Comments on 20-Year Transmission Outlook & May 14 Stakeholder Call

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

ACP-California greatly appreciates CAISO’s efforts to develop the 20-year transmission outlook, which is consistent with the types of transmission evaluations for which ACP-California has been advocating. A more forward-looking transmission evaluation, which provides CAISO with more flexibility in study approach than the tariff defined Transmission Planning Process (TPP) is needed as the state enters a new phase of clean energy development, where additional transmission capacity will be needed to achieve the state’s long-term goals. The 20-year transmission outlook can provide important analysis and information to the CPUC’s Integrated Resource Planning (IRP) process and is a necessary first step to beginning to better align the generation and transmission planning processes. ACP-California supports the assessment’s broad scope, which will include evaluations of in-state and out-of-state transmission solutions, including inter-regional transmission projects and transmission capacity to incorporate offshore wind.

There are several areas where additional information would be helpful to stakeholders. ACP-California encourages CAISO to hold additional stakeholder calls and issue a draft study plan to enable stakeholders more time to review assumptions and approaches to the 20-year transmission outlook during the course of the study process. Some of the areas where additional information would be valuable are discussed below.

Stakeholders will benefit from additional information on the outputs of the 20-year transmission outlook. CAISO should review with stakeholders the type of information that will be provided on the transmission solutions that are evaluated. CAISO could provide a high-level summary of the anticipated outputs of this process as part of the upcoming workshop discussed in the presentation (which will be held in conjunction with the joint energy agencies in June). We understand the outputs of this process will include high-level cost estimates for transmission solutions that are evaluated.

• It may also be valuable to include information on whether additional generation resources (beyond those studied in the resource portfolios of the 20-year outlook) are expected to be able to be accommodated on the transmission solutions. This information will likely be helpful for the CPUC it its planning efforts. ACP-California encourages early communication with the CPUC to ensure that the outputs from the 20-year transmission outlook are as valuable as possible to the IRP process. This type of up-front communication and coordination with the CPUC and stakeholder will help ensure the results of the 20-year outlook are meaningful and supportive of other ongoing processes, such as the IRP.
• ACP-California also requests that CAISO provide additional details on how the outlook studies will be conducted. During the stakeholder call, CAISO indicated that the 20-year outlook will not focus on deliverability studies nor evaluation of transmission solutions to provide deliverability of resources but will instead focus on transmission solutions which are needed to simultaneously achieve reliability and GHG metrics. While ACP-California has raised concerns with deliverability assumptions for resources studied in the TPP, we agree with CAISO that focusing on deliverability requirements, in a study looking out 20-years, is not appropriate. It is, however, critical to ensure that the 20-year studies are focused on the right metrics. It would be helpful for CAISO to provide the reliability and GHG metrics and/or output that will be evaluated as part of the 20-year outlook for stakeholders to comment on. CAISO should build opportunities for stakeholder review of both inputs and outputs of the 20-year outlook and individual scenarios and sensitivities.
• As the CAISO considers new metrics and scenarios for the 20-year outlook, ACP-California suggests scenarios that ensure CAISO can maintain reliable and economic service while meeting the goals of SB 100 and supporting increased electrification.  To this end, CAISO should include one or several scenarios that are significantly more aggressive than current IRP study scenarios, with reliability consideration and consistent with the ARB’s greenhouse gas electricity sector greenhouse gas planning target range of 30-44 MMT CO2e, which will likely be reduced in the upcoming cycle of the Scoping Plan.[1]
• Additionally, the assumptions that are incorporated about the non-CAISO west will be important to the 20-year outlook. It may be helpful to hold a stakeholder workshop and work with regional stakeholders to help develop and refine these assumptions.
• CAISO should work with the joint energy agencies to ensure that the outcomes of this effort are actionable and provide efficient linkages back into regulatory processes to approve the right transmission elements in the near-term, recognizing the long time horizon associated with transmission development.

ACP-California reiterates our appreciation for the CAISO developing this proposal and encourages continued engagement with the CPUC, CEC, and other stakeholders on the items outlined in these comments to help ensure this analysis is as valuable as possible.

[1] https://ww2.arb.ca.gov/sites/default/files/2021-04/sb350-final-report-2020.pdf

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

ACP-California also appreciates CAISO discussing the Out-of-State (OOS) wind sensitivity which will be part of the 2021-22 TPP. As with the 20-year transmission outlook, it would be valuable for CAISO to provide additional information on the anticipated outputs of the OOS wind sensitivity and how the sensitivity results might be utilized/considered in the assessment of the base portfolio, which also includes OOS wind delivered on new transmission.

CAISO indicated that the analysis of out of state transmission alternatives will only include production cost simulation. ACP-California requests clarification on this and whether deliverability studies will be conducted or other metrics/analysis might be performed as part of the out-of-state wind sensitivity.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

No comments at this time

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

On May 14, 2021, the CAISO held a stakeholder call to kick-off its 20-Year Transmission Outlook as an expansion of its existing Transmission Planning Process (TPP) and to review details of the Out of State (OOS) wind sensitivity study it will be performing under the CAISO 2021-22 TPP. The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on these two topics.

BAMx Supports the CAISO’s Broad Objectives for the 20-Year Transmission Outlook Initiative

On slide #5 of its May 14^th presentation, the CAISO indicated that it is “Launching the 20-Year Transmission Outlook initiative to explore longer term grid requirements and options for meeting the State’s greenhouse gas reduction and renewable energy objectives reliably and cost-effectively.” The CAISO further explained it has opened this initiative in response to stakeholder feedback and noted that its focus will be on exploring longer term grid requirements and options to support meeting California’s objectives. However, it will not be focusing on specific project approvals, which will continue to be pursued through the existing near-term TPP. BAMx supports the CAISO’s objective of this study to engage in meaningful discussion without focusing on specific project approvals. BAMx also supports the CAISO’s plans to coordinate the 20-Year Transmission Outlook initiative with the other state agencies including the California Energy Commission (CEC) and California Public Utilities Commission (CPUC). As explained below, we recognize the critical role of the CPUC in helping Load Serving Entities (LSE) select the best options to meet the State’s goals as laid out by Senate Bill (SB) 100 (DeLeón, 2018)[2] (SB 100, hereafter).    

BAMx Recommends Utilizing the CPUC 2019 IRP Model Used for the Year 2045 As A Starting Scenario

The State’s climate goals are likely to require a transformation of the state’s electrical infrastructure including the In-State, Offshore, and OOS solar, wind, and storage resources, including the transmission facilities associated with the expanding supply infrastructure. Such large-scale planning needs to co-optimize economic, land use, transmission, and interconnection issues associated with the amount of renewables and storage needed to be online in the 20-year timeframe to achieve the state’s SB 100 goal of 100% clean electricity by 2045, as well as 80 percent below 1990 emissions by 2050. Therefore, BAMx concurs with the CAISO that a longer-term context for framing issues in the existing 10-Year Transmission Plan is necessary. One natural candidate for the starting point for study assumptions for the 20-year outlook is the year 2045 modeling of the 46MMT 2019 Reference System Plan (RSP) portfolio as shown in Table 1 below. BAMx understands that this portfolio is extrapolated from the 46 MMT by 2030 target using the same assumptions that were used for incorporating post-2030 years (into select modeling runs) to reflect achievement of the SB 100 2045 goals in the development of the 2019 RSP. There are two major advantages of using this portfolio as the starting set of study assumptions. First, this portfolio is readily available as part of the CPUC 2019 IRP. Second, it is consistent with the 46MMT portfolio (with resource build-out in 2031) that is used as the Base portfolio for the 2021-2022 TPP. This means that the resources to busbar mapping for the 20-year case would not only be consistent with the 2031 Base portfolio used in the 2021-2022 TPP, but also the efforts required for this mapping exercise would likely be manageable given the current timeline that envisions the CAISO sharing the draft results of the 20-year outlook with the shareholders by November 2021. BAMx hopes that the high-level technical analysis of the CPUC’s 2045 (or 2041 for a 20-year case) portfolio based upon 46MMT 2019 RSP will provide stakeholders with useful insights into transmission project needs and approvals beyond the 10-year planning horizon.

Table 1: Capacity Additions 46 MMT with 2019 IEPR Portfolio[3]

[1] BAMx consists of the City of Palo Alto Utilities and City of Santa Clara, Silicon Valley Power.

[2] See https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100

[3] Source: Figure 1 in the “Descriptions of the Proposed Portfolios for the 2021-2022 TPP,” CPUC Energy Division, October 23, 2020, p.B-3.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

Out of State (OOS) Wind Sensitivity Study Should Help Policy and Decision Makers Identify Realistic Assessment of Additional In-State Transmission Upgrades and Related Costs to Accommodate OOS Wind

RESOLVE,^[1]  a capacity expansion model, that is used to develop the resource portfolios by the CPUC, is a linear model that applies only an estimate of the cost on a $/kW basis of the necessary transmission to deliver the energy to the CAISO system. For example, in the Sensitivity 1 portfolio used in the 2021-2022 TPP, RESOLVE selected 1,500 MW of Full Capacity Deliverability Status (FCDS) New Mexico wind interconnected into the “SCADSNV-Riverside_Palm_Springs” transmission zone.[2] This selection assumed that the transmission costs to reach the CAISO system are approximately $121/kW-Yr.[3] The RESOLVE model does not capture in-state transmission buildout to access the OOS resources. In other words, RESOLVE might underestimate the overall transmission costs associated with procuring OOS wind. Presumably, the CAISO modeling of the Base and Sensitivity portfolios in the 2021-2022 TPP will capture these additional transmission upgrades to accommodate the OOS wind. These additional internal (gateway) upgrades need to be fed back into the CPUC IRP to accurately capture the overall transmission cost associated with the OOS wind. It is pertinent that all types of transmission costs associated with OOS wind are accurately captured to adequately evaluate the cost-effectiveness of the OOS wind resources relative to the competing In-State and other OOS renewable resources.

Need for a Framework that Ensures the Allocation of Costs of OOS Transmission Project(s) to LRAs/LSEs that Trigger the Need for Them

During the May 14^th meeting, the CAISO explained that it has determined that its economic assessment of the Base portfolio will not assess the transmission outside of the CAISO system and will assume the use of existing transmission to access OOS resources that would be procured. The Base portfolio will consider the injection of the OOS wind at either the Eldorado or Palo Verde (Pinal Central) areas and will also consider related potential internal CAISO system transmission constraints.[4] The CAISO has also indicated that it would assess as a special study a comparison of transmission alternatives for the OOS wind in the Sensitivity 1 portfolio provided by the CPUC.[5] We agree that the benefit of resources should be evaluated at the connection point to the CAISO grid.

On slide #18 of the May 14^th presentation, the OOS Wind Sensitivity study will “directly compare the CAISO ratepayers’ net payments of the selected study scenarios, and provide the comparison results to the CPUC’s IRP for future portfolio development.” Slide #16 indicates that an “(a)nalysis of the out (of) state transmission alternatives will only include production cost simulation.” We agree that the CAISO cannot necessarily determine the economics of OOS transmission. It should be determined by the OOS sellers to deliver its product to the CAISO grid. That will probably be based upon the Seller’s ability to access existing transmission or purchase transmission from developers of that transmission. To perform a systematic comparison of the transmission cost impact of the OOS transmission, the following transmission cost allocation principles must be applied. The fundamental principle for cost allocation is that it should be allocated in a way that is commensurate with benefits. In particular, the LSEs within the Local Regulatory Authorities (LRAs) approving resource procurement that are benefiting from the OOS resources should pay for that transmission delivering those resources to the CAISO border. BAMx believes that having the supplier build in its cost of delivering its product to the CAISO will also improve its ability to optimally deliver its product to the WECC-wide grid. This mechanism ensures that buyers of the remote generation output will have the transmission costs outside of the CAISO captured in the power purchase agreement (PPA) pricing. This will also help accomplish the first principle of FERC Order 1000, that is, costs are allocated in a way that is roughly commensurate with benefits. Broadly, LSEs voluntarily procuring resources using transmission should pay for the cost of delivery. One such example is the SunZia Transmission Project, accessing the New Mexico wind, which is not seeking CAISO Transmission Access Charge (TAC) cost recovery to deliver its product to the CAISO boundary point.[6] In other words, the costs of new transmission outside CAISO are captured in the PPA pricing with LSE off-takers who are procuring New Mexico wind energy and will not be borne by all the CAISO-wide TAC payers.

[1] Further information on RESOLVE is available here: https://www.cpuc.ca.gov/General.aspx?id=6442459770

[2] Source: Figure 3 in the “Descriptions of the Proposed Portfolios for the 2021-2022 TPP,” CPUC Energy Division, October 23, 2020, p.B-6.

[3] “Descriptions of the Proposed Portfolios for the 2021-2022 TPP,” CPUC Energy Division, October 23, 2020, p.B-4.

[4] CAISO May 14^th Presentation. Slide #16.

[5] Ibid.

[6] See Southwestern Power Group and Pattern Energy Group Joint Reply Comments on Administrative Law Judge’s Ruling on Portfolios for the 2021-2022 Transmission Planning Process, November 20, 2020, p.1. Southwestern Power Group (SWPG) is developing SunZia Transmission Project, a 520-mile independent transmission project to deliver New Mexico wind to Pinal Central (Palo Verde area) to serve Arizona and California markets.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

BAMx appreciates the opportunity to comment.  BAMx would also like to acknowledge the significant effort of the CAISO staff in developing the 20-Year Transmission Outlook and OOS Wind Sensitivity Study, as well as the CAISO staff’s willingness to work with the stakeholders in the process of developing the Study Plan. We believe there are many structural issues involved in the recovery of transmission costs that should continue to be examined here or in another forum while the CAISO performs the proposed production cost analysis.  We look forward to participating in such discussions prior to the CAISO presenting its study findings at the November 2021 stakeholder meeting.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

CPUC staff endorse the 20-Year Transmission Outlook study initiative. If structured optimally, this study can answer important questions. The 10-year outlook used in the Transmission Planning Process (TPP), although appropriate for the purpose of that process, has some limitations. To meet state reliability and greenhouse gas reduction goals, including SB100, it is evident that a large amount of new generation and storage resources are needed, and as a result, investments in the transmission system to deliver the electricity to load. When considering that the process for developing a new transmission line can take up to 10 years, the TPP’s 10-year outlook can result in transmission developed just in time for the need. A 20-year outlook can ensure that transmission and resource development decisions within the 10-year TPP outlook are made with the insight of resource and infrastructure needs in the following decade.

CPUC staff appreciates the CAISO holding a stakeholder call to begin a discussion on the scope of this study. We believe a lot of questions remain to be answered and we look forward to collaborating with the CAISO, the CEC, and stakeholders to answer these questions among others.

1. What specific questions do we all aim to answer? Will the end product be more qualitative or quantitative in nature? Will the study explore a range of futures? What use cases do we hope the results will serve?
2. What modeling and interagency resources will be utilized to conduct this study?
3. What inputs and assumptions will be used?
   1. Will a specific resource portfolio need to be mapped to the busbar level?
   2. What supply-side and demand-side assumptions will be considered?
      1. For example, if scenarios from the Joint Agency SB 100 study were to be used, would the core or study scenarios be used? How would other potential routes such as that explored the “CEC Draft Staff Report: California Building Decarbonization Assessment” be considered?
   3. Can a range of import levels be assessed, including a very high amount of imports that would be indicative of a larger CAISO footprint?
4. How can this study be designed to mitigate any potential circularity between the transmission limit and cost inputs used in the SB 100 scenarios and how the resulting resource portfolios will be used to study transmission need in this 20-year study?
   1. The transmission assumptions used in the SB 100 Joint Agency Report study certainly influenced the resource build out. That resource build out would shape the findings on 20-year transmission needs if it were to be used as a direct input into the 20-year outlook study. If the transmission inputs used in the SB 100 study are out-of-date, how may that influence the results of this 20-year outlook study?

CPUC Staff Straw Proposal:

CPUC staff recommend studying a range of cases representing aggressive resource build out futures. For example, if the CAISO had to prioritize one of the SB100 cases, CPUC staff would suggest prioritizing the SB 100 Study Scenario over the SB 100 Core Scenario. If that is not possible, we at least recommend studying bookend scenarios. It will be important to understand how transmission needs would vary under futures including, but not limited to, high electrification and fossil fleet retirement.

Purpose: The study should aim to answer the following questions:

1. What transmission upgrades/development will be required to meet SB 100 goals?
2. How should the 20-year transmission system outlook inform decision-making regarding what transmission and resource investments can best address identified near-term transmission needs while also staying in line with the investments that will be required in the long-term? This could include a cost-benefit analysis to determine whether it is more cost-effective to build a transmission line sooner rather than later.
   1. E.g., How do the 20-year outlook study results inform what urgent transmission projects are recommended for approval in future TPPs
3. Assess whether the current planning processes (IRP, TPP, GIDAP) can adequately serve as a bridge between fulfilling the needs identified in the 20-year outlook study and resource procurement and transmission development identified as part of the regular 10-year study process
   1. E.g., if upgrades require a development timeline of longer than 10 years, how could those upgrades be incorporated into existing processes versus needing new processes.

Use Cases:

• The end product should include quantitative information that can inform other planning processes.
  • For example, if within the TPP the CAISO needs to decide between a few policy-driven project alternatives to recommend one for approval to the Board of Governors, the 20-year study results could serve as an important source of information to determine which of the transmission projects better aligns with the trajectory to meet SB 100 goals.
• CPUC staff believe the 20-year transmission system outlook can inform the following use CPUC cases: Future IRP capacity expansion modeling; resource-to-busbar mapping; and decision-making, such as that required for procurement orders.

Final Product:

• The results of this study should be granular enough that they could serve the same purpose as TPP policy-driven sensitivity studies, which are information only, but do provide a detailed understanding of the transmission development that would be required to accommodate a specific resource portfolio.
• Ideally, the results of this study would provide a list of specific transmission projects that could be necessary to achieve SB 100. For example:
  • Transmission development required to accommodate offshore wind resources. CPUC staff anticipates that need for an increasing amount of offshore wind resources will be identified in modeling results in the decade beginning 2030.
  • Transmission development that would reduce constraints on the LA Basin local capacity area and constraints on power flow from southern to northern CA.
  • Transmission that would increase imports and access to out-of-state resources.
• The list of transmission projects could be ranked/prioritized in a variety of ways. CAISO would not need to take a stance on which prioritization is the best policy, but rather these could serve as a menu of approaches that could be used when assessing implications through various lenses in decision-making. These could include:
  • Least regrets: Identification of transmission improvements that can be considered least regrets based on the range of SB 100 scenarios (transmission that would be required under a variety of paths taken to achieve the SB 100 goals)
  • Most urgent: Based on the order of implementation - taking into consideration when transmission upgrades may be necessary based on resource build out, and expected duration of the transmission development
• It would be useful for the end product to include a roadmap that could easily be used over the coming years to assess whether we are roughly on track to meet SB 100. CPUC staff urge CAISO to consider whether the study could be conducted and the results presented in a manner that would allow for them to be updated over time.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

CPUC staff supports the CAISO’s Out of State (OOS) Wind Sensitivity Study. Transmission upgrades required on the existing transmission system + transmission development outside of CAISO + development of OOS resources are the three elements that need to be assessed before the state can understand the best holistic option for bringing OOS resources to CA load. Per our comment during the stakeholder call, we support the use of Sensitivity 1 rather than the base case for the purpose of this study because we believe it will provide more comprehensive results.

However, the base case portfolio that was transmitted to CAISO by the CPUC does include 1062 MW of OOS resources on new transmission that would be injected into the CAISO grid. There are two potential injection points and depending on at which point the resources would be injected, the implications on the CAISO transmission system can be significantly different. These CAISO system implications will be studied as part of the regular TPP economic assessment. This separate OOS sensitivity study could provide very useful information on the second important component, transmission development outside of CAISO. It is only when options on both sides of the CAISO border are considered that a full picture becomes available. For this reason, the OOS sensitivity needs to be designed in such a manner that the results can be scaled down and conclusions can also be drawn on smaller amounts of OOS resources, such as those included in the base case.

Specific questions on the scope of the study

1. What assumptions will be made about connecting the resources to the interties points studied?
2. What criteria/methods will CAISO use to specifically compare the costs, benefits, long-term risks of the two somewhat disparate approaches for bringing the selected OOS wind resource to current CAISO interties: wheeling the energy through existing OOS transmission or merchant controlled facilities or using a CAISO controlled facilities under TAC?

3. Additional comments on the May 14, 2021 stakeholder call discussion:

•  The 20 Year Outlook could assume or address the specific transmission planning benefits of a larger ISO footprint – how a more diverse set of resources available for dispatch over a wider area could enhance the planning and efficient development of new transmission and identify optimal avenues for this expansion to occur.
• The 20 Year Outlook could include graphics that clearly highlight the scale of transmission buildout that is likely to be needed. NYISO maps this kind of information on approved projects here. 

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

INTRODUCTION

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) is the California’s independent consumer advocate with a mandate to obtain the lowest possible rates for utility services, consistent with reliable and safe service levels, and the state’s environmental goals.[1] 

During the California Independent System Operator (CAISO) presentation on May 14, 2021, the CAISO requested comments on its proposed 20-Year Transmission Outlook Initiative (Initiative) by May 28, 2021.  Cal Advocates provides the following comments and recommendations on the Initiative.

The CAISO proposes this Initiative to engage stakeholders in a meaningful discussion within a less structured framework than its “tariff-based 10-Year Transmission Planning Process (TPP) that focuses on transmission project needs and approvals over a 10-year planning horizon.”[2]  The primary objective of the Initiative is to explore longer term grid requirements and options for meeting the state’s greenhouse gas reduction and renewable energy objectives reliably and cost-effectively, including inter-regional transmission project opportunities.[3]  The CAISO intends to produce a draft 20-year transmission plan by January 31, 2022 that identifies transmission projects within a 20-year planning horizon that could inform the CPUC’s Integrated Resource Plan (IRP)  and CEC’s Integrated Energy Policy Report.

For reference, in February 2021, as part of the CPUC’s IRP proceeding, the CPUC submitted a base case resource portfolio for the CAISO to evaluate in its 2021-2022 TPP.  This base case includes 1,062 megawatts (MW) of wind from out-of-state,[4] and new interregional transmission lines are needed to access these out-of-state resources.  The CPUC also submitted alternative resource portfolios to the CAISO with larger quantities of in-state renewable resources including offshore wind and batteries, and new transmission lines and/or upgrades in California are likely needed to access these in-state resources. 

 COMMENTS AND RECOMMENDATIONS

Cal Advocates is generally supportive of a long-term transmission outlook.  Cal Advocates recommends the CAISO provide cost and economic benefit information to stakeholders on the identified transmission projects needed to meet the state’s clean energy goals.  With this information, stakeholders will better understand the potential costs and benefits of additional transmission investment to meet the state’s goals.

[1] Cal. Pub. Util. Code § 309.5.

[2] CAISO 20 Year Transmission Outlook Kick-Off Meeting (Presentation), May 24, 2021, slide 6.

[3]CAISO 20 Year Transmission Outlook Kick-Off Meeting (Presentation), May 24, 2021, slide 5.

[4] CPUC Decision (D.) 21-02-008, p. 3.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

Recommendations

1. Provide a Comparative Cost Analysis for Out-of-State Transmission Projects to Determine Relative Cost-Effectiveness of Interregional Projects.

Cal Advocates recommends that the CAISO provide a comparative cost analysis of the transmission infrastructure needed to meet the state’s clean energy targets, focusing on in-state resources and with a combination of in-state and out-of-state resources.  The CAISO stated it will provide its 20-year assessment of identified interregional transmission projects at its November 2021 TPP Policy and Economic Projects stakeholder meeting.  As such, Cal Advocates recommends that the CAISO should also present the transmission costs related to meeting the state’s goals with in-state resources only at this meeting.  This information will allow stakeholders to evaluate the range of potential transmission projects to meet the state’s goals and will assist with determining the best option for California ratepayers.

2. Determine all the Economic Benefits and Beneficiaries from New Interregional Transmission Projects Consistent with Federal Energy Regulatory Commission Order No. 1000.

Per Federal Energy Regulatory Commission (FERC) Order No. 1000,

The costs of new interregional transmission facilities must be allocated to each transmission planning region in which that transmission facility is located in a manner that is at least roughly commensurate with the estimated benefits of the transmission facilities in each of the transmission planning regions.  In determining the beneficiaries of interregional transmission facilities, transmission planning regions may consider benefits including, but not limited to those associated with maintaining reliability and shared reserves, production cost savings and congestion relief, and meeting Public Policy Requirements.[1]

Consistent with FERC Order No. 1000 and the Interregional Cost Allocation Principal 1, Cal Advocates recommends that the CAISO identify the regional economic benefits generated from new interregional projects including energy, jobs, and tax benefits for cost allocation purposes.   The regional economic activity associated with large infrastructure projects such as new interregional transmission projects directly benefit local businesses and contribute to the economy of the regions the interregional project passes through,[2] and should be assessed for cost allocation purposes consistent with FERC Order No. 1000.

3. Identify the Economic Benefits from In-State Transmission Projects to Maximize Benefits to the State of California.

Any new transmission projects located in-state to the meet the state’s clean energy goals would create energy benefits in California, as well as economic benefits such as increased employment opportunities and tax base.  The CAISO should identify these benefits when assessing in-state transmission projects to determine the optimal transmission projects for California to pursue to meet its clean energy goals.

4.   Evaluate the Capacity of Proposed Transmission Projects Using Both Energy Only as well as Full Capacity Deliverability Status Resources to Maximize its Cost-Effectiveness.

Cal Advocates requests that the CAISO assess the cost and need for potential new transmission lines and upgrades based on the deliverability assessment for renewable resources portfolios with both full capacity deliverability status resources[3] and energy only (EO) status resources.  EO resources can be used to meet the state’s clean energy goals and are not as costly as full deliverability status resources,[4] for this reason Cal Advocates recommends the CAISO evaluate the proposed transmission project capacity needed to access EO resources both in-state and out-of-state to meet the state’s goals.  This evaluation will assist with determining the most cost-effective transmission projects for California ratepayers.[5]

[1] FERC, Order No. 1000, Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities, July 21, 2011, 2. Cost Allocation Principle 1-cost allocated in a way that is roughly commensurate with benefits, b. 622, Interregional Cost Allocation Principal 1. p. 448.

[2] It is common practice to include job and tax base increases as part of the overall project benefit analysis for large public projects such as bridges, airports, and port terminals.  For example, to estimate the economic activity generated by port capital projects, port authorities in the United States rely on an economic impact model commissioned by the Department of Maritime Administration referred to as MARAD Port Economic Impact kit. This kit estimates expected job and tax base increases with Port capital projects. 

