{"document":{"slug":"motion-el26-71-caiso-abeyance","title":"CAISO requests more time to answer the June 18 show cause order","issued":"2026-08-03","accession":"20260803-5206","docket":"EL26-71-000","group":"CAISO filings","filer":"California Independent System Operator Corporation","kind":"motion for abeyance","file":"sources/originals/20260803-5206_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5206","sha256":"fd35dd424201ad87b6ce4ff4cea43b8e6e4b600dc269a1337dfe2616eb35ad32","pages":11,"tokens":2264,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":163,"text":"UNITED STATES OF AMERICA \nBEFORE THE  \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nCalifornia Independent System Operator \nCorporation \nCitizen S-Line Transmission LLC  \nCitizens Sunrise Transmission LLC  \nCitizens Sycamore-Penasquitos Transmission LLC \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 \nDocket No. \n \nEL26-71-000 \n \n  \n \n \n \n \n \n \n \n \nMOTION FOR ABEYANCE \n \nPursuant to Rule 212 of the Rules of Practice and Procedure of the \nFederal Energy Regulatory Commission, the California Independent System \nOperator Corporation (CAISO) respectfully submits this motion to hold the instant \nproceeding in abeyance for 90 days from the deadline to respond, i.e., until"},{"page":2,"startToken":163,"endToken":454,"text":"2 \nNovember 16, 2026.1 As detailed below, this abeyance period will provide the \nCAISO sufficient time to work with stakeholders to develop all policies necessary \nto address the Commission’s preliminary findings in the Order to Show Cause on \nthe justness and reasonableness of the CAISO tariff concerning large loads, and \nto submit a filing to the Commission under Section 205 of the Federal Power Act \n(FPA).2 The abeyance period also will align with CAISO Participating \nTransmission Owners’ requests, such that the CAISO and its Participating \nTransmission Owners will be able to submit all relevant Section 205 filings to \naddress the findings of the Commission in the Order to Show Cause by \nNovember 16, 2026.  The CAISO appreciates the Commission’s recognition of \nthe unique regional differences present in California in the Order to Show Cause.  \nProviding time for the CAISO and its Participating Transmission Owners to \ndevelop these filings will allow for tailored solutions that reflect these regional \nnuances and will avoid disrupting existing commercial arrangements, as the \nOrder to Show Cause requires.3 The CAISO believes that granting this motion for \nabeyance will enable the CAISO and its Participating Transmission Owners to \nsatisfy the Order to Show Cause, remove the need for further action under FPA \nSection 206, and rather than causing any harm to interested parties, will expedite \nthe overall conclusion of the proceeding and the implementation of the reforms \nenvisioned by the Commission in the Order to Show Cause. \n \n1  \n18 C.F.R. § 385.212.  Capitalized terms not otherwise defined herein have the meanings \nset forth in Appendix A to the CAISO tariff. \n2  \nCalifornia Independent System Operator Corp., 195 FERC ¶ 61,214 at P 35 (2026) \n(Order to Show Cause). \n3  \nId. at P 34."},{"page":3,"startToken":454,"endToken":686,"text":"3 \n \nI. \nBackground \nIn the Order to Show Cause, the Commission identified a series of \ncomplex issues related to integrating large loads onto the transmission system. \nWhile the CAISO has prepared for and reliably served concentrated growth in \nlarge loads to date, it also understands the need to evolve policies and \nprocesses to enable the accelerated additions of large loads and the additional \ncomplexity that they may introduce. The CAISO has identified similar issues to \nthe Commission over the past few months regarding changing system needs \nrelated to new large loads. In response, the CAISO has convened several \nstakeholder processes to enhance large load processes, resource adequacy \nrules, demand-side market participation, and generator interconnection \nprocesses. As explained further below, the CAISO’s Large Load stakeholder \ninitiative will become the vehicle for CAISO reforms to address the Order to \nShow Cause, which the CAISO was planning to file pursuant to FPA Section 205 \nwhen the stakeholder processes concluded. \nThe Commission’s Order to Show Cause contemplated that the CAISO \nmight prefer to address the issues raised in the Order through a Section 205 \nfiling, and suggested that if the CAISO wished to have the Commission hold the \nSection 206 proceeding in abeyance, it should file an appropriate motion for \nabeyance in this docket. The Commission emphasized that it would not grant \nsuch abeyances reflexively, that any abeyance will be limited to 90 days, and that"},{"page":4,"startToken":686,"endToken":910,"text":"4 \nit would look with great disfavor toward requests to extend the abeyance period.4  \nThe Commission anticipated that successful abeyance requests will include both \n(1) a robust description of the content of a potential future filing under FPA \nSection 205, and (2) a reasoned and specific explanation of when such a filing is \nexpected to be made. \n \nII. \nRequest for Abeyance \nThe CAISO files this motion for abeyance in accordance with the \nCommission’s direction in the Order to Show Cause and in recognition of the \nprogress to date and planned future progress toward a Section 205 filing, \ntogether with the CAISO Participating Transmission Owners, that will address the \npreliminary findings in the Order to Show Cause. The CAISO respectfully \nrequests that the Commission hold the Section 206 proceeding initiated with the \nOrder to Show Cause in abeyance for 90 days while the CAISO and its \nParticipating Transmission Owners develop their respective Section 205 filings to \naddress Commission’s preliminary findings.  \nThe CAISO describes below the content of a potential future filing under \nFPA Section 205, with the level of detail currently available given the stage of the \nLarge Load stakeholder initiative, and the explanation of the timeline for an \nanticipated Section 205 filing. The CAISO also includes a description of \ncoordination with its Participating Transmission Owners, which, as the \n \n4  \nId. at P 35."},{"page":5,"startToken":910,"endToken":1177,"text":"5 \nCommission recognized in the Order to Show Cause, have a unique role in the \nlarge load interconnection process in California. \n \na. \nDescription of Content of Potential Future Filing Under FPA \nSection 205 \nBy the end of the abeyance period, the CAISO expects to submit an FPA \nSection 205 filing that, with simultaneous Section 205 filings from the \nParticipating Transmission Owners, will address all the preliminary findings and \nfive categories of reforms set forth in the Order to Show Cause, as appropriate \nfor the CAISO region. The CAISO expects that the vast majority of its tariff \nrevisions will be able to become effective as soon as approved by the \nCommission.5 Submitting such a Section 205 filing will require an expedited \nstakeholder process to develop, vet, and receive approval for the policy changes; \nhowever, a public stakeholder process will ensure policy changes are specifically \ntailored to the regional needs and State policies of California.  \nThe CAISO’s ongoing Large Load stakeholder initiative will become the \nvehicle for CAISO reforms to address the Order to Show Cause. The CAISO \nrecognizes the importance of clarity on roles in planning for large loads and \nlaunched the Large Loads stakeholder initiative last year. Within the initiative, the \nCAISO posted an issue paper in January 2026 outlining roles, responsibilities, \nand processes to effectively integrate large loads. In addition, the CAISO posted \n \n5  \nAlthough it is too early to know for sure, the only likely exceptions could be those \nchanges that require significant software enhancements, such as new settlement charges; \nhowever, the CAISO will expedite any software development to deploy as soon as possible."},{"page":6,"startToken":1177,"endToken":1430,"text":"6 \na straw proposal in June 2026 describing possible technical requirements \nassociated with large loads.  \nThese initial documents are well-aligned with the five categories FERC \nidentified. For example, the issue paper specifically discusses the current \ntreatment of large load interconnection within the CAISO, provisions for co-\nlocation of generation and large loads, transmission service offerings, cost \nallocation and responsibility, technical requirements and standards, and \noperational requirements. The straw proposal takes the next step with regard to \nmany of the technical requirements discussed in the Order to Show Cause, and \nthe CAISO is actively working on a straw proposal to address other issues \nidentified in the Large Loads stakeholder initiative and the Order to Show Cause.  \nIn addition, the CAISO has had numerous discussions with the State \nregulators that oversee retail rate design in California to ensure there is sufficient \ntransparency. The Commission highlights in the Order to Show Cause the need \nto allow state regulators to effectively perform their role in protecting consumers \nfrom cost shifts. As described in comments to the Commission’s Advanced Notice \nof Proposed Rulemaking, California policymakers and utilities already did \nconsiderable work to ensure long-term forecasting, procurement, and planning \naccounted for large load growth.6 The California Public Utilities Commission and \nPacific Gas and Electric Company have likewise been working to create a tariff \n \n6  \nSee, e.g., Interconnection of Large Loads to the Interstate Transmission System, \nComments of Pacific Gas and Electric Co. (Nov. 21, 2025), Comments of California Public \nUtilities Commission (Nov. 21, 2025), Docket No. RM26-4-000."},{"page":7,"startToken":1430,"endToken":1665,"text":"7 \nspecifically tailored to high-voltage interconnections of large loads that aligns \ncosts with benefits for all ratepayer classes.7 \nThe CAISO also is closely coordinating with its Participating Transmission \nOwners, to ensure the matters within their purview that the Commission raises in \nthe Order to Show Cause also will be part of the future Section 205 filings. To be \ncertain, this coordination began before the Order to Show Cause as the \nframework for integrating large loads in California includes significant tariff \nprovisions in the Participating Transmission Owners’ tariffs and the CAISO’s tariff. \n \nb. \nExplanation of When a Section 205 Filing is Expected \nThe CAISO will refocus the Large Loads initiative on the issues the \nCommission has identified in the Order to Show Cause. Given the timeline \ndescribed in the Order to Show Cause and the Commission’s clear prioritization \nof addressing issues around integrating large loads onto the transmission \nsystem, the CAISO expects to expedite the stakeholder initiative, with two \ndiscrete proposals: a straw proposal in August and draft final proposal in \nSeptember, before seeking Western Energy Market Governing Body and Board \nof Governors approval as necessary at the October 20 and October 28 meetings, \nrespectively.8 Although the stakeholder initiative will be expedited, the CAISO will \nhost workshops and solicit stakeholder feedback on the proposals to better \n \n7  \nId. \n8  \nDecisional classifications will become clearer as the proposals within the Large Loads \nstakeholder initiative develop."},{"page":8,"startToken":1665,"endToken":1929,"text":"8 \ninform the policy outcomes.9 The CAISO has already notified stakeholders of the \nexpedited Large Loads initiative schedule and included the schedule in its 30-day \nfiling regarding resource adequacy filed publicly in this docket on July 20, 2026: \n \nRather than causing any harm to interested parties, holding the Section 206 \nproceeding in abeyance will enable the CAISO to work with its stakeholders as \npart of the Large Loads stakeholder initiative that it has already begun—and \nwhich interested parties have already begun to participate—and will resolve the \nissues the Commission identifies in a more expeditious manner than proceeding \nwith a response to the Order to Show Cause and traditional processing of the \nSection 206 proceeding. \n \nc. \nCoordination with Participating Transmission Owners \nThe Order to Show Cause recognizes “the framework under which CAISO \nprovides transmission service is unique among the RTOs/ISOs and that certain \nresponsibilities fall to the Participating Transmission Owners.”10 The Order to \nShow Cause further states that the Commission appreciates that the CAISO and \n \n9  \nThis timeline assumes the Commission grants this motion for abeyance for 90 days, as \ncontemplated by the Order to Show Cause at P 25. \n10  \nOrder to Show Cause at P 37. \nAction \nDate  \nPost Straw Proposal \nAugust 12, 2026 \nStakeholder workshop \nAugust 19, 2026 \nComments due \nSeptember 2, 2026 \nPost Draft Final Proposal \nSeptember 21, 2026 \nStakeholder workshop \nSeptember 28, 2026 \nComments due \nOctober 12, 2026 \nWestern Energy Market Governing Body (if necessary) \nOctober 20, 2026 \nCAISO Board of Governors \nOctober 28, 2026 \nFERC Filing on Order to Show Cause \nNovember 16, 2026"},{"page":9,"startToken":1929,"endToken":2128,"text":"9 \nParticipating Transmission Owner responsibilities may stem from how the CAISO \nand the Participating Transmission Owners allocated rights and responsibilities in \nthe governing documents establishing the CAISO.11  While the Commission \n“do[es] not seek to alter that allocation of rights and responsibilities,”12 it \n“expect[s] that CAISO and the Participating Transmission Owners will coordinate \nwith each other, as appropriate, to develop responses.”13  \nThe CAISO values these directions from the Commission. The CAISO and \nits Participating Transmission Owners coordinated on large load interconnections \nbefore the Order to Show Cause, and have coordinated strongly since, including \nmultiple weekly meetings among various teams of subject-matter experts for the \ncategories of issues identified by the Commission. By being able to maintain the \ncurrent allocation of responsibilities between the CAISO and Participating \nTransmission Owners, Californian stakeholders will not have to start anew, \nenabling the CAISO and Participating Transmission Owners to coordinate on \naddressing all the issues identified in the Order to Show Cause by the end of the \nabeyance period. This coordination should enable rapid and smooth \nimplementation of the policies necessary to address the Order to Show Cause.   \n \n \n11  \nId. at P 51. \n12  \nId. \n13  \nId. at P 37."},{"page":10,"startToken":2128,"endToken":2196,"text":"10 \nIII. \nConclusion \nFor the foregoing reasons, the CAISO respectfully requests that the \nCommission grant the CAISO’s motion for abeyance in this proceeding. \n \nRespectfully submitted, \n \n/s/ William H. Weaver  \nRoger E. Collanton \n  General Counsel \nWilliam H. Weaver \n  Assistant General Counsel \nCalifornia Independent System \nOperator Corporation \n250 Outcropping Way \nFolsom, CA  95630 \n(916) 608-7135 \nbweaver@caiso.com  \n \nCounsel for the California Independent System Operator Corporation \n \nDated:  August 3, 2026"},{"page":11,"startToken":2196,"endToken":2264,"text":"CERTIFICATE OF SERVICE \n \n \nI certify that I have served the foregoing document upon the parties listed on the \nofficial service list in the captioned proceeding, in accordance with the requirements of \nRule 2010 of the Commission’s Rules of Practice and Procedure (18 C.F.R. § \n385.2010). \n \nDated at Folsom, CA this 3rd day of August, 2026. \n/s/ Jacqueline Meredith \nJacqueline Meredith \nAn employee of the California ISO"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":3,"endAt":5,"startToken":0,"endToken":455},{"p":3,"at":5,"title":"I. Background","method":"printed heading","endPage":3,"endAt":9,"startToken":455,"endToken":456},{"p":3,"at":9,"title":"Background","method":"printed heading","endPage":4,"endAt":354,"startToken":456,"endToken":744},{"p":4,"at":354,"title":"II. Request for Abeyance","method":"printed heading","endPage":10,"endAt":4,"startToken":744,"endToken":2129},{"p":10,"at":4,"title":"III. Conclusion","method":"printed heading","endPage":10,"endAt":10,"startToken":2129,"endToken":2130},{"p":10,"at":10,"title":"Conclusion","method":"printed heading","endPage":11,"endAt":0,"startToken":2130,"endToken":2196},{"p":11,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":11,"endAt":423,"startToken":2196,"endToken":2264}]}