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1 April 10, 2013 California Independent System Operator 250 Outcropping Way Folsom, CA Southern California Edison ( SCE ) respectfully offers these written comments on the California Independent System Operator s ( CAISO ) Resource Adequacy ( RA ) Deliverability for Distributed Generation ( DG ) Compliance Paper, posted March 25, 2013 and tariff language posted April 2, On November 16, 2012, the Federal Energy Regulatory Commission ( FERC or Commission ) issued an order 1 in regards to the CAISO s proposed tariff amendment to implement a streamlined process for providing RA deliverability to DG resources, filed September 18, The Commission s order directs thatt CAISO s compliance filing reflect that FERC jurisdictional load serving entities ( LSE ) must assign DG deliverability among projects based on a first come, first served process, subject only to interconnection clustering and operational considerati ions 3. CAISO s compliance proposal and tariff language implement the Commission s order. SCE would like to thank CAISO for the opportunity to submit comments on the compliance proposal and the tariff language. We appreciate all the careful thought that the CAISO has put into addressing the FERC order while developing a workable process that meets the needs of stakeholders. Included in Attachment A are SCE s amendments in redline form to the CAISO s proposed tariff. Attachmen nt A was created by accepting the changes in the CAISO s proposed tariff and showing redlines against a clean version. The significant changes to the tariff as well as other recommendations for the process are discussed below. 1 / com/documents/nov OrderConditionallyAcceptingTariffRevisions DocketNoER pdf 3 At page 13 DistributedGeneration DocketNoER pdf 2 / com/documents/september182012tariffamendmentdistributedgenerationdeliverability 1

2 SCE Supports the CAISO s Framework Particularly the Inclusion of Existing Generators SCE supports the CAISO s framework for studying and assigning deliverability to DG facilities. CAISO s compliance approach is fair and balanced and should yield positive benefits for the California market place. In particular, SCE supports the inclusion of existing generators in the DG deliverability proposal. The process the CAISO has laid out whereby existing generators will be eligible for DG deliverability is reasonable and will maximize the use of the existing grid capacity be allowing generators that are currently operating to provide RA to the system. Failure to Meet Commercial Operation Date ( COD ) due to a Utility Distribution Company ( UDC ) Delay The CAISO has set forth retention criteria that requires the project to come on line within 6 months of its expected COD in order to retain its Deliverability assignment. The CAISO has proposed an exception if the delay is due to the UDC. The CAISO s exception would apply if the UDC is unable to build the required upgrades to meet the COD in the interconnection agreement plus 6 months, or if no interconnection agreement has been executed, the COD in the interconnection request plus 6 months. This exception is overly broad and may lead to disputes during implementation. SCE believes customers should not lose their assignment of deliverability if the UDC is not able to meet the milestones agreed to in an interconnection agreement plus 6 months. SCE has added the word solely in the tariff because there may be instances where the customer has caused delays that would prevent it from meeting the retention criteria. In that situation, even if the UDC has also experienced a delay, the deliverability should be revoked. However, the issue becomes more complicated for customers who do not yet have an interconnection agreement. The COD requested by the customer in the interconnection request may not be realistic or feasible. In that case, it would be unwise to provide an exception because customers will choose artificial CODs, claim the failure to meet the COD is due to the UDC and render the retention criteria meaningless. As SCE pointed out on the April 3, 2013 Deliverability for Distributed Generation stakeholder conference call, it is critical that this section of the tariff is carefully drafted to avoid disputes. Specifically, SCE s proposed language ensures that this exception be applied only to generators with realistic CODs, who built their generating facilities, and but for the UDC would have met the COD plus 6 months. SCE has 2

