- Docket
- EL26-71-000
- Item
- E-10
- Reporter cite
- 195 FERC ¶ 61,214
- Region
- California (+ WEIM footprint)
- Respondents
- CAISO + 24 Participating Transmission Owners
- Length
- 118 pages
Read the order PDF (committed copy) Official source on ferc.gov ↗
What is unique to CAISO
CAISO is the translation problem. It ‘does not offer traditional Order No. 888 network and point-to-point transmission services, offers no firm, long-term transmission reservations of capacity,’ and its Participating TOs (not CAISO itself) ‘play the lead role in managing the interconnection of load’ inside California’s state planning and forecasting processes. So E-10 gives CAISO an alternative no other order offers: either build equivalent large-load protections, or explain why its single daily service and Transmission Access Charge (TAC/RAC) framework already solves the same cost and reliability problems.
What FERC presses CAISO on
- Whether, given that CAISO does not offer Order No. 888 service, its existing framework already addresses the concerns — or what equivalent options it would create (p. 60).
- How load-addition study procedures and operational requirements would work when its Participating TOs, not CAISO, lead load interconnection.
Quoted directives, with page cites
Each quotation below is verbatim from the committed order text and links to the page it appears on. A test asserts every one of them against the extracted source.
-
Application / study process P 5
“the application process, study procedures, and ongoing operational requirements that apply to Eligible Customers seeking transmission service on behalf of large loads”
-
Alternative transmission technologies PP 152-153
“they lack clear and consistent provisions requiring the evaluation of alternative transmission technologies as potential solutions to accommodate an Eligible Customer’s request”
-
Cost-recovery agreement § III.B.3
“a pro forma cost recovery agreement between CAISO, the relevant transmission owner, and Eligible Customer … to mitigate the risk of cost shifting among transmission customers”
-
BTMG netting pp. 60-61
“it allows load with BTMG to net its BTMG against its load for purposes of calculating Regional Access Charges”
-
Service for flexible loads § III.D
“it does not include transmission services that reflect … flexible large loads that are willing and able to limit their use of the transmission system under certain conditions”
Region-specific findings
CAISO is the structural outlier: it ‘does not offer traditional Order No. 888 network and point-to-point transmission services, offers no firm, long-term transmission reservations of capacity, and does not provide a formal application process for transmission service.’ P 19
“does not offer traditional Order No. 888”
It offers only a single ‘daily’ service; all non-historical, non-wheeling energy is treated as ‘new firm use,’ and CAISO curtails on Tariff-defined scheduling priorities. pp. 17-18
“new firm use”
The Participating TOs ‘play the lead role in managing the interconnection of load’; CAISO’s own role is accounting for state-projected load in its Transmission Planning Process. p. 18
“play the lead role in managing the interconnection of load”
That planning process is tightly bound to California state processes — the CEC’s statewide demand forecast and the CPUC’s integrated resource plans. p. 18
“integrated resource plans”
Alternative compliance path no other order offers: CAISO may explain whether, ‘given that CAISO does not offer the transmission services required by Order No. 888,’ its framework already addresses the concerns. p. 60
“does not offer the transmission services required by Order No. 888”
Scheduling Coordinators submit bids or self-schedules for all Eligible Customers; CAISO dispatches the market with all available capacity and curtails on Tariff-defined scheduling priorities when capacity runs short. pp. 18
“Scheduling Coordinators represent”
Participating TOs recover upgrade costs through the Transmission Access Charge: a Local Access Charge for the local component, plus a region-wide Regional Access Charge — a ‘postage stamp’ rate divided by gross load and assessed to all market participants (the high-voltage facilities sit in the regional component, low-voltage in the local). pp. 19-20
“Regional Access Charge”
What the public comment record says about CAISO
7 of the RM26-4 record's public comments name-check CAISO specifically (1 support · 2 oppose · 0 mixed · 4 neutral). That's a floor, not a full count: only about 40% of the corpus carries a region tag at all, so a comment that discusses CAISO without the audit pass catching a region-specific mention won't appear here.
-
California Department of Water Resources State Water Project support
“If CAISO implements real-time load bidding, DWR can provide approximately 2,600 MW of available curtailable load, because the State Water Project's water pumping operations are curtailable in response to market signals.” p. 6
-
California Public Utilities Commission oppose
“adding this new layer of study processes would impact CAISO's recent interconnection process enhancements, approved by FERC last year, and their interaction with the CAISO Transmission Planning Process (TPP).” p. 15
-
California Independent System Operator Corporation neutral
“The longstanding approach of enabling transmission providers to propose tailored processes to meet regional needs under the independent entity standard will allow transmission providers to tailor their studies to ensure the orderly and timely interconnection of large loads.” p. 6
-
Fluence Energy oppose
“By artificially restricting regulation capacity to equal the inverter rating, CAISO is leaving 50% of the BESS resource's regulation capability unutilized, harming both resource economics and system efficiency.” p. 5
See all 7 comments about CAISO →
Section IV briefing questions
This order poses its briefing questions at page 75 of the committed PDF: open at § IV. The questions are templated across the six show cause orders; the full set, and what the public record says on each, is in the comment record.
Respondents named in the order
Citizen S-Line Transmission LLC · Citizens Sunrise Transmission LLC · Citizens Sycamore-Penasquitos Transmission LLC · City of Anaheim, California · City of Azusa, California · City of Banning, California · City of Colton, California · City of Pasadena, California · City of Riverside, California · DCR Transmission, L.L.C. · DesertLink, LLC · GridLiance West LLC · Horizon West Transmission, LLC · LS Power Grid California, LLC · Morongo Transmission LLC · Pacific Gas and Electric Company · San Diego Gas & Electric Company · Southern California Edison Company · Startrans IO, L.L.C. · SunZia Transmission, LLC · Trans Bay Cable LLC · Valley Electric Association, Inc. · Viridon Path 15, LLC · Western Area Power Administration
The other dockets
E-7 PJM · E-8 MISO · E-9 SPP · E-11 ISO-NE · E-12 NYISO · E-2 PJM
Return to the full briefing: the timeline, the five reform categories, the procedural clock, and the 273-comment RM26-4 record.