Summary

On March 29, 2024, the California Independent System Operator (CAISO) released the Track 2 final proposal for its Interconnection Process Enhancements (IPE) initiative. The proposed changes in the IPE proposal aim to address the “unprecedented and unsustainable interconnection request volumes” in the CAISO.  CAISO proposes to adopt a zonal approach that prioritizes project interconnection in areas with existing or planned transmission capacity, to cap the number of projects permitted to proceed into the study process at 150% of the available and planned transmission capacity in specific zones, and adopt scoring criteria for eligibility and prioritization in the interconnection study process. Continue Reading CAISO Releases Interconnection Process Enhancements Final Proposal

On May 20, 2022, the California Public Utilities Commission (CPUC or Commission) issued a proposed decision (PD) that would, among other things, adopt Southern California Edison’s (SCE) 24-hour-slice proposal as the new resource adequacy (RA) framework applicable to load-serving entities (LSEs) under the CPUC’s jurisdiction.  Generally, the proposal would require each LSE to show that it has enough capacity to meet its specific gross-load profile, including a planning-reserve margin, or PRM, for all 24 hours for the “worst day” of each month.  The “worst day” would be defined as the day of the month that has the highest coincident-peak-load forecast.  This new RA framework would likely be implemented in 2025, with 2024 serving as a “test year” for the new framework.

The Commission initially began examining potential changes to its RA framework due to significant and ongoing changes in California’s generation-resource mix, with the increasing reliance on variable resources such as solar and wind, and use-limited resources, such as energy storage and demand response, as well as the retirement of older natural gas generation.  The Commission solicited proposals for a new RA framework starting in 2020, and in 2021 it tentatively adopted Pacific Gas and Electric’s (PG&E) slice-of-day proposal in decision 21-07-014.  The Commission ordered a series of workshops to further develop the proposal, culminating in a workshop report submitted March 1, 2022.  During the workshops, two alternate proposals were developed:  SCE’s 24-hour-slice proposal, and a two-slice proposal developed by Gridwell Consulting.  The parties generally favored one of the two alternate proposals, rather than the PG&E slice-of-day proposal.  The selection of SCE’s 24-hour-slice proposal will set the direction for further development of the new RA framework.
Continue Reading The California Public Utilities Commission Issues Proposed Decision on New Resource Adequacy Framework

On December 6, 2021, the California ISO issued an issue paper and straw proposal (“Straw Proposal”) for its Interconnection Process Enhancements stakeholder proceeding. The California ISO initiated this stakeholder proceeding on September 30, 2021 with the issuance of a preliminary issue paper. The stakeholder process comes at a time when an unprecedented level of energy procurement in California has caused dramatic increases in the number of projects in the California ISO’s interconnection queue. The California ISO’s most recent cluster, cluster 14, saw a record number of 373 interconnection requests being submitted, representing 150,000 megawatts of generating capacity, compared to 155 requests submitted in 2020. Ultimately, the volume of interconnection requests forced the California ISO to seek authority from the Federal Energy Regulatory Commission to extend its interconnection process by approximately one year.

The Interconnection Process Enhancements initiative will have two phases. Phase 1 will focus on near-term enhancements for cluster 14 and before the summer of 2022. The proposals in Phase 1 are scheduled be submitted to the California ISO Board of Governors in May 2022. Phase 2 will focus on longer term modifications and broader reforms to align interconnection processes with procurement activities. Those proposals are scheduled to be submitted to the Board in November 2022.
Continue Reading California ISO Issues Straw Proposal in Interconnection Process Enhancements Stakeholder Proceeding

On October 29, 2021, the California Public Utilities Commission (CPUC) issued three proposed decisions intended to address potential electric capacity shortfalls in 2022 and 2023.  The proposed decisions, if approved, would implement a variety of demand-side and supply-side policies designed to ensure that in the event of extreme weather during the summer of 2022 and/or 2023, California has sufficient electric capacity to avoid outages.

Background

In August 2020, the California ISO experienced outages during the evenings of August 14 and 15, and only extraordinary efforts, including voluntary conservation efforts by California energy users, allowed the California ISO to avoid outages the following week.

After those outages, the CPUC and the California Energy Commission (CEC) have been working towards addressing potential capacity shortfalls during extreme weather events during the summer.  In November 2020, the CPUC opened a rulemaking (R.20-11-003) to ensure reliability in the event of extreme weather during the summer of 2021.  In February 2021, the CPUC adopted a decision directing procurement of additional capacity (D.21-02-028), and in March, adopted a decision directing additional demand-side and supply-side actions to increase supply and decrease load during extreme weather events (D.21-03-056).

California managed to avoid outages during the summer of 2021, although it was helped by relatively mild weather in August and September.  A stack analysis performed by the CEC this summer, however, showed the potential for capacity shortfalls of up to 4,350 megawatts (MW) for summer 2022.  In August, the CPUC implemented a second phase to R.21-11-003, to ensure reliability during the summers of 2022 and 2023.
Continue Reading California Public Utilities Commission Takes Action to Prevent Outages During Summer 2022 and 2023

On September 24, 2021, the Federal Energy Regulatory Commission issued an order (176 FERC ¶ 61,207) approving tariff revisions to amend the California ISO’s (CAISO) interconnection procedures for its current queue cluster (Cluster 14).  The CAISO had requested changes to its interconnection procedures due to the massive increase in the number of interconnection requests it received this year—373 interconnection requests representing 150,000 megawatts of generating capacity, as compared to the 155 requests in 2020.  Prior to 2021, the average number of interconnection requests that the CAISO received each year over the past 10 years was 113.  The volume of interconnection requests in 2020 caused the CAISO to issue a market notice to delay the publication of Phase I interconnection study results by one month, pursuant to its tariff authority to extend the timing for providing study results under Sections 6.6 and 8.5 of its Generator Interconnection and Deliverability Allocation Procedures (GIDAP, Tariff Appendix DD).

Rather than rely on these tariff provisions to extend the study timelines for Cluster 14, however, the CAISO sought approval to establish extensions for various interconnection deadlines early in the process, to provide generators with advance notice of the timing for Cluster 14.  Per the approved tariff revisions, Cluster 14 deadlines will be extended as follows:
Continue Reading FERC Approves Changes to CAISO Interconnection Procedures; Next Queue Cluster Application Window Not Scheduled to Open Until 2023

The California ISO held its final Summer 2021 Readiness Update call on September 24.  As reported on the call, the California ISO managed to get through summer 2021 without any load-shedding events, in contrast to last summer, when load-shedding events occurred on two days in August.  The California ISO; California energy regulatory agencies, including the California Public Utilities Commission (CPUC) and California Energy Commission (CEC); and the Governor’s office have spent considerable effort to avoid any outages for both this summer and summer 2022.  However, as California ISO Senior Vice President and Chief Operating Officer Mark Rothleder explained, California experienced less extreme weather this summer, which helped the state avoid outages.  Although July was challenging, due to a West-wide heatwave and transmission impacted by the Bootleg Fire, August and September were more mild.  In 2020, load peaked at 47,121 megawatts (MW) on August 18, at 15:57.  In 2021, load peaked at 43,982 MW on September 8, at 17:50.  By comparison, the California ISO’s highest peak was 50,270 MW in 2006.
Continue Reading California ISO Survives the Summer with No Blackouts; Battery Energy Storage Beginning to Play Larger Role

In the wake of Governor Newsom’s July 30, 2021 Emergency Proclamation intended to mitigate the strain on the California energy grid, the California Department of Water Resources (CDWR) and the California Energy Commission have been reaching out to generation owners that could accommodate the addition of 30 MW gas turbines generators, an effort now referred to as the State Power Augmentation Project.  So far, two sites have been found:  Greenleaf 1 in Yuba City and Roseville Energy Park.  Each site will accommodate two turbines.  The units were supposed to come online in mid-September.

The two turbines at Roseville Energy Park will be interconnected through the Balancing Authority of Northern California and will participate in the California ISO’s (CAISO) energy imbalance market.  The two turbines at Greenleaf 1 will interconnect to the CAISO.  Under current tariff provisions, the CAISO can interconnect 50 MWs of the 60 MW total.  The Greenleaf 1 site has cogeneration facilities that are currently mothballed but still retain existing interconnection capacity of 49.2 MWs.  Because both the cogeneration facilities and the new gas turbines are gas-fired, there will be no change to the electrical characteristics, and the CAISO can therefore interconnect the two turbines under the repowering provisions of the tariff, but only up to 49.2 MWs.
Continue Reading FERC Grants Limited Waiver to the CAISO to Immediately Interconnect Gas Turbines

On August 31, 2021, the California ISO held its August Summer Readiness Update Call.  During the month of August, the California ISO grid faired well, as temperatures were more mild, and any hot weather was localized, rather than extending across the western United States.

The California ISO also noted recent transparency improvements, including publication of a daily RA Capacity Trend and 7-Day Capacity Trend, as well a Daily Day-Ahead Summer Report and a monthly Summer Market Performance Report.
Continue Reading California ISO Holds Summer Readiness Update Call for August

In a stakeholder call yesterday, the CAISO discussed the Revised Draft Final Proposal in the Generator Deliverability Assessment stakeholder initiative. During the call, the CAISO addressed outstanding stakeholder questions, including confirming key upcoming dates for project developers.

Background on the Proposal

The CAISO is proposing revisions to its deliverability assessment methodology in response to the rapid increase in the amount of solar resources and the California Public Utilities Commission’s (CPUC) resulting transition to an Effective Load Carrying Capability (ELCC) approach to calculating qualifying capacity (QC). The CAISO’s revisions are intended to more closely align the capacity studied in the deliverability assessment with the generator’s anticipated QC under the CPUC’s new ELCC methodology. Under the current deliverability assessment methodology, generators are studied at a higher capacity than the projects can qualify for under the ELCC methodology. Under the revised deliverability methodology, projects are expected to retain their full capacity deliverability status (FCDS) and their NQC value will not be reduced, but the proposed change should be beneficial to future interconnection customers because it will free up some unused deliverability and likely result in fewer required network upgrades to receive FCDS.

As part of the proposal the CAISO is also creating a new sub-status for solar and wind projects: Off-Peak Deliverability Status (OPDS). New solar and wind OPDS resources will receive market scheduling priority by continuing to be allowed to self-schedule as an incentive for resources to develop in locations that do not trigger upgrades or trigger only low-cost localized transmission upgrades.
Continue Reading CAISO Clarifies Generator Deliverability Assessment Proposal

The California Independent System Operator (CAISO) is accepting stakeholder comments until August 13, 2019 on its new Hybrid Resources Issue Paper, kicking off a stakeholder initiative expected to proceed until April 2020. Initial comments submitted now will help shape the direction of the initiative and potential market changes.

Though not exclusively limited to renewables + storage (the CAISO defines “hybrid” to mean any combination of multiple technologies or fuel types combined into a single resource with a single point of interconnection), the CAISO emphasizes the anticipated impacts of increased storage market penetration, including new operational and forecasting challenges,  as a driving force for the initiative. The CAISO has observed that the number of hybrid resource configurations seeking interconnection comprises approximately 41% of the CAISO’s Generator Interconnection Queue’s total capacity.Continue Reading CAISO Seeks Stakeholder Feedback on Hybrid Resource Market Participation