Comments on Issue paper

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

ACP-California appreciates that the development of the annual draft Transmission Plan has become more complex, and that CAISO requires additional time in order to analyze alternative solutions and to prepare and release the Draft Transmission Plan. We generally support the CAISO’s proposal to modify the release of the Draft Transmission Plan from January to March and to move CAISO Board consideration of the Final Plan from March to May. 

We appreciated the discussion during the stakeholder meeting about the potential implications on other processes, such as the Integrated Resource Planning (IRP) process, the Transmission Plan Deliverability (TPD) allocations, Maximum Import Capability (MIC) process, etc. While, based on that discussion, there do not appear to be any substantial impacts to those processes, we encourage CAISO to include a discussion around any potential impacts on these processes (or explain why there are not impacts) in the forthcoming Straw Proposal.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

It is imperative for CAISO to have the ability to look out at transmission needs beyond the current 10-year horizon. This is essential not only because of the ramp up in resource and transmission needs that are projected to occur in the next 10+ years, but also because of the delays that have been experienced in getting transmission projects permitted, constructed, and placed in service. ACP-California therefore strongly supports CAISO’s proposal to enable approvals of major long-lead time transmission projects beyond the 10-year horizon and looks forward to engaging with CAISO on additional details to implement these proposed modifications to the TPP. It is also worth noting that CAISO’s approvals of projects beyond the 10-year horizon in turn have ripple effects for enabling development of non-CAISO transmission projects needed to deliver out-of-state resources such as wind and geothermal.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

ACP-California appreciates CAISO’s efforts to consider solutions to help better align the procurement, interconnection, transmission planning, and MIC allocation processes. As CAISO has recognized, the lack of alignment and coordination between these processes may create challenges, especially if transmission capacity that has been identified for one purpose (to help support public policy goals) is utilized for a different purpose by virtue of this lack of coordination. Failure to coordinate transmission development with these processes could result in excess transmission build and could increase overall ratepayer costs to achieve the state’s public policies. We, therefore, appreciate CAISO seeking to address this issue, even while recognizing that the solution may present challenges.

ACP-California generally supports the CAISO’s proposed approach but offers two sets of suggestions to help this proposal in securing FERC approval.  First, CAISO should utilize a reservation policy only in circumstances with a clear and direct public policy request from an applicable state actor.  Second, ACP-California also asks that CAISO consider applying this proposal not only to new transmission capacity but also for existing transmission capacity, which may be envisioned as supporting specific public policy goals by state agencies.

First, CAISO should limit the use of any reservation mechanism to specific circumstances, and not use this approach across the board for all public policy transmission expansion projects. ACP-California recommends that CAISO should only retain public policy driven capacity for the specific policy purpose for which it was developed when specific direction to do so is provided either by the CPUC, the Governor, or the Legislature. Thus, only when directed to do so by one of these entities, would CAISO reserve public policy transmission capacity for one or more specific resource types.  Additionally, any reservation should not be of unlimited duration; instead, the state should be able to reserve capacity for a fixed number of years (after which any unused capacity would be available pursuant to typical open access rules). This is consistent with some FERC precedent such as Order No. 807, which allows for priority use of additional capacity on gen-tie lines by the sponsoring party for a fixed period.  ACP-California believes that having this direct, transparent, and time-limited tie to public policy direction from the state, and judicious application of this approach, would help improve the chances of these tariff changes being approved by FERC. We anticipate that the direction from the state would be limited to unique circumstances and to resources which are more “location constrained” such as transmission capacity to facilitate delivery of offshore wind, out-of-state wind, or geothermal at the CAISO interties. 

In addition to limiting the application of this approach to specific instances when state policy direction is provided and for a fixed term, we encourage CAISO to consider application of this approach not only to newly approved transmission upgrade capacity but also to existing un- or under-utilized transmission capacity, if so directed by the state. There may be certain instances where the state’s public policy goals are tied to utilization of existing transmission capacity by a specific set of resources (e.g., excess transmission capacity in the Diablo region for offshore wind). If that existing transmission capacity is utilized by other resource types, then additional transmission build out may be required to meet the state’s policy objectives and the overall system buildout may be less efficient. Given this, we encourage CAISO to consider proposing a process where, when provided with specific policy direction by the state (as discussed above), CAISO could reserve either existing or new transmission capacity for the specific public policy purpose for which it was envisioned. ACP does not believe that existing transmission customers should lose the right to existing transmission service (or be forced to use a non-firm product) to accommodate state policies; rather, in the event of significant changes to the grid (such as a power plant retiring, or a reduction in load due to population changes or other factors) CAISO should allow for identification and use of transmission that might be made available.  We recognize that reserving existing transmission capacity in this manner would require further detail to render it just and reasonable; thus, if CAISO moves forward in this manner, it should make the policy proposal to FERC “severable” such that FERC could reject the reservation of capacity on the existing system while still approving reservation of capacity on transmission upgrades or new lines. 

Finally, CAISO should provide additional details about when and how this proposal would be implemented and whether it would impact projects currently in the CAISO queue (and their ability to secure a TPD allocation) or if it would only apply to projects on a going forward basis, presumably starting with Cluster 15. 

ACP-California appreciates CAISO’s proposal to address this important issue and looks forward to working with CAISO and other stakeholders to develop and refine an approach that can help ensure efficient transmission build out for achieving the state’s public policies. 

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

No comment

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

The CAISO intends to extend the posting of the draft transmission plan to March 31, hold a stakeholder meeting in April, and bring the revised draft of the transmission plan to the May CAISO Board of Governors meeting.[1] BAMx appreciates the need to alter the timeline for the current transmission planning cycle given the increased volume and complexity of the alternative analysis required for the development of the transmission plan. Therefore, BAMx supports CAISO's proposed revised timeline.

Historically, the CAISO has been generally responsive to stakeholder comments. For example, it typically posts its responses to the stakeholder comments on reliability assessment (October) sometime in mid-November. However, that was not the case in the 2021-2022 TPP cycle. BAMx requests that the revised 2022-2023 planning cycle schedule should provide timely CAISO responses to the stakeholder comments.

[1] Issue Paper, p.4.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

The CAISO indicates the following.

1. The planning horizon of the CAISO's transmission planning process is currently ten years; however, the tariff requirement is at least ten years and does not limit the CAISO to 10 years.[1]
2. If a need has been identified within the 10-year planning horizon and additional needs are identified in the longer-term beyond the 10-year transmission planning horizon, such as the CAISO’s 20-Year Transmission Outlook, the CAISO currently takes those additional needs into consideration in assessing alternatives and recommending transmission expansion projects for approval by the CAISO Board of Governors.[2]

Given the timelines associated with major transmission development and with the increasing load and resource requirements in the CEC high electrification demand scenarios and CPUC-associated resource portfolios being projected beyond the 10-year planning horizon, BAMx appreciates that there may be a need to approve specific transmission expansion projects to meet these needs when the expected duration to implement the transmission project is beyond the current 10-year planning and project approval horizon. On the other hand, any transmission approval based on the need beyond the 10-year horizon increases the possibility of dated decisions to add transmission assets may become sub-optimal with changing circumstances.

A good example of changing planning conditions is the CAISO reevaluation of the need for certain previously approved projects in the 2015-2016 and 2016-2017 Transmission Plan that resulted in cancellation and scope change for several small-scale and major transmission projects.[3] At that time, consistently declining load forecasts across the entire forecast period – especially for the 1-in-10 peak load forecasts - as well as higher than anticipated development of behind the meter solar photovoltaic generation had put additional downward pressure on load-driven transmission projects, leading to re-evaluation of the need for certain previously approved upgrades that were predominantly load driven. The CAISO’s reevaluation resulted in nearly $3 billion of transmission cost savings to the ratepayers.

While considering enabling approvals for major long lead time transmission projects needed beyond the current 10-year planning horizon, BAMx urges the CAISO to formally incorporate in any changes a process to reassess the appropriateness of prior approved projects based upon the latest knowledge. A recent Federal Energy Regulatory Commission (FERC) Notice of Proposed Rulemaking (NOPR)^[4] envisions such reassessment and revisions to happen at least once every three years. In order to perform a reassessment and revisions at least once every three years, the CAISO needs to develop and review with Stakeholders specific criteria that the CAISO  would apply that would trigger the need for reassessment. These criteria would include, but are not limited to, (i) material changes to the originally assumed load forecast, (ii) permitting challenges for certain generating resources that eliminates or significantly delays its buildout, (iii) permitting difficulty for the proposed transmission addition, etc. BAMx is willing to work with the CAISO and other stakeholders to refine and/or expand these criteria.

[1] Issue Paper, p.4.

[2] Ibid.

[3] CAISO 2016-2017 Transmission Plan, p.1.

[4] FERC NOPR, Docket No. RM21-17-000, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, p.82.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

As part of this initiative, CAISO is proposing to withhold the transmission capacity specifically for the policy-driven processes for which it was planned rather than relying on it for any and all interconnection requests received through the generator interconnection request windows.[1] As we describe in the previous section, the planning, market, and regulatory conditions change over the time. So, it is possible that the specific resource development that drove the policy-driven transmission projects could change, and if that occurs, the CAISO needs to release that capacity. For example, suppose certain transmission projects expanding an intertie capacity as well as downstream transmission capacity within the CAISO grid are set aside for the development of offshore wind, out-of-state, geothermal, or long-duration storage resources, and, therefore, that capacity cannot be relied upon by the other solar, wind or battery storage resources in the CAISO generation interconnection queue. Suppose the subsequent CAISO planning cycles find that the updated renewable resource portfolios have significantly changed the mix of offshore wind, out-of-state, geothermal, or long-duration storage resources assumed in the earlier cycles. In that case, the CAISO should release the withheld transmission capacity to the queued solar, wind, or battery storage resources. BAMx believes the CAISO should propose criteria for releasing the reserved capacity and review those criteria with Stakeholders.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

BAMx appreciates the opportunity to comment on the Transmission Planning Process Enhancements and acknowledges the significant effort of the CAISO staff to frame this initiative, and hopes the BAMx-suggested changes are included in the CAISO straw proposal.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

BHE Renewables, LLC (BHE Renewables) welcomes the opportunity to participate in the transmission planning process enhancement stakeholder process. BHE Renewables develops, owns and operates wind, solar and geothermal resources in California in both the CAISO and neighboring balancing authorities, and it supports the proposed enhancements.

