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Proposed Revision Request Detail Help
PRR Life Cycle*******Final Decision**
PRR Details
PRR #
1647
Title Clarification of project financial-security posting requirements
Date Submitted 9/29/2025 11:43 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
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Existing Language
​Attached​
Proposed Language
Attached​​
Reason For Revision
​Submitted by Susan R. Schneider​, Phoenix Consulting​

Clarify that Interconnection Customer financial-security posting requirements should exclude coverage for the cost of Network Upgrades approved in the Transmission Planning Process.
 
Effective date: Effective at end of PRR process.
Projects are not responsible for paying for Assigned Network Upgrades that are later approved in the annual Transmission Planning Process.  Generator Interconnection Agreements are usually amended to remove payment and security requirement for such upgrades, and it is understandable that those amendments can require a reasonable timeframe.  This PRR is needed to ensure that any increased financial-security requirements (e.g., for a new second or third posting) occurring between TPP approval of the upgrade and the subsequent GIA amendments should not include the cost of the TPP-approved Network Upgrade
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, Six cities
Action

Approve the BPM PRR 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
The CAISO updated its proposal. See the most current attachment for the updated language.
Posted On - 2/19/2026 9:25 AM
The CAISO updated its proposal. See most current attachment for the added language.
Posted On - 2/10/2026 5:40 PM
This PRR will go through an additional review cycle as the recommendation was not posted prior to the January comment deadline.
Posted On - 1/26/2026 1:31 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
The document attached to this PRR is inconsistent with the topic for 1647. The stated goal of the PRR is to clarify that financial-security posting requirements should exclude coverage for the cost of Network Upgrades approved in the Transmission Planning Process. EDF Power Solutions agrees that such costs should be excluded even in the scenario that the CAISO the study report amendment is not yet published. Which upgrades need to be excluded in this scenario is logically clear. Excluding them from project study costs in the GIA reduces administrative burden for all parties (avoiding a later amendment to reconcile information) and improves developer ability to seek, execute, and manage power purchase agreements and arrangements for financial security.

Submitted by: Raeann Quadro, Gridwell Consulting
10/17/2025 12:41 PM
Logged By - Williamson-Duffney, Joseph (CAISO)
The attachment is not consistent with the PRR description but appears to relate to PRR 1650.
10/13/2025 3:10 PM
Logged By - Bonnie Blair (Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, CA)
Recommendation Comments
LSA - PRR 1647 - comms on CAISO Recommendation 020126.docx    
LSA's intent in submitting this PRR was to relieve ICs from any further security postings based on Network Upgrades for which they are no longer responsible.  The Recommendation relieves ICs from having to make the third posting for such upgrades, but not the second posting.  LSA's suggested edits to Section 8.4.1 here are intended to provide that relief for the second posting as well, as soon as possible after the Transmission Plan is approved.
2/9/2026 10:46 AM
Logged By - Susan R. Schneider (Phoenix Consulting)
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 12:43 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