3 proposed a process where the customer that does not meet the retention criteria and believes it is solely due to the UDC, must submit an affidavit to the UDC indicating the plant was constructed in time but was not able to be interconnected due to a delay in building the upgrades necessary for interconnection. The exact form of this affidavit will be described in the business practices manual. SCE believes that such a criteria will avoid protracted disputes regarding why the retention criteria was not met. To further ensure that the most accurate CODs are used (for projects that have not executed an interconnection agreement at the time they submit an application for DG Deliverability), SCE recommends that instead of using the COD in the Interconnection Request, as part of the DG Deliverability application process, the generator provides the most current COD. When a developer submits an Interconnection Request, they have not had the benefit of a scoping meeting or study results. Therefore, the COD requested in an Interconnection Request may not be realistic or feasible. After receiving more information, the generator will have a more accurate COD. A COD provided in the DG Deliverability application should be the basis of retention because it incorporates the most current information and will be documented as part of this process. Lastly, SCE has added an additional requirement. The tariff, as currently drafted, does not include any retention criteria once the exception for UDC delay has been triggered. If there is a delay by a UDC, once the upgrades necessary for interconnection have been built, there needs to be a deadline for the project to reach COD. SCE has included tariff language to this affect. Full Capacity Deliverability Status ( FCDS ) SCE recommends that the CAISO give careful consideration to whether or not this program should be open to generators that apply under for FCDS in their Interconnection Request. It appears that there is no benefit to generators. If this is, in fact, the case, allowing generators to be in two processes to achieve deliverability may ultimately cause confusion or double counting. If the CAISO determines that generators who have requested FCDS are eligible for the DG Deliverability program, the tariff should contain clear rules regarding which program the developer is subject to at any given time. For example, a developer who requested FCDS but is subsequently assigned DG through this process will be subject to the retention criteria which would not be the case if the developer pursued FCDS through the interconnection process. If a developer s Deliverability is revoked pursuant to the retention criteria, it should not be allowed to continue to receive deliverability through the interconnection process. This is just 3

4 one example of why it is important for the tariff to clearly spell out that if an FCDS customer is assigned DG Deliverability, its interconnection request will automatically be changed to and processed as if it were an Energy Only request and the developer will be subject to the tariff rules of this program. Applications SCE believes it is appropriate for all projects that want to be assigned Deliverability, including those that have applied for FCDS, to apply under this process to the CAISO. CAISO should not presume that a generator wants Deliverability absent an application. Furthermore, as explained above, the application will be an opportunity to collect the latest information from the Interconnection Customer. SCE requests that the Participating Transmission Owners ( PTO ) be included in the development of the application form to ensure that all the necessary information is captured. Application Fee SCE recommends that the tariff include an application fee to cover the annual administrative costs of the PTOs (and CAISO, if applicable). The PTOs will expend considerable resources to implement their new responsibilities under this program pursuant to the CAISO tariff. Therefore, it is reasonable for the PTOs to be compensated by generators for the time spent administering this program. Because this Deliverability is an attribute of the CAISO transmission system and DG Deliverability is granted pursuant to the CAISO tariff, the fee should be included in the tariff language and paid to the CAISO when DG Deliverability applications are submitted. Furthermore, including all requirements in the CAISO tariff ensures the all generators seeking DG Deliverability are treated equally regardless of whether they applied under Rule 21 or WDAT and regardless of which FERC-jurisdictional LSE they applied to for interconnection. Presentation of Study Results at Shared Nodes SCE recommends that the study results show the availability at each node by UDC, including muni UDCs as a separate spreadsheet. This will enhance the effectiveness and ease of use of this program by making it more straightforward for developers to know what deliverability is available for their projects. For example, in the recent study report, the CAISO showed the Lewis substation in the SCE service territory. The Lewis substation is an Anaheim substation and any generator that wants to receive the available Deliverability would be required 4

5 to apply for interconnection through Anaheim. Additionally, the CAISO has stated that for shared nodes the available Deliverability would be split based on the load ratio share. SCE recommends that this split should be reflected in the study results table that the CAISO publishes for each UDC so it is clear how much Deliverability will be available to each PTO s queue at each node. For the reasons discussed above, SCE recommends the CAISO make the changes requested. SCE looks forward to working with the CAISO to begin the process of assigning Deliverability Status to Distributed Generation Projects. 5