In particular, as an owner and developer of geothermal resources in the Salton Sea region, BHE Renewables is concerned that the lack of available transmission capacity to support the use of renewable baseload imported from neighboring California balancing areas to meet resource adequacy requirements in CAISO could make it difficult or impossible to meet the policy objectives outlined in Decision 21-06-035. In that decision, the California Public Utilities Commission identifies a critical need for firm (greater than 80% capacity factor) resources. The CAISO transmission planning process includes an effective framework for identifying and approving transmission solutions required to support such resources, but as the issue paper outlines, the CAISO cannot provide any assurance that this capacity will actually be allocated in a way that supports those objectives. BHE Renewables agrees that this element of the CAISO tariff requires reform in order to allow the transmission planning process to function as intended with respect to its mandate to support public policy goals.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

The California Community Choice Association (CalCCA) supports the California Independent System Operator’s (CAISO’s) proposal to extend phase two of the Transmission Planning Process (TPP) such that the draft transmission plan is posted in March and brought to the board in May. The detailed analysis and special studies provided in the draft TPP, which as the CAISO notes are becoming more voluminous and complex, are very valuable. CAISO staff should adjust the timeline of the TPP process in a manner that allows the CAISO to perform and document the studies in the same detailed manner as it has in past years.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

CalCCA supports the CAISO enabling approvals for major long-lead-time transmission projects needed beyond the current 10-year planning horizon. The time it takes to complete major transmission projects, the increased demand projected under the CEC’s high electrification scenarios, and new resource build projected to come online to meet state policy goals may necessitate project approvals beyond the current 10-year horizon.

In the next straw proposal, the CAISO should provide additional detail on how the CAISO would prioritize project approvals whose need extends beyond the 10-year planning horizon. The way the CAISO ultimately prioritizes projects for approval beyond 10 years is a critical component of “least-regrets” planning given the significant cost impacts of transmission upgrades. The 20-year outlook estimated $30.5 billion worth of transmission development needed to integrate resources in the Senate Bill (SB) 100 Starting Point Scenario.[1] Careful prioritization is necessary such that long-lead-time transmission projects are approved and implemented in a manner that minimizes costs over the long term.

[1]             CAISO 20 Year Transmission Outlook at 3: http://www.caiso.com/InitiativeDocuments/20-YearTransmissionOutlook-May2022.pdf

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

CalCCA supports the CAISO exploring the possibility of reserving policy-driven transmission capacity for the specific policy purpose for which it was developed. Reserving transmission capacity allocations to projects in the interconnection queue that would meet the resource portfolio from the Integrated Resource Plan (IRP) portfolios studied within the TPP would help better align the IRP, TPP, and interconnection processes. The CAISO should explore this approach further, and provide additional detail in the straw proposal regarding how the steps for allocating transmission capacity would change to incorporate the consideration of policy-driven upgrades.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

CalCCA has no additional comments at this time.  

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

CESA has no comment at this time.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

CESA supports the ISO’s consideration of how to enable approvals for major long lead-time transmission projects beyond the current 10-year planning horizon, such that study results such as those from the 20-year transmission outlook can be implemented in practice with actual project approvals and transmission buildout. As the ISO discusses in the Issue Paper, the ISO can avoid rapid transmission buildout needs and identify the need to approve and build larger/major transmission upgrades that will likely have long lead times and more readily accommodate future generation and energy storage in the 2032-2045 period. Otherwise, the current Transmission Planning Process (TPP) framework will focus on smaller transmission upgrades and/or put the state in a difficult situation of ramping up resource and transmission buildout on an incremental and year-by-year basis. Especially with all of California’s transmission, distribution, and resource planning processes moving toward higher transportation electrification load forecasts.

As the ISO develops specific proposals, however, CESA raises a number of questions regarding the load forecast allocation and resource mapping methods in scoping and identifying transmission projects for reliability-based and policy-driven projects. It will be important to know the nature, timing, size, and certainty of any “major load increases” to avoid stranded investment costs and to co-optimize for multiple benefits that the transmission investment can provide. For example, while the California Energy Commission (CEC) uses econometric methods to map new electric vehicle (EV) charging infrastructure investments, the actual deployments may differ from these forecasts based on commercial interest, driver needs, and policy guidance or requirements. In addition, the ISO should detail how resource mapping methods will be used on a long-term basis to support the approval of transmission investments beyond the 10-year planning horizon, especially since the current resource mapping methodology may or may not be appropriate for longer-term expectations. For example, commercial interest may be more speculative on a beyond 10-year outlook, and the siting and characteristics of energy storage resources may evolve over time (e.g., co-location versus standalone, duration) because most developers are likely planning for commercial operations within the 10-year window.

Understandably, such questions will be better answered in coordination with the CEC and California Public Utilities Commission (CPUC), who are responsible for developing the appropriate input assumptions within their respective domains. As CESA sees it, having a better understanding of these load forecast and allocation methods (CEC) and resource mapping methods (CPUC) will inform the development and assessment of ISO proposals regarding the criteria and approval of long lead-time transmission projects.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

CESA generally supports the consideration of proposals around the retention of policy-driven transmission upgrade capacity, which the ISO argues would ensure that the TPP is directly linked to interconnection requests or with procurement activities of a large number of load-serving entities, better ensuring the achievement of policy objectives.

However, while generally supportive of the consideration of this issue and solutions, CESA emphasizes the importance and need to align with non-discriminatory principles and maintain technology neutrality when identifying such policy-driven transmission investments. In this sense, the CAISO should coordinate closely with the CPUC to ensure that any policy-driven resources identified in the Integrated Resource Planning (IRP) process are transmitted to the CAISO TPP with resource attributes rather than specific resource types in order to define the policy goal in a way that aligns with non-discriminatory principles. In doing so, the CAISO may not need to retain transmission capacity for a specific resource type for a specified period of time but for any resource type that can meet the identified attributes (e.g., generation/storage profile, capacity factor, dispatchability), regardless of whether the resource is a long lead time resource or not. In addition, given the fact that CPUC resource portfolios can change over time based on modeling inputs and assumptions or other factors, the CAISO and CPUC should coordinate on the criteria for determining the identification and approval of transmission investments that would be reserved for any resource type that provides certain resource attributes.

Furthermore, CESA recommends that the ISO ensure that any retention of policy-driven transmission upgrade capacity incorporate elements related to commercial viability (similar to all other resources in the interconnection queue) and differentiate between whether proposals are addressing existing or incremental transmission capacity. With the adoption of the 24-slice proposal in the CPUC’s Resource Adequacy (RA) docket (R.21-10-002), there may also be considerations around how deliverability methodologies need to be modified to best utilize the transmission capacity enabled by these policy-driven upgrades, beyond just the peak and net peak hours, which could potentially still allow for transmission capacity to be retained for a given policy goal and enable greater utilization of the new transmission capacity in other hours from various other resources.

As the ISO develops proposals on this issue, we recommend that the ISO consider the above comments to ensure alignment with non-discriminatory principles while still meeting identified policy goals.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

CESA has no further comment at this time. We support the scope of the initiative and look forward to reviewing the ISO’s proposals and participating in this initiative.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

CPUC staff recognizes the workload that CAISO must manage every TPP cycle and we appreciate the expertise that CAISO planners consistently contribute to the state’s efforts to decarbonize the electricity grid.

CPUC staff is continuing to assess the impacts of this timing change on the IRP process, specifically the development of resource portfolios and the demand forecasts which are key inputs for each TPP cycle. CPUC staff is eager to work with the CAISO and the CEC to better sync up the development of these inputs.

We note that CAISO still intends to present preliminary results of its analysis in September and November each year, which can provide useful but incomplete information; for example, the draft transmission plan often proposes new transmission upgrades (or alternatives to transmission) that are not identified in the preliminary results but should be incorporated into IRP modeling as soon as possible.       

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

CPUC staff supports this proposal and commends the CAISO for its ongoing efforts to contribute to transmission planning beyond a 10-year horizon. 

We note that the CAISO will be conducting a “high electrification” sensitivity study as part of this TPP cycle for which, at the CPUC’s request, the planning scenarios will extend to 2035. We anticipate IRP modeling will increasingly consider resource needs beyond ten years as the state accelerates initiatives to achieve a carbon-free electricity grid by 2045.  

We appreciate CAISO’s foresight and willingness to include long lead-time transmission projects in in its TPP analysis.   

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

CPUC staff strongly supports this conceptual proposal.  We recognize that many details need to be hashed out, such as a transparent process by which certain resource types would be identified as the key drivers of certain transmission projects and the methods to ensure the transmission is utilized in an efficient manner.  We encourage the CAISO’s efforts to bring forth a straw proposal and lead stakeholder engagement on this proposal. 

CPUC Staff also notes that policy-driven transmission upgrades are paid by California customers through the CAISO’s TAC; thus, the resources that interconnect to these upgrades should be serving California customers.

