Stakeholder Comments Template

Transcription

1 Stakeholder Comments Template Submitted by Company Date Submitted Margaret E. McNaul Bonnie S. Blair Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California ( Six Cities ) Sept. 15, 2015 Please use this template to provide your comments on the presentation and discussion from the stakeholder web conference held on September 8, Submit comments to InitiativeComments@caiso.com Comments are due September 15, 2015 by 5:00pm The revised straw proposal and also the associated presentation may be found at: nhancements.aspx Please provide your comments on the ISO s straw proposal for each of the nine issues identified by stakeholders through this initiative. For your convenience, the nine issues are listed below along with the ISO s proposed action to its straw proposal. The Six Cities note that they raised, in their Supplemental Comments in this stakeholder initiative submitted on July 8 th, an additional issue to which the ISO has not responded. This additional issue is described below on page 4. M&ID 1

2 Independent evaluator The ISO believes that the current process provides for thorough, independent and expert input into the selection of project sponsors and does not propose to use an independent evaluator. Six of the eight comments received on this topic support the ISO s straw proposal. One comment was neutral, and only one stakeholder continued to support the use of an independent evaluator. The ISO agrees with the majority of stakeholders and will not make any changes to the straw proposal. Refer to section 5.1 in the straw proposal. Financial comparison process All but one commenter is supportive of the straw proposal s position on the financial comparison process. The ISO s straw proposal is as follows the ISO believes that the current financial comparison process is aligned with the ISO s commitment to run a fair and nondiscriminatory competitive solicitation process and does not propose further enhancements. The ISO agrees with the majority of stakeholders, and no changes are being proposed to the financial comparison process at this time. The ISO will amend the application in the future to eliminate any perceived disadvantage of a project financed proposal by clarifying that questions F-11 through F-16 apply to all applicants. Refer to section 5.2 of the straw proposal. Collaboration period It is clear from the received comments that widespread consensus does not presently exist for collaboration as it is currently defined in the tariff and that further discussion is needed to determine if collaboration should be modified or retained. Based on this feedback, the ISO now proposes three possible alternatives for collaboration. The ISO notes that this may take additional time and therefore may choose to continue this discussion in a separate stakeholder process. Refer to section 5.3 of the straw proposal. Collaboration Alternative (1): Require collaboration to be completed prior to submitting an application by the close of the bid window. Comments: The Six Cities have no comments on Alternative (1) at this time. Collaboration Alternative (2): Retain the existing collaboration process, but modify it by allowing non collaborating parties to refresh their application (in certain areas) if there is successful collaboration among applicant project sponsors. Comments: The Six Cities have no comments on Alternative (2) at this time. M&ID 2

3 Collaboration Alternative (3): If there are only two qualified project sponsors and they choose to collaborate, the ISO will require that the subsequent joint application result in equal or lower cost (including cost containment) for ISO ratepayers. Comments: The Six Cities support Alternative (3) of the Revised Straw Proposal. The Six Cities note that the application of Alternative (3) would not appear to be needed if Alternative (1) were adopted, but the Cities question whether Alternative (3) could be applied alongside Alternative (2) in addition to serving as a stand-alone proposal. Further, Alternative (3) should not be limited to solicitations where there are only two project sponsor applicants; rather, the ISO should adopt a general rule prohibiting any subsequent joint application from increasing ratepayer costs, irrespective of the number of original bidders. Collateral/credit requirements for approved project sponsors The ISO does not agree that posting of financial security should be a requirement placed on project sponsor applicants. The ISO notes that those stakeholders providing an opinion on this matter are split evenly. The ISO believes it is important to continue to encourage the development of robust cost containment measures by project sponsors and has made the determination not to change the straw proposal and not require posting of financial security at this time. In addition, the ISO will not prevent project sponsors to voluntarily post financial security to strengthen its application in the event that the applicant is identified as the approved project sponsor. Refer to section 5.4 of the straw proposal. Evaluation of selection criteria All but one of the stakeholder comments were in support of the ISO s straw proposal or offered suggestions for clarification and/or transparency. The ISO is committed to being as transparent as possible in its analysis and in a way that will assist project sponsors in developing future proposal while protecting commercially sensitive information. To this end, the ISO encourages parties to participate in post-selection process de-briefings should there be any questions. The ISO will not pursue any tariff changes in this area. Refer to section 5.5 of the straw proposal. Project-specific weighting and scoring methodology As the ISO explained in the October 7, 2014 issue paper, this initiative does not consider issues such as weighting, scoring, and mathematical formulas for selecting project sponsors. The ISO s M&ID 3

4 position remains that this issue is beyond the scope of this initiative. Refer to section 5.6 of the straw proposal. Obligation regarding the transfer of assets There was only one stakeholder that opposed the ISO s position in the straw proposal. The ISO sees merit in further defining the fair compensation standard and agrees that the cost to acquire abandoned facilities should not be greater than the FERC approved cost for the facilities. Refer to section 5.7 of the straw proposal. Comments: The Six Cities generally support the ISO s proposal with one additional change specifically, to provide that the cost of the abandoned facilities should not include amounts associated with incentive adders to a developer s return on equity ( ROE ), which, in the event the project is abandoned, should be refunded to ratepayers by the abandoning developer. Cost estimate standard The ISO s straw proposal is as follows: the ISO agrees that a minimum level of detail is required when a project sponsor submits cost estimates, and proposes to update the project sponsor application to clarify the amount of cost estimate detail a project sponsor is required to provide. All of the stakeholder comments received were either in agreement with the straw proposal, or had no position. The ISO will not make any changes to the straw proposal. Refer to section 5.8 of the straw proposal. Pre-qualification outside of bidding scheme Four of the six stakeholders submitting comments on this topic were in agreement with the straw proposal. The ISO will not make any changes to its straw proposal, which is as follows: the ISO believes that this issue was addressed during the FERC Order No stakeholder process and continues to favor an approach that allows for flexibility. Refer to section 5.9 of the straw proposal. Additional Issue: Comments: The Six Cities reiterate their request that the ISO consider a limited expansion of this stakeholder proceeding to include the additional issue raised in the Six Cities July 8th M&ID 4

5 Supplemental Comments in this stakeholder proceeding. Specifically, the Six Cities request a modification to the ISO tariff to require participants (or prospective participants) in the competitive solicitation process to provide to the ISO and to Participating TOs copies of all FERC filings submitted by the applicant that pertain to ISO participation, ISO projects, or ISO rates. As has been discussed in this stakeholder proceeding, special purpose entities have been formed for the purpose of participation in the ISO s competitive solicitation process. The identities of such special purpose entities are not always known to ISO stakeholders. Thus, when FERC filings are submitted by these entities that may relate to an ISO transmission project (or future projects), the ISO and Participating TOs should be informed and provided with a copy of the filing(s), which the ISO should post on its recent documents page. The ISO should also issue a market notice upon receipt of the filing. This procedural update to the competitive solicitation process should not prejudice participants in the competitive solicitation process and will allow Participating TOs and other market participants to be fully informed when FERC filings are made that are relevant to the Transmission Planning Process and ISO transmission projects generally. Appendix F to the Transmission Control Agreement could be used as the contact list for providing the service copies to the ISO and Participating TOs. This would be in addition to any requirement that filings be served on the California Public Utilities Commission, which the Cities assume is governed by CPUC rules. M&ID 5