(Ii) Initiating the Generator Downsizing Request 24
Submitted September 12, 2014
by Sempra
Section / Comment / ISO Response
6.2.6.3 Qualified Generating Facilities
(i) Commercial Operation Status /
(i) Commercial Operation Status[22]
The Generating Facility must be in one of the following two categories:(a) Currently in the CAISO queue and has not yet achieved the last Commercial Operation Date in its Generator Interconnection Agreement.
(b) Has achieved the last Commercial Operation Date in its Generator Interconnection Agreement with a total megawatt capacity amount that is lower than the amount specified in its Generator Interconnection Agreement by an amount that is greater than five percent (5%) or 10 MW, but not more than 25% of the Generating Facility’s MW capacity. the de minimis threshold set forth in Section 6.2.6.3 (iii)(c).
Sempra Comment: We suggest deletion, as this passage, when combined with the other language in this subsection 6.2.6.3(i)(b), is confusing and could be misinterpreted as limiting requests under the Generator Downsizing Process to a maximum of 25% of the Generating Facility’s capacity.
The CAISO’s August 29 draft BPM recommendation at section 6.2.6.3(i)(b) appears to be for the purpose of clarifying that a Generating Facility would not be eligible for the Generator Downsizing Process if the proposed MW reduction is within the de minimis safe harbor threshold described in section 6.2.6.3(iii)(c). Put another way, the Generating Facility need not
participate in the Generator Downsizing Process unless its MW reduction exceeds the section 6.2.6.3(iii)(c) safe harbor threshold.
However, as drafted, the language at section 6.2.6.3(i)(b) is confusing, and could lead to a mistaken conclusion that a Generating Facility’s maximum eligible MW downsizing amount in the Generator Downsizing Process may not exceed 25% of the Generating Facility’s capacity. As Sempra USGP understands it, that is not the intent of the section 6.2.6.3(i)(b) language, in as much as the CAISO’s May 29, 2014 tariff filing in Docket No. ER14‐2063‐000 made clear at p.2 of the transmittal letter that “[c]ustomers can downsize by any amount desired in each annual” Generator Downsizing Process. Accordingly, in order to remove the potential for confusion, Sempra USGP recommends that the 6.2.6.3(i)(b) language be revised to read as follows:
(b) Has achieved the last Commercial Operation Date in its Generator
Interconnection Agreement with a total megawatt capacity amount that is lower than the amount specified in its Generator Interconnection Agreement by an amount that is greater than the de minimis threshold set forth in Section 6.2.6.3(iii)(c) below. By simply directing the reader to the de minimis safe harbor provision at section 6.2.6.3(iii)(c) of
the BPM, rather than attempting to repeat that provision in section 6.2.6.3(i)(b), this will reduce the potential for confusion as to which projects are eligible for the Generator Downsizing Process. / Sempra revision accepted with an even more specific cross-reference.
Recommendation Comments on PRR 768
Submitted August 25, 2014 Updated Response September 23, 2014
by Susan Schneider on behalf of Large Scale Solar Association
Section / Comment / ISO Response
6.2.6.3 Generator Downsizing Process / An Interconnection Customer that qualifies seeking to downsize the MW capacity of its Generating Facility may submit a complete Generator Downsizing Request during the annual Generator Downsizing Request Window of October 15 to November 15. Such requests in order to will be studied as part of the next annual reassessment process. An Interconnection Customer whose Generating Facility that meets the qualifications requirements described below may participate in the Generator Downsizing Process in more than one generator downsizing study cyclece. / The ISO has incorporated most of LSA’s comments, with the exception of the highlighted section below. The ISO has also added language to make clear that only those downsizing requests that meet the applicable tariff eligibility requirements will be studied.
An Interconnection Customer seeking to downsize the MW capacity of its Generating Facility may submit a complete Generator Downsizing Request during the annual Generator Downsizing Request Window of October 15 to November 15. Such requests that meet the downsizing eligibility requirements will be studied as part of the next annual reassessment process. A Generating Facility that meets the requirements described below may participate in the Generator Downsizing Process more than once.
6.2.6.3 Qualified Generating Facilities / Regardless of whether a Generating Facility is from a previous study process, the Interconnection Customer it will qualify for the Generator Downsizing Process if it meets the following criteria:
LSA’s Comment: What does this mean? / LSA revision accepted.
The Generator Downsizing Process is applicable to all projects regardless of which study process the project is in. The project does not need to be in the most recent study process to participate in the Generator Downsizing Process.
6.2.6.3 Qualified Generating Facilities
(i) Commercial Operation Status /
Commercial Operation Status[23]
The Interconnection Customer Generating Facility must be in one of the following two categories:(a) Generating Facility Ccurrently in the CAISO queue and has not yet achieved the last Commercial Operation Date in its Generator Interconnection Agreement.
