EL26-71-000 · 2026-08-03 · 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. ,

Request for Abeyance of Southern California Edison Company, et al. in response to the Order issued on 06/18/2026

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 
 
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Docket No. EL26-71-000

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REQUEST FOR ABEYANCE OF  
SOUTHERN CALIFORNIA EDISON COMPANY; PACIFIC GAS AND ELECTRIC 
COMPANY; SAN DIEGO GAS & ELECTRIC COMPANY; CITIZENS SUNRISE 
TRANSMISSION LLC; CITIZENS SYCAMORE-PENASQUITOS TRANSMISSION 
LLC; CITIZENS S-LINE TRANSMISSION LLC; SUNZIA TRANSMISSION, LLC; LS 
POWER GRID CALIFORNIA, LLC; DESERTLINK, LLC; GRIDLIANCE WEST LLC; 
HORIZON WEST TRANSMISSION, LLC; TRANS BAY CABLE LLC; VIRIDON PATH 
15 LLC; VALLEY ELECTRIC ASSOCIATION, INC.; AND STARTRANS IO, LLC 
I. 
INTRODUCTION 
Pursuant to Rules 206, 212, and 213 of the Federal Energy Regulatory Commission’s 
(FERC or Commission) Rules of Practice and Procedure,1 Southern California Edison Company; 
Pacific Gas and Electric Company; San Diego Gas & Electric Company; Citizens Sunrise 
Transmission LLC; Citizens Sycamore-Penasquitos Transmission LLC; Citizens S-Line 
Transmission LLC; SunZia Transmission, LLC; LS Power Grid California, LLC; DesertLink, 
LLC; GridLiance West LLC; Horizon West Transmission, LLC; Trans Bay Cable LLC; Viridon 
Path 15 LLC; Valley Electric Association, Inc.; and Startrans IO, LLC (together, the Joint PTOs) 
respectfully submit this Request for Abeyance in response to the Order Instituting Proceeding 
Under Section 206 of the Federal Power Act (the OSC) issued in the above-captioned proceeding 
on June 18, 2026.  The Joint PTOs seek a 90-day full abeyance of the current 60-day deadline to 
respond to all issues raised in the OSC so that the Joint PTOs may each have the additional time 
necessary to prepare Federal Power Act (FPA) section 205 filings revising their respective 
Transmission Owner (TO) Tariffs. 
The Joint PTOs appreciate the Commission’s attention and guidance on issues relating to 
the interconnection of large loads, including data centers, to the FERC-jurisdictional 
transmission system.  The Joint PTOs believe the potential tariff changes the Commission 
discusses in the OSC will provide opportunities for the California Independent System Operator 
 
1 
18 C.F.R. §§ 385.212 and 385.213 (2026).

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Corporation (CAISO) and the PTOs to bring large loads online efficiently and further protect 
ratepayers across the CAISO region from transmission-related costs associated with large loads.  
The Joint PTOs also agree that revising the interconnection process to facilitate the connection of 
large loads to the California grid should be a priority as the stakeholders work through this 
process.  The Joint PTOs seek an abeyance so that they can have further time to develop a robust, 
workable, and transparent set of tariff amendments responsive to the Commission’s identified 
areas of concern as relevant to TOs.  The Joint PTOs acknowledge that there are significant 
differences among the California PTOs (some PTOs serve load while others do not, for example) 
such that the appropriate TO Tariff changes to implement the OSC will also likely vary from 
PTO to PTO such that each PTO must develop its proposed tariff changes to reflect its unique 
circumstances and to coordinate those unique circumstances with CAISO and the other PTOs. 
II. 
ARGUMENT 
In the OSC, the Commission states that it will consider requests for abeyances of up to 90 
days, which should include both (1) a robust description of the content of a potential future filing 
under FPA section 205 and (2) a reasoned and specific explanation of when such a filing is 
expected to be made.2 
The Joint PTOs each plan to develop an FPA section 205 filing to amend their respective 
TO Tariffs, as described below.  The Joint PTOs respectfully request the Commission hold the 
deadline to respond to the OSC in abeyance for a 90-day period.  Good cause exists to grant this 
motion because doing so will allow the Joint PTOs to address issues identified by the 
Commission in the OSC through FPA section 205 filings.  The issues the Commission has raised 
in the OSC are complex and substantial, requiring each of the PTOs to draft entirely new 
sections of their respective TO Tariffs, potentially including new pro forma contract(s), and 
incorporate study and application processes tailored to large loads interconnecting to the 
transmission system.  For those Joint PTOs with retail-load responsibilities, state-jurisdictional 
 
