Comments on Final proposal

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

ACP-California appreciates the significant time, thought and effort that has been put into developing the IPE 2023 Final Proposal and to advancing the interconnection process in CAISO. This initiative has taken significant effort from CAISO’s staff and many stakeholders to develop substantive reforms to the interconnection process that may help address the challenges that have been experienced in recent clusters. And while ACP-California generally supports the final direction of IPE 2023, we have a few concerns related to modifications made in the Final Proposal, as discussed below. Additionally, we seek clarification from CAISO on one item related to the eligibility of Long Lead-Time resources in the scoring criteria.

Limits on LSE-owned Projects

In comments on the Draft Final Proposal, ACP-California noted that “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.”

ACP-California is concerned that the Final Proposal drastically relaxes the restrictions around the provisions of commercial interest points to LSE-owned projects. While the Draft Final Proposal limited LSE self-build point allocation to a single project, the Final Proposal now only limits LSE self-builds to allocating points to three projects per cluster or 25% of their MW allocation whichever is greater. ACP-California is concerned that this relaxation may have anti-competitive impacts and result in IPP projects not being able to fairly compete for entrance into the interconnection queue. The restriction contained in the Draft Final Proposal, while still not ideal, was superior to the restriction in the Final Proposal and we urge CAISO to revert to the prior restriction of one LSE self-build project per cycle. If CAISO does not revert to the prior policy, then at a minimum, we urge CAISO to commit to evaluating this restriction and whether it should be tightened after the first cluster is admitted under the new interconnection rules proposed herein.

Limits on Non-LSE Commercial Interest Expression

ACP-California appreciates that CAISO has incorporated a pathway for non-LSE offtakers to express commercial interest in projects and receive points to assist in entering the queue. We continue to believe the inclusion of non-LSE interest in the process is imperative to ensuring open access and critically important given that, according to ACP’sQ3 2023 report, corporate offtakers are the buyers for nearly 20% of clean power capacity in development across the country. We are, therefore, concerned that CAISO’s new restriction on non-LSE interest (to a single project per cluster) could be highly problematic and is discriminatory. In the Final Proposal, non-LSEs are limited to expressing interest in a single project per cluster cycle with no adjustments based on the size of the project or their expected procurement needs to meet climate goals. Thus, under the Final Proposal, non-LSEs are not only limited to 25% of the commercial interest points available to projects that receive commercial interest from LSEs but also to a single project. This is unduly restrictive for non-LSE offtakers and may prohibit highly viable projects that have real interest from non-LSE offtakers from being able to enter the queue. Given the heavy scoring preference for LSE projects, ACP-California suggests that CAISO remove the restriction on non-LSE commercial interest to a single project and commit to monitoring 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.

Clarification on the Qualifications for Long Lead-time Resources

ACP-California appreciates CAISO’s continued work to refine the definition of the long lead-time point category and appreciates the modifications in the Final Proposal that indicate CAISO will work with the CPUC and LRAs to determine the list of eligibility requirements for this category. And, while we would prefer additional flexibility for allocating these points where CAISO believes there is likely to be transmission capacity approved in the upcoming TPP, based on a CPUC submitted portfolio, we understand CAISO’s argument that these points cannot be allocated until CAISO knows that transmission capacity will exist. ACP-California seeks clarification that points can be allocated to Long Lead-Time resources in areas where there is existing transmission capability and not only in areas where there is newly approved transmission capacity, so long as the project also meets the other criteria in this category. We believe that is the intention of this category of points and, thus, that these points could be allocated to, for instance, OSW interconnecting in the Diablo area. But we would greatly appreciate CAISO clarifying this in the final proposal and associated tariff language for this initiative. We would suggest the following modifications to the language for Long Lead-Time Resources:

“Meets the requirements of the CPUC and other LRA resource portfolios where the TPP has approved transmission projects to provide the necessary transmission requirements or where there is transmission capability on the existing system.”

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

This extended timeline appears necessary to work through the underlying issues around TPD allocation and, therefore, ACP-California supports it. However, we urge CAISO to begin work on Phase 3 immediately and not to delay simply because there is additional time before bringing a proposal to the Board. We anticipate changes to the TPD allocation process will be controversial and will take a significant amount of time from CAISO and stakeholders alike to resolve. Thus, getting started on this policy work early is advisable.

Additionally, as CAISO looks to propose modifications to the TPD Allocation process, we reiterate the points made in our prior comments (available here), including the concerns with the proposed elimination of Group D, CAISO’s tariff-based authority to reserve TPD capacity for resources that align with TPP approved transmission projects, the need to further define how “reserved TPD” will be allocated to individual projects, and the need to clarify the application of the proposed three opportunities to seek TPD to all projects in the queue (including Cluster 14 and earlier).

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

N/A

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

AES appreciates the opportunity to submit comments on the Interconnection Process Enhancements Track 2 Final Proposal. AES appreciates the efforts put together by the CAISO and all stakeholders, but unfortunately, believes that the Final Proposal has not been vetted enough to ensure open access and be considered just and reasonable before FERC. AES does not believe that the CAISO has provided enough justification for the zonal approach backed by empirical data. AES is also concerned that the CAISO has not provided clarity on how it would be implemented, leaving stakeholders questioning the efficacy of the proposal. 

In the comments below, AES provides feedback to CAISO on data accessibility, Cluster 15 timeline, interconnection process timelines, scoring criteria, energy-only treatment, commercial viability criteria, and phase angle measuring units. 

Data Accessibility 

The Final Proposal is unclear on the methodology to calculate the available transmission capacity in each zone. The CAISO states that it will base the available capacity with consideration of the known constraints in each zone because there are cases where determining capacity based on CPUC portfolios doesn’t align with the constraints in each zone. Therefore, is the CAISO subtracting the amount of allocated TPD in each zone from the new resources identified in the CPUC portfolio, then adding on the constraints? 

AES seeks clarity on the CAISO’s definition of TPD zones and Merchant zones. The Final Proposal defines TPD zones as zones with greater than 50 MW available based on known constraints within the zone. Otherwise, the zones are considered Merchant zones. AES seeks clarity on whether the zone would only be considered a TPD zone if at least one project greater than 50MW can fit into a node with no constraints. On the other hand, can a zone be considered a TPD zone if the aggregate available capacity in the entire zone is greater than 50 MWs?  In addition, AES finds that the newly proposed 50MW threshold for TPD zones and Merchant zones is arbitrary without justification. While CAISO staff has noted that they “usually see projects greater than 50MWs”, there is still no data evidence to support the cutoff threshold and explanation on the treatment of the remaining 50 MW of available TPD capacity. 

AES has observed the interchanging use of the words “zone” and “constraint” and has found it confusing for stakeholders. While the CAISO proposes TPD zones, it appears that the ability for a project to enter the “zone” is based on whether there is capacity behind a “constraint”. If so, AES recommends the CAISO to reframe the language around “constraints” rather than “zones” to minimize confusion.  

Regarding the information package released to stakeholders on April 3, 2024, AES recommends the CAISO hold a technical workshop to discuss the published information with stakeholders. AES has observed accounting errors and unexplainable constraints that were not identified in Cluster 14 Phase 2 reports. Regarding accounting errors, in PG&E Fresno Area and SCE Eastern Area base portfolios, the Energy-Only (EO) resource type capacity does not add to the correct total. In the PG&E Fresno Area, the FCDS resource type capacity does not add up to the total. For unexplainable constraints, for example, AES has observed that the overloads identified in Phase II reports are different than the constraints identified for the Greater Bay Area. AES believes that a technical workshop is beneficial for stakeholders to understand the material released as similar information would be released for future queue clusters. 

Cluster 15 Timelines 

AES appreciates the CAISO providing the Cluster 15 process timelines but is immensely concerned with the lack of clarity on the available capacity for Cluster 15. In addition to the process timeline in the Final Paper, the CAISO has noted in their presentation slides that a list of POIs within each zone will be provided to interconnection customers for self-validate changes to POIs by May 1, 2024. AES is incredibly concerned about the information misalignment between the data accessibility document and the actual TPD capacity available for Cluster 15. While the CAISO provided information on the FCDS and EO capacity available in each interconnection area, the CAISO has not considered that the 2024 TPD allocation cycle will likely allocate most of the TPD that is considered “available” at this time. Through AES’ initial analysis, all zones will have zero capacity after the 2024 TPD allocation cycle. Therefore, even if a list of POIs is provided by May 1, 2024 for each interconnection zone, it will still be highly uncertain whether these zones will have capacity after the 2024 TPD allocation cycle, if any. This is an incredible concern as developers are significantly investing in Cluster 15 projects in preparation for the December 1, 2024 scoring deadline but are not clear whether interconnection requests are in TPD zones or Merchant zones. The CAISO needs to update the base case portfolios after the 2024 TPD allocation cycle for developers to have clarity on the available capacity as this information determines whether projects are in TPD zones or Merchant Zones. 

Interconnection Process Timelines 

For Cluster 16 and beyond, AES appreciates the CAISO responding to stakeholder comments to move the request window to sometime after the TPD allocation studies. However, AES notes that there is a really short time between the TPD allocation study results and the updated heatmap before the request window opens. This small window of time of two months does not allow sufficient time for developers to conduct appropriate due diligence to prepare interconnection applications for submission. The CAISO should consider either (1) reverting the TPD affidavits and TPD allocation study to the original timeline, where TPD allocation results are posted by May annually; or (2) pushing the request window to December to give sufficient time between TPD allocation results and queue window opening. 

Zonal-Level Scoping Meetings 

AES does not support only having zonal-level scoping meetings and urges the CAISO to include an option for individual scoping meetings. Developers would not be able to ask project specific questions as confidential information may be shared. 

Scoring Criteria 

AES is disappointed at the final iteration of the scoring criteria. AES finds the final scoring criteria do not include any project viability factors for developers to control the level of readiness for scoring. Instead, the final scoring criteria heavily factors LSE interest as the main determinant of whether projects are accepted into the study process. Outside of LSE interest, the remainder of the scoring criteria consists of system need and existing facility expansion, which neither are within the control of the developer to demonstrate increased readiness. 

AES has two concerns regarding LSE interest. AES is concerned that the LSE point allocation process lacks transparency. While the CAISO encourages the LSEs to include a fair and transparent point allocation process within their operating tariff, it appears that the LSEs cannot commit to including a process into their tariff based on the April 4, 2024 stakeholder call. This is concerning as LSE interest is likely the main factor for projects to enter into the study process, yet lacks transparency. In addition, the revision for LSE self-selection of “three projects or 25% of allocated points, whichever is greater” appears to favor LSE self-builds. At a minimum, CAISO should limit LSE self-build projects to three projects or 25% of allocated points, whichever is less. 

AES does not support the limitations around non-LSEs in the scoring criteria and recommends the CAISO remove the limitation for non-LSEs. Limiting non-LSE interest affidavits to one per queue cluster does not fairly consider non-LSE needs. Many large non-LSEs have procurement goals that result in multiple projects needed. Non-LSE interest already weighs significantly less than LSE interest, and limiting non-LSE customers to one project endorsement per queue cluster will likely eliminate entry for non-LSE customers as these projects would receive overall less points than projects with LSE interest. In addition, CAISO should not require including corporate sustainability policy goals in affidavits. Non-LSEs may have a variety of reasons to procure capacity that is not within corporate sustainability goals. While the CAISO stated that the increased restriction on non-LSEs is meant to prevent gaming within the scoring process, AES believes that there are other checks within the scoring process to mediate the potential issue. For example, the proposed Dfax and auctions for tie breakers would minimize the potential abuse of non-LSE affidavits. AES urges the CAISO to remove specific requirements within affidavits and allow the non-LSE freedom to justify their desire for projects in the affidavits.  

Regarding project viability, AES seeks further clarity on engineering design. In order for interconnection customers to provide meaningful designs for scoring, the CAISO must provide definitions around different engineering designs. AES advises that the industry accepted percentages for engineering design are 30%, 60%, and 90%. The CAISO should consider using these percentages and provide clear definitions (i.e. electrical, civil) of the requirements to meet the engineering designs, rather than just having an affidavit with a professional engineer stamp. 

Energy Only Project Treatment 

AES urges the CAISO to consider a reimbursable path for all EO projects. The current proposed reimbursable EO path heavily depends on CPUC resource planning and does not provide room for planning errors. For merchant projects seeking deliverability, the CAISO proposes reimbursement for local deliverability network upgrades. AES believes that similar principles should apply for the current “non-reimbursable” EO path, where reimbursements for reliability network upgrades (RNUs) should be allowed. Allowing reimbursements for EO projects can also help balance any EO need that is not identified in the CPUC resource planning process. 

Commercial Viability Criteria 

AES seeks clarification on the annual demonstration of commercial viability criteria (CVC). After meeting the CVC requirements, the developer is required to demonstrate the annual process towards meeting the CVC or risk withdrawal if there is a failure in meeting the CVC requirements. AES urges the CAISO to include a cure period before withdrawing projects to allow the developers an opportunity to provide evidence to meet CVC. In addition, the CAISO states that specific and distinct progress must made for permits annually. If a project’s permitting process does not go as planned, can the developer demonstrate a new permitting path and still meet the annual CVC requirements? Alternatively, if the permitting process is dependent on the California Energy Commission’s AB 205 process, would the CAISO allow the status of the AB 205 process to meet CVC requirements? 

In addition, AES seeks clarification on the CVC requirements for the status of engineering and design of the generating facility. For the initial CVC requirements, does the project have to demonstrate the level of engineering design that was originally submitted into the scoring process? If so, it is expected that increased engineering design will be made annually after the initial CVC demonstration. For example, if a developer submitted 50% engineering design in the scoring process, would the same engineering design suffice for the initial CVC demonstration? 

Phase Angle Measuring Units 

AES is not opposed to the CAISO's proposed change to 16 samples per cycle for phase angle measuring unit data. However, AES seeks clarification on what projects this requirement applies to (i.e. projects without LGIAs). 

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

AES supports extending the TPD initiative timeline by targeting the October 3, 2024 CAISO Board of Governors meeting for a decision.  

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Comments on Section 2.5.1 of the CAISO’s Final Proposal for Track Two of its 2023 Interconnection Process Enhancements (“IPE”) initiative

Amazon Energy LLC (“Amazon”) appreciates the opportunity to submit these comments on the CAISO’s Final Proposal for Track Two of its 2023 Interconnection Process Enhancements (“IPE”) Initiative. Amazon focuses its comments exclusively on section 2.5.1 of the current initiative and the proposed prioritization in the Interconnection Study Process for projects that can demonstrate commercial interest from LSEs ahead of those that show non-LSE commercial interest. Amazon is concerned about this prioritization given Amazon’s commitment to developing carbon-free deliverable capacity in California and the potential for this element of the IPE to impede the development of projects that sell capacity to non-LSEs.   

The IPE’s proposed LSE prioritization is reminiscent of the CAISO’s 2021 IPE efforts to preferentially allocate Transmission Plan Deliverability (“TPD”) to Interconnection Customers with LSE offtakers ahead of non-LSE offtakers. Following consideration of comments, the CAISO modified its approach so that Interconnection Customers that contracted with non-LSEs still had the opportunity to obtain an allocation of TPD. The CAISO should similarly follow suit here.

While the Interconnection Study Process prioritization proposed in this initiative is quite different from what was proposed previously, Amazon remains concerned that treating interconnection customers differently based on their offtaker is problematic and likely to impact project development. Under the current IPE proposal, CAISO will base points for commercial readiness on expressions of interest from LSE or non-LSE offtakers, with expressions of commercial interest from LSEs receiving 4 times as many points as non-LSE interest (100 v. 25 points). 

If this proposal remains unchanged, CAISO would prioritize a renewable or other carbon-free project that enters into a power purchase agreement (“PPA”) with a corporate buyer like Amazon lower than one that has a mere expression of interest from an LSE. This is backwards. Corporate PPAs are executed well in advance of project operational dates and are routinely financed by investors and banks. Expressions of interest from LSEs are not financeable on their own and are not bankable for financing. If the CAISO seeks to advance the study process for projects that are more commercially viable, then CAISO non-LSE offtakers should weigh comparably or ahead of those with lower degrees of actual commercial interest from LSEs.

In its 2021 IPE comments, Amazon explained that prioritizing the TPD Allocation Process to advantage LSE projects over projects with corporate offtakers like Amazon who do not have resource adequacy (“RA”) obligations will not help California achieve its goal of cost effectively decarbonizing the power grid while maintaining system reliability. If project developers that contract with corporate offtakers are effectively unable to obtain a TPD Allocation, the end result would be a reduction in the overall deployment of clean energy in the State. It would also end up reducing the supply of RA-eligible resources being developed, as non-LSE offtakers will instead contract for energy-only resources. The reduced supply of RA-eligible resources would lead to higher prices for RA and therefore higher prices to California consumers, with the additional energy-only resources contributing to additional congestion on the transmission system. 

The current IPE proposal with respect to Interconnection Study Process raises the same concerns about reducing the number of projects being developed by discouraging developers from contracting with corporate offtakers like Amazon. 

Amazon recognizes that the CAISO is looking for ways to streamline the interconnection study process for Cluster 15. Given Cluster 15’s size, Amazon encourages this effort. To that end, Amazon understands enabling LSEs to prioritize a limited number of specific projects that are important to that LSE. But scoring projects with LSE commercial interest above those with non-LSE commercial interest goes too far, sends the wrong signal to corporate offtakers and developers, and fails to provide a useful metric for commercial viability. 

Treating interconnection customers differently based on their offtaker is problematic, whether in the context of the Interconnection Study Process or the TPD Allocation process, and should be avoided. Given California’s ambitious objective to decarbonize the power grid while maintaining system reliability, Amazon urges the CAISO not to advance a new set of rules which treats offtakers differently and may delay or prevent the development of much needed resources by corporate offtakers.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

No comment

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the IPE 2023 Track 2 Final Proposal, the work product resulting from extensive efforts put forth by the CAISO and stakeholders to better enable the rapid deployment of new generation. CalCCA supports many elements of the Final Proposal, including:

• The zonal approach to prioritizing interconnection to areas with available or planned transmission capacity;
• Utilizing scoring criteria to prioritize interconnection requests with the zones to the ones that are most ready to move forward;
• The makeup of the scoring criteria, specifically (1) the commercial interest criteria which will allow load-serving entities (LSE) to provide input into the prioritization based upon their needs, preferences, and integrated resource plans, and (2) the system need criteria which will ensure a diverse resource portfolio advances through the interconnection queue; and
• Enhancements to the queue management process, in particular, the revised viability and time in queue requirements that will provide an equitable and reasonable time projects can remain in the queue without reaching certain milestones.

As the CAISO is implementing the interconnection request intake and scoring criteria process, it should strongly consider modifying the timeline for LSE submittal of their commercial readiness scores. The CAISO indicates LSEs will have ten calendar days following interconnection request submittals to submit their scores. This is a very tight turnaround and will likely be insufficient for LSEs to accurately match project information received via LSE requests for information (RFI) with submitted interconnection requests. While the CAISO suggests it needs to limit the time between interconnection request submittal and LSE scores to align with deadlines from FERC, it is not clear that providing LSEs with one month to provide their scores would interfere with these deadlines. This is because (1) LSEs will finalize their Cluster 15 interconnection requests on December 1, 2024, (2) the CAISO will begin reviewing interconnection requests on January 1, 2025, and (3) applicants can withdraw interconnection requests by January 1, 2025, for a full refund. Given these deadlines, it seems LSEs should at least have roughly one month to submit their scores (i.e., from December 1 to January 1). The CAISO should also aim to provide LSEs with a list of interconnection requests detailing the project name, technology, point of interconnection (POI), and megawatts (MW) as soon as requests are submitted on December 1. LSEs will need to finalize their scores after seeing the entire set of interconnection requests, rather than only seeing subsets of proposed projects that responded to individual LSE RFIs. As proposed, the timeline for LSE scoring will result in rushed evaluations based on incomplete knowledge. For LSE scoring to be useful it should be based on the best available information, which would include seeing a complete set of the interconnection requests with project details provided to LSEs by CAISO.

The CAISO should also monitor the 150 percent sub-zonal constraint limit that the CAISO would use to limit the number of projects studied in each zone, to ensure the 150 percent limit supports the pace of build required to meet Senate Bill (SB) 100 (De León, Chapter 312, Statutes of 2018) targets. CalCCA estimates a need for over 6,000 MW of new resource interconnection per year to reach SB 100 targets by 2045.[1] The CAISO’s test run of the constraint analysis using Cluster 15 projects and study results indicates that of the 508 interconnection requests submitted, only 200 of 508 requests were eligible to proceed to scoring based on an initial constraint check. It appears the CAISO found the 308 projects ineligible because they were located in areas with no available transmission capability. After scoring the 200 requests until the CAISO reached 150 percent of each constraint, the CAISO was left with 112 requests that it would study. While it is unclear the number of MW associated with the 300 requests that were ineligible or the 112 requests that would have moved on to the study process, the results of this test could be concerning if it reveals the available interconnection capacity is not keeping pace with the need. If the 150 percent limit restricts the capacity associated with studied interconnection requests in a way that does not keep pace with needs, this could highlight issues with the process for advancing policy-driven transmission to support generation interconnection. The CAISO should monitor the amount of capacity that advances to the study process under the zonal approach to ensure resource planning, transmission planning, and the interconnection process support the need for new capacity on the system.

[1]            2001-2022 Electric Generation Capacity and Energy? California ISO 2023 Year in Review less 2023 retirements list? and SB100 Joint Agency Report Assumes straight line growth between 2024 and 2045.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

CalCCA supports the CAISO’s proposed timeline for initiating Track 3 but recommends flexibility regarding the timeline for bringing Track 3 proposals to the CAISO Board of Governors. Deliverability allocation is a key issue that requires review. Resource Adequacy (RA) capacity is extremely scarce, and enhancements such as the conditional deliverability approach considered in the Generator Deliverability Review initiative could expand the RA supply stack at a time when it is much needed. Therefore, the CAISO’s proposal to start Track 3 shortly after the conclusion of this Track 2 process is prudent. Beginning the stakeholder process this spring and targeting a July 2024 CAISO Board of Governors meeting would result in a very expedited stakeholder process. As the stakeholder process evolves, the CAISO should be open to extending the initiative timeline as long as the extension does not impact the timeline for Cluster 15 TPD allocation.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

CPUC staff appreciate the time and commitment the ISO has spent on the IPE initiative. CPUC staff support the efforts of the ISO to implement the 2022 Memorandum of Understanding (MOU) between the ISO, California Public Utilities Commission (CPUC), and California Energy Commission (CEC) to tighten linkages among resource and transmission planning activities, interconnection processes, and resource procurement, as the ISO works with stakeholders and local, state and federal authorities to accelerate development and deployment of critical resources.  

CPUC staff request the ISO to ensure their FERC filing gives the ISO flexibility to be allowed to share data and allow for maximized transparency to developers and the public. Throughout the IPE process, CPUC staff have supported efforts for transparency in information about data related to interconnection requests with an emphasis on the public release of the parent company in the interconnection queue report. There are two data transparency issues that should be reviewed to see if they warrant inclusion in the FERC filing so that implementation of the transparency is not prohibited by CAISO’s FERC approved tariff.  

CPUC staff think it is important to ensure both interconnection applicant and parent company information is collected during the interconnection request process to ensure the ISO has the data available for reporting, at the appropriate time. Currently queue positions are not identified by customer name, although the LGIA documents are usually publicly filed at FERC with the customer's name identified. While customer name is often an obscure LLC customer name, the parent company of LLC is frequently a matter of public record. Providing this information publicly will allow for increased monitoring of market power concerns that could arise with developers dominating development in geographic areas. Specifically, the CPUC staff wants to ensure that this information is publicly available to increase transparency behind interconnection requests in each zone and allow for the tracking of parent companies' saturation or market dominance in a zone. In addition, identification of customer name allows for tracking interconnection project development as the projects move through the permitting process, conducted via public agencies. So, while historically there has been no customer identification name provided with any queue position, the name of the company could be public at least after the LGIA process and through the online date. The name of the parent company should at least be required (and required to be updated upon transfer) to allow for the assessment of market power, project viability, and permitting tracking. CPUC staff understands that the confidentiality of the interconnection customer and parent company are both provisions of the FERC approved tariff and such provisions would need to be modified to allow this transparency to occur.  

Additionally, CPUC staff encourage the ISO to ensure explicit direction is given for interconnection requests for expansions to ensure queue reporting of project modifications (expansions) does not unintentionally include MWs of projects that have successfully come online.  As the public queue report is currently structured, MWs that have come online already are included in expansion interconnection requests, resulting in a falsely inflated number of MWs in the queue. It also provides data tracking challenges since it now appears that projects have taken an extralong time to come online. For example, a solar project that entered the queue 15 years ago, came online 7 years ago and now wants to add storage at the same point of interconnection – will appear for the next few years to be a project row that is adding both solar and storage, and further will appear to be in the queue for the past 15 years. CPUC staff is not aware whether this particular data transparency issue is inextricably linked to the FERC approved interconnection tariff.  

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

CPUC staff support the proposed expedited timeline of Track 3.  

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

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 Final Proposal. 

Regarding Section 2.5.1 Scoring Criteria for Prioritization to the Study Process – LSE allocations:

As set out in the Final proposal, 30% of the scoring points is determined by the LSEs.  As such, LSEs will be responsible for picking winners and losers in the California ISO (“CAISO”) interconnection process.  CIC has two concerns: (1) allowing LSEs to winnow projects from the cluster process, and (2) the LSE winnowing process is not open and transparent.

LSE winnowing projects:

CIC’s fundamental concern with the Final Proposal is it does not provide a fair opportunity for all projects to enter into the CAISO cluster process. CAISO has set out other scoring criteria to differentiate projects (the balance that forms the remaining 70%), and we do not believe it is appropriate for an LSE to determine which projects can move forward when all else may be equal.  Offtake – by LSE or a non-LSE – is negotiated later in a project development stage, after a project has progressed an interconnection study process, so for an LSE to select projects at the application stage will inherently be very subjective and discriminatory. The LSE allocation should be assessed on an individual basis (pass/fail) and not on a cumulative basis subject to MW limits as proposed. This allows for fair and competitive treatment of all applications at the interconnection request application stage, subject to the remaining scoring criteria based on project stage. Moreover, allowing a fair and open competitive process at the interconnection application stage allows for better value for rate payers when LSEs and non-LSEs are negotiating contracts with generators. 

Project winnowing criteria is not defined:

Notwithstanding CIC’s objection to the LSE’s picking winners and losers as part of the scoring process, we are concerned with the lack of transparency regarding the LSE allocation procedure in the Final Proposal that will be determined by RFIs of the LSEs. CAISO should define clear and objective criteria which should enable an open and competitive market in the CAISO, and open the proposal to stakeholder consultation before finalization. 

Regarding Section 2.5.1 Scoring Criteria for Prioritization to the Study Process - Engineering design plan completeness:

CIC continues to request clarity from CAISO regarding the definition of engineering design, including types of designs (e.g., electrical, civil) and project components (e.g., high voltage facilities, low voltage facilities) that should be included in the design. CIC also emphasizes that engineering design prepared prior to the interconnection studies are subject to change given uncertainty about future upgrades and future transmission projects. CAISO should also understand that engineering design may be modified depending on results of interconnection studies, discussion with the Participating Transmission Owners, and technological changes that could occur in the future.

Furthermore, CIC suggests that CAISO restore the maximum engineering design plan completeness of 30% because 50% engineering design plan is normally prepared after interconnection studies commence. CIC believes that there is a high level of uncertainty for ICs to create 50% engineering design plan without interconnection study results. Therefore, 30% engineering design plan should be the maximum that should be required prior to interconnection studies.

Regarding Section 2.5.1 Scoring Criteria for Prioritization to the Study Process - Expansion of a generation facility:

CIC reiterates its previous comment that CAISO should consider adding the expansion of a generating facility with an executed Large Generator Interconnection Agreement (LGIA) to the subcategory of the expansion of a generation facility. CIC believes that points should be allocated to the expansion of a generating facility with an executed LGIA, especially those who provided the Third Financial Security Posting, because an executed LGIA demonstrates the advanced stage of generating facilities in the queue and Transmission Owners commence construction for facilities once the Third Financial Security Posting is paid. Therefore, the expansion of a generation facility with an executed LGIA and the Third Financial Security Posting that has been paid has a high level of project viability demonstrating the readiness for construction, and full points of 50 points should be awarded to applicable projects.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

No Comment.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

The California Energy Storage Alliance (CESA) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 2 Final Proposal.  CESA’s comments are focused on Section 2.1 – The Zonal Approach and Section 2.5.1 – Scoring Criteria for Prioritization of the Study Process.  CESA opposes the scoring criteria because the commercial viability bucket, which will provide the greatest differentiation among interconnection requests, does not have a defined process by which load serving entities (LSEs) will allocate points to projects. 

During the stakeholder process, CAISO has emphasized that the proposed changes to the interconnection request intake process are aligned with transmission zones consistent with the memorandum of understanding between the CAISO, CPUC and CEC.  This has created a perception that the memorandum of understanding informs how the interconnection process should be modified.  However, it has become clear that the proposed interconnection process changes are not being made at a zonal level, but rather by individual area deliverability constraints.  CAISO must be more precise in its language in future documentation regarding the use of the terms “zonal” and “constraint”.  Also, as demonstrated by data provide by CAISO, applying the FERC Order No. 2023 site control requirements to Cluster 15 significantly reduced the number of interconnection projects that would be accepted for study when evaluating against area deliverability constraints and not zones.        

Based on discussion at the April 4^th stakeholder meeting, the CAISO confirmed that the scoring criteria will be applied by constraint which is significantly more granular than zonal.  This includes the 150% study limit, the application of the DFAX, and the potential auction.  However, the CAISO stated that the 50MW threshold to determine if interconnection requests can elect the merchant deliverability option was calculated by zone.  Given the available transmission plan deliverability provided in the Constraint Mapping with Transmission Plan Deliverability Allocated excel spreadsheet posted on the initiative website it appears the 50MW threshold is more applicable to a given constraint than transmission zone.  CESA requests that CAISO clarify if the 50MW threshold applies to the constraint or the sum of transmission constraints capabilities for a given transmission zone.  CESA notes that if it is by transmission zone, there will be very little opportunity for an interconnection request to be studied under the merchant deliverability option.

The original intent of the scoring criteria was to create a number of differentiating factors that could prioritize those interconnection requests with the highest probability of reaching commercial operation.  Since the initial workshops where stakeholders presented various differentiating factors, the scoring criteria in the final proposal provides very little ability for a specific project to differentiate from other projects based upon its actions.  The means to differentiate interconnection requests relies predominantly with an undefined points allocation methodology by LSEs.

The scoring criteria is split into three buckets: (1) commercial interest, (2) project viability, and (3) system need.  The project viability bucket allows all projects that reach 50% engineering design plan completeness to receive 17.5 points towards the maximum score of 100 points.  CESA believes that the vast majority of interconnection requests will be able to demonstrate 50% completeness, thus providing no differentiation among projects.  Also, CAISO has not provided any definitions of engineering designs and instead relies on affidavits with a professional engineer stamp. The lack of engineering design definitions, such as the requirements to meet different percentage threshold creates uncertainty to stakeholders on what is required and may lead to a vast majority of projects meeting the 50% completeness as definitions may differ from engineers.  Lastly, the highest project viability score a standalone project can receive is 17.5 points.  While additional project viability points are available for expansion of a generation facility, these points are based upon a decision to co-locate a given project with an existing facility, but don’t demonstrate actions the project developer is taking to increase the project’s viability.

The commercial interest bucket provides LSEs with the ability to determine which interconnection requests are studied.  The final proposal clearly outlines how the CAISO will distribute available points to individual LSEs but is silent on the most important aspect of the scoring criteria, how the LSEs will award points to projects in a clear, transparent, and non-discriminatory manner.  The CAISO leaves the development of the point allocation process to interconnection requests to individual LSEs.  During the April 4 stakeholder meeting it became apparent CAISO’s assumption that LSEs could develop an allocation process prior to the Cluster 15 interconnection request deadline of December 1, 2024 is highly unlikely.  First, it is unclear how an appropriate regulatory authority will ensure the new responsibility to allocate points to interconnection requests is through a process developed by an LSE which is transparent and consistent with open access principles. Secondly, CAISO staff stated that it was concerned that not all CAISO LSEs are participating in the Interconnection Process Enhancements 2023 initiative and are most likely unaware of their new responsibilities in the interconnection process. 

In addition, CESA does not support limiting non-LSE interest affidavits to one per queue cluster. Many large non-LSEs have procurement goals that result in the need for multiple projects. Non-LSE interest is already weighted significantly less than LSE interest and limiting non-LSEs to one project endorsement per queue cluster will likely eliminate entry for non-LSE customers as these projects would receive overall less points than projects with LSE interest. Also, CAISO should not require including corporate sustainability policy goals into affidavits as non-LSE may have a variety of reasons to procure capacity that is not within corporate sustainability goals.

The system need bucket, absent clear rules regarding load serving entity allocation in the commercial interest bucket, has the effect of increasing the weighting given to LSEs to 65% of the total scoring criteria.  System need points can be awarded to an interconnection request that is able to provide local resource adequacy or long lead-time resources.  Since LSEs have procurement requirements for both local resource adequacy and long lead-time resources, the LSE does not need to allocate points in the commercial interest bucket to projects that receive points from the system need bucket.  This has the effect of increasing the power to differentiate interconnect requests to LSEs versus actions the project developer can take to demonstrate and receive a higher score.

Since the scoring criteria outlined in the final proposal does not provide project developers with sufficient controllable factors to differentiate the viability of their projects and the process by which LSEs will award interconnection requests commercial interest points is undefined, CAISO cannot apply the scoring criteria to Cluster 15.  CAISO must reconsider other factors to include in the scoring criteria to increase the ability for project developers to control demonstrating that their interconnection request should be selected for study. In addition, CAISO has not provided clarity to stakeholders on the available TPD zones for Cluster 15. While CAISO published a Constraint Mapping with Transmission Plan Deliverability Allocated excel spreadsheet, the information provided does not consider the final 2024 TPD allocation, which will likely absorb majority of TPD capacity given the size of Cluster 14. Given the lack of clarity on Cluster 15 zones and the scoring criteria’s deficiency, CAISO should not apply the scoring criteria to Cluster 15.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

CESA supports the Track 3 proposed timeline. 

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

General comments:

• While Clearway greatly appreciates the effort from CAISO staff throughout more than a year of work on the IPE initiative, the Final Proposal is not ready for adoption and implementation. There are too many open questions remaining about how the new process will work in practice, especially for Cluster 15. For example:
  • How will CAISO reconcile the zonal and constraint-based elements of the proposal – especially classifying projects based on merchant or TPD zones when all the studies and TPD calculations are based on specific constraints?
  • How will hybrid resources with a storage resource seeking FCDS paired with Energy Only solar be treated in the new interconnection process?
  • What recourse will ICs have if LSEs use arbitrary, inconsistent, or biased criteria to award LSE interest points?
  • How will eligibility for points for Local RA and long lead-time resources be limited?
  • What will happen if the mix of resources that score high enough to advance in the study process does not advance system reliability – for example, if all the projects that advance are standalone storage?
• More work is needed to resolve these questions and other issues with the Final Proposal. There are significant new policy elements that appeared for the first time in the Final Proposal, such as the designation of “reimbursement” and “non-reimbursement” Energy Only projects and the limitation on queue entry by constraint rather than by zone. There are also policy elements that are not resolved in the Final Proposal but deferred to later CAISO decisions without stakeholder input, such as the limits on projects eligible for special treatment as long lead-time resources. And there are policy elements that have moved in the wrong direction despite serious stakeholder concerns, such as the increasing role for LSE interest in determining which projects, including LSE-owned projects, move forward.
• Clearway requests that the CAISO hold a workshop focused on implementation. To inform this workshop, the CAISO should provide more information about the Cluster 15 “test run” described in Section 2.4.1 of the Final Proposal and structure the workshop in a Q&A format. Following the workshop, the CAISO should allow for one more round of comments and issue a Revised Final Proposal that clarifies and resolves remaining issues. We realize that this would require delaying the Board vote on IPE to July and delaying the timeline for Cluster 15, but it is more important to get the process right. This revised timeline would also allow for IPE to be sequenced with Order 2023 compliance as originally envisioned.

Section 2.1: The Zonal Approach: Data Accessibility

• In Clearway’s comments on the Track 2 Straw Proposal in January, we proposed an upfront study that would provide preliminary information on cost and timeline for a representative portfolio of projects to interconnect. This study could be used by project developers to secure commitments from LSEs and other offtakers, not just indicating interest in the project but committing to sign a PPA if it advances in the interconnection process. We still believe that this preliminary study would be an enhancement to the CAISO’s proposal that would help achieve the CAISO’s goal of giving LSEs a meaningful role at the start of the interconnection process. With this additional study, offtakers would be able to select projects based on real information (though of course these early study results would be refined once actual projects advance).
• The additional study work could be done without significantly expanding the CAISO’s workload by drawing on existing information. CAISO has already studied most of the Points of Interconnection (POIs) that correspond to CPUC’s portfolio mapping. All of these POIs have been studied multiple times over the last 14 clusters and CAISO already has a robust set of information about upgrade scope, cost and timelines for constructing the required upgrades. CAISO can supplement this information by performing RNU-centric studies on the CPUC portfolios (CAISO already performs deliverability studies on these portfolios as part of the TPP). While this study may seem like additional work, it may reduce the study work required as part of the cluster study and will result in information that will make the scoring criteria meaningful.

Section 2.3.3: Treatment of Full Capacity Deliverability Status and Energy Only resources, and Section 2.5.5: Criteria for Energy Only Projects in Non-reimbursement Zones

• Clearway supports the part of the Final Proposal that requires FCDS, PCDS, and Energy Only projects to meet the same site control requirements and provide the same entry fees and study deposits.
• The “non-reimbursement option” for Energy Only projects is a newly added concept in this final proposal and needs thorough stakeholder input and review. The proposed approach places too much weight on CPUC staff’s busbar mapping of EO resources in CPUC resource portfolios, which does not represent a procurement mandate for resources at certain locations and was not developed as a tool to determine which projects should or should not be eligible for reimbursement of NUs. At the very least, an Energy Only project in any location that secures an Energy Only PPA should be eligible for reimbursement of NUs.
• Rather than using the busbar mapping, CAISO could list feasible substations and zones that can accommodate additional EO projects and allow EO projects at these locations to qualify for reimbursement. CAISO has the ability to test EO capabilities in zones. Some of this information already exists in the past studies that have spanned across 14 clusters pointing to ‘interconnection limitations’ in several zones. This is aligned with Clearway’s recommendation to make more system-wide interconnection analysis available to stakeholders before queue entry.

Section 2.4: Interconnection Request Intake Process

• In addition to the group meetings by zone, Clearway requests that the CAISO allow developers to request individual scoping meetings to discuss commercially sensitive, project-specific information that cannot be shared on a call with competitors.

Section 2.4.1: Fulfillment of 150% of Available and Planned Transmission Capacity

• The proposal to limit access to the study process by constraint rather than by zone would result in outcomes that are unfair to ICs and not aligned with policy. As proposed, if a project is located outside a TPD zone (in an area not aligned with IRP/TPP portfolios), it can proceed with the merchant deliverability option. However, if it is within a TPD zone (more aligned with IRP/TPP portfolios) but behind a constraint without available deliverability, it has no options. Projects in the latter situation should also be allowed to elect the merchant deliverability option. This refinement to the zonal approach was not previously vetted with stakeholders and is a significant change for project developers – it is one of the elements of the Final Proposal that requires more input and clarification before being finalized.   
• If projects’ eligibility to go through the scoring process will be based on constraint rather than zone, then it would be more rational for the other elements of the analysis and queue entry process (including definitions of TPD vs. merchant deliverability areas) should also be by constraint rather than by zone.  
• We request that CAISO explain the intake process and scoring more thoroughly, using examples. In particular, more clarity would be helpful on how CAISO will decide:
  • between TPD and merchant deliverability zones;
  • how to apply the 150% capacity limit (at the zonal level vs. the constraint level);
  • which POIs will be available for projects seeking TPD (CAISO indicated during the meeting that projects at POIs with 0 MW TPD will not be studied. This is a new criterion for inclusion in a study that we are unable to locate in the proposal); and
  • the initial MW number that will be allocated across LSEs by load share.

Section 2.5.1: Scoring Criteria for Prioritization to the Study Process

• Clearway is not opposed to the concept of a scorecard to allow the most ready projects to advance to the study process. However, the scoring criteria in the Final Proposal are not well-calibrated and should not be adopted. Without sufficient points to differentiate projects based on viability, the deciding factor will be interest points awarded by LSEs, who will lack information on the criteria that are most relevant to them (cost and timeline). The scoring criteria need to be revised to produce an outcome that is just, reasonable, and aligned with the needs of the grid. In particular, CAISO should either remove the points for LSE interest or work with the CPUC and LRAs to establish specific rules for LSEs’ evaluation of projects.
• Commercial interest:
  • Without more information upfront on the likely cost and timeline for projects to interconnect, the IR phase is too early in the process for LSEs to determine which projects should advance. Clearway is especially concerned that LSEs are not ready to take on this role for Cluster 15. We know that many LSEs’ procurement teams are already stretched thin keeping up with midterm reliability, Resource Adequacy, and other short-term needs. They do not have the capacity to create an entirely new rubric to evaluate projects at the interconnection request phase, without information on interconnection timeline or cost.
  • If LSE interest stays in the scoring criteria, the CAISO should establish a set of rules for the “clear and transparent RFI processes” recommended in the Final Proposal, or work with the CPUC and LRAs to establish these rules. Among these guidelines, there should be no financial exchange or arrangements that involve exchange of value between the LSE and IC in connection with the awarding of points. Points should be awarded based on factors that are meaningfully related to the needs of the grid and state and local policy goals – for example, project location (e.g., an LSE may wish to advance projects in its service territory) and developer track record.
  • Clearway opposes the proposal to prohibit awarding of non-LSE interest points to an affiliate of the offtaker. These agreements should be allowed if negotiated at arm’s length. Thanks to upstream acquisitions, companies may be partly or fully owned by the same parent company but not coordinate their business activity at all. This prohibition is also unfair in light of LSEs’ ability to award points to their own self-build projects.
  • Clearway is also concerned that the generous allowance for LSE self-built projects (three projects of any size or 25% of the LSE’s points, whichever is larger) is too large and could crowd out non-LSE development. The CAISO should revert to the previous limit of one project per LSE per cycle.
  • Finally, the CAISO should allow LSEs to provide a list of backup awards for interest points, in the event that multiple LSEs or commercial offtakers award points to the same project and the total allocation would exceed the maximum number of points. With only 10 days for LSEs to make awards and antitrust limitations on coordination among buyers, it is possible that there will be overlap in awarded projects. A backup list would ensure that LSEs can always make use of their available points.
• Project viability:
  • Clearway does not support the proposed point structure for engineering design. At such an early stage in project development, these designs will not be the final ones used to build projects – their primary purpose will be to qualify for points in the scoring criteria. All these projects’ designs will change at a later stage, as evidenced in the number of MMAs that are being submitted every year by late-stage projects. The logical result is that developers will collectively spend millions of dollars on project designs (costs that will ultimately be reflected in PPA prices), all projects will achieve the maximum score, and there will be no differentiation between projects – the net result in this case would simply be a transfer of resources from ratepayers to engineering firms.
  • In place of the engineering design points, Clearway suggests returning to some of the other project viability metrics that were considered earlier in this initiative, including LSA’s suggestion to use the CPUC’s RPS Project Viability Calculator.
• System need:
  • Clearway appreciates the CAISO’s intent to place restrictions on eligibility for points for Local RA or long lead-time resources. However, as described, it does not seem that there will be any stakeholder input or opportunity to review this policy before it is implemented – the Final Proposal only states that CAISO will confer with CPUC and LRAs and communicate the decision to stakeholders. These eligibility criteria should be explained in the tariff along with the rest of the scoring criteria, not deferred to an informal process. This is particularly important to clarify for long lead-time resources – while there is a role for these resources, it is important that they not crowd out resources that can come online more quickly to meet system needs.
  • An unaddressed question in this section is how to ensure that the overall set of resources advancing to the study process includes a reasonable mix of technologies that meets the needs of the grid. For example, what will happen if the projects scoring high enough to advance are all standalone storage? With another round of input, the CAISO could consider adding another set of system need points to reflect alignment with the CPUC’s resource portfolio.  

Section 2.5: Cluster 15 Intake Process and Schedule

• We suggest adding a period for the CAISO to review information submitted by ICs before opening the window for LSEs to indicate interest, to ensure that LSEs have access to accurate and updated information on projects.

Section 2.5.2: Auctions

• Clearway is listed in this section as having supported the auction mechanism, but this is not accurate. Given feedback early on that the CAISO was committed to including an auction mechanism as a tiebreaker, we did support the change from requiring bids from all projects at the IR stage to requiring bids only if an auction is triggered.

Section 3.4: Viability Criteria and Time in Queue

• Clearway requests that CAISO clarify the requirement for Energy Only projects to demonstrate CVC, particularly in the case of a hybrid or co-located project that includes an EO component. Our interpretation of how the CVC requirement should apply is:
  • If a project demonstrates CVC for the RA portion that utilizes the Interconnection Service Capacity (ISC), then any EO portion contained within that ISC should not be required to demonstrate any CVC if it needs to phase the EO portion and have schedule flexibility without moving the COD of the portion with an RA contract.
  • If the earliest achievable COD of an EO project is beyond the allowable time in the queue, then EO projects should not be required to demonstrate CVC until the upgrades to allow the project to interconnect are operational.

Section 3.8: Commence Network Upgrades when the first Notice to Proceed is provided to the PTO

• Clearway strongly supports this proposal to strengthen timelines in the LGIA. We appreciate the statement in the Final Proposal that “the PTOs need to move forward once the NTP and third security posting is received and meet the initial synchronization date in the GIA to allow interconnection customers to satisfy their PPA requirements” and request that the CAISO include language to this effect in the tariff.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

Clearway supports extending the timeline for Track 3 to October, given the complexity of the issues involved.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

EDF Renewables (EDFR) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements (IPE) Track 2 Final Proposal and wants to foremost acknowledge that CAISO staff and stakeholders have put an enormous amount of effort and thought work into 2023 IPE Track 2 proposals, and that despite limited concerns below, EDFR believes the IPE Track 2 proposals will significantly change the dynamics of the CAISO’s interconnection queue processes. EDFR respectfully requests that CAISO table a limited few of the Track 2 proposals and take the proposal back up for consideration after FERC Order 2023 reforms and less contentious IPE Track 2 proposals have had an opportunity to demonstrate effectiveness.

Scoring Criteria for Queue Entry     

EDFR is concerned that the current proposal to include LSE (and non-LSE) interest in the scoring criteria for queue entry is not mature enough for implementation, and that well-intentioned but flawed implementation could result in undesirable interconnection queue study outcomes.

The original intent of the scoring criteria was to create a number of differentiating factors that could prioritize those interconnection requests with the highest probability of reaching commercial operation. In the initial IPE workshops stakeholders presented various differentiating factors and CAISO and stakeholders have reviewed these factors for appropriateness as viability criteria. After close consideration many potential criteria were deemed ineffective for that task, or difficult to objectively evaluate.

Despite enormous effort there is still no consensus that the current proposal to allow LSEs to distribute points to specific projects can and will be implemented by CAISO and LSEs in a clear, transparent, and non-discriminatory manner. The final proposal clearly outlines how the CAISO will distribute available points to individual load serving entities but is silent on the most important aspect of the scoring criteria, how the load serving entities will award points to projects. In the most recent IPE meeting the discussion of the need to change “LSE tariffs [sic]” and lack of clarity around what and how such changes would be made is a strong indicator that the proposal has not been considered though to all needed implementation points and is not ready for consideration by the CAISO board or the FERC. Furthermore, LSEs will not be able to develop a publicly vetted allocation process prior to the Cluster 15 interconnection request deadline of December 1, 2024.

EDFR recommends holding off on LSE Interest no earlier than Cluster 16, pending additional thought work and LSE-side implementation.

Zonal Approach vs Constraint based Approach

EDFR appreciates the consolidated report published by CAISO but is concerned with the continued confusion around the implementation of the zonal approach and interconnection customers’ ability to infer zone status (i.e., TPD option or merchant) using publicly available data.

After considerable review EDFR also has reservations regarding the concept of creating the Zones at all. As proposed the zones are defined and redefined constantly based on grid conditions and interconnection request and can cross many study areas and constraints (but not necessarily include a whole area or constraint.)  Close review of the proposal shows that there is a quite likely use case a whole zone can be open even if, based on constraints, there is only a few or even 1 point-of-interconnection in that zone with greater than 50 MW of capacity. During discussion of this (quite likely) use case CAISO staff indicated that POIs in a zone without capacity would not be accepting interconnection requests for TPD –or—merchant pathways. This is overly restrictive and will harm by limiting development optionality, potentially jeopardizing the likelihood that the queue will have 7 GW a year studied, constructed, and ready to come online. 

EDFR recommends shifting to an approach that allows interconnection requests anywhere on the grid except where the POI is within a constraint with less than 50 MW.

This constraint based approach isolates tight grid locations (no matter how many there are) without the drawbacks and confusion created by the proposed zonal approach (where a developer could submit an interconnection request in an acceptable zone only to find out their POI has no capacity.)

Data Accessibility

EDFR is grateful for the CAISO publishing a version of the interconnection report for stakeholders to review as a part of this IPE effort – getting down to this level of granularity is critical to the proposal’s success. EDFR respectfully suggests that the report is not yet mature enough to service as a tool for the actual process and does not meet CAISO’s accessibility standards. This document is meant to serve as the foundation of the new interconnection approach, and all improvements will contribute to better interconnection request outcomes. EDFR offers the following suggestions about the document:

• • Clear objectives: Clearly defining the purpose and goals of the report to guide readers through its content.
  • Contextual clarity: Providing relevant background information to help readers fully grasp the subject matter. Including reference to other CAISO documentation, tariff, and BPM language, etc. to show how information integrates into the larger generator interconnection and transmission planning processes.
  • Thoughtful formatting: the document would benefit from a title page, table of contents, subheadings, and narrative text to guide interpretation
  • Information completeness: Missing details or insufficient data can leave readers with unanswered questions. Ensuring all necessary information is provided in detail, leaving no room for ambiguity. Especially in this context inclusion of defined terms would provide important context and eliminate ambiguity
  • Graphic quality and text accessibility: graphics in the document are difficult to see even when zooming in due to low resolution, text in the document is not searchable (either by having been PDF’d from original images with text or having been run through a high-quality ocular text recognition application like Adobe Acrobat.)

EDFR recommends CAISO continue to iterate this document with stakeholders and work with CAISO training to create stakeholder training resources. 

Queue Management Clarifications

EDFR understand CAISO’s desire to improve queue management procedures and requests clarity on a few granular items in the process. EDFR requests CAISO clarify what happens in a scenario where the PPA is terminated later in project development (after GIA is executed, after construction for network upgrades or the generator itself is underway.) With these IPE commercial viability proposals and stricter enforcement of CAISO’s third posting requirements. Interconnection customers need some kind of certainty that a project that has previously demonstrated commercial viability and is very far into the development process and very vulnerable financially that in the event a PPA is cancelled for whatever reason they have the ability to save what they can of the investment by either having time to obtain a new contract or finishing the project build merchant.

EDFR requests that CAISO amend the commercial viability proposal to allow projects to recover from a lost PPA by either giving a reasonable time window to obtain a new one or going merchant for the remainder of project construction.

This request is not made as a bid to avoid commercial viability controls, but rather protect interconnection customers in these very limited but very serious circumstances. EDFR is aware of at least one solar project that is online without a PPA as a result of circumstances similar to the above.

EDFR requests CAISO consider identifying some set of criteria or controls that would make staff comfortable with giving interconnection customers optionality in these limited circumstances to avoid stranded generator assets.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

EDFR is supportive of CAISO’s move to extend the IPE timeline and move forward with track 3.

In regards to track 3 EDFR requests that development of the issue paper for track 3 include specific process detail and “fail state” use cases for CAISO’s proposed transmission reservation approach. This proposal is a major divergence from existing procedure and warrants thorough consideration. Some examples:

• Does the CAISO propose to reserve transmission for a particular resource type, or a specific queue position?
• What will be the requirements and timelines for retaining that reservation?
• Will there be amended queue management requirements for GIA execution and commercial viability requirements for long-lead resources?
• In the event a resource does not retain its long lead deliverability; how, when, and to whom will that deliverability be released?
• How will transmission construction progress change these questions? For example if construction has not started, deliverability could be released to “the pot” and upgrade changed as needed in restudy; vs when construction is underway and a resource loses deliverability, the capacity will still be in that specific area/ POI. Will CAISO allow interconnection customers to submit interconnection requests in that area for alternate resource types? 

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Engie NA (“ENGIE”) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 2 Final Proposal.  ENGIE’s comments are focused on Section 2.5.1 – Scoring Criteria for Prioritization of the Study Process.

ENGIE NA continues to oppose the scoring criteria proposed by CAISO. In prior comments ENGIE recommended the CAISO allocate more weight to project specific attributes to allow developers some opportunity to differentiate project viability outside of LSE commercial interest. Unfortunately, the proposal moved the opposite direction, giving LSE’s more discretion on what projects will enter the study process. If a project is not long lead time or an expansion of an existing project (which is most projects that will enter the queue) there are only two categories that are actionable outside of LSE interest that a developer can control. Those are 1) achieving 50% engineering design plan and 2) system need. This leaves a minimal amount of points a project can attain absent LSE interest and it is likely only projects with LSE interest will proceed to the study process.  

The CAISO is clear in the draft final proposal how it will distribute available points to individual load serving entities but is silent on what criteria the load serving entities will use to decide what projects they will allocate points to. This leaves point allocation to the discretion of each LSE which could be highly subjective. The final proposal states that it is the intent that LSE’s will conduct RFO’s to solicit viable projects prior to the start of a cluster process. However, no LSE’s have stated their intent to pursue such a process and it is unlikely that they would accomplish this sufficiently in advance of the December 1, 2024 Cluster 15 interconnection request deadline. At the April 4^th stakeholder meeting the CAISO also noted that there are likely smaller LSEs that are not participating in the stakeholder process that may be unaware of the need to designate LSE commercial interest.

ENGIE appreciates CAISO effort to strike a balance with the scoring criteria and the time stakeholders put into this category during working group meetings. Unfortunately, the scoring criteria in the final proposal has still not struck the appropriate balance. Absent more actionable project specific attributes as part of the scoring process and defined criteria for LSE’s to award points for LSE interest, the scoring criteria lacks too many details to ensure the proposal is not unduly discriminatory. The CAISO and stakeholders should consider whether this is the right approach to pursue at all as a  queue gating mechanism and whether  it is necessary at this time.

ENGIE recognizes that moving how scores are weighted around is not going to solve the problem and will no longer advocate for such. ENGIE also recognizes if just the commercial interest category is dropped the remaining scoring criteria wouldn’t be robust enough to meet the objective of identifying projects with the highest probability of reaching commercial operation. The scoring criteria as it stands requires more development and should be eliminated from the proposal and not applied to Cluster 15 projects. ENGIE recommends the CAISO not delay the IEP Phase 2 proposal any further but instead move forward with the 150% study limit by zone (actually by constraint) and evaluate post cluster 15 processing whether additional queue gating mechanisms are needed on the front end. If the CAISO chooses to pursue scoring criteria for Cluster 16 and forward the design must:

• Be non-discriminatory
• Provide equal opportunity to achieve points based on specific project attributes
• Provide transparency on project scores to allow developers to learn and refine future interconnection applications
• If the commercial interest category is to remain, Include criteria for how load serving entities will award points to projects in a clear, transparent manner.

The zonal study limits proposed by the CAISO paired with new FERC Order 2023 requirements, specifically the requirement to meet 90% site control will significantly impact queue volumes as it is. An additional queue gating mechanism on the front end may not be needed.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

ENGIE supports the CAISO extending the discussion on TPD allocation to a Track 3.  

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Golden State Clean Energy, LLC (“GSCE”) provides the following response to CAISO’s final proposal:

• Data accessibility / study timeline
  • The proposed interconnection process timeline now leaves very little time for prospective interconnection customers that are finalizing interconnection requests prior to the request window to react to the most recent TPD allocation that will inform the available and planned transmission for the incoming cluster. We appreciate the tight study timeline in general and CAISO’s willingness to make the latest information available prior to the interconnection request window, but the TPD allocation process could significantly reduce or entirely remove available and planned transmission capacity at a point of interconnection, and it could even change a zone from a TPD Option zone to a Merchant Deliverability Option zone.
    • The proposed timeline could require an interconnection customer to significantly change their project and only provide about a month to do so, which is problematic considering that prior to submitting an interconnection request there is a need to secure sufficient land for a project, post significant deposits, and overall increase the quality of the interconnection request at the earliest stages of project development and demonstrate readiness through the scoring process.
    • An interconnection customer could easily have invested in the land it needs to submit an interconnection request only to find out at the last minute there is no longer capacity to allow that project to submit an interconnection request.
    • The significant initial deposit amount that is additionally required for a project to proceed under the Merchant Deliverability Option and the unique business approach and risk associated with this option further highlights the difficult nature of reacting to the latest TPD allocation results about a month before the interconnection request window.
  • The proposed IPE phase 2 reforms simply remove optionality for developers, and last-minute changes in available information will dictate what a developer can and cannot seek to develop. Providing developers too little time to make informed decisions will hurt the goal of creating more ready, viable projects.
  • Even if not through the TPD allocation heat map, CAISO should maximize the time available to prospective interconnection customers to consider the latest TPD allocation results, and thus the amount of available and planned transmission capacity, before interconnection requests and readiness scoring are due.

• Cluster 15 survey
  • GSCE appreciates CAISO providing high-level survey results to help inform the effectiveness and impact of the proposed readiness scoring process. GSCE believes some additional information about the survey results could further this end.
  • GSCE requests the following additional information on the Cluster 15 survey to better understand the results:
    • How much nameplate capacity and interconnection service capacity is represented by the 200 interconnection requests that advanced to scoring and the 112 interconnection requests that advanced to the study process?
    • Of the nameplate capacity in the 200 interconnection requests that advanced to scoring and the 112 interconnection requests that advanced to the study process, what amount is storage and what amount is generation?
    • What is the zonal allocation of the capacity in the 200 interconnection requests that advanced to scoring and the 112 interconnection requests that advanced to the study process?

• Readiness scoring criteria
  • Overall, GSCE is concerned by the lack of scoring criteria available. More categories are needed to allow projects to distinguish themselves in meaningful ways aside from LSE interest.
    • CAISO already considers permitting and site control during the interconnection process, albeit in different processes than the proposed readiness scoring criteria would. But GSCE believes the challenges associated with these two criteria did not sufficiently consider the lack of scoring criteria that the end proposal would have.
  • Gen-tie site control
    • GSCE opposes removal of the gen-tie site control scoring criterion and urges CAISO re-include this criterion.
    • Some of the opposition to this criterion appears to relate to the final segments of a gen-tie as it approaches its point of interconnection and the uncertainty related to bay positions that will not be known during the interconnection request window. GSCE acknowledges this uncertainty, which is in part why we have supported a scoring process that recognizes the degree to which a gen-tie route is secured.
      • For projects that are many miles from their point of interconnection, the bay position uncertainty has little to no impact on the need to secure land rights between the project and point of interconnection.
      • Projects that require a multi-mile gen-tie line and have not secured any land for the gen-tie route are not being distinguished from those who have begun securing their gen-tie route or even those that are much closer to their point of interconnection and face less challenges securing a gen-tie route.  
    • GSCE believes it is possible to recognize a project that has taken a significant step in securing its gen-tie route, even if there is some uncertainty associated with the entire route, such as awarding points to projects that are either within a certain radius of their POI (accounting for those with shorter gen-ties and not assessing the percentage of gen-tie route secured because of their close proximity and bay position uncertainty) or that have secured a gen-tie route that covers at least 50% of the distance between the project and the radius of uncertainty.
    • To the extent that an interconnection customer may be unable to demonstrate site control for a gen-tie on public lands this early in the development process, it is important to note that this criterion is merely a check for additional development steps taken to make a project more ready, not a necessary requirement. Further, the inability to secure land at an early stage due to regulatory limitations speaks to uncertainty lingering over a project and thus the potential for late-stage project failure. It is not undue to distinguish among different circumstances when there is reason to do so. Securing a gen-tie route is required for a project to proceed, and those that cannot secure this route early have more uncertainty associated with the project that is fair to judge under the new readiness paradigm.
    • Ultimately, CAISO is requiring interconnection customers to prove out their scoring through easily verifiable supporting materials, and if an interconnection customer cannot clearly make the case that they have checked this box then they would not receive points.
    • CAISO should re-institute this proposed criteria and then use the BPM PRR process to further flesh out the details for scoring so that it does not hold up the proposal.  
  • Engineering Design Plan
    • GSCE supports this scoring criterion but believes that a 50% complete plan is much too detailed at this early stage of planning. For many generator projects, a 50% complete plan is (or is close to) the same level of completeness that is used for a building permit application. The ability to design a 50% complete plan at this stage may be more of an investment in the scoring process rather than actual project readiness, as a project will begin construction several years after submitting an interconnection request and its design and plans will likely change after the initial IR due to factors such as technological improvements, manufacturer availability, etc.
    • GSCE recommends the maximum points be awarded to 30% complete plans while retaining the overall weight of the project viability category.  

• Merchant Deliverability Option
  • GSCE continues to oppose the proposed limits on which projects can select the Merchant Deliverability Option and supports the option being available in zones with available or planned transmission capacity.
  • GSCE is not aware of any prevalent use of this option currently under the Option B paradigm, and we do not think the proposed revisions to the option will materially increase interest in the Merchant Deliverability Option. To prevent any significant increase in the Merchant Deliverability Option in zones with available or planned transmission capacity, CAISO could add minimum requirements for a Merchant Deliverability interconnection request in these zones.
  • 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 generation and transmission 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.

• Final comment
  • GSCE remains concerned that the desire to better manage interconnection studies through the 150% cap will fundamentally shift market dynamics and create significant policy impacts. The IPE reforms represent a risk to California meeting its policy and reliability requirements, especially in the late 2020s and early 2030s. If new transmission is not timely approved to unlock resources that can interconnect in this nearer-term time horizon, the state may be left with a resource gap and come up short of its policy goals.
  • 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 and other stakeholder 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.
  • GSCE urges CAISO to consider new processes that allows large amounts of new capacity to interconnect efficiently.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

No comment.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

No comment.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

2.5.1. Scoring Criteria for Prioritization to the Study Process [Updated]

GreenGenStorage, LLC (GreenGen) is a California-based pumped storage hydro (PSH) development company that is permitting a pumped storage project in parts of Amador and Calaveras Counties, California. The Mokelumne Water Battery Project is an eight-hour, 400 megawatt pumped storage project that will store 3,200 megawatt-hours per day of clean, reliable, and dispatchable energy.

GreenGen agrees with the CAISO’s efforts to ensure interconnection requests are based on real and ready projects.  It also supports establishing scoring criteria for long lead time resources. However, GreenGen highlights that the proposed IPE changes, along with existing CPUC resource planning processes, could effectively eliminate development of “real and ready” pumped storage hydro projects.  GreenGen encourages the CAISO to continue to coordinate closely with the CPUC to more accurately identify viable long-lead time resources. The current planning processes have not included unique, site specific, affordable and reliable projects and do not provide clear market or policy signals for long duration storage in California more broadly.

CAISO proposes that "long lead-time resources: Meets the requirements of the CPUC resource portfolios where the TPP has approved transmission projects to provide necessary transmission requirements. Only long lead-time resources that are required to meet the CPUC resource portfolio requirements are eligible, including resource types that are considered for central procurement under Assembly Bill 1373 (2023), or as specifically identified by the CPUC in the portfolios provided to the ISO for use in the transmission planning process.” (2023 IPE Final Proposal at 62). CAISO also proposes to “work with the CPUC and LRAs to determine a list of eligibility requirements for this category of resources prior to the interconnection window opening.” (Id. at 65.)

GreenGen believes that the CAISO should reconsider its scoring for long lead-time resources to ensure there is an opportunity to study such resources in the interconnection process. CAISO should also continue working with the CPUC to ensure that cost effective resources are identified.  GreenGen notes that the current CPUC and proposed IPE processes create tautological obstacles for pumped storage hydro as long lead-time resources. 

Specifically, GreenGen sees two issues with solely relying on the existing CPUC resource portfolios. First, RESOLVE uses criteria that exclude viable technologies as candidate resources in part because it models 8-hour storage duration for only Li-Ion and limits pumped storage to a 12-hour duration. We continue to recommend that pumped storage be similarly modeled at 8 hours to better align with the CPUC’s IRP procurement decisions that define long duration storage as eight hours or more from a single source, be more consistent with available data resources, and the pumped storage industry that is in the process of developing cost-effective projects with 8-plus hours of storage in mind. This 8-hour recommendation also applies to all other long duration storage capable of providing 8-hour duration. Failing to include this distinction seems to exclude non-Li-ion long duration storage and with it, an opportunity for a diverse portfolio. From an affordability and risk perspective, if viable, long lead time projects are not being considered at the appropriate time in the resource and transmission planning processes, these projects cannot get online on time and ultimately cannot take advantage of the Inflation Reduction Act’s investment tax credits or pursue commercialization opportunities, thus decreasing project viability and increasing costs for customers.

Second, there are ongoing challenges with the bus bar mapping criteria for pumped storage in development that will exclude future projects from the CAISO’s interconnection process. The IRP criteria for identifying the geographic location of potential resources needs updating to provide the CPUC and CAISO enough lead time to better gauge project viability for resource planning. GreenGen understands that for pumped storage to be considered as a potential candidate resource in the IRP resource portfolio, the project must have a FERC preliminary license and be in the CAISO queue. We believe that standard has not been consistently applied and is no longer relevant given the changes to the interconnection process. We continue to advocate that the resource portfolio development and the bus bar mapping criteria for pumped storage projects in development include important factors such as whether projects use existing facilities, are located near existing transmission facilities, and/or potential acres of above ground impacts. Reliance on the CAISO queue is not a dependable metric given the changes proposed in the draft final proposal. The current CPUC requirements effectively eliminate development of pumped storage projects regardless of their cost effectiveness and reliability contributions.

More relevant criteria to be considered when identifying the geographic allocation of potential pumped storage candidate projects: license status (e.g., preliminary license), whether the project uses existing infrastructure, project proximity to existing transmission, above ground land impacts. Without these important updates, pumped storage projects will not be included in the IRP resource planning portfolio, resulting in years before CAISO has visibility into these viable long lead time resources, (because no pumped storage projects would be considered a candidate resource until it was both licensed and in the queue). Such a gap in the process currently and will continue to result in the failure to analyze and procure diverse, reliable, cost-effective and environmentally sound resources to meet California’s climate goals and ensure grid reliability.

From a developer perspective, additional implications include challenges in securing offtake agreements, lower priority in the interconnection queue, construction delays, and ultimately, delayed online dates. The financial commitment required to obtain a pumped storage license is substantial and such investments are not speculative. Licensing a pumped storage project takes years and millions of dollars. If there is a such a large gap between the lengthy and expensive permitting process and the project being included in a resource portfolio, studied in the planning process, and ultimately interconnection queue, investors are unlikely to continue funding such large and important infrastructure projects.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

The Independent Energy Producers Association (IEP) respectfully submits the following comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal.

IEP appreciates the time and attention given to crafting the scoring criteria within the IPE but recommends further work needs to be done to ensure the criteria is balanced. IEP finds the scoring criterion is too weighted towards load serving entities (LSEs) in the “commercial interest” section. For example, LSEs are given the ability to assign points to “desired interconnection requests” and “the ISO will add the points to each projects’ score.” This gives LSEs the power to determine which projects are to be studied without sufficient guidelines. Additionally, the final proposal allows for LSEs to award capacity to up to three self-built projects or 25% of capacity allocation per cycle. Together, these two aspects of the final proposal give too much weight to LSEs.  

IEP recommends reconsideration of the weight given—100 points—to this criterion. As stated in our comments on the Draft Final IPE Track 2 Proposal, the points allocated to LSEs’ commercial interest should be decreased to at most 75 points and the non-LSE interest should be increased to at minimum, 50 points. Further, IEP recommends reducing the commercial interest category from 30% to 10%, as suggested in our previous comments, since “project viability” and “system need” are more reflective of project readiness than commercial interest, which should be awarded an additional 15% and 5 %, respectively.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

IEP supports extending the timeline for Track 3 to October 2024 and encourages stakeholder engagement in developing the scope.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Section 2.1: The Zonal Approach

Intersect Power (IP) 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 and TPD Allocations), (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 / Merchant Deliverability 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 interconnection requests 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 along with establishing a minimum capacity level (e.g., 1GW) to be studied without triggering the Merchant Deliverability Option for a zone that is fully depleted (at least for Cluster 15), due to several factors: 

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.

Section 2.3.3: Treatment of Full Capacity Deliverability Status and Energy Only Resources

Application of scoring criteria to Energy Only resources, and the Energy Only portions of co-located technologies seeking different deliverability statuses, is inherently flawed and should be disregarded. During the Final Proposal Stakeholder Meeting, Intersect Power commented on the fact that LSE capacity allocation is not applicable to Energy Only projects because the capacity allocation process is intended to allocate the available deliverable capacity. Hence, an Energy Only resource should require 0MW of capacity allocation to score the full 100 points. In prior comments from CAISO, including language included within proposals for this stakeholder process, CAISO has taken the position that Energy Only resources are likely not commercially viable, and thus are not a major concern for overwhelming the queue. That would seem to indicate many of these provisions aimed at making it more difficult for Energy Only resource inclusion in the Cluster study process are superfluous. Intersect Power recommends CAISO drop the scoring criteria requirement as well as the Energy Only resource reimbursement vs non-reimbursement concept entirely and simply allow Energy Only resources to be included in the study process without further constraints.

Section 2.4: Interconnection Request Intake Process

See comments on Section 2.3.3 above related to the flawed scoring concept for Energy Only projects and the suggested alternative.

Section 2.4.1: Fulfillment of 150% of Available and Planned Transmission Capacity

See comments on Section 2.1 above related to the issues that Intersect Power has consistently highlighted with the proposed zonal approach and the specific recommendations for loosening the rigidity, at least for Cluster 15, if the zonal approach remains.

Section 2.5: Cluster 15 Intake Process and Schedule

Considering how much the process has evolved after QC15 interconnection requests were initially submitted, Intersect Power urges the CAISO to provide a bit of leeway to Interconnection Customers as they reassess and reallocate resources among their various interconnection applications. Given the nature of the somewhat arbitrary zones (e.g., infrastructure may be electrically nearly identical but characterized in different zones based on PTO), and their applicable constraints, Interconnection Customers may need to make modifications to POIs that are located close to zonal boundaries. Intersect Power urges CAISO to retain and utilize some discretion, permitting Interconnection Customers to re-balance POIs as necessary in those unique circumstances where zonal boundaries may need to be crossed.

Section 2.5.1: Scoring Criteria for Prioritization to the Study Process

IP is deeply concerned with 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.

CAISO’s approach to project viability assessment is to essentially shift all responsibility to LSEs via the Commercial Interest scoring category, with the hope that LSEs will be rationale actors and diligently assess project viability in their approach to making capacity awards. However, without implementing an actual requirement or framework to ensure LSEs assess viability and assess it in a consistent manner, this is unlikely to happen. LSEs will be further challenged by timing and resource limitations to conduct comprehensive RFPs to properly gather and assess projects for every queue cluster.

Intersect Power urges CAISO to codify a project viability assessment framework that is either (i) managed by the CAISO as part of the Interconnection Request intake process, or (ii) required for LSEs to comply with in order to make their capacity awards. Intersect Power put forth recommendations for project viability assessment factors in our comments to the Draft Final Proposal and have included them here as well for further consideration.

IP’s Proposed Scoring Rubric

Rational 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 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 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 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.
   

Commercial Interest Capacity Awards Must Reflect Resource Type

During the Final Proposal Stakeholder Meeting, Intersect Power raised the question of whether LSE capacity awards would be adjusted to reflect the resource deliverability requirements, e.g., based on NQC, a capacity award to a 100MW solar resource requires less deliverability than a capacity award to a 100MW BESS resource, and thus, a resource’s ability to achieve 100 points for the Commercial Interest category should properly reflect the required capacity award for the resource type to achieve FCDS. Intersect Power urges CAISO to make this clarification in their final proposal language.

Section 2.5.3: Prioritization of Projects for the Study Process

See comments on Section 2.1 above relating to the need to increase the 150% study level and institute a minimum study capacity level prior to triggering the Merchant Deliverability Option.

Section 2.5.4: 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 that is being 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, 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.

Section 2.5.5: Criteria for Energy Only Projects in Non-reimbursement Zones

See comments on Section 2.3.3 above related to the flawed scoring concept for Energy Only projects and the suggested alternative.

Section 3.6: Earlier Financial Security Postings for Projects with Shared Upgrades

During the Final Proposal Stakeholder Meeting, Intersect Power requested that the CAISO confirm their intent that this mechanism would also apply to projects that issue NTP and make the required security posting under an Engineering and Procurement Agreement (E&P). For instance, a project with an executed E&P may wish to accelerate work for shared upgrades and the E&P grants the ability to issue NTP to the PTO for said upgrades. This action should then result in all parties with shared cost responsibility to contribute their share just as CAISO is contemplating herein. However, the proposal lacks clarity and only references the triggering project as issuing NTP under a GIA. CAISO confirmed this has been their intent all along, so a simple language update to include reference to an E&P alongside the GIA would resolve this issue.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

Intersect Power agrees that additional time is required to understand and debate the merits of the CAISO’s TPD proposals.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

LSA understands the CAISO’s objectives of limiting projects accepted for study to realistic levels, focusing on the most-ready projects, and we have long supported measures to remove non-viable projects from the queue.  Our comments here support those overall objectives, and the significant progress that has been made.

However, we still have concerns with many details of this complex proposal.  LSA’s comments do not cover all its concerns with the Final Proposal (Proposal), or (except where indicated) repeat its past comment submittals.  Instead, LSA’s comments here focus on significant issues and/or new elements of the Proposal that should be addressed before it is made final.

OVERALL PROCESS AND SCHEDULE GOING FORWARD

LSA believes that consideration of the Proposal should be delayed to at least the July Board meeting (and perhaps October), and filed together with the Track 3 proposals.  CAISO staff has worked hard, but still the Final Proposal reads more like a Revised Draft Final Proposal, i.e.:

• The Zonal concept still contains significant unclarities and inequities (and potentially problematic results following the current TPD Allocation cycle);

• Many proposed elements cannot be fairly applied to Cluster 15, even if they might be appropriate for later clusters;

• The proposal contains significant new elements (e.g., Energy Only proposals) that have not been sufficiently considered or vetted; and

• The interactions between the Intake and Queue Management proposals here and the TPD Allocation process cannot be determined with the deferral of rules for the latter to Track 3, and the CAISO should consider putting the final proposals for both tracks into a single package.

SUMMARY OF COMMENTS

• Zonal framework:  Additional clarifications, and consideration of inequities and potential adverse TPD Allocation impacts, are needed.

• Energy Only proposals:  Additional clarifications and details, and consideration of inequities, are needed.

•  Zonal-level Scoping Meetings:  Should be supplemented by a means for Interconnection Customers (ICs) to pose questions about their projects on a confidential basis.

• Scoring Rubric

• Commercial Interest:  Should be deferred to Cluster 16.  If retained:

• The points weighting should be decreased significantly, since they will otherwise determine which projects are studied, and LSEs themselves have not had sufficient time to implement fair and open project selection methods;

• The Self-Build and Full Allocation options should be modified, to prevent limitations on open access and competition and “crowding out” of more-viable projects; and

• The non-LSE interest element should be clarified and modified.

• Project Viability

• The Engineering Design Completeness element should better define the “percent complete” status markers.

• The elements related to facility expansion should: (1) include projects that have not yet started construction but have progressed significantly along that path; (2) apply to projects that have interconnected in a variety of study paths (e.g., WDAT); and (3) clarify that the parties owning the original project and the expansion need not be the same.

• Additional elements should be considered, such as developer experience and equipment procurement.

• System Need – Local Capacity Area (LCA):  The CAISO should clarify whether potential charging limitations will impact awards of these points, and if so, how that will be done.

• MD projects – use of Commercial Readiness Deposit forfeits:  Because these deposits are provided specifically by Merchant Development Zone projects to fund ADNUs, they should be divided among any remaining projects sharing that ADNU instead of being diluted through the normal forfeited-funds process.

COMMENT DETAILS

ZONAL FRAMEWORK OVERALL

LSA appreciates the many clarifications and explanations provided at the April 4^th stakeholder meeting about Transmission Plan Deliverability (TPD) Zones vs. Merchant Deliverability (MD) Zones.  However, there are still some definitional unclarities, as well as some apparent inequities, in the zonal framework as described.

Unclarities

The terms “zones” and “constraints” need to be better defined.  It appears that “zones” are defined by larger constraints and the term “constraints” means inter-zonal constraints, but that is not clear. 

In particular, the TPD-MD zonal distinction of “at least 50MW of available capacity” is not at all clear.  For example:

• Is the 50MW limit the total of capacity behind all intra-zonal constraints within a zone?  The CAISO said at the last stakeholder meeting that the available capacity behind the intrazonal constraints was not necessarily additive, but then how is the zonal capacity determined?

• How is available capacity behind zonal and intra-zonal constraints allocated to specific POIs?

In addition, LSA is very concerned about the impact of the current TPD Allocation cycle results, especially with respect to from the very large Cluster 14 group.  The Proposal states that the CAISO did a kind of “dry run” on the available Cluster 15 data and determined that about 200 (of 500+) projects were located in TPD Zones, and 112 would be accepted for study. 

However, it seems a distinct possibility that many or most zones now shown as having available capacity currently will not have it after the TPD Allocation is complete, e.g., all or nearly all zones will be defined as MD Zones, and many projects in remaining TPD Zones but at POIs without available capacity will be disqualified from study (see more below). 

Is there a minimum number of projects, or amount of capacity, below which the CAISO might reconsider this framework?  For example, if only, say, 40 or 50 projects can be accommodated in remaining TPD Zones, will the CAISO consider that to be an acceptable result?  The CAISO should consider defining a minimum amount of capacity or projects to be accepted for study under TPD Zone rules to avoid an undesirable outcome.

Inequities

There are inequities embedded in the zonal grouping of POIs and constraints into TPD Zones vs. MD Zones.  Further, some elements that may be fair for later clusters – which will have the benefit of the consolidated and enhanced information packages the CAISO is starting to develop, perhaps six months before they submit their Interconnection Requests – may not be fair to apply to Cluster 15 projects, which did not receive this useful information so far in advance (and still do not have updated information due to the need for updates after the current TPD Allocation cycle).

The zonal framework generally would impose a major inequity on TPD Zone projects seeking interconnection and deliverability at POIs behind sub-zonal constraints.  Factually, these projects would be in the same situation as projects seeking interconnection and deliverability in MD Zones (i.e., no deliverability currently available at their locations), but they would receive worse treatment – they won’t be studied, no matter how high their viability scores, and (unlike MD Zone projects seeking deliverability), they would have no option to fund even reasonable-cost ADNUs (perhaps more reasonable-cost ADNUs than in MD Zones). 

The inequities for projects in this situation are compounded for Cluster 15 projects.  Developers submitting projects in future clusters will have the benefit of the aforementioned advance information and can avoid POIs in TPD Zones without available deliverability, but C15 projects did not have that advance information.

LSA understands that the CAISO strongly desires to reduce the number of Cluster 15 projects studied to a workable number, and excluding projects at POIs in TPD Zones without deliverability would help achieve that goal.  However, it would fairer and more equitable to allow these C15 projects a one-time pass and use an MD option in this cycle.

ENERGY-ONLY PROJECT PROVISIONS - ZONES WITHOUT CPUC IRP BASE-PORTFOLIO CAPACITY NEED  

The proposals related to EO projects are brand new in the Proposal, and thus there has only been limited opportunity for meaningful consideration.  LSA has several concerns about these proposals.

First, the EO zones will be defined by the presence or absence of deliverability, when EO need has nothing to do with deliverability.  There is no particular reason why those zonal definitions should apply to EO projects.

Second, this proposal is not fully fleshed out.  For example, would EO projects at busses in zones where the CPUC IRP base portfolio indicates an EO resource need (call them “EO Reimbursement Zones”) also apply at the POI level, i.e., would projects at POIs within EO Reimbursement Zones where there is no CPUC EO need shown still have an RNU Reimbursement Option? 

Third, this proposal has inequities also.  In particular, LSA is concerned that EO projects seeking interconnection in MD Zones showing no CPUC EO need would receive no RNU reimbursement, while projects seeking interconnection and deliverability within such zones would receive reimbursement for both RNU and LDNU costs. 

In both situations, the projects are seeking interconnection in areas without indications of need in CPUC portfolios, and there is no basis for treating them different with respect to RNU costs.  If projects seeking deliverability in areas without a portfolio need would qualify for RNU refunds, then so should EO projects seeking interconnection only under the same circumstances. 

Again, there are particular inequities concerning Cluster 15 timing, where developers did not have the same consolidated and enhanced information before IR submittal that will be available in advance for future clusters.  There certainly was no advance notice that the CPUC IRP base portfolio would be used for this purpose.

ZONAL-LEVEL SCOPING MEETINGS

LSA is concerned that frank discussions about confidential individual project details that now occur in Scoping Meetings won’t take place in the proposed zonal-level Scoping Meetings.  LSA urges CAISO to implement a supplemental process (e.g., Q&A in writing) for project-specific details needed by developers to make POI and other critical post-meeting decisions.

SCORING RUBRIC

Commercial Interest category - LSE points:  LSA continues to share the significant reservations expressed by TerraGen and others about this element of the scoring rubric. 

Disproportionate weight

Most projects (and especially most solar and wind projects) will not qualify for points under the System Need category (Local Capacity Area location or long-lead-time technologies).  Thus, most projects can qualify for a maximum of only 65 points – 30 for Commercial Interest (off-taker need (mainly LSE)) and 35 for Project Viability. 

Thus, nearly half of the possible points for most projects will be based on Commercial Readiness, where LSE interest points carry a weight four times non-LSE interest points.  It seems almost unavoidable that this element will therefore be the deciding factor determining which projects are accepted for study, a result that large numbers of stakeholders (and the CAISO itself) have said should be avoided. 

The problem is compounded by the timing of this initial implementation.  While the CAISO encourages LSEs to modify their tariffs to provide for open solicitations, with fair and transparent project selection and points allocation processes, there is not enough time for those processes to be applied to Cluster 15 between the time when zones are defined as TPD or MD (perhaps in July) and the December LSE points allocations.

This proposal could thus potentially exclude highly viable projects, through non-transparent, unclear, and potentially uncompetitive LSE processes. 

LSE self-builds

This is a particular concern given the new proposed rules for LSE designation of self-build projects, allowing such designations for the greater of three projects or 25% of an LSE’s allocation points.  It is not hard to envision at least some LSEs designating three large self-build projects that would meet all of their needs and short-circuiting the competitive process entirely. 

Full Allocation option

LSA is also concerned about removal of the 150% of need limitation for the Full Allocation option, allowing small LSEs to designate large projects many times their actual resource need.  There is little justification for this proposal – resources supported by only 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 very small LSEs could use this election (e.g., a 10MW LSE supporting a 100-200MW resource) to crowd out otherwise higher-scoring resources.  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.  

Applicability to Cluster 15

Like other elements of the scoring rubric, this category has the potential to be even more unfair if applied to C15, where even LSEs wanting to apply competitive processes will be severely limited given the timing. 

LSA understands that CAISO wants encourage a system where LSEs conduct significant solicitation activities before IRs are submitted; the Proposal urges them to make tariff and process changes to accommodate project assessments much earlier in the process.  However, those before-submittal tariff changes and preliminary activities did not happen for Cluster 15; in fact, LSA member discussions with LSEs has indicated considerable confusion and concern about how those entities will be able to make those judgments in the few months remaining before scoring-rubric application.

Conclusion

LSA urges the CAISO to focus on strengthening the Project Viability category elements (see below), and defer consideration of Commercial Interest preference elements to future clusters, once experience is gained with Cluster 15 and LSEs have the opportunity for rational pre-IR implementation of open and transparent project-assessment processes.  It will be a long time before the Cluster 16 application window opens, and the CAISO can use information gained from the Cluster 15 process to refine and revise this approach considering the systems that LSEs have put in place by then.

If the CAISO nevertheless retains the Commercial Interest element for Cluster 15, to ensure that the most viable Cluster 15 projects are retained and studied, it should:

• Reduce LSE/non-LSE points weighting from 30 points to 10 points for Cluster 15;

• Reduce LSE ability to designate self-build projects to the lower of three projects or 25% of their points total, instead of the greater of those two measures; and

• Restore the 150% of need limit for LSEs using the Full Allocation option, or at least exclude capacity beyond 150% of that LSE’s points allocation from the zonal 150% capacity limit.

Commercial Interest category - non-LSE points 

As noted above, LSA believes that the entire Commercial Interest category (including this element) should be deferred, or at least carry a reduced weight, consistent with its above views on LSE interest.

If the Commercial Interest category is retained, then the CAISO should revisit some of the restrictions proposed for non-LSE expressions of interest, specifically:

• Limit of one project per cycle:  Non-LSEs with large and dispersed loads would be restricted to only one project,like those with small and more localized loads.  Commercial entities should be able to designate projects in a manner that reflects their needs, not only by capacity (e.g., the attestation required that the designation reflects the size of their needs) but also location, e.g., choosing a larger number of smaller projects over a single very large project.

• Purpose of non-LSE procurement:  The CAISO should not concern itself with the purpose of non-LSE procurement, which could reflect multiple legitimate corporate objectives besides “corporate sustainability policy goals.”  For example, a non-LSE could want to ensure a reliable local supply of energy or economic development in areas where it has facilities (an objective shared by LSEs like NCPA and some CCAs).  The CAISO should not 

• Market offers for deliverability:  To ensure that any deliverability awarded to projects endorsed by non-LSEs is available to the market, the CAISO can include in the required affidavits an attestation pledging to offer RA provided by projects eventually contracted to LSEs or entities selling RA to LSEs.

• The CAISO should better define which entities qualify as “non-LSEs.”  For example, is this category limited to commercial/industrial end-users with facilities in the CAISO area?  Would municipal governments or residential customers qualify?

Project Viability category - engineering design completion  

LSA is concerned that this criterion will be simply a “pay to play” requirement, i.e., will favor those willing to lay out money for the work, and not necessarily a genuine measure of project viability.

In addition, while most LSA members have significant and wide-ranging experience designing and building generation and storage projects, we are puzzled by the “engineering design plan completeness” criterion.  The CAISO should provide more detail as to what constitutes “10% completion,” “20% completion,” and so on, and add a requirement that the work must be specific *to the site, in order to add clarity to this process. 

The CAISO should also consider adding a requirement that the certifying engineer be from an independent company.

Project Viability category - “facility expansion” 

The current proposal would award points for: (1) Expansion of facility in operation/under construction where existing Gen-Tie can accommodate the new resource, 50 points; (2) expansion of operating facility, 20 points; or (3) expansion of facility under construction, 10 points.

LSA suggests one modification and two clarifications to this criterion.

The modification is an additional category (e.g., 5 points) for expansion of a facility that is in the queue and clearly moving ahead but is not yet under construction, e.g., that has: (1) made its second postings; and (2) executed GIAs and is in good standing with those agreements.  This change would recognize that sharing of facilities between projects in the queue would tend to increase the financial and other viability of both projects.  It could also help in adding points variations and avoiding tie scores.

The two clarifications are as follows.

• The “existing facility” under construction or operational (or, per LSA’s suggestion above, in the queue and moving ahead) should include those under any type of interconnection arrangement, e.g., WDAT, Rule 23, QF, behind-the-meter, etc.; because:

• There is no restriction in the Proposal on the definition of an “existing facility.” 

• Facility expansion effectively is a stand-in for “more cost-effective,” “needing fewer Interconnection Facilities,” “more likely to be permitted,” “built by an entity that knew how to make it happen,” and other factors.  That would be true regardless of the voltage level or interconnection contract form of the facility being expanded.

• The developer of the expansion facilities need not be the owner of the original facility.  The CAISO said that at the stakeholder meeting that it would treat this situation the same as the current rules for project IRs proposing to share gen-ties owned by others, i.e., IRs with a demonstration that an arrangement is under negotiation, and later provision of an agreement.

Project Viability Category – other possible measures

LSA is concerned that the proposed measures in the Project Viability category will result in a large number of scoring ties, making the Commercial Interest (primarily from LSEs) the main determinant of which projects are accepted for study.  Another way to mitigate this effect (aside from the Commercial Interest revisions suggested by LSA above) is to add more criteria to this category.  Below are some measures suggested by LSA earlier in this process.

• 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. 

The CAISO said earlier that this assessment would be too subjective and difficult to validate, but any major market procurement of significant import would at least consider the experience and skill of the supplier.  LSA suggests that the CAISO check with the CPUC and PTOs to see how that factor has been applied in the Viability Calculator process before dismissing it as unworkable. 

• Master Service Agreement, Engineering/Procurement/Construction (EPC) agreement with equipment included, or similar purchase arrangement for major equipment, such as transformers, inverters, and/or key technology-specific equipment, with extra points for a demonstration that the equipment is specific to the site or project.

System Need - Local Capacity Area (LCA) charging limitations 

The CAISO should clarify how LCA charging limitations would be applied to storage capacity in the scoring/intake process.  The CAISO said at the stakeholder meeting that those limitations were not in the Final Proposal, then there was a discussion about whether those limitations might in fact be imposed, then there was confusion over whether the CAISO might impose a 100% or 150% limit.  It was clear that this important issue had not yet been considered in depth by the CAISO, and the final framework should contain clear rules about the process to be used.

MD PROJECTS - USE OF COMMERCIAL READINESS DEPOSIT FORRFEITS  

The Proposal would require MD projects seeking deliverability tot provide a Commercial Readiness Deposit of:

• 5% of estimated ADNU costs with their Interconnection Requests, or $10K/MW if no estimates are available ($500K min./$5M max., 50% non-refundable after IR validation completion); and

• 50% of estimated ADNU costs after cluster-study completion, 50% non-refundable.  The deposit “will be a portion of the overall funding used by the PTO to construct the ADNU” and thus will not be refundable after COD.

The Proposal says that any forfeits of these postings would be treated like any forfeits today under GIDAP, i.e., per GIDAP Section 7.6.  Section 7.6 allocates forfeited security amounts to reduce the cost to remaining projects for still-needed Network Upgrades proportional to the share of Current Cost Responsibility (CCR) accounted for each upgrade. 

The problem is that, due to the ADNU posting requirements above – which are due in higher proportion earlier than postings for other upgrades – the proportion of the posted (and thus) forfeited security when a project withdraws that would be accounted for by ADNU costs would be higher than the CCR proportion.  In other words, Section 7.6 is only fair when the postings for the different upgrades are proportionate, which would not be the case for ADNUs under the Proposal.

Thus, Section 7.6 should be revised to provide that forfeited security posted separately and specifically as Commercial Readiness Deposits for ADNUs should be used to reduce the ADNU costs allocated to remaining projects sharing the ADNU costs, which must now assume the cost share no longer covered by the withdrawing project.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

LSA believes that the complicated Track 3 scope will require deferral until October.  That delay is acceptable, assuming that the next TPD Allocation cycle affidavits are not due until aroung March 2025.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Introduction

MN8 Energy appreciates both the opportunity to comment on CAISO’s proposal for interconnection process reform and the effort put forth by CAISO staff in conducting its stakeholder process. However, CAISO’s final proposal is at odds with third party access and would introduce administrative judgment that risks undermining the effective functioning of the competitive electricity market that CAISO administers today. For this reason, we recommend that CAISO not file IPE changes at FERC at this time. We instead propose that CAISO (1) implement Order 2023 compliance, (2) evaluate the impact of these changes, and (3) resume IPE to address any remaining issues at a later time, as we’ve stated in previous rounds of comments.

Section 2.3.1. Site Control

On pages 16 and 35 of the final proposal, CAISO proposes to generally not extend O.2023 requirements to C14 because (1) it believes that O.2023 requirements generally do not apply to projects that have already been studied and (2) it asserts that the commercial viability criteria (CVC) proposed by IPE include requirements for site control. Cluster 14 will not be required to demonstrate all CVC until April 30, 2028, at which time C14 projects must demonstrate, among others:

1. Executed PPA for a minimum 5-year term
2. 3^rd Interconnection Financial Security per Appendix DD
3. 100% site control
4. Annual report on GIA milestones, permits and authorizations, EPC status

Per site exclusivity requirements under the GIDAP, C14 projects are only required to demonstrate (1) site control for 50% of the total land area needed to support a project or (2) a deposit in lieu of site exclusivity. We expect the carrying costs for C14 projects to be substantially less than those for projects subject to O.2023 requirements, despite projects in C14 and being similarly situated to projects in subsequent clusters. Further, C14 and C15+ projects are very likely competing for the same off-take contracts; such a material discrepancy between queue requirements will confer an undue competitive advantage to one set of projects (C14) over the other. Furthermore, it will fail to weed out less viable projects in C14, which is exactly the issue that motivated CAISO’s efforts in IPE.

We would recommend that CAISO extend the O.2023 requirements for site control to all projects in the queue, including C14, to apply consistent treatment to all similarly situated projects in the queue, and to ensure that limited CAISO resources are focused on viable projects.

Section 2.5.1. Scoring Criteria

We continue to oppose the general scoring framework put forward by CAISO because it relies on criteria that assess a limited range of attributes and indicators that are neither meaningfully predictive of project viability, nor agnostic to technology type, project location, project counterparties, or even project owner. We are concerned that CAISO’s proposal undermines open access, and in turn, the competitive electricity market, by given certain projects preferential treatment; for example:

1. Due to the structure of the matrix and point allocations, load serving entities will very likely be the deciders of which projects are eligible for interconnection in California, despite the conflicts of interest between third party interconnection customers and LSEs, which are also transmission and generation owners. Relatedly, projects with non-LSE offtake will be eligible to earn ¼ as many points as projects with LSE offtake. CAISO has not justified why LSE offtake should receive preferential treatment.
2. In its final proposal, CAISO removed a scoring criterion that awarded points to projects that had achieved site control at the gen-tie. CAISO then gives material points to existing facilities. This unduly disadvantages greenfield development projects that are comparably viable to expansions at existing facilities.
3. CAISO proposes to award points to projects that provide local RA and projects that are long lead time resources but not for projects that provide system or flexibility RA, or for projects that are not long lead time resources.

As stated in previous rounds of comments, CAISO’s scoring system has the adverse potential to replace market forces with administrative project selection, driven in large part by LSE’ preferences. This outcome is antithetical to open access principles.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

Feedback on Track 3 Timeline

CAISO punted major TPD allocation design components to Track 3. In our previous round of comments, we noted an issue with misaligned timelines between the study process and the TPD allocation process. If deliverability that was the basis for setting zonal caps at intake is made available immediately in the subsequent TPD allocation process, then there is a chance that it will not be available for projects that were originally admitted to the queue on the basis of that deliverability. For example:

• Consider that projects in Cluster Y are admitted to the queue based on a quantity of transmission capacity being available at the time of application.
• If projects in Cluster X go through TPD allocation before projects in Cluster Y, then the headroom available might be taken up by Cluster X projects.
• This then introduces the risk that projects in Cluster Y might complete the study process but not receive any deliverability awards, which would defeat the purpose of the zonal approach.

CAISO did not address this issue in its final proposal.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

New Leaf Energy, Inc. (“NLE”) appreciates the CAISO’s continued leadership in the IPE initiative and its work on the Track 2 Final Proposal. Despite the significant effort developing the proposal, NLE believes that substantial implementation issues remain and that these issues must be resolved before bringing the proposal to the CAISO Board.

Importantly, the CAISO and stakeholders have not had an opportunity to consider how implementing the Federal Energy Regulatory Commission (“FERC”) Order 2023 and IPE reforms will affect Cluster 15. Though the CAISO presented analysis on how the IPE proposal will impact Cluster 15 in the Track 2 Final Proposal, this analysis cannot be relied upon because it is based on dated available deliverability figures. Until the updated transmission plan deliverability (“TPD”) allocation results for Clusters 14 and prior are released in May 2024, it will be unclear how much deliverability there is available to award to Cluster 15 projects located in TPD zones. It is possible that too many Cluster 15 projects will withdraw or not be eligible for study after implementing the Order 2023 and IPE reforms, which could negatively impact California’s ability to meet its clean energy goals. The CAISO and stakeholders should have an opportunity to evaluate the possible effects of the significant reforms proposed in the IPE initiative—and their interaction with the Order 2023 reforms—before the CAISO Board considers the Track 2 Final Proposal.

Therefore, NLE respectfully urges the CAISO either to delay consideration of IPE Track 2 to a later CAISO Board meeting or to delay consideration of the scoring rubric to IPE Track 3—and have the CAISO Board address both modifications to the TPD allocation process and the scoring rubric in IPE Track 3 during the October 2024 CAISO Board meeting. NLE provides details on the remaining implementation challenges in the sections below.

1. Zonal Approach

NLE respectfully urges the CAISO to clarify the definition of “zones” and “constraints” for the zonal approach. For the last 11 months and up until the last stakeholder meeting on April 4, 2024, which was the last stakeholder meeting before the CAISO Board is scheduled to vote on the Track 2 Final Proposal, stakeholders understood the CAISO’s proposal to be that a project in a “zone” with available TPD capacity would be eligible for study if the project received a sufficiently high score.

However, NLE now understands that the CAISO’s proposal has changed and that a project would not be eligible for study under the TPD option unless there is a total of 50 megawatts (“MW”) or more of available TPD capacity behind specific “constraints” within a “zone.” NLE cautions that there are significant unresolved issues with the zonal approach under the new methodology based on “constraints.”

First, it would be unreasonable to apply this new approach to Cluster 15 because the CAISO has not yet provided the final information package on available capacity behind individual constraints. The earliest the updated information package will be available is following release of the TPD allocation report in May 2024, and developers must find new pints of interconnection with available TPD capacity before the Cluster 15 Interconnection Request modification window—proposed to open on October 1, 2024, and close on December 1, 2024. Due to these significant changes, NLE believes developers should have more than six months between receiving the updated information package and modifying their Cluster 15 Interconnection Requests to meet the modified requirements.

Second, there is a substantial issue with this new approach related to treatment of projects in Merchant Deliverability (“MD”) zones compared to projects that are in TPD zones with at least 50 MW of available TPD capacity but behind constraints without deliverability. Under the revised proposal, projects in TPD zones located behind constraints without sufficient TPD capacity will have no option to be studied, regardless of their viability score, whereas projects in MD zones without available capacity will still be eligible for study if they agree to fund their network upgrades. This establishes a paradigm where projects within target zones but behind certain constraints are treated as lower priority than projects outside of target zones, which seems contrary to the goal of focusing development in target areas. NLE respectfully urges the CAISO to modify the proposal to allow all projects in TPD zones to be eligible for study. Allowing MD projects to interconnect in TPD zones would allow the CAISO to holistically consider cost-effective ways to expand the transmission system during the interconnection study process. NLE understands that this will require additional work by the CAISO and stakeholders to refine the proposal, which is one of the primary reasons why NLE believes delaying the IPE initiative is warranted.

2. Scoring Rubric

Due to the remaining issues with the scoring rubric described below, the CAISO should delay consideration of the Track 2 Final Proposal or the scoring rubric proposal, at minimum, until the October 2024 CAISO Board meeting.

1. Commercial Interest Category: Load-Serving Entity (“LSE”) Interest

NLE remains concerned with the commercial interest category and its high maximum point allocation for the following reasons:

• First, prioritizing projects selected by LSEs for study creates open access issues under FERC Order 2003.[1] 
• 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 this very early indication of LSE preference over other criteria more indicative of increased project viability.
• 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, especially for this first application of the scoring criteria to Cluster 15 projects. Further, the CAISO must ensure that projects receive points in a fair and transparent manner that does not violate FERC Order 2003 open access principles. In the Track 2 Final Proposal and during the April 4, 2024, stakeholder meeting, CAISO staff encouraged the LSEs to modify their tariffs to include a process for issuing Requests for Information (“RFIs”) and allocating commercial interest points. However, the LSEs explained that they do not have applicable tariffs to host this information, and the implementation timeline does not allow sufficient time to develop the necessary processes. The CAISO must explain in its IPE FERC filing how the LSEs can conduct RFIs and select projects within a fair and transparent process.

Additionally, during the April 4, 2024, stakeholder meeting, CAISO staff agreed that it should host a technical workshop on this category and publish a list of LSEs containing contact information for procurement leads at each LSE. NLE strongly supports both of these proposals that would help LSEs—many of whom have not been active in the IPE initiative—to learn more about this process, connect with developers, and receive information on projects prior to conducting an RFI.

Due to these remaining issues and the aggressive timeline for implementing new processes needed for the commercial interest category, NLE respectfully urges the CAISO to delay consideration of this part of the IPE proposal to a later CAISO Board meeting. Alternatively, it may be prudent to move forward with implementing the other scoring rubric categories for Cluster 15 and to delay implementation of the commercial interest category until Cluster 16.

2. Project Viability Category: Engineering Design Plan Completeness

NLE is concerned that the Track 2 Final Proposal does not contain sufficient details needed to implement the Engineering Design Plan criterion. The IPE Track 2 Draft Final Proposal stated that the CAISO “will further explore guidelines from the Association for the Advancement of Cost Engineering or the Institute of Electrical and Electronics Engineers to validate and determine the percent completion of each engineering design plan.”^[2] However, the Track 2 Final Proposal does not contain details on what guidelines to use to evaluate completeness of the Engineering Design Plans. This important detail must be included in the Track 2 Final Proposal so that developers have sufficient lead time to assemble Engineering Design Plans for each of their Cluster 15 projects.

3. System Need Category: Ability to Provide Local Resource Adequacy (“RA”) in a Local Capacity Resource Area (“LCRA”) with an Independent System Operator Demonstrated Need for Additional Capacity in That Local Area

During the April 4, 2024, stakeholder meeting, CAISO staff explained that it proposes to reinstate a requirement from the IPE Track 2 Revised Straw Proposal 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 Track 2 Final Proposal. The CAISO already examines charging capacity within the Transmission Planning Process, and therefore 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, as it would be redundant to existing processes.

If the CAISO nevertheless adopts this additional restriction, it should provide information—within the package of information on available zonal capacity—regarding specific charging restrictions in 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 any individual project if the cumulative capacity of batteries applying for interconnection is greater than the identified one-for-one replacement capacity. As the CAISO has yet to finalize these important details of the proposal, NLE does not believe that this part of the Track 2 Final Proposal is ready for CAISO Board consideration in May 2024.

4. System Need Category: Long Lead-Time Resources

NLE continues to be concerned with the proposal to award 100 points to long lead-time resources. The significant point allocation essentially makes all long-lead time resources in TPD zones eligible for study—over other more near-term projects that may be needed to meet California’s clean energy goals. This creates a discriminatory process as it gives preferential treatment to a subset of technologies, which provide the same services as other projects that will not be studied.[4] NLE respectfully urges the CAISO to, at minimum, decrease the points available to long lead-time resources from 100 to 50.

3. Zonal-Level Group Scoping Meetings

NLE respectfully urges the CAISO to supplement the zonal-level group scoping meetings with a process for developers to ask project-specific questions. NLE understands that hosting group scoping meetings will address CAISO staff resourcing constraints, but the CAISO should retain the ability for developers to ask questions that may contain competitively sensitive information. This could be done, for example, by allowing developers to submit written questions to the CAISO before or after the group scoping meetings.

[1] The principles of open access require “non-discriminatory treatment for all eligible users of the transmission system.” Calif. Indep. Sys. Operator Corp., 168 FERC ¶ 61,105 at 13 (2019). The concept of fair, non-discriminatory and open access to transmission service was one of the core rationales behind the FERC’s creation of the Open Access Transmission Tariff (“OATT”) with Order 888, and maintaining open and non-discriminatory treatment has been the justification for nearly all subsequent rulemakings on the OATT, including those pertaining to interconnection service. See Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission on Servs. by Pub. Utils; Recovery of Stranded Costs by Pub. Utils. & Transmitting Utils., Order No. 888, 61 FR 21540 (May 10, 1996), FERC Stats. & Regs. ¶ 31,036 (1996), on reh’g, Order No. 888-A, FERC Stats. & Regs. ¶ 61,048, on reh’g, Order No. 888-B, 81 FERC ¶ 61,248 (1997), on reh’g, Order No. 888-C, 82 FERC ¶ 61,046 (1998), aff’d sub nom. New York v. FERC, 535 U.S. 1 (2002); Standardization of Large Generator Interconnection Agreements & Proc, Order No. 2003, 68 FR 49845 (Aug. 19, 2003), 104 FERC ¶ 61,103 at 9 (2003) (stating that interconnection “is a critical component of open access transmission service and thus is subject to the requirement that utilities offer comparable service under the OATT”) citing Tenn. Power Co., 90 FERC ¶ 61,238 (2002); see also Improvements to Generator Interconnection Procedures and Agreements, Notice of Proposed Rulemaking, 179 FERC ¶ 61,194 at 22 (2022) (proposing changes to the pro forma LGIP, LGIA, SGIP and SGIA to ensure “interconnection customers are able to interconnect to the transmission system in a reliable, efficient, transparent, and timely manner, thereby ensuring that rates, terms, and conditions for Commission-jurisdictional services remain just and reasonable and not unduly discriminatory or preferential”).

[2] CAISO, 2023 IPE Track 2 Draft Final Proposal at 36 (Feb. 8, 2024), available at: http://www.caiso.com/InitiativeDocuments/DraftFinalProposal-InterconnectionProcessEnhancements2023.pdf (citing Association for the Advancement of Cost Engineering, Cost Estimate Classification System (Aug. 7, 2020), available at: https://web.aacei.org/docs/default-source/toc/toc_18r-97.pdf?sfvrsn=4).

[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] It is a core principle of the Federal Power Act that the FERC must ensure that all rates are just and reasonable and that “no public utility…with respect to any transmission or sale…subject any person to any undue prejudice or disadvantage” or “maintain any unreasonable difference in rates, charges, service, facilities, or in any other respect, either as between localities or as between classes of service.” See 16 U.S.C. §§ 824d(a)-(b); see also S. Carolina Pub. Serv. Auth. v. FERC, 762 F.3d 41, 49 (D.C. Cir. 2014). Rates or practices are unduly discriminatory when they treat similarly situated customers differently. Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services, 119 FERC ¶ 61,295 at 963 (2007) (“The standard for judging undue discrimination…has always been: disparate rates or service for similarly situated customers”); Elec. Consumers Res. Council v. FERC, 747 F.2d 1511, 1515 (D.C. Cir. 1984).

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

NLE supports CAISO staff’s recommendation—made during the April 4, 2024, stakeholder meeting—to delay consideration of proposals to modify the TPD allocation process until the October 2024 CAISO Board meeting. For the reasons stated above in response to Question 1, NLE also respectfully urges the CAISO to delay consideration of IPE Track 2 or at least the scoring rubric proposal to the October 2024 CAISO Board meeting as well. 

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Section 2.1

NCPA appreciates CAISO’s recognition that the resource plans and portfolios of non-CPUC jurisdictional LSEs must be taken into consideration in the CAISO Transmission Planning Process (TPP). Tightening the linkages among the TPP, the procurement process and the interconnection process is an important goal, but the zonal approach can be just and reasonable only if the plans of all CAISO LSEs are studied on a comparable basis and are included and incorporated in each process. The Proposal represents good progress in this regard.

Section 2.3.3

CAISO proposes that the Reimbursement option for Energy Only projects be limited to zones where the CPUC IRP base case portfolio identifies the need for Energy Only resources. Consistent with the principle of consistent treatment of all LRAs, CAISO should clarify that, in identifying Reimbursement option zones, it will also consider any need for Energy Only resources identified in non-CPUC jurisdictional LRA resource plans.

Section 2.5.1

CAISO has struck the appropriate balance of incorporating LSE resource needs into the interconnection process while preserving ample space for merchant and developer projects, all within the real constraints of the number of projects per cycle that CAISO can study and obtain useful results. Incorporation of LSE interest is essential to prioritize the most viable projects for limited study capacity, while keeping the door open to all types of projects. While NCPA would not favor every element of the package in isolation, NCPA supports the Proposal as a package that balances these competing concerns.

NCPA further appreciates CAISO’s work at reframing the language to reflect the interests of all CAISO LSEs, not just the CPUC-mandated resource portfolio. 

CAISO should be cautious about prescribing terms affecting LSE procurement processes or the allocation of LSE interest points. To the extent that generators are claiming they lack sufficient information about what projects LSEs are interested in procuring, this concern is overstated and unsupported. LSEs routinely issue RFPs to acquire projects. NCPA recently concluded an RFP process that received a robust response, which included multiple pages of detail regarding NCPA’s needs and what it is looking for in terms of projects to meet its loads and environmental requirements. NCPA does not believe that there is any shortage of information on what LSEs want and need. However, the conduct of RFPs is not a one-size-fits-all activity, nor are all LSEs subject to the same jurisdictional authority. Any concerns about RFP or other procurement-related activities should be raised outside of the IPE 2023 initiative.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

 NCPA has no objection to the October 2024 Board Meeting as the target for Phase 3.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

PG&E appreciates the opportunity to provide comments on the CAISO’s Final Proposal in the Interconnection Process Enhancements 2023 Track 2 initiative.  PG&E acknowledges the significant effort CAISO staff and management have put into this phase of the initiative. PG&E looks forward to working with CAISO to implement the reforms to enable clean energy resources to connect to the grid.

PG&E is generally supportive of the reforms in the Final Proposal. PG&E provides comments below on several components that would further strengthen CAISO’s and PG&E’s shared goal of queue reform and creating a pathway for the deliverability of clean energy resources.

1. Zonal Approach

Under the current proposed process in the Final Proposal, it is PG&E’s understanding that in zones designated as TPD Zones, where applicants whose point of interconnection (POI) has at least one constraint with zero TPD availability (or not enough availability for the applicant to be studied), those applicants will not be considered in the TPD scoring process.  PG&E believes this unduly disadvantages interconnection applicants that plan to utilize an existing gen-tie to deliver the MWs requested in the study application.  Existing generation facilities with existing gen-tie lines that are expanding capacity do not have an option to choose their POI and where they are interconnected, and therefore should be allowed to pursue the Merchant Option. 

PG&E also requests the CAISO clarify the following statement:

“[The] [h]ighest ranking projects will advance to the study phase in descending order of a project’s score, until the available and planned transmission capacity for each constraint is filled to 150% of that capacity.”  

For example, does this mean that a 200 MW project that scored highest in a zone will “use” 200 MW from each of its applicable constraints 150% TPD availability, and then the second highest scored project in that zone would be evaluated to see if any of its applicable constraints now have inadequate TPD availability or zero availability remaining from the 150% and hence be excluded from study (and so on for the next highest scored)?  If this is the case, PG&E is concerned that during the scoring process and allocation of available TPD, interconnection requests to expand existing generating facilities with existing gen-tie lines are similarly disadvantaged because they do not have an option to choose their POI, and change it if needed to be included in the cluster study.  For this reason, PG&E recommends allowing the Merchant Option.  In the case where applicants would be excluded from the cluster study and if those applicants are existing generation facilities with existing gen-ties, then those applicants should be allowed to pursue the Merchant Option similar to the example in the comment above.  Otherwise the currently proposed framework may not allow for exsiting generating facilities that seek to expand capacity from having the ability to be included in any future cluster studies. 

Lastly, PG&E recommends CAISO Update all Zone and TPD availability information based on the recently approved New Deliverability Methodology.

2. Treatment of Full Capacity Deliverability Status and Energy Only Resources

PG&E stresses again that it does not support the ability for an uncapped number of Energy Only (EO) resources to be studied in the cluster process. Under CAISO’s significantly modified proposal for EO resources, having a non-reimbursable option for EO projects without any limit increases the MW amount to be studied in reliability studies. Even though EO resources do not seek deliverability, EO projects still contribute towards short-circuit duty (SCD), substation and other reliability network upgrades. The additional upgrades triggered by EO resources could potentially delay in-service dates for FCDS projects.

PG&E also notes that increasing the amount of MW that is studied in a zone, without any limits for EO projects goes against the problem statements and principles that were adopted by CAISO and stakeholders as the foundational pillars for reviewing and moving forward proposed reforms:  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”.

Given the potential for the non-reimbursable option for EO resources - which would be uncapped - to increase the MW amount to be studied  in zones by a large sum more than the existing and planned transmission capacity, the study results would lose accuracy similar to what has been witnessed with Cluster 14 study results.  PG&E recommends the CAISO remove its non-reimbursable pathway for EO projects in its next iteration of the Final Proposal prior to taking the package of interconnection reforms to the CAISO Board for approval.

3. LSE Points for Utility-Owned Storage/Generation

While PG&E recognizes the change in the Final Proposal is generally in the right direction, PG&E recommends that the cap on LSE points eligible for awarding to utility-owned projects not apply to expansions of existing generation/storage facilities.  Expansion of existing hydroelectric generation facilities, for example, presents an opportunity to increase the utilization of existing generation and grid facilities, while expanding the diversity of generation at possibly a lower cost to customers and lower environmental impacts.  This opportunity is both beneficial to customers and supports the state’s decarbonization goals. However, the CAISO’s proposal as currently written, may jeopardize the ability for these multi-benefit projects to be studied. In fact, the Final Proposal’s project viability scoring provides the most points to projects which are an “expansion of a facility that is under construction or in operation, where the Gen-Tie already has sufficient surplus capability to accommodate the additional resource” specifically acknowledging the preference of expansions over projects requesting new POIs. As such, expansions proposed from a utility-owned site should not be further discounted or abandoned through imposition of this cap in favor of projects that would have scored less through the proposed project viability scoring criteria.

For LSE self-built projects proposing new Points of Interconnection, the recommended limitation proposed in the Final Proposal is reasonable.

4. Non-LSE Interest Points

PG&E appreciates the CAISO’s recognition of LSEs’ concern relating to non-LSEs participating in the scoring process and we do not believe that the CAISO has gone far enough to limit the impact of non-LSEs competing for resources, given that these entities do not have obligations to serve load or provide RA. PG&E maintains its prior position that non-LSEs should not have the ability to allocate points during the interconnection intake process.

If it is determined that non-LSE off-takers will have the opportunity to score projects, then PG&E proposes narrowing the definition of non-LSE off-takers to a single parent company that can score a single project.  For example, one parent company may have many subsidiaries, and the single parent company inclusive of its multiple subsidaries should be limited to a total number of one project to allocate points towards.  Doing so will prevent the development of a company with several subsidiaries gaming the system to allocate points to multiple projects.

5. Schedule for Cluster 15 / LSE Point Allocation

PG&E is aware that Southern California Edison (SCE) in its comments on the Final Proposal recommends that CAISO provide LSEs with 15 business days from the deadline for interconnection customers to modify their interconnection requests.  PG&E supports SCE’s recommendation for the reasons outlined in their comments.

Similary, PG&E agrees with SCE's comments that CAISO clarify and confirm that it will provide LSEs with information that will enable LSEs to verify the accuracy of key interconnection parameters. 

6. Scoring Criteria for Prioritizing Projects for Study: DFAX as Tie-Breaker

For projects that are interconnecting to substations behind multiple constraints, PG&E requests CAISO clarify which constraint would be used for the DFAX calculation.  If the most limiting constraint for both projects are used, and happen to be different constraints with different amount of available deliverability, how would the CAISO determine which project should be studied.

7. Viability Criteria and Time in Queue

PG&E supports CAISO’s proposal and agrees that Commercial Viability Criteria (CVC) and Time in Queue requirements should apply to all projects in the CAISO queue regardless of deliverability status. 

While PG&E also agrees with CAISO that FERC Order 2023 site control requirements and timing should supersede CAISO CVC requirements once implemented, PG&E believes it makes sense to revise the CVC requirements in the Final Proposal to match FERC Order 2023 (and Order 2023-A) requirements in anticipation of those requirements being implemented.

In regard to the CVC requirements in the Final Proposal, PG&E generally supports them but has several recommendations outlined below:

1. Under the requirement for an interconnection customer to provide a report with a “list of all necessary permits, environmental assessments,” PG&E recommends that this list also include the current status of those permits (e.g., in application, under review, approved) and the effective dates or completion dates (if any) for each.  Having the current status of permits will provide CAISO and the PTOs with information on an expected completion date to assess the projects status in moving forward to commercial operation.
2. PG&E supports the proposal to restrict further project changes once CVC is met until post-COD.  However, PG&E suggests the CAISO consider an exception for changes driven by either a reassessment study, or unforeseen or changed field conditions.

8. Earlier Financial Security Postings for Projects with Shared Upgrades

Establishing consistent and quicker timelines for posting of financial securities and requiring Notices to Proceed (NTP) from all customers sharing an upgrade is a good step toward speeding up the post-GIA interconnection work.  While the proposal does identify the possible need for amending the GIA at a later date to account for the additional financial security posting and notice to proceed for these specific upgrades, it is likely that in practice the CAISO, the PTOs, and interconnection customers will seek and develop language that identifies these shared upgrades and their financial security and NTP requirements in the original GIA in such a way that allows for the financial security and NTP to be called from the customer when needed, and then prevent the need for additional administrative time and effort developing a GIA amendment or Engineering & Procurement Agreement for these situations.

PG&E recommends that such language be developed under CAISO’s purview sooner rather than later so that it can be used in the near future (i.e., in Cluster 14 GIAs) to avoid what might amount to a significant amount of contract re-work given the current size of Cluster 14 and the expected size of Cluster 15.

9. Revise Timing of GIA Amendments to Incorporate Modification Results

PG&E does not support CAISO’s current proposal.  Rather, PG&E continues to support CAISO’s original proposal that the process of amending the GIA that will include all of the MMAs should start no later than nine months prior to synchronization.  PG&E recommends CAISO not allow any MMAs during the final nine-month period prior to synchronization if an interconnection customer asking for amendment to be completed.  Under current proposal, scenarios may exist that would create overlapping administrative requirements with a GIA amendment and an MMA in process at the same time.  PG&E’s understanding of CAISO’s prior proposal is that the intent of a GIA amendment during this period is to incorporate all existing MMAs.\

The CAISO’s proposal would still allow post-COD MMAs and PG&E agrees with this portion, however PG&E’s  believes it not beneficial to have duplicative administrative contracts in process.

10. Update to the Phase Angle Measuring Units Data

PG&E requests the CAISO clarify if it is proposing 16 samples per cycle or 16 phasors per cycle.  PMUs are not required to report out at anything higher than 60 frames per second. Snippet from IEEE C37.118.1 is pasted below for what PMUs are required to report out at.  If CAISO wants to propose a rate higher than the requirement in IEEE C37.118, then the CAISO may need to work with vendors and IEEE to update.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Track 2 has been surprisingly effective in developing a process that can manage the large number of interconnection requests in Cluster 15. Though a number of issues remain to be addressed. Its is expeted that the outstanding issues will be addressed in Track 3.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

The proposed timeline is reasonable.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Qcells USA Corp (“Qcells”) appreciates the opportunity to provide feedback on CAISO’s IPE 2023 process and proposal. Although Qcells is supportive of certain aspects of the final proposal, such as CAISO’s approach to making information available, Qcells continues to have concerns with several aspects of CAISO’s proposal, to include the zonal approach, the LSE interest process, and the availability of capacity and its impact on project development. Qcells is primarily addressing CAISO’s provisions in sections 2.4.1, 2.5.1, and 2.5.2.

CAISO proposes to limit the study of each sub-zonal constraint to 150% of the available capacity at that constraint. Once that limit is reached, projects that have submitted requests for that POI will not have the opportunity to be studied under the interconnection study process. Those projects that are excluded from the interconnection process are unable to switch from the TPD option to the merchant option. Qcells believes that those projects should have the option to modify their request to either choose the merchant option or select a new POI in a merchant zone during the modification window.

Qcells is concerned that CAISO will have very little capacity available for study in Cluster 15 and beyond. As CAISO noted, the results of its Cluster 15 test resulted in only 112 out of 508 projects advance to study; approximately 300 of these projects did not make it past the initial constraint check. In the April 4, 2024 meeting, CAISO noted that there could be even less available capacity after Cluster 14 TPD is allocated in July 2024. Given the size of CAISO’s queues and limited available capacity to-date, Qcells appreciates CAISO working towards a process so that more capacity will become available for more than just offshore wind.

The IPE’s zonal approach is further complicated by its proposal allowing a zone to be studied as a merchant zone where “less than 50 MW of available capacity exists within the zone based on an assessment of the known constraints within the zone” After the stakeholder meeting on April 4, 2024 there remains ambiguity whether the 50 MW applies to the individual constraint, or if 50 MW is the threshold for the total available capacity in a zone. CAISO should consider the former approach, which may allow more opportunities for capacity constrained zones to be studied as merchant zones.

Qcells disagrees with CAISO’s commercial interest approach and views the heavy weighting of LSE interest as anti-competitive and a barrier to viable projects that may obtain commercial interest other than LSE interest. Additionally, Qcells is concerned about the lack of detail in how the LSE selection process will work in practice. CAISO provides a high-level outline of how LSE points will be allocated but defers to the LSEs to build-out a process to fairly and transparently identify projects to allocate their points, adding that FERC jurisdictional LSEs “should consider updating their tariffs to establish clear and fair process for allocation points.” Given the upcoming Cluster 15 deadlines, Qcells is concerned that LSEs will not have adequate time to draft quality tariff revisions addressing these new necessities. Given the significant weight of LSE interest in the scoring process, it is of utmost importance that the selection processes be fair, transparent, and well-vetted prior to implementation, as well as after LSE’s project selections are made.

Finally, Qcells continues to oppose using DFAX as a tiebreaker, and subsequently utilizing the auction if DFAX fails to break the tie. Qcells maintains that projects that tie for the 150% capacity threshold should continue to the interconnection study process.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

Qcells understands the importance of this topic and appreciates that CAISO will take the extra time to focus on TPD allocation in a Track 3 of the IPE 2023 process. Qcells is therefore supportive of the October 3, 2024 target of bringing this initiative to the Board of Governors.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

REV Renewables (REV) appreciates CAISO’s work and the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 2 Final Proposal. Given this is at the final proposal stage, REV’s comments are focused on continuing to oppose Section 2.5.1 – Scoring Criteria for Prioritization of the Study Process, particularly the LSE Interest criteria. The LSE interest criteria put the filing at risk of violating FERC Order 888 which ensures non-discriminatory open access to the electric transmission system.

REV thinks the scoring criteria persist in being weighted towards LSE interest and that LSEs having a say in which projects should be studied under this process may go against open access. CAISO continues to reference the December 2022 Memorandum of Understanding (MOU) as a justification for the LSE interest points. In reviewing this MOU, REV assumes points 10 and 11 are likely the relevant points. Point 11 in particular states “The ISO will seek to prioritize interconnection process activities to support the resources with the operational characteristics and geographic locations consistent with the resource planning conducted by the CEC and CPUC, and the transmission planning conducted by the ISO based on that resource planning.”[1] However, the MOU has no mention of needing to take into account specific LSE interest. As REV has stated in previous comments[2], LSE interest is already incorporated into the process through the CPUC’s Integrated Resource Planning (IRP) Process, which is based on individual LSE procurement plans, and the resulting resource portfolio gets sent to CAISO for transmission planning. The CAISO’s annual Transmission Plan is using the CPUC’s zonal approach to identify new transmission needs to accommodate new resources. Therefore, REV submits that LSE interests on commercial procurement activities is already built into the transmission and interconnection process at an early stage with the IRP process and should not need to also be an additional screen to interconnection applications. The MOU is with CPUC, not the LSEs, and as laid out above, the interconnection process already incorporates CPUC resource planning processes. If any additional LSE inputs are deemed necessary, these should be incorporated in CPUC’s IRP process and not CAISO Interconnection processes.

REV is also concerned that the process by which LSEs will provide points to projects is undefined, not transparent, and has risk of it potentially becoming a discriminatory process. Without clear information from LSEs on how they will implement their scoring, this category is subjective and unfairly puts the fate of all projects into LSE hands. Given the proposed point allocation of up to 30 out of 100 points, it is likely that any project that receives LSE interest points will be studied, which gives LSEs an inappropriate influence at the interconnection request intake stage. This is an elevated concern given that LSEs can award capacity to three self-built projects or 25% of the LSE’s capacity allocation per cycle, all but guaranteeing any LSE self-built projects will be studied compared to third-party projects that have to compete to be studied. At the time of filing the interconnection request, Developers, CAISO and LSEs will not know CODs for projects and/or scope/cost of required interconnection upgrades (which can drive the cost of the project). Given this, LSEs will have very little information to make a decision which projects should proceed. The main factors LSEs will likely use to judge are resource type, size, and location. However, CPUC already indicates its preferred resource type, quantities, and locations in the IRP process so it’s unclear what additional color LSEs can even provide. Also, at this early stage of the project, developers are in the most appropriate position to weigh development risks and also appropriately bear the burden of those risks, not LSEs. By providing inputs to CAISO on which projects should proceed with the interconnection study, LSEs will be inadvertently taking on a responsibility of analyzing project risk which is extremely difficult to do at this early stage.

REV recommends this Commercial Interest category be dropped from the scoring criteria. REV recognizes that would leave even fewer categories for scoring. If CAISO desires more criteria, REV suggests CAISO continue to refine the scoring criteria, and revisit suggestions from stakeholders early in the IPE process. For example, there was discussion on certain criteria to enter (e.g. Order 2023 requirements) and then ability to increase commercial viability requirements, deposits, and withdrawal penalties as a project progresses through the study process. While REV recognizes this could still entail studying a larger number of projects than CAISO desires in the initial cluster study, it can also align more appropriately to the development process and increasing viability as more information is known on the interconnection process.

For the System Need-Local RA scoring criteria, REV is also concerned with CAISO’s approach in adopting the requirement regarding available of sufficient capacity in the LCRA to charge any proposed new energy storage facilities. CAISO does not limit the amount of local RA a battery counts for due to its local capacity technical study, so it does not seem appropriate to not provide points to storage in these local areas that may currently show charging restrictions. It is also not clear on how these charging limits in the LCR areas get used in the TPP portfolio development process, if at all, and therefore how these charging restrictions should be applied to the interconnection process particularly at intake. In addition, CAISO has suggested using the 2029 LCR result to identify these charging limitations for the LCR area starting with Cluster 15. Will CAISO be using the same 2029 LCR information for the next or subsequent portfolio development process? Is there a risk of these numbers changing based on evolving system conditions and new energy or transmission resources that may come online? It is also not clear on how this will be applied to co-located projects which will also use the grid to charge resulting in a similar situation as energy storage projects. We would request CAISO to reconsider this approach and not impose this additional requirement on the energy storage projects.

[1] https://www.caiso.com/Documents/ISO-CEC-and-CPUC-Memorandum-of-Understanding-Dec-2022.pdf

[2] See REV Revised Straw Proposal comments December 21, 2023

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

REV supports extending the initiative timeline for Track 3 of the IPE 2023 initiative to October 2024. REV suggests starting this track as soon as possible to ensure sufficient time to discuss this important topic. REV also requests that CAISO revisit suggestions from stakeholders in summer/fall 2023 on this topic to ensure it is properly scoped.

Additionally, REV noticed in the Cluster 16 and 17 sample timeline that more explanation is needed on how CAISO will determine TPD availability for allocation and for the next cluster. For example, in the sample timeline, it shows that Cluster 17 will start without factoring in Cluster 16 projects into available capacity. Therefore, Cluster 17 projects may be entering assuming that a certain megawatt level is available, but when they get through the study or allocation process there may be nothing there. CAISO could consider some sort of reservation or vintage TPD available based on queue entry, or have certain transmission upgrades tied to certain cluster classes as is done in some other ISO/RTOs like MISO and SPP. These issues can be discussed in Track 3.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

SDG&E appreciates the opportunity to comment on the Final Proposal for the Interconnection Process Enhancements (IPE) 2023 Track 2 initiative. In general, SDG&E believes the Final Proposal makes positive changes in adjusting the scoring criteria to account for the concerns of LSEs with significant departed load, such as SDG&E, and supports several modifications included in the Final Proposal. Below, SDG&E offers targeted feedback regarding the elements of Section 2.5.1 that have changed in the Final Proposal.

LSE Allocation Process: As a foundational element of the interconnection process enhancements proposal, SDG&E supports the inclusion of LSE-interest points as a part of the overall scoring criteria. Our recommendations focus on two elements of the allocation process: first, we encourage CAISO to extend the timeline for LSEs to submit their interest scores, and second, CAISO should provide sufficient data to the LSEs in support of project scoring. The Final Proposal made incremental improvements to the timeline by giving LSEs an additional ten days to submit their interest scores, but SDG&E urges CAISO to consider further extending this period to one month after the close of the interconnection window.  LSEs are being asked to implement a new process that will impact decisions many years into the future.  Given the lasting impacts on future planning, it is essential for LSEs to have sufficient time to thoroughly review and compare interconnection requests to the results of their RFIs to ensure consistency and meaning allocation of points.  Especially in the early rollout of this new process, additional time will be needed to make sure the allocation process is successful in meeting its purpose.  

The Final Proposal also contemplates how LSEs might facilitate a process for scoring and allocating points to projects. However, there is still a great deal of ambiguity relating to what level of information CAISO will provide to the LSEs during the scoring process and how that will align with information that is gathered via RFIs, solicitations, and bilateral discussions. Based on initial analysis, SDG&E anticipates that, at a minimum, its RFI process would request from developers sufficient information to evaluate the viability of projects in areas including but not limited to: (i) project location, which may include evaluation of available interconnection capacity, site control and permitting status, including potential or actual permitting obstacles; (ii) developer experience in completing projects; and, (iii) the reasonableness of the proposed commercial operation date, including timelines for achieving major milestones, such as permitting and interconnection processes, to determine the reasonableness of the project online date.  It is critical that CAISO delivers sufficient information to LSEs, within a reasonable timeframe, so that it is possible to verify any developer provided information that results from their RFIs.

SDG&E requests clarification on what CAISO means by “LSEs should consider revisiting their tariffs to ensure they award points using fair and reasonable processes”.  SDG&E does not believe it is appropriate for CAISO to direct the approach that LSEs should take to allocate their capacity in the CAISO tariff. Initially, SDG&E notes that the Transmission Owner or WDAT Tariffs may not be the best place for these revisions as they are FERC jurisdictional, whereas the LSE procurement effort is CPUC jurisdictional.  Indeed, SDG&E’s procurement process is not governed by tariffs but by its bundled procurement plan, legislative procurement requirements, CPUC procurement mandates, etc.  Actions taken by SDG&E in the procurement area are discussed with stakeholders via its procurement review group, solicitations are monitoring by an independent evaluator and all procurement decisions are ultimately reviewed by the Commission.  Enshrining what is ultimately an assessment of procurement need in a tariff would not only be contra to current processes described above it could ensure a cycle where SDG&E was constantly updating a tariff to meet a new procurement requirement.  This would not only upend current practices (and regulatory requirements) it would also be inefficient and take additional time, undercutting the very goal of this initiative. While SDG&E understands, and supports, the need allocate points in a “fair and reasonable process”, SDG&E encourages CAISO to continue to explore viable options for housing these requirements that works within established procurement frameworks.

Allocation Methodology and Full Allocation Election: The Final Proposal provides two significant improvements in the scoring criteria. SDG&E appreciates the change to the LSE weighting factor and the removal of the 150% available capacity threshold for the full allocation elections. This is an improvement to the scoring criteria, given how LSEs will be able to allocate their limited MW capacity to support projects to be studied in the queue to meet their portfolios requirements. The changes not only increase the pool of available capacity for LSEs, but guarantee that smaller LSEs will retain the ability to allocate points towards larger MW capacity projects capable of achieving economies of scale.

Limits on LSE-Owned Projects: While SDG&E still opposes restrictions on the ability of LSEs to allocate points to projects based on their status as utility-owned, the “greater of” approach in the Final Proposal is a significant improvement to the arbitrary one-project limit presented in the Draft Final Proposal. Allowing LSEs to award capacity to either three self-built projects or 25% of each LSEs capacity allocation cycle is a more workable approach should the CAISO move forward with this limit.

Finally, SDG&E sees significant challenges once the interconnection process starts again related to our previous comments on a) stricter CVC demonstration timeline requirements and b) stricter requirements regarding IFS postings. SDG&E encourages CAISO to review those comments from previous rounds of the IPE process, as the absence of these measures may lead to a bumpy interconnection process when it commences.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

1. Data Accessibility

SEIA appreciates the consolidated report published by CAISO but is concerned with the continued confusion around the implementation of the zonal approach and interconnection customers’ ability to infer zone status (i.e., TPD option or merchant) using publicly available data. It is imperative that CAISO provide developers with clear, accurate, and timely data ahead of a cluster window to allow adequate time to produce informed and competitive interconnection requests. Based on stakeholder comments made during the April 4^th IPE meeting, it is evident that there continues to be significant uncertainty around the zonal approach implementation, particularly around how CAISO will define TPD option zones or constraints, how the amount of available transmission capacity will be determined, and how that information can be gleaned from publicly available reports. For example, CAISO staff noted on the call that, as of today, only the East of Pisgah constraint has been identified as a merchant zone. The consolidated report published by CAISO, however, shows two constraints within the East of Pisgah with more than 50 MWs of available TPD which, based on the language of the final proposal, should make the East of Pisgah constraint a TPD option zone. This is a significant concern for SEIA; it is difficult to comment on the merits of the zonal approach when some of the central elements of the proposal – how the zones are defined, and available capacity determined – is unclear. This is particularly concerning as this is the final proposal and CAISO plans on filing tariff revisions with FERC shortly. SEIA echoes AES’ request for a technical workshop to review the consolidated report and walk through examples of how zones and zonal capacity can be derived using that report.

2. Timeline

SEIA appreciates the changes made to the timeline for Cluster 16 and beyond but recommends increasing the time between the heatmap update and opening the cluster window, even if this means delaying the opening of Cluster 16. It is important that interconnection customers have sufficient time to process the updates prior to submitting interconnection requests. SEIA also appreciates the update to the Cluster 15 timeline and, given the uncertainty around Order 2023 compliance timelines, asks that CAISO continue to update stakeholders on changes to the timing of Cluster 15 activities.

SEIA encourages CAISO to provide interconnection customers with updated TPD data and the list of POIs within each zone as quickly as possible to provide sufficient time and information for interconnection customers to make informed decisions regarding C15 interconnection requests.

3. Scoring Criteria

SEIA continues to be concerned about the scoring criteria CAISO will use to prioritize and select interconnection requests for study. Though weighted less than Project Viability and System Need, the Commercial Interest will likely be determinative in many instances since the Project Viability and System Need categories offer little opportunity for differentiation. Within the Commercial Interest category, CAISO gives preference to LSEs by permitting LSEs to “award capacity to either three self-built projects or 25% of the LSE’s capacity allocation per cycle, whichever is greater.” This appears to give LSEs the opportunity to fully allocate capacity to self-builds while limiting non-LSEs to award a single project with 25 points. Many commercial offtakers have large loads that require significant procurement, and the Commercial Interest category should reflect that just as it is has for LSEs. SEIA recommends that the LSE provision limited to the lesser of three-self build projects or 25% of the LSE’s capacity allocation per cycle, and that non-LSEs be given greater weighting in the Commercial Interest category. Further, the Commercial Interest category potentially “double counts” LSE commercial interests; the zonal approach inherently accounts for LSE interest as it is informed by the CPUC resource portfolio and capturing that interest again through the scoring criteria provides LSEs with significant influence over resource intake.

Further, SEIA echoes AES’ concerns regarding the lack of transparency in the LSE RFI processes, especially given the significance of the Commercial Interest scoring category. SEIA encourages CAISO to establish minimum RFI standards to ensure uniformity and fairness for project evaluation. SEIA also agrees with AES’ recommendation to remove the requirement that non-LSE affidavits include language on corporate sustainability policy goals.

4. Treatment of Energy-Only Resources

SEIA views the update to treatment of Energy-Only (EO) interconnection requests as an improvement upon the draft final proposal but has concerns with the dependence upon the CPUC resource portfolio. It is unclear to SEIA why a distinction needs to be made with respect to EO siting and reimbursement. It seems that CAISO argues the EO resources in the CPUC portfolio should be eligible for reimbursement because that is where EO procurement is most likely to occur and where the CPUC has determined EO resources are needed. This affords the CPUC with significant influence over project interconnection and siting and disincentivizes EO procurement outside of CPUC portfolio zones. Further, it is unclear to SEIA why non-reimbursable EO projects can proceed in reimbursable EO zones, but merchant projects cannot interconnect in TPD option zones. CAISO notes, “Energy Only projects seeking to interconnect under the Non-reimbursement option will not be required to submit scoring information because all such projects will be eligible to be studied…Projects seeking to interconnect using the Non-reimbursement option can be studied in zones that are eligible under the Reimbursement option. Such projects would not have to compete to be studied in the scoring process and would continue to be ineligible for reimbursement of RNUs.” SEIA argues that the same principles should be applied to merchant projects that wish to interconnect in TPD option zones without reimbursement.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

SEIA supports the extended timeline for Track 3 and urges the ISO to provide stakeholders with a timeline and begin these discussions as soon as possible. SEIA also asks that Track 3 include consideration of the likely issue that TPD levels differ between interconnection request intake and TPD allocation, and how projects will be treated when this issue arises.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

As outlined below, the Six Cities support or do not oppose the proposals included in the Final Proposal, and thank the CAISO for its efforts to engage with a large number of stakeholders to address a wide range of policy issues and concerns throughout this initiative process.  The Six Cities are hopeful that the reforms included in the Final Proposal will lead to a streamlined interconnection process that will enable more efficient and timely interconnection of resources.  The Six Cities provide below a limited set of comments on discrete elements of the Final Proposal. 

Section 2.1 – The Zonal Approach: Data Accessibility

The Six Cities support the Final Proposal’s reliance on transmission zones for purposes of identifying locations where transmission capability is either available or planned to accommodate additional resource interconnections.  The Six Cities’ support for this element of the proposal is contingent upon the CAISO fulfilling its commitment to coordinate with non-CPUC jurisdictional entities, such as the members of the Six Cities, to determine approved resources in their Integrated Resource Plans to include in the CAISO’s annual Transmission Planning Process (“TPP”).  As a part of the implementation phase for this initiative, and as a part of the 2024-25 TPP, the Six Cities request more information about how and what steps the CAISO will take to ensure that the Cities’ IRPs are reflected in the transmission planning studies in a way that is comparable to the inputs and assumptions provided by the CPUC.  The Six Cities have requested this information throughout this initiative, and, while the CAISO has pledged its commitment to coordination, it has not provided any details concerning how this coordination will take place.  The Six Cities are concerned that, without documented specifics, the CAISO’s approach may be ad hoc and might not fully address the interconnection and transmission planning issues necessary to meet the resource needs of non-CPUC jurisdictional entities.  The Six Cities are prepared to meet with the CAISO in order to discuss approaches to integration of non-CPUC planning materials into the transmission and interconnection studies. 

As discussed during the April 4^th stakeholder meeting, it would be beneficial for the CAISO to hold one or more workshops focused on review of the zones, constraints within zones, and the various documents the CAISO intends to provide so that stakeholders understand how to identify areas of the grid where there is existing and planned capacity and can therefore attempt to site resources efficiently.

Section 2.5.1 – Scoring Criteria for Prioritization to the Study Process

The Six Cities identified several concerns with the scoring criteria in the Draft Final Proposal, and are pleased to see that the CAISO has taken steps to address these concerns in a way that makes the scoring criteria, including the load-serving entity (“LSE”) interest element, more workable, especially for smaller LSEs.  The Six Cities believe that it is critical to reflect the LSE interest component in the criteria, given that LSEs, acting under the authority of their respective local regulatory authorities (“LRAs”) are primarily responsible for engaging in resource procurement for energy and capacity products.  As such, LSEs, especially non-California Public Utility Commission (“CPUC”) jurisdictional LSEs, must have the ability to reflect in the prioritization process projects that have been identified as meeting their policy goals and reliability needs. 

While the Six Cities continue to have reservations about how the proposal to allocate transmission capacity points to LSEs based on load ratio shares will work in practice, the Six Cities believe that the Final Proposal includes provisions that are designed to address the concerns of smaller LSEs.  First, the Six Cities understand that the CAISO intends to permit LSEs to coordinate with one another to aggregate points for projects that are being developed on a joint or coordinated basis, and the Six Cities support this application of the scoring rules. 

Second, the full allocation election is an option that is available to LSEs that have an interest in a single, specific project.  The Six Cities understand that the CAISO no longer intends to restrict the application of this election to projects that represent 150% of the LSE’s individual capacity allocation in a cycle, a change that the Six Cities view as critical to the viability of this option.  During the April 4^th stakeholder meeting, a commenter posed a hypothetical that involved an LSE using the full allocation election to support prioritization of a 1000 MW project.  While the Six Cities do not agree that this is a particularly realistic scenario or that LSEs have reason to “game” this option to advance disproportionately large projects, the Six Cities are not opposed to the CAISO considering adoption of reasonable, qualitative restrictions on the use of the full allocation election in the future.  The Six Cities encourage the CAISO to monitor the use of the full allocation election and to consider adding restrictions only if they are needed. 

Third, the Six Cities support the CAISO’s increase in the limits on LSE-owned projects for purposes of the LSE transmission capacity points allocation.  While the Six Cities continue to believe that the concerns underpinning any restriction on LSEs’ abilities to allocate points to their own projects are misplaced, as a practical matter, it appears unlikely based on past practice that any individual LSE would be seeking to advance more than three projects (and/or more than 25% of the LSE’s capacity allocation) per cycle.  The Six Cities request that the CAISO clarify in its filing to FERC that it is not seeking to impose limitations on the legal authority of LRAs to engage in resource planning and procurement, consistent with good utility practice, including development by an LSE of its own internal resources, and that the restrictions in the Final Proposal relate solely to awarding LSE interest capacity points as a part of the scoring criteria in a single interconnection cycle.  Several of the Six Cities meet the needs of their loads with a combination of owned and contracted-for resources, and, as vertically integrated entities, the Cities are not subject to limitations under state law or federal open access policy on resource ownership, which remains within the purview of each of their LRAs.  The Six Cities request that the CAISO commit to revisiting this limitation in the future if it appears to be hampering resource development by LSEs. 

Fourth, the Six Cities share reservations about the CAISO’s proposal permitting non-LSE offtakers to award points to advance projects to interconnection studies, and more detail and examples appear to be needed.  There are a potentially unknown number of non-LSE offtakers, and the CAISO proposes only limited measures to ensure the legitimacy of these commercial arrangements.  It will be necessary to actively monitor the implementation of this aspect of the scoring criteria to ensure that it does not inappropriately limit opportunities for LSE procurement.

There are relatively few restrictions in the Final Proposal on which types of non-LSE entities are permitted to receive capacity points.  Who are the “commercial and industrial users” that can participate in this process?  Will a large chemical plant or data center be permitted to allocate the same number of points as a medium-sized office building or a small coffee shop?  As an example, could a grocery store located in the City of Banning allocate up to 25 points to a project, while the Electric Department for the City of Banning (which has RA obligations for more than 50 MWs of peak load) receives a capacity points allocation (based on load ratio share) of 10 MWs?  Or will the CAISO limit the ability of a non-LSE to allocate points to a proportional or corresponding MW share of a project?  What if the load of the commercial or industrial end-user has been factored into an LSE’s resource planning?  In short, this part of the proposed scoring criteria in the Final Proposal would benefit from added clarification.  If the CAISO intends to permit any commercial or industrial end-user with documented procurement goals, regardless of size, to allocate up to 25 points to a project, then the CAISO should revisit the concept of a floor on the minimum number of points that it will allocate to LSEs. 

Fifth, the Six Cities suggest that the CAISO commit to issuance of a report following the application of the scoring criteria to Cluster 15 to analyze if the policy changes in the Final Proposal achieved their intended objective or whether there are areas where improvement or clarification may be appropriate.

Finally, the Final Proposal addressed the concept of CPUC-jurisdictional LSEs potentially considering tariff modifications or other measures to establish procedures for allocation of LSE interest points.  The Cities note that, as public agencies, each City has its own rules and requirements relating to procurement of goods and services, and any power purchase agreements or resource development would take place under the oversight of their respective City Councils and public utility boards and applicable procurement policies.  The Cities do not perceive a need to revise these processes to be specific to the allocation of LSE interest points at this time, but understand the CAISO to be advising that LRAs will need to make this determination for the LSEs that they regulate. 

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

At this time, the Six Cities have not identified concerns with the proposed timing for Track 3 of this stakeholder process. 

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

N/A

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

SCE commends the CAISO for its visionary leadership in navigating stakeholders through a lengthy 2023 IPE Track 2 policy initiative to reach the current Final Proposal stage. SCE supports the overall proposed reforms in 2023 IPE Track 2 to establish a new process for evaluating and advancing interconnection applications that best align with resource planning, transmission availability, and procurement.  SCE provides the following comments on certain sections of the CAISO’s Final Proposal and requests the CAISO provide clarifying language for each of the following topics in the CAISO’s 2023 IPE Track 2 draft tariff language:

Cluster 15 Intake Process and Schedule

CAISO indicates it plans to submit, as part of its FERC Order No. 2023-A compliance filing, a timeline for the Cluster 15 intake process which includes all interconnection request scoring information being due to the CAISO by December 1, 2024.  Further, the CAISO proposes that all LSE project selection information be due to the CAISO by December 11, 2024.[1]  SCE is concerned the proposed ten-calendar day window, after all interconnection request scoring information has been submitted on December 1, 2024, is insufficient for LSEs to submit all project selection information. CAISO seems to suggest this same 10-calendar day window will apply to clusters beyond QC 15[2]. As applicable to QC 15, and clusters beyond if such is CAISO’s intent, SCE requests the CAISO allow 15 business days after the deadline for completion of interconnection requests with no opportunity to cure or the close of the interconnection request window for LSEs to submit their project selection information.

LSE Allocation Process

(1) Commercial Interest – LSE Allocation Process[3]

• “The ISO notes that FERC-jurisdictional entities may need to modify their tariffs to provide processes that award points in a just and reasonable manner. The ISO defers to them on that issue and how they award points or publish the information.”

(2) Limits on LSE-owned projects in the LSE allocation process[4]

• “FERC jurisdictional LSEs, in particular, should consider updating their tariffs to establish clear and fair processes for allocating points.”

SCE respectfully disagrees with the above two CAISO suggestions that “FERC jurisdictional entities” and “FERC-jurisdictional LSEs” [5] may need to modify their tariffs to provide processes that award points in a just and reasonable manner.  SCE believes the first step in the two-step LSE capacity allocation process involves the CAISO filing at FERC proposed tariff revisions to its GIDAP, which describe how the initial CAISO capacity (MW) allocation to LSEs on a relative load share basis is just and reasonable and non-discriminatory. Once the capacity allocations have been transferred to LSEs, there is no need for LSEs to update any tariff regarding how the LSEs will allocate their respective share of points. In the case of SCE, the CPUC has regulatory oversight of our procurement activities and provides existing guardrails to ensure there is no inappropriate, unfair, discriminatory, unjust, unreasonable, and/or preferential behavior in SCE’s procurement activities. To achieve a fair and consistent LSE allocation process, SCE believes the criteria and description regarding on what basis an LSE will allocate capacity/points should be contained in the issuance of either a Request for Interest (RFI) or a formal Request for Offer (RFO) prior to the allocation of points/capacity to a particular resource.

Regarding how LSEs will communicate their commercial interest to the CAISO, the CAISO indicates that they will provide a standard form for LSEs to use in submitting their project capacity selections. SCE seeks to clarify and confirm that the CAISO will provide LSEs with information that will enable LSEs to clearly identify projects and validate key interconnection parameters. This will ensure LSEs can match projects that have submitted interconnection requests to the CAISO with projects they are planning to allocate points to. Data to be transmitted to LSEs should include all information contained in the current public queue cluster report, including but not limited to, project name, project unique identifier (such as QC#), location, point of interconnection, capacity requested, technology, and requested online date. SCE further seeks confirmation that the window given to LSEs after the close of the interconnection request window will start once the CAISO has provided this information.

Limits on LSE-Owned Projects in the LSE Allocation Process

“To avoid preferential treatment of LSE-owned resources in the LSE allocation process, the ISO proposes that in each LSE allocation cycle (each cluster) LSEs may only award capacity to either three self-build projects or 25% of the LSE’s capacity allocation per cycle, whichever is greater.”[6]

SCE appreciates the CAISO revising its prior proposal to limit LSE-owned resources in the LSE allocation process from one project per cycle to either three self-build projects or 25% of the LSE’s capacity allocation per cycle, whichever is greater. This updated proposal more accurately captures SCE’s procurement experience in recent years. For clarity, SCE recommends the CAISO’s 2023 IPE Track 2 draft tariff language reflect the following:

 “To avoid preferential treatment of LSE-owned resources in the LSE allocation process, the ISO proposes that in each LSE allocation cycle (each cluster) LSEs may only award capacity to either three self-build projects or 25% of the LSE’s capacity allocation per cycle, whichever provide the greater capacity.”

This addition is intended to clarify how the determination will be reached on “whichever is greater” between a number of projects (i.e., three) versus an allocation of capacity (i.e., 25% of the LSE’s capacity allocation).

Criteria for Energy Only Projects in Non-Reimbursement Zones

SCE understands the CAISO's proposal to be that there would be no ceiling on the number or capacity of Energy Only (EO) projects seeking to be studied in non-reimbursement zones.  SCE believes a cap should be placed on the study of such EO projects seeking interconnection in non-reimbursement zones. SCE is concerned this could potentially cause a strain on PTO resources who perform the studies and divert the study focus away from Full Capacity Deliverability Status (FCDS) and EO projects seeking to interconnect in zones where the CPUC’s resource portfolios have identified needs.  As a further reason to implement a cap on the study of EO projects seeking to interconnect in non-reimbursement zones, SCE is not aware of any developers who have opted for Option B (i.e., developer-funded upgrades) under the current GIDAP rules.  SCE requests the CAISO provide clarifying language in its 2023 IPE Track 2 draft tariff language that EO projects in non-reimbursement zones still must meet a minimum threshold of commercial viability criteria to prevent speculative projects from impeding viable projects that align with the CPUC resource portfolio.

[1] 2023 IPE Track 2 Final Proposal, p. 42.

[2] Ibid., p. 57. – “The ISO proposes to require LSEs to provide the ISO with their elections no later than ten calendar days after the close of the interconnection request window.”

[3] ibid., p. 48.

[4] ibid., p. 60.

[5] SCE is not clear on what the CAISO intends to mean by “FERC-jurisdictional LSE” and would appreciate the CAISO providing a clarification for this term. SCE’s LSE procurement activities are regulated by the CPUC.  Most, if not all, LSEs are regulated by the CPUC or a local regulatory agency, not FERC.  SCE’s FERC-jurisdictional tariffs include its Transmission Owner Tariff (TOT) and Wholesale Distribution Access Tariff (WDAT), which are both resource interconnection tariffs (i.e., not appropriate for capturing LSE procurement activities).

[6] Ibid, p. 60.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

SCE supports extending the 2023 IPE Track 3 initiative timeline by targeting the October 3, 2024, CAISO Board of Governors meeting for decision. It is SCE’s understanding there are no scheduled Board of Governors meetings in August and September. To seek a Track 3 decision from the CAISO Board at its July 18, 2024, meeting, the Track 3 initiative would need to commence immediately, overlapping Track 2 before it is finalized at the expected May 2024 CAISO Board meeting, with uncertainty regarding whether multiple white papers on Track 3 can be posted within such a compressed timeline. With the CAISO’s Order 2023-A compliance filing, 2023 IPE tariff filing, and PTO's Wholesale Distribution Access Tariff (WDAT) FERC Order 2023-A compliance filings all pending, there is no need to rush to start Track 3. The extension of approximately three months from July to October for seeking CAISO Board approval of Track 3 should allow sufficient time for more thoughtful consideration and vetting of the deliverability allocation-related issues and would still allow sufficient time for implementation of the new deliverability allocation rules to Cluster 15 in 2025.  

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Terra-Gen, LLC (Terra-Gen) appreciates the opportunity to provide comments on the 2023 Interconnection Process Enhancements Track 2 Final proposal.

Terra-Gen is opposed to CAISO’s IPE 2023 Track 2 final proposal framework.

Terra-Gen continues to express concerns with the impacts of the overall framework on the ability for independent developers to receive fair treatment and appropriate opportunities to be studied through the CAISO’s interconnection process if the CAISO’s final proposal framework revisions are implemented in its current form.

Terra-Gen requests that CAISO further consider stakeholder opposition to specific elements of its proposal, as detailed below. Terra-Gen also criticizes the lack of evaluation and discussion by CAISO regarding proposals from stakeholders to study a reasonable volume of generation interconnection capacity in each study zone based on Interconnection Requests (IR) applications.

We specifically highlight our strong opposition to the Load Serving Entity (LSE) interest element of its scoring criteria commercial interest category, which will result in LSEs having undue influence over the ability of independent developers to receive fair opportunities for IRs to be studied.

Terra-Gen remains concerned about certain aspects of the proposal that could potentially exacerbate existing issues. Specifically, we highlight that the proposed study process might prioritize factors other than essential elements like transmission upgrade costs and timelines, which could lead to subjective decision-making by LSEs becoming an oversized influence on IR outcomes. This subjectivity could introduce arbitrary and anti-competitive behavior, likely impacting the economic viability of many projects.

In terms of the scoring criteria proposal element, Terra-Gen criticizes the disproportionate weight proposed to be provided to LSE interest in the commercial interest category.  We are concerned this proposal element could lead to unfair outcomes, especially for Cluster 15 projects. We continue to recommend further reducing the weight of LSE preference points and revisiting certain restrictions on non-LSE interest to ensure fairness and transparency in project selection.

Regarding the terminology and framework used in the proposal, Terra-Gen urges CAISO to provide clearer definitions of terms used in its Zonal Approach proposal element. Specifically, the terms "zones" and "constraints" and how they will be used in CAISO’s implementation of the proposal should be clarified to avoid confusion. 

Overall, Terra-Gen reiterates and emphasizes the need for greater transparency, fairness, and flexibility in the proposed interconnection process to avoid anti-competitive behavior, promote project viability, and ultimately benefit electricity consumers and the state's electrification goals.

Terra-Gen provides more specific feedback regarding its concerns related to elements of the CAISO proposal below.

Scoring Criteria Screening Proposal: Commercial Interest and LSE Point Allocation

Terra-Gen continues to express strong opposition to CAISO’s proposal for commercial interest withing the scoring criteria element of the framework for screening IRs. The commercial interest category essentially provides LSEs with the exclusive ability to determine which interconnection request are studied.

Terra-Gen is very concerned with this element of the CAISO proposal and believes that the scoring criteria concept remains unfairly skewed towards LSE interests, potentially excluding highly viable projects from the study process. Despite repeated insistence by CAISO that its reliance on the December 2022 Memorandum of Understanding (MOU) is appropriate justification to design its proposal to rely on LSE interest points, Terra-Gen notes that the MOU does not specifically mention the need to prioritize specific LSE interests. Terra-Gen and other stakeholders have indicated that LSE interests are already integrated into the process through the CPUC's Integrated Resource Planning (IRP) Process, which informs transmission planning conducted by CAISO but concerns of duplicative preference for LSE interest have been largely dismissed by CAISO throughout this process. The inclusion of LSE interests as an additional screen to IR applications duplicates processes already established through the IRP process unjustly.

Additionally, Terra-Gen expresses concerns about the lack of clarity surrounding how LSEs will allocate points to projects. We believe that this process is subjective and potentially discriminatory and allowing LSEs to exert significant influence over project selection at the early stage of IR intake is inappropriate, especially considering that developers may not have access to crucial information such as online dates or interconnection costs. Terra-Gen emphasizes that developers are best positioned to assess and bear the risks associated with project development.

Terra-Gen emphasizes that while the final proposal delineates CAISO's method of allocating points to individual LSEs, it remains silent on a critical aspect of the scoring criteria: how LSEs will allocate points to projects in a transparent, fair, and unbiased manner. CAISO delegates the development of the point allocation process to individual LSEs but FERC jurisdictional LSEs themselves have expressed concerns about expanding their individual open access transmission tariffs to accommodate this new responsibility. CAISO staff also acknowledged concerns that not all LSEs may be closely engaged in the IPE 2023 Track 2 initiative and may be unaware of these new responsibilities.

The absence of clear rules governing LSE allocation in the commercial interest category results in an increase in the weighting given to LSEs, amounting to 65% of the total scoring criteria. System need points may be granted to an interconnection request capable of providing local resource adequacy or long lead-time resources. Given that LSEs have procurement obligations for both local resource adequacy and long lead-time resources, they may not need to allocate points in the commercial interest bucket to projects receiving points from the system need bucket. Consequently, this will allow LSEs an outsized influence to differentiate projects compared to the actions project developers can undertake to demonstrate and obtain a higher score.

Considering that the scoring criteria outlined in the final proposal does not offer project developers sufficient controllable factors to differentiate the viability of their projects and the process by which LSEs will award interconnection requests commercial interest points remains undefined, CAISO cannot apply the scoring criteria to Cluster 15. Terra-Gen recommends that, at minimum, CAISO should postpone finalizing its proposal and carefully consider additional or alternative elements to incorporate into the scoring criteria to enhance project developers' control in demonstrating why their IRs should be chosen for study. Terra-Gen requests the CAISO amend its proposal with an addendum to is final proposal to remove the commercial interest category from the scoring criteria and advises CAISO to explore refinements based on stakeholder suggestions made early in the IPE process. For example, Terra-Gen suggests considering criteria for project entry, such as Order 2023 requirements, and increasing commercial viability requirements, deposits, and withdrawal penalties as projects progress through the study process. While this approach may result in studying a larger number of projects initially, Terra-Gen believes it would better align with the development process and increase project viability as more information becomes available during the interconnection process.

Terra-Gen is also notably concerned that the CAISO’s proposal to allow LSEs to allocate points to their own self-build projects for up to three projects or 25% of their capacity essentially guarantees that any LSE self-build projects will be studied whereas independent developers will need to compete for a limited pool of remaining LSE points which is anti-competitive and may result in potentially discriminatory outcomes. However, if CAISO decides to maintain the Commercial Interest element for Cluster 15, measures should be taken to ensure that the most viable projects in Cluster 15 are adequately studied. Terra-Gen suggests that this could involve reducing the weight of LSE/non-LSE preference points to 10% (10 points), limiting the LSEs' ability to designate self-build projects to one or two projects, or a lower portion of their point total, and reinstating the 150% of need limit for LSEs using the Full Allocation option, or at least excluding the capacity beyond 150% of their points allocation toward the zonal 150% capacity limit.

Zonal Study Framework

During the stakeholder process, CAISO has emphasized that the proposed changes to the interconnection request intake process are aligned with transmission zones consistent with the December 2022 MOU between the CAISO, CPUC, and CEC. CAISO has consistently relied upon the existence of this MOU to inform modifications to its interconnection process. However, it has become evident that the proposed changes will not be implemented at a zonal level but rather based on individual area deliverability constraints. CAISO must use more precise language in its proposal, and any forthcoming tariff filing, as well as its future documentation regarding the terms "zonal" and "constraint" in the context of the supposed zonal framework it has proposed.

CAISO has confirmed that the scoring criteria will be applied by constraint, which is significantly more granular than a zonal approach. This includes aspects such as the 150% study limit, the application of the DFAX, and the potential auction tie-breaker mechanism, that would be applied on a constraint level. CAISO also mentioned that the 50 MW threshold to determine if interconnection requests can elect the merchant deliverability option was calculated by zone. Upon reviewing the available transmission deliverability provided in the Constraint Mapping with Transmission Plan Deliverability Allocated Excel spreadsheet posted on the initiative website, it appears that the 50MW threshold is more applicable to a given constraint than a transmission zone. CAISO should clarify if the 50 MW threshold applies to the constraint or the sum of transmission constraints' capabilities for a given transmission zone. Terra-Gen notes that if it applies by transmission zone, there will be very little opportunity for an interconnection request to be studied under the merchant deliverability option.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

Terra-Gen recommends that CAISO delay the Track 2 process to allow for further refinement and consideration of suggested alternatives to address the major concerns noted above.  CAISO should take the time necessary to ensure its proposal adequately reflects the independent developers input and concerns. This approach would be responsive to the serious concerns that many stakeholders have raised and allow for more time to vet alternative options, as well as continue to discuss the Track 3 elements focused on the TPD allocation process.  This is the only acceptable option that should be pursued because of the inherent linkages between the Track 2 and Track 3 elements, specifically, the TPD allocation process outcomes being necessary inputs into the resulting deliverability availability that will be a key input into the proposed IR modifications for the proposed zonal study process and 150% zonal limitation.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

Please see attached.  

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

Please see attached.  

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.

Please see attached.  

1. Please provide your organization's comments on the Interconnection Process Enhancements (IPE) 2023 Track 2 Final Proposal:

Please specify which section of the proposal your comments address.

While Vistra is open to a set of interconnection reforms that adopt “transformational change”, it is paramount that those reforms do not unfairly preference utility developers over non-utility developers. Vistra appreciates the work performed by the team to arrive at the proposal, however the set of proposals on Interconnection Request (IR) intake introduce significant open access and undue discrimination concerns. It is important that the CAISO advance the queue management proposals ready for approval and expected to provide practical benefits. It is equally as important that CAISO remove from this proposal the scoring criteria scope that will risk the success of the interconnection request intake proposals subject to scrutiny by the CAISO Board of Governors as well as FERC.

Vistra opposes the package of proposals put forward by CAISO in Section 2, Interconnection Request Intake. The proposed approach in its entirety adopts processes that would limit open access to the transmission system by affording preference to the interconnection process to load serving entities also acting as developers. CAISO has made significant changes from the last iteration that further skews this preference in the direction of utility-preference. In addition to the inherent preference to utility developers incorporated in this set of proposals on interconnection screening, there are also elements that have not been sufficiently developed or vetted by stakeholders.

The two main areas of concern are in Section 2:

• Proposal should consistently apply constraint approach instead of selectively proposing constraint versus zonal approach: CAISO’s proposal refers to a zonal approach; however, it is clear the CAISO is not proposing a zonal approach for screening. Instead, the CAISO proposes a constraint approach where Interconnection Requests (IR) at each Point of Interconnection (POI) would be evaluated against the POI’s effectiveness to the most limiting area deliverability constraint. CAISO should move away from the “zonal” language and be clear it is adopting a constraint approach that should be applied consistently. For example, in Section 2.4.1, CAISO applies this constraint approach to the 150% of the most limiting constraint to the POI for interconnection screening, but then toggles, in Section 2.5.4, to seemingly propose that an entire transmission zone preclude merchant options if any constraint within that transmission zone has less than 50 MW of deliverability available. Instead, CAISO should also apply this distinction at the POI and use the most limiting constraint effective to the POI to designate a POI eligible for TPD option versus the merchant option.

• Proposal should remove the scoring criteria in Section 2.5.1 as it creates a set of procedures that will systematically preference utility developers over non-utility developers: CAISO’s scoring criteria adopts a framework that will result in Load Serving Entities being able to allocate points to interconnection requests to move its preferred projects up the ranking and ensure its projects will have first priority access to the interconnection process, and consequently the transmission system. This violates non-discriminatory, open access principles. Importantly, the scoring criteria step is also not needed to further reduce projects within the 150% of constraint, because CAISO proposal includes an auction that would allow prioritizing projects based on the project’s competitiveness. This auction approach is additional to the already limiting screening due to FERC Order 2023’s site control requirements and increased study deposits. Vistra requests the CAISO remove the scoring criteria from the final proposal for Track 2 that will apply to Cluster 15. If the CAISO continues to believe an additional procedure is needed prior to the auction, we recommend that a future track of Interconnection Process Enhancements can continue to explore a competitive, non-discriminatory approach that fairly balances access between utility and non-utility developers that could apply to Cluster 16. Vistra incorporates by reference our prior comments detailing our concerns with the scoring approach that affords outsized utility preference to accessing the interconnection process.

2. Provide your organization's feedback on the proposed timeline for Track 3 of the IPE 2023 initiative, which focuses on the Transmission Plan Deliverability Allocation process:

The ISO would like your feedback on extending the initiative timeline by targeting the October 3, 2024 ISO Board of Governors meeting for decision.

Vistra supports the deferral of Transmission Plan Deliverability allocation process changes to Track 3, and reserves judgement on whether the proposal is ready to be advanced to the Board by October 2024 depending on the developments in Track 3.

3. The ISO is seeking stakeholder feedback on the effectiveness of its recently adopted working group process and its overall contributions to the IPE 2023 proposal development process. We would greatly appreciate your responses to the following survey by end of day April 18, 2024: https://www.surveymonkey.com/r/YHWNWC2

Please leave the below text box blank. All responses to the survey will be kept anonymous.