Approved Project Sponsor s Participating TO Application Process Clean-Up Proposal and Tariff September 30, 2015 M&ID Page 1
Table of Contents 1 Executive Summary... 3 2 Stakeholder Process Next Steps... 4 3 Proposal and Tariff... 4 3.1 Draft Tariff... 7 M&ID Page 2
Approved Project Sponsor s Participating TO Application Process Clean-Up Proposal and Draft Tariff 1 Executive Summary In 2010 the California Independent System Operator Corporation developed its competitive solicitation process for the selection of approved project sponsors to finance, construct, own, operate and maintain regional transmission facilities eligible for competitive solicitation included in the annual transmission plan approved by the CAISO Board of Governors. At the conclusion of the comprehensive evaluation process, the CAISO executive team selects the Approved Project Sponsor. Approved Project Sponsors must enter into an agreement that documents the terms and conditions applicable to the siting and construction of the approved transmission facilities. 1 The Approved Project Sponsor s Participating TO Application Process Clean-up initiative is needed to exempt Approved Project Sponsors from the CAISO s normal application process for New Participating TOs. 2 The CAISO believes the New Participating TO application process is duplicative of the competitive solicitation process and requiring Approved Project Sponsors to submit an application would be inefficient and unnecessary. All of the notice and information requirements of the New Participating TO process are satisfied by the competitive solicitation process. 1 See CAISO Tariff, Appendix X. 2 See CAISO Tariff, Section 4.3.1.1. M&ID Page 3
2 Stakeholder Process Next Steps Table 2 summarizes the anticipated stakeholder process schedule for the initiative. Table 2 Stakeholder process schedule Step Date Milestone Proposal Final Proposal to Board September 30, 2015 October 7, 2015 October 14, 2015 November 4-5, 2015 3 Proposal Posted Stakeholder meeting (web conference) Stakeholder comments due Board of Governors Meeting 3 Proposal and Tariff The competitive solicitation process policy requires bidders to submit an application to the CAISO and, after a comprehensive evaluation of all applicants, the bid is awarded to the Approved Project Sponsor upon approval by the CAISO. The CAISO and the Approved Project Sponsor enter in to an Approved Project Sponsor Agreement ( APSA ) that provides the roles and responsibilities to construct the approved transmission project and turn it over to CAISO Operational Control. Since the transmission project has already been approved by the CAISO Board in the transmission planning process, and the selection of the successful bidder has already been determined by the CAISO, requiring an entity to then go through the New Participating TO application process should be moot because they are already required by the APSA to provide technical information and become a Participating TO. The following is a comparison of the Transmission Control Agreement sections that address the requirements of an entity to include in their Participating TO application versus the requirements to provide information in the Approved Project Sponsor process, including the APSA: 3 The Board timing is due to the first competitive transmission project which is scheduled to energize in April 2016 to allow time for FERC approval of this initiative, then negotiation of the Transmission Control Agreement and filing of the TO Tariff and Regional Transmission Revenue Requirement for the project. M&ID Page 4
Transmission Control Agreement Approved Project Sponsor Section Requirement Document and Requirement 2.2.1 Application Procedures. Bid for competitive solicitation project 2.2.1(i) 2.2.1(ii) 2.2.1(iii) All applications under this Section 2.2 shall be made in accordance with the procedures adopted by the CAISO from time to time and shall be accompanied by: a description of the transmission lines and associated facilities that the applicant intends to place under the CAISO s Operational Control; in relation to any such transmission lines and associated facilities that the applicant does not own, a copy of each document setting out the applicant s to such lines and facilities; a statement of any Encumbrances to which any of the transmission lines and associated facilities to be placed under the CAISO s Operational Control are subject, together with any documents creating such Encumbrances and any dispatch protocols to give effect to them, as the CAISO may require; Functional Specifications and Key Selection Factors and APSA Appendix A Not applicable Not applicable M&ID Page 5
