EL26-71-000 · 2026-08-03 · Southern California Edison CompanySan Diego Gas & Electric CompanyPacific Gas & Electric Company ,SunZia Transmission, LLC ,Citizens Sunrise Transmission LLC ,Citizens Sycamore-Penasquitos Transmission LLC ,Citizens S-Line Transmission LLC ,LS Power Grid California, LLC ,DesertLink, LLC ,Horizon West Transmission, LLC ,GridLiance West LLC ,Trans Bay Cable, LLC ,Viridon Path 15 LLC ,Valley Electric Association, Inc. ,Startrans IO, L.L.C. ,
Request for Abeyance of Southern California Edison Company, et al. in response to the Order issued on 06/18/2026
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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
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Docket No. EL26-71-000
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REQUEST FOR ABEYANCE OF
SOUTHERN CALIFORNIA EDISON COMPANY; PACIFIC GAS AND ELECTRIC
COMPANY; SAN DIEGO GAS & ELECTRIC COMPANY; CITIZENS SUNRISE
TRANSMISSION LLC; CITIZENS SYCAMORE-PENASQUITOS TRANSMISSION
LLC; CITIZENS S-LINE TRANSMISSION LLC; SUNZIA TRANSMISSION, LLC; LS
POWER GRID CALIFORNIA, LLC; DESERTLINK, LLC; GRIDLIANCE WEST LLC;
HORIZON WEST TRANSMISSION, LLC; TRANS BAY CABLE LLC; VIRIDON PATH
15 LLC; VALLEY ELECTRIC ASSOCIATION, INC.; AND STARTRANS IO, LLC
I.
INTRODUCTION
Pursuant to Rules 206, 212, and 213 of the Federal Energy Regulatory Commission’s
(FERC or Commission) Rules of Practice and Procedure,1 Southern California Edison Company;
Pacific Gas and Electric Company; San Diego Gas & Electric Company; Citizens Sunrise
Transmission LLC; Citizens Sycamore-Penasquitos Transmission LLC; Citizens S-Line
Transmission LLC; SunZia Transmission, LLC; LS Power Grid California, LLC; DesertLink,
LLC; GridLiance West LLC; Horizon West Transmission, LLC; Trans Bay Cable LLC; Viridon
Path 15 LLC; Valley Electric Association, Inc.; and Startrans IO, LLC (together, the Joint PTOs)
respectfully submit this Request for Abeyance in response to the Order Instituting Proceeding
Under Section 206 of the Federal Power Act (the OSC) issued in the above-captioned proceeding
on June 18, 2026. The Joint PTOs seek a 90-day full abeyance of the current 60-day deadline to
respond to all issues raised in the OSC so that the Joint PTOs may each have the additional time
necessary to prepare Federal Power Act (FPA) section 205 filings revising their respective
Transmission Owner (TO) Tariffs.
The Joint PTOs appreciate the Commission’s attention and guidance on issues relating to
the interconnection of large loads, including data centers, to the FERC-jurisdictional
transmission system. The Joint PTOs believe the potential tariff changes the Commission
discusses in the OSC will provide opportunities for the California Independent System Operator
1
18 C.F.R. §§ 385.212 and 385.213 (2026).
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Corporation (CAISO) and the PTOs to bring large loads online efficiently and further protect
ratepayers across the CAISO region from transmission-related costs associated with large loads.
The Joint PTOs also agree that revising the interconnection process to facilitate the connection of
large loads to the California grid should be a priority as the stakeholders work through this
process. The Joint PTOs seek an abeyance so that they can have further time to develop a robust,
workable, and transparent set of tariff amendments responsive to the Commission’s identified
areas of concern as relevant to TOs. The Joint PTOs acknowledge that there are significant
differences among the California PTOs (some PTOs serve load while others do not, for example)
such that the appropriate TO Tariff changes to implement the OSC will also likely vary from
PTO to PTO such that each PTO must develop its proposed tariff changes to reflect its unique
circumstances and to coordinate those unique circumstances with CAISO and the other PTOs.
II.
