{"document":{"slug":"filing-20260731-5157","title":"Motion to Rescind Show Cause Order on behalf of the Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California","issued":"2026-07-31","accession":"20260731-5157","docket":"EL26-71-000","group":"CAISO filings","filer":"Six Cities CA","kind":"motion","file":"sources/originals/20260731-5157_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260731-5157","sha256":"ed8537798b22b6e87a5997ddf137ed81de3c54ec652a894483022356ba2d63f9","pages":6,"tokens":1229,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":170,"text":"- 1 - \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nCalifornia Independent System Operator \nCorporation \nCitizen S-Line Transmission LLC  \nCitizens Sunrise Transmission LLC  \nCitizens Sycamore-Penasquitos \nTransmission LLC  \nCity of Anaheim, California  \nCity of Azusa, California  \nCity of Banning, California  \nCity of Colton, California  \nCity of Pasadena, California  \nCity of Riverside, California \nDCR Transmission, L.L.C.  \nDesertLink, LLC  \nGridLiance West LLC  \nHorizon West Transmission, LLC \nLS Power Grid California, LLC  \nMorongo Transmission LLC  \nPacific Gas and Electric Company  \nSan Diego Gas & Electric Company  \nSouthern California Edison Company  \nStartrans IO, L.L.C.  \nSunZia Transmission, LLC  \nTrans Bay Cable LLC  \nValley Electric Association, Inc.  \nViridon Path 15, LLC  \nWestern Area Power Administration \nDocket No. EL26-71-000 \n \n \nMOTION TO RESCIND SHOW CAUSE ORDER  \nON BEHALF OF THE CITIES OF ANAHEIM, AZUSA, BANNING, COLTON, \nPASADENA, AND RIVERSIDE, CALIFORNIA \n \n \nPursuant to Rule 212 of the Commission’s Rules of Practice and Procedure,1 the Cities of \nAnaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California (collectively, the “Six \n \n1 18 C.F.R. § 385.212 (2026)."},{"page":2,"startToken":170,"endToken":489,"text":"- 2 - \nCities”) hereby submit this motion to rescind the show cause order issued by the Commission in \nthe above-referenced proceeding on June 18, 2026,2 as directed to each of the Six Cities as \nParticipating Transmission Owners (“TOs”) in the California Independent System Operator \nCorporation (“CAISO”).  \nI. \nDESCRIPTION OF THE SIX CITIES \nEach of the Six Cities operates a municipal electric system that is located within the \nCAISO Balancing Authority Area.  The Cities are each electrically surrounded by Southern \nCalifornia Edison Company (“SCE”), which is an Original Participating TO3 in the CAISO.  \nAlthough each of the Cities has made arrangements to obtain energy and capacity from a variety \nof resources, the Cities are dependent upon the CAISO and SCE for the delivery of the majority \nof these resources.   \nThe Cities of Anaheim, Azusa, Banning, and Riverside became Participating TOs in the \nCAISO and signed the Transmission Control Agreement (“TCA”) among and between the \nCAISO and its Participating TOs effective January 1, 2003.  The City of Pasadena executed the \nTCA and became a Participating TO as of January 1, 2005, and the City of Colton executed the \nTCA and became a Participating TO as of January 1, 2013.  As Participating TOs in the CAISO, \neach of the Cities has transferred to the CAISO’s Operational Control certain transmission \nfacilities and Entitlements, and they each have a TO Tariff on file with the Commission that \nestablishes rates, terms, and conditions of service on their facilities and Entitlements consistent \nwith the CAISO Tariff and the TCA.  In general, the Six Cities’ facilities and Entitlements over \nwhich the CAISO has assumed Operational Control represent either shares of jointly-owned \n \n2 Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (the “Show Cause Order”).   \n3 Capitalized terms used in this filing and not defined herein have the meanings set out in Appendix A to the \nCalifornia Independent System Operator Corporation Fifth Replacement Tariff (“CAISO Tariff”)."},{"page":3,"startToken":489,"endToken":774,"text":"- 3 - \nfacilities with, in some cases, entities that are not CAISO Participating TOs and/or are likewise \nnot Commission-jurisdictional, or contractual rights to transmission service on other parties’ \nsystems, which are governed by the terms and conditions of those parties’ tariffs and/or bilateral \ntransmission service agreements.   \nII. \nRELEVANT BACKGROUND \nOn June 18, 2026, the Commission issued the Show Cause Order, thereby initiating a \nproceeding under Section 206 of the Federal Power Act.  The Show Cause Order found that the \nCAISO Tariff and/or the TO Tariffs of each of the CAISO Participating TOs appear to be unjust, \nunreasonable, or unduly discriminatory or preferential to the extent that they do not include \nprovisions establishing the rates, terms, and conditions for the interconnection of and service to \ncertain large and co-located loads.  The Show Cause Order therefore directed the CAISO and the \nCAISO Participating TOs to either explain how their respective tariffs remain just and \nreasonable without specific provisions for the interconnection of large and co-located loads or to \ndevelop such provisions.4  \nIII. \nJUSTIFICATION FOR RESCISSION \nEach of the Six Cities is a non-public utility that is exempt from the Commission’s \njurisdiction pursuant to Section 201(f) of the Federal Power Act.5  The Commission \nacknowledged that the Show Cause Order included Participating TOs that are not subject to the \nCommission’s jurisdiction and explained that it would “rescind the show cause order” against \nsuch entities at their request, provided that the CAISO “respond[s] to this order regarding the \n \n4 Show Cause Order at P 3.   \n5 16 U.S.C. 824(f) (2024), City of Anaheim, 171 FERC ¶ 61,263, at PP 19-22 (2020), cited in Show Cause Order at P \n3, n.9."},{"page":4,"startToken":774,"endToken":1021,"text":"- 4 - \nnon-public utility’s CAISO Tariff provisions on file with the Commission.”6  Accordingly, as \nnon-public utilities, the Six Cities request that the Commission rescind the Show Cause Order \nagainst each of the Six Cities. \nIn requesting recission of the Show Cause Order, the Six Cities will coordinate and \ncooperate with the CAISO in responding to the Show Cause Order, to the extent that the CAISO \nrequests assistance from the Six Cities and with respect to provisions in the Cities’ TO Tariffs \nthat pertain to load interconnections.7  The Six Cities have conferred with the CAISO and are \nauthorized to state that the CAISO supports this motion.  The Six Cities also acknowledge the \nCommission’s authority to review their transmission revenue requirements as set forth in their \nTO Tariffs to ensure the CAISO’s rates remain just and reasonable.8  Consistent with the Cities’ \npractice, if any of the Cities determines that changes to its TO Tariff are needed to address the \nissues in the Show Cause Order or any other topics, each City will file proposed revisions to its \nTO Tariff with the Commission.9   \n \n \n \n6 Show Cause Order at P 3, n.9.   \n7 See id. (explaining that certain non-jurisdictional entities’ TO Tariffs include wholesale load interconnection \nprocesses).   \n8 See id. \n9 See, e.g., TO Tariff EDAM Revisions, City of Anaheim, Docket No. ER26-2310-000 (filed Apr. 27, 2026) \n(proposing revisions to the City’s TO Tariff to reflect modifications related to Extended Day Ahead Market Access \nCharge revenues)."},{"page":5,"startToken":1021,"endToken":1123,"text":"- 5 - \nIV. \nCONCLUSION \nWHEREFORE, for the foregoing reasons, the Six Cities respectfully request that the \nCommission rescind the Show Cause Order against each of the Cities as non-public utilities and \nask that the Commission waive any notice and comment periods that might be applicable to this \nmotion. \n \nRespectfully submitted, \n \n \n/s/ Margaret E. McNaul \n \n \nMargaret E. McNaul \n \nRebecca L. Shelton \n \nJenna E. Cliatt \n \n \n \n \nAttorneys for the Cities of Anaheim, Azusa, \nBanning, Colton, Pasadena, and Riverside, \nCalifornia \n \nLaw Offices of: \n \nThompson Coburn LLP \n \n1909 K Street, N.W., Suite 600 \n \nWashington, D.C. 20006-1167 \n \n202.585.6900 \n \n202.585.6969 (facsimile) \n \nJuly 31, 2026"},{"page":6,"startToken":1123,"endToken":1229,"text":"CERTIFICATE OF SERVICE \nI hereby certify that I have on this 31st day of July, 2026, caused a copy of the foregoing \ndocument to be sent to all parties on the list compiled by the Secretary of the Commission in this \nproceeding, by electronic mail or such other means as may have been specified by such party, \npursuant to Commission Rule 2010. \n \n \n/s/ Margaret E. McNaul \n \n \nMargaret E. McNaul \n \nAttorney for the Cities of Anaheim, Azusa, \nBanning, Colton, Pasadena, and Riverside, \nCalifornia \n \nLaw Offices of: \n \nThompson Coburn LLP \n \n1909 K Street, N.W., Suite 600 \n \nWashington, D.C. 20006-1167 \n \n202.585.6900 \n \n202.585.6969 (facsimile)"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":310,"startToken":0,"endToken":216},{"p":2,"at":310,"title":"I. DESCRIPTION OF THE SIX CITIES","method":"printed heading","endPage":3,"endAt":338,"startToken":216,"endToken":536},{"p":3,"at":338,"title":"II. RELEVANT BACKGROUND","method":"printed heading","endPage":3,"endAt":1144,"startToken":536,"endToken":661},{"p":3,"at":1144,"title":"III. JUSTIFICATION FOR RESCISSION","method":"printed heading","endPage":5,"endAt":7,"startToken":661,"endToken":1022},{"p":5,"at":7,"title":"IV. CONCLUSION","method":"printed heading","endPage":5,"endAt":12,"startToken":1022,"endToken":1023},{"p":5,"at":12,"title":"CONCLUSION","method":"printed heading","endPage":6,"endAt":0,"startToken":1023,"endToken":1123},{"p":6,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":6,"endAt":648,"startToken":1123,"endToken":1229}]}