6 Attachment A SCE s Tariff Revisions Draft Tariff Language Resource Adequacy Deliverability for Distributed Generation Compliance with November 16, 2012 FERC Order California Independent System Operator Fifth Replacement FERC Electric Tariff Posted April 2,

7 Deliverability of Distributed Generation The CAISO will perform an annual Deliverability Assessment, as described in Section , to determine MW quantities of Potential DGD at specific Nodes of the CAISO Controlled Grid for assigning Deliverability Status to Distributed Generation Facilities interconnected or seeking interconnection to the Distribution System of a Utility Distribution Company pursuant to the interconnection procedures of the Utility Distribution Company, where such interconnection and Deliverability Status can be provided: (i) without any additional Delivery Network Upgrades (although Reliability Network Upgrades, Distribution Upgrades or other mitigation may be needed); (ii) without the need for the CAISO to conduct any further Deliverability Assessment; and (iii) without degrading the Deliverability Status of Generation in Commercial Operation, proposed Generating Facilities in the CAISO Interconnection queue, or the Distributed Generation Facilities of interconnection customers who have previously requested Full Capacity or Partial Capacity Deliverability Status. Following the CAISO s publication of the nodal Potential DGD quantities resulting from the Deliverability Assessment, applicable Utility Distribution Companies will assign Full Capacity Deliverability Status or Partial Capacity Deliverability Status to specific Distributed Generation Facilities pursuant to the rules set forth in Section below. This Section is intended to supplement, and not to preclude or limit, the ability of an interconnection customer for a Distributed Generation Facility to seek and receive Full Capacity Deliverability Status or Partial Capacity Deliverability Status through applicable interconnection procedures. Nothing in this Section is intended to relieve the interconnection customer for a Distributed Generation Facility from the requirements to request and achieve interconnection to the Distribution System through the applicable interconnection procedures. In addition, the amount of Resource Adequacy Capacity a Distributed Generation Facility may provide in any given Resource Adequacy Compliance Year is subject to annual Net Qualifying Capacity determination, as specified in Section

8 Deliverability Assessment to Determine Potential DGD This Section describes the annual Potential DGD Deliverability Assessment the CAISO will perform to determine nodal MW amounts of Potential DGD available to Utility Distribution Companies for assigning Deliverability Status to Distributed Generation Facilities in accordance with Section The Potential DGD Deliverability Assessment and its results will be based on the assumption that the Distributed Generation Facilities that are eventually assigned Deliverability Status under this Section complete all requirements for interconnection to the Distribution System under the applicable interconnection process and that these Distributed Generation Facilities will be supported by needed Reliability Network Upgrades, Distribution Upgrades or other mitigation that would be needed to safely and reliably interconnect to the Distribution System and deliver Energy from the Distribution System to the appropriate CAISO Controlled Grid Node Developing the Assessment Model To develop the base case model for the Potential DGD Deliverability Assessment, the CAISO will include: (i) The most recent GIP or GIDAP Queue Cluster Phase II Interconnection Study deliverability power flow base case; (ii) Those Generating Facilities that have obtained Deliverability using the annual full capacity deliverability option under either Section 8.2 of the GIP or Section 9.2 of the GIDAP; (iii) Transmission additions and upgrades approved in the final comprehensive Transmission Plan for the most recent Transmission Planning Process cycle; (iv) Any Generating Facilities in the most recent GIDAP Phase I Interconnection Study that have been determined to be deliverable in accordance with their requested Deliverability 8