Transmission Control Agreement Approved Project Sponsor Section Requirement Document and Requirement 2.2.1(iv) 2.2.1(v) 2.2.1(vi) 2.2.1(vii) a statement that the applicant intends to place under the CAISO s Operational Control all of the transmission lines and associated facilities referred to in Section 4.1 that it owns or, subject to the treatment of Existing Contracts under Section 16 of the CAISO Tariff, to which it has Entitlements and its reasons for believing that certain lines and facilities do not form part of the applicant s transmission network pursuant to Sections 4.1.1.i and 4.1.1.ii; a statement of any Local Reliability Criteria to be included as part of the Applicable Reliability Criteria a description of the applicant s current maintenance practices; a list of any temporary waivers that the applicant wishes the CAISO to grant under Section 5.1.6 (applicable reliability criteria) and the period for which it requires them; APSA Section 3.4 Requires Approved Project Sponsor to become a Participating TO APSA Article 9 Not applicable Not applicable 2.2.1 (viii) a copy of the applicant s proposed TO Tariff, if any, must be filed; 2.2.1 (ix) address and contact names to which notices under this Agreement may be sent pursuant to Section 26.1 APSA Section 5.2 APSA Appendix D M&ID Page 6
Transmission Control Agreement Approved Project Sponsor Section Requirement Document and Requirement 2.2.1(x) 2.2.1(xi) any other information that the CAISO may reasonably require in order to evaluate the applicant s ability to comply with its obligations as a Participating TO; and details of the applicant s intent to establish a settlement account APSA Section 5.2 This is done as part of the onboarding process prior to commencing testing 3.1 Draft Tariff The draft tariff for this initiative would exempt the Approved Project Sponsor from the New Participating TO application process. 4 This initiative will be brought to the November Board of Governors meeting for approval. 4.3 Relationship Between CAISO And Participating TOs 4.3.1 Nature Of Relationship Each Participating TO shall enter into the Transmission Control Agreement with the CAISO. In addition to converting Existing Rights in accordance with Section 16.1.4, and except as provided in Section 4.3.1.3, New Participating TOs that are not Approved Project Sponsors will be required to turn over Operational Control of all facilities and Entitlements that: (1) satisfy the FERC s functional criteria for determining transmission facilities that should be placed under CAISO Operational Control; (2) satisfy the criteria adopted by the CAISO Governing Board identifying transmission facilities for which the CAISO should assume Operational Control; and (3) are the subject of mutual agreement between the CAISO and the Participating TOs. The CAISO shall notify Market Participants when an application has been received from a potential Participating TO and shall notify Market Participants that a New Participating TO has executed the Transmission Control Agreement and the date on which the CAISO will have Operational Control of the transmission facilities. 4 The tariff language is draft tariff language. Stakeholders may submit comments or proposed edits and the CAISO may revise it. As with all draft tariff language in the stakeholder process, the CAISO reserves the right to revise the tariff language, including up to the time of filing at the Federal Energy Regulatory Commission. M&ID Page 7
4.3.1.1 In any year, a Participating TO that is not an Approved Project Sponsor applicant must declare its intent in writing to the CAISO to become a New Participating TO by January 1 or July 1, and provide the CAISO with an application within fifteen (15) days of such notice of intent. Applicable agreements will be negotiated and filed with the Federal Energy Regulatory Commission as soon as possible for the New Participating TO, such that the agreements can be effective the following July 1 or January 1. 4.3.1.3 CAISO Relationship with Specific Participating TOs (a) Western Path 15. Western Path 15 shall be required to turn over to CAISO Operational Control only its rights and interests in the Path 15 Upgrade and shall not be required to turn over to CAISO Operational Control Central Valley Project transmission facilities, Pacific AC Intertie transmission facilities, California-Oregon Transmission Project facilities, or any other new transmission facilities or Entitlements not related to the Path 15 Upgrade. For purposes of the CAISO Tariff, Western Path 15 shall be treated with respect to revenue recovery as a Project Sponsor in accordance with Section 24.14.3.1. (b) New Participating TOs After April 1, 2014. An Approved Project Sponsors that was not a Participating TO as of April 1, 2014, shall be required to turn over to CAISO Operational Control only its rights and interests in the Regional Transmission Facilities it has been selected to finance, construct and own under section 24.5. Such a Participating Transmission Owner will be subject to all obligations of a Participating TO with regard to the facilities placed under CAISO Operational Control, except the obligation in Section 4.3.1.1 to submit an application to become a Participating TO and the obligation in Section 2.2 of the Transmission Control Agreement to apply to become a Participating TO. M&ID Page 8