EL26-71-000 · 2026-07-31 · Six Cities CA
Motion to Rescind Show Cause Order on behalf of the Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
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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
MOTION TO RESCIND SHOW CAUSE ORDER
ON BEHALF OF THE CITIES OF ANAHEIM, AZUSA, BANNING, COLTON,
PASADENA, AND RIVERSIDE, CALIFORNIA
Pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure,1 the Cities of
Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California (collectively, the “Six
1 18 C.F.R. § 385.212 (2026).
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Cities”) hereby submit this motion to rescind the show cause order issued by the Commission in
the above-referenced proceeding on June 18, 2026,2 as directed to each of the Six Cities as
Participating Transmission Owners (“TOs”) in the California Independent System Operator
Corporation (“CAISO”).
I.
DESCRIPTION OF THE SIX CITIES
Each of the Six Cities operates a municipal electric system that is located within the
CAISO Balancing Authority Area. The Cities are each electrically surrounded by Southern
California Edison Company (“SCE”), which is an Original Participating TO3 in the CAISO.
Although each of the Cities has made arrangements to obtain energy and capacity from a variety
of resources, the Cities are dependent upon the CAISO and SCE for the delivery of the majority
of these resources.
The Cities of Anaheim, Azusa, Banning, and Riverside became Participating TOs in the
CAISO and signed the Transmission Control Agreement (“TCA”) among and between the
CAISO and its Participating TOs effective January 1, 2003. The City of Pasadena executed the
TCA and became a Participating TO as of January 1, 2005, and the City of Colton executed the
TCA and became a Participating TO as of January 1, 2013. As Participating TOs in the CAISO,
each of the Cities has transferred to the CAISO’s Operational Control certain transmission
facilities and Entitlements, and they each have a TO Tariff on file with the Commission that
establishes rates, terms, and conditions of service on their facilities and Entitlements consistent
with the CAISO Tariff and the TCA. In general, the Six Cities’ facilities and Entitlements over
which the CAISO has assumed Operational Control represent either shares of jointly-owned
2 Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (the “Show Cause Order”).
3 Capitalized terms used in this filing and not defined herein have the meanings set out in Appendix A to the
California Independent System Operator Corporation Fifth Replacement Tariff (“CAISO Tariff”).
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facilities with, in some cases, entities that are not CAISO Participating TOs and/or are likewise
not Commission-jurisdictional, or contractual rights to transmission service on other parties’
systems, which are governed by the terms and conditions of those parties’ tariffs and/or bilateral
transmission service agreements.
II.
RELEVANT BACKGROUND
On June 18, 2026, the Commission issued the Show Cause Order, thereby initiating a
proceeding under Section 206 of the Federal Power Act. The Show Cause Order found that the
CAISO Tariff and/or the TO Tariffs of each of the CAISO Participating TOs appear to be unjust,
unreasonable, or unduly discriminatory or preferential to the extent that they do not include
provisions establishing the rates, terms, and conditions for the interconnection of and service to
certain large and co-located loads. The Show Cause Order therefore directed the CAISO and the
CAISO Participating TOs to either explain how their respective tariffs remain just and
reasonable without specific provisions for the interconnection of large and co-located loads or to
develop such provisions.4
III.
JUSTIFICATION FOR RESCISSION
Each of the Six Cities is a non-public utility that is exempt from the Commission’s
jurisdiction pursuant to Section 201(f) of the Federal Power Act.5 The Commission
acknowledged that the Show Cause Order included Participating TOs that are not subject to the
Commission’s jurisdiction and explained that it would “rescind the show cause order” against
such entities at their request, provided that the CAISO “respond[s] to this order regarding the
4 Show Cause Order at P 3.
5 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
3, n.9.
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non-public utility’s CAISO Tariff provisions on file with the Commission.”6 Accordingly, as
non-public utilities, the Six Cities request that the Commission rescind the Show Cause Order
against each of the Six Cities.
In requesting recission of the Show Cause Order, the Six Cities will coordinate and
cooperate with the CAISO in responding to the Show Cause Order, to the extent that the CAISO
requests assistance from the Six Cities and with respect to provisions in the Cities’ TO Tariffs
that pertain to load interconnections.7 The Six Cities have conferred with the CAISO and are
authorized to state that the CAISO supports this motion. The Six Cities also acknowledge the
Commission’s authority to review their transmission revenue requirements as set forth in their
TO Tariffs to ensure the CAISO’s rates remain just and reasonable.8 Consistent with the Cities’
practice, if any of the Cities determines that changes to its TO Tariff are needed to address the
issues in the Show Cause Order or any other topics, each City will file proposed revisions to its
TO Tariff with the Commission.9
6 Show Cause Order at P 3, n.9.
7 See id. (explaining that certain non-jurisdictional entities’ TO Tariffs include wholesale load interconnection
processes).
8 See id.
9 See, e.g., TO Tariff EDAM Revisions, City of Anaheim, Docket No. ER26-2310-000 (filed Apr. 27, 2026)
(proposing revisions to the City’s TO Tariff to reflect modifications related to Extended Day Ahead Market Access
Charge revenues).
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IV.
CONCLUSION
WHEREFORE, for the foregoing reasons, the Six Cities respectfully request that the
Commission rescind the Show Cause Order against each of the Cities as non-public utilities and
ask that the Commission waive any notice and comment periods that might be applicable to this
motion.
Respectfully submitted,
/s/ Margaret E. McNaul
Margaret E. McNaul
Rebecca L. Shelton
Jenna E. Cliatt
Attorneys for the Cities of Anaheim, Azusa,
Banning, Colton, Pasadena, and Riverside,
California
Law Offices of:
Thompson Coburn LLP
1909 K Street, N.W., Suite 600
Washington, D.C. 20006-1167
202.585.6900
202.585.6969 (facsimile)
July 31, 2026
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CERTIFICATE OF SERVICE
I hereby certify that I have on this 31st day of July, 2026, caused a copy of the foregoing
document to be sent to all parties on the list compiled by the Secretary of the Commission in this
proceeding, by electronic mail or such other means as may have been specified by such party,
pursuant to Commission Rule 2010.
/s/ Margaret E. McNaul
Margaret E. McNaul
Attorney for the Cities of Anaheim, Azusa,
Banning, Colton, Pasadena, and Riverside,
California
Law Offices of:
Thompson Coburn LLP
1909 K Street, N.W., Suite 600
Washington, D.C. 20006-1167
202.585.6900
202.585.6969 (facsimile)