EL26-71-000 · 2026-08-12 · Morongo Transmission

Answer of Morongo Transmission LLC: no tariff amendment required, a non-load-serving participating transmission owner

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
California Independent System Operator Corporation 
Citizen S-Line Transmission LLC  
Citizens Sunrise Transmission LLC  
Citizens Sycamore-Penasquitos Transmission LLC  
City of Anaheim, California  
City of Azusa, California  
City of Banning, California  
City of Colton, California  
City of Pasadena, California  
City of Riverside, California 
DCR Transmission, L.L.C.  
DesertLink, LLC  
GridLiance West LLC  
Horizon West Transmission, LLC 
LS Power Grid California, LLC  
Morongo Transmission LLC  
Pacific Gas and Electric Company  
San Diego Gas & Electric Company  
Southern California Edison Company  
Startrans IO, L.L.C.  
SunZia Transmission, LLC  
Trans Bay Cable LLC  
Valley Electric Association, Inc.  
Viridon Path 15, LLC  
Western Area Power Administration 
 
 
 
       
 
 
    
 
 
 
   Docket No. EL26-71-000 
 
ANSWER OF MORONGO TRANSMISSION LLC 
 
Morongo Transmission LLC (“Morongo Transmission”) submits this answer pursuant to 
Rules 206 and 213 of the Federal Energy Regulatory Commission’s (“Commission”) Rules of 
Practice and Procedure in response to the Commission’s Order to Show Cause in the above-
captioned proceeding.1  Morongo Transmission respectfully submits that no amendments to its 
tariff are required in response to the Order to Show Cause because Morongo Transmission is a 
 
1 18 C.F.R. §§ 385.206(f), 385.213(a); Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 at P 3 (2026) 
(“CAISO”) (directing Participating Transmission Owners to respond to the Order to Show Cause).

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non-load-serving Participating Transmission Owner under the California Independent System 
Operator (“CAISO”) tariff with no end-use customers.  Morongo Transmission nevertheless 
intends to continue participating as a party in this proceeding due to the numerous important issues 
raised in the Order to Show Cause, including resource adequacy and large load interconnection 
reform. 
I. 
DESCRIPTION OF MORONGO TRANSMISSION 
 
Morongo Transmission is a Participating Transmission Owner in CAISO.  It is wholly 
owned by the Morongo Band of Mission Indians (“Tribe”), a federally recognized American 
Indian Tribe exercising jurisdiction over the Morongo Indian Reservation (“Reservation”), which 
spans roughly 40,000 acres in the San Gorgonio Pass, near Banning, California.  Morongo 
Transmission holds a 30-year lease of a portion of the transfer capability of Southern California 
Edison Company’s (“SCE”) upgraded West of Devers transmission facilities, which cross the 
Tribe’s Reservation. 2  Morongo Transmission recovers its transmission revenue requirement 
through a Commission-approved formula rate under its tariff (“Morongo Tariff”), paid by 
CAISO’s collection of Transmission Access Charge (“TAC”) rates.3  
II. 
ANSWER OF MORONGO TRANSMISSION 
 
Morongo Transmission respectfully submits that the Morongo Tariff is just and reasonable 
and that no amendment is required in response to the issues identified in the Commission’s Order 
 
2 Morongo Transmission LLC, Docket No. ER21-669-000, Transmittal Letter (Dec. 17, 2020) (“Morongo 
Transmittal Letter”); Morongo Transmission LLC, 178 FERC ¶ 61,062 at P 5 (2022) (approving 
uncontested settlement establishing transmission revenue requirement for Morongo Transmission). 
3 E.g., Morongo Transmission LLC, Docket No. ER26-642-000 (Jan. 23, 2026) (delegated order) (accepting 
revisions to the Morongo Tariff reflecting updates to annual operating cost revenue requirement); Morongo 
Transmittal Letter at 2.

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to Show Cause.  In this proceeding, the Commission has preliminarily ordered CAISO to reform 
its tariff to take jurisdiction over, and facilitate, interconnection of large loads, including by: 
• Developing an efficient application and study process for Eligible Customers seeking 
transmission service for large loads; 
• Increasing transparency regarding network upgrade costs to provide transmission service 
for large loads, establishing mechanisms to mitigate cost shifting to other transmission 
customers, and creating a pro forma cost recovery agreement between CAISO, the relevant 
transmission owner, and the Eligible Customer; 
• Developing new transmission services to accommodate flexible large loads willing to 
accept interruptible service and/or contracts for less than their peak demand; and 
• Developing processes to efficiently study generation facilities serving electrically 
proximate large loads (i.e., not more than two substations apart) or co-located large loads, 
with the goal of avoiding unnecessary network upgrades.4 
 
These areas of reform do not implicate the Morongo Tariff, which expressly provides that 
“Morongo Transmission LLC is a Non-Load-Serving Participating [Transmission Owner] and has 
no End-Use Customers.”5  This language reflects the arrangement between Morongo Transmission 
and SCE, where Morongo Transmission holds a 30-year lease of a portion of the transfer capability 
of SCE’s West of Devers line across the Tribe’s Reservation.6  The Morongo Tariff is therefore 
different from the tariffs of other CAISO Participating Transmission Owners that do serve load 
and have end-use customers and whose tariffs may be subject to the Order to Show Cause. 
 
Furthermore, the Morongo Tariff provides that the tariff provisions governing the load 
interconnection process—Section Eight (Obligation to Interconnect or Construct Transmission 
Expansions and Facility Upgrades), Section Nine (Expansion Process (including the study process 
for necessary facilities)), and Section Ten (Interconnection Process)—“shall be superseded by the 
 
4 CAISO, 195 FERC ¶ 61,214 at P 3.  
5 Morongo Transmission LLC Transmission Owner Tariff (“Morongo Tariff”) § 1 (May 15, 2021) 
(emphases added). 
6 See Part I, supra.

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corresponding sections of the TO Tariff of Southern California Edison.”7  Thus to the extent that 
amendments to the Participating Transmission Owners’ tariffs are necessary to implement large 
load interconnection reforms to CAISO’s tariff in response to the Order to Show Cause,8 SCE 
could implement those reforms to its own tariff without Morongo Transmission needing to take 
further action to amend the Morongo Tariff.9  The Morongo Tariff thus will not be impacted by 
reforms facilitating interconnections of large loads.  However, to the extent that the Commission 
determines any residual or conforming amendments are required to the Morongo Tariff, Morongo 
Transmission will make compliance filings as directed. 
 
The Order to Show Cause nonetheless targets a range of issues of great importance to 
Morongo Transmission and the Tribe, including resource adequacy and reform of large load 
interconnection processes.  These topics are significant to Morongo Transmission and the Tribe as 
they work to expand economic opportunity on the Reservation while ensuring affordable and 
reliable electricity for the Tribe’s members.  Morongo Transmission accordingly looks forward to 
continuing to participate as a party in this proceeding and assisting the Commission as it weighs 
these important matters—in keeping with Order No. 1920’s recognition of the critical role that 
federally recognized Tribes play in developing policies affecting the interstate transmission grid.10  
III. 
SERVICE, COMMUNICATIONS, AND CORRESPONDENCE 
Morongo Transmission requests that the persons listed below be included on the official 
 
7 Morongo Tariff § 16.12 (cross-referencing Sections 8, 9, and 10).  
8 See CAISO, 195 FERC ¶ 61,214 at P 3.   
9 Southern California Edison Transmission Owner Tariff §§ 8-10 (effective May 1, 2019). 
10 Bldg. for the Future Through Elec. Reg’l Transmission Planning and Cost Allocation, Order No. 1920, 
187 FERC ¶ 61,068 at PP 409, 482, 528 (2024), on reh’g, Order No. 1920-A, 189 FERC ¶ 61,126 (2024), 
reh’g denied, Order No. 1920-B, 191 FERC ¶ 61,026 (2025); see also CAISO, Tribal Engagement on Long-
term Transmission Planning 67 (Apr. 9, 2026), https://www.caiso.com/documents/presentation-tribal-
engagement-on-long-term-transmission-planning-apr-09-2026.pdf.

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service list for this proceeding, and respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) to 
permit the designation of more than two persons upon whom service is to be made in this 
proceeding. 
Sam Cohen 
Chief Legal Officer 
MORONGO TRANSMISSION LLC 
12700 Pumarra Road 
Banning, CA 92220 
(909) 454-4515 
scohen@morongo-nsn.gov 
 
Max Spivak 
MORONGO BAND OF MISSION INDIANS 
12700 Pumarra Road 
Banning, CA 92220 
(951) 755-5122 
morongotransmissionllc@morongo-nsn.gov 
 
Suedeen G. Kelly 
JENNER & BLOCK LLP 
1099 New York Avenue NW, Suite 900 
Washington, DC 20001 
(202) 639-6055 
SKelly@jenner.com 
 
IV. 
CONCLUSION 
 
For the reasons given above, the Morongo Tariff is just and reasonable and does not require 
amendment in light of the Order to Show Cause. 
 
Respectfully submitted, 
 
/s/ Sam Cohen  
 
 
Sam Cohen 
Chief Legal Officer 
MORONGO TRANSMISSION LLC 
12700 Pumarra Road 
Banning, CA 92220 
(909) 454-4515 
scohen@morongo-nsn.gov 
 
On behalf of Morongo Transmission LLC 
 
 
Dated: August 12, 2026

CERTIFICATE OF SERVICE 
 
 
I certify that, on August 12, 2026, I served the foregoing document upon each person 
designated on the official service list compiled by the Secretary in this proceeding.  
 
/s/ Suedeen G. Kelly  
 
 
 
 
 
 
 
 
 
Suedeen G. Kelly