EL26-71-000 · 2026-08-12 · Morongo Transmission
Answer of Morongo Transmission LLC: no tariff amendment required, a non-load-serving participating transmission owner
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UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
California Independent System Operator Corporation
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
Docket No. EL26-71-000
ANSWER OF MORONGO TRANSMISSION LLC
Morongo Transmission LLC (“Morongo Transmission”) submits this answer pursuant to
Rules 206 and 213 of the Federal Energy Regulatory Commission’s (“Commission”) Rules of
Practice and Procedure in response to the Commission’s Order to Show Cause in the above-
captioned proceeding.1 Morongo Transmission respectfully submits that no amendments to its
tariff are required in response to the Order to Show Cause because Morongo Transmission is a
1 18 C.F.R. §§ 385.206(f), 385.213(a); Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 at P 3 (2026)
(“CAISO”) (directing Participating Transmission Owners to respond to the Order to Show Cause).PDF page 2
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non-load-serving Participating Transmission Owner under the California Independent System
Operator (“CAISO”) tariff with no end-use customers. Morongo Transmission nevertheless
intends to continue participating as a party in this proceeding due to the numerous important issues
raised in the Order to Show Cause, including resource adequacy and large load interconnection
reform.
I.
DESCRIPTION OF MORONGO TRANSMISSION
Morongo Transmission is a Participating Transmission Owner in CAISO. It is wholly
owned by the Morongo Band of Mission Indians (“Tribe”), a federally recognized American
Indian Tribe exercising jurisdiction over the Morongo Indian Reservation (“Reservation”), which
spans roughly 40,000 acres in the San Gorgonio Pass, near Banning, California. Morongo
Transmission holds a 30-year lease of a portion of the transfer capability of Southern California
Edison Company’s (“SCE”) upgraded West of Devers transmission facilities, which cross the
Tribe’s Reservation. 2 Morongo Transmission recovers its transmission revenue requirement
through a Commission-approved formula rate under its tariff (“Morongo Tariff”), paid by
CAISO’s collection of Transmission Access Charge (“TAC”) rates.3
II.
ANSWER OF MORONGO TRANSMISSION
Morongo Transmission respectfully submits that the Morongo Tariff is just and reasonable
and that no amendment is required in response to the issues identified in the Commission’s Order
2 Morongo Transmission LLC, Docket No. ER21-669-000, Transmittal Letter (Dec. 17, 2020) (“Morongo
Transmittal Letter”); Morongo Transmission LLC, 178 FERC ¶ 61,062 at P 5 (2022) (approving
uncontested settlement establishing transmission revenue requirement for Morongo Transmission).
3 E.g., Morongo Transmission LLC, Docket No. ER26-642-000 (Jan. 23, 2026) (delegated order) (accepting
revisions to the Morongo Tariff reflecting updates to annual operating cost revenue requirement); Morongo
Transmittal Letter at 2.
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to Show Cause. In this proceeding, the Commission has preliminarily ordered CAISO to reform
its tariff to take jurisdiction over, and facilitate, interconnection of large loads, including by:
• Developing an efficient application and study process for Eligible Customers seeking
transmission service for large loads;
• Increasing transparency regarding network upgrade costs to provide transmission service
for large loads, establishing mechanisms to mitigate cost shifting to other transmission
customers, and creating a pro forma cost recovery agreement between CAISO, the relevant
transmission owner, and the Eligible Customer;
• Developing new transmission services to accommodate flexible large loads willing to
accept interruptible service and/or contracts for less than their peak demand; and
• Developing processes to efficiently study generation facilities serving electrically
proximate large loads (i.e., not more than two substations apart) or co-located large loads,
with the goal of avoiding unnecessary network upgrades.4
These areas of reform do not implicate the Morongo Tariff, which expressly provides that
“Morongo Transmission LLC is a Non-Load-Serving Participating [Transmission Owner] and has
no End-Use Customers.”5 This language reflects the arrangement between Morongo Transmission
and SCE, where Morongo Transmission holds a 30-year lease of a portion of the transfer capability
of SCE’s West of Devers line across the Tribe’s Reservation.6 The Morongo Tariff is therefore
different from the tariffs of other CAISO Participating Transmission Owners that do serve load
and have end-use customers and whose tariffs may be subject to the Order to Show Cause.
Furthermore, the Morongo Tariff provides that the tariff provisions governing the load
interconnection process—Section Eight (Obligation to Interconnect or Construct Transmission
Expansions and Facility Upgrades), Section Nine (Expansion Process (including the study process
for necessary facilities)), and Section Ten (Interconnection Process)—“shall be superseded by the
4 CAISO, 195 FERC ¶ 61,214 at P 3.
5 Morongo Transmission LLC Transmission Owner Tariff (“Morongo Tariff”) § 1 (May 15, 2021)
(emphases added).
6 See Part I, supra.
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corresponding sections of the TO Tariff of Southern California Edison.”7 Thus to the extent that
amendments to the Participating Transmission Owners’ tariffs are necessary to implement large
load interconnection reforms to CAISO’s tariff in response to the Order to Show Cause,8 SCE
could implement those reforms to its own tariff without Morongo Transmission needing to take
further action to amend the Morongo Tariff.9 The Morongo Tariff thus will not be impacted by
reforms facilitating interconnections of large loads. However, to the extent that the Commission
determines any residual or conforming amendments are required to the Morongo Tariff, Morongo
Transmission will make compliance filings as directed.
The Order to Show Cause nonetheless targets a range of issues of great importance to
Morongo Transmission and the Tribe, including resource adequacy and reform of large load
interconnection processes. These topics are significant to Morongo Transmission and the Tribe as
they work to expand economic opportunity on the Reservation while ensuring affordable and
reliable electricity for the Tribe’s members. Morongo Transmission accordingly looks forward to
continuing to participate as a party in this proceeding and assisting the Commission as it weighs
these important matters—in keeping with Order No. 1920’s recognition of the critical role that
federally recognized Tribes play in developing policies affecting the interstate transmission grid.10
III.
SERVICE, COMMUNICATIONS, AND CORRESPONDENCE
Morongo Transmission requests that the persons listed below be included on the official
7 Morongo Tariff § 16.12 (cross-referencing Sections 8, 9, and 10).
8 See CAISO, 195 FERC ¶ 61,214 at P 3.
9 Southern California Edison Transmission Owner Tariff §§ 8-10 (effective May 1, 2019).
10 Bldg. for the Future Through Elec. Reg’l Transmission Planning and Cost Allocation, Order No. 1920,
187 FERC ¶ 61,068 at PP 409, 482, 528 (2024), on reh’g, Order No. 1920-A, 189 FERC ¶ 61,126 (2024),
reh’g denied, Order No. 1920-B, 191 FERC ¶ 61,026 (2025); see also CAISO, Tribal Engagement on Long-
term Transmission Planning 67 (Apr. 9, 2026), https://www.caiso.com/documents/presentation-tribal-
engagement-on-long-term-transmission-planning-apr-09-2026.pdf.
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service list for this proceeding, and respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) to
permit the designation of more than two persons upon whom service is to be made in this
proceeding.
Sam Cohen
Chief Legal Officer
MORONGO TRANSMISSION LLC
12700 Pumarra Road
Banning, CA 92220
(909) 454-4515
scohen@morongo-nsn.gov
Max Spivak
MORONGO BAND OF MISSION INDIANS
12700 Pumarra Road
Banning, CA 92220
(951) 755-5122
morongotransmissionllc@morongo-nsn.gov
Suedeen G. Kelly
JENNER & BLOCK LLP
1099 New York Avenue NW, Suite 900
Washington, DC 20001
(202) 639-6055
SKelly@jenner.com
IV.
CONCLUSION
For the reasons given above, the Morongo Tariff is just and reasonable and does not require
amendment in light of the Order to Show Cause.
Respectfully submitted,
/s/ Sam Cohen
Sam Cohen
Chief Legal Officer
MORONGO TRANSMISSION LLC
12700 Pumarra Road
Banning, CA 92220
(909) 454-4515
scohen@morongo-nsn.gov
On behalf of Morongo Transmission LLC
Dated: August 12, 2026
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CERTIFICATE OF SERVICE
I certify that, on August 12, 2026, I served the foregoing document upon each person
designated on the official service list compiled by the Secretary in this proceeding.
/s/ Suedeen G. Kelly
Suedeen G. Kelly