[3]  There are three possible deliverability designations for resources when they interconnect to the grid: (1) Full Capacity Deliverability Status (FCDS); (2) Partial Capacity Deliverability Status; or (3) Energy Only (EO).  A FCDS designation means a generator can deliver its maximum capacity to the grid under peak load and stressed conditions. FCDS also qualifies a generating facility to offer its capacity to Load Serving Entities (LSE) to meet their Resource Adequacy (RA) requirement.  The cost responsibility for Area and Local Delivery network upgrades are initially born on generators selecting full deliverability status.  CAISO Tariff Appendix DD, September 9, 2020, 8.4 Cost Responsibility for Local Delivery Network Upgrades and 8.4.1 Cost Responsibility for Area Delivery Network Upgrades. These upgrade costs are then passed on to ratepayers after the upgrades are completed.

[4] Energy only resources are resources that are interconnected to the CAISO grid and can deliver energy only to the grid. Generators can select to provide energy only during peak conditions or just off-peak conditions.  For energy only deliverability status projects, local and area delivery network upgrades are not required, CAISO Tariff Appendix DD, 8.4. Cost Responsibility for Delivery Network Upgrades.

[5] Expedited Generator Interconnection and Deliverability Allocation Procedures (GIDAP) and Enhancements Draft Issue Paper and Straw Proposal, July 24, 2017, CASIO pp. 9-10 “it remains to be determined whether additional transmission capacity should be built to make the additional renewable capacity needed to make 50% deliverable, which impacts whether incremental renewable capacity should be procured as FCDS or Energy Only.”  

3. Additional comments on the May 14, 2021 stakeholder call discussion:

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

Comments of California Western Grid Development, LLC

On Presentation of CAISO 20 Year Transmission Outlook

Three Rivers Energy Development, LLC (TRED) is an Independent Transmission Developer that is developing the proposed Pacific Transmission Expansion Project (“PTE Project” or “PTEP”) on behalf of California Western Grid Development, LLC. (“California Western Grid”).[1]  The PTE Project is a 2,000 MW controllable HVDC subsea transmission cable that the California Independent System Operator (“CAISO”) has found will allow new and existing supply available to the Diablo Canyon 500 kV switchyard or new offshore wind to be delivered to the West LA Basin to reduce local capacity requirements, potentially allowing for the replacement of up to 1,993 MWs of thermal plant generating capacity.  The PTE Project is more fully described in Section 4.8.8 of the 2020-2021 CAISO Transmission Report issued March 24, 2021.  The PTE Project is also currently being restudied by the CAISO as part of 2021-2022 CAISO Transmission Planning Process (“TPP”).

We are pleased to submit these comments on behalf of California Western Grid with regard to the May 14, 2021 kick-off meeting for the CAISO 20-Year Transmission Outlook.

We applaud the CAISO for creating a process to plan for and address transmission needs that will be crucial for allowing the State of California to meet SB100 goals, support increased electrification and plan for reduced reliance on fossil fuels in the production of electricity.  Respectfully, however, based on the May 14 presentation, TRED is concerned that this process, and the CAISO objectives could be “too little, too late” without the changes recommended herein.

The State will be procuring tens of thousands of new renewable resources in coming years.  And by law, most existing gas plants will need to retire.  Yet, the high voltage transmission system in California has changed little in the last decade and as of the recently concluded CAISO 2020-2021 TPP almost no significant new transmission is contemplated.  As a result, the State is facing a transmission crisis which, unless acted upon immediately, will threaten grid reliability, perpetuate sub-optimal economic resource procurement decisions, and threaten system reliability. Further, the failure to act now to plan and approve new transmission will actually increase the usage of existing gas plants as demand grows which affects disadvantaged communities and minorities disproportionately.

The lack of transmission into LA and resulting requirement to rely on local capacity is particularly problematic now in light of the extraordinary State and Federal public policy actions being taken to advance an Offshore Wind (“OSW”) industry in California.  While OSW can be delivered to costal locations such as Diablo Canyon, it cannot reach LA because of the transmission constraints that define the LA Basin as a Location Constrained Resource Area (LCRA) and preclude LA from accessing or relying on clean energy, including OSW, that is located outside the LA Basin. 

This is unfortunate in light of the recent State and Federal policy efforts to develop OSW in California and for LA that desperately needs access to clean energy to reduce reliance on gas plants and the related adverse impacts on DAC’s.  CAISO approval of new transmission into LA as part of the current 2020-2021 TPP is now more essential than ever.

California badly needs a transmission roadmap identifying transmission additions that are “least regrets,” and robust under a variety of future scenarios.  With the 10-year lead time for new transmission, the CAISO and other agencies must act now to implement high voltage transmission additions while complying with SB 100—which, in part, requires prioritization in areas such as Los Angeles, which has poor air quality and is disproportionately affecting DACs. New transmission would relieve congestion into the Los Angeles Basin, allowing for non-emitting resources to displace emitting local thermal generation. 

California Western Grid urges the CAISO to:

• Create a “grid roadmap” as part of its 20-Year Transmission Outlook.  That roadmap should identify the new long-lead time, least regrets transmission that California will need to maintain reliable and economic service while enabling the goals of SB100.

• Explore “low”, “mid” and “deep” decarbonization (aggressive thermal retirement) scenarios to examine how much additional transmission development will be required under each scenario (instead of the 7.2 GW shown in slide 11 of the May 14^th Presentation). 

• Model additional transmission requirements required to support load growth associated with electrification of transportation and buildings,

• Ensure the 20-year transmission outlook is actionable.  If “least regrets” new transmission is identified in the 20-Year Transmission Outlook, , the CAISO should move to study and approve those new transmission elements as part of the 2021-2022 TPP. 

California Western Grid strongly supports a less administrative and more collaborative approach to identifying transmission additions needed over a 20-year time horizon.  This less prescriptive approach must be adopted also by State agencies to allow the CAISO and stakeholders to engage with a focus on long-term reliability requirements and ensuring compliance with State policy goals.   

The task of creating a state-wide 20-Year Transmission Outlook will likely require more than a single year.  Accordingly, the CAISO should place the highest priority on the development of a 20-Year Transmission Outlook for each area with a preference for transmission additions which would enable the greatest amount of additional renewable generation development; however, this approach should also consider regions with the worst air quality which is disproportionately impacting communities of color.  As suggested, regions such as the LA Basin would benefit from new transmission development to enable retirement of emitting resources. 

Each region will eventually need a “Plan of Service” that integrates new transmission, new local storage, zero carbon generation, and allows for the retirement of existing gas plants.   The goals must be to identify least cost transmission solutions that will strengthen the grid, enhance resource diversity and allow eventual retirement of fossil fuel thermal plants that are currently essential to local area reliability. 

LA desperately needs access to clean energy to reduce reliance on gas plants and the related adverse impacts on DAC’s.  CAISO approval of new transmission into LA as part of the current 2020-2021 TPP is now more essential than ever.

In summary, while California Western Grid is encouraged that the CAISO has taken the initiative to proactively plan for the grid of the future, we are concerned that additional steps are necessary at a minimum for California to support SB 100 goals.  The CAISO has a unique and critical role in ensuring the grid is robust to support SB 100 goals reliably and cost effectively.  We look forward to participating in the development of the CAISO’s 20-Year Transmission Outlook.

Marty Walicki

Managing Partner

Three Rivers Energy Development, LLC                            May 28, 2021

[1] As the CAISO is aware,  the PTE Project was recently transferred from Western Grid Development, LLC to California Western Grid Development, LLC.  TRED’s role as developer of the Project has not changed.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

3. Additional comments on the May 14, 2021 stakeholder call discussion:

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

To be meaningful, the CAISO’s 20-Year Transmission Outlook must be informed by CPUC planning decisions. Absent specific, actionable long-term guidance regarding the generation resources to be accessed or replaced, the 20-Year outlook will be aimless.  But, with such guidance, the CAISO can begin to approve “least-regrets” transmission upgrades that serve immediate near-term needs while also supporting long-term objectives.  

The CAISO tariff is linked to CPUC directives, not to state reports such as the SB 100 Joint Agency Report.[1]  Thus, the CPUC must first make long-term planning decisions before the CAISO’s 20-year outlook will serve any real purpose.   The CPUC could direct the CAISO to use the SB 100 Joint Agency Report as the basis for the policy-driven upgrade process, which includes a baseline and “stress scenarios” that are compared to the baseline scenario.[2]   As examples: while the SB 100 report includes 10 GW of offshore wind, different development patterns could be studied (e.g., more or less at the Central Coast vs. the North Coast), and offshore wind resources could exceed 10 GW; different combinations of gas-plant retirements could be studied; and different patterns of solar development could be studied. 

The CPUC and CAISO should consider whether an update to the 2010 Memorandum of Understanding on the Transmission Planning Process (TPP) is needed to ensure that there is a clear understanding of the relationship between the CPUC’s adoption of long-term resource planning, the 20-year transmission outlook, and the annual TPP.   

[1] Section 24.4.6.6 of the CAISO tariff provides that, for Policy-Driven Transmission Solutions, “the CAISO shall evaluate transmission solutions needed to meet state, municipal, county or federal policy requirements or directives” (emphasis added).

[2] As CalWEA has advised in the past, the CAISO should plan transmission solutions for each alternate scenario that meets the identified objective and move forward with solutions that are common to all scenarios.  This type of “least-regrets” planning will ensure that planned upgrades will serve a variety of possible resource futures.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

3. Additional comments on the May 14, 2021 stakeholder call discussion:

The CAISO should contemplate reforming its deliverability standards and transmission planning processes in response to the CPUC’s Resource Adequacy reforms.

As the CAISO is aware, the CPUC is considering major structural reforms to its Resource Adequacy (RA) program.[1] The reforms are in response to the changing nature of the grid and its resources, which in the future will revolve principally around non-dispatchable, carbon-free renewable and integration resources, namely, solar and wind energy generation resources and storage resources.  The RA reforms recognize the need to ensure that energy needs are met in all hours, rather than just one hour in each month, which is at odds with the CAISO’s current deliverability methodology that is designed around rare system operating conditions during the monthly system-peak hour.  The CAISO should consider to what extent, under CPUC RA reforms, reform of the CAISO’s deliverability standards is also needed, particularly for non-dispatchable resources and the conditions that are expected in the hours of these resources’ production.  Under the new RA framework being contemplated, wind and, especially, solar resources will largely serve to charge dispatchable storage resources when these renewables are not serving load directly, and act mainly as load modifiers.  These conditions will not be nearly as constrained as the rare system operating conditions that CAISO currently uses for its deliverability test.  The deliverability standard for dispatchable RA resources should also be modified to some extent, given greatly expanded hours of concern rather than a worst-case, peak-hour condition. 

Deliverability reforms also have important implications for transmission planning, which should be considered as part of the CAISO’s 20-year transmission outlook process as well as its annual TPP.  With deliverability reform, there could be multiple levels of deliverability and, in well-developed areas of the grid, it will be much easier for wind and solar resources to obtain the relevant level of deliverability, and thus to interconnect to the grid.  This will reduce the need for transmission upgrades that are focused on providing Transmission Planning Deliverability (“TPD”) `capacity and shift the focus of transmission planning toward (1) relieving congestion within major transmission-constrained areas to enable battery charging, delivery of clean resources, and gas-plant retirements, and (2) strengthening the grid to interconnect needed resources (such as North Coast offshore wind).

Given these important implications of RA reform, once the direction of those reforms take shape, the CAISO should initiate a forum specifically to plan for deliverability reforms and how those reforms will change the CAISO’s Transmission Planning Process.

[1] CPUC R. 19-11-009, Assigned Commissioner’s Scoping Memo and Ruling (January 22, 2020).

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

EDF-R appreciates the CAISO being proactive in assessing the long term transmission system needs to meet SB100 by performing a 20 year transmission study.  This study, if performed correctly, could provide insights into CAISO’s future transmission needs.

With regards to the planned study process, at a high level EDF-R suggests the CAISO should utilize an economic production cost model instead of power flow models.  An economic model would provide more meaningful assessment of the transmission system on an 8760 hour basis, including energy (GWH) requirements, charge/discharge patterns, emissions, imports/exports, transmission constraints, and prices. Power flow studies could be later used to supplement the economic models after a better understanding of viable scenarios and dispatch assumptions are determined on an annual basis.

• At the 20 Year Plan meeting the CAISO described this moment as a inflection point for storage, renewable integration, and reliability for the California system and EDF-R enthusiastically agrees on this point. MISO’s study results demonstrate that an integrated planning process that includes cost considerations and makes solve recommendations in each milestone is needed to solve issues related to all focus areas and to achieve desired penetration levels. https://cdn.misoenergy.org/20191115%20RIIA%20Workshop%20Item%203%20Lesson%20Learned400989.pdf slide 27. MISO’s approach ultimately identified that moving to a renewable centric grid will require transmission technologies equipped with dynamic support to move renewables from transmission constrained regions; existing infrastructure was inadequate for Energy Adequacy throughout the year; and Resource Adequacy needs were occurring at non typical hours of the day.
   
• NYISO is in the process of moving to a 20-year System & Resource Outlook which will provide energy deliverability as a metric reported for the resources on the system. This assessment will be done as an 8760-hour chronological assessment using production cost simulation tools versus snapshots assessments.  In its March 22, 2021 comments, NYISO highlights how “traditional system upgrade analysis only examines temporal snapshots of system conditions, and must be supplemented to properly assess temporal issues that should drive the extensive buildout expected in the next few decades”.

