP section 8.9.4, PTO(s) will not tender a GIA or UFA while project(s) are parked.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

SCE is appreciative of the CAISO’s proposal to include this SCE-recommended topic in the 2021 IPE. SCE supports the CAISO’s proposal to add a deadline for the validation of Appendix Bs, where all Appendix Bs and any associated technical data must be submitted within ten (10) Business Days following the Phase I Interconnection Study Results Meeting and be deemed valid by the PTO and CAISO no later than seventy (70) Calendar Days after the date of the original Phase I Interconnection Study Report. Projects with invalid Appendix Bs by the due date will be withdrawn from the interconnection queue pursuant to GIDAP Section 3.8. 

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

 SCE is appreciative of the CAISO’s proposal to include this SCE-recommended topic in the 2021 IPE.  SCE would like for the CAISO to make it explicit in GIDAP and BPMs, if necessary, that when an Interconnection Customer requests to share a Generation Tie-Line, PTO Interconnection Facilities, and any related IRNUs at a substation or switchyard (e.g., line position to terminate the shared Generation Tie-Line) with an earlier-queued affiliate or non-affiliate project with an executed GIA across clusters, that the shared IRNUs shall not be subject to GIDAP section 14.2.2 if the interconnection customer of the earlier-queued project terminates its GIA. SCE understands the benefits (cost and schedule) of interconnection customers sharing facilities across clusters, but it is also our position that the Interconnection Studies and IA will reflect that the interconnection customer of the later-queued project will be jointly and severally liable for up to one hundred percent (100%) of the shared IRNU costs, IFS, and ITCC, if applicable. In essence, the Interconnection Studies for the later-queued project will treat the shared IRNUs as CANUs, not PNUs. This exclusion does not apply in the case where the shared IRNU is a Stand-Alone Network Upgrade (e.g., Loop-In Substation). Once this exclusion is reflected in GIDAP and BPMs, SCE will no longer have to treat applicable GIAs as non-conforming and have to file these GIAs with FERC requesting a waiver of GIDAP section 14.2.2. 

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

SCE supports Gridwell’s proposal for the CAISO to provide additional data, in a usable format, to the interconnection customers.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

If anything has been learned from the changes to the interconnection process since the implementation of clustering more than a decade ago, is that the process needs to continually change and evolve along with the changes in the overall generation/storage industry.  As the equipment such as smart inverters continues to evolve, as PTOs implement advanced technologies such as CRAS continues, the need for new Standards will be inevitable.  Each PTO should be allowed to continue to change its Standards whenever it feels necessary to deal with the ever-increasing complexity and reflect learnings over time in its study efforts, engineering, equipment specifications, etc.  SCE understands that changes in Standards can be disruptive, but they are necessary part of continuous improvement that is a hallmark of the industry.  

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

SCE agrees that “upgrades stacked upon upgrades” is one of the after-effects of the cluster study process.  Various attempts to remedy this issue have thus far not made much difference, because of the lumpy nature of network upgrades, and the “not needed until really needed” mentality among CAISO and PTO engineers.  SCE believes that ultimately it is an engineering question as to when certain upgrades are required, and the risk of an upgrade becoming “triggered” earlier as opposed to later is a natural outcome of how upgrades are studied.  Allowing leapfrogging of upgrades ultimately causes the same type of pitfalls as leapfrogging of queue positions.  How does one fairly allocate upgrades other than “who triggers”? 

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

Conceptually, SCE does not oppose transferring deliverability within the same substation but would need to see the rules that allow such a transfer to ensure it remains a fair practice.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

SCE supports revisiting the GIDAP tariff requirement that a project over 5% shift factor fails the electrical independence test according to Section 4.2.1.1. There may be instances where a small project would fail the criteria, though engineering judgment indicates that the project could be considered electrically independent. Instead of setting new numeric criteria, SCE would suggest that the tariff be revised to allow justification for an exception to this criterion.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

SCE is unsure if the minimal incremental benefit from this proposed topic is worth the significant added complexity to implement. 

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

SCE agrees with the requirement to provide documentation (as part of the IR) that demonstrates that the owner of the gen-tie agrees to the sharing arrangement.  A gen-tie agreement does not necessarily have to be entered into prior to an IR being deemed valid and complete but will need to be by the time a GIA is executed, so requiring documentation of such an “agreement in principle” as part of an IR submittal should help in this situation.  

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

SCE provides no additional commentary. 

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

SCE provides no additional commentary. 

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Upstream appreciates the opportunity to comment on the CAISO’s IPE Issue Paper and Straw Proposal as well as proposals put forth by stakeholders as part of this initiative.  Upstream supports many of the proposals put forth by CAISO and our comments are limited to specific concerns and ideas that would improve the interconnection process for stakeholders.  

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

Upstream supports eliminating the downsizing process and replacing it with a “MMA-like” process that can be submitted to the CAISO at any time.  

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

Upstream is concerned that eliminating the current “Allocation Group 3 - Proceeding to Commercial Operation without a PPA” would restrict the ability of an energy storage resource to come online as a merchant facility.  In the straw proposal, CAISO notes that only one project has used Allocation Group 3 to come online without a PPA.  This has historically been true because non-dispatchable solar and wind projects are energy resources that require a PPA to obtain project financing.  Unlike wind and solar, energy storage resources are dispatchable capacity resources that can achieve commercial operation without a PPA and then choose to participate in the short-term RA market.  Simply put, dispatchable resources need a path to commercial operation as a merchant facility without outlaying millions of dollars in capital costs “betting on the come” that they’ll receive deliverability in the future under the CAISO’s Proposed Allocation Group 3. 

Upstream would be supportive of the Proposed Allocation Groups if CAISO created an “Allocation Group 4 – Proceeding to Commercial Operation without a PPA.”  Doing so would support the CAISO’s goal of prioritizing deliverability for contracted and short-listed projects while balancing the requirement that dispatchable resources have a path to achieve commercial operation as a merchant facility.  

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

Upstream supports the CAISO proposal to not proceed with the accelerated process for “ready” projects because there are already provisions in the tariff that allow projects to be accelerated through the study process.  In lieu of adding a redundant third process for highly viable projects, the CAISO could make improvements to the Independent Study Process and Fast Track processes.  Projects proceeding under the CAISO or PTO’s WDAT Independent Study Process are studied for deliverability purposes as part of the next Phase 1 and Phase 2 Interconnection Studies for the Queue Cluster study performed for the next Queue Cluster Window that opens after the CAISO received the request (See 4.6 of Appendix DD). Rather than tie highly viable projects studied through ISP to the queue cluster process, the CAISO should allow these projects to submit for an Energy Only TP Deliverability Study (See 8.9.2 of Appendix DD) as soon as the ISP System Impact Study and Facility Studies are complete and with the next TP Allocation Cycle.  This minor change in the tariff would allow these projects to achieve commercial operation earlier without having to wait for the queue cluster deliverability study. 

Upstream strongly opposes the CAISO proposal to create a reliability-driven interconnection service for interim interconnection on the basis that there are a significant number of queued projects that can come online in 2023 and 2024 and this proposal is not needed.  Providing interim interconnection service would essentially amount to queue jumping and would increase the level of uncertainty other interconnection customers would face.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

Upstream is supportive with one minor change – the CAISO should align the refundability provisions of the site exclusivity deposit with the refundability provisions of the study deposit.  50% of the study deposit and 50% of the site exclusivity deposit should become nonrefundable thirty calendar days after the Scoping Meeting (in lieu of 50% of the site exclusivity deposit becoming nonrefundable when the interconnection request is deemed complete).   

With respect to limiting the number of interconnection requests by a parent company, Upstream would appreciate additional clarity on how this will be enforced.  The CAISO notes in 4.1 that developers were encouraged to break larger projects into small projects to mitigate study costs – increasing the study deposit based on the number of projects may incentivize developers to circumvent the rule change by hiding who the parent entity is.  

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

Upstream is supportive of CAISO requiring site exclusivity to move into the Phase II Study and making this applicable to Cluster 14 and future queue clusters.  The QC14 study window has been extended and developers have until the end of 2022 to obtain site exclusivity.  This should not be viewed as a retroactive change.      

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

Upstream supports addressing this proposal in Phase 2.    

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

Upstream supports the CAISO's proposal.  

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Upstream supports formalizing the process to allow interconnection customers to transfer interconnection requests to the appropriate tariff.  

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Upstream supports CAISO’s proposal to restrict changing sites and POIs to the same study area.  

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

Upstream supports the CAISO proposal to not allow projects to submit a MMA while the project is parked.  A large percentage of projects that park are ultimately withdrawn from the queue.  Allowing these projects to submit MMAs while they’re parked diverts resources away from commercially viable projects that are proceeding through the queue.    

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

Upstream is generally supportive of making more information available to interconnection customers, but this needs to be viewed from the perspective that CAISO and PTO staff are already stretched thin – especially with QC14.  Most of the data stakeholders are asking for is available on the Market Participant Portal and repackaging this data will “pull” staff away from completing technical studies, MMAs, MRs, and other studies that are requested by developers.   

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

Upstream has no comments on this issue at this time.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

Upstream opposes the “re-stacking NUs” without reallocating costs because it would incentivize developers to “piggy-back” on earlier queue positions.  An example of this would be a developer who files into a 230kV BAAH position in QC15 and then subsequently files into QC16 utilizing the same 230kV BAAH position with an earlier COD.  If re-staking of NUs were allowed, the developer could withdraw the QC15 position in which case the NU cost associated with the QC16 position would be paid by the TAC with no reimbursement limit.

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

Upstream opposes allowing developers to “sell” deliverability at the same POI because it will lead to anti-competitive behavior.  Developers will be incentivized to “box out” other developers from accessing particular POIs across the CAISO BAA in an attempt to force the transfer of deliverability.  Futhermore, the tariff allows CAISO to alllocate deliverability but also take deliverability away.  This could unnecessarily place the CAISO in the middle of third-party commercial transactions where interim/full deliverability was sold and transferred, but then temperorarily or permanantly taken away.     

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

Upstream agrees with CalWEA that revisions need to be made to the Electrical Independence Test.  The current Electrical Independence Test was drafted prior to significant changes to the tariff, including the introduction of the ANU, CANU, and PNU concepts, and needs to be updated.     

In its current form the EIT is overly restrictive in determining if a project is independent of other projects in the queue.  The Flow Impact Test and the five percent threshold imply that if an ISP project is behind the same constraints as the current cluster, then the ISP is not independent of other projects in the queue.  This was true prior to the introduction of the ANU, CANU, and PNU concepts but is now outdated.  RNUs identified in the current cluster would be classified as CANUs or PNUs (to the extent a contributing project executes its LGIA).  Since the cost responsibility for these RNUs has been assigned to the current cluster, the incoming ISP project would be electrically independent.  If current cluster projects withdrew and the need for the RNU went away, then the cost responsibility of the identified RNU would fall on the ISP project and subsequent queue clusters (to the extent that subsequent queue cluster triggered the need for the RNU).

Upstream supports eliminating the Flow Impact Test and Short Circuit Test now that the CAISO has introduced the ANU, CANU, and PNU concepts into the tariff.  The CAISO should also consider allowing PTOs to perform the EIT sixty calendar days after the start of the previous queue cluster study (or engineering judgement) at which point the cluster study would have cleared planning. 

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

Upstream supports the requirement that Interconnection Customers submitting an IR that utilizes a third-party owned gen-tie should submit commercial documentation showing that the gen-tie owner has agreed to the arrangement.  

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Valley Electric Association, Inc. (“Valley”) appreciates the efforts of the CAISO to propose an alternative cost allocation treatment for network upgrades related to generator interconnections to local low-voltage transmission facilities.  In addition, Valley agrees with those commenters who stated that this issue should be addressed in this initiative.  Valley's comments on item 9 are further adressed in the attached document.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

Valley's comments on item 9 are addressed in the attached document.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

1. Provide a summary of your organization’s comments on the Interconnection Process Enhancements (IPE) 2021 issue paper and straw proposal:

Please see attached comments below.

2. Provide your organization’s comments on the ISO’s proposal to remove the downsizing window and simplifying downsizing request requirements, as described in section 3.1, as modified in the stakeholder discussion that if a network upgrade only impacts that project, then the ISO would not need to wait for the reassessment to make a final decision on the downsizing:

Please see attached comments below.

3. Provide your organization’s comments on the ISO’s proposal for revising the Transmission Plan Deliverability (TPD) Allocation process, as described in section 3.3:

Please see attached comments below.

4. Provide your organization’s comments on the ISO’s proposal for addressing the question of how can the interconnection process and procurement activity align with transmission system capabilities and renewable generation portfolios developed for planning purposes, as described in section 3.4:

Please see attached comments below.

5. Provide your organization’s comments on the ISO’s proposal for determining if a solicitation model be considered for some key locations and constraints not addressed in portfolio development, as described in section 3.6:

Please see attached comments below.

6. Provide your organization’s comments on the ISO’s proposal for determining if an accelerated process for "Ready" projects be considered, as described in section 3.7:

Please see attached comments below.

7. Provide your organization’s comments on the ISO’s proposal for determining if higher fees, deposits, or other criteria be required for submitting an IR, as described in section 4.1:

Please see attached comments below.

8. Provide your organization’s comments on the ISO’s proposal for determining if site exclusivity be required to progress into the Phase II study process, as described in section 4.2:

Please see attached comments below.

9. Provide your organization’s comments on the ISO’s proposal for determining if the ISO should re-consider an alternative cost allocation treatment for network upgrades to local (below 200 KV) systems where the associated generation benefits more than, or other than, the customers within the service area of the Participating TO owning the facilities, as described in section 5.1:

Please see attached comments below.

10. Provide your organization’s comments on the ISO’s proposal for determining the policy for ISO as an Affected System - how is the base case determined and how are the required upgrades paid for, as described in section 5.2:

Please see attached comments below.

11. Provide your organization’s comments on the ISO’s proposal for the expanded errors and omissions process to provide criteria and options when changes to network upgrade requirements occur after Financial Security (IFS) postings have been made, as described in section 5.3:

Please see attached comments below.

12. Provide your organization’s comments on the ISO’s proposal for clarifying the definition of Reliability Network Upgrade (RNU), as described in section 5.4:

Please see attached comments below.

13. Provide your organization’s comments on the ISO’s proposal for transferring Participating Transmission Owner (TO) Wholesale Distribution Access Tariff (WDAT) Projects into ISO Queue, as described in section 5.5:

Please see attached comments below.

14. Provide your organization’s comments on the ISO’s proposal for changing sites and POIs during IR validation, as described in section 5.6:

Please see attached comments below.

15. Provide your organization’s comments on the ISO’s various questions for addressing whether the ISO have the ability to terminate the GIA earlier than the seven year period, if a project cannot prove that it is actually moving forward to permitting and construction, as described in section 5.7:

Please see attached comments below.

16. Provide your organization’s comments on the ISO’s proposal for should parked projects be allowed to submit any type of MMAs while parked, as described in section 5.8, and if yes, what criteria should be required:

Please see attached comments below.

17. Provide your organization’s comments on the added scope item from SCE to add due dates for curing deficiencies in Appendix B, to avoid delays in starting Phase II studies, as described in section 6.1:

Please see attached comments below.

18. Provide your organization’s comments on the added scope item from SCE to make it explicit that when ICs agree to share a gen tie-line, PTO interconnection facilities, and any related IRNUs at a substation across clusters, the shared IRNUs are not subject to GIDAP Section 14.2.2, as described in section 6.1:

Please see attached comments below.

19. Provide your organization’s comments on the added scope item from Gridwell on a proposal to include an issue focused on improved transmission grid data transparency, and specifically what data your organization would like to obtain publically, as described in section 6.2:

Please see attached comments below.

20. Provide your organization’s comments on the added scope item from LSA/SEIA to resolve delays caused by PTOs via modifications to commercial viability criteria, as described in section 6.3:

Please see attached comments below.

21. Provide your organization’s comments on the added scope item from LSA/SEIA to address network upgrade re-stacking and how your organization would suggest the Participating TOs would prioritize the various upgrades versus project CODs, as described in section 6.3:

Please see attached comments below.

22. Provide your organization’s comments on the added scope item from LSA/SEIA to address expanding deliverability transfer opportunities, as described in section 6.3:

Please see attached comments below.

23. Provide your organization’s comments on the added scope item from CalWEA to address re-examining the ISP electrical independence test in section 6.4 and provide specific proposals for revisions to the ISP electrical independence test criteria that provides a methodology that addresses the condition where a current cluster project is impacted or a potential impact cannot be ruled out:

Please see attached comments below.

24. Provide your organization’s comments on the added scope item from REV Renewables to address examining the issue of when a developer issues a notice to proceed to the PTO, requesting the PTO/ISO should start planning for all upgrades that are required for a project to attain FCDS, including the upgrades that get triggered by a group of projects, as described in section 6.4:

Please see attached comments below.

25. Provide your organization’s comments on the added scope item from SDG&E recommending there be a requirement that any IR that proposes to utilize a third party owned gen-tie must provide documentation as part of their IR that demonstrates that the gen-tie owner has agreed to the project using its gen-tie, as described in section 6.4:

Please see attached comments below.

26. Provide your organization’s comments on the added scope item from SDG&E recommending that after the IR validation, the ISO should be consistent in using RIMS for all documents, details, etc. related to projects, as described in section 6.4:

Please see attached comments below.

27. Additional comments on the IPE 2021 issue paper and straw proposal and December 13, 2021 stakeholder workshop discussion:

Please see attached comments below.