163. See Duke Energy Fla., LLC, 165 FERC , 61.230, P 22 (2018) (“[t]he Commission precedent is clear that costs in an LGIA are merely estimates and that interconnection customers are responsible for the actual costs of interconnections and network development”). 79. See Id. P 86 (the finding that a liaison client, if he can make use of the possibility of building, cannot be close to the construction option . . . . wait longer for the construction of the transport provider`s interconnections and stand-alone network upgrades”). 67. Generation Developers argues that the Commission erred in not requiring transmission providers to explain their justification if they do not agree with a connection customer as to whether a network upgrade is the only one.  They justify that the interconnection client`s ability to exercise the opportunity to build up undermines the client`s ability to increase the transparency of the process being affected by the fact that such a declaration is not necessary.  You also disagree with the Commission that such a declaration would be difficult before the transmission provider has the results of the system impact assessment, since these results will be available prior to the LGIA phase of the Print Started Page 8168 interconnection process, when the interconnection customer can first express his wish to use the construction option.
 In addition, Generation Developers argues that in the event of disagreement, dispute resolution or a complaint filed pursuant to Section 206 of the VPA are not viable options, as these options involve costly delays.  252. Id. (“Use of excess connection service – The transmission provider must provide a process for a connection customer to use or transfer the excess connection service to an existing connection point. The initial link customer or one of its affiliates has priority in the use of the surplus interconnection service. If the existing liaison customer or one of its related companies does not exercise its priority, this service may be made available to other potential liaison customers. 28. SoCal Edison is seeking clarification on the “Order No. 845” option for the construction of revisions.  In particular, the Commission argues that the Commission does not risk costs to California taxpayers under the CAISO tariff, whereby transmission customers, not third-party manufacturers or interconnection customers, should ultimately bear the costs of network development.  SoCal Edison notes that, under the CAISO tariff, the transmission provider would reimburse the liaison customer, over a five-year period, for the amount that the interconnection customer spent on stand-alone network development operations.  SoCal Edison notes, however, that the LGIA does not contain a mechanism for taxpayers to challenge the accuracy and adequacy of the construction costs borne by the liaison client.
 For these reasons, SoCal Edison invites the Commission to determine whether it intends to apply these new rules in cases where the interconnected customer ultimately does not bear the costs of its construction for network extension.  In addition, SoCal Edison asks the Commission to clarify that it would not prohibit the transmission service provider from simply paying the costs of the link customer at the CAISO rate rates.  149. The IEE asks the Commission to clarify that it does not change the definition of the material amendment defined in Regulation No.