ARGUMENT
In the OSC, the Commission states that it will consider requests for abeyances of up to 90
days, which should include both (1) a robust description of the content of a potential future filing
under FPA section 205 and (2) a reasoned and specific explanation of when such a filing is
expected to be made.2
The Joint PTOs each plan to develop an FPA section 205 filing to amend their respective
TO Tariffs, as described below. The Joint PTOs respectfully request the Commission hold the
deadline to respond to the OSC in abeyance for a 90-day period. Good cause exists to grant this
motion because doing so will allow the Joint PTOs to address issues identified by the
Commission in the OSC through FPA section 205 filings. The issues the Commission has raised
in the OSC are complex and substantial, requiring each of the PTOs to draft entirely new
sections of their respective TO Tariffs, potentially including new pro forma contract(s), and
incorporate study and application processes tailored to large loads interconnecting to the
transmission system. For those Joint PTOs with retail-load responsibilities, state-jurisdictional
2 OSC at P 35.
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retail load tariffs, agreements, rates, and processes must also be carefully considered. Moreover,
many of the Commission’s identified concerns can only be resolved with complementary or, at a
minimum, non-conflicting tariff provisions among the CAISO Tariff and the various TO Tariffs.
In order to develop a comprehensive set of TO Tariff revisions addressing the myriad concerns
the Commission has raised and reflecting each PTO’s unique circumstances, the Joint PTOs must
therefore closely coordinate with the CAISO as they each draft new tariffs provisions and, as
applicable, revise existing provisions. The CAISO is separately seeking an abeyance to engage
in its stakeholder process, requiring a corresponding abeyance for the Joint PTOs. Coordination
with other stakeholders, including the undersigned California Investor Owned Utilities (IOUs),
the undersigned TOs, and other TOs, will also be necessary. Filing tariff revisions on August 17
would require the Joint PTOs to submit tariff provisions that would likely conflict with the
CAISO’s design, which the Joint PTOs cannot reasonably predict this early in the stakeholder
process. The requested 90-day abeyance will instead permit a coordinated set of filings.
Accordingly, the Joint PTOs seek an abeyance until November 16, 2026, for each of the Joint
PTOs to submit its response to the OSC, including its anticipated FPA section 205 filing.
A.
Proposed TO Tariff Revisions
In the OSC, the Commission has identified five areas of potential deficiency in either the
CAISO and/or TO Tariffs. First, the Commission has stated that the CAISO and/or TO Tariffs
may lack provisions that address, with sufficient clarity and consistency, how CAISO and/or the
Participating TOs will timely study the provision of transmission service to Eligible Customers
on behalf of large loads.3 The OSC states that the CAISO and/or the TOs should explain
whether their respective tariffs remain just and reasonable without provisions outlining an
application process, study procedures, and ongoing operational requirements that address the
unique characteristics and challenges of providing transmission service to Eligible Customers on
behalf of large loads, or propose appropriate tariff revisions. Second, the OSC indicates that the
3 OSC at Section III.A.
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CAISO and/or TO Tariffs may be unjust and unreasonable because they appear to lack (1)
transparency regarding the assignment of network upgrades, and their associated costs, that are
needed to provide transmission service to Eligible Customers on behalf of large loads; and (2) a
pro forma cost recovery agreement among CAISO, the relevant transmission owner, and the
Eligible Customer taking transmission service on behalf of large loads that helps ensure that
Eligible Customers bear the risk and are ultimately responsible for costs incurred to provide
transmission service.4 Third, the Commission has identified the CAISO Tariff as potentially
deficient without clear and consistent provisions addressing the rates, terms, and conditions
applicable to co-location arrangements and for transmission services that reflect an Eligible
Customer taking transmission service on behalf of Eligible Load that is willing and able to limit
its energy withdrawals from the transmission system under certain conditions.5 Fourth, the OSC
states that the CAISO Tariff appears unjust and unreasonable because it does not include
transmission services that reflect Eligible Customers taking transmission service on behalf of
flexible large loads that are willing and able to limit their use of the transmission system under
certain conditions.6 Fifth, the Commission preliminarily finds that the CAISO Tariff appears to
be unjust and unreasonable because it does not contain provisions allowing an interconnection
customer to seek the generator interconnection service(s) reflecting the operational dynamics of
serving electrically proximate or co-located load with a high peak load.7
The OSC does not suggest that the TO Tariffs are unjust and unreasonable with respect to
all Commission concerns. For instance, the third, fourth, and fifth issues – co-located load,
flexible services, and proximate load – are primarily directed at the CAISO Tariff, where these
4 OSC at Section III.B.
5 OSC at Section III.C. The CAISO Tariff also is identified as potentially unjust and unreasonable with
regards to how it allows “load with BTMG to net its BTMG against its load for purposes of
calculating Regional Access Charges.” The CAISO Tariff’s existing BTMG netting rule requires the
relevant BTMG load to take retail standby service from the relevant utility, a fact omitted in the OSC
discussion of this issue and which fact impacts the relevant utility and others.
