EL26-71-000 · 2026-08-03 · California Independent System Operator Corporation

CAISO requests more time to answer the June 18 show cause order

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 FOR ABEYANCE 
 
Pursuant to Rule 212 of the Rules of Practice and Procedure of the 
Federal Energy Regulatory Commission, the California Independent System 
Operator Corporation (CAISO) respectfully submits this motion to hold the instant 
proceeding in abeyance for 90 days from the deadline to respond, i.e., until

2 
November 16, 2026.1 As detailed below, this abeyance period will provide the 
CAISO sufficient time to work with stakeholders to develop all policies necessary 
to address the Commission’s preliminary findings in the Order to Show Cause on 
the justness and reasonableness of the CAISO tariff concerning large loads, and 
to submit a filing to the Commission under Section 205 of the Federal Power Act 
(FPA).2 The abeyance period also will align with CAISO Participating 
Transmission Owners’ requests, such that the CAISO and its Participating 
Transmission Owners will be able to submit all relevant Section 205 filings to 
address the findings of the Commission in the Order to Show Cause by 
November 16, 2026.  The CAISO appreciates the Commission’s recognition of 
the unique regional differences present in California in the Order to Show Cause.  
Providing time for the CAISO and its Participating Transmission Owners to 
develop these filings will allow for tailored solutions that reflect these regional 
nuances and will avoid disrupting existing commercial arrangements, as the 
Order to Show Cause requires.3 The CAISO believes that granting this motion for 
abeyance will enable the CAISO and its Participating Transmission Owners to 
satisfy the Order to Show Cause, remove the need for further action under FPA 
Section 206, and rather than causing any harm to interested parties, will expedite 
the overall conclusion of the proceeding and the implementation of the reforms 
envisioned by the Commission in the Order to Show Cause. 
 
1  
18 C.F.R. § 385.212.  Capitalized terms not otherwise defined herein have the meanings 
set forth in Appendix A to the CAISO tariff. 
2  
California Independent System Operator Corp., 195 FERC ¶ 61,214 at P 35 (2026) 
(Order to Show Cause). 
3  
Id. at P 34.

3 
 
I. 
Background 
In the Order to Show Cause, the Commission identified a series of 
complex issues related to integrating large loads onto the transmission system. 
While the CAISO has prepared for and reliably served concentrated growth in 
large loads to date, it also understands the need to evolve policies and 
processes to enable the accelerated additions of large loads and the additional 
complexity that they may introduce. The CAISO has identified similar issues to 
the Commission over the past few months regarding changing system needs 
related to new large loads. In response, the CAISO has convened several 
stakeholder processes to enhance large load processes, resource adequacy 
rules, demand-side market participation, and generator interconnection 
processes. As explained further below, the CAISO’s Large Load stakeholder 
initiative will become the vehicle for CAISO reforms to address the Order to 
Show Cause, which the CAISO was planning to file pursuant to FPA Section 205 
when the stakeholder processes concluded. 
The Commission’s Order to Show Cause contemplated that the CAISO 
might prefer to address the issues raised in the Order through a Section 205 
filing, and suggested that if the CAISO wished to have the Commission hold the 
Section 206 proceeding in abeyance, it should file an appropriate motion for 
abeyance in this docket. The Commission emphasized that it would not grant 
such abeyances reflexively, that any abeyance will be limited to 90 days, and that

4 
it would look with great disfavor toward requests to extend the abeyance period.4  
The Commission anticipated that successful abeyance requests will 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. 
 
II. 
Request for Abeyance 
The CAISO files this motion for abeyance in accordance with the 
Commission’s direction in the Order to Show Cause and in recognition of the 
progress to date and planned future progress toward a Section 205 filing, 
together with the CAISO Participating Transmission Owners, that will address the 
preliminary findings in the Order to Show Cause. The CAISO respectfully 
requests that the Commission hold the Section 206 proceeding initiated with the 
Order to Show Cause in abeyance for 90 days while the CAISO and its 
Participating Transmission Owners develop their respective Section 205 filings to 
address Commission’s preliminary findings.  
The CAISO describes below the content of a potential future filing under 
FPA Section 205, with the level of detail currently available given the stage of the 
Large Load stakeholder initiative, and the explanation of the timeline for an 
anticipated Section 205 filing. The CAISO also includes a description of 
coordination with its Participating Transmission Owners, which, as the 
 
