A new resource needed for reliability may apply to defer the rights and obligations of a capacity supply obligation (CSO) by one capacity commitment period (CCP). This provides additional time for a resource to reach FCM commercial operation. All CSO deferral requests must be approved by the Federal Energy Regulatory Commission (FERC).
Eligibility
A resource may only request a CSO deferral once. The resource seeking the deferral must be able to demonstrate both of the following conditions:
- The deferral is critical to the resource’s ability to achieve FCM commercial operation.
- The reasons for the deferral are beyond the project sponsor’s control.
Obligations with a Deferral
After receiving a CSO deferral:
- The resource must continue to submit timely Critical Path Schedule Reports.
- Remaining financial assurance is due 30 days after FERC approval of the CSO deferral.
The resource is not subject to shortage-event penalties during the year of deferral. However, the ISO retains its right to seek FERC termination of a deferred resource’s CSO should it become apparent that the resource will not achieve all its critical path schedule milestones by the start of the CCP in which the deferral is effective.
Deadlines
Project Sponsor Responsibilities
- A project sponsor must submit a CSO deferral notification no later than the first business day in September of the year before the third annual reconfiguration auction (ARA 3) for the CSO’s corresponding CCP. Example: The CSO deferral notification for the 2024–25 capacity commitment period must be submitted no later than September 1, 2023.
- If the ISO determines that the project is needed for reliability (see below), the project sponsor must file the CSO deferral request with FERC no later than the first business day of the following November.
ISO Responsibilities
Within 30 days of receiving a CSO deferral notification, the ISO must conduct these tasks:
- Perform a reliability review in both the CCP for which the deferral is sought and the subsequent CCP
- Review the need with the Reliability Committee; an advisory vote may be requested
- Provide a written determination to the project sponsor
How to Submit a CSO Deferral Notification
A project sponsor must submit a CSO deferral notification to the ISO using Ask ISO, the Participant case tracking system.
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