EL26-71-000 · 2026-08-03 · Six Cities CA

Conditional Motion for Abeyance 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 
 
 
CONDITIONAL MOTION FOR ABEYANCE  
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 conditional motion to hold in abeyance the 60-day deadline to 
respond to the show cause order issued by the Commission in the above-referenced proceeding.2  
This motion is conditional because the Six Cities have filed a motion to rescind the Show Cause 
Order,3 and, if that Motion to Rescind is granted, the Cities’ abeyance request will be moot.   
I. 
MOTION FOR ABEYANCE 
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 
Open Access Transmission Tariff of the California Independent System Operator Corporation 
(“CAISO”) and/or the Transmission Owner (“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.4  The Show Cause Order 
therefore directed the CAISO and its 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.5  
As explained in the Motion to Rescind, 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 
(“FPA”).6  In the Show Cause Order, the Commission acknowledged that some of the 
 
2 Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (the “Show Cause Order”).   
3 Motion to Rescind Show Cause Order on behalf of the Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and 
Riverside, Cal., Cal. Indep. Sys. Operator Corp., Docket No. EL26-71-000 (filed July 31, 2026) (“Motion to 
Rescind”).   
4 Show Cause Order at P 3.   
5 Id.   
6 16 U.S.C. 824(f) (2024), City of Anaheim, Cal., 171 FERC ¶ 61,263, at PP 19-22 (2020) (cited in Show Cause 
Order at P 3, n.9).

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Participating TOs in the CAISO 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.”7  Accordingly, the Motion to Rescind requested that the 
Commission rescind the Show Cause Order against each of the Six Cities.  The Motion to 
Rescind, which is supported by the CAISO, is pending at this time.   
Because the Commission has yet to act on the Motion to Rescind, the Six Cities 
conditionally request a 90-day abeyance of the 60-day deadline to respond to the Show Cause 
Order.  In the Show Cause Order, the Commission explained that it would consider requests “to 
hold, for up to 90 days, all or certain aspects of this FPA section 206 proceeding in abeyance, 
including the deadline to respond to this order.”8  The purpose of the abeyance, according to the 
Commission, is to allow sufficient time for the CAISO and Participating TOs to develop FPA 
section 205 filings proposing revisions to their respective TO Tariffs to address the issues in the 
Show Cause Order.9   
Good cause exists for the Commission to grant the Six Cities’ conditional request for 
abeyance.  As an initial matter, this abeyance request will be moot in the event the Commission 
grants the Motion to Rescind.  Recission is appropriate because each of the Six Cities is a non-
public utility exempt from the Commission’s jurisdiction pursuant to Section 201(f) of the 
FPA.10   
 
7 Show Cause Order at P 3, n.9.   
8 Id. at P 35.   
9 Id.   
10 Motion to Rescind at 3, n.5 (citing inter alia 16 U.S.C. 824(f) ).  As explained in the Motion to Rescind, the Six 
Cities will coordinate and cooperate with the CAISO in responding to the Show Cause Order with respect to the 
provisions of the Cities’ TO Tariffs that are relevant to the issues in the Show Cause Order.

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If the Motion to Rescind is not granted, the Six Cities will need an additional 90 days to 
prepare responses to the Show Cause Order, develop potential revisions to each of their TO 
Tariffs to address any modifications that are determined to be needed, and coordinate both their 
responses to the Show Cause Order and proposed tariff revisions with the CAISO (which has 
advised that it intends to conduct a stakeholder proceeding to develop responsive policies and 
tariff changes) and the other Participating TOs.  Moreover, the Six Cities’ facilities and 
Entitlements in the CAISO generally represent either shares of jointly-owned facilities with, in 
some cases, entities that are not CAISO Participating TOs and/or are also not Commission-
jurisdictional, or contractual rights to transmission service on other parties’ systems governed by 
those parties’ tariffs and/or bilateral agreements.11  Therefore, the Six Cities may potentially 
need to coordinate their responses to the Show Cause Order with these parties as well.  Finally, 
each City will need to evaluate whether proposed revisions to their TO Tariffs to address the 
Show Cause Order require review and approval by the City’s Public Utility Board or the City 
Council (or both) and obtain any necessary authorizations from those regulatory authorities.   
Given that the issues raised in the Show Cause Order are both important and novel, it is 
critical that the Cities have adequate time to fully consider and prepare responsive filings if the 
Show Cause Order is not rescinded.  For these reasons and in light of the circumstances 
described above, the Six Cities conditionally seek a 90-day abeyance of the 60-day response 
deadline if and to the extent that the Commission does not grant the Six Cities’ pending Motion 
to Rescind.   
 
 
 
11 Motion to Rescind at 2-3.

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II. 
CONCLUSION 
WHEREFORE, for the foregoing reasons, the Six Cities respectfully request that the 
Commission grant the Six Cities’ request to hold the 60-day deadline to respond to the Show 
Cause Order in abeyance for an additional 90 days.  As explained above, in the event that the 
Commission grants the Six Cities’ currently-pending Motion to Rescind the Show Cause Order, 
this motion is moot. 
 
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) 
 
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/ 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)