Motion for Leave to File Answer and Answer - CAISO Tariff Amendment to Implement Track 2 of Interconnection Process Enhancements 2023 Initiative

Sep 17, 2026

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Motion submitted by the California Community Choice Association requesting leave to file an answer in FERC Docket No. ER24-2671-000 regarding CAISO’s Tariff Amendment implementing Track 2 of the 2023 Interconnection Process Enhancements Initiative. The filing argues the Commission should reject protesting parties’ claims that CAISO’s commercial interest scoring criterion is discriminatory or forces unfair exclusivity and deposits, emphasizing exclusivity agreements are longstanding and necessary under current market conditions.

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Motion for Leave to File Answer

Answers

Protesting Parties’ Arguments on the Scoring Criterion

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) California Independent System Operator ) Corporation ) Docket No. ER24-2671-000 MOTION FOR LEAVE TO FILE ANSWER AND ANSWER OF CALIFORNIA COMMUNITY CHOICE ASSOCIATION IN RESPONSE TO CERTAIN PROTESTS AND ANSWERS Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (Commission’s) Rules of Practice and Procedure, 1 the California Community Choice Association2 (CalCCA) respectfully submits this Motion for Leave to File Answer and Answer to certain answers and protests to the California Independent System Operator Corporation’s (CAISO’s) Tariff Amendment to Implement Track 2 of Interconnection Process Enhancements 2023 Initiative3 (Tariff Amendment), dated August 1, 2024. The Tariff Amendment includes reforms for the CAISO to adapt to dramatically increased requests to connect to the CAISO controlled grid. CalCCA responds herein to the 1 18 C.F.R. §§ 385.212, 385.213. 2 California Community Choice Association represents the interests of 24 community choice electricity providers in California: Apple Valley Choice Energy, Ava Community Energy, Central Coast Community Energy, Clean Energy Alliance, Clean Power Alliance of Southern California, CleanPowerSF, Desert Community Energy, Energy For Palmdale’s Independent Choice, Lancaster Energy, Marin Clean Energy, Orange County Power Authority, Peninsula Clean Energy, Pico Rivera Innovative Municipal Energy, Pioneer Community Energy, Pomona Choice Energy, Rancho Mirage Energy Authority, Redwood Coast Energy Authority, San Diego Community Power, San Jacinto Power, San José Clean Energy, Santa Barbara Clean Energy, Silicon Valley Clean Energy, Sonoma Clean Power, and Valley Clean Energy. 3 California Independent System Operator Corporation’s Tariff Amendment to Implement Track 2 of Interconnection Process Enhancements 2023 Initiative, ER24-2671-000 (Aug. 1, answers and protests of certain parties (Protesting Parties)4 to the CAISO’s answer to comments and protests to its Tariff Amendment.5 As set forth below, the Commission should reject the unfounded claims of Protesting Parties that the CAISO’s commercial interest scoring criterion (Scoring Criterion) causes discriminatory conduct of load serving entities (LSE) requiring exclusive arrangements or deposits with developers to ensure projects move forward in good faith. In fact, exclusive arrangements and deposits have been used by LSEs and developers long before the CAISO introduced the Scoring Criterion. The CAISO Tariff incorporating the Scoring Criterion should be adopted as filed given the Scoring Criterion is a reasonable tool for the CAISO to identify projects most likely to be fully developed. I. MOTION FOR LEAVE TO ANSWER Pursuant to Rules 212 and 213 of the Commission’s Rules of Practice and Procedure, CalCCA respectfully requests waiver of Rule 213(a)(2) to permit it to file this Answer.6 Good cause exists to grant this waiver because this Answer will assist the Commission in understanding the issues in the proceeding, aid the Commission in making its decision, and ensure a complete and accurate record. CalCCA, therefore, respectfully requests the Commission accept it into the record. 4 See Motion for Leave to File Answer and Answer of Clearway Energy Group LLC, ER24-2671-000 (Sept. 18, 2024); Motion for Leave to Answer and Answer of the Electric Power Supply Association, ER24-2671-000 (Sept. 18, 2024); Motion to Intervene Out-of-Time and Limited Protest of The Independent Energy Producers Association, ER24-2671-000 (Sept. 17, 2024); Answer and Supplemental Protest of Calpine Corporation, ER24-2671-000 (Sept. 17, 2024); Motion for Leave to Answer and Answer of Vistra Corp. and Dynegy Marketing and Trade, LLC, ER24-2671-000 (Sept. 17, 2024); Motion for Leave to Answer and Answer ofAypa Power LLC, ER24-2671-000 (Sept. 13, 2024) . 5 Motion for Leave to File Answer and Answer of the California Independent S

FAQs

What does the California Community Choice Association request in this filing?

CalCCA requests waiver of the applicable rule to file its answer and asks the Commission to accept the answer into the record so it can assist the Commission in understanding and deciding the issues.

What is the core dispute addressed in the answers?

CalCCA argues that the protesting parties’ claims should be rejected because the scoring criterion does not cause discriminatory conduct, and exclusivity arrangements are already established components of procurement processes.

Why does CalCCA contend the scoring criterion is justified?

CalCCA states the scoring criterion is a reasonable tool to identify projects most likely to be fully developed and studied, particularly given dramatically increased interconnection requests and related system and market conditions.

Sep 17, 2026

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