EL26-71-000 · 2026-08-03 · Western Area Power Administration

Motion to Rescind Show Cause Order as applied to Western Area Power Administration

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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 WESTERN AREA POWER ADMINISTRATION 
 
 
Pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure,1 the Western 
Area Power Administration (WAPA) hereby submit this motion to rescind the show cause order 
 
1 18 C.F.R. § 385.212 (2026).

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issued by the Commission in the above-referenced proceeding on June 18, 2026,2 as directed to 
WAPA in its capacity as a Participating Transmission Owner (“TO”) in the California 
Independent System Operator Corporation (“CAISO”).  
I. 
WAPA BACKGROUND 
WAPA is a power marketing administration of the U.S. Department of Energy.  WAPA 
was created in 1977 by section 302(a)(1)(E) and (F) of the Department of Energy Organization 
Act.  WAPA’s mission is to market and deliver reliable, renewable, cost-based federal 
hydroelectric power, transmission, and related services within a 15-state region of the central and 
western United States.  WAPA was established to assume the marketing functions of power 
generated by the various dams owned and operated by the U.S. Department of Interior, Bureau of 
Reclamation (Reclamation), and the U.S. Army Corp of Engineers.  WAPA is engaged in, 
among other things, marketing, transmitting, and arranging for delivery of power to its customers 
– which include Reclamation’s project-use loads and WAPA’s other electric service customers.  
WAPA markets power to preference entities who are generally nonprofits including public utility 
districts, municipalities, water and irrigation districts, federal and state agencies, rural electric 
cooperatives, and Native American Tribes.  WAPA also owns, operates, and maintains high 
voltage transmission systems to facilitate delivery of its power to its customers, and sells excess 
transmission capacity. 
WAPA’s Sierra Nevada Region (WAPA-SN) sells power at wholesale to preference 
customers in California from multiple hydroelectric powerplants of the Central Valley Project 
(CVP) and market purchases, using the CVP transmission system.  The great majority of WAPA-
SN’s system operates as a sub-balancing authority area under the Balancing Authority of 
 
2 Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (the “Show Cause Order”).

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Northern California (BANC).  However, one of WAPA-SN’s transmission lines is within the 
operational control of the CAISO.   
WAPA-SN became a Participating TO in the CAISO and signed the Transmission 
Control Agreement (“TCA”) among and between the CAISO and its Participating TOs in 
December 2004.  WAPA only placed under the operational control of the CAISO its rights and 
interests in the Path 15 Upgrade Project, a single, approximately 83-mile, 500-kilovolt 
transmission line extending from the PG&E Los Banos Substation to the PG&E Gates 
Substation.  A federal entity, WAPA has reserved various rights and authorities necessary to 
facilitate its participation as a TO for the Path 15 Upgrade project, including use of its own Tarif 
or OATT for interconnections to the Path 15 Upgrade to the extent the CAISO provisions are 
inconsistent.  
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’s Open Access Transmission Tariff (“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.3  
 
3 Show Cause Order at P 3.

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III. 
JUSTIFICATION FOR RESCISSION 
WAPA is a non-public utility that is exempt from the Commission’s jurisdiction pursuant 
to Section 201(f) of the Federal Power Act.4  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 non-public utility’s CAISO 
Tariff provisions on file with the Commission.”5  Accordingly, as a non-public utility, WAPA 
requests that the Commission rescind the Show Cause Order against it. 
WAPA has and will continue to coordinate and cooperate with the CAISO in responding 
to the Show Cause Order, to the extent that the CAISO requests assistance from WAPA and 
other non-public utilities.  WAPA has conferred with the CAISO in advance of the filing of this 
motion. In accordance with WAPA policy and practice, if in the course of WAPA’s continued 
coordination with the CAISO that it determines changes to its Tariff are needed to address the 
issues in the Show Cause Order, WAPA will file proposed revisions to its Tariff with the 
Commission in due course. 
 
 
4 16 U.S.C. 824(f) (2024) (”No provision in this subchapter shall apply to, or be deemed to include, the United 
States”), cited in Show Cause Order at P 3, n.9. 
5 Show Cause Order at P 3, n.9.

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IV. 
CONCLUSION 
WHEREFORE, for the foregoing reasons, WAPA respectfully requests that the 
Commission rescind the Show Cause Order against WAPA as a non-public utility and ask that 
the Commission waive any notice and comment periods that might be applicable to this motion. 
 
Respectfully submitted, 
 
 
/s/ J.Ben Summerhays 
 
 
 
 
 
Attorney for Western Area Power Administration 
 
 
Western Area Power Administration 
 
12155 W. Alameda Parkway 
 
Lakewood, CO 80228-8213 
 
(720) 962-7023 
 
summerhays@wapa.gov 
 
 
 
August 3, 2026

CERTIFICATE OF SERVICE 
I hereby certify that I have on this 3rd day of August, 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/ J. Ben Summerhays 
 
 
 
Attorney for Western Area Power Administration 
 
Western Area Power Administration 
12155 W. Alameda Parkway 
Lakewood, CO 80228-8213 
(720) 962-7023 
summerhays@wapa.gov