2  OSC at P 35.

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retail load tariffs, agreements, rates, and processes must also be carefully considered.  Moreover, 
many of the Commission’s identified concerns can only be resolved with complementary or, at a 
minimum, non-conflicting tariff provisions among the CAISO Tariff and the various TO Tariffs.  
In order to develop a comprehensive set of TO Tariff revisions addressing the myriad concerns 
the Commission has raised and reflecting each PTO’s unique circumstances, the Joint PTOs must 
therefore closely coordinate with the CAISO as they each draft new tariffs provisions and, as 
applicable, revise existing provisions.  The CAISO is separately seeking an abeyance to engage 
in its stakeholder process, requiring a corresponding abeyance for the Joint PTOs.  Coordination 
with other stakeholders, including the undersigned California Investor Owned Utilities (IOUs), 
the undersigned TOs, and other TOs, will also be necessary.  Filing tariff revisions on August 17 
would require the Joint PTOs to submit tariff provisions that would likely conflict with the 
CAISO’s design, which the Joint PTOs cannot reasonably predict this early in the stakeholder 
process.  The requested 90-day abeyance will instead permit a coordinated set of filings.  
Accordingly, the Joint PTOs seek an abeyance until November 16, 2026, for each of the Joint 
PTOs to submit its response to the OSC, including its anticipated FPA section 205 filing.  
A. 
Proposed TO Tariff Revisions 
In the OSC, the Commission has identified five areas of potential deficiency in either the 
CAISO and/or TO Tariffs.  First, the Commission has stated that the CAISO and/or TO Tariffs 
may lack provisions that address, with sufficient clarity and consistency, how CAISO and/or the 
Participating TOs will timely study the provision of transmission service to Eligible Customers 
on behalf of large loads.3  The OSC states that the CAISO and/or the TOs should explain 
whether their respective tariffs remain just and reasonable without provisions outlining an 
application process, study procedures, and ongoing operational requirements that address the 
unique characteristics and challenges of providing transmission service to Eligible Customers on 
behalf of large loads, or propose appropriate tariff revisions.  Second, the OSC indicates that the 
 
3  OSC at Section III.A.

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CAISO and/or TO Tariffs may be unjust and unreasonable because they appear to lack (1) 
transparency regarding the assignment of network upgrades, and their associated costs, that are 
needed to provide transmission service to Eligible Customers on behalf of large loads; and (2) a 
pro forma cost recovery agreement among CAISO, the relevant transmission owner, and the 
Eligible Customer taking transmission service on behalf of large loads that helps ensure that 
Eligible Customers bear the risk and are ultimately responsible for costs incurred to provide 
transmission service.4  Third, the Commission has identified the CAISO Tariff as potentially 
deficient without clear and consistent provisions addressing the rates, terms, and conditions 
applicable to co-location arrangements and for transmission services that reflect an Eligible 
Customer taking transmission service on behalf of Eligible Load that is willing and able to limit 
its energy withdrawals from the transmission system under certain conditions.5  Fourth, the OSC 
states that the CAISO Tariff appears unjust and unreasonable because it does not include 
transmission services that reflect Eligible Customers taking transmission service on behalf of 
flexible large loads that are willing and able to limit their use of the transmission system under 
certain conditions.6  Fifth, the Commission preliminarily finds that the CAISO Tariff appears to 
be unjust and unreasonable because it does not contain provisions allowing an interconnection 
customer to seek the generator interconnection service(s) reflecting the operational dynamics of 
serving electrically proximate or co-located load with a high peak load.7 
The OSC does not suggest that the TO Tariffs are unjust and unreasonable with respect to 
all Commission concerns.  For instance, the third, fourth, and fifth issues – co-located load, 
flexible services, and proximate load – are primarily directed at the CAISO Tariff, where these 
 
4  OSC at Section III.B. 
5  OSC at Section III.C.  The CAISO Tariff also is identified as potentially unjust and unreasonable with 
regards to how it allows “load with BTMG to net its BTMG against its load for purposes of 
calculating Regional Access Charges.”  The CAISO Tariff’s existing BTMG netting rule requires the 
relevant BTMG load to take retail standby service from the relevant utility, a fact omitted in the OSC 
discussion of this issue and which fact impacts the relevant utility and others. 
6  OSC at Section III.D. 
7  OSC at Section III.E.

