Docket No. ER23-2058-000

I support today’s draft order granting California Independent System Operator Corporation (CAISO)’s requests to extend the timelines for its massive Cluster 14 interconnection queue cluster and to pause its (even more massive) Cluster 15 interconnection queue cluster.  As discussed in the order, these measures will allow CAISO an opportunity to address the unprecedented challenges raised by Clusters 14 and 15.[1]

The issues that CAISO is facing are emblematic of the unbearable queue delays and costs that interconnection customers and utilities are facing around the country.  Order No. 2023, “Improvements to Generator Interconnection Procedures and Agreements,” includes reforms that will improve interconnection processes across the country.  However, as I noted in my concurrence, while the rule “can be expected to improve matters, more will be necessary to solve the problem.”[2]  Therefore, I urge all transmission providers to consider the additional reforms and improvements to generator interconnection processes that I discuss in detail in my concurrence to Order No. 2023, which I’ve appended below for convenience.

For these reasons, I respectfully concur.


[1] Cluster 14 included 343 interconnection requests, a 241% increase above CAISO’s previous record-high cluster.  Cluster 15 included 541 interconnection requests, a 45% increase above Cluster 14.

[2] Improvements to Generator Interconnection Procedures & Agreements, Order No. 2023, 184 FERC ¶ 61,054 (2023) (Clements, Comm’r, concurring at P 3).


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This page was last updated on September 05, 2023