Comments on November 18, 2021 stakeholder meeting

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

ACP-California appreciates the work CAISO is doing on the 20-year Transmission Outlook and looks forward to seeing the results of this high-level, forward-looking analysis and working with CAISO the CPUC and other stakeholders to begin to incorporate the longer-term transmission requirements of the system into the more formalized IRP and TPP processes. The results of the 20_year Outlook analysis are likely to show a substantial amount of major transmission is necessary to achieve a resource portfolio consistent with SB100 and the state’s goals. The results should serve as a helpful indication of the scope of transmission investment that will be necessary to continue to reliably serve customers and achieve GHG reduction goals. And they should reinforce that there is a need to continue to increase and accelerate transmission project approvals not only for the longer-term needs of the system but also to serve mid-term reliability procurement needs. And, it will be critical to use the 20-Year Outlook as a platform to begin the transition to long-term procurement-transmission planning. Thus, it will be important to:

• Begin exploring the hypothetical transmission solutions identified in the 20-year Outlook as early as possible;
• Incorporate the results of this longer-term study into actional processes (such as the IRP and TPP); and
• For stakeholders to recognize the critical reliability benefits that transmission solutions will provide in a clean energy future.

After seeing the draft results of the 20-Year Outlook, we look forward to working with CAISO and other stakeholders to consider refinements and next steps for this type of analysis and how it can be turned into more actionable results to put the state on a proactive path to authorizing transmission and procurement, which will provide ratepayer and reliability benefits.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

ACP-California appreciates the opportunity to comment on the materials presented at the November TPP stakeholder meeting. This section of our comments focuses on suggestions related to the OSW sensitivities, in order to help make these studies as useful as possible to stakeholders. Additionally, in this section of comments, ACP-California recommends that CAISO further consider accelerating transmission upgrades, as it outlined it was considering during the September stakeholder meeting. We look forward to continuing to work with CAISO on the 2021-22 TPP and in reviewing the results of the 20-Year Transmission Outlook.

OSW Sensitivities

CAISO has undertaken substantial efforts to complete the OSW sensitivities, along with other studies in the TPP, and it is important that those efforts result in the most useful, understandable, and digestible results possible, such that they can be utilized in other processes. In prior comments on the 2021-22 TPP, ACP-California had requested that CAISO provide additional specificity around the anticipated outputs of various sensitivities. That insight was requested because, ultimately, the value of the substantial study work that CAISO is undertaking will be determined by the outputs that are presented, the clarity of the results, and the depth of the recommendations that CAISO makes following conducting these study activities.

For the OSW sensitivities, it would be particularly helpful for CAISO to use its study work to make several conclusions and recommendations and produce key outputs, including:

• Provide high-level capital cost estimates for the various transmission solutions that have been studied:
  • During the November call, CAISO indicated it is already planning to include this information, but it is important to highlight the critical nature of providing these cost estimates for ongoing work on OSW planning.
• Summarize the total relative curtailment of each potential transmission solution to deliver OSW
• Summarize the relative total congestion costs associated with each potential transmission solution (including the relative differences in overall production costs of each case/transmission solution analyzed)
• To the extent possible, provide recommendations on preferred transmission solutions to integrate the OSW portfolios communicated by the CPUC and the reason for their selection as the preferred transmission option
• Additionally, if CAISO has suggestions on different transmission strategies for accommodating OSW, such as highly economic approaches to accommodating OSW in different quantities than what the CPUC transmitted in these portfolios, providing those insights in the Draft Transmission Plan would be would very helpful

We look forward to the finalization of the OSW sensitivities and greatly appreciate the substantial work and effort that CAISO has put into these studies, and other sensitivities already.

Finally, while not directly applicable to the TPP, it is important to continue to highlight the need to address the unique situation related to OSW and the retirement of Diablo Canyon Nuclear Power Plant and the associated deliverability rights in the region. It will be important to seek to preserve the transmission deliverability rights in this area for OSW generation in the central coast area as a matter of state policy. In the context of the IRP, TPP, and Interconnection Process Enhancements initiative it will be necessary to continue to explore methods by which this type of state policy preference may be communicated and by which the unique nature of the deliverability rights in this area (and their interaction with OSW resources) can be recognized. ACP-California looks forward to continuing to engage with CAISO, the CPUC and others as this issue continues to be discussed.

OOS Wind Study

Regarding the OOS wind study, ACP-California appreciates the amount of rigor put into the study and the breadth of options considered and offers a few areas for improvement. First the capacity factors used in the PCM (shown on p. 124) are substantially lower than those used in the CPUC’s RESOLVE model, which would artificially suppress the economic benefits and therefore should be corrected. Second, ACP-CA believes that all the regions studied offered diversification benefits to the grid and therefore CAISO may want to study cases with wind from all 3 regions, after adjusting for the capacity factors. Third, it was unclear what conclusions or recommendations can be drawn from the study so CAISO may want to clarify what next steps are being considered.

Advancing Transmission Upgrades to Address Procurement Mandates, Reliability, and Policy Requirements

ACP-California strongly encourages CAISO to further consider advancing several “least-regrets” transmission upgrades as part of the 2021-22 TPP, as was discussed during the September stakeholder meeting. Based a brief discussion during the most recent (November) stakeholder meeting, we understand CAISO may now only considering advancing one of the projects outlined in September, plus a circuit-breaker project suggested in comments from SCE.[1] ACP-California appreciates that CAISO is looking at advancing these two projects, but also strongly encourages CAISO to further explore the approval of additional projects on that list in this TPP cycle. Doing so would help to enhance and protect provision of reliable service to customers and would help advance the interconnection of clean the resources needed to meet growing demands and to account for retirement of gas resources and the Diablo Canyon Nuclear Power Plan. And, given that the question will not be whether, but how many upgrades and new transmission projects are required[2], it is prudent to begin advancing these least regret options as quickly as possible.

The need to move transmission to approval as expeditiously as possible is particularly acute given the pervasive delays in transmission development that are occurring on the CAISO system, even after the approval of a project by CAISO. As one example, the Bellota – Warnerville 230kV project was initially approved in 2013 with a scheduled in service-date of 2018. Today, the project is targeting an online date of 2023 – a nearly five-year delay in its online date, which is delaying clean energy resources from coming online and delivering their output to load. Given that magnitude of delays that are being experienced after project approval, the state and its customers cannot afford to further delay transmission approvals to bring more clean resource adequacy capacity online. Doing so could drag out the resource shortages and associated reliability issues that have plagued California for the last two years.

Furthermore, not advancing transmission upgrades is particularly problematic in the face of major retirements, such as the Diablo Canyon Nuclear Power Plant, that are slated to happen relatively soon. Not pushing forward with approval of these, relatively minor, transmission upgrade projects could make it nearly impossible to bring online the necessary resources to replace Diablo by the time it retires, potentially creating reliability gaps. Rather than continue the “just in time” (or too late) transmission approvals, CAISO should consider the value of initiating the process of progressing these transmission upgrades through the permitting, design and approval processes ahead of significant system resource retirements. And, conversely, should the potential reliability risks of not moving them forward this year.

We understand that some of the projects included in the September meeting slide deck for potential accelerated approval, would not fully “unlock” the Full-Capacity Deliverability Status (FCDS) capacity listed in the CAISO’s tables and transmission capability estimates, due to the existence of “nested constraints” (i.e., other constraints that may need to be mitigated to make the capacity fully deliverable once the constraint at hand is addressed). This may be seen by some as a reason to forego advancing these projects towards approval in the 2021-22 TPP. But it is unwise to continue to put off approval of, relatively minor, upgrades that will almost certainly be needed in the coming years, simply because other projects may also be needed to fully deliver resources to load and those other projects would not also be approved in this cycle. ACP-California suggests that it would be beneficial to get a “head-start” on advancing some of these projects now, so that the transmission developers can better allocate personnel and other resources to the design, permitting, and construction processes for these projects. Waiting to advance all necessary transmission upgrade projects in “one batch” could lead to a logjam on the PTO and CPUC permitting and approval side of transmission advancement, which may exacerbate already existing delays in bringing transmission online. We encourage CAISO and other stakeholders to consider the value of proactively spacing the approval of transmission upgrades by advancing some of these projects forward in the 2021-22 TPP.

As the development of the 20211-22 Draft Transmission Plan moves forward and additional consideration is given to advancing these upgrades, we encourage CAISO and other stakeholders to consider not only the costs of advancing these projects (some of which are <$50M) but also the risks. There are substantial risks associated with continuing to delay transmission approvals to allow various IRP-TPP cycles to run their course, resulting in additional years of delay to transmission upgrades and delivery of clean resources that are even more urgent in light of upcoming retirements and already existing delays in bringing transmission upgrades online. These risks should be seen as additional justification for CAISO to move forward with the accelerated approval of the upgrade projects presented in September.

[1] The circuit-breaker replacement project suggested by SCE would not increase deliverability of clean energy resources but it would advance circuit breaker replacements that going to be needed and, if not advanced, could result in delays to the interconnection of renewable resources in the Antelope area.

[2] For instance, the 20-Year Transmission Outlook will likely identify substantial new transmission needs, many of which will needed soon that 20 years out. And a recent analysis by the Clean Air Task Force (CATF) and Environmental Defense Fund (EDF) found that substantial increases in transmission will be needed to decarbonize, even with optimistic assumptions regarding distributed resource development (available here: https://ww2.arb.ca.gov/sites/default/files/2021-11/EDF-sp22-electricity-ws-11-02-21.pdf).

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

• Arevia Power observed that CAISO did not state how it was going to make a policy decision for 1062 MW of OOS Wind. CAISO conducted a very high level economic analysis comparing three transmission projects, but it lacked any recommendation from CAISO staff to regulators.  Based on the current state of affairs and per the CPUC Base Portfolio, CAISO must approve policy-driven OOS transmission in this cycle. Where is CAISO landing on its selection of one or all transmission projects to advance toward regulatory approval?

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

• Under the section entitled “Out of state wind study – Base portfolio and Sensitivity 1 portfolio”
  • In its analysis, CAISO adopted a methodology of comparing the various out of state wind resources/transmission projects by using NM wind as a baseline against WY or ID. If the baseline of the analysis was to compare Cross-Tie, SWIP North, and TransWest against each other, why was NM wind used as a base for comparison?
  • In its analysis, CAISO adopted a methodology of stating some facts and costs related to Cross-Tie, SWIP North, and TransWest transmission projects. Other than differences in NCF, each transmission project is vastly different from a capital cost and transmission rights perspective.
  • Based on your presentation and our research:
    • •  
    • Cross-Tie – transmission line will cost $667M to build. As planned, CAISO would have no transmission rights on this line. So any out-of-state wind generation will need to pay wheeling fees to transmit power into the CAISO system without the creation of another line parallel to SWIP South between Robison Summit and Harry Allen.
    • SWIP North – this transmission line will cost $635M to build. As planned, CAISO will be granted 1000MW of transmission rights, which means any out-of-state wind resources on this line will be able to transmit power directly into CAISO without additional tolling/wheeling fees. This equates to cheaper/unencumbered wind energy directly transmitted in the CAISO system. Additionally, if SWIP-North were built, the existing SWIP-South path rating could be increased from 900 (N-S)/600 (S-N) MW to 2000/2000 MW, giving CAISO about 1000 MW transmission right from Midpoint to Harry Allen. 
    • TransWest – this transmission line will cost $2.1B to build + $660M to $840M to realize its full capabilities. This line was by far the most expensive of the three. The presentation wasn't clear if CAISO would be granted transmission rights on this line. Therefore we assume any out-of-state wind generation will need to pay wheeling fees to transmit power into the CAISO system.
  • CAISO is in need of out-of-state wind resources; thus we do not understand why didn’t CAISO approach the analysis by looking at the longer-term economic benefits (ex. 20-30 year outlook) to the California rate payers that factors in the “all in costs?” We recommend that CAISO should:
    • 1) look at the benefits of the lines not compared to NM
    • 2) weigh the capital costs including transmission lines, transmission rights, wheeling etc.,
    • 3) obtain net present value of benefits and costs over the long term as CAISO has always done for these types of exercises in the past.

All of these transmission projects have taken years to develop and will bring in out-of-state wind resources, therefore every one of them deserve serious consideration. Preferably all at once but at very least one at a time over a period of time.

Arevia Power believes that to reach the goals of accessing the necessary out-of-state wind and increasing reliability in CPUC Base portfolio, SWIP-North is the logical and best value first step. The SWIP-North project increases existing SWIP-South line capacity dramatically and compliments the proposed GreenLink West and GreenLink North projects, expanding the potential for a broader Western regional transmission system. This increase in capacity may also create an opportunity with the Cross-Tie to deliver into CAISO in the future after SWIP North is built.  SWIP-North opens up access to Idaho, and potentially Nevada, wind resources and projects. SWIP-North is the lowest cost, and of all the potential options available, it is the most advanced development, and it should be built first. While other good options exist and should be considered seriously, SWIP-North presents an opportunity to make an immediate “no regrets” investment to help CAISO achieve its stated policy goals.      

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

BAMx applauds the CAISO staff’s efforts in relying on the implementation of Remedial Action Schemes (RAS) and storage solutions in its Preliminary Policy Assessment. As shown in Table 1 compiled by BAMx below, the CAISO has effectively and rightfully utilized the existing/planned RAS dispatching portfolio battery storage in charging mode, and including new battery storage as mitigations wherever applicable to mitigate the contingency overloads.

Table 1: Recommended Non-Wires Mitigations*

*Source: November 18^th Presentation, “2021-2022 TPP Policy-driven Assessment,” pp. 30-55.

BAMx encourages the CAISO to consider the combinations of such non-wires mitigations in its future assessment. For instance, in the case of both the Encina-San Luis Rey 230 kV and San Luis Rey-San Onofre230 kV constraints, the CAISO indicated that planned RAS to trip Encina was not sufficient in the Secondary System Need (SSN) scenario under the two sensitivity portfolios, and therefore new 230kV lines might be required to address P7 contingencies.[1] In such cases, a combination of RAS and relocation of battery storage should be considered as potential mitigation solutions. Since these two projects are expected to be identified as Category 2 policy-driven projects[2], BAMx encourages the CAISO to consider such mitigation solutions in the next planning cycle.

Furthermore, in the case of some transmission projects that the CAISO staff is considering recommending for approval as Category 1 policy-driven projects, it is not clear to BAMx why relocating battery storage is not an effective mitigation. For example, for the On-Peak Fulton 60kV lines constraint, it is clear that there is no energy storage portfolio behind the constraint where only 0MW to 40MW of baseline and portfolio resources remain undelivered in the Base and the two sensitivity portfolios. However, it is not clear to us why relocating battery storage, that is, adding battery storage behind the constraint, is not an appropriate mitigation solution. We encourage the CAISO staff to continue to investigate less costly mitigations for such projects. Until then, these projects should not be identified as Category 1 policy-driven projects. 

BAMx acknowledges the tremendous amount of effort by the CAISO staff in identifying the interconnection transmission alternatives, the onshore network, and additional transmission upgrades that might be required to address the capacity issue of transferring OffShore (OS) wind out of the Diablo/Morro Bay area and the Humboldt Bay area.[3] It is critical that the CAISO develops capital cost estimates for all different types of transmission upgrades required for offshore wind development to inform stakeholders as soon as possible. It is very important that the CPUC IRP team use this information to develop resource portfolios for the CAISO 2022-2023 TPP in a timely manner. The transmission costs, including the cost of all connection facilities and the potential network upgrades scope and cost information, need to be transferred for the base and sensitivity portfolios, including the required additional transmission to accommodate the OS wind.

Similar additional transmission cost information needed to accommodate the Out-of-State (OOS) wind should be communicated to the CPUC IRP team. For example, the Off-Peak deliverability assessment identified worse overloads on the Eldorado-McCullough 500 kV tie-line with 1,062 MW OOS wind at Eldorado in the Base Portfolio compared with that injection at Palo Verde.[4] In other words, the Wyoming/Idaho wind tends to trigger more transmission costs than the New Mexico wind over and above the major transmission upgrades that are needed to get the OOS wind resources to the CAISO border. This exercise will validate whether the selection of 1,500MW of OOS wind and 1,708MW of OS wind, originally selected by the RESOLVE model in the CPUC’s 38MMT Core portfolio considered in its Proposed Preferred System Plan (PSP)[5], is economically justified. It is important  that all types of transmission costs associated with OS/OOS wind are accurately captured to adequately evaluate the cost-effectiveness of the OS/OOS wind resources relative to the competing In-State and other OOS renewable resources.

^[1] See November 18th Presentation, “2021-2022 TPP Policy-driven Assessment,” pp. 46-48.

^[2] Since they are found to be needed only in the sensitivity portfolios.

^[3] See November 18th Presentation, “2021-2022 TPP Policy-driven Assessment,” pp. 70-81.

^[4] See November 18th Presentation, “2021-2022 TPP Policy-driven Assessment,” p.89.

^[5] Rulemaking 20-05-003, ALJ Ruling Seeking Comments on PSP, August 17, 2021, p. 16.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

At this time, BAMx has no comments on this topic.

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

Out of the six projects the CAISO is considering for approval included in Table 2 below, energy storage options were evaluated as an alternative to transmission solutions for the three projects highlighted in yellow. The energy storage mitigation options were rejected as they were not  found to be economically attractive due to PG&E’s added costs to upgrade the involved substations to a breaker-and-a-half (BAAH) configuration.

Table 2: Less than $50 Million Project Approvals and Project for Concurrence**

**Source: 2021-2022 Transmission Planning Process, PG&E Area, Less than $50 Million Project Approvals and Project for Concurrence, November 18, 2021, pp.2-8.

BAMx encourages the CAISO staff to look for innovative methods to connect storage when the standard method triggers major interconnection costs, including the three projects above where storage as an option was rejected. BAMx recommends the Staff consider the connection to the area distribution system as one method to be considered. If that increases battery installation costs, those increased costs could be considered as incremental interconnection costs and treated appropriately.

PG&E’s Cortina 230/115/60 kV Bank #1 Replacement Project proposed replacing the existing Cortina Bank #1 with two transformers (a 230/115 kV and a 115/60 kV unit), a project cost of $21 million to $42 million.  BAMx encourages the CAISO staff to evaluate an alternative that replaces the existing Cortina Bank #1 with a 200 MVA 230/60 kV transformer.  The existing Cortina Bank #1 is operated as a 230/60 kV transformer with its 115 kV winding disconnected from the CAISO grid.  According to the CAISO reliability assessment, the 230/60 kV winding of the Cortina #1 transformer is forecasted to be overloaded.  Replacing the existing Cortina Bank #1 with a 200 MVA 230/60 kV transformer appears to be the most direct and cost-effective means to mitigate the forecasted overload.

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

 At this time, BAMx has no comments on this topic.

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

BAMx supports the CAISO’s broad objectives for the 20-Year Transmission Outlook Initiative. BAMx appreciates the update provided on November 18th regarding the two steps identifying the transmission alternatives to potentially meet SB100 goals. Step 1 entailed transmission facilities to integrate the resources in the SB100 starting point, whereas step 2 included transmission facilities needed to get from resource areas to the load centers. BAMx acknowledges that the transmission paths, especially those explored under step 2, are only for illustrative purposes at this time. However, it is important that the CAISO soon develop rough cost estimates for all transmission facilities needed under step 1 and step 2. Without such cost estimates made available in the current timeframe, the policymakers and stakeholders at large will not be able to assess their impact in refining long-term resource planning.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

No comments at this time.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

California Community Choice Association (CalCCA) supports the California Independent System Operator’s (CAISO) identification of policy-driven projects under the base portfolio and requests the CAISO also consider projects identified in the sensitivity-1 portfolio based on the 38 MMT green-house gas (GHG) target.

CalCCA supports the CAISO’s identification of policy-driven projects under the base portfolio. Additionally, in the previous Transmission Planning Process (TPP) workshop, the CAISO indicated that it intends to consider additional upgrades to reflect the increase in resource procurement and provide flexibility for resources not currently in the base portfolio.[1] CalCCA supports the CAISO’s intention to “get ahead of” the large number of resources expected to be included in future portfolios by considering additional upgrades beyond those identified using the base portfolio. Identifying additional upgrades now in anticipation of increased resource build could provide the necessary signals to resources as to where to site new resource build necessary to meet the required forty percent reduction in statewide GHG emissions by December 31, 2030, the Renewable Portfolio Standard of 60 percent by December 31, 2030, and the goal of a zero-carbon electric system by 2045.[2]

To do this, the CAISO should consider projects identified in the sensitivity-1 portfolio based on 38 million metric ton (MMT) green-house gas (GHG) targets. As outlined in CalCCA’s comments in the Integrated Resource Planning (IRP) proceeding, CalCCA supports the base case of 38 MMT Core for the preferred system plan and for consideration in the TPP.[3] CalCCA appreciates the CAISO including the sensitivity-1 scenario as a sensitivity in this year’s TPP, and recommends the CAISO consider the sensitivity-1 scenario when considering additional upgrades beyond those identified in the base portfolio.

[1]             CAISO Day 2 Presentation on the 2021-2022 Transmission Planning Process, Sept. 27-28, 2021 at 12.

[2]             Health and Safety Code § 38566, Public Utilities Code § 399.15(a), Public Utilities Code § 454.53(a).

[3]             California Community Choice Association’s Comments on Administrative Law Judge’s Ruling Seeking Comments on Proposed Preferred System Plan, R.20-05-003, Sept. 27, 2021.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

No comments at this time.

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

No comments at this time.

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

No comments at this time.

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

CalCCA supports the CAISO’s efforts in developing the 20-year transmission outlook based on the Senate Bill (SB) 100 starting point scenario.

 CalCCA reiterates its appreciation from previous comments on the CAISO’s efforts to develop the 20-year Transmission Outlook. [1] Forward planning with a long enough lead time will be critical in ensuring the state is prepared to meet SB 100 goals that require renewable energy and zero-carbon resources to supply 100 percent of electric retail sales to end-use customers by 2045.

[1]             CalCCA Comments on the July 27, 2021, TPP Stakeholder Call and CalCCA Comments on the Sept. 28, 2021, TPP Stakeholder Call

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

CalCCA supports the CAISO's identifying load impacts of potential Public Safety Power Shutoff (PSPS) events.

CalCCA commends the CAISO for its look at wildfire impacts in the TPP. As wildfires become increasingly prevalent in California, this assessment will provide useful information regarding grid resiliency. CalCCA requests clarity on how the CAISO plans to utilize the results of the impact assessment to reduce future PSPS events or wildfire impacts.

The CAISO Should Consider How to Incorporate Policy-Driven Assessments in Local Areas in the Next TPP Cycle.

CalCCA understands that the CAISO assesses proposed transmission upgrades and alternatives for reducing reliance on gas-fired resources in local capacity areas in its economic-driven study phase. In the 2020-2021 TPP cycle, the CAISO assessed the economic value of reducing the need for gas-fired generation through transmission and other alternatives by applying the differential between the local and system capacity prices.[1] As the fleet of resources evolves, the potential for a local constraint to become binding will increase. Analysis of the divergence of system and local prices will be important to inform the impacts and to determine whether transmission should be built to resolve local area resource constraints. In addition to these economic assessments, a policy-driven assessment should be performed to identify transmission upgrades or alternatives that facilitate retirements for fossil fuel plants on a timeline that maintains reliability in local areas and makes progress on state environmental requirements including minimizing air emissions in disadvantaged communities.[2]

In the next TPP cycle, the CAISO should incorporate a policy-driven assessment into its evaluation of transmission upgrades or alternatives needed to address local needs. As the state works towards achieving a zero-carbon electric system by 2045, more renewable resources and storage will necessarily come online creating opportunities for existing fossil fuel plants to retire. However, if an existing fossil fuel plant is in a locally constrained area, the resource retirement will not occur until the transmission constraint is eliminated or enough carbon-free resources are built in the local area to fulfill the local need. This could result in delays in meeting environmental standards if transmission capacity or other alternatives are not built to address the local need. The CAISO should consider transmission upgrades and potential alternatives to alleviate local area transmission constraints that would allow fossil fuel plants to retire to meet the State’s GHG mandate reliably.

[1]             2020-2021 Transmission Plan at 250.

[2]             See Public Utilities Code § 454.52(a)(1)(h).

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

Base Case: 46 MMT GHG target

The CAISO’s on-peak deliverability assessment identifies where transmission constraints would occur using the base portfolio of resources (provided by the CPUC) under scenarios of highest and secondary system need. The CAISO also offers its initial recommendations for mitigating such constraints.

In many cases, the CAISO indicates that remedial action schemes (operating procedures) should be sufficient for managing these transmission constraints.

In some cases, dispatching battery storage into charging mode (another operational procedure) is recommended as the preferred mitigation tool.

In some cases, transmission upgrades are identified as the preferred option for mitigation. These specific upgrades include:

• Mesa-Laguna Bell 230 kV line (SCE area) at a cost to be determined ($15 million or less)
• Delevan-Cortina 230 kV line (PG&E) ($41.39 million)
• Cayetano-North Dublin 230 kV line (PG&E) ($42.4 million, or a new 500 kV line)
• Lone Tree-USWP-JRW-Cayetano 230 kV line (PG&E) ($55.1 million, or a new 500 kV line)
• Las Positas-Newark 230 kV line (PG&E) ($47.65 million, or a new 500 kV line)
• Rio Oso-SPI Jct – Lincoln 115 kV line (PG&E) ($30.62 million)
• Borden-Storey #2 230 kV line (PG&E) ($24.24 million)
• Fulton 60 kV line (PG&E) (possible $28.38 million reconductoring project, to be determined)

CPUC Staff suggests it would be helpful if the CAISO could provide further details, including a summary of the cost and benefits, regarding the potential new 500 kV source that is identified as a mitigation option for three of these recommended upgrades.  CPUC Staff also requests more thorough justification for the recommended $24 million reconductoring of the Borden-Storey #2 230 kV line, since it appears the key benefit would be ensuring deliverability for only 44 MW in the base portfolio.

The CAISO’s assessment also identified off-peak constraints and potential mitigation options, notably:

• Midway-Whirlwind 500 kV line (PG&E) (possible transmission upgrades under consideration to mitigate high congestion costs and renewable curtailments)
• Several off-peak constraints were identified in the VEA/GLW area, and the CAISO is continuing to analyze these constraints before recommending its preferred option for mitigation, which could include a significant amount of new transmission.

In summary: based on the preliminary results presented at this 11/18/2021 stakeholder meeting, the CAISO’s analysis of these portfolios of future renewable generation is leading to recommendations for specific transmission upgrades of modest cost. The CPUC’s policy-driven portfolio for this 2021-2022 cycle is spurring new transmission facilities. This has not happened in recent TPP cycles. Explaining this analysis and justifying the recommended upgrades within the CAISO’s draft Transmission Plan will be an important demonstration of the cost-effectiveness of integrated resource planning. CPUC Staff generally supports the upgrades shown to be needed to meet the anticipated future resources that were mapped in the CPUC-provided portfolios.

CPUC staff appreciates the CAISO’s update on this policy assessment and looks forward to the completed analysis and recommendations.

Additional Transmission Upgrades

The CAISO also has discussed recommending a limited number of transmission projects that could be beneficial proactive investments towards helping meet California’s resource portfolio goals. Such additional upgrades could be triggered by resource additions beyond those within the base case portfolio. The CAISO might also consider recommendations for upgrades that would provide deliverability for a significant amount of renewable resources outside of the base case portfolio at a modest cost.

CPUC Staff supports this general approach and encourages the CAISO to move forward with recommendations in the draft Transmission Plan that explain why such upgrades make sense and would advance the anticipated resource portfolios in future TPP cycles. Because annually the CPUC has to transmit to the CAISO a resource portfolio for the following TPP cycle by mid-February, this overlap with the ongoing TPP cycle, which does not approve a Transmission Plan until late March, provides an opportunity to confirm the general direction of resource planning before approving transmission projects beyond those contained in the base case.

Sensitivity #2: 30 MMT with Offshore Wind Resources

CPUC Staff appreciates the CAISO’s work on this sensitivity analysis, which could shape development of future transmission needed to bring offshore wind power to California load centers.

For the north coast the CAISO is considering three different transmission technologies that could be utilized to bring 1.6 GW south to the Bay Area, as well as 12.8 GW of additional offshore wind power being considered in the “outlook assessment.”

For the central coast region, the CAISO also is considering alternative technologies that could transfer offshore wind out of the Diablo/Morro Bay area. The CAISO also recognizes need for a new 500 kV substation to manage the 2.3 GW of offshore wind being modeled for a Morro Bay interconnection.

The CAISO notes that it is working with PG&E to develop “order of magnitude” cost estimates for the connection facilities and the potential network upgrades for these alternative transmission technologies. CPUC Staff looks forward to the CAISO’s ranking of these interconnection and transmission alternatives for the north and central coast regions. We support this ranking structure as we expect it will provide better understanding of transmission needs and the options for developing such infrastructure, especially for delivering north coast wind resources.  As the CAISO finalizes this sensitivity analysis within the draft Transmission Plan, CPUC Staff urges thorough explanation of:

• The sources of cost information and the key assumptions for costs, including explanation of the certainty or evolving nature of cost assumptions. For example, we assume the source for the assumptions underlying the “maximum resource dispatch for offshore wind” that is listed within the table in slide #33 is the 2020 NREL Technical Report on the Cost of Floating Offshore Wind Energy in California, but it would be important to ensure a common understanding of these assumptions.

• Deliverability of potential offshore wind MWs in the central coast region, specifically the amount of transmission headroom currently on the existing system and under the assumption of a new Morro Bay 500 kV substation. It would be helpful for the CAISO to explain how the retirement of Diablo Canyon will impact transmission capacity in this region.

• How a rational sequence of transmission development could be mapped out as the volume of offshore wind MWs in the Humboldt Bay increases over a specific timeframe. A key result of the CAISO’s outlook assessment should consider how and when to develop transmission facilities needed to accommodate a huge amount of offshore wind MWs coming from the north coast.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

Sensitivity #1: 38 MMT GHG target with Out-of-State Wind Resources

1. CPUC Staff notes that not all capital costs that CAISO ratepayers would ultimately bear were accounted for in the Net Ratepayer Benefits for Base Portfolio Study of OOS alternative projects (slide 125).

Summary of CPUC Staff understanding of what costs are and are not accounted for in this study:

• • The analysis does not account for the capital costs of any of the three alternative transmission projects: SWIP North, Cross-Tie or TransWest Express.
  • The analysis does not account for the capital cost of the Sunzia project, nor of the cost of transmission rights required to get the power from Pinal Central to the Palo Verde CAISO injection point (See Figure A for an illustrative depiction of this gap between Pinal Central and Palo Verde).
  • The analysis assumes use of the One Nevada (ON) line and does not account for the capital cost that would be required to develop a separate line from Robinson to Harry Allen for the Cross-tie project, which CPUC Staff understand to be a likely possibility.
  • Delivery of Wyoming wind to the CAISO system on the SWIP North line and delivery of Idaho wind to the CAISO on the Cross-Tie line would both rely on the construction and utilization of the Gateway West and South projects respectively. The capital cost of the Gateway projects is not accounted for. For reference, Figure A below depicts illustratively CPUC Staff understanding of the locations of the various relevant transmission lines.

Figure A: CPUC Staff Illustrative Depiction of Transmission Lines Relevant to the CAISO’s OOS Assessment in the 2022-2023 TPP

If the CPUC or other stakeholders were to use this analysis and wanted to account for the full cost to CAISO ratepayers, it would be important to subtract all the above capital costs from the net benefits. CPUC Staff request that the final results clearly lay out what capital costs were accounted for (and what cost was assumed) and which costs were not accounted for and whether the CAISO has an estimate for the costs not accounted for.

2. CPUC Staff request that the CAISO clarify whether transmission rights costs for third party transmission needed to utilize projects that do not interconnect resources directly to the CAISO boundary are accounted for in the benefits analysis, and if so, how?

Possible situations where this occurs:

• • Wyoming wind using Cross-tie: Transmission rights on the Gateway and One Nevada Lines
  • Wyoming wind using SWIP-North: Transmission rights on Gateway
  • New Mexico wind: Transmission rights from Pinal Central to Palo-Verde

3. CPUC Staff support the capacity factor assumptions used by the CAISO for the OOS wind resources.

CPUC believe that the wind profiles provided by NREL for ADS PCM development are a good source of information and more up-to-date than the source of this information used in CPUC IRP’s capacity expansion model, RESOLVE. Additionally, because the CAISO calculated the average capacity factor of the wind profiles at locations close to the project terminals, the information used for this detailed transmission assessment is more granular than that used for capacity expansion modeling by RESOLVE. Overall, the capacity factor assumptions used by the CAISO do not differ significantly from those used in RESOLVE.¹

4. CPUC Staff want to note that in addition to the production cost benefits of each project captured by the CAISO’s analysis, there are costs and benefits to each of these alternatives that are more challenging to quantify. This includes various risks.

For example, the risks associated with the CAISO not having transmission rights to a line and what this may mean for whether the CAISO and therefore CA can count on these out of state resources for decades to come.

CPUC Staff request that the CAISO note for each scenario whether additional transmission rights/lines, beyond the specific proposed projects studied, are required to fully deliver the resources to the CAISO border and whether these lines are currently online or are also in development or under construction.

5. CPUC Staff’s understanding is that these preliminary TPP results indicate that no CAISO transmission system upgrades would be required to accommodate the injection of OOS resources into the CAISO, however, two caveats exist.

We understand that the CAISO plans to conduct further analysis of congestion, specifically on Path 26 to understand how the injection of OOS resources into the CAISO system increases congestion on that line and whether this may create the need for any downstream transmission upgrades.

CPUC Staff also notes that OOS wind resources would compete with projects in the CAISO’s balancing area already in the interconnection queue for use of the existing CAISO transmission headroom downstream of the OOS wind injection point. If a significant number of these in-BAA projects were to be built, they would utilize the existing downstream transmission system capability and leave the OOS wind resources needing downstream transmission upgrades.

6. CPUC Staff seeks guidance from the CAISO on how stakeholders can generalize the results of the base case and the sensitivity portfolio to come to any conclusions regarding OOS resource amounts that were not specifically studied.

For example, the PSP ruling² included 1500 MW of OOS resources online by 2030. This could mean the full 1,500 injected at Palo Verde or at El Dorado, or it could also occur in the form of a combination not directly studied by the CAISO. For example, 1,000 MW at El Dorado and 500 MW at Palo Verde. CPUC Staff is not seeking input specifically on this example but rather requesting broad guidance.

Footnote 1:  ftp://ftp.cpuc.ca.gov/energy/modeling/Inputs%20%20Assumptions%202019-2020%20CPUC%20IRP%202020-02-27.pdf

Footnote 2:  https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/integrated-resource-plan-and-long-term-procurement-plan-irp-ltpp/2019-2020-irp-events-and-materials/ruling_proposed-psp.pdf

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

CPUC Staff greatly appreciates the update on the CAISO’s plans for its first-ever 20-Year Outlook, which we anticipate will be posted around the same time (late January 2022) as the draft Transmission Plan. We view this study as a valuable new addition to the set of transmission planning analyses that the CAISO produces. It will be useful to multiple state agencies and stakeholders. We hope the CAISO will consider running the 20 Year Transmission Outlook on a more regular basis and with refinements over time.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

Context and Takeaways from TPP Presentations

CPUC Staff greatly appreciates the time and dedication of the CAISO staff that was demonstrated throughout this stakeholder meeting. We recognize the limited time to condense the information and analysis on a variety of complex topics, and overall the presenters conveyed key points in an understandable way. Nonetheless, it may be useful for the CAISO to consider ways to frame the context better for each topic and provide key takeaways for each section of the presentation, especially since certain “results” were preliminary or incomplete at this stage of the TPP. This update on TPP process can be quite helpful for stakeholders’ understanding.

