{"document":{"slug":"filing-20260803-5170","title":"Motion to Hold Filing Obligation in Abeyance of DCR Transmission, L.L.C","issued":"2026-08-03","accession":"20260803-5170","docket":"EL26-71-000","group":"CAISO filings","filer":"DCR Transmission, L.L.C.","kind":"motion","file":"sources/originals/20260803-5170_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5170","sha256":"a79cecd49f7e9b702f6acbcf9a220eab221b44e8619809ab919580890f1a33fb","pages":16,"tokens":4247,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":191,"text":"1 \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \nCalifornia Independent System Operator \nCorporation  \nCitizen S-Line Transmission LLC  \nCitizens Sunrise Transmission LLC  \nCitizens Sycamore-Penasquitos Transmission \nLLC  \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 \n \n) \n) \n) \n) \nDocket No. EL26-71-000 \nMOTION TO HOLD FILING OBLIGATION IN ABEYANCE  \nOF DCR TRANSMISSION, L.L.C. \nPursuant to Rules 206, 212, and 213 of the Federal Energy Regulatory Commission’s \n(“FERC” or “Commission”) Rules of Practice and Procedure,1 DCR Transmission, L.L.C. \n(“DCRT”) respectfully submits this motion for abeyance of the above-captioned proceeding \nestablished by the Commission’s June 18, 2026, Order Instituting Proceeding Under Section 206 \n \n118 C.F.R. §§ 385.206, 385.212, and 385.213 (2026)."},{"page":2,"startToken":191,"endToken":485,"text":"2 \nof the Federal Power Act (“FPA”) (the “OSC”).2  Consistent with the OSC and as explained herein, \nDCRT requests the Commission hold this proceeding, including the deadline for responding to the \nbriefing questions, in abeyance for ninety (90) days, up to and including November 16, 2026, so \nthat DCRT may fully respond to the issues raised in the OSC and submit any necessary filings \nwith the Commission.  The deferral of DCRT’s deadline to respond to the OSC would allow DCRT \nto coordinate with the relevant stakeholders, including the California Independent System \nOperator Corporation (“CAISO”) and, as necessary, DCRT’s interconnecting utilities in Arizona \n(as explained below), to comprehensively analyze the issues identified by the Commission and \nprepare any necessary submissions to the Commission, including an FPA section 205 filing \nrevising DCRT’s Transmission Owner (“TO”) Tariff.   \nI. \nBACKGROUND  \nDCRT is a Participating Transmission Owner (“PTO”) and thus a TO under the CAISO \nOpen Access Transmission Tariff (“CAISO Tariff”).  DCRT owns and manages the 125-mile, 500 \nkilovolt Ten West Link Transmission Line (“Ten West Link”), which runs from Arizona Public \nService Company’s (“APS”) Delaney Substation to Southern California Edison’s (“SCE”) \nColorado River Substation.  In 2015, DCRT won the CAISO’s competitive solicitation leading to \nthe development of Ten West Link.  Ten West Link entered commercial operation in June 2024, \nand is currently one of the few interconnections between Arizona and southern California.  \nApproximately 100 miles of Ten West Link are in Arizona.  \nThe entirety of Ten West Link, including the portion located in Arizona, is part of the \nCAISO Balancing Authority Area (“BAA”) and is subject to the CAISO’s operational control, \nwith transmission-related service over the line provided under the CAISO Tariff and DCRT’s TO \n \n2 Cal. Independent Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (“OSC”)."},{"page":3,"startToken":485,"endToken":809,"text":"3 \nTariff.  Therefore, Ten West Link is integrated into the CAISO transmission system, and, in fact, \nextends the CAISO footprint into the retail franchise territory of APS, a state-franchised utility \nthat is not a PTO and that operates its own BAA and is regulated by the Arizona Corporation \nCommission.  This means a large load seeking transmission service from the Arizona portion of \nDCRT’s facility would sit within the retail service territory of a state-franchised utility, outside the \nCAISO BAA, while interconnecting to a facility that is part of the CAISO controlled grid.   \nAs the Commission understands, the OSC raises a wide range of issues for industry \nparticipants, especially transmission-only companies (“Transcos”) like DCRT.  Tariff provisions \nthat presume a traditional franchised public utility model (e.g., a retail tariff, traditional native load \ncustomers, a retail regulator) do not properly apply to Transcos.  