4  
Id. at P 35.

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Commission recognized in the Order to Show Cause, have a unique role in the 
large load interconnection process in California. 
 
a. 
Description of Content of Potential Future Filing Under FPA 
Section 205 
By the end of the abeyance period, the CAISO expects to submit an FPA 
Section 205 filing that, with simultaneous Section 205 filings from the 
Participating Transmission Owners, will address all the preliminary findings and 
five categories of reforms set forth in the Order to Show Cause, as appropriate 
for the CAISO region. The CAISO expects that the vast majority of its tariff 
revisions will be able to become effective as soon as approved by the 
Commission.5 Submitting such a Section 205 filing will require an expedited 
stakeholder process to develop, vet, and receive approval for the policy changes; 
however, a public stakeholder process will ensure policy changes are specifically 
tailored to the regional needs and State policies of California.  
The CAISO’s ongoing Large Load stakeholder initiative will become the 
vehicle for CAISO reforms to address the Order to Show Cause. The CAISO 
recognizes the importance of clarity on roles in planning for large loads and 
launched the Large Loads stakeholder initiative last year. Within the initiative, the 
CAISO posted an issue paper in January 2026 outlining roles, responsibilities, 
and processes to effectively integrate large loads. In addition, the CAISO posted 
 
5  
Although it is too early to know for sure, the only likely exceptions could be those 
changes that require significant software enhancements, such as new settlement charges; 
however, the CAISO will expedite any software development to deploy as soon as possible.

6 
a straw proposal in June 2026 describing possible technical requirements 
associated with large loads.  
These initial documents are well-aligned with the five categories FERC 
identified. For example, the issue paper specifically discusses the current 
treatment of large load interconnection within the CAISO, provisions for co-
location of generation and large loads, transmission service offerings, cost 
allocation and responsibility, technical requirements and standards, and 
operational requirements. The straw proposal takes the next step with regard to 
many of the technical requirements discussed in the Order to Show Cause, and 
the CAISO is actively working on a straw proposal to address other issues 
identified in the Large Loads stakeholder initiative and the Order to Show Cause.  
In addition, the CAISO has had numerous discussions with the State 
regulators that oversee retail rate design in California to ensure there is sufficient 
transparency. The Commission highlights in the Order to Show Cause the need 
to allow state regulators to effectively perform their role in protecting consumers 
from cost shifts. As described in comments to the Commission’s Advanced Notice 
of Proposed Rulemaking, California policymakers and utilities already did 
considerable work to ensure long-term forecasting, procurement, and planning 
accounted for large load growth.6 The California Public Utilities Commission and 
Pacific Gas and Electric Company have likewise been working to create a tariff 
 
6  
See, e.g., Interconnection of Large Loads to the Interstate Transmission System, 
Comments of Pacific Gas and Electric Co. (Nov. 21, 2025), Comments of California Public 
Utilities Commission (Nov. 21, 2025), Docket No. RM26-4-000.

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specifically tailored to high-voltage interconnections of large loads that aligns 
costs with benefits for all ratepayer classes.7 
The CAISO also is closely coordinating with its Participating Transmission 
Owners, to ensure the matters within their purview that the Commission raises in 
the Order to Show Cause also will be part of the future Section 205 filings. To be 
certain, this coordination began before the Order to Show Cause as the 
framework for integrating large loads in California includes significant tariff 
provisions in the Participating Transmission Owners’ tariffs and the CAISO’s tariff. 
 
b. 
Explanation of When a Section 205 Filing is Expected 
The CAISO will refocus the Large Loads initiative on the issues the 
Commission has identified in the Order to Show Cause. Given the timeline 
described in the Order to Show Cause and the Commission’s clear prioritization 
of addressing issues around integrating large loads onto the transmission 
system, the CAISO expects to expedite the stakeholder initiative, with two 
discrete proposals: a straw proposal in August and draft final proposal in 
September, before seeking Western Energy Market Governing Body and Board 
of Governors approval as necessary at the October 20 and October 28 meetings, 
respectively.8 Although the stakeholder initiative will be expedited, the CAISO will 
host workshops and solicit stakeholder feedback on the proposals to better 
 
7  
Id. 
8  
Decisional classifications will become clearer as the proposals within the Large Loads 
stakeholder initiative develop.

