PRR - 1450

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Initial Comment for PRR - 1450

Description: LSA comments on PRR 1450 - please see attachment.
-By Susan R. Schneider (Phoenix Consulting) on Tuesday, August 16, 2022 4:57:42 PM

Initial Comment for PRR - 1450

Description: CAISO received written comments from Raeann Quadro at Gridwell Consulting. EDF-R consulting appreciates CAISO’s timely action in submitting PRRs to incorporate elements of policy created in the Interconnection Process Enhancements (IPE) Phase 1 effort. EDF-R supports the CAISO’s edits to remove the referenced to the Bureau of Land Management references in the BPM for GIDAP. Publish permitting can take place at a number of different agency levels and this change is prudent. EDF-R wishes to make the point in this venue that getting a final, non-revocable, exclusive permit on public land is already a high bar for site exclusivity. As we consider CAISO’s IPE Phase 2 proposal to require site exclusivity earlier in the study process (before a project can enter Phase II of the cluster study), it has become clear that the CAISO’s definition of site exclusivity on public land is overly onerous and not in keeping with increased federal support for construction on public land. As an example of the permitting and GIDAP incompatibility. Before issuing a final, irrevocable, exclusive permit the BLM needs to complete a full right-of-way issuance process, including compliance with the National Environmental Policy Act, which commonly takes 3-5+ years and involves significant field surveys and analysis. Developers often only consider initiating this substantial undertaking once the Phase 1 interconnection study is complete and they have more information about the feasibility of interconnection. EDF-R asks CAISO to consider changing the definition of site exclusivity on public land to ”the lead public agency has deemed an application for the project as complete” or language with comparable intent. For example, when the BLM serializes as application it is a signal of this determination of completeness and then they initiate exclusive processing of that application. State and federal agencies all have different process but for the most part; once they deem an application complete, it starts the internal process for exclusive consideration on that site. In contrast, private land in California must also be permitted and satisfy the California Environmental Quality Act but CAISO’s proposal does not require that this process be completed for private land prior to Phase 2 like it does for public land. This puts public land at a significant disadvantage for supporting renewables which runs counter to efforts that the State has previously made to support them (such as with the CA Desert Renewable Energy Conservation Plan) or more recently with the Federal Inflation Reduction Act which is aimed at spurring renewable energy development on federal lands. In many areas, public lands are the only lands remaining where utility scale development can still be accomplished do to the urbanization and numerous other constraints that are encountered throughout the state. Therefore, it is imperative that development of these lands is facilitated and not discouraged or delayed which is what the current proposal will do.
-By Hines, Nicole on Wednesday, August 17, 2022 7:58:51 AM

Recommendation for PRR - 1450

Proposed Language:

Modifications were influenced by the comments received. Where tariff language was used in the BPM; no modifications were made. Not all style suggestions were incorporated. See attached Rdline

Action: Approve the BPM PRR as modified.
Effective Date: 01/01/0001

Final Decision for PRR - 1450

Final Decision: Same as recommendation
Stakeholder Comment: No comments on recommendation
Action: Adopt the recommendation as modified
Effective Date: 10/26/2022

RSS Feed for Proposed Revision Request - 1450

PRR - 1450

Initial Comment for PRR - 1450

Initial Comment for PRR - 1450

Recommendation for PRR - 1450

Final Decision for PRR - 1450