Comments on Transmission Call 6/17

1. Please provide a summary of your organization’s comments regarding the ISO's presentation on Oakland Area Transmission Reinforcement:

The Bay Area Municipal Transmission Group (BAMx)[1] appreciates the opportunity to comment on the material presented at the CAISO 2023-2024 Transmission Plan—Extension (Extension, hereafter) stakeholder meeting on June 17, 2024. BAMx understands that the CAISO is considering the additional transmission upgrades in the area to supply the anticipated increased load in Oakland without relying on the local thermal generation.

A considerable analysis is needed to determine the preferred project to address the Oakland area transmission needs, which has yet to be performed. This includes a comparison of several 115 kV and 230 kV alternatives in terms of their scope and costs.[2] Therefore, BAMx supports the CAISO’s proposal to continue the assessment of the Oakland area reinforcement in the 2024-

2025 transmission planning process. This additional time will provide the stakeholders with the necessary time to perform independent evaluations.

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

[2] Extension, p.8.

2. Please provide a summary of your organization’s comments regarding the ISO's presentation on Short Circuit Mitigation for Miguel 230 kV Circuit Breakers:

San Diego Gas and Electric’s (SDG&E) request window application[3] for the Short Circuit Mitigation for Miguel 230 kV Circuit Breakers did not entail installing a 3-Ohm series reactor on TL23026 Silvergate –Bay Boulevard 230 kV line, which will be located at the Bay Boulevard substation as proposed by the CAISO. It appears that the other element of the proposed project, i.e., opening the Miguel 230 kV CB 6X, leads to additional issues requiring installing the proposed series reactors. The CAISO’s June 17, 2024 presentation lacks crucial details. BAMx, therefore, requests the CAISO to include those details in the CAISO Board approval of the project. We also request the CAISO to provide the detailed cost estimates, by component, of the Short Circuit Mitigation for Miguel 230 kV Circuit Breakers, which have increased from the $1 million initially proposed project by SDG&E to $51 million.

[3] 2023 TPP Projects – SDG&E, p.18, September 27, 2023.

3. Please provide a summary of your organization’s comments regarding the ISO's presentation on Short Circuit Mitigation for Imperial Valley 230 kV Circuit Breakers:

BAMx notes that the scope for the proposed Short Circuit Mitigation for Imperial Valley 230 kV Circuit Breakers[4] is different from the one included by SDG&E in its request window application. BAMx requests the CAISO provide a detailed cost estimate for each component of the proposed project

[4] Extension, p.15.

4. Please provide any additional comments on the 2023-2024 Transmission Planning Process:

BAMx appreciates the CAISO staff’s efforts and due diligence in keeping the stakeholders updated on the additional proposed analysis and recommended approvals as part of the 2023-2024 TPP.

1. Please provide a summary of your organization’s comments regarding the ISO's presentation on Oakland Area Transmission Reinforcement:

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) provides these comments on the California Independent System Operator’s (CAISO) stakeholder meeting on the 2023-2024 Transmission Planning Process: Transmission Plan Extension on June 17, 2024.  Cal Advocates is an independent ratepayer 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]

Cal Advocates has no comments on the June 17, 2024 Oakland Area Transmission Reinforcement project update at this time.

[1] Pub. Util. Code, § 309.5.

2. Please provide a summary of your organization’s comments regarding the ISO's presentation on Short Circuit Mitigation for Miguel 230 kV Circuit Breakers:

Please refer to our response to questions 3.

3. Please provide a summary of your organization’s comments regarding the ISO's presentation on Short Circuit Mitigation for Imperial Valley 230 kV Circuit Breakers:

Cal Advocates recommends greater transparency on the project scopes, which are provided in CAISO’s Transmission Planning Process.  Specifically,  Cal Advocates requests that the Participating Transmission Owners (PTO) provide detailed cost estimates for all proposed projects when they are presented for approval.  With detailed project cost estimates, stakeholders would be able to compare the project costs to alternatives as well as PTO Per Unit Cost Guides, to verify whether the costs are reasonable or require further explanation.  

Cal Advocates makes this request based on its experience reviewing PTOs final project proposals.  For example, during the 2023-2024 Transmission Plan Extension stakeholder meeting on June 17, 2024, San Diego & Electric Company (SDG&E) explained that the proposed Short Circuit Mitigation for Imperial Valley 230 kV Circuit Breakers and for the Miguel 230 kV Circuit Breakers involve new breakers.[1]  However, new breakers are not listed among the project scope components for these proposed Short Circuit Mitigation projects.[2], [3]  SDG&E only provided the total estimated project costs for its Short Circuit Mitigation projects and not the cost for each project component.  SDG&E also revised its project scope for the Short Circuit Mitigation projects from the September 27, 2023 proposals, to include different equipment and other substation changes that increased costs.  Yet, the revised June 17, 2024 project scope still does not include the new breakers that are also needed for this project. The Miguel 230 kV Circuit Breaker project description explained that the original solution had drawbacks.  However, the Imperial Valley 230 kV Circuit Breaker project description did not explain the need for changes and the project cost increased by $2 million. 

If stakeholders had a detailed cost estimate for each project, they could know with confidence that all capital costs are accounted for in the total project cost estimate.  Additionally, stakeholders would better understand the reason for the project scope revisions and project selection.  Providing only the total project cost just does not provide sufficient information to understand SDG&E’s project development and selection process.

[1] These projects are the Miguel 230 kV circuit breaker project and Imperial Valley 230 kV circuit breaker project. 

[2] Reliability Assessment Recommendations – SDG&E Area Addendum to 2023-2024 Transmission Plan (Presentation), CAISO. June 17, 2024 at p. 11.

[3] Reliability Assessment Recommendations – SDG&E Area Addendum to 2023-2024 Transmission Plan (Presentation), CAISO. June 17, 2024 at p. 13.

4. Please provide any additional comments on the 2023-2024 Transmission Planning Process:

Cal Advocates also recommends CAISO develop a project cost review process similar to Southwest Power Pool’s (SPP) to manage project costs and ensure these costs remain just and reasonable.  For 11 years now, SPP’s project review process has tracked project costs starting from the project estimation phase to construction on a quarterly basis.  If a project’s quarterly report reveals that its cost exceeds 10% of the original project cost, the project is reviewed to ensure that the escalations are appropriate.[1]  If a project cost exceeds 20% of the original cost estimate, SPP’s Board can suspend the project or order the project not be constructed.[2]  SPP officials have stated that this process has resulted in projects completed at or below their original cost estimates.[3]

The Federal Energy Regulatory Commission (FERC) also recently issued Order No. 1920, which requires transmission providers to reevaluate long-term regional transmission projects if the reported costs of a previously selected facility “significantly exceed” the cost estimate used to select the project.[4]  To this end, transmission providers are required to have a mechanism to track project costs so that transmission providers can determine if the reported cost for a selected project will exceed the approved cost.[5]

Since it is an accepted practice for transmission providers to track project costs, CAISO should track the costs of approved regional transmission projects and reevaluate projects if their reported costs are 10% or greater than approval costs.  This recommendation is consistent with SPP’s business practice which FERC approved.[6]  Having estimated costs for each project component should also assist with project cost tracking.

[1] Statement of Paul Suskie at the FERC Technical Conference on Transmission Planning and Cost Management. Docket No. AD22-8-000. Lines 5-10 on page 188 of the transcript, available at https://www.ferc.gov/media/transcript-docket-no-ad22-8-000.

[2] “If [the project’s costs] reach above 20 percent out of bandwidth, then the Board of Directors can order that the project be suspended and no longer constructed, and that has happened in our footprint.” Statement of Paul Suskie at the FERC Technical Conference on Transmission Planning and Cost Management. Docket No. AD22-8-000. Lines 10-13 on page 189 of the transcript.

[3] Statement of Paul Suskie at the FERC Technical Conference on Transmission Planning and Cost Management. Docket No. AD22-8-000. Lines 14-18 on page 188 of the transcript.

[4] Building for the Future Through Electric Regional Transmission Planning and Cost Allocation, FERC Docket No. RM 21-17-000, Order No. 1920, May 13, 2023 at pp. 740-741, section 1049.

[5] Building for the Future Through Electric Regional Transmission Planning and Cost Allocation, FERC Docket No. RM 21-17-000, Order No. 1920, May 13, 2023 at p. 744, section 1052.

[6] Southwest Power Pool, Inc. Open Access Transmission Tariff Business Practices, Southwest Power Pool Staff, November 5, 2018 at pp. 110-111.