Comments on July 27 stakeholder call discussion

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

ACP-California appreciates the opportunity to comment on the 2021-22 Transmission Planning Process (TPP) stakeholder meeting that was held on July 27, 2021. While stakeholder meetings at this juncture of the TPP are not “standard” we offer our support, and appreciation, for stakeholder meetings of this nature, which help stakeholders better understand some of the assumptions and approaches CAISO is taking to the studies and analysis it is undertaking. This meeting, and the meeting held in May 2021 were valuable for stakeholders and we encourage CAISO to continue to hold meetings in the spring and summer of the TPP cycle, to better inform stakeholders on the approach and assumptions that will inform the draft results released later in the year.

In the following sections, ACP-California offers comments on the transmission capability estimates, Offshore Wind sensitivities, economic modeling, and the 20-year outlook. In particular, ACP-California points out that it is critical that this TPP provide as much information and data as possible to feed into the current and upcoming IRP cycle and SB100 planning process. For the current IRP cycle, it would be valuable for CAISO to provide, as quickly as possible, any draft or high-level planning estimates it has for transmission upgrades related to Offshore Wind Sensitivity 1. As discussed more below, if this information can be available to the CPUC in the near-term, as it may be able to inform the upcoming Preferred System Plan. Additionally, given that the IRP has shifted to a three-year cycle, the likelihood of delays and misalignment between the IRP and TPP cycles are even more pronounced. And the need to feed data, sensitivities and available information into the IRP process is even more urgent. The best chance for informing the upcoming three-year IRP cycle will be by providing information, sensitivities, and analysis from work conducted during the 2021-22 TPP cycle. Therefore, we urge CAISO to provide as much information as possible to the CPUC through the 2021-22 TPP results. As discussed more below, this includes additional data on the transmission capability estimates, information on Offshore Wind transmission solutions and more. The need to feed transmission-related information into the IRP cycle and SB100 process is urgent, and CAISO should do all it can to provide various pieces of information from ongoing activities related to the 2021-22 TPP to key stakeholders.

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

The transmission capability estimates presented by CAISO will become critical inputs into the CPUC’s IRP process, as they as a significant driver of where new generation will be sited in the IRP and, in turn, those IRP portfolios are fed back into the TPP to determine what policy-driven transmission is needed. Thus, these estimates represent an incredibly important dataset that will affect the transmission that is likely to be approved and, therefore, impact California’s ability to meet its various energy goals. These estimates have been updated to reflect the recently implemented deliverability assessment methodology, which is an improvement. However, there are limitations to these figures which should be more clearly communicated and considered in various venues.

First, these estimates represent the capability of the existing and approved (but not yet in operation) transmission system. While this scope for the transmission availability estimates makes sense for long-term planning, it is important to recognize that many approved transmission projects are experiencing significant delays in their permitting and construction. Thus, these transmission capability estimates may be overly optimistic.

Additionally, while these estimates represent the technical capability of the transmission system, they do not necessarily line up with commercial viability for project development. Thus, the estimates may overstate the true ability to bring resources online on the existing, and approved, transmission system.

ACP-California asks for CAISO to conduct additional analysis and provide more data to help better inform the CPUC and other stakeholders regarding the capabilities of the transmission system and the limitations of the transmission capability estimates. First, it would be beneficial if CAISO could provide the same set of estimates for only the currently operational transmission system. This would help demonstrate the capabilities added by approved, but not yet online transmission, and will help demonstrate the importance of timely completion of outstanding transmission projects. It would also be helpful for CAISO to provide information on the commercial interest (queued resources) in each area relative to the transmission capability estimates. This may help provide improved transparency on where resources are most likely to be commercially viable and how commercial development activities align with transmission capability on the system. Finally, it would be helpful for CAISO to provide additional information on which of these constraints is “nested” and how stakeholders should interpret the total capability of the system, given that simply adding the capabilities in these tables would likely result in a gross overestimation of the capability of the system. This type of additional information and data would be useful for stakeholders and could also be valuable for the CPUC’s IRP to consider. Therefore, we ask that CAISO provide this type of information as an appendix to the whitepaper on estimated transmission capability.

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

ACP-California appreciates the work CAISO is performing to conduct the two Offshore Wind sensitivities in the 2021-22 TPP. ACP-California has concerns about the timeline on which Offshore Wind transmission solutions, and other transmission solutions, are being evaluated and when they may be able to be approved and the information on these transmission solutions may be able to be fed into the IRP process. The circular nature of the IRP and TPP, along with the recent transition to a three-year IRP cycle, are creating a very long lead time towards consideration of any transmission solutions for approval at the CAISO. The lead time is so long, it could threaten California’s ability to meet its GHG reduction and reliability goals. We encourage CAISO to work with the CPUC to find efficiencies in the IRP-TPP integration process and to better streamline and expedite approval of transmission to reach OSW and other diverse resources.

Additionally, with respect to Sensitivity 1 for Offshore Wind, ACP-California urges CAISO to expeditiously provide any draft/high-level transmission cost results for this sensitivity to the CPUC and CEC. Making high-level information on the necessary transmission upgrades and cost information available to the CPUC and CEC may allow these transmission costs to be considered in development of the IRP’s Preferred System Plan for the 2020-21 IRP cycle and within the context of ongoing SB100 efforts. Providing information on transmission costs, even if highly preliminary, would allow Offshore Wind to be available as a candidate resource in the selection of the Preferred System Plan for the 2020-21 IRP and would allow Offshore Wind to be more thoroughly considered in SB100 planning efforts. While we recognize that any information CAISO would provide to the CPUC and other stakeholders on these transmission costs would be highly preliminary, having some information available to inform the development of the Preferred System Plan and SB100 process would be better than the lack of information that currently exists and which serves as a barrier to Offshore Wind’s selection.

To the extent it is feasible to do so, without slowing down the TPP, ACP-California also recommends that CAISO explore other Points of Interconnection to the CAISO system for the Offshore Wind sensitivities. Specifically, an evaluation of delivery to Moss Landing would also be helpful.

Finally, as ACP-California commented during the call, especially with respect to the longer-term Offshore Wind sensitivity, we recommend that CAISO consider the use of the 1,400 MW generator drop limits which appears to be a significant driver of the quantity of transmission that is deemed to be necessary to integrate OSW resources. The “outlook” Offshore Wind sensitivity is looking well into the future of OSW wind development, perhaps representing development in the 10-20 year time horizon. Therefore, it is reasonable for CAISO to assess whether, 20 years in the future, a 1,400 MW generator drop limit is likely to be in effect or if a higher limit may apply as CAISO navigates the clean energy transition. ACP-California recommends that CAISO consider a “sensitivity” or “scenario” case where a higher generation drop limit is assumed and outline for stakeholders how that higher limit might affect the overall transmission needs for OSW in the two sensitivity cases CAISO is assessing in the 2021-22 TPP. This type of information will be valuable to the CPUC’s ongoing IRP process and in other forums.

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

With respect to assumptions made regarding, Co-Located and Hybrid Resources and grid charging, ACP-California echoes comments made by other stakeholders during the meeting. Notably, stakeholders commented that opting to not model grid-charging restrictions in the 2031 case may be reasonable (since ITC-related restrictions are expected to have rolled off by 2031), but CAISO should use caution in how the 2031 case is utilized. If the 2031 case is relied upon to reassess any previously approved transmission projects or to evaluate congestion patterns for years before 2031, then CAISO should consider whether modeling grid charging restrictions in those instances is appropriate.

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

CAISO’s efforts to conduct the 20-year transmission outlook should be applauded. CAISO is coordinating these studies with the CEC and CPUC and appears to be relying heavily on assumptions that are consistent with SB100 studies and other ongoing activities at the CPUC/CEC.

While this is a logical starting place, it may also be useful for CAISO to utilize the 20-year outlook or other informational study processes to incorporate some of its own perspective and expectations regarding the future grid and its resource composition. CAISO should consider conducting other types of studies, or augmenting the 20-year outlook, to evaluate transmission needs that reflect CAISO’s own expectations regarding generation development and resource needs across the grid. These types of informational studies, relying on CAISO’s own significant expertise, may provide useful information for the CPUC in its ongoing resource planning efforts and for other stakeholders in helping to identify the “least regrets” transmission solutions.

Additionally, ACP-California encourages CAISO to use the 20-year outlook cases to explore and assess various solutions for Offshore Wind, including a subsea cable to deliver into the LA Basin and different Points of Interconnection to the CAISO-grid which will accommodate larger quantities of Offshore Wind. As discussed under the response to question #3, Moss Landing is an example of an interconnection point for Offshore Wind which deserves further exploration in the context of the CAISO’s planning efforts. Having additional information and analysis will be valuable for SB 100 planning efforts at the CPUC and CEC.

7. Additional comments on the July 27, 2021 stakeholder call discussion:

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

On July 27, 2021, the CAISO held a stakeholder call to provide some updates on the CAISO 2021-22 transmission Planning Process (TPP) and to review details of the out of state (OOS) wind sensitivity study it will be performing under the CAISO 2021-22 TPP. These updates included the following topics.

1. Updated Transmission Capability Estimates for Use in California Public Utilities Commission’s (CPUC) Resource Planning Process
2. 2021-2022 Transmission Planning Process Updates
   1. Policy-driven Assessment Sensitivity 1 –Offshore Wind Studies
   2. Economic Assessment Assumption Update for 2021-2022 Planning Cycle
   3. Out of State Wind in Portfolios -Update
3. 20 Year Transmission Outlook Update

The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on some of these topics. BAMx applauds the CAISO staff’s efforts in updating the transmission capability estimates for use in CPUC’s Resource Planning Process and seeks additional details of the CAISO’s calculations as elaborated in Section 2 below.

BAMx appreciates the CAISO staff’s progress in modeling the 10-year and 20-year offshore wind as well as the out-of-state (OOS) wind. BAMx is fully supportive of taking any necessary steps to achieve the State’s climate goals. Further, BAMx understands that electric rates will continue to rise to achieve those goals. That said, it is incumbent on us all to do so in a manner that achieves those goals as cost-effectively as possible. Incorporating the cost of needed transmission to deliver new resources to load is critical to achieving our climate goals in a cost-effective manner.

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

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

The CAISO’s white paper (White Paper, hereafter) provides very helpful insights into the transmission capability estimates that are used in the CPUC’s resource planning process.[1] Estimated existing system Full Capacity Deliverability Status (FCDS) capability is expressed based on the resource-type specific resource output assumptions used in on-peak deliverability assessment rather than based on installed capacity.[2] As a result, the FCDS capability estimates are resource-type neutral and can be translated into any combination of resource types by applying the applicable resource output factors. BAMx supports the “resource-type neutral” transmission capability estimates as they can be translated into any combination of resource types by applying the respective deliverability study resource output factors.

The updated transmission capability estimates provided in Table 3-1 of the White Paper and slides #14 and #15 of the CAISO’s July 27^th presentation are comprehensive and data-intensive. It would be helpful for the CAISO to provide the additional information listed below for better stakeholder understanding and meaningful feedback.

1. BAMx has reviewed the more detailed locational information of resources affected by each constraint, which is provided in the form of substation-line diagrams or BES substation lists in a separate PowerPoint document.[PW1]   However, that information does not clearly lay out whether the affected constrained zones can be standalone, nested, or overlapping. Please provide this detail for each relevant zone.
2. As part of the generation interconnection process, the CAISO conducts on-peak and off-peak deliverability assessments of active generation in its interconnection queue. These assessments lead to the identification of deliverability constraints and transmission upgrades along with the cost to mitigate the constraints identified.[3] Please identify the specific cluster study that determined all the relevant deliverability constraints and transmission upgrades along with the cost to mitigate the identified constraints.
3. There are some zones, where BAMx found the transmission capability estimates were lower than what was in earlier provided estimates. Given the CAISO revised deliverability assessment methodology implemented at the beginning of the year 2020, we would expect the transmission capability numbers to be at least as high as the previous amounts used in the CAISO 2020-2021 TPP. For example, in the Tehachapi area, the updated transmission capability limit is listed as 3,000MW, whereas earlier it was as high as 4,000MW. Please explain whether this reduction of 1,000MW in the Tehachapi area is attributed to the baseline contracted future resource amounts the CPUC transmitted for use in the CAISO 2020-2021 TPP. If not, please identify other reasons, if any.
4. The White Paper envisions the FCDS capacity estimates based on on-peak deliverability constraints both in the Highest System Need (HSN) and Secondary System Need (SSN) scenarios.[4] The HSN represents the most important hours for resource adequacy purposes and reflects the reality that solar resources contribute little to the system reliability during this period. The SSN represents the highest load hours when solar resources contribute to the system reliability.[5] BAMx believes it is important to understand to what extent the FCDS capacity estimates are driven by HSN versus SSN scenarios. Therefore, BAMx encourages the CAISO to separately provide whether the transmission capability amounts are driven by HSN or SSN. During the CAISO 2020-2021 Transmission Planning Process (TPP) cycle, the CAISO had identified deliverability assessment results separately for HSN and SSN.[6] Therefore, we request they do so again for this year. 

[1] “Transmission Capability Estimates for use in the CPUC’s Resource Planning Process,” White Paper, CAISO Transmission Infrastructure Planning, July 19, 2021.

[2] White Paper, p.8.

[3] White Paper, p.7.

[4] White Paper, p.9.

[5] CAISO “Deliverability Assessment Methodology Revisions,” Draft Final Proposal, September 27, 2019, p.6.

[6] For example, see Table 3.5-3: Deliverability assessment results – South of Kramer – Kramer to Victor constraint in the CAISO 2020-2021 Transmission Plan, March 24, 2021, p.177.

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

On slide #34, the CAISO had categorized the transmission reinforcements required to interconnect offshore wind generation into the following three groups.

