Comments on Draft Final Proposal

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

ACP-California thanks CAISO for taking the time to provide the proposed generic timeline for various studies and key dates under the proposed, new interconnection process. This provides a useful tool for developers and other stakeholders to review the timing of various studies and data points and how they will interact. At this time, we do not offer any specific comments on the overall timeline, other than recommending that CAISO provide, at the earliest opportunity, its thinking for when Cluster 16 might realistically open.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

ACP-California appreciates that CAISO has clearly articulated a viable path forward for Energy-Only projects under the TPD Deliverability Option within the Draft Final Proposal. Providing the details and a path for these resources to interconnect is necessary to maintain open access and, therefore, ACP-California greatly appreciates CAISO attention to this matter and the details added to the Draft Final Proposal.

We encourage CAISO to provide additional details in the Final Proposal regarding how Energy Only projects seeking to interconnect under the Merchant Deliverability Option would be treated. There should be a path for Energy Only projects to interconnect in areas which are not deemed part of a “TPD Deliverability Zone,” but resources which interconnect as Energy Only in a Merchant Deliverability zone should not be able to later convert to Full Capacity Deliverability Status unless they pay their share of network upgrades which were paid for by those selecting Full Capacity Deliverability Status in a Merchant Deliverability zone. CAISO’s Final Proposal should ensure that Energy Only projects can interconnect in Merchant Deliverability zones but that they cannot use this approach to “free ride” on the upgrades paid for by others under the Merchant Deliverability approach.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

The Draft Final Proposal provides a significant number of improvements in the Scoring Criteria. Notably, we appreciate that CAISO has revised the weighting of the commercial interest score downward from the prior draft. This is an improvement, given how early projects will be in their development cycles when they seek to enter the queue and demonstrate commercial interest. We request that CAISO commit to revisiting the weighting of the commercial interest score after the first cluster is scored and studied under the new process.

As discussed below, ACP-California strongly supports the inclusion of points for arrangements with corporate offtakers and reiterates that providing this option is necessary to ensure open access and non-discriminatory treatment for projects serving these customers. We also reiterate the need for meaningful limitations on or restrictions for LSE self-build projects allocating themselves points under the commercial interest metric. And we request that CAISO provide additional details and modifications to the definitions under the scoring criteria for Long-Lead Time resources. 

Point Allocation for Commercial Interest

The addition of the availability of points for interconnection projects which have demonstrated interest from commercial and industrial (corporate) offtakers is a significant improvement to the overall scoring process in the Draft Final Proposal. ACP-California commends CAISO for adding this component to the scoring criteria and reiterates that maintaining availability of points for these types of projects is imperative to a just and reasonable IPE proposal which ensures continued open access across the CAISO grid. While there may be disagreements over the exact number of points allocated to projects with commercial interest from corporate offtakers, what CAISO has put forward is a compromise. On the one hand, it does not provide projects with verified interest from corporate offtakers with the same level of points that are possible from LSE interest. But, on the other hand, it still appears to offer a potentially viable avenue for these projects to enter the queue.

ACP-California understands that some LSE’s expressed concern about the points from corporate offtaker projects potentially “crowding out” LSE projects. We do not believe this is likely to occur, especially given the higher number of points LSEs interest provides to a project, currently proposed to provide projects with LSE interest, with the Draft Final Proposal proposing to allocate four times the number of points for LSE interest as for corporate offtake interest. Given the heavy scoring preference for LSE projects, ACP-California suggests that CAISO monitor for any potential for “crowding out” when the new interconnection process is implemented and, if warranted, discuss potential modifications with stakeholders after observing how the process works during the first cluster. ACP-California looks forward to continuing to work with CAISO and other stakeholders to finalize a commercial interest point allocation process that maintains reasonable points for projects looking to sell their output to non-LSEs and which ensures projects that LSEs are interested in and intend to pursue can also enter the queue.

Limitations on LSE Self-Build Point Allocation

It is imperative that CAISO include limitations on the ability for LSEs to allocate commercial interest points to projects that they wish to self-build (referred to as “LSE-owned projects” in the Draft Final Proposal). This is necessary because without such restrictions LSEs might only allocate points to their own projects or may provide favoritism to their own projects over those of third-parties, providing discriminatory and preferential treatment to LSE projects over those developed by independent power producers and diminishing competition to provide generation resources to serve California customers. Because IPPs cannot “self-allocate” commercial interest points, while LSEs can, the ability for LSEs to self-allocate points must include restrictions to preserve competition. There may be a number of different approaches that could be utilized to address this concern, but the proposed simple approach of limiting LSEs to a single self-build project per cluster is a minimum requirement as part of a reasonable approach which prevents self-dealing and guards against the diminishment of competition through utilities self-selecting their own projects to enter the queue.

Point Allocation for System Need (Long Lead-Time Resources)

ACP-California appreciates CAISO’s ongoing work on long-lead time resources and the updates to the definition of long-lead time resources to correspond with the diverse resources eligible for central procurement under AB 1373 (2023) in the scoring criteria. However, we continue to believe that refinements are necessary to ensure this point category works as intended. First, CAISO should clarify that in order to receive points under this metric, the resource type seeking the points must:

1. Be included in the CPUC’s base case resource portfolio; and
2. Be eligible to be considered for central procurement under Assembly Bill 1373 (2023); and
3. Be located in an area where the TPP has approved transmission projects to provide the necessary transmission or where transmission is known by CAISO to be required in order to provide transmission for the resources in the most recent  CPUC approved base case resource portfolio.

These requirements will ensure that the sphere of resources eligible to receive long lead-time points is appropriately narrow and limited to resources that should receive such treatment. If the definition is not appropriately narrow, we are concerned that CAISO may need to implement other processes to limit the number of projects allocated these points.

Also, and importantly, we urge CAISO to expand how it considers transmission related to long-lead time resources. Rather than limiting long-lead time resources (and the associated points) to areas where the TPP has already approved the necessary transmission, CAISO should also allow resources to qualify in areas where CAISO knows that transmission approvals will be required to integrate the long-lead time resources included in a recent CPUC base case portfolio. In order for CAISO to allocate these points, it is not imperative for the transmission to already be approved. If CAISO knows that transmission will be required to integrate the resources in the CPUC’s approved base case portfolio, those resources should be eligible to receive long lead-time points (assuming they meet the other requirements as well). Take, for example, the case of north coast offshore wind. In order for these resources to receive long lead-time points, it should not be necessary for CAISO to have an approved transmission solution. Rather, if CAISO knows that transmission will be required for these resources, then once they are part of the CPUC’s approved base case, they should be eligible to receive points as a long lead-time resource. By limiting the point allocation to only areas where transmission has already been approved in a TPP, CAISO will unnecessarily prevent resources from getting in the queue at an earlier date and may, thereby, delay development efforts and extend timelines for projects to enter the queue and proceed to operation. Thus, we urge CAISO to expand the definition to allow for a more integrated and timely approach to allowing long lead-time resources to receive a point allocation under the TPD Deliverability Option. This recommendation is also in keeping with our comments below on TPD prioritization as well as the need to sync CAISO’s TPP and interconnection processes in a manner that facilitates diverse, long-lead time resource development.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

As discussed above, ACP-California urges CAISO to provide some additional details around how Energy-Only projects might interconnect under the Merchant Deliverability option. Providing a path for Energy-Only interconnections in these zones, where there is not existing or approved transmission capacity, will be important to maintaining full open access to the grid. But CAISO needs to exercise caution in the details of how Energy-Only projects can receive future deliverability (even after they enter commercial operation) when one or more different customers paid for the transmission upgrades that allow deliverability in that area. In other words, the process needs to ensure that Energy-Only interconnections in a Merchant Deliverability area are not able to “free ride” on the deliverability that customers pay for under the Merchant Deliverability Option. 

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

CAISO should be commended for providing its initial thinking on modifications to the TPD allocation process in the Draft Final Proposal, even though such modifications are likely to be approved on a separate (later) track than the rest of the IPE 2023 proposals discussed in the Draft Final Proposal. ACP-California generally supports the modifications that CAISO has proposed, while recognizing that additional discussion and details will be required to ensure there is understanding and agreement on the path forward and to ensure that the “chicken and the egg” problem of securing a TDP allocation and a PPA/short list are addressed.

Notably, ACP-California agrees with CAISO that it already possesses the tariff-based authority to reserve TPD capacity for resources that align with TPP approved transmission projects to meet specific CPUC portfolio requirements. As the process moves forward, it would be valuable for the CAISO to provide additional details on what criteria it will use to reserve this capacity, as well as which network resources could be eligible for reservation. That detail could be provided through a business practice or other process document. To ensure competitiveness, it will be imperative that the CAISO not overly rely on this authority to broadly reserve TPD capacity but also have sufficient authority to achieve deliverability for specific policy-driven resources. Thus, having additional details around the considerations that CAISO will use in implementing this tariff authority would be helpful for all stakeholders and interconnection customers.

Additionally, ACP-California notes that the proposed elimination of Group D and restrictions on Group C may create challenges for resources looking to secure a TPD allocation. As CAISO is aware, offtakers generally want to have certainty that a project will have a TPD allocation before signing a PPA. If a PPA or short-list is required to get a TPD allocation, it may present challenges, even if there are more opportunities to seek an allocation and fewer resources in the queue under CAISO proposal and associated interconnection reforms. ACP-California recommends that CAISO consider a new TPD allocation group (“Group E”). Group E could receive a “conditional” TPD allocation and could then use that conditional allocation to secure a short list or PPA ahead of the following allocation cycle.[1] While there are certainly details to be worked out, this concept deserves further exploration as the proposed TPD changes proceed forward in the stakeholder process.

Additionally, CAISO should clarify that all active projects seeking TPD allocations (including those in Cluster 14 or earlier) will be permitted the proposed maximum opportunities (three) to seek a TPD allocation. Ensuring this proposed change is applied to all active interconnection customers will provide an appropriate opportunity for earlier projects to seek an allocation and ensure equitable treatment of all projects. Furthermore, we encourage CAISO to think through whether long lead-time resources may require additional opportunities to secure a TPD allocation or other treatment (perhaps longer granting of “conditional TPD” under the Group E concept discussed above).

And, finally, ACP-California requests that CAISO provide additional time for dialog with stakeholders around the proposed restrictions on Energy Only (Group C) allocations. Notably, stakeholders should consider whether projects which are involuntarily converted to Energy Only should be provided with an opportunity to withdraw before that conversion or are provided smaller withdrawal penalties, etc. We look forward to further discussions on this matter as the proposed TPD allocation modifications move forward in the stakeholder process.

[1] Note that the proposed new “Group E” which provides conditional deliverability may be, functionally, similar to retaining a revised Group D but not allowing any allocations under Group D to count against the 150% limits applied to new resources entering the queue. ACP-California recommends classifying this as a new allocation group to provide more opportunities to rethink how it would function.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

ACP-California thanks CAISO for, within the proposed Commercial Viability Criteria, providing additional time for projects to secure a PPA should they lose a PPA due to a PTO delay. ACP-California appreciates the additional 12-months to secure a PPA in these instances.  And we appreciate that CAISO has clarified the CVC requirements do not rely on a project’s commercial operation date.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

ACP-California generally supports the CAISO’s proposal and is encouraged at the exploration of solutions to help reduce the long timelines that are being experienced for completing upgrades. While the CAISO’s proposal to secure earlier financial security postings and to require PTOs to commence activity on these upgrades within 30 days will be helpful, it is just one of many reforms that are necessary to address the persistent delays being experienced. We look forward to continuing to explore options to reduce the significant delays to upgrades in this and other forums.

Additionally, we encourage CAISO to consider options for developers responsible for shared network upgrades to delay payment of the third financial security posting if a GIA is not executed by the PTO.  

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comments at this time.

9. Additional comments:

ACP-California thanks the CAISO for its ongoing work and diligence in improving the IPE 2023 proposal. We are encouraged by the modifications made in the Draft Final Proposal and look forward to continuing to engage with CAISO to finalize this proposal and move towards implementation and engagements with Cluster 15.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

AES Clean Energy, ”AES”, appreciates the opportunity to submit comments on the CAISO’s draft final proposal.

AES appreciates the CAISO providing an updated single document with data to enable the zonal approach. AES also supports the CAISO providing a single capacity number for each zone, but seeks clarification if each zone’s capacity number will be the accepted MWs for each Transmission Plan Deliverability (TPD) zone. If so, AES seeks clarification on when the CAISO will provide the single capacity numbers for each zone for each year. 

AES supports the proposed data including the single line diagrams, transmission constraints in each zone, list of substations in each interconnection area, POIs behind constraints, and allocated TPD.  However, AES is disappointed that CAISO cannot provide critical information needed for the zonal approach including short circuit data, breaker ratings, and POI feasibility. Regarding POI feasibility information, the CAISO incorrectly states, “PTOs have provided within their interconnection handbooks known substations where there is not capacity to interconnect.”[1] PTO interconnection handbooks do not provide design standards nor a list of unavailable substations.[2] The CAISO sets the data requirements for interconnection studies.  Since the CAISO is the central clearing house in enabling the zonal approach, the CAISO should ensure that interconnection customers have the necessary information to submit the readiest projects. It is AES’s understanding that CAISO already receives this information from the PTOs.   If the CAISO does not provide the additional necessary information, at minimum, the CAISO should include: (1) the breaker ratings in the short-circuit models in the Cluster Study Interconnection Area Reports and (2) include all attachments to the published Appendix A individual interconnection reports with confidential information removed. AES is concerned with the timing mismatch of the proposed generic timeline. The CAISO should not open the request window until after the TPD allocation study. Developers need to be clear on the level of deliverability available prior to submitting applications, and the CAISO will also need to know how many MWs to accept in each study cycle. CAISO has stated during the February 15, 2024 stakeholder meeting that changing the TPD allocation study could disturb the timing of the Transmission Planning Process studies. If study timelines are a concern, then AES recommends the CAISO to take a TPD vintaging approach, by reserving a portion of the TPD from the current TPP cycle for the following cluster. For example, the results of the 2023-2024 TPP would be reserved for Cluster 15, and the results of the 2024-2025 TPP would be reserved for Cluster 16. This approach would allow the CAISO to conduct the TPD allocation study after the request window since a portion of the previous year’s TPP would be reserved for the upcoming cluster.

AES also seeks clarity on the proposed generic timeline with respect to CAISO’s intent to move into a single-phased study process. The proposed generic timeline assumes that cluster studies, restudy, and interconnection facilities studies are separate phased studies. If CAISO intends to move forward with a single-phased study, the generic timeline should be updated. Under the single-phased study process, the CAISO should also clarify: (1) how restudies would be performed and (2) whether the existing cost cap for network upgrades would apply.

In the near term, AES appreciates the CAISO’s willingness to provide the list of substations in each interconnection priority zone by the end of February. However, given that the TPD allocation studies conclude in May, the results may affect the boundaries of each zone. AES recommends the CAISO to update the list of substations in each interconnection priority zone after the TPD allocation study results so customers can accurately locate the interconnection priority zones for Cluster 15.

[1] Draft Final Proposal, p.24,

[2] See for example: https://www.sce.com/sites/default/files/custom-files/Web%20files/SCE_InterconnectionHandbook.pdf

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

AES does support exempting Energy Only Resources from the 150% study cap, but it does not support requiring Energy Only projects be subject to the scoring rubric and be held to the same standards as TPD projects. AES understands the CAISO’s intent to ensure that Energy Only projects have the same level of readiness and that Interconnection Customers don’t abuse Energy Only projects as a “work-around” the study cap. However, as the revised scoring criteria stand, Energy Only projects are not eligible to meet most of the criteria. As illustrated in Example 3 below, Energy Only projects can at most receive 21 points. LSEs would likely not allocate points to Energy Only projects since the points are based on the LSE’s available deliverability. The system need category would not apply to Energy Only projects. Based on the scoring criteria, Energy Only projects would not have equal access for entry. 

Instead, the CAISO should approach Energy Only projects similar to Merchant projects. Energy Only projects would also be required to meet 90% site control requirements and study deposits. These projects should also be required to pay a commercial readiness deposit of $4,000/MW. The higher entry fees would incentivize the most ready Energy Only applications to enter the queue. Using this approach, the CAISO should also allow Energy Only projects into Merchant zones.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

AES appreciates the CAISO’s revised scoring criteria. AES supports the removal of permitting within the scoring criteria. However, AES is concerned that the revised scoring criteria do not provide enough granularity in the project viability and system need categories, leading to the commercial interest being the main determinant of selected projects. Below, AES provides examples of mock scoring to demonstrate how commercial interest will be the final determinant of projects being selected for studies.

Example 1: Project with LSE interest 

Commercial Interest (30%) 

• LSE allocation: 100 points  
• Total category points: 30  

Project Viability (35%) 

• 20% Engineering Design: 20 points 
• Expansion of gen facility: 10 points 
• 100% site control of gen tie: 40 points 
• Total category points: 24.5  

System Need (35%)

• Local RA: 50 points 
• Total category points: 17.5  

Scoring Total: 72 points 

----------------------------------------------------

Example 2: Project with non-LSE interest 

Commercial Interest (30%): 

• Non-LSE interest: 25 points  
• Total category points: 7.5  

Project Viability (35%) 

• 20% Engineering Design: 20 points 
• 100% site control of gen tie: 40 points 
• Total category points: 21 

System Need (35%) 

• Local RA: 50 points 
• Total category points: 17.5  

Scoring Total: 46 points

In the examples above, the project viability categories have similar points, while the system needs category points are the same. Given that the project viability and system need category points are similar, this would mean that LSE interest is the final determinant of projects entering into the studies. Projects are also at risk of having the same score if given the same allocation points from the LSE or non-LSE. To increase point granularity in the scoring criteria, AES recommends the CAISO revise the project viability category. Instead of granting points to projects with 100% site control of gen tie, the CAISO can grant points up to the level of gen tie secured by interconnection customers. For example, interconnection customers can get 5 points per 10% of the gen tie secured.

AES supports the inclusion of non-LSEs in the commercial interest category, but believes that non-LSE interest criteria should be increased to a minimum of 50 points. As the proposal stands, at 25 points, projects with non-LSE interests would likely not be competitive in the selection process. To ensure equitable competition between LSE and non-LSE projects, the non-LSE criteria points should be increased. In addition, the CAISO should clarify what entity qualifies as non-LSE. For example, do non-LSE need to have Market Base Rates filed at FERC?

Regarding engineering designs, the CAISO should provide clearer definitions of the different proposed percentages. Although the CAISO recommended alignment with the Association for the Advancement of Cost Engineering (AACEI), these cost guidelines do not provide enough clarity to delineate engineering design percentage thresholds. The proposed design percentages do not align with the Class V – Class I cost definitions as defined by the AACEI.[1] AES recommends the CAISO provide definitions that include the package required to meet the proposed engineering design percentages. The engineering design definitions should include items, such as long lead time equipment count, general arrangement with total system size, and developer substation single line diagram showing metering and protection, parcels/easements, and site layout indicating multiple gen tie routes. Including clear definitions of required items for each design percentage will eliminate potential disputes as each developer may have different definitions for each design percentage.

Expansion of the generating facility under construction and expansion of operating facility should have higher point value should as incumbents have demonstrated experience in building a project to operation. AES recommended increasing the expansion of the generating facility under construction to 20 points and the expansion of operating facility to 30 points.

In addition, as discussed above, the scoring criteria would preclude Energy Only projects from entering the queue as the criteria do not apply. Below is an example of a mock Energy Only project scoring.

Example 3: Energy Only Project  

LSE Interest (30%) 

• LSE allocation: 0 points  
• Total category points: 0  

Project Viability (35%) 

• 20% Engineering Design: 20 points 
• 100% site control of gen tie: 40 points 
• Total category points: 21  

System Need (35%)

• Local RA: 0 points 
• Long Lead Time Resource: 0 points
• Total category points: 0 

Scoring Total: 21 points 

Energy Only projects would not receive points in either LSE interest or system need given the options under the categories. The mock score of 21 points would not allow projects to enter into interconnection studies as the examples above show a minimum score of 46 points.

[1] Table 1. Association for the Advancement of Cost Engineering. Cost estimate classification system. https://web.aacei.org/docs/default-source/toc/toc_18r-97.pdf?sfvrsn=4

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

 AES continues to urge the CAISO to allow projects that are unselected through the scoring process and Energy Only projects to continue as Merchant projects. If companies are willing to self-fund network upgrades within the priority zones, the CAISO should allow this to occur. The additional network upgrade built by self-funded projects provides additional grid benefits beyond the project's interconnection. The CAISO stated that allowing Merchant projects in priority zones would result in studying capacity in those zones potentially well above the 150% threshold and would be counterproductive to solving the issue identified in the problem statements of studying capacity levels so high that the study results lose accuracy, meaning, and utility. To prevent this issue, the CAISO can study TPD projects first, then study Merchant projects to prevent the loss of study accuracy. Merchant projects in the interconnection priority zones can help increase generation supply and help keep any potential market power in check by increasing competition. Merchant projects could also provide a cushion and more margin of error if the state’s resources planning process do not identify enough resources to cover increases in demand as they materialize in the future.

AES continues to be concerned that cost recovery of ADNUs will continue to be a roadblock in making the Merchant option viable.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

AES believes that the TPD allocation process modifications warrant further discussion to understand the implications of the changes. AES recommends that CAISO defer the proposal and bring it to the Board of Governors in July 2024. The CAISO should provide an analysis of how the removal of Group D allocation group would affect available TPD for future clusters with the zonal approach. AES’s initial concern is that the removal of Group D allocation group could exacerbate the issue of entities signing PPAs with multiple exit clauses determined by whether the project receives TPD; this could deflate the value of offtake agreements. AES opposes the CAISO’s proposal for limiting existing Energy Only projects to apply for allocation Group C (commercial operation). Existing Energy Only projects are further in development and in some cases, such as Cluster 13, were forced to convert to Energy Only due to the lack of TPD. AES believes it would be unfair to subject existing Energy Only projects to new TPD allocation rules.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

AES understands the CAISO’s proposed commercial viability criteria (CVC) and time in queue requirements. AES seeks clarification if these requirements would also apply to Energy Only projects. Regarding the 3^rd interconnection financial security posting requirement, the CAISO should clarify what portion would be at risk. Finally, the CAISO should elaborate further on the permitting requirements for the CVC. For the initial report, does a list of all permits suffice? For the annual reports after the CVC requirement, is there a minimum threshold that permitting needs to meet in order to meet CVC?

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

AES supports this proposal and recommends that CAISO clarify that the policy would apply to all shared network upgrades, such as deliverability network upgrades, reliability network upgrades, and local area network upgrades.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

AES supports the modified proposal for it to become voluntary to amend GIA nine months prior to synchronization. On a similar note, SCE opposed the original proposal, stating that the project scope changes through MMAs submissions and that the PTO should not be required to finance costs associated with incremental scope changes triggered through a modification. AES is concerned that developers are not provided with the most up to date scope and cost when submitting a modification.  If there is not a requirement to provide this scope and cost updates, the PTOs will miss additional information that is key to developers. In AES’s experience, the amended scope has been missed by the PTOs or is not comprehensive in relation to the previously assigned scope, resulting in additional changes in a later process (i.e. execution) that shifts unknown financial risk to the developers. PTOs should be responsible for updating the scope that was originally identified in the studies through a modification. AES recommends that the PTO be responsible for providing a more comprehensive integration of the modification into the past report. This would further support the CAISO’s goals of having developers submit project ready and viable projects and modifications in a timely fashion.

9. Additional comments:

AES is immensely concerned about the lack of timing certainty to reengage with Cluster 15. AES understands that CAISO cannot implement IPE Track 2 until all compliance filings, including CAISO’s Order 2023 compliance filing and IPE Track 2 compliance filing, are accepted.  To mitigate timing uncertainty, the CAISO should reengage with Cluster 15 on April 1, 2025, or 60 days after FERC acceptance of all compliance filings, whichever date is later.

The CAISO should also amend the FERC-approved tariff in IPE Track 1 (Appendix DD, Section 17.1) given the timing delays of cluster 15 and clarify the one-time modifications allowed. The current tariff contains upcoming dates that will become moot given the pending IPE Track 2 changes and Order 2023 compliance filing. In addition, the tariff states the one-time modification period will commence between May 1, 2024 and September 26, 2026, and allow customers to make modifications permissible under Section 6.7.2.2(a)-(h).[1] However, the tariff language under Section 6.7.2.2(a)-(h) does not conform with the Final Track 1 proposal that was published.[2] Section 6.7.2.2(a)-(h) describes the allowed modifications at the time of Phase 1 Interconnection Study Results meeting, and not the unique modifications that were permissible under IPE Track 1. Particularly, Section 6.7.2.2(a)-(h) does not explicitly state that projects can make a POI modification within a study area, although the Final Track 1 proposal allows for this modification.  AES requests the CAISO to amend the tariff to clarify the modifications, particularly changing POIs within a zone, that are allowed unique to Cluster 15 projects.

[1] Appendix DD, Section 17.1.

[2] IPE Track 1 Final Proposal, page 8.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

The Bay Area Municipal Transmission Group (BAMx)^[1] appreciates the opportunity to comment on the CAISO’s 2023 Interconnection Process Enhancements Track 2 Draft Final Proposal (“Draft Final Proposal,” hereafter) and the subsequent workshop held on February 14, 2024.

BAMx supports this initiative's central tenet, prioritizing projects in areas with available transmission capacity for progression into the study process. This Draft Final proposal reflects the first principle established by the working group to “Prioritize interconnection in areas where transmission capacity exists, or new transmission has been approved while providing opportunities to identify and provide alternative points of interconnection or upgrades.”[2] BAMx also supports the element of the Draft Final Proposal, which allows the option to self-fund network upgrades through a modified “Merchant Deliverability” process to the projects or interconnection requests outside the zones.

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

[2] Draft Final Proposal, p.24.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

BAMx finds this section of the Draft Final proposal reasonable because the Energy Only resource capacity will not count toward the 150% cap. BAMx appreciates that the 150% cap is based on Transmission Plan Deliverability capacity, and the inclusion of Energy Only projects would increase the number of projects that advance to the study process but would not increase the deliverable capacity to be studied.[1]

[1] Draft Final Proposal, p.30.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

With any scoring process, BAMx strongly supported, including any project that a non-CPUC jurisdictional Load-Serving Entity (LSE) demonstrates is a preferred resource in its resource plan approved by its Local Regulatory Authority (LRA).[1] This element of the Straw Proposal provided similar treatment to non-CPUC LRAs as the CAISO has provided to the CPUC LRA by prioritizing the CPUC-provided portfolio resources in the annual TPP. However, we are disappointed that this element of automatic study inclusion has been eliminated in the Draft Final proposal.

BAMx believes that the current study process is unfavorable to non-CPUC jurisdictional LSEs. The joint agency (CPUC/CEC/CAISO) MOU does not include these LSEs or their LRAs as signatories, and these LSEs have not historically been included in the TPP. The proposal to incorporate them in the TPP going forward is a welcome change but does not correct the fact that multiple prior clusters are still being studied against a TPP that does not consider non-CPUC LRA resource needs.

BAMx supports using LSE interest points to allow LSEs to indicate projects they need to meet regulatory and other requirements. The LSE-interest scoring criteria would assure comparable access to the interconnection process for non-CPUC jurisdictional LSEs by ensuring they receive sufficient LSE-interest points to have a meaningful opportunity to designate needed projects. The LSE interest points mechanism is already designed to limit the use of LSE interest points to a percentage of the overall transmission capability available. It is important to note that LSE interest points also contribute only 35% of the overall points potentially obtainable.[2] This leaves plenty of room for other projects to earn points for other sources.

In the draft Final proposal, the CAISO proposes that LSEs may only award points to one self-built project each cycle. In particular, if an LSE opts to use the full allocation election for a self-built project, that election may not exceed 150% of that LSE’s total capacity allocation for the cluster.^[3] BAMx finds such limitations on the LSE-owned projects to be arbitrary and discriminatory. The Draft Final Proposal allows merchant generators to receive points for any or all of their projects, while LSEs may only receive points for some of their own projects. This seems to be unduly discriminatory. BAMx supports Northern California Power Agency’s (NCPA) comments on the Draft Final Proposal on why LSEs pursuing self-build projects is not discriminatory to the FERC Open Access principle, especially as FERC does not deal with LSE procurement processes, which is LRA-jurisdictional. In summary, BAMx strongly opposes any limitations on LSE-owned projects, especially for the non-CPUC jurisdictional LSEs.

BAMx also supports NCPA’s request that the Draft Final Proposal should be updated to clarify that multiple LSEs can aggregate their Full Allocation Election priority interest in one project when the individual LSEs participating in the aggregation do not have sufficient aggregate capacity to allocate to that project’s full MW size, including the 150% capacity threshold being included for the group of LSEs selection for a single preferred project election.

[1] Straw Proposal, p.26 and CAISO Workshop Presentation, p.23.

[2] Draft Final Proposal, p.39.

[3] Draft Final Proposal, p.41.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

BAMx believes the following elements in the Draft Final proposal to be reasonable.

• Only projects seeking to interconnect in areas that have no available or planned TPD capacity are eligible to select the Merchant option.
• Merchant option projects are not eligible to seek to interconnect in zones with available capacity, and projects not selected to be studied in these zones cannot switch to the Merchant option.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

 No comments at this time.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

 No comments at this time.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

 No comments at this time.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

 No comments at this time.

9. Additional comments:

 No comments at this time.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) Interconnection Process Enhancements (IPE) Draft Final Proposal. The Draft Final Proposal reflects the CAISO’s ongoing collaboration with stakeholders to improve the interconnection queuing and study processes to align them with transmission planning, resource planning, and resource procurement. It further solidifies important improvements to the interconnection process that will enable it to keep pace with the need for new capacity on the system to support reliability and greenhouse gas (GHG) emissions reduction goals.

CalCCA supports the CAISO’s commitment to providing data to stakeholders to support the zonal approach. The data will be critical for developers, who must plan their proposed projects in locations where transmission capacity exists or is planned. It will also be critical for load-serving entities (LSE), who will evaluate and procure proposed projects based on their ability to meet system reliability and GHG-reduction targets, their compliance obligations, and their customers’ needs and preferences. Data transparency before the submittal of interconnection requests and before LSE interest scoring should result in a zonal approach to interconnection that is aligned with transmission planning, resource planning, and resource procurement.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

CalCCA has no comments on this element of the Draft Final Proposal at this time.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

LSE Interest Scoring Criteria

CalCCA supports most elements of the Draft Final Proposal as it relates to the scoring criteria for prioritization in the study process. The CAISO’s proposal recognizes the importance LSE interest will play when narrowing down the pool of interconnection study requests. LSEs, as procuring entities, conduct long-term planning activities in their individual integrated resource plans, where they start to identify the technologies, locations, and magnitudes of projects they will pursue to support the communities they serve. This information is factored into the California Public Utilities Commission’s (CPUC) preferred system plan, which then informs the CAISO’s transmission planning process. Without an LSE interest scoring criteria, the CAISO would risk having an interconnection queue that is not aligned with resource and transmission planning processes taking place in these forums. Under a zonal approach that does not study all interconnection requests submitted, the CAISO must ensure that the requests that do get studied result in an interconnection queue that offers a diverse set of resources. Scoring criteria that reflect LSE interest can drive a balanced interconnection queue because LSEs must procure a range of technologies to meet reliability and GHG-reduction targets in a cost-effective manner that meets their customers’ needs and, for some LSEs like community choice aggregators, directives from their boards. Indeed, the need to have balanced resources to meet load profiles throughout the day is important not only for Integrated Resource Plan (IRP) but are increasingly important to meet RA obligations as hourly needs for capacity are increasing. 

The result of CAISO’s project scoring should be an interconnection queue that reflects LSEs’ desired resource mix planned for in resource planning processes like the CPUC’s IRP proceeding. A 30 percent weighting for LSE interest balances the need for LSEs to help drive interconnection studies without making LSE interest a determining factor that impinges on the ability for other interconnection requests to move forward. For these reasons, the CAISO should adopt its proposal to allow LSEs to score projects based on their interest to inform the interconnection study requests the CAISO studies.

The CAISO must, however, reconsider its proposal to require LSEs to submit their interest scores at the same time interconnection customers submit their interconnection requests. The CAISO should modify the draft final proposal to (1) have the CAISO issue a simple report with project name, technology, point of interconnection, developer name, and megawatts (MW) for each interconnection request received, and (2) allow LSEs to use this report to finalize their interest scores and submit them one month after the issuance of the report. These proposed modifications would allow LSEs to review interconnection requests and finalize their interest scores in parallel with other work the ISO will be doing to validate interconnection request information before starting the cluster study.

This process is superior to requiring LSEs to submit their interest scores based solely upon requests for information (RFI) because it allows LSEs to review interconnection requests, compare the requests to the results of their RFIs to ensure consistency, and submit interest scores that correctly reflect projects they are interested in as communicated in the interconnection request. Requiring LSEs to submit their interest scores before seeing the interconnection requests submitted seems prone to errors that could require more work for the CAISO to validate.

Based on the proposed schedule posted on the CAISO’s website,[1] this would result in LSEs conducting RFIs in advance of interconnection customers submitting their interconnection requests by July 31, reviewing interconnection requests in August, and finalizing and submitting their interest scores by late August or early September. When finalizing the timeline, the CAISO should clarify when it will allocate capacity/points to LSEs. Such information should be provided well before LSEs submit their interest scores to the CAISO.

Self-Built Projects

The CAISO proposes to only allow LSEs to submit points to one self-built project per cycle. The intent of this proposal is to prevent LSEs from giving preferential treatment to their own projects. The CAISO should remove this limitation due to its potential unfair impacts on different LSEs. A single project could be 1 MW or 1,000 MW. Basing a limitation on number of projects would benefit LSEs who can self-build one large project over those who can self-build multiple small projects. It also makes the possibility of assigning points to projects that are jointly built by multiple LSEs more difficult. If the CAISO determines some sort of limitation on assigning points to self-built projects is needed, it should create a limit based upon a share of the LSEs’ allocated points rather than number of projects (e.g., an LSE can only allocate half its points to self-built projects). This would avoid over-preference on self-built projects without eliminating the possibility of building more than one project.

Auction

The CAISO proposes to conduct a market-clearing, sealed-bid auction for the right to be studied if excess proposed capacity exists after applying the viability criteria and projects are deemed equal in viability rating. For the reasons described in previous comments,[2] the CAISO should, instead of developing an auction, focus on scoring criteria robust enough to rank projects’ viability and minimize occurrences of equal viability scores among projects. If projects do receive the same viability score, the CAISO should study all tied projects.

