September 7, 2012
COMMENTS ON BEHALF OF THE CITIES OF ANAHEIM, AZUSA, BANNING, COLTON,
PASADENA, AND RIVERSIDE, CALIFORNIA REGARDING THE REVISED DRAFT TARIFF
LANGUAGE FOR ORDER NO. 1000 COMPLIANCE
In response to the ISO’s request, the Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and
Riverside, California (collectively, the “Six Cities”) submit the following comments regarding the August 30,
2012 Order 1000 Draft Tariff Language.
The Six Cities have a general comment regarding the ISO’s proposal, indicated throughout the draft
tariff language, to revise the terminology to refer to “Regional” transmission facilities (rather than “High
Voltage” or “HV”) transmission facilities and “Local” transmission facilities (rather than “Low Voltage” or
“LV”) transmission facilities and corresponding changes in the terminology for Transmission Revenue
Requirements and Access Charges. While the proposed changes in terminology make sense conceptually, the
existing terminology appears not only in the ISO Tariff but also in many other documents relating to the
relationships among the ISO and Market Participants, including the Transmission Control Agreement and the
Transmission Owner Tariffs of the Participating Transmission Owners. Although it would be reasonable to
submit conforming changes to those other documents as other revisions become necessary, it would be unduly
burdensome to require immediate revision of all documents that include references to the terms the ISO
proposes to change. The Six Cities recommend, therefore, that the ISO retain the existing terms so that they can
be used as necessary to clarify the meanings of those terms in other documents, at least for a reasonable
transition period.
The Six Cities suggest the following revisions to specific sections of the draft tariff language:
Section 24.4.5 - - In the fourth line from the end of the section, change “ISO” to “CAISO”.
Section 24.4.10 - - In the seventeenth line, change “a” to “an”.
Section 24.5.2.1 - - In the second line, delete “to”.
Section 24.6 - - The Six Cities recommend that the following language, which the ISO proposes to move
to Section 24.6.4, be retained in this section: “The Approved Project Sponsor shall not sell, assign or
otherwise transfer its rights to finance, construct and own the project before the project has been
energized and, if applicable, turned over to the CAISO’s Operational Control unless the CAISO has
approved such proposed transfer.” The Six Cities believe that it is more appropriate to retain the
language in this section, because it will be applicable to a broader range of situations. Section 24.6.4
applies when an Approved Project Sponsor is unable to complete a project. The requirement for the
CAISO’s approval for any transfer of an Approved Project Sponsor’s rights to finance, construct and
own the project should apply in all situations where such a transfer may be considered, not just where
the Approved Project Sponsor is unable to complete the Project.
Section 24.6.4 - - See the comment on Section 24.6 above re positioning of the language on transfer of
rights to finance, construct and own projects.
Section 24.14.4 - - In the last line, delete the phrase “regardless of which TAC Area the facility is
geographically located.” The phrase the Cities propose to delete is unnecessary and potentially
confusing.
Section 26.1.2 - - In the fourth line delete “, as applicable,”.
Section 26.1.4.1 - - Change the first two sentences to read as follows:
The Wheeling Access Charge shall be determined by the TAC Area and
transmission ownership or Entitlement, less all Encumbrances, associated with the
Scheduling Point at which the Energy exits the CAISO Controlled Grid. The
Wheeling Access Charge for Scheduling Points contained within a single TAC
Area, that are not joint facilities, shall be equal to the Regional Access Charge for
the applicable TAC Area in accordance with Schedule 3 of Appendix F plus the
applicable Local Access Charge if the Scheduling Point is on a Local
Transmission Facility.
Section 26.1.4.3.1 - - In the fifth line, change “TO’s” to “TOs’”.
Appendix F, Schedule 3, Section 1.1(a) - - Delete this sub-section.
Appendix A, definition of “Local Transmission Facility” - - In the first line, change “control” to
“Control”.
Appendix A, definition of “Location Constrained Resource Interconnection Facility” - - The reference to
Section 24.1.3 is incorrect, as that section is [NOT USED]. Also, it is not appropriate to define a
“Location Constrained Resource Interconnection Facility” as a type of “Regional Transmission
Facility,” and doing so is inconsistent with the proposed definition of “Regional Transmission Facility”.
Appendix A, definition of “Transmission Access Charge Area (TAC Area)” - - As the TAC Area
concept no longer affects the Regional Transmission Revenue Requirements or the Regional Access
Charge, the Six Cities recommend revising this definition simply to read: “A portion of the CAISO
Controlled Grid as identified in Section 3 of Schedule 3 of Appendix F.”
Appendix A, definition of “Transmission Revenue Credit” - - In the third line, delete “Original”.
Submitted by
Bonnie S. Blair
Thompson Coburn LLP
bblair@thompsoncoburn.com
202-585-6905
Attorney for the Cities of Anaheim, Azusa, Banning, Colton,
Pasadena, and Riverside, California
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