{"document":{"slug":"answer-el26-71-morongo","title":"Answer of Morongo Transmission LLC: no tariff amendment required, a non-load-serving participating transmission owner","issued":"2026-08-12","accession":"20260812-5158","docket":"EL26-71-000","group":"Six large-load show-cause orders, one per RTO/ISO","filer":"Morongo Transmission","kind":"answer to order to show cause","file":"sources/originals/20260812-5158_Morongo Transmission - PTO OSC Answer.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20260812-5158","sha256":"2446f4cf733f6ec9fe8e375c3b6293aa1d25019d8043406b0b1fc87bb1e7dfa3","pages":6,"tokens":1339,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":222,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \nCalifornia Independent System Operator Corporation \nCitizen S-Line Transmission LLC  \nCitizens Sunrise Transmission LLC  \nCitizens Sycamore-Penasquitos Transmission LLC  \nCity of Anaheim, California  \nCity of Azusa, California  \nCity of Banning, California  \nCity of Colton, California  \nCity of Pasadena, California  \nCity of Riverside, California \nDCR Transmission, L.L.C.  \nDesertLink, LLC  \nGridLiance West LLC  \nHorizon West Transmission, LLC \nLS Power Grid California, LLC  \nMorongo Transmission LLC  \nPacific Gas and Electric Company  \nSan Diego Gas & Electric Company  \nSouthern California Edison Company  \nStartrans IO, L.L.C.  \nSunZia Transmission, LLC  \nTrans Bay Cable LLC  \nValley Electric Association, Inc.  \nViridon Path 15, LLC  \nWestern Area Power Administration \n \n \n \n       \n \n \n    \n \n \n \n   Docket No. EL26-71-000 \n \nANSWER OF MORONGO TRANSMISSION LLC \n \nMorongo Transmission LLC (“Morongo Transmission”) submits this answer pursuant to \nRules 206 and 213 of the Federal Energy Regulatory Commission’s (“Commission”) Rules of \nPractice and Procedure in response to the Commission’s Order to Show Cause in the above-\ncaptioned proceeding.1  Morongo Transmission respectfully submits that no amendments to its \ntariff are required in response to the Order to Show Cause because Morongo Transmission is a \n \n1 18 C.F.R. §§ 385.206(f), 385.213(a); Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 at P 3 (2026) \n(“CAISO”) (directing Participating Transmission Owners to respond to the Order to Show Cause)."},{"page":2,"startToken":222,"endToken":488,"text":"2 \nnon-load-serving Participating Transmission Owner under the California Independent System \nOperator (“CAISO”) tariff with no end-use customers.  Morongo Transmission nevertheless \nintends to continue participating as a party in this proceeding due to the numerous important issues \nraised in the Order to Show Cause, including resource adequacy and large load interconnection \nreform. \nI. \nDESCRIPTION OF MORONGO TRANSMISSION \n \nMorongo Transmission is a Participating Transmission Owner in CAISO.  It is wholly \nowned by the Morongo Band of Mission Indians (“Tribe”), a federally recognized American \nIndian Tribe exercising jurisdiction over the Morongo Indian Reservation (“Reservation”), which \nspans roughly 40,000 acres in the San Gorgonio Pass, near Banning, California.  Morongo \nTransmission holds a 30-year lease of a portion of the transfer capability of Southern California \nEdison Company’s (“SCE”) upgraded West of Devers transmission facilities, which cross the \nTribe’s Reservation. 2  Morongo Transmission recovers its transmission revenue requirement \nthrough a Commission-approved formula rate under its tariff (“Morongo Tariff”), paid by \nCAISO’s collection of Transmission Access Charge (“TAC”) rates.3  \nII. \nANSWER OF MORONGO TRANSMISSION \n \nMorongo Transmission respectfully submits that the Morongo Tariff is just and reasonable \nand that no amendment is required in response to the issues identified in the Commission’s Order \n \n2 Morongo Transmission LLC, Docket No. ER21-669-000, Transmittal Letter (Dec. 17, 2020) (“Morongo \nTransmittal Letter”); Morongo Transmission LLC, 178 FERC ¶ 61,062 at P 5 (2022) (approving \nuncontested settlement establishing transmission revenue requirement for Morongo Transmission). \n3 E.g., Morongo Transmission LLC, Docket No. ER26-642-000 (Jan. 23, 2026) (delegated order) (accepting \nrevisions to the Morongo Tariff reflecting updates to annual operating cost revenue requirement); Morongo \nTransmittal Letter at 2."},{"page":3,"startToken":488,"endToken":806,"text":"3 \nto Show Cause.  In this proceeding, the Commission has preliminarily ordered CAISO to reform \nits tariff to take jurisdiction over, and facilitate, interconnection of large loads, including by: \n• Developing an efficient application and study process for Eligible Customers seeking \ntransmission service for large loads; \n• Increasing transparency regarding network upgrade costs to provide transmission service \nfor large loads, establishing mechanisms to mitigate cost shifting to other transmission \ncustomers, and creating a pro forma cost recovery agreement between CAISO, the relevant \ntransmission owner, and the Eligible Customer; \n• Developing new transmission services to accommodate flexible large loads willing to \naccept interruptible service and/or contracts for less than their peak demand; and \n• Developing processes to efficiently study generation facilities serving electrically \nproximate large loads (i.e., not more than two substations apart) or co-located large loads, \nwith the goal of avoiding unnecessary network upgrades.4 \n \nThese areas of reform do not implicate the Morongo Tariff, which expressly provides that \n“Morongo Transmission LLC is a Non-Load-Serving Participating [Transmission Owner] and has \nno End-Use Customers.”5  This language reflects the arrangement between Morongo Transmission \nand SCE, where Morongo Transmission holds a 30-year lease of a portion of the transfer capability \nof SCE’s West of Devers line across the Tribe’s Reservation.6  The Morongo Tariff is therefore \ndifferent from the tariffs of other CAISO Participating Transmission Owners that do serve load \nand have end-use customers and whose tariffs may be subject to the Order to Show Cause. \n \nFurthermore, the Morongo Tariff provides that the tariff provisions governing the load \ninterconnection process—Section Eight (Obligation to Interconnect or Construct Transmission \nExpansions and Facility Upgrades), Section Nine (Expansion Process (including the study process \nfor necessary facilities)), and Section Ten (Interconnection Process)—“shall be superseded by the \n \n4 CAISO, 195 FERC ¶ 61,214 at P 3.  \n5 Morongo Transmission LLC Transmission Owner Tariff (“Morongo Tariff”) § 1 (May 15, 2021) \n(emphases added). \n6 See Part I, supra."},{"page":4,"startToken":806,"endToken":1144,"text":"4 \ncorresponding sections of the TO Tariff of Southern California Edison.”7  Thus to the extent that \namendments to the Participating Transmission Owners’ tariffs are necessary to implement large \nload interconnection reforms to CAISO’s tariff in response to the Order to Show Cause,8 SCE \ncould implement those reforms to its own tariff without Morongo Transmission needing to take \nfurther action to amend the Morongo Tariff.9  The Morongo Tariff thus will not be impacted by \nreforms facilitating interconnections of large loads.  However, to the extent that the Commission \ndetermines any residual or conforming amendments are required to the Morongo Tariff, Morongo \nTransmission will make compliance filings as directed. \n \nThe Order to Show Cause nonetheless targets a range of issues of great importance to \nMorongo Transmission and the Tribe, including resource adequacy and reform of large load \ninterconnection processes.  These topics are significant to Morongo Transmission and the Tribe as \nthey work to expand economic opportunity on the Reservation while ensuring affordable and \nreliable electricity for the Tribe’s members.  Morongo Transmission accordingly looks forward to \ncontinuing to participate as a party in this proceeding and assisting the Commission as it weighs \nthese important matters—in keeping with Order No. 1920’s recognition of the critical role that \nfederally recognized Tribes play in developing policies affecting the interstate transmission grid.10  \nIII. \nSERVICE, COMMUNICATIONS, AND CORRESPONDENCE \nMorongo Transmission requests that the persons listed below be included on the official \n \n7 Morongo Tariff § 16.12 (cross-referencing Sections 8, 9, and 10).  \n8 See CAISO, 195 FERC ¶ 61,214 at P 3.   \n9 Southern California Edison Transmission Owner Tariff §§ 8-10 (effective May 1, 2019). \n10 Bldg. for the Future Through Elec. Reg’l Transmission Planning and Cost Allocation, Order No. 1920, \n187 FERC ¶ 61,068 at PP 409, 482, 528 (2024), on reh’g, Order No. 1920-A, 189 FERC ¶ 61,126 (2024), \nreh’g denied, Order No. 1920-B, 191 FERC ¶ 61,026 (2025); see also CAISO, Tribal Engagement on Long-\nterm Transmission Planning 67 (Apr. 9, 2026), https://www.caiso.com/documents/presentation-tribal-\nengagement-on-long-term-transmission-planning-apr-09-2026.pdf."},{"page":5,"startToken":1144,"endToken":1301,"text":"5 \nservice list for this proceeding, and respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) to \npermit the designation of more than two persons upon whom service is to be made in this \nproceeding. \nSam Cohen \nChief Legal Officer \nMORONGO TRANSMISSION LLC \n12700 Pumarra Road \nBanning, CA 92220 \n(909) 454-4515 \nscohen@morongo-nsn.gov \n \nMax Spivak \nMORONGO BAND OF MISSION INDIANS \n12700 Pumarra Road \nBanning, CA 92220 \n(951) 755-5122 \nmorongotransmissionllc@morongo-nsn.gov \n \nSuedeen G. Kelly \nJENNER & BLOCK LLP \n1099 New York Avenue NW, Suite 900 \nWashington, DC 20001 \n(202) 639-6055 \nSKelly@jenner.com \n \nIV. \nCONCLUSION \n \nFor the reasons given above, the Morongo Tariff is just and reasonable and does not require \namendment in light of the Order to Show Cause. \n \nRespectfully submitted, \n \n/s/ Sam Cohen  \n \n \nSam Cohen \nChief Legal Officer \nMORONGO TRANSMISSION LLC \n12700 Pumarra Road \nBanning, CA 92220 \n(909) 454-4515 \nscohen@morongo-nsn.gov \n \nOn behalf of Morongo Transmission LLC \n \n \nDated: August 12, 2026"},{"page":6,"startToken":1301,"endToken":1339,"text":"CERTIFICATE OF SERVICE \n \n \nI certify that, on August 12, 2026, I served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding.  \n \n/s/ Suedeen G. Kelly  \n \n \n \n \n \n \n \n \n \nSuedeen G. Kelly"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":389,"startToken":0,"endToken":273},{"p":2,"at":389,"title":"I. DESCRIPTION OF MORONGO TRANSMISSION","method":"printed heading","endPage":2,"endAt":1229,"startToken":273,"endToken":386},{"p":2,"at":1229,"title":"II. ANSWER OF MORONGO TRANSMISSION","method":"printed heading","endPage":4,"endAt":1493,"startToken":386,"endToken":1025},{"p":4,"at":1493,"title":"III. SERVICE, COMMUNICATIONS, AND CORRESPONDENCE","method":"printed heading","endPage":5,"endAt":619,"startToken":1025,"endToken":1240},{"p":5,"at":619,"title":"IV. CONCLUSION","method":"printed heading","endPage":5,"endAt":624,"startToken":1240,"endToken":1241},{"p":5,"at":624,"title":"CONCLUSION","method":"printed heading","endPage":6,"endAt":0,"startToken":1241,"endToken":1301},{"p":6,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":6,"endAt":261,"startToken":1301,"endToken":1339}]}