Transmission and Wholesale DG Working Groups:

SEIA has just become aware of a CAISO tariff filed with FERC for approval that, among other things, likely has an impact on certain SEIA project developer members seeking interconnection under the CAISO GIP, which applies to both small (20 MW or less) and large (more than 20 MW) generation  (Docket No. ER12-1855-000). The CAISO filing was made May 25, 2012. According to CAISO, the purpose of the suggested tariff changes are to better integrate CAISO transmission planning and generator interconnection procedures. The tariff changes would apply “prospectively, i.e. to the ISO queue cluster 5 (for which the cluster application window closed on March 31, 2012) and subsequent queue clusters.”

AWEA/CalWEA Protest

AWEA and CalWEA have filed a protest with the Commission regarding the CAISO tariff proposal.  AWEA states that CAISO is moving from a “first-come-first served” queue priority process to a “first ready first served approach”. AWEA  objects  that CAISO’s implementation of this approach is unjust and unreasonable because projects are deemed “viable…almost entirely on whether they have power purchase agreement’s (PPAs).” AWEA  states that PPA execution is often not a good indicator of project viability because of the “high failure rate of PPAs, which have exceeded 50% in recent years….”

Large-Scale Solar Association Limited Protest

LSA filed a “limited protest” supporting the tariff filing in part because it is a “compromise position among many stakeholders.”  However, LSA opposes “the provisions limiting reimbursement of Reliability Network Upgrades (“RNUs) to  $60,000 per megawatt (“MW”) for all projects without any corresponding “first comer, late mover” provisions….”  LSA objects to this provision on many grounds, including that it vastly underestimates the cost of Reliability Network Upgrades and thus will substantially limit reimbursement to certain generators for network upgrades.  LSA also states that,  in its current form, the tariff effectively puts Transmission Owners in charge of the Reliability Network Upgrade process, thus affording the opportunity for implementation that is discriminatory.

Next Steps for SEIA

Unless there is an objection, SEIA staff intend to file a “clean” motion to intervene out of time on Monday July 2, 2012.   This would likely make SEIA a party in the proceeding going forward.  However, the intervention would be silent on the merits of the CAISO proposal.  SEIA staff and Committee Chairs will  solicit the views of the members of the Transmission and Wholesale DG working groups as well as the California State Committee. If there is sufficient consensus on the merits, pro or con, SEIA would then file a protest and/or comments, or stay silent.  Given the short time frames if we are going to do a substantive filing the sooner the better but in no event later than Friday.

Attached are copies of:

1. The CAISO Tariff Filing May 25, 2012
2. AWEA/CalWEA Protest June 22, 2012
3. LSA Limited Protest June 22, 2012

Please do not hesitate to contact me if you have any questions, concerns or comments.

Daniel M. Adamson
VP Regulatory Affairs & Counsel