We appreciate the CAISO’s efforts conducting this important analysis and meeting the ambitious deadlines throughout this year’s TPP schedule.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

The following are comments from the Public Advocates Office at the California Public Utilities Commission (Cal Advocates).  Cal Advocates is an 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]   

Background

The California Public Utilities Commission (CPUC) submitted three policy portfolios to the California Independent System Operator (CAISO) for evaluation in its 2021-2022 Transmission Planning Process (TPP).  These portfolios are as follows:

1. A Base portfolio with a greenhouse gas (GHG) emissions target of 46 million metric ton (MMT) by 2031, with 1,062 megawatts (MW) of out-of-state (OOS) wind on new transmission.[2]
2. A Sensitivity 1 portfolio with a lower GHG emissions target of 38 MMT and 3,000 MW of OOS wind on new transmission.[3]
3. A Sensitivity 2 portfolio with a lower GHG emissions target of 30 MMT and 3,000 MW of OOS wind and 8,351 MW of offshore wind.[4]  

Based on these portfolios, CAISO assumed that 27,695 megawatts (MW) of new renewable resources will be added to the California grid for its transmission deliverability analysis.  For comparison, the 2020 base portfolio added only 10,387 MW to the California grid.[5]^{, [6]}  

To accommodate this additional capacity, Cal Advocates strongly supports full utilization of the existing grid capacity before investing in new transmission.  Consistent with this principle, in comments submitted to the CPUC on these policy portfolios, Cal Advocates provides the following reasons why it is premature to move forward with new transmission investments that would access OOS wind to meet the state’s policy goals before considering other alternatives. 

1. The resource modeling assumptions used to develop the 2020-2021 Integrated Resource Planning (IRP) policy portfolios do not include actual transmission costs.[7]  This means that the selection of OOS wind on new transmission is not based on consideration of all the associated transmission costs for bringing out of state wind to California load centers.  Specifically, the costs for identified new interregional transmission projects in Wyoming and Idaho are not included nor are costs for the transmission upgrades that would be needed to bring the proposed new wind capacity to load centers in California.

 2. The CPUC has stated that it is not certain of the exact amount of OOS wind that will be needed to meet the state’s 2030 and 2045 goals and the amount of out of state wind that can be imported through existing transmission.[8]

3. The California Load Serving Entities (LSE) did not select OOS wind on new transmission lines in their 10-year system portfolios submitted on September 1, 2020.  Instead, LSE selected wind resources from New Mexico and the Pacific Northwest on existing transmission.[9]

4. High levels of transmission headroom may be available for importing out of state wind on existing transmission during constrained hours.[10]

5. CPUC modeling assumptions do not account for the risks related to new transmission development, such as delays in permitting, land acquisition and construction that can add hundreds of millions to the initial estimated project costs.[11]

6. CPUC’s resource modeling does not consider the interaction between solar and storage and thus the cost reductions from shared infrastructure for solar plus storage projects are not modeled.”[12]  With shared resources, co-located batteries have reduced site and installation costs in comparison to stand-alone batteries.[13] Batteries co-located with solar can also operate at their optimal level without triggering new transmission upgrades.[14]

7. The CPUC did not provide an evaluation of the ratepayer cost impacts associated with OOS wind procurement through power purchase agreements that include firm transmission rights or through expansion of the CAISO footprint through investment in new transmission.   

8. Any decision on California investment in OOS wind transmission to meet the state’s clean energy goals should also consider the Federal Energy Regulatory Commission’s (FERC) current inquiry into whether or not reforms to the existing interregional transmission project cost allocation policies and interregional transmission coordination process policies are necessary.[15]  The pending FERC policy reforms would directly impact the cost allocation for interregional transmission projects such TransWest Express, which is one of the transmission project alternatives identified for accessing OOS wind.  The developer for TransWest Express already submitted its project to NorthernGrid and the CAISO for cost recovery consideration.[16]  NorthernGrid is currently studying this project to determine whether it is needed.[17]

2021-2022 TPP Policy-Driven Assessment

During the November 18, 2021, TPP stakeholder meeting, the CAISO presented results from its production cost simulation and transmission deliverability analysis on the three CPUC provided policy portfolios.  This assessment identified areas on the California grid where transmission upgrades would be needed to integrate the proposed policy portfolios.  The CAISO also reviewed transmission mitigation options considered to address the identified deliverability issues with the proposed policy portfolios and recommended preferred transmission mitigations.  Per the CAISO tariff, if a transmission project is identified as needed for the base case portfolio and at least a significant percentage of the stress scenario portfolios, it may be recommended for approval as a Category 1 policy-driven project in the current TPP cycle.[18]  Given this policy, the CAISO may propose up to nine projects as policy-driven transmission projects for approval in this TPP cycle.[19]   

The following are Cal Advocates’ recommendations on these policy-driven transmission projects by service territory.  In summary, Cal Advocates supports the lowest priced options such as installing grid enhancing technologies to address the identified deliverability issues, if these options can effectively eliminate the identified overloads.  Grid enhancing technologies such as SmartWires and energy storage can also be relocated if it is determined that they are not needed and thus they are least cost and least regrets options. 

Southern California Edison Service Area

Laguna Bell Mesa No. 1 230 kV Line: the CAISO recommends reconductoring the Laguna Bell Mesa No. 1 230 kilovolt (kV) line in the Southern California Edison Company’s (SCE) service area to address possible overloads with the proposed policy portfolios.  The CAISO estimated that up to 3,098 megawatts (MW) of new proposed capacity would be undeliverable due to overloads on the Mesa-Laguna Bell No. 1 230 kV line.  CAISO presented two mitigation alternatives to address the overload issues on the Laguna Mesa line and they are: (1) SmartWires’ Laguna Bell – Mesa Series Compensation project estimated at $6.7-$8 million and (2) the Laguna Bell Mesa line reconductoring project which has a cost estimate of $15 million.[20]

Cal Advocates supports the SmartWires’ Laguna Bell – Mesa Series Compensation mitigation option, on the condition that this project would effectively eliminate the contingency overloads on the Mesa-Laguna Bell No. 1 230 kV line. 

Pacific Gas and Electric Company Service Area

The remaining eight policy-driven projects are in the Pacific Gas and Electric Company’s (PG&E) service territory.  Seven projects are line reconductoring projects, with cost estimates ranging from $24.24 million to $55.1 million, for a total cost of $269.78 million.[21]  PG&E’s line reconductoring projects have significantly higher cost estimates compared to SCE’s estimated line reconductoring project costs of $15 million.  The remaining project is to address overloads on the Weedpatch 70 kV line, but a recommended mitigation is not provided.

CAISO’s mitigation analysis for the identified deliverability issues in the PG&E services area is incomplete and does not include the following information:

1. Reasons why relocating energy storage cannot be considered as an alternative option; its analysis just states “no” for this option or not applicable.[22], [23]
2. Cost estimates for other grid enhancing technologies that could be considered, such as SmartWires, energy storage or series compensations. 
3. Recommended mitigations for the On-Peak Fulton 60kV line and for the Off-Peak Weedpatch 70 kV Area constraints.  The analysis states that a recommendation is still to be determined (TBD) for these constraints.[24]

The CAISO  should provide complete alternative analysis and specifically provide the reasons why energy storage cannot be considered or the costs for project alternatives considered and its recommended mitigation.  

Based on the information currently provided, Cal Advocates does not support the proposed line reconductoring projects in the PG&E service area because the estimated line reconductoring costs are likely to be two to three times more than other viable grid enhancing technologies mitigation alternatives, such as energy storage, smart wires, or series capacitors based on the cost estimates provided in the SCE constraint mitigation analysis.  

CAISO also proposed two line reconductoring projects in PG&E’s service territory to address overload issues with the proposed policy portfolios that range between 44 MW and 181 MW, and as little as 0 MW and 40 MW; these projects are the Borden-Story #2 230 kV line reconductoring and Fulton 60 kV line reconductoring projects.[25]  These projects have estimated costs of $24.24 million and $28.38 respectively.[26] Given the deliverability impact range and size, mitigations with lower costs should be investigated concurrent with evaluating these projects.

Cal Advocates cannot provide an assessment of the proposed Weedpatch 70 kV area projects because CAISO has not yet provided its recommended mitigation.

Potential Ratepayer Cost Impacts:

To improve the CAISO TPP stakeholder process, Cal Advocates recommends that the CAISO provide the costs and ratepayer impacts for all the proposed transmission projects considered for approval in the given TPP cycle.  Direct ratepayer cost impacts such as cumulative additions to regional and local transmission revenue requirements and impacts to the transmission access charge (TAC) should be analyzed and formally presented when discussing proposed projects.  Merely providing estimated capital costs does not provide actionable information for meaningful stakeholder engagement on ratepayer impacts.  

Using the proposed project capital cost estimates provided at the November 18, 2021 TPP stakeholder meeting, Cal Advocates estimates that the proposed line reconductoring projects will have the following impacts to the Transmission Revenue Requirement (TRR) and TAC.  These TAC and TRR impacts are summarized in Table 1, Ratepayer Impact of Proposed High Voltage Transmission Projects, and Table 2, Ratepayer Impact of Proposed Low Voltage Transmission Projects.  Cal Advocates provides these impact estimates for consideration during project vetting until the CAISO confirms project scope and cost estimates, and the requested project alternative analyses.

Table 1 - Ratepayer Impact of High Voltage Proposed Transmission Projects

*   The in-service date for all projects is assumed to be 2023.  The average annual TAC increase, 40-yr TRR Contribution, and 40-yr TRR Contribution Net Present Value (NPV) all assume project costs are added to the TRR in 2023.  

Table 2 – Ratepayer Impact of Low Voltage Proposed Transmission Projects

*   The in-service date of all projects is assumed to be 2023.  The average annual TAC increase, 40-yr TRR Contribution, and 40-yr TRR Contribution NPV all assume project costs are added to the TRR in 2023.

** Cal Advocates presents the average annual TAC for low-voltage projects as a placeholder value to show the order of magnitude of ratepayer impacts.  The cost of projects with a rated voltage of <200kV is recovered through the Local Transmission Revenue Requirement (LTRR) and is paid for entirely by loads within the incumbent utility’s service area.  The values presented show the average annual TAC increase for each project if the costs were collected regionally (as done for projects with a rated voltage of >200kV).

            A recent CPUC white paper found that the transmission access charges ($/MWh) has increased 255% since 2009, this increase is a key driver of rising electricity bills.[27]  If these line reconductoring projects were to be approved, Cal Advocates estimates an approximate NPV of $390 million will be added to transmission revenue requirements, contributing to higher electricity bills.  Cal Advocates recommends CAISO consider the lower-cost options discussed herein. 

Preliminary Results for PG&E Area Offshore Wind

The CAISO’s Offshore Wind (OSW) sensitivity study evaluated the proposed 8,350 MW of offshore wind (OSW) in IRP Sensitivity Portfolio 2 by 2031 and an outlook assessment for 21,171 MW of OSW resources by 2045.[28]  This evaluation considers California OSW potential at Del Norte, Cape Mendocino, Humboldt, as well as Morro Bay and Diablo Canyon. 

Consistent with California Wind Energy Association’s (CalWEA) comments on the proposed policy portfolios for the 2021-2022 TPP, Cal Advocates recommends that the CAISO, CPUC and CEC consider the development of offshore wind in phases that align with regulatory constraints.[29]  To this end, the CAISO should consider the transmission investments needed to integrate no more than 3,000 MW of central California offshore wind by 2031,[30] and the transmission investments needed for the development of up to 1,605 MW of offshore wind at Humboldt Bay based on recent Bureau of Ocean Energy Management (BOEM) designations.[31]  The costs for all connection facilities and necessary network upgrades should be included in the CAISO’s total offshore wind project integration costs.  With these cost estimates, the initial phase of offshore wind development in California, which could be up to 4,605 MW versus 8,350 MW, can be assessed along with the other options to meet the state’s 10- and 24-year goals to comply with Senate Bill (SB) 100.[32]

Interconnection Options for 1,607 MW of Offshore Wind at Humboldt Bay.

Additional studies are needed to determine which of the three presented interconnection options for integrating Humboldt Bay wind would be the least cost option.  At this time, Cal Advocates recommends the CAISO consider the land-based transmission options - the 500 kV AC line to Fern Road 500 kV substation and the HVDC Bipole to Collinsville 500/230 kV substation.  Option 2, which includes an underseas cable to a converter station in the Bay area, should be carefully scrutinized for viability.   Currently, there is no known developer experience in building and operating undersea cables at extreme ocean depths, across deep underwater canyons, and in very high seismic activity zones (offshore Humboldt coast is classified as a potential category 9 on the Richter scale (M9) seismic subduction zone).[33]  The Fern Road alternative also appears to have the least resource curtailment among the three alternatives considered.[34]

Integration Options for 2,300 MW of offshore wind at Morro Bay and Diablo

Cal Advocates supports further studies on proposed Morro Bay offshore wind integration options at a new 500 kV substation looping into the Diablo – Gates 500 kV line,[35]  and for the integration of Diablo offshore wind at the existing Diablo 500 kV substation.[36]

The CAISO proposed three other transmission upgrade options addressing possible undeliverable resources with the introduction of OSW on the grid at Morro Bay and Diablo Canyon.[37]  Cal Advocates recommends that the CAISO provide detailed cost justifications for each proposed alternative and assessment of long-term risks involved for each alternative.

[1] Cal. Pub. Util. Code § 309.5.

[2] D.21-03-08, February 11, 2021, p. 3.

[3] CPUC R.20-05-003, Attachment A Modeling Assumptions for the 2021-2022 Transmission Planning Process, February 2021, p.16.

[4] CPUC R.20-05-003, Attachment A Modeling Assumptions for the 2021-2022 Transmission Planning Process, February 2021, p. 19.

[5] CAISO 2021-2022 TPP Policy-Driven Assessment Presentation, November 18, 2021, p. 11.

[6] CPUC D.21-02-008 provides the capacity of new resources in the 2021-2022 TPP Base Case Portfolio as 28,303 MW and the prior 2020-2021 TPP Base Portfolio as 9,011 MW at p. 20.

[7] CEC, Joint Agency Workshop on Next Steps to Plan for Senate Bill 100 Resource Build – Transmission, July 22, 2021.

[8] Administrative Law Judge’s Ruling Seeking Comments on Proposed Preferred System Plan, CPUC R.20-05-003, August 17, 2021, p. 47.

[9] Administrative Law Judge’s Ruling Seeking Comments on Proposed Preferred System Plan, CPUC R.20-05-003, August 17, 2021, p. 48.

[10] Public Advocates Office Comments on Administrative Law Judge’s Proposed Preferred System Plan Ruling, September 27, 2021, R. 20-05-003, p. 7.

[11]SDG&E Sunrise Powerlink Project, https://drmcnatty.com/sdge-sunrise-powerlink-project, accessed September 20, 2021. SCE Tehachapi Renewable Transmission Project, https://www.sce.com/aboutus/reliability/upgrading-transmission/TRTP-4-11, accessed September 20, 2021.

[12] CPUC R.20-05-003, RESOLVE Preferred System Plan (PSP) Modeling Results (Presentation), August 2021, slide 9.

[13] 2018 U.S. Utility-Scale Photovoltaics-Plus-Energy Storage System Cost Benchmark, Ran Fu et al NREL. November 2018.

[14] Methodology for Resource-to-Busbar Mapping & Assumptions for the Annual TPP, R.20-05-003, CPUC Energy Division, August 2021, p. 16.

[15] FERC Docket No. RM21-17-000, July 15, 2021, Item 57.

[16]  ITP Evaluation Process Plan, TransWest Express Transmission Project, June 14, 2020, CAISO and NorthernGrid.

[17] Draft Regional Transmission Plan for the 2020-2021 NorthernGrid Planning Cycle, November 18, 2021, p. 19.

[18] CAISO, Fifth Replacement FERC Electric Tariff, Section 24, Comprehensive Transmission Planning Process, September 9, 2020, Section 24.4.6.6.

[19] These projects are: (1) Mesa-Laguna Bell Mo. 1 230 kV line, (2) Delevan-Cortina 230 kV line, (3) Cayetano-North Dublin 230 kV line, (4) Lone Tree-USWP-JRW Cayetano 230 kV L, (5) Las Positas-Newark 230 kV Line, (6) Rio Oso-SPL JCt-Lincoln 115 kV Line, (7) Borden-Storey #2 230 kV line, (8) Fulton 60 kV Line, and (9) Weedpatch 70 kV Area.

[20] CAISO 2021-2022 TPP Policy-Driven Assessment Presentation, November 18, 2021, slide 29.

[21] CAISO 2021-2022 TPP Policy-Driven Assessment Presentation, November 18, 2021, slides 51-65.

[22] CAISO 2021-2022 TPP Policy-Driven Assessment Presentation, November 18, 2021, slide 55, 57-61.

[23] CAISO 2021-2022 TPP Policy-Driven Assessment Presentation, November 18, 2021, slides 63-65.

[24] CAISO 2021-2022 TPP Policy-Driven Assessment Presentation, November 18, 2021, slides 61 and 64.

[25] CAISO 2021-2022 TPP Policy-Driven Assessment Presentation, November 18, 2021, slides 60-61.

[26] CAISO 2021-2022 TPP Policy-Driven Assessment Presentation, November 18, 2021, slides 60-61.

[27] Utility Costs and Affordability of the Grid of the Future. California Public Utilities Commission En Banc Hearing Presentation. Slide 21. February 24, 2021.

[28] CAISO, 2021-2022 Transmission Planning Process Stakeholder Meeting, Preliminary Policy and Economic Assessment and Study Updates, November 18, 2021, pp 78-87, Presentation-2021-2022TransmissionPlanningProcess-Nov18-2021.pdf (caiso.com).

[29] California Wind Energy Association, Comments on Ruling Seeking Comments on Portfolios to be used in the 2021-22 Transmission Planning Process, November 10, 2021, R. 20-05-003, p. 4.

[30] Bureau of Ocean Energy Management recently reduced the size of the Morro Bay offshore wind opportunity area and has given no indication that the Diablo Canyon offshore wind area will be opened up. BOEM Designates Wind Energy Area off Central California | Bureau of Ocean Energy Management

[31] DOE Bureau of Ocean Energy Management Director Memorandum for the Northern California Area ID, July 16, 2021, p.2, Table 1.

[32] Senate Bill (SB) 100 (De Leon) Stats. 2018. Ch 312.

[33] California North Coast Offshore Wind Studies, Overview of Geological Hazards, Schatz Energy Research Center, p.2, Overview of Geological Hazards (schatzcenter.org).

[34] Preliminary Results for PG&E Area – Offshore Wind, CAISO 2021-222 TPP Presentation, November 18, 2021, Page 35.

[35] CAISO, 2021-2022 Transmission Planning Process Stakeholder Meeting, Preliminary Policy and Economic Assessment and Study Updates, November 18, 2021, p. 93.

[36] CAISO, 2021-2022 Transmission Planning Process Stakeholder Meeting, Preliminary Policy and Economic Assessment and Study Updates, November 18, 2021, pp 91-95

[37] Preliminary Results for PG&E Area – Offshore Wind, CAISO 2021-222 TPP Presentation, November 18, 2021, Slide 80.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

Out of State Wind Study - Preliminary Results

Cal Advocates has pointed out that the three OOS study projects CAISO discussed at the November 18, 2021 TPP stakeholder meeting – the Cross Tie, Southwest Intertie Project North, and TransWest Express - would provide multiple benefits to planning regions outside of California. [1]  As the CAISO continues to analyze these interregional projects, it also should consider the efforts underway at the federal level to reform interregional transmission planning coordination and cost allocation policies.  This reform effort is intended to ensure that cost allocation for interregional projects is consistent with Federal Energy Regulatory Commission (FERC) Order No. 1000’s cost causation principle.  As stated in the FERC Rulemaking (RM) 21-17-000 – “Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection,” FERC seeks “to appropriately identify and allocate the costs of new transmission infrastructure in a manner that satisfies the Commission’s cost-causation principle.”[2]

FERC Order No. 1000 established the regulatory framework that governs interregional project review coordination and cost allocation.  To this end, FERC Order No. 1000 required that transmission planning regions include in their tariffs interregional cost allocation methodologies for determining interregional transmission project cost allocation amongst planning regions.[3]

In statements made in stakeholders’ opening comments and in technical conferences in response to RM 21-17-000, FERC Commissioners and several stakeholders acknowledge that the current framework for allocating the cost of interstate transmission projects is not effective.[4]  In its opening comments on RM 21-17-000, SCE stated that, since FERC Order No. 1000 went into effect, “coordination efforts among the CAISO, NorthernGrid, and WestConnect have not resulted in a single interregional transmission project.”[5]  CAISO also recommended an alternative interregional project cost allocation framework in its opening comments on RM21-17-000.[6]

In presentations on the Cross-Tie, SWIP-North, and TransWest at the annual Western Planning Regions Stakeholder meetings[7] and at the SB 100 Resource Bill Transmission Workshop,[8] the developers for these projects acknowledged that their proposed projects would benefit ratepayers outside of California.  If these projects were to be approved, the first principle of FERC Order No. 1000 would dictate that ratepayers outside of California fund these projects in a manner commensurate with their benefits.[9]   However, existing regional transmission planning and interregional planning coordination and cost allocation policies in the western United States are not in place to ensure this.  Thus, approval of any interregional transmission project by the CAISO alone before federal reforms are enacted would deprive California ratepayers of the benefits of those reforms, and quite possibly saddle Californians with the entire cost of projects that would provide reliability and economic and policy benefits to ratepayers in neighboring states.

Finally, it is critical that the CAISO consider all of the transmission costs associated with importing OOS wind to serve California load, including any and all costs for in-state CAISO transmission upgrades that may be needed.  The CAISO’s OOS wind study analysis seems to only consider the cost of bringing OOS wind to California’s injection points at Eldorado and Palo Verde.[10]  However, in-state transmission upgrades may be needed to bring the proposed 1,000-3,000 MW of OOS wind to California load centers. 

The 2021-2022 TPP policy portfolios are based on IRP modeling that estimates transmission costs based on a linear representation that collapses the full set of transmission costs into a limited topology of the CAISO footprint.[11] The IRP modeling assumptions for the new OOS transmission projects are also based on estimates from the California Energy Commission that are at least five years old[12] and were derived from California-centric assumptions.[13]Therefore, the CAISO’s TPP proposal for new transmission to access OOS wind is not based on complete or current transmission cost information.  Imputing all if the most complete, up-to-date costs associated with OOS wind transmission projects and required mitigations available to the CAISO would likely have reduced the IRP resource selection of out of state wind on new transmission.

To illustrate this point, the CAISO’s November 18, 2021 presentation identified that the injection of wind at El Dorado may require more significant upgrades than at Palo Verde.  Specifically, the CAISO noted “worse overloads on the Eldorado-McCullough 500 kV tie-line with 1,062 MW OOS wind at Eldorado (Base A) in the Base Portfolio compared with that injection at Palo Verde (Base B).”[14]  These transmission overloads were not identified during the CPUC IRP portfolio modeling; however, these overloads would need to be mitigated on the transmission line to ensure resource deliverability. 

Economic Planning Study Requests and CAISO Assessments

Cal Advocates recommends that the CAISO provide more information on the proposed economic projects presented in its November 2021 TPP meeting.  The CAISO should provide this information by January 10, 2021, so that stakeholders have adequate time to assess the projects prior to CAISO Board for approval.  For example, the CAISO did not provide adequate information (e.g., projects needs or costs, or project analysis) for the proposed Moss Landing – Las Aguilas 230 kV line project.  As required by the Transmission Evaluation Assessment Methodology (TEAM) guidance document, the CAISO must perform benefit-cost and multi-scenario analyses on proposed economic transmission projects to determine if the projects are justified.  However, the CAISO did not present the results from its Moss Landing – Las Aguilas 230 kV line TEAM analysis at the November TPP meeting.^[15]

[1] Comments on the July 27 Stakeholder Call Discussion. 2021-22 Transmission Planning Process. Public Advocates Office, California Public Utilities Commission. Submitted August 11, 2021. 

[2] Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection.  RM121-17-000.  The Federal Energy Regulatory Commission. Published July 15, 2021. P.7. Available at https://www.ferc.gov/media/e-1-rm21-17-000.

[3] FERC Order No. 1000. RM10-23-000. Issued July 21, 2011. P. 2. Available at https://www.ferc.gov/sites/default/files/2020-04/OrderNo.1000.pdf.

[4] “In addition, we are concerned that, largely due to the potential shortcomings with the current regional transmission planning and cost allocation processes, transmission infrastructure is increasingly being developed through the generator interconnection process.” (RM21-17-000, P.7.)

[5] Comments of Southern California Edison Company in RM21-17-000. P.4. Available at https://elibrary.ferc.gov/eLibrary/#.

[6] CAISO, RM21-17-000, October 12, 2021, p. 7.

[7] https://www.caiso.com/planning/Pages/InterregionalTransmissionCoordination/default.aspx

[8] Joint Agency Workshop: Next Steps to Plan for Senate Bill 100 Resource Build – Transmission, Session 1, July 22, 2021.

[9] “…the principles-based approach requires that all regional and interregional cost allocation methods allocate costs for new transmission facilities in a manner that is at least roughly commensurate with the benefits received by those who will pay those costs.” (FERC Docket No. RM10-23-000, Order No. 1000, Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities, July 21, 2011, p. 15-16)

[10] 2021-2022 TPP Policy-driven Assessment, CAISO, November 18, 2021, p. 14.

[11] CPUC Rulemaking 20-05-003 (IRP), 2019-2020 Inputs and Assumptions, February 27, 2020, pp. 50 et seq.

[12] CPUC Rulemaking 20-05-003 (IRP), 2019-2020 Inputs and Assumptions, February 27, 2020, pp. 57.

[13] See, e.g., California Energy Commission Docket 15-RETI-02, Renewable Energy Transmission Initiative v2.0 Transmission Technical Input Group Update TTIG Meeting 29 July 2016.

[14] Preliminary Policy and Economic Assessment and Study Updates. November 18, 2021. p. 89.

[15] CAISO Transmission Economic Assessment Methodology, 2017.

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

Cal Advocates recommends the CAISO provide energy storage integration cost comparisons based on projects that have completed the CAISO interconnection queue process.  This will allow Cal Advocates and other stakeholders to confirm whether PG&E’s presented energy storage integration cost estimates in the TPP are reasonable.  For example, for the proposed 70 kV Reinforcement Project, energy storage was not recommended as an alternative option due to the integration costs PG&E provided.  PG&E’s estimated integration costs were between $35 and $70 million,[1] and no information was provided to confirm if these costs are reasonable.

[1] 2021-2022 Transmission Planning Process PG&E Area Less than $50 million Project Approvals and Project for Concurrence, CAIS, November 18, 2021, Presentation, slide 4.

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

At this time, Cal Advocates has no comments on this issue.

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

The objective of the CAISO’s 20-Year Transmission Outlook is to perform a long-term assessment of the transmission needs and investment options for meeting the state’s clean energy goals.  For this long-term assessment, the CAISO uses the Senate Bill (SB) 100[1] Starting Point scenario jointly developed by the CAISO, CEC and the CPUC.  This portfolio scenario is used to identify the state’s long-term transmission needs and to further investigate the transmission investment options.[2]  The SB 100 Starting Point scenario includes 10,000 MW of offshore wind and 12,000 MW of OOS wind.  This proposed wind procurement may require new transmission investments to ensure resource deliverability.[3]  The transmission projects presented at the SB 100 Transmission project workshop will be further evaluated in this 20-year Transmission Outlook as alternatives to deliver the SB 100 Starting Point scenario resources.[4]  These proposed transmission projects include TransWest Express, SWIP-North, Cross-Tie projects, as well as wind developments and transmission projects in New Mexico.[5]  However, the SB 100 Starting Point scenario is, intended as “informational only and should not be used, in itself, to support approval of near-term infrastructure investments.”[6]

Cal Advocates recommends that the CAISO 20-Year Transmission Outlook analysis consider the following information:

1. All the costs associated with new transmission investments to deliver renewable resources to California load centers in-state, not just to the California border.  As mentioned herein, transmission upgrades in-state may be necessary to bring the proposed quantities of OOS wind to California load centers.  To understand the total cost of delivering OOS wind to California load centers, all transmission costs should be included in the CAISO’s analysis.
2. The cost of new transmission investments needed to increase the existing maximum import capacity (MIC) at the identified resource injection points on the California Border to access the proposed amount of OOS wind.  The policy portfolio model analysis seems to consider accessing OOS wind with and without MIC expansion.[7]
3. Enhancements to complement the Transmission Economic Assessment Methodology (TEAM) project assessments.

1. Isolation of the Western Electricity Coordinating Council System Benefits: For the interregional transmission projects considered in the 20-Year Transmission Outlook, Cal Advocates recommends the CAISO isolate the Western Electricity Coordinating Council (WECC) societal benefits from the other TEAM benefits assessed for interregional transmission projects.  Isolating these benefits will assist with future discussions on interregional transmission project benefits and cost allocation.  Specifically, Cal Advocates requests that the CAISO isolate the consumer, producer and transmission owner benefits that other Balancing Authority Areas (BAA) in the western interconnection could receive from the proposed interregional transmission projects.  As the CAISO states, the WECC societal benefit perspective is “especially important for projects with obvious interregional impacts.”[8]
2. Perform and Update Project Sensitivity Case Studies:

1. For all the proposed transmission projects considered in the TPP and including the 20-Year Transmission Outlook, Cal Advocates recommends that the CAISO complete the project sensitivity case studies outlined in the November 2, 2017, TEAM guidance document to test the robustness of its economic assessments.[9]  These project studies should include consideration of future load growth, future fuel costs, and availability of hydro.  
2. The CAISO should also consider a sensitivity analysis focused on the assumed reliability attributes of wind resources.  The CPUC is currently reforming its Resource Adequacy (RA) program, including reforms that may transition the RA program towards an “exceedance” methodology for counting wind resources.[10]  Any transition to an exceedance methodology, as well as the choice of the specific exceedance level, could undermine the assumptions that underpin the SB 100 Starting Point Scenario and its inclusion of high volumes of new wind capacity.
3. Cal Advocates recommends the CAISO review and provide its TEAM sensitivity analysis and results in its TPP documents or presentations.  These documents and presentations should provide details on the CAISO’s consideration of future costs of wind, solar and energy storage, including long duration energy storage and hybrid resources other possible generation technologies in their future scenarios. 
4. Going forward, Cal Advocates recommends that the CAISO update its sensitivity analysis for the transmission projects considered in the TPP and in the 20-Year Transmission Outlook every 2-years to ensure that projects that are no longer needed due to declining resource costs or new technologies are not approved.   This updated information should also assist transmission and resource cost analysis data sharing between the CPUC IRP and preferred system portfolio development and the CAISO TPP.

4. Cal Advocates recommends that the SB 100 Starting Point scenario analysis include more than one scenario portfolio.  As FERC Chairman Glick stated during the RM21-17-000 technical conference on November 15, 2021 “There is broad agreement that transmission planners should consider a range of scenarios and factors in transmission planning.”[11]  
5. Cal Advocates requests that the CAISO confirm whether or not it is considering the most cost-effective option to access OOS wind, which is through existing transmission lines between California and New Mexico.

As stated in our prior comments, Cal Advocates requests that the CAISO confirm the New Mexico wind capacity that would be available to meet California’s resource goals in 2025 and 2032 through a combination of existing and new transmission.  Based on recent power purchase agreements, the delivery of New Mexico wind capacity is possible through firm transmission deliverability rights on existing and new transmission.[12] 

[1] Senate Bill (SB) 100 (De Leon) Stats. 2018. Ch 312.

[2] SB 100 Starting Point for the CAISO 20-year Transmission Outlook, September 13, 2021, California Energy Commission, (SB 100 Starting Point) p. 1.

[3] SB 100 Starting Point, p. 5.

[4] SB 100 Starting Point, p. 10.  ”The SB 100 resource build workshop that focused on transmission included presentations from project developers with transmission projects under development. Of the projects that were presented, the majority were related to bringing out of state wind to California.”

[5] Joint Agency Workshop: Next Steps to Plan for Senate Bill 100 Resource Build – Transmission, Session 1 July 22, 2021, slide 3.

[6] SB 100 Starting Point, pp. 2-3.

[7] 2021-2022 TPP Policy-drive assessment, CAISO, November 18, 2021, p. 12.

[8] Transmission Economic Assessment Methodology (TEAM), CAISO, November 2, 2017, p. 10.

[9] Transmission Economic Assessment Methodology (TEAM), CAISO, November 2, 2017, p. 3.

[10] CPUC Rulemaking 19-11-009, Decision 21-07-014, pp. 32, 37, and 43.  Under an exceedance methodology, the CPUC’s RA program would credit the reliability contributions of wind resources according to the historical probability that the resource will generate a certain expected energy level.  For example, 50% exceedance means that the resource will be credited with the amount of energy it has historically produced at least 50% of the time.

[11] Technical Conference on Building for Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection.  ferc.capitolconnection.org/111521/fercarchive_wmv.htm

[12] Comments of Southern Power Group II, LLC and Pattern Energy Group LP on the Administrative Law Judge’s Ruling Seeking comments on Proposed Preferred System Plan, Rulemaking 20-05-003, May 7, 2020, pp. 7-8.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

CAISO's Wildfire Impact Assessment should reflect planned removal of transmission infrastructure

CAISO's Wildfire Impact Assessment for PG&E’s service area includes transmission facilities that PG&E may remove in the near future.  Notably, the analysis considers the impact of the potential de-energization of the Geysers #9 - Lakeville transmission line.[1]  CAL FIRE concluded, and PG&E does not contest, that the 2019 Kincade Fire originated from a mechanical failure on the Geysers #9 line.[2]  At this time, an official determination on whether or not the Geysers #9 line will be removed is not available.

Under an Administrative Consent Order between PG&E and the Safety Enforcement Division of the CPUC, PG&E agreed to partially or completely remove 70 transmission lines.[3]  However, this Administrative Consent Order does not identify the specific facilities to be removed.[4]  Cal Advocates urges the CAISO and PG&E to identify the lines that will be removed, pursuant to the proposed Administrative Consent Order, so that the CAISO will have updated transmission line information for its Wildfire Impact Assessment study.

Transparency in the Transmission Planning Process

Cal Advocates recommends the CAISO provide transparency in its TPP in the following areas:

1. All proposed economic and policy projects that the CAISO intends to recommend for approval should be clearly indicated in the planning process as early as possible, so stakeholders have sufficient opportunity to review and comment on these projects. 
2. CAISO should provide capital costs or best estimates of capital costs for all proposed projects and project alternatives in the TPP, as early as possible.
3. CAISO should clearly present how capital cost estimates for proposed transmission projects are generated.  If all cost estimates are provided by the incumbent utility, this should be clearly stated as a modeling assumption.  In order to confirm cost estimates, Cal Advocates recommends that the CAISO consider using a third-party cost estimator for proposed projects as well.
4. Cal Advocates recommends that the CAISO record all TPP meetings and post recordings in a publicly accessible location consistent with its practice for other CAISO stakeholder engagement initiatives and workshops.  TPP meetings provide important information and a key engagement platform for stakeholders.  All TPP meetings should also be recorded for stakeholders who cannot attend at the specific time and published for public accountability.  CAISO already demonstrates that there is no technological or logistical barrier to recording and publishing other workshops or stakeholder engagement events.
5. For economic evaluations of transmission projects that may go before the CPUC for a Certificate of Public Convenience and Necessity (CPCN), Cal Advocates recommends that the CAISO Board make the findings required by CPUC Decision (D.) 06-11-018 with regard to the economic evaluation:
   1. 1. During the TPP, the CAISO sponsored at least two meetings open to the public with opportunity for public comment both at the meeting and following the meeting, including: (1) an initial meeting, which occurs sufficiently early in the CAISO’s assessment process to provide an opportunity to discuss the scope of the proposed economic assessment, including identification of the base case and other relevant assumptions, as well as resource alternatives and (2) a second meeting to take public comment on the draft economic evaluation prior to its submission to the CAISO Board.
      2. The final economic evaluation that is submitted to the CAISO Board includes reasoned responses to all public comments by explaining how the comment was addressed in the final evaluation, either through incorporation in full, modification, or rejection, and the reasons thereof.
      3. The public participation process has provided interested stakeholders with sufficient time and opportunity (including sufficient access to information) to adequately review and comment on the draft evaluation.
      4. That the final economic evaluation meets all the requirements of D.06-11-018, as it may be amended by future CPUC decisions, including the Principles and Minimum Requirements for the Economic Evaluation of Proposed Transmission Projects set forth as Attachment A to D.06-11-018.
      5. That the final economic evaluation determines that the proposed transmission project promotes economic efficiency in that it constitutes a cost-effective upgrade to the CAISO Controlled Grid based on clearly defined information, assumptions, and weighting or combination of the relevant benefit-cost rations and other economic criteria, including (but not limited to) difficult to quantify economic benefits, such as system operational benefits.

[1] CAISO, 2021-2022 TPP Wildfire Impact Assessment – North Coast North Bay Area Update, November 18, 2021, p. 4.

[2] Settlement Agreement Between Pacific Gas and Electric Company and the Safety and Enforcement Division of the California Public Utilities Commission Resolving the Investigation into the Kincade Fire Pursuant to a Proposed Administrative Consent Order (Resolution M-4846), November 1, 2021 (Settlement Agreement), pp. 2-3. https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M420/K105/420105479.pdf.

[3] Settlement Agreement, p. 5.

[4] Cal Advocates has issued discovery to PG&E to obtain this information and expects responses on December 10, 2021. Public Advocate’s Office data request CalAdvocates-PGE-NonCase-AWM-11132021, November 24, 2021.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

CAISO 2021-22 TPP and 20 Year Outlook November 18, 2021, Stakeholder Meeting

California Western Grid, LLC - Stakeholder Comments

December 6, 2021

California Western Grid Development, LLC (“California Western Grid” or “CWG”) appreciates this opportunity to submit comments and recommendations that arise from the November 18, 2021, Stakeholder Meeting and Slide Presentation (“Presentation”).

CWG has been an active stakeholder in the CAISO 2021-22 TPP and the CAISO 20-Year Outlook. We submitted stakeholder comments on August 10, 2021, and on October 12, 2021, related to the CAISO Stakeholder meetings held on July 27, September 27, and September 28, 2021. On October 15, 2021, CWG submitted a Project Review Request for the subsea HVDC Pacific Transmission Expansion Project (“PTE” or “PTEP”).

CWG will not repeat our prior comments, but we would like to emphasize three points made in our earlier submissions that are very relevant to the remaining 2021-22 TPP CAISO analysis and the January 2022 draft final report.

• The CAISO must take the initiative to identify and approve least regrets long lead time transmission projects immediately as part of this 2021-22 TPP. (CWG 11/12 comments page 1) The November 18 stakeholder meeting presentations make clear that an unprecedented amount of new preferred generation sources will be connected to the grid in the next 10 to 20 years. The CPUC portfolios and procurement orders have not given CAISO sufficient time for planning long lead time transmission (Presentation at 179/186). It is time for the CAISO to provide grid planning leadership and start approving public policy driven transmission projects that are required to meet California’s SB 100 and other policy goals.
• The CAISO must focus on reliably transmitting power from remote areas where new renewable resources will be developed and delivered to urban load centers.  The recent CAISO TPP cycles have been driven by CPUC resource portfolios which appear to have entirely ignored the need to get power to load and focused only on getting power to the grid. The result is stubbornly high LCR Procurement requirements and curtailment of renewables during the same hours that gas plants continue to run in urban load centers. Studies described by the CAISO on November 18 will identify some least regrets transmission solutions. Specifically, the scenario portfolios for OSW, along with the CAISO 20-year outlook will identify some least regrets solutions to bring power into the SF Bay area and LA Basin. Combine those findings with the recently completed CAISO Battery study (see CAISO 2020-21 TPP final report, appendix G, page G-140) and recent CAISO LCRA studies and it is clear new transmission into locally constrained load pocket is needed and failure to plan for new transmission will add costs and ultimately degrade reliability to California ratepayers. CAISO should identify and approve best fit, most effective transmission solutions for delivery into the LA Basin and SF Bay Area in this planning cycle. Delaying transmission projects that are consistent with the CAISO’s 20 Year Outlook to enable CA climate legislation is not in the public interest.
• CAISO should fulfill its Tariff obligation to identify and approve transmission needed to meet State Public Policy Objectives. (Section 24.4.6.6 of the CAISO’s tariff). As the CAISO is aware, CWG has requested that the PTE Project be studied in the 2021-22 TPP as an economic project and a project needed to accommodate State Public Policy requirements. As CWG described at pages 9 – 21 of our October 15 Project Review Request Submittal, California’s Public Policy objectives have been made clear by SB 100 and other laws and Proclamations and Executive Orders issued by Governor Gavin Newsom. Strictly approving transmission that falls out of CPUC preferred resource portfolios is not enough and fails to prepare the State for more than 100,000 MW of new wind and solar resources[1] by 2040, the phasing out of existing fossil generation and delivery of energy to transmission constrained urban load centers.

CWG is encouraged to see that the CAISO in the 2021-22 TPP is “intending to consider additional upgrades beyond those identified through an analysis in this planning cycle using the base portfolio…”  CAISO September 28, 2021, Stakeholder Presentation Slide 12/18) thereby demonstrating CAISO willingness to exert long over-due leadership in development of the grid of the future needed to fulfill SB100 requirements. This is not a time for timid or limited action. Least regrets long lead time transmission projects must be approved in the 2021-22 TPP in order to jumpstart the long and tenuous process to ultimately putting steel in the ground. The CAISO has repeatedly cautioned the CPUC that new transmission has a 10 year or more lead time and therefore new transmission must be planned and approved immediately if we intend to rely on new transmission solutions. It is neither possible or practical to triple the amount of new generating resources on the grid by 2040 or 2045¹ without significant expansion of existing grid capacity. And given the long lead time to plan, permit and build new transmission, the CAISO must start new least regrets transmission now. The CAISO’s approval of these transmission solutions is needed now to begin the process. Otherwise, California risks failing to meet its Public Policy Climate goals.

We appreciate that the CAISO is planning to evaluate an under-sea transmission project like PTEP that can meet local reliability needs, bring clean preferred resources from the 500KV backbone transmission system in central California directly to the West LA LCRA where it can reduce dependence on gas plants within the LA Basin, allow recharging of batteries with zero emission resources, reduce system curtailment of renewable resources².while also providing other benefits such as reducing wildfire risk. We see the CAISO intends to evaluate the benefits of such a project in three contexts: (1) evaluating the CPUC OSW sensitivity portfolio (Slide 93/186), as an economic project (Slide 143/186) and in the 20-year outlook (slide 182/186). But CAISO must also address CWG’s request for PTE to be studied as a Public Policy Project as is required by its own tariff provisions.

In summary, CWG believes the 2021-22 TPP is making some progress in meeting California’s transmission needs, but without bold action taken by the CAISO now, it will fall far short in addressing the critical need for the CAISO to identify and approve long lead time transmission like PTEP needed to meet State Public Policy, as articulated in SB 100 and elsewhere by the legislature and Governor.

CALIFORNIA WESTERN GRID COMMENTS ON SPECIFIC PRESENTATIONS AND SLIDES FROM THE NOVEMBER 18 STAKEHOLDER MEETING 

Policy Assessment - General

The CAISO should summarize key findings in a more understandable way. Buried in 186 slides on November 18 were some key findings, and in some cases other key findings have been left out of the presentation all together and must be addressed in the January 31,2021 Preliminary final report.

For example:

• How many GWH of system wide curtailment of renewables is expected in 2031 and at what cost given the CPUC base or preferred portfolio and the CAISO recommended transmission upgrades? How much curtailment of renewables is expected in 2031 and at what cost under each of the CPUC sensitivity portfolios?
• How many GWH of dumping energy at negative prices to neighboring utilities and LSEs is expected in 2031 and at what cost given the CPUC base or preferred portfolio and the CAISO recommended transmission upgrades? How much dumping of energy is expected in 2031 and at what cost under each of the sensitivity portfolios?
• Instead of reporting cumulative findings for various combinations of OSW sensitivity portfolio transmission project alternatives, and thereby co-mingling Humboldt transmission solutions with Diablo/Morrow Bay transmission solutions, show how individual transmission alternatives contribute to the delivery of OSW for each Diablo/Morrow or Humboldt, separately.

Offshore Wind Sensitivity Portfolio

For the OSW sensitivity, CWG is pleased CAISO is including a subsea cable as one of three alternatives for delivery of Diablo/Morro Bay wind energy to Southern California. (Slide 93/186). When assessing the benefits of the three alternatives, CWG urges the CAISO to evaluate all the attributes of each alternative. For example, the VSC HVDC subsea solution will allow delivery of OSW and Central California solar directly to the transmission constrained LA Basin, thereby allowing phase out of gas generation, reduce LCR payments and avoid system wide curtailment of renewable resources². Other benefits of a subsea transmission solution should also be included in the analysis; for example, the health benefits of reduced criteria pollutants on citizens of the LA Basin, reduced impact on Disadvantaged Communities, providing resiliency in affected areas by hardening the system against wildfire risk, and improving the reliability of the LA Basin with a grid conforming HVDC source that provides local inertia and rapid stability response.

Preliminary Economic Assessment Results

CWG asks CAISO to share key assumptions that will be used in the 2021-22 TPP economic assessment. No single assumption is more important than the values the CAISO will use in determining economic benefits of LCR reduction.

At the November 2020 TPP Stakeholder meeting the CAISO shared values for RA which were derived from public information provided by the CPUC. Among the values were NP26 and SP26 values of $2.87 /kw/mo. and $2.38 /kw/mo., and for the LA Basin $3.66 /kw/mo. CWG asks the CAISO to share what RA values will be used by CAISO in the 2021-22 TPP Economic Assessment. CWG further requests CAISO share why it believes the CPUC-provided RA Values are appropriate for TEAM analysis and if there are additional costs to ratepayers, beyond the RA values of continuing to rely on gas fired generation in meeting local reliability needs that should be included in the TEAM analysis.

CWG further asks the CAISO to explain how health effects, impact on DACs, reduced wildfire risk, reduced renewable curtailment, and how the potential to reduce reliance on Aliso Canyon gas storage facility will factor into the 2021-22 TPP assessment of potential economic solutions.

Economic Planning Study Requests

CWG looks forward to seeing the results of the CAISO assessment of the Pacific Transmission Expansion Project (slide143/186).

As the CAISO knows, study of this project in a previous TPP cycle showed the project can reduce LCR needs in the LA Basin by 1,993 MW. CWG looks forward to an update on the amount LCR the CAISO finds can be avoided should a project such as PTE be approved. CWG further urges the CAISO include in its assessment a quantification of the amount and cost of system wide curtailment of renewables that can be avoided by the Pacific Transmission Expansion Project.

In CWGs October 15 Project Review Request submission, we shared results of a study we did that shows a subsea transmission line such as PTE can reduce system-wide renewable curtailment. The savings to customers had a minimum NPV of $750 Million. (CWG October 15, 2021, Filing at Attachment A, pp. 19-23). The calculation was derived from running the CAISO 2030 Production cost model with and without the PTE for the year 2030. We found in only four months of 2030 the PTE saved ratepayers $57 million by bringing power from 500 KV backbone system in central California to the transmission constrained LA Basin. Renewable energy which would have otherwise been curtailed. This is renewable energy that customers had already paid for but could not be delivered to major load centers where it can be used. The calculation note above, was for only one year (2030), extrapolated out into the future. Given the significant increase in new renewables proposed to be added to the system in just the next decade (2030-2040), where more than an additional 100,000 MWs are being planned over that period, this problem is likely to be substantially exacerbated at increasing costs to California’s customers. The PTE provides an elegant solution for part of that problem.

20-Year Transmission Outlook

CWG fully supports the direction the CAISO 20-year Transmission Outlook is heading. Especially the study to identify transmission needed to get power from resource areas to load centers and with a special focus on the SF Bay Area and LA Basin (Slide 182/186).

However, we urge the CAISO make the results of this 20-year outlook analysis actionable in this 2021-22 TPP cycle. The CAISO should identify candidate transmission solutions to bring resources to load centers, rank those alternatives and request the CAISO Board to approve one or more least regrets long lead time transmission solutions in the current 2021-2022 cycle.

CWG understands the CAISO 20-year outlook is anchored by a resource portfolio for 2040, a point on the path to meeting current SB 100 goals. However, On July 9, 2021, Governor Newsom issued a directive asking the CPUC and CARB look at accelerating achievement of the SB 100 goals: https://www.gov.ca.gov/2021/07/09/governor-newsom-holds-virtual-discussion-with-leading-climate-scientists-on-states-progress-toward-carbon-neutrality/.  Given the Governor’s statement, the CAISO should be preparing for transmission on a least regrets basis that could enable the State to meet any new requirements for earlier implementation of State policy.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          

Evidence builds every day that indicates the timeframe for meeting SB100, and related State Policy goals is likely to be accelerated as a political and environmental imperative, making his directive more likely to be implemented.

The convergence of climate urgency (as COP26 has so highlighted), social and environmental justice for DACs, pressure to wean our economy from natural gas and shut down facilities such as Alison Canyon, the need to harden the grid to wildfires, and address wasteful renewable curtailment and dumping of renewable energy are all gathering momentum, and all require a more resilient robust energy grid.

The CAISO needs to provide leadership to envision, plan and start on the path to building the grid that California needs. The CAISO cannot continue to keep waiting for guidance from the CPUC and cannot ignore its own FERC tariff obligation to plan transmission for public policy needs.

CWG has been participating in the CPUC IRP Proceeding with both written comments and oral comments at CPUC Workshops. In a September workshop we asked when the CPUC would start planning to meet the needs of local capacity areas. The response we got was “we are going to need to develop tools to do the local areas planning.” Here it is, the end of 2021, and the CPUC does not have a plan or timeframe to build the tools it feels are necessary to begin to evaluate phasing out gas fired generation.

If the CPUC takes 2-3 years to build, test and implement these new tools, the IRP’s that will determine whether new transmission can be built cannot be approved by the CPUC until after 2025 at the earliest.  Given that it takes 10 years or more to add significant new transmission lines, which means small increments of new transmission will enter service late in the next decade, leaving only a few short years to meet the requirements of SB100 in 2045. If there is any consideration to move forward the SB 100 timeline suggested by the Governor, the CAISO will be at risk of being the cause for failing to be able to implement the directive. It would not be surprising if in the very near future, the CPUC yields to the political urgency to address climate change, achieve social justice for DACs, accelerate closure of Aliso Canyon and responds by announcing a willingness to shut down gas plants in urban areas such as LA and shut them down quickly.  If so, CAISO can be caught flat footed with a grid that is not up to the task.

The CAISO simply cannot keep waiting for the CPUC to lay out a plan for phasing out gas plants in transmission constrained urban load centers such as LA. California public policy goals are clear, but they depend on an expanded transmission grid and cannot be achieved without leadership from the CAISO. The CAISO is the only party capable of doing that and it has an obligation to do so. Tomorrow’s grid will simply need to be different and stronger to accommodate the coming changes.

The CAISO 20-year transmission outlook and other studies the CAISO has done will show a path forward, however, the CAISO needs to do more than provide studies to inform the public debate. The CAISO must lead and lead by approving long lead time least regrets transmission in 2022.

[1] A key highlight of the March 2021 Joint Agency Summary Report on SB 100 is the conclusion that "California will need to roughly triple its current electricity grid capacity.”  And the projected SB 100 renewable portfolio will include over 100GW of new wind and solar resources  https://www.energy.ca.gov/news/2021-03/california-releases-report-charting-path-100-percent-clean-electricity

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

Preliminary Economic Assessment Results

CWG asks CAISO to share key assumptions that will be used in the 2021-22 TPP economic assessment. No single assumption is more important than the values the CAISO will use in determining economic benefits of LCR reduction.

At the November 2020 TPP Stakeholder meeting the CAISO shared values for RA which were derived from public information provided by the CPUC. Among the values were NP26 and SP26 values of $2.87 /kw/mo. and $2.38 /kw/mo., and for the LA Basin $3.66 /kw/mo. CWG asks the CAISO to share what RA values will be used by CAISO in the 2021-22 TPP Economic Assessment. CWG further requests CAISO share why it believes the CPUC-provided RA Values are appropriate for TEAM analysis and if there are additional costs to ratepayers, beyond the RA values of continuing to rely on gas fired generation in meeting local reliability needs that should be included in the TEAM analysis.

CWG further asks the CAISO to explain how health effects, impact on DACs, reduced wildfire risk, reduced renewable curtailment, and how the potential to reduce reliance on Aliso Canyon gas storage facility will factor into the 2021-22 TPP assessment of potential economic solutions.

Economic Planning Study Requests

CWG looks forward to seeing the results of the CAISO assessment of the Pacific Transmission Expansion Project (slide143/186).

As the CAISO knows, study of this project in a previous TPP cycle showed the project can reduce LCR needs in the LA Basin by 1,993 MW. CWG looks forward to an update on the amount LCR the CAISO finds can be avoided should a project such as PTE be approved. CWG further urges the CAISO include in its assessment a quantification of the amount and cost of system wide curtailment of renewables that can be avoided by the Pacific Transmission Expansion Project.

In CWGs October 15 Project Review Request submission, we shared results of a study we did that shows a subsea transmission line such as PTE can reduce system-wide renewable curtailment. The savings to customers had a minimum NPV of $750 Million. (CWG October 15, 2021, Filing at Attachment A, pp. 19-23). The calculation was derived from running the CAISO 2030 Production cost model with and without the PTE for the year 2030. We found in only four months of 2030 the PTE saved ratepayers $57 million by bringing power from 500 KV backbone system in central California to the transmission constrained LA Basin. Renewable energy which would have otherwise been curtailed. This is renewable energy that customers had already paid for but could not be delivered to major load centers where it can be used. The calculation note above, was for only one year (2030), extrapolated out into the future. Given the significant increase in new renewables proposed to be added to the system in just the next decade (2030-2040), where more than an additional 100,000 MWs are being planned over that period, this problem is likely to be substantially exacerbated at increasing costs to California’s customers. The PTE provides an elegant solution for part of that problem.

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

20-Year Transmission Outlook

CWG fully supports the direction the CAISO 20-year Transmission Outlook is heading. Especially the study to identify transmission needed to get power from resource areas to load centers and with a special focus on the SF Bay Area and LA Basin (Slide 182/186).

However, we urge the CAISO make the results of this 20-year outlook analysis actionable in this 2021-22 TPP cycle. The CAISO should identify candidate transmission solutions to bring resources to load centers, rank those alternatives and request the CAISO Board to approve one or more least regrets long lead time transmission solutions in the current 2021-2022 cycle.

CWG understands the CAISO 20-year outlook is anchored by a resource portfolio for 2040, a point on the path to meeting current SB 100 goals. However, On July 9, 2021, Governor Newsom issued a directive asking the CPUC and CARB look at accelerating achievement of the SB 100 goals: https://www.gov.ca.gov/2021/07/09/governor-newsom-holds-virtual-discussion-with-leading-climate-scientists-on-states-progress-toward-carbon-neutrality/.  Given the Governor’s statement, the CAISO should be preparing for transmission on a least regrets basis that could enable the State to meet any new requirements for earlier implementation of State policy.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          

Evidence builds every day that indicates the timeframe for meeting SB100, and related State Policy goals is likely to be accelerated as a political and environmental imperative, making his directive more likely to be implemented.

The convergence of climate urgency (as COP26 has so highlighted), social and environmental justice for DACs, pressure to wean our economy from natural gas and shut down facilities such as Alison Canyon, the need to harden the grid to wildfires, and address wasteful renewable curtailment and dumping of renewable energy are all gathering momentum, and all require a more resilient robust energy grid.

The CAISO needs to provide leadership to envision, plan and start on the path to building the grid that California needs. The CAISO cannot continue to keep waiting for guidance from the CPUC and cannot ignore its own FERC tariff obligation to plan transmission for public policy needs.

CWG has been participating in the CPUC IRP Proceeding with both written comments and oral comments at CPUC Workshops. In a September workshop we asked when the CPUC would start planning to meet the needs of local capacity areas. The response we got was “we are going to need to develop tools to do the local areas planning.” Here it is, the end of 2021, and the CPUC does not have a plan or timeframe to build the tools it feels are necessary to begin to evaluate phasing out gas fired generation.

If the CPUC takes 2-3 years to build, test and implement these new tools, the IRP’s that will determine whether new transmission can be built cannot be approved by the CPUC until after 2025 at the earliest.  Given that it takes 10 years or more to add significant new transmission lines, which means small increments of new transmission will enter service late in the next decade, leaving only a few short years to meet the requirements of SB100 in 2045. If there is any consideration to move forward the SB 100 timeline suggested by the Governor, the CAISO will be at risk of being the cause for failing to be able to implement the directive. It would not be surprising if in the very near future, the CPUC yields to the political urgency to address climate change, achieve social justice for DACs, accelerate closure of Aliso Canyon and responds by announcing a willingness to shut down gas plants in urban areas such as LA and shut them down quickly.  If so, CAISO can be caught flat footed with a grid that is not up to the task.

The CAISO simply cannot keep waiting for the CPUC to lay out a plan for phasing out gas plants in transmission constrained urban load centers such as LA. California public policy goals are clear, but they depend on an expanded transmission grid and cannot be achieved without leadership from the CAISO. The CAISO is the only party capable of doing that and it has an obligation to do so. Tomorrow’s grid will simply need to be different and stronger to accommodate the coming changes.

The CAISO 20-year transmission outlook and other studies the CAISO has done will show a path forward, however, the CAISO needs to do more than provide studies to inform the public debate. The CAISO must lead and lead by approving long lead time least regrets transmission in 2022.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

Generally, as we anticipated in our August 10, 2021, comments, the current TPP cycle is proving to be of extremely limited value due to the stunted vision reflected in the CPUC’s IRP-TPP base portfolio – which seemed designed to avoid transmission upgrades -- and the ISO’s unwillingness to exercise its own prerogative to conduct more robust studies in view of clear future needs.  California’s ability to efficiently and timely meet its SB 100 goals will suffer as a result. 

More specifically, we offer the following comments:

1. The deliverability study assumption for offshore wind is set to 100% in the HSN deliverability assessment, which seems unrealistically high. Please clarify how the study assumptions were determined for both HSN and SSN and whether more realistic assumptions can be used for future TPP cycles.

2. The presentation shows that 5.3 GW of Central Coast offshore wind and 1.6 GW Humboldt offshore wind under option 2 or 3 are deliverable without transmission upgrades.  While these appear to be encouraging results, they assume that the Diablo Canyon Nuclear Power Plant (DCNPP)’s transmission planning deliverability (TPD) capacity will become available and be made available exclusively for offshore wind. Please explain whether this available deliverability could vanish if PG&E retains its transmission rights and in view of the various resources in the generation interconnection queue that do not show up in the policy studies.

CAISO should seek to improve the likelihood that offshore wind projects will acquire a portion of any available TPD capacity rights at the Central Coast in two ways:

First, the ISO should make available considerable deliverability capacity by making reasonable reforms to its deliverability methodology, as CalWEA discussed in its August 10, 2021, TPP comments (see response to question 2).  To make some progress on this issue, CalWEA suggests removing the SSN deliverability methodology.

Second, the ISO should seek to acquire the necessary TPD capacity for Central Coast offshore wind from PG&E and its retiring DCNPP. The payment offered by the ISO (via the Transmission Access Charge) would be based on the embedded cost of transmission infrastructure built to support DNCPP, and the proceeds should reduce the TAC for PG&E’s customers.  Assuming the ISO acquires the TPD capacity rights, those rights will become part of the network and immediately available for subscription to developers in the area where there is considerable demand for TPD rights from solar and storage projects. Therefore, it is essential that rights acquisition be timed such that (a) the leases for offshore wind development have been issued by the federal BOEM, expected in 2022-23, so that developers are in a position to file and secure an interconnection agreement under the ISO’s tariff, and (b) developers have secured power purchase agreements (PPAs), given that the ISO assigns TPD rights on a priority basis and gives developers holding PPAs the highest priority.  While this will not ensure that all offshore wind projects obtain TPD capacity, it will give them a strong opportunity.  The ISO should coordinate with the Commission on this matter.

Request for clarification:  We note that p. 92 of the PDF file containing the ISO’s presentation shows the affected transmission zones as Humboldt, which we believe should, instead, reflect the Central Coast area.

3. No significant policy upgrades were identified due to the large amount of energy-only (EO) resources in the portfolio. The EO assumption does not align with the reality that all generators in the interconnection queue want deliverability. Again, to make some progress on this issue, CalWEA suggests removing the SSN deliverability methodology.

4. Please clarify how the out-of-state wind study assumptions were determined in the deliverability assessment. It looks like out-of-state wind has much lower output than offshore wind during the net-load peak hours and somewhat lower output during the gross load peak hours. In the context of the generation interconnection queue, granting deliverability to out-of-state wind in addition to the import deliverability already being preserved would take away deliverability available to the generation already in the queue. Considering all the factors, offshore wind appears to be more beneficial to ISO ratepayers in terms of performance to meet reliability need, cost of facilities for California to access resources, and impacts on other resources obtaining deliverability.

5. The development of the current on-peak deliverability assessment methodology focused on peak load shifting and wind/solar performance during different load condition time periods. The Secondary System Need (SSN) scenario, in particular, is for high gross load and relatively high solar output. The assumption is that, although the reliability risk is low due to available solar output, there is still a risk if a large amount of solar output is constrained by transmission. However, there was little attention on the performance of dispatchable resources during the SSN time window. All non-wind and non-solar resources were simply assumed to produce up to their full NQC. This assumption is unrealistic. When there is abundant solar, flexible resources are at low, or even negative, output (i.e., storage charging) to get ready for later hour, fast net-load ramping requirements and the peak net load (HSN). With full NQC output, the SSN analysis is contaminated by skewed dispatch assumptions due to over-supply. The SSN study does not, therefore, properly identify the potential reliability risk that the deliverability assessment intends to identify and should be eliminated. 

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

It will be helpful to see the utilization of the out-of-state wind and the offshore wind in various sensitivity studies. We encourage the ISO to include plots of wind output, load and import in the draft report.

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

CalWEA generally supports the relatively limited reliability projects.

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

No comment at this time. 

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

• CalWEA questions why in-state wind would drop to 2,237 MW in the SB 100 Starting Point scenario from the 3,553 MW in 2025 and 2032.  
• As explained in our August 10, 2021, TPP comments, we continue to recommend that the ISO study an offshore network to efficiently integrate offshore wind resources while also strengthening the backbone grid.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

No additional comment.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

• Fulton 60KV Transmission Upgrade in PG&E

Calpine appreciates that the ISO agrees to recommend a Fulton 60kV transmission upgrade/reconductor as P7 contingency issue.  This upgrade will enhance local 60kV and 115kV transmission capability.  Calpine appreciates that both PG&E and the ISO diligently develop this resolution. Calpine asks more information on this upgrade including timeline.

• Doublet Tap-Friars 138kV Line Constraint in SDG&E

Calpine appreciates that both the ISO and SDG&E acknowledged the P6/P7 reliability need and developed the resolutions for the Doublet Tap-Friars 138kV line constraint.  This same issue has been discussed last year.   SDG&E proposed a split of two lines, or the rearrangement of TL 23013 and TL 6959 230KV lines, for them not to share the same tower, thus removing the double contingency issue.  The cost will be $19 Million, with an in-serve date in 2026.  The ISO did not approve the SDG&E’s proposal and instead, its board approved a Remedial Action Scheme (RAS) using the local Otay Mesa generation.  Calpine thinks that the CAISO’s approval for the RAS as interim or near-term resolution is viable, as its expected in-service date will be around summer 2022.   However, the RAS proposal will not be able to mitigate this constraint: Per ISO’s 2020-2021 TPP study, the RAS approach only solves one third of the problem, since the annual congestion cost only reduces from 78.59 Million to $52.74 Million for the planning year 2030; the ISO also studied the case with the extended RAS and concluded the extended RAS does not meet economic criteria.   In this year’s meeting, CAISO acknowledged that an extended RAS may not be practical and agreed to give stakeholder an update after rerunning its cases.  Most probably, the constraint will continue to remain as one of the top constraints without the extended RAS.  In addition, majority of the congestion of the Doublet Tap -Friars 138KV line occurs outside the solar hours, so using solar generation for RAS will not be practical.  Furthermore, the constraint is more correlated with the San Diego importing flow (including renewable generation from east) than with the generation output in the Otay Mesa area over the year. 

SDG&E continues to observe this overload issue during heavy north bound flow as of today and the issue is expected to become more severe in 2026.  SDG&E therefore proposed a new reliability project this year: rerating for the 138KV line from 150MVA to 204MVA. The expected cost will be $5.5Million, with ISD in 2022.  This enhancement will be able to alleviate the overload for the next several years.  However, this does not completely solve the issue and the overload will come back by the end of this decade with more renewable flowing from East to San Diego area.

Calpine appreciates the discussion on this reliability issue, and values all the projects proposed by the ISO and SDG&E.   To help California to transfer more renewable energy and develop a more robust transmission grid, Calpine leans its preference to transmission upgrade as a final resolution.  Calpine offers the following comments to the three options, and deems the first option as its preferred option:

1. The “Rearrange TL 23013 and TL 6959” is Calpine’s preferred approach.  This approach can remove the double-contingency, thus resolve the overload of the 138kV constraint totally.  This approach will also be able to bring more renewable generation to SDG&E and SCE area.  Even though it will cost $19 Million, the cost is still reasonable for the #1 constraint in the ISO. The next two approaches do not 100% solve the problem, not to mention that additional budget will be needed in later years.
2. As a short-term to mid-term approach, Calpine also supports the “Friars –Double Tap Reconductor” approach.  The cost is relatively less and ISD is earlier in 2022.  However, this approach still does not solve the problem, and the issue will come back around or before 2030.
3. As a temporary approach, the approved RAS is a relatively quick and easy approach and Calpine anxiously awaits conversations with SDG&E to include Otay Mesa Energy Center in the RAS.  As discussed above, it only addresses 1/3 of the issue and it relies on RAS action tripping generation in Otay Mesa area.  It does not fundamentally address the transmission issue, and the congestion will be severe again with more renewable in coming years.
4. To 100% solve the problem, combination of #1 and #3 approach, or combination of #1 and #2 approach might also be good options in terms of balancing ISD and cost.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

As commented in the Policy section, CAISO will rerun the economic study and present the updated results by removing the extended RAS for the Doublet Tap-Friars 138kV line constraint.

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

• Wildfire Impact Assessment in North Coast North Bay area.

Calpine appreciates that the ISO has studied different scenarios in the North Coast and North Bay area and developed 230KV transmission hardening recommendation to prevent loss of load in the region.  Calpine welcomes the thorough scenarios that the ISO developed.  This effort is expected to trigger generation tripping and local transmission outages.  Calpine would offer full support and close coordination among the ISO, PG&E and its generation assets. Calpine asks more information on this hardening plan including timeline.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

Meeting California’s 100% decarbonization goals require additional Variable Renewable Resource facilities that will need to be overbuilt by a factor of 2.5 to 4 times to ensure the resiliency, security, and reliability of the new GHG-neutral grid by 2045.  But additional generation facilities are only part of the transition resources needed. The California grid system will also need to increase its present transmission system by 150% to accommodate the VRE growth. 

Out of state generation and storage and out of state transmission must be part of the infrastructure in place to not overwhelm in-state transmission infrastructure while reaching the benchmarks of the 2045 mandates. The SWIP-N and Great Basin high-voltage line would be a critical component of this infrastructure.  It should be considered a California ISO transmission asset.  

SWIP-N and its Harry Allen/Eldorado terminus will provide large scale transmission access directly to the CAISO system.  Cat Creek Energy & Water Renewable Power Station (CCEW) helps bridge any service requirement in the transition to Net Zero by 2030 and well into the 22^nd Century.  At the northern Midpoint terminus of SWIP-N, CCEW furnishes 720 MW in a generation and storage facility capable of instantaneous response in a suite of services which a utility is obligated to provide, simultaneously, in sequence, or with the ability to fluctuate between any of those services as called on within seconds.  

As important, it allows a firm hourly resource for other VRE resources [e.g., LS Power’s Idaho wind park] that can help reach the California 2045 full decarbonization mandate.  But of far more import is the ability of CCEW’s massive Large Volume, Long Duration energy storage component [87,120 MWhrs] to absorb the inevitable oversupply of California-based VRE resources daily and be redeployed as called on back into the CAISO grid.  

From a grid stability standpoint, it seems necessary for the CAISO to consider Out of State resources in energy, storage, and transmission given the huge lift required to at least double the existing transmission grid over the coming 23 years.  

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

 The CAISO is to conduct an outlook assessment for 21.2 GW of OSW to ensure potential transmission development for early offshore wind resources is “least regrets.” EDF-R supports “least-regrets” planning and encourages the CAISO to continue with these efforts. In the same vein, EDF-R encourages CAISO to collaborate with PTOs to identify more multi-benefit upgrades that address reliability purposes and also improve new-resource deliverability for the same areas. EDF-R supports CAISO’s recommended upgrades GLW/ VEA, and believes complexities of coordination between LADWP, NV Energy and WAPA are surmountable given the pressing need to increase generation across the west.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

EDF-R supports CAISO’s recommendation to approve the Contra Costa 230 kV upgrade, Vasona-Metcalf 230 kV Project, Coppermine 70 kV Reinforcement Project, Cortina 230/115/60 kV Bank #1 Replacement, Manteca-Ripon-Riverbank-Melones Area 115 kV Line Reconductoring, and the Weber - Mormon Jct 60 kV Line Section Reconductoring.

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

EDF-R appreciates this forward-looking study and agrees with the CAISO’s current approach. As CAISO embarks on the next steps for the 20-year review EDF-R continues to encourage the CAISO to seek agreement from the joint agencies to adopt a more agile approach to transmission planning. It seems logical that, in addition to the process outlined in the joint agencies alignment plan, the CAISO could have an urgent transmission planning process to complement and neatly align with the CPUC’s emergency procurement efforts. For example, the CAISO’s urgent transmission planning process could review and confirm sufficient transmission exists to support the interconnection and deliverability levels outlined in any approved emergency procurement, and if not, make recommendations for transmission solutions to be inserted into whatever TPP is open at the time, and to facilitate speedy approval for upgrades needed to support urgent procurement, rather than waiting for the start of a new cycle.

EDF-R appreciates CAISO’s effort to this end in efforts like the transmission capability estimate inputs for CPUC integrated resource plan published Jul 27, 2021, and strongly supports the CAISO moving forward with Antelope-Vincent 500 kV line rating increase and Gates Transformer #3 upgrades, given the cost per MW, the benefits being in the GW magnitude, and the relatively quick construction time. EDF-R also supports the SIlvergate – Bay Blvd 230 kV 2-ohm series reactor, despite its longer construction time.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

Golden State Clean Energy (“GSCE”) appreciates the California ISO’s effort this year to study the system for the transmission infrastructure needed to support sufficient levels of renewable energy resources to enable California to reach its GHG reduction goals. The ISO’s efforts to think more broadly about how its annual transmission planning process can support timely development is critical, as is the 20-year transmission outlook. We believe that the ISO is putting the right focus on the significant growth in resource portfolio capacity and challenging how the TPP process can adapt to respond to increasing infrastructure development requirements that will be essential to meeting policy goals reliably and affordably.

GSCE continues to support the ISO in its examination of out-of-cycle needs and would support the ISO ultimately approving projects based on anticipatory needs. The majority of commenters in the previous TPP comment cycle also appear to support the ISO in this examination. Whether it is the list of ADNUs the ISO discussed during a previous TPP meeting, or the two upgrades the ISO raised during the November 18 meeting, the issue that the ISO has raised is clear and important to address. Although there is debate about the ultimate composition and location of the resources on the system in the 10-year timeframe, there is a clear trend of new capacity coming online over the coming decades that will stress the system throughout. Likely much of the ISO controlled grid is faced with a when question and not an if question in considering the need for transmission upgrades, meaning transmission investments in areas where future capacity is expected has a reduced risk of stranded investment. Since the California Public Utilities Commission has generally not required procurement of the exact resources or location represented in its resource portfolios, waiting on the next portfolio of resources to direct transmission investments does not necessarily provide a reduction in investment risk. Indeed, the most regrettable decision is delaying action on transmission development and failing to reach policy goals rather than committing to transmission development that may not be perfectly aligned with future resource portfolios.

In addition, while we have previously offered our view of what is needed to allow California to most orderly and efficiently reach its 2045 SB 100 goals, we understand this is not an easy task and that much uncertainty lies ahead. We appreciate the ISO taking the step of beginning the 20-year transmission outlook in recognition of the state’s needs. We look forward to the draft results being provided early next year and hope to continue discussing the 20-year outlook and its role moving forward after the ISO has completed its inaugural effort.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

GridLiance West (GLW) appreciates the CAISO’s extensive deliverability and congestion analysis for this cycle’s policy needs. Also notable, as Jeff Billinton later presented during the meeting, is that the expected renewable buildout going forward will occur at levels drastically greater than the CAISO has studied previously.  To a great degree this nearly renders the 46 MMT base case as outdated. Nevertheless, the CAISO has identified several policy upgrade needs for which it finds no other (e.g., different better placement, RASs, etc.) means to mitigation.

With respect to the GLW/VEA system the CAISO is proposing that policy upgrades are needed to the system for the renewable portfolios. These upgrades were identified in prior cycles, most recently in the 2020 – 2021 TPP. As the CAISO has indicated these upgrades were not pursued last cycle given the need to address affected system issues.

GLW supports the CAISO’s findings this cycle that these upgrades are warranted by even the 46 MMT base case portfolios. 

The CAISO’s presentation notes neighboring system coordination that is needed before the project approval can be confirmed by the CAISO. Each of the affected system impacts are to limited network elements that are small in comparison with the substantial increase in grid interconnection capability the proposed upgrades provide, and the issues have been known as problematic for some time.  Resolution of these seems limitations will be beneficial to the CAISO’s policy goals and to Western Interchange exchanges generally. GLW understands this coordination is progressing. CAISO controlled mechanisms (e.g., RASs and phase-shifting transformers) are being considered in parallel with coordination with the affected neighboring BAAs.  GLW encourages the CAISO to progress toward approval of the GLW/VEA upgrade while finalizing remedies for the neighboring effects.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

The Economic Assessment confirms through the CAISO’s production cost modeling that the GLW/VEA upgrade is beneficial for incorporating the Base Case resources into the grid while minimizing congestion costs. With over $30 million per year in congestion on the GLW/VEA network shown by the analysis under the base case, upgrades will enable significant savings by allowing more solar energy delivery to load centers.

GLW sought an economic study (Economic Study Request #2) of the interconnection of 500 MWs of geothermal energy and upgrades necessary to interconnect such geothermal development. The CAISO in its November stakeholder presentation did not mention results for such a study. With geothermal being such a critical and valuable resource for the CAISO grid we urge the CAISO to complete the economic study this cycle, or in the alternative ensure that the portfolios for the 2022 – 2023 TPP include between 500 MWs and 1000 MWs of geothermal in this region such that the needs related to this geothermal build out will be identified within the base case portfolio in the next cycle.

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

GLW appreciates the CAISO’s efforts and intention in conducting the 20-year study. On an aggregate level GLW agrees with the CAISO’s assessment of the extensive levels of renewables that will be needing integration into the grid. GLW’s also supports the CAISO’s taking early action on some of the necessary critical infrastructure upgrades; waiting until the major upgrades are indicated in the TPP base portfolios will likely not ensure such upgrades are complete in time to meet California’s goals.

While GLW supports the general direction implicated in the 20-yaer study, it should also be recognized that the portfolio is incomplete with respect to more localized transmission needs. SB100 was begun several years ago and lacks several of the known findings of the IRP process. It also lacks the more developed transmission limitation structure that the CPUC has since built into the IRP models.  For example, for the GLW system build out the Starting Point portfolio used in the 20-year study falls short in several regards.

• The Starting Point portfolio significantly underrepresents the likely build out of geothermal energy in Southern Nevada;
• It limits the Southern Nevada GLW solar build-out to those levels currently sited in the IRP portfolios without recognizing likely additional growth;
• It fails to site wind in Southern Nevada despite wind frequently being built in the IRP portfolios at its maximum allowed levels.

Given the above, GLW recommends two actions on the part of the CAISO. First, if the 20-year study does not identify further needs in the GLW system, the CAISO should not take these results as meaningful. (Studying no incremental build out beyond that in the current portfolios of course likely result in this outcome). Second, the GLW recommends the CAISO consider the flexibility of the GLW system to afford additional incremental upgrades without the need for major new rights of ways, land disruptions or stranded assets.  While this optionality need not be chosen as part of the CAISO’s 20-year study, GLW recommends the CAISO consider opportunities for low-cost additional expansion for the 2022 – 2023 TPP. For example, GLW has presented to the CAISO that for approximately $125k per interconnected MW, GLW can increase the capacity of its upgrades by over 2,000 MWs by deploying larger equipment (e.g., 500kV poles and insulation in place of 230kV poles and insulation), with a short deployment time horizon, and with virtually no incremental land impacts.

GLW asks that if the CAISO intends to further use these study results, or if the CAISO intends to conduct a similar study in a future TPP process, that the GLW capabilities and representation be updated for such purposes before the portfolio is finalized.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

Thank you for the opportunity to submit comments. 

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

Additional coordiantion among the agencies on which numbers to use for the GHG accounting is necessary.  The 30MMT base case should be the upper limit in the TPP scenarios and not the 46MMT CAISO used.  The CPUC used 38MMT in the recent IRP proceeding, which is better than 46MMT. In order fro CA to meet its climate and reliabilty needs, we must adjust the MMT to lower amounts. 

Thank you. 

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

CAISO’s decision on out-of-state (OOS) transmission in the 2021/22 TPP will impact California grid reliability and resiliency as early as 2024 and 2025 when Diablo Canyon units 1 and 2 are scheduled to retire.  One OOS transmission project, SWIP-North, can be operational soon after Diablo unit 1 retires and prior to unit 2 retiring but only if approved by the CAISO Board in the ‘21/22 TPP process.  Further delay will be a missed opportunity to deliver ~1100 MW of cost-effective & diverse out of state wind energy to California. OOS wind and new transmission can not only help meet policy goals but also enhance grid reliability, wildfire resiliency and help the state meet any near term capacity shortfalls in the 2024/2025 time frame. 

Although CAISO’s draft results only publish residual benefits of OOS Transmission project (See response to Question 2), further analysis of CAISO study results suggests SWIP-North’s economic benefits pay for the project cost with a ratio greater than 1 (the standard for approval of economic projects).  That doesn’t even attribute value to the significant policy, reliability and wildfire resiliency benefits a third transmission network path from the Pacific Northwest to CAISO provides.  By being proactive in the ‘21/22 TPP, CAISO will have 1100 MW of incremental resource and transmission capability to manage extreme weather, fire or other reliability challenges before Diablo Canyon is fully retired.

LS Power offers the following detailed comments on the Preliminary Public Policy Assessment, particularly with regard to the OOS wind evaluation:

1. LS Power reiterates the importance of the Policy-Driven Assessment to address transmission needs to deliver OOS wind to California. In its Decision 21-02-008, dated February 11, 2021, the California Public Utilities Commission (CPUC) directed CAISO to plan for over 1 GW of OOS wind energy on new transmission as part of the Base Portfolio.[1] As explained in our previous comments in this TPP cycle, CAISO is not comprehensively evaluating the CPUC Base Portfolio (which assumed the need for new OOS transmission) by simply modeling OOS wind at existing CAISO boundary stations.
2. The current Policy-Driven Assessment approach revealed to date only considers in-state transmission needs. Due to the remoteness of OOS wind resources as required by the CPUC Base Portfolio, if not advanced to the next logical step of considering OOS transmission, the current approach leaves a large portion of the transmission need unaddressed in the Policy-Driven Assessment. Therefore CAISO should acknowledge in the draft transmission plan that there is a need for OOS transmission to meet the policy-driven study objective for the 46 MMT Base Portfolio. Furthermore, CAISO should identify a least regrets OOS transmission solution to meet this need for approval in the 2021-22 plan. 
3. CAISO should focus evaluations on those OOS transmission projects that are willing to dedicate their capacity for the benefit of serving CAISO load.  CAISO can dictate the completion date, have operational control over these projects and realize additional economic and reliability benefits from these projects, whereas CAISO would have no such control over or additional benefit realization from subscriber based projects.
4. As LS Power commented previously in this TPP cycle[2], CAISO must apply the criteria defined in the CAISO Tariff Section 24.4.6.6 regarding evaluation and selection of policy-driven projects.

Given the supply shortages in California over last several years, it is prudent to have new transmission that can enable delivery of OOS renewables to be in place around the time of Diablo Canyon retirement to replace this generation with a diverse resource that complements in-state solar and can serve evening peak load. The Policy-Driven Assessment must recommend a transmission project in the current TPP cycle that can enable delivery of 1062 MW of OOS wind to meet the objectives of the CPUC’s 46 MMT Base Portfolio, but CAISO should also specify such project should be placed into CAISO Operational Control by the end of 2025 when Diablo Canyon is planned to be fully retired.

[1] D.21-02-008, CPUC Decision Transferring Electric Resource Portfolios to California Independent System Operator for 2021-2022 Transmission Planning Process, February 11, 2021. https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M366/K426/366426300.PDF

[2] See LS Power’s August 10 comments to the TPP Study Plan, https://stakeholdercenter.caiso.com/Comments/AllComments/ea55dbb9-1deb-49b9-bfba-a148064c5ff0#org-26f21fef-96be-4177-aedf-43f72b133369

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

LS Power applauds CAISO planners for evaluating numerous scenarios for OOS wind in its Economic Assessment. CAISO’s economic study and the additional analysis conducted by LS Power using CAISO’s model shows that SWIP-North provides net economic benefits to California ratepayers with a Benefit-to-Cost ratio of well above 1.0. SWIP-North therefore could be approved as an economic project even without including the significant policy, reliability, resiliency, and wildfire mitigation benefits it offers. SWIP-North provides enhanced benefits compared to other OOS projects being evaluated and at less than half the cost of those projects. SWIP-North has its federal right-of-way secured and could be online in 2025 if approved in this TPP cycle.

LS Power offers the following specific comments on the preliminary results presented by CAISO.

1. It appears the cost of transmission is not considered in the preliminary results presented during the stakeholder meeting. LS Power requests clarification that capital costs are included in the analysis of each of the projects to assist in the evaluation and comparison process.
2. The estimated cost included in the project overview slide for SWIP-North represents the “total” transmission cost to bring 1062 MW from Midpoint to Harry Allen. There are no additional wheeling costs or other hidden capital costs required. It should be noted that LS Power, pursuant to its FERC-approved Transmission Use and Capacity Exchange Agreement with NV Energy, has exclusive rights to transmission capacity on the ON Line Project (Robinson Summit - Harry Allen) for dedication to CAISO at no incremental cost in conjunction with the construction of SWIP-North. That capacity is over and above the capacity held by NV Energy. Likewise, CAISO needs to ensure that the capital cost of required transmission infrastructure and the cost of any firm transmission service required to deliver 1062 MW from resource locations to the CAISO boundary is considered for other OOS transmission projects as well for a fair comparison.
3. Results from the ongoing SWIP-North WECC path rating study process confirm that over 1100 MW of transmission capacity will be available to CAISO from Midpoint to Harry Allen free of any wheeling charges in conjunction with the approval of SWIP-North.
4. The -48 degree phase shifter angle is a more realistic operational mode for SWIP-North than the other two scenarios identified by CAISO. The primary use for the phase shifters in the SWIP-North plan of service is to direct flows to the 500 kV system to protect NV Energy’s interconnected 345 kV system under certain contingency conditions. A zero degree scenario with high cost is similar to having no phase shifter which is not a viable scenario for SWIP-North. Similarly, as CAISO noted, the zero cost scenario, mimicking automated operation, results in frequent phase shifter movement which is not how phase shifters are currently operated by NV Energy or elsewhere in the region. Therefore, LS Power recommends that CAISO continues solely with the -48 degree scenario for further analysis of SWIP-North consistent with the expected manual phase shifter operation at Robinson Summit to mitigate overloads in NV Energy’s 345 kV system.
5. As requested in our verbal comments during the meeting, LS Power recommends CAISO to perform another scenario by removing NM wind from the current base case. While CAISO explained that the base case included 1062 MW of wind to match the required CPUC Base Portfolio, modeling the base case with representative NM wind is not an appropriate reference for evaluating the three identified transmission projects to deliver WY and ID wind to CAISO. By including NM wind in the base case, the reference is artificially raised for comparing ID and WY wind benefits. Consequently the results only show residual benefits for the transmission projects under evaluation.
6. To demonstrate this, LS Power performed an additional analysis utilizing the preliminary CAISO Production Cost Model (PCM) cases. LS Power’s analysis benchmarked the CAISO study runs and new reference cases with no NM wind were created. The results are summarized below:
   • A reference case without NM wind and without any replacement (i.e. letting the Gridview software serve the load economically) results in a CAISO Net Payment of $4,691 Million. Comparing this with CAISO results of SWIP-North delivering 1062 MW of Idaho wind (Net Payment=$4,570 Million) yields an annual benefit of $121 Million for SWIP-North with ID wind.
   • A separate reference case replacing NM wind with a corresponding increase in new in-state solar capacity shows an annual benefit of $103 Million for SWIP-North with ID wind.
   • Further, LS Power calculated annual transmission revenue requirements for SWIP-North using typical CAISO financial assumptions. Results show a Benefit-to-Cost ratio of 1.78 and 1.51 for the above two reference cases respectively. This demonstrates that SWIP-North also meets the criteria of an economically beneficial project for CAISO ratepayers under both reference case scenarios and is more than double the benefit of any other transmission projects. Therefore, not only does SWIP-North meet the policy requirement to deliver 1062 MW of OOS wind, it is also pays for itself in terms of economic benefits.  Furthermore, it provides significant reliability, resiliency, wildfire mitigation and other benefits that are not captured in this analysis.
7. Further analysis performed by CPUC as part of draft preferred system plan to study in the 2022-2023 TPP shows OOS wind chosen by the RESOLVE model on an economic basis starting 2030 even with outdated inputs and assumptions^[1]. LS Power modeling with updated inputs results in 1,893 MW of Idaho wind starting in 2025 in the 38 MMT Core Scenario and a system cost savings of $360 million (net present value 2022-2045) compared to the Core (38 MMT) Scenario^[2].  This demonstrates clear economic benefits to California ratepayers from Idaho wind.  Further, OOS wind facilitates delivering energy during the net peak hours, are complementary to in-state solar, supplement in-state battery projects, provide diverse production profiles to in-state wind, and enable more fossil fuel generation retirement resulting in a greater reduction in GHG emissions.
8. The CAISO PCM results show SWIP-North as a “no-regrets” transmission project that provides net positive benefits to ratepayers for both Idaho and Wyoming wind. Please refer to our response to Question 6 for details of this conclusion.

[1] Administrative Law Judge Julie A. Fitch’s Ruling Seeking Comments on Proposed Preferred System Plan (“Ruling”), dated August 17, 2021

[2] Reply comments of LS Power Development, LLC on the Administrative Law Judge’s Ruling Seeking Comments on the Proposed Preferred System Plan, October 11, 2021

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

No comments at this time.

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

No comments at this time.

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

LS Power supports the 20 Year Transmission Outlook assessment in general. However, there should be an urgency to develop transmission solutions in the near term to maintain reliability and fulfill load serving needs of California especially in light of recent capacity shortages and impending Diablo Canyon and OTC unit retirements. LS Power cautions CAISO to not lose focus on identifying near-term policy-driven and economic-driven transmission solutions that should be approved in this year’s TPP while working on the 20 Year Transmission Outlook in parallel.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

LS Power has two additional comments identified as A and B below.

1. LS Power reviewed the preliminary economic study results for OOS transmission to deliver 1062 MW of OOS wind as included in the presentation slides. The results show SWIP-North as the OOS transmission project that ranks the highest in all of the following categories described below.

1. Lowest Capital Cost - As shown in Table 1, SWIP-North is the least cost project among all OOS transmission projects evaluated by CAISO in terms of capital cost, cost per mile, and cost per MW of capacity.

Table 1. Capital Cost Comparison

Source: CAISO slides 120-122 of 186 from the November 18 stakeholder meeting presentation.

2. Net Benefits for Both ID and WY Wind - As shown in Table 2, SWIP-North is the only project considered that delivers net positive benefits (compared to CAISO’s base case which assumes NM wind) for both WY and ID wind based on CAISO’s preliminary economic study results for the Base Portfolio. This provides value in terms of optionality and diversity for future wind resource development. Moreover, it demonstrates the benefits of SWIP-North for delivery of OOS wind as compared to other projects delivering wind from NM, ID or WY.  It should be noted that since CAISO compared each project to a base scenario that included 1 GW of NM wind, CAISO’s calculation of benefits are relative to this base scenario and they do not represent the true absolute benefits of the project to California as compared to a scenario with no OOS wind.  The absolute benefits are significantly higher as presented in response to Question 2 above.

Table 2. WY and ID Wind Benefits Comparisons

Source: CAISO slide 125 of 186 from the November 18 stakeholder meeting presentation.

3. Lowest Capital Cost/Relative Benefit Ratio - As shown in Table 3, SWIP-North ranks the highest in the CAISO base portfolio evaluation (considering all scenarios CAISO studied) taking the capital costs of the projects into account. As an indicator, the ratio of project capital cost to production cost benefits relative to the base scenario which includes NM wind was derived from the CAISO results for comparison purposes.

Table 3. Project Ranking based on Lowest Capital Cost to Relative Production Cost Benefits Ratio

Source: CAISO slide 125 of 186 from the November stakeholder meeting presentation.

4. Lowest Net Payment for Sensitivity 1 - In addition, CAISO’s analysis for the Sensitivity 1 Portfolio (3000 MW of OOS wind) shows that SWIP-North ranks the highest for all projects considered for both WY and ID wind scenarios. Table 4 below shows ranking based on the Net Payment (lowest to highest). Not only does SWIP-North result in the lowest CAISO Net Payment but it accomplishes this at less than half the cost of any competing project.

Table 4. Project Ranking for Sensitivity 1 Portfolio based on the CAISO Net Payment

Source: CAISO slide 128 of 186 from the November stakeholder meeting presentation.

In summary, SWIP-North provides benefits relative to other projects being considered whether for NM, ID or WY wind.  It is the only project that provides positive relative benefits for both ID and WY wind.  Its cost is less than half of other projects being considered.  It also provides the most benefit of any project under CAISO’s Sensitivity 1 Portfolio.  It is the only project that can be in service by 2025 helping California meet its near term capacity shortfall.  It is the only project that is positioned to utilize California labor for construction. Given the ambitious California GHG emission targets, we understand multiple transmission projects and resource solutions will likely be needed to help meet these goals. However, approving a “no-regrets” transmission solution like SWIP-North in the 2021-2022 TPP cycle for a 2025 in service date will not only allow CAISO ratepayers to realize benefits of OOS wind much sooner but also address potential capacity shortfalls in the near term.

2. For any project recommended for approval in the Draft Transmission Plan, CAISO should identify specific components of the project that will be eligible for competitive solicitation in accordance with the CAISO tariff along with a corresponding explanation for any components determined by CAISO to be directly assigned to the incumbent PTO in accordance with the tariff.

[1] 213 miles to Robinson Summit, plus additional 231 miles of new transmission to Harry Allen as Cross Tie will need to build a new line from Robinson Summit to Harry Allen as there is no incremental capacity available on ON Line in excess of LS Power and NV Energy’s entitlements.

[2] Adjusted from $667mm in 2015 dollars (based on average annual inflation of 1.82% from 2015 to 2020) resulting in $730mm for first 213 miles to Robinson Summit ($3.43mm per mile), plus $792mm for additional 231 miles to Harry Allen (using same $/mile rate).

[3] Capital cost to Relative benefit is not a conventional metric. It was developed solely for comparison purposes as the CAISO preliminary results did not calculate absolute benefits and annual revenue requirements for each OOS transmission project.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

Please see the Attachment - the CAISO's comment tool does not seem to accommodate the format of certain charts in our comments.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

PG&E appreciates the updates CAISO provided on the Policy Assessment Study Results in the November 18 stakeholder meeting. PG&E has reviewed the preliminary policy driven project proposals and the scopes are aligned with our expectations. PG&E will continue working with CAISO on the feasibility evaluation and detailed cost estimation.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

PG&E offers the following comment in regards to the Ames – Palo Alto 115 kV line proposal in the third party 2021 CAISO Request Window Submissions.  PG&E needs additional information on the proposal in order to provide meaningful comments.  PG&E is not aware of a NERC TPL-001-4 reliability criteria violation with the lines in question and thus would need to collaborate with CAISO and City of Palo Alto Utilities (CPAU) to further understand the driver and scope of the project.  If PG&E is expected to construct, own, and finance the project, PG&E needs to do in-depth feasibility evaluation, cost, and duration estimates.

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

PG&E appreciates the updates CAISO provided on the 20 Year Transmission Outlook that shared more information on scope and methodology. We look forward to future updates and the draft report.

PG&E encourages the CAISO to also include in the draft report the recommended roadmap going forward. Given that large-scale transmission projects are likely to be more complicated and involve large groups of stakeholders to collaborate and coordinate, they will tend to take a long time to plan and construct. Therefore, it is important to lay out a roadmap, even in high level, to help to drive relevant parties to start necessary conversations and make strategic plans accordingly. In addition, PG&E encourages the CAISO to lay out how the 20-year outlook should be considered in future TPP studies, especially in policy driven analysis.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

PG&E commends the CAISO for the continued work on the 2021-2022 TPP Wildfire Impact Assessment for PG&E North Coast/North Bay Area.  PG&E concurs with CAISO’s observation and insight for the two studied events that outage of the 230 kV gen-tie lines causes significant loss of local generation, which would in turn require higher levels of reliance and support from the remaining 230 kV lines supplying the North Coast/North Bay Areas.  As the assessment studies show, losing such significant amounts of generation during non-summer peak conditions, could result in overloads of the critical supply 230 kV lines, even before undertaking an operational N-1 study.  CAISO also makes mention that for Event 9, the situation is more extreme, as it would incrementally result in the outage of several 115 and 60 kV lines, resulting in significant impacts to the ability to serve the local area load under those conditions and while preparing for operating an N-1 secure system. 

Lastly, it is also important to note that CAISO’s assessment evaluated the system assuming a scaled down summer peak load level to try to represent the fall season when PSPS events typically occur.  However, PG&E notes that while fall historically has the most potential for PSPS events, they may also occur at other times in the year (e.g., PG&E has experienced PSPS events in January, and August); thus PG&E believes it is also helpful to study summer conditions to provide another bookend perspective for those scenarios. The wildfire assessment information presented is a good reference as long as it recognizes that the range of events and outcomes could be wider depending on when a PSPS may occur.

PG&E looks forward to the continued engagement and collaboration with the CAISO on this important work.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

No comments at this time.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

No comments at this time.

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

The City of Santa Clara dba Silicon Valley Power (SVP) appreciates the opportunity to comment during the 2021-2022 Transmission Planning cycle. SVP has reviewed the results of the CAISO reliability assessment for the SVP/San Jose areas and the proposed mitigations in PG&E’s Request Window filing . SVP appreciates the CAISO and PG&E staff’s tremendous efforts in identifying potential transmission alternatives to mitigate expected CAISO planning criteria violations  driven by rapid load growth expected in the near future in the SVP/San Jose areas. CAISO reliability assessment shows that some of the reliability violations are expected to occur as early as 2023, which is extremely concerning to SVP.

PG&E has identified potential short-term mitigation measures as part of its South Bay 115 kV Reinforcement Conceptual Project[1] request window application submitted in the 2021-2022 TPP. They include reconductoring Los Esteros-Nortech 115 kV and Nortech-NRS 115 kV lines. Separately, Smart Wires has also submitted its “Santa Clara Area Series Compensation Project,” request window application to address the SVP/San Jose area reliability needs.[2] Since time is of the essence, SVP was hopeful that the CAISO management would approve such transmission upgrades costing less than $50 million in December 2021 required to address the SVP/San Jose area’s short-term reliability issues. However, during the November 18^th stakeholder meeting, the CAISO indicated that these transmission solutions were still under study and that the CAISO would be providing an update in the January 31^st Draft Plan. SVP appreciates the CAISO’s objective to develop short-term mitigation solutions that align with the long-term solutions it plans to develop in coordination with PG&E. But priority needs to be given to feasible and timely solutions that minimize the chances of load interruption during contingencies. To that extent, SVP urges the CAISO to approve both the short- and long-term solutions proposed in the current planning cycle that would effectively address SVP’s reliability needs.

While choosing the short- and long-term mitigation solutions, SVP suggests that the CAISO considers several factors. They include their long-term effectiveness in light of increasing load growth in the SVP system and the San Jose area, in general. For example, in terms of long-term adequacy of PG&E-proposed Alternative 1, i.e., reconductoring Newark-NRS 115kV lines #1 and #2 with conductor rated for 1,500 Amps[3], we believe it is inadequate in addressing SVP’s reliability issues in the long-term (2031). SVP believes there are other factors that require special attention. The technical, physical, and permitting feasibility of the transmission mitigation solutions need to be considered. Important criteria include the overall ability of the proposed transmission alternatives to be constructed on time and construction feasibility aspects, including the required clearances that could be substantial for some of them.[4] SVP requests the CAISO to fully explain their decision-making criteria in identifying both the short- and the long-term alternatives to address SVP/San Jose area reliability needs in the Draft Transmission Plan.  This should go beyond just showing that a proposed alternative mitigates the expected reliability criteria in a least-cost manner.

In summary, since any reinforcement of the transmission in the SVP/San Jose area will probably take significant time to construct, CAISO must approve both the short-term and long-term mitigation projects in the current planning cycle. Again, SVP appreciates the opportunity to comment on the 2021-2022 Transmission Plan November 18^th stakeholder meeting and acknowledges the significant efforts of the CAISO and PG&E staff to develop proposed mitigations to expected CAISO planning criteria violations.

[1] PG&E’s 2021 Request Window Proposals, September 28, 2021, CAISO 2021-2022 Transmission Planning Process, pp.37-48.

[2] “Introduction and Overview: Preliminary Reliability Assessment Results, 2021-2022 Transmission Planning Process Stakeholder Meeting, November 18, 2021, p.8.

[3] PG&E’s 2021 Request Window Proposals, September 28, 2021, CAISO 2021-2022 Transmission Planning Process, p.45.

[4] PG&E states the following “The two Newark NRS #1 & #2 115 kV lines are a critical power source into SVP. The clearance windows for these lines will be limited and should be coordinated to avoid any conflicts with SVP’s planned upgrades.” in PG&E’s 2021 Request Window Proposals, September 28, 2021, p.48.

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

No comments at this time.

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

No comments at this time.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

No comments at this time.

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

SCE appreciates this opportunity to provide comments regarding the CAISO’s TPP stakeholder meeting held on November 18, 2021. 

While the CAISO identified some impacts of the proposed GLW Upgrade on the neighboring systems of LADWP, NV Energy, and WAPA, there is a further need to assess the upgrade in the context of the short circuit duty concerns at the Eldorado 500/230 kV substation. SCE is the operating agent for the Eldorado 500/230 kV substation which is jointly owned by LADWP and NV Energy and is currently investigating mitigations for this short circuit duty issue in partnership with the Eldorado co-owners. These mitigation options may impact the GLW Upgrade and vice versa. As such, the future analysis and coordination efforts recommended by CAISO should include dependencies with the Eldorado 500/230 kV substation. Additionally, the potential impact of the Trans West Express project terminating at Eldorado 500 kV should also be considered. 

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting:

SCE hereby expands on its previous comment regarding the benefits of a new Lugo No.3 500/230 kV transformer bank on outage flexibility. The main system tie for the North of Lugo area is through the two existing Lugo 500/230 kV transformer banks and the CAISO outage planning criteria requires that P0 and P1 performance requirements in NERC TPL-001-4 must be maintained for a scheduled outage. So, a planned outage on either of the existing 500/230 kV banks requires the system to maintain P1 requirements under contingency of the other bank, but under this condition the North of Lugo region relies on five very weak ties. Meeting this requirement requires meticulous coordination of several factors including load, exceptional dispatch and/or curtailment of generation, manual modifications to two remedial action schemes in the area, and strict import/export limits to maintain stability. 

?In practice, this restriction has been an impediment to maintenance and necessary capital upgrades in the Lugo area. CAISO approved an SCE project to connect the two Lugo 500/230 kV transformer banks to circuit breaker positions in 2008, but challenges in coordinating an outage for these transformer banks has driven some delays in the project and the earliest projected start date is currently 2024. Adding the third 500/230 kV transformer bank at Lugo will provide a strong tie to the rest of CAISO system during the above scenario (scheduled outage plus P1) and alleviate constraints under scheduled or forced outages. 

1. Please provide your organization’s comments on the Preliminary Policy Assessment, as described in the second portion of the presentation:

Southwestern Power Group (SWPG) and Pattern Energy appreciate CAISO’s inclusion of dual out-of-state (OOS) wind injection options with Base A including 1062MW of Wyoming wind at Eldorado and Base B with 1062MW of New Mexico wind at Palo Verde. (Note there is a minor but important typo on top of p. 26 where these injection points are reversed).

On p. 101 it states that the Off-Peak deliverability assessment identified worse overloads on the Eldorado-McCullough 500 kV tie-line with 1062 MW OOS wind at Eldorado compared to the 1062MW injection at Palo Verde. It would be helpful to know the degree of the difference in magnitudes of overload between the cases, as well as other overloads where there is a material difference between these 2 OOS injection cases. It would also be helpful to know what additional conclusions or next steps can be drawn from the Base A and Base B analysis.

SWPG/Pattern also point out that while studying 1062MW of OOS wind from each of these regions is helpful, it is still much smaller than the actual injections planned from these regions between now and 2026. For the New Mexico region specifically, Pattern is about to reach commercial operations by end of December 2021 for its 1050MW Western Spirit wind projects which will deliver almost entirely to the California market with ~70% to the CAISO grid. In addition SWPG and Pattern are jointly developing the SunZia Transmission Project that will deliver 2 to 3 GW of New Mexico wind to the CAISO grid by 2026. Therefore CAISO should conduct future OOS wind studies on much larger volumes.

2. Provide your organization’s comments on the Preliminary Economic Assessment, as described in the third portion of the presentation:

Regarding the out-of-state (OOS) wind study, SWPG/Pattern appreciate the level of rigor put into the study and the breadth of scenarios considered. SWPG/Pattern believe California will need large amounts of wind imports from multiple OOS regions due to their profile diversification benefits, and offer the following suggestions on the OOS wind study.

First the capacity factors used in the PCM (shown on p. 124) are materially lower than those used in the CPUC’s RESOLVE model, which would artificially suppress the economic benefits and therefore should be increased to be consistent with RESOLVE.

Second, the study data reveals the benefits of the various scenarios (e.g. p. 125-126) but does not detail the costs of each option either outside or inside the CAISO footprint. Third it was unclear what conclusions or recommendations can be drawn from the study so CAISO may want to clarify what next steps are being considered with respect to OOS wind. More specifically here are some questions that would be helpful for CAISO to answer:

1. What constraints are incurred/impacted by each scenario and what upgrades are required to alleviate them and at what cost?
2. What upgrades does CAISO intend to pursue as a result of the study to allow more OOS wind to be imported?  

3. Provide your organization’s comments on Reliability Projects less than $50 million, as described in the fourth portion of the presentation:

4. Provide your organization’s comments on the PG&E Area High Voltage Assessment (update), as described in the fifth portion of the presentation:

5. Provide your organization’s comments on the 20 Year Transmission Outlook (update), as described in the final portion of the presentation:

SWPG/Pattern appreciate CAISO’s efforts on the 20-year Transmission Outlook and look forward to seeing the results of this important forward-looking analysis. The results of this analysis are likely to show a substantial amount of new transmission is necessary to achieve a diverse resource portfolio consistent with SB100 and the state’s goals. SWPG/Pattern point out that the SB100 scenarios show a need for 12 GW of new out-of-state (OOS) wind by 2045 including more than 5 GW from New Mexico alone. It is important for CAISO to initiate work on the transmission upgrades needed to enable these imports as soon as possible, and in particular those upgrades with longer lead-times.

6. Provide additional comments (if any) on the November 18, 2021 stakeholder meeting: