Comments on draft final proposal

1. Please provide a summary of your organization’s comments on the draft final proposal.

The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on the California Independent System Operator (CAISO)’s Draft Final proposal on the Subscriber Participating Transmission Owner (SPTO) Model, dated April 11, 2023, and subsequent presentation (April 11 meeting, hereafter) discussed during the April 18, 2023 stakeholder meeting.

BAMx strongly supports the SPTO concept and the CAISO’s willingness to amend its Transmission Control Agreement (TCA) to facilitate TransWest Express LLC's (TWE) proposed vehicle to accommodate this concept. Besides reducing the impact on the CAISO-wide Transmission Access Charge (TAC), it promotes cost causation as a recovery mechanism for those projects needed to deliver generation from out-of-State (OOS) and offshore wind (OW) projects. BAMx believes such a mechanism will send appropriate price signals to encourage the purchasing entity to buy power from the most cost-effective projects. In addition to Sunzia and TWE projects, which are being developed on a subscriber basis, BAMx believes that the CAISO should encourage other OOS as well as offshore wind project developers to consider the subscriber model projects. If this model were applied, it could have a significant impact on containing the cost of the ever-growing TAC, while providing appropriate price signals for resource procurement.  BAMx’s analysis indicates that if all the transmission projects needed to access OOS wind envisioned in the CAISO 20-year outlook elected the subscriber model, nearly $9.95 billion of transmission costs would not be recovered via CAISO-wide TAC. As a result, the projected CAISO-wide HV TAC 15-20 years from now would reduce by as much as $7/MWh. The transmission costs needed to deliver the power from the OOS or offshore wind projects would instead be recovered from the parties electing to procure the output of those projects, thus enabling them to consider the full costs of those projects in comparison to other projects that don’t require as much transmission investment.

BAMx strongly supports the intent of the CAISO proposal to be not narrowly focused on the TransWest Express case, but be flexible enough for various scenarios of Subscriber PTOs, providing a path for future generation-only BAAs to instead join the CAISO grid.[2]

[1] BAMx consists of City of Palo Alto Utilities and City of Santa Clara, Silicon Valley Power.

[2] Draft Final Proposal, p.6.

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

No comments at this time.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

Per the Draft Final Proposal, entities that choose to use the transmission capacity of the project, as either a Subscriber or a Non-Subscriber, will pay for that use in accordance with a FERC-approved tariff.[1] BAMx appreciates the Draft Final Proposal support for the principle that the costs of a Subscriber PTO project should not be included in CAISO’s TAC.

[1] Draft Final Proposal, p.15.

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

Per the Draft Final Proposal[1],

“the ISO will collect the TAC or the WAC on the Subscriber Participating TO scheduling points from Scheduling Coordinators that do not have a Subscriber Encumbrance (i.e., non-subscribers). The Subscriber Participating TO will develop a Subscriber Wheeling Charge in accordance with the ISO tariff and the Subscriber Participating TO’s transmission owner tariff and will be approved by FERC, following the same process and meeting the same regulatory requirements as all other Participating TOs do today. This Subscriber Wheeling Charge will be deducted from the revenue collected by the TAC and WAC.” And

“The TAC and WAC revenue received from non-subscriber uses of the Subscriber Participating TO facilities will be used to first, pay the Subscriber Participating TO, with any remaining revenue allocated to the other Participating TOs consistent with the existing revenue allocation process for non-load serving Participating TOs.” And

“The ISO will not include the revenue requirement of the Subscriber Participating TO facilities in the calculation of the TAC or WAC.”

BAMx supports the above-mentioned revisions to the revenue recovery of the Subscriber Wheeling Charge because they are consistent with the principle that the Subscriber Participating TO costs should not affect the CAISO-wide TAC or WAC. BAMx suggests that the CAISO use the term Subscriber Wheeling Access Charge (SWAC) in the revised draft final proposal and draft tariff language instead of TAC or WAC to avoid any confusion with the CAISO-Wide TAC or WAC.

[1] Draft Final Proposal, p.13.

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

On Page 18 of the Draft Final Proposal, the CAISO states that

“The ISO will not charge the SC the cost of transmission service, congestion, bid cost recovery, offsets, and IFM congestion allocation for the portion of the transaction that uses the CRN.”

The above statement could be misinterpreted to mean that SPTO offtakers do not have to pay TAC/WAC for the portion of the transaction that uses the CAISO Controlled Grid that is not covered by the SPTO CRN. BAMx requests the CAISO to revise the language in the Revised Draft Final Proposal to clarify that the use of CAISO transmission that is not covered by the subscriber encumbrance would be subject to the CAISO-wide load-based TAC/WAC as suggested below.

 “The ISO will not charge the SC the cost of transmission service, congestion, bid cost recovery, offsets, and IFM congestion allocation for the portion of the transaction that uses the CRN, but will charge CAISO TAC/WAC for the use of ISO transmission not covered by the CRN.”

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

BAMx opposes allowing reimbursement of the cost of the CAISO network upgrades needed to support the SPTO transmission facilities.  While the CAISO tariff currently requires the interconnection customer (or the PTO) to upfront finance those upgrades, subject to later reimbursement by the affected PTO, SPTO facilities are not similarly situated since they would not have been approved through the TPP process and would not have gone through an adjacent BAA’s transmission planning or generator interconnection process. Therefore, the subscriber(s) for the SPTO facilities should be responsible for the costs of the transmission interconnection and deliverability network upgrades without reimbursement. The Draft Final Proposal indicates that adopting the BAMx position would not be consistent with the FERC order.[1] We disagree. The FERC order approves cost reimbursement by the CAISO Participating TOs for all network upgrades needed for generators interconnecting to an affecting system.[2] However, the SPTO facilities would not be connecting to an affecting system, and instead would be part of the CAISO BAA; therefore, generators connecting to the SPTO facilities should not be treated as those connected to an affecting system. Similarly, unlike other generators connected to the CAISO system, the CAISO TAC should not increase as a result of an SPTO project, as doing so would violate the principle that SPTO facilities should not result in a TAC increase because such projects were not approved through the TPP. For these reasons, the current CAISO Generator Interconnection and Deliverability Allocation Procedures (GIDAP) provisions and the recent FERC order allowing for generator reimbursement of network upgrade costs should not be applicable to the SPTO generator interconnections subsequent to the original build of the SPTO transmission facilities.

[1] Draft Final Proposal, p.22.

[2] Draft Final Proposal, p.21.

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

No comments at this time.

1. Please provide a summary of your organization’s comments on the draft final proposal.

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California Independent System Operator’s (ISO) Subscriber Participating Transmission Owner (PTO) Model Draft Final Proposal. CalCCA supports the Subscriber PTO model as an alternative way to develop new transmission with commercial interest without increasing the ISO’s transmission access charge (TAC). The ability to develop new transmission through multiple avenues will enable the development of more transmission that is critically needed to support the state’s clean energy policy goals.

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

First and foremost, CalCCA agrees with the principle that the capital and operations and maintenance (O&M) costs of the Subscriber PTO transmission projects should not receive cost recovery through the ISO’s TAC. Subscriber PTO projects will not go through the Transmission Planning Process (TPP) to receive approval and, therefore, should not receive cost recovery through TAC. Given the subscribers and their offtakers will fund the project, rather than the TAC, CalCCA agrees the subscribers should receive encumbrances with scheduling rights and the perfect hedge.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

CalCCA generally supports the ISO’s proposal to charge non-subscribers the TAC or wheeling access charge (WAC) to use the Subscriber PTO line and use the TAC or WAC charges to first pay for the subscriber WAC developed by the subscriber and approved by the Federal Energy Regulatory Commission (FERC). The ISO should ensure that it is clear in what instances a non-subscriber load-serving entity would be charged the TAC versus the WAC. As long as this information is clear, the non-subscriber can schedule their load in a manner that makes them indifferent from using the subscriber PTO line versus another path.  

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

See response to question 3.

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

The Draft Final Proposal indicates that the decision of whether to continue the subscriber encumbrance after the original encumbrances end will be determined based upon the regulatory requirements at the time and the Subscriber PTO’s intentions for the future of its transmission facilities. CalCCA does not oppose this treatment so long as the Subscriber PTO project is fully subscribed, and the Subscriber PTO project will not receive any TAC cost recovery for the original project's costs and associated O&M.

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

CalCCA supports the Subscriber PTO developing a transmission revenue requirement for network upgrades associated with only subsequent generator interconnection requests that are not a part of the original build of the project. The ISO should only include generator network upgrades identified after the original build and identified through the generator interconnection and deliverability allocation procedures in the TAC.

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

CalCCA agrees that the ISO should add a new Subscriber PTO upgrade to the TAC if the upgrade is incremental to the original build costs and if the ISO has selected the upgrade through the TPP. The ISO must ensure it does not later include the costs associated with the original build of the project in the TAC.

1. Please provide a summary of your organization’s comments on the draft final proposal.

Clearway Energy Group (Clearway) appreciates the opportunity to comment on the Draft Final Proposal. Clearway supports the Subscriber PTO model as a route to get regional transmission built on the scale and timeline that California needs.

Clearway recommends delaying the Final Proposal to allow for additional clarifications and dialogue with stakeholders. This is a new and complex model, and the Draft Final Proposal leaves several questions that require further clarification. With Cluster 15 now on a longer timeline, it does not seem necessary to maintain the July 2023 date for approval of the Subscriber PTO model. Instead, market participants would benefit from the CAISO taking additional time to work through the details of the model and make sure it is well-understood by stakeholders.

Specifcially, we would appreciate additional clarification or discussion on the following questions:

• Congestion revenue rights (CRRs): Based on the discussion on the stakeholder call, Clearway’s understanding is that there would be no CRRs for the non-subscribed use of the north-south capacity. If there are no CRRs on the north-south portion, then who would receive the congestion revenue based on the congestion component of LMPs at the three new CAISO scheduling points on the TransWest Express system? Similarly, for south-north congestion, who would receive congestion revenues, assuming no market participant holds CRRs for that south-north path?
• Subscriber Wheeling Access Charge (SWAC): Clearway’s understanding is that the SWAC is not required to be formulaic; we request that the CAISO clarify whether this is the case and, if so, whether the SWAC would be required to go through the same process and meet the same regulatory requirements associated with TAC additions by other Participating TOs, or whether the process would be different.
• Non-contiguous Subscriber PTO: During the stakeholder meeting on April 18, CAISO staff mentioned the possibility that a Subscriber PTO facility could be non-contiguous to the CAISO system if it had firm point-to-point transmission service. Clearway requests further clarification and opportunity for stakeholder input on the mechanics of this model. For example, if the Subscriber PTO facility relies on firm point-to-point transmission service to reach the CAISO, how would generators interconnecting to that facility be evaluated in the interconnection and deliverability process? Would generators be required to secure transmission service from the Subscriber PTO facility to the main CAISO system, and if so, at what point in the interconnection process would this happen? 

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

1. Please provide a summary of your organization’s comments on the draft final proposal.

Golden State Clean Energy supports the innovative thinking by the California ISO and TransWest Express that has gone into the Subscriber PTO model. California has ambitious policy goals, and the rate of build required to timely and reliably meet these goals creates significant challenges that require all to look beyond conventional processes for solutions. This initiative shows that CAISO takes California’s challenges seriously and is willing to work with stakeholders to find creative solutions. This collaborative approach is critical to the success of state policy goals. 

Further innovation will likely be needed to better ensure California meets its policy goals. Of course, the transmission planning process will continue to be at the center of CAISO’s planning for new transmission, but alternative methods for developing new transmission will only increase the state’s chances of succeeding while managing ratepayer concerns. Additional optionality allows for new business models to be created that can result in ratepayer savings and increased competition. Thus, we urge CAISO to refrain from including any unnecessary limitations on the Subscriber PTO model and instead preserve optionality and not create hurdles for future innovation. The primary benefit of the Subscriber PTO model is transmission development that avoids increasing the Transmission Revenue Requirement of the Transmission Access Charge. That benefit can be captured irrespective of the physical location of transmission and generation resources, so CAISO should ensure it does not limit this potential.

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

1. Please provide a summary of your organization’s comments on the draft final proposal.

I am submitting these questions on my own behalf, and not on behalf of any particular organization.  

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

I have some questions regarding how Subscriber PTO Charges and TAC Charges will apply in different situations:

1) Assume that a generator with Subscriber Rights (and that has thus paid for capacity on the Subscriber PTO system) is interconnected to the Subscriber PTO system in Wyoming.   That generator schedules a delivery power to the New Substation where the Subscriber PTO facility connects to the existing CAISO grid.  At that point the generator sells its power to a California Load Serving Entity for delivery to its own load.  Does the LSE then pay the full CAISO TAC for delivery from the New Substation to its load?   Is there any partial or full crediting of that TAC revenue back to the Subscriber PTO or to the generator that used its Subscriber Rights?  If not, haven't the generator seller and the LSE buyer effectively paid "pancaked rates" for transmission over both the Subscriber PTO facility and the existing CAISO grid?  If not, please explain.  

2) Assume instead that a non-subscriber generator is interconnected to the Subscriber PTO system Wyoming.  That generator sells power to a California LSE at its point of interconnection in Wyoming, and the LSE then schedules that power over the Subscriber PTO faciitites and the existing CAISO grid for delivery to its own load.  Does that LSE then pay both the Subscriber PTO's Wheeling Access Charge and the CAISO TAC?  According to the discussion at pages 12-13 and 17-20 of the Draft Final Proposal, it appears that the LSE would pay only the TAC, and that an amount of revenue equal to the Subscriber Wheeling Access Charge would be subtracted from the TAC revenue and paid to the Subscriber PTO, is that correct?  If that is not correct, please explain how and why.

3) If, in Scenario 1 above, there is no partial or full crediting of TAC revenue back to the Subscriber PTO or to the generator that used its Subscriber Rights, wouldn't the non-subscriber generator described in Scenario 2 have a competitive advantage over the Subscriber Generator?  Please explain why or how this is not the case.  

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

Regarding Maximum Import Capacity for Deliverability, at pages 24-25 of the Draft Final Proposal:  CAISO states that "existing MIC will retain priority above the deliverability allocation for the resources subsequently connecting to Subscriber Participating TO facilities," and that "Full or Partial Capacity Deliverability Status for a generator seeking to interconnect to the ISO controlled grid via a Subscriber PTO project is contingent upon all pre-cursor TPP, generation interconnection process, and reliability and deliverability network upgrades specified in the generator interconnection agreement being in service. If any required upgrade mentioned above is not yet in-service, a generating facility can obtain “Interim Deliverability” status if the annual net qualifying capacity deliverability study determines that the generating facility can have deliverability during the next resource adequacy cycle, in advance of completion of all upgrades."

Does this mean that if TransWest Express comes on line in, say, 2028, and the Trout Canyon – Lugo 500 kV line proposed in the Draft 2022-23 TPP does not come online until 2033, then generators interconnecting to the TWE line in Wyoming could only obtain "Interim Deliverability" until the Trout Canyon-Lugo line is in service?  If not, please explain fully.   

1. Please provide a summary of your organization’s comments on the draft final proposal.

 LS Power appreciates CAISO’s effort to develop a new option for PTO participation through the Subscriber PTO (SPTO) initiative.  LS Power does not have comments on all areas of the proposal but instead requests additional clarification on two aspects, when a new SPTO line would be added to the Transmission Planning Process (TPP) and Maximum Import Capability (MIC).

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

  LS Power has no comment at this time.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

  LS Power has no comment at this time.

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

  LS Power has no comment at this time.

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

  LS Power has no comment at this time.

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

  LS Power has no comment at this time.

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

 In the draft final proposal, CAISO indicates that a new SPTO line would be added to the TPP if: (1) a generator interconnection request is approved by CAISO that requires the SPTO transmission facilities, and the transmission provider agrees to be a SPTO in CAISO’s BAA; or (2) a new PTO wanting to join CAISO that desires the SPTO rate recovery, and it meets all of the transmission control agreement requirements and the ISO Governing Board approves the new PTO.  With regard to item 1, it is unclear at what point in the generator interconnection process a request is “approved by CAISO”.  This is not clearly defined in the tariff or GIDAP BPM.  LS Power requests additional clarification on when CAISO approves an IR within the cluster study process timeline.  With regard to item 2, clarification on when CAISO considers that a project “meets all of the transmission control agreement requirements” is needed.  It is not clear if this requires the transmission control agreement be executed or at what point CAISO would consider that all requirements of the transmission control agreement have been met. 

Given the current status of TransWest Express (TWE), it would be helpful for CAISO to identify the anticipated timeline for TWE to be considered like the other CAISO approved (rate base) transmission projects in TPP based on item 1 as well as item 2 in the proposal. It would also be helpful for CAISO to identify how these two process points provide certainty that the project will come to fruition such that it should be included in the TPP base cases.

With regard to MIC, LS Power appreciates the clarification that CAISO provided in the draft final proposal on the deliverability allocation process for generator interconnections on an SPTO line.  While it is understood that the existing MIC will retain priority consistent with the CAISO tariff, the tariff does allow CAISO to transfer MIC to internal resources.  Does CAISO plan to transfer MIC associated with the out-of-state capacity in the CPUC;s 2022-2023 TPP portfolio to the Power Company of Wyoming LLC projects?

Although not directly addressed in the draft final proposal, on slide 9 of the April 18, 2023 presentation[1] CAISO indicates a potential for consideration of a second or non-contiguous ISO BAA to support SPTO projects.  LS Power requests more detail on this aspect of the proposal with explicit identification of MIC implications for both new and existing MIC. 

[1] http://www.caiso.com/InitiativeDocuments/Presentation-Subscriber-Participating-Transmission-Owner-Model-Draft-Final-Proposal-Apr182023.pdf

1. Please provide a summary of your organization’s comments on the draft final proposal.

NextEra Energy Resources, LLC (NextEra Resources) appreciates the opportunity to provide comments on the CAISO’s draft final proposal and strongly supports creative ideas that further the goal of much needed transmission infrastructure that increases access to renewable energy resources.  We appreciate and support the CAISO’s recommended approach to treat subscriber network upgrade cost reimbursement in a manner that is comparable to the treatment of network upgrade cost reimbursement of all other generators in the CAISO Balancing Authority.  

As noted by CAISO in its draft final proposal, and by NextEra Resources in its prior comments, FERC has approved cost reimbursement by the CAISO Participating Transmission Owners (PTO) for all network upgrades needed for generators interconnecting to CAISO assets or to an affected system, and there is no reason that generators interconnecting to Subscriber Participating Transmission Owner (SPTO) facilities should be treated any differently.

NextEra Resources acknowledges that the SPTO model is premised on SPTO developers recovering the capital costs of the original SPTO transmission facilities from initial project subscribers.  However, the long-lived nature of linear transmission facilities (which can exceed 50 years), paired with CAISO’s proposed termination of the subscriber encumbrance after the initial SPTO agreement (e.g., 30 years) would effectively require SPTO developers to “depreciate” the full value of certain transmission assets before the end of such assets’ useful life.  As discussed in more detail in its response to question 5, NextEra Resources suggests that this mismatch may result in scenarios that are inconsistent with FERC accounting and ratemaking principles and may be unsupported by market prices for delivered power. 

Furthermore, under the CAISO draft final proposal, the transmission owner would then turn over the assets to CAISO free of encumbrances and with a zero-cost basis, notwithstanding the assets’ residual book value. Such a requirement may place stress on the SPTO business model by inflating the cost to initial subscribers through “accelerated depreciation”, while creating a windfall for CAISO customers that are able to use the SPTO asset at the end of the initial subscription period without paying for the asset’s residual book value.  The SPTO developer may be left with stranded costs if it cannot fully recover the book value of the assets during the initial subscription period.  NextEra Resources encourages CAISO to acknowledge this challenge and consider whether there are ways that SPTO developers might either retain the ability to remarket subscription-based encumbrances at the end of the initial subscription period, or otherwise ensure that SPTO developers are not left with stranded costs to the extent the economics or duration of the initial subscriptions will not support full recovery of the SPTO developer’s initial capital costs.

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

NextEra Resources supports the use of encumbrances but maintains that the termination of subscriber encumbrances (as detailed in NextEra Resources’ response to question 5) warrants additional clarification.  To better understand how Existing Transmission Contracts (“ETC”) would apply, NextEra Resources requests that the CAISO provide additional details, with examples, of the scheduling and settlement mechanics of a ETC transaction.  Specifically, the potential market exposure from the drop point of the point-to-point ETC at Eldorado and settlement at the SCE load aggregation point.  In other words, if the scheduling coordinator (“SC”) submits a self-schedule bid for Wyoming generation that sinks to Eldorado, would the SC submit a separate bid to move the power to a CAISO delivery point such as the SCE Default Load Aggregation Point (DLAP)?  If so, what portion of that transaction would receive the scheduling priority that would exempt the subscriber rights holder from congestion?  Would that priority extend to the bid from Eldorado to a DLAP in the CAISO BAA, or would the SC with the ETC be competing with all other resources attempting to inject into the CAISO BAA at the same source (and potentially expose themselves to curtailment risk)?

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

NextEra Resources supports assessment of a Subscriber Wheeling Charge to non-subscribers using SPTO facilities.  However, it should be noted that the wheeling charge is likely inadequate compensation for the system benefits provided by a network facility.    

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

NextEra Resources understands the revised proposal to be a netting of the Subscriber Wheeling Charge from the applicable TAC/WAC rate charged to non-subscribers using the transmission facilities. The proposal further recommends that any revenue surplus be credited toward other Transmission Owners (“TO”). It would be helpful to provide clarity on why the TOs are the correct entity to receive the overcollection as opposed to the non-subscriber SC that was overcharged for use of the subscriber transmission facility.  It would also be helpful to understand the cost allocation principles used to set up the proposed allocation process and whether those principles continue to be reasonable for the SPTO use case and cost recovery construct.

In the instance of under-collection, the Subscriber Wheeling Charges will be “allowed an adjustment through the transmission revenue balancing account.”  NextEra Resources requests further information about settlements and mechanics of under-collected revenues over time.

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

NextEra Resources believes there is a potential disconnect between the depreciable life of linear transmission facilities and the typical term of SPTO subscribers power purchase agreements with Load Serving Entities.  While the former can exceed 50 years or longer - Pacific Gas & Electric (PG&E) has reported estimated service lives for transmission facilities that range between 15 to 75 years[1] and Southern California Edison (SCE) has been authorized by the CPUC to establish estimated useful lives for transmission assets that range from 30 to 65 years (with a weighted average useful life of 53 years[2]) - the latter is typically no longer than 30 years. 

This may create a situation where the owner of SPTO Transmission Facilities must either accelerate the recovery of its original capital costs over a shorter period than the assets’ useful life, which is inconsistent with FERC accounting and ratemaking principles and may be unsupported by the price an off-taker is willing to pay for delivered power[3] or enter sequential subscription agreements/offtake agreements that extend the length of time the asset is encumbered within the CAISO model. NextEra Resources suggests that CAISO evaluate whether this is an acceptable tradeoff, or whether it is more appropriate to consider whether residual undepreciated costs of long-lived SPTO facilities could be included in TAC/WAC rates following a 30-year encumbrance period,.  Alternatively, CAISO should consider extending the encumbrance period to re-contracted or re-powered facilities that may shoulder ongoing non-depreciated transmission asset costs.    

[1] Pacific Gas & Electric Company, 2022 Joint Annual Report to Shareholders, Page 117, https://www.pgecorp.com/investors/financial_reports/annual_report_proxy_statement/ar_pdf/2022/2022_Annual_Report.pdf

[2] Southern California Edison, 2022 Annual Report, Page 77, https://s3.amazonaws.com/cms.ipressroom.com/406/files/20232/2022-eix-sce-annual-report.pdf

[3] See generally Depreciation Accounting, Order No. 618, 92 FERC ¶ 61,087 (2000) (“The

primary objective of recording depreciation expense is to allocate an asset's service value over its remaining useful life.”). 

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

NextEra Resources supports the CAISO draft final proposal allowing for reimbursement of network upgrades comparable to the treatment of all other CAISO BAA interconnecting customers. 

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

NextEra Resources supports the CAISO draft final proposal that allows for the annual CAISO transmission planning processes to identify and approve future transmission upgrades interconnecting with, or upgrading to, SPTO original facilities. While the SPTO model may provide a pathway for recovery of capital costs and operating and maintenance costs, the SPTO model is by nature singularly focused on enabling the initial investment. However, once part of the CAISO network transmission grid, any new upgrades or expansion to the line that are incremental to the initial subscriber-based investment, should be approved through the CAISO transmission planning process and recovered via the TAC.

1. Please provide a summary of your organization’s comments on the draft final proposal.

The Six Cities have identified various questions and concerns regarding elements of the Draft Final Proposal, as outlined below.  These questions and concerns relate to (i) implementation of the encumbrance structure; (ii) the proposal for the Subscriber Participating TO (“SPTO”) to recover revenue associated with non-subscriber use; and (iii) the proposal for cost recovery of and allocation for network upgrades. 

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

The Six Cities do not have any further comments on the proposed use of encumbrances to implement the SPTO model, specifically as they relate to the TransWest Express project and associated Wyoming wind resources.  The Six Cities note that their prior comments included several questions on the implementation of encumbrances, which were not fully addressed in the Draft Final Proposal.  These include the following:

If an offtaker located within the CAISO purchased 100 MW of wind output from Power Company of Wyoming resources and paid for corresponding transmission rights on the TransWest Express project, would the seller then be delivering 100 MW of said wind energy to the CAISO grid at Ferris or Wyoming?  After accounting for transmission line losses, the “delivered quantity” at Eldorado would only be 90 MWs.  Would the Scheduling Coordinator for the CAISO offtaker be scheduling 100 MW at Ferris/Wyoming or 90 MW at Eldorado?  The Six Cities request that the CAISO describe in additional detail the charges that would apply to the offtaker—as a subscriber and as a non-subscriber—after accounting for the “perfect hedge”.  Additionally, how and at what location would the quantity of energy delivered into the CAISO be determined for purposes of generating renewable energy credits? 

The Six Cities note the CAISO’s confirmation that the “perfect hedge” associated with encumbrances does not encompass losses, which would remain allocable to the subscribers associated with their use.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

As the Six Cities understand the CAISO’s proposal, the SPTO will develop its own rate for the use of the line by non-subscribers, and it will seek approval for such rate at FERC.  The CAISO will then assess the applicable CAISO Access Charges—either the Transmission Access Charge or “TAC” or the Wheeling Access Charge or “WAC”—for use of line by non-subscribers (with assessment of TAC and WAC for general use of the CAISO controlled grid continuing as it does today).  To compensate the SPTO for non-subscriber use of the SPTO facilities, the CAISO will deduct from TAC and WAC revenues and distribute to the SPTO amounts associated with the quantity of non-subscriber use of the SPTO facilities based on the SPTO’s approved rate.  Remaining TAC and WAC revenues will then be distributed to the remaining CAISO PTOs, consistent with current practice.

Assuming that the above description reflects the CAISO’s intended proposal, this appears to be a potentially reasonable approach to addressing recovery of revenues for use of the facilities by non-subscribers.  The Six Cities request that the CAISO provide examples to show how this process will work in more detail.  As an initial matter, the Six Cities would like to understand whether there is any possibility that a diversion of WAC revenues to the SPTO may result in an under-allocation of such revenues to the remaining CAISO PTOs.  While the WAC revenues are credited against the TRRs of PTOs through the operation of the Transmission Revenue Balancing Account Adjustment (“TRBAA”), the Six Cities are concerned about a potential scenario where the level of the credit against the TRRs of CAISO PTOs is less than it otherwise would be as a result of allocating a share of revenues to the SPTO.  Initially, the Six Cities think there may not be such an impact, because the usage of the SPTO facility would likewise generate WAC revenues (that would then be credited back at the SPTO rate), but request confirmation and an example demonstrating how this would work.

The Six Cities also request an example showing how a non-subscriber that is a CAISO load-serving entity will be charged for use of the line.  If use by such an entity would result in a payment to the SPTO from TAC revenues at the SPTO rate, how will this payment be traced back to the non-subscriber LSE, such that CAISO LSEs that elect not to use the SPTO facilities are not indirectly subsidizing such use by a CAISO LSE that is not a subscriber? 

Finally, the Six Cities also request the CAISO to provide an example depicting a scenario whereby the SPTO’s rate is higher than the CAISO TAC/WAC.  While the Six Cities note the CAISO’s perspective that such a scenario seems unlikely at this time, the CAISO is designing a new rate structure that is intended to be applicable to a variety of facilities.  For example, it could be possible that transmission associated with offshore wind facilities may be developed under this model, and it does not seem outside the realm of possibility that the SPTO’s rate may indeed exceed the TAC/WAC.  Indeed, even now, several Utility Specific rates for existing Participating TOs exceed the TAC to varying degrees.  (See, e.g., Jan. 1, 20203 TAC Rates Based on Filed Annual TRR/TRBA and Load Data, available at HighVoltageAccessChargeRatesEffectiveJan012023R4.pdf (caiso.com).)  Additionally, during the stakeholder meeting to discuss this element of the CAISO’s proposal, the CAISO mentioned the use of a balancing account mechanism—presumably the TRBAA—as a means of ensuring that the SPTO will be made whole with respect to non-subscriber use.  The Six Cities assume that for the purpose of this element of the revenue recovery proposal, the SPTO will be considered a non-load serving Participating TO.  Is this assumption correct?  The mechanism for any potential true up of the SPTO’s revenue requirement (and whether an over or under collection is even possible) needs to be discussed in more detail, and examples are needed.  

The Six Cities also note that stakeholders, during the CAISO’s meeting to discuss the Final Proposal, raised valid concerns regarding the potential design by the SPTO for its rate—namely, how and what costs will be recouped through such a rate, given that the full costs of the SPTO facility are intended to be funded by subscribers.  The Six Cities understand that it will be the Subscriber PTO’s burden to design and support its intended rate as just and reasonable and consistent with FERC’s cost causation principles.  CAISO stakeholders will have the opportunity to review and potentially challenge the SPTO’s filing proposing rates for non-subscriber use of its assets if appropriate.  

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

Please refer to the comments provided above in response to Question 3.  Additionally, relevant requirements related to the tracking of original build costs and depreciation will need to be adThe Six Cities do not have comments on this element of the CAISO’s proposal at this time.   dressed in an agreement executed by a SPTO (such as the Transmission Control Agreement, for example).

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

The Six Cities do not have comments on this element of the CAISO’s proposal at this time.   

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

The Six Cities continue to have concerns regarding the CAISO’s proposal regarding treatment of network upgrades on the CAISO’s system associated with generation that is interconnecting directly to the SPTO’s facilities.  Although there were inconsistencies in the CAISO’s discussion of this element of the proposal during the stakeholder meeting, the Six Cities now understand the CAISO’s proposal to be that such upgrades will be funded through the CAISO’s Access Charges and not by the SPTO.  The Six Cities acknowledge the CAISO’s analogy to its new policy regarding affected system mitigation reimbursement, but note that this policy is not directly applicable to the SPTO structure, and the CAISO did not discuss this particular implication of its policy for affected system mitigation in the stakeholder initiative when it was developed.  Reliance on this policy alone to dictate any funding structure for network upgrades associated with interconnecting generation under the SPTO model is misplaced.  It does not seem reasonable to fully insulate potential subscribers from costs associated with upgrades on the CAISO system that are necessary to accommodate interconnection of generation and transmission services that they are purchasing.  If it can be demonstrated that subscribers will also be paying TAC and WAC charges associated with their full use of the line (i.e., not FOR the use of the line, but for any associated use to withdraw power from the line and deliver it on the CAISO system or elsewhere), then it may be reasonable to include initial generation network upgrade costs in the CAISO’s Access Charges. 

With respect to network upgrade costs associated with interconnecting generation subsequent to the initial generation resources, the Six Cities reiterate their earlier comments, which requested that the CAISO address situations where offtakers are not CAISO LSEs.  As explained previously, it does not seem appropriate to require CAISO transmission customers to fund upgrades on a line they cannot use for the benefit of a resource procured by a non-CAISO entity.  On the other hand, if the CAISO’s proposal is that non-CAISO, non-subscriber offtakers of subsequently-interconnected resources would contribute to a share of the cost of any network upgrades through assessment of the CAISO WAC, then the CAISO’s approach may be reasonable.  

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

The Six Cities do not have comments on this element of the CAISO’s proposal at this time.   

1. Please provide a summary of your organization’s comments on the draft final proposal.

Southern California Edison (“SCE”) is supportive of the concept of the Subscriber PTO model as a new pathway for adding needed transmission to the CISO grid, and that would enable California to access significant amounts of renewable wind generation to meet its out-of-state wind goals.  However, SCE is concerned with two aspects of the proposal in particular: 1) The use of new Encumbrances on the CAISO grid as a means of providing subscribers with the ability to move their power to CAISO load; and 2) Aspects of the proposal that appear to open the door for some “original build” transmission costs, including network upgrades attributable to the project, to be recovered through the CAISO’s Transmission Access Charge (“TAC”).  There should be no new Encumbrances placed on the CAISO grid, and there should be no scenario whereby any “original build” (including network upgrades) transmission costs are included in the ISO’s TAC.

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

SCE opposes the use of new contractual Encumbrances as a means of honoring Subscriber Rights. Rather, SCE is supportive of providing the S-PTO with CRRs and an appropriate level of scheduling priority through its tariff.  SCE’s opposition to formal contractual Encumbrances is based on concern that a new set of Encumbrances on the CAISO grid could create future inefficiencies in operation of the grid, the future of which is unknown in many areas.  The CAISO is currently working on creating a larger Day-Ahead market in the Western States, and the future of grid operation could include even more changes and evolution, some of which may not be foreseeable in terms of impacts to grid operations and how any Encumbrance may affect efficiency. 

Provision of CRRs to the S-PTO with an appropriate level of scheduling priority would provide an S-PTO, and its subscribers, with the necessary ability to schedule its power with the highest certainty and without financial congestion impacts. 

SCE also notes that its proposal to use CRRs as the means of assuring the ability of the S-PTO to use its own facilities to provide service to its subscribers has nothing to do with funding the investment of the S-PTO (as in the case of a Merchant PTO).  The S-PTO will recover its investment through its subscriber fees, not through CRR revenue.  The CRR revenue obtained would merely offset congestion charges incurred through the operation of the CAISO market, which is entirely appropriate.  And to the extent the S-PTO is not using (all of) its transmission, but instead it is congested by other users, the S-PTO would still receive all CRR revenues.  In effect, CRRs act as a mechanism to provide compensation to the S-PTO when others are using the S-PTO line (to the point of congestion).  Thus, if the CAISO is proposing the (unworkable) S-WAC approach simply to “compensate the S-PTO when others use its line”, CRR can accomplish this in a more workable and more reasonable manner.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

The Draft Final Proposal includes a proposal for a Subscriber Wheeling Access Charge (“S-WAC”) to be paid by non-subscribers for Wheeling service over the S-PTO facility portion of the CAISO grid (Section 3.2.1).  SCE believes that there is no basis for an S-WAC charge, since all of the costs of the S-PTO facility are to be recovered through charges to the subscribers.  From a rate development perspective, since the revenue requirement costs for Wheeling service over the S-PTO line would be $0, any S-WAC rate would be $0 per MWh.  Any revenue collected through a positive S-WAC rate would represent a double collection of the underlying revenue requirement costs of the S-PTO facility.  This approach also avoids the administrative burden of the S-PTO filing a rate case at FERC (that may ultimately be rejected since all costs are already recovered from subscribers).

SCE therefore proposes that the ISO Wheeling charge assessed for use of the S-PTO facility should not include any aspect of an S-WAC charge:  The Wheeling rate assessed to exit the S-PTO facility to a non-ISO area should equal the ISO’s HV WAC rate (and, as with all ISO Wheeling, there should not be a charge assessed to enter the ISO grid).  It should not include any S-WAC as an explicit additive component to the ISO Wheeling rate.  Neither should it provide for a carve out of ISO Wheeling revenue to be disbursed to the S-PTO, as the new ISO S-WAC proposal would do,    

Instead, the ISO should pay the S-PTO congestion revenue associated with the exit point from the S-PTO by allocating the S-PTO CRRs associated with its transmission.  This would not involve any rate pancaking, and would also generate revenues for the S-PTO which could be returned to the S-PTO subscribers.

SCE also notes that under the CAISO proposal, if the S-PTO’s S-WAC was greater than the CAISO WAC, this would result in an uplift to California customers.  This is completely contrary to the fundamental premise of the Subscriber model, namely S-PTO costs will not be recovered form CAISO customers and costs will not be put in the TAC.  

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

 Please see discussion in Section 3.

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

As explained in Section 2, SCE is not supportive of the use of Encumbrances.

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

SCE is supportive of the Draft Final proposal (as described on page 22) to allow for generator interconnection costs attributable to an interconnection to the S-PTO after the initial project has been built to be included in a new Transmission Revenue Requirement (“TRR”) of the S-PTO, and for those TRR costs to be recovered through and included in the CAISO’s TAC. 

However, SCE now understands the Draft Final proposal would also provide for the S-PTO to recover initial network upgrade costs associated with the “original build” costs of the S-PTO to also be eligible for reimbursement of network upgrade costs, thus allowing the S-PTO to include the costs in its TRR and recover those costs through the CAISO’s TAC mechanism (from all load serving PTOs and also through WAC rates). 

SCE strongly opposes the recovery of initial network upgrade costs, which really have to do with the initial project and are a cost associated with the initial build, to affect the CAISO’s TAC.  In SCE’s opinion, recovery of these initial network upgrade costs through the TAC would represent a gigantic violation of the principle that the S-PTO model should not result in the ISO’s TAC being increased.

As SCE stated in its comments on the Straw proposal (page 4), S-PTO transmission facilities do not go through the CAISO’s Transmission Planning Process, but instead are developed based on economic considerations by subscribers and the S-PTO entity.  The decision to go forward with an S-PTO facility should be based on a consideration of all of the costs and benefits of the S-PTO, without ignoring network upgrade costs.  If network upgrade costs are to be socialized to all other PTOs with load through the CAISO’s TAC, the subscribers will be more prone to move forward with the S-PTO facility, and in fact, the facility may be uneconomic from a societal point of view.

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

As stated in Section 6, SCE is very concerned that the network upgrade cost issue may result in sub-optimal transmission planning.

1. Please provide a summary of your organization’s comments on the draft final proposal.

TransWest Express LLC (“TransWest”) appreciates the California Independent System Operator’s (“CAISO”) diligent efforts in formulating the Subscriber Participating Transmission Owner (“SPTO”) model and preparing the Draft Final Proposal published on April 11, 2023 (“Draft Final Proposal”). 

The SPTO Model is a key part of the CAISO’s strategy to facilitate development of much-needed transmission infrastructure in the West.  As the CAISO notes, recent planning cycles have identified an accelerating need for new transmission development to meet projected load requirements, improve system reliability, and further the coordination and sharing of resources among neighboring Western states.  TransWest plans to use the SPTO Model to connect the TransWest Express transmission project (“TWE Project”) to the CAISO grid, which will facilitate access to new diverse wind resources that complement California’s resource needs and make additional transmission capacity available to the real-time and day-ahead markets.  Beyond California’s internal resource planning objectives, market enhancements like the Extended Day-Ahead Market and a potential western regional transmission organization will also benefit from developments like the TWE Project through integration with other utility systems in the WECC. 

The California Public Utilities Commission (“CPUC”) and the CAISO recognize the need for out-of-state wind resources.  The CPUC’s February 2023 Integrated Resource Planning base case portfolio now includes 4,828 MW of out-of-state wind on new transmission by 2030.  Similarly, the CAISO’s 20-Year Transmission Outlook demonstrates that meeting California greenhouse gas objectives will require over 24 GW of new wind generation, with offshore wind projected to provide a substantial portion this generation.  Wyoming wind operates with capacity factors comparable to those projected for California offshore wind at a fraction of the capital cost.  California offshore wind is also likely more than a decade out and will require expensive seaport infrastructure and a land-based transmission buildout.  Conversely, the TWE Project is a shovel-ready project that can deliver 3,000 MW of Wyoming wind in advance of the State’s SB 100 deadlines.  Wyoming wind, delivered on the TWE Project, will reduce greenhouse gas emissions, help curtail the use of natural gas, improve reliability, and make a significant contribution towards meeting load-serving entities’ Renewables Portfolio Standard requirements.

2. Please provide your organization’s comments on the proposed use of encumbrances, as described in the draft final proposal.

TransWest fully agrees with the Draft Final Proposal that honoring Subscriber Rights as Encumbrances is essential to the development of new transmission facilities.  Subscriber Rights must be recognized through Encumbrances to allow for the financing and construction of a subscriber-funded transmission project that is intended to support California load-serving entities.  The Draft Final Proposal correctly explains why the Subscriber Right should be treated in the same manner as an Existing Contract, i.e., receive a “perfect hedge.”  The contract rights holders should be entitled to scheduling priority for the contract path and exemption from transmission service charges and congestion because they will pay for the transmission under their transmission service agreements with the Subscriber Participating TO.

By implementing the SPTO Model, the CAISO is essentially expanding the existing CAISO Balancing Authority Area (“BAA”) to incorporate what could have been a generation-only BAA with previously-executed agreements into the existing CAISO BAA Tariff construct, all without increasing the Transmission Access Charge.  If a generation-only BAA was to interconnect to the CAISO grid, its existing transmission contracts would be treated as encumbrances.  Treating all existing Participating Transmission Owner (“PTO”) contracts in a similar manner is fair and avoids the need to develop and administer an alternative mechanism.

3. Please provide your organization’s comments on the proposed Subscriber Wheeling Charge, as described in the draft final proposal.

TransWest supports the transmission charges, including the Subscriber Wheeling Charge, that are described in the Draft Final Proposal.  TransWest will be funding the cost to build and operate the TWE Project, similar to other PTOs.  However, unlike the existing PTOs, TransWest will not receive any payments via the CAISO’s existing Transmission Access Charge or Wheeling Access Charge.  Therefore, TransWest will need to charge both subscribers and non-subscribers for transmission services on the TWE Project.  The Draft Final Proposal accommodates these requirements in a fair and equitable manner consistent with both open access principles and the general concept in FERC-regulated transmission that the “beneficiary pays”.

4. Please provide your organization’s comments on the proposed revision to the revenue recovery of the Subscriber Wheeling Charge, as described in the draft final proposal.

No comments.

5. Please provide your organization’s comments on the proposed termination of the Subscriber Encumbrance, as described in the draft final proposal.

No comments.

6. Please provide your organization’s comments on the proposed Subscriber PTO project interconnection cost recovery for generator interconnections subsequent to the original build of the Subscriber PTO transmission facilities, as described in the draft final proposal.

TransWest supports the Draft Final Proposal’s interconnection cost recovery for generator interconnections.  For purposes of cost recovery, treating downstream network upgrades for new generation projects that interconnect with a Subscriber Participating TO in the same manner as other projects in the CAISO generator interconnection process is fair and consistent with CAISO policy and FERC precedent.  Generators subscribing to transmission services on a new transmission project intended to serve the CAISO system should be eligible under the CAISO Tariff for reimbursement of network upgrades to the existing CAISO system.

7. Please provide your organization’s comments on the transmission planning process and transmission issues, as described in the draft final proposal.

No comments.