EDF-R would also like to comment that although the 20 year study is purely informative the CAISO should work with the CEC and CPUC to use the information from this study to ensure short sighted transmission decisions are not advanced from TPP or GIP studies if the 20 year plan calls for more robust expansion. While the uncertainty is higher long-term, it is not only practical but also important to look at both the medium term and longer term needs to inform transmission prioritization decisions. Ultimately, the cost of the transmission expansion is born by ratepayers and a piece-meal expansion could result in higher costs to them, in addition to market and transmission planning inefficiencies that could ensue from such decisions.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

3. Additional comments on the May 14, 2021 stakeholder call discussion:

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

Golden State Clean Energy (GSCE) appreciates CAISO undertaking this effort. We are very supportive of CAISO creating a transmission planning process with a longer outlook than the current 10-year outlook of the TPP. California absolutely needs new transmission studies to complement the SB 100 report and facilitate its long-term carbon reduction goals. In addition, CAISO should use this novel outlook to push forward a vision for the grid of the future, thereby ensuring transmission planning is not just reacting to external planning processes and resource portfolios dominated by a limited set of current technologies. California should understand the ramifications of planning a system dominated by 4-hour batteries, the risk this may create for persistent reliance on natural gas generation, and what generation and transmission alternatives can be paired to provide a different path forward that better meets the state’s carbon reduction goals.

Our comment focuses on two main points: (1) ensuring this effort can be translated into more immediate action and that this effort is actionable; and (2) scoping the outlook to consider scenarios beyond the SB 100 report’s primary cases.

I.  Ensuring the outlook is actionable and able to produce meaningful results

GSCE appreciates the limits CAISO notes regarding the purpose of this 20-year outlook – that it is not called for by the tariff but is intended to provide higher-level technical studies to test the feasibility of alternatives, rather than the detailed level of comprehensive analysis that underpins the 10-year transmission plan.[1]

However, one goal of this exercise is to inform existing planning processes that do drive results such resource development, procurement, and new transmission. Thus, the 20-year outlook must produce meaningful results that not only inform existing planning processes but also facilitate action.

The IRP and the SB 100 report are two clear areas that can benefit from additional transmission studies. The outlook also needs to inform CAISO’s TPP and produce results that TPP can use.  CAISO should consider whether revisions to its tariff-based transmission planning process are needed to incorporate the results from the 20-year outlook process. We cannot ignore least-regrets in-state transmission that can be developed now and push California forward with the infrastructure needed to achieve climate goals.

Ensuring the 20-year outlook’s results are in a form that TPP can act on will help CAISO avoid its stated intent of not conducting an academic exercise. There has been talk of the 20-year outlook creating a window into the future so we can see how the TPP’s 10-year results compare. TPP needs to be able to incorporate information that can better inform the annual plan and projects approved for construction. For example, if TPP shows a major transmission line is needed, but the 20-year finds a need for a second line (or a larger line), CAISO should assess whether there are benefits to building that second line sooner or as an upsized version of the line identified by the transmission plan. It will make the 20-year outlook actionable and meaningful for TPP purposes if CAISO considers this interface with the 20-year outlook now and revises its tariff process to accommodate the input.

CAISO could consider a process whereby the 20-year outlook has the ability to promote transmission projects to be studied in the tariff-based TPP, providing those projects with a realistic path forward in the TPP. Thus, CAISO would have its 20-year outlook process that studies several projects to meet various longer-term policy needs, and the outlook can then promote some of these projects to the TPP for the more rigorous studies needed to support their construction.

If the 20-year outlook is to promote projects to be studied and considered for construction in the TPP, it seems the TPP needs an additional method for approving such projects beyond reliability, economic, or policy needs. These three existing avenues for construction and the TPP’s 10-year outlook may not capture the value created by longer-term planning. For instance, a 20-year outlook transmission project would likely appear premature in the economic assessment, as the financial benefits that can be realized in a 20-year timeframe may not sufficiently materialize in a 10-year timeframe to justify the project based on the current economic assessment’s standards.

Considering that new criteria appears needed to recognize the advantage of building sooner and not wait for TPP’s existing pathways to select the project, potential TPP criteria for promoted 20-year projects includes ensuring the following:

• the project does not create reliability issues if brought online in this earlier timeframe;
• the project does not create negative economic impacts in the immediacy;
• the project provides an acceptable amount of certainty it will not result in stranded costs; and
• the project provides some quantifiable benefits or improved efficiencies if constructed in the earlier timeframe (i.e., permitting and construction efficiencies, cost reductions from those efficiencies, directly driving a reduction in use or early retirement of natural gas resources).

A policy-driven criterion is likely not needed because a 20-year project should be inherently policy-justified. Considering the risk of stranded costs more accurately assesses uncertainties around competing paths forward for meeting our policy goals.

II.   Framing the outlook beyond the SB 100 Core and Study cases

GSCE supports CAISO’s plan for the SB 100 report’s Base and Study cases to be the starting point for the 20-year outlook. There is a natural fit here, as the SB 100 report needs to be informed by transmission studies. We also suggest that CAISO run an updated 20-year outlook following each future SB 100 report to ensure updated resource assumptions are tested and the grid is planned around emerging technologies.

We also support CAISO conducting additional studies to more fully examine the transmission implications of scenarios besides the SB 100 report Base and Study cases. It is important for CAISO to preserve and protect its independence as the transmission planner for its grid and its ability to critically examine the assumptions that are the inputs to the planning process and modify them using its independent judgment if needed. Through its tariff, CAISO has the ultimate responsibility over resource assumptions that are assessed for transmission solutions related to policy projects.[2]  Study cases should be altered or additional scenarios created to ensure California is prepared for realistic future scenarios and that both our transmission system and resource portfolios work to produce a reliable plan for the future. 

High storage penetration, high grid charging need scenario

GSCE believes CAISO should study a high storage penetration, high grid charging need case that helps illuminate deliverability needs for solar resources and helps plan for avoiding excessive curtailment. We are concerned about ever-rising solar curtailment and believe curtailment should be an important issue in the 20-year outlook, considering the amount of solar predicted to be online by then and considering solar’s role on the grid will evolve. Battery storage already appears in large amounts throughout the SB 100 report portfolios, but sensitivities involving green hydrogen should also be considered in this proposed study scenario as a means of storing midday solar. The SB 100 report’s primary cases and hydrogen sensitivities should be assessed under a scenario where they are reliant on a substantial amount of midday grid energy to properly test future grid conditions.

In the future, California expects to have a significant amount of storage on the grid with increased amounts of lithium-ion batteries, long-duration storage, and green hydrogen facilities. While current concerns about curtailment may be mitigated by co-locating batteries with solar, as the ITC falls off or if a stand-alone storage ITC materializes, a major incentive to co-locate may disappear. There are also advantages to stand-alone storage,^[3] and some newer storage technologies may not be as feasible to co-locate with sufficient on-site generation. Thus, it does not appear to be a safe assumption that storage will largely have access to on-site generation, or that storage will be the solution to mitigate excess curtailment for nearby solar. We need to be prepared for a scenario where a significant amount of storage or green hydrolysis is heavily reliant on energy from the grid.

This scenario is important for two reasons, one being policy-driven and the other being reliability-driven. Regarding California’s policy needs, storage is not a renewable resource or even inherently carbon-free, it merely stores energy produced by other resources. The storage we see in the SB 100 report needs clean energy resources backing it, likely to be mostly reliant on inexpensive, midday solar generation. Thus, if California is grid charging its storage fleet to a significant degree, storage will only further the pursuit of state policy goals and allow California to wean off thermal resources if the solar fleet is deliverable midday.^[4]  We must ensure our storage fleet is not reliant on or prolonging the use of natural gas resources.

The argument for this scenario being important to our reliability needs is similar to the policy-pursuit argument. Storage resources are turning out to be, and likely will remain, critical resources for California’s RA program as well as provide other products needed to keep our grid reliable. To the extent California is looking to storage to provide reliability services, it needs access to energy from generation sources as an extension of RA and reliability needs. This reliability assessment should also be stress-tested with more aggressive natural gas retirement assumptions to align policy with reliability.

Now that we can see why midday solar deliverability is important if storage or green hydrogen facilities rely on grid energy to a significant degree, we can consider what the 20-year outlook needs to do to study that scenario. This comes back to the concern about rising levels of curtailment. The scenario should examine and stress-test deliverability studies that are to occur in the 20-year outlook for a number of the study cases (i.e., Base, hydrogen sensitivities), and CAISO should consider a new deliverability assessment that could properly assess the deliverability of solar for the purposes of charging stand-alone storage and facilitating green hydrogen production.

This assessment of solar’s ability to support grid-charging should also evaluate the meaning of excessive curtailment. One approach could be a cost analysis that compares what degree our solar fleet needs to overbuild to create sufficient generation redundancies in a high variable energy resource grid versus transmission that can reduce curtailment and make more use of solar resources. Overall, CAISO needs to take a look at curtailment; what would be deemed excessive curtailment; and ensure that the enormous solar fleet that is coming can be utilized by retail users chasing time-of-use rates, storage resources that are enabling state policy and ensuring reliability, and a host of areas that are newly electrifying that may shift our peak usage in unpredictable ways.

Central Valley build-out scenario

GSCE also believes there should be a scenario where a larger portion of future resources, especially solar, are developed in the Central Valley. In-state resources will be increasingly important for California as baseload capacity throughout the West retires, congestion and flow issues increase, and regional competition becomes more apparent. Within California, the Central Valley has historically been left behind in broader developmental efforts. In this instance of an evolving energy sector, development in the Central Valley carries environmental justice principles by focusing investments and decarbonization in an area that has a long history of environmental injustice.

The Central Valley offers a win-win for large scale development of renewable generation along with the necessary in-state transmission expansion that is needed to meet California’s SB 100 goals that is “smart from the start”.  The valley has ample land that is already environmentally impaired, transmission corridors that can be expanded for increased access to in-state renewables, and the ability to displace fossil generation and reduce air pollution in many disadvantaged communities. There are also overlapping policy goals with the Sustainable Groundwater Management Act given the significant acreage of agricultural lands to be retired. And the increasing pressure to reduce development on public lands to protect fragile desert ecosystems also provides support for locating more solar resources in the Central Valley and planning transmission to deliver this solar.

Lastly, more transmission through the Central Valley could help California’s wheel-through issues by increasing north-south flows, which in turn could improve the economics of in-state transmission development. Increasing in-state transmission capacity could provide numerous benefits to southern California load and the desert Southwest. The wheel-through issues before CAISO in the 2021 summer reliability initiative are not going away, and entities seeking Northwest hydro will only increase as supply in the West becomes tighter and other states also increase their decarbonization efforts.

[1] Cal. ISO, 20 Year Transmission Outlook Kick-off Meeting – Agenda, at 12, May 14, 2021, available at: http://www.caiso.com/InitiativeDocuments/Presentation-20YearTransmissionOutlook-May14-2021.pdf.

[2] See Tariff §24.4.6.6 (“The CAISO will create a baseline scenario reflecting the assumptions about resource locations that are most likely to occur and one or more reasonable stress scenarios that will be compared to the baseline scenario. Any transmission solutions that are in the baseline scenario and at least a significant percentage of the stress scenarios may be Category 1 transmission solutions.”).

[3] See Will Gorman, et. al., Are coupled renewable-battery power plants more valuable than independently sited installations?, May 2021, available at: https://emp.lbl.gov/publications/are-coupled-renewable-battery-power.

[4] See Cal. ISO, 20 Year Transmission Outlook Kick-off Meeting – Agenda, at 10, May 14, 2021 (This initiative will consider “[b]roader ranges of resource transitions including potentially more aggressive gas-fired generation fleet retirement”).

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

No comment.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

No additional comments.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

GridLiance West (GLW) supports the CAISO’s proposal to conduct a 20-Year Outlook study.  The goal of the study, in addition to supporting more specific input for the SB100 and IRP studies, should be to identify least-regrets paths, including transmission upgrades, that can be selected in the short run that would serve the long-term needs.

GLW offers suggestions for study enhancements in two major areas: The base scenario to be used and the impact of the transmission assumptions of any scenario used.

Base Scenario for 20-Year Study

We encourage the CAISO to consider what base assumption set, or portfolio(s), it uses for its study.  The CAISO included a chart on slide 11 of its May 14, 2021 presentation (shown below) that suggests that it is considering the SB100 Core and Study scenarios.

While the SB100 Core and Study scenarios were well defined and rather appropriately chosen for the SB100 study, the scenarios this time are more than 15 months old (originally developed in early 2020), and they do not reflect the reliability needs recently articulated by the CPUC in its mid-term reliability procurement process, nor do they reflect the needs that the CAISO articulated in its response to the CPUC in that same process.  These scenarios pre-date the August 2020 heat wave events, the lessons learned about the resources needed for extended severe weather, and the increasingly near-term nature of the Diablo Canyon retirement.  Thus, studying the Core or Study scenarios would produce long-term transmission insights that are in part no longer responsive to the current resource needs of the grid. The CPUC, SB100 Study Group and the CAISO could develop an alternate scenario (likely needing to be re-assessed in RESOLVE). The CAISO could alternatively use, for its 20-year study, an SB100 case that is more aligned with responsive generating resources, namely, the SB100 case seeking high flexibility and high electrification (“CEC_B_SB100_HighElec_HighFlex_20210204”). 

Irrespective of which SB100 study is used, for any portfolio that has not yet been mapped to busbars, GLW recommends that CAISO apply the methodology and mapping choices applied in the IRP to the portfolio for the 20-year study.  Additionally, GLW recommends that the CAISO consider the resources who submitted requests in Cluster 14 as informing the mapping process.

