{"document":{"slug":"filing-20260803-5166","title":"Request for Abeyance of Southern California Edison Company, et al. in response to the Order issued on 06/18/2026","issued":"2026-08-03","accession":"20260803-5166","docket":"EL26-71-000","group":"CAISO filings","filer":"Southern California Edison CompanySan Diego Gas & Electric CompanyPacific Gas & Electric Company ,SunZia Transmission, LLC ,Citizens Sunrise Transmission LLC ,Citizens Sycamore-Penasquitos Transmission LLC ,Citizens S-Line Transmission LLC ,LS Power Grid California, LLC ,DesertLink, LLC ,Horizon West Transmission, LLC ,GridLiance West LLC ,Trans Bay Cable, LLC ,Viridon Path 15 LLC ,Valley Electric Association, Inc. ,Startrans IO, L.L.C. ,","kind":"request","file":"sources/originals/20260803-5166_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5166","sha256":"3db264502e19151cd857e32226b3e33eb59aa7965d004bed12cc39d521843c45","pages":13,"tokens":2774,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":115,"text":"1 \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \nCalifornia Independent System Operator \nCorporation  \nCitizen S-Line Transmission LLC  \nCitizens Sunrise Transmission LLC  \nCitizens Sycamore-Penasquitos Transmission \nLLC  \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) \n) \n) \n) \n) \n) \n) \n) \n) \n) \n) \n) \n) \n) \n) \n) \n) \n) \nDocket No. EL26-71-000"},{"page":2,"startToken":115,"endToken":408,"text":"2 \nREQUEST FOR ABEYANCE OF  \nSOUTHERN CALIFORNIA EDISON COMPANY; PACIFIC GAS AND ELECTRIC \nCOMPANY; SAN DIEGO GAS & ELECTRIC COMPANY; CITIZENS SUNRISE \nTRANSMISSION LLC; CITIZENS SYCAMORE-PENASQUITOS TRANSMISSION \nLLC; CITIZENS S-LINE TRANSMISSION LLC; SUNZIA TRANSMISSION, LLC; LS \nPOWER GRID CALIFORNIA, LLC; DESERTLINK, LLC; GRIDLIANCE WEST LLC; \nHORIZON WEST TRANSMISSION, LLC; TRANS BAY CABLE LLC; VIRIDON PATH \n15 LLC; VALLEY ELECTRIC ASSOCIATION, INC.; AND STARTRANS IO, LLC \nI. \nINTRODUCTION \nPursuant to Rules 206, 212, and 213 of the Federal Energy Regulatory Commission’s \n(FERC or Commission) Rules of Practice and Procedure,1 Southern California Edison Company; \nPacific Gas and Electric Company; San Diego Gas & Electric Company; Citizens Sunrise \nTransmission LLC; Citizens Sycamore-Penasquitos Transmission LLC; Citizens S-Line \nTransmission LLC; SunZia Transmission, LLC; LS Power Grid California, LLC; DesertLink, \nLLC; GridLiance West LLC; Horizon West Transmission, LLC; Trans Bay Cable LLC; Viridon \nPath 15 LLC; Valley Electric Association, Inc.; and Startrans IO, LLC (together, the Joint PTOs) \nrespectfully submit this Request for Abeyance in response to the Order Instituting Proceeding \nUnder Section 206 of the Federal Power Act (the OSC) issued in the above-captioned proceeding \non June 18, 2026.  The Joint PTOs seek a 90-day full abeyance of the current 60-day deadline to \nrespond to all issues raised in the OSC so that the Joint PTOs may each have the additional time \nnecessary to prepare Federal Power Act (FPA) section 205 filings revising their respective \nTransmission Owner (TO) Tariffs. \nThe Joint PTOs appreciate the Commission’s attention and guidance on issues relating to \nthe interconnection of large loads, including data centers, to the FERC-jurisdictional \ntransmission system.  The Joint PTOs believe the potential tariff changes the Commission \ndiscusses in the OSC will provide opportunities for the California Independent System Operator \n \n1 \n18 C.F.R. §§ 385.212 and 385.213 (2026)."},{"page":3,"startToken":408,"endToken":765,"text":"3 \nCorporation (CAISO) and the PTOs to bring large loads online efficiently and further protect \nratepayers across the CAISO region from transmission-related costs associated with large loads.  \nThe Joint PTOs also agree that revising the interconnection process to facilitate the connection of \nlarge loads to the California grid should be a priority as the stakeholders work through this \nprocess.  The Joint PTOs seek an abeyance so that they can have further time to develop a robust, \nworkable, and transparent set of tariff amendments responsive to the Commission’s identified \nareas of concern as relevant to TOs.  The Joint PTOs acknowledge that there are significant \ndifferences among the California PTOs (some PTOs serve load while others do not, for example) \nsuch that the appropriate TO Tariff changes to implement the OSC will also likely vary from \nPTO to PTO such that each PTO must develop its proposed tariff changes to reflect its unique \ncircumstances and to coordinate those unique circumstances with CAISO and the other PTOs. \nII. \nARGUMENT \nIn the OSC, the Commission states that it will consider requests for abeyances of up to 90 \ndays, which should include both (1) a robust description of the content of a potential future filing \nunder FPA section 205 and (2) a reasoned and specific explanation of when such a filing is \nexpected to be made.2 \nThe Joint PTOs each plan to develop an FPA section 205 filing to amend their respective \nTO Tariffs, as described below.  The Joint PTOs respectfully request the Commission hold the \ndeadline to respond to the OSC in abeyance for a 90-day period.  Good cause exists to grant this \nmotion because doing so will allow the Joint PTOs to address issues identified by the \nCommission in the OSC through FPA section 205 filings.  The issues the Commission has raised \nin the OSC are complex and substantial, requiring each of the PTOs to draft entirely new \nsections of their respective TO Tariffs, potentially including new pro forma contract(s), and \nincorporate study and application processes tailored to large loads interconnecting to the \ntransmission system.  For those Joint PTOs with retail-load responsibilities, state-jurisdictional \n \n2  OSC at P 35."},{"page":4,"startToken":765,"endToken":1116,"text":"4 \nretail load tariffs, agreements, rates, and processes must also be carefully considered.  Moreover, \nmany of the Commission’s identified concerns can only be resolved with complementary or, at a \nminimum, non-conflicting tariff provisions among the CAISO Tariff and the various TO Tariffs.  \nIn order to develop a comprehensive set of TO Tariff revisions addressing the myriad concerns \nthe Commission has raised and reflecting each PTO’s unique circumstances, the Joint PTOs must \ntherefore closely coordinate with the CAISO as they each draft new tariffs provisions and, as \napplicable, revise existing provisions.  The CAISO is separately seeking an abeyance to engage \nin its stakeholder process, requiring a corresponding abeyance for the Joint PTOs.  Coordination \nwith other stakeholders, including the undersigned California Investor Owned Utilities (IOUs), \nthe undersigned TOs, and other TOs, will also be necessary.  Filing tariff revisions on August 17 \nwould require the Joint PTOs to submit tariff provisions that would likely conflict with the \nCAISO’s design, which the Joint PTOs cannot reasonably predict this early in the stakeholder \nprocess.  The requested 90-day abeyance will instead permit a coordinated set of filings.  \nAccordingly, the Joint PTOs seek an abeyance until November 16, 2026, for each of the Joint \nPTOs to submit its response to the OSC, including its anticipated FPA section 205 filing.  \nA. \nProposed TO Tariff Revisions \nIn the OSC, the Commission has identified five areas of potential deficiency in either the \nCAISO and/or TO Tariffs.  First, the Commission has stated that the CAISO and/or TO Tariffs \nmay lack provisions that address, with sufficient clarity and consistency, how CAISO and/or the \nParticipating TOs will timely study the provision of transmission service to Eligible Customers \non behalf of large loads.3  The OSC states that the CAISO and/or the TOs should explain \nwhether their respective tariffs remain just and reasonable without provisions outlining an \napplication process, study procedures, and ongoing operational requirements that address the \nunique characteristics and challenges of providing transmission service to Eligible Customers on \nbehalf of large loads, or propose appropriate tariff revisions.  Second, the OSC indicates that the \n \n3  OSC at Section III.A."},{"page":5,"startToken":1116,"endToken":1506,"text":"5 \nCAISO and/or TO Tariffs may be unjust and unreasonable because they appear to lack (1) \ntransparency regarding the assignment of network upgrades, and their associated costs, that are \nneeded to provide transmission service to Eligible Customers on behalf of large loads; and (2) a \npro forma cost recovery agreement among CAISO, the relevant transmission owner, and the \nEligible Customer taking transmission service on behalf of large loads that helps ensure that \nEligible Customers bear the risk and are ultimately responsible for costs incurred to provide \ntransmission service.4  Third, the Commission has identified the CAISO Tariff as potentially \ndeficient without clear and consistent provisions addressing the rates, terms, and conditions \napplicable to co-location arrangements and for transmission services that reflect an Eligible \nCustomer taking transmission service on behalf of Eligible Load that is willing and able to limit \nits energy withdrawals from the transmission system under certain conditions.5  Fourth, the OSC \nstates that the CAISO Tariff appears unjust and unreasonable because it does not include \ntransmission services that reflect Eligible Customers taking transmission service on behalf of \nflexible large loads that are willing and able to limit their use of the transmission system under \ncertain conditions.6  Fifth, the Commission preliminarily finds that the CAISO Tariff appears to \nbe unjust and unreasonable because it does not contain provisions allowing an interconnection \ncustomer to seek the generator interconnection service(s) reflecting the operational dynamics of \nserving electrically proximate or co-located load with a high peak load.7 \nThe OSC does not suggest that the TO Tariffs are unjust and unreasonable with respect to \nall Commission concerns.  For instance, the third, fourth, and fifth issues – co-located load, \nflexible services, and proximate load – are primarily directed at the CAISO Tariff, where these \n \n4  OSC at Section III.B. \n5  OSC at Section III.C.  The CAISO Tariff also is identified as potentially unjust and unreasonable with \nregards to how it allows “load with BTMG to net its BTMG against its load for purposes of \ncalculating Regional Access Charges.”  The CAISO Tariff’s existing BTMG netting rule requires the \nrelevant BTMG load to take retail standby service from the relevant utility, a fact omitted in the OSC \ndiscussion of this issue and which fact impacts the relevant utility and others. \n6  OSC at Section III.D. \n7  OSC at Section III.E."},{"page":6,"startToken":1506,"endToken":1906,"text":"6 \ntypes of transmission services would typically reside.8  Nonetheless, the issues for the CAISO \nand TOs to address are interconnected, whether they require changes to the CAISO Tariff, the \nTO Tariffs, or both.  Accordingly, successful FPA section 205 filings will require significant \ncoordination among the CAISO, TOs, and other stakeholders, such as California regulators.  The \nJoint PTOs understand that the CAISO plans to file responsive tariff amendments in November \n(assuming its abeyance request is granted), and the Joint PTOs cannot revise their respective TO \nTariffs in a vacuum.9  For example, the roles, responsibilities, and processes to interconnect and \nserve large loads taking new types of transmission services will likely be dependent on \nmodifications to existing services under the CAISO Tariff.  As the stakeholders work through \nthis process, necessary deviations to reflect regional differences in CAISO must also be \nconsidered.  The Joint PTOs have already been meeting with the CAISO weekly, and have \ncoordinated in developing their respective requests for abeyance, including by conferring \nregarding the issues expected to be addressed, the contemplated process for implementing \nappropriate FPA section 205 revisions, and the anticipated filing schedule.  Although CAISO \nand the Joint PTOs are filing separately in recognition of their distinct responsibilities and filing \nrights, their respective requests reflect a coordinated regional effort consistent with Commission \ndirection.10  The Joint PTOs intend to continue working together through the stakeholder process \n \n8  LS Power Grid California, LLC and DesertLink, LLC more specifically note that they are \nindependent transmission owners that do not serve retail load or have load-serving obligations.  \nMatters involving state-jurisdictional retail tariffs and agreements, retail standby service, resource-\nadequacy procurement, and CAISO-administered transmission services, ancillary services, market \nparticipation, and generator-interconnection service therefore do not implicate their TO Tariffs in the \nsame manner.  Any potential FPA section 205 filing by either company would be limited to matters \nthat implicate its own TO Tariff or a PTO-administered agreement. \n9  See CAISO Informational Report at p. 15 (July 20, 2026).  Given CAISO governance rules and the \nneed for CAISO Board approval, revisions to the CAISO Tariff are unlikely to be finalized until close \nto the November 16 filing deadline, assuming the CAISO is granted its own abeyance.  The CAISO \ndoes not currently plan to seek Board approval until October 28, just over two and a half weeks \nbefore a 90-day extended filing deadline for tariff changes. \n10  See OSC at P 35."},{"page":7,"startToken":1906,"endToken":2202,"text":"7 \nto identify appropriate revisions to the CAISO and/or TO Tariffs.11  The Joint PTOs’ FPA \nsection 205 filings are currently expected to present revisions to the TO Tariffs to include study, \napplication, and operational procedures for the interconnection of large loads, as well as \nprovisions to address transparency, cost-recovery, financial-security, and rate-treatment \nprovisions intended to prevent cost shifting.  These matters remain under development and may \nevolve through coordination with CAISO and stakeholders.  Joint PTOs will coordinate with \nCAISO according to its publicly posted schedule, conform their proposed revisions following \nCAISO's scheduled October 28, 2026 Board consideration, and complete internal approvals in \ntime to submit their filings by November 16, 2026.   \nB. \nBriefing Questions \nThe Commission also identifies several issues for further briefing.12  The Joint PTOs also \nrequest to toll the deadline to respond to the briefing questions for 90 days, consistent with the \nOSC’s explanation of the effect of an abeyance.13  The Joint PTOs believe an abeyance is \nappropriate as to the briefing questions as they are wholly interrelated with the issues to be \naddressed in the Joint PTOs’ Section 205 filings, as described above.  \nIII. \nCONCLUSION \nFor the reasons described above, the Joint PTOs respectfully request that the Commission \ngrant the Request for Abeyance and extend each of the Joint PTOs’ deadlines to respond in full \nto the OSC to November 16, 2026.   \n \n \n \n11  For example, the Joint PTOs cannot create new application processes and study processes to account \nfor new CAISO flexible, co-located, and/or proximate transmission services without knowing the \ncharacteristics of those services. \n12  OSC at Section IV. \n13  See OSC at P 35 (holding that “the deadline to respond to this order” will be held in abeyance for 90 \ndays upon a successful petition by a TO)."},{"page":8,"startToken":2202,"endToken":2306,"text":"8 \nRespectfully submitted, \nEllen C. Kenney \n/s/ Ellen C. Kenney \nBy: \nEllen C. Kenney \nAttorneys for \nSOUTHERN CALIFORNIA EDISON COMPANY \n2244 Walnut Grove Avenue \nPost Office Box 800 \nRosemead, California 91770 \nTelephone: \n(626) 302-9519 \nE-mail: \nEllen.Kenney@sce.com \n \nJonathan J. Newlander \n/s/ Jonathan J. Newlander  \nBy: \nJonathan J. Newlander \nAttorney for \nSAN DIEGO GAS & ELECTRIC COMPANY \n8330 Century Park Court, CP32D \nSan Diego, California 92123 \nTelephone: \n(619) 577-3468 \nE-mail: \nJNewlander@sdge.com \n \nTara Kaushik \nGrady Mathai-Jackson \nJohn P. Perkins, III \nWilliam Brenc \n/s/ John P. Perkins, III \nBy: \nJohn P. Perkins, III \nAttorneys for \nPACIFIC GAS & ELECTRIC CO. \nPacific Gas and Electric Company"},{"page":9,"startToken":2306,"endToken":2391,"text":"9 \nLaw Department, 19th Floor  \n300 Lakeside Drive, Suite 210  \nOakland, CA 94612  \nTelephone: 501-551-4036 \nEmail: john.perkins@pge.com \n \n \n \nRobert L. Daileader \n/s/ Robert L. Daileader \nBy: \nRobert L. Daileader \nAttorney for \nSUNZIA TRANSMISSION, LLC \nNixon Peabody LLP \n799 Ninth Street NW, Suite 500 \nWashington, DC  20001 \nTelephone: \n(202) 288-2069 \nE-mail: \nrdaileader@nixonpeabody.com \n \n \nAmy E. McDonnell \nAshley M. Bond \n/s/ Ashley M. Bond \nBy: \nAshley M. Bond \n \nCounsel for  \nCITIZENS SUNRISE \nTRANSMISSION LLC, CITIZENS SYCAMORE-\nPENASQUITOS