Topics in the text: Connecting load and generation · Cost allocation · Filing procedure
Morongo Transmission LLC · Direct response
Morongo said it leases transmission capacity and receives revenue through CAISO’s access charge. Because it serves no end-use customers, it argued that its own tariff needed no amendment. It still intended to participate in the proceeding.
PDF pp. 1–3Elliot Mainzer, CAISO president and CEO, quoted by APPA · Related public statement
After the October board action, Mainzer said CAISO expected its response to improve operational visibility, protect other customers from cost shifts and speed connections for flexible loads. His statement described a plan, not FERC approval.
October 28, comments following board actionEolian · Direct response
Eolian sought clarification that generation located electrically close to a large load could qualify for permanent limited service if it could constrain grid withdrawals over the long term. FERC dismissed the request because the preliminary order was not final.
Eolian request and FERC discussion (unpaginated)Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Cost allocation
195 FERC ¶ 61,214 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Before Commissioners: Laura V.Read this passage
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D.Read this passage
printed heading · Topic match: Connecting load and generation
EL26-71-000 - 3 - Over the past year, the Commission has taken action in numerous dockets1 to address issues related to (a) unprecedented increases in requests for transmission service to serve large loads2 and (b) growing interest in the co-location of loads with generating facilities (co-location…Read this passage
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I.Read this passage
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BackgroundRead this passage
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CAISO and PG&E generally support standardized study process requirements, as contemplated in the ANOPR with accommodation for regional variations, for large loads and co-location arrangements.30 CAISO also supports establishing operational and information sharing requirements for large loads to…Read this passage
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Representatives November 21 ANOPR Comments at 1. 38 See, e.g., AI Supply Chain Alliance November 21 ANOPR Comments at 2; DCC November 21 ANOPR Comments at 3; ECA November 21 ANOPR Comments at 6; Geronimo November 21 ANOPR Comments at 1-2; Google November 21 ANOPR Comments at 2-3; Verrus December 5…Read this passage
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EL26-71-000 - 13 - co-located load and Eligible Customers taking transmission service on behalf of co- located load.43 Specifically, the Commission found that the PJM tariff was unjust and unreasonable because there is a lack of sufficient clarity or consistency as to the rates, terms, and…Read this passage
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P 32 (explaining that SPP will grant HILLGA customers a new type of interconnection service, load limited resource interconnection service, which grants limited interconnection service solely to serve the associated HILL). 57 Id.Read this passage
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P 62. 60 For the HILL delivery point study, SPP required a $10,000 non-refundable application fee and a $100,000 study deposit, with an additional $200,000 study deposit if an Electromagnetic Transient study was also required.Read this passage
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II.Read this passage
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An interconnection customer may also request, and CAISO may provide, surplus interconnection service for an unneeded portion of interconnection service capacity at an existing point of interconnection.104 If the interconnection customer would not require a new interconnection request under the…Read this passage
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DD, § 3 (Interconnection Requests) (17.0.0), 3.4 (Surplus Interconnection Service); id. app.Read this passage
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III.Read this passage
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We emphasize that we will not grant such abeyances reflexively, that any abeyance will be limited to 90 days, and that we will look with great disfavor toward requests to extend the abeyance period.Read this passage
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Co., 46 FERC ¶ 61,153, order on reh’g, 47 FERC ¶ 61,275 (1989). 116 We recognize, for example, that under the current framework, CAISO does not conduct a study process for the provision of transmission service and note that the Participating Transmission Owners may be able to augment their existing…Read this passage
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Specifically, we find that it is within the Commission’s exclusive authority to ensure that transmission provider and/or transmission owner tariffs include sufficiently clear and consistent provisions governing how transmission service to Eligible Customers on behalf of large loads interconnecting…Read this passage
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EL26-71-000 - 36 - behalf of load;144 create a substantial risk of cost shifts if the large load additions do not materialize as planned;145 and distort load forecasts.146 Clear and consistent study procedures that include readiness requirements (i.e., meaningful milestones and/or financial…Read this passage
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Cost Shifting Risk Among Transmission Customers We next preliminarily find that CAISO’s Tariff and/or the TO Tariffs appear to be unjust and unreasonable because they lack adequate mechanisms to mitigate the risk of cost shifting among transmission customers, which may result in unjust and…Read this passage
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In response to the ANOPR, many commenters raise concerns about the impact that large load additions can have on retail ratepayers, particularly the concern that other retail ratepayers may be forced to subsidize network upgrades needed to add large loads to the transmission system.162 While we…Read this passage
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We preliminarily find that, for network upgrades evaluated in the local transmission planning process174 that are needed to accommodate transmission service for Eligible Customers on behalf of large loads are evaluated, CAISO must provide clear, timely, and detailed information regarding the extent…Read this passage
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EL26-71-000 - 50 - protect wholesale transmission customers from cost shifting.177 Specifically, commenters in the record contend that, while a retail-level large load tariff protects the load serving entity taking wholesale transmission service and its retail customers, it fails “to provide any…Read this passage
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See infra P 90. 188 PJM Co-Location Order, 193 FERC ¶ 61,217 at P 2; PJM Co-Location Rehearing Order, 195 FERC ¶ 61,209 at PP 91, 102. 189 While this section is directed to both CAISO and the Participating Transmission Owners, we believe it will mostly implicate the CAISO Tariff, as it appears that…Read this passage
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In this order, we will also use the term co-location arrangement when referring to both the co-located load and the associated generating facility.Read this passage
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As we explained in the PJM Co- Location Order, states retain exclusive authority over the specific terms of retail sales and retail rate design, including retail cost allocation to the co-located load; which entities are legally permitted to provide electricity to retail customers in co-location…Read this passage
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Additionally, in the PJM Co-Location Order, the Commission found that it was necessary to clarify that interconnection customers seeking to use new generating facilities to serve co-located load may (1) request interconnection service at a level below the generating facility’s maximum facility…Read this passage
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Finally, we note that the Commission has found it just and reasonable that, in order for an Eligible Customer to take interim NITS, firm contract demand transmission service, and non-firm contract demand transmission service, an Eligible Customer must have necessary control technologies and/or…Read this passage
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EL26-71-000 - 65 - uncertainty for both parties234 and “is necessary to match the pace of AI innovation in the United States.”235 CEBA also highlights that cost and timeline factors drive developers to submit multiple requests for price and timing discovery, which inflates queue volumes, distorts…Read this passage
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EL26-71-000 - 68 - requiring generator interconnection services that allow certain generating facilities to interconnect more quickly through the use of provisional interconnection service and surplus interconnection service,253 and has approved interconnection processes that allow certain…Read this passage
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Definitions For purposes of this order, it appears to be reasonable to use the term “electrically proximate large load” to mean a large load, as defined in this order,255 that is sufficiently electrically close to the interconnection customer’s requested point of interconnection, such that the…Read this passage
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Given that generator interconnection service in and of itself does not convey transmission service, we encourage CAISO to consider, in responding to these concerns, what type of transmission service an Eligible Customer will need to take on behalf of the electrically proximate large load or large…Read this passage
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The informational report must include a detailed schedule of key milestones, such as stakeholder or CAISO Board votes, that includes the estimated date on which CAISO expects to file any such proposals with the Commission.Read this passage
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We find that there may be a variety of possible approaches to protect customers from significant cost shifts associated with network upgrades triggered by large loads.Read this passage
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Overview of Today’s Orders In each of today’s orders to show cause, the Commission identifies a series of issues raised by the ongoing growth of large loads, directs briefing on whether existing tariffs remain just and reasonable in light of those developments, and describes possible solutions to…Read this passage
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The Commission Needs Good Records to Ensure Reasoned Decision-Making I first want to emphasize that the Commission needs active participation from interested stakeholders to develop thorough records in each region.Read this passage
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As we develop the new infrastructure, many have raised concerns about whether these costs are being fairly assigned to new and existing customers, whose benefits must be commensurate with the costs they pay.Read this passage
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While it is important to identify innovative solutions that can adapt to the needs of the system, the Commission and grid operators must also be careful not to implement changes that create unforeseen reliability risks.Read this passage
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The Orders Recognize the Importance of Evaluating Advanced Transmission Technologies Lastly, today we preliminarily find that each RTO/ISO’s tariff is unjust and unreasonable because the tariff lacks clear and consistent provisions requiring the evaluation of alternative transmission technologies…Read this passage
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VI.Read this passage
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While this is a long journey, even so, we must continue to move at breakneck pace to win the AI race.Read this passage