Provide your organization’s comments on the Out of State Wind In Portfolios topic, as described in slides 66-73 related to the 2021-2022 Transmission Planning Process:
LS Power applauds CAISO’s effort to assess transmission alternatives to deliver OOS wind in the Base Portfolio. This is a critical step to bringing OOS wind into California in a timely manner, and will help address California’s capacity shortage and reliability risks. LS Power agrees with CAISO’s proposal to evaluate alternative transmission projects for the WY, ID and NM areas.
LS Power’s SWIP-North transmission project consists of a new 500 kV AC transmission circuit, 70% series compensated, traversing approximately 275 miles from Idaho Power Company’s Midpoint 500 kV substation (near Twin Falls, Idaho) to the Robinson Summit 500 kV substation (near Ely, Nevada). SWIP-North will also include other upgrades to existing infrastructure as described in the detailed model previously submitted to CAISO. The new line and associated upgrades will create a new >2000 MW 500 kV transmission path between Midpoint and Harry Allen and ~1100 MW out of this is being offered to CAISO. SWIP-North can effectively be treated as new long-term firm transmission from CAISO’s current boundary station at Harry Allen 500 kV to Midpoint 500 kV, potentially a new CAISO scheduling point or boundary station.
LS Power offers the following comments for CAISO’s consideration to help ensure the analysis is based on transparent, equitable and justifiable assumptions resulting in selection of a transmission solution.
- Stakeholder Collaboration – LS Power requests that CAISO release their production cost model (PCM) and policy-driven deliverability power flow model as soon as it is ready so that stakeholders can review and provide feedback prior to CAISO performing the analysis for OOS transmission projects. This step will increase transparency and avoid identifying issues after it is too late in the process to make changes.
- Updated Modeling Approach – The ever-changing climate conditions and their impact on the power grid demands looking beyond CAISO’s normal planning approaches with more realistic scenarios that also consider extreme weather events. For example, CAISO normally includes transmission outages in its economic planning simulations based on the average historical frequency of outages. CAISO should update the assumed outages in the PCM analysis to account for the recent increase in outages, especially due to wildfires. Further, CAISO should simulate their system under recent extreme market conditions to ensure the system can handle the increased frequency of their occurrence, such as the August 2020 heat waves, cold snaps, drought conditions, and major wildfires. These events could be added (as replacements) to individual weeks of the weather-normalized inputs of the WECC ADS data set. Failure to capture and plan for these types of events could result in a planning approach that falls short of the goal of creating a reliable grid.
Regarding the study approach for OOS wind alternatives, CAISO plans to use a PCM case with 1062 MW of New Mexico wind with new transmission (delivered to Pinal Central 500kV) as the reference “pre” case for production benefit (slide 71 of the July 27 presentation). LS Power requests clarification on this approach and is concerned that this could bias the model towards NM wind and artificially reduce benefits of OOS transmission/wind from WY and ID. Furthermore, SunZia has indicated that its commercial strategy is to be a merchant line and, in fact, it has in place an anchor shipper arrangement with Pattern for wind from NM. It is unclear to LS Power how this structure fits with CAISO’s obligation to plan for transmission to meet the requirements of CPUC’s Base Portfolio if CAISO has no control over the timing or capacity of the SunZia line due to its proposed commercial structure. LS Power suggests that the “pre” case should include no new OOS wind, and then each project/location should be added as an alternative in the “post” case model.
Regarding the benefit horizon, normally CAISO would study all alternatives 10 years out. For this new OOS transmission alternative analysis, each of the project alternatives has a different permitting status, risk profile and earliest achievable in service date. Projects that can be placed in service sooner, resulting in earlier economic, reliability and policy benefits, should be credited accordingly. CAISO’s analysis should be able to capture capital cost savings and other incremental benefits if certain projects can be placed in service earlier.
- Comparison of Transmission Alternatives – Analysis of transmission needs to facilitate access to 1062 MW of OOS wind in the Base Case Portfolio warrants a thorough evaluation of all the benefits for each proposed alternative solution.
To ensure CAISO is positioned to move forward with a recommended solution that offers the broadest scope of benefits for ratepayers, it is imperative that CAISO perform a comprehensive comparison of alternatives. Comparison criteria at a minimum should include:
- project readiness and expected in-service date, and the associated economic benefits that come with advanced development projects that can move forward quickly,
- transmission project cost including interconnection facility costs and network upgrades,
- unit cost of delivery of the 1062 MW of OOS wind ($/MW) to existing CAISO BAA, including cost and availability of long term firm transmission rights (or transmission upgrades outside CAISO BAA) required to bring the OOS wind into CAISO BAA (from the source to the CAISO boundary station),
- economic benefits from PCM and additional benefits from the TEAM methodology,
- greenhouse gas (GHG) emission reduction benefits, including access to OOS wind and other renewable energy and storage projects,
- economic, resiliency and reliability benefits of the transmission project for CAISO ratepayers, and
- potential downstream upgrades (within CAISO) required to facilitate delivery of OOS wind.
By comparing transmission alternatives against a variety of criteria, CAISO can consider a more comprehensive picture of each alternative’s benefits to support the TPP decision making process.
- Comprehensive Benefits Analysis – As described above, to robustly compare alternatives, CAISO must quantify the full benefits offered by each alternative. For example, a recently conducted study by Brattle Group quantified numerous benefits for LS Power’s SWIP-North project as described below, and which we recommend CAISO use as guiding points to estimate similar benefits for each OOS alternative in the Base Portfolio. CAISO should estimate the investment cost savings and environmental benefits of accessing more diverse and lower-cost renewable resources, accounting for the resource costs, capacity and correlation factors, energy market value, Resource Adequacy (RA) market value, and GHG reduction benefits. These additional benefits are in line with CAISO’s TEAM methodology. This is also consistent with the CPUC’s final Decision which included several statements about the need to consider reliability, policy, and economic benefits combined, not just in silos as separate studies, when evaluating projects to recommend for approval. The Decision’s Finding of Fact 6 states, “Transmission solutions to support both policy and reliability goals combined with ratepayer savings can provide significant benefits to California.” Additionally, Conclusion of Law 3 states, “Based on analysis conducted by Commission staff thus far, utilizing the electric resource portfolio that meets the 46 MMT GHG emissions target as a reliability and policy-driven base case in the TPP will likely result in the need for new transmission investment to make the portfolio deliverable. Transmission projects should be evaluated for reliability, policy, and economic benefits.”
- Resource Adequacy (RA) benefit from incremental importing capability
SWIP-North provides RA benefits to CAISO since the following four conditions noted in CAISO’s TEAM methodology are satisfied simultaneously:
- SWIP-North will provide a diverse new import path to CAISO. Absent SWIP-North, CAISO’s import capability with Idaho Power and PacifiCorp East is limited, the import path between NVE-CAISO in the Sierra Region is congested and NVE’s internal path that connects its northern and southern system (ON Line) is fully utilized. SWIP-North and associated upgrades on ON Line will enable a new ~1100 MW import capability path between various BAAs.
- As evident through CAISO’s own stack analysis in CPUC proceedings, there is projected insufficient capacity to maintain resource adequacy in the CAISO BAA starting this year in 2021.
- The existing import capability has been fully utilized to meet RA requirement in the CAISO BAA in the study years. A recent WECC analysis shows that even when all planned internal and import resources are added, Southern California has hours at risk of unserved load.
- The capacity cost in the CAISO BAA is greater than in other BAAs (Idaho Power, PacifiCorp, NV Energy) to which the new transmission connects.
CAISO should estimate the RA/Capacity value of SWIP-North based on load diversity (seasonally and hourly) between Idaho and Southern California and capacity cost savings from building new supply in ID vs CA. Recent historical load shapes to determine the reduction in peak requirements should be used for this analysis. Enabling ~1100 MW of transmission capacity from CAISO to neighboring regions will allow the flexible ramping requirement for CAISO and the regions to be reduced as they will be able to take advantage of the diversity of resources and shape of the load. These diversity saving benefits should be accounted for. CAISO’s Quarterly EIM reports capture these benefits and this is an approach that CAISO Transmission Planning can use as well for this study. The Brattle Group estimates these load diversity benefits to be at least $11 million-$18 million annually.
The value of reduction in peak capacity requirements based on prevailing costs of capacity in Southern California and Idaho should also be estimated. The Brattle Study does not estimate these additional capacity benefits based on the ID and CA capacity cost difference of importing up to ~1100 MW of firm capacity. However, CAISO has estimated these capacity benefits for economic transmission projects in past and we recommend CAISO conduct this analysis for the economic portion of its policy analysis.
- Deliverability benefit
SWIP-North will enable deliverability of OOS renewables which are identified in both the Base Case and Sensitivity 1 portfolios for the 2021-22 TPP.
- Public Policy Benefit
SWIP-North will increase the firm import capability with a line that flows directly into the CAISO controlled grid. SWIP-North will enable access to thousands of megawatts of diverse renewable energy resources that can help reduce the cost of reaching renewable energy targets. As noted in CAISO’s TEAM methodology “When there is a lot of curtailment of renewable generation, extra renewable generators will need to be built or procured to meet the goal of renewable portfolio standards (RPS). The cost of meeting the RPS goal will increase because of that. By reducing the curtailment of renewable generation, the cost of meeting the RPS goal will be reduced. This part of cost saving from avoiding over-build is categorized as public-policy benefit”. In CAISO’s TPP studies, SWIP-North has been shown to help reduce renewable curtailments in the CAISO footprint by providing a conduit to export surplus renewable energy from California. These capital cost savings should be captured.
- Renewable Integration benefit
Interregional coordination can help mitigate integration problems, such as over-supply and curtailment, by allowing sharing energy and ancillary services (A/S) among multiple BAAs.
SWIP-North will increase importing and exporting capability of BAAs (CAISO, NVE, Idaho Power, PacifiCorp) and will facilitate sharing energy among BAAs, so that the potential over-supply and renewable curtailment problems within a single BAA can be relieved by exporting energy to other BAAs, whichever can or need to import energy. SWIP-North will also facilitate A/S Sharing between the areas. The total A/S requirement for the combined areas may reduce if the areas are allowed to share A/S. This benefit should be captured in CAISO’s study.
- Proper Modeling of SWIP-North – Consistent with LS Power’s previous comments on SWIP-North modeling, the following must be addressed to ensure correct results when evaluating the SWIP-North alternative:
- Include all facility upgrades required to interconnect SWIP-North in the economic study model, including the addition of 70% series compensation to the existing ON Line 500 kV Transmission Line (Robinson Summit to Harry Allen) and phase shifting transformers on the existing Robinson Summit-Gonder and Robinson Summit-Falcon 345 kV lines. Without these planned upgrades, the current ON Line path will be limited to ~1000 MW which will artificially limit flows on SWIP-North. Properly modelling these upgrades will increase the transmission capability from Robinson Summit to Harry Allen to approximately 2300 MW.
- Remove the $9/MWh NVE wheeling charge that is hardcoded in the ADS PCM model. This charge is not applicable to SWIP-North. Pursuant to the FERC-approved Transmission Use and Capacity Exchange Agreement (TUA) between LS Power affiliates and NVE, the SWIP-North project includes a firm capacity entitlement over the ON Line (SWIP-South) project at no additional capital cost and free of any wheeling charges. This modeling technique may entail modeling the Midpoint to Harry Allen path as two separate ~1100 MW paths, one allowing direct imports into CAISO with no hurdle, and one as part of the NV Energy system. This modeling approach would be similar to how CAISO models COI capacity for different transmission balancing authorities.
- Enforce COI path limits to capture only CAISO’s 3200 MW share of the 4800 MW COI/PACI rating in the study model. If this is not modelled correctly, congestion on PACI will be artificially reduced as flows across COI path into CAISO will utilize 1600 MW of the COI path that belongs to TANC and not CAISO. A large hurdle rate should be applied for limiting loop flows from COI through TANC path into CAISO.
- CAISO modeling of resource locations, and authority to review and approve OOS transmission projects – CAISO’s Policy-Driven Study should capture deliverability of OOS wind from resource location to CAISO load, as directed in CPUC's final decision D.21-02-008 (Decision) that includes 1062 MW of OOS wind in the Base Case Portfolio. In addition, similar to the precise busbar level mapping of in-state baseline resources, OOS wind resources should also be mapped accurately at their respective resource locations in the base and other sensitivity deliverability studies. For example, for the Idaho wind scenario, 1062 MW OOS wind should be modelled at Midpoint, not Harry Allen or Eldorado given that wind generation is being actively developed in the vicinity of Midpoint and SWIP North originates at Midpoint. CAISO’s Tariff section 126.96.36.199 on Policy-Driven Solutions also notes that “CAISO will determine the need for, and identify such policy-driven transmission solutions that efficiently and effectively meet applicable policies under alternative resource location and integration assumptions and scenarios, while mitigating the risk of stranded investment.” CAISO Tariff criteria in section 188.8.131.52 also state that CAISO will analyze generation associated with a geographic location of a resource, such as applicable geographic area, renewable energy zones, and resource areas, in determining the needed transmission solutions. Further, the CPUC Decision clearly identifies a regional need for new OOS transmission to deliver OOS wind. CAISO’s tariff provides the basis for the transmission plan to accommodate this analysis and approval of projects: Tariff section 24.13 states that the CAISO may consider potential interregional solutions to regional needs during Phase 2 of the Transmission Planning Process, and this is not limited to only economic, or only reliability, or only policy needs. By studying OOS transmission as a regional project, CAISO could more accurately take into account policy, economic, reliability benefits, and access to other diverse OOS renewables. These CPUC Decision and CAISO Tariff authorities combined provide significant justification to consider OOS transmission as a Category 1 solution for Policy-Driven Study in the 2021-22 TPP. If CAISO does not consider new OOS transmission that extends beyond the current CAISO boundary to access OOS renewables, that increases the risk that those valuable resources will never be developed and will never be delivered to the current CAISO boundary.
We further encourage CAISO to explore options beyond limiting the current deliverability study framework to existing MIC numbers at the interties. For OOS study, this could potentially mean applying the deliverability study framework to study the impact of the simultaneous injection of base portfolio OOS capacity and the MIC on both the regional and interregional transmission in the area.
- Application of Criteria in Tariff Section 184.108.40.206 –
As the sponsor of the SWIP-North alternative, LS Power offers our evaluation of SWIP-North using the criteria in the CAISO Tariff Section 220.127.116.11 regarding evaluation and selection of policy-driven projects.
- Commercial interest in the resources in the applicable geographic area (including renewable energy zones) accessed by potential transmission solutions as evidenced by signed and approved power purchase agreements and interconnection agreements;
There has been a significant commercial interest in this region as SWIP-North, as a network connected line, provides easy access to resources in Idaho Power, BPA, NV Energy and PacifiCorp, including more than 20,000 MW of renewables in the current generator interconnection queues that could be accessed via SWIP-North. The interconnection queue for Idaho Power alone currently has over 6000 MW of active projects, mostly renewables and hydro. This total includes over 2500 MW of wind projects under active development, a number of which could be constructed and operational by 2025 if a firm transmission path to CAISO were constructed on the same schedule. Additionally, the Idaho Power queue has an 870 MW pumped storage project combined with solar and wind that could potentially access SWIP-North.
