Updates to the Interconnection Application Process in the Wake of FERC Order 2023

Earlier this year, Clean Energy Counsel issued a Client Alert regarding the proposed Revised Addendum to Final Proposal and CAISO’s initiative to adopt processes that build on the requirements established by FERC Order 2023.? As the process changes continue to move forward, CAISO held a 2024 Resource Interconnection Standards Fair on September 17, 2024, to update stakeholders that have submitted interconnection requests for the Queue Cluster 15 study process (“Cluster 15”). ?

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The meeting was highly informative and instructional, and it provided interconnection customers with a glidepath for proceeding through the application process.? If your organization has a pending application in Cluster 15 and a representative of your organization was unable to attend the meeting, we highly encourage you to visit CAISO’s website to review materials discussed at the meeting.? Materials can be found at Resource Interconnection Standards Fair | California ISO (caiso.com).

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Highlights from the meeting include:

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• Overview of the Resource Interconnection Standards (new Appendix KK) pending FERC Approval), which will be applicable to Cluster 15 and future clusters.
• Discussion on process for re-submission of interconnection request and supporting documentation within the new Grid Resource Interconnection Portal (“GRIP”). Cluster 15 interconnection requests will not be managed through RIMS as was the case with previous requests.? GRIP will go live on October 1st, and interconnection customers will be able to re-submit interconnection requests through December 2nd.? The application window will close on December 2, 2024.
• Updates regarding the new fee and study deposit amounts and timing for submission of fees. All fees and deposits must have already been paid at the time of submission of an updated interconnection request.? Fees and deposits include an Interconnection Study Deposit, Application Fee and Commercial Readiness Deposit.? There are also additional deposits that may be required depending upon project specific circumstances, including: Merchant Option Deposit, Regulatory Limitation Site Control Deposit, and Auction Deposit.
• Overview of site control requirements and the parameters for demonstrating site control. Interconnection Customers must demonstrate no less than ninety (90%) Site Control, unless Site Control is unobtainable due to regulatory limitations (as further defined in the Business Practice Manual) in which case interconnection customer may submit a deposit in lieu of Site Control of $10,000/MW, subject to a minimum of $500,000 and a maximum of $2,000,000.
• Discussion of acceptable modifications to interconnection requests during the resubmission process. There are several areas where interconnection customers can modify interconnection requests including: changing technology or fuel; decrease in electrical output; changing deliverability status to Energy Only Deliverability Status Requested, Partial Capacity Deliverability Requested, or a lower fraction of Partial Capacity Deliverability Status Requested; adding or increasing energy storage capacity, without increasing Interconnection Service Capacity; and changing Point of Interconnection within the same Transmission Zone.? Take note that the CAISO will not be accepting modifications to increase Interconnection Service Capacity or requested Deliverability.
• Walkthrough of interconnection data posted to the CAISO website, use of the Points of Interconnection Heatmap, and GRIP.

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To assist with completing and re-submitting an interconnection request in GRIP, interconnection customers can review information from new appendices 1,2,3 and Attachment A of pending CAISO Tariff Appendix KK (Resource Interconnection Standards), found here.? As part of the interconnection request submission process, interconnection customers must also submit their own scoring assessment, which will be considered by the CAISO along with the LSE point allocations.? CAISO will conduct an analysis with a scoring assessment to determine projects eligible to move forward in the Cluster 15 study process. ?CAISO anticipates that there may be circumstances where projects may have tied scores.? In such circumstances, CAISO will resolve the ties by allowing the tied projects to elect to either participate in an auction or withdraw their interconnection request.? The auction process will take place in February 2025, and interconnection customers with an impacted project will be allowed to submit a single, sealed bid of $/MW.? Auction winners will be notified by March 5, 2025, and are required to post an Auction Deposit.

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Another key process change is that the CAISO will no longer have individual project scoping meetings.? There will only be one scoping meeting per transmission zone and each scoping meeting participant must have a transmission planning NDA (“TP NDA”) in place.? For applicants that have executed a company TP NDA, each company representative must have his/her own Exhibit A to attend the scoping meeting.? With respect to consultants, the consulting entity will not be allowed to execute a TP NDA unless such consultant has established clients that have TP NDA’s on file.? The scoping meeting is expected to occur in the April/May 2025 timeframe.

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Finally, as noted in our previous client alert, participation in a RFI, RFO, bilateral negotiation or other procurement process with an LSE could possibly enhance the likelihood of a project moving forward in the Cluster 15 study process as the new process contemplates LSE point allocations.

For further information concerning this update, please contact Shae Harvey.