CAISO moved a step closer to meeting Order 845 requirements last week when FERC accepted most Tariff revisions included in a second compliance filing after the ISO’s first attempt met a raft of rejections in February (ER19-1950).

Two inland West utilities, Public Service Company of Colorado (PSCo) and Deseret Generation & Transmission Cooperative, also nearly reached compliance with the order, which FERC issued in 2018 to amend its pro forma large generator interconnection agreement and large generator interconnection procedures to increase the transparency and speed of the interconnection process.

RTOs, ISOs and utilities have struggled to fully comply with the order, with most facing FERC directives to submit second — and even third — compliance filings. (See CAISO, NYISO, Companies Win Partial OK on Order 845.)

The commission on Thursday approved the majority of CAISO’s proposed revisions in the second round, including those dealing with:

• transparency around study models and assumptions, with CAISO planning to maintain an Open Access Same-Time Information System link to a secured section of its website containing interconnection base case data;
• interconnection study deadlines, with CAISO incorporating FERC’s pro forma language into its Tariff to describe how the ISO will provide summary statistics on the processing of interconnection studies;
• provisional interconnection service, with the ISO removing language restricting the use of limited operation studies to instances when a transmission owner is unable to complete facilities by the interconnection customer’s commercial operation date; and
• surplus interconnection service, with FERC agreeing to CAISO’s plan to rely on existing Tariff provisions to memorialize the transfer of such service.

But FERC only partially accepted a proposal outlining the ISO’s planned response to an interconnection customer’s request to incorporate a technological advancement into a project after that project has entered the queue, which could trigger the need for additional studies ahead of a final interconnection study.

While CAISO’s second compliance filing offered no revisions to the plan FERC originally rejected in February, the filing did provide additional details explaining the ISO’s approach. CAISO explained that its “material modification assessment process” enables interconnection customers to make modifications to their projects without losing their place in the queue. Additionally, the ISO offers a “permissible technological advancement process” as a faster, cheaper alternative for “simple” modifications.

“Rather than create a limited, rigid list of permissible technological advancements, CAISO created a list of known permissible advancements and allowed for any other advancements that meet CAISO’s definition of permissible technological advancement,” FERC noted.

Under the proposed Tariff provision, customers seeking to make technological changes to their projects would need to advance CAISO a flat $2,500 fee to cover the costs of studying the impacts of the changes. The commission accepted the fee but found that the ISO had not complied with Order 845 requirements and the compliance directives in the February 2020 order “with respect to the requirement that CAISO provide a more detailed explanation of the studies that CAISO will conduct to determine whether the technological advancement request will result in a material modification and determine whether or not a technological advancement is a material modification within 30 calendar days of receipt of the initial request.”

FERC also found that the CAISO Tariff’s use of the terms “conditionally assigned network upgrades” and “precursor network upgrades” — instead of the term “contingent facilities” — does not comply with Order 845 and the February compliance directive with respect to interconnection facilities.

“While CAISO states that it will apply the terms ‘conditionally assigned network upgrades’ and ‘precursor network upgrades’ to all facilities identified in the interconnection customer’s study reports, it is unclear how these terms, which by their own names and definitions relate to network upgrades, address interconnection facilities that may also be contingent facilities pursuant to the pro forma LGIP definition of ‘contingent facilities,’” FERC wrote.

The commission directed the ISO to submit a further compliance filing within 120 days addressing the technological changes issue and how it will identify interconnection facilities that are contingent facilities “in light of the fact that the two terms with which CAISO proposes to replace the term ‘contingent facilities’ do not by definition include interconnection facilities.”

Utilities Near Compliance

The commission on Thursday accepted nearly every provision of PSCo’s Order 845 compliance filing but ordered the utility to revise its tariff to explicitly state that it will take no more than 30 days to determine whether an interconnection’s technological change request actually qualifies as a “material modification” requiring additional study (ER19-1864).

Utah-based Deseret similarly came within a hair’s breadth of compliance, with the commission ordering the co-op to specify the deposit that interconnection customers must provide to cover additional studies when submitting a technological change request (ER19-902).