(b) Generating Facility hHas achieved the last Commercial Operation Date in its Generator Interconnection Agreement with a total megawatt capacity amount that is lower than the amount specified in its Generator Interconnection Agreement by an amount that is greater than the greater of five percent (5%) or 10 MW, or more than 25% of the Generating Facility’s MW capacity. / First three LSA revisions accepted.
Please see below modified language.
(b) Has achieved the last Commercial Operation Date in its Generator Interconnection Agreement with a total megawatt capacity amount that is lower than the amount specified in its Generator Interconnection Agreement by an amount that is greater than the de minimis threshold set forth in Section 6.2.6.3 (iii)(c).
6.2.6.3 Qualified Generating Facilities
(i) Commercial Operation Status / Total MW Capacity in GIA / Actual MW Capacity / Downsizing Request Required / Reason
100 / 95 / No / Shortfall MW not greater than 5% or 10 MW of GIA MW capacity
100 / 90 / No / Actual MW within 10 MW of GIA MW capacity
200 / 185 / Yes / Shortfall MW greater than 5% and or 10 MW of GIA MW capacity
40 / 30 / No / Shortfall MW reduction not more than the greater of 5% or 10 MW, or 25% of GIA MW capacity
20 / 10 / Yes / Actual MW reduction more than 25% of GIA MW capacity
LSA’s Comment: It is not greater than 10% of the MW capacity. / 1st LSA revision accepted.
The ISO did not accept the 2nd change, but did include the addition of a criteria summary table based on the Draft Final Proposal.
6.2.6.3 (ii) Good Standing Requirements / The Interconnection Customer must meet the following requirements:
(a) Interconnection Customer must be in compliance with all applicable requirements of the CAISO Tariff it is being processed under which the Interconnection Request is being processed, including timely submittal of all Interconnection Financial Security postings that have come due.
LSA’s Comment: This language repeats the same thing twice and is unnecessary. / The ISO agrees that rewording is appropriate. Please see below modified language.
Interconnection Customer must be in compliance with all applicable requirements of the CAISO Tariff under which the Interconnection Request is being processed, including timely submittal of all Interconnection Financial Security postings that have come due.
6.2.6.3 (ii) Good Standing Requirements (c) / An Interconnection Customer’s GeneratingHowever a Generating Facility under category (i)(b) above that failings to meet these good standing criteriona of good standing solely due to having achieved the last Commercial Operation Date indicated in its Generator Interconnection Agreement with a total megawatt capacity being lower than the amount specific in its Generator Interconnection Agreement by an amount greater than the de minimis threshold under category (i)(b) is eligible to participate in the annual Generator Downsizing Process.
LSA’s Comment: Indented to make it clear that this is part of (c) and deleted unnecessary language. / LSA revision accepted with the modification of changing “good standing” criterion to “Commercial Operation status” criterion.
However a Generating Facility failing to meet the Commercial Operation status criterion under category (i)(b) is eligible to participate in the annual Generator Downsizing Process.
6.2.6.3 (iii) Other Opportunities to Reduce Generating Facility Size / (a) Interconnection CustomersGenerating Facilities that have not yet entered into the Phase II study process that can reduce the generating capacities of their Generating Facilities pursuant to GIDAP Section 6.7.2.
(b) Interconnection CustomersGenerating Facilities with a partial termination clause in their Generator Interconnection Agreements.
(c) Commercially operational Generating Facilities within the Dde Mminimis threshold of five percent (5%) or 10 MW of their MW capacities, whichever is greater, but not more than 25% of the MW capacities of the Generating Facilities. / LSA revisions accepted other than suggested capitalization of “de minimis.”
Additional CAISO Revisions are included.
Commercially operational Generating Facilities within the de minimis threshold of no more than the greater of five percent (5%) of their MW capacities or 10 MW but not more than 25% of the Generating Facilities MW capacities.
6.2.6.3 (iii) Other Opportunities to Reduce Generating Facility Size (d) / Any other proposed modifications must be submitted separately pursuant to GIDAP Section 6.7.2. CAISO evaluation of such proposed modifications to Generating Facilities that are also participating in the annual Generator Downsizing Process will be deferred until the completion of the Generator Downsizing Process if they would affect the outcome of the reassessment study where the Generator Downsizing Request will be evaluated.
LSA’s Comment: There is no reason to defer consideration of modification requests that would not affect the study results, and such deferrals could impede project development progress and cause the IC to miss critical milestones. / The ISO is not recommending incorporating LSA’s proposed additions into the GIDAP BPM because they are inconsistent with the provisions in Section 7.5.2 of the GIDAP shown in boldface type below:
7.5.2Modifications Other than Generator Downsizing Requests
Proposed modifications to Generating Facilities other than proposed reductions in the megawatt capacities of Generating Facilities are separately addressed in Section 6.7.2 and in the modification provisions under other CAISO interconnection procedures and are beyond the scope of the annual Generator Downsizing Process. Such proposed modifications must be submitted separately and will not be evaluated as part of the Generator Downsizing Process under this Section 7.5.
