6.9.2.1. Market Notice of Timeline , Submission of Affidavits and Commencement of Allocation Activities [1]
The CAISO will issue a Market Notice to inform interested parties as to the timeline for commencement of allocation activities. The market notice will specify the due date for Interconnection Customer submittal of affidavits attesting to each proposed Generating Facility’s eligibility status and retention information, the due date for the study deposit for Energy Only projects seeking TP Deliverability, and the anticipated release date of the allocation results to Interconnection Customers. There are two major components of the allocation process, which are described in detail in GIDAP BPM Sections 6.2.9.3 and 6.2.9.4, respectively.
The remainder of this GIDAP BPM Section 6.2.9.1 describes the affidavits that Interconnection Customers submit in support of the process for allocating TP Deliverability. The three different affidavits needed prior to the allocation process are listed below:
1. Affidavit for Queue Cluster 4 and earlier queued projects.
2. Affidavit to retain TP Deliverability allocations for Interconnection Customers that currently have a TP Deliverability allocation from a previous allocation cycle.
3. Affidavit for projects seeking allocation of TP Deliverability, including projects that have exercised the parking option, and eligible Energy Only projects.
All affidavits shall be notarized. All affidavits will be reviewed by the CAISO to ensure completeness and accuracy based on information available to the CAISO. If the CAISO determines that an affidavit is not acceptable it will be returned to the submitter for correction and resubmittal for further review. The CAISO and the Interconnection Customer shall work together to resolve any issue on a best efforts basis.
(i) Affidavit for Cluster 4 and Earlier Queued Projects
The first component of the GIDAP allocation procedures, as described in GIDAP BPM Section 6.2.9.3(a), requires that the CAISO identify MW quantities of TP Deliverability to be reserved for proposed Generating Facilities in Queue Cluster 4 and earlier that are expected to achieve Commercial Operation.
Specifically, GIDAP Section 8.9.1(a) requires the CAISO to identify commitments that will utilize MW quantities of TP Deliverability for proposed Generating Facilities in Queue Cluster 4 or earlier that have executed power purchase agreements (PPAs) with Load-Serving Entities and have GIAs that are in good standing.
For this purpose, each year following the completion of the current Queue Cluster’s Phase II Interconnection Study, the CAISO will require all Interconnection Customers that meet the criteria just stated to provide an affidavit that attests to information associated with their PPAs and GIAs, as well as other information to assist in the evaluation of these Generating Facilities’ progress toward Commercial Operation.
However, the content of these affidavits, if submitted, will not be used to determine the retention of TP Deliverability for any Cluster 4 and earlier-queued projects, i.e., they would receive the level of deliverability requested once they reach Commercial Operation and the required Network Upgrades are completed even if they do not meet the criteria of reserving TP Deliverability.
The affidavit must include:
· The name and queue number of the Generating Facility being attested to;
· An attestation to the existence of an executed and active PPA, and specify the MW of generating capacity covered under the PPA and the date the PPA was fully executed; and
· The name of the purchasing entity associated with the PPA.
(ii) Affidavit for Retaining TP Deliverability Allocation
a) Generating Facilities in Queue Cluster 5 through 9 that have been allocated TP Deliverability or that parked pursuant to GIDAP Section 8.9.4 or 8.9.4.1 must demonstrate, by the date set forth in the Market Notice each year, and according to the process described in this GIDAP BPM, that the Generating Facility meets the criteria to retain its TP Deliverability as described in GIDAP Section 8.9. 3.1.
For Generating Facilities in Queue Cluster 5 through 9 that claimed balance sheet financing when seeking a TP Deliverability allocation prior to November 27, 2018, those projects may cite those previous affidavit submittals when submitting retention affidavits in order to confirm their intention to continue their balance sheet financing choice.
b) Generating Facilities in Queue Cluster 10 or later, that have been allocated TP Deliverability under GIDAP Section 8.9.2, on the date set forth in the Market Notice each year and according to the process described in this GIDAP BPM, must demonstrate that the Generating Facility meets the criteria to retain its TP Deliverability as described in GIDAP Section 8.9.3.
(iii) Affidavit for projects seeking allocation of TP Deliverability, including projects that have exercised the ir parking option (s), eligible projects with Partial Capacity Deliverability Status, and eligible Energy Only projects
This affidavit is applicable to Generating Facilities that fall into one of three categories. The first category consists of Generating Facilities that have just completed the GIDAP Phase II Interconnection Study process and are seeking an allocation of TP Deliverability for the first time. The second category consists of Generating Facilities that have completed the GIDAP Phase II Interconnection Study process in a previous Interconnection Study Cycle that have exercised the parking option or extended parking option, pursuant to GIDAP Section 8.9.4 or 8.9.4.1 respectively, including Partial Capacity Deliverability Status projects that elected to park any non-allocated portion of their project, and are seeking an allocation of TP Deliverability in the current Queue Cluster’s allocation process. The third category includes Energy-Only Generating Facilities, including Partial Capacity Deliverability Status projects that elected to convert any non-allocated portion of their project to Energy Only, that are seeking TP Deliverability.
For Generating Facilities in Queue Cluster 5 through 9 that claimed balance sheet financing when seeking a TP Deliverability allocation and elected to park prior to November 27, 2018 and are seeking a TP Deliverability allocation after November 27, 2018, those projects may cite those previous affidavits when submitting retention affidavits in order to maintain the same treatment as the previous balance sheet financing claims.
Interconnection Customers may only attest that they are proceeding without a power purchase agreement (in allocation group 8.9.2(3), “group 3”) in the allocation cycle immediately following receipt of their Phase II Interconnection Study. Interconnection Customers that request TP Deliverability in group 3 and do not receive TP Deliverability, or only receive a partial allocation, may continue to attest to group 3 status in subsequent TP Deliverability cycles in which they are eligible to seek an allocation. Interconnection Customers in group 3 may elect to park only that portion of their Interconnection Request (up to 100%) that does not receive TP Deliverability. Such parked portions may receive TP Deliverability in subsequent allocation cycles from any group for which they qualify (including allocation group 3). If an Interconnection Customer elects a group other than group 3 in subsequent allocation cycles, it may not select group 3 in a future allocation cycle. Interconnection Customers that receive TP Deliverability allocations for less than requested may also elect to permanently reduce their requested Interconnection Service Capacity to the amount of TP Deliverability received following the allocation.
The CAISO shall allocate available TP Deliverability to all or a portion of the full MW Interconnection Service Capacity of the Generating Facility as specified in the Interconnection Request based on the criteria defined in GIDAP BPM Section 6.2.9.4. Where a criterion is met by a portion of the full MW Interconnection Service Capacity of the Generating Facility, the eligibility score associated with that criterion shall apply to the portion that meets the criterion. Therefore, the affidavit must relate to the same proposed Generating Facility as described in the Interconnection Request and, for each allocation group attested to, must specify the MW quantity of Interconnection Service Capacity that meets the criteria for inclusion in the allocation group. At a minimum, the Generating Facility must meet criteria established in one of the seven allocation groups defined in GIDAP Section 8.9.2.
Projects with Energy-Only Deliverability Status, including Partial Capacity Deliverability Status projects that elected to convert any non-allocated portion of their project to Energy Only, requesting Deliverability must submit to the CAISO a $60,000 study deposit for each Generating Facility seeking TP Deliverability. The $60,000 study deposit is due on the same due date of the Seeking TP Deliverability affidavit as established and provided in the annual Market Notice published in accordance with GIDAP BPM Section 6.2.9.1. A market notice is provided thirty (30) calendar days in advance of the TP Deliverability Affidavit due date. Refer to GIDAP Section 8.9.2 for further details.
The study deposit will be applied to pay for prudent costs incurred by the CAISO, the Participating TO(s), and/or third parties as applicable, to perform and administer the TP Deliverability studies for the Energy Only Interconnection Customers. Any and all costs of the Energy Only TP Deliverability study will be borne by the Energy Only Interconnection Customers seeking a TP Deliverability allocation. The CAISO will coordinate the study with the Participating TO(s). The Participating TO(s) will invoice the CAISO for any work within seventy-five (75) calendar days of completion of the study, and, within thirty (30) days thereafter, the CAISO will issue an invoice or refund to the Interconnection Customer, as applicable, based upon such submitted Participating TO invoices and the CAISO’s own costs for the study. If the actual cost of the study is greater than the deposit provided by the Interconnection Customer, the Interconnection Customer will pay the balance within thirty (30) days of being invoiced.
Any refunds will be processed in accordance with the CAISO’s established business practice whereby interconnection deposit refunds are processed in batches and payments are disbursed monthly. If the Interconnection Customer has not provided the CAISO with the appropriate documents to facilitate a refund or if the Interconnection Customer has any outstanding invoice balance due to the CAISO on another project owned by the same Interconnection Customer, the thirty (30) calendar day period for the refund will be suspended until such issue(s) are cured.
The affidavit must include the following current information:
(1) The TP Deliverability allocation group as identified above
(2) PPA status (applicable to allocation Groups 1 and 4 only)
(3) Shortlist status (applicable to allocation Groups 2 and 5 only)
(4) Permitting status (applicable to allocation Groups 1 through 7)
(5) Land acquisition status (applicable to allocation Groups 1 through 7)