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types of transmission services would typically reside.8  Nonetheless, the issues for the CAISO 
and TOs to address are interconnected, whether they require changes to the CAISO Tariff, the 
TO Tariffs, or both.  Accordingly, successful FPA section 205 filings will require significant 
coordination among the CAISO, TOs, and other stakeholders, such as California regulators.  The 
Joint PTOs understand that the CAISO plans to file responsive tariff amendments in November 
(assuming its abeyance request is granted), and the Joint PTOs cannot revise their respective TO 
Tariffs in a vacuum.9  For example, the roles, responsibilities, and processes to interconnect and 
serve large loads taking new types of transmission services will likely be dependent on 
modifications to existing services under the CAISO Tariff.  As the stakeholders work through 
this process, necessary deviations to reflect regional differences in CAISO must also be 
considered.  The Joint PTOs have already been meeting with the CAISO weekly, and have 
coordinated in developing their respective requests for abeyance, including by conferring 
regarding the issues expected to be addressed, the contemplated process for implementing 
appropriate FPA section 205 revisions, and the anticipated filing schedule.  Although CAISO 
and the Joint PTOs are filing separately in recognition of their distinct responsibilities and filing 
rights, their respective requests reflect a coordinated regional effort consistent with Commission 
direction.10  The Joint PTOs intend to continue working together through the stakeholder process 
 
8  LS Power Grid California, LLC and DesertLink, LLC more specifically note that they are 
independent transmission owners that do not serve retail load or have load-serving obligations.  
Matters involving state-jurisdictional retail tariffs and agreements, retail standby service, resource-
adequacy procurement, and CAISO-administered transmission services, ancillary services, market 
participation, and generator-interconnection service therefore do not implicate their TO Tariffs in the 
same manner.  Any potential FPA section 205 filing by either company would be limited to matters 
that implicate its own TO Tariff or a PTO-administered agreement. 
9  See CAISO Informational Report at p. 15 (July 20, 2026).  Given CAISO governance rules and the 
need for CAISO Board approval, revisions to the CAISO Tariff are unlikely to be finalized until close 
to the November 16 filing deadline, assuming the CAISO is granted its own abeyance.  The CAISO 
does not currently plan to seek Board approval until October 28, just over two and a half weeks 
before a 90-day extended filing deadline for tariff changes. 
10  See OSC at P 35.

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to identify appropriate revisions to the CAISO and/or TO Tariffs.11  The Joint PTOs’ FPA 
section 205 filings are currently expected to present revisions to the TO Tariffs to include study, 
application, and operational procedures for the interconnection of large loads, as well as 
provisions to address transparency, cost-recovery, financial-security, and rate-treatment 
provisions intended to prevent cost shifting.  These matters remain under development and may 
evolve through coordination with CAISO and stakeholders.  Joint PTOs will coordinate with 
CAISO according to its publicly posted schedule, conform their proposed revisions following 
CAISO's scheduled October 28, 2026 Board consideration, and complete internal approvals in 
time to submit their filings by November 16, 2026.   
B. 
Briefing Questions 
The Commission also identifies several issues for further briefing.12  The Joint PTOs also 
request to toll the deadline to respond to the briefing questions for 90 days, consistent with the 
OSC’s explanation of the effect of an abeyance.13  The Joint PTOs believe an abeyance is 
appropriate as to the briefing questions as they are wholly interrelated with the issues to be 
addressed in the Joint PTOs’ Section 205 filings, as described above.  
III. 
CONCLUSION 
For the reasons described above, the Joint PTOs respectfully request that the Commission 
grant the Request for Abeyance and extend each of the Joint PTOs’ deadlines to respond in full 
to the OSC to November 16, 2026.   
 
 
 
11  For example, the Joint PTOs cannot create new application processes and study processes to account 
for new CAISO flexible, co-located, and/or proximate transmission services without knowing the 
characteristics of those services. 
12  OSC at Section IV. 
13  See OSC at P 35 (holding that “the deadline to respond to this order” will be held in abeyance for 90 
days upon a successful petition by a TO).

8 
Respectfully submitted, 
Ellen C. Kenney 
/s/ Ellen C. Kenney 
By: 
Ellen C. Kenney 
Attorneys for 
SOUTHERN CALIFORNIA EDISON COMPANY 
2244 Walnut Grove Avenue 
Post Office Box 800 
Rosemead, California 91770 
Telephone: 
(626) 302-9519 
E-mail: 
Ellen.Kenney@sce.com 
 
Jonathan J. Newlander 
/s/ Jonathan J. Newlander  
By: 
Jonathan J. Newlander 
Attorney for 
SAN DIEGO GAS & ELECTRIC COMPANY 
8330 Century Park Court, CP32D 
San Diego, California 92123 
Telephone: 
(619) 577-3468 
E-mail: 
JNewlander@sdge.com 
 
Tara Kaushik 
Grady Mathai-Jackson 
John P. Perkins, III 
William Brenc 
/s/ John P. Perkins, III 
By: 
John P. Perkins, III 
Attorneys for 
PACIFIC GAS & ELECTRIC CO. 
Pacific Gas and Electric Company

9 
Law Department, 19th Floor  
300 Lakeside Drive, Suite 210  
Oakland, CA 94612  
Telephone: 501-551-4036 
Email: john.perkins@pge.com 
 
 
 
Robert L. Daileader 
/s/ Robert L. Daileader 
By: 
Robert L. Daileader 
Attorney for 
SUNZIA TRANSMISSION, LLC 
Nixon Peabody LLP 
799 Ninth Street NW, Suite 500 
Washington, DC  20001 
Telephone: 
(202) 288-2069 
E-mail: 
rdaileader@nixonpeabody.com 
 
 
Amy E. McDonnell 
Ashley M. Bond 
/s/ Ashley M. Bond 
By: 
Ashley M. Bond 
 
Counsel for  
CITIZENS SUNRISE 
TRANSMISSION LLC, CITIZENS SYCAMORE-
PENASQUITOS TRANSMISSION LLC, AND CITIZENS S-
LINETRANSMISSION LLC

10 
Duncan & Allen LLP 
1730 Rhode Islan Ave., N.W 
Suite 700 
Washington, DC  20036 
Telephone: 
(202) 289-8400 
Facsimile: 
(202) 289-8450 
E-mail: 
amb@DuncanAllen.com 
 
 
 
Blake R. Urban 
/s/ Blake R. Urban 
By: 
Blake R. Urban 
Attorney for 
LS POWER GRID CALIFORNIA, LLC AND DESERTLINK, 
LLC 
16150 Main Circle Drive, Suite 310 
Chesterfield, MO 63017 
Telephone: 
(636) 231-0475 
E-mail: 
burban@lspower.com 
 
 
 
Elizabeth Ramey 
/s/ Elizabeth Ramey  
By: 
Elizabeth Ramey 
Attorney for 
GRIDLIANCE WEST LLC; HORIZON WEST 
TRANSMISSION, LLC; AND TRANS BAY CABLE LLC 
 
NextEra Energy, Inc. 
801 Pennsylvania Avenue NW, Suite 200 
Washington, DC 20004 
Telephone: 
(202) 909-5695 
E-mail: 
elizabeth.ramey@nexteraenergy.com

11 
Verónica Gómez  
/s/  Verónica Gómez 
By: 
Verónica Gómez  
Attorney for 
VIRIDON PATH 15 LLC 
 
515 North State Street, Suite 1150 
Chicago, IL 60654 
Telephone: (773) 551-1920  
E-mail: veronica@viridon.com 
 
 
 
 
Dakota L. Councilman 
/s/ Dakota L. Councilman 
By: 
Dakota L. Councilman 
Attorney for 
VALLEY ELECTRIC ASSOCIATION, INC. 
 
Davison Van Cleve, P.C.                   
4675 W. Teco Ave., Suite 230          
Las Vegas, NV 89118                       
Telephone: (702) 267-6763                 
E-mail: dlc@dvclaw.com

12 
Joseph C. Hall 
/s/ Joseph C. Hall 
By: 
Joseph C. Hall 
Attorney for 
STARTRANS IO, LLC 
 
Joseph C. Hall 
Edwin G. Kichline 
Kelly A. Cuthbertson 
Eversheds Sutherland (US) LLP 
700 Sixth Street, NW, Suite 700 
Washington, DC 20001-3980 
Telephone: (202) 383-0100 
Email: joehall@eversheds-sutherland.com 
Email: edwinkichline@eversheds-sutherland.com  
Email: kellycuthbertson@eversheds-sutherland.com 
 
Ali Amirali 
General Manager 
Startrans IO, L.L.C. 
5 Greenwich Office Park 
Greenwich, Connecticut 06831 
Telephone: (408) 204-7630 
Email: aamirali@lotuspartners.com 
Dated:  August 3, 2026

13 
CERTIFICATE OF SERVICE 
I hereby certify that I have this day served the foregoing REQUEST FOR ABEYANCE 
OF SOUTHERN CALIFORNIA EDISON COMPANY; PACIFIC GAS AND ELECTRIC 
COMPANY; SAN DIEGO GAS & ELECTRIC COMPANY; CITIZENS SUNRISE 
TRANSMISSION LLC; CITIZENS SYCAMORE-PENASQUITOS TRANSMISSION 
LLC; CITIZENS S-LINE TRANSMISSION LLC; SUNZIA TRANSMISSION, LLC; LS 
POWER GRID CALIFORNIA, LLC; DESERTLINK, LLC; GRIDLIANCE WEST LLC; 
HORIZON WEST TRANSMISSION, LLC; TRANS BAY CABLE LLC; VIRIDON PATH 
15 LLC; VALLEY ELECTRIC ASSOCIATION, INC.; AND STARTRANS IO, LLC upon 
each person designated on the official service list compiled by the Secretary in this proceeding. 
Dated at Rosemead, California, this 3rd day of August 2026. 
 
 
/s/ Karen Abarca 
 
 
Karen Abarca 
Senior Legal Administrative Assistant 
SOUTHERN CALIFORNIA EDISON COMPANY 
2244 Walnut Grove Avenue 
Post Office Box 800 
Rosemead, California 91770