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Proposed Revision Request Detail Help
PRR Life Cycle*******Final Decision**
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 Final Decision
Status End Date 3/17/2026 11:59 PM
Related BPM Generator Interconnection and Deliverability Allocation Procedures
BPM Section Section 8.4.6
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Existing Language

​Attache​​d

 

Proposed Language
Attached
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.
Click here to view the Recommendation Details for this PRR
BPM PRR Submitter

Wilson, Daune (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

​Approve as modified. 

Identification of the authorship of comments

Gridwell Consulting
Action

Approve the BPM PRR as modified.

Approve as modified.
Statement of apparent requirements of the BPM PRR

Priority and rank for any BPM PRR requiring a CAISO system change

Proposed effective date(s) of the BPM PRR

Other recommended actions

Click here to view the Final Decision for this PRR
Final Decision

Change management process completed. The latest redline version of the BPM will be published to the document library.
Stakeholder Comment

consensus achieved

Effective Date

2/27/2026
Action

Adopt the recommendation as modified

Announcements
This PRR will go through an additional review cycle as the recommendation was not posted prior to the January comment deadline.
Posted On - 1/22/2026 5:19 PM
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
The Recommendation Details suggest approving the PRR "as modified," but as of the comment date, the attachment to the PRR appears to include only the language originally proposed by the PRR sponsor.  The Six Cities request that the CAISO clarify whether the attachment currently reflects the language the CAISO proposes to adopt.  If it does not, the Six Cities further request that the CAISO provide the modified language it proposes to adopt and extend the Recommendation Comment period for potential comments on the modified language.
1/8/2026 12:30 PM
Logged By - Bonnie Blair (Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, CA)
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# of Appeals Closed - 0
# of Appeals Abandoned - 0
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Attachments