1. Transfer Path: The transmission lines to connect the onshore substations to the rest of the system.
2. The onshore network that connects the export cables to the rest of the system.
3. Other reinforcements required across the CAISO system to interconnect the OSW and reliably manage the resulting flows.

BAMx believes it would be helpful for the CAISO to classify the envisioned transmission by definitions used in the CAISO tariff. We believe those characterizations would be interconnecting customer interconnection facilities (or gen-tie) that connect the offshore wind to appropriate onshore substations (points of interconnections) and other transmission facilities required to achieve an economically justified distribution of the new wind resources throughout the CAISO grid. We believe the offshore wind resources should connect to major onshore substations with rough equivalency to those major substations that connect OOS wind to the CAISO grid like Eldorado and Pinal Central substations. BAMx believes this methodology will help provide the proper signals to load-serving entities to select the economically efficient renewable resources to comply with the State's goals. 

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

No comments at this time.

5. 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:

Some OOS transmission projects are complementary, whereas other transmission projects serve as substitutes for others. BAMx notes that the resources accessed by these transmission projects compete against off-shore wind and in-State solar, wind, geothermal, and short- and long-term storage generation. In particular, the extent and location of battery storage will be critical in meeting the State policy goals. For example, locating battery storage in a highly congested area with high renewable curtailment would help to reduce congestion and renewable curtailment, thereby minimizing the need for certain competing transmission solutions.^[1] The CAISO’s past comprehensive battery remapping studies^[2] have demonstrated not only that transmission congestion and renewable curtailment can be further reduced by remapping or allocating batteries to constrained areas, but also that the latter is more effective than the transmission alternatives.^[3] This lesson learned is important for studying all resource portfolios and scenarios going forward on a state-wide basis. In other words, it is pertinent to perform an additional layer of analysis to check whether any transmission upgrades triggered by a given resource portfolio could be eliminated or scoped differently by remapping the renewable and battery storage resources. We encourage the CAISO, the CPUC and the California Energy Commission to have such study processes built-in as they evaluate the need for future transmission solutions.

Any evaluation of alternative transmission projects to deliver needed resources to load should identify a realistic assessment of any in-State transmission upgrades and related costs. See BAMx’s recommendations regarding how all transmission costs need to be considered while evaluating transmission resources needed to import OOS and to connect offshore California wind to the CAISO grid.[4] In these comments, BAMx also emphasized the need for a framework that ensures the allocation of costs - of OOS renewable and offshore wind resources connecting to the appropriate delivery points on the CAISO grid – to purchasers of the related energy from these resources.

[1] See BAMx Comments on the CAISO 2020-2021 Transmission Plan Stakeholder Presentation Materials from November 17, 2020, December 1, 2020 located at https://flynnrci.com/wp-content/uploads/2021/03/BAMx-Comments-on-CAISO-2020-21-Transmission-Plan_12012020-2.pdf

[2] “Economic Assessment and Production Cost Simulation,” Draft 2020-2021 Transmission Plan, 2020-2021 Transmission Planning Process Stakeholder Meeting, February 9, 2021.

[3] 2020-2021 Draft Plan, pp. 224-232.

[4] BAMx Comments on CAISO 20-Year transmission outlook, June 24, 2021.

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

The State’s climate goals are likely to require a transformation of the State’s electrical infrastructure, including the In-State, Offshore, and OOS solar, wind, and storage resources, including the transmission facilities associated with this expanding supply infrastructure. The state agencies need to look out further in time but recognize the increased importance of the economic principles covered in the above comments. Following these principles is even more important in the longer term since it is in this timeframe that more OOS renewables and/or offshore wind resources will be economically justified.

7. Additional comments on the July 27, 2021 stakeholder call discussion:

No comments at this time.

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the presentations from the July 27, 2021 stakeholder call. Forward planning and coordination between the CAISO, California Public Utilities Commission (Commission), and the California Energy Commission (CEC) will play a critical role in ensuring California can meet its ambitious climate goals reliably and cost-effectively. Transmission planning is a major piece of this coordination, and the CAISO must approve transmission projects far enough in advance to accommodate the influx of clean resources that will come online to meet Senate Bille (SB) 100 targets. The 20-year Transmission Outlook should inform transmission planning that results in the approval of projects far enough in advance to reliably meet climate goals.

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

CalCCA supports the CAISO’s efforts updating the transmission capability estimates used in the Integrated Resource Planning (IRP) Process and appreciates the collaborative effort between the CAISO and the Commission. Coordination between the CAISO and the Commission is crucial to ensure transmission and resource build can reliably meet climate goals.

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

No comments at this time.

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

The CAISO’s presentation indicates their model will assume co-located storage resources can charge from the grid, noting this will result in a loss of investment tax credit dollars for the resource owner. The CAISO should reconsider whether this assumption appropriately reflects how storage resources will operate given the significant cost impact grid charging has on resource owners eligible for the investment tax credit.

5. 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:

CalCCA is encouraged that the CAISO plans to perform a special study on out-of-state wind transmission alternatives. The CAISO, Commission, and CEC should consider these out-of-state transmission projects in the context of both IRP and Transmission Planning Process (TPP) processes to understand how each project enhances California’s ability to access clean and renewable resources in the most cost-effective and reliable way to meet SB 100 goals. In particular, resource profiles for out-of-state wind appear attractive when looking at potential resource output during critical hours but the CAISO, the Commission, and the CEC should also consider IRP cost assumptions and individual load-serving entities' IRP reporting to determine whether or not such resources are selected in IRP modeling.

Any such consideration of out-of-state wind, or other out-of-state resources should be evaluated with cost-effectiveness in mind. The results of the TPP should not simply find resources that are attractive but will never be built and imported due to cost constraints while building transmission in anticipation of such resources. Modeling of the need and the costs of alternatives will therefore play a critical role in this process.

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

CalCCA appreciates the CAISO’s efforts to develop the 20-year Transmission Outlook and commends the CAISO for its collaboration with the Commission and the CEC in the IRP, SB 100, and Integrated Energy Policy Report (IEPR) processes. Coordination with these processes will ensure resource procurement and new transmission build aligns. 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. The CAISO should consider how the 20-year Transmission Outlook could be incorporated into the existing Transmission Planning Process (TPP) to consider what transmission build will need to occur and in what timeframe to meet policy goals. Given the time required to develop new transmission, the 10-year look ahead in the TPP can result in transmission projects coming online just in time to meet an identified reliability need.

CalCCA is encouraged that the 20-year Transmission Outlook will utilize the SB 100 "No Combustion" scenario for 2040. Recognizing that decarbonization goals necessitate significant resource build, it is prudent to use this scenario to inform potential transmission projects so that new clean resources do not get stranded behind transmission constraints. Considering the large number of resources expected to come online to meet state policies, the TPP could benefit from the insight of a longer planning horizon provided by the 20-year Transmission Outlook to inform policy-driven transmission projects. The 20-year Transmission Outlook should be used to inform the TPP of transmission needs driven by clean energy policies like SB 100 so that projects approved in the TPP also contribute to meeting policy goals that will be realized beyond 10 years out.

CalCCA also supports the 20-year Transmission Outlook’s consideration of key environmental and land use impacts provided by the CEC. Land use and habitat concerns can create serious delays or project cancellations if not incorporated into site evaluation from the start. By incorporating these considerations into transmission planning, the CAISO, the Commission, and the CEC can help steer projects to less sensitive areas and avoid potentially serious delays or cancellations of transmission projects needed to integrate future resource procurement.

7. Additional comments on the July 27, 2021 stakeholder call discussion:

No additional comments at this time.

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

CESA appreciates and supports the updated transmission capability estimates, particularly the improvement to organize estimates by deliverability constraint rather than zone as well as the timing and cost of the conceptual ADNU, which provides greater locational and timing guidance not only for IRP modeling and planning purposes but also for interconnection siting. 

While supportive of the estimates and the white paper explanations, CESA seeks clarification on the following:

• Confirm the baseline of existing or contracted resources: Specifically, does the baseline exclude resources that may have executed generator interconnection agreements (GIAs) but do not yet have a contract?
• Clarify how energy storage could fit in as an AOPNU to provide incremental EODS capability: As CESA understands it, the incremental amount of queued energy storage behind an off-peak constraint increases the EODS capability, but CESA wishes to better understand whether and how the IRP models will interact with these estimates - e.g., to site storage to function as an AOPNU provide incremental EODS capability instead of triggering AOPNUs to support more renewable generation. Furthermore, given these transmission capability estimates and the large queue of storage projects in QC14, the CAISO should consider identifying queued storage projects as representing good fits for the network application process that could provide economic benefits and address transmission congestion. This would help manage the current supercluster and support the identification of effective system resources. 

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

7. Additional comments on the July 27, 2021 stakeholder call discussion:

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

The Public Advocates Office at the California Public Utilities Commission (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

Skyrocketing transmission costs provide a backdrop for the California Independent System Operator (CAISO) 2021-2022 Transmission Planning Process (TPP).   Since 2009, the CAISO Transmission Access Charge (TAC) increased 255 percent.[2]  Between 2016 and 2021 alone, California’s transmission revenue requirement increased approximately 38 percent while gross load declined over the same time frame.[3]  These transmission costs are anticipated to rise with the State’s increased renewable portfolio (RPS) targets and transportation electrification goals.

New Transmission Projects to Integrate Renewables

In February 2021, the California Public Utilities Commission (CPUC) submitted three renewable portfolios for the CAISO to study in the 2021-2022 TPP to meet the state’s 2031 clean energy goals.  The base case portfolio includes 18,000 megawatts (MW) of new renewable generation, including 1,062 MW of out-of-state wind resources.  The policy driven 38 million metric ton (MMT)[4]  portfolio consists of nearly 22,000 MW of new renewable generation, including 3,000 MW of out-of-state wind resources.  The sensitivity portfolio includes 8,000 MW of California offshore wind resources at several locations.[5]  These procurement portfolios require significant in-state and out-of-state transmission investments. 

Required Interregional Transmission Project Analysis

In compliance with FERC Order No. 1000, the CAISO and other western public utilities and planning regions referred to as Northern Grid[6]  and WestConnect,[7]  are required to include interregional transmission coordination and cost allocation requirements in their respective tariffs.[8]  The proposed out-of-state transmission alternatives presented during the July 27, 2021 CAISO TPP stakeholder meeting are interregional transmission projects that have requested cost recovery from the CAISO and one or both of the above-mentioned western planning regions.  So, far the CAISO and the western planning regions have not conferred on the cost assignments for these interregional transmission projects per their tariffs.

RECOMMENDATIONS

To support any forthcoming discussions on interregional transmission cost allocation for the presented out-of-state transmission alternatives, Cal Advocates recommends the following:

1. The CAISO should provide a transmission cost analysis that includes all known costs.  These known costs should include:

1. The costs for new transmission lines to deliver renewable resources to California load centers in-state, not just to the California border.  Transmission upgrades in-state may also be needed to bring the proposed 1,000-3,000 MW of out-of-state wind to California load centers.  To understand the total cost of delivering out-of-state wind to California load centers, all transmission costs should be included in the CAISO’s analysis.
2. The expected revenue requirements for the proposed new transmission projects. The expected revenue requirement for a transmission project is a better indicator of how a project will impact California ratepayers than the capital cost estimate.

Conservative assumptions indicate that every dollar included in transmission rate base costs ratepayers in excess of $3.50 over the life of the transmission asset.  For example, the $2.75 billion in capital additions for the three investor-owned utilities (IOUs) in 2020 alone can be expected to cost ratepayers at least $9.7 billion over the life of the assets, using a conservative asset life estimate of 36 years.[9]

2. The CAISO should provide an economic benefits analysis of the transmissions options to meet the state’s clean energy goals.

The interregional projects presented at the CAISO’s July 27, 2021, TPP meeting range in cost from $525 million to $3 billion.  These proposed transmission lines will also provide transmission reliability and economic benefits to out-of-state regions where the lines pass through.  Consistent with FERC Order No. 1000 and the Interregional Cost Allocation Principle 1, the cost for these interregional projects must not be solely borne by California ratepayers.  This Order requires that the cost allocation for new transmission facilities be allocated in a manner that is roughly commensurate with estimated benefits.[10]   Thus the CAISO should analyze the potential regional economic benefits generated from the proposed interregional transmission projects to meet the state’s clean energy goals.  The regional economic activity generated from large infrastructure projects, such as new interregional transmission projects, directly benefit local businesses and contribute to the economy of the regions that the interregional project passes through.[11]  These benefits include transmission reliability as well as new job and tax revenue growth.  Assessing these benefits will assist with forthcoming negotiations between the CAISO and the other western planning regions that benefit from the proposed interregional transmission projects on the cost allocation for these interregional projects with the other states. 

[1] Cal. Pub. Util. Code § 309.5.

[2] Utility Costs and Affordability of the Grid of the Future, An Evaluation of Electric Costs, Rate and Equity Issues Pursuant to P.U. Code Section 913.1, (California Utility Cost - May 2021) CPUC, May 2021, pp. 41-42.

[3] California Utility Cost - May 2021, pp. 38 & 41.

[4] The policy-driven portfolio examines a portfolio that is modeled to produce 38 MMT of greenhouse gas emissions, whereas the base case portfolio produces 46 MMT of greenhouse gas emissions.

[5] Fact Sheet: Decision Transferring Electric Resource Portfolios to California Independent System Operator (CAI SO) for 2021-2022 Transmission Planning Process, CPUC, February 11, 2021, p. 2.

[6] Northern Grid includes the states of Washington, Oregon, Idaho and portions of Wyoming and Utah.

[7] West Connect includes portions of Nevada, Arizona, New Mexico, Colorado, and Wyoming.  It also includes the California municipal utility districts.

[8] California ISO, 2014-2015 Conceptual Statewide Transmission Update, 2015 – 2016 Regional Transmission Planning Process, August 31, 2015, CAISO, pp. 11-12.

[9] California Utility Costs, May 2021, p. 39.

[10] Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities, Federal Energy Regulatory Commission, Docket No. RM10-23-000; Order No. 1000, July 21, 2011, section 622, p. 447.

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

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

The CAISO has performed an extensive review that identifies by transmission areas, the full capacity delivery service (FCDS) of resources capabilities during peak and off-peak periods.  The CAISO also identifies the projected costs of transmission system upgrades for increasing transmission area capabilities.  This information is provided to the CPUC as an input to the Integrated Resource Planning (IRP) process to develop the Resource Adequacy plan for 2031.

The CAISO White Paper[1] proposes FCDS capacity estimates based on on-peak deliverability constraints both in the Highest System Need (HSN) and Secondary System Need (SSN) scenarios.^[2]   The highest system need scenario represents when the capacity shortage is most likely to occur.  In this scenario, the system reaches its peak and net peak during hours with low solar output.  The highest system need hours are hours between 5 pm to 10 pm  in the summer months with an unloaded capacity margin less than 6 percent in the CAISO annual summer assessment.[3]  The secondary system need scenario represents when the capacity shortage risk will increase if the intermittent generation, while producing at a significant output level, is not deliverable.  In this scenario, the system load is modeled to represent the peak consumption level, and solar output is modeled at a significantly high output.  The secondary system need hours are hours between 2 pm to 5 pm in the summer months.^[4]  

It is critical to understand to what extent the FCDS capacity estimates are driven by HSN versus SSN scenarios.  Therefore, Cal Advocates recommends the CAISO to separately provide the transmission capability amounts and identify whether those amounts are driven by HSN or SSN.  Such analysis would be consistent with the deliverability assessment results the CAISO provided as part of the CAISO 2020-2021 TPP.[5]

[1] “Transmission Capability Estimates for use in the CPUC’s Resource Planning Process,” White Paper, CAISO Transmission Infrastructure Planning, July 19, 2021.

[2] Transmission Capability Estimates for use in the CPUC’s Resource Planning Process,” White Paper, CAISO, July 19, 2021, p. 9.

[3] CAISO Generator On-Peak Deliverability Assessment Methodology, On-Peak Deliverability Assessment Methodology (for Resource Adequacy Purposes), March 2020, p. 3.

[4] CAISO Generator On-Peak Deliverability Assessment Methodology, On-Peak Deliverability Assessment Methodology (for Resource Adequacy Purposes), March 2020, p. 4.

[5] As an example, see CAISO 2020-2021 Transmission Plan, March 24, 2021, p. 177.

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

Cal Advocates is technology neutral with regards to specific renewable energy resources.  Cal Advocates supports the goal of examining offshore wind transmission costs and to this end requests that CAISO provide the costs for connecting the offshore wind resources to substations. 

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

Cal Advocates has no comment on this topic at this time.

5. 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:

As specified on presentation slide 68 in the July 27, 2021 CAISO TPP presentation, the analysis of out-of-state transmission alternatives to access the out-of-state wind portfolio will only include a production cost simulation.^[1]  Though this production cost simulation analysis will assess the impact of the proposed transmission projects on energy costs, congestion, and curtailment to California, the assessment does not consider the significant energy and economic benefits the proposed out-of-state transmission projects could generate in other regions.  The later analysis is necessary to determine the scope of benefits and beneficiaries of interregional projects consistent with FERC Order No. 1000.^[2]

As shown in Table 1 below, the proposed out-of-state transmission alternatives are located in other states and, as a result, will impact other regions.  These impacts should be assessed as part of the out-of-state transmission alternatives analysis to assist with determining the interregional cost allocation.  Additionally, consistent with the CAISO’s Tariff Section on Interregional Transmission Project Assessment,[3] the CAISO must compare California’s in-state resource and transmission options to meet the state clean energy goals with the out-of-state resource and transmission alternatives in order to determine the more cost-effective and efficient solution.

Since 2016, the CAISO and the other western planning regions have reviewed and considered the above proposed out-of-state transmission alternatives.  The developers’ submittals characterized the projects’ regional benefits as follows:

TransWest Express would:

1. Assist with meeting California’s, Arizona’s, and New Mexico’s RPS targets.[1]
2. Provide economic opportunities through an expanded grid and accommodate planned resources.[2]

SWIP North:

1. “Improves transfer capability between CAISO, PacifiCorp, NV Energy, Idaho Power, and Bonneville Power Association.” [1]
2. “Helps meet west wide” renewable portfolio standards (RPS) and greenhouse gas (GHG) goals.[2]
3. Enhances system reliability for the entire western Grid.[3] 

The 2018 presentation on SWIP-North to the western planning regions states that the project will also create 250-300 construction jobs and local and state tax revenues.[4]  These benefits will likely accrue to just Idaho and New Mexico, where the proposed SWIP North project is located.

Cross-Tie would:

1. Increase transmission capacity between PacifiCorp, NV Energy, CAISO and Idaho Power Balancing Areas.[5]
2.  Facilitate “development of renewables to meet RPS and GHG goals of western states - enable lower cost ways to meet policy objectives by tapping the best resources in the West and sharing those resources across the region.”[6]
3. Substantially interconnect Berkshire Hathaway Energy’s two largest load and generation centers (BAs) in the west (PacifiCorp East and NV Energy).[7]

Thus, it is clear based on the TransWest, SWIP-North and Cross-Tie project submittals to the western planning regions that the CAISO’s proposed out-of-state transmission alternatives will have multiple benefits to regions outside of California.  It is also clear that it is necessary to determine the scope of benefits and beneficiaries of these interregional projects consistent with FERC Order No. 1000.

[1] Southwest Intertie Project (SWIP) North, Overview of March 2016 ITP Submissions to CAISO, NTTG & WestConnect, LS Power (SWIP North Presentation 2016), slide 11.

[2] SWIP North Presentation 2016, slide 11.

[3] 2018-2019 Interregional Transmission Coordination – Interregional Transmission Project Submittal, Great Basin Transmission ITP Submission to California ISO presentation, May 2018, (SWIP-North Presentation 2018), slide 6.

[4] SWIP North Presentation 2018, slide 6.

[5] 2018-2019 Interregional transmission coordination – Interregional Project Submittals, 2018 TransCanyon Cross Tie Transmission Line Project Summary, TransCanyon, May 18, 2018, (Cross-Tie Presentation 2018) slide 3.

[6] Cross-Tie Presentation 2018, slide 3.

[7]Cross-Tie Presentation 2018, slides 4.

[1] TransWest Express Transmission Project 2016-2017 Interregional Transmission Project Submittal to California Independent System Operator, WestConnect and Northern Tier Transmission Group, March 31, 2016, slide 2.

[2] TransWest Express Transmission Project 2018-2019 Interregional Transmission Project Submittal to California Independent System Operator, WestConnect and Northern Tier Transmission Group, March 31, 2018, slide 2.

[1] Out of State Wind in Portfolios – Update, 2021-2022 Transmission Planning Process, CAISO, July 27, 2021, slide 68.

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

[3] CAISO Fifth Replacement FERC Electric Tariff, September 9, 2020, Section 24.17.2.

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

Please refer to responses to questions 1 and 5. 

7. Additional comments on the July 27, 2021 stakeholder call discussion:

At, the July 27, 2021 CAISO TPP stakeholder meeting, the CAISO also presented additional proposed interregional transmission projects as well as new in-state transmission projects that could assist with meeting the state’s clean energy goals on slide 77.[1]  The same list of transmission projects was also presented in the Joint Agency Workshop on Next Steps to Plan for Senate Bill 100 Resource Bill - Transmission on July 22, 2021. 

Cal Advocates requests that the CAISO, CPUC, and the California Energy Commission conduct the same cost and benefit analysis and comparison for these projects as described in our responses to questions 1 and 5 above.  This analysis should consider both the direct energy benefits such as reduced transmission congestion and energy curtailment as well as indirect benefits such as new jobs and tax revenue to specific regions in the west out-side of California.

[1] 20 Year Transmission Outlook - Update, CAISO, July 27, 2021, slide 77.

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

CAISO 2021-22 TPP and 20 Year Outlook July 27, 2021, Workshop

California Western Grid, LLC - Stakeholder Comments

August 10, 2021

California Western Grid, LLC (CWG) appreciates this opportunity to submit both comments and questions that arise from the July 27, 2021, Stakeholder Webinar.    CWG applauds the work CAISO has put into the 2021-22 TPP and 20-year Outlook.  We offer these comments and questions in the spirit of supporting the work of the CAISO and to improve our understanding of that work. We also seek to clarify expectations and understand limitations of the analysis being done in the 2021-22 TPP and the 20-year Transmission Outlook.

Questions related to the CAISO Transmission Capability Estimates

CWG understands the tables on slides 14 and 15 show estimates, among other things, of the available transmission on the bulk power system (115 KV and above) at specific locations to support and enable Full Capacity Deliverability Status (FCDS) of generators that interconnect in those locations.  However, CWG is concerned that connecting new resource to the bulk power system is only part of the problem.  We are concerned that new renewable power, unless directly connected to the bulk power system inside of a Local Capacity Area (LCA), will not be able to support the reliability needs in the LCAs (such as the LA Basin).  And we believe that while distributed energy resources will assist in meeting LA Basin energy needs and lowering GHGs, new transmission will be essential if we are going to meet California’s ambitious carbon emission goals.

CWG is also concerned that new renewable resources that are connected to the bulk power system using existing transmission capability, without new transmission facilities that bring that power into the LCA load centers, is likely to result in more curtailment of renewables and/or more exporting of those renewable resources to other states.

The CPUC IRP base portfolio sent to the CAISO for use in the 2021-22 TPP envisions significant new amounts of renewable generation by 2031.  Has the CAISO modeled or does the CAISO plan to model how much of that connecting new generation is likely to affect the amount of renewable curtailment and/or amount of renewable power exported to neighboring states?  If not, CWG respectfully request the CAISO do that modeling and share the results with Stakeholders.

After reviewing Slides 14 and 15, CWG observes that the existing transmission capability estimates for the Central California Westland / Carrizo zones stands head and shoulders above all other zones shown on slides 14 and 15.  Our understanding is some 10,830 MW of FCDS capability can connect without further reinforcements.  CWG believes new transmission is needed to bring power from the existing bulk power system at Diablo Canyon to the West side of load centers into the LA Basin.  Assuming new renewable generation connects to the existing bulk power system in the Westland / Carrizo zones, does the CAISO believe that at least 2,000 MW of that power could be delivered to the DCPP 500 KV Switchyard without further reinforcement of the existing bulk power system? 

Comments and Questions related to the Offshore Wind Sensitivity Study

CWG is pleased the CAISO is planning to study transmission options for delivering Offshore wind from the Humboldt area in Northern California and Morrow Bay / Diablo Canyon in Central California.

However, CWG is concerned that the CAISO appears to limit the delivery options for Central California to land solutions, assuming all power will be delivered to Diablo Canyon or Morrow Bay area Substations.  On the other hand, we noticed the Northern California Wind study will include up to five (5) delivery locations, including an option for an undersea cable to deliver power to the San Francisco Bay Area LCA.

CWG urges the CAISO similarly study an undersea transmission option for Central California that would (1) bring Offshore wind power to DCPP 500 KV switchyard where that power could meet Northern California needs and (2) connect to an HVDC multi-terminal subsea transmission line connecting the DCPP 500 KV switchyard to delivery points in the LA Metro LCA.  A multi-terminal HVDC under sea transmission line could terminate at points that allow use of the exiting transmission system that serves coastal gas plants in the Western LA Basin. 

In conducting such an analysis CAISO should review the many benefits of an undersea transmission line.  CWG believes an undersea cable option would compare favorably to the land-based solutions the CAISO plans to study for Central California Offshore wind.

Comments and Questions related to the CAISO 20-year Transmission Outlook

CWG is trying to understand what the CAISO 20-year Transmission Outlook is trying to achieve once the study is complete.  After hearing the CAISO presentation on July 27, CWG does not understand what the final product of the 20-year outlook would look like, what questions would the study answer, or how its conclusions may influence the 21-22 TPP, if at all. Long term solutions identified in the 20-year plan will likely need to be initiated immediately if the transmission solutions are to be available when needed.

CWG in previous comments has urged the CAISO produce a road map of the transmission needed to meet SB 100 goals. Does the CAISO plan to create such a roadmap as part of the 20-year Transmission Outlook?

The Joint Agency SB 100 report of March 15, 2021, envisions the need to “triple the grid”:  https://www.greencarcongress.com/2021/03/20210316-cali.html  The time is now to start identifying key new transmission that would begin to triple the grid.  Specifically, the CAISO should identify, study, and compare the least regrets transmission projects that would perform well under a variety of resource procurement futures and under high de-carbonization and expanded EV load forecasts.

Does the CAISO plan to use a high de-carbonization load forecast in its 20-year outlook?  What load forecasts does the CAISO plan to use?

Does the CAISO plan to look at several resource procurement futures, in addition to the modest gas retirement forecast shown at slide 78? CWG describes the resource portfolio on slide 78 as modest because of the roughly 28,000 MW of existing gas fired generation, only 15,000 is retired by 2040 in that portfolio. CWG recommends the CAISO use the resource portfolio for 2035 instead of 2040 for achievement of SB 100 as shown in the March 15, 2021 SB100 Joint Agency Report.  And, the CAISO should evaluate the transmission additions needed to achieve the Zero Carbon Scenario from that same Joint Agency Report.

Will the CAISO look at accelerating the achievement of the SB100 goals.  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/ 

How will CAISO work with CARB and the CPUC to explore scenarios for accelerated achievement of SB 100 goals and incorporate those scenarios in the 20-year transmission outlook? What is the timeline for initiating this work?

Pursuant to the CAISO Tariff 24.4.6.6, the CAISO is obligated to evaluate transmission solutions needed to meet state, municipal, county, or federal policy requirements or directives. How does the CAISO reconcile the CAISO 20-year transmission plan that appears to defer immediate action on identifying transmission needed to reduce reliance on a large portion of California’s fossil generation fleet with the public policy objectives to eliminate fossil emissions including the Governor’s directive to explore acceleration of achieving of SB 100 goals?

Finally, CWG urges the CAISO to make the results of it 20-year transmission outlook “actionable”.  If new transmission projects or additions are identified that perform well under multiple scenarios and/or will further the Public Policy objectives of the State, then the CAISO should move to approve those projects in the current 2021-22 TPP.

Conclusion

CWG urges the CAISO to fulfill its obligation to plan for and approve a grid that is up to the task of meeting the Public Policy Requirements or Objectives including those articulated by President Biden in his Executive Order “Tackling the Climate Crisis at Home and Abroad,” on January 27, 2021:

“It is the policy of my Administration to organize and deploy the full capacity of its agencies to combat the climate crisis to implement a Government-wide approach that reduces climate pollution in every sector of the economy; increases resilience to the impacts of climate change; protects public health; conserves our lands, waters, and biodiversity; delivers environmental justice; and spurs well-paying union jobs and economic growth, especially through innovation, commercialization, and deployment of clean energy technologies and infrastructure (emphasis added).  Successfully meeting these challenges will require the Federal Government to pursue such a coordinated approach from planning to implementation, coupled with substantive engagement by stakeholders, including State, local, and Tribal governments.”

Policy Objectives for the State of California, as articulated in SB 100, as noted above, will require a tripling of the grid. And as mentioned above, on July 9, 2021, Governor Newsom asked the CPUC and CARB to “….evaluate pathways for the state to achieve carbon neutrality by 2035 – in advance of the 2045 target:  https://www.gov.ca.gov/2021/07/09/governor-newsom-holds-virtual-discussion-with-leading-climate-scientists-on-states-progress-toward-carbon-neutrality/ 

And again, on July 30, 2021, Governor Newsom emphasized the need to get moving in his emergency proclamation which directs the following:

 “The California Energy Commission, in consultation with the California Air Resources Board, the CAISO, and the California Public Utilities Commission, shall identify and prioritize action on recommendations in the March 2021 Senate Bill 100 Joint Agency Report, and any additional actions, that would accelerate the State's transition to carbon-free energy” (emphasis added) – Page 10

These public policy needs demand immediate CAISO action.  The CAISO should focus its efforts in the 2021-22 TPP and the 20-year transmission outlook and integrate solutions identified between them to find and approve transmission projects that begin to meet these Federal and State Public Policy needs in a responsible manner.

                                                                   Respectfully submitted on behalf of California Western Grid, LLC

                                                                       /S/ Martin Walicki

                                                          By:    Martin Walicki

                                                                               Managing Partner & CEO

       Three Rivers Energy Development, LLC

       307 3rd Street SE

       Washington DC 20003

       (240) 277-8968

                                     MWalicki@TRED-LLC.com  

August 11, 2021         

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

Questions related to the CAISO Transmission Capability Estimates

California Western Grid, LLC (CWG) understands the tables on slides 14 and 15 show estimates, among other things, of the available transmission on the bulk power system (115 KV and above) at specific locations to support and enable Full Capacity Deliverability Status (FCDS) of generators that interconnect in those locations.  However, CWG is concerned that connecting new resource to the bulk power system is only part of the problem.  We are concerned that new renewable power, unless directly connected to the bulk power system inside of a Local Capacity Area (LCA), will not be able to support the reliability needs in the LCAs (such as the LA Basin).  And we believe that while distributed energy resources will assist in meeting LA Basin energy needs and lowering GHGs, new transmission will be essential if we are going to meet California’s ambitious carbon emission goals.

CWG is also concerned that new renewable resources that are connected to the bulk power system using existing transmission capability, without new transmission facilities that bring that power into the LCA load centers, is likely to result in more curtailment of renewables and/or more exporting of those renewable resources to other states.

The CPUC IRP base portfolio sent to the CAISO for use in the 2021-22 TPP envisions significant new amounts of renewable generation by 2031.  Has the CAISO modeled or does the CAISO plan to model how much of that connecting new generation is likely to affect the amount of renewable curtailment and/or amount of renewable power exported to neighboring states?  If not, CWG respectfully request the CAISO do that modeling and share the results with Stakeholders.

After reviewing Slides 14 and 15, CWG observes that the existing transmission capability estimates for the Central California Westland / Carrizo zones stands head and shoulders above all other zones shown on slides 14 and 15.  Our understanding is some 10,830 MW of FCDS capability can connect without further reinforcements.  CWG believes new transmission is needed to bring power from the existing bulk power system at Diablo Canyon to the West side of load centers into the LA Basin.  Assuming new renewable generation connects to the existing bulk power system in the Westland / Carrizo zones, does the CAISO believe that at least 2,000 MW of that power could be delivered to the DCPP 500 KV Switchyard without further reinforcement of the existing bulk power system? 

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

Comments and Questions related to the Offshore Wind Sensitivity Study

California Western Grid, LLC (CWG) is pleased the CAISO is planning to study transmission options for delivering Offshore wind from the Humboldt area in Northern California and Morrow Bay / Diablo Canyon in Central California.

However, CWG is concerned that the CAISO appears to limit the delivery options for Central California to land solutions, assuming all power will be delivered to Diablo Canyon or Morrow Bay area Substations.  On the other hand, we noticed the Northern California Wind study will include up to five (5) delivery locations, including an option for an undersea cable to deliver power to the San Francisco Bay Area LCA.

CWG urges the CAISO similarly study an undersea transmission option for Central California that would (1) bring Offshore wind power to DCPP 500 KV switchyard where that power could meet Northern California needs and (2) connect to an HVDC multi-terminal subsea transmission line connecting the DCPP 500 KV switchyard to delivery points in the LA Metro LCA.  A multi-terminal HVDC under sea transmission line could terminate at points that allow use of the exiting transmission system that serves coastal gas plants in the Western LA Basin. Will CAISO study an undersea cable option for delivery of Central California Offshore wind to Southern California coastal load centers?

In conducting such an analysis CAISO should review the many benefits of an undersea transmission line.  CWG believes an undersea cable option would compare favorably to the land-based solutions the CAISO plans to study for Central California Offshore wind.

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

Comments and Questions related to the CAISO 20-year Transmission Outlook

CWG is trying to understand what the CAISO 20-year Transmission Outlook is trying to achieve once the study is complete.  After hearing the CAISO presentation on July 27, CWG does not understand what the final product of the 20-year outlook would look like, what questions would the study answer, or how its conclusions may influence the 21-22 TPP, if at all. Long term solutions identified in the 20-year plan will likely need to be initiated immediately if the transmission solutions are to be available when needed.

CWG in previous comments has urged the CAISO produce a road map of the transmission needed to meet SB 100 goals. Does the CAISO plan to create such a roadmap as part of the 20-year Transmission Outlook?

The Joint Agency SB 100 report of March 15, 2021, envisions the need to “triple the grid”:  https://www.greencarcongress.com/2021/03/20210316-cali.html  The time is now to start identifying key new transmission that would begin to triple the grid.  Specifically, the CAISO should identify, study, and compare the least regrets transmission projects that would perform well under a variety of resource procurement futures and under high de-carbonization and expanded EV load forecasts.

Does the CAISO plan to use a high de-carbonization load forecast in its 20-year outlook?  What load forecasts does the CAISO plan to use?

Does the CAISO plan to look at several resource procurement futures, in addition to the modest gas retirement forecast shown at slide 78? CWG describes the resource portfolio on slide 78 as modest because of the roughly 28,000 MW of existing gas fired generation, only 15,000 is retired by 2040 in that portfolio. CWG recommends the CAISO use the resource portfolio for 2035 instead of 2040 for achievement of SB 100 as shown in the March 15, 2021 SB100 Joint Agency Report.  And, the CAISO should evaluate the transmission additions needed to achieve the Zero Carbon Scenario from that same Joint Agency Report.

Will the CAISO look at accelerating the achievement of the SB100 goals.  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/ 

How will CAISO work with CARB and the CPUC to explore scenarios for accelerated achievement of SB 100 goals and incorporate those scenarios in the 20-year transmission outlook? What is the timeline for initiating this work?

Pursuant to the CAISO Tariff 24.4.6.6, the CAISO is obligated to evaluate transmission solutions needed to meet state, municipal, county, or federal policy requirements or directives. How does the CAISO reconcile the CAISO 20-year transmission plan that appears to defer immediate action on identifying transmission needed to reduce reliance on a large portion of California’s fossil generation fleet with the public policy objectives to eliminate fossil emissions including the Governor’s directive to explore acceleration of achieving of SB 100 goals?

Finally, CWG urges the CAISO to make the results of it 20-year transmission outlook “actionable”.  If new transmission projects or additions are identified that perform well under multiple scenarios and/or will further the Public Policy objectives of the State, then the CAISO should move to approve those projects in the current 2021-22 TPP.

7. Additional comments on the July 27, 2021 stakeholder call discussion:

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

On July 30, 2021, Governor Newsom signed an emergency proclamation that, in part, requested the state’s energy agencies, including the CAISO, to accelerate the construction and deployment of diverse clean energy resources and storage projects, and to modernize the grid, in the face of California’s supply shortage during the net peak period and in response to the grid challenges posed by climate change.  In view of these urgent needs, CalWEA urges the CAISO to address unnecessary barriers to new resource development that are the result of its own construct for resource deliverability rather than actual physical system constraints.  The CAISO must look to improve the efficient use of the grid while it also plans boldly for holistic transmission solutions that will be needed to achieve the state’s SB 100 goals.   

In these comments, therefore, CalWEA highlights the need to anticipate reforms to the CAISO’s deliverability assessment methodology that will be needed in conjunction with planned reforms to the CPUC’s Resource Adequacy program. These reforms will open the grid to many more wind and solar resources, including 3 GW of offshore wind (OSW) at the Central Coast potentially without relying on deliverability capacity transfer from the retiring Diablo Canyon Nuclear Power Plant (DCNPP). The CAISO should separately plan for this 3 GW of OSW – the most likely near-term scenario for offshore wind development  – in addition to a larger potential build-out of offshore wind resources.  

Finally, CalWEA urges the CAISO to plan for lower GHG targets than are reflected in the CPUC’s IRP-TPP portfolio; specifically, the CAISO should plan for transmission upgrades that are common to the two separately developed transmission plans – one developed for the Sensitivity Case 1, the 38-MMT portfolio, and the other developed for the Sensitivity Case 2, the 30-MMT portfolio with OSW.

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

The CAISO should anticipate reforms to its deliverability assessment methodology in the updated transmission capability estimates that it supplies to the CPUC for its IRP process, and use those reforms in the sensitivity studies performed in this TPP cycle.

As the CAISO is aware, the CPUC has adopted a conceptual framework as the basis for major structural reforms to its Resource Adequacy (RA) program in 2022 , with implementation in 2024.[i] The reforms are in response to the changing nature of the grid and its resources, which in the future will revolve principally around non-dispatchable, carbon-free renewable and integration resources, namely, solar and wind energy generation resources and storage resources.  The RA reforms recognize the need to ensure that energy needs are met in all hours, rather than just one hour in each month, which is at odds with the CAISO’s current deliverability methodology that is designed around the rarest and most constrained system operating conditions during the year.  Parties in the CPUC’s RA reform proceeding have recognized that parallel reform of the CAISO’s deliverability standards are needed, particularly for non-dispatchable resources and the conditions that are expected in the hours of these resources’ production.[ii] 

Under the new RA framework being contemplated, wind and solar resources are likely to act mainly as load modifiers and largely serve to charge dispatchable storage resources when these renewables are not directly serving demand.  These conditions will not be nearly as constrained as the rare system operating conditions that CAISO currently uses for its deliverability test.  The deliverability assessment methodology for dispatchable RA resources should therefore be modified, given greatly expanded hours of concern rather than a worst-case, peak-hour condition.  Under the CPUC’s new RA framework, the annual 8760 hours will be divided into seasons and time-of-day “slices” (for example, four time-of-day blocks for four seasons, or 16 “slices” in total, although the definition of slices is yet to be determined). The CPUC requested that CAISO directly participate in its implementation workshops, particularly on issues that pertain to their direct involvement and that “CAISO identify any required tariff modifications as early as practicable to allow for implementation prior to 2024.”[iii]

Deliverability reforms have important implications for the transmission capability estimates that the CAISO will be updating for the CPUC’s IRP process as well as for the sensitivity studies conducted in this TPP cycle (recognizing that the CAISO must use its current deliverability methodology as it considers approving system upgrades in the current TPP cycle).  With deliverability reform, it will be much easier in well-developed areas of the grid for wind and solar resources to obtain an appropriate level of deliverability, and thus to interconnect to the grid.  This has important implications for offshore wind resources at the Central Coast, and should help resources in all CREZs, particularly where the grid is relatively strong.

Therefore, we encourage the CAISO to immediately seek stakeholder input on the specific deliverability reforms that the CAISO should adopt for non-dispatchable renewable and storage resources to be able to count towards an LSE’s RA requirement or, alternatively, that allows non-dispatchable renewables to be netted from LSE load thus reducing the LSE’s RA requirement, depending on whether a net or gross load approach is adopted.  Such a methodology that is in line with expected RA reforms would be used to determine the resources in each CREZ that could achieve that level of deliverability and be employed in the offshore wind sensitivity studies. 

CalWEA recommends that the current deliverability assessment methodology be modified as follows:  assume an N-1 condition (i.e., assume that one major transmission segment is offline rather than two) for each slice, and assume a set of conditions for load, charging and generation dispatch that is reasonable for the conditions expected during individual non-peak slices – for example, wind and solar resource dispatch assumptions should be realistic (e.g., no solar generation assumed after dusk).  (Separately, the CPUC and CAISO will need to revisit the Planning Reserve Margin to assure that sufficient RA capacity is procured to address on-peak conditions.) 

[i] CPUC D.21-07-014.

[ii] CPUC R.19-11-009, SCE and CalCCA Revised Track 3B.2 Proposal at p. 11 (December 18, 2020).

[iii] CPUC D.21-07-014 at p. 40.

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

1. CAISO should study 3 GW of offshore wind at the Central Coast as a discrete element of the study, including under a revised deliverability assessment methodology pursuant to CPUC Resource Adequacy reforms

If the CAISO’s study of OSW is to be meaningful, realistic, and thus useful, it must include a focus on 3 GW of potential offshore wind (OSW) development off the coast at Morro Bay. Studying only an 8.3 GW scenario is unlikely to provide useful information regarding near-term OSW development potential. 

At present, the Bureau of Ocean Management (BOEM) has authorized potential OSW development within 399 square miles off Morro Bay, which would accommodate up to 3 GW of OSW development.  While the U.S. Navy has acceded to this development, it has not yet acceded to OSW development of the coast at Diablo Canyon due to its military operations there and, in fact, has historically expressed very strong reservations about the impact that such development would have on its military operations.[i]

Given the very real possibility that additional OSW development beyond 3 GW off the coast at Morro Bay will not occur during the CAISO’s current planning horizon, CAISO should separately study the transmission upgrades that would be necessary only to accommodate the OSW development that is possible within the BOEM’s Morro Bay call area.  In addition, the grid at the Central Coast is very strong, given the facilities that were built to ensure deliveries from the retiring DCNPP, whereas the grid at the North Coast (and Northern California more generally) is very weak and will require very substantial upgrades requiring at least a decade to plan and build.  These considerations warrant a specific transmission planning focus on the upgrades required to accommodate 3 GW of OSW off Morro Bay.

Further, the CAISO should consider the far more limited upgrades that would be needed if the CAISO adjusts its deliverability assessment methodology for variable renewable resources consistent with reforms to the CPUC’s Resource Adequacy Program now underway as discussed above.  With such reforms, which would recognize that 3 GW of OSW at Morro Bay could be delivered under conditions reasonably expected during many, if not all, of the seasonal/time slices, relatively very limited upgrades are likely to be needed (e.g., the addition of a 500 kV switchyard at Morro Bay Substation).  Assuming that RA and deliverability reforms are implemented, which seem appropriate and, in the case of RA reform, likely, it would largely remove the transmission interconnection hurdle for that 3 GW of OSW and thus greatly increase the likelihood that this development could occur in the 2030 timeframe.

2. CAISO should also study 3 GW of offshore wind at the Central Coast in conjunction with an offshore transmission network as part of a potentially larger offshore wind development plan

The CAISO’s draft plan includes detailed consideration of an offshore network only for 1.6 GW for the Humboldt Bay area, connecting to the Bay Area via HVDC cable, as one of three options.  CalWEA supports consideration of this option but recommends that the CAISO consider offshore solutions more broadly.  Given the increasing risk of major wildfires, as the state is once again experiencing, offshore networks will bring considerable risk-reduction benefits, and would also avoid the difficult task of obtaining siting approvals with a large number of land owners along a statewide, land-based path. Moreover, given other system network upgrades that will be necessary to achieve the 38 and 30 MMT GHG targets, at least some of which will be studied in this cycle, CAISO should study offshore networks in conjunction with longer-term OSW development.

To that end, as part of the study of 3 GW of OSW at Morro Bay, the CAISO should study system upgrades that bolster the grid between Northern and Southern California while resolving the LA Basin and Greater Bay Area local reliability constraints.  Addressing all these needs at once is likely to produce overall efficiencies that will reduce total costs.  Specifically, the CAISO should study an offshore network that connects the LA Basin to one or more Central Coast substations (Diablo Canyon and/or an expanded Morro Bay) via HVDC subsea cables. The OSW projects would connect via a shared gen-tie line to the Central Coast substation(s) where the subsea cable from the LA Basin would connect.  The plan could, and we believe should, also involve a subsea cable from the same Central Coast substation(s) to the Bay Area.    

CalWEA also encourages the CAISO to study an offshore network for its 21 GW outlook assessment. 

Experience in the U.K. underscores these points.  The U.K. is the current global leader in terms of deployed offshore wind capacity, with about 10 GW deployed over the past decade.  It’s current effort, called the Offshore Coordination Project, is underway to completely overhaul the UK's offshore wind transmission planning process.[i]  UK energy regulator, Ofgem, has noted that the continued construction of individual offshore wind farm grid connections may prevent the UK from reaching its goal of 40 GW by 2030.  As part of the Offshore Coordination Project, therefore, grid operator National Grid ESO conducted a report that found that the benefits and opportunities of an integrated offshore transmission approach, involving both shared gen-ties and what we would call “network” facilities, are maximized if advanced early in the development process.  To illustrate that, the report estimates that initiating an integrated approach in 2025 could save consumers 18 percent (approximately $8 billion USD) in combined capital and operating costs out to 2050 relative to continued pursuit of an individual project approach.

[i] National Grid ESO, “Offshore Coordination Phase 1 Final Report” (December 16, 2020).  Available at: https://www.nationalgrideso.com/document/183031/download.

[i] See, e.g., “Outreach on Additional Considerations for Offshore Wind Energy off the Central Coast of California.” (“The [Carbajal] group did not re-examine areas within the Diablo Canyon Call Area at this time due to DoD’s significant mission activities in the area.”)  Available at https://www.boem.gov/sites/default/files/documents/renewable-energy/state-activities/UPDATED-NOA-Outreach-on-Additional-Considerations_0.pdf.

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

 No comment at this time.

5. 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:

In considering any new transmission development out of state or within CAISO’s footprint to bring out-of-state (OOS) wind into CAISO load centers, the CAISO should first consider (a) the deliverability reforms discussed above, and (b) the transmission capacity that will free up due to reduced imports from OOS fossil fuel resources, many of which are scheduled to retire, as discussed in the state’s RETI 2.0 report.  That report confirms the potential of energy-only transmission service within California previously identified by the CPUC and CAISO that could enable over 23,000 MW of renewable energy capacity without added transmission.[i]   Some of this energy-only capacity may become deliverable capacity for variable renewables under deliverability reforms.  Still needed, however, is to fill out the range of transmission options with more-specific cost and availability information on firm transmission service in the WECC region as coal plants retire,[ii] and the far greater potential to transmit power on existing infrastructure using conditional firm transmission service, advanced grid technologies and operating agreements between the CAISO and other balancing authorities inside and outside California to dynamically schedule Western resources into California particularly based on conditional firm transmission service.

[i] Renewable Energy Transmission Initiative 2.0 Plenary Report (Final Report) at pp. 9-10 (February 23, 2017).  Available at:  https://efiling.energy.ca.gov/getdocument.aspx?tn=216198.

[ii] According to the RETI 2.0’s Western States Outreach Project Report (at p. 20), there were 3,000 MW of coal units planned to come offline in the West by 2019, and another 4,000 MW by 2025, creating the ability to “repurpose” a significant amount of transmission capacity previously used for coal, although it is not clear how much of that capability would be available for deliveries to California.

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

Our comments in regarding deliverability reform and offshore wind planning apply also to the CAISO’s 20-year Transmission Planning outlook.  

7. Additional comments on the July 27, 2021 stakeholder call discussion:

CalWEA urges the CAISO not to constrain itself to the CPUC’s 46 MMT base portfolio for the purpose of planning upgrades in the current TPP cycle.  The 46 MMT scenario will not likely require substantial transmission upgrades; therefore, using it as the basis for the TPP would be largely pointless. A more realistic basis for transmission planning during the current 10-year planning horizon will be necessary to achieve the state’s lower GHG targets given the lead-time required to build transmission.  The CPUC recently stated that it “is strongly inclined to adopt” a 38 MMT target later this year.[i] The CAISO itself stated in comments last year that its production cost modeling analysis shows that load-serving entities (LSEs) will need to procure resources exceeding the Commission’s 46 million metric ton (“MMT”) Reference System Plan (“RSP”) and its 38 MMT portfolio to maintain reliability as early as 2026.[ii] Thus, CAISO should act on the authority granted to it by FERC to plan for upgrades that it believes to be needed to maintain reliability and meet the states policy goals.

CalWEA believes that CAISO needs to take bold actions now to meet the state’s reliability and policy goals.  Hence, CalWEA recommends that the CAISO develop a least-regrets transmission plan, consistent with its tariff, based on the upgrades that are common to each of two separately developed transmission plans:  one developed for the Sensitivity Case 1 (38-MMT portfolio) and the other developed for the Sensitivity Case 2 (30-MMT portfolio).  The CAISO can be confident that the upgrades that are common to both portfolios will be “backbone” transmission upgrades that will accommodate multiple possible resource futures.

While the current TPP cycle must be based on the CAISO’s existing deliverability criteria, future cycles should reflect reformed criteria: 

• In parallel and in coordination with the CPUC’s RA reform stakeholder working group process, the CAISO should develop companion deliverability reforms that will be necessary. (The working group report is due to be transmitted to the CPUC by February 2022). 

• The next (2022-23) IRP-TPP portfolio (typically adopted in February) should be put on hold pending a CPUC decision on structural RA reforms so that those reforms can inform the CPUC’s IRP-TPP portfolio.  (If the CAISO plans based more realistic assumptions in the current cycle, as described above, sufficient transmission upgrades will be identified or planned to warrant such a planning hold.)  The TPP process can, however, reflect the CPUC’s decision on RA structural reforms (expected during summer 2002) and the companion CAISO deliverability reforms. 

Lastly, CalWEA notes that the CAISO should not encourage a CPUC busbar mapping process that is designed to avoid transmission upgrades. The point of transmission planning should be to identify the optimal combination of transmission, generation and storage resources, while ensuring reliability.  Such optimization cannot occur if decisions regarding any of these elements are pre-empted by subjective judgements. 

[i] D.12-06-035, issued June 30, 2021, at p. 78.

[ii] CAISO October 23, 2020, Comments in CPUC R. 20-05-003 at p. 2-3.

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

August 5, 2021

California Independent System Operator  

CAISO

Request for Comments on the 2021/2022 TTP

P.O. Box 639014
Folsom, CA 95630

Attn.:   Isabella Nicosia

Dear Ms. Nicosia,

            This letter is in response to the California Independent System Operators’ (CAISO) request for Comments on the 2021-2022 Transmission Planning Process (TTP).  As you are aware, the California Public Utilities Commission (CPUC) made a ruling on January 7, 2021, with respect to offshore wind resources in northern California.  The TTP, as described in their Attachment B, (Descriptions of the Proposed Portfolios for the 2021-2022 TTP, as developed by the CPUC, Energy Division, dated October 23, 2020) describes the need for future development of a 6.6 GW Transmission Corridor out of the Del Norte County Region.

Del Norte County is the most northwestern county in California. It borders both Oregon on the north and the Pacific Ocean on the west. According to a study recently conducted by the National Renewable Energy Laboratory (NREL) Del Norte County has one of the premier sites to produce offshore wind power on the pacific coast of California. As you are aware, both the federal and state governments have set a goal to bring offshore wind energy online by 2030 to meet the future energy needs of the people of California. 

The Tri Agency Economic Redevelopment Agency (which is comprised of two city councilmen, two county supervisors and two harbor commissioners) recently met and voted unanimously to pursue the development of offshore wind power.  In addition, the Schantz Energy center recently completed a study for the Crescent City Harbor Commission.  The study shows that offshore wind power is a viable concept and that it can provide economic growth in this county.  Our understanding is that when offshore wind is developed off the Del Norte Coast new electrical transmission corridors will be needed to export the power out of Northern California.

As a potential exporter of offshore wind power, the Tri-Agency would encourage you to study the transmission of wind power out of Del Norte County.  With the potential of 6.6 GW of new electrical energy production we would like to submit our comments on the 2021-2022 TTP.

The Tri-Agency has reviewed one existing and three potential transmission corridors out of Del Norte County.  We would like to recommend that CAISO study these four potential corridors for future development.

Attached are four maps showing the potential location of each of the transmission corridors. The Tri agency believes that any one of the four suggested corridors would provide an economical and cost-effective way of bringing offshore wind power to California’s electrical grid.  

The following is a discussion of each of the potential corridors:

1)         As shown on the Exhibit A map, the existing Pacific Power and Light (PP&L) right of way going east, currently intersect the major north south Interconnection Transmission Lines east of Yreka, California.  There is an approximate 15 mile stretch of right of way that goes up into the State of Oregon and then back down into California.  The entire corridor is about 95 miles in length to reach the existing north-south high voltage transmission corridor in California.  We understand that this existing transmission corridor would require major upgrades and the expansion of the right of way.  But we believe this would be one of the most economical ways to export the power out of Del Norte County and that it would be far cheaper than a 400-mile undersea cable to the bay area.

2)         If the State of California for political reasons requires that the transmission corridor out of Del Norte County must be within the borders of our state then Exhibit B would provide an answer to the problem.  This alternative would require the creation of a new 15-mile segment of right of way from Collier Tunnel just west of Highway 199 to a point just north of Happy Camp, California.  Again, this corridor would be much more economical than and undersea cable to the bay area.  We understand that the use of this existing transmission corridor would require major upgrades and expansions to the right of way as well as the purchase of the new 15-miles of right of way.  In addition, this proposed 15-mile corridor would cross primarily over federal forest land which would reduce the cost of the project to the taxpayers.

3)         The attached map entitled “Exhibit C” would provide a third alternative. This new transmission corridor would extend east from the south end of the Crescent City Harbor and go east to join up with the existing PP&L right of way above Happy Camp, California. This corridor would then extend eastward using the existing PP&L right of way to the existing north-south high voltage transmission corridor by Yreka, California.  It should be noted that most of this proposed route would cross over federally owned forest land.  Therefore, the cost associated with the purchase of new rights of way would not cost the taxpayers as much.

4)         Exhibit D is centered around the idea of a separate and distinct right of way that would not include the use of PP& L rights of way.  This would need to be a new and separate right of way that is not associated with either PP&L or PG&E.  This right of way would allow a new utility or company that owns the right of way to be associated with the CAISO marketing process.  This would allow the power to be sold to the public at CAISO agreed upon rates.  As shown in Exhibit D this right of way would go from the south end of the Crescent City Harbor and extend due east to the existing north-south high voltage transmission corridor by Yreka, California.  In addition, this right of way would also go over primarily federal forest land which would reduce the cost of developing the right of way and be one of the most cost-effective ways to export wind power to the citizens of California.

We would like you to consider studying all four of the potential corridors for future transmission of offshore wind from the Del Norte County Coast.  All four corridors could help provide a pathway for future power generation to the citizens of California in an economical and cost-effective way.

Therefore, we would appreciate your serious consideration to study these four possible corridors. 

Sincerely,

Wes White,                                                                 Brian L. Stone,

Secretary, Crescent City Harbor Board, and                    President, Crescent City Harbor Board, and

Tri-Agency Economic Development Agency                 Tri-Agency Economic Development Agency

Member                                                                                              Member

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

August 10, 2021

California Independent System Operator  

CAISO

Request for Comments on the 2021/2022 TTP

P.O. Box 639014
Folsom, CA 95630

Attn.:   Isabella Nicosia

Dear Ms. Nicosia,

            We would like to submit an addendum to the 2021-2022 TTP comments previously submitted on August 6,2021 (August 6, Letter) in response to the California Independent System Operators’ (CAISO) request for Comments on the 2021-2022 Transmission Planning Process (TTP). 

As shown in our submission, we made some suggestions as to how to transport the potential 6.6 gigawatts of wind power from the Del Norte Coast to the north/south interconnection lines. We all know that there are major hurdles to be overcome when selecting transmission corridors. We wish to address two important areas that need to be discussed when selecting a possible corridor. 

1)  Cost Effectiveness

When choosing a route for the ratepayers there needs to be serious consideration as to the cost of a suggested transmission corridor.  Obviously, the cost of upgrading an existing corridor and/or the creation of a new corridor will play heavily in the decision-making process.  As we all know the taxpayer will ultimately pay for the cost of either. One thing to keep in mind is the cost per mile of any project. 

When talking to industry consultants and reviewing existing technical studies, we came up with a ballpark estimate of the cost of construction.  As a rule of thumb, taking an overland route will be far less expensive than laying an undersea cable. 

Example:          A) The cost of developing a new corridor will range from 2.5 million dollars a mile while the cost to upgrade an existing transmission corridor can be as low as 1.5 million dollars per mile, and

B)  It can cost as much as six (6) million dollars a mile for an undersea cable. 

As with any route there are also the costs associated with acquiring the right of way, adding additional width to the existing right of way and all the other associated costs needed for the project. 

We believe that any of the costs associated with developing any of the right of ways described in our August 6, Letter would be far more cost effective than either upgrading the overland right of way out of

Eureka, California to Cottonwood California (Eureka Route) or the undersea cable (Undersea Route) running to the Bay Area that has been proposed.

Below are the mileages needed to develop the corridors described in our August 6, Letter.  The mileages from Crescent City Harbor to the north/south transmission lines east of Yreka California are as follows:

1)         Exhibit A is the existing Pacific Power and Light (PP&L) corridor that goes from the north end of the Crescent City Harbor up into Oregon and back down into California. The length of this right of way is about 110 miles to the north/south transmission lines (See Exhibit A submitted in the August 6, Letter.)

2)         Exhibit B uses the existing PP&L corridor to a point just west of the Collier Tunnel near State Highway 199 with the creation of a new right of way running east to Happy Camp, California and then back onto the existing PP&L right of way and then east to the north/south transmission lines.  The length of this right of way is approximately 105 miles.  (See Exhibit B submitted in the August 6, Letter.)

3)         Exhibit C uses the existing PP&L corridor extending out of the south end of the Crescent City Harbor and goes through the existing State and National Redwood Park lands to a point five (5) miles east of State Highway 101. A new right of way would then be created running east to Happy Camp, California, then back onto the existing PP&L right of way and then east to the north/south transmission lines.  The length of this right of way is approximately 100 miles.  (See Exhibit C submitted in the August 6, Letter.)

4)         Exhibit D would basically create a new transmission corridor.  This route would use the existing PP&L corridor extending out of the south end of the Crescent City Harbor and then extend east through the existing State and National Redwood Park lands to a point 5 miles east of State Highway 101. Then a new right of way would then be created running east to the north/south transmission lines east of Yreka, California.  The length of this right of way is approximately 95 miles (See Exhibit D submitted in the August 6, Letter.)

5)         The Eureka Route is about 140 miles in length to the north/south transmission lines by Cottonwood, California.  As you can see any of the above proposed right of ways are shorter.  We understand that the main north/south transmission lines would need to be upgraded, but when you consider that this right of way would have to be upgraded anyway due to the expected out of state power transmission from Idaho or Montana into California there would not be an increase cost for the mileage between Yreka, California and Cottonwood, California, when comparing the overall cost of a project.

6)         The Undersea Cable route that has been proposed would be approximately 400 miles from the south end of the Crescent City Harbor to a connection in the Bay Area. The Undersea Cable route will travel through sensitive fishing grounds, seismically sensitive areas, and cross over numerous undersea canyons. With respect to crossing under sea canyons, engineers are not certain as to how to cross them creating further problems.

By holding an industry estimate of cost per mile constant, you can see a comparison for each of the suggested routes:

            Exhibit A         110 miles x 2.5 million per mile =           $275 Million Dollars

            Exhibit B          105 miles x 2.5 million per mile =           $255 Million Dollars

            Exhibit C          100 miles x 2.5 million per mile =           $250 Million Dollars

            Exhibit D           95 miles x 2.5 million per mile =           $237.5 Million Dollars

            Eureka Route   140 miles x 2.5 million per mile =           $355 Million Dollars

            Undersea          400 miles x 5.5 million per mile =         $ 2.2 Billion Dollars

Obviously, the cost for each route will need to be studied to arrive at the actual cost for each of the above suggested routes so they could be accurately studied.  Bottom line is that any one of the four routes that we proposed in our August 6, Letter would be far more cost effective for the taxpayers.

2)         Vaulting or Underground Cables

While our previous letter already laid out the above suggestions, the main point of this letter is to suggest that serious consideration be given to vaulting or placing new transmission cables underground. A cost analysis is suggested as to whether this should be done only in sensitive areas (such as through parks, environmentally sensitive areas or areas prone to forest fires) or the whole of a project. Doing so would further reduce the cost per mile of the project and greatly reduce the potential fire hazard in the region or area that one is traversing.  All four of the routes suggested, in our August 6, Letter will travel through existing forest land. Vaulting or putting the transmission cables underground would eliminate the potential for forest fires in fire prone areas thereby reducing the cost to the state of California and local governments by billions of dollars per year in fire protection costs.

In a recent article, PG&E stated that it would cost approximately 1.5 to 2 million dollars per mile to vault or bury their existing transmission lines to prevent future forest fires. 

Vaulting or burying any of the new or existing right of ways, as suggested in our Aug. 6 letter, would require less land to develop any new or improved transmission corridor. This means that the additional area needed for fire breaks would be reduced and likewise reduce the required cost of purchasing the additional land for the right of way.  In place of needing to acquire a 400 foot right of way for a proposed route, the developer of the new route would need to acquire only half of the needed width or a 200 foot right of way. This would vary based upon the conditions and requirements of the specific right of way.

Could you please consider studying the four potential corridors for future transmission of offshore wind from the Del Norte County coast.  Any of the potential corridors could help provide a pathway for future power generation to the citizens of California in an economical and cost-effective way.

Thank you for your serious consideration of these possible corridors as well as the above suggested methodologies. 

Sincerely,

George Wesley White                                                  Brian L. Stone

Wes White,                                                                   Brian L. Stone,

Secretary, Crescent City Harbor Board, and                    President, Crescent City Harbor Board, and

Tri-Agency Economic Development Agency                 Tri-Agency Economic Development Agency

Member                                                                       Member

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

7. Additional comments on the July 27, 2021 stakeholder call discussion:

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

On behalf of Defenders of Wildlife (Defenders), we respectfully submit these comments in response to the July 27, 20 Year Transmission Outlook Update (Workshop).  Defenders is committed to achieving a low carbon energy future, a future that centers on the health of California communities, our economy, and the environment.  We appreciate the thoughtful discussion during the Workshop. We are pleased to see the California Independent System Operator (CAISO) undertake a 20 Year Transmission Outlook as part of their work to meet the demands of planning for SB 100.  Transmission must be integrated into planning for SB 100 to match resource build with the grid build.  Consideration of land use and environmental opportunity and constraints is foundational to enable effective transmission planning that reduces risks of unintended impact, conflict, and disputes and ensures timely build-out.

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

The benefits of using landscape-level approaches for transmission planning include early identification and resolution of large issues or barriers to development, coordinated agency permitting processes, increased transparency in decision making, increased collaboration, avoidance of impacts, and more rapid development of environmentally responsible renewable energy projects. CAISO has an opportunity to plan for and coordinate this effort and it must happen now. Accordingly, we offer the following observations and recommendations:

Recommendations

1. Collaborative geospatial analysis for transmission planning to accelerate permitting timelines and lower overall project costs.

Recommendation 3 (pg. 134) in the 2021 Joint Agency Report[1] rightly identifies that understanding how land use impacts vary across scenarios and assessing the relative environmental impacts in different areas is foundational to identifying strategies to avoid, minimize or mitigate environmental impacts and maximize environmental impact co-benefits.  Project failure is a significant concern in meeting SB 100 goals, and one only needs to look at projects that have failed due to siting conflicts with natural resources or litigation, or both.  Siting a transmission project that conflicts with high-value natural resources such as endangered species and their habitats will likely result in increased permitting uncertainty, increased mitigation costs, project development delays, litigation, and/or project failure.  Avoiding and minimizing conflicts with high-value natural, agricultural, and cultural resources is the simplest and most cost-effective way to reduce project failure.  The CAISO should collaborate with Joint Agency staff to integrate the California Energy Commission’s geospatial planning tools into transmission planning as part of the “Starting Point” resource mapping for their 20 Year Transmission Outlook. 

2. Establish a Transmission Technical Working Group to ensure transmission planning is consistent with goals set forth in SB 100.

The lack of transmission capacity to support responsibly sited renewable energy development and deployment of distributed generation needs a dedicated approach by the Joint Agencies and CAISO to prioritize transmission development to serve those areas.  Effective implementation of Recommendations 3, 4, and 12 of the 2021 Joint Agency Report[2]  can only occur if transmission planning is fully integrated.  California cannot balance clean electric grid infrastructure needs with efforts to restore, conserve, and strengthen natural and working lands unless transmission is planned to support and prioritize energy development in locations that avoid or minimize impacts to natural and working lands.

We strongly urge the CAISO and Joint Agencies to establish a transmission technical working group promptly.  This is similar to the recommendation from the Preliminary Root Cause Report[3] for the mid-August heat storm outages that states:

“Building on the Senate Bill (SB) 100 (De Leon, 2018) scenarios, consider where diverse resources can be built and the transmission and land use considerations that must be taken into account.  Establish a transmission technical working group (CAISO, Bas, CEC, CPUC) to evaluate the transmission options and constraints from the SB 100 scenarios.

[1] https://efiling.energy.ca.gov/EFiling/GetFile.aspx?tn=237167&DocumentContentId=70349

[2] https://efiling.energy.ca.gov/EFiling/GetFile.aspx?tn=237167&DocumentContentId=70349

[3] http://www.caiso.com/Documents/Preliminary-Root-Cause-Analysis-Rotating-Outages-August-2020.pdf at pg. 68

7. Additional comments on the July 27, 2021 stakeholder call discussion:

Thank you for the opportunity to provide comments on the Workshop and the next steps to plan transmission to serve the SB 100 resource build.  We appreciate the CAISO’s time at the workshops and their hard work on moving forward with the 20 Year Outlook.  Please contact Kate Kelly at kate@kgconsulting.net with any questions. 

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

GridLiance West (GLW) appreciates the CAISO revising its transmission capabilities for the IRP in addition to the CAISO’s ongoing efforts on the TPP. We appreciate the opportunity to submit these comments.

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

The CAISO’s transmission capabilities are very important inputs to the CPUC’s IRP process.  Improperly constrained limits result in a suboptimal RESOLVE siting solution and a more expensive capital buildout portfolio.   GridLiance appreciates the CAISO’s willingness to expand the limits where possible and further detail characteristics of possibly higher limits in its revised paper.

GridLiance offers a question and comment specific to the GridLiance-relevant constraints.  GridLiance also offers a more general comment related to the Energy-Only limits.

GridLiance-Relevant Constraint Comments

The CAISO included the GLW-VEA Area Constraint as one of the SCE/GLW East of Pisgah (EOP) Study Area Constraints shown in Table 3-1 of the white paper. In table 3-1, the CAISO indicates that the upgrades to relieve this constraint will take 60 months to construct.  However, as GridLiance has previously reported to the CAISO, these upgrades will only take 36 months, significantly less time than captured in the table.  Table 3-1 should be corrected to show the accurate construction time, which will benefit developers and load-serving entities in making commercial decisions to meet near-term reliability and climate goals.

Secondly, the SCE/GLW East of Pisgah (EOP) Study Area Constraints include this aforementioned GLW-VEA Area Constraint as well as two other constraints.  The Mohave/Eldorado 500kV constraint is also indicated as affecting the Southern_Nevada zone.  The Eldorado 500/230kV Transformer #5 Constraint is indicated to affect the Southern_Nevada zone and Eldorado/Mountain Pass (230kV).   GridLiance seeks clarification as to which of these constraints limits renewable buildout in the GridLiance region. That is, does only the GLW-VEA Area Constraint limit the GridLiance region’s RESOLVE siting, or would RESOLVE buildout in the GridLiance area also be constrained by either or both the Mohave/Eldorado 500kV and the Eldorado 500/230kV Transformer #5 Constraint limits?   GridLiance requests that the CAISO explain further whether these Southern_Nevada constraints are nested or overlapping. If more than one is binding on GridLiance-area buildout and the constraints are not “nested” or overlapping,  GridLiance asks that the CAISO further explain the relationship between the respective Southern_Nevada constraints and the GLW RESOLVE siting that would be allowed, should the constraints be implemented in RESOLVE.

GridLiance Comments on Energy-Only Limits

The CAISO proposes to derive the revised Energy-Only limits based on the off-peak deliverability levels found through the CAISO’s Generation Interconnection process (GIDAP).  The CAISO bases the application of these off-peak deliverability GIDAP values for use as Energy Only limits based on the presumption that any siting in excess of these limits would result in excessive curtailment.  GridLiance finds this proposed method unduly restrictive. The off-peak deliverability limit is the limit at which the resource is no longer fully deliverable.  For example, if the off-peak deliverability limit was 100 MWs, that would mean that  a 101 MW resource would be curtailed by 1 MW.  However, this curtailment would not occur during all hours. Thus, a RESOVLE siting solution that places additional capacity in those locations may still be a lowest cost, best fit, solution for RESOLVE, i.e., levelized cost and value as a charging resource or otherwise is infra-marginal even assuming incremental curtailment.  Further, in many cases the CAISO’s transmission capability limits shown in its white paper Table 3-1 would not be determined at all. In these instances - indicated by an asterisk in Table 3-1 column “Incremental due to AOPNU” roughly 60% of the limits are of this type. In these instances, the CAISO has proposed that Energy-Only siting in RESOLVE be capped at the level of buildout that did not cause any binding off-peak constraint. For example, if the constraint was listed as “100*” MWs, it is possible that 200 MWs of resources could be sited behind this constraint with no curtailment.  The CAISO has not explained why, rather assuming that siting above an observed level (e.g., 100 MWs in this example) would result in “excessive curtailment” when it hasn’t seen any curtailment at studied level of MWs itself (100 MWs).

In the 2020 – 2021 TPP, the CPUC asked the CAISO to examine Energy-Only limits by testing to measure the curtailment at higher presumed levels of buildout.  Only in this manner can the CAISO determine if curtailment would be excessive or not.  Energy-Only levels should not be based on being fully deliverable under off-peak tests.  To address this issue for this current cycle, GridLiance requests that the CAISO or CPUC compare the Energy-Only limits from the white paper Table 3-1 to the findings of the CAISO’s 2020-2021 policy sensitivity case 2 study and the prior Energy Only transmission limits.  Where the true Energy Only limits found previously are higher, those limits should be used. If the revised white paper’s transmission capability limits are shown to be higher – for example based on transmission upgrades – those limits could be employed.  Ultimately, the CPUC and CAISO need to find a means to regularly reconsider the Energy Only limits as was done in the 2020 – 2021 Policy Sensitivity 2 study – especially when upgrades are being considered or have been made for certain areas. 

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

GridLiance appreciates the CAISO’s consideration of the projects identified by GridLiance (slide 77).  GridLiance believes that these projects offer significant benefits for the cost, and they can also be implemented very quickly. One of the GridLiance projects was submitted to the CAISO in the form of an Economic study request in the 2021 – 2022 TPP cycle, and it would enable interconnection of 500 MWs of resources, including potentially high capacity factor geothermal energy, from Nevada directly to the CAISO through the GridLiance footprint. The second conceptual submission would be to install the needed 230kV upgrades in a manner that they would be 500kV enabled.  We expect this low-investment upgrade solution will produce significant “bang-for-the-buck” benefits and drastically reduce timelines to site a subsequent wave of Southern Nevada renewables including reducing congestion.  GridLiance appreciates the CAISO’s consideration of these projects within those studied in the 20-year study process.

GridLiance encourages the CAISO to determine benefit-to-cost findings for the projects studied to inform the SB100 buildout decisions.

GridLiance also requests that stakeholders be consulted as part of the busbar mapping process for the 20-year study. GridLiance has found that certain RESOLVE settings result in suboptimal siting, and this warrants reconsideration of the mapping process. We expect the approaches developed by the CPUC from past IRP cycles will be considered by the CPUC, CEC and CAISO as part of the 20-year study. Nevertheless, GridLiance strongly encourages these agencies to take stakeholder input as part of the busbar mapping process.

7. Additional comments on the July 27, 2021 stakeholder call discussion:

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

LS Power applauds CAISO’s effort to assess transmission alternatives to deliver out-of-state (OOS) wind in the Base Portfolio. LS Power appreciates the opportunity to submit these comments, which are summarized for the OOS study as follows:

1. The Economic Study should capture all benefits in addition to production cost modelling benefits, as detailed below and outlined in the CAISO TEAM methodology, and as directed by the California Public Utilities Commission (CPUC). Modelling assumptions used in this study should  a) not include a wheeling hurdle rate across NV Energy for the SWIP-North path from Midpoint to Harry Allen b) incorporate limits for the COI path consistent with CAISO’s portion of COI (3200 MW). CAISO should also do a stress test to mimic recent fire situations and extreme weather conditions by incorporating more realistic de-rates/outages.
2. The 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.[1] This OOS wind in the Base Portfolio creates a regional need, and CAISO’s Tariff 24.13 states that CAISO may consider potential interregional solutions to meet regional needs (including policy needs). In order to correctly capture deliverability for the policy study, OOS wind resources should be mapped accurately at their respective resource location 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. CAISO should not limit the current deliverability study framework to existing maximum import capability (MIC) numbers at the interties. The framework should be adjusted 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. CAISO Tariff section 24.13 provides the basis for the transmission plan to accommodate this analysis and any new transmission projects required as a Category 1 solution should be identified as part of this study.
3. The Reliability Study should also capture resiliency benefits and quantify diversity benefits (supply diversity, load diversity, transmission path diversity).
4. OOS transmission projects should be compared based on common metrics, including those proposed below.
5. Since this is a new study, stakeholders should be provided additional opportunities for inputs as CAISO finalizes its study methodology and kicks off the study. Study models, including CAISO’s production cost and policy-driven deliverability power flow models should be released for stakeholder review before study results are released.

[1] CPUC’s final decision D.21-02-008 on Transferring Electric Resource Portfolios to CAISO for 2021-2022 Transmission Planning Process. February 17, 2021. 

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

LS Power does not have any comments at this time.

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

LS Power suggests that CAISO consider the transmission planning approach recently adopted by the New Jersey Board of Public Utilities (BPU) related to transmission for offshore wind development.[1] New Jersey has an offshore wind goal of 7500 MW and is working to coordinate shared on- and offshore transmission facilities for projects, rather than individual generation interconnection lines and onshore upgrades for each project. This approach of coordinating transmission from multiple projects is expected to result in considerable ratepayer savings, minimize environmental impact, better grid stability, and significantly reduce permitting risk. A key component of New Jersey’s process is conducting a competitive bid process to solicit innovative, low cost solutions for ratepayers.  LS Power understands this approach may not be possible for this year’s 2021-22 TPP, but suggests it be considered in the future.

[1] New Jersey BPU Order 11-18-20-8D, Docket No. QO20100630, https://publicaccess.bpu.state.nj.us/CaseSummary.aspx?case_id=2109468

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

LS Power does not have any comments at this time.

5. 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[1] 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.

1. 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.

2. 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.[2]  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.

3. 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:

1. 1. project readiness and expected in-service date, and the associated economic benefits that come with advanced development projects that can move forward quickly,
   2. transmission project cost including interconnection facility costs and network upgrades,
   3. 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),
   4. economic benefits from PCM and additional benefits from the TEAM methodology,
   5. greenhouse gas (GHG) emission reduction benefits, including access to OOS wind and other renewable energy and storage projects,
   6. economic, resiliency and reliability benefits of the transmission project for CAISO ratepayers, and
   7. 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.

4. 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[3] 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.”

1. 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.[4]
  • 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.[5]
  • 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.

2. 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.

3. 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.

4. 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.

5. Proper Modeling of SWIP-North – Consistent with LS Power’s previous comments on SWIP-North modeling[7], the following must be addressed to ensure correct results when evaluating the SWIP-North alternative:
   1. 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.
   2. 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.
   3. 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.

6. 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 24.4.6.6 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 24.4.6.6 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.

7. Application of Criteria in Tariff Section 24.4.6.6 –

As the sponsor of the SWIP-North alternative, LS Power offers our evaluation of SWIP-North using the criteria in the CAISO Tariff Section 24.4.6.6 regarding evaluation and selection of policy-driven projects.

1. 1. 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.[8] 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.

1. 2. 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.  

1. 3. 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.

1. 4. 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.

1. 5. 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.   

1. 6. 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.

1. 7.  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.

1. 8.  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.   

1. 1. 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.

1. 10. 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.

[1] 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.

[2] SunZia presentation at the July 22, 2021 Joint Agency Workshop on Next Steps to Plan for SB 100 Resource Build: Transmission.

[3] “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

[4] Testimony of Jeff Billinton on behalf of CAISO in R.20-11-003, January 11, 2021

[5] 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

[6] OATI OASIS for Idaho Power Company, Generation Interconnection Queue, Accessed August 10, 2021 http://www.oasis.oati.com/ipco/

[7] LS Power Stakeholder Comments, 2021-2022 TPP, March 11, 2021, http://www.caiso.com/InitiativeDocuments/LSPowerComments-2021-2022TransmissionPlanningProcess-Feb252021StakeholderCall.pdf

[8] OATI OASIS for Idaho Power Company, Generation Interconnection Queue, Accessed 8/9/2021 http://www.oasis.oati.com/ipco/

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

LS Power supports CAISO’s 20-Year Transmission Outlook initiative. Given the significant amount of clean energy the state needs by 2045, it is critical to start planning for longer-lead time transmission connections today. LS Power looks forward to participating in and reviewing results for this important initiative. Additionally, for any offshore wind assessment, LS Power suggests an approach similar to New Jersey BPU’s coordinated transmission planning for offshore wind, as described above in #3.

7. Additional comments on the July 27, 2021 stakeholder call discussion:

LS Power has no additional comments at this time.

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

Improve the coordination of the Generation Interconnection Process (GIP) studies and Transmission Planning Process (TPP) studies.

The CAISO uses the resource portfolios developed by the CPUC in its TPP studies to identify the policy-driven upgrades to support future resource portfolios. The process allows the mapping of generic storage resources for system requirements and can be optimized in a manner by either increasing or decreasing the amount of storage mapped behind the constraint that mitigates the need for the policy upgrades. While this supports a least cost approach to infrastructure planning it does not ensure that the resources will seek to interconnect through the GIP at that MW level studied or effectuate procurement of resources in a manner that obviates the need for policy upgrades. PG&E recognizes the CAISO’s attempts to improve the GIP over the last few years, but increased coordination of the GIP and TPP studies are needed to ensure that resources expected to obviate the need for policy upgrades in the TPP studies are not triggering those same upgrades due to the interconnection assumptions in GIP.

Account for resources being constructed under an executed interconnection agreement that are not included in the transmission capability estimates.

The transmission capability estimates provide the estimated FCDS capability based on On-peak and Off-peak study resource outputs. The estimates represent the over and above amounts of the baseline future resources transmitted by the CPUC in its resource portfolios but this may overstate the amount available if there are resources that do not currently have a contract with a CPUC jurisdiction LSE but have been allocated the existing capacity through the GIP. The CAISO should consider deducting this amount from the existing estimates to account for resources that have executed interconnection agreements and are expected to take up the existing estimated FCDS capability. Additionally, although many generating resources could be at different stages in the GIP it would also be useful to identify the amount that presently has a priority allocation in a previous Cluster. Accounting for resources with an executed interconnection agreement and resources with a priority allocation will provide a transparent view of how much additional capability is available within the existing system.

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

7. Additional comments on the July 27, 2021 stakeholder call discussion:

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

SDG&E would like to further explore a process to map Transmission Capability Estimates developed by CAISO to their respective RESOLVE renewable zone. Understanding the nuances behind this process may allow stakeholders to potentially develop and propose more economic, efficient, and environmentally sensitive solutions to support the SB100 future. Additionally, these steps would be helpful in allowing for transmission constrained zones to be fairly considered for upgrade in cost analyses.

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

• When considering the transmission projects mentioned in the “2021-2022 Transmission Planning Process Updates” section, SDG&E urges CAISO to consider the risks behind a major natural event occurring along the transfer paths mentioned in the presentation.
• Mapping resources more closely to load regions has significant advantages.  If, for example, most of the resources are located in the northern part of the CAISO system, the lack of resiliency and diversity of location can pose a serious threat to the reliability of the entire CAISO system.  As an example, if a major natural event (such as a wildfire or earthquake) occurs in proximity to where resources are located, the result may be an outage of such resources or insufficient capacity back to load centers. This point is emphasized considering eight of the largest Californian wildfires have occurred in the last four years (https://www.fire.ca.gov/media/4jandlhh/top20_acres.pdf). One way the CAISO could mitigate this, in part, could be to factor-in commercial interest throughout the system.  This can be done by using a resource allocation ratio based on the CAISO’s Generation Interconnection (GI) Queue to assign resources to each Transmission Access Charges (TAC) area geographically. The result would likely be greater locational diversity and resiliency.
  • Another possible solution to help plan for this type of risk is to consider transmission or generation resources that cross a particular wildfire (or other natural disaster) area as a Credible Multiple Contingency. 

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

The 20-year outlook represents a great opportunity to analyze and identify potential challenges associated with SB100. SDG&E believes one of the keys lies with not only transporting resources to California, but also efficiently distributing resources to load centers. These transmission upgrades should be also considered and planned in the 20-Year Outlook to provide for plenty of lead-time for development, consider that some transmission projects can take about 10-years to permit and build.

Further, SDG&E appreciates the Load Serving Capability analysis that CAISO published in the 2022 Local Capacity Technical Study Report. This analysis raises important points behind potential battery charging restrictions associated with each LCR area. An important area of study for the 20-Year Transmission Outlook may be to analyze whether the batteries prescribed by resource portfolios in the 20-Year Outlook can be accommodated according to the Load Serving Capability analysis in the 2022 LCT report.

7. Additional comments on the July 27, 2021 stakeholder call discussion:

•  
• Complex RAS that requires a nomogram or to trigger other RAS or opening a 500kV line can degrade system reliability hence not meeting system performance criteria if the RAS fails or inadvertently operates. 
• SDG&E recommends avoiding the removal of critical facilities (e.g., 500 kV lines) during a RAS operation. Removal of critical facilities by a RAS, during PSPS events which also coincide with peak loads, can lead to greater reliability issues.
• The amount of generation tripped by a single RAS should be limited. As we diversify our resource portfolio, resource resiliency will become key to system reliability. However, replacing large gen drop RAS with several smaller gen drop RAS is also not conducive to a reliable system because additional RAS will make the system overly complicated for grid operators. This may result in reliability issues if operators are unable to keep track of the resulting system that is unnecessarily complex.

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

Southern California Edison (SCE) appreciates the CAISO leading the July 27 stakeholder call and offers the following comments on the CAISO’s 2021-2022 Transmission Planning Process (TPP) efforts.  During the stakeholder call, the CAISO discussed how its analysis in the 2021-2022 TPP will be predominantly focused at the 500 and 230 kV system-level (as opposed to the local level).  The CAISO also mentioned it will utilize prior TPP and GIDAP results to help inform other assessments and forecasts such as the TPP Local Capacity Requirements (LCR) gas generation retirement studies and transmission capability estimates, respectively.  SCE requests the CAISO further explain this two-prong approach which will be used to develop the comprehensive 2021-2022 TPP.

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

SCE requests clarifications in the following areas of the 20-Year Transmission Outlook: 

No discussion of demand forecast for the 20-Year Transmission Outlook  

• What is the 2040 demand forecast and underlying assumptions, including changes in load demand due to building and transportation electrification (BE and TE)?? How does this 2040 demand forecast compare to the IEPR forecast assumed in the 2030 TPP Policy Driven Assessment? 

• For the 20-Year Transmission Outlook, what will be the level of disaggregation for demand forecasts – CAISO level?? PTO level?? Other??  

  • SCE agrees that it is not feasible to perform a 20-Year Transmission Outlook assessment that identifies grid needs at the individual circuit level given lack of both granularity and forecast certainty.? However, specifying resources and demand in terms of both location and capacity to some extent is necessary to yield meaningful results and provide strategic direction.? SCE encourages CAISO to clearly document and provide these assumptions so stakeholders, including SCE, can be in a better position to develop additional data and provide additional coordination, if required.  

  • In terms of both the cumulative 2040 resource portfolio and demand forecast, SCE recommends presenting a comparison with the 2030 Baseline Policy Driven Assessment case along with high-level underlying assumptions.? At minimum, it is recommended the portfolio and forecast presented at the CAISO-system level and then disaggregated to the extent assumed as described above. 

? 

The overall study methodology is unclear  

• While SCE realizes that the 20 Year Transmission Outlook is not as rigorous as the TPP assessment, it is still unclear how prior assessments and insights will be compiled to inform a 20-Year Transmission Outlook.? SCE encourages a simplified study plan, methodology, or framework to better communicate the approach and help solicit feedback from stakeholders. 

• Will grid stability impacts and needs be evaluated?

7. Additional comments on the July 27, 2021 stakeholder call discussion:

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

Southwestern Power Group (SWPG) and Pattern Energy submit these joint comments on the July 27 stakeholder call, focusing on the topics that are most relevant to the import of out-of-state (OOS) wind and specifically wind from New Mexico into CAISO. SWPG and Pattern are development partners of the SunZia Transmission Project which will deliver approximately 2 GW of New Mexico wind to CAISO in 2025.

Unfortunately our team was not able to participate in the July 27 stakeholder call for the most relevant areas and the call was not recorded. Therefore our comments are based on review of the information and subsequent communication with CAISO staff and other stakeholders.

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

A. Affected Zone Nesting

SWPG/Pattern appreciate the information the CAISO provided on transmission capability information on slides 14-15 and also in Table 3-1 of the July 19, 2021 Transmission Capabilities white paper.  However it is unclear how the CAISO intends that the detailed information in the tables should be implemented by the CPUC in its subsequent IRP portfolios.  For example, in prior IRP cycles NM wind is treated as being imported to the Riverside Palm Springs RESOLVE area, which itself was part of the larger Southern California Desert – Southern NV (SCAD_SNV) area.  In these prior cycles both the Riverside Palm Springs and SCAD_SNV areas had constraints – constraints to which the NM Wind imports, in conjunction with other renewable resources in or imported into that area – were bound. 

The slide 14-15 tables list transmission elements which are relevant to various “Affected Zones” which are similar to the previous RESOLVE transmission delivery zones but without the “parent” zones such as SCAD_NV. Also some constraints apply to multiple Affected Zones and some to just one. Therefore we pose the following questions to the CAISO:

1. What are the net resulting limitations to each individual “Affected Zone”? e.g. Riverside Springs, Arizona, Imperial
2. What are the net resulting limitations to the “parent” Affected Zones, to the degree they still exist? e.g. SCAD_NV

It would be relevant to know how the CAISO intends for these transmission element limits to be applied to various IRP resource injections. If all busses importing to, and within, any area are treated with equal impact the limits could potentially distort the optimal siting in RESOLVE.

Note: It has come to our attention that the CPUC very recently posted a document to its 2019-2020 IRP Events and Materials website entitled “Preferred System Plan RESOLVE Updates” which contains some of the information to which we refer. However this documentation should have been provided along with the CAISO’s white paper and presentation, or there should otherwise be allowed opportunity for stakeholder input on the data and assumptions contained in it. 

B. Energy Only Limits

SWPG/Pattern are also concerned about the derivation of the Energy-Only (EO) limits. In the 2020- 2021 TPP the CAISO tested expanded EO limits in its Policy Sensitivity Case 2 and found no issues of significance with the Riverside Palm Springs RESOLVE area’s proposed expansion. SWPG seeks clarity on how the new EO limits – proposed to be based on off-peak delivery values – relate to the findings of the Policy Sensitivity Case 2 from last cycle. SWPG believes the CAISO should not overly restrict RESOLVE’s EO siting.  It seems incorrect for the CAISO to conclude that RESOLVE siting above the off-peak delivery limits from the CAISO’s generation interconnection studies would result in excessive curtailment, especially in cases where the CAISO has not done any investigation of the level of curtailment that would occur.

Note: In the white paper Table 3-1 an “*” indicated that the capability estimates reflected the amount of resources studied and that the deliverability case did not uncover any binding estimates. Thus no siting above the limit was studied, and what the CAISO is showing as a constraint – above which presumably the CPUC would have RESOLVE not site additional resources – was in found by the CAISO to be the opposite; those values were found to not all be limiting. SWPG/Pattern seek clarity on this point, beyond the CAISO’s simple restatement of its concern regarding excessive curtailment offered in the stakeholder meeting.

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

No comments on this topic.

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

No comments on this topic.

5. 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:

SWPG/Pattern appreciate the CAISO’s update on this study which we consider to be very important due to the critical resource diversification and reliability benefits these OOS wind resources provide. Our comments are mainly a clarification of the distinction made around how the NM wind resources are being modeled compared to the WY/ID wind, as specifically stated on slide 71.

Slide 70 notes the alternative transmission projects to deliver wind from WY or ID that have submitted previously as interregional transmission projects and studied as such. Then slide 71 lists a reference “pre” case with 1062MW of NM wind and a “post” case with WY and/or ID wind. As we understand, the reason for such labeling is that in the “pre” case the cost of the new build transmission from the NM wind region is not being included, whereas in the “post” case the cost of new build transmission from the WY/ID wind regions is included in order to assess the production benefit of these costs. However the two (2) cases are still mutually exclusive in terms of the wind additions meaning the “pre” case contains 1062MW of NM wind and 0MW of WY/ID wind and vice versa for the “post” case.

As the developers of the SunZia Transmission Project we also point out that the reason for this distinction is that SunZia is being proposed as more of a “subscription” model whereby the costs of the new transmission from the wind region will be borne by the customers or users of the line rather than by the CAISO ratebase as a whole. That being said, we are still open to and would even encourage the CAISO to study as an additional sensitivity a case with 1062MW of wind from BOTH NM and WY/ID since both regions offer diversification benefits.

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

Regarding the 20-year transmission outlook, our only comments are to point out that the CAISO could potentially use findings of the 20-year study to inform its choice of what projects to nominate for approval as part of the 10-year 2021-22 TPP. That is, the constraints that appear on the system in the 10-year regular TPP and are also implicated as necessary in the 20-year study should no longer be delayed if resolving those constraints can enable further interconnection or delivery of renewable resources in accordance with the SB100 goals in addition to those of the 10-year TPP. 

7. Additional comments on the July 27, 2021 stakeholder call discussion:

SWPG and Pattern have no further comments on the discussion, but would suggest that the CAISO record future stakeholder calls and make the replay available to stakeholders who are unable to attend the live meeting. In this case there was not much notice given for the stakeholder call and it was a 3.5-hour event which makes live attendance challenging and thus limits stakeholder participation.

1. Provide a summary of your organization’s comments on the July 27, 2021 stakeholder call discussion:

2. Provide your organization’s comments on the transmission capability information provided to the California Public Utilities Commission through its Integrated Resource Planning Process, as described in slides 4-28:

3. Provide your organization’s comments on the Policy-driven Assessment Sensitivity 1 – Offshore Wind Studies topic, as described in slides 29-50 related to the 2021-2022 Transmission Planning Process:

4. Provide your organization’s comments on the Economic Assessment Assumption Update for 2021-2022 Planning Cycle topic, as described in slides 51-65 related to the 2021-2022 Transmission Planning Process:

5. 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:

Slide 67 identifies that the inclusion of portfolios with out-of-state resources raises "questions as to if or how the ISO would examine out of state transmission needs". With respect to the "if" question it is not clear on what basis the ISO would not examine out-of-state transmission needs in accordance with its tariff and in particular the policy-driven solution portion of the TPP in direct response to the portfolios provided by the CPUC for the TPP.

The CPUC IRP modeling reflects the findings of the ISO from its own special study completed a few years ago that remote resources in Wyoming would require new transmission capacity for California CAISO consumers (served through there respective LSEs) to access these resources. The term "Out-of-State" for the Wyoming resource area is of course accurate. However, the question of "if " the ISO would examine "out-of-state transmission needs" is more accurately phrased as whether the ISO would examine transmission needs that go beyond its present network extents as the ISO Network does currently include out-of-state transmission, the ISO does not extend throughout the state of California as there are several other Transmission Providers, and expansion of the ISO network or BAA has been considered in many regional forums.

With respect to the question of how to examine "out-of-network" expansion needs, TransWest suggests that the policy driven criteria from the Tariff and the BPM be considered in thier entirety. We appreciate the ISO is planing to conduct "economic"analysis based on production cost analysis although it is not clear how this analysis would supplement the IRP economic findings that considered both capital costs for transmission, resources and other key IRP information such as capacity factors and diversity for different resource areas. If the "economic" analysis finds differences in production costs between the various transmission configurations it is not clear how the ISO would use this information to help inform the TPP or the IRP.  If the production costs are lower for a certain transmission solution but the renewable resource plus new transmission costs are higher, as modeled in the IRP for Idaho versus Wyoming for example, how would these analyses inform the TPP? 

Within the ISO special study of out-state resources, one of the key findings was the importance of "Available Transmission Capacity" (ATC) in making any assessment. Production cost modeling simply assumes all (AC at least) transmission capacity is available, whether the transmission capacity is fully subscribed to provide transmission service for local areas. 

6. Provide your organization’s comments on the updates related to the 20-Year Transmission Outlook, as described in slides 74-84:

See TransWest's response to question 6. Whether it is a five year outlook or a 20-year outlook, there needs to be a comprehensive study plan that ties directly to the IRP-driven investment case for policy-driven solutions for the ISO to support the states policy objectives.

7. Additional comments on the July 27, 2021 stakeholder call discussion: