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Proposed Revision Request Detail Help
PRR Life Cycle*********On Hold
PRR Details
PRR #
1644
Title Stand-Alone Network Upgrade Clarification
Date Submitted 9/29/2025 11:21 AM
PRR Category A
Priority Normal
Owner Wilson, Daune (CAISO)
Status On Hold
Status End Date 10/15/2025 11:59 PM
Related BPM Generator Interconnection and Deliverability Allocation Procedures
BPM Section Section 8.4.6
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Existing Language
 

​Attached

 

Proposed Language
Atrtached
Reason For Revision
​Submitted by Susan R. Schneider​, Phoenix Consulting​

Clarify the risks that Interconnection Customers assume if they elect to self-build Stand-Alone Network Upgrades
Effective date: Effective at end of PRR process.
The cost and timing risks assumed by an Interconnection Customer electing to self-build a Stand Alone Network Upgrade – e.g., non-recovery of cost overruns and/or COD extension risks for timing delays – are not clear in the existing language.  This PRR would help ensure that Interconnection Customers are fully aware of these risks and can consider them in making the self-build election.
Announcements
This PRR is on hold to give the CAISO an opportunity to develop language that better accomplishes LSA’s purpose.
Posted On - 10/16/2025 12:35 PM
Impact Analysis
Impact Analysis not available.
Initial Comments
This PRR clarifies the risks that Interconnection Customers assume if they elect to self-build Stand-Alone Network Upgrades. It is a matter of fact that no maximum cost responsibility protection for self-build upgrades.
EDF Power Solutions also understands that the CAISO’s position on COD delays due to SANU delays is that they should not be considered “PTO delays.” The nomenclature of “PTO delay” is not appropriate for such delays. However, delays to SANU building not caused by the developer should be executed based on the same logic. Interconnection customers are not immune to the various delays that PTOs experience. CAISO should have a provision to allow for COD extensions based on unavoidable SANU delays. This delay type can be categorized under its own category, “SANU COD delays” or something similar.
Adopting a policy for SANU COD delays is also very forward looking for the CAISO. Emerging federal policies, government shut down, permitting agency staffing, and international politics straining supply chains for large transformers, control equipment, steel structures, and certified high-voltage labor are likely to cause COD delay no matter which party is building an upgrade – PTO or interconnection customer. Interconnection customers should be allowed to extend CODs under provisions PTO has access to when the interconnection customer has the same responsibilities and development environment.

Submitted by: Raeann Quadro, Gridwell Consulting
10/17/2025 11:59 AM
Logged By - Williamson-Duffney, Joseph (CAISO)
Recommendation Comments
No Recommendation Comments available for this PRR.
Attachments