DCRT is a prototypical example: \nDCRT is not a Load Serving Entity (“LSE”), has no network customers, and every mile of its \ntransmission facility is part of the CAISO controlled grid, even though most of its facilities are in \nArizona, across a state boundary and within the retail franchise territory of APS.  APS is not fully \nintegrated into the CAISO footprint.3   \nDCRT’s differences from a traditional utility with a franchised service territory are a \nstructural feature of DCRT’s Commission-approved role as a transmission-only PTO, not a defect \nin DCRT’s existing TO Tariff.  It does mean, however, that the potential tariff provisions DCRT \ndevelops in response to the OSC may not necessarily be adapted from the integrated-utility model; \nthey must be drafted for the transmission-only context, and this distinction is what primarily drives \nDCRT’s requested abeyance.  DCRT’s TO Tariff revisions must not only address DCRT’s \nobligations under the CAISO framework but also interface with the retail framework of a state-\n \n3 APS voluntarily participates in the CAISO-administered Western Energy Imbalance Market; that \nparticipation does not place APS’s transmission facilities under CAISO operational control."},{"page":4,"startToken":809,"endToken":1074,"text":"4 \nfranchised utility in whose non-CAISO-controlled territory a large load sits.  DCRT must balance \nthese obligations without displacing that utility’s franchise and without converting DCRT, or any \nother wholesale entity, into a retail supplier in Arizona. \nDCRT’s operational circumstances are equally distinct.  Ten West Link currently \ncontributes significantly to the westbound delivery of Arizona resources to California load, and a \nlarge load withdrawing energy at or near the Arizona portion of the line would run counter to those \nprevailing flows.  DCRT’s network upgrade, cost-causation, and curtailment analyses that the OSC \ndirects must provide for that configuration. \nII. \nMOTION FOR ABEYANCE \nA. \nThe OSC Requires Substantial Coordination by Multiple Stakeholders and \nTime to Address DCRT’s Unique Circumstances \nDCRT understands the Commission is focusing on the integration of large loads into the \nbulk power system and the national and regional economies.  DCRT commends the Commission \nfor focusing on this issue to promote the greater national interest.  DCRT believes that the \ninterconnection and provision of transmission service to Eligible Customers on behalf of large \nloads in the CAISO region can be faster, more cost-effective, and ultimately better for transmission \ncustomers.  DCRT appreciates the Commission’s desire for prompt action and the invitation to be \nthe “first wielder of the pen.”4    \nIn the OSC, the Commission states that it will consider requests for abeyances of up to 90 \ndays, which should “include both (1) a robust description of the content of a potential future filing \nunder FPA section 205 and (2) a reasoned and specific explanation of when such a filing is \n \n4 OSC at LaCerte Concurrence, P 5."},{"page":5,"startToken":1074,"endToken":1399,"text":"5 \nexpected to be made.”5  DCRT is evaluating its TO Tariff and recognizes that it likely needs to \nmake certain tariff amendments to respond to the OSC; however, DCRT needs additional time to \nensure that any potential filing addresses the Commission’s concerns and objectives for large load \ninterconnection.  DCRT therefore respectfully requests an abeyance until November 16, 2026, so \nthat DCRT can conduct the process described above thoughtfully and thoroughly, yet with “all due \ndeliberate haste,”6 to promote cost-effective economic growth in DCRT’s footprint.  Below, DCRT \nexplains the process it must complete to prepare this filing and why the abeyance is needed. \nConsistent with the OSC’s objectives, DCRT will consult with the CAISO, other TOs, and \nrelevant stakeholders, such as large load developers, to evaluate potential tariff revisions that \naddress the OSC’s concerns.7  Moreover, DCRT may need to draft new tariff provisions and \nprocesses, including new pro forma contract(s), and incorporate study and application processes \ntailored to large loads interconnecting to the transmission system.8   \nAs a CAISO PTO, DCRT must ensure that its tariff proposal is consistent with and \nsupportable by the CAISO.  