In summary, the assumption set used by the CAISO in its 20-year assessment must both recognize the carbon goal trajectory and recognize the flexibility/reliability requirements of the generation fleet.  While the SB100 cases do reflect the carbon goal requirements (some cases more accelerated than others), the primary Core and Study cases do not include the generating flexibility needs that have been since identified by the CPUC and CAISO.  GLW specifically encourages the CAISO to ensure sufficient diversity exists in the fleet; both technological diversity to complement the vast levels of California solar generation, and geographic diversity to ensure deliverability and grid resilience, especially in light of the impending Diablo Canyon retirement. Among other such study assumptions, GLW requests the CAISO ensure the 20-year study include benefits of interconnecting diverse Nevada resources to the CAISO grid.[1]

Transmission Assumptions Underlying the Scenario

GLW also feels it is critical for the CAISO, along with the CPUC, SB100 Study Group, and other stakeholders, to consider the transmission assumptions underlying the study portfolio resources.   The CAISO has traditionally provided to the CPUC transmission system limitations for use in the RESOLVE model resource build out optimizations.  In some, but not all cases these limitation assumptions include costs for exceeding existing capabilities.  It is not clear the extent to which the CAISO has verified those costs as time progresses.  These pre-defined limitations will constrain the buildout in many cases to not exceed the existing transmission capabilities.  Given that, the CAISO’s powerflow study of these portfolios will not yield transmission upgrades.  A study with such constraints already driving the resource buildout therefore would be circular and would not provide useful current information about the transmission needs of the system. GLW urges the CAISO to revisit these assumption limits and associated exceedance costs – especially in light of the more recent emphasis on additional grid resources needed to ensure resource adequacy and sufficient reserve and ramping capability. GLW is open to the exploration of how best to ensure that this circularity – concluding that no upgrades are warranted – is avoided.  One possibility is re-establish the transmission limitation data. Another option would be to relax the transmission limitations to some degree (for example a 20% increase in capabilities) and see where resources would be sited in RESOLVE to meet the scenario goals. This could be akin to the work that was performed for Policy Sensitivity Case 2 – the case testing the Energy-Only limits – conducted as part of the CAISO’s 2020 – 2021 TPP. At this juncture, however, it is very important to also revisit the full deliverability limits in light of the short supply of reliability resources. If there is information that PTOs can provide in support of this study, GLW would be pleased to provide such information.  In that case, GLW requests that CAISO clarify what information would be beneficial.

GLW also believes the study would benefit from further CAISO and stakeholder discussion about the level of export capability (i.e., the export limit) assumed over the study duration.

[1] GLW submitted into the 2021-2022 TPP an Economic Study Request for the CAISO to study a transmission system upgrade to interconnect a geothermal-rich qualified resource area in Nevada to the CAISO grid. (http://www.caiso.com/InitiativeDocuments/GLWEconomicStudyRequest-2021-2022TransmissionPlanningProcess-Feb252021StakeholderCall.pdf), pp. 7-8. 

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

GLW supports additional CAISO study of renewable resource injections to the CAISO grid. GLW looks forward to further information about the methods the CAISO will apply in study and how the resultant information will be used to choose the most beneficial in-CAISO and external transmission enhancements. 

The August 2020 heatwave events, and the impending Diablo Canyon retirement, point to the necessity for California to leverage a wide range of renewable sources.  The CPUC and the CAISO have recently clarified Resource Adequacy rules for imports. Given the reliability needs and policy goals of California, it will likely become critical to integrate significant renewable RA imports as well as significant renewable RA build out within the CAISO grid.  For these reasons, GLW is supportive of this sensitivity study.

The CAISO indicates that its base case TPP study will examine deliveries of wind at either Eldorado or Palo Verde (slide 16), and that its out of state sensitivity case will aid in choosing between New Mexico and Wyoming sources (slide 18).  GLW encourages the CAISO and other parties to recognize the need for deliveries from both locations and not just one or the other.  The more progressive SB100 cases resulted in up to 6,000 MWs of imported wind at Eldorado and 6,000 MWs of imported wind at Palo Verde.  Thus, the out of state wind case, or at a minimum, the 20-year transmission study, should explore the CAISO’s grid readiness to accept these levels of imported renewables.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

From a process perspective, for both the 20-year study and the out of state wind study GLW asks that CAISO take stakeholders’ comments, develop and post more descriptive study plans, and invite additional stakeholder comments on those study plans.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

Horizon West Transmission (HWT) applauds the CAISO’s proposal to conduct a 20-Year Outlook study to anticipate and plan for transmission needs in support of SB100. The goal of the study, in addition to supporting more specific input for the SB100 and IRP studies, should be to identify least-regrets paths, including transmission upgrades, that can be selected in the short run and would serve the long-term needs. In order to meet the 100% clean energy goal by 2045 per SB 100, California requires a significant renewables buildout. CPUC’s 2019-20 Reference System Portfolio (RSP) default scenario forecasts ~130 GW of new in-state solar and storage buildout by 2045, more than 10x the current installed solar and storage capacity. It is important to note that exponential growth in new resources is needed especially post-2030, as renewable penetration in CAISO increases and it gets harder to reliably decarbonize the remaining fossil power generation. In addition, large-scale transmission development typically has a long lead time, often spanning 10-15 years. As such, a longer planning horizon envisioned by the CAISO is critical to reliably and cost-effectively identify and develop transmission to accommodate this huge surge in renewables. Considering the long lead time for large-scale transmission development, proactive need identification and planning of new transmission is crucial for ensuring that both the renewable generation and associated new transmission can be planned, permitted, and constructed in time to meet the state’s GHG goals.

HWT offers opportunities for study enhancements in two major areas: The base scenario to be used and the impact of the transmission assumptions of any scenario used.

Base Scenario for 20-Year Study

We encourage the CAISO to consider what base assumption set, or portfolio(s), it uses for its study.  The CAISO included a chart on slide 11 of its May 14, 2021 presentation (shown below) that suggests that it is considering the SB100 Core and Study scenarios.

While the SB100 Core and Study scenarios were well defined and rather appropriately chosen for the SB100 study, the scenarios at this time are more than 15 months old (originally developed in early 2020), and they do not reflect the reliability needs recently articulated by the CPUC in its mid-term reliability procurement process, nor do they reflect the needs that the CAISO articulated in its response to the CPUC in that same process.  These scenarios pre-date the August 2020 heat wave events, the lessons learned about the resources needed for extended severe weather, and the increasingly near-term nature of the Diablo Canyon retirement.  Thus, studying the Core or Study scenarios would produce long-term transmission insights that are in part no longer responsive to the current resource needs of the grid. The CPUC, SB100 Study Group and the CAISO could develop an alternate scenario (likely needing to be re-assessed in RESOLVE). The CAISO could alternatively use, for its 20-year study, an SB100 case that is more aligned with responsive generating resources, namely, the SB100 case seeking high flexibility and high electrification (“CEC_B_SB100_HighElec_HighFlex_20210204”). 

Irrespective of which SB100 study is used, for any portfolio that has not yet been mapped to busbars, HWT recommends that CAISO apply the methodology and mapping choices applied in the IRP to the portfolio for the 20-year study.  Additionally, HWT recommends that the CAISO consider the resources who submitted requests in Cluster 14 as part of the mapping process.

In summary, the assumption set used by the CAISO in its 20-year assessment must recognize both the carbon goal trajectory and the flexibility/reliability requirements of the generation fleet, including portion of the resources that should be fully deliverable for resource adequacy.  While the SB100 cases do reflect the carbon goal requirements (some cases more accelerated than others), the primary Core and Study cases do not include the generating flexibility needs that have been since identified by the CPUC and the CAISO.  HWT specifically encourages the CAISO to ensure sufficient diversity exists in the fleet; both technological diversity to complement the vast levels of California solar generation, and geographic diversity to ensure deliverability and grid resilience, especially in light of the impending Diablo Canyon retirement.

Transmission Assumptions Underlying the Scenario

HWT also believes it is critical for the CAISO, along with the CPUC, SB100 Study Group, and other stakeholders, to consider the transmission assumptions underlying the study portfolio resources.  The CAISO has traditionally provided to the CPUC transmission system limitations for use in the RESOLVE model resource build out optimizations.  In some, but not all cases these limitation assumptions include costs for exceeding existing capabilities.  It is not clear the extent to which the CAISO has verified those costs as time progresses.  These pre-defined limitations will constrain the buildout in many cases to not exceed the existing transmission capabilities, and therefore the CAISO’s powerflow study of these portfolios will not yield transmission upgrades.  A study with such constraints already driving the resource buildout would be circular and would not provide useful current information about the transmission needs of the system. HWT urges the CAISO to revisit these assumption limits and associated exceedance costs – especially in light of the more recent emphasis on additional grid resources needed to ensure resource adequacy and sufficient reserve and ramping capability. HWT is open to the exploration of how best to ensure that this circularity – concluding that no upgrades are warranted – is avoided.  One possibility is to re-establish the transmission limitation data. Another option would be to relax the transmission limitations to some degree (for example a 20% increase in capabilities) and see where resources would be sited in RESOLVE to meet the scenario goals. This could be akin to the work that was performed for Policy Sensitivity Case 2 – the case testing the Energy-Only limits – conducted as part of the CAISO’s 2020 – 2021 TPP.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

HWT supports additional CAISO study of renewable resource injections to the CAISO grid. HWT looks forward to further information about the methods the CAISO will apply in study and how the resultant information will be used to choose the most beneficial in-CAISO and external transmission enhancements. 

The August 2020 heatwave events, and the impending Diablo Canyon retirement, point to the necessity for California to leverage a wide range of renewable sources.  The CPUC and the CAISO have recently clarified Resource Adequacy rules for imports. Given the reliability needs and policy goals of California, it will likely become critical to integrate significant renewable RA imports as well as significant renewable RA build out within the CAISO grid.  For these reasons, HWT is supportive of this sensitivity study.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

From a process perspective, for both the 20-year study and the out of state wind study, HWT asks that CAISO take stakeholders’ comments, develop and post more descriptive and defined study plans during this 2021-2022 planning cycle, and invite additional stakeholder comments on those study plans.

HWT thanks the CAISO for the opportunity to provide these comments on the May 14, 2021 Stakeholder Call as input to the process.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

IEP supports CAISO’s 20-Year Transmission Outlook. This effort will provide an important forum for stakeholders to examine the costs, benefits, and feasibility of various transmission options before CAISO reaches the 10-year mark, at which point CAISO must commit to authorizing investments in new transmission paths and major upgrades of existing infrastructure.  Having a process to preliminarily examine a large set of transmission options could enhance the efficiency of transmission planning by paring down less viable options and narrowing CAISO’s attention in the Transmission Planning Process on projects that are more feasible and more likely to cost-effectively enable the build-out of the enormous portfolio of renewable energy that California will need to decarbonize the grid. To support the timely development of cost-effective transmission solutions, CAISO should consider expanding the role of independent transmission companies.  

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

IEP agrees that CAISO should study scenarios for bringing in additional out of state wind from both the Northern Rockies and the Southwest. CAISO should also study scenarios to access other resources outside the CAISO territory, such as evaluating new transmission needed to import geothermal energy from the Imperial Irrigation District or from other states. As CAISO begins to evaluate longer-term transmission options, IEP encourages CAISO to coordinate closely with other WECC balancing area authorities, including California’s non-CAISO publicly-owned utilities (POUs), to find opportunities for shared investments that can help meet the needs of load-serving entities in the CAISO territory as well as the needs of non-CAISO POUs and other jurisdictions.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

LS Power supports CAISO’s 20-Year Transmission Outlook initiative. California must bring online a significant amount of new clean energy resources to meet its SB 100 and greenhouse gas reduction goals, and it is critical that the appropriate transmission infrastructure is in place to deliver these resources. Given the long lead-time needed to plan, permit, and construct transmission infrastructure, it is important for CAISO to start looking beyond its typical 10-year transmission planning cycle to evaluate infrastructure needs. LS Power looks forward to working with CAISO and the other agencies and stakeholders in this initiative.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

LS Power supports with caveats the Out-of-State (OOS) Wind Sensitivity Study that CAISO is planning for the 2021-22 TPP. The proposed study is a step in the right direction, but LS Power suggests a few key adjustments must be made in order to appropriately evaluate policy, economic and reliability benefits of new transmission that will be required to bring diverse OOS renewable resources to California load.

• CAISO must conduct an OOS wind and new transmission study for the Base Case portfolio, not just the 38 MMT Sensitivity portfolio, to avoid delays in connecting diverse renewable resources to California.
  • The CPUC’s Base Case Portfolio identifies a clear regional policy need for OOS wind and CAISO should evaluate transmission alternatives to deliver those resources to CAISO. The CPUC’s final decision D.21-02-008 on Transferring Electric Resource Portfolios to CAISO for 2021-2022 Transmission Planning Process includes 1062 MW of OOS wind in the Base Case Portfolio. As noted in the CPUC’s Attachment A Modeling Assumptions for 2021-22 TPP[1] document that was transmitted to CAISO with information on Base Case and Sensitivity portfolios, and as confirmed by CPUC staff at the May 14 CAISO stakeholder meeting, the IRP process assumed new OOS transmission will be required to deliver the 1062 MW OOS wind to California.
    • At the May 14 meeting, CPUC staff also emphasized that they hope that the OOS study will be designed in such a manner that the results can be used or scaled down to inform decisions on resource plans and the injection points used in the plans (i.e., not just for information purposes).
    • It is also LS Power’s understanding that the Pacific Northwest OOS wind on existing transmission (noted on slide 17 of the May 14 presentation) is not included in the 1062 MW to be delivered at Palo Verde or Eldorado.
  • LS Power supports CAISO conducting a study of the 3000 MW of OOS wind identified in the Sensitivity 1 scenario, but reiterates that the need for a robust study for the Base portfolio should be a high priority. While a Sensitivity analysis can provide great insights into incremental benefits of additional OOS wind, our understanding is that Sensitivity studies are typically done for informational purposes only. CAISO will miss out on an opportunity to recommend any new OOS transmission projects for approval this cycle if it only conducts a Sensitivity study. This will delay getting access to OOS wind and developing the new transmission required to help mitigate shutdown of Diablo Canyon and OTC replacement in the near future.  Every year of delay brings increased costs and risks for California ratepayers and increases the odds of firm load shedding such as what California witnessed in Aug 2020.

• CAISO’s Tariff provides the authority to evaluate and approve OOS transmission projects if they meet a regional need.
  • CAISO’s Tariff section 24.4.6.6 defining Policy-Driven Solutions notes that “CAISO will determine the need for, and identify such policy-driven transmission solutions that efficiently and effectively meet applicable policies under alternative resource location and integration assumptions and scenarios, while mitigating the risk of stranded investment. The CAISO will create a baseline scenario reflecting the assumptions about resource locations that are most likely to occur and one or more reasonable stress scenarios that will be compared to the baseline scenario.”  Further, it lays out criteria to consider, including commercial interest in the applicable geographic area (e.g. interconnection queue), results and identified priorities of the CPUC’s resource planning process, and the potential for a particular transmission solution to provide access to resources needed for integration. CPUC indicated the locations for potential injections of these OOS renewables and concluded that CAISO should rely on other regions’ interconnection queues to demonstrate commercial interest in and viability of particular geographic areas. 
  • The only way to develop a transmission plan that is responsive to the CPUC policy guidance is for CAISO to evaluate interregional projects which help meet CAISO regional needs (i.e., policy, reliability, and/or economic) in the Base Case scenario, and preserve the ability to recommend these projects for approval in the TPP should they prove efficient and effective in meeting applicable policy needs.[2]
  • CAISO has the authority to approve OOS transmission projects if they meet a regional need - CAISO’s Tariff section 24.13 states that the CAISO may consider potential interregional solutions to regional needs during Phase 2 of the Transmission Planning Process, and this is not limited to only economic, or only reliability, or only policy needs.

• CAISO should conduct a robust study of OOS projects including the combined reliability, policy, and economic benefits, as directed by the CPUC.
  • In the May 14 meeting, CAISO noted it plans to only do a production cost simulation when evaluating the transmission alternatives to deliver OOS wind for the Sensitivity 1 portfolio. LS Power supports this production cost analysis but we believe a more robust analysis should be conducted for the 1062 MW in the Base Case portfolio. As currently proposed, CAISO is not planning to conduct reliability, economic and public policy studies for the OOS wind in the Base Case portfolio, other than analyzing the need for any transmission upgrades downstream of CAISO boundary injection points (Eldorado & Palo Verde). We believe this approach will fall short as it will not provide a complete picture of the cost of the needed transmission from resource locations to CAISO load and all the benefits such new transmission can provide to CAISO ratepayers. Absent this information, CAISO, CPUC, and CEC policy makers will not be able to understand all benefits new OOS transmission can provide in addition to enabling delivery of diverse renewable resources. Additionally, without a complete analysis CAISO Board will not be able to confidently evaluate decisions on approving new transmission in this year’s TPP cycle; such decisions are time sensitive given the upcoming capacity shortages in the next five years.
  • Conducting a robust combined benefits study for the Base Case portfolio is also in line with CPUC’s directive and expectations. The CPUC's final Decision included several statements about the need to consider reliability, policy, and economic benefits combined, not just in silos as separate studies, when evaluating policy projects to recommend for approval. The Decision's Finding of Fact 6 states, "Transmission solutions to support both policy and reliability goals combined with ratepayer savings can provide significant benefits to California." Additionally, Conclusion of Law 3 states, "Based on analysis conducted by Commission staff thus far, utilizing the electric resource portfolio that meets the 46 MMT GHG emissions target as a reliability and policy-driven base case in the TPP will likely result in the need for new transmission investment to make the portfolio deliverable. Transmission projects should be evaluated for reliability, policy, and economic benefits."

• California needs 11.5 GW of new resources by mid-decade and OOS resources can be online to serve this need.
  • In recent IRP comments on mid-term reliability, CAISO emphasized the need for resource diversity to meet net demand peak and procuring at least 10,000 MW of capacity to be online by 2026.[3] The CPUC just issued a proposal with an even higher amount of 11,500 MW of new capacity by 2026. Additionally, as recently announced, CAISO’s interconnection process will be significantly delayed for Cluster 14 and CAISO plans to skip the next year’s new project cluster. Given the need for more capacity and in-state delays on infrastructure to connect new resources, it is more critical than ever to consider OOS transmission that can deliver diverse resources over a firm transmission path in time for Diablo Canyon replacement. If the state wants to limit reliance on gas-fired resources to meet net demand peak needs, improving access to diverse OOS resources is crucial given the significant capacity required to maintain mid-term reliability

• CAISO should limit its OOS wind/transmission study to transmission projects that submitted a study request and requested cost allocation in the current Interregional planning cycle, with a focus on projects in advanced development stage that can be placed under CAISO Operational Control in mid-decade to support the new resource need.
  • LS Power recommends that CAISO focus its evaluation of transmission alternatives on the applicable projects that have been submitted in the interregional transmission planning (ITP) process for cost allocation in either this current cycle or at most the last few cycles. If any new transmission projects are already being developed under the merchant transmission framework and have not requested cost allocation from CAISO through the ITP process, these should not be included in CAISO’s study for reasons noted below.
  • When evaluating all ITP projects, CAISO should develop metrics that help stakeholders better understand benefits of these transmission projects. In addition to quantifying economic, policy and reliability benefits, some additional metrics for CAISO to weigh in are the ability for the transmission project to help meet new resource needs by 2026, whether a project is a network facility or a radial generation intertie (gen-tie) line, whether a project will rely on any firm transmission rights outside CAISO BAA footprint to be able to deliver Full Capacity Deliverability OOS resources to CAISO boundary and if so what is the cost of these transmission rights and the risk of this transmission getting curtailed.
  • Regarding Merchant transmission projects, we recommend not to include these for CAISO study. CAISO does not have control over timeline of development or likelihood of success of such projects and once built CAISO will have no operational control over these projects. In addition, the useful life of such projects is hard to access and it typically depends on the length of resource contracts for which the transmission projects are being built and uncertainty associated with use of this transmission after resource contracts expire. Therefore, it would be difficult to quantify benefits of these projects to CAISO ratepayers and/or rely on those projects for delivery of OOS wind. In contrast, a transmission project in the TAC is fully integrated into the CAISO system and can be accessed for the life of the project (typically 50+years). For these reasons we recommend merchant projects should not be included in the CAISO study.
  • If CAISO does consider merchant transmission projects, it should look at more than just the dollar cost amount of new transmission line. It should also include the cost of any third party transmission service outside CAISO BAA a new line will need to be able deliver to CAISO. Plus is there any risk associated with curtailment of transmission that would make the resources undeliverable to CAISO. Also, CAISO should look at whether a new project is a networked line or a radial gen-tie line? A network line integrates into the electric grid and enables access to existing and new resources from multiple geographic locations, which can provide additional reliability, policy, and economic benefits. A network line could relieve congestion on parallel paths, improve regional resource and load diversification, and could improve the ability to serve evening net peak demand. A gen-tie line, in contrast, connects a specific project(s) and does not have the ability to access other grid resources, may not be used as an export path, and cannot provide further system reliability and resiliency benefits to CAISO since CAISO will have no operational control.  A network line, depending on its location, can also enable west-wide EIM benefits in both directions.

• CAISO should provide a stakeholder update to the OOS wind study before evaluating begins.
  • LS Power requests that CAISO provide another stakeholder update to its OOS wind study after consideration of comments. In the May 14 stakeholder call, CAISO provided a high level proposal of its study, but parties raised several important questions as well. The next step in the timeline CAISO showed is for an analysis provided in November. However, by that time it would likely be too late to request any further changes to the analysis. It would be helpful for CAISO to provide another update before the study begins to improve transparency on the analysis and criteria it will use.

• SWIP-North can enable access to diverse OOS renewables. SWIP-North’s benefits should be correctly analyzed in this OOS study.
  • LS Power supports CAISO’s proposal to study Southwest Intertie Project-North (SWIP-North) for the OOS study. SWIP-North is the final link of a new transmission path that would create ~1050 MW of incremental transmission capacity from Idaho into California for CAISO. The completed path will allow California to access diverse renewable resources from the Pacific Northwest and ensure reliability by relieving existing congestion that limits critical imports. SWIP-North would physically connect Midpoint 500 kV substation in Idaho Power to Robinson Summit 500 kV in Nevada, enabling transfer through to Harry Allen 500 kV, a CAISO boundary substation.
  • SWIP-North will provide reliability, policy, and economic benefits for California, such as:
    • Provide access to 1062+MW of out-of-state (Idaho) wind, which the CPUC has identified in their Base Case Portfolio as necessary to maintain grid reliability and meet greenhouse gas goals. The project will also facilitate access to other diverse Pacific Northwest renewables. According to a recent Brattle Group study, net public policy-related costs of Idaho wind to CA customers are $20/MWh lower than CA solar due to higher energy and capacity value, and GHG reduction benefits.[4]
    • Access to ~1050 MW incremental firm transmission capacity to improve reliability and resource adequacy in time for Diablo Canyon's retirement in 2024.
    • Relieves economic congestion by offering a parallel path to Northern California interties, thereby enabling increases in low-cost imports from the northwest and providing CAISO ratepayers savings of up to $105 Million/year.[5] For example, SWIP-North would help alleviate economic congestion at the CA-OR border that limited CA's ability to import critical energy resources during the August 2020 extreme heat event. 
    • Provides a pathway to export excess Southern California solar to the North, reducing renewable curtailments, and capturing Energy Imbalance Market benefits.
  • LS Power also recommends ensuring that the following changes are included for the SWIP-North study in this TPP cycle. Not including these will artificially reduce economic benefits of this project.
    • Include all facility upgrades required to interconnect SWIP-North in the economic study model, including required upgrades to the existing ON Line 500 kV Transmission Line (Robinson Summit to Harry Allen). Without these upgrades the current ON Line path will be limited to 1000 MW and this will artificially limit flows on SWIP-North. Modelling these upgrades will increase the transmission capability of this path to over 2200 MW.
    • Remove the $9/MWh NVE wheeling charge that is hardcoded in the ADS PCM model. This charge is not applicable to SWIP-North pursuant to the FERC-approved Transmission Use and Capacity Exchange Agreement (TUA) between LS Power affiliates and NVE, the SWIP-North project includes a capacity entitlement over the SWIP-South/ON Line project at no additional capital cost and free of any wheeling charges.
    • Correctly enforce COI path limits to capture only 3200 MW CAISO's share of COI/PACI in the study model, instead of the full 4800 MW limit of this path.
    • Quantify additional benefits of SWIP-N as outlined in CAISO's TEAM methodology - Capacity Benefits, Renewable curtailment reduction benefits and diversity benefits. A recently conducted study by Brattle Group[6] shows these benefits as well, which we recommend CAISO use as guiding points to estimate these benefits.
    • Details of LS Power recommendations are in the Appendix 1 and 2 of our TPP Study Plan comments.
  • LS Power looks forward to working with the CAISO transmission team to correctly analyze SWIP-North for this OOS study, and requests the opportunity to validate key assumptions for accuracy prior to model runs commencing.

[1] Modeling Assumptions for the 2021-2022 Transmission Planning Process, 2/9/2021 Final version, e.g. pages 12 and 13. https://www.cpuc.ca.gov/General.aspx?id=6442466555

[2] CAISO Tariff section 24.4.6.6 “Policy-Driven Transmission Solutions”, section 24.4.3 “Phase 2 Request Window”, and section 24.13 “Interregional Transmission Proposals in the Regional Process.” https://www.caiso.com/Documents/Section24-ComprehensiveTransmissionPlanningProcess-asof-Aug12-2019.pdf

[3] CAISO comments on ALJ Ruling in R.20-05-003, March 26, 2021 https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M374/K638/374638000.PDF

[4] “SWIP-North Benefits Analysis.” February 2021. Michael Hagerty, Johannes Pfeifenberger, and Evan Bennett. The Brattle Group. https://brattlefiles.blob.core.windows.net/files/21438_swip-north_benefits_analysis.pdf

[5] Ibid

[6] “SWIP-North Benefits Analysis.” February 2021. Michael Hagerty, Johannes Pfeifenberger, and Evan Bennett. The Brattle Group. https://brattlefiles.blob.core.windows.net/files/21438_swip-north_benefits_analysis.pdf

3. Additional comments on the May 14, 2021 stakeholder call discussion:

None at this time.

Thank you for your consideration of our comments. LS Power believes all stakeholders will benefit from access to results from a timely study of OOS transmission to deliver Base Case resources.  We hope this analysis will allow the more timely completion of efficient and effective transmission to meet the state’s mid-decade, reliable capacity addition requirements.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

We appreciate the foresight of the CAISO in initiating its new 20-year planning process to identify long term transmission needs.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

3. Additional comments on the May 14, 2021 stakeholder call discussion:

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

Ormat Nevada Inc. supports the CAISO 20-year transmission outlook initiative, as integration of renewables and achieving the California initiatives of 100% renewable and carbon-free grid by 2045 will require additional review and study of the transmission system beyond the current 10-year scope of the TPP in order to identify and construct the necessary transmission infrastructure.

Ormat would like to stress the importance of starting with the SB100 framework (as indicated in Slide 11) for the study assumptions for the 20-year transmission outlook that includes up to 2.3 GW of geothermal generation.  As the CAISO knows, the reference system portfolios provided by the CPUC for the TPP the last several years have included a range of differing amounts of geothermal from 2 GW down to zero.  Ormat believes that in order to successfully achieve current procurement requirements as well as future energy goals and greenhouse gas reductions, it is important not to exclude specific resources from the study assumptions of the 20-year transmission outlook as well as to consider a diverse set of locations for each of the resources.  It is important to include all resource types in the framework as different resource types have different resource area locations both within the state of California and inter-regionally that inclusion in the study framework will better outline the transmission infrastructure required for integration.  Further, Ormat believes that there could be great value in identifying inter-regional transmission opportunities and enhancing coordination throughout WECC when going through the 20-year transmission outlook.

Ormat will engage in the future Stakeholder initiatives to ensure that geothermal is represented in the study assumptions for the 20-year transmission outlook.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

None.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

Ormat Nevada Inc. wants to commend the CAISO for recognizing that analysis outside of the 10-year TPP needs to be completed in order to achieve the state’s goals.  Thank you for the time presenting the overview of the process and allowing stakeholders the opportunity to provide input.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

PG&E welcomes the CAISO’s 20-Year Transmission Outlook effort. PG&E agrees that while there is not currently a CAISO tariff-mandated or other direct ‘home’ for this analysis, it may nevertheless prove highly valuable in informing long-term resource and infrastructure planning for California and the West. PG&E applauds the CAISO’s effort to increase its active participation in the CPUC and CEC proceedings related to resource and load planning, both through this initiative and in other ways.[1] PG&E supports the stated objective of this initiative, which is to develop long-term transmission information that will support and inform the CPUC’s IRP and the Joint Agencies’ SB100 efforts.[2] As the scope and specific output(s) of this initiative are made clear, PG&E supports the CAISO’s stated intent to repeat this longer-term planning look at regular intervals going forward.[3] Below is a summary of our general comments:

• The CAISO’s contribution to the SB100 effort and Joint Agency Report should include a comprehensive system reliability assessment that considers the deliverability of flexible resources and an energy sufficiency test—including a full loss of load study and production cost modeling.
• The CAISO should provide estimated costs for new transmission investment as an input to the RESOLVE model in order to identify a least-cost portfolio and better estimate of the customer rate impact should the SB100 resource portfolio scenarios require additional transmission investments to maintain reliability or for resource deliverability.
• PG&E recommends that the CAISO consider climate resilience (e.g., wildfire) in the 20-Year Transmission Outlook.
• PG&E recommends that the 20-Year Transmission Outlook identify the needs and possible solutions for load centers impacted by the retirement of gas-fired generation.
• PG&E recommends that the CAISO clarify and establish a mechanism on how the 20-Year Transmission Outlook should be considered in the Transmission Planning Process (TPP).

PG&E acknowledges the critical role the CAISO plays in supporting the reliability and affordability of California’s energy system. The CAISO’s contribution to the SB100 effort and Joint Agency Report should include a comprehensive system reliability assessment that considers the deliverability of flexible resources and an energy sufficiency test—including a full loss of load study and production cost modeling—to ensure that the energy needs of the system are met at all times. Without this critical planning input, neither the CPUC nor the CEC would be able to confirm that the resource portfolios adequately address operational reliability needs nor would they have visibility into incremental costs associated with necessary infrastructure upgrades.

Long term load forecasts, with increased multi-industry electrification

PG&E supports the CAISO’s plan to consider the impacts of long-term load forecasts on transmission upgrade requirements.  PG&E suggests that the analysis include, but not be limited to the drivers below:

• Impact of increased electrification, such as charging stations in urban areas and along major highways
• Charging needs of storage resources
• Any identified areas with heavy load growth beyond organic growth

These factors may affect the size, location, and hourly profile of future load, and therefore transmission requirements. Multiple load scenarios may be developed with different emphases.

Load should be reliably served from both capacity (MW) and energy (MWh) perspectives. For example, the transmission system should have sufficient capacity to charge storage resources during off-peak hours for them to provide generation capacity in peak hours. It is important that the long-term forecasts utilized in this process seek to realize the full value of storage capacity resources by evaluating transmission upgrades that ensure full charging capability rather than curtailment as the primary solution. In addition, the charging demand from electric vehicles may coincide with storage charging demand, and therefore stress the transmission system in conventional off-peak hours. Such impacts on load profiles should be considered to ensure reliability can be maintained in all hours.

More aggressive gas-fired generation retirement

With a more aggressive gas generation retirement plan plus additional load growth, load centers that currently rely on local gas generation (e.g., Greater Bay Area, Kern) are expected to require transmission upgrades. These upgrades are needed in both the bulk and local transmission systems to deliver power from resources to hub substations of the load centers, and then to load customers. PG&E recommends the 20-Year Transmission Outlook identify the needs and possible solutions for load centers impacted by the retirement of gas-fired generation. This should support both the orderly retention of the resources with the right reliability characteristics and retirement/replacement of those resources in a manner that minimizes costs to customers.

Interregional opportunities

PG&E supports further analysis to ascertain the least cost, best-fit resources and associated bulk electric system buildout needed to meet California’s long-term resource and climate goals. PG&E believes interregional opportunities—including expanding transmission to access high-quality interior wind resources—are a promising area of focus for this study.  PG&E is optimistic that the CAISO’s efforts will improve planning awareness and insights regarding the realistic necessity of infrastructure build out and costs to accommodate out-of-state resources. Currently, PG&E believes that the CPUC’s IRP analysis does not effectively consider transmission costs, potentially discounting holistic procurement costs of out-of-state resources. It will be useful to improve this awareness as an input to resource planning activities including the costs of external transmission.

Starting Assumptions

PG&E supports the CAISO’s initial recommendation to rely on long-term resource portfolios developed in conjunction with the Joint Agencies’ SB100 workshops.[4] PG&E notes that the SB100 resource portfolios were developed to assess a variety of pathways to achieving SB100, but none were intended to be prescriptive. This initiative offers an opportunity to refine and provide additional insight into the Joint Agencies’ modeling. PG&E recommends that the CAISO perform analyses on multiple of the SB100 portfolios to better assess the costs and feasibility of future resource build scenarios for California.

Coordination with the Transmission Planning Process (TPP)

As part of this initiative the CAISO has an opportunity to significantly improve the reliability assessment of the CPUC’s future IRP portfolios; support the affordability assessment of the different scenarios developed in the SB100 Joint Agency Report and the CPUC IRP studies; and enhance the effectiveness of existing planning and procurement processes.[5] Transmission needs and related transmission costs for resource planning are insufficiently refined in existing modeling efforts.

Specifically, the CAISO should use this initiative to chart a path for incorporating the following items into its coordination of the TPP and California’s resource planning activities:

• Comprehensive reliability assessment of resource portfolio scenarios:
  • A resource adequacy assessment to determine whether the system has sufficient resources to meet load under various likely system conditions given transmission constraints or limitations.
  • An operational reliability assessment to determine whether changes in the resource mix (resource types and locations) create operational reliability challenges.
• Estimated cost of new transmission: If the SB100 resource portfolio scenarios require additional transmission investments to maintain reliability or for resource deliverability, the CAISO should provide estimated costs for new transmission investment as an input to the RESOLVE model, thereby supporting a key planning objective to identify a least-cost portfolio and better estimate of the customer rate impact.
• Magnitude of renewable generation curtailment due to transmission congestion: Coupled with the identification of local transmission that should be developed, this initiative should work to improve the inputs around transmission costs associated with delivering energy in Renewable Energy Transmission Initiative Competitive Renewable Energy Zones (RETI CREZ), and the impact of transmission upgrades on renewable energy curtailment. More generally, the CAISO, CEC, and CPUC’s various planning processes need to better account for transmission constraints and costs across the entire system to ensure that selected resources can meet load where and when it is needed. The CPUC’s RESOLVE model does not include a detailed transmission representation. The CAISO has modified its Deliverability Assessment and now uses Off-peak Deliverability Status (“OPDS”) for resources to assess the CPUC’s transmitted portfolio. By using OPDS, the CAISO may significantly increase congestion and curtailment risk for both new and existing resources. This initiative should estimate the curtailment or congestion of renewable resources and evaluate the benefit and costs of mitigating that curtailment or congestion with transmission expansion, either as a direct product of this initiative or as an input to resource planning activities. The CAISO should provide clarity around the magnitude of transmission congestion-related curtailment from the TPP which will help fine-tune the RESOLVE model GHG emission estimates.
• CPUC guidance on transmission-considerations for new resources or existing resource retention: The CAISO indicated that this initiative’s 20-year horizon was meant to avoid questions regarding the orderly retirement of existing thermal generation. Nevertheless, PG&E suggests that the CAISO can provide valuable planning insights regarding areas where new resources might be sited or existing resources might be retained, given limitations facing new transmission build out.
• Minimum generation requirement for local areas, at the sub-regional level (e.g., Bay Area or North/South of Path 26): The CAISO should include in this initiative and within TPP studies an analysis to determine what minimum generation requirement there may be for transmission reliability and provide this information to refine IRP modelling to ensure that the dispatch of resources reflect how they will be operated by the CAISO and planned at the right location. For example, California’s transmission and resource planning processes need to consider transmission inter-zonal upgrades (e.g., to Path 26) to ensure that energy can flow effectively within the CAISO operating footprint, particularly as the IRP procurement continues to favor resource development in a specific region while load must be served across the system.

[1] 20-Year Transmission Outlook Kick-off Meeting Presentation May 14, 2021, slide 9.

[2] See slide 6.

[3] As represented during the May 14, 2021 stakeholder call.

[4] See slide 11 and as represented during May 14, 2021 stakeholder call.

[5] See planning and procurement process feedback loop shown on slide 7.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

 PG&E supports the out-of-state wind sensitivity study focused on transmission expansion to access Wyoming and New Mexico wind resources. The opportunity for these resources to lower the cost of reaching California's clean energy goals is promising and worthy of more detailed analysis, such as the CAISO proposes here. Part of this analysis must provide better information about transmission costs associated with accessing out-of-state resources. PG&E looks forward to engaging in the CEC workshops in June.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

PG&E recommends that the CAISO consider geologic and climate resilience (e.g., earthquakes and wildfires) in the 20-year transmission outlook. Among the myriad risks from climate change, the CAISO and stakeholders should consider reliability risks associated with wildfires when identifying future transmission requirements and comparing transmission alternatives.

PG&E recommends that the CAISO clarify and establish a mechanism for integrating the analysis in this 20-Year Transmission Outlook (and successor long-term outlook initiatives) into the shorter-term planning of the TPP. For example, a 20-year outlook may be considered when comparing various alternatives of nearer-term solutions, so the nearer-term solution is either an intrinsic part of the 20-year plan or accommodates a least regret path between the nearer-term TPP and longer-term resource and transmission expectations identified in the 20-Year Transmission Outlook.

PG&E expects this initiative will be valuable for transmission and resource planning. PG&E suggests that the CAISO help set expectations for the frequency this effort will occur alongside future TPPs.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

Overall

SDG&E supports CAISO’s decision to launch the 20-Year Transmission Outlook initiative, as it allows for better planning around the potential challenges associated with California’s ambitious environmental goals. SDG&E encourages CAISO to keep the inputs (e.g., resource portfolio and load forecasts) of this study up to date as further analyses are performed by the joint agencies. Furthermore, SDG&E encourages the CAISO to have future cycles of this study every time one of the state agencies (CPUC, CEC, CARB) publishes a new 2045 portfolio.

Diversity of Location Should Be Studied as a Scenario to Inform the IRP and the SB 100 Proceeding

The 20-year Transmission Outlook presents a good opportunity to analyze the resource mix of the future. However, it is also important that resources are mapped throughout the system commensurate with commercial interest. This can be done by using a resource allocation ratio based on the CAISO’s Generation Interconnection (GI) Queue to assign resources to each TAC area. This would provide a measure of “commercial interest” that could represent interconnection demand in the future. Additionally, mapping resources throughout the CAISO footprint, in one of the scenarios, might also help the CPUC and CEC have information regarding the benefits of having a resilient resource portfolio and transmission system. The current SB 100 portfolio allocates most of the resources in the northern part of the CAISO system. This lack of resiliency and diversity of location can pose a serious threat to the reliability of the entire CAISO system if a major natural event, similar to the ones that happened in the past, occurs in northern area of the CAISO system.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

CAISO Should Capture the Benefits of Other Planning Regions and Explore Cost Sharing Mechanisms Options with the CPUC

CAISO should look to assess and highlight the Production Cost benefits that out of state large-scale transmission projects would bring to neighboring regions. Benefits that commonly accompany such large-scale transmission projects include increased transfer capability, decreased congestion, and increased reliability.  If CAISO can use this study to demonstrate these benefits, it may increase interest and support amongst neighboring entities. Furthermore, having this information available will help the CAISO and the CPUC determine if these projects could benefit or should be part of a cost sharing mechanism with other regions.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

Southern California Edison (SCE) appreciates the opportunity to comment on the CAISO’s 20-Year Transmission Outlook initiative and commends the CAISO for its proposed increased coordination efforts with the CEC and CPUC to meet California’s objectives to vastly increase renewable energy and drastically reduce greenhouse gas (GHG) emissions.  Leveraging on the progress already achieved with respect to the renewable resources fleet interconnected to the CAISO controlled-grid, the State’s ambitious goal of powering all retail electricity sold in California with renewable and zero-carbon resources by 2045 requires such coordination. As described during the CAISO’s stakeholder call on May 14, the 20-Year Transmission Outlook, and its focus on exploring longer-term grid requirements and options for meeting the State’s GHG reduction and renewable energy objectives reliably and cost-effectively, will help inform, as well as receive input from, efforts in the CEC’s Senate Bill 100 and IEPR, CPUC’s IRP, and CAISO’s 2021-2022 TPP.  This type of cross-pollination of information across state agencies is essential to enable California to meet its renewable energy and GHG objectives by 2045 in a cost-effective and reliable manner. 

            Based upon SCE’s Pathway 2045, both in-state and out-of-state transmission have been identified to deliver the bulk of future renewables to urban centers, however these upgrades have yet to be identified and approved within past CAISO 10-year Transmission Plans due to relatively low resource portfolios from the CPUC IRP.  As a result, the scope and costs of transmission required to support the scaling of energy necessary to achieve 2045 goals is speculative.  Given, the coordination of procurement of resources with the long lead time transmission needed to integrate the resources, SCE believes the CAISO’s 20-Year Transmission Outlook initiative is timely and that it should be repeated periodically every few years. SCE also encourages the CAISO adopt a “future-back” approach, identifying a set of objectives for the 20-year time frame and work backwards from that objective to understand timing and changes required to achieve the objective.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

The development of new, regional transmission infrastructure will be critical to realizing the availability of out-of-state resources to support 20-year out-of-state goals.  Regarding the development of interregional transmission, the CPUC, CAISO or CEC should take the following actions:

• Identify critical transmission paths, with the necessary upgrades and methods-of-service specified, so that projects can be expeditiously selected, properly managed, and executed in a timely manner.
• If California wishes to partner in several regional transmission development plans, then it is recommended the appropriate subject matter experts and state representatives (i.e. CPUC, CAISO) participate in the development and approval of these projects backed by clear policy and mandates supporting project execution.
• Identify the necessary upgrades for integration and delivery, beyond delivery to California’s border, into the California transmission system along with the appropriate cost recovery mechanisms.
• Evaluate the regulatory and permitting requirements to support the construction of these projects to minimize execution time and expense to implement. For example, seek alignment with DOE/FERC designation of national interest electric transmission corridors.
• Explore converting existing transmission corridors to HVDC/HVDC super-grid as an option for increasing transmission capacity.
• The CAISO should encourage discussion and information exchange with other entities within the WECC so that the region has greater confidence that independent plans will work constructively for the benefit of the entire region.[1]

• [1] SCE was a signatory to the February 2021 Western Electricity Industry Leaders (WEIL) Group Position Statement on the Western Interconnection Regional Electricity Dialogue (WIRED) effort that included a recommendation to establish a formal multi-state process to allow for the exchange of information on integrated resource planning and transmission planning.  The Statement included leadership of Arizona Public Service, Avista, Balancing Authority of Northern California, Bonneville Power Administration, California Independent System Operator, Idaho Power, Los Angeles Department of Water and Power, NV Energy, NorthWestern Energy, PacifiCorp, Portland General Electric, Powerex, Public Service Company of New Mexico, Puget Sound Energy, Salt River Project, San Diego Gas and Electric, Southern California Edison, Tri-State Generation and Transmission, Western Area Power Administration, and Xcel Energy.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

In its “Transmission Capability Estimates as an Input to the CPUC IRP Portfolio Development”  Whitepaper and most recent 2020-2021 Transmission Plan, the CAISO has published transmission capability estimates for renewable zones, which is a key input for the CPUC’s development of IRP portfolios.  For the 20-year Transmission Outlook, SCE supports the continued use and expansion of these transmission capability estimates to ultimately provide insights as to what transmission alternatives will be required to deliver incremental resources from various locations (both in-state and out-of-state) as well as their associated costs.  For mapping of future resource portfolios, SCE also encourages the continued use of the IRP-to-TPP bus-bar mapping methodology captured in “CPUC Staff Proposal: Methodology for Resource-to-Busbar Mapping & Assumptions for the 2021-2022 TPP” and encourages a public process to solicit feedback from stakeholders regarding scenario inputs and assumptions. SCE respectfully requests that the final bus-bar allocations of portfolio resources be made publicly available. 

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

Southwestern Power Group (SWPG) and Pattern Energy appreciate CAISO’s efforts to develop a 20-year transmission outlook, a broader, more forward-looking evaluation that will be needed to achieve California’s mid- and long-term policy objectives.

1. SWPG and Pattern observe from slide 11 Starting Point for Assumptions that the CAISO currently intends to use the SB100 “Core” and “Study” scenarios as the basis for the 20-year analysis. We note that these cases are roughly 15-months dated and predate both the August 2020 Stage 3 emergency events and the recent CPUC Mid-Term Procurement ruling and impending decision, and therefore may not be an appropriate study basis. We instead recommend a more aggressive SB100 case such as the case assessing high electrification and high flexibility.
2. It would be helpful for CAISO to issue a draft study plan for its 20-year Transmission Outlook for increased transparency. The study plan could be analogous to a draft TPP plan but much abbreviated. We also suggest that CAISO include in its draft study plan the GHG and reliability metrics and/or output that will be evaluated in the study. (Note if CAISO is already planning to issue a 20-year study plan this comment can be disregarded.)

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

First off, SWPG and Pattern appreciate the CAISO’s transparency regarding this Out-of-State (OOS) Wind Sensitivity Study as these resources are critical to diversifying the state’s energy portfolio and therefore must be studied as accurately as possible. We offer the following comments and observations:

1. Slide 18 states that the OOS Wind Sensitivity Study will directly compare CAISO ratepayers’ net payments of the selected study scenarios. Subsequent slides describe the study approaches for both Wyoming and Idaho wind (slide 21) and New Mexico wind (slide 22). Based on the modeling injections points listed on the slides it appears that the WY/ID wind cost analysis will include costs of new transmission whereas the NM wind cost analysis will not since the injection point is the Pinal Central 500 kV bus which is in Arizona. 

As the developer and owner of the SunZia Transmission Project, SWPG agrees with the proposed handling of new transmission costs as indicated by these assumptions (subject to comment on Pinal Central in subsequent point below). Unlike the projects listed on slide 19 SunZia is not being proposed as an interregional transmission project (ITP) and therefore its costs would not be borne by CAISO ratepayers through the Transmission Access Charge (TAC). Instead the costs of new transmission to deliver the NM wind to Pinal Central will be borne by the load-serving entities (LSEs) who take delivery of the output, which raises the question of how CAISO will study the costs of NM wind deliveries on an “apples-to-apples” basis with those of the other regions. SWPG and Pattern simply wish to raise the point that whatever cost assumptions are used should be made transparent and with opportunity for stakeholder input. 

b. Since CAISO plans to model NM wind as delivered to the Pinal Central 500kV bus, whereas the CPUC’s TPP Portfolios base case considers injection at Palo Verde (from slide 16), it raises the question of how CAISO will assess the costs for firm transmission service from Pinal Central to Palo Verde and how the ratepayer impacts will be assessed. As with the costs of the SunZia project, SWPG and Pattern expect that the costs for firm transmission service from Pinal Central to Palo Verde will likewise be borne by the LSEs taking delivery of NM wind through SunZia and not recovered through the TAC. Here again SWPG and Pattern simply raise the point that whatever cost assumptions are used for firm transmission service should be made transparent and with opportunity for input in order to achieve the most accurate results possible. Alternatively and to simplify the study, since SWPG and Pattern can confirm that adequate available transfer capacity (ATC) exists for firm delivery to Palo Verde CAISO could model the injection at Palo Verde instead of Pinal Central while accounting for the costs of the firm transmission service.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

SWPG and Pattern have no specific comments on the May 14 stakeholder call, but as a procedural matter request that the CAISO post recordings of future stakeholder calls in this effort. With the volume of concurrent proceedings underway it is not always practical for stakeholders to attend such calls live and therefore a recording would be appreciated.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

TransCanyon is fully supportive of the CAISO initiative to perform a 20 year transmission outlook in parallel with the CAISO 2021-2022 Transmission Planning Process. Given the extremely aggressive requirements of California Senate Bill 100 (SB100) passed in 2018 which requires 100% of electric energy to be produced by renewable and zero-carbon resources by 2045, and the long lead time for transmission development; transmission planning looking only ten years ahead is not going to produce the robust transmission system necessary to effectively and efficiently facilitate the achievement of these goals.

TransCanyon agrees with the use of the SB100 central core and study scenarios which will likely show the need for significant regional transmission additions both within and outside the CAISO so support delivery of up to 11.9GW of out of state wind.

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

TransCanyon is also supportive of the Out of State Wind Sensitivity Study that will be performed as part of the 2021-2022 Transmission Planning Process. As there is significant out of state wind from Wyoming and New Mexico included in the base portfolio to determine policy-driven transmission needs, it is not sufficient to determine the adequacy of just the CAISO transmission system to deliver these wind resources by modeling the resources at the point of injection to CAISO (Eldorado or Palo Verde). Rather the resources need to be modeled where they will be geographically developed and transmission from these sources and locations to the CAISO must be studied as well.

3. Additional comments on the May 14, 2021 stakeholder call discussion:

As sponsor of the Cross-Tie Transmission Project (Cross-Tie), TransCanyon is pleased to see that the CAISO will analyze benefits to California ratepayers that will be realized from this project allowing the wind from Wyoming to cross the PacifiCorp system to the Planned 500kV Clover station, utilize Cross-Tie to move to the NVE system at the 500kV Robinson Summit and through the NVE system to the CAISO. TransCanyon has submitted Cross-Tie as an Interregional Transmission into the CAISO as well as WestConnect and Northern Grid (formerly NTTG) for the past three biennial planning cycles. If the CAISO needs any additional data about Cross-Tie for modeling purposes please let us know.

1. Provide your organization’s comments on the 20-Year Transmission Outlook topic, as described in slides 4-13:

Valley Electric Association, Inc. (VEA) supports the CAISO’s preparation of the 20-Year Outlook study.   From VEA’s perspective, the benefits of performing the study include: (1) the ability for the CAISO to identify transmission upgrades that are necessary to accommodate the large number of renewable projects that would like to connect to the CAISO Grid in the VEA/GridLiance West footprint, and (2) the ability for the CAISO to identify the transmission upgrades needed to support Maximum Import Capability (MIC) sufficient for VEA’s and other LSEs’ Resource Adequacy (RA) import amounts driven by the expansion of renewable RA supplies outside of California. 

VEA requests that the study identifies transmission upgrades that will be needed in the long run, but also those upgrades that would be beneficial to approve now. 

At this time, the CAISO has not published much information about the study assumptions; therefore, VEA strongly encourages the CAISO to develop and vet a study plan for this work.  To be useful, the study must use an appropriate study case.  The CAISO pointed in its presentation to the two SB100 cases – the Core and Study cases.  However, the CAISO should evaluate a new resource mix given the August heat events and the increased need for additional 24x7 and shaping resources to meet intermittent resource ramping needs and to aid in replacing the baseload capacity of Diablo Canyon.

In response, VEA suggests that the CAISO consider using a case such as the High Flexibility scenario[1] from the SB100 study work, instead of the Core or Study scenarios.  Such a case reflects a portfolio that better complements intermittent solar and wind. 

This case will need to include mapping to specific busbar locations, and VEA encourages the CAISO to apply the mapping processes used in the IRP process, including allowing for stakeholder input.  As part of this mapping process, VEA encourages the CAISO to make use of the siting locations included in the resources within Cluster 14. 

VEA also seeks more information from the CAISO about the extent to which the CAISO may test new transmission capabilities that it provided to the CPUC in 2019.  Without expanding these transmission limits, the study cases may likely be self-limiting and not produce portfolios that represent the least cost build out solutions, especially in cases where the CAISO did not provide cost estimates for increasing transmission capacity.

[1]E.g., CEC_B_SB100_HighElec_HighFlex_20210204

2. Provide your organization’s comments on the Out of State Wind Sensitivity Study, as described in slides 14-23:

VEA supports additional CAISO study of renewable resource injections to the CAISO grid. If for no other reason, VEA seeks to import resources needed to serve its load and RA needs at Mead, and Eldorado and Palo Verde imports affect common constraints with Mead deliverability.[1]  It will benefit VEA and other LSEs for the CAISO to ensure the grid is reinforced sufficiently to accept those wind deliveries and still support other energy and RA import needs at Mead and other import locations.  

Several scenarios in the SB100 modeling suggest that there will be as much as 12,000 MWs of wind energy – 6,000 MWs from Wyoming, conceivably through Eldorado, and 6,000 MWs from New Mexico, through Palo Verde – all affecting the same Lugo-area constraints that seem to limit MIC at Mead. 

VEA urges the CAISO to plan for these wind deliveries and plan grid enhancements accordingly such that when these renewable resources are delivered, they do not simply offset other high-quality (e.g. flexible) renewable imports already under contract to CAISO LSEs.  To address this potential problem, the CAISO study should consider all external RA resources that are currently contracted to LSE’s, including non-jurisdictional LSEs like VEA who are not considered in the CPUC IRP portfolio process.

[1] For example, the CAISOs Maximum Import Capability Enhancement Straw Proposal shows the Eldorado and Mead are both impacted by constraints at Lugo (p. 10). 

3. Additional comments on the May 14, 2021 stakeholder call discussion: