3.
Provide your organization's comments on PG&E's proposed reliability alternatives presentation
The following are Cal Advocates’ comments on nine of Pacific Gas and Electric Company’s (PG&E) recommended reliability projects and assessments for the 2025-2026 Transmission Planning Process (TPP) cycle.
- Mariposa 70 kilovolts (kV) Voltage Support Project
To address low voltage issues at the Mariposa substation and neighbouring substations, PG&E recommends installing a 20 Megavolt-Ampere Reactive (MVar) voltage support device at the Mariposa substation and associated equipment to integrate this device.[1] CAISO, in contrast, recommends a redundant relay or battery and the already approved Wilson area reinforcement to address potential thermal overloads in the project area.[2] For low voltage issues in the project area, CAISO recommends continuing to monitor the area since reliability issues may occur only during the off-peak timeframe.[3] Cal Advocates supports CAISO’s recommendation to pursue redundant relays and batteries and the already-approved Wilson area reinforcement project because these are cost-efficient solutions to address potential future reliability issues in the area.
- Oro Loma 70 kV Area Reinforcement Project Rescope
To mitigate overloads and low voltage issues in the Oro Loma substation area, PG&E recommends rescoping the Oro Loma and Los Banos 70 kilovolt (kV) Area reinforcement projects to add a new line and to expand the Mercy Springs Switching Station and Ortiga 70 kV buses as needed.[4] In contrast, CAISO recommends the Los Banos area reinforcement project “as is” for addressing area issues.[5] Cal Advocates recommends CAISO and PG&E rely on the previously approved Los Banos area reinforcement project to address area issues. CAISO’s reliability results did not provide justification for a new line or other improvements in the project area. In addition, to address low voltages issues, Cal Advocates recommends CAISO and PG&E evaluate series capacitors on the 70 kV line between the Canal and Ortega substations to address voltage drops.[6] CAISO and PG&E should provide their results from their series capacitor evaluation at the November TPP meetings.
- Midway 115 kV Bus Upgrade Project
To protect against potential overloads on certain sections of the Midway 115 kV line, PG&E recommends expanding the Midway bus and relocating connections to the bus.[7] In contrast, CAISO’s reliability assessment did not recommend upgrades on the identified sections of Midway 115 kV line. Instead, CAISO confirmed that the previously approved Kern Reinforcement project can address reliability issues in the area and identified possible issues with only the sensitivity scenario in 2040.[8] Cal Advocates recommends CAISO and PG&E rely on the previously approved Kern Reinforcement project to address reliability and recommends considering additional energy storage, if necessary, to address the potential reliability issues identified in the project area.
- Eastshore and Newark Area Import Capability Reinforcement Conceptual Project
To address possible overloads in the Eastshore and Newark area, PG&E proposes reconductoring approximately 92 miles of 230 kV lines in the project area.[9] In contrast, CAISO’s August 2025 reliability results recommends minor mitigations ranging from considering a transformer capacity increase and relying on the already approved San Jose Area HVDC line project[10] and to continue monitoring issues in the area.[11] In the September 24, 2025 reliability assessment stakeholder meeting (September 2025 meeting), CAISO stated that there will be potentially significant overloads in the area due to forecasted load from data centers. CAISO explained that they are currently reviewing network upgrades for the area and the overloads due to large loads.[12] Cal Advocates supports CAISO additional investigation to confirm the large loads in the area and their contribution to overloads. Cal Advocates also recommends that PG&E and CAISO conduct an additional power flow study to determine if the Eastshore area can receive power through a different substation rather than the Newark substation station and to continue evaluating the alternative options, which include transformer additions or upgrades. Cal Advocates recommends that PG&E and CAISO present their analysis to stakeholders at the November TPP meetings.[13]
- South Oakland Reinforcement Conceptual Project Phase 2
To address potential overloads in the South Oakland area, PG&E proposes reconductoring 16 miles of 115 kV lines or building a new substation amongst other improvements.[14] PG&E’s proposed conceptual project for the South Oakland area is significantly different from the project PG&E proposed last year. In 2024, PG&E’s scope for the South Oakland area included a greater amount of line reconductoring and new loops.[15] In contrast, in 2024 CAISO recommended reconductoring fewer lines in the South Oakland area.[16] At the September 2025 meeting, CAISO recommended continuing to monitor possible reliability issues in the South Oakland area[17] or to consider a capacity increase for confirmed large load.[18] Since the scope for the South Oakland project significantly changed from PG&E’s 2024 proposal, and CAISO is still reviewing the large load demand growth for the area, Cal Advocates recommends CAISO withhold approval of PG&E’s conceptual proposal. Instead, Cal Advocates recommends that CAISO undertake the following and provide their results at the November TPP meetings:
- Confirm the large load growth in the California Energy Commission (CEC)-Integrated Energy Policy Report (IEPR) proceeding.
