On October 13, 2025, the California Independent System Operator (CAISO) released its Draft Final Proposal for Interconnection Process Enhancements (IPE) 5.0—continuing its multi-year effort to modernize and streamline the interconnection process for new energy resources. The proposed reforms build on lessons learned from Cluster 15, previous IPE tracks, and stakeholder feedback.

Highlights of CAISO’s Draft Final Proposal:

  • Revised Scoring for Non-LSEs: Projects backed by non-load-serving entities (LSE) no longer need to cite sustainability goals—broadening access to the commercial interest scoring process.
  • Deliverability Cap Recalibration: A new cap limits how much full deliverability large LSEs can allocate for projects requesting Full Capacity Deliverability Status or Partial Capacity Deliverability Status.
  • Revisions for Distributed Energy Resources (DER): DERs seeking deliverability and to participate in the CAISO market will now be scored and studied alongside transmission-connected projects, subject to queue caps.
  • Expanded Deliverability for Energy Only Projects: Energy Only projects in operation can now pursue deliverability—if backed by a five-year resource adequacy contract with an LSE.
  • Tighter Queue Management: Projects seeking commercial operation date extensions beyond seven years must show proof of commercial viability through a PPA.

Other changes include refined processes for affected system studies, adjusted deposit timing, the elimination of the pre-application step for small generators, and added flexibility for dispute resolution.

Next Steps:

Stakeholder comments are due by November 3, 2025. CAISO plans to issue the final proposal on December 22 and present it to its Board of Governors in March 2026.

Read the full article for a deeper dive into what’s changing—and what’s not—in CAISO’s interconnection reforms.

Photo of Seth Hilton Seth Hilton

Seth Hilton, a partner in Stoel Rives’ Energy Development group, focuses his practice on energy regulation and litigation, representing clients before a variety of energy regulatory agencies in California, including the California Public Utilities Commission and California Energy Commission, as well as…

Seth Hilton, a partner in Stoel Rives’ Energy Development group, focuses his practice on energy regulation and litigation, representing clients before a variety of energy regulatory agencies in California, including the California Public Utilities Commission and California Energy Commission, as well as in stakeholder proceedings at the California Independent System Operator. His clients include developers of thermal and renewable generation, energy storage developers, transmission developers, energy service providers, and investor-owned and publicly-owned utilities. Seth also represents energy clients in state and federal court and has significant experience in a wide variety of complex commercial litigation.

Click here for Seth Hilton’s full bio.

Photo of Meghan O’Brien Meghan O’Brien
Meghan O’Brien offers a solid energy regulation and policy background. Her practice includes representing clients before the California Public Utilities Commission and in stakeholder proceedings at the California Independent System Operator to advocate for favorable state energy policies and ensure compliance. Meghan advises
Meghan O’Brien offers a solid energy regulation and policy background. Her practice includes representing clients before the California Public Utilities Commission and in stakeholder proceedings at the California Independent System Operator to advocate for favorable state energy policies and ensure compliance. Meghan advises independent power producers, utilities, investors, and large users of gas and power resources on matters arising in power markets under the jurisdiction of the Federal Energy Regulatory Commission (FERC). She also assists project developers with regulatory due diligence associated with mergers and acquisitions, as well as energy project financings.

Click here to view Meghan O’Brien’s full bio.