- the results and identified priorities of the California Public Utilities Commission’s or California Local Regulatory Authorities’ resource planning processes;
The CPUC Base Portfolio identifies the need for 1062 MW of OOS wind from Idaho or Wyoming with new OOS transmission, and SWIP-North is in an advanced development stage such that it can directly meet this need as early as the end of 2024 with a very low development risk profile compared to other alternatives. Furthermore, Sensitivity 1 identifies the need for an additional 3000 MW of OOS wind with new transmission that could in part also be accessed via SWIP-North.
- the expected planning level cost of the transmission solution as compared to the potential planning level costs of other transmission solutions;
LS Power has previously provided the planning level cost estimate for SWIP-North to CAISO and is available to offer any clarification or updates upon request.
It is important to recognize that interregional cost allocation has already occurred on the overall SWIP path from Midpoint to Harry Allen that will enable >2000 MW of 500 kV transmission for 506 miles. Pursuant to the FERC-approved Transmission Use and Capacity Exchange Agreement (TUA) between LS Power affiliates and NVE TUA, the 231-mile ON Line portion of the path (Robinson Summit to Harry Allen) was placed into service in 2014, and has been paid for by NVE and LS Power. LS Power’s project proposal for CAISO provides ~1100 MW of transmission capacity from Midpoint to Harry Allen (506 miles), for the cost of building only the 275-mile SWIP-North portion of the path (Midpoint to Robinson Summit). Nearly half of the total SWIP path has already been paid for by other benefitting regions, meaning interregional cost allocation has already taken place.
It is also important to recognize the capital cost benefits and other market based economic benefits that can be realized sooner for SWIP-North. Due to the advanced development status, the project could be placed in service by the end of 2024 if selected by CAISO in this cycle, resulting in at least 6 additional years of benefits and significantly lower up-front cost compared to waiting until 2031. Signaling to the market the availability of new transmission as early as 2024 will increase the supply of new renewable resources already under development that will position themselves to be the low cost providers to California LSEs, including the use of currently available federal tax credits.
- the potential capacity (MW) value and energy (MWh) value of resources in particular zones that will meet the policy requirements, as well as the cost supply function of the resources in such zones;
Idaho wind has a complementary generation profile to California solar, as Idaho wind generally decreases as solar ramps up and increases in the evening hours as solar decreases.
Enabling ~1100 MW of transmission capacity from Harry Allen to Midpoint will allow the flexible ramping requirement for CAISO to be reduced by taking advantage of the diversity of resources and shape of the load. These diversity saving benefits should be accounted for. CAISO’s Quarterly EIM reports capture these benefits and this is an approach that CAISO Transmission Planning can use as well for this study. The Brattle Group estimates these load diversity benefits to be at least $11 million-$18 million annually.
The value of reduction in peak capacity requirements based on prevailing costs of capacity in Southern California and Idaho should also be estimated. The Brattle Study does not estimate these additional capacity benefits based on the ID and CA capacity cost difference of importing up to ~1100 MW of firm capacity. However, CAISO has estimated these capacity benefits for economic transmission projects in past.
- the environmental evaluation, using best available public data, of the zones that the transmission is interconnecting as well as analysis of the environmental impacts of the transmission solutions themselves; the extent to which the transmission solutions will be needed to meet Applicable Reliability Criteria or to provide additional reliability or economic benefits to the CAISO grid;
The Federal National Environmental Policy Act (NEPA) process is complete for SWIP-North, including having BLM Rights-of-Way secured, Construction/O&M Plan approved, and Conditional Notice to Proceed with Construction issued. No California Environmental Quality Act (CEQA) permits are required.
Considering the location of SWIP-North project, it brings tremendous resiliency benefits by creating a parallel North-South path to the two historically congested corridors – COI and PDCI – SWIP-North will improve resiliency, reliability and operational flexibility. Furthermore, there are significant economic benefits described herein including, but not limited to, load diversity, capacity, and GHG savings.
- potential future connections to other resource areas and transmission facilities;
SWIP-North is a network connected transmission line, providing bidirectional flow capabilities and access to the Western grid, including future increased access to the Pacific Northwest and Wyoming via Gateway West and Boardman to Hemmingway.
- resource integration requirements and the costs associated with these requirements in particular resource areas designated pursuant to policy initiatives;
Integration requirements for renewable resources in Idaho via SWIP-North are expected to be minimal compared to other alternatives being evaluated:
- SWIP-North connects two large 500 kV substations (Midpoint and Robinson) as well as Harry Allen 500 kV via ON Line, and it does not involve a long one-way generation tie line to access renewables.
- SWIP-North does not require third party transmission service to deliver to the CAISO BAA and provides CAISO access to and control over the capacity.
- the potential for a particular transmission solution to provide access to resources needed for integration, such as pumped storage in the case of renewable resources;
SWIP-North, as a transmission solution provides access to integrate other resources such as the Cat Creek Energy & Water pumped storage/wind/solar project in Idaho and geothermal resources in northern Nevada. Additionally, by providing another connection to the Pacific Northwest and providing a parallel alternative path to COI (PACI) and PDCI, SWIP-North offers increased access to existing hydro power which can further help with integration. SWIP-North will also expand interchange capability among CAISO and other BAAs including Idaho Power and PAC East.
- the effect of uncertainty associated with the above criteria, and any other considerations, that could affect the risk of stranded investment; and
SWIP-North is a low risk, low cost alternative considering the advanced development status including completion of NEPA and securing a BLM right-of-way grant, approved construction/O&M plan, and conditional notice to proceed. LS Power also has secured a wheel-free direct path to CAISO via a FERC-approved TUA with NV Energy providing capacity rights on the ON Line, thereby accomplishing interregional cost allocation and cost savings for California. It is a “no regrets” alternative that will pay for itself with economic benefits, plus it provides the exact policy benefits prescribed in the Base Portfolio. Selecting SWIP-North is the lowest risk/highest return solution for CAISO ratepayers.
- the effects of other solutions being considered for approval during the planning process.
CAISO should evaluate the impacts of each alternative on other transmission solutions being considered in this cycle. It is also important to note the positive effects on other solutions as well as the existing system as noted in the comprehensive benefits section above. For example, SWIP-North provides a parallel path to COI and PDCI which avoids High Fire Risk Areas and provides congestion relief.
 LS Power had previously submitted SWIP-North as a ~1050 MW new transmission capacity path, however recent WECC path rating studies for the project support ~1100 MW of new transmission capacity in N-S direction and ~1000 MW in S-N direction, which is what LS Power is offering to CAISO and requesting to be studied.
 SunZia presentation at the July 22, 2021 Joint Agency Workshop on Next Steps to Plan for SB 100 Resource Build: Transmission.
 “SWIP-North Benefits Analysis.” February 2021. Michael Hagerty, Johannes Pfeifenberger, and Evan Bennett. The Brattle Group. https://brattlefiles.blob.core.windows.net/files/21438_swip-north_benefits_analysis.pdf
 Testimony of Jeff Billinton on behalf of CAISO in R.20-11-003, January 11, 2021
 WECC Western Assessment of Resource Adequacy, Subregional Spotlight: California and Mexico (CAMX). February 12, 2021. https://www.wecc.org/_layouts/15/WopiFrame.aspx?sourcedoc=/Administrative/Western%20Assessment_California%20and%20Mexico%20Report.pdf&action=default
 OATI OASIS for Idaho Power Company, Generation Interconnection Queue, Accessed August 10, 2021 http://www.oasis.oati.com/ipco/
 LS Power Stakeholder Comments, 2021-2022 TPP, March 11, 2021, http://www.caiso.com/InitiativeDocuments/LSPowerComments-2021-2022TransmissionPlanningProcess-Feb252021StakeholderCall.pdf
 OATI OASIS for Idaho Power Company, Generation Interconnection Queue, Accessed 8/9/2021 http://www.oasis.oati.com/ipco/