- Consider lower cost alternatives to increase the power transfer capability of the existing lines and provide power system stability such as with capacitors in a series/series compensation [19] instead of considering only reconductoring the area lines. Specifically, consider an alternative with series reactors[20] installed as part of the solution for the parallel lines between Grant and Eden Landing substations versus considering only reconductoring.[21]
- Consider rebuilding certain substation equipment at the Oakland and Grant substations instead of building a new substation.
- Metcalf – Monta Vista 230 kV Transmission Corridor Reinforcement
To address potentially significant overloads in 2040 in Santa Clara County, PG&E proposes reconductoring nearly 50 miles of 230 kV lines.[22] In contrast, CAISO’s August 2025 reliability results only recommends continued monitoring. [23] However, at the September 2025 meeting, CAISO presented mitigations to address new data center loads in Santa Clara County that are smaller in scope.[24] Since the load growth in Santa Clara County is still uncertain, Cal Advocates recommends CAISO confirm the load growth, determine the least cost mitigations and present their results at the November TPP meetings. For the noted overloads, PG&E should consider a “DC run back” operational procedure similar to other schemes which can automatically reduce or reserve power flow for the Metcalf – Monta Vista 230 kV line. Cal Advocates also recommends that PG&E and CAISO consider lower cost alternatives to increase line capacity, such as installing energy storage or capacitors.
- Metcalf 230/115 kV Banks Upgrade Project
To address potential overloads in the South Bay area, PG&E proposes to upgrade all four of the transformers at the Metcalf substation along with any additional equipment needed to achieve full transformer capacity.[25] In contrast, CAISO’s August 2025 reliability results recommends to continue monitoring the area.[26] Cal Advocates recommends CAISO only approve the Metcalf substation transformers #2 and #3 upgrades at this time. Based on PG&E’s power flow results, transformers #2 and #3 may need to be upgraded in the near term, if PG&E’s load forecasts are valid. As an alternative, Cal Advocates recommends CAISO and PG&E continue evaluating a fifth transformer at Metcalf substation or consider energy storage as a lower cost option to upgrading all four transformers. Cal Advocates also recommends that CAISO and PG&E provide their results at the November TPP meeting.
- San Jose B 230/115 kV Transformer Bank Addition Project.
To address potential overloads in the San Jose Area, PG&E proposes to add a transformer to the San Jose B substation which currently has only one transformer.[27] In contrast, CAISO’s August 2025 reliability assessment suggests to continue monitoring the area and stated that they are still reviewing the long-term issues related to large loads.[28] However, in the September 2025 meeting, CAISO recommended a transformer capacity increase or substation upgrade at Newark.[29] Since PG&E and CAISO are proposing different solutions for the San Jose area and CAISO is still reviewing the long-term load forecasts, Cal Advocates recommends: (1) CAISO complete their review and power flow studies to determine the appropriate solution for the San Jose area. (2) PG&E and CAISO evaluate energy storage’s potential to address the potential overloads. (3) PG&E and CAISO provide the results of their completed project evaluations that consider energy storage at the November TPP meetings.
- South Bay 115 kV system Reinforcement Conceptual Project
To address load growth in the South Bay area, PG&E proposes reconductoring eight line segments and installing two new transformers at area substations.[30] Last year, PG&E proposed a more limited project scope with only two line segment reconducting areas.[31] CAISO stated that PG&E’s proposal includes a capacity increase on the Los Esteros – Metcalf 230 kV line and that the overload driving this capacity increase is under review for “potential contribution from large loads.”[32] Since CAISO is still reviewing the load growth for this area, Cal Advocates recommends CAISO confirm the load growth and provide their determination at the November TPP meetings. Cal Advocates also recommends PG&E consider lower cost alternatives to increase line capacity such as installing energy storage or capacitors.
The following are Cal Advocates’ recommendations regarding new data center load.
- CAISO should confirm whether new data centers are pursuing strategies to reduce their impact on the grid and ratepayers.
In its September 2025 presentation, PG&E explained that new data center load is partially driving the need for eight of its 10 proposed reliability projects.[33] PG&E also stated that there are 14 new data centers proposed in its service area that all have site control.[34] PG&E did not confirm, however, whether any behind the meter measures will or can play a role in reducing the expected data center load demand during critical need hours.[35] This is inconsistent with PG&E’s statement earlier this year in a CEC Demand Analysis Working Group (DAWG) meeting that it will continue to evaluate load-shifting capabilities and strategies for data centers.[36] CAISO stated during the September 2025 meeting that CAISO staff is still analyzing whether the new expected data center load in the greater Bay Area can be interruptible.[37],[38] To confirm that the identified transmission upgrades are appropriately sized, CAISO and PG&E should first determine if the expected new data center load can be interruptible. If data centers can power down or rely on their own energy storage during critical need hours, nine of PG&E’s proposed new reliability projects may not be necessary.
Data center load needs could also be reduced if the data centers co-located with generation, connected to a microgrid or pursued energy efficiency upgrades such as advanced data cooling technologies[39],[40] and information technologies efficiencies.[41],[42],[43] The three major California electric utilities and CEC discussed these strategies along with load flexibility strategies in a February 2025 CEC workshop but PG&E failed to address this topic during its September 2025 meeting presentation.
Notably, other states require data center flexibility for interconnection. For example, the state of Texas recently passed a law that requires new data centers to either deploy back-up generation or curtail load during an emergency grid event and to also contribute to interconnection costs.[44]
This example illustrates that PG&E’s approach to addressing new data center load with only wire solutions is not cost-effective and is inconsistent with practices in other states and PG&E’s own “looking forward” statements at the DAWG.
- CAISO and the Participating Transmission Owners should isolate the costs to integrate new large loads to inform state policy.
CAISO and the PTOs fail to provide the cost impacts for the different drivers of new transmission investments in the TPP. Instead, the cost impacts associated with accommodating new data center demand and new building and transportation electrification demand are undistinguishable. California is in the midst of determining how to respond to new data center load and how to allocate costs for integrating new data center loads. For this reason, CAISO should require the PTOs to estimate the portion of new TPP transmission projects that are associated with integrating new data center load. This will enable the state to properly evaluate the impact of new data center load.
In addition, PG&E failed to provide the project cost estimates for individual interconnection projects and capacity upgrades in its Load Cluster 2024 (LC24) or Serial Data Center interconnection studies. Instead, PG&E presented a total cost estimate for interconnection and capacity upgrades.[45] This provides no insight into the costs for specific loads in the LC24 Scope Study and Serial Data Center projects in San Jose. The estimated cost of the upgrades should be disaggregated and estimated for each data center project. This will help improve large load upgrade cost transparency and support analysis on cost allocation for these upgrades going forward.
- There should be more review and transparency on new data center loads to confirm new projects are no regrets.
PG&E staff stated that the 14 proposed new data centers in their service area have site control. However, PG&E staff did not confirm whether these data centers provided assurances that they are committed to their projects through security deposits and interconnection agreements or whether these data centers can be interruptible.[46] Also, data center additions to load forecasts should demonstrate certainty of the load beyond just engineering drawings to ensure proposed transmission projects are “no regrets.” On September 18, 2025, the Federal Energy Regulatory Commission (FERC) Chairman Rosner recommended that utilities’ criteria for assessing the commercial readiness of large loads include observable milestones such as contracts, financial security deposits, and physical site control.[47] Thus, to verify new data center load and confirm the data center driven transmission projects are appropriately sized, PG&E should be required to provide: (1) proof of signed interconnection agreements; (2) proof of compliance with financial commitments (e.g., security deposits and required financial advances); (3) proof of site control; and (4) relevant information to determine whether the new data center load can be interruptible.
[1] PG&E’s 2025 Request Window Proposal, CASIO 2025-2026 Transmission Planning Process (Presentation), PG&E, September 25, 2025 (PG&E Presentation) at slide 7.
[2] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Fresno Area, CAISO, August 15, 2025, Thermal Overloads at pp. 1-2.
[3] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Fresno Area, CAISO, August 15, 2025, Low-Voltage at pp. 6-8.
[4] PG&E Presentation at slides 9-11.
[5] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Fresno Area, CAISO, August 15, 2025, Thermal Overloads & Low Voltage at pp. 3, 6, 7 & 9.
[6] Capacitors are connected to lines for voltage compensation and power transfer enhancement. This practice, known as series compensation, helps to improve the efficiency and stability of long-distance power transfers through transmission. Sources: https://insights.globalspec.com/article/23194/role-of-capacitors-in-distribution-lines & https://www.electricaltechnology.org/2025/03/capacitors-in-series-in-power-lines.html
[7] PG&E Presentation slides at 15-18.
[8] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Kern Area, CAISO, August 15, 2025, Thermal Overloads at p 1.
[9] PG&E Presentation slides 21-23.
[10] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Bay Area, CAISO, August 15, 2025, Thermal Overloads at pp. 11-12.
[11] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Bay Area, CAISO, August 15, 2025, Thermal Overloads at pp. 1-2 &4, 9 & 10.
[12] 2025-2026 Transmission Planning Process, Stakeholder Meeting September 24-25, 2025, CAISO, (CAISO presentation) at slide 74.
[13] PG&E Presentation at slide 25.
[14] PG&E Presentation at slides 29-31.
[15] PG&E’s 2024 Request Window Proposals, CAISO 2024-2025 Transmission Planning Process, September 24, 2024 at pp. 58-61.
[16] Reliability Assessment Recommendations – PG&E Area Draft 2024-2025 Transmission Plan, CAISO, April 15, 2025 at slide 32.
[17] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Bay Area, CAISO, August 15, 2025, Thermal Overloads at p. 2 &4 & Low Voltage at p. 20.
[18] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Bay Area, CAISO, August 15, 2025, Thermal Overloads at p. 3 & 4.
[19] Advances in Series-Compensation Line Protection, Schweitzer Laboratories Inc., 63th Annual Georgia Tech Protective Relaying Conference, April 24-29, 2009 at p. 2.
[20] https://american-power.com/industry-news-blog/difference-between-shunt-reactor-and-series-reactor/
[21] PG&E Presentation at slide 30.
[22] PG&E Presentation at slide 36.
[23] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Bay Area, August 15, 2025, Thermal Overloads at pp. 4,6,8, 9, 16 & 18.
[24] CAISO presentation at p. 76.
[25] PG&E Presentation at slide 46.
[26] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Bay Area, CAISO, August 15, 2025, Thermal Overloads at pp. 7-8.
[27] PG&E Presentation at slides 49-51.
[28] 2025-2026 ISO Reliability Assessment – Preliminary Study Results, Study Area: PG&E Greater Bay Area, CAISO, August 15, 2025 at pp. 3, 5, 7-12, 21 and 27.
[29] CAISO presentation at slide 77.
[30] PG&E Presentation at slides 54-55.
[31] PG&E’s 2024 Request Window Proposals, CAISO 2024-2025 Transmission Planning Process, September 24, 2024 at slide 80.
[32] CAISO presentation at slide 77.
[33] PG&E presentation at slide 57.
[34] PG&E presentation at slide 2.
[35] S&P Global Market Intelligence Datacenters and energy — truths and myths two years into the Gen AI revolution (On-Demand) (5010190). This webinar discussed the truths and myths regarding data centers’ capacity to shift their load. at minute 53.34. Dan Thompson, principal research analyst with S&P, clarified that older data centers are not as flexible at responding to grid needs because they were not designed with automated functions to respond to grid needs so it takes longer for them to react to grid issues. However, Google found that when they shifted the load from their data center’s AC units/cooler and chillers, it shaved the data center’s load enough to be meaningful for the grid. As a result, Google recently announced that its next generation of data centers will be designed to be able to shift AC load when needed. Google and other Hyperscalers are also investigating ways to shift their workload to times when there is less stress on the grid. Google is already shifting some workload to the night time frame when the grid is less stressed.
[36] PG&E Data Center Forecasting Presentation, Presented at the July 16, 2025 DAWG Workshop, July 18, 2025 at slide 14.
[37] Interruptible data centers, also known as flexible or grid-interactive data centers, can reduce their power consumption during times of high demand or grid stress, often in exchange for interruptible tariffs, lower rates, or faster interconnection. By curtailing usage for short periods, these data centers help stabilize the power grid, reduce costs for the utility and its customers, and can defer the need for costly infrastructure upgrade.
[38] Power Association of Northern California (PANC) meeting entitled Removing Friction from the Grid, June 11, 2025, Elliott Mainzer, President and CEO of CAISO statements at minute 49:15 “The big question that I have for the data center community is how can they prove that they can come to the table with some actual legitimate flexibility in their demand for electricity whether they install some batteries or whether they have some gen sets and how can the system operator and the utilities count on the use of some of that flexibility during peak periods. So that the cost of accommodating them [data centers] on the grid are not so high.”
[39] https://www.microgridknowledge.com/data-center-microgrids/article/33038792/microgrids-help-create-data-centers-that-dont-break-the-grid-or-the-environment
[40] https://www.microgridknowledge.com /data-center-microgrids/article/55019485/how-power-hungry-data-centers-and-large-industries-are-turning-to-microgrids-on-and-off-grid
[41] https://www.forbes.com/councils/forbestechcouncil/2024/03/26/heres-why-data-center-cooling-is-the-hottest-innovation-in-the-sector/, Liquid cooling systems also use less power—and, perhaps surprisingly, less water—than their air-driven rivals.
[42] https://news.mit.edu/2025/new-chip-tests-cooling-solutions-stacked-microelectronics-0428
[43] Opportunities to Use Energy Efficiency and Demand Flexibility to Reduce Data Center Energy Use and Peak Demand, ACEEE, October 2025 at p. iii. Opportunities to improve efficiency include developing and using more efficient chips in servers, improving software and algorithms, adding heat recovery, and improving cooling and electric systems.
[44] Enrolled Version of Texas Legislature Senate Bill No. 6, June 2025 at p. 3. Senate Bill No. 6 2025, Amends Section 35.004 of Texas Utilities Code.
[45] PG&E presentation at slide 60 (total cost estimate for LC24 of $633 to $1,265 million for interconnection projects and $278- $556 million for capacity upgrades); and PG&E presentation at slide 69 (total cost estimate for serial data center projects in San Jose of $182 to $387 million for interconnection projects and $45 to $100 million for capacity upgrades.)
[46] California ISO (CAISO) 2025-2026 Transmission Planning Process, September 24-25, 2025, Customized Energy Solutions, October 3, 2025 at p. 17
[47] FERC Chairman Rosner's Letter to the RTOs/ISOs on Large Load Forecasting | Federal Energy Regulatory Commission, September 18, 2025.
6.
Provide your organization's comments on SDG&E proposed reliability alternatives presentation
The following are Cal Advocates’ comments on San Diego Gas & Electric Company’s (SDG&E) recommended reliability projects and assessments.
- Reconductor TL690B & TL697
SDG&E proposes to reconductor lines TL690B and TL697 to address possible overloads with expected load growth in Oceanside.[1] CAISO observes similar issues in its assessment for the area.[2] However, during the September 2025 meeting, CAISO confirmed that energy storage could be considered as part of the solution to address the potential reliability issues in Oceanside. For this reason, Cal Advocates recommends that CAISO withhold approval of SDG&E’s proposed project and evaluate energy storage as part of the project scope to reduce the total project costs. Cal Advocates also recommends that SDG&E provide the results of their energy storage evaluation at the November TPP meetings.
Cal Advocates also notes that the estimated costs for these reconductoring projects appears to be inconsistent with SDG&E’s 2025 Per Unit Cost Guide. To illustrate, the Reconductor TL690B and TL697 project includes approximately 7.6 miles of reconductoring and is estimated to cost $100 million.[3] According to SDG&E’s 2025 Per Unit Cost Guide, reconductoring a transmission line costs between $1.62 million and $2.7 million per mile, depending on complexity.[4] Assuming this is a “high complexity” project, applying the high end of SDG&E’s cost scale results in a cost of $20.52 million,[5] five times less than SDG&E’s project cost estimate.[6] Cal Advocates recommends that SDG&E explain the cost deviation from its Per Unit Cost Guide and confirm whether additional work beyond reconductoring is necessary in the November TPP meetings.
- Reconductor TL647 and TL623B
SDG&E proposes to reconductor TL647 and TL623B to address an anticipated overload in the Border area starting in 2032.[7] CAISO anticipates a similar overload but recommends system adjustments to the energy storage in the area to address the potential overload.[8] Cal Advocates recommends CAISO withhold approving this project, and recommends SDG&E consider energy storage as a lower cost solution and provide their results at the November TPP meetings.
- Reconductor TL623C, TL623B and TL647
SDG&E proposes to reconductor TL 623C and TL 623B to address potential overloads starting in 2032 in southern San Diego.[9] CAISO anticipates similar overloads but recommends system adjustments and operational actions.[10] Cal Advocates recommends SDG&E and CAISO continue studying the system adjustment options that CAISO outlined, since they are more cost-effective options than reconductoring. Cal Advocates also recommends that SDG&E consider energy storage or capacitors as lower cost alternatives to address line capacity issues than reconductoring.
- New Oceanside Area 69 kV substation
SDG&E proposes addressing the growing demand in Oceanside and the Border load pocket with new substations to be installed by 2032 in San Diego.[11] SDG&E fails to mention whether it considered cost effective alternatives. CAISO also anticipates potential overloads in Oceanside and the Border areas, but recommends considering a range of mitigations including system adjustments, operational actions, energy storage, and power flow devices.[12] Cal Advocates recommends that CAISO withhold approving SDGE’s proposed project. Instead, Cal Advocates recommends, CAISO confirm whether the combination of the aforementioned lower cost alternatives could effectively address the identified reliability issues at the November TPP meetings.
Cal Advocates also notes that SDG&E’s two proposed substation projects have nearly the same, scope but the cost for the proposed New Border Area 69/12 kV substation is a significantly higher cost than the proposed New Oceanside Area 69kV substation project. For reference, the New Border Area 69/12 kV substation project could cost up to $140 million[13] while the New Oceanside Area 69kV substation project could cost up to $40 million.[14] Cal Advocates recommends that SDG&E explain the cost discrepancy between its two proposed substation projects at the November TPP meetings.
- New Penasquitos- Mira Sorrento 69KV #2 line
SDG&E proposes a new Penasquitos- Mira Sorrento 69KV #2 line project that will be 2.01 miles long (assuming it is the same length as TL6959) with an expected cost of $124.5 million.[15] According to SDG&E’s 2025 Per Unit Cost Guide, a new transmission line costs between $4.32 and $8.64 million per mile, depending on the complexity.[16] Assuming this is a “high complexity” project, applying the high end of SDG&E’s cost scale results in approximately $17.37 million,[17] seven times less than SDG&E’s estimated project cost. However, SDG&E’s presentation provided no indication of other work that would contribute to SDG&E’s higher project cost estimate. SDG&E should explain the reason for this cost deviation from its Per Unit Cost Guide and specify whether additional work, not specified in the project scope, is necessary.
[1] SDG&E Presentation, 2025-26 TPP Proposals, September 25, 2025 (SDG&E Presentation), SDG&E at slide 3.
[2] San Diego Gas & Electric Area, Preliminary Reliability Results, 2025-2026 Transmission Planning Process Stakeholder Meeting, September 24-25, 2025 (CAISO Presentation for SDG&E Area) CAISO at slide 315.
[3] SDG&E Presentation at slide 3.
[4] SDG&E Final 2025 Per Unit Cost Guide, July 10, 2025, available at https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/Participating-transmission-owner-per-unit-costs-2025
[5] (7.6 miles) x ($2.7 million / mile) = $20.52 million
[6] SDG&E’s project scope gives no indication of other work that would contribute to the high project cost estimate.
[7] SDG&E Presentation at slides 5-6.
[8] CAISO Presentation for SDG&E area at slide 318.
[9] SDG&E Presentation at slides 5-6.
[10] CAISO Presentation for SDG&E area at slides 317-318.
[11] SDG&E Presentation at slides 8-9.
[12] CAISO Presentation for SDG&E Area at slides 312 and 317.
[13] SDG&E Presentation at slide 9.
[14] SDG&E Presentation at slide 8.
[15] SDG&E Presentation at slide 7.
[16] SDG&E Final 2025 Per Unit Cost Guide, July 10, 2025, available at https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/Participating-transmission-owner-per-unit-costs-2025.
[17] (2.01 miles) x ($8.64M / mile) = $17.37M.