CAISO has proposed new interconnection criteria to flush out stale projects from a generator interconnection queue that has reached record volumes in recent years.

The proposed change is part of the ISO’s Interconnection Process Enhancements 5.0 initiative. CAISO held a workshop Jan. 7 to review its interconnection enhancements final proposal.

In the proposal, CAISO would apply “commercial viability criteria” (CVC) to projects that had requested to extend their commercial operation date (COD) — specifically when a COD had exceeded or would exceed seven years from the date of the original interconnection request. Projects that could not meet such CVC would be withdrawn from the interconnection queue, the proposal says.

This approach would “broaden the applicability of CVC from only projects and capacity with transmission plan deliverability to all projects and capacity, including energy only projects,” the proposal says.

CAISO says the current process for limiting a project’s time in the interconnection queue is time-intensive and requires project-specific analysis. The ISO “remains concerned with the [number] of older, seemingly stagnant projects in the interconnection queue and wants to see projects advance toward commercial operations or withdraw,” the proposal says.

Calpine asked CAISO to exempt projects that will repower an existing generating facility. However, the proposal notes the ISO has “been challenged with generating facilities that have retired or come offline and have submitted repower requests and are not proceeding to redevelopment and commercial operation.”

“The ISO will continue to hold repower projects … accountable to the commercial viability requirements,” CAISO said in the proposal. “The ISO believes retired generating facilities and repower projects should proceed to redevelopment and commercial operation in a timely manner, same as queued projects.”

The proposed process would not apply to projects that have been delayed due to interconnection study results or transmission owner construction.

American Clean Power (ACP) of California urged CAISO to be cautious with the proposed interconnection queue revisions.

Excessively stringent requirements “could actually derail viable projects, particularly at a time where projects are simultaneously trying to expedite commercialization to secure expiring tax credits and facing uphill battles with permitting challenges,” said Caitlin Liotiris, principal at Energy Strategies, who represented ACP in comments on the plan.

“Unless CAISO includes exceptions and flexibility in its proposed queue management process, ACP-California opposes this aspect of the proposal,” Liotiris said.

EDF power solutions opposed the revision too, saying federal policy shifts are “significantly changing the permitting and procurement landscape.”

Those shifts include changes to environmental and land-use permitting processes; supply chain and materials procurement constraints; and labor market and wage policy changes affecting project timelines, the company said in its comments.

Another revision in the final proposal is one that would remove requirements for projects to meet the ISO’s non-load serving entities (LSE) corporate sustainability policies to receive commercial interest points.

The corporate sustainability policy requirement was unnecessarily restrictive, CAISO said in the proposal. Previous CAISO scoring data indicated non-LSE projects competed effectively in the scoring process, and CAISO had not received concerns about point values from non-LSE entities, the proposal says.

The final proposal also includes, among other items:

• • the addition of distribution system interconnection projects into CAISO’s intake project scoring system;
  • an updated process for CAISO’s generation interconnection and deliverability allocation procedures that would allow a named vice president on the committee to appoint another ISO vice president as a delegate if the named vice president is unavailable. This would avoid any risk of non-compliance with the five-business day requirement, the proposal says;
  • the elimination of a requirement that non-LSE projects meet corporate sustainability goals in order to obtain commercial interest points in interconnection scoring.

Comments on the final proposal are due Jan. 21, with a vote by the ISO Board of Governors planned for March 5.