The CAISO will defer evaluation of any other proposed modification made by an Interconnection Customer that is participating in the annual Generator Downsizing Process until the completion of the applicable annual Generating Downsizing Process. Other than the deferral of such modification requests, nothing in this Section 7.5.2 will diminish the rights of the Interconnection Customer to request a modification pursuant to the applicable interconnection procedures under which the Interconnection Customer’s Interconnection Request is being processed.
The ISO will accept requests for other proposed modifications for projects requesting downsizing. However, as required by Section 7.5.2 of the GIDAP, the ISO will defer evaluation of any other proposed modification made by an Interconnection Customer that is participating in the annual Generator Downsizing Process until the completion of the applicable annual Generating Downsizing Process.
6.2.6.3 (iv) Initiating the Generator Downsizing Request / Failure to submit either of these two items will void the Generator Downsizing Request, while submitting the Generator Downsizing Request for with some errors or omissions will not void the Generator Downsizing Request provided the Interconnection Customer cures the deficiency pursuant to Section 6.2.6.3(v) below. If the Generator Downsizing Request does not include both items, the CAISO will return the Generator Downsizing Request package to the Interconnection Customer as incomplete and not evaluate the package. The Interconnection Customer may re-submit a complete package if the Generator Downsizing Request Window is still open. / LSA revision accepted.
6.2.6.3 (v) Validating the Generator Downsizing Request / The CAISO will provide the Interconnection Customer with a Downsizing Generator Payment Obligation Agreement executed by the CAISO within ten (10) Business Days of the Generator Downsizing Request being deemed complete, valid, and ready to be studied. The Interconnection Customer must execute and return to the CAISO the Downsizing Generator Payment Obligation Agreement within ten (10) Business Days thereafter.
LSA’s Comment: If the request is complete and valid, it is “ready to be studied.” / LSA revision not accepted because the BPM language as proposed by the ISO is consistent with the Tariff.
6.2.6.3 (v) Validating the Generator Downsizing Request / After a Generator Downsizing Request has been deemed valid, the reduced MW value of the project will be updated in RIMS and reflected in the CAISO Generator Interconnection Queue.
LSA’s Comment: It seems preferable to reflect the reduced value in RIMS and the queue once the downsizing request is studied and approved. However, it would be appropriate to note in the queue listings that a downsizing request is pending. / Once the Generator Downsizing Request has been deemed valid, the reduced MW have been approved and should be included in RIMS. Once the Generator Downsizing Request Window has closed and the request is deemed to be valid there is no option for going back to pre-downsizing requested capacity.
6.2.6.3 (vi) Validating the Generator Downsizing Request / A Generator Downsizing Request may only be withdrawn by the Interconnection Customer during the applicable Generator Downsizing Request Window. The Generator Downsizing Deposit, less costs incurred during the validation process, will be refunded to those withdrawing during this timeframe.
Interconnection Customers that withdraw their Interconnection Requests from the Generator Interconnection Queue following the close of the Generator Downsizing Request Window will not be refunded any portion of the Generator Downsizing Deposit.
LSA’s Comment: Indentation added. However, it seems contradictory to state that the request can’t be withdrawn after the window closes but then provide that an IC withdrawing a project after the window closes won’t get its money back. Can they withdraw the request after the window closes or not? / LSA’s proposed commas and indentation accepted.
Once the Generator Downsizing Request Window closes the downsizing request cannot be withdrawn. However, the IC can withdraw the original IR from the ISO queue, which will result in the customer’s downsizing request also being deemed withdrawn and the IC will forfeit its Generator Downsizing Deposit.
6.2.6.3 (vii) Use of the Generator Downsizing Deposit / The Generator Downsizing Deposits will be deposited into an interest-bearing account and used to pay prudent costs incurred by the CAISO, the applicable Participating TO(s), and/or third parties at the direction of the CAISO and the applicable Participating TO(s) to perform and administer the Generator Downsizing Process. These costs include, but are not limited to, the costs of studying the Generator Downsizing Request in the reassessment process performed pursuant to GIDAP Section 3.5.1.2 (where the Generator Downsizing Requests are studied), and costs associated with amending the Generator Interconnection Agreement of the Downsizing Generator to incorporate changes resulting from the Generator Downsizing Process. / LSA revision accepted.
6.2.6.3 (ix) Invoicing and Payment of Downsizing Costs / The applicable Participating TO(s) will submit an invoice to the CAISO for completed work in support of the Generator Downsizing Process within 75 calendar days. The Interconnection Customer will receive invoices from the CAISO that list study expenses incurred and corresponding amounts due, including the costs invoiced by the Participating TO(s). The amounts due will be offset against the Interconnection Customer’s Generator Downsizing Deposit. If the amounts due exceed the amount on deposit, the invoice will direct the Interconnection Customer to pay the amount required in excess of the deposit within thirty (30) calendar days. If the amounts due are less than the amount on deposit, the unused balance plus applicable interest from the interest-bearing account where funds are deposited will be refunded to the Interconnection Customer. / LSA revision accepted.
6.2.6.3 (xii) Interaction with Executed Generator Interconnection Agreements / Downsizing Generators with executed Generator Interconnection Agreements derived from either Appendix CC or Appendix EE to the CAISO Tariff, GIDAP Section 7.5.13 will apply in lieu of Article 5.19.4 of such Generator Interconnection Agreements, and any Generating Facility capacity reductions permitted under Article 5.19.4 will be performed in accordance with and subject to GIDAP Section 7.5.13.
LSA’s Comments: It does not seem proper for language in a BPM (or even in the tariff) to supersede language in an executed GIA. / This language is from the tariff developed through the stakeholder process and approved by FERC in Docket No. ER14-2063.
Please see below modified language.
With respect to Interconnection Customers with executed Generator Interconnection Agreements derived from either Appendix CC or Appendix EE to the CAISO Tariff as they existed prior to the effective date of the Generator Downsizing amendment in FERC Docket No. ER14-2063, any Generating Facility capacity reductions permitted under Article 5.19.4 will still be permitted, but will be performed in accordance with and subject to GIDAP Section 7.5.13.
Recommendation Comments on PRR 768
Submitted August 25, 2014
by Brad Wetstone on behalf of PG&E Updated Response September 23, 2014
Section / Comment / ISO Response
6.2.6.3
(ii) Good Standing Requirements / (a) Interconnection Customer must be in compliance with all applicable requirements of the CAISO Tariff it is being processed under which the Interconnection Request is being processed, including timely submittal of all Interconnection Financial Security postings that have come due. / PG&E comment accepted.
6.2.6.3
(ii) Good Standing Requirements / (b) Interconnection Request cannot be withdrawn or deemed withdrawn by the CAISO. A Generating Facility that is deemed withdrawn with a cure period that has not expired by the close of the applicable Generator Downsizing Request Window may apply, but cure must be made prior to the expiration of the cure period. Failure to cure during the cure period will result in the withdrawal of the Generating Downsizing Request from the annual Generator Downsizing Process.
PG&E’s Comments: PG&E requests clarification of the meaning of “cure period” as used in this provision. The phrase “cure period” appears three times. It is not clear if the phrase refers to a need to cure a deficiency in connection with the underlying IR or a deficiency associated with the IC’s Generator Downsizing Request. Please clarify. / The project must cure all items for which it had a deemed withdrawn status (i.e. not meeting requirements related to an active Interconnection Request, or a GIA) at the time it applied for the annual Generator Downsizing Process in order to be eligible for this annual process. Similar language regarding the cure period is contained in Section 7.5.3.2(b) of the GIDAP.
6.2.6.3
(iv) Initiating the Generator Downsizing Request /
(ii) Initiating the Generator Downsizing Request[24]
During the Generator Downsizing Request Window (October 15 through November 15 of each year) a qualifying Interconnection Customer must submit a Generator Downsizing Request package consisting of the following:- Completed Generator Downsizing Request form – Link: Link to be added at a later date.
- Generator Downsizing Deposit of $60,000 (Fed wire or check)
Failure to submit either of these two items will void the Generator Downsizing Request. Submitting the Generator Downsizing Request with some errors or omissions will not void the Generator Downsizing Request provided the Interconnection Customer cures the deficiency pursuant to Section 6.2.6.3(v) below. If the Generator Downsizing Request does not include both items, the CAISO will return the Generator Downsizing Request package to the Interconnection Customer as incomplete and not evaluate the package. The Interconnection Customer may re-submit a complete package if the Generator Downsizing Request Window is still open.
6.2.6.3
(xii) Interaction with Executed Generator Interconnection Agreements /
(xii) Interaction with Executed Generator Interconnection Agreements[25]
For Downsizing Generators with executed Generator Interconnection Agreements in derived from either Appendix CC or Appendix EE to the CAISO Tariff, GIDAP Section 7.5.13 will apply in lieu of Article 5.19.4 of such Generator Interconnection Agreements, and any Generating Facility capacity reductions permitted under Article 5.19.4 will be performed in accordance with and be subject to GIDAP Section 7.5.13. / PG&E comments accepted.1