EL26-71-000 · 2026-07-31 · Six Cities CA

Motion to Rescind Show Cause Order on behalf of the Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California

- 1 - 
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 
 
 
MOTION TO RESCIND SHOW CAUSE ORDER  
ON BEHALF OF THE CITIES OF ANAHEIM, AZUSA, BANNING, COLTON, 
PASADENA, AND RIVERSIDE, CALIFORNIA 
 
 
Pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure,1 the Cities of 
Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California (collectively, the “Six 
 
1 18 C.F.R. § 385.212 (2026).

- 2 - 
Cities”) hereby submit this motion to rescind the show cause order issued by the Commission in 
the above-referenced proceeding on June 18, 2026,2 as directed to each of the Six Cities as 
Participating Transmission Owners (“TOs”) in the California Independent System Operator 
Corporation (“CAISO”).  
I. 
DESCRIPTION OF THE SIX CITIES 
Each of the Six Cities operates a municipal electric system that is located within the 
CAISO Balancing Authority Area.  The Cities are each electrically surrounded by Southern 
California Edison Company (“SCE”), which is an Original Participating TO3 in the CAISO.  
Although each of the Cities has made arrangements to obtain energy and capacity from a variety 
of resources, the Cities are dependent upon the CAISO and SCE for the delivery of the majority 
of these resources.   
The Cities of Anaheim, Azusa, Banning, and Riverside became Participating TOs in the 
CAISO and signed the Transmission Control Agreement (“TCA”) among and between the 
CAISO and its Participating TOs effective January 1, 2003.  The City of Pasadena executed the 
TCA and became a Participating TO as of January 1, 2005, and the City of Colton executed the 
TCA and became a Participating TO as of January 1, 2013.  As Participating TOs in the CAISO, 
each of the Cities has transferred to the CAISO’s Operational Control certain transmission 
facilities and Entitlements, and they each have a TO Tariff on file with the Commission that 
establishes rates, terms, and conditions of service on their facilities and Entitlements consistent 
with the CAISO Tariff and the TCA.  In general, the Six Cities’ facilities and Entitlements over 
which the CAISO has assumed Operational Control represent either shares of jointly-owned 
 
2 Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (the “Show Cause Order”).   
3 Capitalized terms used in this filing and not defined herein have the meanings set out in Appendix A to the 
California Independent System Operator Corporation Fifth Replacement Tariff (“CAISO Tariff”).

- 3 - 
facilities with, in some cases, entities that are not CAISO Participating TOs and/or are likewise 
not Commission-jurisdictional, or contractual rights to transmission service on other parties’ 
systems, which are governed by the terms and conditions of those parties’ tariffs and/or bilateral 
transmission service agreements.   
II. 
RELEVANT BACKGROUND 
On June 18, 2026, the Commission issued the Show Cause Order, thereby initiating a 
proceeding under Section 206 of the Federal Power Act.  The Show Cause Order found that the 
CAISO Tariff and/or the TO Tariffs of each of the CAISO Participating TOs appear to be unjust, 
unreasonable, or unduly discriminatory or preferential to the extent that they do not include 
provisions establishing the rates, terms, and conditions for the interconnection of and service to 
certain large and co-located loads.  The Show Cause Order therefore directed the CAISO and the 
CAISO Participating TOs to either explain how their respective tariffs remain just and 
reasonable without specific provisions for the interconnection of large and co-located loads or to 
develop such provisions.4  
III. 
JUSTIFICATION FOR RESCISSION 
Each of the Six Cities is a non-public utility that is exempt from the Commission’s 
jurisdiction pursuant to Section 201(f) of the Federal Power Act.5  The Commission 
acknowledged that the Show Cause Order included Participating TOs that are not subject to the 
Commission’s jurisdiction and explained that it would “rescind the show cause order” against 
such entities at their request, provided that the CAISO “respond[s] to this order regarding the 
 
4 Show Cause Order at P 3.   
5 16 U.S.C. 824(f) (2024), City of Anaheim, 171 FERC ¶ 61,263, at PP 19-22 (2020), cited in Show Cause Order at P 
3, n.9.

- 4 - 
non-public utility’s CAISO Tariff provisions on file with the Commission.”6  Accordingly, as 
non-public utilities, the Six Cities request that the Commission rescind the Show Cause Order 
against each of the Six Cities. 
In requesting recission of the Show Cause Order, the Six Cities will coordinate and 
cooperate with the CAISO in responding to the Show Cause Order, to the extent that the CAISO 
requests assistance from the Six Cities and with respect to provisions in the Cities’ TO Tariffs 
that pertain to load interconnections.7  The Six Cities have conferred with the CAISO and are 
authorized to state that the CAISO supports this motion.  The Six Cities also acknowledge the 
Commission’s authority to review their transmission revenue requirements as set forth in their 
TO Tariffs to ensure the CAISO’s rates remain just and reasonable.8  Consistent with the Cities’ 
practice, if any of the Cities determines that changes to its TO Tariff are needed to address the 
issues in the Show Cause Order or any other topics, each City will file proposed revisions to its 
TO Tariff with the Commission.9   
 
 
 
6 Show Cause Order at P 3, n.9.   
7 See id. (explaining that certain non-jurisdictional entities’ TO Tariffs include wholesale load interconnection 
processes).   
8 See id. 
9 See, e.g., TO Tariff EDAM Revisions, City of Anaheim, Docket No. ER26-2310-000 (filed Apr. 27, 2026) 
(proposing revisions to the City’s TO Tariff to reflect modifications related to Extended Day Ahead Market Access 
Charge revenues).

- 5 - 
IV. 
CONCLUSION 
WHEREFORE, for the foregoing reasons, the Six Cities respectfully request that the 
Commission rescind the Show Cause Order against each of the Cities as non-public utilities and 
ask that the Commission waive any notice and comment periods that might be applicable to this 
motion. 
 
Respectfully submitted, 
 
 
/s/ Margaret E. McNaul 
 
 
Margaret E. McNaul 
 
Rebecca L. Shelton 
 
Jenna E. Cliatt 
 
 
 
 
Attorneys for the Cities of Anaheim, Azusa, 
Banning, Colton, Pasadena, and Riverside, 
California 
 
Law Offices of: 
 
Thompson Coburn LLP 
 
1909 K Street, N.W., Suite 600 
 
Washington, D.C. 20006-1167 
 
202.585.6900 
 
202.585.6969 (facsimile) 
 
July 31, 2026

CERTIFICATE OF SERVICE 
I hereby certify that I have on this 31st day of July, 2026, caused a copy of the foregoing 
document to be sent to all parties on the list compiled by the Secretary of the Commission in this 
proceeding, by electronic mail or such other means as may have been specified by such party, 
pursuant to Commission Rule 2010. 
 
 
/s/ Margaret E. McNaul 
 
 
Margaret E. McNaul 
 
Attorney for the Cities of Anaheim, Azusa, 
Banning, Colton, Pasadena, and Riverside, 
California 
 
Law Offices of: 
 
Thompson Coburn LLP 
 
1909 K Street, N.W., Suite 600 
 
Washington, D.C. 20006-1167 
 
202.585.6900 
 
202.585.6969 (facsimile)