6 OSC at Section III.D.
7 OSC at Section III.E.
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types of transmission services would typically reside.8 Nonetheless, the issues for the CAISO
and TOs to address are interconnected, whether they require changes to the CAISO Tariff, the
TO Tariffs, or both. Accordingly, successful FPA section 205 filings will require significant
coordination among the CAISO, TOs, and other stakeholders, such as California regulators. The
Joint PTOs understand that the CAISO plans to file responsive tariff amendments in November
(assuming its abeyance request is granted), and the Joint PTOs cannot revise their respective TO
Tariffs in a vacuum.9 For example, the roles, responsibilities, and processes to interconnect and
serve large loads taking new types of transmission services will likely be dependent on
modifications to existing services under the CAISO Tariff. As the stakeholders work through
this process, necessary deviations to reflect regional differences in CAISO must also be
considered. The Joint PTOs have already been meeting with the CAISO weekly, and have
coordinated in developing their respective requests for abeyance, including by conferring
regarding the issues expected to be addressed, the contemplated process for implementing
appropriate FPA section 205 revisions, and the anticipated filing schedule. Although CAISO
and the Joint PTOs are filing separately in recognition of their distinct responsibilities and filing
rights, their respective requests reflect a coordinated regional effort consistent with Commission
direction.10 The Joint PTOs intend to continue working together through the stakeholder process
8 LS Power Grid California, LLC and DesertLink, LLC more specifically note that they are
independent transmission owners that do not serve retail load or have load-serving obligations.
Matters involving state-jurisdictional retail tariffs and agreements, retail standby service, resource-
adequacy procurement, and CAISO-administered transmission services, ancillary services, market
participation, and generator-interconnection service therefore do not implicate their TO Tariffs in the
same manner. Any potential FPA section 205 filing by either company would be limited to matters
that implicate its own TO Tariff or a PTO-administered agreement.
9 See CAISO Informational Report at p. 15 (July 20, 2026). Given CAISO governance rules and the
need for CAISO Board approval, revisions to the CAISO Tariff are unlikely to be finalized until close
to the November 16 filing deadline, assuming the CAISO is granted its own abeyance. The CAISO
does not currently plan to seek Board approval until October 28, just over two and a half weeks
before a 90-day extended filing deadline for tariff changes.
10 See OSC at P 35.
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to identify appropriate revisions to the CAISO and/or TO Tariffs.11 The Joint PTOs’ FPA
section 205 filings are currently expected to present revisions to the TO Tariffs to include study,
application, and operational procedures for the interconnection of large loads, as well as
provisions to address transparency, cost-recovery, financial-security, and rate-treatment
provisions intended to prevent cost shifting. These matters remain under development and may
evolve through coordination with CAISO and stakeholders. Joint PTOs will coordinate with
CAISO according to its publicly posted schedule, conform their proposed revisions following
CAISO's scheduled October 28, 2026 Board consideration, and complete internal approvals in
time to submit their filings by November 16, 2026.
B.
Briefing Questions
The Commission also identifies several issues for further briefing.12 The Joint PTOs also
request to toll the deadline to respond to the briefing questions for 90 days, consistent with the
OSC’s explanation of the effect of an abeyance.13 The Joint PTOs believe an abeyance is
appropriate as to the briefing questions as they are wholly interrelated with the issues to be
addressed in the Joint PTOs’ Section 205 filings, as described above.
III.
CONCLUSION
For the reasons described above, the Joint PTOs respectfully request that the Commission
grant the Request for Abeyance and extend each of the Joint PTOs’ deadlines to respond in full
to the OSC to November 16, 2026.
11 For example, the Joint PTOs cannot create new application processes and study processes to account
for new CAISO flexible, co-located, and/or proximate transmission services without knowing the
characteristics of those services.
12 OSC at Section IV.
13 See OSC at P 35 (holding that “the deadline to respond to this order” will be held in abeyance for 90
days upon a successful petition by a TO).
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Respectfully submitted,
Ellen C. Kenney
/s/ Ellen C. Kenney
By:
Ellen C. Kenney
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone:
(626) 302-9519
E-mail:
Ellen.Kenney@sce.com
Jonathan J. Newlander
/s/ Jonathan J. Newlander
By:
Jonathan J. Newlander
Attorney for
SAN DIEGO GAS & ELECTRIC COMPANY
8330 Century Park Court, CP32D
San Diego, California 92123
Telephone:
(619) 577-3468
E-mail:
JNewlander@sdge.com
Tara Kaushik
Grady Mathai-Jackson
John P. Perkins, III
William Brenc
/s/ John P. Perkins, III
By:
John P. Perkins, III
Attorneys for
PACIFIC GAS & ELECTRIC CO.
Pacific Gas and Electric Company
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Law Department, 19th Floor
300 Lakeside Drive, Suite 210
Oakland, CA 94612
Telephone: 501-551-4036
Email: john.perkins@pge.com
Robert L. Daileader
/s/ Robert L. Daileader
By:
Robert L. Daileader
Attorney for
SUNZIA TRANSMISSION, LLC
Nixon Peabody LLP
799 Ninth Street NW, Suite 500
Washington, DC 20001
Telephone:
(202) 288-2069
E-mail:
rdaileader@nixonpeabody.com
Amy E. McDonnell
Ashley M. Bond
/s/ Ashley M. Bond
By:
Ashley M. Bond
Counsel for
CITIZENS SUNRISE
TRANSMISSION LLC, CITIZENS SYCAMORE-
PENASQUITOS TRANSMISSION LLC, AND CITIZENS S-
LINETRANSMISSION LLC
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Duncan & Allen LLP
1730 Rhode Islan Ave., N.W
Suite 700
Washington, DC 20036
Telephone:
(202) 289-8400
Facsimile:
(202) 289-8450
E-mail:
amb@DuncanAllen.com
Blake R. Urban
/s/ Blake R. Urban
By:
Blake R. Urban
Attorney for
LS POWER GRID CALIFORNIA, LLC AND DESERTLINK,
LLC
16150 Main Circle Drive, Suite 310
Chesterfield, MO 63017
Telephone:
(636) 231-0475
E-mail:
burban@lspower.com
Elizabeth Ramey
/s/ Elizabeth Ramey
By:
Elizabeth Ramey
Attorney for
GRIDLIANCE WEST LLC; HORIZON WEST
TRANSMISSION, LLC; AND TRANS BAY CABLE LLC
NextEra Energy, Inc.
801 Pennsylvania Avenue NW, Suite 200
Washington, DC 20004
Telephone:
(202) 909-5695
E-mail:
elizabeth.ramey@nexteraenergy.com
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Verónica Gómez
/s/ Verónica Gómez
By:
Verónica Gómez
Attorney for
VIRIDON PATH 15 LLC
515 North State Street, Suite 1150
Chicago, IL 60654
Telephone: (773) 551-1920
E-mail: veronica@viridon.com
Dakota L. Councilman
/s/ Dakota L. Councilman
By:
Dakota L. Councilman
Attorney for
VALLEY ELECTRIC ASSOCIATION, INC.
Davison Van Cleve, P.C.
4675 W. Teco Ave., Suite 230
Las Vegas, NV 89118
Telephone: (702) 267-6763
E-mail: dlc@dvclaw.com
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Joseph C. Hall
/s/ Joseph C. Hall
By:
Joseph C. Hall
Attorney for
STARTRANS IO, LLC
Joseph C. Hall
Edwin G. Kichline
Kelly A. Cuthbertson
Eversheds Sutherland (US) LLP
700 Sixth Street, NW, Suite 700
Washington, DC 20001-3980
Telephone: (202) 383-0100
Email: joehall@eversheds-sutherland.com
Email: edwinkichline@eversheds-sutherland.com
Email: kellycuthbertson@eversheds-sutherland.com
Ali Amirali
General Manager
Startrans IO, L.L.C.
5 Greenwich Office Park
Greenwich, Connecticut 06831
Telephone: (408) 204-7630
Email: aamirali@lotuspartners.com
Dated: August 3, 2026
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CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing REQUEST FOR ABEYANCE
OF SOUTHERN CALIFORNIA EDISON COMPANY; PACIFIC GAS AND ELECTRIC
COMPANY; SAN DIEGO GAS & ELECTRIC COMPANY; CITIZENS SUNRISE
TRANSMISSION LLC; CITIZENS SYCAMORE-PENASQUITOS TRANSMISSION
LLC; CITIZENS S-LINE TRANSMISSION LLC; SUNZIA TRANSMISSION, LLC; LS
POWER GRID CALIFORNIA, LLC; DESERTLINK, LLC; GRIDLIANCE WEST LLC;
HORIZON WEST TRANSMISSION, LLC; TRANS BAY CABLE LLC; VIRIDON PATH
15 LLC; VALLEY ELECTRIC ASSOCIATION, INC.; AND STARTRANS IO, LLC upon
each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Rosemead, California, this 3rd day of August 2026.
/s/ Karen Abarca
Karen Abarca
Senior Legal Administrative Assistant
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770