Non-LSE Points

The CAISO proposes to allow non-LSEs, like commercial entities, to assign up to 25 points to projects if the commercial entities can provide signed affidavits indicating and affirming commercial interest from its procurement division. Prior to this addition, the proposed scoring criteria only allowed for scoring by entities that have a tariff-defined relationship with the CAISO (i.e., LSEs). The CAISO now proposes to allow a non-LSE commercial entity to apply points. The CAISO notes concerns that without a tariff-based relationship, the CAISO will need to carefully evaluate the legitimacy of such requests. The CAISO notes that it is “is reluctant to provide a definition or criteria” to further define how the CAISO will implement this feature. This represents a significant departure from how entities with a relationship to the CAISO interact with the CAISO. For those entities, the tariff and business practice manuals clearly define expectations and are transparent to all market participants.   In the Final Proposal, the CAISO should better define the process that will be used to allow non-LSEs to assign points so that the process is transparent and subject to a tariff. Not only will this ensure that points are only assigned by legitimate entities but the process will be transparent and have a process through FERC to resolve any disputes of the application of the tariff.

Additionally, if the CAISO allows non-LSEs to assign points to interconnection requests, it should ensure it maintains a prioritization process in the deliverability allocation process that prioritizes non-LSE projects that have Resource Adequacy (RA) contracts with LSEs over those that do not have RA contracts with LSEs. This will ensure deliverability is assigned to projects that will actually be used as RA.

Long-Lead Time (LLT) Resource Category

The CAISO proposes to give points to interconnection requests that will address system needs, including the need for LLT resources. CalCCA supports the LLT resource category. This category, along with the LSE interest category, appears to be the mechanism that will be relied upon to ensure resource diversity among the portfolio of projects selected for study. While the Draft Final Proposal indicates resources required to meet the CPUC resource portfolio are eligible, the CAISO should update the Final Proposal to provide more clarity around how it will categorize LLT resource for the purpose of assigning points. It appears the Draft Final Proposal adopts some of CalCCA’s recommendations on the process for defining LLT in its January 9, 2024 comments,[3] additional clarity would be helpful to ensure the definition (1) reflects actually needing a long period of time, such as five years or more, to construct from the initial proposal, not inclusive of the period spent in the CAISO interconnection queue, (2) includes priority for resource types that are needed, as defined by the CPUC in its IRP process, but underrepresented in the CAISO queue, and (3) assigns LLT resource points to interconnection requests that fit the definition regardless of the type of LSE procuring, (e.g., central procurement entity, groups of LSEs, or single LSE).

Ensuring Competition Among Developers Contracting with LSEs

If the CAISO implements a transmission zone-based approach that limits the amount of interconnection requests based on existing and planned transmission capacity, the CAISO must ensure sufficient interconnection capacity is studied to maintain competition among developers contracting with LSEs to meet LSE procurement obligations. Studying capacity up to 150 percent of the available and planned transmission capacity is too limiting, especially in light of the fact that the CAISO decided to forego its proposal to put a cap on the number of interconnection requests it would study from a single developer. The ISO plans the transmission system based on resource portfolios the CPUC projects will be needed to support reliability and policy goals. LSEs will ultimately need to procure capacity consistent with those plans. If the ISO only studies 150 percent of the amount of capacity needed to support reliability and policy goals, LSEs may experience significantly reduced bids in their request for offers (RFO) relative to their procurement needs. Past experience also shows that many projects do not ultimately proceed in the development process and may drop out after submitting their interconnection request but before the contracting process. While some projects may offer to multiple LSEs, multiple LSEs may have interest in the same project, too. Using 150 percent as the overall ratio of total capacity to total need is likely too low to ensure competition among developers competing for contracts with LSEs. The CAISO should study as much capacity as maintains the usefulness of the study results, but at least 200 percent of the available and planned transmission capacity.

[1]   https://www.caiso.com/InitiativeDocuments/ProposedSchedule-InformationAvailability-InterconnectionStudyProcess.pdf.

[2] https://stakeholdercenter.caiso.com/Comments/AllComments/db2a7c50-3962-46ad-b217-59749bef1704#org-cefa3c17-c05a-494f-8e8e-9d8e1c470eeb.

[3] https://stakeholdercenter.caiso.com/Comments/AllComments/db2a7c50-3962-46ad-b217-59749bef1704#org-cefa3c17-c05a-494f-8e8e-9d8e1c470eeb

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

The CAISO proposes that only projects interconnecting in areas with no available or planned transmission deliverability capacity would be eligible to use the merchant deliverability option. The merchant deliverability option would not be available for projects that did not score enough to be studied in the transmission zones with planned or available capacity. The CAISO should modify this proposal to allow projects within transmission zones to elect to move forward using the merchant deliverability option. If the CAISO anticipates an influx of merchant deliverability projects after the implementation of IPE 2023, the CAISO could consider additional requirements to ensure the merchant deliverability projects do not overwhelm the interconnection queue, like requiring interconnection customers to select the merchant deliverability option up front or limit the amount of merchant deliverability projects that can move forward through the same scoring criteria used by projects electing not to use the merchant deliverability option.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

The Draft Final Proposal indicates that the scoring process for allocating transmission plan deliverability (TPD) will be determined once the scoring process for interconnection intake is completed. When defining the scoring process for allocating TPD, the CAISO should aim to align it with the scoring criteria for interconnection intake as much as possible, so that the projects deemed most ready are first to receive TPD allocations.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

The CAISO should adopt its proposal to require all projects in the queue to demonstrate commercial viability to remain in queue beyond seven years, regardless of deliverability status. The CAISO should also adopt its proposal to require each project to meet commercial viability criteria by an unavoidable time-in-queue requirement. These changes should prevent the stagnation of projects in the interconnection queue without a clear process for moving them forward or removing them from the queue.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

CalCCA has no comments on this element of the Draft Final Proposal at this time.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

CalCCA has no comments on this element of the Draft Final Proposal at this time.

9. Additional comments:

CalCCA has no additional comments on the Draft Final Proposal at this time.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) provides these comments on the California Independent System Operator’s (CAISO Interconnection Process Enhancements), 2023 Phase 2 Revised Straw Proposal.? Cal Advocates is an independent consumer advocate with a mandate to obtain the lowest possible rates for utility services, consistent with reliable and safe service levels, and the state’s environmental goals.[1]

Cal Advocates supports the CAISO’s proposed generic timeline, which includes posting of Transmission Plan Deliverability (TPD) Heat Maps eight (8) months before the opening of the Interconnection Request submission window.[2]  Cal Advocates supports the CAISO’s proposal to increase the accessibility of grid information by consolidating the available information, along with lists of substations and constraints in each transmission zone, into a single-user accessible data source.  Cal Advocates supports CAISO’s development of TPD Heat Maps to comply with Federal Energy Regulatory Commission (FERC) Order 2023.

Cal Advocates supports the CAISO proposed study timelines indicating completion of Cluster Study within 150 days which complies with FERC Order 2023.

[1] CAISO Draft-Final-Proposal-Interconnection-Process-Enhancements 2023 Initiative - Track 2, February 8, 2024, pp. 14-28, DraftFinalProposal-InterconnectionProcessEnhancements2023.pdf (caiso.com)

[2] Public Utilities Code Section 309.5.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Cal Advocates supports the CAISO proposal that the process of submitting and reviewing interconnection requests be the same for all projects seeking Full Capacity Deliverability Status (FCDS), Partial Capacity Deliverability Status (PCDS), and Energy Only Status.  In doing so, the CAISO proposal appears to provide equal and non-discriminatory access to the transmission system for all Interconnection Customers submitting Interconnection Requests.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

No comment

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

Cal Advocates supports the CAISO proposal to have the developer of a Merchant Deliverability Option project  finance all of the delivery network upgrades necessary to connect that project to CAISO service area.[1]  In addition, CAISO customers should not compensate the developer for funds used to construct the required Area Deliverability Network Upgrades (ADNUs) for a Merchant Deliverability project.

Implementation of this CAISO proposal protects ratepayers from additional TAC charges.

[1] CAISO Draft-Final-Proposal-Interconnection-Process-Enhancements 2023 Initiative - Track 2, February 8, 2024, p. 59-62.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

No Comment

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

Cal Advocates supports the CAISO proposal for implementing strict Commercial Viability Criteria (CVC) and time-in-queue requirements for all projects in the generation interconnection queue.[1] The CVC requires Interconnection Customers in the queue to demonstrate commercial viability by showing both a signed Generation Interconnection Agreement and an executed Purchase Power Agreement within seven (7) years of submission of the proposed project Interconnection Request.

Reducing the number of non-viable projects in the queue through implementing strict Commercial Viability Criteria (CVC) and time-in-queue requirements for all projects would reduce delays to viable projects reaching their Commercial Operation Date and help California meet its climate change goals.    By implementing strict CVC and time-in-queue requirements, the CAISO can utilize its resources more efficiently which in turn should lower costs to ratepayers.

[1] CAISO Draft-Final-Proposal-Interconnection-Process-Enhancements 2023 Initiative - Track 2, Feb 15, 2024, pp. 80-89.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

Cal Advocates supports the CAISO proposal that the designated Participating Transmission Owner will have 30 days to commence the transmission upgrade project upon receipt of all Resource Developers financial security deposits for Shared Network Upgrades as specified in the Generation Interconnection Agreements.[1]  The proposed improvements in this process should lead to more certainty in the completion of generation interconnection transmission grid upgrades and deliverability of new resources to support customer loads. 

[1] CAISO Draft-Final-Proposal-Interconnection-Process-Enhancements 2023 Initiative - Track 2, Feb 15, 2024, pp. 92-97.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

Cal Advocates acknowledges the CAISO’s efforts to address inefficiencies in executed Generator Interconnection Agreement contract management.[1]   Cal Advocates supports revising the timing of updating Amendments to an executed Generation Interconnection Agreement (GIA) in order to expeditiously incorporate project modifications reducing time and resources executing changes to the GIA.  The CAISO reports that the GIA must be changed each time an Interconnection Customer (Resource Developer) submits a Material Modification for a proposed project.  Continuous revisions to projects through the current Material Modification Assessment (MMA) process then require that contract negotiators for the Interconnection Customer, CAISO, and Participating Transmission Owner (PTO) work together to update changes to the GIA.  PTOs and CAISO are required to continually amend the GIAs.  From 2021 to date, the CAISO and PTOs have serially processed 376 MMAs. To reduce this time-consuming effort, CAISO’s Draft Final Proposal proposes that the MMA Results Report, which incorporates any change to scope, schedule, or cost, be the binding document and that the GIA would only be amended once.  By addressing the timing of GIA Amendments issue, CAISO, PTO, and Resource Developer resources would be more efficiently utilized which in turn lowers costs to ratepayers.

[1] CAISO Draft-Final-Proposal-Interconnection-Process-Enhancements 2023 Initiative - Track 2, Feb 15, 2024, pp. 97-100.

9. Additional comments:

No Additional comments.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

CalWEA recommends that the timeline also include the following information:

• Show when the three TPD allocation opportunities start for a particular cluster.
• Show when the CPUC provides its specific IRP resource portfolios to be used by the CAISO for its queue entry selection.
• Show when the available capacity information will be published by CAISO.

Since the TPD allocation study happens in parallel with the cluster window that is underway, the projects going through the TPD allocation process are not counted against the capacity ostensibly available for the next queue cluster. The consequence is that, while queue entry is eased, interconnection customers (ICs) will find it to be more difficult to get a TPD allocation once the study process is completed unless CAISO ensures sufficient ADNU (policy upgrade) capacity is added to the grid as part of its cluster study(ies) – which itself can take many years to complete.  So, while the proposed process requires ICs to achieve a very high level of readiness, the timeline inherently creates a high level of uncertainty regarding the availability of timely TPD capacity.  This increased risk of the costly study process will limit developer participation and is one reason why CalWEA objects to the overall proposal (see response to Question 9).

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Requiring EO projects to go through the same scoring process as projects requesting FCDS will make it nearly impossible for EO projects to proceed.  At points of interconnection (POIs) where no FCDS is available, the proposal prevents EO projects from being studied simply because FCDS resources cannot be studied, which does not make sense. Where FCDS is available, LSE allocation points will presumably go to FCDS applications, which will prevent most, if not all, EO projects from being studied.

EO requests should be allowed in all zones purely based on project readiness independently of FC availability or requests. Alternatively, CAISO could use the EO resources in the CPUC’s IRP resource portfolio to identify a zonal EO study limit for each zone.  

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

CalWEA first reiterates previously stated concerns that CAISO’s overall proposal is fundamentally flawed because it moves the study process forward for a small minority of early-stage projects absent the information that is most important to project viability:  transmission upgrade costs and timelines.  Thus, the entire process upon which projects are proposed to be advanced rests on subjective control by LSEs and subject to anti-competitive behavior by developers, and thus is likely to leave many projects behind that could otherwise prove to be the most attractive and viable.  Moreover, because the proposed process will drive applications and LSE selections to local capacity reliability (LCR) areas where development costs are typically much higher(suitable for developers with deepest pockets) and large-scale solar and wind development are simply infeasible.

Nevertheless, we offer the following recommendations to marginally improve the proposed process. 

Commercial interest

The LSE-interest scoring element provides too much subjective control over the process by LSEs without these LSEs having any information about the transmission impact of the resources they are selecting.  To address this, CAISO should:

• reduce the LSE-interest score to a maximum of 20% of the total score;
• adopt the CAISO proposal to limit each LSE to scoring only one of the LSE’s sponsored or affiliated projects per cycle;
• further develop the CAISO proposal to also award points for projects with documented commercial interest from non-LSE off-takers, which should be consistent with the point system for LSE interest; and
• establish guidelines to ensure a transparent and objective process for the allocation of points.

In its next paper, CAISO should explain how total available capacity on the system is calculated and should provide a realistic estimate of that capacity. This figure should be used in the example illustrating the process.

Project viability:

• It is not clear how the AACEI cost estimate classification helps to define the percentage of engineering design plan completeness. In any case, engineering design plans are only a matter of expense, increasing the cost of development without differentiating the viability of projects, and this criterion is therefore not a useful indicator of project viability.

System need:

• Long lead-time (LLT) resources (a term that requires further consideration as discussed below) should not be placed in the same scoring system as other resources. Elsewhere in the proposal, CAISO proposes to reserve TPD capacity for such resources in the resource portfolio.  Such reservation will require a separate scoring process for LLT projects in which LLT projects would compete only against each other for the reserved TPD capacity. Non-LLT projects behind the same constraint would compete for any remaining capacity.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

This element of the proposal requires further clarification: “The ISO will calculate a single capacity number for each zone, which will be based on the CPUC portfolio. These zonal capacity numbers will be used to designate Transmission Plan Deliverability zones and Merchant Deliverability zones.” Please clarify whether the CPUC portfolio will serve as the CAISO’s base portfolio and whether the zonal capacity is the total FC capacity in the base portfolio.

Regarding this statement: If the Merchant Deliverability project(s) has not executed a GIA, and the ADNU has not been included in the TPP base case, projects are released from funding the ADNU and be refunded once GIA executed. The project retains the deliverability for two years, with a retention requirement of meeting TPD allocation Group A or B within the next two years. Converting to EO if it can't retain. If the Merchant Deliverability project(s) has executed GIA, and the ADNU has been included in TPP base case as a merchant ADNU, the project continue funding the ADNU and proceed as MD” -- these two paths could leave a gap, where some projects may not fall into either path. CalWEA recommends that, regardless of GIA status, a project be able to choose one of the options right after ADNUs are approved in the TPP.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

CalWEA supports the proposal to reserve TPD capacity for “long-lead-time” resources with some modifications:

• The nebulous term “long-lead-time” (which could encompass any resource awaiting transmission) should be replaced with “location-constrained resources” – i.e., projects that tap resources that exist in limited locations on the CAISO grid – and that are contained in the resource portfolios of the CPUC or other Local Regulatory Authority.  CAISO should request that LRAs identify such resources in their resource portfolios. 
• CAISO should clarify that location-constrained resources may be supported by existing transmission as well as newly approved transmission upgrades.
• As discussed in response to question 3, the scoring process for queue entry should align with the TPD capacity reservation.
• CAISO must place phantom projects, equal to the capacity being reserved, in the base case so that needed capacity throughout the system will be reserved.

In addition:

• Energy Only projects, especially ones that have converted to EO due to lack of transmission capacity, should continue to be able to seek TPD under Groups A and B upon securing a PPA or being short-listed.
• TPD-Allocation Group D should be retained. Even under the proposed queue entry process, projects will still have a high risk of not getting deliverability. Group D helps to break the deadlock of PPA and deliverability interdependency.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

EO projects should be able to acquire a PPA for RA capacity and at that point request TPD capacity. 

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No comment. 

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

CalWEA supports the updates.

9. Additional comments:

Zones

• Please confirm that Morro Bay Offshore Wind and Humboldt Offshore Wind will be treated as separate zones from Fresno and North of Greater Bay Area as shown in Figure 1.

TPP portfolio and base case

• Please confirm that, where CAISO refers to “TPP portfolio” and “base case,” it means the base portfolio.

Fulfillment of 150% available capacity 

• Zonal capacity is the capacity in the IRP portfolio, directed to the CAISO TPP, which by design could exceed the current transmission capacity and trigger new transmission upgrades.  In contrast, fulfillment of 150% of available capacity is based on actual deliverability constraints. At the time of fulfillment, the new transmission upgrades may not be approved yet. Thus, it is possible that zonal capacity could exist, but no projects in the zone are allowed into the study process due to the deliverability constraints. This disconnect between zonal capacity and transmission capacity could cause inefficiency and delay projects in needed areas by potentially many years.  This additional flaw in CAISO’s proposal is one more reason why CalWEA cannot support it.

Limitation to TPD transferability

• CalWEA objects to requiring a project that transfers its deliverability to withdraw from the queue or to downsize its generating capacity to its remaining deliverability. Such projects are subject to the commercial viability criteria and time-in-queue requirements proposed in Section 3.6. Therefore, they should be allowed to develop as EO projects if shown to be commercially viable as an EO project or seek deliverability if viability criteria are met.

Overall Proposal

As indicated in our responses to questions 1 and 3, and the comment on 150% available capacity above, CalWEA does not support the CAISO’s overall proposal to address the large volume of resources in the queue.  It is fundamentally flawed because it moves the study process forward for a small minority of early-stage projects from deep-pocketed developers based on information other than what is most vital to project viability --  transmission upgrade costs and timelines.  The proposal increases the risk of the study process by requiring developers to commit to the study process without knowing the amount of available capacity.  The process upon which projects are proposed to be advanced rests on subjective control by LSEs and is thus subject to anti-competitive behavior.  As a result of all of these factors, the process is likely to leave many projects behind that could otherwise prove to be the most attractive and viable. It will also drive applications to LCR areas where development costs are higher and large-scale solar and wind development is not feasible.  For all of these reasons, the proposal is fundamentally at odds with open-access principles and is anti-competitive, which will drive costs up for electricity consumers. 

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

No comment.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

No comment.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Capstone Power Development (US), LLC, a wholly owned subsidiary of Capstone Infrastructure Corporation (“CIC”), appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Draft Final Proposal.

Regarding engineering design plan completeness:

CIC requests clarity from the California ISO (“CAISO”) whether only the electrical design is required or other designs, such as civil and structural designs. CIC further notes that with the rapid advancement of renewable energy and energy storage technologies, any design plans prepared early in the project interconnection request process are bound to change given the long lead time for the cluster study process and the interconnection process with the Participating Transmission Owners.  

Regarding expansion of a generation facility:

CIC supports CAISO’s addition of subcategories for an expansion of a generation facility, which includes “Expansion of a generation facility that is currently under construction”, and “Expansion of an operating facility”. Expansions offer multiple benefits over new build projects, including lowered execution risk, enhanced rate payer benefit, and decreased complexity and lead-times for interconnection. We suggest that CAISO add a third type of expansion, being Expansion of a generation facility that has an executed Large Generator Interconnection Agreement (LGIA). Furthermore, CIC argues that all three subcategories merit the same points in order to demonstrate project viability given the capital commitments for projects that are under construction or in advanced state of execution with a GIA executed.  

Regarding site control of the gen-tie:

CIC does not support the newly proposed criterion of 100% site control of the gen-tie given the number of circumstances in which this may not apply, for example:  

(1) Depending on local regulations, consent from landowners (by way of private land agreement) is not required if the gen-tie line is built within the public right-of-way. Approval from local municipalities is generally not granted before a project has secured an LGIA. Such projects should be deemed to satisfy the 100% site control of gen-tie.

(2) For new substations being permitted for construction in accordance with approved TPP’s, it may not possible for an IC to demonstrate site control of the gen-tie when such substation location has not been finalized (and thus the gen-tie location cannot be known). Given the long lead-time for the CAISO cluster process, and in order to maximize utilization of those new approved transmission resources once constructed, CAISO should not penalize such projects where an approved TPP project substation location is not finalized.

In addition, CIC suggests that CAISO explicitly clarify that for expansion projects (whether for facilities that are operating, under constructed, or committed [i.e., an LGIA has been executed], that these proposed projects qualify for the full 40 points available for site control of the gen-tie.  

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No comment.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

No comment.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

No comment.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No comment.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comment.

9. Additional comments:

No comment.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

The California Energy Storage Alliance (CESA) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 2 Draft Final Proposal.  CESA supports the ISO providing additional information as early as possible so interconnection customers can fully consider transmission availability prior to submitting an interconnection request into a transmission zone. CESA appreciates the proposed generic schedule demonstrating the relative timing of information availability related to key milestones.  The ISO also agreed to provide a list of all substations within each identified zone, identity for each transmission constraint, the point of interconnection where resources in the queue are located behind studied constraints, and the TPD that has been allocated for each transmission constraint.  The ISO should consider shifting the TPD allocation study prior to opening the request window or if summary data from the submitted TPD affidavits could be provided to better inform whether an interconnection request is submitted.

In the short term, CESA requests CAISO to provide an updated list of substations within each identified zone after the 2024 TPD allocation studies. While CESA appreciates the CAISO to provide the data document by end of February, the list of substations within each interconnection zone be may out of date once the 2024 TPD allocation studies are completed.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

CESA supports applying the same site control, entry fees & deposits, scoring criteria for FCDS, PCDS.  CESA doesn’t oppose scoring EO projects because the EO projects do not count towards the 150% study cap since the cap is based upon transmission plan deliverability.  However, CESA is concerned that under the current scoring criteria an EO project will be unable to receive enough points to ever be studied.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

CESA reiterates prior comments that additional indications of LSE interest provide little differentiation between the viability of projects given the CPUC portfolio must be achieved to meet state policy objectives and such interest will most likely be non-binding since costs and timing are uncertain.  CESA would support a higher weighting for project viability than the current 35%.  CESA does appreciate the lower weighting provided to LSE interest but remains concerned that without a more standardized and transparent LSE allocation process to projects leaves too much discretion to LSEs. In addition, CESA is concerned that LSEs may bias utility-built projects over other potential interconnection requests.  Thus, if the ISO maintains the LSE weighting, the recommended limits on LSE-owned projects must be maintained including (1) LSEs may only award points to one self-build project each cycle, (2) the fully allocation election cannot exceed 150% of that LSEs total capacity allocation for the cluster, (3) limitations apply to both CPUC-jurisdictional and non-CPUC jurisdictional LSEs. CESA does support a minimum points allocation as suggested by NCPA and Six Cities. The CAISO should also hold a workshop following the application of the scoring criteria to Cluster 15 to evaluate its effectiveness and potential areas of improvement.

As stated in prior comments, the 150% limit should not be seen as a firm limit, but rather it should set the minimum quantity of projects that will be accepted for study.  In the event that there are projects with equal scoring criteria and DFAX which exceed the 150% baseline, all those projects should be studied. 

CESA continues to oppose auctions as a tie breaker for projects which cross the transmission capability study threshold.  The benefit of an auction is to allocate scarce resources and provide price discovery of the value of the scarce resources.  This benefit is not applicable to breaking ties as the price formation ignores the willingness to pay of all resources seeking to submit an interconnection study request in the transmission zone.  Also, with the introduction of prioritizing interconnection requests with the same scoring criteria based upon the DFAX, the additional step of requiring additional at-risk study deposits is unnecessary if the 150% limit is not seen as a firm limit.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No comment. 

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

CESA believes additional discussion is needed on the TPD allocation process changes.  Given the long lead time of certain deliverability upgrades it seems unrealistic that those projects requiring the upgrades will be able to execute a PPA within the three opportunities to seek a TPD allocation.  These projects would then be converted to EO which now requires the project to reach COD to request a TPD allocation.  There should be an option to allow projects with long lead time upgrades to defer their initial request for a TPD allocation.  Also, the concept of multi-year interim deliverability should be discussed as a potential solution to contracting issues.

The ISO should reconsider restricting EO projects from eligibility to request TPD allocation only to once the project is online (Group 3) given the currently limitations in Appendix DD that EO projects cannot trigger the construction of delivery network upgrades.  

In addition, the proposal of only allowing EO projects to seek allocation under Group C should not apply to existing projects who are likely further developed than later-queued projects. Projects in the previous cluster (i.e. Cluster 13) were forced to convert to EO given the lack of TPD from the previous allocation cycle. It would be unfair of CAISO to apply new allocation rules to existing EO projects.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

No comment.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

Support 

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comment. 

9. Additional comments:

None.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

Clearway appreciates CAISO’s commitment to invest time and effort in providing additional data to stakeholders in order to make the interconnection process more meaningful. Clearway would like to commend CAISO for laying out the process framework in Figure 4 of the Draft Final Proposal. We understand that the timelines depicted in Figure 4 are subject to change. Given that, Clearway requests that CAISO confirm that the TPD Allocation study to be performed in 2025 will be tied to the timing of the Board of Governors’ approval of the 2024-2025 Transmission Plan and will include all the approved projects as topology assumptions. Not doing so will result in a lost opportunity to allocate TPD to generation projects that are mature in the study process. This will potentially result in a constrained supply of resources for offtakers looking to contract resources to meet long-term RA needs.

CAISO already provides transparent and valuable deliverability information, and Clearway supports the efforts to enhance this information. Clearway requests that CAISO and PTOs summarize substation feasibility information, at minimum for all the substations that are included in CPUC’s portfolio mapping. PTOs have evaluated and monitored evolution of cost and timelines for building out many of these substations across several clusters for more than a decade. It would be extremely valuable to educate developers on certain locations which may have reached full buildout potential or locations which may have significant room for expansion.

Clearway supports CAISO’s proposal to post redacted individual interconnection reports.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Clearway supports the proposal to allow Energy-Only projects that meet reasonable viability criteria into the study process without counting toward the 150% cap. However, there does not seem to be a compelling policy reason that the project viability cutoff for Energy-Only projects should depend on the competitiveness of deliverability in the transmission zone where they are interconnecting, as the CAISO has proposed. As an alternative, CAISO should consider setting a minimum number of points for any Energy-Only project to proceed into the study process. The minimum score should be based on the number of points that an Energy-Only project could reasonably qualify for. As an illustrative example, based on the CAISO’s proposed scoring system in the Draft Final Proposal, the minimum score for Energy-Only projects could be 80 points, which could be met through a combination of customer interest (25 points), engineering design plan completeness (20 points), site control of gen-tie (40 points), and expansion of operating facility (10-40 points).

To alleviate the concern that excessive EO projects will create phantom RNUs (especially short circuit duty upgrades), CAISO and PTOs should commit to evaluating sequential short circuit duty issues.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Most of our comments on this section relate to the Project Viability score, which in the Draft Final Proposal does not provide sufficient opportunity to differentiate between projects and advance the most viable projects.

Developer track record should be incorporated into the project viability score. This was suggested by several parties in comments on the Revised Straw Proposal – for example, LSA recommended adopting a version of the CPUC’s RPS Project Viability Calculator, which takes into account whether a developer has successfully developed and/or operated projects of similar size and technology before. These proposals were not addressed in the Draft Final Proposal but should be revisited. A developer’s credibility and track record is one of the most valuable signals the CAISO can use to determine the likely viability of a new interconnection request.

CAISO should also restore the points available for significant equipment procurement, which represents a meaningful commitment to develop a project.

In contrast, engineering design plan completeness at such an early stage is not a useful metric for project viability. It is likely that all projects will score the maximum points available in this category, as developers will simply pay to complete the required engineering design work to secure the maximum score to enter the study process, while planning to redo the work later when the project reaches the appropriate stage of development. Clearway suggests removing this element from the scoring criteria, as it is likely to add cost and workload (including added work for the CAISO team responsible for scoring projects) without providing useful differentiation between projects.

Clearway also recommends that as part of Project Viability, CAISO should assign points to projects that expand existing active queued projects that are not under construction but have an executed LGIA and have met certain development milestones, such as projects that have posted the 3^rd IFS and issued the first NTP under the LGIA. These projects could be assigned fewer points than expansions of projects that are already operating or under construction, providing additional granularity in the scoring process.

Clearway supports the proposal to limit LSEs to awarding LSE interest points to one self-build project per interconnection cycle. With LSE interest still comprising a large percentage of available points, and LSEs limited in the total number of points they can award, this limitation is necessary to address the inherent conflict of interest in LSEs awarding points to their own projects.

Finally, we reiterate our earlier recommendation that in the System Need category, the number of MWs awarded points should be limited based on the size of the identified need. If the CPUC’s resource portfolio has identified a need for 1 GW of a particular long-lead-time resource and 10 GW of that resource enter the queue at that location, only 1 GW (or 1.5 GW to account for attrition) should qualify for points in this category. These points could be awarded to the eligible projects with the highest scores in other categories. Given the large number of points proposed for projects this category, it is important not to award points to projects that are far in excess of the identified need for a given long-lead-time resource, when projects of other technology types may be lower-cost, more advanced in development, and more consistent with the CPUC’s resource portfolios.   

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No additional comments at this time.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

The newly proposed TPD allocation process modifications are significant changes and should be deferred to Track 3 of this initiative to provide more time for stakeholder input.

Clearway strongly opposes applying the proposed changes to projects prior to Cluster 15, including the restriction of Energy-Only projects to Group C and the elimination of Group D. Developers have made significant investments to move Cluster 14 and earlier projects forward under the current rules, and they should be able to continue under these rules, including projects that may intend to seek a TPD allocation in Group D in 2025 if they are not awarded in 2024.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

Clearway shares the concerns raised by others that 7 years may be insufficient for some Cluster 14 projects, given the long timelines and frequent delays for network upgrades to enable Energy-Only interconnection and to enable deliverability. Based on the timelines in the TPP for upgrades enabling TPD, projects in Cluster 14 may not achieve FCDS or PCDS status until as late as 2034. We request that CAISO provide for a longer time in queue for projects that are waiting for network upgrades with more than 7 years’ lead time to be able to interconnect or to reach FCDS or PCDS status.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No additional comments at this time.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No additional comments at this time.

9. Additional comments:

Interim Deliverability

CAISO is proposing to remove the multi-year Interim Deliverability topic that was previously contemplated in this initiative. The Draft Final Proposal states, “There is not expected to be a significant amount of longer-term interim deliverability available.” We request that the CAISO clarify this expectation. When Clearway evaluated specific projects adversely affected by upgrade delays, it was evident that significant long-term (2+ years) interim deliverability was available for these projects. The Draft Final Proposal further states, “TPD is allocated annually and typically all available TPD is allocated. Generation projects receiving allocations are expected to utilize that deliverability as soon as the precursor delivery network upgrades are completed and the deliverability becomes available.” Clearway agrees that projects are expected to use the allocated deliverability as soon as upgrades are completed. However, there is sometimes also capacity that is available before the upgrades are completed, and the current process does not allow projects to get a contractable assurance of being able to access that capacity in the interim. This especially affects the viability of projects that are waiting for long-lead upgrades such as those included in the 2022-23 Transmission Plan. With more long-lead upgrades being identified in the TPP, finding creative solutions to maximize the use of all available deliverability will be important to enable California to meet its clean energy and reliability needs in the late 2020s and early 2030s. While Clearway recognizes that the multi-year interim deliverability study would be a complex undertaking, we strongly urge CAISO to design and offer a multi-year Interim Deliverability framework as part of IPE Track 2 or Track 3.

Changes to Cluster 15 Projects

Section 2.5.1 of the Draft Final Proposal, related to the fulfillment of 150% of planned transmission capacity in each zone, states: “The ISO cannot allow any changes in POI after a project submits its IR. The information provided prior to the opening of each interconnection request window should be sufficient for projects to select the best POI for their proposal.” We request that the CAISO confirm that this statement applies to future clusters and that for Cluster 15 (which did not have access to zonal data prior to the opening of the IR window), projects will still be allowed to change POI within the same study area during the designated window for changes to interconnection requests, as adopted in Track 1 of this initiative.

Timing Challenges

These comments relate to the timing challenges created by the dates for FERC Order 2023 compliance and filing and approval of IPE Track 2 tariff changes:

• Cluster 14 projects that park and wait for a second chance at TPD allocation in 2025 should be allowed to extend their 2nd IFS posting date until after receiving their 2025 TPD allocation results. As of now, if a C14 project parks in 2024, pursuant to Section 16.1 k) of Appendix DD of GIDAP, it gets a 12-month extension to post 2nd IFS and must post by July 01, 2025. However, according to the timeline for TPD allocation contemplated in the Draft Final Proposal, results of the 2025 TPD allocation process will not be known until September 2025, thereby forcing C14 projects to post their 2nd IFS while still waiting for TPD allocation results. The 2nd IFS posting date should be after completion of the second round of TPD allocation for Cluster 14 (2025 TPD allocation).  
• CAISO has indicated that it will modify dates in Section 17 of the tariff so that all dates align with the start of studies for Cluster 15. In addition to the deadline to withdraw without penalty (currently April 1, 2024), this presumably also includes the window for Interconnection Customers to make changes to their projects (currently May 1 – September 26, 2024). Since CAISO’s Order 2023 compliance filing will not be approved prior to these dates, Clearway requests that the CAISO let stakeholders know as soon as possible what the new dates will be – if possible, prior to the Order 2023 compliance filing, the deadline for which is still more than a month away. Interconnection Customers contemplating significant changes to one or more Cluster 15 projects would benefit from more advance notice on when the window to make changes will close (the current September 26 date).
• CAISO should clarify as soon as possible the date when C15 projects will have to demonstrate the required site control. Clearway recommends that this date should be 60 days after FERC’s approval of CAISO’s Order 2023 compliance. Additionally, since FERC Order 2023 implementation will require projects in Cluster 15 to demonstrate 90% site control to advance and there will no longer be an in-lieu deposit available, Clearway recommends that the CAISO release in-lieu deposits that were previously provided for Cluster 15 projects, as they no longer serve a purpose.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

EDF-R appreciates CAISO’s continued effort on refining the zonal approach proposal and supports CAISO’s decision to move the IR window to June. This move is in line with developing cluster groups with the best information possible. EDF-R requests CAISO add more granularity to this schedule and clarify the activities that will be performed within the 45-day window given the current application window is only 15 days.

In the Draft Final Proposal CAISO states the interconnection queue report contains interconnection area where the queue project is located, however, "the interconnection areas that are in the queue report do not reflect the current interconnection areas identified in CPUC busbar mapping effort Figure 1." [emphasis added.]  EDF-R requests CAISO normalize data across such that they do share definitional boundaries. This apples-to-apples approach facilitates correct resource mapping across multi agency efforts. LSE’s map resources to specific areas and substations in the integrated resource plan resource data templates (RDT) submitted to the CPUC, and this helps to ensure that information about procurement transmits between California entities accurately and the CAISO’s TPP produces results that support procurement.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

EDF-R recommends that the IR viability requirement that the developer demonstrate “100% site control of the gen-tie” be eliminated from the proposal. Developers no not have sufficient information to meet this requirement until the information is provided in attachment 10 of the study report (e.g. bay position assignment.)

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

EDF-R thanks the CAISO for Dropping the A/B deliverability names to eliminate potential confusion and for modifying the merchant option choose to retain their existing arrangements in the event that ADNUs are picked up by the TPP.  

EDF-R shares stakeholder concerns about the feasibility of CRRs providing adequate repayment of ADNU costs, especially given the changes in CRR procedures in recent years. 

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

The CAISO proposes to discontinue parking and allow projects three consecutive opportunities to seek TPD. EDF-R requests CAISO clarify if the new deposit structure will be done in lieu of or on top of existing posting requirements, for example,if a project withdraws after the receipt of the draft GIA will it receive 50% of posted security back (posting security at that time being 30% of project cost responsibility)? Or will requirements for how much security projects have to post and when change?

EDF-R also requests CAISO provide more detail on GIA procedural steps. For example, if a project does not receive an allocation and desires to remain in queue and seek an allocation for the second or third time, will that project have to execute GIAs in the meantime and consent to RNU work? Or post against LDNU without a TPD allocation? Does this mean projects who wish to exercise second or third allocation attempts must have completed their third financial security posting?

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

EDF-R does not believe it is reasonable for CAISO to apply commercial viability tests to projects that are on track to meet their earliest-achievable CODs as identified in study reports or PTO delay requests. For example, if a project’s longest lead network upgrade will take 9 years to construct after GIA execution, that project should not be required to provide an executed PPA to stay in queue 6 years before COD. As reported by the majority of commenters on the CAISO’s proposal, this timeframe is not consistent with procurement markets and CAISO should outline an exception for these cases, and is quite likely to unfairly remove otherwise viable projects from the queue.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

 CAISO’s proposal requires that parked projects would need to execute an engineering and procurement agreement (E&PA)– EDF-R notes that project can request E&PAs from PTOs, but cannot force PTOs to tender, negotiate, or execute them. EDF-R requests CAISO outline that in these cases the interconnection customers that have requested E&PAs in good faith will not be withdrawn.

EDF-R continues to have concerns about scenarios where the PTO does not initiate construction within 30 days of E&PA or GIA execution but appreciates that the CAISO acknowledges these situations would need to be evaluated on a case-by-case basis.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

EDF-R appreciates CAISO’s flexible approach to modification and GIA amendment timing. EDF-R seeks confirmation from the CAISO that financial security amounts and posting schedules in GIAs will be revised consistent with modification report scope changes, and that such changes will be recorded in the MMA results report.

9. Additional comments:

In section 2.2.2 CAISO clarifies that Order No. 2023 imposes several new entry fees and study deposits and that the CAISO is not considering changes to current entry fees. EDF-R requests CAISO please clarify if new fees to comply with order 2023 will be applied in addition to CAISO’s existing fee structure.

Regarding 2.5.2. Auctions, EDF-R requests that CAISO clarify in the auction procedures that if a winning bid fails to post security required by their bid, that the CAISO will move to provide the opportunity to be studied to the next highest bidder.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

 ENGIE NA (“ENGIE”) appreciates the additional detail provided by the CAISO on the generic timeline for various studies and key dates under the proposed new interconnection process. We have no additional comments on the timeline.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

No comment

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

ENGIE appreciates the improvements CAISO  made to the draft final proposal specific to the scoring criteria and reducing the score allocated to the LSE commercial interest category. ENGIE still remains concerned that scoring allocated to the commercial interest category is too high. Considering how early projects will be in their development cycle and how far out many projects CODs are projected in the interconnection process, commercial interest at this stage is not a valuable measure of potential project viability and is not commercially binding. More weight should be applied towards project attributes rather than commercial interest. ENGIE recommends that the Commercial Interest Category be reduced from 30% weighting to 20% and additional weighting be added to the Project Viability and System Need categories.

ENGIE supports the inclusion of corporate off takers to the commercial interest category to support open access and a viable option for those projects to enter the queue. LSE’s expressed concern about commercial  off takers potentially crowding out LSE projects. ENGIE believes the CAISO has struck the appropriate balance considering corporate off takers are allocated a lower number of points as compared to LSE’s who have resource adequacy obligations.

ENGIE supports the CAISO’s proposed limits on LSE self-build projects to preserve competition and avoid LSE’s allocating all its points as a means to self-select their own projects to enter the queue. ENGIE recommends CAISO evaluate and report on how the construct of the interconnection queue  after the scoring criteria is applied to the first queue cycle.

As noted in prior comments, ENGIE the available capacity in each zone subject to scorning should be estimated, exclusive of Group D TPD allocations.  Group D  TPD  are conditional, subject to the  generator-developer securing an off taker in a subsequent year.  Although some generators will succeed at this requirement, many will not and the TPD not be retained and will become available for a future allocation.   If the TPD made available by CAISO in each zone excludes Category D, it will underestimate the amount of TPD available 1-2 years out when C15 projects are receiving their studies.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

ENGIE continues to support CAISO allowing projects not selected through the scoring process to pursue the Merchant Deliverability option. The CAISO can consider limiting access to Merchant Deliverability in the future if it proves to be a strain on CAISO resources. ENGIE also requests more information on how Energy-Only projects could connect through the merchant deliverability option.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

ENGIE appreciates CAISO including some initial thoughts on modifications to the TPD allocation process and looks forward to further developing details around these proposals. Although not expressly stated, CAISO is indicating its policies for allocation of TPD to Cluster 15 and subsequent clusters.  Thus, this proposal does not interfere with allocations underway with Cluster 14.  Furthermore,  because Cluster 14 projects will receive Category D allocations in both 2024 and 2025, CAISO should, as noted in Section 3, above , exclude those allocations from computing TPD headroom for as long as Category D exists. . Developers currently need this option to address the challenge around securing TPD allocation in order to obtain a PPA. Eliminating Category D will require a determination that projects in the new study process will have meaningful opportunities to contract.  Among other things, CAISO needs to clarify how all active projects seeking TPD allocations (including those in Cluster 14 or earlier) will be given up to three  opportunities  to seek a TPD allocation. Ensuring this proposed change is applied to all active interconnection customers will provide an appropriate opportunity for earlier projects to seek an allocation and ensure equitable treatment of all projects.

In this same section, CAISO floated a very significant change to TPD allocation policy; namely that it be allowed to “hold back” TPD for long-lead time projects such as offshore wind.  CAISO’s proposal is to take such TPD out of the pool that is available to allocate in a (nearer-term) year.  This requires further discussion as it could potentially unfairly disadvantage other projects seeking to interconnect.  

While ENGIE supports changes to TPD allocation, more discussion is required and should be addressed through a separate stakeholder process.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

ENGIE supports and appreciates CAISO’s modifications to the proposal to allow additional 12-months for projects to secure a PPA should they lose a PPA due to a PTO delay.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

no comment

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

no comment

9. Additional comments:

 ENGIE appreciates CAISO’s collaborative approach to developing the Draft Final proposal. We request that CAISO provide a schedule for Cluster 15 reengagement as soon as possible so interconnection customers can prepare to meet new requirements under FERC Order 2023.

ENGIE still supports the CAISO considering the 150% zonal limit as a floor rather than a ceiling.  In the event that there are projects with equal scoring criteria and DFAX which exceed the 150% baseline, all those projects should be studied. The CAISO may need to increase the 150% limit to meet the needs of different queue cycles and transmission availability. ENGIE recommends that CAISO delay the complexity involved with the implementation of an auction to a future queue cycle as it may not be needed

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

esVolta appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 2 Draft Final Straw Proposal.  esVolta develops, owns and operates utility-scale battery energy storage projects across North America. esVolta's portfolio of operational plus utility-contracted backlog projects totals nearly 1.5 GWh, and we are developing a pipeline approaching 20 GWh of further large project opportunities. esVolta has both operational battery storage projects in the ISO as well as requests in the ISO’s interconnection queue. esVolta takes no position on the majority of CAISO’s Draft Final Straw Proposal, and instead focuses its comments here on issues that are of the most significant concern to esVolta’s interests. However, esVolta’s silence should not be construed as endorsement.

esVolta continues to oppose the viability scoring criteria points CAISO proposes to award to expansion projects, and in the alternative, to reduce the points awarded to expansion projects. esVolta offers points of clarification regarding CAISO’s proposal to award project viability points to site control for gen-ties.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

N/A

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Expansions

esVolta continues to oppose Scoring Criteria Points for expansion projects and incorporates prior comments to that effect. Except for the narrow scenario where a project is located adjacent to an existing facility where the capacity of the gen-tie can accommodate the additional resource, there is no additional Project Viability added by simply being adjacent to an existing operating or in construction facility.

Indeed, as demonstrated in esVolta’s prior comments and not rebutted by CAISO in the Draft Final Proposal, expansion of existing projects can actually be less viable than greenfield projects due to community opposition and cumulative effects. To the extent that there are cost savings or time savings associated with expansion projects, those benefits can be reflected in the points LSEs award to projects under the Commercial Interest category. Furthermore, it would be discriminatory to give expansion projects additional Project Viability points simply for being adjacent to existing projects if other projects that may be just as speedy or inexpensive do not get those points for having the same or better underlying project characteristics. CAISO’s proposal is simply not based on evidence, is discriminatory, and will prejudice California’s ability to achieve the MOU’s goals.

CAISO’s proposal to award Project Viability points to expansion projects may also have unintended consequences and lead to gaming. Existing projects that are operating could extend their operations in an otherwise uneconomic way in order to provide points to an affiliated or contracted expansion project.  The same concerns that arise for generator retirement and replacement with respect to the interconnection queue policy also exist here. Surplus interconnection was limited by FERC to the original interconnection capacity due to the queue jumping that could occur under CAISO’s proposal. If the existing and expansion facility are affiliated, CAISO’s proposal could lead to market power in a way that even prevents those entities who could avoid market power from being studied. If CAISO continues with the expansion points proposal, it should require any expansion projects to have received Market Based Rate Authorization from FERC.

If CAISO moves forward with additional Scoring Criteria points for expansion projects, then it should at least require those projects to be fully permitted. At the last Stakeholder Meeting, CAISO stated that they declined to do so because requiring permitting is not an objective measure. This is mistaken, permitting can be objectively verified in at least two different ways. First, CAISO could simply require an affidavit from the Interconnection Customer swearing that the project has received all air, water, and land permits necessary to commence construction. Second, if CAISO is unwilling to rely on an affidavit or seeks more flexibility for expansion projects, then it could require “reasonable evidence … all required permits (air, water, or land use) required to construct the Generating Facility are approved…” as does PSCO in its FERC-approved interconnection queue. Public Service Company of Colorado OATT, Att. N., Sec. 5.1.1.1(c)(iv), 7.7.1(d), 7.7.4(d). These are FERC-approved, objective ways to verify whether a project has either applied for or received all permits necessary to commence construction. CAISO should require at least that of the projects that are being proposed to be awarded significant points in the name of “Project Viability.” If an expansion project cannot demonstrate it is permitted, CAISO has not demonstrated that it is any more viable than any other project. CAISO’s excuse that requiring expansion projects to be permitted is not objective fails scrutiny, especially given that CAISO already has similar requirements in other contexts for CAISO Metered Entities and Utility Distribution Companies, among others. CAISO OATT Appendix B.6 Article 8.2; Appendix B.8, Article 8.2.

If CAISO moves forward with additional Scoring Criteria points for expansion projects, then it should reduce the relative points given to expansion projects versus the other Project Viability categories such as Engineering Design Plan or Site Control of the Gen-Tie.

Site Control of the Gen-Tie

esVolta could support additional project viability scoring criteria points for site control of the gen-tie, as proposed in CAISO’s Draft Final Proposal. Understandably given its recent introduction, details are scant, so esVolta offers details CAISO should clarify below.

CAISO should clarify whether there is a separate requirement for private versus public sites as is the case with Generating Facility Site Exclusivity in CAISO’s tariff and BPMs or whether CAISO will adopt the different stie control regime from FERC Order 2023 regarding “qualifying regulatory limitations.” If there are separate requirements, CAISO should describe what documentation would reasonably demonstrate site control for public sites and incorporate those provisions in its GIP BPM regarding BLM sites. Consistent with FERC Order 2023, CAISO should allow Interconnection Customers with qualifying regulatory limitations to submit additional deposits in lieu of site control to obtain the Scoring Criteria Points. Qualifying Regulatory Limitations are spelled out in detail in Paragraphs 605-612 of FERC Order 2023, but generally include federal, state, Tribal, or local laws that makes it practically infeasible to obtain site control.

Given the early stage of project requests with respect to electrical design, indeed a project with 0% complete Engineering Design Plans could theoretically be a high-scoring project due to other criteria, CAISO should also clarify where the gen-tie line will be measured to and from for purposes of demonstrating site control. The current terms used in the context of Generating Facilities reference “the property necessary to construct the facility,” which could suggest measuring the gen-tie from the Generating Facility property site boundary closest to the point of interconnection. SPP measures gen-tie site control from the collector system station to the Point of Interconnection. SPP Site Control Criteria (https://opsportal.spp.org/documents/studies/SPP%20Site%20Control%20Criteria.pdf) at 11. CAISO should clarify that Gen-Tie Site Control does not include lands owned by the interconnecting PTO.

Finally, in the interest of increasing scoring granularity and to reduce the chance of scoring ties, CAISO could provide Scoring Criteria points for gen-tie site control on a sliding scale (i.e. 7 miles of site control for a 10 mile gen-tie would result in 40*.7 or 28 points). This retains the initial proposal’s objectivity, adds granularity, and recognizes project progress for different types of development.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

N/A

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

N/A

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

N/A

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

N/A

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

N/A

9. Additional comments:

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

No comment.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Golden State Clean Energy (“GSCE”) supports Energy Only projects having a fair opportunity to seek entry into the queue given the value of these projects for REC production and the possibility for merchant development. In addition, the CPUC has been planning for a substantial amount of Energy Only capacity, and the ability to interconnect is being limited by IRP planning, so CAISO must account for Energy Only.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

GSCE offers the following comments on the scoring criteria:

• Non-CPUC jurisdictional LSEs
  • GSCE is concerned with the proposal to no longer automatically study projects that are included in a non-CPUC jurisdictional LSE’s LRA approved plan. It is unclear that incorporating these LSEs’ individual IRPs into the TPP will have the same dynamics as the CPUC’s IRP does in the TPP, especially in the initial years that this new process is undertaken, and meanwhile non-CPUC jurisdictional LSEs have critical procurement deadlines quickly approaching that now involve new regulatory risks.
• Allowing non-LSE/commercial offtakers to award points
  • GSCE supports this additional option for showing project viability and maintaining open access.
• Engineering Design Plan
  • GSCE supports CAISO’s consideration of a reasonable degree of design completion at this early stage in project development (i.e., less than 30%). Some level of engineering design does speak to project readiness, and the design can also interact with other interconnection request requirements or readiness scoring planning to make inclusion of the category worthwhile. But beyond a certain degree of design completion much of the work will have to be re-done and thus not show increased readiness.
  • GSCE is unclear what is being distinguished in the current tiered scoring for this category. At this stage in development, we do not see much engineering design work that can be parsed out to show meaningful tiers of readiness. Instead, GSCE recommends this be a single check-the-box option indicating whether sufficient engineering design has taken place. A single-line diagram is already required as part of the interconnection request, and thus only a site plan should be necessary that shows the following:
    • general layout of the facility matching information to the single-line diagram;
    • verification of generator site control and technology acreage requirements; and
    • verification of the gen-tie route and site control percentages.
  • GSCE appreciates CAISO’s desire to anchor this requirement in existing industry standards. However, it is unclear how the AACEI classification system is intended to be used to for this scoring. GSCE recommends CAISO incorporate by reference what it is requiring for this scoring criteria so it is clear exactly what needs to be done to receive points.
• Site control for the gen-tie
  • GSCE appreciates CAISO’s consideration of our comments on this topic and supports inclusion of gen-tie site control in the scoring criteria.
  • GSCE continues to support tiered scoring for this category because this development effort can occur incrementally, involving multiple parcels of land, multiple landowners, and many miles of development. Securing some amount of land for the gen-tie is measurable progress, and the more land secured for the gen-tie the further the project is progressing in a necessary step for development. To address this, GSCE recommends 50%, 75%, and 100% site control tiers in this scoring criteria.
    • CAISO’s proposed 100% take-it-or-leave-it scoring for this category does not recognize the incremental steps being taken in development or even projects that have secured nearly all (but less than 100%) of the land needed for gen-tie site control.
    • In addition, it is unclear what the result is in a situation where a project anticipates interconnecting to one bus but may be directed by the PTO to interconnect to another bus in the substation – if this minor re-routing could ruin a project’s anticipated 100% gen-tie site control, then either an exception should be spelled out or tiered scoring is needed so this project can receive points for its significant project development efforts. Regardless of an exception for this case, tiered scoring is reasonable given the incremental progress that occurs in this development effort.
    • We recognize there should be some threshold to receiving points in this category and a limited number of tiers. Other categories have examined three tiers of scoring, and thus we see this as reasonable. We support a minimum site control requirement of 50% so that significant land has been secured, and a mid-tier option should be available to distinguish projects that are close to 100% but have some final issues to address.
    • Our proposal for the Engineering Design Plan can help show the percentage of gen-tie site control that has been secured.
• Supply of major equipment
  • GSCE supports removal of a business partnership for future supply of major equipment as a scoring criterion.
• Permitting
  • GSCE is concerned that the current scoring criteria will not sufficiently distinguish projects. We continue to believe that CAISO’s consideration of permitting in the TP Deliverability affidavit process shows it is reasonable for CAISO to assess permitting.  

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

GSCE continues to oppose the proposed limits on which projects can select Option B/Merchant Deliverability and supports the option being available in zones with available or planned transmission capacity. CAISO could add additional minimum requirements for a Merchant Deliverability interconnection request in zones with available or planned transmission so to further raise the bar for projects using this option.

• Given this option has historically not been used and CAISO is not proposing to change fundamental issues with it, it seems unlikely there would be an explosion of applications in the future such that CAISO’s desire to limit future interconnection requests is truly undermined.
• CAISO’s current proposal allows projects to finance additional transmission on a merchant basis only in areas where resource planning is not directing future transmission, thus incentivizing some projects to seek interconnection outside of planning areas and undermining the goal of focusing development in key planning areas. CAISO should be welcoming additional transmission in key planning areas and not creating incentives to develop outside of these areas.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

 No comment.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

 No comment.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

 No comment.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

 No comment.

9. Additional comments:

GSCE remains concerned that the desire to better manage interconnection studies (i.e., through the 150% cap) could fundamentally shift market dynamics and have significant policy impacts. Where, when, and how much capacity will be allowed to seek interconnection in the future will be almost entirely limited by the integrated resource planning process, a process that has created many concerns and does not sufficiently consider developer input to steer planning toward viable projects. The primary way commercial interest is gauged in the IRP is through assessment of what is in the queue, a reactive approach that allows the queue to drive transmission planning and one that will become even less useful when future interconnection requests are being limited to reflect the IRP. GSCE believes allowing future development to almost entirely be dictated by the IRP is a major risk underlying the entire 2023 IPE track 2 effort.  

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

GSW does not have any comments on this topic at this time.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

GSW does not have any comments on this topic at this time.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Long-Lead-Time (LLT) projects – alternative approaches

GSW does not object to the concept of using the scoring rubric to screen LLT Interconnection Requests (IRs) in zones with available capacity.  In particular, the 100-point addition for LLTs under the System Need category appears to be the continuation of the capacity-reservation proposal in the TPP Enhancements initiative. 

However, a points addition is not the same as a reservation, and the specific scoring rubric under consideration may not allow for sufficient project study participation by LLTs, for the reasons discussed below.  GSW suggests some issues and revisions below to the proposed scoring rubric, but ultimately the CAISO’s original set-aside proposal is the best way to ensure that the LLT projects accepted for study will reflect the transmission approved for such projects.

Specifically, the CAISO could separately evaluate projects with LLT technologies as competing against each other for access to deliverability provided by TPP-approved upgrades for those technologies.  Higher-scoring projects within the LLT group with these technologies would be accepted for study at least up to a cap of 150% of the approved LLT capacity amount.  Lower-scoring projects in the LLT group would have to compete with other projects of all technologies in order to be accepted for study.

Alternatively, the CAISO could also use a financial approach, exempting LLT projects from the scoring rubric but requiring an additional financial posting as a viability demonstration.

Specific scoring rubric issues and recommendations

Commercial Interest scoring category:  It seems unlikely that LLTs will receive many or any points in this category.  LSEs would be assigned evaluation points based on their share of available TPD, and they will probably use these points first to show interest in projects that will meet their regulatory and other procurement obligations and timelines.  The TPP planning time horizon is much longer than the current procurement mandates; thus, LLT Resources will probably score low in this category.

The Commercial Interest weighting reduction from 40% to 30% will help LLT projects in this respect, but GSW supports a further reduction to 20%, given the long lead times for recent projects and lack of useful project-specific assessment information at this very early development point.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

GSW does not have any comments on this topic at this time.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

GSW does not have any comments on this topic at this time.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

GSW does not object to the concepts of GIA execution deadlines and Energy Only project viability criteria.  However, these proposals need more structure in order to be fair and equitable.

GIA execution deadlines

GSW agrees with past LSA comments that simply setting deadlines, without any other timeline or process structure, is not fair or workable.  For example, it is still not clear whether each project must request a draft GIA on its own, or dates by which PTOs must tender such agreements.  In particular, there should be an appeals process if the deadline is missed through no fault of the developer.    

Commercial Viability Criteria demonstrations

Decoupling CVC from COD:  With the proposed CVC demonstration at 7 years time in queue, the process of requesting COD extensions would essentially be decoupled from the CVC, e.g., a request to delay COD beyond 7 years in queue would not trigger CVC.  Instead, the CAISO should clarify that the only demonstration that must be met would be compliance with is the existing tariff provision below.  Projects requesting COD delays beyond the applicable time-in-queue limits for legitimate reasons, as defined by this tariff provision, would be required to demonstrate CVC compliance by 7 years time in queue, and then annually thereafter.

6.5.2.1  Time in Queue

As noted in Section 6.1.5, projects studied in the serial study process, the In-Service Date shall not exceed ten (10) years from the date the Interconnection Request is received by the CAISO and projects studied in the cluster study process the COD shall not exceed seven (7) years from the date the Interconnection Request is received by the CAISO.

Interconnection Customers requesting to remain in the queue beyond the allowable time in queue must clearly demonstrate that engineering, permitting, and construction will take longer than the applicable maximum period and that circumstances that caused the delay were beyond the control of the Interconnection Customer.  In addition, the Interconnection Customer must demonstrate how the requested COD is achievable in light of any engineering, permitting and/or construction impediments.  The CAISO and Participating TO will not unreasonably withhold agreement to this extension, but the Interconnection Customer must provide sufficient documentation to support the request in its modification request.

In addition, the CVC should not apply at 7 years time in queue if the earliest achievable COD – based on the latest interconnection study or reassessment – is more than three years later (10 years time in queue), unless the COD was significantly delayed through IC action.  CVC compliance can be extremely difficult for projects with CODs far into the future, since permits have deadlines and LSEs generally won’t execute PPAs with projects that are many years away from COD.

Finally, it seems like the removal of TPD Allocation Group D in favor of the “three strikes and you’re out” approach (three years for acquiring TPD, no parking) will tend to lengthen project timelines, especially since most new projects coming off the study process will be unlikely to qualify for TPD Allocation Groups A-C.  The proposed Order 2023 study process would still take around two years, and adding three years to acquire a TPD allocation plus time to negotiate a GIA would leave little time for a project to take all the actions needed to meet the CVC.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

GSW does not have any comments on this topic at this time.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

The CAISO should add back into the Proposal its earlier statement that developers could receive a draft GIA within 120 CDs of a request, e.g., if they need it for financing, and are entitled to prompt CAISO and PTO processing.  The CAISO said at the stakeholder meeting that it would “make it happen” if the request was made for a good reason, but that commitment should be an obligation in the new framework.

9. Additional comments:

Deliverability-award information

The CAISO should revise its TPD Allocation award processes to include information about upgrades needed to implement awards and the expected in-service dates of those upgrades.  This additional information should be included in the notices for this allocation cycle in May; the CAISO should also go back to prior awards where the resources are not yet on-line and provide this additional information, to avoid last-minute unpleasant surprises when a resource reaches COD.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

N/A

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

N/A

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

N/A

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

N/A

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Hecate Grid LLC (“Hecate Grid”) appreciates the diligence in which CAISO has approached enhancing the interconnection process and commends CAISO for the current proposal, which will improve the viability of the interconnection process and aid in developers bringing their projects to fruition in a timely manner. Hecate Grid would like to address elements of a newly added provision in Section 2.7.1 (TPD Allocation Process Modifications), specifically item 3 & 3.1. Hecate Grid is opposed to provision item 3, which restricts Energy-Only projects to allocation group C – in commercial operation (COD) and especially opposed to item 3.1, which unfairly applies the restriction to projects already in the queue.  

CAISO explains in the draft final proposal their expectation Energy-Only projects will rarely make it to commercial operation. However, existing Energy-Only projects did not enter the queue with an awareness of this future provision. Retroactively altering the status and the options available for these projects to seek deliverability is effectively pulling out the rug from under them, due to – in some instances – no failing of their own. Many of Hecate Grid’s Energy-Only projects have sought, are seeking, and will seek Full Capacity Deliverability Status prior to commercial operation. Moving existing project opportunities to seek deliverability until COD negatively shifts the risk of development towards that milestone, unfairly endangering projects in the queue.  

Effectively, these projects will be developed blindfolded throughout the lifecycle of the project, increasing the likelihood of greater sunk costs – which negatively impact California ratepayers – if a project reaches COD and is unable to receive deliverability. Fewer projects reaching COD delays our energy transition and reduces overall energy supply. Further, the sunk costs of failed projects will have to be baked into any successful projects’ costs, once again leading to higher costs for electricity customers. Californians want clean energy and lower bills; this change helps accomplish neither. 

In CAISO’s own words, there is an allotment for Energy-Only projects in the CPUC’s IRP and there is a need to ensure a pathway for these projects through the interconnection process. While CAISO's aim going forward is to ensure that projects which advance as Energy-Only are viable enough and that developers have the intention to advance them to commercial operation, retroactively applying this restriction harms projects which already qualify under those criteria and have just narrowly missed out on being allocated deliverability in previous allotments.  

Hecate Grid’s view is that CAISO is creating an unnecessary provision which negatively impacts the risk profile of projects. Hecate Grid strongly opposes CAISO’s position and expects CAISO to reconsider the merit of including this provision.  

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

N/A

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

N/A

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

N/A

9. Additional comments:

N/A

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

IEPA does not have further comment on this section.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

IEPA respectfully requests an adjustment to the zonal cap of 150% of Transmission Plan Deliverability capacity. IEPA members are concerned this percentage is too low and does not represent the reality that projects in previous clusters have failed to reach commercial operation. To ensure enough projects reach commercial operation to satisfy 100% of available and planned capacity, IEPA recommends increasing the 150% cap to upwards of 200%, if CAISO’s data analysis lends itself to that percentage.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

IEPA is supportive of the two opportunities to earn points in the commercial interest category: commercial interest from an LSE and commercial interest from a non-LSE/commercial offtaker. Now that interest from a commercial offtaker is included in the Scoring Criteria, IEPA recommends increasing the points for “non-LSE interest” from 25 to 50 points, and reducing LSE allocations from 100 to 75 points, to ensure value is given to projects that interest commercial offtakers. Finally, IEPA recommends reducing the “commercial interest” category from 30% to 10%, since “project viability” and “system need” are more reflective of project readiness than “commercial interest.”

“Project viability” should be awarded an additional 15%, to make the category worth a total of 45%. Project viability is the most important aspect of a project in the queue and more emphasis on this category, especially with the breakdown of points, will allow for more competitive applications.

“System need” should be awarded an additional 5%, to make the category worth a total of 40%. However, the split between “ability to provide Local RA in an LCRA with an ISO demonstrated need for applicational capacity in that local area” and “long lead-time resources” should be equal, rather than 100 and 50. While the grid transitions to cleaner resources, it is imperative local RA is in the queue to ensure investments are going towards resources that are reliable and available. Long lead-time resources are needed for the transition, but prioritizing their applications in the queue, instead of allocating equal points to Local RA, puts the grid at risk for not meeting clean energy demand.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

 IEPA does not have further comment on this section.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Due to stakeholder feedback about the difficulty for projects to remain in the TPD allocation cycle without a PPA when experiencing longer than anticipated network upgrade delays, IEPA recommends additional workgroup discussions on this section prior to finalization.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

IEPA does not have further comment on this section.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

IEPA does not have further comment on this section.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

IEPA does not have further comment on this section.

9. Additional comments:

IEPA does not have further comment on this section.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

No comments.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Intersect Power does not support the idea that Energy Only (EO) projects be scored in the same manner as those seeking deliverability. If the CAISO is concerned with an influx of EO projects, a concern which has been downplayed by the CAISO to-date, then the implementation of an additional filing deposit would likely be more appropriate.

One area that requires additional clarification from the CAISO, is how it will assess Interconnection Requests (IRs) that have co-located technologies, such as solar PV and BESS, that are seeking different deliverability statuses for those technologies. For example, if a developer submits an IR contemplating a 100MW max output at the POI, with 100MW of solar PV and 50MW of BESS seeking EO for the PV and Full Capacity Deliverability Status (FCDS) for the BESS, how will the CAISO assess from scoring and counting against the 150% cap? If a developer is competing for both EO and FCDS portions, and only one technology prevails in the scoring process, there’s a high likelihood that the developer may not choose to proceed with the IR entirely. It would greatly simplify the process to not require the EO components to be scored, and instead limit that evaluation to the FCDS/PCDS portions of the IRs.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Intersect Power (IP) appreciates the intent of CAISO’s initial scoring rubric framework, however, IP is deeply concerned about the outsized weighting of Commercial Interest and System Need relative to Project Viability. Additionally, the lack of differentiated project viability criteria is alarming, and as currently contemplated, the scoring rubric provides very little insight into actual project or developer viability. As has been raised in all of IP’s prior comments, IP is opposed to the implementation of the zonal approach due primarily to the fact that it favors central planning assumptions over developer-informed insights of viable and economic POIs. The CAISO’s proposed scoring rubric further diminishes the value of project and developer differentiation by essentially ignoring all meaningful viability enhancing indicators. IP puts forth the following recommendations that seek to provide a more appropriate balance between Commercial Interest, System Need, and Viability, and offer the opportunity for projects and developers to differentiate their likelihood of success.

IP’S PROPOSED SCORING RUBRIC

RATIONALE FOR IP'S PROPOSED SCORING RUBRIC

Commercial Interest

• Non-LSE Interest: CAISO’s proposal of counting Non-LSE interest as a quarter of the value of LSE interest is a stark change of policy as compared to the current TPD scoring process wherein Non-LSE interest has the ability to be counted on equal footing for LSE interest. How does CAISO justify this dissonance between the two scoring processes? At a minimum, IP is proposing to increase the Non-LSE Interest to 50 points, but a full 100 points could also be justified based on current precedent.

Project Viability

• Weight: IP increased the weight of the Project Viability category to 50% to reflect the importance of project and developer viability when judging the merits of whether a project’s Interconnection Request (IR) is more deserving for inclusion in the Cluster Study process.  
• Engineering Design Completeness: IP removed the Engineering Design Plan Completeness indicator as it does not provide any valuable insights into project advancement or viability. Every developer can easily engage an engineering consultant to develop a design/cost estimate based on the known or assumed conditions of the site. Designs can be developed based on highly conservative assumptions without any real field data, which will cover a vast majority of the possible site conditions, and thus capable of meeting the highest proposed percentage complete milestone. This clearly does not indicate a project is more viable, it simply exhibits that a developer was willing to pay internal or external resources to produce a design and cost estimate. CAISO could simply implement a higher filing fee to the same effect.
• Site Control >90%: IP added an indicator reflecting a project’s achievement of site control above and beyond the minimum 90% threshold. Inclusion of a minimum threshold is welcomed, and also required by FERC, but failure to award benefits to those that go above and beyond the minimum is a missed opportunity. The points in this category would be awarded on a sliding scale, for instance, if a project can evidence 95% site control it would receive 5 of the available 10 points.
• 100% Site Control for Gen-Tie: IP adjusted the points for this category from 40 to 15 to more appropriately reflect the value of this indicator relative to the other viability criteria proposed by IP. IP is also proposing that CAISO explicitly exclude from the definition of gen-tie site control the requirement to have rights secured that may be subject to CEQA, such as encroachment permits with CalTrans or other public agencies. These rights typically take years to secure given the length of time to complete CEQA and the subsequent processes with the AHJ’s, can be ministerial, and would not be appropriate for a project at this stage.
• Procurement of Key Generator Equipment: IP included a new indicator to reflect advanced procurement of key generator equipment such as solar modules, batteries, wind turbine generators, thermal generators, etc. CAISO’s Draft Final Proposal indicated it may be both challenging to validate procurement milestones and unlikely that projects would have advanced procurement at this stage, IP feels both concerns are insufficient rationale for omission of such a critical component of a project’s success. Supply chain certainty has been, and will almost certainly continue to be, a key factor of a project’s timing and in some cases project success. Developers that are not proactively planning to secure their critical supply chains years in advance of construction, are going at risk global supply chain dynamics that have seen a substantial increase in volatility. IP strongly urges CAISO to include a procurement indicator for key generator equipment, which could be validated by either (A) a framework supply agreement at the company (developer)-level, or (B) supply agreements at the individual project entity (IC) level. The value of company-level supply agreements should not be discounted. These agreements reflect a commercial relationship, with monetary downsides if one side fails to perform, and they provide the company and its projects with certainty and security for the critical components used to generate energy. A lack of commercial relationship in this regard should be concerning to the CAISO as opposed to the fear that the company-level commercial relationships are disingenuous.
• Supply Chain Security: Tiering off of IP’s proposed Procurement of Key Generator Equipment indicator, IP is also proposing the inclusion of a Supply Chain Security indicator, which awards points for projects that can attest to the fact that their procured key generator equipment are products manufactured in the United States. As we saw before, and to a greater extern during COVID, global supply chains, and foreign economic policy have the ability to completely destabilize our industry. Foreign manufactured solar modules have encountered multiple challenges spanning from a complete blockage into the United States, to higher costs due to imposed tariffs. The Inflation Reduction Act of 2022 marks the single largest investment in climate and energy in American history. It heavily incentives domestic manufacturing, which will result in cascading economic benefits domestically, and will also provide a secure, reliable source of key generator equipment for our industry. This needs to be acknowledged as a key differentiator for project viability, project timing certainty, and ultimate likelihood of success.
• Expedited Judicial Review or No Discretionary Permits: Considering the importance of land use permitting within the state of California, the lack of any permitting related indicators from the scoring rubric is concerning. IP is proposing that projects be awarded points for either (A) attesting to the fact that no discretionary permits are required, or (B) evidencing that the company has the intent and experience to qualify for expedited judicial review under California’s SB-7 as extended by SB-149 or AB 205 (or an equivalent in other states). Securing expedited judicial review is a critical deterrent to frivolous lawsuits under CEQA and limits schedule impacts caused by a lawsuit to a defined and manageable amount of time.
• CEC Land Use Screens: Considering the CAISO is proposing such a large dependence on CPUC and CEC inputs in limiting where generating resource can be sited, it would be natural to evaluate the land use screening criteria that informs resource plans in the assessment of project viability. For example, the CEC’s 2023 Land Use Screens for Electric System Planning report (https://www.energy.ca.gov/publications/2022/land-use-screens-electric-system-planning-using-geographic-information-systems) identifies potential solar development areas within the state that have the lowest system-wide biodiversity and community impacts. The CPUC and CAISO use these land use screens in their electric system planning process to identify transmission system upgrades to accommodate the lowest-impact, highest-benefit clean energy transition.
• Evidence of Company Past Success: While project viability is critical, it is also essential that the companies and individuals working to develop those projects have the necessary experience and credentials to succeed. IP has added an indicator that would require the IC to provide evidence or an attestation that they have successfully developed project(s) of a similar scale culminating in the achievement of commercial operations.
• Expansion of a Generating Facility: IP is proposing to modify this indicator to assess whether the facility is adjacent to an existing facility, currently owned by the developer, that has a signed E&P or LGIA. IP feels that simplifying in this manner is superior due to the variety of possible situations such as shared interconnection facilities, shared rights-of-way, tiered permitting, ability to leverage stand-alone network upgrades, etc, that make assessment of the viability benefits by CAISO difficult and non-objective. IP is also proposing the point value be reduced to 10 points to better align with the other viability criteria proposed herein.

System Need

• Weight: Reduced to the weight to 20% to better reflect the importance of project and developer viability in the overall scoring of the IR.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

Intersect Power generally agrees with the CAISO’s proposal. However, Intersect Power continues to believe that the CAISO should allow Merchant Deliverability Option elections (fka Option B elections) for projects seeking deliverability in zones with available capacity that do not make the scoring cutoff, with the same up-front deposit required in areas without available transmission capacity.  Intersect Power sees great benefit to a scenario where developers voluntarily agree to fund additional transmission in areas with high locational demand, even if that would require some additional analyses in the study process. Otherwise, we the CAISO’s current proposal is simply delaying the inevitable, which is an irresponsible approach considering the lofty goals the state has established for non-carbon emitting resources.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Intersect Power agrees with the proposed modifications, subject to clarification from CAISO as to the timing of various elements related to the TPD process. It’s unclear from the proposed generic schedule in Figure 4 of the Draft Final Proposal when the TPD Affidavits and subsequent TPD allocations occur for a Cluster (lack of clarity is mainly due to the Task Description, which indicates a Year 1 Cluster schedule and Year 2 Cluster schedule and identifies the TPD milestones for the initial Cluster in the Year 2 row). It appears the Affidavits would be due immediately following the Cluster Study and the Allocation Study would occur simultaneous to a Re-Study. Can you please confirm that is the intention?

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

Intersect Power agrees with CAISO’s proposal.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

Intersect Power strongly supports the CAISO’s proposal. Intersect Power also requests that CAISO clarify that NTP for shared upgrades, and the associated 3^rd IFS, can be issued under the LGIA OR an Engineering and Procurement (E&P) Agreement. E&P Agreements are an essential tool for advanced, highly viable projects to accelerate their interconnection upgrades, but not having the ability to utilize this new mechanism under an E&P Agreement would undercut the effectiveness of this mechanism and be a massive missed opportunity.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

Intersect Power agrees with CAISO’s proposal.

9. Additional comments:

As in all of Intersect Power’s prior written comments, Intersect Power remains opposed to the establishment of capacity caps implemented on a zonal or constraint level and strongly encourages the CAISO to instead take a simpler approach by implementing a reasonable maximum total queue capacity and maximum number of projects for each Cluster. The zonal approach has several unnecessary complications and disadvantages including, but not limited to: (i) necessity to accurately define the zones geographically / electrically, (ii) determination of the base zonal capacities (which are inherently dynamic and heavily influenced by processes such as the TPP), (iii) rationalization and establishment of an arbitrary zonal capacity buffer (e.g., 150% of available or planned capacity), (iv) timing misalignment for transmission planning inputs and the establishment of cluster study assumptions, (v) necessity for bespoke Option B pathways, and (vi) the elimination of a valuable market feedback mechanism due to an overreliance on CPUC planning assumptions (further described below).

Intersect Power is primarily concerned with an overreliance on the CPUC portfolios, which are constructed using a variety of planning-level assumptions that carry a wide-range of uncertainty and accuracy, to constrain where developers can pursue projects. It is critical to maintain a robust, diverse, market-driven approach to generation development to ensure that realized portfolios (as opposed to planned portfolios) are the most cost-effective outcome for rate payers. The CAISO’s Transmission Planning Process (TPP), which relies upon the CPUC’s recommended generation portfolios, already analyzes impacts to the grid for the described portfolio and provides market signals, in the form of transmission upgrades, to generator developers for where resources are preferred based on techno-economic modeling outcomes. The CPUC’s current Busbar Mapping process utilizes commercial interest (i.e., the active CAISO interconnection queue) as one of its factors influencing portfolio creation, serving as a valuable feedback loop between planning institutions and market participants. Implementation of strict locational restrictions for generator IRs eliminates that valuable feedback loop and creates a self-fulfilling portfolio outcome entirely driven by the CPUC, lacking any real competitive pressure to challenge planning-level assumptions and their resulting outcome. CAISO is adopting an approach that heavily favors central planning at the expense of market-driven insights.

Given the CAISO has provided no indication for reconsideration of the zonal approach, Intersect Power strongly believes the 150% capacity buffer needs to be significantly increased (and CAISO should consider adding a minimum MW-level, i.e., 150MW, because 150% of an insignificant number is still insignificant), at a minimum for Cluster 15, due to several factors, including: 

1. The novelty of the of the concept and lack of precedent and objective rationale for its establishment at the current 150% level.
2. The lack of sufficient data for the market to assess caps by zone / constraint at the time of initial interconnection applications (note, site control efforts are well underway to support QC15 applications, and these rules are still in the process of being debated and devised).
3. Following QC14 TPD allocations, there may be little to no deliverability available in many areas, thus, this approach will effectively close off the queue for potential deliverable projects in those areas and eliminate any ability for new projects to provide insurance for queue attrition.
4. The inability for CAISO, or any stakeholder, to accurately foresee potential negative ramifications of these drastic changes to the study process. 

These factors serve as more than sufficient justification to err on the side of conservatism, i.e., to study a larger amount. The 150% study cap may be where the CAISO ultimately settles in future clusters, but it would be prudent to start at a higher level and refine the cap down (if necessary) once the process has been utilized and the proper evaluation of outcomes can be assessed.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

LRE supports the LSA comments and has no additional details to add.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

LRE supports the LSA comments and has no additional details to add.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

LRE supports the LSA comments on this issue and wants to highlight the following points:

• LRE encourages the CAISO to consider a further reduction in the commercial interest scoring weighting from 30% to 20%. The project viability and system need scoring elements lack granularity and do not offer many opportunities for projects to differentiate themselves. As a result, many projects might end up with the same score but for the commercial interest component. Therefore, the way the scoring criteria is currently designed puts undue weight on the commercial interest which is a component that is out of the control of the IC and unrelated to whether the project is likely to reach commercial operation.
• LRE does not believe the engineering design plan completeness is an accurate measure of project viability. Design plans can easily change from when a project first enters the interconnection queue to when the project reaches commercial operation. This scoring component creates the incentive for ICs to submit a plan to maximize total scoring points rather than the final plan, which undermines the purpose of the viability scoring criteria. The likely effect of this component being used in the scoring criteria is that all ICs submit a plan to get the full 20 points for their projects and the component ends up not being a differentiator between projects.
• LRE supports the LSA recommendations for the CAISO to adopt the alternative criteria that would better evaluate the viability of a project:
  • Overall developer experience/success at bringing on-line and/or operating projects of the technology type and size of the proposed projects, similar to that element in the CPUC “RPS Project Viability Calculator” (https://www.cpuc.ca.gov/search#q=%22viability%20calculator%22&sort=relevancy).  That scoring measure counts by the CPUC for up to 25% of a project viability score, with “project development experience” weighted to 20% and “ownership/O&M experience” worth up to 5%.

This broad experiential measure would capture, not only productive relationships with vendors, but also overall competent and experienced project construction skills and operating experience. 

• • Master Service Agreement for purchase of major equipment, such as transformers, inverters, and/or key technology-specific equipment.
  • Purchase order for such equipment by the LLC or other ownership entity, with extra points for a demonstration that the equipment is specific to the site or project.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

LRE supports the LSA comments and has no additional details to add.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

 LRE supports the LSA comments and wants to underscore the following points for this section:

• LRE does not understand the CAISO’s rationale for limiting TPD allocation requests for EO projects. As long as EO projects can meet the applicable milestones, they may be just as or more viable than other projects in the queue and may even be able to come online sooner than those in Groups A, B, and C. Therefore, if the CAISO does not allow these projects to request TPD allocation, the new rules would be creating unnecessary roadblocks for otherwise viable projects to secure TPD allocation and come online.
• Specifically, EO projects currently in the queue may have entered the queue assuming the current rules would apply and expected to maintain the ability to request TPD allocation if they qualify. The CAISO should not change this rule for ICs that made business decisions based on the rules that were in place at the time – and continue to be in place today. If the CAISO decides to move forward with this rule change, LRE requests that it apply to prospective queues only so that ICs will have more certainty of what rules will apply as they develop EO projects.
• A significant number of upgrades in the southern part of the CAISO system were approved for the 2022-2023 TPP, whereas upgrades in the north are expected, but have not yet been approved for the 2023-2024 TPP. Due to the misalignment between the TPP and the TPD allocation process, this means that if the new rules concerning EO projects goes into effect, EO projects in the northern region will not receive equal treatment to those in the south as the TPD acquisition needed to support the PPAs they are negotiating will not likely occur until the next allocation cycle.
• LRE supports the LSA recommendation that if the CAISO decides to move forward with the EO proposal, it should consider the following exceptions:
  • Pre-C15 EO projects in the queue, at least for the next TPD allocation cycle. That would at least give them prior notice before this option was removed.
• • EO projects in the north, in the next TPD allocation cycle.  This would give them the opportunity to secure an allocation from the expected new transmission capacity in the 2023-2024 Transmission Plan.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

LRE supports the LSA comments and has no additional details to add.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

LRE supports the LSA comments and has no additional details to add.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

LRE supports the LSA comments and has no additional details to add.

9. Additional comments:

LRE supports the LSA comments and has no additional details to add.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

LSA fully supports CAISO efforts to provide consistent, consolidated, usable data, by POI and zone, and offers the comments below.

General comments:  Many activities in the schedule are not clear.  For example:

• The “bubble” for TPD affidavits looks like it is 2.5 months long, but affidavits are usually due on a specific date.  Is that date the first part of the bubble (mid-February) or the last part (late April)?  Is the 2.5-month period also supposed to cover validation of the affidavits?  If so, why is there a two-month period between the TPD Affidavit bubble and the beginning of the TPD Allocation Study bubble?

• The CAISO has yet to define the contents of the three studies shown, from FERC Order 2023, in the context of the CAISO’s markets and studies.

• The timing and other details of the security postings should be added to the timeline, so it’s clear what information Interconnection Customers (ICs) will have when those commitments are made.

Specific comments

• The timeline shows update timing for heat maps but not update timing for the rest of the information listed in the Proposal.  This information package should be provided at least six months before the IR submittal window deadline. 

(This proposal should be combined with LSA’s earlier suggested “cutoff date” for information to screen/score IR submittals for Cluster 16 and beyond.  For example, if the IR submittal window will be in April, CAISO can use the prior June 1^st as the cut-off date for assumptions to be used for Intake processing.  That date would allow for completion of other processes (e.g. TPP and TPD allocation) that affect the next cluster cycle. 

• The IR submittal window should occur after the March 31^st draft Transmission Plan is issued.  There is not enough information in the November TPP meetings for ICs to determine where additional transmission capacity will be recommended and thus available.

• The CAISO should add to the timeline the CAISO’s interpretation of the financial-security posting requirements under Order 2023.

• In addition to providing the above information/clarifications, the CAISO should inform stakeholders about the timing for the 2025 TPD allocation cycle. Projects under development need this information in order to properly time their development activities to qualify for high-priority TPD allocation groups.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

LSA continues to believe that FCDS projects scoring below the points cutoff threshold should be allowed to fund Merchant Option upgrades.  LSA sees no harm in allowing transmission expansion on a merchant basis within zones having available capacity.  The additional ADNUs would provide additional grid benefits beyond the project interconnection. Merchant Option projects in these zones can help increase generation supply and help mitigate potential market power by increasing competition.  

Moreover, portfolio mapping is an inexact science, and Merchant Option ADNUs can provide additional capacity in promising development areas, to better reflect demand for projects in those areas and potentially reduce the need for upgrades in less-promising areas.  

LSA’s remaining comments in this area focus on Energy Only (EO) Resources. 

General comments

LSA has long supported reasonable applicability of Commercial Viability Criteria (CVC) and other viability measures for EO projects.  However, LSA believes that the CAISO’s proposals for EO Resources reflect conflicting goals that are leading to policy inconsistencies. 

On the one hand, the CAISO says it wants to “provide a path” for such projects, in light of their presence in the CPUC portfolio and recent Energy-Only contracting activity for the REC value.  On the other hand, the CAISO is proposing to add many obstacles to such projects, e.g.:

• Remove or limit their ability of existing EO projects in the queue, and new (Cluster 15+) projects, to request TPD allocations, even where they qualify to do so and may be further along in the development process than newer projects requesting allocations;

• Require them to remove their EO capacity from the queue (downsize or withdraw) if they transfer their deliverability to other projects as allowed under the tariff, unless they immediately provide an executed EO PPA; and

• Subject them to minimum scores under a scoring rubric that they are unlikely to meet.

The CAISO thus should generally consider its policies for Energy Only projects in a more holistic fashion, to ensure a rational and consistent approach. 

Specific comments

Treatment of Cluster 15 and later Energy-Only projects – scoring rubric

LSA does not object to the concept of using the scoring rubric to screen EO IRs in zones with available capacity.  However, the specific scoring rubric under consideration is not likely to allow for much EO project study participation.  For example:

• Commercial Interest:  LSEs are only assigned evaluation points based on their share of available TPD, and it seems unlikely that they will use these points to show interest in EO projects where no deliverability benefit is expected.  Even if EO projects can demonstrate considerable interest from non-LSEs, the lower points a in that category won’t make up for lack of LSE interest.

• System Need:  They will likely not qualify for any of the points in this category.

Thus, even if they score high for Project Viability, EO Resources are unlikely to gain more than 35 weighted points of the possible 100.  If the CAISO wants to provide a meaningful opportunity for EO Resources, it should either add readiness criteria that EO projects can meet or otherwise revise the criteria to provide that opportunity (e.g., change weighting scheme for such projects). 

The CAISO could also use an approach suggested by AES, i.e., exempt EO projects from the scoring rubric (per the CAISO’s prior proposal) but require an additional financial posting as a viability demonstration.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Applicability of scoring rubric:  LSA does not understand the proposed requirement that projects submitting Interconnection Requests (IRs) in areas without available capacity be required to self-score based on the scoring rubric.  The rubric will not be used for any purpose for those projects, so the self-scoring requirement seems pointless.

Commercial Interest scoring element  

LSE interest

LSA is very glad to see the elimination of the earlier proposal to allow all resources in an approved non-CPUC-jurisdictional LSE resource plan to evade the readiness scoring rubric applicable to other resources, thereby reducing the capacity available to those (possibly more ready) projects.

LSA also supports the weighted-points total reduction from 40% to 30% and urges the CAISO to apply a further reduction to 20%.  As many have said, it’s quite possible that there will be points ties in the other areas, making LSE Interest the critical determinant of which projects are studied.

LSA urges the CAISO to keep these features of its proposal intact:

• Full allocation election:  Some stakeholders were concerned that “very small” LSEs electing this option would not be able to commit to much capacity, e.g., an LSE with 16 allocation points could only apply this to a resource with a maximum of 24 MW (150% of its allocation points). 

However, resources supported by only these small LSEs can downsize like other projects if they do not receive interest from other LSEs, so they would still qualify for the full number of weighted points and be able to support the load needs of the small LSE.  They could also seek interest from non-LSEs. 

It would certainly distort the process if the hypothetical small LSE above could use this election for, e.g., a 100-200MW resource and thus crowd out otherwise higher-scoring resources supported by other LSEs.  If such LSEs can extend their points allocation to resources that exceed their need by such large amounts, then the additional capacity accepted as a result should not be allowed to exclude other viable resources, i.e., it should not count toward the 150% limit.  

• LSE self-build limitation:  The CAISO should retain the LSE self-build allocation limit of one project per cycle.  LSE interest can be used to support multiple projects, and large entities like SCE (the most vocal opponent of this element) have many points they can use for that purpose.

Non-LSE interest

LSE is glad to see a provision for non-LSE interest.  However, the cap on points that can be earned – only ¼ of the total that can be awarded for LSE interest – is too low.  Instead, the CAISO should take a page from its new non-LSE rules for TPD allocations and allow non-LSE interest to count as much as LSE interest, with a deposit required if the developer or non-LSE does not have an RA arrangement with an LSE.

Project Viability scoring element

Design completion:  This element is vague, and (as some have pointed out) spending money for a design plan (which at this point would likely not reflect permitting or other site-specific factors) is not really meaningful.  LSA suggests below some other potential criteria that could be used to implement this concept.  (These criteria were suggested in LSA’s earlier comments but not responded to by the CAISO.)

• Overall developer experience/success at bringing on-line and/or operating projects of the technology type and size of the proposed projects, similar to that element in the CPUC “RPS Project Viability Calculator” (https://www.cpuc.ca.gov/search#q=%22viability%20calculator%22&sort=relevancy).  That scoring measure counts by the CPUC for up to 25% of a project viability score, with “project development experience” weighted to 20% and “ownership/O&M experience” worth up to 5%.

This broad experiential measure would capture, not only productive relationships with vendors, but also overall competent and experienced project construction skills and operating experience. 

• Master Service Agreement for purchase of major equipment, such as transformers, inverters, and/or key technology-specific equipment.

• Purchase order for such equipment by the LLC or other ownership entity, with extra points for a demonstration that the equipment is specific to the site or project.

Expansion of related facilities:  The Proposal broadens consideration of related facilities to those under construction or in operation, instead of just in operation.  LSA supports this change but suggests that it could go further, providing an easily-verifiable means of adding points granularity that could help avoid scoring ties.

Specifically, given the synergies and economics of sharing equipment and other facilities, the CAISO could add points tiers for expansions of projects in the queue that have:

• Made their second postings
• Executed GIAs in good standing
• Provided third postings and Notice to Proceed

System Need scoring element

Local RA capacity:  LSA agrees with New Leaf Energy’s prior comments that the CAISO should clarify the “determination of need” aspect, such as: (1) the time horizon (e.g., 1-year or 5-year technical study results); and (2) treatment of uncertainty (e.g., possible margin of error).

Long-lead-time resources:  LSA understands this element as the continuation of the capacity-reservation proposal in the TPP Enhancements initiative, and understands the comments of others that this significant points boost does not constitute a reservation.  LSA believes that the CAISO should only consider this points boost for a limited amount of capacity tied to the amount of capacity for the identified technology, to avoid having these additional points used to unnecessarily crowd out other resource types. 

For example, if the CPUC portfolio identifies 1,000MW of that technology for a specific zone and the TPP approves capacity for that amount of generation, the points boost would only apply to a maximum of 1,500MW (up to 150% of the reservation amount, to allow for attrition) – perhaps the projects of that technology scoring the highest in the other categories – to help ensure that they would be selected for study without impinging on the capacity approved for other technologies.  Projects not receiving the points boost would compete for study on the same basis as other projects.

Alternatively, the CAISO could separately evaluate those technologies as competing against each other, again up to a cap of 150% of the approved capacity amount.  Lower-scoring projects in this group would not be studied in this cycle, to avoid reducing capacity approved for other technologies.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

LSA’s comments are in two areas: 

• The proposed revisions for Merchant Option ADNU incorporation into the Transmission Planning Process (TPP); and

• Additional revisions that should be made.

Merchant Opton ADNUs incorporated into the TPP

The language in the proposal was very confusing, referring to Merchant Deliverability ADNUs “approved” in the TPP, when only one of the two situations addressed was actually related to TPP approval.  LSA suggests alternative language below, based on its understanding after the stakeholder meeting discussion of the CAISO’s position, with clarification or correction requested if this description is not accurate.

Once Merchant Deliverability (MD) projects have executed GIAs, the ADNU they are sponsoring would be included in the base case for the next TPP, and the MD projects must then fund the ADNU and proceed as MD project(s). 

However, if the MD projects did not execute GIAs by the time the base case for the current TPP is established (so the ADNU was not included in this TPP base case) and the ADNU is approved as needed in the current TPP, the MD projects would:

• Be released from their funding obligation, and their ADNU security would be released.

• Retain their TPD allocation, if they demonstrate TPD Allocation Group A/B compliance within two years.  (The deadline would be the affidavit due date of the second TPD allocation cycle after the CAISO Board approves the transmission plan with the ADNU (e.g. for a May 2026 TPP Plan Board approval date, the MD project (s) must meet retention requirements by the 2028 affidavit due date).)

Additional Option B revisions that should be made:  LSA continues to believe that the CAISO should include these elements in its Option B reforms:

• Security forfeits to remaining projects:  GIDAP Section 7.6 should be revised to allow the full benefit of forfeited ADNU security to go to remaining Merchant Deliverability projects, where there are multiple sponsoring projects and one or more withdraws.  Specifically, if the CAISO is requiring additional up-front security for Merchant Deliverability customers to fund ADNUs, then this up-front amount should be added to any proportional allocation of other posted security to the projects that still must fund the upgrade.

• Provide advance estimates of potential CRR revenue for the applicable ADNUs, upon request.  Otherwise, it will be difficult for project sponsors to estimate net cost of an ADNU.  The CAISO has not provided a good reason why such estimates could not be calculated using existing methodologies.

• Allow reimbursement of Option B ADNU costs to the extent that sponsors can demonstrate system benefits.  These upgrades will be open for use by all as part of the CAISO’s transmission network, and cost reimbursement would be appropriate by the beneficiaries of such projects, as provided for under regional transmission-planning practices.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Treatment of pre-Cluster 15 EO projects – limitations on TPD allocation requests

LSA strongly believes that the CAISO has not provided reasonable rationale for limiting TPD allocation requests by EO projects to post-COD requests.  If these projects can meet the applicable milestones (e.g., they secure a qualified PPA), LSA sees no reason to exclude them.   There is no question of “gaming” the scoring rubric process for these projects, at least, since there was no such thing before now.

This proposal is completely contrary to the recent removal of inferior EO project treatment in the last TPD Allocation process (e.g., combining earlier Groups 1 and 4 into Group A, and combining Groups 2 and 5 into Group B).  These projects have been in the queue longer and may score higher in many viability measures than those just coming off the study process.

These projects may have been proceeding assuming that they could come back and request a TPD allocation if they qualify, and the CAISO should not change applicable rules at this late date.  This proposal was issued just a week before the closure of the current TPD allocation affidavit submittal deadline, e.g., essentially without notice to the affected projects of this critical change.

This proposal is especially unfair to EO projects in the northern part of the system, due to the current misalignment of the Transmission Planning Process (TPP) and the TPD Allocation Process.  Significant transmission upgrades were approved in the southern part of the system in the 2022-2023 TPP, and it is widely expected that such upgrades may be approved in the north the 2023-2024 plan.  There is currently activity PPA activity in the north in anticipation of those new upgrades, with the objective of Group A or B qualification in the next TPD allocation process, making the TPD acquisition needed to support this PPA activity much more likely in the next allocation cycle.

Finally, this proposal would likely stop in its tracks any energy storage additions to existing projects (operational or in the queue), as well as other capacity additions making use of existing facilities.  Those additions will simply not be viable without the ability to request and receive additional TPD allocations for their capacity, as TPD transfers from other fuel types are extremely limited under the current On-Peak Deliverability Assessment Methodology.  (The additional proposed points under the scoring rubric for such expansions reflect the attractive economics of such additions for new projects, and the same economic drivers apply to expansions under the same queue position.)

In summary, this proposal should be withdrawn in its entirety, for the reasons described above. 

However, if the CAISO nevertheless decides to retain this flawed proposal, it could be made somewhat fairer by allowing exceptions for, e.g.:

• Pre-C15 EO projects in the queue, at least for the next TPD allocation cycle.  That would at least give them prior notice before this option was removed.

• EO projects in the north, in the next TPD allocation cycle.  This would give them the opportunity to secure an allocation from the expected new transmission capacity in the 2023-2024 Transmission Plan.

• Expansions of projects in the queue under the same GIA or queue position.  This would avoid confounding the efficient use of facilities to support additional capacity.

Treatment of EO Resources reaching COD

The CAISO should clarify that EO projects reaching COD could request a TPD allocation under Groups A or B if they qualify, and not just Group C.  There is no policy reason to exclude these projects from those higher-priority groups if they meet the PPA-related qualifications, and in fact they should be even better qualified than new projects to receive an allocation since they have already demonstrated their economic and operational viability by reaching COD.

Treatment of Cluster 15 and later Energy-Only projects – limitations on TPD allocation requests

The issue of EO Resources in areas with available capacity later requesting a TPD allocation arose in the context of possible avoidance of the scoring rubric.  The concern was that EO projects would not be subject to the rubric, so they could come in avoiding the scoring when they wouldn’t otherwise qualify, and then deprive a more-ready project of its TPD allocation.

However, unless the CAISO does not revise its proposal so that more EO projects qualify (as recommended above), there is no reason to prohibit such EO projects from later requesting a TPD allocation.  EO Resources would still have to score high enough to pass the screening process for study despite the disadvantages described above, and if they qualify for an allocation later ahead of a project that came in as FCDS, there is no policy reason for excluding them.

The fact is that the scoring rubric, and its application so early in the project development process, will not be an ironclad indicator of which projects are most likely to progress.  If a project entering the process as Energy Only proves itself to be more viable (e.g., by acquiring a PPA), then it should be awarded a TPD allocation ahead of a project entering as FCDS that has not made as much progress.

Treatment of Cluster 15 and later Energy-Only projects – removal of Group D in favor of “three strikes and you’re out”

LSA would not object to this proposal as long as the CAISO:

• Changes its approach to allowing EO projects to later request TPD allocations, so that these projects would have a chance to come back after their initial three tries and request an allocation if system or project circumstances change.

• Clarifies how this proposal would apply to C15+ projects qualifying for Group B, i.e., allows them to modify their COD so they can still stay on the shortlist with a realistic COD.

• Clarifies how this proposal would apply to C14 projects that park after this TPD allocation cycle.  Would they still have access to Option D as they exit from parking in the next TPD allocation cycle, and/or would they have two more opportunities to request TPD?

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

LSA has long supported measures to remove non-viable projects from the queue, and it does not object to the concepts of GIA execution deadlines and Energy Only project viability criteria.  However, LSA has several comments to improve the Proposal proposals in these areas.

GIA execution deadlines

LSA continues to maintain that simply setting deadlines, without any other timeline or process structure, is simply not fair or workable.  These concerns were not ameliorated by the discussion at the stakeholder meeting – for example, it is still not clear whether each project must request a draft GIA on its own or dates when PTOs must tender such agreements, or a r. 

Instead, LSA still believes that the process would be much more transparent and effective if the CAISO would:

• Set uniform dates for PTO tender of draft GIAs for each “tranche” of contracts, without the need for each developer to request a draft separately, to ensure that sufficient time is left for reasonable negotiation and finalization.  LSA suggests tender dates approximately 4 months in advance of the respective execution deadlines.

• Set uniform turnaround times for drafts applicable to each side, e.g., two weeks. 

• Provide an appeals process if the deadline is missed through no fault of the developer.

The consequence of missing the deadlines is so severe – complete loss of the project – that this process warrants more structure than contained in any Proposal documents to date. 

Commercial Viability Criteria demonstrations

Decoupling CVC from COD:  With the proposed CVC demonstration at 7 years time in queue, the process of requesting COD extensions would essentially be decoupled from the CVC, e.g., a request to delay COD beyond 7 years in queue would not trigger CVC.  Instead, the CAISO should clarify that the only demonstration that must be met would be compliance with is the existing tariff provision below.

6.5.2      COD Changes

6.5.2.1  Time in Queue

As noted in Section 6.1.5, projects studied in the serial study process, the In-Service Date shall not exceed ten (10) years from the date the Interconnection Request is received by the CAISO and projects studied in the cluster study process the COD shall not exceed seven (7) years from the date the Interconnection Request is received by the CAISO.

Interconnection Customers requesting to remain in the queue beyond the allowable time in queue must clearly demonstrate that engineering, permitting, and construction will take longer than the applicable maximum period and that circumstances that caused the delay were beyond the control of the Interconnection Customer.  In addition, the Interconnection Customer must demonstrate how the requested COD is achievable in light of any engineering, permitting and/or construction impediments.  The CAISO and Participating TO will not unreasonably withhold agreement to this extension, but the Interconnection Customer must provide sufficient documentation to support the request in its modification request.

Definition of qualifying PPA:  The CAISO needs to clarify the definition of a qualifying PPA in the proposed CVC demonstrations.  Many early projects received their TPD awards before the current 5-year minimum term was applied for new TPD awards; consistent with CAISO practice, the required PPA terms should be consistent with the required PPA terms when the TPD award was received (or, for projects receiving deliverability before establishment of the TPD award process, when the interconnection studies were complete).

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

This proposal has not changed, and LSA still does not object to the CAISO’s proposal for all projects to provide third postings, NTPs, and (as a clarification from the stakeholder meeting) payment initiation for shared upgrades when the first sharing project moves forward.

LSA still considers related proposals – separate posting/NTP/payment timing for other upgrades, and PTO obligation to begin the upgrade – as integral to its support for this proposal.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

LSA supports the proposal for more flexible GIA amendment timing, with its new voluntary applicability.  As the CAISO has acknowledged, some developers will want updated GIAs as they go, while others would be content to receive an updated version at the end of the development process.  We note that the Proposal says that an executed and amended GIA would no longer be required to enter the New Resource Implementation Process (NRIP), which is critical to implementing this proposal.

However, the CAISO should add back into the Proposal its earlier statement that developers could receive a draft LGIA within 120 CDs of a request, e.g., if they need it for financing.  The CAISO said at the stakeholder meeting that it would “make it happen” if the request was made for a good reason, but that commitment needs to be more solid than that general statement.

9. Additional comments:

Phase Angle Measuring Units data

The CAISO issued a clarification on the afternoon of February 28^th stating that the proposal was to revise the Phase Angle Measuring Unit data resolution from 30 samples per second to 16 samples per cycle, which would provide the CAISO 960 samples per second. Unfortunately, LSA did not have sufficient time to vet this clarification with its members before the February 29^th due dates for these comments and thus cannot offer any feedback to the CAISO at this time.  LSA suggests that the CAISO defer this proposal to the July Board meeting, to allow for rational discussion and consideration.

Zonal auctions

LSA still believes that this mechanism will be complicated and is unnecessary; should the scoring rubric and DFAX tiebreaker be insufficiently limiting, LSA prefers simpler methods like pro rata awards and acceptance of all projects “on the margin.”

One-time withdrawal

LSA understands (though does not agree with) CAISO’s concerns about PTO impacts.  However, LSA does not understand why the CAISO is not willing to proceed with this concept where there would be no impact on PTOs, such as those listed below.  LSA requests further explanation for why the CAISO is not willing to make the withdrawal offer in these easily-verifiable situations.

• Cluster 14 projects, since withdrawal would not adversely impact PTOs or other projects.

• Other projects where withdrawal would not adversely impact PTOs or other projects because there are no costs, or the upgrades would be eliminated, e.g., those: (1) without Network Upgrades; (2) without shared Network Upgrades; and (3) where withdrawal would remove the need for Network Upgrades that are not Precursor Network Upgrades (PNUs).

• Other projects where withdrawal would not adversely impact PTOs because costs would be borne by other projects, i.e., those: (1) without executed GIAs; (2) with shared Interconnection Reliability Network Upgrades (IRNUs); (3) with upgrades that are Conditionally Assigned Network Upgrades (CANUs).

This concept could be extended to other groups as well.  With just a little more nuanced approach, the CAISO could offer this opportunity to many projects while avoiding adverse PTO outcomes.

TPD transfers

Please see LSA’s statements above about contradictory policies applicable to EO projects.  The CAISO could support these potentially still-viable EO projects by allowing these potentially still-viable EO projects to:

• Provide an EO PPA within one year, or alternatively, require provision of the third posting and Notice to Proceed under the GIA as an interim viability demonstration, instead of forcing projects transferring their deliverability to others to downsize or exit the queue immediately if they do not provide an EO PPA.

• Seek a new Group A/B award if they qualify, on the same basis as other projects, instead of providing that the project can only seek a new TPD award under Group C, i.e., if the project reaches COD as Energy Only.  There is no reason to disqualify them from a new award if they otherwise qualify.

Long-term Interim Deliverability

LSA agrees that recent changes in the Generation Deliverability Assessment Review initiative will help some resources get FCDS faster under limited circumstances.  (We don’t know how many, despite requests for this information.)  However, it appears that many or most resources won’t meet those conditions, leaving years between their CODs and their FCDS status or, alternatively, forcing them to postpone their CODs despite the urgent system need.

LSA believes that the CAISO should continue to pursue this concept to provide at least some actionable information for PPA contracting, even if the amount available may be small.

Deliverability-award information

As a separate matter, the CAISO should revise its TPD Allocation award processes to include information about the upgrades needed to implement awards and the expected in-service dates of those upgrades.  This additional information should be included in the notices for this allocation cycle in May; the CAISO should also go back to prior awards where the resources are not yet on-line and provide this additional information as well, to avoid last-minute unpleasant surprises when a resource reaches COD.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

The proposed generic schedule seems reasonable.  As stakeholders have offered, it would be ideal to have information about the availability of deliverability before the request window; in the CAISO’s generic schedule, that information is available on a lagging basis, which may be the best that can be done.   

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

MRP has no comment on this aspect of the Draft Final Proposal (DFP). 

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

The “wild card” in the proposed scoring criteria continues to be how the LSEs will use their substantial interest weight to influence the scoring process.  MRP appreciates that the CAISO has clarified that LSEs may award LSE-interest points to only one utility self-build project (which could, as the CAISO acknowledges, take up the entire 150% capacity to be studied within an area).  MRP would prefer the LSE interest number to be as small as possible and remains concerned that this scoring category will detrimentally affect competition.   

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

MRP's only comment on this aspect of the proposal is to acknowledge the CAISO has undertaken reasonable efforts to preserve this option, which no project has yet used, but might use. 

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

MRP looks forward to the CAISO proposing criteria for how to rank projects seeking an allocation of TPD and supports continuing the TPD allocation discussion beyond the IPE 2023 Phase 2 process as needed.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

MRP has no comments on this aspect of the DFP. 

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

MRP has no comments on this aspect of the DFP. 

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

MRP appreciates the CAISO’s response to MRP’s concern about this aspect of the proposal.  While MRP does not dispute the CAISO’s assertion that the GIA amendment process cannot be started until the MMA process is complete, MRP’s concern – perhaps too obliquely stated before – is that the CAISO and PTOs often do not keep to the timeline for processing MMAs.  MRP understands the CAISO’s observation about that the challenges of dealing with a large number of MMAs, but offers that the CAISO simply slipping the deadline is not a solution that provides much comfort for the developer, as such a delay impacts the ability, and timing, to obtain financing.  MRP would like to see the CAISO and PTOs hire the staff they need to timely process these requests or amend the tariff to include achievable deadlines.

9. Additional comments:

MRP commends the CAISO on its efforts to improve its generator interconnection process and the transparent, thorough way it has engaged stakeholders through this process.  After this monumental effort, MRP offers one last observation: the most efficient, effective interconnection process will not be able to keep California on track to meet its climate goals as long as it takes ten years to develop transmission and only three years to develop generation, with generation development leading and transmission development always playing “catch-up”.   MRP therefore respectfully urges the CAISO to more proactively plan and develop transmission.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

Comments in this section are focused on requests for greater transparency into how CAISO uses remedial action schemes (RAS) and congestion management (CM) in deliverability studies. We offer comments on the timeline and sequencing of queue intake and TPD allocation in Section 5 of these comments.

In our comments on the Revised Straw Proposal, we requested that CAISO make available more methodological details on how it uses RAS and CM in deliverability assessments. We suggested that CAISO publish data files that govern each RAS, either publicly or under NDA with market participants.

CAISO staff referred us to the ISO Planning Standards, a document that outlines transmission system planning guidelines that complement NERC and WECC standards to maintain a reliable transmission system in California. The descriptions are helpful in informing developer inferences about how CAISO implements RAS and CM, but are insufficient to support accurate modeling.

We reiterate our request for more transparency on the design and implementation of RAS in CAISO. We also specifically request that for each RAS in use, CAISO should publish the current available headroom on the existing RAS so that developers can know the injection allowable under the RAS. Additionally, we request that CAISO provide information on how RASs impact system conditions under different contingencies. One specific request is for descriptions of which elements of the transmission system are affected by a RAS under each contingency. Absent this information, it is difficult for developers to understand violations that may be caused or affected by RAS under different contingencies. It is critical that developers be able to accurately model RAS that are employed both to mitigate a contingency, and that might cause violations in certain contingencies.

We urge CAISO to provide more transparency into its implementation of RAS. Ultimately, this will allow developers to better assess system deliverability and submit more viable interconnection requests.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

In its current proposal, CAISO proposes to limit the intake of Energy Only (EO) resources in the same way that it proposes to limit capacity resources (i.e., those requesting FCDS/PCDS) by scoring them and only admitting for study IRs that score higher than the marginal capacity resource IR. CAISO’s current IR cap proposal is based on a measure of Transmission Plan Deliverability (TPD) that is fundamentally designed to capture headroom for capacity resources. MN8 believes that this is an inappropriate basis for limiting the intake of EO resources, which do not require deliverability.

MN8 continues to oppose CAISO’s proposal to cap IRs at intake; we offer more on this in the comments below. That said, if CAISO insists on retaining caps and a scoring mechanism, then we contend that it is inappropriate to limit EO resources on the basis of TPD availability, which is fundamentally a measure for capacity resources. During the February 15 workshop, staff informed stakeholders that while EO resources would not be expected to require deliverability network upgrades (DNUs), they could theoretically require reliability network upgrades (RNUs) because of short circuit duty or dynamic instability impacts, for example. We request that CAISO consider whether there are more appropriate ways of managing the volume of EO projects seeking to interconnect that might be based on a measure of EO availability.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

We continue to oppose CAISO’s proposal to limit intake to 150% of TPD capacity. As we have written in previous rounds of comments, we believe the proposal eliminates projects prematurely when there is still a high degree of uncertainty as to which projects are ultimately the most viable and competitive.

As we wrote in our comments on the Revised Straw Proposal, we continue to recommend that CAISO follow a phased approach in which it first implements FERC Order 2023 requirements for Cluster 15 before returning to the stakeholder process as needed. If CAISO insists on capping and scoring IRs at intake, then we would offer an alternative, next-best proposal, which we articulated in our comments on the Straw Proposal, wherein CAISO would raise the cap to at least 250% of transmission capacity and, when there are ties, advances all tied projects.

We offer these comments on CAISO’s criteria as written in the Draft Final Proposal not as an endorsement, but to give feedback on how CAISO might make marginal improvements to its current proposal.

Commercial Interest

We do not support a scoring process that relies on LSEs awarding points to projects. We feel that this is too early in the project lifecycle for LSE’s to be able to assess meaningful differences between projects, and thus, such an assessment and awarding of points would not in fact be indicative of project viability.

Should CAISO decide to move forward with this proposal nonetheless, we propose a slight modification to the existing points allocation proposal that would limit the total amount of capacity that would earn LSE points within each cycle. We propose that LSEs should not be allowed to award points to more projects than whose aggregate MW total comprises 35% of the available TPD across the CAISO footprint. In other words, projects should not be able to earn partial credit. In practice, LSEs would be able to choose which projects they wish to allocate points but would have to give full credit to those projects (e.g., a 100 MW project must be given 100 points). Recognizing that it may be difficult to perfectly align an LSE’s point total with the capacity that projects are offering, it may be reasonable to allow LSEs to award its last points as partial credit to one project per cycle.

We suggest this proposal to ensure that this criterion does not have undue impact on the project selection process. During the February 15 workshop, CAISO staff explained that by limiting the number of points that each LSE gets to award to projects, LSEs would be required to be selective in how they administer points so that they could not influence outcomes for the entire studied queue. Our understanding is that CAISO expects that many projects that advance to the study round would not have been given preference by LSEs, which would encourage competition by allowing projects without LSE preference to compete for interconnection on their own merits. We are concerned that allowing LSEs to allocate partial credit to projects (e.g., awarding 50 points to a 100 MW project) is at odds with this expectation.

As MN8 and others have written, criteria for project readiness and system need are unlikely to differentiate projects because the points for Project Readiness are easily attainable for all interconnection customers (ICs) and the points for System Need are only attainable for a small subset of the types of projects that are seeking to interconnect in California. Therefore, it is reasonable to expect that earning partial credit for LSE interest could be critical for a project advancing to the study phase. We think that our “no partial credit” proposal mitigates this concern.

Project Readiness

We support CAISO’s proposal to award points to projects that have achieved 100% site control of the gen-tie as we think this is a reasonable indication of greater project viability for those using greenfield sites.

CAISO should include this as an option that is mutually exclusive of the options for “Expansion of a Generation Facility.” As currently structured, expansion projects can earn points for both expanding on an existing resource and for having site control at the gen-tie; this rubric gives undue preference toward retrofit projects over greenfield projects where both may be equally viable. Including “100% site control of the gen-tie” as one of four options that could be selected would correct this issue and award fair treatment toward both retrofits and greenfield projects.

System Need

Points awardable to projects that can address a limited set of specific system needs (e.g., local RA, long lead time (LLT) public policy resources) should be capped in proportion to the size of the given need. This reflects the fundamental principle of the zonal approach. For LLT resources, we propose that the CPUC and other applicable LRAs be responsible for awarding points to ICs. For local RA, we propose that the LSEs with local capacity need be responsible for awarding points.

For instance, if there is need for 100 MW of local RA within a zone with 500 MW of TPD available, then no more than 150 MW of projects should be eligible to earn points for their ability to provide local RA so that the remaining 600 MW that will be accepted into the queue will be the most viable projects that provide either generic RA or local RA. A similar constraint should be applied to LLT resources.

Further, we request that CAISO clarify if and how it proposes to limit local RA resources based on local charging constraints.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

n/a

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Under the zonal approach, projects will be admitted to the queue on the premise of there being sufficient TPD available in their zones for them to interconnect and receive a deliverability award. According to the timeline in Section 2.1 of the Draft Final Proposal, there will be an expected 2 or 3 TPD allocations before projects will be fully studied and have a reasonable chance of signing GIAs. If the deliverability that was the basis for project selection is made available during the TPD allocation process immediately, then there is a good chance that it will not be available at the time when projects that were admitted to the queue on the basis of that TPD are seeking an allocation. In these instances, projects might not receive deliverability awards. This is fundamentally at odds with the intent of CAISO’s intake proposal – the whole point of it is to study approximately as many projects as there is deliverability (factoring in some attrition). The parallel nature of the Cluster and TPD study processes complicates this.

One way to deal with this would be to earmark deliverability available at the time of intake, upon which the cluster size was premised, for projects in that cluster (or at least, until the first TPD Allocation occurred that the cluster could participate in). However, earmarking deliverability is likely not the most efficient use of the transmission system because it risks underutilization. We believe this is one of numerous reasons why the zonal approach to intake should not be adopted.

Zones without TPD capacity suffer from the current proposal as well. If additional TPD were to become available in a zone that was previously excluded to TPD Deliverability Option (formerly Option A) resources, then it is possible that this deliverability could be underutilized because there would not be a readily available queue of projects that could utilize the TPD once it becomes available. Under the status quo, this doesn’t happen because projects can “skate to the puck” in anticipation of TPD coming onto the system, which promotes an efficient use of the transmission system.

If CAISO retains the zonal approach and does not earmark deliverability for specific clusters, then MN8 proposes that customers that drop out of the queue because (1) they don’t receive a TPD allocation and (2) the available headroom during their TPD studies was less than what was available at intake, then those customers should get their interconnection financial securities (IFS) returned in full.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

n/a

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

n/a

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

n/a

9. Additional comments:

We thank CAISO staff for the time and effort they have given to the IPE process, and we thank them for the opportunity to share comments.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

New Leaf Energy, Inc. (“NLE”) appreciates the CAISO’s continued leadership in the Interconnection Process Enhancements (“IPE”) initiative and work on the Track 2 Draft Final Proposal.

The timeline proposed in the Draft Final Proposal is useful to help stakeholders think through sequencing of the CAISO’s interconnection and other processes. NLE suggests that it may be helpful to begin the Transmission Plan Deliverability (“TPD”) Allocation Study earlier and/or expedite it in order to provide the TPD Allocation Heat Maps prior to initiating the Cluster Study in early October, as currently proposed. It may also be useful for the Interconnection Request window to open after the CAISO releases the draft Transmission Plan in late March. Finally, NLE respectfully urges the CAISO to provide certainty on the timing for the 2025 TPD allocation cycle. Projects under development need this information to properly time their development activities and qualify for higher-priority TPD allocation groups.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

NLE does not have any comments on this item.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

a) Commercial Interest Category 

NLE supports the Draft Final Proposal reducing the maximum available points under the commercial interest category, but NLE remains concerned with the category and its high maximum point allocation for the following reasons:

• First, prioritizing projects selected by LSEs for study creates open access issues under Federal Energy Regulatory Commission (“FERC”) Order 2003. 
   
• Second, LSE interest may be the primary determinant of whether the CAISO accepts a project for study, even over other projects that score much higher under the other categories. This would place a disproportionate emphasis on LSE preference over other, more valuable criteria.
   
• Third, LSEs will not have sufficient information to select the most viable or valuable projects before they enter the queue. The projects will still be in the early stages of development when key information is not yet known—including permitting risks and interconnection costs, which are the primary driver of project viability and value.

If this category is retained, the CAISO should reduce the maximum number of points available to 10-20 percent of total points. Additionally, NLE supports the CAISO adopting the proposal to limit LSE point allocations to one self-built project each cycle. This is an appropriate limit to avoid preferential treatment of utility-owned resources.
 

b) System Need Category

i) Ability to Provide Local RA in a Local Capacity Resource Area (“LCRA”) with an Independent System Operator (“ISO”) Demonstrated Need for Additional Capacity in That Local Area

NLE supports the Draft Final Proposal’s point allocation for the Local RA criterion in the system need category. NLE has previously offered several suggestions to define “ISO-demonstrated need” for the criterion, but the Draft Final Proposal does not include a definition of this term.^[1] During the December 19, 2023 and February 14, 2024 IPE stakeholder meetings, CAISO staff proposed using the annual local capacity technical studies to determine whether a need exists in an LCRA, but the criterion still needs further clarification.

For the need determination, NLE reiterates its recommendations that:

• Projects in both LCRAs and sub-LCRAs showing deficiencies be eligible for points.
   
• The CAISO include a buffer of a reasonable amount (e.g., 10 percent) on the reported LCRA deficiencies when performing the need determination, as the deficiencies reported in the study are only estimates that are based on load and available supply estimates. Some areas where the LCRA need and capacity available are quite close might, in fact, end up experiencing a deficiency. Applying this buffer would help ensure that sufficient resources are coming online to resolve potential deficiencies.
   
• The CAISO clarify which reported deficiency years it will use in the need determination. The local capacity technical studies annually report deficiencies for one and five years into the future. For example, in the most recent local capacity technical studies, released on April 28, 2023, the CAISO examined system conditions in 2024 and 2028.^[2] Using the five-year projections—or perhaps new projections even further out—seems most prudent due to development timelines. 
   
• The CAISO not adopt the IPE Track 2 Revised Straw Proposal’s requirement that “sufficient capacity is available in the LCRA to charge any proposed new energy storage facilities without needed additional transmission as outlined in the annual local capacity technical study.”^[3] This additional restriction is unnecessary and unfair, and NLE supports its elimination from the Draft Final Proposal. The CAISO already examines charging capacity within the Transmission Planning Process (“TPP”), and the CAISO does not require batteries to demonstrate sufficient charging capacity in order to receive full capacity deliverability status. Batteries should therefore not be subject to this additional requirement in the IPE scoring rubric.

If the CAISO nevertheless adopts this additional restriction, it should provide information—within the package of information on available zonal capacity—regarding specific restrictions for qualifying LCRAs and sub-LCRAs. The CAISO should also clarify that any proposed battery with capacity less than the one-for-one replacement capacity for a four-hour battery, reported in the local capacity technical study, is eligible for points under the Local RA criterion. In other words, the CAISO should not withhold points from individual projects if the cumulative capacity of batteries applying for interconnection is greater than the identified one-for-one replacement capacity.
 

• The CAISO expand eligibility for this criterion to include more LCRAs and sub-LCRAs using the three additional methods described below to define “ISO-demonstrated need.” All of the following proposals would be administratively easy to implement, as they use existing sources of published data. The CAISO should apply all of these need determinations together, along with its proposal, to identify additional qualifying areas under the Local RA criterion. 

1. Fossil or other generation likely to retire in the applicable time horizon: Use the CAISO’s Net Qualifying Capacity (“NQC”) List—supplemented with data from the California Public Utilities Commission (“CPUC”) Qualifying Capacity Rules Final Classification List—to determine if an LCRA contains a certain percent of thermal generation (e.g., 25 percent or more) and/or other generation likely to retire in the time period considered.^[4] This would ensure that projected deficiencies properly account for future retirements.
    
2. RA price premium: Use the CPUC’s annual RA Report to examine whether there is a premium (e.g., of 20 percent or more) on Local versus System RA prices.^[5] This proposal would help identify LCRAs where supply for Local RA resources is tight.
    
3. LSE/Central Procurement Entity (“CPE”) procurement problems: Determine whether an LSE or CPE has documented procurement challenges in an LCRA. For example, San Diego Community Power (“SDCP”) submitted an advice letter to the CPUC reporting that, despite good-faith efforts, it was unable to secure contracts that would satisfy its entire Local RA procurement obligation.^[6] This proposal would help identify LCRAs where there are insufficient Local RA resources needed to satisfy procuring entities’ Local RA requirements.
    

ii) Long-Lead-Time Resources

NLE recommends that the CAISO place a time constraint on the long-lead-time resources criterion in the system need category. The CAISO should limit eligibility for this criterion to long-lead-time resources identified as needed within a certain number of years in the CPUC’s resource portfolios provided to the CAISO for use in the TPP.

Further, the CAISO should reduce the number of available points under this criterion by half to ensure that long-lead-time projects receiving points do not prevent all other projects in a zone from being studied. Many long-lead-time resources will likely be offshore wind resources or other technologies with generating capacities of 1,000 megawatts (“MW”) or more each, based on Interconnection Requests submitted to date. Providing 35 percent of total available points to these resources is too high of an allocation for projects that are likely more speculative than many other projects entering the interconnection queue.

[1] CAISO, 2023 IPE Track 2 Draft Final Proposal at 45 (Feb. 8, 2024), available at: http://www.caiso.com/InitiativeDocuments/DraftFinalProposal-InterconnectionProcessEnhancements2023.pdf.

[2] CAISO, 2024 Local Capacity Technical Study (Apr. 28, 2023), available at: http://www.caiso.com/InitiativeDocuments/Final-2024-Local-Capacity-Technical-Report.pdf; CAISO, 2028 Local Capacity Technical Study (Apr. 28, 2023), available at: https://www.caiso.com/InitiativeDocuments/Final-2028-Long-Term-Local-Capacity-Technical-Report.pdf.

[3] CAISO, 2023 IPE Track 2 Revised Straw Proposal at 40 (Dec. 12, 2023), available at: http://www.caiso.com/InitiativeDocuments/Revised-Straw-Proposal-Interconnection-Process-Enhancements-2023-Dec192023.pdf.

[4] See CAISO, Reliability Requirements, https://www.caiso.com/planning/Pages/ReliabilityRequirements/Default.aspx.

[5] See CPUC, 2021 Resource Adequacy Report (Apr. 2023), available at: https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/resource-adequacy-homepage/2021_ra_report_040523.pdf.  

[6] SDCP, Advice Letter 15-E, Request of San Diego Community Power for Waiver of 2024 and 2025 Local Procurement Obligations (Oct. 31, 2023), available at: https://sdcommunitypower.org/wp-content/uploads/2023/11/SDCP-AL-15-E-YARA-Local-RA-Waiver-Request_Public.pdf.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

NLE understanding of the Draft Final Proposal is that projects selecting the Merchant Deliverability Option are required to fund Area Delivery Network Upgrades (“ADNUs”) triggered for their clusters, which may include previously queued projects in the base cases studied. NLE recommends that ADNUs identified for Merchant Deliverability projects should only have to relieve Area Deliverability Constraints for the Merchant Deliverability projects’ capacity, and not also for the capacity of all the projects in the base cases.  

For example, if the total Interconnection Service Capacity for the Merchant Deliverability projects is 500 MW, the CAISO should determine the cost of upgrades to reduce the overload by 500 MW and assign those upgrades to those projects. It would be unfair to require the Merchant Deliverability projects to mitigate overloads caused by projects not willing to pay for mitigation.

Finally, the CAISO should allow reimbursement of applicable ADNU costs for Merchant Deliverability projects to the extent a developer can demonstrate system benefits from the relevant ADNUs. Because these upgrades would be available for use within the CAISO’s entire transmission system, cost reimbursement would be justified for any projects benefiting from the upgrades.  

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

a) Proposal to Limit TPD Allocations for Energy Only Projects

The Draft Final Proposal limits eligibility for Energy Only projects in the TPD allocation process to Group C (i.e., projects that have achieved commercial operation). As NLE has previously argued, limiting deliverability allocations for Cluster 14 and earlier queued Energy Only projects is unjust and would raise costs for ratepayers because it would prevent more mature projects from receiving deliverability awards. These projects have remained in the queue and continued to meet development milestones under the assumption that they could convert to Energy Only and later seek a deliverability award through TPD allocation Groups A and B.

The CAISO should therefore not adopt this retroactive change. At minimum, Cluster 14 and previously queued Energy Only projects should get three opportunities to apply for a TPD allocation under Groups A-C after FERC approves the IPE filing. In other words, the 2024 TPD allocation cycle should not count towards one of the three opportunities to apply for deliverability.
 

b) Prioritizing Resources that Provide Local RA within the TPD Allocation Process

As first presented in prior IPE comments, NLE proposes to add an additional Local RA component to the TPD allocation scoring rubric. As shown in the table below, the existing scoring rubric for the TPD allocation process contains four categories of commercial readiness criteria: Permitting, Power Purchase Agreement Status, Shortlist Status, and Land Acquisition.^[1]

NLE’s proposal would add a new column to the TPD scoring rubric. A project that the CAISO verifies is sited in an LCRA would receive 5 points. This would achieve the appropriate balance of giving Local RA projects a meaningful boost in instances where there is less deliverability available than capacity applying within a given TPD allocation group.

Prioritizing Local RA resources in the TPD allocation process would address the need for greater efficacy in the volume and location of interconnection requests that the CAISO studies.^[2] Giving points to resources in LCRAs would also advance state policy goals, as the retirement of thermal generation resources—many of which are serving as Local RA resources—is critical to meeting the state’s greenhouse gas reduction goals.^[3] Retiring these resources while maintaining reliability in LCRAs is only possible if new clean Local RA resources are commercially available. Moreover, this proposal would meet reliability needs by increasing the potential pool of commercially viable resources located in LCRAs, which are inherently more vulnerable during reliability events when System RA resources cannot always be counted on to serve load in LCRAs.

[1] CAISO Business Practice Manual: Generator Interconnection and Deliverability Allocation Procedures Version 33.0, Section 6.2.9.4.2 at 107-109 (Apr. 26, 2023), available at: https://bpmcm.caiso.com/Pages/BPMDetails.aspx?BPM=Generator%20Interconnection%20and%20Deliverability%20Allocation%20Procedures.

[2] CAISO, Summary of June 20 & 21 Track 2 Working Group Meeting Revised Principles and Problem Statements 1 and 2 at 4 (June 23, 2023), available at: http://www.caiso.com/InitiativeDocuments/Revised-Principles-and-Problem-Statements-Interconnection-Process-Enhancements-2023-Track%202-Jun%2020-212023.pdf.

[3] Senate Bill (“SB”) 100 (de León, 2018) increases the Renewable Portfolio Standard to 60 percent by 2030 and requires all the state's electricity to come from carbon-free resources by 2045. SB 100 (de León, 2018), available at: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

NLE does not have any comments on this item.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

NLE does not have any comments on this item.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

NLE does not have any comments on this item.

9. Additional comments:

a) Timing of Cluster 15 Validation and Study

The Draft Final Proposal stated that Cluster 15 interconnection request processing will likely resume in Q2 2024. During the February 14, 2024 IPE stakeholder meeting, CAISO staff clarified that the CAISO intends to delay resuming Cluster 15 until after the FERC rules on both the CAISO’s IPE filing and the CAISO’s Order 2023 compliance filing—meaning that the CAISO likely will not begin Cluster 15 validation until Q1/Q2 2025.

It would be useful for the CAISO to explicitly state a no-sooner-than date for switching Points of Interconnection before Cluster 15 validation begins. Additionally, because Cluster 15 projects will need to provide site control documentation before the Cluster 15 study commences, pursuant to Order 2023, it would be helpful for the CAISO to also explicitly state a no-sooner-than date for demonstrating site control. NLE respectfully urges the CAISO to include these no-sooner-than dates in the final IPE proposal, as well as in its IPE and Order 2023 filings, in order to provide more certainty to developers.
 

b) One-Time Withdrawal Opportunity

NLE encourages stakeholders and the CAISO to continue to explore potential options to create an effective withdrawal opportunity. The one-time withdrawal opportunity proposal—supported by many stakeholders—likely represents the most significant opportunity to relieve queue congestion and ensure that only the most viable projects remain in the queue. It is also the only proposal that would encourage developers to voluntarily withdraw nonviable projects.
 

c) Interim Deliverability

The first iteration of the IPE Straw Proposal stated the CAISO’s intent to “continue to work with stakeholders in both the IPE initiative and the Deliverability Assessment Methodology initiative to construct a methodology where a multi-year Interim Deliverability allocation process could bridge the gap between the in-service date of an LDNU and the project’s requested [commercial online date (“COD”)].”^[1] NLE supported the CAISO’s continued focus on this issue because it would help provide contractable assurance of Interim Deliverability. However, the CAISO declined to move forward with the proposal to provide longer-term interim deliverability for projects that can reach COD prior to the completion of associated network upgrades. The Draft Final Proposal justified this decision by stating “there is not expected to be a significant amount of longer-term interim deliverability available.”^[2]

NLE respectfully urges the CAISO to include an interim deliverability provision in the final IPE proposal even though there may not be a significant amount of interim deliverability available. Providing even a small amount of interim deliverability would help LSEs meet their procurement obligations. To implement this proposal, NLE encourages the CAISO to perform multi-year interim deliverability studies that include both ADNUs and Local Delivery Network Upgrades—taking into account each project’s current COD. NLE understands that this may lead to lower interim deliverability values for later years, but that is a better outcome than operating under the false assumption that interim deliverability is available.

[1] CAISO, 2023 IPE Track 2 Straw Proposal at 41 (Sept. 21, 2023), available at: http://www.caiso.com/InitiativeDocuments/Straw-Proposal-Interconnecton-Process-Enhancements-2023-Sep212023.pdf.

[2] CAISO, 2023 IPE Track 2 Draft Final Proposal at 71 (Feb. 8, 2024), available at: http://www.caiso.com/InitiativeDocuments/DraftFinalProposal-InterconnectionProcessEnhancements2023.pdf.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

NextEra Energy Resources, LLC (“NextEra Resources”) appreciates the opportunity to comment on the CAISO’s Interconnection Process Enhancements (“IPE”) – Track 2 Draft Final Proposal. In general, NextEra Resources is supportive of the proposed timeline of the new interconnection study process but has a few clarifying questions.  First, it is unclear if this timeline is intended to apply to Cluster 15 or Cluster 16.  Given the existing backlog to the interconnection queue, NextEra Resources requests that the proposed timeline apply to Cluster 15 projects so that the changes would result in a more immediate impact.  Second, NextEra Resources appreciates CAISO’s thoughtfulness in moving the opening of the Request Window to after the ISO Board of Governors’ approval of the annual Transmission Plan to better align with the most recent upgrades.  However, CAISO should also move the TPD Allocation Studies window forward, so they are completed prior to the opening of the request window to better align the TPD Allocation heat map with the new cluster study. The heat map is intended to identify areas where there is available deliverability but if the windows are not aligned then the heat map will only identify areas where deliverability has already been allocated, or, areas where deliverability is no longer available by the time the projects entering the queue are eligible to apply for TPD.  Lastly, it is unclear when a cluster would first be eligible to apply for TPD: in year two after the Cluster Study; in year three during the Interconnection Facility Studies; or even further out into year four? Any further clarification the CAISO can provide would be greatly appreciated, as TPD is critical to the development of almost all projects.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

No comment at this time.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

NextEra Resources appreciates CAISO’s attempt to simplify the scoring criteria and to provide clarity regarding how the criteria will be assessed; however, the latest proposal still contains a great deal of ambiguity.  From a purely administrative standpoint, CAISO needs to specify in the final proposal any limitations associated with how points are allocated to each of the indicators of project readiness.  For instance, in the stakeholder workshop CAISO indicated that an entity seeking points for non-LSE interest would be capped at 25 points notwithstanding the number of signed affidavits they provide.  This is an important caveat and level of granularity that should be captured in the final proposal to maximize transparency and to ensure that parties who are allocating points are not burdened by obtaining unnecessary documentation.

Additionally, the criteria for establishing project viability remains unclear and CAISO has placed too much emphasis on awarding points for System Need, which can change dramatically over time, and result in a misalignment with actual system needs when a project finally comes online.  While NextEra Resources is generally supportive of the categories, the weighting for prioritization should be changed as follows: Commercial Interest 35%; Project Viability 55%; System Need 10%. Commercial Interest can be an indicator of whether a project is viable and the 35% weighting is reasonable at this time.  Conversely, if the criteria established under Project Viability are clear and measurable then establishing a higher weighting of 55% for these indicators is reasonable to include prior to a project entering the queue because they aren’t driven by information that becomes known to a developer later in the interconnection process.  Additionally, the sub-categories in Project Viability should be adjusted to include 10 points for generation facilities that have executed LGIAs/provided NTPs. Expansion of a generation facility that is currently under construction should be combined with Expansion of an operating facility and awarded 20 points.  NextEra Resources supports keeping the 40 point score for expansion of a facility where the Gen-Tie has sufficient surplus capability.  

Lastly, System Need is already accounted for in the zonal allocations and should be reduced to 10% in this scoring criteria.  As noted previously, System Need represents a snapshot in time when a project is looking to enter the queue and conditions are likely to change as the project advances through the interconnection study process. Every project is likely to score the same number of points under this category and it wouldn’t serve as a robust tool to differentiate projects.  If there is an identified local need, all projects would be awarded the full points in this category.  Finally, long-lead time resources would receive 100% of points in the System Need category, giving them an inherent advantage over other resources even though they may not come online for a number of years.  Reducing the System Need weighting to 10% would make the results more balanced.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No comment at this time.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

CAISO acknowledged early in the straw proposal the need for alignment of the TPD allocation process with first-ready, first-served principles through revisions to the current affidavit scoring process associated with the TPD allocation process.  NextEra Resources has advocated consistently throughout our comments in the IPE initiative that CAISO should treat earlier clusters and earlier projects fairly and non-discriminatorily in terms of access to deliverability.  A fundamental inequity in the existing process is that projects that did not get an allocation on their first attempt will have to make financial security postings to stay in the queue long enough to apply for the second or third year for TPD.  And, as NextEra Resources has highlighted in prior comments, it is possible for projects in more recent clusters (that are not as far along in their maturity) to receive priority in obtaining deliverability on their first try. This contradicts the intent of the first-ready, first served principle in FERC Order No. 2023.  While NextEra Resources had previously (and unsuccessfully) advocated for CAISO to redress this issue in the context of Cluster 13 and Cluster 14 projects, it is vital that projects in future clusters be allowed in their second or third allocation cycle (specifically, those who have made a financial security posting) to be allocated before less mature projects. 

NextEra Resources also has some clarifying questions regarding the proposed TPD allocation modifications.  CAISO has indicated that if a project fails to receive an allocation in its first attempt, it will be required to make a financial security posting.  Please confirm whether a project is also required to post for Local Deliverability Network Upgrades (LDNU).  Such a posting does not logically follow.  A project should not have to make LDNU postings prior to confirming whether it will be allocated deliverability.  It makes sense to post for Interconnection Facilities (IF) and Reliability Network Upgrades (RNU) because those will be necessary regardless of whether a project fails to obtain deliverability and must convert to Energy Only.  However, if a project tries three times and does not get TPD, it will no longer require LDNUs and should not need to post a deposit before they are confirmed to be required.

Additionally, CAISO has proposed that Energy Only projects will only be eligible for an allocation through Group C and that this change will apply to “all new and existing projects.”  NextEra Resources also requests that CAISO clarify whether this change is intended to be applied comprehensively to all previous Clusters?  If the proposal applies to Cluster 13 and Cluster 14 projects, then it would appear the CAISO would ultimately be disadvantaging projects that are first ready and that should be first served. 

Finally, NextEra Resources would like to reiterate that CAISO’s proposal to reserve TPD for long-lead projects (like offshore wind) that have been prioritized in the CPUC’s resource portfolio provides undue preference to a single resource type.  It is important for the CAISO to ensure that all viable and ready projects (regardless of resource type) are treated consistently and fairly.  Furthermore, offshore wind projects are far from “ready” given the additional non-transmission infrastructure required to enable the manufacturing and shipping of equipment.  CAISO needs to be focused on what it can do in the near-term to meet California’s aggressive decarbonization goals and planning to accommodate proven technologies should be the priority.  To that end, the CAISO has also indicated that the ISO Tariff Appendix DD section 8.9.1 (b) and (c), “allows the ISO to reserve TPD for resources meeting specific portfolio policy goals when other resource types may be able to utilize that TPD capacity sooner, but do not meet the specific resource needs of the portfolio.”[1]  NextEra Resources would like to confirm whether this language is intended to allow projects with other technology to use that reserved capacity when the long-lead term projects (like offshore wind) are not yet operational?  And, if so, requests additional clarification from CAISO regarding how that capacity will be allocated before a long-lead project is online.

[1]CAISO, 2023 Interconnection Process Enhancements: Track 2 Draft Final Proposal at 70 (February 8, 2024) (“Draft Final Proposal”).

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

NextEra Resources is generally supportive of the updates made to Section 3.6 and has no additional comments at this time.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

NextEra Resources is generally supportive of the updates made to Section 3.8 and has no additional comments at this time

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

NextEra Resources is generally supportive of the updates made to Section 3.9 and has no additional comments at this time.

9. Additional comments:

If a central tenet of the CAISO’s IPE reform is prioritization of projects in zones where there are planned capacity additions and “System Need,” it is critical for the CAISO to advance transmission upgrades in zones with “least regrets” solutions. It is imperative that CAISO accelerate those transmission upgrades via the Transmission Planning Process in areas with heavier volume of clean energy resources aligned with CPUC portfolios.  A prime example of this is the clean energy resources seeking TPD in the Greater Fresno area/zone.  There are several gigawatts of resources in this zone that are stuck behind planned transmission projects and underlying transmission constraints that directly support the advancement of the CPUC’s clean resource procurement and local resource adequacy.  If the intent behind the IPE initiative is to truly advance clean energy resources in the generator interconnection process, then the same priority and expediency should be applied to the transmission projects in the CAISO’s TPP that are clearly needed but not moving quickly enough to help the state reach its goals.  

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

 No comment at this time.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

No comment at this time. 

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

A.  LSE Interest Points Are an Essential Part of the Scoring Criteria.

NCPA strongly supports the inclusion of LSE-interest points as part of the overall scoring criteria. Ultimately, a workable and feasible interconnection process must ensure that all LSEs in the CAISO balancing authority area (BAA) can access resources they need to serve their loads reliably, at just and reasonable rates, and in compliance with state directives and regulatory requirements. California and the CPUC have directed jurisdictional LSEs to procure specific types and amounts of new resources, and non-CPUC jurisdictional LSEs are subject to similar, sometimes more stringent, requirements imposed by their own Local Regulatory Authorities (LRAs). A significant amount of procurement will be necessary to meet these requirements, and these procurement needs must be a core element of how CAISO determines which projects are most viable and needed for purposes of study prioritization. Otherwise, there could be a mismatch between state and LRA requirements and available supply, further exacerbating existing problems and the strains on the interconnection queue process.

The Draft Final Proposal properly recognizes that commercial interest is one of the key aspects of scoring criteria used to prioritize projects for the study process. LSE interest is an inherent and important means of assessing commercial interest, as LSE support is a strong indicator of what projects are most likely to successfully be developed. Indeed, FERC has recognized that “because load-serving entities have an obligation to serve their native load, generating facilities that are being developed by such entities are generally less speculative.”^[1] Accounting for LSE interest is also vital to meeting many of the principles identified underlying IPE 23, such as: ensuring that study results take into account resource planning and procurement; aligning interconnection and transmission plan deliverability process with resource procurement functions; enhancing procedures for ensuring projects proceed to commercial operation; and enhancing the ability of the interconnection process to support procurement necessary to meet CPUC resource portfolios, CEC Senate Bill 100 portfolios, and portfolios established by non-CPUC jurisdictional LRAs.[2]

At the same time, the Draft Final Proposal also includes significant limits on LSE-interest points and makes tradeoffs between LSE interest and other competing goals, such as preserving open access and paths for merchant generation. First, there is a 35% LSE weighting factor, which means that the CAISO only allocates LSE interest points in an amount sufficient to allow LSEs to allocate them to projects equivalent to approximately 35% of the total Transmission Plan Deliverability (TPD) available in that planning cluster. This LSE weighting factor means that LSE interest points represent an even smaller percentage of the projects that get selected, because the scoring criteria is used to select projects that fulfill 150% of available and planned transmission capacity in each zone (whereas the LSE interest points are 35% of total, i.e. 100%, TPD). Second, LSE-interest points are not the exclusive points under the commercial interest factor. While the 100-point amount for LSE interest reflects the greater certainty and viability associated with LSE-supported projects, there is no cumulative limit on Non-LSE interest points in a given study cycle (as there is with LSE-interest points because of the 35% LSE weighting factor). Third, the entire commercial interest component of the scoring criteria accounts for just 30% of the total scoring criteria, with the remaining criteria identifying system needs and other indicia of project viability.

These limits on the LSE-interest points mechanism mean that there is more than ample opportunity for non-LSE supported projects to earn points from other sources and be prioritized for study. NCPA believes that these limits appropriately balance LSE-interest against other considerations and provide plenty of opportunity for non-LSE projects.

As a result, there is no need for additional restrictions on the amount of LSE interest points and no justification for the unsupported and unduly discriminatory additional restriction preventing LSEs from awarding their limited LSE-interest points to more than one self-build project per cycle.

B.  The limitation on LSE Self-Build Projects is Unsupported and Discriminatory

Restricting LSEs from awarding points to more than one self-build project while allowing merchant generators to receive points for any and all of their projects is arbitrary, unsupported and unduly discriminatory.

NCPA urges CAISO to amend this limitation on self-build projects and foresees opposing the proposal if CAISO moves forward with the limitation as currently stated. Such a limitation is not only arbitrary and discriminatory on its face, but it is also unnecessary to meet the goals of open access and prevention of LSE self-favoritism. It will instead hamper CAISO’s goals of a more optimized interconnection process.

The Commission’s open access requirements have always been concerned with preventing transmission owners from discriminating against their competitors by using their control of their own transmission systems, a concern which is reduced in situations where the system is controlled by an ISO or RTO.[3] Here, CAISO controls the transmission system, so CAISO does not need to prevent LSE self-favoritism in the name of open access. CAISO admits as much, saying it “does not foresee a significant risk of LSE self-favoritism.”[4] As discussed above, the Commission has recognized LSE projects as particularly viable and limiting the number of LSE self-build projects that can be awarded points will limit the number of viable projects in the queue—hindering CAISO’s goal of a more efficient queue process.

Discriminating between merchant and LSE self-build projects in terms of eligibility for LSE interest points is simply discriminatory. The Commission has never said that open access prevents LSEs from self-building projects; nor could it do so, as project development and procurement is within the purview of state and local LRAs. CAISO itself admits that self-build projects are relatively rare in California due to CPUC restrictions.[5] While CPUC restrictions are not applicable to non-CPUC jurisdictional LRAs, there is no evidence that these are any more common. However, they remain a vital tool in the non-CPUC jurisdictional LSE toolbox, and open access does not provide a basis to discriminate against them, particularly when built by entities that are not FERC-jurisdictional themselves. Moreover, a limit of one self-build per cycle is particularly problematic given the inherent lumpiness of resource acquisition.

By discriminating against LSE self-build projects, CAISO is doubling down on existing discrimination against non-CPUC jurisdictional LSEs already inherent in the development of the planning process to date. The relationship among CAISO’s Transmission Planning Process (TPP), CPUC-mandated resource procurement and the interconnection process is based heavily on a Memorandum of Understanding (MOU) between the CPUC, the CEC, and CAISO. The current MOU is an update of the 2010 MOU, which also prioritized the CPUC, the CEC, and CAISO in transmission planning—to the exclusion of non-CPUC jurisdictional entities. As a non-CPUC jurisdictional LRA, NCPA was not involved in the MOU and so its needs have not been explicitly solicited or explicitly considered in past planning processes. NCPA appreciates CAISO’s efforts to remedy this and to consider NCPA and other non-CPUC jurisdictional LRAs in its 2024-2025 TPP. But this is only a going-forward fix—multiple prior interconnection clusters are still being studied against an older TPP that does not consider non-CPUC LRA needs. Because the 2024-2025 TPP is the first to consider non-jurisdictional LRA needs, it is uncertain how the plans and needs of non-CPUC jurisdictional LSEs will be incorporated.[6] It is also far from clear what capacity will remain after processing prior clusters when the next cluster study window opens.

CAISO has shown no need to discriminate against LSE self-build projects, especially in light of the robust limitations that already exist on the awarding of LSE points. Given that the occurrence of LSE self-build projects is small, and LSE interest points are limited to projects making up only 35% of TPD in the cluster cycle and that LSE interest points are only about a third of points that projects may earn, the impact of potential LSE self-build projects is already quite limited. CAISO should discard this restriction.

C.  CAISO Must Ensure that Small LSEs Have Appropriate Access to LSE Points

NCPA continues to believe that the current points allocation system discriminates against smaller LSEs. Under CAISO’s proposal, the number of points available to LSEs depends on the amount of TPD in a given study cycle. If there were 45,000 MW of deliverability in a cycle, as in CAISO’s example, NCPA believes that its members’ combined load ratio share may yield sufficient points to allow access to projects necessary to meet ratepayer needs and procurement mandates. Given the projected resource needs of NCPA’s members, and assuming aggregation of points is possible (see below), this amount may be sufficient to meet evolving needs in most years. However, in a year when less TPD is available, the lower number of points could leave NCPA with too few points to designate needed resources. This is especially true given the inherent lumpiness of resource acquisition.

NCPA stresses that CAISO’s points system must accommodate the practical realities of LSE procurement processes, including the fact that there may be significant ratepayer benefits to intermittent procurement of large projects capable of achieving economies of scale, rather than steady year-to-year procurement of smaller projects.

D.  Small LSE Expansion Option

CAISO’s response to the problem presented by small LSEs that may not receive a sufficient number of LSE interest points to access a project of meaningful or realistic size is to propose a “full allocation election.”[7] This election allows an LSE (whether or not CPUC jurisdictional) with a high priority interest in a single project but insufficient points to allocate for that project’s full megawatt size to award all of its points toward that single project and enable that project to receive the full 100 LSE interest points.[8] Use of this expansion option is limited to one project per cycle per LSE, and the project may not exceed 150% of the LSE’s individual capacity allocation for that particular cycle. However, the capacity awarded to projects using the expansion option may exceed the 150% of available capacity threshold to advance in the study process.

NCPA appreciates CAISO’s willingness to address the difficulties the process may create for small LSEs and concurs in making the expansion available to all LSEs. As it is unlikely that the larger LSEs will wish to dedicate all of their points to a single project, the option will likely only be used by smaller entities. However, NCPA fears that the expansion option suffers from the same flaws as the original LSE points allocation when it comes to small LSEs. The concern about both methodologies comes from the starting point. For both, CAISO starts with the total transmission capability available and takes a percentage, then allocates the points based on that percentage to LSEs based on their load ratio share in the CAISO BAA. The starting number is only known after the TPP is completed, and there is no way of forecasting it from year to year. Much depends on whether that number is similar to or lower than the number CAISO used as an example in the Draft Final Proposal. If the actual number is significantly smaller, small LSEs could still end up with a trivial number of points—perhaps fractions of a megawatt. For example, if the City of Biggs was allocated a half point under a low TPD scenario, using the full expansion election still leaves it able to designate a project of only 0.75 MW—not a meaningful project size.

NCPA continues to believe that its earlier proposal to award each LSE with a minimum number of points (say twenty points or its load ratio share, whichever is larger) is both conceptually cleaner and simpler to administer. However, if CAISO prefers the expansion option, the solution lies in the ability of LSEs to aggregate their points for a joint project. As the CAISO has recognized in the past, it is common and often necessary for LSEs to engage in joint procurement or project development to allow smaller LSEs to gain access to larger projects and benefit from economies of scale, and the CAISO has previously indicated that more than one LSE may allocate points to a project. NCPA often aggregates and administers the CAISO interests of its LSE members (such as managing their allocated CRRs) on a joint basis. In the context of the expansion option, CAISO should clarify that its proposal contemplates such joint action, and that multiple LSEs may aggregate their one-time Full Allocation Election options for one larger project when the group of LSEs does not have sufficient LSE interest points to allocate for the project’s full megawatts. Aggregation should be available for a merchant project or an LSE self-build project. The final project could not be more than 150% of the collective capacity allocation share of the participating LSEs. In this manner, small LSEs could still aggregate their interests to access a project of reasonable size.

E.  Project Viability and System Need Points

NCPA strongly supports the proposal to award points for Project Viability. NCPA believes that many operating projects or those under construction (whether LSE or merchant owned) could be modified to provide additional capacity to the system relatively quickly and at relatively low cost. These types of projects represent the low-hanging fruit that could quickly be brought online to ease current shortage concerns during tight periods, which the CAISO needs as soon as possible.

NCPA also appreciates CAISO’s recognition, with regard to System Need projects, that points for long-lead time resources should not be limited to projects in the CPUC resource portfolio, but should also be available for the portfolios approved by other LRAs and incorporated into the TPP.[9]

[1] Ariz. Pub. Serv. Co., 184 FERC ¶ 61,188, P 40 (2023).

[2] CAISO, 2023 Interconnection Process Enhancements, Track 2 Draft Final Proposal, 8 (Feb. 8, 2024), https://www.caiso.com/InitiativeDocuments/DraftFinalProposal-InterconnectionProcessEnhancements2023.pdf.

[3] Standardization of Generator Interconnection Agreements and Procedures, Order No. 2003, 104 FERC ¶ 61,103, P 822 (2003) (subsequent history omitted).

[4] Draft Final Proposal at 34.

[5]Id.

[6] The 2024-2025 TPP is just beginning, but the early stages suggest that NCPA’s plans may not be appropriately recognized. For example, the sensitivity portfolio developed by the CPUC lists certain NCPA gas units as slated for retirement by 2039, when NCPA has not announced an intention to retire them and has listed them in its own Inter-Agency Resource Plan (IARP) as slated for repowering.  See CPUC, Gas Capacity Not Retained Assumption List for the Base Case and Sensitivity Portfolios, (Feb. 15, 2024) https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/integrated-resource-plan-and-long-term-procurement-plan-irp-ltpp/2023-irp-cycle-events-and-materials/assumptions-for-the-2024-2025-tpp/gasnotretained_mappingresults.xlsx and NCPA’s IARP at 4-7.

[7] Id. at 41.

[8] Id.

[9] Id. at 43-44.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

 No comment at this time.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

NCPA notes that similar to the point made above in response to Question 3 related to System Need Project points, CAISO continues to use terminology referencing the CPUC resource portfolio for long lead time resources[1], rather than specifying long lead time resources in any CAISO LRA portfolio. This language should be corrected.

[1] Id. at 70.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

 No comment at this time.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

 No comment at this time.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

 No comment at this time.

9. Additional comments:

 No comment at this time.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

PG&E has no comments at this time on the proposed generic timeline proposal.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

In the Draft Final Proposal, the CAISO proposes to study all Energy Only (EO) projects that score high enough but not count the EO projects towards the 150% zonal cap.  PG&E does not support this new addition for the reasons listed below.  However, notwithstanding PG&E’s concerns about allowing for all EO projects scoring high enough to be studied without counting towards the 150% zonal cap, PG&E understands that CAISO has a desire to establish a pathway for EO projects to submit interconnection requests given open-access rules, and recommends that if CAISO proceeds with this proposal that it establish a cap of no more than the two highest-scoring EO projects - that are in the group scoring higher than the last project included in the 150% zonal cap - be eligible for study per zone.

1. Not including EO projects in the 150% cap increases the MW amount to be studied in reliability studies. Even though these projects do not seek deliverability, EO projects still contribute towards Short Circuit Duty (SCD), substation and other reliability network upgrades that need to be accounted for in the cluster study process.  Thus, increasing the amount of MW that is studied in a zone, without any limits for EO projects, would impact all the projects in the cluster and the future clusters, and would be in conflict with the efforts of this initiatives to make study results more accurate and provide meaningful information to determine the appropriate level of network upgrades necessary.  At the outset of Track 2 in this initiative, the CAISO and stakeholders developed a set of problem statements, including Interconnection Request Problem Statement 4: “Study results lose accuracy, meaning and utility when the level of cluster interconnection request capacity is multiple times the existing or planned transmission capacity for an area,” which would be contradicted by the current CAISO proposal for studying EO projects.

An example: If the available transmission capacity of a zone is 1,000 MW, then the 150% cap brings the total MW to be studied to 1,500 MW.  Since there is currently no minimum score for a project to be studied, if higher scoring projects account for 1,400 MW and, there are 5 x 100 MW projects with the same score of which one is FCDS, and the other four are EO projects, the total MW to be studied in that zone is now 1,900 MW.  So, the total MW to be studied for the same zone is now 40% higher than a scenario where EO projects are also included in the 150% cap.

2. The draft final proposal proposes in Section 2.7.1 that all existing and new EO projects are eligible for Transmission Plan Deliverability (TPD) allocation only through Group C - Interconnection Customers that have achieved COD.  The paper also states that CAISO has not seen significant interest or viability in EO projects advancing in the queue (page 33).  These two facts imply that it is very unlikely that the EO projects that would be studied in the initial cluster study would successfully come online.  It is also unclear to PG&E that the addition of EO projects is necessary for meeting energy-only resource needs identified in the CPUC’s Integrated Resource Planning (IRP) process, as at least one-third of projects that are being studied in a TPD Option zone will potentially not get deliverability.  Further, projects that are co-located or hybrid may allocate deliverability to storage components, while still developing solar. Therefore, the inclusion of EO resources in the IRP portfolio does not mean that EO projects should get a carve out to be studied in the cluster process.

3. FERC Order 2023 mandates completion of cluster studies in 150-calendar days.  Not including a firm limit on the number of projects already puts PTOs at potential risk of not meeting the mandated deadlines.  Removing the proposed limit of MW by introducing a pathway for EO projects to be studied exacerbates the risk of not meeting the 150-calendar day timeline.  The proposed generic schedule by CAISO on page 25 shows the cluster study process to occur in parallel with the Interconnection Facility Study of the previous cluster, which will further stress PTO resources and increases the risk of not meeting the required timelines.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

PG&E generally supports the proposed scoring criteria and prioritization process but opposes certain aspects of the modified CAISO proposal as outlined below.  

1.  Assignment of Commercial Interest Points by Non-LSEs

PG&E strongly opposes the proposed scoring criteria outlined by CAISO that would allow for the assignment of points to non-load serving entities (LSEs) as defined by the CAISO tariff. This proposal will create a duplicative process that is contrary to established processes and principles and is inefficient and inequitable.

First, the CAISO’s proposal is contrary to the intent of the Memorandum of Understanding between the CEC, CPUC, and CAISO, where the intent of the MOU is to have an organized process from planning to project development.  As stated by the CAISO, “[p]rocurement will focus on the expected quantities enabled by the planned transmission development, as set forth in the ISO’s transmission planning process (TPP).”  The MOU approach “is necessary because of the long development timeframe of transmission resources relative to many energy supply resources. Procurement of new energy supply resources must consider the availability of transmission resources to ensure reliable delivery of the supply resources to the grid.”

In PG&E’s view, the proposal is in contrast to the spirit of the following established principle developed by CAISO and stakeholders in this initiative: “[e]nsure meaningful study results that take into account system capability, resource planning and procurement. Resource planning includes the CEC, CPUC, and other LRAs engaged in these activities” and “[a]lign interconnection and transmission plan deliverability processes with resource procurement functions.”[1]

Moreover, it is PG&E’s understanding that the MW allocation pool is based on CPUC IRP portfolios built off individual LSE resource needs, and that they are then transmitted to the CAISO for its TPP.  PG&E has significant concerns that the CAISO’s proposal here would add inequity to that process.  More specifically, the TPP develops transmission expansion projects based on the IRP portfolios, which are primarily based on plans from load serving entities.[1]  Introduction of non-LSE points for projects at the cluster stage of the process introduces inappropriate influence for competition of TPP expansion capacity from a group of participants who were not involved in the planning stage and for whom the TPP-approved projects were not designed.

Second, if the non-LSE participants (e.g., end-use customers that enter into their own power purchase agreements) have CAISO load, then their load needs are already represented in the planning process by an LSE that has a responsibility to develop an IRP plan.  The CAISO’s proposal is inefficient and allows non-LSE participants to contravene existing processes.  It is incumbent on the end-use customers to work with their LSEs to ensure the LSE is meeting the needs of its customer base.  Specifically, the non-LSE participant should work with the CPUC-jurisdictional LSE to capture its needs within the IRP planning process and work with the CPUC’s Energy Division staff to appropriately study the proposed project.  It is inappropriate to implement a prioritization criterion here that effectively bypasses this process and unfairly advantages non-LSEs over LSEs, especially given that LSEs face compliance penalties and state regulatory obligations while non-LSEs do not.  To the extent this is not already happening, upfront coordination would improve the IRP planning and procurement process, ensuring customers interested in greater control over their procurement have a part in the process.

Moreover, the proposal - as it currently stands - lacks sufficient rigor and review and is not consistent with planning principles.  For example, 1) there is no limit on the number of non-LSEs that can participate, 2) there is no limit on the number of projects that each entity can give a letter to, and 3) there is no natural limit on projects because the allocation of points would not be based on load share or any reasonable and quantifiable measure.  This results in an easier logistical hurdle for non-LSEs to receive higher priority on their project(s) over an LSE.  

Finally, on the topic of non-LSE points, the CAISO raised the question of whether decisions made in the 2021 IPE Track 2 are relevant to the present discussion.  The 2021 IPE Track 2 tariff changes to allow non-LSEs the ability to obtain TPD with certain restrictions is independent from establishing a process for selecting which projects proceed to the cluster study and should not be precedential.  That TPD allocation process will still exist for all projects at a later point in the process, and that process does not contravene the MOU.  The process being decided now is the process for which projects get studied based on the amount of TPP upgrades, not the prioritization of allocation of TPD based on contracts.

2.  Restrictions on Utility-Owned Projects

The CAISO’s new addition in the Draft Final Proposal to restrict allocation of LSE points to a single utility-owned generation (UOG) project per cluster is flawed, discriminatory, and runs counter to the spirit of the open access tariff that the CAISO. PG&E opposes this proposal for the following reasons:

• Open Access – This proposal runs counter to the open-access tariff to provide open and non-discriminatory access to the CAISO controlled grid.  PG&E received over 200 interconnection applications in one cluster, many of which from a single parent company.  LSEs being limited to scoring based on the entity proposing the project would be discriminating based on the applicant and not the viability of the project and its benefit to customers. The CAISO in the Draft Final Proposal removed a proposed limit to the number of project megawatts that could be studied from a single parent developer based on developer input that there is no evidence of market power and the market power concerns were a theoretical exercise.  In this same vein, the CAISO should not limit LSEs to scoring UOG projects either based on concerns of favoritism, especially since LSE points will only by eligible for no more than 35 percent of the total available and planned MWs eligible for TPD allocation in a cluster.
• Concern Over LSE Favoritism – The concern of favoritism based on the belief that the LSEs would favor UOG projects is unfounded. Through the proposal, the CAISO is encouraging LSEs to follow an RFI process in order to make their determinations on which projects receive LSE points.  If there is concern over favoritism, this process can be bolstered to reduce any chance of that perceived favoritism. Additionally, UOG project proposals by investor-owned utilities are assessed by the CPUC via application for their viability and cost-effectiveness compared to non-UOG resources and must receive CPUC approval that finds there is a need for the project prior to commercial development.
• Limits Customer Benefits – UOG is built for the benefit of customers and the operation of the projects benefit customers since they are assessed by the CPUC to do just that. This proposal puts a limit on potentially more cost-effective and viable projects that could benefit utility customers.
• UOG is Less Common – The CAISO’s own analysis has indicated that the number of UOG applications is extremely low when compared to the hundreds of applications received in Clusters 14 and 15.  Putting unnecessary restrictions is thus a discriminatory sanction based on unfounded concerns.
• Size of LSE – This proposal also does not take into account that there are LSEs of different sizes.  For example, PG&E serves approximately 15% of the total load in CAISO, while there are small LSEs within CAISO that serve only 1-2% of the overall load and providing LSEs with widely differing load shares the same opportunity to give points to only one UOG project does not properly take into account their varying customer needs.
• Size of the Proposed UOG – This proposal disregards the potential that the proposed UOG may be a 15 MW expansion project to existing plant or may be a 500 MW new build project.

While PG&E opposes the CAISO’s proposal and believes a cap on UOG projects eligible to receive LSE points is discriminatory, if the CAISO decides to continue pursuing establishing any limit, then PG&E recommends that CAISO base it on LSEs’ respective load share tied to the LSE allocated amount of points.  Consistent with a prior CPUC decision (D.13-10-040) that is still currently in effect, which allows CPUC-jurisdictional utilities to procure utility-owned storage resources up to 50 percent of the cumulative procurement targets across all three grid domains, PG&E suggests that LSEs be allowed to allocate up to 50 percent of their LSE points to utility-owned projects.[1]

[1] See CPUC Decision 13-10-040 at: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M079/K533/79533378.PDF

[1] PG&E understands that in future iterations of TPP the CAISO will include resources from the publicly owned utilities’ IRPs.

[1] Draft Final Proposal, p. 11.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

If a zone has very little available or planned capacity (but not zero capacity), most, if not all projects that applied to interconnect into that zone would not be studied under the TPD Option.  Additionally, as currently drafted in the Draft Final Proposal, those projects would be ineligible to be studied under the Merchant Option.  PG&E recommends that a minimum available capacity criterion be added to qualify as a TPD Option zone.  A minimum available or planned capacity of 25 MW, would help to ensure that a zone with minimal capacity would not preclude any project(s) from being studied in that zone and would provide an opportunity for interconnection applicants a choice to be studied under the Merchant Option if they so desire.  An alternative to a set MW minimum could be that if the available capacity is not adequate to study any applicant within a TPD Option zone (all applicants within the zone exceed 150% of the available and planned capacity), then that zone is reclassified as a Merchant Option zone.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

PG&E supports CAISO’s proposal to further explore modifying the TPD Allocation Process during a new Track 3 in this initiative.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

PG&E supports CAISO’s proposal for the reasons previously articulated in PG&E’s comments on the Revised Straw Proposal.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

PG&E supports CAISO’s proposal for the reasons previously articulated in PG&E’s comments on the Revised Straw Proposal.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

PG&E supports CAISO’s proposal for the reasons previously outlined in PG&E’s comments on the Revised Straw Proposal.

9. Additional comments:

PG&E recommends that modifications to increase the interconnection service capacity for projects for interconnection requests in Cluster 15 be allowed since, unlike previous clusters, the studies for Cluster 15 have not yet commenced and will likely not commence for approximately another year.  In Track 1 of this initiative, the CAISO adjusted the Cluster 15 timeline and provided that interconnection customers in Cluster 15 may modify their interconnection requests between May 1, 2024, and September 26, 2024, however the CAISO noted that increases to requested Interconnection Service Capacity would not be accepted primarily due to CAISO tariff provisions.  PG&E understands that making such a modification was not plausible in previous clusters since it would affect others in the queue and the study process; however, given that lag in time between the interconnection application window and the start of the Cluster 15 study process, a modification to allow Cluster 15 applicants to increase interconnection service capacity requests should not impact the study process and would not increase the number of applications within the CAISO queue.  As such, PG&E requests that CAISO allow interconnection customers to modify their requested Interconnection Service Capacity, along with the already permissible modifications to generating technology/fuel and to add or increase energy storage capacity.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

It is suggested that the Draft Proposal clearly define the difference between "Zones" and "Study Areas"  and the list of substations and transmission lines that fall under each category,   Of specific interest is ability of the Cluster 15 applications to move their POI into and out of a Zone and Study Area prior to the validation of their application.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

EO Resources:

While there is some level interest by the investors in EO projects, it is not a liquid market and many stay in the Queue and never get built.

The question is, "Can CAISO create a product in between the EO and full capacity and Deliverability extremes that  invites more interest by the investment community? This  is probably something that requires group disucssions outsider this Draft Proposal.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Commercial Viability:
The Draft Proposal does not recognize developers’ with past experience. I suggest recognizing developers who have developed renewable and storage projects in California that are currently operational. This will weed out developers that have no experience in the industry with high probability of failure as well as flippers that want  projects and do not have an investor.

Engineering Design: 

In the electrical  facility design world we have 15% 30% 60% 90% and 100%.. 15% design commonly understood by  the industry and its requirements are clear to the designers. 20% design is not.  I suggest changing the 20% to 15%. Scoring level does not require any changes.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No comments

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

No comments

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

No comments

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No comments

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comments

9. Additional comments:

Please note PMU stands for Phasor Measurement Unit.. Th term "Phase Angle Measurement  Unit" as described in the Draft Proposal does not properly name these devices. Please revise.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

It is great that CAISO is being proactive about only allowing projects into the interconection study process if they have higher feasibility from an interconnection/transmission/deliverability perspective. The heat maps for deliverability allocation will be very useful.  However, Power Flow Development, LLC would ask that the QC15 process be expedited sooner than re-engaging in the first half of 2025.  

Power Flow Development, LLC is also concerned that following the 2024 deliverability round that there will be limited deliverability left over in CAISO.  This is a larger issue for California, where the state is trying to achieve the CPUC mandated construction of >56 GW of clean energy resources by 2035.  There are renewable generation and battery needs in every zone in California, regardless of whether there is no transmission plan deliverability available today in these zones.  

This relates to the "Merchant-Financing "Merchant Deliverability Option" process below and will provide comments and recommendations there.    

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Considering that the deliverability assessment will be done prior to the QC15 Phase I study kick-off, there will be several rounds of much needed CAISO transmission upgrades approved prior to the actual allocation of deliverability, and that there is regularly significant project attrition due to issues with site control, permitting, etc, Power Flow Development, LLC recommends to raise the 150% TPD cap to 200% for each zone.    

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Given historical timelines for previous cluster projects, and with Cluster 15 being approximately three years behind Cluster 14, we can expect that a majority of Cluster 15 projects will not achieve commercial operation until 2035 or later.  It is not realistic to expect developers to get true commercial interest from LSEs for projects that are so far in the future, especially with all the uncertainties that come with project development.  It is unclear why the Commercial Interest category is even included here, let alone the extremely high weight that it carries considering that historically LSEs have procured off-take for projects that will reach commercial operation in 3-7 years from contract execution.    

Furthermore, and more importantly, this scoring process is skewed to benefit LSEs that plan to build and own their own projects.   Any LSE that has interest in owning their own projects will without doubt choose their own projects and thus score 100 points in this category.  All private developer/IPPs will be left to compete for second placement within the zones.  If you leave the scoring process as proposed you will end up with a remaining queue that is heavily weighted with LSE owned projects, and upon these rules being set and the scoring completed it seems there will be no way to remedy this. 

Recommended Alternative: the Commercial Interest aspect should be reduced to 0% or significantly reduced.  If not reduced to 0% or significantly lower than 30%, instead of LSEs being limited to one project of their own, LSE owned projects should be limited to no more than 50% of the total MW of projects that are allowed to be studied within an interconnection zone. 

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

Power Flow Development, LLC understands that CAISO is attempting to give projects the ability to move forward if there is no TPD available in a specific zone.  However, making 50% of the "Commercial Readiness Deposit" is too high considering  the ADNU amounts are unknown prior to the study.

Recommended Alternative: Adjust the"Commercial Readiness Deposit" refundability to 80% if withdrawal is made prior to the Phase I Interconnnection Financial Security Postings.  This allows developers to have "skin in the game" but also not have commercially unreasonable amounts of risk prior to receiving a written interconnection study.  

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

No comments. 

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

No comments.  

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No comments.  

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comments.  

9. Additional comments:

No comments.  

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

Prologis has no comments at this time.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Prologis has no comments at this time.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Prologis appreciates CAISO’s clarification of its proposed site control requirements but is disappointed that it will not impose site control restrictions on Cluster 14 projects.  Prologis is concerned that Cluster 14 projects with no site control will receive TPD ahead of Cluster 15 projects, which will have site control, in the next round of TPD allocations.  The simplest way to eliminate non-viable projects from the queue is to require site control.  CAISO could provide notice of this requirement now and then provide a grace period so that Cluster 14 and earlier projects have time to obtain site control before the next TPD allocation cycle.  This would help CAISO to ensure only the most viable projects receive TPD allocations.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

Prologis has no comments at this time.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Prologis is concerned that CAISO’s proposal to limit TPD allocations for Energy Only (EO) projects is too restrictive.  CAISO proposes to convert all projects to EO after their third deliverability allocation attempt, and then prevent EO projects from seeking deliverability again until they achieve COD.  This proposal is too restrictive because it could eliminate highly viable projects from the TPD allocation process.  For example, developers might sign a PPA for a highly viable project after the Phase 1 study, then find out that the Phase 2 study requires upgrades that will delay the COD beyond the PPA deadline, resulting in a default.  The developer still has a highly viable project but may need more than 3 cycles to execute a new PPA. 

Instead of restricting all Energy Only projects from re-seeking TPD allocations, CAISO should apply viability screens to projects after their 3rd attempt to determine whether they are commercially ready enough to remain in line to receive deliverability.  Projects that can show that they are more viable than new projects entering the TPD allocation process should remain eligible.  For example, CAISO could allow projects that have a PPA or are shortlisted to remain eligible for TPD allocations even after their third attempt. CAISO’s main goal should be to allocate deliverability to the most viable projects that can use it, which in some cases may be a project that has been converted to EO.

Prologis also urges CAISO to carefully consider its proposal to reserve deliverability for long lead-time (LLT) resources and clarify whether it applies to existing transmission capacity.  Prologis does not object to CAISO’s plan to reserve new transmission capacity that is triggered specifically by LLT resources included in the CPUC’s TPP portfolio.  However, CAISO should clarify how it will allocate existing deliverability among LLT and non-LLT resources.  CAISO should not reserve near-term deliverability for LLT projects that cannot achieve COD until later.

For example, if a commercially viable storage project can use existing deliverability starting in 2026, and a LLT resource cannot use it until 2028, that deliverability should go to the storage project, even if the LLT resource would then have to wait until 2030 for new transmission to be built.  It is unfair to force commercially ready projects to wait for LLT resources to get built and may result in higher overall pricing for customers if the non-LLT resources cannot hold their pricing.  At a minimum, CAISO must establish a process to determine the most cost-effective allocation of existing deliverability among LLT v. non-LLT resources based on project viability criteria.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

Prologis urges CAISO to ensure that projects in Cluster 13 and earlier must sign a GIA before the next cluster study.  Based on CAISO’s indications that the next open window will occur in 2025 and the draft schedule on p. 25 of the Draft Final Proposal, it appears that the next cluster study is likely to begin around November of 2025.  However, the deadline for Cluster 13 projects to execute a GIA is December 31, 2025 (see Table 1 on p. 88 of the Draft Final Proposal).  This means that halfway through CAISO’s next cluster study, it could find out that a significant volume of capacity will drop out.  It seems logical for CAISO to adjust the Cluster 13 GIA deadline from December 31, 2025 to September 30, 2025 (or a date that occurs before the next Cluster study) so that it can eliminate as many non-viable projects as possible before the next cluster study.  CAISO would also have to adjust the Cluster 13 Commercial Viability Criteria demonstration date in Table 2 to reflect this change. 

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

Prologis has no comments at this time.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

Prologis has no comments at this time.

9. Additional comments:

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

Qcells USA Corp. ("Qcells") appreciates CAISO’s iterative stakeholder process and another opportunity to provide comment on its Interconnection Process Enhancements. Qcells supports CAISO’s efforts to provide critical data in a transparent and accessible manner. Regarding the timeline provided by CAISO, Qcells requests that CAISO consider adjusting the timing of the TPD Allocation Study to occur prior to the Request Window. This way developers will have access to the most accurate and updated data for their decision-making.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

No comments at this time.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Qcells appreciates CAISO’s receptiveness to previous stakeholder feedback on this matter. However, Qcells continues to oppose the 150% cap as a firm limit. Further, Qcells believes that if more than one project is scored equally and exceeds the 150% threshold, those projects should be studied. In this regard, Qcells also opposes using auctions as tie breakers.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No comments at this time.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

No comments at this time.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

No comments at this time.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No comments at this time.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comments at this time.

9. Additional comments:

No additional comments at this time.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

   Heat Map

• When does ISO plan to upload the redacted individual interconnection reports on the MPP Portal? Is it Q3 - along with the Heat Map expected in October?
• Is there a way projects connecting to substations with no prior Q request can seek information from PTOs on IRNU requirements to connect their project?
• As part of the Data accessibility exercise, will CAISO be willing to share a list of substations and the LRAs/LCRAs they come under so that developers can assess if their projects may really qualify for the system need requirement?
• Where can IC find the ‘Constraint-Boundary-Substation-List’ for SCE and SDGE? PGE published their Matrix as an appendix to T-capability white paper; however, SCE & SDGE posted the area constraint images, not the excel. I understand CAISO plans to publish more consolidated information sometime in Jan 2024; however, if there is any MPP portal resource I can access to get this specific information, I would greatly appreciate it if you could guide me to that.
• Not all substations are included in the ‘Constraint-Boundary-Substation-List’ for PGE? If our C15 project is connecting to a POI that is not in the list, what can we do to determine the Transmission capability for the area that project belongs to?
• Is there some kind of mapping for the substation names in the Substation_Constraint Matrix and the substation names in Queue List published by CAISO? If not, can CAISO create something like this and share?

   Schedule

• When does CAISO plan to publish a more concrete schedule for C15? It’s our understanding that Y1 does not reflect the schedule for C15, as it’ll be more like a transition cluster and Yr 1 may fit better for C16 when things are more streamlined. For C15, can we assume that moving everything ahead by 5 months, i.e., starting the request window from Jan 2025 is accurate? IC would appreciate clarity on this.
• If it is not accurate, can CAISO add C15 schedule to this Gantt Chart?
• Will the new process include scoping calls prior to the cluster study kick-off?
• Also, how does the schedule for IFS Posting look like with restudy and interconnection facility study added to the timeline? Do projects make 1st IFS Posting after Cluster Study, 2nd after Restudy, and 3rd interconnection facility study.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

   IC appreciates the addition of this aspect to the proposal.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

   Commercial Interest

   •          IC appreciates the score addition for commercial off-takers.

   •          Can CAISO explain/clarify the concept of allowing 35% of the total TPD capacity for LSE score allocation? When all available TPD MWs will be available for allocation, then why only 35% TPD MW’s are being provided scores, why not 100%? IC just wants to understand how 35% correlates with the procurement needs of LSE’s and what will happen to the remaining 65% (+ 50%) that do not get points/scores from LSE’s? Will those see scores from commercial off-taker and be destined to get a lower score?

 [35% that get LSE score + 65% of the remaining TPD ( Seek score from Commercial Off-taker) + 50% of the additional capacity that will be studies in Option A ( Seek score from Commercial Off-taker) = 150% TPD studied]

   •          At what point does the project find out if scores were awarded to a project and what score project received from LSE? Will LSE inform the project of its selection for score assignment at all.

   System Need

   •          As part of the Data accessibility exercise, will CAISO be willing to share a list of substations and the LRAs/LCRAs they come under so that developers can assess if their projects may really qualify for the system need requirement.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

   •          Does Scoring Criteria apply to merchant deliverability option?

   •          Is the commercial Readiness Deposit refundable post COD of the Merchant deliverable project? Or is the entire amount non-refundable post cluster study even if the project comes into service?

   •          Can CAISO help IC understand why the repayments of ADNU funded under Merchant Deliverability Option can only be done via CRR’s? I think the main concern with CRR from Developer’s perspective is in what amount and after how long that investment be fully repaid. With the Cash repayment option, there is certainty on caps, at-risk amount and Surety that within 5 years of COD that amount will be paid back. The same may not be true for repayment in form of CRRs.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

   With group D gone, will a 60K deposit be required for all projects every time they seek deliverability moving forward in their allowed three consecutive opportunities?

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

  Requirements like procurement status must include some accountability/status update from PTOs as well. It has been observed that the majority of project delays are triggered by PTO procurement delays lately. Unless this provision is made, projects will continue to face multi-year delays in their ISD due to PTO-triggered delays, and the whole point of the exercise will be defeated. Further, with CAISO and CPUC working on a solution to add some accountability on PTOs part in the matter, it makes sense/seems like a logical next step to add such a provision in this IPE cycle, to demonstrate a timely action item implementation on their part; waiting for another IPE process or Working Group to resolve this issue might seem to procrastinate resolving the root cause of project delays. Happy to hear CAISO's thoughts.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

   •          The language provided in this proposal stands if the PTOs meet the Date commitments that they make in the LGIAs. It will be crucial for the true realization of the proposal that PTOs are held accountable if they digress from the dates they commit to in the GIA, and are subjected to similar due diligence like IC's when they want to implement such delays.

   •          A provision to have PTO provide a concrete schedule for the NU/NTP Date that they plan to achieve along with this notification of payments for the Projects must be added to this section.

   •          The tariff language that this change will be reflected on must be modified such that the language on the timeline for PTO to act on the upgrade is enforced not optional, ‘once the PTO has received the NTP and 3rd IFS posting, it will have 30 BD to commence the upgrades.’

   •          This proposal adds uncertainty to the timeline for the payment, which will become a challenge for developers who seek investor approvals before making high financial security and monthly payment posting. IF CAISO can add more predictability on the notification timeline/payment schedule front for upcoming payments in a year or quarter that might be helpful. The 90 day clock starts ticking once notification is received from CAISO; in addition to this notification, if a yearly heads up on upgrades that may trigger payments due to IA’s getting closer to execution will be helpful.

   •          Generally, developers make a calendar view of the payments that they expect to go out at least a year in advance as part of the financial year planning. Any abrupt payments that were not accounted for are drawn from some reserve or emergency funds. If random payment notification becomes a norm, it will cause developers to overdraw from those emergency funds.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

   No comments 

9. Additional comments:

   1. Can CAISO show some sort of backend calculation that went into coming up with $100,000 deposit and how it will help fix this problem?

   2. IC is having a hard time understanding How will these additional fees help CAISO overcome staffing issues? I think the root cause is overworked staff with bandwidth limitation to cater t the growing interconnection supply and demand needs of the system.

      a. IC feels additional fees won't solve that problem.

      b. On several occasions, IC has heard how overworked everyone is and how they are trying to make ends meet with the limited resources they have working overnight or through Holidays.

   3. CAISO needs to have a plan for hiring and training staff that is able to address time constraint and resource overload issues. CAISO has confessed in several platforms that their workforce has not scaled according to the workload in the last few years. Taking an example from the ‘for-profit world’, companies scale their staff when work increases, they don’t reduce the work and keep staff the same. The fight for climate change is real, CA is on the forefront of several revolutionary changes in the energy transition space, and CAISO has been the bearer of many of these changes. The Interconnection Process Enhancement will not be the end of the struggle here, and it seems pertinent they seriously consider upscaling their staff and bring in more gen Z in the workforce that feels Passionate about the subject and adds new perspectives/more efficient ways of operating.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

REV Renewables (REV) appreciates the generic timeline included in the Draft Final proposal as it is helpful to understand when CAISO plans to update transmission availability and how clusters may overlap. This timeline highlights the complexity of the process and particularly for creating a line in the sand on determining the 150% of available capacity for the new cluster. For example, the Cluster Study heatmap seems that it will be the most recent transmission availability to use for the following cluster interconnection request window, but the Transmission Plan approval is expected shortly after the Cluster Study heatmap and any additional availability from the approved Plan should be included for the next cluster. Yet in the generic timeline this is only about one month before the request window opens, which creates limited ability for developers to respond. REV requests CAISO add in when will be the cut off for determining the available capacity for the next cluster. This question of “150% of what” is critical for developers to understand in order to create a viable interconnection request.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

REV supports applying the same requirements to FCDS, PCDS, and Energy Only projects, and that Energy Only resources will not count against the 150% cap.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

REV appreciates CAISO’s continued improvements to the draft final proposal, but REV continues to oppose the proposed Interconnection Request Intake process, particularly for the zonal caps, scoring criteria, and auction approach.

While the scoring criteria have improved compared to the straw proposal, REV thinks they are still unfairly weighted towards LSE interest and that a project could be highly viable and yet not have a chance to be studied under this process. REV recommends further shifting the weight of each category to the following: LSE Interest = 15%, Project Viability = 55%, System Need = 30%

A few specific items of feedback:

• LSE Interest
  • Without clear information from LSEs on how they will implement their scoring, this category is subjective and unfairly puts the fate of an early-stage project into LSE hands. Given the proposed point allocation, it is likely this category will still be a primary determining point to get a project studied. At a minimum, CAISO should decrease the percentage weight to 15% of total points.
    • If this category remains, REV recommends that CAISO work with CPUC to alert all LSEs of this proposal and ensure they are prepared to review interconnection requests and engage in bilateral discussions on interconnection requests.
  • REV supports limiting LSEs to providing points to one self-built project each cycle. However, given the potential for limited available transmission capacity, REV is still concerned about the potential for preferring utility-owned projects and recommends further consideration of this proposal. REV proposes a further guardrail that a utility-owned project should be no more than 50% of available capacity in a transmission zone, to ensure the utility-owned project does not dominate the zone (especially in years with low amounts of available capacity.
  • REV appreciates and supports inclusion of non-LSE interest points, and thinks this is a necessary inclusion if commercial interest is a category. The proposed process gives LSEs significantly more points compared to non-LSEs (100 vs. 25), so should not detract or limit access to projects from LSEs.
  • REV supports the change to make non-CPUC jurisdictional LSEs use this point system rather than automatically have their projects move forward to be studied and counting towards the 150% cap.
• Project Viability
  • Engineering Design – While REV understands the intent of getting granularity on the design level, REV does not think the Association for Advancement of Cost Engineering is an appropriate guide for assessing engineering design as that is only for cost estimate accuracy. There is little meaningful distinction between engineering design at 10% vs. 20%, and anything beyond 20-30% is unreasonable at the early project stage as it would be more costly to redesign later as project details inevitably require.   
  • Expansion of generation facility – REV recommends increasing the potential points for “expansion of a generation facility that is currently under construction” to 20 points the same as expansion of an operational facility. Given the facility is under construction and will come online imminently, it should be considered equally viable as a project already in operation.
  • Expansion of a facility that is under construction or in operation, where the GenTie already has sufficient surplus capability to accommodate the additional resource - REV also requests reconsideration if its request that this also include existing Gen-Tie that need minor upgrades, not necessarily zero upgrades. For example, an existing Gen-Tie facility can be upgraded to higher capacity with relatively inexpensive and quick upgrades, and should be allowed to count for this indicator.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

REV continues to disagree with CAISO that Merchant Deliverability projects in zones with available capacity would be counterproductive or lead to inaccurate results. If the Merchant Deliverability projects are self-funding any upgrades necessary, they are not taking away from the available capacity in the zone. CAISO could consider providing limitations on Merchant Deliverability projects in these zones, such as if it is in a constrained sub-zone with less than X MW. Accordingly, REV continues to request that Merchant Deliverability B be available for projects to pursue if the customer does not make it through the scoring criteria screening or auction, as only projects with a high degree of confidence and likelihood of success would pursue this option. If the project has to wait until the next cluster to apply as a Merchant Deliverability, then a different set of projects would also be applying to the system which could lead to different cost estimates for network upgrades.

REV also does not agree with CAISO’s position on project’s LGIA signing status in order to get released from obligation to fund the ADNUs. CAISO should not make this distinction and once CAISO sees the need for the ADNU, a project should be released from the responsibility to fund the upgrade. As these projects have already posted for these ADNUs, these should continue to get higher TPD priority as compared to later projects which could be come become eligible to be studied in this zone due to some new available capacity because of CAISO’s approval of the upgrade.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

REV recommends further workgroup discussions on this topic and not moving this proposal forward with the rest of the package. Stakeholders originally raised this issue in summer 2023 workshops with the concern that network upgrades were taking longer than expected to complete, which creates challenges for projects to stay in the TPD allocation cycle without a PPA, given that LSEs are generally not seeking PPAs for 2030+. CAISO’s proposal does nothing to address this issue and seems to limit opportunities to remain viable while waiting for long-lead time upgrades. Given this issue, REV does not support elimination of Group D or elimination of parking. While expanding the opportunities to three consecutive years to seek allocation is helpful, it is unlikely to be long enough to resolve this concern. CAISO should reconsider the concept of allowing projects with these long upgrades to park until, for example, four years before the expected upgrade online date at which time CAISO could require a PPA in order to unpark.

REV also requests clarity on when the TPD modifications would be applied, would it start for all projects in the 2025 TPD allocation cycle? Or for Cluster 15 and beyond projects that enter the allocation process? REV does not think that these modifications should be applied to earlier queued projects and should only be for Cluster 15 and beyond.

CAISO should also clarify how postings would work, would it be based on the FERC Order 2023 timeline or based on the current timeline?

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

REV does not support CAISO’s proposal for projects to downsize to the capacity that has PPAs. REV reiterates that PCDS projects are special distinct category separate from standalone EO projects, where these projects are already ahead in terms of site control, permitting and engineering design processes. There could be a plausible scenario where a project might want to pursue a merchant route without a PPA. The current CAISO proposal, for instance will subject all QC8 and prior projects (including PCDS) to secure a EO PPA by 2025, thus precluding the option to construct this capacity as a merchant option.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

REV supports this proposal.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

REV supports this proposal.

9. Additional comments:

REV appreciates the additional details on FERC Order 2023 compliance plan, and particularly CAISO’s updated determination that the site control requirements would not apply to previous clusters.

REV supports the removal of the 25% developer cap and agrees CAISO can revisit this at a later if needed.

REV continues to request further justification for CAISO’s proposed limit of 150% of available transmission capacity in the zone. REV understands CAISO’s rationale is that each cluster will result in a surplus studied capacity that will accumulate over time. However, this does not take into account historical rates of projects achieving COD, which in previous clusters have been quite low. REV suggests that at a minimum CAISO increase its proposed limit to 200%, and commit to evaluating this limit after a cluster cycle and seeing how many projects move on to interconnection facility study as an indicator of early project success.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

No comment.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

No comment.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

SDG&E appreciates the work CAISO has done to develop a proposal to score and rank the interconnection requests which advance to the study process. While we are broadly supportive of the use of a scoring criteria, the Load Serving Entity (LSE) point allocation methodology and inclusion of the proposed limit on LSE-owned projects as written in the Draft Final Proposal are highly problematic, unduly discriminatory and will diminish the ability of LSEs to support viable and cost-competitive projects that meet their portfolio requirements. In addition to our opposition to the LSE-owned one-project limit, SDG&E provides the following comments on the points allocation methodology more broadly, which will significantly disadvantage LSEs with a smaller load share from expressing interest in projects and supporting their entry into the study phase.

Allocation Methodology

SDG&E is concerned that by basing LSE allocations on peak demand information, CAISO is putting Investor Owned Utilities (IOUs) like SDG&E, who have significant departed load, at a disadvantage to prioritize projects that will best help meet their RA obligations, when compared to other IOUs who may have more bundled customers.

Approximately 80% of SDG&E’s load has departed for CCA or DA service. Using public data from the 2023 IEPR, SDG&E serves approximately 1.4 percent of statewide load.[1]  If SDG&E did not have departed load in its service territory, this figure would be approximately 7.4 percent. Despite this significant customer departure, SDG&E must still comply with a system-wide Resource Adequacy (RA) obligation and is often asked to procure on behalf of the region and serve as the backstop procurement entity for the region.[2] For example, the IOUs, including SDG&E, have been tasked with emergency procurement of additional resources through California Public Utility Commission (CPUC) Decisions (D.) 21-12-015 and D.23-06-029.  Ultimately, those resources are allocated to all LSEs in the service territory through the Cost Allocation Mechanism (CAM) or the Modified CAM (MCAM). Yet, when using the CAISO’s formula from the Draft Final Proposal, SDG&E’s allocation would be:

SDG&E Load Share = 1.4%

SDG&E Capacity Allocation = Total LSE Capacity Allocation x LSE Load Share

= 15,750 MW x 0.014 = 221 MW

SDG&E is eligible to allocate 221 MW of project capacity

As LSEs cannot make a full allocation election for a project that exceeds more than 150% of that LSE’s individual capacity allocation for that particular cycle,[3] SDG&E would be limited to allocating points to projects smaller than 332 MW based on current bundled load (even though in certain instances, as mentioned above, SDG&E has been tasked with procuring on behalf of more than is represented in its load share). Additionally, if load in SDG&E’s service territory continues to depart, this allocation could become even more limiting.[4] For LSEs with smaller allocations, this limitation could prevent larger projects from continuing the study process.

SDG&E also requests clarification on whether the LSE capacity allocation will be made public. Per the Draft Final Proposal, CAISO will provide each LSE with its total capacity allocation, based on confidential peak demand information in the California Energy Commission’s most recent Integrated Energy Policy Report (IEPR). SDG&E is concerned that it may be possible for entities to back into these confidential numbers if LSE allocations are made public, and requests clarification on this topic.

Limits on LSE-Owned Projects

Under the “Scoring Criteria” section, a new proposed limit was added for LSE-owned projects seeking commercial viability points. SDG&E does not support additional restrictions on an LSE’s ability to allocate their (in the case of SDG&E) already limited points to viable and competitive LSE-owned projects and suggests such an approach is unduly discriminatory.

Generally, LSEs indicate their interest in projects based on a least-cost, best-fit methodology. In line with this principle, SDG&E does not believe projects should be arbitrarily differentiated in the scoring criteria simply due to their status as LSE-owned or non-LSE-owned. CAISO’s proposed approach would preclude an LSE from awarding points to two LSE-owned projects even though they both may represent the least-cost, best-fit options for the LSE.  Conversely however, CAISO’s proposed approach would allow for two non-LSE-owned projects which may be the least-cost best options to the LSE to be awarded points.  The awarding of points should not be driven by LSE ownership, and such an approach upsets the least-cost, best-fit principles the IOUs must adhere to.

Moreover, it is unclear what preferential treatment risk CAISO is attempting to mitigate with its limits on LSE-owned projects.  As stated in the Draft Final Proposal, utility-owned projects already represent a small minority of the storage procured in California[5] and are also subject to higher levels of scrutiny with the CPUC when justifying utility ownership.[6] Adding additional limitations for these projects to be considered in the study process is overly restrictive, as safeguards are already in place (e.g., codes of conduct, firewalls and independent evaluators) to ensure that an IOU does not favor its self-developed projects. To address the concerns of other commenters, SDG&E suggests that CAISO monitor the number of self-built interconnection requests that advance through the queue in each cluster cycle to consider if, first, preferential treatment exists, and second, whether refinements are warranted for the points allocation process in the future.

Commercial Interest from a non-LSE Offtaker

CAISO proposes to give an additional opportunity for interconnection requests to obtain points in the commercial interest category through a “documented, verifiable demonstration of commercial interest” from a valid non-LSE/commercial offtaker. While SDG&E understands the desire to retain flexibility for developers and energy purchasers, we urge CAISO to better define how they evaluate these arrangements and what documented, verifiable demonstrations of interest will entail. Without more detail on the proposal, SDG&E is concerned that non-LSE/commercial offtakers may have access to an outsized representation in the points allocation process. For example, it is unclear whether one non-LSE/commercial offtaker could assign 25 points to multiple projects if they demonstrate verifiable interest, or if there would be a cap on the number of projects any single non-LSE offtaker could express interest in. If CAISO’s proposal is to allow non-LSE/commercial offtakers to assign points to multiple projects, SDG&E is concerned that these entities could express interest in a disproportionately high MW capacity of projects in the queue, potentially displacing projects that would otherwise provide resource adequacy or serve LSE load, especially given the limited MW capacity LSEs have to prioritize projects.

Additionally, we are concerned that a portion of this commercial offtaker category may already be represented by other LSEs. If a non-LSE/commercial offtaker is located within an LSE’s service territory, then that LSE should be allocating points to projects that are in the best interest of the customers it serves. Finally, SDG&E is concerned by CAISO’s lack of definition of non-LSE/commercial offtaker. If CAISO allows offtakers that are not located in the CAISO BAA to assign points, then the CAISO’s ratepayers will be paying for projects that are benefitting a commercial interest outside the BAA. For these reasons, SDG&E reiterates its recommendation that CAISO more clearly define the non-LSE/commercial offtaker category.

[1] Because peak demand information is confidential, SDG&E is using load (GWh) in this example. Per “CED 2023 Baseline LSE and BAA Tables”, Form 1.1c, 2024 year. https://efiling.energy.ca.gov/GetDocument.aspx?tn=254423&DocumentContentId=89807

[2] See D.19-06-015, D.21-06-035 and D.22-05-015.

[3] Draft Final Proposal IPE 2023, p. 41.

[4] Draft Final Proposal for IPE 2023, p. 34. https://www.caiso.com/InitiativeDocuments/DraftFinalProposal-InterconnectionProcessEnhancements2023.pdf

[5] Lumen Energy, “Energy Storage Procurement Study: Realized Benefits and Challenges”, Figure 27, October 24, 2022, at page 43.

[6] D.24-02-047, Decision Adopting 2023 Preferred System Plan and Related Matters, and Addressing Two Petitions for Modification.  “The IOUs shall submit Tier 3 advice letters for approval of contracts for resources procured according to this authorization, unless they are utility-owned requiring applications, and unless the contracts are otherwise authorized pursuant to another proceeding before the Commission where another authorization vehicle is in place.” p.45.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No comment.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

No comment.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

SDG&E urges CAISO to consider making all CVC applicable to all clusters immediately. As demonstrated by CAISO’s CVC Demonstration Requirement table (slide 46) in the Draft Final Proposal, Cluster 14 is exponentially large. Processing this cluster as has been done in the past will likely result in similar issues that led to IPE in the first place, such as skewed study results and excessive administrative burdens. According to this schedule, these issues will not be solved until April 30, 2028, after which all projects will be required to meet the proposed CVC. Further, these artificial timelines may lead to undue prioritization of earlier clusters in order to meet the CVC schedule.  

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No comment.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comment.

9. Additional comments:

3^rd IFS Posting:

While SDG&E still believes the best path forward is for the 3^rd posting to be due prior to execution of the GIA, CAISO’s current 3^rd posting proposal could work if the 3^rd posting requirements were defined in the tariff. This would alleviate concerns with burdening PTOs with enforcing 3^rd posting-related deadlines and decrease speculative GIAs and projects in the study process.  

Alleviation of General Administrative Burden:

Across the IPE and FERC Order no 2023 requirements, SDG&E acknowledges good progress has been made towards a more streamlined and sustainable interconnection process. However, SDG&E still sees areas where the interconnection is still bogged down. The CAISO should look at some of the proposals and consider the abilities of CAISO/PTO staff to process them in a timely manner. A few areas to consider are:

• Refer to comments on CVC/time in queue where there will be no streamlining benefits realized for a few years.
• Requiring GIAs to be amended 9 months prior to synchronization with all MMA reports incorporated will be extremely difficult to achieve with few practical benefits. Perhaps it is prudent to consider allowing these amendments after sync, with priority given by customer request.
  • By extension, it may be good to consider limiting the scope of MMAs, potentially also by customer request.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

SEIA appreciates the opportunity to comment on the 2023 Interconnection Process Enhancements (IPE) draft final proposal and thanks CAISO staff for their hard work and responsiveness in this effort.

With the implementation of the Zonal Approach, it is critically important that CAISO provides developers with clear and robust data and that CAISO be transparent in how that data will be used in the interconnection process. SEIA appreciates CAISO’s proposal to consolidate interconnection area and transmission capability information into a single document and looks forward to those reports being published. SEIA also appreciates and supports the proposal to implement a “cut-off” point that will establish a common dataset for interconnection request development and evaluation. SEIA encourages CAISO to provide more information on how that cut-off point will be determined and where it will fit in the interconnection procedures timeline. SEIA continues to encourage CAISO to consider expanding the data provided to include critical information like short circuit data, breaker ratings, and POI feasibility to support the development of competitive projects.

Recognizing that there are several moving pieces to consider in developing the interconnection procedures timeline, SEIA recommends that the study timeline be modified so that the interconnection window opens after the TPD allocation study concludes to ensure CAISO and stakeholders are working with the most up-to-date information and accurate representation of available TPD.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

 SEIA supports the AES proposal on this issue.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

LSE Interest

SEIA appreciates the inclusion of a non-LSE scoring metric and the proposed LSE self-build limitations. These additions are an improvement upon the criteria included in the previous version of the proposal. That said, SEIA continues to be concerned with the potential for the LSE Interest category to be determinative in project selection. Without greater differentiation in the Project Viability and System Need scoring categories, the LSE Interest category will have a greater impact on determining which projects are studied, regardless of the weighting. SEIA encourages CAISO to consider gradated scoring, particularly for Project Viability, to reduce the likelihood that any one scoring category determines the outcome.

Non CPUC-Jurisdictional LSEs

SEIA appreciates and supports the removal of the automatic inclusion of non-CPUC jurisdictional LSE projects from the scoring criteria.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

SEIA continues to propose that CAISO expand the Merchant Deliverability option to projects not selected through the scoring process. Given the limited use of the Option B pathway today, SEIA is not convinced that opening the Merchant option to projects that are not selected through the scoring process will significantly divert CAISO resources or overwhelm the interconnection queue. CAISO can also consider higher thresholds to grant access to the Merchant Deliverability option, such as increased at-risk deposits, to manage the volume of Merchant Deliverability projects. Additionally, CAISO can monitor and limit Merchant Deliverability in the future if it does indeed cause issues.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Given the stage in the IPE, SEIA encourages CAISO to consider the TPD allocation process modifications through a separate IPE Track 3 with working group discussions. The proposed changes are relatively high level and could have significant impacts on existing and future interconnection requests depending on the details and implementation. SEIA encourages CAISO to apply these new rules only to future TPD allocation groups to reduce impacts on existing projects that could not have predicted such rule changes. SEIA continues to oppose the proposal to limit energy-only projects to allocation Group C. SEIA requests more information on the expected impact of removing Group D (i.e., how many Group D projects exist today?).

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

 SEIA echoes AES’ comments.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

 SEIA echoes AES’ comments.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comment.

9. Additional comments:

SEIA shares AES’ concerns regarding the uncertainty around Order 2023 and IPE implementation, the interaction with Cluster 15, and the timing of Cluster 15 reengagement. SEIA stresses the importance of revising the tariff to allow for modifications and withdrawals consistent with the timing of Cluster 15 activities.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

See below. 

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

See below. 

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

See below. 

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

See below. 

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

See below. 

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

See below. 

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

See below. 

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

See below. 

9. Additional comments:

Shell Energy North America (US), L.P. (“Shell Energy”), Shell New Energies US, LLC (“Shell New Energies US) (together, “Shell”), and Savion, LLC (“Savion”) (Shell Energy, Shell New Energies US and Savion, collectively, the “Shell Companies”) appreciate the opportunity to comment on the IPE draft final proposal.  On the whole, The Shell Companies support the IPE draft final proposal and believe it is a meaningful improvement versus the status quo. The Shell Companies appreciate the inclusion of zonal auctions as a concept to efficiently allocate scarce zonal interconnection capacity.  While their use will likely be limited, we believe this represents a novel and elegant manner to allocate scarce interconnection capacity. 

The Shell Companies have specific questions related to CS15.

• With respect to site control requirements applying to C15 projects, assuming FERC approves CAISO Order 2023 compliance filing, how much time will CAISO allow for the customers to provide proof of site control?

• Which updates and design changes will CAISO allow for C15 projects to make after or during the review process?  Would CAISO allow for inverter, total MW interconnection size, collector system, and/or POI changes during or after the review?

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

The Six Cities have only limited comments on the CAISO’s discussion of data accessibility in section 2.1 of the Draft Final Proposal.  As an initial matter, the listing of information that the CAISO proposes to make available to evaluate zones with available transmission capacity appears to be a good start.  The CAISO may need to refine the information that it provides as market participants gain experience in working within the zonal approach and using the scoring criteria under development. 

Much of the discussion in this section addresses information that is available and activities to document zones and the mapping of resources within zones based on CPUC inputs.  The Six Cities assume that the many references to CPUC portfolios should also be read to include resource portfolios of non-CPUC jurisdictional load-serving entities (“LSEs”).  As stated in their earlier comments in this initiative, the Six Cities support the CAISO’s efforts to coordinate with non-CPUC jurisdictional LSEs.  Because this coordination has not occurred prior to the 2024-25 Transmission Planning Process, which is only now beginning, there may be a gap reflected in the CAISO’s earlier Transmission Plans, including the 2023-24 Transmission Plan, which is not yet available, to the extent that the transmission system has not been planned to reflect the resource planning and procurement by non-CPUC jurisdictional entities.  The Six Cities request information about whether the CAISO agrees that such a gap may exist and how it intends to address it.  In particular, if there is no transmission capacity within a zone, and a non-CPUC jurisdictional LSE has identified a required project, how will the CAISO ensure that such a project can advance through the interconnection study process on a non-discriminatory basis given that the CAISO had not previously requested any information from such LSEs regarding their resource procurement plans?  This presents a particular concern in the context of any resources to be developed within a non-CPUC jurisdictional entity’s service territory, but equally applies to externally-located resources.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

The Six Cities do not have comments on the CAISO’s proposed approach to intake for Energy Only projects, as discussed in section 2.2.3, and, likewise, do not oppose the proposal to exclude Energy Only projects from the proposed cap on projects to be studied.   

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

As noted during the stakeholder meeting held on February 15^th, the Six Cities are extremely disappointed with the removal of the CAISO’s proposal to include resources approved by non-CPUC jurisdictional local regulatory authorities (“LRAs”) in the interconnection studies.  The Six Cities expect that this significant change may have a chilling effect on the ability of smaller LSEs to engage in resource planning and procurement by limiting their influence over the interconnection projects that will advance to the study phase, including projects that they may intend to develop themselves. 

With respect to the scoring criteria that the CAISO has proposed, the Six Cities have significant concerns that the CAISO has not provided adequate information to allow stakeholders to meaningfully evaluate the impact of the CAISO’s proposed scoring criteria, including changes to the scoring criteria introduced in the Draft Final Proposal.  The Six Cities therefore oppose the CAISO’s scoring criteria pending the CAISO providing additional, realistic examples of how the point system allocation process will work, both with respect to smaller LSEs and with respect to the amount of transmission capacity that is likely to be available throughout the CAISO footprint.  For example, the scenario provided by the CAISO on page 39 reflects a total of 45,000 MWs of available capacity.  For a large LSE comprising 30% of the CAISO’s load, this results in a generous allocation of 4,725 MWs of project capacity that this LSE is eligible to allocate.  For a smaller entity that represents 1.0% of CAISO load, the resulting allocation would be 157.5 MW of capacity to allocate, and for an entity representing an even smaller share of CAISO load, such as .05%, the allocation would be 7.9 MWs. 

However, if the CAISO actually does not have a full 45,000 MWs of available and planned transmission capacity on its system, these numbers may look very different.  As a hypothetical, if the amount of available and planned transmission capacity across the CAISO system is only 6,000 MWs, the results seem to be as follows:

6,000 x 0.35 weighting factor = 2,100 MWs to be shared by all LSEs

The Six Cities request information regarding how the CAISO will determine the available and planned transmission capacity for the purpose of the LSE allocation process and identify and provide an estimate of the amounts that is currently available.

At smaller load levels and at reduced amounts of available capacity across the CAISO system, the CAISO’s proposed methodology limits the ability of smaller LSEs to allocate a meaningful amount of points to projects, appears to place their preferred projects at a disadvantage, and diminishes the ability of these LSEs to engage in meaningful resource planning.  An LSE that comprises 1% of CAISO load may have a peak load of around 500 MWs.  An LSE that comprises .05% of CAISO load may have a peak load of around 50 MWs.  The Six Cities are concerned that project capacity allocations do not seem to align with the planning needs that systems of these sizes may have.  A minimum allocation based on the methodology proposed by the Six Cities and NCPA in their supplemental comments would help mitigate this impact for the very smallest LSEs.  It is not clear why the CAISO has rejected this approach in a way that appears likely to hamper efforts by small LSEs to engage in long term planning to meet existing resource adequacy and renewable portfolio standard requirements, much less increased needs such as might result from an LRA decision to increase the planning reserve margin in the future. 

The Six Cities note that the CAISO’s proposed “full allocation election” approach may help address their concerns, but, as discussed during the stakeholder meeting, it is unclear how this proposal is intended to work, and there are no examples included in the Draft Final Proposal that provide assurances to smaller LSEs that they will have a meaningful chance to advance even one project of their choosing.  For example, an LSE that is allocated a single MW of capacity would appear eligible to allocate points for projects totaling 1.5 MWs of capacity.  For an LSE with a 50 MW peak load and a 15% planning reserve margin, this approach does not provide an ability to specify interest in a reasonably-sized project.  The Six Cities would like to discuss with stakeholders how this proposal could be adapted to address the Six Cities’ concerns. 

Finally, the Six Cities strongly oppose the CAISO’s proposal to limit study of utility owned resources.  This element of the Draft Final Proposal establishes an unreasonable restriction on the authority of non-CPUC jurisdictional LSEs to engage in resource planning and procurement activities that they are permitted to conduct, which includes development of their own resources.  According to the Draft Final Proposal, the CAISO has newly identified concerns about “preferential treatment of utility-owned resources” and therefore proposes that LSEs may only award points to one self-built project each cycle, and to limit the size of the resource eligible for this election to 150% of the LSE’s total capacity allocation for the cluster.  This effectively limits the future ability of the Cities to develop their own resources, even though the Cities own and operate their own resources now.  For example, the Cities of Anaheim and Riverside each own and operate 200 MWs of gas-fired generation within their systems, consisting of the Canyon Power Plant and the Riverside Energy Resource Center, respectively.  Pasadena likewise owns resources internal to its system.  It appears that the CAISO’s proposal will operate to restrict the ability of the Cities to potentially study replacement capacity for these resources in the event of their retirement. 

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

The Six Cities oppose the CAISO’s proposals related to the merchant deliverability option to the extent that the CAISO will require a non-CPUC jurisdictional LRA approved project to proceed as a merchant project if it seeks to interconnect in an area with no existing or planned transmission capacity, even if the project is being developed by an LSE pursuant to an LRA-approved resource plan and is located within the LSE’s service territory, such as the service territory of a municipal utility.  Given that the CAISO has not historically planned the transmission system to accommodate the resource plans of non-CPUC LRAs, it is not appropriate to apply the merchant deliverability requirements to projects being developed by LSEs pursuant to LRA-approved resource plans. 

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Conceptually, the Six Cities do not oppose the CAISO’s initial approach to revisions in the TPD allocation process as outlined in section 2.7.1.  However, the Six Cities observe that the CAISO’s discussion of part 6 of the proposal on page 70 includes a reference to “CPUC portfolio requirements for specific resource types.”  Did the CAISO intend to limit its discussion of reserving and allocating TPD for long lead time projects to CPUC policy decisions?  If so, what is the reason for excluding non-CPUC LRA determinations regarding potential needs for long lead time resources?

Additionally, it is not clear what the CAISO means by the phrase “any other commitments having a basis in the Transmission Plan.”  (See Draft Final Proposal at 69.)  It would be helpful in analyzing the CAISO’s proposal to understand what is meant by this phrase, and if it includes policy and procurement determinations by non-CPUC jurisdictional LRAs. 

The Six Cities agree with the CAISO’s suggestion that deliverability-related topics may require additional time to resolve in an extended phase of this Initiative.  (See id. at 69.)

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

The Six Cities do not have comments on this section of the Draft Final Proposal at this time.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

The Six Cities do not have comments on this section of the Draft Final Proposal at this time.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

The Six Cities do not have comments on this section of the Draft Final Proposal at this time.

9. Additional comments:

The Six Cities have no additional comments at this time.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

SCE supports the CAISO’s proposal to provide stakeholders with information on the available transmission capacity within the transmission zones prior to the interconnection request window.  SCE also supports the CAISO’s proposal to consolidate the information for each of the interconnection areas into one document, so it is easier to assess the available interconnection capability at POIs.  SCE supports the CAISO, consistent with FERC Order 2023, developing the requirements of the heat map and associated information.

However, regarding the proposed generic timelines in Section 2.1, SCE would like to caution stakeholders that adherence to the generic schedule will only be possible if the total number of interconnection request (IR) applications is kept to a manageable, meaningful, and sustainable number, which could be approximately 50 requests for a larger PTO and significantly fewer for a smaller PTO. Consistent with Section 3.9 (5) of Appendix C of FERC Order 2023, the CAISO should consider proactively negotiating these application amount thresholds with the PTO, Interconnection Customers, and Affected System Interconnection Customers so that if they are exceeded, the allowable thirty (30) Business Day extension can be invoked without issue.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

SCE supports the CAISO’s proposal regarding the process of submitting and reviewing interconnection requests to be the same for all projects seeking FCDS, PCDS and EO status within zones with available transmission capacity. FCDS, PCDS, and EO projects should be required to meet the same site control requirements, provide the same entry fees and study deposits, and provide a self-assessment IR score sheet. FCDS, PCDS, and EO would go through the scoring process and compete to be studied.  SCE also supports the CAISO’s proposal that EO resource capacity will not count toward the 150% cap on zonal studies provided that the total number of IR applications is right sized to facilitate timelines and meaningful results. An unchecked amount of EO projects could unnecessarily trigger long lead time short circuit duty upgrades, which would create a barrier to viable projects. As well as create additional report writing and costs estimating work that could hinder the PTOs’ ability to meet the generic timelines in Section 2.1. SCE requests that the CAISO consider other measures, such as limiting the number of IR applications, if the numbers of EO projects do not result in an overall manageable, meaningful, and sustainable process.  

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

SCE generally supports the CAISO’s latest proposal regarding scoring criteria for prioritization to the study process.  SCE believes the three main scoring categories – commercial interest, project viability, and system needs – are meaningful barometers for gauging a project’s readiness to proceed into the interconnection study process. SCE also believes these three main scoring categories are measurable and relatively straightforward to implement.    

SCE, however, strongly opposes the CAISO’s latest proposal that LSEs may only award points to one self-build project each “cycle” (presumably, cluster). This arbitrary limit on LSE self-build projects is unwarranted and discriminatory.  LSEs are already held to high standards by the CPUC regarding self-build projects, and there is no need for the CAISO to assert itself in this issue.  The one self-build project per cycle would also be inconsistent with SCE’s actual recent experience where SCE has submitted three self-build projects in each of queue clusters 12, 14, and 15.  The CAISO itself has admitted it “does not foresee a significant risk of LSE self-favoritism[1]” and there simply is no need for such a restriction. Rather than prejudging LSE behavior, the CAISO should proceed in a similar fashion as it now intends to forego the previous CAISO proposal regarding the 25% cap limitation on the number of IR applications a developer (at the parent company level) could submit in a given cluster application window, given potential monopolistic behavior by developers.  If, based on actual experience after several cycles, the CAISO sees potential concerning behavior regarding LSE self-favoritism, the CAISO can address the issue at that future time with further proposed revisions to its IR intake process that includes criteria to limit any perception that LSEs are awarding points based on anything other than rational criteria.          

While SCE strongly maintains its position that the CAISO should remove the one self-build project per cycle proposal, should the CAISO decide to move forward with a cap on LSE self-build projects, SCE recommends that any cap should be based on a capacity cap (MW), not the number of applications, and this capacity cap should be based on LSE load shares. SCE proposes that such a limit, if imposed, be set at 50% of CAISO-allocated points. This is consistent with SCE’s historical IR submission while allowing an additional buffer for growth and unknown mandates. To accommodate smaller LSEs, the cap on LSE self-build projects could also be based on the largest capacity resulting from either awarding points to a single project or allocating points to several projects but not exceeding 50% of the CAISO-allocated points.

SCE also strongly opposes the CAISO’s revisions in the Draft Final Proposal as they relate to a developer’s opportunity to obtain points in the commercial interest scoring category by demonstrating commercial interest from a non-LSE/commercial off-taker.  These non-LSE/commercial off-takers do not have the same Resource Adequacy (RA) obligations as LSEs whose customers have paid for the transmission system and who need the available Deliverability to meet the CPUC-mandated RA requirements.  Non-LSE off-takers should not be allowed to consume the available Deliverability on the grid and should only be permitted to move into the study process as Energy Only projects if there is more interconnection capability than deliverability capacity. Furthermore, if a non-LSE enters PPA(s) for projects with FCDS, they will need to “resell” the RA product, which could potentially increase RA prices for CA customers by inserting a middleman. Consequently, SCE requests the following:

1. Limit the type of products: non-LSEs should only be able to assign points to Energy Only projects or to a co-located project with an FCDS application that includes a renewable project.
2. Add the following requirement to the Affidavit:
   1. Signature authority: a representative that is authorized to execute power purchase agreements (not a “procurement manager at the company”).
   2. Attest non-LSE off-taker is supporting this project in support of corporate policy goals on sustainability
   3. Attest that the size of application is aligned with the non-LSE off-taker needs
   4. Attest that non-LSE off-taker is not affiliated with the IC or its holding company
   5. Attest that the non-LSE off-taker has not supported more applications than the size of its needs

SCE further requests that the CAISO confirm, as clarified during the Feb. 15^th Stakeholder call, that a project can receive 25 points from only one non-LSE off-taker.

SCE commends the CAISO’s removal of the unbounded automatic bypass of the interconnection request scoring process by any project that a non-CPUC jurisdictional LSE demonstrates is a preferred resource in its resource plan that has been approved by its local regulatory authority.  SCE appreciates the CAISO taking into consideration SCE’s previously expressed concerns regarding the substantial preferential treatment that would be provided to projects that met the non-LSE criteria by giving them different interconnection rules and in effect allowing them to bypass CAISO’s interconnection application study selection process.  Eliminating such preferential treatment to a sub-segment of LSEs’ projects provides a more level playing field.

[1] CAISO 2023 IPE Draft Final Proposal, p. 34.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

SCE supports the CAISO’s proposed additional modifications to the merchant deliverability option.  SCE agrees that only projects seeking to interconnect in areas that have no available or planned TP Deliverability capacity are eligible to select the Merchant option.  Also, Merchant option projects should not be eligible to seek to interconnect in zones with available capacity and projects not selected to be studied in these zones should not be permitted to switch to the Merchant option.  Merchant projects which require LDNUs should be eligible for cost recovery of the interconnection financial security posted for the LDNU.  Merchant option projects should be eligible to receive Merchant Transmission Congested Revenue Rights for constructed ADNU.  SCE supports requiring Merchant option projects to make an additional commercial readiness deposit with IR towards the cost of the ADNU as well as requiring projects that complete the cluster studies to increase their commercial readiness deposit to 50%.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

SCE supports the CAISO’s TPD allocation process modifications, including:

• Discontinuing project “parking”
• Providing projects three consecutive opportunities to seek an allocation, beginning with the first affidavit window after the interconnection facilities study
• EO projects are only eligible for an allocation through allocation Group C – in commercial operation
• Discontinuing allocation Group D

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

SCE continues to strongly support the CAISO’s proposal under this section as written in its Draft Final Proposal. SCE has no further recommendations at this time.   

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

SCE continues to strongly support the CAISO’s proposal under this section as written in its Draft Final Proposal. SCE has no further recommendations at this time.   

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

SCE supports the CAISO’s latest proposal that will give SCE, as a PTO, the flexibility to amend a GIA after every approved MMA and/or other approved changes to the Project, such as PTO Delay notices, addendums, or revisions to the final PII Interconnection Study, and Reassessments, to ensure that SCE’s Major Project Organization is designing, engineering, procuring, and constructing an IC’s Project based on the latest approved changes captured in a single source document, the amended GIA.  

SCE appreciates CAISO’s recognition that developers as well as PTOs may have a variety of reasons to amend a Project’s GIA to incorporate modifications or other approved changes sooner than later.  With this in mind, SCE requests that the CAISO include language in its final proposal that if the PTO elects to amend the GIA immediately after an approved change, an IC and CAISO will also take all reasonable action necessary to ensure required amendments result in an executed GIA for submission to FERC (neither party objects to the PTO’s request to amend the GIA).  SCE’s intent with this recommendation to be included in CAISO’s final proposal is to avoid having the PTO file amended GIAs unexecuted at FERC, which may result is delays in the project moving forward.

SCE also remains concerned that including changes to scope, project payments, costs, financial security amounts (ITCC and IFS) and their due dates, and schedule will require negotiation with the Interconnection Customer before finalizing these terms and conditions in the report. This will certainly extend the overall timeline to complete the MMA/FRR beyond the 60 days or 120 days as prescribed in Section 3.7.  In which case, SCE proposes that CAISO allow in its final proposal extension to these timelines as addressed in the CAISO tariff. See for instance Section 6.7.2.3 in the CAISO Tariff addressing Modifications.

9. Additional comments:

SCE has no additional comments at this time

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

Strata Clean Energy recognizes and appreciates the connection between the generation interconnection and transmission planning processes taking place.  There is opportunity with this concept only if the deliverability study is at the back part of the interconnection process following the release of the transmission plan and opening of the cluster study window.  Once the transmission plan is published, there should be a window and adequate time for developers to evaluate where new deliverability may be available prior to submitting projects and opening up a new deliverability study.   Once developers understand where deliverability may be created by the transmission plan, developers can submit projects to the open window and cluster study that culminates in a deliverability study.  Figure 4 has the deliverability test taking place during the window opening process, it needs to be moved back further so that projects in the cluster study can be eligible to participate.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Strata Clean Energy supports CAISO's proposal.

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Strata does not support the scoring approach that the CAISO has developed.  We strongly believe that the CAISO should implement other pro-forma Order 2023 requirements such as site control and commercial readiness to control the queue before introducing subjective scoring mechanisms.  Other markets that have implemented the pro-forma requirements are seeing sharp pullbacks, we dont belive it is necessary to present the complexity of the scoring process to an already complex and long interconnection process. 

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No comments

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

There are not clear enough signals in the generation interconnection process and transmission planning process to remove Energy Only resources from the queue.  We believe the CAISO should table this approach until more stakeholder discussion takes place and this version of the reform is implemented.  Once Order 2023 requirements are implemented, CAISO like other markets that have implemented the Order 2023 requirements will likely see a sharp pullback in active projects.  If more aggressive measures are taken beyond the Order 2023 requirements, it could present a situation where there could be a shortfall of resources where the Energy Only projects could be there to help. If CAISO successfully aligns the transmission planning and interconnection processes, these Energy Only projects could be part of larger area reliability solutions for the transmission system.  If CAISO takes these resources out of the queue, we have lost resources that could play a meaninful role in maintaining a reliable system.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

Time in Queue requirements need to have flexibility around long lead transmission upgrades that are being utilized for awarding deliverability.  If transmission upgrades are extended or planned several years in advance, interconnection customers should have the ability to modify their schedules and remain active.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No comments

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No comments

9. Additional comments:

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

Terra-Gen, LLC (Terra-Gen) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 2 Draft Final Proposal.

Terra-Gen supports CAISO providing additional information as early as possible so interconnection customers can fully consider transmission availability prior to submitting an interconnection request into a transmission zone. Terra-Gen requests CAISO commit to providing this key information, further detailed below, at least six months before the IR submittal window deadline. 

In addition, Terra-Gen recommends CAISO provide the following specific information and related clarifications regarding the timing of these elements of the proposed zonal approach:

• CAISO should indicate clearly when the available capacity information will be published by CAISO;
• CAISO should clarify the contents of the three studies from FERC Order 2023 in the context of the CAISO’s proposed process and studies;
• CAISO should specify the start of timing for the three TPD allocation opportunities for a particular cluster; and
• CAISO should specify when the CPUC would need to provide its specific IRP resource portfolios to be used by the CAISO for its queue entry selection.

Terra-Gen also requests the timing and other details of the security postings should be added to the timeline, so it’s clear what information Interconnection Customers (ICs) will have when those commitments are made. CAISO should also add its interpretation of the financial-security posting requirements under Order 2023 to the proposed timeline. The timeline also shows timing for heat maps but not timing for the rest of the information listed in the proposal.

Terra-Gen also suggests that CAISO should consider shifting the TPD allocation study prior to opening the request window or if summary data from the submitted TPD affidavits could be provided to better inform whether an interconnection request is submitted.

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Terra-Gen believes that FCDS projects scoring below the points cutoff threshold should be allowed to fund Merchant Option upgrades.  Portfolio mapping is an inexact science, and CAISO should not be concerned with allowing transmission expansion on a merchant basis within zones having available capacity. 

Terra-Gen is concerned that CAISO’s proposal will prevent most, if not all, EO projects from being studied. Even if they score high for Project Viability, EO Resources are unlikely to gain more than 35 weighted points of the possible score of 100.  If the CAISO wants to provide a meaningful opportunity for EO Resources, it should either add criteria that EO projects can meet or otherwise revise the criteria to provide that opportunity (e.g., change the weighting scheme for such projects). 

Terra-Gen also supports CAISO reconsider the alternative approach suggested by AES, i.e., exempt EO projects from the scoring rubric (per the CAISO’s prior proposal) but require an additional financial posting as a viability demonstration.

Terra-Gen suggests that EO requests should be allowed in all zones purely based on project readiness, independently of deliverability availability or other requests. Alternatively, CAISO could use the EO resources in the CPUC’s IRP resource portfolio to identify a zonal EO study limit for each zone. 

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Terra-Gen reiterates its previously stated concerns, also echoed by other stakeholders on this aspect of the CAISO’s proposal, as noted below.

CAISO’s overall proposal is fundamentally flawed because it moves the study process forward for a small minority of early-stage projects absent the information that is most important to project viability: transmission upgrade costs and timelines. CAISO has not considered or explored the need to provide more key information on these upgrade costs and timelines for each zone as suggested by many of the development community in prior feedback.  Terra-Gen believes CAISO should work to provide a proposal that incorporates this feedback and actually provides more useful information to differentiate projects and zones more upfront.

Terra-Gen is concerned that the entire process upon which projects are proposed to be advanced for study rests on subjective control by LSEs and is subject to anti-competitive behavior. This approach is likely to leave many projects behind that could otherwise prove to be the most attractive and viable. Terra-Gen also reiterates prior comments that additional indications of LSE interest provide little differentiation between the viability of projects given the CPUC portfolio must be achieved to meet state policy objectives and such interest will most likely be non-binding since costs and timing are uncertain. Terra-Gen has concerns that the proposed process will drive IR applications and LSE selections to Local Capacity Areas (LCA) where development costs are typically much higher and large-scale solar and wind development are simply infeasible. Additionally, Terra-Gen is concerned that the process would also unduly favor Long-Lead Time (LLT) resources that can also be eligible for additional points that other projects cannot receive under the proposal.  For all of these reasons, the proposal is fundamentally at odds with open-access principles and anti-competitive. 

Terra-Gen strongly opposes the proposed LSE scoring criteria aspect and recommends that CAISO should remove this aspect of its proposal.  Terra-Gen also suggests CAISO should instead simply rely on the FERC Order 2023 requirements for 90% site control demonstration and increased study deposits as the main criteria and requirements that would be responsible for reducing the excessive amount of interconnection request submittals. Terra-Gen appreciates the lower weighting provided to LSE interest criteria but remains concerned that without a more standardized and transparent LSE allocation process to projects leaves too much discretion to LSEs.

If CAISO continues to propose to use the scoring criteria screening mechanism to limit the number of IR submittals, Terra-Gen suggests the following feedback for further refinements of the scoring criteria. The LSE-interest scoring element provides too much subjective control over the process by LSEs without these LSEs having any information about the transmission impact of the resources they are selecting.  To address these concerns, CAISO should consider the following changes to its proposal:

• Reduce the LSE-interest score to no greater than 20% of the total score weighting;
• Adopt the CAISO proposal to limit each LSE to scoring only one of the LSE’s sponsored or affiliated projects per cycle;
• Further develop the CAISO proposal to also award points for projects with documented commercial interest from non-LSE off-takers, which should be consistent with the point system for LSE interest - The cap on points that can be earned is only 25% of the total that can be awarded for LSE interest, which is too low and CAISO should allow non-LSE interest to count as much as LSE interest, with a deposit required if the developer or non-LSE does not have an RA arrangement with an LSE; and
• Establish guidelines to ensure a transparent and objective process for the allocation of points.

Terra-Gen supports the elimination of the earlier proposal to allow all resources in an approved non-CPUC-jurisdictional LSE resource plan to evade the readiness scoring rubric applicable to other resources, thereby reducing the capacity available to those (possibly more ready) projects.

Terra-Gen also recommends CAISO continue to include the Full allocation election and LSE self-build limitation aspects of the proposal.  CAISO should retain the LSE self-build allocation limitation to one project per cycle. LSE interest can be used to support multiple projects, and large entities like SCE (the most vocal opponent of this element) have many points they can use for that purpose.

Terra-Gen continues to oppose auctions as a tie breaker for projects which cross the transmission capability study threshold. The benefit of an auction is to allocate scarce resources and provide price discovery of the value of the scarce resources. This benefit is not applicable to breaking ties as the price formation ignores the willingness to pay of all resources seeking to submit an interconnection study request in the transmission zone. Also, with the introduction of prioritizing interconnection requests with the same scoring criteria based upon the DFAX, the additional step of requiring additional at-risk study deposits is unnecessary if the 150% limit is not seen as a firm limit.

Terra-Gen believes that the proposed auction tie-breaker mechanism will be complicated and is unnecessary; should the scoring rubric and DFAX tiebreaker be insufficiently limiting, LSA prefers simpler methods like pro rata awards and acceptance of all projects “on the margin.”

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

No Comment.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Terra-Gen believes additional discussion and effort is needed on the TPD allocation process changes.

Given the lead time of some deliverability upgrades it seems unrealistic that projects requiring such upgrades will be able to execute a PPA within the three opportunities to seek a TPD allocation. These projects would then be converted to EO which now requires the project to reach COD for eligibility to request a TPD allocation. Terra-Gen believes there should be an option to allow projects with long lead time upgrades to defer their initial request for a TPD allocation if necessary.

Terra-Gen notes the concept of multi-year Interim Deliverability should be reconsidered and further discussed as a potential solution to contracting issues. Regarding this concept for longer-term Interim Deliverability, Terra-Gen notes that recent changes in the Generation Deliverability Assessment Review initiative will help some resources get FCDS faster under limited circumstances. However, it appears that many or most resources won’t meet the related requirements, resulting in years between their CODs and their FCDS status or, alternatively, forcing them to postpone their CODs despite urgent system needs and policy directives. Terra-Gen believes that the CAISO should continue to pursue this concept to provide at least some actionable information for PPA contracting, even if the amount available may be small. 

Terra-Gen recommends CAISO should revise its TPD allocation processes to include information about the upgrades needed to implement awards and the expected in-service dates of those upgrades. This additional information should be included at least at the same time that notices are issued for each TPD allocation cycle.

Terra-Gen also suggests that EO projects, especially ones that have converted to EO due to lack of transmission capacity, should continue to be able to seek TPD under Groups A and B upon securing a PPA or being short-listed.

Terra-Gen objects to requiring a project that transfers its deliverability to withdraw from the queue or to downsize its generating capacity to its remaining deliverability. Such projects are subject to the commercial viability criteria and time-in-queue requirements proposed in Section 3.6. Therefore, they should be allowed to develop as EO projects if shown to be commercially viable as an EO project or seek deliverability if viability criteria are met. CAISO could support these potentially still-viable EO projects by allowing these potentially still-viable EO projects to seek a new Group A or B award if they qualify, on the same basis as other projects, instead of providing that the project can only seek a new TPD award under Group C, i.e., if the project reaches COD as Energy Only.  There is no reason to disqualify them from a new award if they otherwise qualify.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

No Comment.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

No Comment.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

No Comment.

9. Additional comments:

No Comment.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

Upstream does not have any comments

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Upstream supports the CAISO proposal that FCDS and EO projects are treated equally during the intake process. 

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

Upstream does not have any comments

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

Upstream does not have any comments

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

• The proposed modifications to the TPD Allocation Process have been introduced extremely late in a stakeholder process that’s been proceeding for almost a year.  The scope of this proposal and the impact that it will have on the interconnection process and queue deserves a robust discussion that could only be facilitated through a new stakeholder process.    
• CAISO’s proposal to limit Energy Only projects to Allocation Group C is misguided and an effort to bludgeon energy only projects out of the queue. 
  • CAISO frequently states that Energy Only projects rarely achieve Commercial Operation.  This was true when Energy Only Projects were relegated to Allocation Groups 4-7 (and behind Allocation Groups 1, 2, and 3 in terms of receiving an Allocation).  In the 2021 IPE, CAISO modified the Allocation Groups so that Energy Only Projects can qualify for Group A, B, C, or D.  With this change, many projects that were Energy Only have received deliverability and are contracted to meet Mid-Term Reliability obligations of LSEs.
  • The proposed modification implies that projects that recently filed in the queue are more viable than earlier queued projects.  This is often not true.  Earlier queued projects are more viable than later queued projects due to the length of time it takes to permit energy projects in California (whether through CEQA or NEPA).  If CAISO wants to refute this, then CAISO should release the percentage of QC13 or earlier queue projects that have i) received their draft environmental document or ii) received government approval and compare this against the percentage of QC14 projects that have i) received their draft environmental document or ii) received government approval.  This information can be found in the recently filed TP Affidavits.  
• In the 2021 IPE, CAISO modified the Allocation Groups so that Energy Only Projects could qualify for Allocation Group A or B (and be on an equal footing to FCDS).  The Tariff does not allow an IC to negotiate their LGIA while parked and CAISO advised ICs to convert to Energy Only in order to proceed with their LGIA and move into execution with the PTO.  Under CAISO’s proposal, these projects would now qualify for Allocation Group C and effectively be forced out of the            queue by CAISO (no rational developer will invest millions of dollars hoping they’ll receive an allocation behind projects that have a PPA or are short-listed).  CAISO has completely flipped positions in less than two years with this “bait and switch.”
• The goal of the TP Allocation Process is to ensure deliverability is allocated to the most viable projects.  If CAISO is serious about this goal, then the Allocation Groups should be reconfigured as follows…
  • Allocation Group A – Achieved Commercial Operation (FCDS or EO)
    • No developer is more committed to their project than one who has invested millions of dollars to bring the project to commercial operation.
  • Allocation Group B – Contracted (FCDS only)
    • CAISO and stakeholders would need to determine how best to manage ESPs and LSEs who attempt to profit from this by entering into contracts that provide the developer with a termination right if they receive deliverability.  
  • Allocation Group C – Short-Listed (FCDS or EO)
    • EO projects must be contracted within one year.
    • CAISO and stakeholders would need to determine how best to manage ESPs and LSEs who attempt to profit from this by short-listing projects in exchange for a fee.  
• Reserving Transmission Plan Deliverability for public policy initiative that may or may not materialize like offshore wind and advanced geothermal will ultimately harm ratepayers if these technologies fail to become “least-cost, best-fit resources”.  The development of offshore wind has performed horribly on the east coast with far less development challenges than offshore wind faces in California (deep water versus shallow water being one).  Reserving TPD for previously allocated projects and MIC aligns with the policy goal of open access.  Picking winners and losers based on the hope of future technological advancement and declining cost curves does not.  CAISO should allow a competitive market to dictate resource development via LSEs “least-cost, best-fit” procurement.  

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

• Power Purchase Agreements used to demonstrate CVC must not include a provision that allows the developer to terminate the PPA.  Without this, certain LSEs will turn this into a profit center and offer contracts with a “termination for a fee” provision once the IC has demonstrated CVC.  
• QC14 triggered a number of long-lead time RNUs that are required for QC14 projects that won’t be placed-in-service until well after CAISO’s proposed QC14 CVC date of April 30, 2028.  In addition, the majority of approved 2022-2023 TPP Policy-Driven Upgrades that add additional deliverability won’t be placed-in-service until well after April 30, 2028.  For these reasons, CAISO should consider moving the QC14 CVC date to April 30, 2030.  

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

Upstream supports the CAISO proposal to notify ICs when an IC executes a LGIA with shared upgrades and allow the PTO to proceed with design and construction of the shared upgrades.   

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

Upstream supports CAISO proposed hybrid approach of allowing the ICs and PTOs to decide when to amend LGIAs with the backstop that the amendment must be done no later than nine months prior to synchronization.   

9. Additional comments:

Eliminating the proposed One-Time Withdrawal Penalty was a lost opportunity to reduce the number of non-viable projects in queue.  The potential cost exposure to the PTOs is minimal if the project hasn’t executed its LGIA and provided Authorization to Proceed.  CAISO should look for another funding mechanism to cover this (the balance of QC14 Phase 1 and Phase 2 study deposits not spent or QC13 2^nd IFS posting to the extent this hasn’t already been allocated).  At a minimum, CAISO could ask ICs for a preliminary list of projects that would potentially withdraw under the One-Time Withdrawal Penalty to determine the actual financial exposure that the PTOs may have.

1. Provide your organization’s comments on the proposed generic timeline proposed in Section 2.1 - The Zonal Approach: Data Accessibility:

Vistra appreciates the CAISO providing this timeline. We suggest that the CAISO should revise the draft to accommodate the following:

• Transmission Plan Deliverability (TPD) affidavits and allocation study steps shown in Year 1 Cluster Schedule are for prior clusters as currently shown but that the first TPD cycle that applies for the Cluster shown in green would be in Year 3 in Feb-Apr and Jul-Sep.
• Move Interconnection Request window close to after the TPD allocation heat map has been updated with the TPD allocation study that uses the most recent ISO Board of Governors approved Transmission Plan.
• Add the Interconnection Facility Study to Year 2 Cluster Schedule in Oct-Dec of that year.
• Consider adding out Years 3-7 to show through the final TPD allocation cycle opportunity and then proceeding to Generator Interconnection Agreement (GIA).

2. Provide you organization’s comments on new section 2.2.3 – Treatment of Full Capacity Deliverability Status and Energy Only Resources:

Vistra supports CAISO’s proposal to not count Energy Only (EO) capacity towards the 150% threshold. The CAISO should clarify that only the Full Capacity Deliverability Status (FCDS) portion of a Partial Capacity Deliverability Status (PCDS) projects would count towards the 150% in line with this proposed policy. 

3. Provide your organization’s comments on modifications to Section 2.4 Scoring Criteria for Prioritization to the Study Process:

As Vistra noted in its straw proposal comments, we do not support a scoring method that unfairly allocates points for screening based on Load Serving Entities (LSE) interest category and System Need category instead of whether a project is more viable. Vistra appreciates the CAISO revising its straw proposal to put more reasonable limits on the ability of LSE to unduly preference their self-build projects over non-utility build projects. Vistra supports the proposed limitations placed on allocated LSE interest points to no more than one self-build project as a positive step. While CAISO’s limits to self-build prioritization are a step in the right direction, Vistra believes additional changes are needed to place greater scoring weight on project viability. Vistra requests the CAISO reduce the weighting on system need points to 20% so that the combined maximum non-project related points would more fairly be limited to 50% of total project points. This balance more fairly and accurately scores projects based on their characteristics and others preference for that project.

4. Provide your organization’s comments to additional modifications to the merchant deliverability option:

Vistra requests the CAISO commit to a Transmission Planning Enhancement initiative that would explore a network service subscription model for developers to subscribe to Network Upgrades and reduce the overall cost of the transmission project in exchange for guarantee of Transmission Plan Deliverability. The network service subscription model should allow for more merchant deliverability options above what is contained in this report.

5. Provide you organization’s comments on new section 2.7.1 – TPD Allocation Process Modifications:

Vistra has consistently maintained that commercial practices to offer projects into RA solicitations prior to executing a Generator Interconnection Agreement (GIA) would be akin to offering an speculative project to the off-takers and inappropriately introduces risks into solicitations. We appreciate the greater dialogue on this the CAISO and stakeholders have been willing to engage in. Based on the discussion at the February 15, 2024 stakeholder meeting on this Draft Final Proposal, Vistra understands the CAISO’s view is that offering a project to a RA off-taker prior to the executed GIA is acceptable, but that it is not acceptable to offer a project that is not seeking Full Capacity Deliverability Status at the time into a RA solicitation. We request the CAISO be clear about this view in its proposal. In addition to this clarity, we request the CAISO specify whether it has a view on what point in the interconnection process that it would be appropriate for a FCDS project to offer into a RA solicitation. For example, is the CAISO’s view on Good Utility Practice that FCDS projects that have received Cluster Study results should begin offering into RA solicitations or instead that FCDS projects should begin offering after the Interconnection Facility Study results? Under the current process, there is little certainty on commercial operation dates or costs until after Phase II results and, consequently, we are seeking clarity on whether this level of certainty should be expected after Cluster Study results or after the Facilities Study results.

The single most important element to this proposal being successful is that the CAISO be explicit in the Final Proposal, Board memo, and Tariff filing that CAISO approves of the commercial practice to offer FCDS projects during the study process. Vistra interprets CAISO’s TPD allocation process to be codifying a clear policy intent that CAISO will only allocate TPD to FCDS projects that either have executed a long-term RA agreement (Group A) or are shortlisted for a long-term RA agreement (Group B). This proposal may be workable, if the CAISO is extremely clear that this is its policy intent. With this clarity, stakeholders can have more confidence in our efforts to align commercial activities with CAISO’s new rules and procedures proposed.

If CAISO’s policy intent is to only allocate TPD to FCDS projects, projects that need TPD to affirm their FCDS pending deliverability studies to fulfill the long-term RA obligations, then Vistra requests CAISO remove both Group C and Group D. By removing both Group C and Group D options, CAISO will make even clearer its policy intent that it will only allocate TPD to projects that are or are likely to be selling RA. This change also ensures queue projects without long-term RA agreements and Energy Only projects that have achieved commercial operations without long-term RA agreements are treated on an equal playing field. If an Energy Only project that is online or a queue project that is progressing through the queue seek TPD allocation, then they will both need to participate in solicitations and either secure or be shortlisted for a long-term RA agreement. With this accommodation to treat all projects fairly and apply the clear standard of meeting Group A or Group B this proposal could be workable.

Additionally, Vistra requests the CAISO clarify that before beginning the Interconnection Facility Study that all projects must have 100% site control demonstration unless eligible for deposits in lieu under FERC Order 2023.[1] At the time of TPD allocation cycle all projects would as a result have 100% site control.

[1] FERC Order 2023 at Paragraph 594.

6. Provide your organization’s comments on updates made to Section 3.6 - Viability Criteria and Time in Queue:

Vistra requests clarity on how the TPD allocation (Section 2.7.1) proposal to only allocate TPD to interconnection projects seeking FCDS that have entered or have been shortlisted for a long-term RA agreement (i.e., PPA), and this proposal to require that PPA five years from the Interconnection Financial Security study. The Commercial Viability Criteria (CVC) Part A requires “Providing proof of having an (or multiple) executed power purchase agreement (whether for Resource Adequacy requiring TPD or for Energy Only) by providing the ISO a copy of such executed agreement(s) and other supporting documentation as applicable.”

Please confirm the following scenarios are accurate representation of the proposal:

• Scenario 1: Receives TPD allocation through Group A (executed PPA) so has already met CVC Part A requirements.
• Scenario 2: Receives TPD allocation through Group B (shortlisted PPA) so proceeds forward and must secure final executed agreement before CVC requirements.
• Scenario 3: Unless Group C is removed, receives TPD allocation through Group C may have a executed PPA – CVC met – or must have secured final executed agreement before CVC requirements.[1]

Please clarify the proposal on page 84 that for any of the above three scenarios, to achieve CVC requirement to retain TPD allocated to the project that this means all Groups A-C would be considered having FCDS at the time the CVC is due. Generally, please clarify that a project seeking to obtain (TPD allocation process) or retain TPD allocation by meeting CVC requirements must have a PPA that requires Resource Adequacy benefits. 

Vistra requests the CAISO revise its proposal for the CVC requirements as these appear inconsistent with FERC Order 2023 requirement stating, “pursuant to revised sections 8.1 and 11.3 of the pro forma LGIP, provide evidence of 100% site control for the generating facility at the time of execution of the facilities study agreement and when executing, or requesting the unexecuted filing of, the LGIA.”[2] Our interpretation of the FERC Order 2023 is that while 90% site control is required at the time of submission of the interconnection request that the CVC demonstration of 100% site control is required at the facilities study agreement, which would be prior to the new Interconnection Facilities Study roughly beginning October of Year 2 in the CAISO’s draft new schedule.[3] Given that 100% site control is required during at time of the execution of the Interconnection Facility Study agreement including this in the CVC may cause confusion, and we request the final proposal revise to make clear that retaining 100% site control demonstrated for eligibility to be studied in the Interconnection Facility Study is the requirement. As it currently reads it implies the CVC deadline is the first 100% demonstration deadline, which is inconsistent with FERC Order 2023 requirement.

[1] Vistra requests the CAISO remove Group C altogether and only allow projects whether energy only that have achieved commercial operations or in progress queue projects to compete for TPD if they have an executed long-term RA agreement (Group A) or shortlisted for a long-term RA agreement (Group B). If CAISO makes this policy change then Scenario 3 is moot.

[2] FERC Order 2023 at Paragraph 594.

[3] Vistra believes 100% site control is required under FERC Order 2023 prior to beginning the Interconnection Facility Study that is shown in the proposed schedule roughly beginning October of Year 2. Proposed schedule available at https://www.caiso.com/InitiativeDocuments/ProposedSchedule-InformationAvailability-InterconnectionStudyProcess.pdf.

7. Provide your organization’s comments on updates made to Section 3.8 – Earlier Financial Security Postings for Projects with Shared Upgrades:

None currently.

8. Provide your organization’s comments on updates made to Section 3.9 – Revise Timing of GIA Amendments to Incorporate Modification Results:

None currently.

9. Additional comments:

None currently.