MOTION FOR LEAVE TO ANSWER AND ANSWER OF THE ELECTRIC POWER SUPPLY ASSOCIATION - Docket ER24-2671-000

Sep 16, 2026

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Motion requesting leave to answer and submitting an answer on behalf of the Electric Power Supply Association in FERC Docket No. ER24-2671-000. The filing responds to CAISO’s September 3, 2024 answer to comments and protests regarding proposed tariff amendments to improve interconnection processes. EPSA argues CAISO’s commercial interest scoring criteria are unjust, unreasonable, unduly discriminatory, and contrary to open access principles and the Federal Power Act, including effects tied to LSE exclusivity agreements.

LanguageEnglish

CategoryLetters

FormatPDF

Pages10

Reading Time4 min

AccessFree to download

Motion for Leave to Answer

Motion Basis and Good Cause

Answer

Proposed Commercial Interest Scoring Category

Discriminatory Outcomes and Open Access Concerns

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION California Independent System Operator Corporation )) )) Docket No. ER24-2671-000 MOTION FOR LEAVE TO ANSWER AND ANSWER OF THE ELECTRIC POWER SUPPLY ASSOCIATION Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) Rules of Practice and Procedure, 18 C. F. R. § 385.212 , 385.213 (2023), the Electric Power Supply Association 1 (“EPSA”) respectfully moves for leave to answer and answer to respond to the California Independent System Operator Corporation’s (“CAISO” or “the ISO”) September 3, 2024 Answer2 to comments and protests on its proposal to amend its tariff to improve its interconnection process.3 Despite CAISO’s contentions, the commercial interest scoring category contained in its proposal is unjust, unreasonable, and unduly discriminatory and runs contrary to Open Access and the Federal Power Act. In addition, as EPSA explained in its initial comments, the ISO’s proposal does not adequately address discriminatory outcomes already arising from insufficient oversight of the commercial interest scoring category – including the effects of LSE exclusivity agreements. To avoid these unlawful outcomes , the Commission should 1 EPSA filed a document-less motion to intervene in this proceeding on August 6, 2024, and a Limited Protest and Comments on August 22, 2024. This pleading represents the position of EPSA as an organization, but not necessarily the views of any particular member with respect to any issue. 2 California Independent System Operator Corporation , Motion for Leave to File Answer and Answer of the California Independent System Operator Corporation to Comments and Protests , Docket No. ER24- 2671-000 , (Sept. 3, 2024) (“CAISO Answer”) . 3 California Independent System Operator Corporation , Tariff Amendment to Implement Track 2 of Interconnection Process Enhancements 2023 Initiative, Docket No. ER24-2671-000 , (August 1 , 2024) .(“CAISO Filing” or “August 1 Filing”) reject CAISO’s proposed commercial interest scoring criteria as detailed in EPSA’s limited protest submitted in the instant docket.4 I. MOTION FOR LEAVE TO ANSWER EPSA respectfully requests waiver of Rule 213(a)(2), 18 C. F. R.§ 385.213(a)(2), to permit it to answer CAISO’s Answer filed in the instant proceeding. Good cause for the waiver exists because the answer addresses specific points in the CAISO Answer to ensure a more accurate and complete record and assists the Commission in its decisionmaking process.5 As this answer will help to ensure a complete and accurate record in the case, EPSA requests that the Commission admit this answer into the record of this proceeding. II. ANSWER A. The Proposed Commercial Interest Scoring Category Is Unjust and Unreasonable and Should be Rejected CAISO’s lengthy answer attempts to justify its proposed commercial interest scoring category by dismissing valid open access concerns raised in initial comments and protests as unfounded conjecture. CAISO states that “the very low levels of load-serving entity generation self-builds have never been challenged as problematic in the past in a Commission proceeding or even raised as a concern in any prior CAISO stakeholder 4 Electric Power Supply Association, Limited Protest and Comments of the Electric Power Supply Association, Docket No. ER24-2671-000,(August 22, 2024) (“EPSA Limited Protest”) . 5 See, e.g. , N. Y. Indep. Sys. Operator Inc. , 133 FERC ¶ 61,178 at P 11 (2011) (allowing answers to answers and protests “because they have provided information that have assisted [the Commission] in [its] decision-making process”); Midwest Indep. Transmission Sys. Operator, Inc. , 102 FERC ¶ 61,069 at P 5 (2003) (accepting answers “because they provide information that clarifies the issues and aids [the Commission] in the decisional process.”); Morgan Stanley Capital Group, Inc. v. N. Y. Indep. Sys. Operator, Inc. , 93

FAQs

What does EPSA request in the motion portion of this filing?

EPSA requests a waiver of Rule 213(a)(2) and permission to answer CAISO’s September 3, 2024 answer so the Commission has a more complete and accurate record.

What is EPSA’s main objection to CAISO’s proposal?

EPSA argues CAISO’s commercial interest scoring criteria are unjust, unreasonable, unduly discriminatory, and contrary to open access and the Federal Power Act.

How does EPSA say the scoring category affects open access and oversight?

EPSA contends the category shifts LSE roles in a way that creates a barrier to open access and leaves LSEs evaluating projects without sufficiently specific, measurable criteria or supervision, contributing to discriminatory outcomes.

Sep 16, 2026

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