The interactions between the transmission planning, interconnection and LSE procurement processes can create challenges for meeting ambitious milestones and goals for rapid achievement of a carbon-free grid.  CPUC staff applauds the CAISO for elevating this proposal and we urge priority in addressing this innovative and constructive approach.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

N/A

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

California Western Grid supports adding approximately two months to the TPP Phase 2 for the 2022-23 TPP and for future TPP cycles. It is important to build enough time into each TPP cycle to allow the CAISO to properly evaluate high electrification scenarios and portfolios that add significant resource additions to reduce carbon emissions and have a chance of meeting SB 100 goals.

California Western Grid envisions the CAISO will need the additional time in each TPP to approve significantly more transmission than in previous years if we have any hope of meeting SB100 goals. California Western Grid encourages the CAISO to also use the added time in the 22-23 TPP cycle to evaluate the 2035 high electrification / 30 MMT sensitivity portfolio and approve long lead time least regrets transmission additions that are found needed and are consistent with the 20-Year Outlook.

California policy is explicit and is set forth in SB 100 and numerous executive orders and directives. The CAISO has the tariff authority and responsibility to begin approving needed transmission solutions that are identified from resource portfolios that extend beyond 10 years. California Western Grid urges the CAISO to use the additional two months in the 2022-23 TPP to identify and approve needed long lead time transmission.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

California Western Grid supports a “greater than 10 years” planning horizon for identifying and approving new transmission projects. Given the long lead time for approving, siting, permitting, and constructing new transmission the planning horizon should be at least 15 years.

California Western Grid urges the CAISO implement this TPP enhancement immediately, beginning with the 2022-23 TPP. At the July 22, 2022, Stakeholder meeting (slide #15) the CAISO suggested   this enhancement be delayed until the 2023-24 TPP. It is critical not to wait any longer.  The magnitude of the need and the long lead-times involved make that all too clear. On July 1, 2022, the CPUC transmitted a 2035 high electrification sensitivity portfolio for use in the 2022-23 TPP. That portfolio should be used to identify least regrets long lead time transmission needs that are critical for a 2035 high electrification future. Those long lead-time transmission solutions should be brought to the CAISO Board for approval in May 2023. Upon Board approval, those solutions should proceed directly to Phase 3 of the 2022-23 TPP.

The CAISO has the authority and responsibility to approve needed long lead-time transmission. The CAISO 20-Year Transmission Outlook has already provided the road map. Instead of limiting the analysis of the 2035 high electrification portfolio to sensitive studies, that 2035 portfolio can and should be used to start approving needed new transmission now.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

While California Western Grid supports enhanced coordination between the generator interconnection process and the Transmission Planning Process, California Western Grid believes the CAISO has defined this issue too narrowly. California Western Grid supports the notion of reserving transmission upgrades for the policy purpose that drove their approval.  However, the CAISO July 15 Issue Paper unnecessarily restricts this concept to transmission built to bring power from the generation load pocket to the high voltage grid and improvements on the High Voltage backbone grid. Totally missing is a clear need to plan and build transmission in anticipation of the need to bring power from the high voltage backbone into load centers. The CAISO should not only coordinate its TPP long term planning with the generator interconnection process, BUT the CAISO should also improve the linkage and coordination between the long-term planning project approval and special studies the CAISO does in TPP cycles. Specifically, the LCRA studies and, more recently, the CAISO battery study from Appendix G of the 2020-21 TPP indicate that local resources will not be sufficient to meet local needs.  This must be addressed on a priority basis.

Indeed, those CAISO studies indicate a profound need for transmission from the high voltage grid into load centers. The CAISO has ten defined transmission constrained load centers, known as LCRAs. Those load centers are transmission constrained and will need a multitude of new resources, energy storage, and transmission solutions to reliably meet load as California reduces its dependence on carbon emitting generating sources.

The CAISO should put at least an equal focus on the two critical transmission needs : (1) bringing renewable energy from generation resource areas to the high voltage grid and (2) allowing renewable resources to be delivered to the load centers where it is needed. California Western Grid urges the CAISO to identify and approve transmission needed in anticipation of the high electrification demand and reducing reliance on carbon emitting generation in urban load centers like Los Angeles in this 2022-23 TPP.

Continuing to delay approving long lead time transmission will lead to a massive build requirement in the next decade that will not only overwhelm the supply chain for critical transmission equipment, but  will also overwhelm the California Agencies ability to process permit applications. Combined with siting challenges for new transmission it is easy to see how new transmission could take well over 10 years to complete. It is simply disingenuous to ignore the need to start approving new transmission now if there is any intent to try to meet SB 100 goals especially with high electrification included in the plan. The global climate crisis and the existing burden to disadvantaged communities like Los Angeles (“LA”) must be addressed now. The combination of the 2021 Joint Agency Report to the Legislature and the CAISO’s 20-YearTransmission Outlook, along with high electrification demand leaves no credible doubt. CAISO must start approving least regrets new transmission immediately in this 2022-23 TPP cycle. A roadmap of the needed new transmission has already been identified in the CAISO’s 20-Year Transmission Outlook. It now a matter of executing on those plans.

California Western Grid urges the CAISO to follow the roadmap in the CAISO’s 20-Year Transmission Outlook and approve significant new transmission in its 22-23 TPP focusing first on load centers like the LA Basin that have the worst air quality significantly harming disadvantaged communities. Failure to do so will have a profound impact if we fail to meet California’s SB 100 goals.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

Three Rivers Energy Development, LLC (TRED) is an Independent Transmission Developer that is developing the proposed Pacific Transmission Expansion Project (“PTE Project” or “PTEP”) on behalf of California Western Grid Development, LLC. (“California Western Grid”). The PTE Project is a 2,000 MW controllable HVDC subsea transmission cable that the California Independent System Operator (“CAISO”) has found will allow new and existing supply available to the Diablo Canyon 500 kV switchyard, or new offshore wind, to be delivered to the West LA Basin to reduce local capacity requirements. The PTE Project is described in Section 4.8.8 of the 2020-2021 CAISO Transmission Report issued March 24, 2021. The PTE Project is also currently being restudied by the CAISO as part of 2022-2023 CAISO Transmission Planning Process (“TPP”).

We are pleased to submit these comments on behalf of California Western Grid regarding the Transmission Planning Process (“TPP”) Enhancements dated July 15, 2022.  We commend the CAISO for recognizing that changes to the TPP are needed immediately if the CAISO is going to be able to plan and approve transmission to accommodate the tripling of clean energy resources the 2021 Joint Agency Report to the legislature found is necessary to meet SB 100 goals.  As discussed below, we urge the CAISO to focus not only on transmission needed to connect resources to the Grid but also transmission needed to be able to deliver the new clean energy to local load centers like Los Angeles needed to meet SB 100 goals including high electrification demand. Indeed, SB 100 places a high priority on delivering clean energy to disadvantaged communities like those in LA that experience the worst air quality.

We will now address the three proposed enhancements in the July 15^th Issue Paper.

Issue #1: Adjust the timeline for the release of the draft transmission plans from the end of January to the end of March, targeting final approval in each year’s May Board of Governors meetings.

California Western Grid supports adding approximately two months to the TPP Phase 2 for the 2022-23 TPP and for future TPP cycles. It is important to build enough time into each TPP cycle to allow the CAISO to properly evaluate high electrification scenarios and portfolios that add significant resource additions to reduce carbon emissions and have a chance of meeting SB 100 goals.

California Western Grid envisions the CAISO will need the additional time in each TPP to approve significantly more transmission than in previous years if we have any hope of meeting SB100 goals. California Western Grid encourages the CAISO to also use the added time in the 22-23 TPP cycle to evaluate the 2035 high electrification / 30 MMT sensitivity portfolio and approve long lead time least regrets transmission additions that are found needed and are consistent with the 20-Year Outlook.

California policy is explicit and is set forth in SB 100 and numerous executive orders and directives. The CAISO has the tariff authority and responsibility to begin approving needed transmission solutions that are identified from resource portfolios that extend beyond 10 years. California Western Grid urges the CAISO to use the additional two months in the 2022-23 TPP to identify and approve needed long lead time transmission.

Issue #2: Coordination with other planning processes and enable approvals for major long lead time transmission projects needed beyond the current 10-year planning horizon

California Western Grid supports a “greater than 10 years” planning horizon for identifying and approving new transmission projects. Given the long lead time for approving, siting, permitting, and constructing new transmission the planning horizon should be at least 15 years.

California Western Grid urges the CAISO implement this TPP enhancement immediately, beginning with the 2022-23 TPP. At the July 22, 2022, Stakeholder meeting (slide #15) the CAISO suggested   this enhancement be delayed until the 2023-24 TPP. It is critical not to wait any longer.  The magnitude of the need and the long lead-times involved make that all too clear. On July 1, 2022, the CPUC transmitted a 2035 high electrification sensitivity portfolio for use in the 2022-23 TPP. That portfolio should be used to identify least regrets long lead time transmission needs that are critical for a 2035 high electrification future. Those long lead-time transmission solutions should be brought to the CAISO Board for approval in May 2023. Upon Board approval, those solutions should proceed directly to Phase 3 of the 2022-23 TPP.

The CAISO has the authority and responsibility to approve needed long lead-time transmission. The CAISO 20-Year Transmission Outlook has already provided the road map. Instead of limiting the analysis of the 2035 high electrification portfolio to sensitive studies, that 2035 portfolio can and should be used to start approving needed new transmission now.

Issue #3: Retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed

While California Western Grid supports enhanced coordination between the generator interconnection process and the Transmission Planning Process, California Western Grid believes the CAISO has defined this issue too narrowly. California Western Grid supports the notion of reserving transmission upgrades for the policy purpose that drove their approval.  However, the CAISO July 15 Issue Paper unnecessarily restricts this concept to transmission built to bring power from the generation load pocket to the high voltage grid and improvements on the High Voltage backbone grid. Totally missing is a clear need to plan and build transmission in anticipation of the need to bring power from the high voltage backbone into load centers. The CAISO should not only coordinate its TPP long term planning with the generator interconnection process, BUT the CAISO should also improve the linkage and coordination between the long-term planning project approval and special studies the CAISO does in TPP cycles. Specifically, the LCRA studies and, more recently, the CAISO battery study from Appendix G of the 2020-21 TPP indicate that local resources will not be sufficient to meet local needs.  This must be addressed on a priority basis.

Indeed, those CAISO studies indicate a profound need for transmission from the high voltage grid into load centers. The CAISO has ten defined transmission constrained load centers, known as LCRAs. Those load centers are transmission constrained and will need a multitude of new resources, energy storage, and transmission solutions to reliably meet load as California reduces its dependence on carbon emitting generating sources.

The CAISO should put at least an equal focus on the two critical transmission needs : (1) bringing renewable energy from generation resource areas to the high voltage grid and (2) allowing renewable resources to be delivered to the load centers where it is needed. California Western Grid urges the CAISO to identify and approve transmission needed in anticipation of the high electrification demand and reducing reliance on carbon emitting generation in urban load centers like Los Angeles in this 2022-23 TPP.

Continuing to delay approving long lead time transmission will lead to a massive build requirement in the next decade that will not only overwhelm the supply chain for critical transmission equipment, but  will also overwhelm the California Agencies ability to process permit applications. Combined with siting challenges for new transmission it is easy to see how new transmission could take well over 10 years to complete. It is simply disingenuous to ignore the need to start approving new transmission now if there is any intent to try to meet SB 100 goals especially with high electrification included in the plan. The global climate crisis and the existing burden to disadvantaged communities like Los Angeles (“LA”) must be addressed now. The combination of the 2021 Joint Agency Report to the Legislature and the CAISO’s 20-YearTransmission Outlook, along with high electrification demand leaves no credible doubt. CAISO must start approving least regrets new transmission immediately in this 2022-23 TPP cycle. A roadmap of the needed new transmission has already been identified in the CAISO’s 20-Year Transmission Outlook. It now a matter of executing on those plans.

California Western Grid urges the CAISO to follow the roadmap in the CAISO’s 20-Year Transmission Outlook and approve significant new transmission in its 22-23 TPP focusing first on load centers like the LA Basin that have the worst air quality significantly harming disadvantaged communities. Failure to do so will have a profound impact if we fail to meet California’s SB 100 goals.

Marty Walicki, 

Managing Partner

Three Rivers Energy Development, LLC                                        August 5, 2021                                                            

[1] Issue Paper - Transmission Planning Process Enhancements dated July 15, 2022 (“July 15^th Issues Paper”).

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

NRG has no comments on this proposed change.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

While the proposal to approve transmission projects beyond the 10 year planning horizon are well intended, NRG urges caution on over reliance of any planning study beyond 10 years for making transmission investments due to the inherent uncertainty of a study with such a long planning horizon.

The electric grid is on the brink of momentous change with regards to load requirements, what resources will be used to meet future needs, and how existing resources may or may not be part of future solutions.  Although the intention is to pursue “no regrets” transmission solutions, it is very unclear if “no regrets” options even exist given the range of future options and how past long-term planning studies have done a questionable job at forecasting future needs.  NRG is not opposed to the voluntary use of 20 year planning studies to inform shorter term transmission decision making, but does not believe that reliance on CAISO’s 20 year transmission planning analysis to drive investment decisions will necessarily lead to just and reasonable outcomes.  A shorter-term assessment would be more certain, fit within the planning horizon necessary to make transmission investment decisions, and still reflect policy goals.

Some ISOs do currently perform 20 year planning studies but have recognized the inherent limitations in their outcomes.  SPP uses their 20 year study to inform, but not drive, transmission decision making and CAISO’s May 2022 20 year plan is not meant to drive specific project approvals but instead “is meant to engage with stakeholders in more informal yet meaningful discussion.”  Both SPP and CAISO currently recognize the inherent uncertainty that goes with any plan of this study length and properly limit how the study is meant to be used. 

A closer look at some of the factors to be used in any 20 year planning study and the results of past long-term planning studies create concerns for if they can be used to accurate forecast transmission needs.  Predictions for the future price of natural gas and thus the economics of gas generation in long-term forecasts has been notoriously inaccurate.  Work done by Lawrence Berkeley National Laboratory that reviewed long-term natural gas price forecasts performed by the US Department of Energy in its Annual Energy Outlook since 1985 found that they “have significantly missed their mark” with some forecasts being very high (1985-1986 forecasts had 15 year forward prices over $7/MMBTU and 2008 forecasts predicted prices remaining above $6/MMBTU for 10 years) and others being low (1996 to 2001 forecasts projected long-term prices remaining below $3/MMBTU).  Projecting future loads is also inherently inaccurate; the California Energy Commission’s 2021 Integrated Energy Policy Report (“IEPR”) forecasts 2035 managed system peak demand in the CAISO of anywhere from 45 to 58 GW, with the uncertainty growing significantly as the timeframe is extended.

Determining what technologies will be deployed to meet future loads is another area fraught with considerable uncertainty which past studies have failed to accurately forecast.  The California Public Utilities Commission initiated the Renewable Energy Transmission Initiative (RETI) in 2008-2010 to forecast the locations most attractive for renewable development to meet long-term renewable energy goals.  At the time, the most economic technologies were found to be wind and geothermal, with study recommendations made to prioritize development and interconnection in regions of the state with those resources.  Solar technologies at the time were significantly more expensive than they are today (utility scale PV was priced at $4 to $7/W in the study, compared to <$1/W today) with debate over if solar thermal or solar PV technologies should be prioritized.  If that study was used to prioritize and develop new transmission for California in 2008, it would have placed an emphasis on geothermal and solar thermal development, while inaccurately forecasting the need to develop transmission for solar PV and battery projects that the CAISO queue now reflects (the use of battery technology was not even considered at the time).

Similar to the crossroads that the RETI project found California to be in back in 2010, many parts of the US grid face a wide range of technology options with great uncertainty for which will be most economic or effective to meet future needs.  Besides the general question of what to do with existing baseload fossil and nuclear units, questions abound for whether renewable energy can replace baseload capacity, what emerging technologies will become cost effective (offshore wind, small modular nuclear, enhanced geothermal, etc.), the type and duration of storage that is needed (lithium-ion, flow batteries, pumped storage, compressed air energy storage, etc.), the breadth and impact of distributed resources which may greatly reduce the need for new transmission, and, in states with aggressive greenhouse gas reduction goals, if natural gas will play any role at all in the future electric grid.  This leads to uncertainty that will make any planning study beyond 10 years fraught with significant inaccuracy.

It is unclear to NRG, given the range of uncertainty in a 20 year transmission forecast, if a “no regrets” transmission plan extending beyond 10 years exists.  For example, in the range of CAISO load forecasts developed in the 2021 CEC IEPR, a study planning for low end of peak load growth would likely recommend little to no new transmission development.  Technology breakthroughs in distributed technologies and significant changes to customer demand profiles could greatly reduce new transmission needs which may conflict with transmission builds forecasted in what may be categorized as a “no regrets” scenario.  In addition, very few load serving entities forecast their loads or projected resource builds in their IRPs more than 10 years out, making it very difficult for any grid planner to develop a “no regrets” scenario for more than 10 years in the future.  Load serving entities in California forecasted resource needs in their 2020 IRP only through 2030; concrete policy goals are well defined through 2030 (60 percent RPS) while considerable uncertainty exists for what actions will be taken beyond 2030 to meet long-term goals. 

Given the significant uncertainty inherent in transmission planning beyond 10 years, NRG recommends 1) a shorter term analysis (10 years or less) for informing transmission planning, or 2) if a 20 year forecast is to be used, it solely be used for informational purposes and not be the basis for investment decisions.  A very high bar should be used in any long-term study to determine if there truly are any investments which represent “no regrets” in the scenarios explored.    Only in cases where robust sensitivity analysis looking at a range of costs, performance, and land use availability point to specific economic transmission development supporting policy objectives in all scenarios should development of those facilities be considered.  Priority for transmission development should remain on near-term reliability and economic transmission needs.  Once these goals have been met, only then should transmission planners use analysis of mid-term (10 year) needs informed by load serving entity IRPs, interconnection queues, and state policy objectives to prioritize additional transmission development.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

As with NRG’s comment on the previous question, NRG would caution the CAISO against a rigid approach that holds transmission capacity solely for policy driven purposes.  Market dynamics, changing interests, and technological advancements will make the assumptions used in development of policy-driven transmission obsolete.  Flexibility should be included in any policy-driven transmission process that allows space on these lines to be available for other purposes if market dynamics dictate.  For example, if the CAISO queue or future CPUC IRP analysis shows significant interest for project development using technologies and at locations other than the original intent of the transmission project, and it is determined that the alternative facilities are cost effective and generally support state policy objectives, space should be awarded to those projects.  Another approach would be to set a development timeline for policy priority projects; these projects can be given priority for usage of transmission upgrades if they meet defined development criteria.  If the projects fall behind in meeting these criteria, they will lose their priority and the transmission should be made available on a non-discriminatory basis to all interested parties.

If this tariff change is enacted, CAISO must consider how cost allocation will be performed if projects never come to fruition.  Transmission upgrades which should be paid by priority projects should not be borne by other market participants if these projects are never placed online.  If the policy-driven project is put in place due to state priorities, the state should be the backstop for payment.    

Finally, CAISO must consider if the approach being advocated is unduly preferential or discriminatory, in contravention of the Federal Power Act, and whether it would promote FERC’s long-established policy of open access to the transmission grid. 

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

NRG has no further comments on the items proposed in this initiative.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

EDF-R’s cursory review of the Joint Agencies’ alignment diagram indicates that the process can accommodate the change without impacts to other processes represented in the diagram.

As a secondary issue, EDF-R also observes that CAISO’s current practice of publishing of the draft plan and its subsequent approval in March serves as a guidestone to developers as they prepare interconnection requests for the year’s Cluster Study window, which closes April 15. Given the changes proposed in CAISO’s interconnection process enhancements initiative, EDF-R thinks it is possible this timeline change will create more disruption during an already confusing transition in the generator interconnection space. However, EDF-R encourages CAISO to continue enhancements for identification and approval of long-lead transmission upgrades more in advance than done historically; such changes will fundamentally provide better and longer-term signals for generation siting and development decisions, making the transmission plan timeline changes less of an issue relative to the interconnection process timelines.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

EDF-R is very supportive of CAISO’s proposal to enable approvals of transmission projects needed beyond the current 10-year planning horizon. EDF-R requests the CAISO move ahead with evaluating, and if appropriate, bringing to their board for approval transmission upgrades needed to support the use of the higher electrification levels for the 2022-23 TPP, consistent with Joint Agencies recently updated assumptions. If tariff changes are required for CAISO to undertake binding transmission needs evaluation beyond a 10-year planning horizon, such reform, in line with the Federal Energy Regulatory Commission (FERC)’s proposed rulemaking on long-term and comprehensive transmission planning for the grid of the future, should be expedited. The 20-year assessment recently conducted by CAISO identified the need for several upgrades, some of which are long lead transmission projects.

For instance, EDF-R would like to bring to the CAISO’s attention the urgent need for a 3rd 500kv Devers-Colorado River line to continue to allow renewable development in the renewable rich Riverside County. This upgrade is indicated as a solution for multiple issues in the 20 year plan and will be necessary for CAISO to meet long term renewable targets.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

EDF-R requests CAISO provide greater detail on this proposal in the next turn of the paper. Has CAISO performed any analysis to identify to what level of effectiveness this proposal would have?
EDF-R believes this proposal has the potential to significantly complicate an already arduous interconnection process and would not support the proposal if proposals already in flight in the IPE initiative are expected to meaningfully address the foundational problem statement for this proposal.

Before CAISO undertakes this change EDF-R requests that CAISO make public an analysis of how much “policy tagged transmission” has been used by interconnection requests that do not meet the policy criteria. CAISO’s issue paper says that the “concept could potentially help where new capacity is created or capacity is currently available and not already allocated to resources in the queue” but it seems that a proposal as radical as withholding interconnection capacity should be justified with compelling empirical evidence.

In order to thoroughly vet this proposal, EDF-R requests that CAISO seek from PTOs the process and criteria they use for prioritizing transmission upgrades for new-resource interconnection vs. other work, prioritizing work between interconnection-related projects. For example, whether upgrades get higher priority based on: (1) First-come, first served; (2) original in-service date; (3) how many projects or how much capacity is depending on them; (4) whether they are RNUs (needed for interconnection) vs DNUs (needed for deliverability). It seems likely that if CAISO implements a process to reserve or withhold interconnection capacity the PTOs will naturally shift their processes for identifying which upgrades to initiate in what order. This process is already opaque to stakeholders, with only PG&E providing brief response to the question in CAISO’s Transmission Development Forum.[1] 

Finally, EDF-R suggests that if the CAISO moved forward with any version of an interconnection capacity withholding or reservation process, that the CAISO include with that proposal a complimentary “interim interconnection status” process, similar to the CAISO’s “interim deliverability status” process. An interim interconnection status process would ensure that transmission is used and useful as soon as it is available.

[1] http://www.caiso.com/Documents/ISOResponsestoCommentsMatrix-TransmissionDevelopmentForum-Jan212022.pdf question 5a

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

 EDF-R appreciates the CAISO’s efforts for transmission planning enhancements and recommends that the CAISO moves forward with any required next step for identification and approval of key upgrades required beyond a 10-year horizon, aligned with upcoming FERC reform on comprehensive and long-term transmission planning.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

Golden State Clean Energy (“GSCE”) does not oppose CAISO adjusting its TPP timeline. We appreciate the challenges associated with receiving TPP study inputs from the state energy agencies, and we support CAISO conducting a robust assessment of alternative solutions to identified transmission needs, especially given CAISO’s proposal in this initiative to expand its transmission approval authority to include projects needed beyond a 10-year study horizon. 

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

GSCE supports this proposal. We agree with the observation that major transmission development timelines can be challenging when CAISO is limited to a 10-year planning horizon because transmission permitting and construction can easily exceed 10 years. It is not only reasonable to expand CAISO’s approval authority to account for this reality, but also essential to getting the necessary infrastructure planned and built to meet California’s clean energy policy and reliability needs.

In addition, extending the approval timeframe beyond 10 years can provide other benefits such as smoothing the transmission development that will occur over the coming decades and ensuring that the infrastructure is available when new generation is expected to be needed. Limiting the transmission planning and approval process to only transmission that is needed to meet new resources planned for in the next 10 years creates a risk that California will not be able to meet its clean energy and reliability needs. These needs include mandates under SB 100, Governor Newsom’s executive order N-19-19 on carbon emission reduction in state government, Governor Brown’s executive order B-55-18 on carbon neutrality, and Governor Newsom’s letter[1] to the California Air Resources Board on July 22, 2022, on moving faster toward climate goals.

We request that CAISO further discuss the 20-Year Transmission Outlook’s role in this proposal. Beyond CPUC resource portfolios and CEC demand scenarios that may use study horizons longer than 10 years and create a need for this increased approval authority, CAISO has already started conducting transmission studies with a 20-year study horizon to complement the SB 100 Report process. GSCE has advocated for making the 20-Year Transmission Outlook more actionable by allowing it to drive transmission approval in the TPP. CAISO should use the instant proposal to frame its intent for future iterations of the 20-Year Transmission Outlook and discuss how that study may need to evolve to take full advantage of CAISO’s increased approval authority being proposed.

Lastly, we ask that CAISO clarify what it needs to change to enact this proposal and what impediments currently exist that prevent CAISO from approving transmission solutions for needs identified beyond a 10-year study horizon.

[1] https://www.gov.ca.gov/2022/07/22/governor-newsom-calls-for-bold-actions-to-move-faster-toward-climate-goals/

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

GSCE appreciates CAISO’s examination of policy-driven transmission development, how it affects the ability to interconnect resources now, and its impact on long-term resource planning and procurement. However, we are concerned that CAISO’s proposal to withhold transmission capacity for specific resources is flawed from both a legal and policy basis and is missing both a significant distinguishing factor and a clearly defined problem it intends to address. We recommend looking to other proposals to address identified problems that may have more sure legal footing. To the extent CAISO’s interconnection queue and deliverability allocation process is proving problematic for certain resources, then CAISO should be clearer about its concern for those specific resources and create a more targeted proposal.

In CAISO’s July 22 presentation as part of this initiative, it stated that withholding transmission service could address issues with “relying on it for any and all interconnection requests received through the generator interconnection request windows.”[1]  But what CAISO is describing as a problem is essentially the nature of open access transmission. This not only raises concerns with a proposal that intends to tackle that issue, but it also points to the absence of a well-defined problem.

Reserving transmission through a subscriber-based model, in contrast to transmission funded through the TAC, has proven permissible while still respecting open access principles. A subscriber-based model is more in line with CAISO’s discussion of withholding transmission service, so CAISO should examine how a subscriber-based model can be part of a solution here. CAISO has recently proposed to implement a new subscriber-based PTO model to facilitate the TransWest Express Transmission Project,[2]  which creates a timely opportunity to discuss more broadly how a subscriber-based PTO model could fit within CAISO transmission planning.

We appreciate CAISO’s willingness to propose bold reforms in order to ensure future policy-driven transmission is able to provide its intended purpose. However, we are hopeful that the proposal to increase CAISO’s ability to approve transmission solutions for needs beyond 10 years will lead to sufficient amounts of new transmission and thereby direct resource development towards the area targeted by new transmission. If CAISO continues to approve new policy-driven transmission assets in areas where needed policy resource types are known to be, then CAISO is already making an effort to interconnect specific future resources that meet policy objectives. Further, scenario planning and targeting least-regrets policy areas will also help ensure investments in policy-driven transmission are prudent.

[1] CAISO, Transmission Planning Process Enhancements presentation, at 18, July 22, 2022: http://www.caiso.com/InitiativeDocuments/Presentation-TransmissionPlanningProcessEnhancements-Jul222022.pdf.

[2] http://www.caiso.com/Documents/california-iso-receives-application-for-new-participating-transmission-owner-stakeholder-call-080122.html.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

GSCE appreciates CAISO undertaking this initiative and examining how the TPP needs to evolve to allow California to meet its long-term policy goals.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

LS Power supports the timeline adjustment provided that the changes do not negatively impact other related processes. 

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

LS Power supports assessing transmission needs beyond the current 10 year horizon. 

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

In general, LS Power supports the ISO considering transmission needs associated with specific state and federal policies and looks forward to additional detail being provided in the straw proposal.  It will be important that these transmission upgrades be eligible for the competitive solicitation process if they meet the applicable criteria, and this aspect should be explicitly addressed in the straw proposal. 

Additionally, LS Power believes that the ISO interconnection queue and associated transmission development should be technology neutral.  Coordination between the ISO, CPUC, and other state agencies on procurement activities could help ensure a more diverse resource mix that will meet policy directives without being overly prescriptive or limiting with regard to technology.  A diverse resource mix will provide additive benefits to California ratepayers as the market optimization will select the most economic resources for dispatch.  However, if a transmission asset is reserved for only one technology type the economic benefits may be stifled. 

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

LS Power does not have any additional comments at this time.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

LSA does not object to the CAISO’s proposal for the TPP timeline adjustment, based on CAISO statements during the stakeholder meeting that this will not delay issuance of Reassessment reports, or draft NQC/EFC values for the following compliance year.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

LSA strongly supports the CAISO’s proposal to allow approvals for major transmission projects needed beyond the current 10-year transmission horizon.  LSA still supports the two-part structure it proposed earlier, where lower-cost efforts for upgrades where need is not completely certain could be approved on a preliminary basis to shorten the development timeline, and final approval coming later when the need is more certain and heavier expenditures start to be needed.

LSA understands the CAISO’s concern with applying this concept where approved transmission projects are subject to competition, since this early work is usually part of the competitive package.  However, this concept would not confound that competitive process; the CAISO could hold that competitive solicitation as usual.

The preliminary work would be performed by the eventual winner, with the understanding that the winner would construct the project later after final CAISO approval.

This is really the case in practice anyway.  Today, the CAISO can always review the need for a project, and cancel if it is not found to be needed later even after the competitive award is made.  LSA’s proposal would simply make that process explicit, with the final approval given first for the preliminary work, and later for the project procurement and construction.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

LSA understands the reason why the CAISO is proposing this new policy for what we have called here “Applicable Resources.”  However, we have concerns about both the concept and the implementation feasibility.

Issues with the concept

Any new policy like the one proposed should only apply under strong state direction.  One model might be the new emergency generator-interconnection process, which relies on specific declarations by the Governor and approvals from state agencies. 

LSA is concerned that it is inconsistent with FERC open-access principles, and it would provide Applicable Resources privileges not afforded any prior technology.  In addition, it is not entirely clear which resources would qualify for this preferential treatment.  The discussion has focused so far on off-shore wind and imported geothermal and wind energy, but would other resources – e.g., pumped storage or large compressed-air storage, also longer-lead-time technologies – also qualify?

Moreover, more consideration should be given to alternative approaches for achieving these policy goals, such as CPUC directions to jurisdictional LSEs to contract for Applicable Resources earlier. 

If those resources have PPAs, they can qualify for high-priority positions in the CAISO’s TPD Allocation process under current rules in the areas where the additional capacity enables additional deliverability, without any special treatment (perhaps beyond a 1-year lag to allow the contracting to occur).

It is not that unusual in other regions (and has occasionally occurred in the CAISO area) for off-takers to contract with resources even before formal studies are available, with specified Network Upgrade limits.  If the later studies find that upgrades exceed the specified limits, the developer or off-taker can agree to absorb the additional amount, or the contract can be canceled.  This type of structure can be used to enable earlier LSE contracting with Applicable Resources, so preferences in the TPD Allocation or Interconnection Studies processes are not needed.

If a preferential policy is implemented, LSA supports use by other resources of capacity approved for Applicable Resources:

• To the extent that it exceeds capacity needed for the Applicable Resources.  Transmission projects are “lumpy” and/or can enable capability elsewhere in the system from Applicable Resource location.  That additional capability should be made available to other resources.

• On a temporary basis, until the Applicable Resources are constructed and operating – e.g., to enable Interim Deliverability, or earlier interconnection than would otherwise be accommodated.  This temporary use can be especially helpful in the early years, when solar and wind resources will still retain significant RA value under ELCC, exceedance, or other counting methodologies that may be adopted.

Finally, this policy should apply only to new approved CAISO system capacity.  Capacity enabled by previously approved transmission projects was not approved only for Applicable Resources, and projects already in the queue are depending on it to acquire or retain their deliverability.  It would be highly inequitable for the CAISO to effectively change that purpose after the fact.

Implementation feasibility

Generally, as explained further below, LSA is concerned that some of the new capacity may be set aside for Applicable Resources that may not eventually materialize, or may not materialize in the locations where the CAISO has assumed (and has planned transmission to accommodate them).  There should be a process for ongoing review of approved transmission projects that would allow for “release” of this capacity to use by other technologies, using transparent criteria and timing.

With respect to CAISO-area Applicable Resources, LSA requests that the CAISO more fully consider and describe how this policy would be applied.  Policy-Driven Upgrades approved in the TPP could enable interconnection and/or deliverability of Applicable Resources.  However, most of the discussion at the stakeholder meeting concerned only the TPD Allocation process, where the process could differentiate between the capacity available for the Applicable Resources that available for others. 

More details are needed about how this policy would be applied in the TPD Allocation process, but it seems like the policy could have to be applied also in Interconnection Studies, to the extent transmission was approved in a given area to enable interconnection of Applicable Resources, and not just deliverability.  The CAISO should explain whether the new policy will apply to Interconnection Studies and, of so, how the current study process would be affected.

With respect to imported Applicable Resources, there are several areas of significant uncertainty.  It seems like the new policy would enable additional imports of Applicable Resources through:

• Approving additional Maximum Import Capability (MIC) along transmission paths connecting to the expected intertie points for these imported resources; and

• Reserving the additional MIC only for CAISO-area LSEs having PPAs with those resources. 

As with the TPD Allocation and other internal processes, LSA requests that the CAISO better describe the mechanics of this process for imports.

Fundamentally, the CAISO may approve MIC to accommodate wind or geothermal imports, but the capacity in the transmission lines expected to carry that energy may not be built, or may be used to deliver energy elsewhere or from other technologies.

The eventual construction of transmission resources elsewhere to transmit electricity to the CAISO is still very much an open question.  Several sponsors are vying to build projects, and it’s unclear whether the capacity the CPUC and CAISO are forecasting will be built.  Moreover, most of that capacity goes through other areas with renewable-energy requirements, so even if these projects are built, some of the energy may be “dropped off” on the way and not reach the CAISO.

In addition, the CAISO cannot control the resources that use any transmission lines that are eventually built.  For example, many of the areas with high wind-energy potential – one resource cited as an Applicable Resource – also have significant solar potential. 

This means that, as noted above, it will be important for the CAISO to continually monitor how resources are contracted and developed, and the progress of out-of-area transmission projects, to release the expanded MIC for use by others if it turns out not to be needed in the amount or on the transmission path for which it was approved.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

LSA has no further comments.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

NextEra Energy supports the CAISO having extra time to properly conduct its TPP studies.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

NextEra Energy supports study of projects beyond the 10-year planning horizon.  NextEra Energy looks forward to additional proposal details about which projects indicated beyond 10 years would be promoted for approval by the CAISO. 

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

NextEra Energy appreciates the CAISO taking up this issue and agrees that it is beneficial to consider policies to ensure that the uses of the transmission capabilities are not at cross purposes with those for which the transmission was approved. NextEra Energy looks forward to further details on the CAISO’s proposal, including clarification on how the CAISO would treat resources already in the queue which are aligned with the policy portfolio. It is beneficial to encourage commercial development that has been initiated consistent with the policy portfolios. Yet it may also be beneficial to allow CAISO queue resources that match the policy objectives to have access to planned transmission upgrades rather than preclude them simply as a result of those projects preceding the CAISO study and approval of new policy projects.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

 NextEra Energy has no additional comments.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

No comment at this time.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

No comment at this time.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

Market conditions and planned resource portfolios can change over time; the ISO should reassess policy capacity allocation in each planning cycle.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

Northern California Power Agency (NCPA) appreciates the opportunity to comment on enhancements to the Transmission Planning Process; no additional comments at this time.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

OWC understands the need for the proper amount of time to address the “increasing load and resource requirements in the California Energy Commission (CEC) high electrification demand scenarios and California Public Utilities Commission (CPUC) associated resource portfolios” when releasing the draft transmission plans each year.

OWC is interested in working with CAISO to identify and recruit the resources required within the industry to study these cases and allocate the proper time needed when developing transmission plans going forward. Resource training of power engineers to create a pipeline of talent working with academia in future years will be imperative to meeting clean energy goals set forth by California. In addition to increasing resources for these planning efforts, OWC encourages CAISO to maximize use of transmission studies being conducted by OWC members, academic institutions, and the federal government. For example, the Pacific Northwest National Laboratory is currently studying coordinated, planned offshore transmission systems.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

OWC supports the process enhancement to develop a mechanism to the plans for and approve projects needed beyond the current 10-year planning horizon. Extending the planning horizon and approving projects in advance of a 10-year planning horizon will be beneficial for the planning of offshore wind farm interconnections, as some upgrades are expected to have a full timeline of study, implementation and installation of greater than 10 years. These public policy transmission needs must not only be studied, but moved to solicitation and award phases so that investments in the grid can be made now and planned to by offshore wind developers.

This planning should not be limited to onshore transmission. Expansion of the grid, both offshore and onshore, is needed to ensure that the state’s legislated climate and energy policies can be met in the most efficient and cost-effective manner, ensuring just and reasonable rates. Lessons from the East Coast and a large and growing body of studies from the United States and around the world demonstrate that transmission planning can enable offshore wind that is much more capable and cost effective, while increasing system reliability and mitigating environmental impacts and conflict with other ocean uses. Such plans can also avoid expansive and difficult to site and construct onshore upgrades. Submarine HVDC cables and conversion stations, development of new 500-kV substations and other long lead time transmission projects will need to have construction start dates in the next year or two to have a chance to be ready to meet clean energy goals required in the early 2030s. Approving the projects to start before the current 10-year planning horizon is necessary. Start dates for construction should be identified and work commenced on time to meet policy goals.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

OWC particularly applauds CAISO creating this mechanism to retain capacity for the policy purposes it was originally developed for. To fully harness the benefits of offshore wind, transmission upgrades will be required on the CAISO grid. This will include reinforcements to existing electrical facilities along with the creation of new transmission and substation infrastructure.