9 Status and were not assigned any Delivery Network Upgrade costs in the Phase I Interconnection Study; (v) Delivery Network Upgrades that have received governmental approvals or for which Construction Activities have commenced; (vi) The MW amounts of resources interconnected to the distribution system below at specific Nodes of the CAISO Controlled Grid contained in the most recent Transmission Planning Process base portfolio, except that the CAISO will remove each Node (by using a zero MW value) located within electrical areas for which the most recently completed GIP or GIDAP Phase I or Phase II Interconnection Study has identified a need for a Delivery Network Upgrade or for which the most recent Phase II Interconnection Study identified and then removed a Delivery Network Upgrade to support Deliverability for MW amounts in the Interconnection queue; Comment [A1]: Please clarify. Are these the QC1 QC4 removed facilities or are these policydriven DNU under GIDAP or both? (vii) Actual distributed generation development based on the MW amount of distributed generation in applicable Utility Distribution Company wholesale distribution access tariff interconnection queues and non-net-energy-metering resources in any Utility Distribution Company CPUC Rule 21 interconnection queue; (viii) Any additional information provided by each Utility Distribution Company regarding anticipated distributed generation development on its Distribution System. (ix) Other information that the CAISO, in its reasonable discretion, determines is necessary Performing the Potential DGD Deliverability Assessment The CAISO will perform the Potential DGD Deliverability Assessment using the Deliverability Assessment procedures described in GIDAP Section to determine the availability of transmission system capability, as reflected in the study model described above, to provide Deliverability Status for targeted amounts of additional distributed generation at given Nodes of the CAISO Controlled Grid. 9

10 Except for Nodes that the CAISO removes by assigning a zero MW value pursuant to Section (vi), the targeted amounts of additional distributed generation at each Node shall be at least as large as the maximum of the corresponding nodal MW amounts determined in accordance with Sections (vi), (vii) or (viii). The CAISO may use larger targeted amounts as it deems appropriate to enhance the information provided by the Potential DGD Deliverability Assessment. The Potential DGD Deliverability Assessment will preserve modeled transmission system capability to provide requested levels of deliverability for the Generating Facilities of Interconnection Customers or the Distributed Generation Facilities of interconnection customers under a wholesale distribution access tariff who have previously requested Full Capacity or Partial Capacity Deliverability Status. Therefore, at each Node where all modeled Generating Facilities, including the distributed generation target amounts, cannot be simultaneously Dispatched to the modeled output levels corresponding to their Full Capacity or Partial Capacity Deliverability Status without violating operating limits of the CAISO Controlled Grid, the CAISO will reduce the modeled distributed generation target amounts as needed to achieve a feasible Dispatch Publishing Results of the Potential DGD Deliverability Assessment The CAISO will publish the results of the Potential DGD Deliverability Assessment by posting on the CAISO Website. The results will identify all Nodes modeled in the assessment with the corresponding nodal MW amounts of Potential DGD that (a) were studied as targeted amounts in the Potential DGD Deliverability Assessment; (b) were found to be deliverable in the Potential DGD Deliverability Assessment; and (c) are available for use by Utility Distribution Companies to assign Deliverability Status to Distributed Generation Facilities in accordance with Section The nodal MW amounts of Potential DGD available for assignment of Deliverability Status by Utility Distribution Companies to individual Distributed Generation Facilities will be denominated in 0.01 MW increments and will not exceed the maximum of the corresponding nodal MW amounts determined in accordance with Sections (vi), (vii) or (viii), even though the amounts that were studied and found to be deliverable may be larger. 10

11 With respect to those Nodes at which more than one Utility Distribution Company s Distribution System is connected, the CAISO will inform publisheach Utility Distribution Company, at the same time it publishes the results of the Potential DGD Deliverability Assessment, of its each Utility Distribution Company s respective share of the Potential DGD available to provide Deliverability Status to Distributed Generation Facilities at these Nodes based on the ratio of Load served via the facilities of each affected Utility Distribution Company at such Nodes Bilateral Transfers of Potential DGD at Shared Nodes A Utility Distribution Company shall be entitled to transfer all or a portion of its MW share of Potential DGD at a Node that is shared with the Distribution System of another Utility Distribution Company, in quantities no smaller than 0.01 MW. Both Utility Distribution Companies participating in such a transfer shall notify the CAISO of the transfer. Utility Distribution Companies may engage in such transfers during the period from the date they received notification of their shares of Potential DGD at shared Nodes under Section through the date on which Deliverability Status assignments must be provided to the CAISO, pursuant to Section Assignment of Deliverability Status to Distributed Generation Facilities After completion of the Potential DGD Deliverability Assessment associated with the current cycle of the process described in this Section , and in accordance with a CAISO market notice setting out the schedule for the cycle, each Utility Distribution Company will assign Deliverability Status to individual Distributed Generation Facilities interconnected, or seeking interconnection, to the Distribution System of the Utility Distribution Company below at each Node where the ISO s Potential DGD Deliverability Assessment for the current cycle has indicated the availability of Potential DGD, consistent with the rules 11

