Stakeholder Comments Template - Integration of Transmission Planning and Generation Interconnection Procedures (TPP-GIP Integration) - Straw Proposal

Sep 11, 2026

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Stakeholder comments template addressing the ISO’s straw proposal to integrate Transmission Planning Process (TPP) with Generation Interconnection Procedures (GIP), focusing on whether the initiative objectives are appropriate and complete. Provides structured prompts for reviewing scope, unresolved GIP issues, study options and timeline reductions, added TPP Stage 2 cost estimation accuracy, and Stage 3 ratepayer upgrade allocation methods. Also solicits input on tariff treatment, cost allocation between early and later interconnection customers, and transition/refund considerations when projects drop out.

LanguageEnglish

CategoryPresentations

FormatPDF

Pages4

Reading Time2 min

AccessFree to download

Stakeholder Comments Template

ISO initiative objectives and scope

GIP issues to address in scope

GIP cluster studies and transition to TPP

TPP Stage 2 network upgrade cost estimation

TPP Stage 3 allocation of ratepayer funded upgrades

Tariff treatment for customer-paid upgrades

Cost allocation between early and later interconnection customers

Transition plan for clusters and refund/compensation

Restudying network upgrade needs and costs when projects drop out

Sequencing TPP before GIP submission

Stakeholder Comments Template Integration of Transmission Planning and Generation Interconnection Procedures (TPP-GIP Integration) Straw Proposal, July 21, 2011 | Submitted by | Company | Date Submitted | | --- | --- | --- | | Wayne Stevens
[wstevens@criticalpathtransmission.com](wstevens@criticalpathtransmission.com)[ ](wstevens@criticalpathtransmission.com)[818.760.5480](818.760.5480) | Critical Path Transmission | 09 August 2011 | 1. The ISO has laid out several objectives for this initiative. Please indicate whether you organization believes these objectives are appropriate and complete. If your organization believes the list to be incomplete, please specify what additional objectives the ISO should include. It is not clear how the ISO plans to accomplish their stated objective to “Provide greater certainty that transmission approved by ISO will be permitted by siting authority (CPUC)”. Throughout the Revised Transmission Planning Process, in stakeholder meetings and official comments, CAISO staff noted that economic comparisons and environmental impacts were not considerations under their tariff, and therefore were not considered for the billions of dollars of projects recently included in the first Statewide Plan. 2. At the end of the Objectives section (section 4) of the straw proposal, the ISO lists seven previously identified GIP issues that may be addressed within the scope of this initiative. a. Please indicate whether your organization agrees with any or all of the identified topics as in scope. If not, please indicate why not. b. Please identify any other unresolved GIP issues not on this list that should be in scope, and explain why. One additional “relevant GIP issue” that was not explicitly listed that needs to be resolved quickly is for the CAISO to allow generators within a cluster to shift from one interconnection point to another without having to “start over” in the queue. This would allow otherwise viable projects to move forward if their only issue is their interconnection point within a cluster. 3. Stage 1 of the ISO’s proposal offers two options for conducting the GIP cluster studies and transitioning the results into TPP. a. Which option, Option 1A or Option 1B, best achieves the objectives of this initiative, and why? Are there other options the ISO should consider for structuring the GIP study process? The issue is not which option, but the time lines suggested for the two options; specifically the time it takes for cluster studies to be performed needs to be reduced by the CAISO by 50% - 80% . b. What, if any, modifications to the GIP study process might be needed? 4. Stage 2 of the straw proposal adds a step to the end of the TPP cycle, in which the ISO identifies and estimates the costs of additional network upgrades to meet the interconnection needs of the cluster. Please offer comments and suggestions for how to make this step produce the most accurate and useful results. 5. Stage 3 of the straw proposal identifies three options for allocating ratepayer funded upgrades to interconnection customers in over-subscribed areas. a. Please identify which option, Option 3A, 3B, or 3C, your organization prefers and why. Are there other options the ISO should consider? b. If Option 3A is selected, what are appropriate milestones to determine which projects are the “first comers?” c. If Option 3B is selected, what is the appropriate methodology for determining pro rata cost shares? d. If Option 3C is selected, how should such an auction be conducted and what should be done with the auction proceeds from the winning bidders? 6. The straw proposal describes how the merchant transmission model in the current ISO tariff could apply to network upgrades that are paid for by an interconnection customer and not reimbursed by transmission ratepayers. Do you agree that the merchant transmission model is the appropriate tariff treatment of such upgrades, or should other appro

FAQs

Are the ISO’s stated objectives for the TPP-GIP integration initiative appropriate and complete?

The comments request confirmation that the objectives are appropriate and complete, and ask stakeholders to propose any additional objectives if the list is incomplete.

What timing improvements are needed for GIP cluster studies and transition into TPP?

The feedback emphasizes that the timeline for performing cluster studies should be reduced by 50% to 80% by CAISO to better achieve the initiative objectives.

Which approach should be used to allocate ratepayer funded upgrades in oversubscribed areas?

Stakeholders are asked to choose among Options 3A, 3B, or 3C, and to provide rationale plus details on milestones (3A), pro rata methodology (3B), or auction design and handling of proceeds (3C).

How should costs and responsibilities be handled when later interconnection customers benefit from network upgrades paid by earlier customers?

The comments ask whether the ISO’s role should be limited to allocating CRRs or whether provisions should also compensate later benefits to reimburse the earlier customer who paid for upgrades.

Sep 11, 2026

Uploaded by Melati