8 
inform the policy outcomes.9 The CAISO has already notified stakeholders of the 
expedited Large Loads initiative schedule and included the schedule in its 30-day 
filing regarding resource adequacy filed publicly in this docket on July 20, 2026: 
 
Rather than causing any harm to interested parties, holding the Section 206 
proceeding in abeyance will enable the CAISO to work with its stakeholders as 
part of the Large Loads stakeholder initiative that it has already begun—and 
which interested parties have already begun to participate—and will resolve the 
issues the Commission identifies in a more expeditious manner than proceeding 
with a response to the Order to Show Cause and traditional processing of the 
Section 206 proceeding. 
 
c. 
Coordination with Participating Transmission Owners 
The Order to Show Cause recognizes “the framework under which CAISO 
provides transmission service is unique among the RTOs/ISOs and that certain 
responsibilities fall to the Participating Transmission Owners.”10 The Order to 
Show Cause further states that the Commission appreciates that the CAISO and 
 
9  
This timeline assumes the Commission grants this motion for abeyance for 90 days, as 
contemplated by the Order to Show Cause at P 25. 
10  
Order to Show Cause at P 37. 
Action 
Date  
Post Straw Proposal 
August 12, 2026 
Stakeholder workshop 
August 19, 2026 
Comments due 
September 2, 2026 
Post Draft Final Proposal 
September 21, 2026 
Stakeholder workshop 
September 28, 2026 
Comments due 
October 12, 2026 
Western Energy Market Governing Body (if necessary) 
October 20, 2026 
CAISO Board of Governors 
October 28, 2026 
FERC Filing on Order to Show Cause 
November 16, 2026

9 
Participating Transmission Owner responsibilities may stem from how the CAISO 
and the Participating Transmission Owners allocated rights and responsibilities in 
the governing documents establishing the CAISO.11  While the Commission 
“do[es] not seek to alter that allocation of rights and responsibilities,”12 it 
“expect[s] that CAISO and the Participating Transmission Owners will coordinate 
with each other, as appropriate, to develop responses.”13  
The CAISO values these directions from the Commission. The CAISO and 
its Participating Transmission Owners coordinated on large load interconnections 
before the Order to Show Cause, and have coordinated strongly since, including 
multiple weekly meetings among various teams of subject-matter experts for the 
categories of issues identified by the Commission. By being able to maintain the 
current allocation of responsibilities between the CAISO and Participating 
Transmission Owners, Californian stakeholders will not have to start anew, 
enabling the CAISO and Participating Transmission Owners to coordinate on 
addressing all the issues identified in the Order to Show Cause by the end of the 
abeyance period. This coordination should enable rapid and smooth 
implementation of the policies necessary to address the Order to Show Cause.   
 
 
11  
Id. at P 51. 
12  
Id. 
13  
Id. at P 37.

10 
III. 
Conclusion 
For the foregoing reasons, the CAISO respectfully requests that the 
Commission grant the CAISO’s motion for abeyance in this proceeding. 
 
Respectfully submitted, 
 
/s/ William H. Weaver  
Roger E. Collanton 
  General Counsel 
William H. Weaver 
  Assistant General Counsel 
California Independent System 
Operator Corporation 
250 Outcropping Way 
Folsom, CA  95630 
(916) 608-7135 
bweaver@caiso.com  
 
Counsel for the California Independent System Operator Corporation 
 
Dated:  August 3, 2026

CERTIFICATE OF SERVICE 
 
 
I certify that I have served the foregoing document upon the parties listed on the 
official service list in the captioned proceeding, in accordance with the requirements of 
Rule 2010 of the Commission’s Rules of Practice and Procedure (18 C.F.R. § 
385.2010). 
 
Dated at Folsom, CA this 3rd day of August, 2026. 
/s/ Jacqueline Meredith 
Jacqueline Meredith 
An employee of the California ISO