12 set forth in this Section , and will report all such assignments to the CAISO. Upon receipt of this information the CAISO will validate that the Utility Distribution Company s assignments of Deliverability Status to specific Distributed Generation Facilities is consistent with the MW quantities of Potential DGD available to that Utility Distribution Company at specific Nodes and with the CAISO s methodology for associating the Deliverability Status of a specific generating resource type with a MW quantity of Potential DGD Associating MW of Potential DGD with Deliverability Status of a Distributed Generation Facility As described further in a Business Practice Manual, a Utility Distribution Company s association of a MW quantity of Potential DGD at a specific Node with the Deliverability Status of a specific Distributed Generation Facility shall be commensurate with the MW Energy production level appropriate to the type of generating resource comprising the facility modeled in the Deliverability Assessment, the qualifying capacity determination method for that resource type, the installed capacity of the facility, and the Deliverability Status (Full Capacity or Partial Capacity) to be assigned to the facility. Such Energy production levels shall be provided by the CAISO to the Utility Distribution Companies no later than the start of the current cycle. If the CAISO identifies an inconsistency between a Utility Distribution Company s assignment of Deliverability Status to a Distributed Generation Facility and the CAISO s Comment [A2]: CAISO may want to publish these factors when it publishes its study. methodology for associating MW amounts of Potential DGD with the Deliverability Status of a Distributed Generation Facility, the CAISO will notify the Utility Distribution Company, and the Utility Distribution Company in consultation with the CAISO will adjust its assignments of Deliverability Status as needed Eligibility of Distributed Generation Facilities to Obtain Deliverability Status Assignment from IOU Participating Transmission Owners Distributed Generation Facilities with an active interconnection request to the Distribution System of an 12

13 IOU Participating Transmission Owner that have requested Deliverability Status (either Partial or Full Capacity) through their underlying interconnection process shall automatically be considered eligible to receive Deliverability Assignments pursuant to the priority rules set forth in Section up to the level requested in their active interconnection request at the time that the ISO begins the Potential DGD Deliverability Assessment for the current cycle. Comment [A3]: SCE strongly prefers that all DG that want to participate in this process fill out an application under this process. Other Distributed Generation Facilities interconnected, or seeking interconnection, to the Distribution System of an IOU Participating Transmission Owner may apply to the CAISO and the applicable Participating Transmission Owner to be eligible to receive a Deliverability Assignment in the current cycle as follows: (i) Distributed Generation Facilities that are already in Commercial Operation and interconnected to the Distribution System of the applicable IOU Participating Transmission Owner that do not have Energy Only Deliverability Status may submit an application to be eligible for Full or Partial Capacity Deliverability Status, and those that have Partial Capacity Deliverability Status may apply to be eligible for a higher level of Partial Capacity Deliverability Status or Full Capacity Deliverability Status. (ii) Distributed Generation Facilities with an active interconnection request in the interconnection queue of an IOU Participating Transmission Owner that have already requested Partial Capacity Deliverability Status may submit an application to be eligible to receive a higher level of Partial Capacity Deliverability Status or Full Capacity Deliverability Status. (iii) Distributed Generation Facilities with an active interconnection request in the interconnection queue of an IOU Participating Transmission Owner that have not requested Energy Only Deliverability Status in the underlying interconnection process may submit an application to be eligible to receive Partial Capacity Deliverability Status or Full Capacity Deliverability Status. Such applications must be submitted by the deadline specified in the schedule for the current DG Deliverability cycle in order for the Distributed Generation Facility to be treated as eligible to receive a 13

14 Deliverability Status assignment in the current cycle. The form of this application shall be specified in a Business Practice Manual. The application shall be submitted to both the CAISO and the applicable Participating Transmission Owner. Comment [A4]: Form should include, at a minimum, Unique Project ID number assigned by the UDC, If project is operating, it s COD. If project is not operating Planned COD (from the current version of the IA or if no IA has been signed yet, the date provided), Full or Partial Deliverability Status, if partial, how much, Assignment Priority for Distributed Generation Facilities Interconnected or Interconnecting to IOU Participating Transmission Owners Utility Distribution Companies that are also IOU Participating Transmission Owners will assign Deliverability Status on a first-come, first-served basis to those Distributed Generation Facilities either interconnected or seeking interconnection to their Distribution Systems at each applicable Node, and that are eligible for assignment pursuant to Section , in the following priority order: (1) Distributed Generation Facilities already in Commercial Operation and interconnected to the Distribution System of the applicable IOU utility Participating Transmission Owner at the time this assignment process commencesdeadline for submitting applications as specified in the CAISO market notice setting out the schedule for the current cycle, in order of the date they achieved Commercial Operation, from earliest to most recent. At Nodes where there is insufficient Potential DGD indicated in the Potential DGD Deliverability Assessment to fulfill all Deliverability Status requests received during the current cycle from Distributed Generation Facilities already in Commercial Operation, and two or more such Distributed Generation Facilities next in order to obtain the last remaining increment of Potential DGD at a Node have the same Commercial Operation date, each such resource shall receive a pro rata share of the remaining Potential DGD in proportion to its MW Energy production level as Comment [A5]: COD is a defined term. Should this be capitalized? modeled by the CAISO for the purpose of the CAISO s deliverability assessment methodology, in accordance with the level of Deliverability Status requested in the current cycle. (2) Distributed Generation Facilities with an active interconnection request in the interconnection queue of the applicable IOU Participating Transmission Owner, which have either requested 14

15 Deliverability Status in the underlying interconnection process, or have submitted a request pursuant to Section to obtain Deliverability Status through the process set forth in this Section , in order of their queue position in the applicable interconnection process. At Nodes where there is insufficient Potential DGD indicated in the Potential DGD Deliverability Assessment to provide Deliverability Status to eligible Distributed Generation Facilities with active interconnection requests, and two or more such Distributed Generation Facilities next in order to obtain the last remaining increment of Potential DGD have the same interconnection queue position, the remaining amount of Potential DGD will be allocated in order of expected Commercial Operation date, from earliest to most recent. For purposes of this determination, the expected Commercial Operation date shall be the Commercial Operation date specified in the Distributed Generation Facility s interconnection agreement, or if no interconnection agreement has yet been executed, the Distributed Generation Facility s current interconnection requestapplication submitted pursuant to Pursuant to this process, an IOU Participating Transmission Owner shall, during each cycle, fully utilize the maximum amount of Potential DGD available at each Node to provide Deliverability Status to eligible Comment [A6]: Revised to tie COD to application because frequently CODs in IR are unrealistic. Developers that have gone through some studies will have a better idea of a realistic COD than what they included in the IR. Distributed Generation Resources. If, however, the total MW quantity associated with eligible Distributed Generation Resources at a particular Node is less than the available Potential DGD for that Node as indicated in the Potential DGD Deliverability Assessment for the current cycle, then the excess quantity of Potential DGD shall be treated as unassigned Potential DGD in accordance with Section below. The IOU Participating Transmission Owners shall complete this assignment process and report the results to the CAISO in accordance with the schedule established by the CAISO for the current cycle Assignment of Deliverability Status to Distributed Generation Facilities by Utility Distribution Companies that are not IOU Participating Transmission Owners Utility Distribution Companies that are not IOU Participating Transmission Owners will assign 15