When it is identified that these transmission upgrades are required to reliably interconnect offshore wind, the capacity either freed up or developed for offshore wind should be retained by those wind farms to interconnect. Providing this mechanism and assurance to the offshore industry will help towards meeting clean energy policies.

This also comports with rules recently approved outside of the PJM Tariff under which the Federal Energy Regulatory Commission is allowing the reservation for high priority uses of onshore and offshore transmission facilities procured directly by the State of New Jersey with the support of the PJM regional transmission organization (See PJM Interconnection, L.L.C. 179 FERC ¶ 61,024 at PP 9 and 40 (2022)).

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

Offshore Wind California (“OWC”) is a trade group of more than 40 companies, including offshore wind developers, technology providers, and consultancies committed to the responsible development of offshore wind power in California. OWC appreciates the opportunity to comment on the California Independent System Operator (“CAISO”) Transmission Planning Process Enhancements.

The National Renewable Energy Laboratory (“NREL”) reports that California has 200 gigawatts (“GW”) of technical potential for generating offshore wind power. The Joint Agency Senate Bill 100 Report (“SB 100 Report”), issued in March 2021, concluded that to reach its goal of 100% clean energy by 2045 California will need to develop a diverse portfolio of renewable energy that includes offshore wind. The “SB 100 Core Scenario” called for 10 GW of offshore wind by 2045, or as much as the model would allow. The California Energy Commission’s (“CEC”) August 2022 report now recommends 2 to 5 GW of offshore wind by 2030 and 25 GW by 2045. Governor Newsom has recommended similar goals of “at least” 20 GW of offshore wind by 2045.

Offshore wind power can provide clean, reliable energy that complements the state’s solar and other renewable resources and helps keep the lights on for Californians throughout the year. Building offshore wind power capacity will create thousands of high-wage jobs, create new domestic supply chains, enable California to cost-effectively meet its 100% clean energy goals, and also help the state manage its growing climate risks. These benefits can be achieved while protecting marine life and ocean resources. Realizing the full benefits of offshore wind development off the California coast will require sustained federal and state support for deployment at scale. Economies of scale will be key to driving down costs, delivering competitively priced clean power, and encouraging industries and jobs to locate in our state.

OWC Supports CAISO’s Transmission Planning Process Enhancements

The CAISO’s Transmission Planning Process Enhancements initiative presents an important step towards cost-effectively meeting California’s clean energy needs. OWC and its members are pleased to see a long-term, strategic transmission planning approach. The CAISO’s effort demonstrates its commitment to help achieve a re-imagined, resilient, and reliable grid that provides the necessary enabling infrastructure necessary to meet the state’s legislated climate targets and energy policy. The three parts of the initiative include:

1. Adjusting the timeline for the release of the draft transmission plans.
2. Retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.
3. Coordinating with other planning processes to enable timely approvals for major transmission projects with development timelines that extend beyond the current 10-year planning horizon.

OWC supports all three of these parts of the initiative to streamline the transmission plans, which should improve processes to incorporate offshore wind into the future generation mix of California in coming years.

OWC appreciates the opportunity to provide comments on the CAISO’s Transmission Planning Process Enhancements and looks forward to continuing to support the CAISO’s efforts.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

In general, it is reasonable to give CAISO two more months for reviewing and approving the reliability, policy, and economic driven projects, considering the complication of resource and load demand changes. However, there will be some unintended consequences on multiple milestones in both the TPP and GIP processes. For example, the PSLF model/Base Case Development starts in January annually and relies upon the CAISO Transmission Plan to finalize the grid topology model by including the newly approved projects. If the Transmission Plan were to be deferred two months, the final TPP base cases will also be postponed. As a consequence, NERC-required P1-P7 outage files for TPP assessment will have to be deferred as well, as these rely upon the final TPP base case topology. With base cases and contingency files delayed, the kick-off of the annual assessment study and CAISO Request Window may need to be adjusted, too. In addition, the GIP reassessment base case timeline will also be impacted due to the need to include newly approved TPP projects in GIP models. In summary, adjusting the timeline for draft and final CAISO Transmission Plan will lead to adjustments for other critical timelines in both the TPP and GIP processes. PG&E recommends CAISO create an overall plan for the potential milestone timeline changes in the TPP and GIP processes.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

Generally, PG&E supports CAISO’s proposed TPP enhancement to allow for approval of major long lead-time transmission projects needed beyond the current 10-year planning horizon.  However, PG&E believes it is vital the load forecasts used as the basis for identifying long-lead time transmission projects be improved. PG&E will continue to engage in the CEC’s IEPR process to support and provide feedback on forecast development. Specifically, PG&E recommends CAISO and PG&E continue working with the CEC to incorporate the following forecast attributes:

• Forecasts reflect the expected impact of transportation electrification and building electrification policies currently in development at the state level (e.g., California Air Resources Board) and at the regional level (e.g., Bay Area Air Quality Management District). These policies can have transformational impact on grid demands, especially in the 2030s and beyond.
• Forecasts extend 20 years from the present year (e.g., 2023-2042 for the upcoming forecast cycle) so planners can understand likely grid needs beyond the 10-year planning horizon.
• Future TPP iterations rely on more analytically robust load distribution methods. Insufficiently robust forecasts could trigger unnecessary transmission capacity projects in some locations and insufficient transmission upgrades in other locations.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

N/A

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

N/A

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

REV Renewables (REV) supports including this issue in scope. REV agrees it may be necessary to change the timeline for approval of the final plan in order to allow for sufficient time to conduct analysis for the plan.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

REV supports including this issue in scope. REV applauds CAISO for considering how to approve transmission projects that have long-lead times. California has significant energy resource needs in order to meet its 100% clean energy goals and, given the long timelines for planning and constructing transmission projects, it may be necessary to approve projects that have a need date beyond the standard 10-year planning horizon.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

REV supports including this issue in scope. REV supports proactive transmission planning for policy-driven upgrade needs since transmission availability will be an important part of enabling California to meet its clean energy goals. However, as stated in the Interconnection Process Enhancements Initiative, REV highlights that CAISO’s interconnection queue and transmission capacity development should be technology neutral and CAISO should not withhold any capacity for any projects studied in any process.

While some specific resource types may be identified in the CPUC portfolios, if these transmission projects are funded by ratepayers (vs. merchant transmission or interconnection upgrades) then it would be discriminatory against other projects to have capacity reserved for specific generators. REV suggests that any generation project that helps meet the state’s overall policy goals should be allowed to interconnect to a policy-driven transmission upgrade. The Tehachapi Renewable Transmission project, for example, was designed to and successfully delivers significant amounts of wind resources to customers. However, access is not restricted to wind only and Tehachapi also delivers solar and storage. If CAISO identifies a need for a transmission line or upgrade for specific resource types, it is likely that those resources will be a significant portion of the mix, but REV does not think it is just or reasonable to limit access to a ratepayer funded line from other projects that could also benefit ratepayers.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

REV has no further comments at this time. 

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

SDG&E appreciates the opportunity to provide comments on the proposed changes to the CAISO’s Transmission Planning Process. SDG&E supports the CAISO’s initiative to adjust the timeline of the transmission plan in anticipation of the volume and complexity of alternative analysis. SDG&E believes that the proposed timeline adjustment should fall under phase 2 of the transmission plan. SDG&E notes that the added volume and complexity will not only affect the CAISO but also the PTO’s timeline to complete the technical studies. For instance, it is not clear if the California Energy Commission (CEC) will publish a 20-year load forecast, addition scenarios and study year will require time for analysis, and lastly it will require time to request for cost estimates.  

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

SDG&E appreciates CAISO’s efforts to forecast transmission needs to achieve California’s 2045 goals. Such an effort is necessary due to the long lead times associated with transmission development. SDG&E supports advance approvals for major long lead time transmission projects. Given that loads and resources will gradually materialize on the electric grid to reach the levels forecasted, some of the transmission upgrades will be needed sooner. Since it can take more than 10 years to build long-lead transmission projects, relying on the current 10-year TPP framework means that we might already be behind. Therefore, it may be important to approve many of the transmission projects with longer lead times identified beyond the 10-year planning horizon. SDG&E notes that there are concurrent proceedings at CPUC and FERC where it may be necessary to coordinate any resulting long term planning horizons.  

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

SDG&E understands that this proposal would effectively reserve space on policy-driven upgrades for the deliverability of long-lead time resource interconnections as identified in applicable resource plans. While certain aspects of this concept may be applicable today, these are valid ideas that would be good to carry over to any extended planning horizon. Further, SDG&E would support such a process as it provides more certainty during the development of such resources.  

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

SDG&E recommends that the CAISO consider charging constraints in the evaluation of CAISO system transmission upgrades, including those identified in interconnection studies. The CAISO’s interconnection process for energy storage performed under the Generator Interconnection and Deliverability Allocation Procedures (“GIDAP”) will only consider discharge mode consistent with CPUC counting rules for deliverability studies. The reliability studies performed under GIDAP consider charging mode but do not require upgrades for transmission congestion constraints that can be mitigated with congestion management. Additionally, the charging constraints that are assumed to be mitigated by congestion management.  

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

The Six Cities do not have comments on this topic, other than to confirm that they do not oppose the proposed revisions to the timeline for the draft transmission plan. 

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

The Six Cities appreciate the CAISO’s concern regarding the timing for approval of long lead time projects, but more details are needed on the CAISO’s proposed approach.  The Issue Paper does not clearly specify whether the CAISO is simply advising stakeholders of a change in its existing practice regarding project approval under its current tariff authority, or whether it is proposing different or additional tariff authority related to the approval of long lead time projects.  Additionally, the Issue Paper does not include any details regarding how the CAISO will evaluate and approve such projects or what protections the CAISO proposes to implement to assure transmission customers that only “least regrets” projects are authorized. 

The Six Cities reiterate that premature approval for costly and speculative transmission projects has adverse ramifications for customers, which may be exposed to abandonment charges incurred by the project developer in the event a project is cancelled.  Additionally, approval of projects on a long-lead time basis may make it challenging for the CAISO and transmission developers to react to changing needs.  For these (and likely other) reasons, it will be critical for the CAISO to develop sound criteria for how it proposes to evaluate and authorize long lead time projects in the TPP.  The Six Cities urge the CAISO to include more details regarding its proposed approach in the next iteration of its proposal. 

Additionally, as the CAISO is likely aware, the Federal Energy Regulatory Commission (“FERC”) is undertaking a rulemaking in Docket No. RM21-17-000, addressing Electric Regional Planning and Cost Allocation and Generator Interconnection.  Among other proposed policies, FERC’s NOPR addresses long term regional transmission planning.  Stakeholders would benefit from understanding the CAISO’s thinking on how the policies addressed in the FERC proceeding, if adopted, would interact with the proposals in this initiative.  It may be prudent to await completion of the FERC rulemaking process on this topic before developing tariff requirements for long lead time projects. 

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

The Six Cities acknowledge the challenges of synchronizing the transmission planning process, the various elements of the generator interconnection process, and the resource procurement activities of load-serving entities.  The Six Cities also acknowledge the CAISO’s creative thinking on the alignment of these three interrelated aspects of planning and procurement. 

As the CAISO evaluates approaches to addressing this issue, the Six Cities urge the CAISO to consider that procurement to comply with state policy objectives is not undertaken solely under the direction of the CPUC.  Rather, there are other local regulatory authorities within the CAISO footprint that have jurisdiction to oversee compliance with state goals.  In performing planning studies, there may be value to considering whether the policy portfolios provided by the CPUC reflect procurement approaches by non-CPUC jurisdictional LSEs. 

In the event that the CAISO determines to proceed with its concept of reserving the capacity associated with policy-driven transmission projects for projects that are associated with or advance state or federal policies, the Six Cities request that the CAISO consider how and on whose behalf the transmission capacity associated with policy-driven transmission projects will be made available, particularly given that the costs of upgrades on the CAISO-controlled grid are funded by all CAISO transmission customers, not just those that are CPUC-jurisdictional.  What entity would be making a determination that a particular resource has been procured for any specific purpose?  Would reserved capacity be provided to CAISO LSEs on a pro rata basis for use in their procurement, or would the reserved capacity be made available to projects meeting criteria?  If the latter, which entity would determine the projects that should be allocated capacity based on satisfying policy goals?

The Six Cities also observe that the CAISO’s proposed approach has potentially significant implications for the transmission plan deliverability allocation processes and its maximum import capability (“MIC”) allocation processes.  If the CAISO intends to hold capacity for policy driven projects, then the CAISO may also need to ensure that there is deliverability and/or MIC available for these projects, or there may be continued misalignment between transmission planning and resource procurement. 

In short, additional details are needed for stakeholders to fully assess this proposal. 

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

The Six Cities have no additional comments at this time.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

SCE appreciates the complexity of analysis that CAISO highlights in their proposal and would like to highlight a few concerns for CAISO consideration.

Each year’s Transmission Planning Process begins with the development of power flow base cases that are intended to best capture the characteristics of the bulk system for both near-term and long-term planning studies. The current cadence of planning cycles allows the approved upgrades from the previous planning cycle to be incorporated into assumptions for the base cases of the subsequent planning cycle. Delaying the approval of the transmission plan in year 1 will either result in a delay for the base cases of the year 2 plan to be developed, which further compresses that study schedule, or would cause the year 2 assumptions to exclude approved projects, which will likely identify those same needed mitigations again. SCE therefore requests that the CAISO explain how the delayed approval of a given transmission plan will coordinate with the following planning cycle.

SCE is further concerned that a two-month delay in the approval of a project identified as needed in a transmission plan will result in a two-month delay in starting execution of a project. Given the challenges of work sequencing and outages, the in-service date of a transmission project whose approval has been delayed by two months would likely be adversely impacted. SCE has been working through challenges to timely project completion amidst factors such as supply chain delays, permitting uncertainty, and an increased and evolving cyber threat environment. Further delays will exacerbate these challenges and highlight the importance of identifying and approving needed projects with adequate project execution time.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

SCE shares the concern that major long lead time transmission projects may take more than 10 years to build and supports approval of projects outside of the 10-year planning horizon provided that these projects follow the same approval steps, including stakeholder feedback and opportunity to submit project alternatives.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

SCE does not support the CAISO retaining transmission capacity for specific resources due to concerns that it violates open access principles. In addition, it would be uneconomic and customer affordability will be negatively impacted if transmission capacity that is paid for by CAISO customers is underutilized or reserved for projects that are not operational. The CAISO Tariff already allows entities, such as generators, to pay for transmission capacity outside of TAC and receive the benefits of a given merchant transmission project that may be developed to access specific policy resources.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

SCE has no further comments at this time.

1. Please provide your organizations comments on adjusting the timeline for the release of the draft transmission plan from the end of January to the end of March, targeting approval in each year’s May Board of Governors meetings.

The Center for Energy Efficiency and Renewable Technologies (CEERT) supports adjusting the timeline for the development and release of the CAISO’s annual transmission plan.  The proposed change in the schedule needs to be closely coordinated with the California Energy Commission and the California Public Utilities Commission. 

We agree that the complexity of analysis required for the annual Transmission Plan has increased recently and that it will be very useful to incorporate evolving information about changes in load dynamics with the increased electrification of transportation and buildings on the horizon.  Also, the CPUC appears to require more time to coordinate the development of a preferred system portfolio that includes consultation with the many load serving entities in California.

Finally, the CAISO should take the opportunity of a lengthened planning schedule to engage in more extensive consultations with other balancing area authorities in California as well as WestConnect and Northern Grid on interregional transmission opportunities that will be mutually beneficial.

2. Please provide your organizations comments on enabling approvals for major long lead time transmission projects needed beyond the current 10 year planning horizon.

CEERT supports the adoption of a 20 year planning horizon in the transmission planning process. Twenty years would greatly improve the ability of transmission planners, load serving entities and project developers to assess and advance the many transmission opportunities that will be needed to meet California’s clean energy goals as articulated in SB 100 and elsewhere.  Governor Newsom has recently communicated with the Chair of the California Air Resources Board (CARB) regarding the manifold challenges that climate change poses for California.  He has stated that CARB “must lay out a clear path to achieve both our 2030 climate goal and statewide carbon neutrality by 2045’.[1]

A 20 year planning horizon for the annual transmission plan is also consistent with the recommendation of the Federal Energy Regulatory Commission in its recent Notice of Proposed Rulemaking regarding “Building for the Future Through Regional Transmission Planning and Cost Allocation and Generator Interconnection.”   The CAISO’s adoption of a 20 year planning horizon would be exemplary for public utility transmission providers. 

California’s resource planners and load serving entities are considering procurement of multiple advanced renewable technologies including geothermal, offshore wind and longer-duration energy storage including thermal energy storage coupled with concentrating solar power.  A 20-year planning horizon for transmission would enable more effective planning and development for these technologies which will be important in meeting California’s decarbonization goals.

The CAISO’s recent 20-Year Transmission Outlook demonstrated the value of a longer-term planning horizon. The CAISO Board would be well advised to incorporate the insights obtained from this planning document into its annual transmission planning process.

[1] July 22, 2022 letter from Governor Gavin Newsom to Liane Randolph, Chair, California Air Resources Board.

3. Please provide your organizations comments on retaining policy-driven transmission upgrade capacity for the specific policy purpose for which it was developed.

The CAISO’s transmission planning process already assesses the need for developing policy-driven transmission based on the resource portfolios provided periodically by the CPUC as part of its Integrated Resource Planning process.  It would be beneficial for the CAISO to augment its current assessment of policy-drive needs through regular reviews of the interconnection queue and the cumulative impact of interconnection requests on specific geographic zones. 

Likewise, it would be beneficial for the CAISO to periodically assess the procurement activities of load serving entities.  The CAISO has initiated this type of consultation as part of its 2021-22 Transmission Plan related to interest in procuring out-of-state wind resources.  A more structured assessment of procurement activities could provide the CAISO with more insight about the interest in and viability of projects in the interconnection queue.

The CAISO notes in its interconnection process enhancement that the issue of improving alignment between the interconnection process, procurement activities and long-term transmission planning was important but specific actions were deferred for consideration in that venue.  We believe the transmission planning enhancement venue is the appropriate location for investigating improving alignment between these related resource development processes.  Coupled with a longer-term planning horizon, improved coordination of transmission planning and resource procurement can better assure that California’s policy objective are met in a timely manner.

Reserving specific elements of transmission capacity to support the development of long lead-time resources like offshore wind and geothermal deserves to be considered in the transmission planning process.  Similarly, policy goals such as promoting clean energy development in less economically advantaged regions of the state with high resource potential like the Central Valley should also be considered in the transmission planning process.  The upcoming straw proposal should identify with some specificity how these public policy considerations can be balanced with contributions to system reliability and economic benefits of developing regional transmission projects.

4. Please provide additional comments your organizations has on the transmission planning process enhancements initiative.

CEERT believes there are opportunities to improve coordination in transmission planning among California’s balancing authorities including with the Los Angeles Department of Water and Power (LADWP), the Balancing Authority of Northern California and the Imperial Irrigation District. Previous collaborations have resulted in new beneficial projects such as an upgrade of the Victorville-Lugo transmission line with LADWP and the upgrade of the Imperial Irrigation District’s S. Line.   More extensive collaboration with these balancing area authorities as well as with WestConnect and Northern Grid could result in more expeditious development of transmission projects that would benefit electric power consumers across the Western United States.