TRANSMISSION LLC, AND CITIZENS S-\nLINETRANSMISSION LLC"},{"page":10,"startToken":2391,"endToken":2495,"text":"10 \nDuncan & Allen LLP \n1730 Rhode Islan Ave., N.W \nSuite 700 \nWashington, DC  20036 \nTelephone: \n(202) 289-8400 \nFacsimile: \n(202) 289-8450 \nE-mail: \namb@DuncanAllen.com \n \n \n \nBlake R. Urban \n/s/ Blake R. Urban \nBy: \nBlake R. Urban \nAttorney for \nLS POWER GRID CALIFORNIA, LLC AND DESERTLINK, \nLLC \n16150 Main Circle Drive, Suite 310 \nChesterfield, MO 63017 \nTelephone: \n(636) 231-0475 \nE-mail: \nburban@lspower.com \n \n \n \nElizabeth Ramey \n/s/ Elizabeth Ramey  \nBy: \nElizabeth Ramey \nAttorney for \nGRIDLIANCE WEST LLC; HORIZON WEST \nTRANSMISSION, LLC; AND TRANS BAY CABLE LLC \n \nNextEra Energy, Inc. \n801 Pennsylvania Avenue NW, Suite 200 \nWashington, DC 20004 \nTelephone: \n(202) 909-5695 \nE-mail: \nelizabeth.ramey@nexteraenergy.com"},{"page":11,"startToken":2495,"endToken":2565,"text":"11 \nVerónica Gómez  \n/s/  Verónica Gómez \nBy: \nVerónica Gómez  \nAttorney for \nVIRIDON PATH 15 LLC \n \n515 North State Street, Suite 1150 \nChicago, IL 60654 \nTelephone: (773) 551-1920  \nE-mail: veronica@viridon.com \n \n \n \n \nDakota L. Councilman \n/s/ Dakota L. Councilman \nBy: \nDakota L. Councilman \nAttorney for \nVALLEY ELECTRIC ASSOCIATION, INC. \n \nDavison Van Cleve, P.C.                   \n4675 W. Teco Ave., Suite 230          \nLas Vegas, NV 89118                       \nTelephone: (702) 267-6763                 \nE-mail: dlc@dvclaw.com"},{"page":12,"startToken":2565,"endToken":2646,"text":"12 \nJoseph C. Hall \n/s/ Joseph C. Hall \nBy: \nJoseph C. Hall \nAttorney for \nSTARTRANS IO, LLC \n \nJoseph C. Hall \nEdwin G. Kichline \nKelly A. Cuthbertson \nEversheds Sutherland (US) LLP \n700 Sixth Street, NW, Suite 700 \nWashington, DC 20001-3980 \nTelephone: (202) 383-0100 \nEmail: joehall@eversheds-sutherland.com \nEmail: edwinkichline@eversheds-sutherland.com  \nEmail: kellycuthbertson@eversheds-sutherland.com \n \nAli Amirali \nGeneral Manager \nStartrans IO, L.L.C. \n5 Greenwich Office Park \nGreenwich, Connecticut 06831 \nTelephone: (408) 204-7630 \nEmail: aamirali@lotuspartners.com \nDated:  August 3, 2026"},{"page":13,"startToken":2646,"endToken":2774,"text":"13 \nCERTIFICATE OF SERVICE \nI hereby certify that I have this day served the foregoing REQUEST FOR ABEYANCE \nOF SOUTHERN CALIFORNIA EDISON COMPANY; PACIFIC GAS AND ELECTRIC \nCOMPANY; SAN DIEGO GAS & ELECTRIC COMPANY; CITIZENS SUNRISE \nTRANSMISSION LLC; CITIZENS SYCAMORE-PENASQUITOS TRANSMISSION \nLLC; CITIZENS S-LINE TRANSMISSION LLC; SUNZIA TRANSMISSION, LLC; LS \nPOWER GRID CALIFORNIA, LLC; DESERTLINK, LLC; GRIDLIANCE WEST LLC; \nHORIZON WEST TRANSMISSION, LLC; TRANS BAY CABLE LLC; VIRIDON PATH \n15 LLC; VALLEY ELECTRIC ASSOCIATION, INC.; AND STARTRANS IO, LLC upon \neach person designated on the official service list compiled by the Secretary in this proceeding. \nDated at Rosemead, California, this 3rd day of August 2026. \n \n \n/s/ Karen Abarca \n \n \nKaren Abarca \nSenior Legal Administrative Assistant \nSOUTHERN CALIFORNIA EDISON COMPANY \n2244 Walnut Grove Avenue \nPost Office Box 800 \nRosemead, California 91770"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":483,"startToken":0,"endToken":179},{"p":2,"at":483,"title":"I. INTRODUCTION","method":"PDF bookmark","endPage":2,"endAt":487,"startToken":179,"endToken":180},{"p":2,"at":487,"title":"INTRODUCTION","method":"printed heading","endPage":3,"endAt":1050,"startToken":180,"endToken":572},{"p":3,"at":1050,"title":"II. ARGUMENT","method":"PDF bookmark","endPage":4,"endAt":1434,"startToken":572,"endToken":977},{"p":4,"at":1434,"title":"A. Proposed TO Tariff Revisions","method":"PDF bookmark","endPage":7,"endAt":802,"startToken":977,"endToken":2018},{"p":7,"at":802,"title":"B. Briefing Questions","method":"PDF bookmark","endPage":7,"endAt":1276,"startToken":2018,"endToken":2095},{"p":7,"at":1276,"title":"III. Conclusion","method":"PDF bookmark","endPage":7,"endAt":1282,"startToken":2095,"endToken":2096},{"p":7,"at":1282,"title":"CONCLUSION","method":"printed heading","endPage":13,"endAt":4,"startToken":2096,"endToken":2647},{"p":13,"at":4,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":13,"endAt":919,"startToken":2647,"endToken":2774}]}