16 Deliverability Status to individual Distributed Generating Facilities interconnected, or seeking interconnection, to the Distribution System of such Utility Distribution Company based on the Potential DGD available at applicable Nodes pursuant to their individual interconnection procedures. Such Utility Distribution Companies may report assignments of Deliverability Status to the CAISO at any time. However, only those assignments of Deliverability Status that are reported to the CAISO in accordance with the assignment schedule established by the CAISO for the current cycle will be eligible for inclusion in the ISO s annual Net Qualifying Capacity determination as specified in Section and thereby eligible to be designated as Resource Adequacy Resources for the next Resource Adequacy Compliance Year Unassigned Potential DGD If a Utility Distribution Company does not fully utilize the MW quantity of Potential DGD available to assign Deliverability Status to specific Distributed Generation Facilities during an annual cycle, the CAISO will preserve the unassigned Potential DGD for that Utility Distribution Company through the next cycle Deliverability Status of Distributed Generation Facilities Subject to the requirements specified in Section , once a Utility Distribution Company has assigned Deliverability Status to a specific Distributed Generation Facility and reported such assignment to the CAISO, and the CAISO has validated and accepted the reported information as specified under Section , the CAISO will notify the Distributed Generation Facility of its Deliverability Status and the Deliverability Status becomes an attribute of the Distributed Generation Facility to which it was assigned. Distributed Generation Facilities that are assigned Deliverability Status pursuant to this Section prior to achieving Commercial Operation must, in order to retain such assignment, achieve Commercial Operation within six months of the Commercial Operation date specified in the Distributed Generation Facility s interconnection agreement, or if no interconnection agreement had been executed at the time the assignment was made, the Distributed Generation Facility s current interconnection requestapplication submitted pursuant to However, such assignment shall not be revoked if the Distributed Generation Facility s failure to achieve Commercial Operation within six months of its 16

17 indicated Commercial Operation date is due to a delay in the Utility Distribution Company s completion of the upgrades necessary for the Distributed Generation Facility s interconnection. The applicable Utility Distribution Company must report any such revocations or delays to the CAISO in accordance with the date set forth in a Business Practice Manual or in a CAISO market notice establishing the annual cycle schedule. However, for a Distributed Generation Facility that had an executed Interconnection Agreement at the time the application was submitted, such assignment will not be revoked, if the failure to reach COD within 6 months is due solely to a failure by the UDC to complete the upgrades necessary for the Distributed Generation Facility s interconnection by the date specified in the Interconnection Agreement that was the basis for the assignment of Deliverability Status. For a Distributed Generation Facility whose assignment was based on a Commercial Operation Date provided in an application submitted pursuant to , such assignment will not be revoked, if the failure to reach Commercial Operation within 6 months is due solely to a failure by the UDC to complete the upgrades necessary for the Distributed Generation Facility s interconnection and if the Interconnection Customer submits an affidavit to the CAISO affirming that the Distributed Generating Facility was built prior to Commercial Operation Date plus six months in such form as will be specified in the Business Practice Manual. In either case, the Distributed Generation Facility must reach Commercial Operation within 6 months of the UDC completing the upgrades necessary for interconnection in order to retain the assigned Deliverability Status. With respect to a Distributed Generation Facility that meets thise Commercial Operation datae requirement, once that Distributed Generation Facility has achieved Commercial Operation, it will send notice to the CAISO and the PTO and it will retain its assigned Deliverability Status for as long it remains in Commercial Operation. This also applies to Distributed Generation Facilities that were already in Commercial Operation at the time the assignment was made. Any loss of Deliverability Status granted pursuant to this Section , due to either retirement of a Distributed Generation Facility or revocation due to failure to meet the Commercial Operation date requirement set forth above will be appropriately modeled by the CAISO in the next Potential DGD Deliverability Assessment cycle. Depending on other changes that may have occurred on the CAISO 17

18 Controlled Grid and connected Distribution Systems, or in associated interconnection queues, additional Potential DGD may be available in the next cycle for assignment of Deliverability Status in accordance with the process set forth in this Section * * * Appendix A Potential DGD Deliverability Assessment The annual Deliverability Assessment the CAISO will perform to determine nodal MW amounts of Potential DGD that will be available to Utility Distribution Companies for assigning Deliverability Status to Distributed Generation Facilities, as set forth in Section