The CAISO’s July 20, 2026 Informational Report describes a \nstakeholder process running through Board action on October 28, 2026, with CAISO Tariff \namendments to be filed in November 2026.9  An abeyance for DCRT is warranted on the same \nschedule.  Coordination with other stakeholders, such as other TOs, other California Investor-\nOwned Utilities, and other independent, non-load-serving transmission owners, will also likely be \nnecessary.  This means that DCRT may not be able to finalize its large load procedures and tariff \n \n5 OSC at P 35. \n6 OSC at Swett Concurrence, P 8. \n7 OSC at P 37.  \n8 OSC at P 56 (identifying the types of tariff revisions that may be necessary).  \n9 Cal. Independent Sys. Operator Corp., Docket No. EL26-71-000, “California Independent System \nOperator Corporation Informational Report,” at 15 (filed July 20, 2026) (“CAISO Informational Report”)."},{"page":6,"startToken":1399,"endToken":1746,"text":"6 \nrevisions until the CAISO has completed its process, and DCRT may need to coordinate with other \nCAISO stakeholders to finalize its filing.   \nWhen developing these tariffs and processes, DCRT will also need to evaluate state-\njurisdictional retail load tariffs, agreements, rates, and processes.10  In addition to CAISO-specific \nissues, DCRT must consider the inter-relationship of the CAISO and APS transmission systems \nwhen evaluating large load interconnections.11  DCRT supports the OSC’s concern for speedy \nfiling of proposed additional or revised tariff provisions related to, among other things, study \nprocesses to service large load,12 as reiterated in two concurrences, but DCRT must ensure that its \ncoordinated processes and procedures reflect the unique regional characteristics of the CAISO and \nAPS systems, as recognized in the OSC and in Chairman Swett’s concurrence.13  \nClear and consistent provisions between the CAISO, CAISO stakeholders, DCRT, and \nlikely APS serve regulatory and process certainty, fairness, and efficiency for large loads and \ntransmission customers alike, and the Commission has stated that it expects the CAISO and the \nPTOs to coordinate with each other, as appropriate, in developing their responses to the OSC.14  \nDCRT will participate in that coordination in good faith, and it expects that much of the resulting \nframework can, and should, be common across the CAISO network.  At the same time, the \nCommission chose to proceed through individualized show cause orders rather than a generic \nrulemaking, an approach that, as Chairman Swett explained, allows solutions “tailored to the \n \n10  OSC at P 41 (recognizing that “that resolution of issues related to large load additions will require the \ninvolvement of both federal and state actors, including the Commission, state public utility commissions, \nand other state and local entities”). \n11 References in this motion to prospective coordination or consultation do not represent the views or \ncommitments of the CAISO, APS, the Arizona Corporation Commission, or any other entity. \n12 OSC at P 35; OSC at Swett Concurrence, P 5; OSC at LaCerte Concurrence, PP 5-6. \n13 OSC at P 35; OSC at Swett Concurrence, P 6. \n14 OSC at P 37."},{"page":7,"startToken":1746,"endToken":2049,"text":"7 \nspecific, varied circumstances” of each region rather than “a one-size-fits-all rule.”15  A uniform \nframework has real value only to the extent it can accommodate the diversity of circumstances \nacross the CAISO network, including those of non-LSE transmission owners whose facilities cross \nretail franchise boundaries.  Accordingly, DCRT will work toward consistency between its tariff \nprovisions and those of the CAISO and other PTOs wherever appropriate, and any section 205 \nfiling will propose provisions tailored to DCRT’s particular circumstances where a uniform \napproach does not accommodate them.   \nLastly, DCRT has been coordinating within the CAISO stakeholder process relating to its \nfiling in response to the OSC, and DCRT is aware that certain other California TOs are submitting \ntheir own joint filing.  While DCRT reserves the right to join any joint filing by the other California \nTOs, DCRT is seeking its own abeyance for a final deadline of November 16, 2026 because of its \nunique status as a Transco in CAISO that also crosses state lines.  \nIII. \nPROPOSED TO TARIFF REVISIONS \nThe following subsections describe the content DCRT anticipates proposing in its section \n205 filing to address each of the Commission’s preliminary findings.  The description provided in \nthis section is intended to satisfy the OSC’s requirement of a robust description of a potential future \nfiling; it is not intended to, and does not, prejudge the specific rates, terms, and conditions that \nDCRT will propose and support in the section 205 filing itself.   \nA. \nTransmission Service to Eligible Customers on Behalf of Large Loads \nThe OSC made a preliminary finding that the CAISO and/or TO Tariffs “appear to be \nunjust and unreasonable because they lack provisions that address, with sufficient clarity and \nconsistency, how the CAISO and/or the Participating TOs will timely study . . . the provision of \n \n15 OSC at Swett Concurrence, PP 5-6."},{"page":8,"startToken":2049,"endToken":2359,"text":"8 \ntransmission service to Eligible Customers on behalf of large loads.”16  The OSC invites the \nCAISO and/or the TOs to revise their respective tariffs to outline “an application process, study \nprocedures, and ongoing operational requirements that address the unique characteristics and \nchallenges of providing transmission service to Eligible Customers on behalf of large loads.”17  \nDCRT accepts this invitation. It will coordinate with the CAISO and the relevant stakeholders, as \nappropriate, and will submit responsive TO Tariff changes addressing these issues in its section \n205 filing.  DCRT will define “Large Load” when developing potential tariff revisions; however, \nit is not clear to DCRT that a 50 MW threshold is appropriate.18   \nDCRT’s proposed revisions will outline the transmission service application process, study \nprocedures, and ongoing operational requirements that the OSC invites, as applied to requests for \ntransmission service from DCRT’s facilities, and will provide for such service in a manner that \npreserves the existing westbound delivery capability of Ten West Link and the deliveries it \ncurrently supports.  These procedures will contemplate the CAISO’s ability to curtail customers \n(if necessary).19  DCRT expects that it will also need to evaluate the scope of affected systems for \nCAISO non-adjacent utilities. \nAs the Commission is aware, in CAISO, the TOs are responsible for interconnecting loads \nwhile the CAISO has operational control of most transmission assets.20  Thus, a high degree of \ncoordination between TOs and the CAISO is required for many of the tariff revisions or additions \ndirected by the OSC.  To address the concerns that the Commission has identified for transmission \n \n16 OSC at Section P 38. \n17 OSC at P 40.  \n18 OSC at P 57; see also OSC at P 113 (referencing a 50 MW threshold for large co-located loads).  \n19  OSC at P 63 (addressing the potential need to curtail large loads). \n20  OSC at PP 21-27."},{"page":9,"startToken":2359,"endToken":2670,"text":"9 \nservice for large loads, DCRT will need time to coordinate with the CAISO about allocating \nresponsibility for studying, and for providing, transmission service to Eligible Customers on behalf \nof large loads.  To draft the necessary tariff amendments and revisions, among other things, the \nCAISO, DCRT and other TOs must craft mutually compatible processes so all parties understand \nwhat information should be evaluated to ensure that operational risks of providing transmission \nservice to Eligible Customers on behalf of large loads are mitigated.   \nFurther, because of this division of responsibility between the CAISO and TOs, DCRT \nmust also coordinate with the CAISO in determining the information required for large-load \ninterconnection requests.  This is regardless of whether the large load is willing and able to limit \nits energy withdrawal under specific system conditions.   \nDCRT and/or the CAISO will also likely need to tailor the new tariff provisions and study \nprocess concerning large load interconnection to the operational needs of large loads.  DCRT must \nalso align with the CAISO about tariff additions addressing ongoing operational requirements for \ntransmission customers taking transmission service on behalf of large loads.21  Some provisions \nmay best be included in the CAISO Tariff while others may best be included in the TO Tariffs.  \nFor example, the OSC identifies the potential need for the CAISO to monitor large loads for \nimpacts of fast-ramping load that may affect the transmission system too quickly to be captured \nby conventional data acquisition systems.22  This may necessitate provisions requiring TOs to \ninstall, and the responsible Eligible Customer to pay for, new equipment to enable such \nmonitoring.  DCRT will also need to discuss with developers what kinds of mechanisms will \nsuccessfully deter speculative or duplicative requests for transmission service while allowing \n \n21 OSC at P 37 (recognizing the need for coordination among TOs, the CAISO, and other stakeholders). \n22 OSC at P 63."},{"page":10,"startToken":2670,"endToken":2934,"text":"10 \ncommercially viable projects to be promptly interconnected without excessive and unnecessary \nnetwork upgrades.23   \nDCRT also is evaluating procedures for the use of alternative transmission technologies \n(“ATTs”) and determining when ATTs should be used over traditional network upgrades.24  Thus, \nbefore drafting pro forma provisions addressing these and other issues identified in the OSC, \nDCRT will need time to carefully consider the issues, both internally and in discussion with \nexternal stakeholders, such as the CAISO and large-load developers, whose knowledge and input \nare critical.  Doing so will require careful engineering and cost-benefit analysis to ensure the \nprocess protects reliability while consistently identifying the best solution for customers in the 60–\n90 day timeframe targeted in the OSC.25   \nB. \nCost Shifting Risk Among Transmission Customers \nThe OSC  states that the CAISO and/or TO Tariffs may be unjust and unreasonable because \nof “the apparent lack of (1) transparency regarding the assignment of network upgrades, and their \nassociated costs, that are needed to provide transmission service to Eligible Customers on behalf \nof large loads; and (2) a pro forma cost recovery agreement between CAISO, the relevant \ntransmission owner, and the Eligible Customer taking transmission service on behalf of large loads \nthat help ensure that Eligible Customers bear the risk and are ultimately responsible for costs \nincurred to provide transmission service, including the cost of Network Upgrades.”26  DCRT will \nalso address these cost-shifting concerns with proposed TO Tariff changes in its section 205 filing.  \n \n23 OSC at P 55.  \n24 OSC at PP 60-61. \n25 OSC at P 62.  \n26 OSC at P 65."},{"page":11,"startToken":2934,"endToken":3222,"text":"11 \nThose revisions will address the transparency of network upgrade cost information and will \nprovide a just and reasonable pro forma cost recovery agreement.   \nWith respect to transparency, DCRT, the CAISO, and other TOs will need to collaborate \nand assign responsibilities to enable the robust, accurate, and systematic provision of data on the \nCAISO’s website in a single location, and in an easily accessible format that is searchable and \nallows users to filter the data, regarding the cost for network upgrades needed to provide \ntransmission service to Eligible Customers on behalf of large loads, as noted in the OSC.27  \nThe OSC has also identified an issue with the lack of a pro forma cost recovery agreement \nbetween the CAISO, the relevant TO, and the Eligible Customer taking transmission service on \nbehalf of a large load, and invites tariff revisions to establish one.28  Such an agreement, by \ndefinition, requires alignment between the CAISO, TOs, and potentially other stakeholders both \non the terms of the agreement and on whether the agreement needs to be included in one or both \nsets of tariffs.   \nAs stated above, DCRT is a single-asset Transco that crosses state lines; it must also \nconsider federal-state jurisdictional cost-allocation issues when interconnecting large loads.  \nDCRT must resolve the state-level issue of which entity will have the right to construct assets \ninterconnecting with DCRT’s line when addressing required network upgrades and align with both \nCalifornia and Arizona regulatory regimes.  DCRT’s tariff provisions will address (and where \nappropriate, govern) the interface between its TO Tariff and the state-jurisdictional retail regimes \nof the franchise territories that its facility crosses, in a manner that preserves the retail franchises \n \n27 OSC at PP 66, 70. \n28 OSC at PP 34, 65."},{"page":12,"startToken":3222,"endToken":3485,"text":"12 \nand retail regulatory authority of the affected states.  Drafting just and reasonable tariff provisions \naddressing these issues requires time to carefully analyze and balance all of these concerns.   \nC. \nCo-Location Arrangements; Flexible Transmission Services; Electrically \nProximate Large Load and Co-Located Load \nWith respect to co-located loads, flexible loads, and large loads that are electrically \nproximate to new generation, the Commission has identified the following issues with respect to \nthe CAISO Tariff, as opposed to the TO Tariffs.  First, the Commission noted that the CAISO \nTariff appears to be unjust and unreasonable without “clear and consistent provisions addressing \nthe rates, terms, and conditions that apply to co-location arrangements and for transmission \nservices that reflect an Eligible Customer taking transmission service on behalf of Eligible Load \nthat is willing and able to limit its energy withdrawals from the transmission system under certain \nconditions.”29  Second, the Commission found that the CAISO Tariff appears unjust and \nunreasonable because it does not include “transmission services that reflect Eligible Customers \ntaking transmission service on behalf of flexible large loads that are willing and able to limit their \nuse of the transmission system under certain conditions.”30  Third, the Commission found that the \nCAISO Tariff appears to be unjust and unreasonable because it does not contain provisions \n“allowing an interconnection customer to seek the generator interconnection service(s) that reflects \nthe operational dynamics of serving either: (1) electrically proximate large load or; (2) a co-located \nload . . . that has a high peak load.”31   \n \n29 OSC at P 85.   \n30 OSC at P 104. \n31 OSC at P 113."},{"page":13,"startToken":3485,"endToken":3784,"text":"13 \nWhile these three concerns are directed at the CAISO Tariff, they likely will have \nimplications for the PTOs.32  As appropriate, DCRT will address these issues in its tariff \nrevisions.33  For example, the CAISO’s tariff revisions regarding curtailment would require \nconforming changes to a TO Tariff. The CAISO’s revisions on BTMG may affect a TO’s \nassociated interconnection processes in its tariff.  DCRT notes that it welcomes BTMG as an \navenue that can improve interconnection times by reducing the impact of a new co-located load \non the grid.  Further, DCRT will need to coordinate with the CAISO concerning electrically \nproximate large load or a co-located load that has a high peak load and evaluate whether the \nCAISO’s definitions of proximate and high-peak loads are acceptable to DCRT.  \nDCRT understands that the CAISO plans to file its proposed tariff amendments in \nNovember 2026.34  DCRT’s TO Tariff will need to accommodate study processes for Eligible \nCustomers taking any new flexible, co-located, or proximate transmission services the CAISO \nTariff establishes.  DCRT cannot create new application processes and study processes for these \nnew transmission services without knowing the characteristics of those services.  The roles, \nresponsibilities, and processes to interconnect large loads taking new services will also depend on \nthe revisions to existing services under the CAISO Tariff, such as generator interconnection and \ntransmission planning.   \nHere too, the division of responsibility, where the CAISO currently studies generation \ninterconnection while the TOs study load interconnection, requires careful collaboration.  \nDesigning a new process for the interconnection of co-located load will therefore require allocation \n \n32 OSC at P 86. \n33 DCRT also anticipates addressing or explaining why the CAISO Tariff rather than the TO Tariff is the \nproper vehicle for, billing-determinant provisions concerning load with Behind-The-Meter Generation \n(“BTMG”). \n34 CAISO Informational Report at p. 15."},{"page":14,"startToken":3784,"endToken":4090,"text":"14 \nof responsibilities between the CAISO and TOs, especially when considering the possibility of \njoint studies as suggested by Commissioner Rosner.35  The same applies when determining criteria \nfor which loads may be jointly studied with electrically proximate generation and how to do so; \nand in determining clear and consistent provisions for the rates, terms, and conditions of service \nthat apply to interconnection customers serving co-located load after they are interconnected.   \nBased on the CAISO’s stakeholder process timeline, revisions to the CAISO Tariff will \nlikely not be finalized until close to the requested November 16 filing deadline if the CAISO is \ngranted an abeyance.  Under the timeline in the CAISO Informational Report, the CAISO Board \nis scheduled to act on October 28, 2026, with CAISO Tariff revisions filed thereafter in November \n2026.36  DCRT’s proposed November 16, 2026 filing will address each of the OSC’s directives \nthat implicates DCRT’s TO Tariff, based on the CAISO proposal then before the Commission.  If \nthe Commission’s ultimate action on the CAISO’s filing requires conforming changes to DCRT’s \nTO Tariff, DCRT will propose them promptly in the ordinary course under FPA section 205; no \nfurther extension of the abeyance is requested for that purpose.  \nD. \nBriefing Questions \nThe Commission also identifies several issues for further briefing.\n37  DCRT requests that \nthe deadline to respond to the briefing questions also be tolled for 90 days.\n38  DCRT so requests \nbecause the briefing questions are inextricably linked with the issues to be addressed in DCRT’s \nforthcoming section 205 filing. \n \n35 OSC at Rosner Concurrence, PP 11-13.  \n36 CAISO Informational Report at p. 15.  \n37 OSC at Section IV. \n38 See OSC at P 35 (allowing a Participating Transmission Owner to request the Commission to “hold, for \nup to 90 days, all or certain aspects of this FPA section 206 proceeding in abeyance”)."},{"page":15,"startToken":4090,"endToken":4178,"text":"15 \nIV. \nCONCLUSION \nDCRT respectfully requests that the Commission grant this Motion for Abeyance and \nextend DCRT’s deadline to respond in full to the OSC to November 16, 2026, for the reasons \ndescribed above.   \nRespectfully submitted, \n \n \n \n \nJoseph C. Hall  \n \nJoseph C. Hall \nHeather Harrison  \nShenghao Wang \nKelly A. Cuthbertson \nEversheds Sutherland (US) LLP \n700 Sixth Street, NW, Ste. 700 \nWashington, DC 20001 \nTel: (202) 383-0915 \njoehall@eversheds-sutherland.com \nheatherharrison@eversheds-sutherland.com \nshenghaowang@eversheds-sutherland.com \nkellycuthbertson@eversheds-sutherland.com \nAttorneys for DCR Transmission, L.L.C. \n     \n \n \n \nDated: August 3, 2026"},{"page":16,"startToken":4178,"endToken":4247,"text":"16 \nCERTIFICATE OF SERVICE \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding. \nDated at Washington, D.C., this 3rd day of August 2026. \n \nKelly A. Cuthbertson  \n \n \nKelly A. Cuthbertson  \nEversheds Sutherland (US) LLP \n700 Sixth Street, NW, Ste. 700 \nWashington, DC 20001 \nPhone: (202) 383-0246 \nEmail: kellycuthbertson@eversheds-sutherland.com"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":906,"startToken":0,"endToken":326},{"p":2,"at":906,"title":"I. BACKGROUND","method":"printed heading","endPage":2,"endAt":910,"startToken":326,"endToken":327},{"p":2,"at":910,"title":"BACKGROUND","method":"printed heading","endPage":4,"endAt":686,"startToken":327,"endToken":905},{"p":4,"at":686,"title":"II. MOTION FOR ABEYANCE","method":"printed heading","endPage":4,"endAt":712,"startToken":905,"endToken":909},{"p":4,"at":712,"title":"A. The OSC Requires Substantial Coordination by Multiple Stakeholders and","method":"printed heading","endPage":7,"endAt":1074,"startToken":909,"endToken":1911},{"p":7,"at":1074,"title":"III. PROPOSED TO TARIFF REVISIONS","method":"printed heading","endPage":7,"endAt":1573,"startToken":1911,"endToken":1987},{"p":7,"at":1573,"title":"A. Transmission Service to Eligible Customers on Behalf of Large Loads","method":"printed heading","endPage":10,"endAt":833,"startToken":1987,"endToken":2789},{"p":10,"at":833,"title":"B. Cost Shifting Risk Among Transmission Customers","method":"printed heading","endPage":12,"endAt":206,"startToken":2789,"endToken":3251},{"p":12,"at":206,"title":"C. Co-Location Arrangements; Flexible Transmission Services; Electrically","method":"printed heading","endPage":14,"endAt":1311,"startToken":3251,"endToken":3984},{"p":14,"at":1311,"title":"D. Briefing Questions","method":"printed heading","endPage":15,"endAt":4,"startToken":3984,"endToken":4091},{"p":15,"at":4,"title":"IV. CONCLUSION","method":"printed heading","endPage":15,"endAt":9,"startToken":4091,"endToken":4092},{"p":15,"at":9,"title":"CONCLUSION","method":"printed heading","endPage":16,"endAt":4,"startToken":4092,"endToken":4179},{"p":16,"at":4,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":16,"endAt":466,"startToken":4179,"endToken":4247}]}