Comments on draft transmission plan

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

ACP-California appreciates the opportunity to comment on the Draft 2022-2023 Transmission Plan and stakeholder call. ACP-California welcomes and strongly supports the CAISO’s more proactive and forward-looking approach to approving transmission in the 2022-23 TPP cycle, where the 30 MT Sensitivity Case (in addition to the base resource portfolio) was considered, where possible, in the selection of new transmission projects recommended for approval. This represents a more proactive approach to transmission planning than we have seen in the past and this type of approach is critically important to continue, and build on, in order to meet the infrastructure challenges that the state and the region are facing to bring new resources online to meet policy and reliability needs. As discussed below, proactive transmission planning is even more important given the delays we have seen in PTOs bringing approved projects online. Finally, we support CAISO’s efforts to explore transmission partnership opportunities and creative solutions and we encourage continued work on this front.

ACP-California is encouraged to see CAISO’s more proactive approach to transmission planning taken in the 2022-23 Draft Transmission Plan. In the 2022-23 Draft Transmission Plan CAISO has used the base case portfolio as the basis for project approvals but has also looked to the sensitivity case to help “right size” the proposed solutions. By using the sensitivity studies to advise approvals, CAISO may “get ahead” of the anticipated needs in next year’s TPP, allowing the better identification of transmission projects that are necessary to maintain the reliability of the ISO transmission system and unlock access to renewable resources to meet California’s energy needs.

This is critical for a number of reasons. For starters, it is efficient and represents prudent planning, given that the sensitivity case is far more reflective of the longer-term direction of the system (as compared to the base case in this cycle). Thus, right sizing proposed transmission to the long-term direction of the system will likely result in overall savings to ratepayers. Relatedly, the CAISO acknowledges its efforts to date to study transmission alternatives to facilitate offshore wind in the north and central coasts, as well as its intention to make decisions about these alternatives in the next transmission planning cycle. Following two cycles of sensitivity analyses, we are pleased that such projects will be considered for approval next cycle and expect the CAISO’s past analyses will help right-size projects and accelerate approvals to ensure offshore wind projects can be online on time.

Additionally, a more proactive approach to transmission approvals is imperative given the substantial delays that continue to be experienced by the PTOs in permitting and bringing approved transmission projects online. We appreciate the work CAISO has done in seeking to address these delays, such as hosting the Transmission Development Forum and also appreciate work ongoing in multiple venues to try to reduce these delays. However, this issue continues to create challenges in bringing new generation on to the system and it is essential for CAISO, the PTOs and stakeholders to seek to identify and implement other solutions to ensure timely transmission permitting and approval going forward. Given the significant delays that are being experienced, and the potential for them to be further exacerbated by ongoing supply chain issues, it is crucial for transmission projects to be approved as soon as possible, so that work can commence in permitting, construction and operationalization of the lines. We therefore commend CAISO for being more proactive and welcome continued work in this area in the future.

In the 2022-23 Draft Transmission Plan CAISO notes several projects where it is exploring partnership opportunities, such as SWIP-North and the Pacific Transmission Expansion Project (PTEP). We urge CAISO to continue to explore these projects, the potential for project partnerships on them and to engage in  other creative transmission partnerships and solutions to bring renewable resources to California markets (such as what CAISO is doing with the Subscriber PTO process).

ACP-California commends the CAISO for all the work it has performed to-date on the 2022-2023 TPP and looks forward to continuing our engagement on these important issues, including in the upcoming 2023-34 TPP.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Advanced Energy United appreciates this opportunity to submit comments regarding the draft 2022-23 Transmission Plan.

Advanced Energy United is a national trade association with over 100 member companies across the clean energy landscape, from large-scale renewable energy and transmission developers to providers of distributed clean energy resources, grid services and technologies. United members are highly impacted by the Transmission Plan as providers of transmission solutions,  generators and offtakers of clean energy, and participants in energy markets.

In general, United is pleased that the Transmission Plan proposes a robust suite of transmission solutions to the daunting challenge of the clean energy development needs identified by the California Energy Commission (CEC) and Public Utilities Commission (CPUC). The projects identified in the Plan will help unlock tremendous clean energy resources across the state, strengthen energy and capacity trading opportunities across the West, and facilitate the integration of responsive, distributed energy resources in local communities. In short, this draft Transmission Plan is a response commensurate with the scale of the challenge.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

1. Support for tighter linkage between CAISO and California energy agencies, and between planning and procurement

United is pleased to see the benefits in this draft Transmission Plan (TP) of the tighter coordination between the ISO and California energy agencies as outlined in the December 2022 Memorandum of Understanding (MOU). That MOU was significant in that it builds on the longer-term statewide clean energy planning required by SB 100, incorporates the additional proactive resource planning capabilities at the CEC, memorializes the increased geographic specificity (busbar mapping) of the CPUC’s resource portfolios, and proposes tighter linkages between planning and procurement.

This last point is of critical importance, and it is a still nascent goal in the process of being operationalized at both the CPUC and CAISO. United appreciates CAISO’s re-iteration of its commitment to pursuing revisions to its interconnection process to prioritize resources with the operational characteristics and geographic locations consistent with the CPUC’s resource planning.

United believes the importance of this initiative can be substantiated with additional analytic output from the TP. Specifically, United recommends that where possible the CAISO highlight in the TP areas where such consistency is particularly important to the plan’s conclusions. In other words, if resource procurement or interconnection were not consistent with the CPUC’s resource portfolios in a given region, would the conclusions regarding transmission constraints and deliverability be materially different?

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

1. Addressing long-known constraints

United applauds CAISO for addressing major transmission constraints for the development of priority resources identified in multiple previous CAISO and state conceptual planning exercises, dating at least to the RETI 2.0 exercise in 2016-17. These include accessing the substantial renewable resources of the San Joaquin Valley, north of Lugo area, the Imperial Valley, and Eastern San Bernadino and Riverside counties.

Further, the substantial investments in new and re-conductored 500 kV lines between the LA Basin and southern Nevada and, through the Imperial Valley, to eastern Arizona are a critical investment to resolve long-known constraints to increased imports from out-of-state resources. United strongly supports both the technical advantages of strengthening linkages to the southwest, as well as the market signal this represents in the state’s openness to out-of-state resources and increased cooperation in both power and capacity transactions.

2. Preferred Resources, Grid-Enhancing Technologies, and Non-Wires Alternatives

United strongly supports the consideration and integration of solutions to transmission constraints that leverage the capabilities of preferred resources, grid-enhancing technologies, and other non-wires alternatives (NWAs). We are concerned however that the TPP methodology for identifying and evaluating NWAs is opaque and potentially outdated, and we urge CAISO to include greater data and explanation of where and how NWAs were evaluated.

The final Study Plan for the 2022-23 TPP discussed preferred resources, including energy efficiency, demand response, renewable resources, and energy storage, and the evaluation methodology that CAISO initiated in 2013. The Study Plan attests that the methodology has been used in a limited number of special areas for specific local capacity areas conducted in certain years – including the Moorpark study in 2017 and the Oakland Clean Energy Initiative in 2018. The Study Plan states that the TP’s reliability assessment would evaluate the use of NWAs from a universe of resources comprising a) existing DR capacity, b) CEC’s projection of uncommitted energy efficiency, and c) CPUC-authorized storage procurement as mitigations. Lastly, the Plan promises that any storage identified as a transmission solution would be “for informational purposes only and clearly documented,” and that such options could be “pursued through a resource procurement process. In some situations, the storage could be approved as a transmission asset.”[1]

United notes that the final Transmission Plan does not in fact identify any targeted preferred resource deployments as mitigation. In fact, the TP mentions projects where previously-identified storage solutions are recommended for cancellation or reconfiguration.[2] We are concerned that, even after many years of effort, the consideration of preferred resources is lagging its potential. Accordingly, United suggests that CAISO:

• Provide greater clarity on the potential for storage as a transmission asset (SATA), either by re-opening the SATA initiative or explaining in the TP the criteria or general principles that could justify the CAISO’s approval of storage as a transmission asset.
• Update its methodology for evaluation of preferred resources, especially regarding the functionality of aggregated DERs or Virtual Power Plants

United also urges CAISO to provide greater clarity regarding the consideration of Grid-Enhancing Technologies (GETs), including dynamic line rating, advanced power flow control technologies, and topology optimization. GETs can be used to address constraints and unlock critically needed transmission capacity in the near term.  A 2021 granular industry assessment[3] looked at the Southwest Power Pool system and found that deploying GETs could enable 2 adjoining states (Kansas and Oklahoma), to integrate 5,200 MW of wind and solar generation currently in interconnection queues by 2025 without any new large-scale transmission buildout, more than double the development possible without the technologies. This GETs deployment also created $175 million in annual production cost savings. 

United would like to draw attention to the CAISO’s own comments to FERC in 2020, contending that RTO/ISOs specifically detail the consideration of GETs and how they were considered and evaluated for application. “The CAISO believes greater focus on how transmission providers consider grid enhancing technologies in the transmission planning process may help identify opportunities to pilot and deploy grid enhancing technologies. For example, transmission providers could publish within their transmission plans a summary of efforts to deploy grid enhancing technologies and the barriers or challenges that exist to such deployment. This information would provide transparency regarding how grid enhancing technologies might increase the capacity, efficiency, or reliability of transmission facilities.”[4]

United agrees with this recommendation, and requests that the CAISO follow its suggestion to include specific discussion of how GETs are evaluated and their barriers to deployment.

3. Offshore wind scenarios

United understands that the base case CPUC resource portfolios transmitted for this TPP cycle do not include substantial North Coast offshore wind resources, and that the development potential of both Central and North Coast offshore wind resources are rapidly evolving in line with other state and federal planning processes. United supports the continued examination of transmission solutions that not only unlock these critical resources but also provide other critical system benefits. United looks forward to continued engagement on these opportunities in the 2023-24 Transmission Planning Process.

In the nearer term, United is supportive of continued investigation of the Pacific Transmission Expansion Project proposed HVDC line between Diablo Canyon and the LA Basin. United suggests that in its examination of this project, and in discussion with the Los Angeles Department of Water and Power (LADWP), that CAISO examine the potential for this project to deliver benefits for offshore wind development in the Morro Bay area beyond the 1.6 GW currently included in the CPUC resource portfolio, and in achieving goals for reducing local capacity requirements in the LA Basin.

[1] Final Study Plan, 2022-2023 Transmission Planning Process, June 30, 2022, section 2.8.1

[2] These include the North of Mesa and Wheeler Ridge Junction projects

[3] “Unlocking the Queue with Grid-Enhancing Technologies,” Brattle Group prepared for WATT Coalition, February 1, 2021

[4] Post-Technical Workshop Comments of the California Independent System Operator Corporation (at p. 2), Federal Energy Regulatory Commission Docket Number AD19-19-000 Grid Enhancing Technologies, February 14, 2020

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

1. SB 887 Local Capacity Areas analysis

In the draft TP, the ISO has done important work in laying a foundation for identifying the transmission needs necessary to deliver clean resources into capacity-constrained local areas and reducing the need for local gas-fired resources. Indeed, the plan proposes twelve projects that will increase capacity into these areas. Of particular note, the upgrades to existing 500 kV and 230 kV lines and addition of new 500 kV lines to the LA Basin and San Diego areas represent the potential addition of significant new clean firm and ramping resources that promise to be significantly helpful in reducing local capacity requirements.

However, United is disappointed that CAISO has taken a conservative approach in valuing just the local capacity value of these projects. There appears to be sufficient information available to begin planning for the transmission impacts of gas-fired local capacity curtailments or retirements. For instance, the Aliso Canyon special study presented in Appendix K examines the transmission implications of substantial gas curtailments in the LA Basin and presents potential transmission project mitigations. United urges CAISO to continue this analysis to begin identifying projects that address these contingencies in the event of significant reduction of local gas-fired generation. As a specific and near-term example, it appears from the Aliso Canyon analysis that the Pacific Transmission Expansion Project would offer significant benefits to alleviating constraints in the event of reduced in-basin gas generation that are not currently considered in the reliability-, policy-, and economic-driven considerations of this project. United urges the ISO to include these benefits in its evaluation of this line as discussion with LADWP continues.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on the Draft 2022-2023 Transmission Plan (Draft Plan, hereafter), dated April 3, 2023.  The comments and questions below also address the material presented at the CAISO Stakeholder meeting on April 11, 2023. BAMx recognizes the tremendous amount of work the CAISO staff has completed in this planning cycle. BAMx also believes the CAISO staff must allow a corresponding amount of time to engage the stakeholders to explain the staff’s work.

BAMx supports several elements of the Draft Plan. For example, BAMx supports the right-sizing of the projects when the Base portfolio assessment triggers them to ensure that the capacity offered by the proposed transmission projects is adequate to accommodate resources identified in the Sensitivity portfolio. BAMx also supports relatively low-cost mitigation measures like power system control devices that balance the flow on the existing transmission network and the CAISO's consideration of a generic Battery Energy Storage System (BESS) to address potential violations of off-peak deliverability constraints. [See BAMx’s response to Q.3 and Q.4 for details].

On the other hand, BAMx opposes the Draft Plan’s recommendation to approve transmission projects based only on the need identified in the sensitivity portfolio. Per the CAISO's FERC-approved tariff, a Category 1 policy-driven transmission solution has to be identified to be needed "in the baseline scenario and at least a significant percentage of the stress scenarios." Since some of the projects currently recommended for approval are not identified as needed under the Base portfolio, they clearly do not satisfy the criteria for Category 1 transmission and, therefore, should not be approved during the current TPP cycle. Furthermore, the draft 2023-2024 TPP CPUC portfolios or any synergy with the CAISO 20-Year Outlook should not be used as criteria to recommend any projects as Category 1 policy-driven transmission solutions in the current TPP. They could be classified as Category 2 policy-driven transmission solutions and can be studied in subsequent transmission planning cycles. BAMx recognizes that the CPUC’s letter[2] to the CAISO, dated January 13, 2023, in accordance with SB 887, requests CAISO to consider whether to approve the highest priority transmission facilities that are needed to allow for increased transmission capacity into local capacity areas to deliver renewable energy resources or zero-carbon resources that are expected to be developed by 2035 projects as part of the CAISO’s 2022–23 TPP. But that does not mean that the CAISO should rush approvals of the projects in violation of its FERC-approved tariff. As we indicate below, the CPUC resource portfolios can differ significantly from one transmission planning cycle to another. For instance, the 2035 Base portfolio that will be studied as part of the 2023-2024 TPP departs from its utilization of transmission capability from the 2035 Sensitivity portfolio that was studied under the 2022-2023 TPP, although both these portfolios are based on the 30MMT GHG target.[3] [See BAMx’s response to Q.4 for details].

In these comments, BAMx also raises some major concerns about the skyrocketing CAISO transmission access charges (TAC) and the CAISO’s financial fiduciary responsibilities to Californians and grid users. BAMx comments should be construed as attempting to assist the State in its journey to achieve its climate goals and not as any opposition to taking the necessary steps. Further, BAMx recognizes that electric rates will probably continue to rise as a necessary outcome in achieving the State’s climate goals. That said, it is imperative and incumbent on the CAISO to design and develop an appropriate and cost-effective electric grid to accomplish those goals.

In order to understand the TAC impact of the projects the CAISO management may recommend for approval as part of the current planning process, BAMx developed a High Voltage (HV) TAC forecast for the period of 2023-2031. BAMx’s forecast shows that the HV TAC would rise to $24.5/MWh in 2036 purely based on the recommended project approval under the Draft Plan relative to the existing level of $15/MWh, a staggering 63% increase in thirteen years. [See BAMx’s response to Q.8 for details].

Out of the $24.5/MWh of forecasted HV TAC in 2036, more than 50% of the increase (or ~$5/MWh[4]) is solely attributed to the nearly $8.6 billion[5] HV transmission projects the CAISO is considering for approval in the current TPP cycle. BAMx’s HV TAC projections show the tremendous impact these potential project approvals will have on the ever-increasing CAISO-wide HV TAC. As detailed in the remaining BAMx comments,  the CAISO and stakeholders must complete thorough reviews and analyses to ensure the “right” projects are proceeding forward while eliminating excessive costly or unnecessary projects.

As the California Municipal Utilities Association (CMUA) issue brief[6] indicates,

“Based on California’s planned and anticipated transmission upgrades, this upward cost pressure could lead to another 43% increase to [HV + LV] TAC by 2030, reaching $48.7 per MWh, and a potential 98% increase by 2040, reaching $67.5 per MWh. This means the monthly cost of transmission for an average Northern California residential customer could rise from $27 in 2022 to $37 by 2030, and $54 in 2040 — a 100% increase over 18 years.”

The CMUA brief also compares the transmission costs in California to the rest of the nation.

“To put this in context, Northern California’s transmission costs are more than two and a half times the national average in 2022. Nationwide residential electric customer spending on transmission is expected to further increase by 86% by 2040, but in Northern California, it may rise an estimated 100%. The result is electric customers in California could be paying almost three times the national average for transmission in 2040.”

Rushed investments to build out additional transmission could lead to higher electricity prices and make California’s climate goals more difficult and more expensive to achieve. We caution that prohibitively expensive transmission costs could also compel current CAISO Load-Serving Entities (LSE) to exit the CAISO Balancing Authority Area (BAA), leading to a death spiral, further increasing the transmission costs for those LSEs that remain within the CAISO BAA.

BAMx recognizes that the combination of the dramatically increasing pace of new renewable generation and load forecast growth are driving an increase in transmission requirements under certain portfolio scenarios. However, the CAISO and the stakeholders must refrain from rushing to approve projects without allowing adequate time to complete the appropriate evaluation of each proposed project.

Furthermore, the CAISO typically posts its responses to past stakeholder comments before issuing the Draft Plan. This year, the CAISO posted them on the same day as the stakeholder meeting. This meant that stakeholders did not have adequate time to review the CAISO’s responses to their comments submitted in early December 2022 or digest their contents before having an opportunity to ask questions during the April 11^th stakeholder meeting.  BAMx finds it extremely challenging to respond and comment on certain aspects of the Draft Plan without fully assessing the CAISO’s responses to prior concerns raised by BAMx and other stakeholders.

In a nutshell, although BAMx does not oppose the need for most of the transmission projects recommended for approval, some of the remaining transmission projects that the CAISO has recommended for approval in this planning cycle need to be studied more extensively in the next cycle or at the very least their approval needs to be delayed until later in this cycle after the Board approval of the Plan in May 2023. The CAISO claims that “the [Draft] Plan also aligns with the 20-Year Transmission Outlook –and puts us on the right trajectory to meet 2045 goals.”[7] However, more information is necessary to systematically compare the transmission upgrades recommended in the Draft Plan and those envisioned in the 20-Year Transmission Outlook[8]. We see multiple benefits of such an exercise. First, it will provide the policy-makers, decision-makers, and stakeholders with information on how the CAISO’s transmission prioritization has evolved over the last transmission planning. Second, it will provide insights into updated cost estimates of the transmission projects needed to meet the State policy goals and their impact on the transmission access charge. Third, it will provide a glimpse into how the long-term plan or a refresh of the 20-Year Transmission Outlook expected in the 2023-2024 TPP cycle needs to be changed to account for the transmission recommended for approval in the Draft plan. BAMx has included a high-level analysis performing such a comparison based on certain assumptions (see BAMx’s response to Q.8. In particular, Table 8.1); however, we request the CAISO to confirm this assessment and include it in the Final Transmission Plan.

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

[2] http://www.caiso.com/InitiativeDocuments/Letter-2022-2023-Transmission-Planning-Process-Jan%2013,%202023.pdf

[3] See Policy-driven Assessment Recommendations Draft 2022-2023 Transmission Plan, Transmission Infrastructure Planning 2022-2023 Transmission Planning Process Stakeholder Meeting, April 11, 2023, pp.5-6.

[4] This amount is consistent with the CAISO’s estimate of 0.5 cents per kWh impact included in the Draft Plan (p.4)

[5] This amount purely captures the HV portion of the $9.3 billion of a total infrastructure investment plus a revised cost estimate of two previously approved projects, that is, Wheeler Ridge Junction Project and incremental GLW/VEA Area Upgrades project.

[6] https://www.cmua.org/Files/Issue%20Briefs/CMUA_Transmission_Costs_IB_August2022.pdf?mc_cid=d19a1104ee&mc_eid=92addbdaa9

[7] Introduction Draft 2022-2023 Transmission Plan, Neil Millar, Vice-President, Infrastructure & Operations Planning, 2022-2023 Transmission Planning Process Stakeholder Meeting, April 11, 2023, pp.5-6.

[8] http://www.caiso.com/InitiativeDocuments/20-YearTransmissionOutlook-May2022.pdf

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

BAMx agrees with the CAISO that the role of battery storage is expected to continue to grow as a complement to renewable generation and also as a key source of capacity to meet both system and local capacity needs.[1] Ultimately, storage resources will be available to meet energy needs during most periods when renewable resources are not available to generate. BAMx agrees with the conclusion that only the incremental interconnection cost for the storage should be compared to transmission costs when the batteries are located in local constrained areas.

BAMx applauds the CAISO staff’s efforts in relying on the implementation of Remedial Action Schemes (RAS) and storage solutions in its Preliminary Policy Assessment. The CAISO has effectively and rightfully utilized the existing/planned RAS dispatching portfolio with battery storage in charging mode, and also includes new battery storage to mitigate the contingency overloads. BAMx understands the CAISO’s recommendation for transmission upgrade alternatives for the base portfolio that take into consideration the inadequacy and complexity of RAS in certain planning areas. BAMx encourages the CAISO to transfer such valuable feedback to the California Public Utilities Commission (CPUC) and California Energy Commission (CEC) so that it is incorporated as part of the battery storage mapping exercise in the next Transmission Planning Process (TPP) cycle.

[1] Draft Plan, p.26.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

Consideration of Reliability Upgrades: Cortina 60 kV Line and Garberville Area Reinforcement Projects

In our prior comments in this planning cycle, BAMx had encouraged the CAISO to explore other options for PG&E's Cortina and Garberville areas, where PG&E is proposing capital-intensive projects ($300 million) to accommodate small incremental demand increases. Since then, we have had the opportunity to further examine the reliability needs in these areas.

BAMx’s examination of the CAISO-posted reliability assessments and underlying power flow cases indicate no overloads on the Cortina #1 60 kV, as observed in the PG&E assessment[1]. BAMx found low voltages in the 2032 case – 0.892 at the end of the line at the Dunnigan substation. Under normal conditions, the loading on the Cortina #1 60 kV was 91.5%. The Cortina # 1 60 kV line is a radial line that serves one load and has no generation. So, its loading depends only on the load and is unrelated to the generation dispatch. The installation of battery storage will improve loading and voltages, but PG&E stated that this alternative is infeasible because the charging capability on the transmission line is limited.

Several switches are normally opened in this area. Closing some of them improves voltages. The system model has two open switches at the Arbalt 60 kV substation. Closing these connections between Arbalt and Arbuckle and Arbalt and Dunntap improves voltages and reduces loadings. In the 2032 case, the loading on the Cortina # 1 60 kV line was reduced from 91.5% to 77.4% by closing these switches. Closing the normally open switch on Wilkins between DIST2047 and DIST1500 60 kV buses will also improve voltages and reduce loadings. In the 2032 case, the loading was further reduced to 65.9%.[2]  BAMx supports the Draft Plan determination to not approve the Cortina #1 60 kV line reconductoring in the current cycle.

When considering the Bridgeville-Garberville upgrade, it should be noted that loading of the Bridgeville-Garberville 60 kV line significantly depends on the output of the Humboldt Bay power plant, and its overload can be mitigated by reducing Humboldt Bay generation. It appears the Humboldt Bay Power plant output was reduced in the summer cases but was modeled at full output in winter. Reducing its output in the 2032 Winter case will mitigate the overload but will not help relieve low voltage criteria violations. Additional reactive support should be investigated as a solution for low-voltage violations. According to PG&E, space limitations at the Garberville substation prevent the installation of battery storage there. BAMx believes the feasibility of BESS needs to be investigated further. Even if a BESS at one of the substations connected to the Bridgeville-Garberville 60 kV line is unfeasible, other alternative locations should be investigated. Those investigations should include installation on the low side of existing transformers or obtaining a new site for installing BESS. BAMx endorses the CAISO methodology of only considering incremental interconnection costs for BESS that are needed for system issues. Even if there are interconnection costs, in this case, only those incremental costs should be included in an analysis of BESS for this area. A BESS should be investigated to mitigate any voltage or thermal criteria violations. In response to BAMx’s query on the consideration of battery storage as alternative mitigation, the CAISO stated that the battery storage size was limited by the capacity on the line south of Bridgeville and also that the 4-hour battery storage was found to be inadequate in addressing the 24-hour commercial load in this area. BAMx requests the CAISO to include more detailed explanation of all alternatives considered to justify the need for the proposed Garberville Area Reinforcement project in the Final Transmission Plan.

BAMx Appreciates CAISO’s Due Diligence In Identifying Relatively Low-Cost Mitigation Measures

BAMx supports relatively low-cost mitigation measures like the Series compensation proposed on the Lone Tree – Cayetano – Newark Corridor path.[3] BAMx also appreciates the CAISO's consideration of a generic BESS to address potential violations of off-peak deliverability constraints. As the CAISO has noted, a number of the criteria violations are identified in local areas on the 70 kV and 115 kV systems. As noted, alternatives that map generators at higher voltages (likely at 230 kV) need to be considered in subsequent planning cycles.[4] BAMx encourages the joint agencies (California Public Utility Commission, California Energy Commission, and CAISO) to develop such alternative mapping for the next TPP cycle.

[1] PG&E September 28^th Presentation, p.34.

[2] We also believe alternatives, such as installing energy storage and shunt capacitors, should be explored. There needs to be a more detailed investigation of the feasibility of an appropriate charging cycle for the storage and the ability of shunt capacitors to solve any remaining voltage issues.  Those alternatives should be investigated before approving the Cortina #1 60 kV line reconductoring.

[3] Draft Plan pp.43-44.

[4] Ibid, p. 110.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

BAMx Needs to See More Complete Information Provided in Draft Plan for Better Stakeholder Understanding of CAISO Policy-Driven Assessment

For the preliminary policy-driven assessments, the CAISO had not provided adequate information to stakeholders to understand and independently analyze the need for proposed Policy-Driven Projects. However, in the Draft Plan, consistent with BAMx’s request[1], the CAISO has provided the critical data for each deliverability constraint, identifying the renewable portfolio capacity (MW) levels behind the constraint, energy storage (ES) portfolio capacity (MW) behind the constraint, renewable curtailment levels without mitigation (MW), etc. BAMx appreciates the CAISO staff's responsiveness to stakeholder input.

BAMx Opposes CAISO Recommended Approval of Transmission Needs Only Identified in Sensitivity Portfolio

BAMx opposes the Draft Plan’s recommendation to approve transmission projects based on the need identified only in the sensitivity portfolio. Per the CAISO's FERC-approved tariff, a Category 1 policy-driven transmission solution has to be identified to be needed "in the baseline scenario and at least a significant percentage of the stress scenarios." Since some of the projects currently recommended for approval are not identified as needed under the Base portfolio, they clearly do not satisfy the criteria for Category 1 transmission and, therefore, should not be approved during the current TPP cycle. Furthermore, the draft 2023-2024 TPP CPUC portfolios or any synergy with the CAISO 20-Year Outlook should not be used as criteria to recommend any projects as Category 1 policy-driven transmission solutions in the current TPP. They could be classified as Category 2 policy-driven transmission solutions and can be studied in subsequent transmission planning cycles.

Therefore, BAMx urges the CAISO to delay the approval of the following projects and any others that do not meet the criteria included in the CAISO tariff in the 2023-2024 TPP.

1. Trout Canyon – Sloan Canyon 500 kV Upgrade: The Trout Canyon – Sloan Canyon 500 kV Upgrade was considered to alter the scope of the GLW/VEA Area Upgrades project when the need for the former project was only triggered in the Sensitivity portfolio.[2] The Innovation RAS appears adequate to address GLW 230 kV System issues in the Base portfolio.
2. Trout Canyon – Lugo 500 kV Line: The Trout Canyon – Lugo 500 kV Line is recommended for approval based on the sensitivity portfolio to address Lugo-Victorville 500 kV constraint.[3] Lugo – Victorville RAS's expansion seems adequate in the Base portfolio.

Furthermore, it appears that the proposed Serrano–Del Amo–Mesa 500 kV Transmission Reinforcement project is not needed in the Sensitivity portfolio given its lack of need to address the Serrano–Barre corridor constraint[4] and South of Mesa corridor constraint[5]. Therefore, the CAISO needs to fully explain the need for the Serrano–Del Amo–Mesa 500 kV Transmission Reinforcement project under the Sensitivity portfolio. But the project should not be approved now because it does not seem to be needed in the base portfolio.

BAMx recognizes that the CPUC’s letter[6] to the CAISO, dated January 13, 2023, in accordance with SB 887, requests CAISO to consider whether to approve the highest priority transmission facilities that are needed to allow for increased transmission capacity into local capacity areas to deliver renewable energy resources or zero-carbon resources that are expected to be developed by 2035 projects as part of the CAISO’s 2022–23 TPP. But that does not mean that the CAISO should rush approvals of the projects when uncertainty exists about the need and proper scope of the  transmission upgrades, especially when they are driven by CPUC resource portfolios that differ significantly from one transmission planning cycle to another. For instance, the 2035 Base portfolio that will be studied as part of the 2023-2024 TPP departs from its utilization of transmission capability from the 2035 Sensitivity portfolio that was studied under the 2022-2023 TPP, although both these portfolios are based on the 30MMT GHG target. As seen from those tables reproduced in Table 4.1 below, the last two columns are not identical and differ significantly for some of the transmission constraints, such as the Victor to Lugo 230 kV Constraint and Lugo 500/230 kV Transformer Constraint.[7] Therefore, any project that is approved in the current TPP based on the Sensitivity portfolio may not be needed or have the proper scope based on next year’s Base portfolio. It is important to recognize that the CPUC resource portfolios are dominated by generic resource buildout and not by projects that are currently under development. Similarly, it may make sense to wait for another year to determine the scope of the new policy-driven transmission projects or expansion of the previously-approved transmission projects, such as the GLW/VEA Area Upgrades project. As shown in Table 4.1 below, the FCDS capability exceedance level is dramatically reduced from 1,676 MW in the current TPP Sensitivity portfolio to 1,058 MW in the next year’s TPP Base portfolio for the GLW-VEA Area constraint.

Table 4.1: Utilization of Transmission Capability by Portfolios  

Furthermore, BAMx’s analysis of the CPUC busbar mapping spreadsheet indicates that CPUC’s 2035 Base portfolio of FCDS resources exceeds the FCDS capability of not only the existing system FCDS capacity as shown in the CAISO’s February 28^th presentation as part of the 2023-2024 TPP, but also exceeds the incremental FCDS capacity offered by the additional area delivery network upgrades (ADNU) identified by the CAISO.[8] BAMx’s analysis suggests inadequate assessment of transmission cost, where the CPUC-provided Base portfolio of resources in the year 2035 exceeded the FCDS capability of the existing plus the Area Delivery Network Upgrades (ADNU) identified by CAISO for thirteen (13) different transmission constraints, such as the Los Banos 500/230kV Transformer Constraint and Serrano – Alberhill – Valley 500 kV Constraint.

CAISO Should Explore Every Option to Reduce TAC-payer Burden for Approving Out-of-State Transmission Projects

BAMx appreciates the CAISO's recognition of the need to take into account evolving CPUC portfolios for out-of-state (OOS) resources and concerns expressed by stakeholders.[9] Since the 2022-2023 TPP does not explicitly include OOS wind from Idaho in the Base Case, BAMx believes it would be inappropriate for the CAISO to approve the SWIP-North project in the current TPP.[10]  It is the only current proposal providing direct access to the Idaho resources. SWIP-North project is not needed in the Base portfolio for the current TPP but only in the sensitivity portfolio. [11] The SWIP-North project appears not to meet the criteria defining interregional transmission projects.[12] Since the SWIP-North project developer is not opting for a subscriber-based model, if this project is approved as a policy-driven project, its entire cost of $640 million would be borne by the CAISO TAC payers.  Therefore, it is incumbent that every effort needs to be made for sharing that burden with other potential beneficiaries. BAMx welcomes the CAISO discussion with Idaho Power (and potential other transmission service providers) regarding their interest in the part of the South to North capacity of the SWIP North project.[13]  BAMx also supports the opportunities for DOE funding for unutilized capacity that the CAISO is currently exploring. [14] BAMx does not believe that the CAISO should approve the SWIP North as a regional policy-driven project until the TAC reduction efforts associated with it are fully explored in consultation with the stakeholders.

[1] See BAMx’s comments on the CAISO Preliminary Policy-Driven and Economic Assessment, December 5, 2022.

[2] Draft Plan p. 76

[3] Draft Plan p. 80

[4] CAISO April 11^th Stakeholder Meeting Presentation, p.101

[5] CAISO April 11^th Stakeholder Meeting Presentation, p.103

[6] http://www.caiso.com/InitiativeDocuments/Letter-2022-2023-Transmission-Planning-Process-Jan%2013,%202023.pdf

[7] See Policy-driven Assessment Recommendations Draft 2022-2023 Transmission Plan, Transmission Infrastructure Planning 2022-2023 Transmission Planning Process Stakeholder Meeting, April 11, 2023, pp.5-6.

[8] See BAMx’s comments on the CAISO 2023-2024 Draft Transmission Study Plan (See Table 1 in Response to Q.2) , dated March 14, 2023.

[9] “Accessing out-of-state Idaho wind resources,” 2022-2023 Transmission Planning Process Stakeholder Meeting

November 17, 2022, p.8.

[10] BAMx recognizes that the CPUC Base portfolio calls for 1,062MW either Idaho or Wyoming wind. However, if 1,062MW Wyoming accessed via Transwest Express is assumed, then there will not be anu need to access Idaho wind in compliance with the Base portfolio.

[11] Ibid, pp3-4.

[12] Draft Plan, p.100.

[13] Ibid.

[14] Ibid.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

No comments.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

No comments.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

No comments.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

No comments.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

BAMx found the schematics presented by the CAISO during the April 11^th meeting mapping the recommended policy-driven project for approval to the zonal resource portfolio driving their needs to be very helpful.[1] BAMx suggests that the CAISO include it in the Final Transmission Plan.

The Draft Plan does not include an estimate of future High Voltage Transmission Access Charge (HV TAC) rates at this time. The CAISO may be currently in the process of updating the “starting point” for the HV TAC estimating tool to January 1, 2023. Given the need for urgency to show the TAC impact of the projects the CAISO has recommended for approval as part of the current planning cycle, BAMx developed an HV TAC forecast for the period of 2023-2036, as shown in the figure below. In this analysis, BAMx used the last version of the CAISO’s TAC Estimating model developed for the 2021-2022 TPP, and updated the model to include the CAISO January 01, 2023, TAC Rates (updated as of April 7, 2023). The newly added capital expenditures associated with the transmission projects and their schedule were based on the transmission projects found to be needed in the 2022-2023 TPP as per the Draft Plan.[2] That is, those included in

• Table 8.2-1: New Reliability Projects Found to be needed; and
• Table 8.2-2: New Policy-driven Transmission Projects Found to be needed.

Figure 8.1: Transmission Capital Expenditures and HV TAC Projections (Base and Draft Plan Recommended Approvals): 2023-2036

As shown in Figure 8.1 above, the HV TAC would rise to $24.5/MWh in 2036 purely based on the recommended project approval under the Draft Plan relative to the existing level of $15/MWh, a staggering 63% increase in thirteen years.

Out of the $24.5/MWh of forecasted HV TAC in 2036, more than 50% of the increase (or ~$5/MWh[3]) is solely attributed to the nearly $8.6 billion[4] HV transmission projects the CAISO is considering for approval in the current TPP cycle.

The CAISO claims that “the [Draft] Plan also aligns with the 20-Year Transmission Outlook –and puts us on the right trajectory to meet 2045 goals.”[5] However, more information is necessary to systematically compare the transmission upgrades recommended in the Draft Plan and those envisioned in the 20-Year Transmission Outlook[6]. We see multiple benefits of such an exercise. First, it will provide the policy-makers, decision-makers, and stakeholders with information on how the CAISO’s transmission prioritization has evolved over the latest transmission planning cycle. Second, it will provide insights into updated cost estimates of the transmission projects needed to meet the State policy goals and their impact on the transmission access charge. Third, it will provide a glimpse into how the long-term plan or a refresh of the 20-Year Transmission Outlook expected in the 2023-2024 TPP cycle needs to be changed to account for the Draft Plan recommended approvals. BAMx has included a high-level analysis performing such a comparison in Table 8.1 below. However, we request the CAISO confirm this assessment and include some version of it in the Final Transmission Plan. For instance, we request the CAISO to confirm whether the projects recommended for approval under the Southern Area Reinforcement project replace and therefore eliminate the need for any (all) of the projects envisioned in the 20-Year Transmission Outlook, such as  Devers – La Fresa HVDC ($1.2 B), Lugo – LA Basin HVDC ($1.0 B), and Sycamore – Alberhill HVDC ($1.0 B).

Table 8.1: A Comparison of Project Approvals in the 2022-2023 Draft Transmission Plan and Those Identified in the 20-Year Transmission Outlook and Associated Capital Cost

*Possible reduction due to a potential joint project with IID?

The 20-Year Outlook does not include an estimate of future HV TAC at this time. Given the need to show the TAC impact of the projects the CAISO has recommended for approval as part of the current planning cycle, BAMx developed an HV TAC forecast for 2023-2036, as shown in Figure 8.2 below. BAMx then incrementally considered the transmission projects identified in the 20-Year Outlook, namely $10.4 billion of upgrades to the existing CAISO footprint, $8.11 billion for Offshore Wind (OW) integration, and approximately $9.95 billion for Out-of-State (OOS) wind integration.[7] Table 8.2 compares the capital cost identified in the original CAISO 20-Year Transmission Outlook, and the 20-Year Transmission Outlook Refresh used to develop the HV TAC forecast included in Figure 8.2 using the updated information in the Draft Plan.

*Replaces the capital cost for the projects (or their substitutes) in the Original 20-Year Outlook with those included in the Draft Plan based on the assessment in Table 8.1.

**  Assumes that both the Transwest Express and SunZia projects opt for the subscriber model, excluding the $2.1B and $2.6B capital costs associated with those two projects, respectively.

Figure 8.2: Transmission Capital Expenditures and HV TAC Projections (Base, Draft Plan Recommended Approvals and Refreshed 20-Year Transmission Outlook): 2023-2036

As shown in Figure 8.2 above, the HV TAC would rise to $37.8/MWh in 2036 based on the recommended project approval under the Draft Plan and incremental expected transmission upgrades under the 20-Year Transmission Outlook Refresh. As can be seen in Figure 8.2, these incremental transmission upgrades under the 20-Year Outlook Refresh of nearly $20 billion will add another $13.3/MWh to the HV TAC by 2036. Even with a very conservative estimate of these potential transmission projects, BAMx’s HV TAC projections show the immense impact they will have on the ever-increasing CAISO-wide HV TAC.

Rushed investments to build out additional transmission could lead to higher electricity prices and make California’s climate goals more difficult and more expensive to achieve. We caution that prohibitively expensive transmission costs could also compel current CAISO LSEs to exit the CAISO BAA leading to a death spiral, further increasing the transmission costs for those LSEs that remain within the CAISO BAA. In summary, although BAMx does not oppose the need for most of the transmission projects recommended for approval in the Draft Plan, some of the remaining transmission projects that the CAISO has recommended for approval need to be studied more extensively in the next cycle or at the very least their approval needs to be delayed until later in this cycle after the Board approval of the Plan in May 2023 with a better understanding of how those projects fit into the CAISO’s long-term transmission outlook.

[1] Introduction Draft 2022-2023 Transmission Plan, Neil Millar, Vice-President, Infrastructure & Operations Planning, 2022-2023 Transmission Planning Process Stakeholder Meeting, April 11, 2023, p.6.

[2] Draft Plan, pp.165-176.

[3] This amount is consistent with the CAISO’s estimate of 0.5 cents per kWh impact included in the Draft Plan (p.4)

[4] This amount purely captures the HV portion of the $9.3 billion of a total infrastructure investment plus a revised cost estimate of two previously approved projects, that is, Wheeler Ridge Junction Project and incremental GLW/VEA Area Upgrades project.

[5] Introduction Draft 2022-2023 Transmission Plan, Neil Millar, Vice-President, Infrastructure & Operations Planning, 2022-2023 Transmission Planning Process Stakeholder Meeting, April 11, 2023, pp.5-6.

[6] http://www.caiso.com/InitiativeDocuments/20-YearTransmissionOutlook-May2022.pdf

[7] See CAISO 20-Year Transmission Outlook, May 2022, pp.56-59.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

The California Community Choice Association (CalCCA) commends the California Independent System Operator (ISO) for the extensive work it has put into the 2022-2023 Draft Transmission Plan (Draft Transmission Plan). The Draft Transmission Plan reflects the proactive steps taken by the ISO to inform transmission infrastructure needed to reliably and economically achieve the state’s clean energy goals. As the ISO notes, California’s climate goals and escalating load forecasts necessitate an unprecedented amount of new resource development, and in turn, transmission capacity to support those resources. The California Energy Commission’s Senate Bill 100 Core Scenario which was used to develop the 20 year-outlook indicates a need for roughly 175,000 megawatts (MW) of cumulative capacity additions by 2045. The Draft Transmission Plan puts the ISO on the trajectory to meet the transmission needs to support this level of development.

This year, the ISO also developed a zonal representation of the proposed transmission projects in the plan, signaling the MW of incremental capacity that can be accessed as a result of the proposed projects. CalCCA supports the ISO including this information as a regular output of the transmission planning process (TPP) going forward, particularly if the ISO begins to prioritize interconnection requests that align with existing or planned transmission capacity. CalCCA requests clarification on the zones presented on page 4 of the Draft Transmission Plan to better understand what the zones and capacity in each zone represent. Specifically, several zones indicate which policy-driven projects enable access to the capacity in base and sensitivity portfolios (e.g., Policy-Driven Projects 1 and 2 in the Pacific Gas and Electric Company (PG&E) Fresno Area). Other zones do not list the policy-driven projects enabling access to new capacity (e.g., PG&E Greater Bay Area, Southern California Edison Company Northern, etc.). For those areas that do not have policy projects associated with them, the ISO should clarify how the transmission system will allow for access to that capacity (i.e., existing transmission capacity, reliability projects, future policy projects, etc.).  Additionally, CalCCA requests the ISO clarify how it incorporates land-use screens to ensure the zones do not violate land-use constraints.

The ISO has indicated that, when recommending projects, the ISO has in some cases considered mitigating for the sensitivity case in addition to the base case, given the 2022-2023 sensitivity case largely mirrors the base case that will be used in the 2023-2024 TPP. CalCCA supports the ISO considering future needs when recommending projects, either by considering cases in future TPP portfolios or the 20-year outlook. CalCCA also supports the ISO recommending projects for approval when the ISO is confident that approving those projects now will mitigate both immediate needs and future needs, therefore avoiding paying for mitigation twice. The Draft Transmission Plan includes 24 reliability projects totaling $1.76 billion and 22 policy projects totaling $7.53 billion. The ISO indicates that this will translate to a $5/ megawatt-hour (MWh) increase in the transmission access charge (TAC) over the life of the projects, relative to the current TAC of $16.62/MWh. Given the transmission projects recommended in the Draft Transmission Plan represent a 30 percent increase in the TAC, and the ISO anticipates over $30 billion of transmission project costs in the 20-year outlook, minimizing transmission costs where possible will be necessary to avoid exacerbating the impact of transmission on customer affordability.

The ISO indicates that it plans to update the 20-year outlook in parallel with the 2023-2024 TPP. CalCCA supports the ISO updating the 20-year outlook. The 20-year outlook provides valuable information about the needs of the system further into the future than is contemplated in the IRP portfolios transmitted to the ISO for study in the TPP or the TPP itself. From the load-serving entity (LSE) perspective, the 20-year outlook can provide information about how the system may evolve as LSEs plan procurement further out than 10-12 years. For example, CalCCA has commented previously in the TPP[1] and Integrated Resource Planning (IRP) proceeding[2] on the resource potential in areas like Northern Nevada, but they have not yet been identified in the California Public Utilities Commission (CPUC) base portfolios. The ISO should consider how it can use the 20-year outlook to inform the TPP and IRP processes where possible in order to provide more certainty around transmission needs and resource potential further out. The ISO’s important work on the 20-year outlook will need to be coupled with work at the CPUC to develop clear and regularly updated needs assessments that reflect needs and opportunities many years forward.

Finally, page 8 of the Draft Transmission Plan indicates that the ISO is recommending 12 reliability or policy-driven projects for approval that also reduce gas-fired generation local capacity requirements. CalCCA appreciates the ISO including this information in the plan, and encourages the ISO and the CPUC to continue to expeditiously study the ability to reduce reliance on fossil fuel resources in local areas to ensure an orderly and reliable transition from reliance on fossil fuels in local areas at least cost. This is especially important given the trends the ISO is seeing in its long-term local capacity technical studies. The long-term local capacity technical study included in the Draft Transmission Plan indicates that the 2032 local capacity requirement trends are 18.5 percent higher than the 2027 trends primarily due to load forecast increases. (See Footnote 3.)  Because local areas depend heavily on gas-fired resources, it will be critical for the ISO and the CPUC to identify when transmission can cost-effectively reduce local capacity requirements, even as load increases, to meet state policy goals.

[1]             See https://stakeholdercenter.caiso.com/Comments/AllComments/f19a7845-cd76-4d0c-9ebf-041832dbbe23#org-93e17ef0-4df0-49b2-b29b-67f80a1459a4.

[2]             See https://cal-cca.org/wp-content/uploads/2022/04/Informal-Comments-on-the-Reliability-Pther-Filing-Requirements-for-LSEs-2022-IRPs-around-MAG-Webinar-04-21-22.pdf and https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M441/K159/441159816.PDF.  

[3]             Draft Transmission Plan at Appendix J.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

CalCCA has no additional comments at this time.  

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

CalCCA has no additional comments at this time.  

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

CalCCA has no additional comments at this time.  

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

CalCCA has no additional comments at this time.  

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

CalCCA has no additional comments at this time.  

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

CalCCA has no additional comments at this time.  

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

CalCCA has no additional comments at this time.  

9. Provide your organization’s comments on chapter 8 Transmission Project List.

CalCCA has no additional comments at this time.  

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

COMMENTS OF THE STAFF OF THE CALIFORNIA PUBLIC UTILITIES COMMISSION REGARDING THE DRAFT 2022-2023 TRANSMISSION PLAN FOLLOWING THE APRIL 11, 2023 STAKEHOLDER MEETING

April 25, 2023

The Staff of the California Public Utilities Commission (“CPUC Staff”) appreciates this opportunity to provide comments on the Draft 2022-2023 Transmission Plan discussed at the CAISO’s April 11, 2023 stakeholder meeting.

General Statement

This annual TPP assessment utilized the “Preferred System Plan” (PSP) portfolio adopted by the Commission in D.22-02-004, which is designed to drive greenhouse gas emissions down to a 38 million metric ton (MMT) target in 2030, dropping to 35 MMT by 2032. This portfolio incorporated the integrated resource plans of 40+ LSEs that were filed in 2020 and supplemented or revised in 2021. It is based on modeling to optimize clean energy resource procurement and reflects the most cost-effective system plan to reach these aggressive greenhouse gas emissions targets, while ensuring reliability. Notably, the CPUC’s modeling takes into account the capital costs of new resources, including any necessary new transmission infrastructure, and the variable costs of reliably operating the grid.

Together with the CEC’s high electrification demand assumptions, these key inputs drove a significant increase in the transmission infrastructure that CAISO staff has identified for development within the 2022-2023 Draft Transmission Plan -- especially for policy-related projects -- compared to previous TPP cycles.

For the 2023-2024 TPP cycle, the Commission already (in D.23-02-040) has conveyed to CAISO a base case portfolio with a 30 MMT emissions target that includes an even larger set of new resources (69 GW by 2033) compared to the 2022-2023 TPP.  This portfolio reflects the potential for increased electrification occurring in other sectors of California’s economy and, notably, this is largely the same portfolio that the CPUC had requested CAISO to study as a sensitivity case in this 2022-2023 TPP cycle.  Thus, it is helpful that CAISO staff has utilized its analysis of this sensitivity case to create more inclusive upgrades in this 2022-2023 Draft Transmission Plan that will fit the bigger portfolio that is coming as the base case for the 2023-2024 TPP.  The Commission (in D.23-02-040) encouraged getting this kind of a “head start” on needed transmission projects wherever possible. 

Overall, CPUC Staff greatly appreciates CAISO’s efforts to produce this comprehensive transmission analysis, which is extremely important for reliability while achieving the state’s clean energy goals. We support this 2022-2023 Draft Transmission Plan in which the CAISO has identified the transmission buildout currently needed to reliably integrate the resource mix that will keep the state on the optimal and most cost-effective pathway toward a 100% carbon-free CAISO grid by 2045.

It is also important to reiterate how the CPUC’s integrated resource planning process continually interacts with the CAISO’s Transmission Planning Process to identify cost-effective ways to achieve this transition in the state’s electric grid. Along with these expected large increases in transmission investments, CPUC Staff anticipates intensified efforts to ensure ratepayers are getting good value. 

For example, CPUC Staff looks forward to working with CAISO and others to consider possible refinements to the methodology for estimating costs of transmission projects.  We will be seeking ways and possibly new tools to minimize cost escalations, enhance the competitiveness of bidding to develop certain transmission projects and utilize timely updates on transmission limits to enhance RESOLVE capacity resource modeling.  The CAISO’s quarterly Transmission Development Forums have been helpful in providing information and greater public visibility on transmission project delays and the implications on project costs; this has helped improve coordination with resource developers and provided valuable details for ratepayer advocates and other stakeholders.  We hope to build on these efforts to enhance the cost-effectiveness of California’s resource and transmission investment.

Cost Management and Ratepayer Protections

The 2022-2023 Draft Transmission Plan proposes approval of $9.3 billion in projects, with $1.76 billion on 24 reliability-driven projects and $7.53 billion on 22 policy-driven projects aimed at furthering California’s clean energy goals.  Energy Division looks forward to supporting the CAISO as it takes steps to manage costs in the implementation of these projects, particularly with ongoing monitoring of estimated costs and schedules of the proposed projects.

Opportunities exist for the CAISO to support cost containment of the proposed projects in the Draft Transmission Plan. These include careful consideration of total costs for both the incumbent and independent TOs’ portions of projects in Phase 3 of the TPP and in the implementation of these projects.  The potential benefits from a well-priced and cost-capped competitive bid could be lost if careful cost management of the incumbent utility’s portion does not also occur.

CPUC Staff also encourages expeditious implementation of projects to avoid unnecessary accrual of allowance for funds used during construction (AFUDC). The accrual of AFUDC on projects of this magnitude could result in substantial additions to rate base and unnecessary impacts on ratepayers.

CPUC Staff notes that the impact on the Transmission Access Charge (TAC) was missing in Section 8.5 of the Draft Transmission Plan.    CPUC Staff encourages the CAISO to include this information for stakeholders as soon as possible, as the approval of this scale of projects will result in substantial impacts on ratepayers.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Comments of California Western Grid

on CAISO’s Draft 2022-2023 Transmission Plan

April 25, 2023

Three Rivers Energy Development, LLC (TRED) is an Independent Transmission Developer that is developing the Pacific Transmission Expansion Project (“PTE Project” or “PTEP”) on behalf of California Western Grid Development, LLC. (“California Western Grid” or “Cal Western”). 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 (OSW) delivered to the LA Basin and Big Creek Ventura areas to reduce local capacity requirements while also solving other significant issues. 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”).

California Western Grid appreciates the opportunity to submit comments on the CAISO’s April 3, 2023, Draft 2022-2023 Transmission Plan (“Draft Plan”). As an initial matter, we note that on October 14, 2022, we submitted comments on behalf of California Western Grid regarding the CAISO’s Strawman Proposal dated September 22, 2022 (“Strawman Comments”). In those comments we commended the CAISO for recognizing that changes to the TPP are needed if the CAISO is going to be able to plan and approve transmission to accommodate the tripling of clean energy resources that the 2021 Joint Agency Report to the Legislature found is necessary to meet “SB 100”[1] goals. We also detailed the various public policy findings embodied in SB 887[2] that confirm that new transmission is urgently needed to accommodate State public policy needs. We pointed out that to comply with SB 887, the CAISO must make considerable progress on planning and approving new transmission in the current 2022-2023 TPP under its FERC Tariff obligation to timely plan and approve transmission to meet State public policy goals. We will not repeat those Strawman Comments but rather incorporate them herein by reference.

We commend CAISO for taking significant steps forward in the Draft 2022/2023 TPP Plan issued April 3, 2023. The Draft Plan recommends approval of $9.3 Billion of transmission projects that are urgently needed to maintain grid is reliability and take initial steps to meet the State Public Policies reflected Senate Bill 100 and Senate Bill 887. However, more is needed. The PTE Project is an example of the type of muti-purpose project that should be approved in this 2022-2023 planning cycle.

In this regard, the CAISO concluded in its Draft Plan[3] that:

The ISO will also continue to explore gas-fired generation retirement plans with the CPUC and work with LADWP on potential collaboration opportunities regarding the Pacific Transmission Expansion Project both leading up to presenting this Plan to the ISO Governors for approval, and after the Plan has been approved.

 Cal Western appreciates the CAISO’s continued review of PTEP and its efforts to accommodate the transmission needs of both the CPUC’s resource plans and the needs of LADWP that can be addressed by a Joint Subsea Project with PTEP. In these comments we urge the CAISO to take proactive steps in the months ahead to assure needed transmission projects such as PTEP are available when needed.

As the CAISO points out on page 8 of the Draft Plan:

While SB 887 calls for the CPUC to provide to the ISO by March 31, 2024, resource projections expected to reduce the need to rely on non-preferred resources in local capacity areas by 2035, these projections are not yet reflected in the portfolios provided by the CPUC for the 2022-2023 Plan and the gas-fired generation is being relied upon across the planning horizon for system capacity.

The CAISO should request the CPUC to provide guidance on reduced use of gas fired generation in local capacity areas including any expected gas plant retirement plans in advance of the SB 887 March 2024 statutory deadline. CAISO should request this information be made available to the CAISO this summer. The CPUC has already studied these issues, and the gas plants in question will in many cases be more than 40 years old in the next decade. In the case of LADWP, it has already announced plans to reduce reliance on the gas plants and planning for gas plant retirements by 2035. [4] Surely the CAISO working with the CPUC in the next few months can arrive at the guidance needed in this 2022-23 TPP to reduce reliance on gas plants, at least for the LA Basin, where there is also growing pressure to phase out or retire Aliso Canyon.

Cal Western also applauds the CAISO for producing the special study to identify transmission that is needed to reduce reliance on Aliso Canyon Gas Storage facility. Cal Western agrees that PTEP is a robust solution to assist in Aliso Canyon closure while also reducing Path 26 congestion, reducing Local Capacity Resource (LCR) requirements, reducing the current expense of maintaining an aging fleet of gas-fired generation, and providing a myriad of other benefits.

As the CAISO knows, the CPUC has sent CAISO a portfolio for the 2023-2024 TPP that includes an incremental 86 GW of clean energy to be in-service by 2035. It is also likely that transmission will be needed in this same time period to be able to reduce its reliance on the Aliso Canyon gas storage facility and gas plants generally. Cal Western submits that, given the recharging limitations on batteries, it is not likely that these needs can be met without new transmission particularly into populated coastal load centers like Los Angeles (“LA”). Indeed, when faced with similar needs reflected in the 2021 Joint Agency Report to the Legislature on the meeting SB 100 goals, the CAISO found that a project like PTEP is needed between Diablo and LA.

Any project approved this year will have 11-12 years to develop, permit, finance, and construct the transmission to meet these needs. The CAISO has advised the CPUC repeatedly that the lead time for new transmission is 10 years or more which, in this case, leaves little time for unexpected delays. Yet there are many reasons to expect the unexpected.

First, as CAISO is aware, there are many projects in California that have historically exceeded a 10-year lead-time to design, permit, procure materials and build.

Second, the CAISO’s 20-Year Transmission Outlook concludes that to meet SB 100 needs will require $30.5 billion of new transmission. With the amount of new transmission in the Draft Plan and the dramatic amounts of additional transmission that will be added as we move forward, it is almost certain to cause logjams at the permitting agencies including the CPUC. This is particularly true given the challenges of permitting land-based transmission in large coastal load centers like LA.

Third, the dramatic amount of new transmission needed is not unique to California. Cable and converter manufacturers are expecting to be overwhelmed by increasing worldwide demand and have indicated that projects that do not contract now are likely to find themselves in long queue lines or worse. Currently, there are similar shortages developing with respect to skilled workers and construction equipment and ocean vessels.

On the positive side, the CPUC has wisely requested the CAISO to focus on multi-purpose projects that will foster least-risk planning. PTEP is just such a project:

• PTEP is needed to relieve congestion on Path 26 with or without the gas plants in service.

• PTEP is needed for OSW to reach Southern California with or without Diablo running.

• PTEP allows for increased battery storage in LA by providing recharging power.

• PTEP provides the ability to access and deliver solar from the Central Valley directly to the LA Basin

• PTEP allows the flexibility for the use of gas plants to be decreased or eliminated.

• PTEP allows the flexibility for reduced reliance on Aliso Canyon.

• PTEP has the best chance of navigating environmental permitting challenges and providing a contribution to urgent transmission needs.

• PTEP provides a major contribution to mitigating wildfire service interruptions.

• PTEP increases the likelihood that clean energy can meet increasing electrification demand in LA.

• PTEP’s costs, under conservative assumptions, are offset 50% by economic benefits that are quantifiable.

• PTEP also provides many other benefits that are difficult to quantify but easy to recognize such as assistance in black start events to rapidly restore normal operations.

• PTEP allows for reduced gas use that will improve air quality in Disadvantaged Communities in the LA Basin—a major goal underlying SB 100 and SB 887.

• PTEP is the type of project that DOE has in mind as eligible for federal funding.[5]

In light of all of the above, we submit that the proper path forward is to plan for the worst and hope for the best. We urge the CAISO to proactively engage with the CPUC to collaborate on plans to reduce reliance on gas plants in advance of the SB 887 March 2024 statutory deadline. We also encouraged continued collaborative discussions with LADWP to explore the potential for a joint subsea transmission project with PTEP.

We appreciate CAISO’s continued review of PTEP in this 2022-2023 planning cycle and we stand ready to help in any way that would be constructive.

Respectfully submitted,

Marty Walicki, Managing Partner

Three Rivers Ener

[1] “The 100 Percent Clean Energy Act of 2018,” Senate Bill 100 (SB 100, De León): 

[2] Senate Bill 887 “Accelerating Renewable Energy Delivery Act” (“SB 887”).

[3]  Draft Plan pp. 14-15.

[4] https://www.ladwpnews.com/100-percent-carbon-neutral-power-by-035-los-angeles-city-council-approves-landmark-initiative/

[5] Infrastructure Investment and Jobs Act signed into law on Nov. 15, 2021. Find a summary of key electric transmission provisions at: https://www.energy.gov/bil/transmission-facilitation-program [5] and

https://www.energy.gov/bil/program-upgrading-our-electric-grid-and-ensuring-reliability-and-resiliency

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

Cal Western has no comment

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

Cal Western has no comment

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

We commend CAISO for taking significant steps forward in the Draft 2022/2023 TPP Plan issued April 3, 2023. The Draft Plan recommends approval of $9.3 Billion of transmission projects that are urgently needed to maintain grid is reliability and take initial steps to meet the State Public Policies reflected Senate Bill 100 and Senate Bill 887. However, more is needed. The PTE Project is an example of the type of muti-purpose project that should be approved in this 2022-2023 planning cycle.

In this regard, the CAISO concluded in its Draft Plan[1] that:

The ISO will also continue to explore gas-fired generation retirement plans with the CPUC and work with LADWP on potential collaboration opportunities regarding the Pacific Transmission Expansion Project both leading up to presenting this Plan to the ISO Governors for approval, and after the Plan has been approved.

 Cal Western appreciates the CAISO’s continued review of PTEP and its efforts to accommodate the transmission needs of both the CPUC’s resource plans and the needs of LADWP that can be addressed by a Joint Subsea Project with PTEP. In these comments we urge the CAISO to take proactive steps in the months ahead to assure needed transmission projects such as PTEP are available when needed.

As the CAISO points out on page 8 of the Draft Plan:

While SB 887 calls for the CPUC to provide to the ISO by March 31, 2024, resource projections expected to reduce the need to rely on non-preferred resources in local capacity areas by 2035, these projections are not yet reflected in the portfolios provided by the CPUC for the 2022-2023 Plan and the gas-fired generation is being relied upon across the planning horizon for system capacity.

The CAISO should request the CPUC to provide guidance on reduced use of gas fired generation in local capacity areas including any expected gas plant retirement plans in advance of the SB 887 March 2024 statutory deadline. CAISO should request this information be made available to the CAISO this summer. The CPUC has already studied these issues, and the gas plants in question will in many cases be more than 40 years old in the next decade. In the case of LADWP, it has already announced plans to reduce reliance on the gas plants and planning for gas plant retirements by 2035. [2] Surely the CAISO working with the CPUC in the next few months can arrive at the guidance needed in this 2022-23 TPP to reduce reliance on gas plants, at least for the LA Basin, where there is also growing pressure to phase out or retire Aliso Canyon.

Cal Western also applauds the CAISO for producing the special study to identify transmission that is needed to reduce reliance on Aliso Canyon Gas Storage facility. Cal Western agrees that PTEP is a robust solution to assist in Aliso Canyon closure while also reducing Path 26 congestion, reducing Local Capacity Resource (LCR) requirements, reducing the current expense of maintaining an aging fleet of gas-fired generation, and providing a myriad of other benefits.

As the CAISO knows, the CPUC has sent CAISO a portfolio for the 2023-2024 TPP that includes an incremental 86 GW of clean energy to be in-service by 2035. It is also likely that transmission will be needed in this same time period to be able to reduce its reliance on the Aliso Canyon gas storage facility and gas plants generally. Cal Western submits that, given the recharging limitations on batteries, it is not likely that these needs can be met without new transmission particularly into populated coastal load centers like Los Angeles (“LA”). Indeed, when faced with similar needs reflected in the 2021 Joint Agency Report to the Legislature on the meeting SB 100 goals, the CAISO found that a project like PTEP is needed between Diablo and LA.

Any project approved this year will have 11-12 years to develop, permit, finance, and construct the transmission to meet these needs. The CAISO has advised the CPUC repeatedly that the lead time for new transmission is 10 years or more which, in this case, leaves little time for unexpected delays. Yet there are many reasons to expect the unexpected.

First, as CAISO is aware, there are many projects in California that have historically exceeded a 10-year lead-time to design, permit, procure materials and build.

Second, the CAISO’s 20-Year Transmission Outlook concludes that to meet SB 100 needs will require $30.5 billion of new transmission. With the amount of new transmission in the Draft Plan and the dramatic amounts of additional transmission that will be added as we move forward, it is almost certain to cause logjams at the permitting agencies including the CPUC. This is particularly true given the challenges of permitting land-based transmission in large coastal load centers like LA.

Third, the dramatic amount of new transmission needed is not unique to California. Cable and converter manufacturers are expecting to be overwhelmed by increasing worldwide demand and have indicated that projects that do not contract now are likely to find themselves in long queue lines or worse. Currently, there are similar shortages developing with respect to skilled workers and construction equipment and ocean vessels.

On the positive side, the CPUC has wisely requested the CAISO to focus on multi-purpose projects that will foster least-risk planning. PTEP is just such a project:

• PTEP is needed to relieve congestion on Path 26 with or without the gas plants in service.

• PTEP is needed for OSW to reach Southern California with or without Diablo running.

• PTEP allows for increased battery storage in LA by providing recharging power.

• PTEP provides the ability to access and deliver solar from the Central Valley directly to the LA Basin

• PTEP allows the flexibility for the use of gas plants to be decreased or eliminated.

• PTEP allows the flexibility for reduced reliance on Aliso Canyon.

• PTEP has the best chance of navigating environmental permitting challenges and providing a contribution to urgent transmission needs.

• PTEP provides a major contribution to mitigating wildfire service interruptions.

• PTEP increases the likelihood that clean energy can meet increasing electrification demand in LA.

• PTEP’s costs, under conservative assumptions, are offset 50% by economic benefits that are quantifiable.

• PTEP also provides many other benefits that are difficult to quantify but easy to recognize such as assistance in black start events to rapidly restore normal operations.

• PTEP allows for reduced gas use that will improve air quality in Disadvantaged Communities in the LA Basin—a major goal underlying SB 100 and SB 887.

• PTEP is the type of project that DOE has in mind as eligible for federal funding.[3]

In light of all of the above, we submit that the proper path forward is to plan for the worst and hope for the best. We urge the CAISO to proactively engage with the CPUC to collaborate on plans to reduce reliance on gas plants in advance of the SB 887 March 2024 statutory deadline. We also encouraged continued collaborative discussions with LADWP to explore the potential for a joint subsea transmission project with PTEP.

We appreciate CAISO’s continued review of PTEP in this 2022-2023 planning cycle and we stand ready to help in any way that would be constructive.

[1]  Draft Plan pp. 14-15.

[2] https://www.ladwpnews.com/100-percent-carbon-neutral-power-by-035-los-angeles-city-council-approves-landmark-initiative/

[3] Infrastructure Investment and Jobs Act signed into law on Nov. 15, 2021. Find a summary of key electric transmission provisions at: https://www.energy.gov/bil/transmission-facilitation-program [3] and

https://www.energy.gov/bil/program-upgrading-our-electric-grid-and-ensuring-reliability-and-resiliency

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

Cal Western has no comment

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

Cal Western has no comment

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

Cal Western has no comment

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

Cal Western also applauds the CAISO for producing the special study to identify transmission that is needed to reduce reliance on Aliso Canyon Gas Storage facility. Cal Western agrees that PTEP is a robust solution to assist in Aliso Canyon closure while also reducing Path 26 congestion, reducing Local Capacity Resource (LCR) requirements, reducing the current expense of maintaining an aging fleet of gas-fired generation, and providing a myriad of other benefits.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

Cal Western has no comment

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

CalWEA appreciates and supports the very substantial progress that would be made in this draft plan towards several elements in the CAISO’s 20-Year Transmission Outlook aimed at achieving California’s SB 100 climate goals.  We are disappointed, however, at the lack of progress in this cycle on intra-state upgrades that would facilitate clean energy developments in, and directly interconnected to, California, particularly upgrades that would support offshore wind in Northern California and relieve north-south transmission constraints. 

Given a reasonable expectation that there will be significant public challenges to portions of the planned upgrades from the eastern border into the Los Angeles (L.A. )area, we urge CAISO to add the subsea Pacific Transmission Expansion Project (PTEP) to the 2022-23 plan.  This project similarly relieves the transmission-constrained Los Angeles area while bringing additional important benefits and it avoids land-based siting challenges, thus it would additionally serve as a hedge against the potential delays and cost-overruns – and even cancellations -- that are possible with planned project elements that course through numerous sensitive and urban areas.  Moreover, adding the PTEP in the current plan would enable it to capture substantial federal tax benefits and to begin the development process.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

No comment at this time.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

No comment at this time.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

In its December 2022 comments, CalWEA noted that CAISO was planning to use a very different approach to identifying mitigations in the PG&E area than in southern California and the GridLiance planning areas and advocated for uniform treatment wherein the 30 MMT high electrification sensitivity portfolio would be used to bolster transmission upgrades identified as needed in the base case. As this incongruity was not addressed, it is unfortunate, but not surprising, that relatively few upgrades in the PG&E planning area are included in the draft plan. Thus, the effect of the plan is to promote resources in Nevada, Arizona, and New Mexico without providing comparable support for in-state resources, particularly in PG&E’s planning area. (While the plan does support development in San Diego and Imperial Valley, as well as direct interconnections from Baja California, CalWEA disagrees with the statements in the plan summary posted on the CAISO’s blog1 that the plan supports development in the Central Valley and Tehachapi areas. Very limited upgrades are planned for PG&E’s planning area.2)

As a result, the plan does not address the Path 26 constraint, which is needed for Northern California resources to obtain deliverability, does not include upgrades that may be needed to achieve the Central Coast offshore wind in the base resource portfolio, and does not make significant progress toward the offshore wind resources in the 30 MMT plan. Instead, the plan relies on two proposals from the eastern border to relieve transmission constraints into the L.A. basin, at least one of which could prove very difficult to permit. We discuss these issues in turn.

Path 26. The PTEP project would bring many policy benefits, including providing Path 26 congestion relief, reducing the transmission constraints to the L.A. basin, reducing reliance on gas resources in the L.A. basin, providing access to Morro Bay offshore wind resources for the major southern California load centers, and facilitating access to Central Valley resources. In addition, this subsea solution would provide important wildfire risk-reduction benefits and, by interconnecting at coastal sites, would avoid the need for new urban infrastructure. The latter aspect is particularly relevant because the subsea routing is likely to face fewer permitting challenges compared with the fraught paths of at least one of the proposed projects from the eastern border of the state into the L.A. Basin, discussed below. Including PTEP in this year’s plan, while earnestly working to bring in LADWP as a participant, would position the project to capture substantial federal grants and loans that are available from the Infrastructure Investment and Jobs Act legislation that Congress passed in 2021. These benefits would significantly lower costs to ratepayers. Including the project in this year’s plan would also allow the project to begin the development process, which would better enable the state to timely achieve its SB 100 goals.

Offshore wind. While the base resource portfolio includes only 1,588 MW of Morro Bay offshore wind, the sensitivity portfolio includes 3,100 MW of that resource. The methodology used for southern California and GridLiance, but inexplicably not for PG&E, allowed solutions needed for the base case to be expanded based on the sensitivity case.3 Assuming the retirement of the Diablo Canyon nuclear power plant, sufficient capacity could theoretically become available for the base case amount of offshore wind, but there is and will be substantial competition for this capacity and therefore it cannot be counted on, certainly not for 3,100 MW of offshore wind capacity, or more.4  California resources, CalWEA encourages CAISO to add to the plan a 500-kV collector station at Morro Bay. Inclusion in this year’s plan would also expedite this upgrade, which will support the Energy Commission’s adopted 2030 offshore wind planning goals of 2-5 GW.5 Additionally, CalWEA encourages CAISO to make incremental steps to support the CPUC’s plans for major offshore wind capacity at the North Coast. Upgrading the Fern Road Substation to Tesla Substation path, as noted in the CAISO’s 20-year conceptual plan, would be a very reasonable backbone upgrade that would support North Coast offshore wind resources as well as other Northern California resources.

Fraught path of proposed Southern California upgrade. As noted above, the proposed plan relies on two proposals for major upgrades from the eastern California border to relieve transmission constraints into the L.A. basin. CalWEA appreciates that these upgrades generally respond to SB 887, which encouraged relieving LA basin transmission constraints, and we support these proposals. However, at least one of the proposals could prove very difficult to permit. The proposed 500-kV transmission line from the Imperial Valley Substation to a new substation just north of the San Onofre Nuclear Generating Station (IV-to-SONGS) would greatly enhance reliability along the coastal region of Southern California, would provide access to an abundant supply of new renewable energy resources, and reduce reliance on, if not enable the decommissioning of, aging coastal fossil fuels power plants.

But the IV-to-SONGS path is a difficult one. The experience of the Sunrise Powerlink is instructive. It took SDG&E over seven years to permit that upgrade, a 500-kV line that now runs from Imperial Valley to San Diego, partly along the U.S. border. The CPUC rejected a proposed route through the Anza-Borrego Desert State Park and required SDG&E to implement significant and costly mitigation measures to minimize the environmental impact of the project. The initial $700 million cost estimate rose to some $2 billion when finally completed in 2012.

The proposed IV-to-SONGS upgrade will be similarly controversial, because it will likely require a new transmission corridor through areas of the Anza Borrego and/or the Cleveland National Forest and tribal lands, requiring more time to permit and likely leading to costly mitigation measures. (Using the Sunrise Powerlink corridor would not diversify wildfire and other risks.) The proposed plan estimates the cost of IV-to-SONGS at $2.3 billion, only modestly above the cost of Sunrise. And yet the plan estimates that the upgrade would traverse 145 miles – nearly 40 percent more than the distance of the 92-mile Sunrise Powerlink,6 which was built over a decade ago. Thus, the estimated cost seems too low, particularly given the likelihood of delay and mitigations.

None of the above is to oppose inclusion of the proposed IV-to-SONGS upgrade. Regulators and the public are far more cognizant and supportive of the need for transmission to meet urgent climate change goals at least cost. But the potential controversy and cost of this particular path could lead to delay, and concceivably project cancellation, and therefore it would be prudent also to include in the plan the PTEP project, which avoids impacts on local communities and sensitive areas and would bring additional benefits as noted above.

 See http://www.caiso.com/about/Pages/Blog/Posts/Draft-2022-2023-Transmission-Plan-posted.aspx.

 We do appreciate that the plan reflects CalWEA’s proposal for a longer-term solution than the previously proposed series reactor solutions for the 230kV line overloads North of the Greater Bay Area. Specifically, we support the removal of the series cap from Vaca Dixon to Collinsville, which will effectively reduce flows not only on Collinsville-Pittsburg, but also on Vaca Dixon to Collinsville to Tesla.

 For example, CAISO adjusted the CPUC portfolio by adding all resources in the south that have allocated TPD. This was not done for PG&E area. These adjustment played a big role in triggering upgrades in southern California. Additionally, CAISO boosted upgrades using the sensitivity portfolio in the south, but not in the north. For example, there is 2,689 MW undeliverable resources behind Borden-Storey in the sensitivity portfolio in the Fresno LCR Area, but CAISO is only proposal reconductoring for 581 MW resources in the base portfolio.

 The three Morro Bay offshore wind lease areas will be able to support 5 GW or more, given industry norms that enable power densities of at least 5 MW/km2.

 See CEC Report CEC-800-2022-001-REV (August 2022).

 See https://ia.cpuc.ca.gov/environment/info/aspen/sunrise/dnas/PMR_DNA_090110.pdf.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

No comment at this time.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

No comment at this time.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

No comment at this time.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

No comment at this time.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

No comment at this time.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Please incorporate by reference our February 23, 2022, Objections, Comments, and Notice of Intent to bring Petition for Enforcement before the FERC regarding the CAISO 2022-2023 Transmission Planning Process - Draft Study Plan SUBMITTED 03/07/2022, 02:07 PM

On behalf of CAlifornians for Renewable Energy, Inc. (“CARE”) and Michael E. Boyd (“we”) respectfully object to the draft CAISO 2022-2023 Transmission Plan (“plan” herein) as unlawful under Public Utility Regulatory Policies Act ("PURPA"), state, and federal anti-trust laws.

We contend that the proposed CAISO 2022-2023 Transmission Plan is part of a conspiracy by California’s Governor,  the California Energy Commission, the California Public Utilities Commission (“CPUC”), the Governor’s appointed state utility CAISO, and the three investor owned utilities, Pacific Gas and Electric Company (“PG&E”), Southern California Edison Company (“SCE”), and San Diego Gas and Electric Company (“SDG&E”), to unlawfully discriminate against IOU customers with behind-the-meter generation in particular and the plan is designed to exclude behind-the-meter generation participation in CAISO electricity markets in violation of state and federal anti-trust provisions.

California ISO Public [1]

Generation Assumptions

Distribution connected resources modeling

• Behind-the-meter generators: Model explicitly as component of load

• In-front-of-the-meter with resource ID: Model as individual generator

• In-front-of-the-meter without resource ID:

– Model as individual generator if >10 MW,

– Model as aggregate if <10 MW for same technology

In the CAISO’s 20-year outlook planning document, the energy agencies CPUC and CEC accounted for the resources needed to meet California’s 2045 goals and put together a “starting point” scenario, which took into consideration CAISO’s forecasted 2040 peak load, subtracted the contribution of forecasted behind-the-meter resources, and then factored in a projected reduction of 15,000 MW of natural gas-fired generation. CAISO discriminates when it treats behind-the-meter generation as negative load instead of generation.

We claim this is part of a pattern and practice of behind-the-meter generation price fixing, group boycotting, price discrimination, and tying their wholesale sales compensation to their participation in CPUC’s net energy metering (“NEM”) program. See NEM3.0 Rehearing Request Tort Claim at pages 23-24. [2]

As participants in WREGIS our ability to participate in the state’s RPS program has been unlawfully excluded.

[1] From page 30 http://www.caiso.com/InitiativeDocuments/Presentation-2022-2023TransmissionPlanningProcess-Feb282022.pdf

[2] See January 17, 2023, Application for Rehearing of Decision 22-12-056 https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M501/K282/501282480.PDF

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

We object to the contribution of forecasted behind-the-meter resources being subtracted as part of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

We object to the contribution of forecasted behind-the-meter resources being subtracted as part of the Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

We object to the contribution of forecasted behind-the-meter resources generation not being included in the needs assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

We object to the contribution of forecasted behind-the-meter resources generation not being included in the cost-benefits analysis.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

No comment

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

No comment

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

No comment

9. Provide your organization’s comments on chapter 8 Transmission Project List.

We object to the Transmission Project List because the contribution of forecasted behind-the-meter resources generation is not included in the reliability assessment, the needs assessment, the cost-benefits analysis, and the Economic Planning Study.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Our company is developing Cat Creek Energy & Water (“CCEW”) a grid-scale pumped storage power station near Mountain Home, Idaho. We are thankful CAISO will recommend SWIP-North as a potential regional policy driven transmission project. This shovel ready project needs to start serving California and the West. Action during the extension is imperative. Californians need the out of state clean energy this line will transport to meet aggressive climate goals and to keep the lights on. Delay will ultimately saddle California with more carbon producing, air polluting and water consuming Natural Gas plants.

With CCEW at the north terminus, up to 870 MW of overproduction California renewable energy, otherwise curtailed, can be sent north to its 87,120 MWh capacity energy storage facility. In one action, the CAISO can add SWIP-N transmission and identify CCEW’s energy storage as a non-transmission preference. Paired with CCEW the line will bring at-scale benefits to California. This storage has no environmental mine to landfill chemical battery concerns. It does not degrade over its 100-year design life. Incredibly, it cycles indefinitely, delivering energy services while in ‘charging’ mode. 

California is CAISO’s purview, but SWIP-North’s added capacity and reliability is a benefit to the entire West. The new transmission line and CCEW will be a great benefit to Idaho in particular. Idaho Power company’s interest in using part of the line’s South-North direction is welcome news. Both Idaho and California customers can benefit from energy resources that sit outside of their climate zones. Indeed, as we move to one energy market in the West, the bi-directional capacity and reliability of SWIP-N justifies federal assistance in defraying costs. CCEW will be operational in 2027, just in time to capture and enhance a predicted explosion of VRE curtailments by directly connecting a baseload renewable power generator to the California market.

We expand further on these points in sections 4 and 5 of these comments.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

SWIP-N is a reliability solution for California. It has been standing in the wings for too long.  CAISO must pull the trigger. Cat Creek Energy urges CAISO to recommend SWIP-N during this special extension of the transmission plan. CCEW is a multi-module 1,762 MW energy and water storage project in Idaho. We hear from our potential customers, members of the CalCCAs, that they are upset that aggressive policy mandates from CPUC are hamstrung by CAISO transmission delays. CCEW and SWIP-N will allow California LSEs to answer the CPUC charge to deliver daily and multi day resource adequacy to the electrical system. We hope that CAISO is not scapegoated for system failure while a shovel ready Transmission project sits on the drawing board. 

Around about the time Californians who are born this year reach kindergarten, there will be an explosion of policy driven VRE overproduction. SWIP-N and CCEW are uniquely positioned to turn that otherwise curtailed energy into a vital resource for the West. CCEW revolutionizes pumped storage hydropower, the only grid scale tested clean technology in the long duration energy storage category. CCEW ‘s operating attributes mimic natural gas plants without spewing carbon and other harmful pollutants or wasting water. If approved during the extension, SWIP-N will be operational by 2027. Next week, Cat Creek Energy and one of the most respected companies in the world will announce a landmark deal. The upshot is CCEW will be fully operational in 2027, just in time to capture and enhance the predicted explosion of VRE curtailments by directly connecting a baseload renewable power generator to the California market through SWIP-N.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

Cat Creek Energy believes that CAISO’s transmission planning process uses an economic model that is flawed because it does not consider the long life of pumped storage hydro facilities like CCEW. We note that CAISO uses a capital cost to revenue requirement multiplier based on the long life associated with transmission lines. The current thinking is that the multiplier is not appropriate for shorter lifespans expected for current battery technologies. The draft is silent on any consideration for long life energy storage facilities like CCEW. 

Pumped Storage facilities have four or five times the operational life of chemical batteries, without the mine to landfill costs. We believe running a model using the correct multiplier matching the long life of pumped storage energy would produce a favorable economic recommendation for SWIP-N. As CCEW sits at the terminus of the SWIP-N line, it is appropriate to model the effect of CCEW’s large volume, long duration energy storage specifically. Such a model would value the capacity and resource adequacy that could be brought to the California system through SWIP-N. 

We believe that the current exclusion of pumped storage hydropower in the model encourages last minute reliance on polluting Natural Gas plants. These plants have proven unreliable during heat waves, are often built in disadvantaged communities and consume large quantities of water.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Protecting and restoring natural ecosystems and imperiled species through
science, education, policy, and environmental law
Submitted online via comment submittal portal
April 25, 2023
Jeff Billington
Director, Transmission Infrastructure Planning
California Independent System Operator (ISO)
RE: Comments on ISO’s 2022-2023 Draft Transmission Plan
Dear Mr. Billington:
The Center for Biological Diversity (Center) submits these comments in order to help improve
transmission planning in California. The Center support California’s clean energy goals, and we
believe this can be achieved through responsible and appropriately-sited clean energy
infrastructure in concert with Executive Order N-82-20.
SCE Eastern Area
The Center understands that the ISO has identified constraints in the transmission system in the
region with mitigation strategies for following lines: (1) Devers-Red Bluff 500kV; (2) Colorado
River-Red Bluff 500kV.
The Center appreciates the ISO’s focus on increasing the rating of these two lines to maximize
the use of the existing transmission system. However, we are concerned about the decisionmaking
process for these proposals, as the draft Transmission Plan does not include additional
mitigation strategies that have been contemplated in the transmission planning stakeholder
process. The desert lands in this region provide habitat to a variety of special-status desert
species, as well as providing carbon-sequestration and other climate benefits, and we are
concerned about the ISO’s future consideration of expanding the transmission system in the
region due to potential environmental conflicts1, which could cause both project complexity and
delays and move the state backwards on its commitments to nature-based climate and
conservation solutions.
We are also concerned about the ISO potentially piecemealing an expansion of the transmission
system in the area and/or moving forward with projects that may impact California’s critical
1 The Trout Canyon – Sloan Canyon 500 kV Upgrade: Desert tortoise throughout Pahrump Valley outside
the City of Pahrump, likely affecting important desert tortoise habitat linkages and the Trout Canyon
desert tortoise recipient translocation site where desert tortoises have been moved from other
development sites. Beatty 230 kV Project (Build 32 miles Beatty – Lathrop 230 kV line next to the
existing 138 kV line in an adjacent ROW; Build 30 miles Johnnie Corner – Valley Switch – Lathrop 230
kV DCTL lines next to the existing 138 kV line in an adjacent ROW): Desert tortoise, including Priority 2
habitat linkage. Existing transmission intersects BLM lands with high conservation value.
(https://gblcc.databasin.org/maps/new/#datasets=21240fc2bafe460d922d212edc3c9786 )
2
desert ecosystem under a sense of urgency without consideration of well-proven mitigation
strategies, despite its statements that the ISO can identify these strategies as the preferred
mitigation solutions in the same manner as operational solutions.
The ISO should provide greater clarity on the needs in the region and should look at non-wire
alternatives in consultation with the California Public Utilities Commission (CPUC), such as
grid-enhancing technologies, storage-as-a-transmission asset, and others, before considering
expanding the transmission system in the region.
Prioritizing Low-Environmental Implication Areas
The ISO identified the Central Valley as a prime area for clean energy development with the 20-
year Transmission Outlook estimating a potential of 30 gigawatts. This region was also identified
by the State as a prime area for “smart from the start” clean energy projects more than a decade
ago. Unfortunately, the ISO has only allocated about $70 million to support clean energy
development in the region compared to $7.53 billion in the overall policy-driven transmission
portfolio that is pushing clean energy development to the desert and out of state.
In particular, the Central Valley has multiple aging 70kV and 115kV power lines that need to be
upgraded beyond the bare minimum in order to unlock clean energy development in the region.
To ensure deliverability of these new clean energy resources, the ISO would also need to look at
upgrading the transmission pathway from the Central Valley to load centers (e.g., Path 15).
Alignment with Land Use Screens and Other Processes
Along with looking at transmission development to develop clean energy in low-conflict areas,
the ISO must also coordinate with the CPUC and the California Energy Commission (CEC) to
ensure transmission investments are aligned across land use screens, the busbar mapping process,
and the resource planning process. Some misalignment between these processes is evidenced by
the split of resources between Northern and Southern California and the ISO’s utilization of
outdated procurement portfolios by load-serving entities.
We believe land use screens should have a greater impact on these processes, as land use screens
can be utilized to target development in low-conflict zones and can avoid sensitive resources,
longer permitting time, the threat of litigation, and higher costs. The CEC’s updated Land Use
Screens for Electric System Planning should be integrated into RESOLVE and busbar mapping
at the CPUC to identify areas of high and low environmental conflict and direct energy
development and transmission to areas of low environmental conflict.
Energy planning should not be separate from land use policies – coordination across these
various processes with a greater priority for land use policies is critical for deploying new
generation and infrastructure projects and have an overall “no-regrets” strategy to meet
California’s growing clean energy needs while protecting the State’s wildlife and diverse
habitats.
3
To note, the Central Valley not only has many total acres that meet the land use screens, and also
the most concentrated clean energy portfolio of any area. This aligns well with the need to
prioritize low-conflict clean energy development as part of an overall no-regrets strategy.
Conclusion
Thank you for considering these comments. We look forward to continued participation in these
processes. Please include me with all notices associated with this process.
Sincerely,
Ileene Anderson
Senior Scientist
Center for Biological Diversity

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

EDF-R appreciates this opportunity to provide brief comments on the 2022-2023 Transmission Planning Process draft report. EDF-R applauds the general proactive direction of CAISO’s draft results. The proposed policy projects are needed to meet California’s GHG goals. EDF-R looks forward to CAISO providing an estimate of future High Voltage Transmission Access Charges (TAC) with this version, those results at the May Board meeting.  

EDF-R observes that in other venues stakeholders have suggested changes to the deliverability methodology that would “free up” ~10 GW in deliverability. As it relates to the transmission planning process, EDF-R urges CAISO not to undertake any transmission study methodology changes that would slow the velocity pace of transmission development. Meeting the state’s GHG goals will require transmission at a magnitude never seen before, and previous large transmission projects in California (i.e.,TRTP, 10 West Link, etc.) have taken at least 10 years at a minimum to bring into service. Given the need to bring 85 GW of new resources online essentially We collectively cannot afford to undertake any process changes that have the (unintended) effect of slowing TPP process.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

No comments at this time. 

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

No comments at this time. 

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

EDF-R is supportive of the overall recommendations in the Draft Transmission Plan, and the recommendation for significant amounts of new and upgraded transmission in order to meet California’s energy needs and climate goals. But EDFR has lingering concerns that the proposed policy upgrades may be insufficient of what new transmission capacity is ultimately needed in the Colorado River-Redbluff-Devers area. 

 Two policy projects were recommended for approval to mitigate the Devers-Red Bluff 500 kV constraint in the base portfolio: 

• Colorado River-Red Bluff 500 kV 1 Line Upgrade 

• Devers-Red Bluff 500 kV 1 and 2 Line Upgrade 

EDF-R continues to be concerned that this area is not getting the magnitude of upgrades needed to accommodate development interest and that the CAISO’s recommendations are not the magnitude needed for current or future need.  

Figure 1: Colorado River – Devers 500KV corridor 

The transmission corridor between Colorado River and Devers serves as a vital connection between the strong solar resources in Riverside County and the load centers in Southern California. Recent renewable energy development in this region has already filled all available transmission capacity and existing projects are experiencing severe curtailment and congestion due to limited transmission.  

Several new projects are also proposed in this region and they are experiencing difficulty in acquiring transmission access and deliverability. In addition to the in-state projects, the transmission in this region will also help deliver out of state wind and solar resources and the new Ten West transmission line in Arizona is expected to connect in the Colorado River area. 

In order to meet the state’s ambitious clean energy goals, a third transmission line will be necessary in this Colorado River-Redbluff-Devers area of the state, not just transmission upgrades.  

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

EDF-R appreciates all the hard work put into the economic models and values the important information these models provide. EDF-R would like to better to better understand how the CAISO is applying OMS constraints, with lower ratings, as is experienced in actual market operations. Based on asset performance in Riverside County it is EDFR’s experience that outages on the Colorado River-Devers-Valley segment of lines often result in OMS constraints that are more restrictive and result in increased congestion and curtailment. The current methodology of not applying OMS constraints under outage scenarios understates the congestion and curtailment experienced in real world operations. This will become even more impactful as more resources are built in Riverside county as well as other renewable rich zones. 

Additionally, the CAISO should reevaluate the curtailment bid prices assumptions used in the modlel post IRA. PV projects will likely take PTC and be bidding the negative grossed up PTC value closer to -$40? in 2033, whereas generators built Pre-IRA will not be able to bid down to these levels and will experience higher levels of curtailment. It does not seem that the current models are accounting for the bidding changes.  

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

No comments at this time. 

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

No comments at this time. 

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

No comments at this time. 

9. Provide your organization’s comments on chapter 8 Transmission Project List.

No comments at this time. 

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Fervo Energy (Fervo) is concerned about the opaque nature of the April 11, 2023 stakeholder call discussion. The lack of recordings of Transmission Planning meetings is exclusionary towards those stakeholders who lack the flexibility to attend a full-day meeting. Stakeholder engagement is a critical aspect of RTO governance, and includes ensuring transparent access to the transmission planning process. The discussions that take place in stakeholder meetings is a foundational component of the transmission planning process, and should not exclude those who are unable to participate for an entire day. Similarly, a lack of minutes for these meetings excludes those who wish to follow the proceeding but are unable to devote an entire day to attendance. 

Another important element to lend transparency to the process is allowing participants to see the list of other participants. Whether or not this was a temporary “glitch” due to Webex, participants’ lack of knowledge about the other entities participating in a stakeholder meeting only makes the transmission planning process more opaque.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

Fervo appreciates the opportunity to comment on the 2022-2023 Draft Transmission Plan (Draft Plan). Fervo continues to see positive enhancements being made to each year’s plan and looks forward to continuing to work with the CAISO to continuously improve the planning process. Coordination and joint strategic direction between CAISO, CPUC, and CEC is necessary to ensure achievement of California’s clean energy objectives, and the Draft Plan is an important step towards achieving alignment across policy, planning and operating entities.

The need for 70GW of installed capacity by 2033, as envisioned by the TPP, presents a daunting challenge for CAISO to manage increasing load, rapid renewable development, and ambitious climate goals. The massive resource buildout required by CPUC procurement planning will require commensurate levels of transmission buildout. To support this development, CAISO will need to continuously expand transmission capacity and increase its ability to study and process interconnection requests in the immediate future. 

Achieving these goals will require sustained and increased coordination with the MOU entities, as well as significant reform, especially the interconnection process and procedures for securing Maximum Import Capability. Out-of-state resources and long-lead-time resources are necessary for meeting CPUC procurement orders, grid reliability and carbon emission goals. Together with the MOU entities, CAISO should prioritize meeting these unique policy goals and enable the efficient interconnection and delivery of the associated compliance resources.

Plans to focus procurement efforts on areas where resources can connect to the grid with minimal or no upgrades are counterproductive. Such an approach would have a discriminatory effect on resource technologies that face restricted siting flexibility, either by their resource availability or zoning and permitting conditions. Areas with the best subsurface thermal resources and potential may not be those in which resources can connect to the grid with minimal or no upgrades. However, these resources remain necessary to meet policy directives and carbon-free reliability needs. CAISO should focus on ensuring transmission investment supports the procurement of the best resources, rather than trying to push procurement into areas needing the least new investment. 

Additionally, enabling new generation only around transmission that doesn’t require extensive upgrades will concentrate resources in a few areas and reduce grid resilience. Geographically dispersed resources distribute risk and exposure to various hazards, such as wildfires, extreme flooding, earthquakes, and other weather conditions that may be exacerbated by climate impacts. Artificially limiting development to certain areas will concentrate the system’s risk exposure, ultimately proving counterproductive to the supply of clean, safe and reliable energy to meet the state’s policy goals.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

No comment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

The projects identified in the Policy-Driven Need Assessment are an important step towards accessing the resources called for in the CPUC’s transmitted portfolio and California’s renewable energy aspirations more generally. The Plan facilitates access to increased amounts of renewable energy from both within and outside of CAISO.

Fervo has noted in previous comments that increased attention should be devoted to the deliverability of geothermal into CAISO, especially when considering CPUC’s specific direction¹ to study the deliverability and corresponding transmission needs related to out-of-ISO long lead-time resources. Given out-of-state geothermal’s critical role in providing reliability to the California grid, it is imperative that CAISO further improve the deliverability process for imported geothermal resources. 

As such, Fervo is particularly pleased at the Plan’s inclusion of upgrades to facilitate the import of more than 1GW of firm, clean, geothermal energy in the base portfolio, and close to 2GW in the sensitivity portfolio. These geothermal resources will help California achieve its reliability and renewable energy goals. However, even these expectations may prove to be too conservative. The rapid pace of geothermal technology innovation means that the data inputs, learning curves and resource assumptions that underpin California’s planning analysis are quickly outdated. Near-term updates to the base portfolio are likely to include potentially significant increases in new geothermal resources. CAISO should work with the CEC and the CPUC to develop scenarios that can better capture these market developments.

The policy-driven upgrades, including those in the East of Pisgah Interconnection Area and the SCE North of Lugo Interconnection Area are critical to LSEs ability to meet procurement requirements issued by the CPUC² by enabling renewable developments and imports to CAISO that will support California’s policy objectives. Specifically, the Trout Canyon-Lugo 500 kV Line and the Lugo–Victor–Kramer 230 kV Upgrade are critical to ensuring deliverability of geothermal resources into the ISO. Similarly, proposed upgrades to the GLW/VEA area, specifically the Beatty 230 kV line, are necessary to facilitate renewable imports to the CAISO area.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

No comment.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

No comment.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

CAISO’s Maximum Import Capability expansion process appears misaligned with the resource procurement called for by CPUC. This disconnect means that LSEs have difficulty procuring out-of-state resources, even then they provide the most readily-available and economic option for meeting reliability needs and satisfying CPUC procurement orders. As noted in the Draft Plan: 

“The mitigations proposed in the TPP must allow the internal resources with prior TPD and DGD allocation to remain deliverable before MIC is allowed to permanently increase to account for import resources included in the CPUC portfolio and if possible to allow for further MIC increase due to MIC expansion requests.”

Deliverability must be expanded to ensure that import resources included in the CPUC portfolio as well as those with valid MIC requests (to serve RA requirements) are able to achieve import allocation in accordance with their commercial and operational requirements.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

No comment.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

No comment.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

Gallatin Power Partners is supportive of and excited about the recommendations for the Trout Canyon-Lugo 500 kV line and Beatty 230 kV upgrades included in the Draft Transmission Plan. Gallatin has been actively developing solar with co-located battery projects in Nevada over the past few years. With the release of the Draft Transmission Plan, Gallatin submitted a total of 2,000 MW of interconnection requests for their Nevada projects into the CAISO Cluster 15. 

In addition, Gallatin has reviewed GridLiance West’s 2023-2024 Economic Study Request and recommends that CAISO expedite consideration of the Beatty - Esmeralda Project in future cycles. The Esmeralda area has over 11 GWs of proposed renewable projects, which would be easier to access with the addition of the Beatty-Esmeralda Project.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

These comments reflect my own personal views and are not sponsored by Gridworks.   The Draft 2022-23 TPP represents a major step forward in coordinated transmission and resource planning for CA.  Still, more work is needed to enable faster transmission development on a timeframe that will ensure that transmission is available in time for new resources to be interconnected.  CA will not be able to reach its decarbonization goals if new clean resources have to wait ten or more years for new transmission lines to be planned, sited and constructed.  

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

Chapter 3 generally does a very good job of anticipating the transmission that will be needed to make new policy-preferred resources deliverable to CAISO load.  However, a more creative approach than that employed currently may be needed in the case of major new transmission projects that are likely to face significant permitting and siting challenges.  The primary example in the current draft TPP is the proposed Imperial Valley to North of SONGS 500 kV line.  Based on simple geography, such a line will be extremely challenging to permit, and may prove to be simply infeasible, given the mountains, parks and developed suburbs that lie in the proposed path.  The previous history of the Valley-Rainbow and Sunrise Powerlink projects suggests that if such a line is feasible at all from a permitting standpoint, it may end up looking very different from the conceptual project identified in the draft Plan.  In Appendix F of the draft TPP, Section F.15, CAISO concludes that that Alternative A2 would be the most economic, but that line may not be permittable as outlined, or the required environmental mitigations may lead to costs higher than those projected for the other alternatives, such as A1 or C.  There is a real risk that if CAISO solicits competitive proposals only for Alternative A2, the project eventually approved for construction could be much more expensive than anticipated, and more expensive than some of the other alternatives if those had been pursued instead.  And at the end of the day, the line that is eventually permitted may not even look like A2, but more like one of the alternatives. 

For these reasons, the competitive solicitation process for this project (and others like it, such as transmission for North Coast wind in the next TPP) may need to be modified to allow for proponents to propose alternative approaches for meeting the identified need to move power into the coastal load centers of southern CA.  While this would certainly complicate the selection of a winning competitive proposal, that may be less of a problem than putting all of the eggs in the Imperial Valley to North of SONGS basket.  It is not difficult to imagine a multi-year CPCN process that ends up selecting a Southeast California Transmission Development plan very different from IV to SONGS, or that requires such expensive mitigation that IV to SONGS would no longer be the preferred alterantive.  A simple comparison of the approved Sunrise Powerlink to the intial proposal for that line demonstrates how much a proposed line can change in the course of the siting process.  

At the end of the day, it might even make sense to allow more than one potential transmission solution to move forward into the permitting and siting phase, with the understanding that only one ultimate solution will prevail.  While such an approach would entail higher upfront costs, the line that is ultimately approved could end up being cheaper than what would result from relying exclusively on the IV to SONGS option as the only acceptable alternative.  The challenge of this particular transmission project is likely to be so great that a new and more creative approach may be warranted.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

The proposed Transmission Project List makes sense, but CAISO should consider modifying its competitive solicitation process for permtitting-challenged projects such as the Southeast California Transmission Development plan such that the creativity of the marketplace can be brought to bear on this monumentally difficult transmission challenge.  

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Golden State Clean Energy (“GSCE”) applauds the significant work CAISO has done in this Transmission Planning Process cycle to address the resource portfolio capacity growth and respond to the various policy needs of the State of California, including studying transmission needs related to out-of-CAISO long-lead time resources and the additional planning to preliminarily address SB 887. The Draft 2022-2023 Transmission Plan represents a historic investment in new transmission, and GSCE supports CAISO taking major steps forward to approve new transmission projects to meet California’s growing need for new transmission infrastructure. 

For California to reliably meet its policy goals, this level of investment and planned development must continue. This draft plan will bring significant benefits to the ratepayers of Southern California, but noticeably absent from the plan is a clear strategy for development in the Central Valley and for clean resources to reach load in Northern California. CAISO has noted its vision of future transmission plans continuing to build off this TPP cycle, which is a reasonable plan and helpful for level-setting stakeholders’ expectations, but the planning updates that are occurring around the CEC’s land use screens and the CPUC’s busbar mapping, as well as the effort already undertaken for the 20-Year Transmission Outlook, all show considerable clean energy resource potential in the San Joaquin Valley that California is seeking to capture. Considering these planning efforts, there should be an expectation that, similar to what is seen in Southern California in this draft plan, the largest region of in-state renewable and storage potential in California, the Central Valley, will be addressed in a significant way starting with next year’s transmission plan.  We suggest CAISO make that plan and commitment clear when presenting this draft plan to the Board. GSCE looks forward CAISO continuing to build on the momentum it started this year in the next TPP cycle. 

Location of California resources and transmission upgrades

• CAISO provides the following in its draft transmission plan: “The network upgrades are recommended in this plan to make all of the base amounts available and, in Southern California, to also make most of the sensitivity amounts available as well.”[1]  As one might expect, the decision to focus on Southern California when considering the sensitivity portfolio has led to nearly all policy-driven projects recommended for approval to be located in Southern California. A mere 70 million dollars of the 7.5 billion proposed to be spent on policy projects on all ratepayers’ behalf would benefit Northern California.
  • We do not oppose the increased role the sensitivity is playing in Southern California or deny that these types of investments in the grid in Southern California are needed. In fact, we strongly support CAISO looking toward the sensitivity when determining what transmission projects to approve, and we would like to see CAISO make a commitment to using the sensitivity for the San Joaquin Valley when recommending policy-driven transmission projects in the next TPP cycle.
  • Solar and storage capacity in the Fresno and East Kern areas become much more significant in the sensitivity (over a threefold increase compared to the base case). The sensitivity portfolio should be able to justify a level of development in Northern California similar to the new high voltage lines and substations that are recommended in Southern California. If there is additional information or outstanding issues to address that would help inform stakeholders and the CPUC of any uncertainty CAISO has regarding Norther California’s future transmission needs, we would appreciate CAISO further discussing such shortfalls so all parties can be more responsive in future TPP and IRP cycles.  
• CAISO also noted that Path 26 has recurring congestion with large congestion cost. The main driver CAISO identified was the portfolio’s renewable resources in Southern California trying to reach load in Northern California.[2] Congestion on Path 26 in the south to north direction means that the disproportionate amount of new resource potential unlocked by recommended transmission projects in the south cannot reliably reach load in Northern California.  
  • Despite the economic studies focused on Path 26 congestion and other nearby areas, no economic projects were selected to address this congestion. 
  • We urge CAISO to continue to examine Path 26 and Path 15 in the 2023-24 TPP. 
• Additionally, we are concerned that Central Valley solar is too often mapped to the low voltage system. 
  • For example, CAISO’s economic study of the Panoche/Oro Loma area observed solar generation in the 115 kV system contributing to the congestion.[3]
  • This may help explain why more modest reliability-driven upgrades are approved in the Northern California compared to Southern California. 
  • Mapping resources to the high voltage system is more reasonable given the need to facilitate the significant capacity growth being called for in long-term planning. Additional high voltage points of interconnection are needed in areas like the Central Valley, as well as 500 kV lines to begin delivering to load in the Greater Bay area. 
• We recognize CAISO is in its final stages of developing this transmission plan and that the portfolio mapping process has a major impact on the types of issues we are raising. However, it is appropriate to step back now and consider the future system that this TPP will help put in place and look at how this transmission plan compares with longer term needs, such as the high voltage transmission envisioned in the 20-Year Transmission Outlook. 
  • CAISO notes that the “2022-2023 transmission plan is a transitional step, recognizing the ISO and industry at-large are not yet positioned within this single planning cycle to address the full impact of the pivot to these new challenges.”[4]  GSCE appreciates the realities of this situation but hopes to receive more insight into what is needed to set up these future TPP cycles. 
  • We urge CAISO to share any concerns that have arisen during this TPP cycle in the upcoming IRP inputs and assumptions process where busbar mapping will be examined and updated to include the new CEC land use screens. The CPUC is wrestling with how to look at new transmission versus upgrading the existing system in the IRP, and CAISO can provide a valuable voice in speaking to the benefits of interconnecting to the high voltage system and providing renewables access to the bulk grid.
  • We also find CAISO’s input important as the CPUC creates a portfolio of resources that are responsive to SB 887. 
  • The Central Valley needs a coordinated plan for bringing on tens of gigawatts of solar and batteries in the coming decade and delivering this to load. This requires high voltage points of interconnection and direct access to the bulk system, in parallel with strategic gas retirement in Northern California load centers that continue to be relied on following the 2022-23 TPP. 

Other comments

• Table 3.5-8 of the draft plan shows significant curtailments behind the Los Banos 500 kV constraint. No mitigation is recommended because the constraint only appears in the sensitivity. CAISO should look at approving a Category 2 project so mitigating this constrain is part of a detailed study next year. A Category 2 project could also be used to provide an additional transmission solution with cost information that the IRP and RESOLVE can consider. 
• In general, we urge CAISO to provide an updated and much more robust list of potential transmission solutions to the CPUC for RESOLVE to optimize. That should include new substations and high voltage transmission lines. The updated list should be incorporated into the IRP’s upcoming inputs and assumptions process. 

[1] Draft 2022-2023 Transmission Plan, at pg. 3, April 3, 2023. 

[2] Presentation on Draft 2022-2023 Transmission Plan, Economic Assessment and Production Cost Simulation, at slide 5, April 11, 2023. 

[3] Presentation on Draft 2022-2023 Transmission Plan, Economic Assessment and Production Cost Simulation, at slide 15, April 11, 2023.

[4] Draft 2022-2023 Transmission Plan, at pg. 12, April 3, 2023.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

The Large-scale Solar Association (LSA) provides comments on two topics:

1. LSA supports CAISO’s reliance on the sensitivity portfolios to inform its decisions on the scope of recommended transmission upgrades and requests clarification regarding which upgrades were triggered by the base v. sensitivity portfolios.
2. LSA requests confirmation that the energy storage resources that CAISO contemplates using to mitigate transmission constraints are part of either the base or sensitivity portfolios.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

LSA requests confirmation that the energy storage resources that CAISO contemplates using to mitigate transmission constraints are part of either the base or sensitivity portfolios.  In Section 1 of the Draft TPP, CAISO points out that:

“Energy storage solutions can be a transmission resource or a non-transmission alternative (e.g. market-based).  The ISO has considered storage in both contexts in the transmission planning process, although market-based approaches have generally prevailed due to their ability to also participate in the electricity market.” (p. 27)

It is unclear, however, in some instances whether CAISO’s proposed energy storage mitigations contemplate resources that are included in the TPP portfolios (market-based) or something else (potentially a transmission resource). 

For example, CAISO described the potential mitigation for the Greater Bay and North of Greater Bay Off-Peak Deliverability Assessment as “portfolio energy storage in charging mode”, which clearly indicates that the storage is included in the portfolios (p. 65).  However, CAISO describes the potential mitigation for the SCE North of Lugo area as Planned NOL CRAS or “energy storage charging”, without specifying whether the storage is included in the TPP portfolios (p. 86).  LSA requests that CAISO clarify whether energy storage relied upon for mitigations is included in the TPP portfolios such that it has been tested as part of a deliverable portfolio for which transmission upgrades are triggered if needed.  If not, LSA requests that CAISO confirm what type of storage it contemplates relying upon and how it will function on the grid.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

LSA has no comment at this time.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

LSA supports CAISO’s reliance on the sensitivity portfolios to inform its decisions on the scope of recommended transmission upgrades.  In Decision 22-03-004, the CPUC provided CAISO with a base case portfolio that meets the 42 million metric ton (MMT) GHG emissions target by 2032.  That decision also instructed CAISO to study a sensitivity portfolio that meets the 30 MMT GHG emissions target.  The CPUC has since adopted this 30 MMT portfolio as the base case for the 2023-24 TPP.  The 30 MMT portfolio calls for 86 GW of new resources by 2035, which nearly doubles the nameplate capacity on the system within 12 years (Decision 23-02-040, p. 47). 

Since transmission planning and construction typically has lead times of 8 to 12 years, it is important to begin the process as soon as possible.  Although the sensitivity case on its own does not provide justification for CAISO to approve new transmission projects, they can and should influence CAISO’s decisions about which potential mitigation is most appropriate.  As stated in Decision 23-02-040, “its is just a matter of exactly when, and not if, the transmission will be needed”. (Decision 23-02-040, p. 49).

To provide maximum transparency to the stakeholder community, LSA requests that CAISO provide more detail regarding whether the base or sensitivity portfolio triggered each upgrade.  CAISO appears to have provided this information for some upgrades but not for others.  For example, CAISO explains that the proposed Lugo-Victor-Kramer 230 kV Upgrade addresses constraints and voltage instability identified in both the base and sensitivity portfolios (Draft TPP p. 85).  But for the proposed Colorado River – Red Bluff 500 kV 1 Line Upgrade, CAISO only states that it addresses the Colorado River-Red Bluff 500 kV constraint, without indicating whether the upgrade will mitigate constraints triggered by the base and/or sensitivity portfolios.  LSA recommends that CAISO provide a more comprehensive discussion of whether the base or sensitivity portfolios triggered each upgrade so that stakeholders can identify which areas still have constraints that CAISO will need to address in the next TPP cycle.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

LSA has no comment at this time.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

LSA has no comment at this time.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

LSA has no comment at this time.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

LSA has no comment at this time.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

LSA has no comment at this time.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

IBEW Local 1245 proudly represents over 28,000 outside linemen, groundmen and utility workers in Northern California and Nevada.  We are the exclusive hiring hall for line installation on the SWIP North transmission project.  We are pleased that CAISO has identified SWIP North as a policy-driven project in this draft transmission plan for 2022-23, and we urge CAISO to approve SWIP North now and wait no more.  Please see our further comments on Chapter 3.   

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

IBEW Local 1245 is pleased that CAISO has identified SWIP North as a policy-driven project in this draft transmission plan for 2022-23, and we urge CAISO not to linger any further to approve the project.  With CAISO’s current TPP plus last year’s plan, there is over $12b of transmission projects in CAISO alone that are planned to be placed in service between now and 2032, and it appears CAISO must add more to the list next year to address off-shore wind as well as other policy and reliability needs.  Furthermore, there are two major projects planned by NV Energy in Nevada that will require significant resources in the same timeframe.  SWIP North, as an already permitted and designed project, is uniquely positioned to keep our skilled workforce busy and further train our apprentices prior to that glut of work we are anticipating in 2027 and beyond. Failure to approve SWIP North this year will certainly reduce the availability of labor and potentially increase the cost of labor as our current collective bargaining agreement expires in May 2027. Again, we urge CAISO to approve SWIP North now and wait no more.  

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

LS Power applauds CAISO’s effort to develop a draft transmission plan that is forward looking and takes into consideration the future system needs to integrate renewables in support of meeting the SB100 policy objectives.  The additional coordination with the California Public Utilities Commission (CPUC) and the California Energy Commission (CEC) based on the December 2022 update to the  Memorandum of Understanding (MOU) has already proven beneficial in the proactive direction that this year’s draft transmission plan has taken.   

LS Power appreciates CAISO’s continued work on the evaluation of SWIP North as part of the current TPP.  Approval as part of the current TPP would facilitate SWIP North being in service in 2026 -- in time to allow Out of State (OOS) resources to support the recent incremental CPUC reliability procurement targets for 2026 through 2028 and it will enable earlier realization of the identified reliability and economic benefits.  Additionally, approval of SWIP North in the current TPP cycle will significantly reduce cost and schedule risks that are inherent with any further delay. 

However, while LS Power understands and supports CAISO’s desire to optimize the cost of the project for ratepayers, we are concerned that waiting for commitment from other entities interested in the northbound capacity could create a new chicken-and-the-egg scenario leading to costly delays.  A clear policy need for the project exists in California and reliability and economic benefits resulting from the project will accrue to California irrespective of interest from third parties in northbound capacity. CAISO’s approval of SWIP North in the current cycle will provide certainty to LSEs, generators and those interested in northbound capacity that the project will be built and, importantly, provide encouragement to the latter to come on board.  Approval now does not forego an opportunity to optimize the cost of the project for ratepayers but instead enables such conversations to progress with certainty.  Approving SWIP North now provides certainty that ratepayers will realize the maximum policy, economic and reliability benefits. Waiting to approve ensures that such benefits will be reduced.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

LS Power has no comments at this time.  

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

LS Power has no comments at this time.  

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

LS Power encourages CAISO to approve SWIP North as part of the current 2022-2023 TPP cycle. As demonstrated by the 1,062 MW of OOS wind capacity from Idaho/Wyoming in the base portfolio and 1,000 MW of OOS wind capacity from Idaho in the sensitivity portfolio, and consistency of this same amount being reflected in the 2023-2024 TPP base case, it is clear that a project such as SWIP North is required to support California’s policy needs.  In addition to the CPUC’s request in accordance with SB 887 (Becker, 2022) that CAISO identify high priority transmission projects and consider whether to approve them as part of the 2022-23 TPP, the CPUC has also encouraged CAISO to “get a head start on identifying any associated transmission needs by considering the results of the similar sensitivity case that is currently undergoing analysis in the 2022-2023 TPP cycle”.[1]  SWIP North is uniquely situated as an advanced development project with significant cost advantages given that it comes with transmission rights over the ON Line segment connecting Robinson Summit Substation to Harry Allen Substation, which is nearly half of the length of the entire SWIP path. ON Line is already in service and is paid for by Nevada ratepayers.  Given the demonstrated policy need and the significant economic  and reliability benefits (see further discussion below) that come with such a unique opportunity, the current cycle is the ideal time to approve the project.

Additionally, CAISO has indicated potential interest from Idaho Power in a portion of the northbound capacity if SWIP North is approved by CAISO.  This could result in a unique cost saving opportunity for California ratepayers that could be realized if CAISO approves SWIP North in the current TPP.  This approach will provide certainty for Idaho Power that the project is moving forward and that it can be analyzed in and counted on as a resource in its upcoming integrated resource plan.  Failure to approve SWIP North in the current cycle may result in a loss of such opportunity as Idaho Power plans future resources.  LS Power is committed to exploring with CAISO opportunities to reduce the costs of the project for California ratepayers via northbound capacity sales or otherwise and believes these discussions will be more fruitful if CAISO provides schedule certainty. 

Further delay of the approval of SWIP North will increase cost and schedule risks at the expense of ratepayers.  Costs continue to escalate at a record pace for both equipment and labor.  Each month that equipment orders and construction contracts are delayed brings new cost increases from inflation, supply chain challenges, and market demand dynamics.  The cost of capital has also continued to increase exacerbating the impact of increased construction costs.  Adding to the cost concerns are availability of major equipment.  For example, major substation equipment such as reactors and phase shifting transformers have unprecedented lead times of three years or more, and manufacturers have indicated those lead times are only going to increase with the amount of high voltage transmission projects being planned worldwide for installation between 2027-2032.  SWIP North is uniquely situated to secure equipment for a 2026 in service date if CAISO approves the project in this cycle.  For this same reason there is a risk of labor shortages if the project is delayed as local qualified linemen and other classes of labor will be needed to construct the other forty-six projects recommended for approval in the current cycle. Furthermore, the current collective bargaining agreement includes established rates through May 2027, after which they will be renegotiated.  SWIP North reflects a unique opportunity as an advanced development project that can take advantage of available equipment and labor ahead of the onslaught of resources required to support the $9 billion of transmission needs recommended for approval by CAISO this year in addition to the $3 billion already approved in CAISO’s 2021-2022 Transmission Plan. 

[1] CPUC R.20-05-003, February 23, 2023, Decision Ordering Supplemental Mid-Term Reliability Procurement (2026-2027) and Transmitting Electric Resource Portfolios to California Independent System Operator for 2023-2024 Transmission Planning Process, page 50 at: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M502/K956/502956567.PDF  

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

LS Power appreciates CAISO’s economic evaluation of SWIP North.  In addition to the economic benefits that were assessed by CAISO, it is important to consider additional factors which further contribute to the economic benefits of SWIP North. 

Load diversity between California and neighboring systems will provide significant benefits.  SWIP North will provide a transmission path to allow California and neighboring systems to take advantage of this natural diversity and, specifically for California, it will provide access to excess capacity that is available when California has historically experienced capacity shortages. 

SWIP North creates incremental import capability of approximately 1,100 MW to California from Idaho.  Consistent with CAISO’s TEAM methodology, it is important to consider system capacity benefits created by this new import path. Capacity benefits also have an “indirect” component resulting from a more competitive market in California driving lower prices and cannot be ignored. CAISO has considered such benefits in their evaluation in approving other projects in the past.

As noted in the draft report, the economic benefit analysis does not take into account the transmission capacity rights LSEs would have to procure to bring Idaho resources to California in absence of a direct wheel-free path to CAISO that is being offered by SWIP North.

In addition to the benefits of congestion relief on COI as identified in CAISO’s assessment, it is important to consider the benefits that this parallel transmission path offers in terms of resiliency during wildfire or extreme heat-related events.  For example, SWIP North would help alleviate congestion at the California-Oregon border that limited CAISO’s ability to import critical energy resources during the August 2020 extreme heat event and July 2021 Bootleg fire. 

In addition to SWIP North’s ability to cost-effectively deliver Idaho wind to Southern California and increase market transactions under the current day-ahead market design, the project will provide substantial additional benefits in both EIM and the new Extended Day-Ahead Market (EDAM).  With the approval of EDAM, commitments from CAISO and PacifiCorp, and expectations of additional members in the Northwest (such as Idaho Power), SWIP North will provide a valuable new path in the Western EIM and EDAM markets. While EDAM transmission capability is not yet determined, PacifiCorp currently has limited transmission capability from Idaho to CAISO in the EIM.  SWIP North is expected to increase the available transfer capability between CAISO and PacifiCorp by about 1,100 MW in EIM and EDAM.

Being able to schedule substantially higher market-based exports between California, Idaho, and the Northwest in EIM and EDAM will have several additional economic and policy benefits not captured in the draft transmission plan, including (1) reducing renewable generation curtailments in California, (2) allowing California customers to benefit from revenues for surplus solar generation, (3) providing substantial additional flexibility and ramping capability, (4) reducing the cost of supplying California load during the evening peak, and (5) generating EIM and EDAM congestion and transfer revenues that offset California costs.  With existing links between California and the Northwest facing significant congestion, the additional 1,100 MW of North-South transfer capability provided by SWIP-N will reduce those congestion charges as well, particularly when fully optimized through the combination of day-ahead (EDAM) and real-time (EIM) markets.

In summary, regardless of how the above benefits are (or are not) considered for the Economic Planning Study, the economic benefits of SWIP North are real and significant, and provide standalone justification for approval if fully quantified (as reflected in prior comments and studies by LS Power), but in any event provide an inherent bonus for ratepayers if CAISO approves SWIP North as a policy-driven project.  Approving SWIP North as part of the current cycle will maximize such benefits for ratepayers.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

LS Power has no comments at this time.  

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

LS Power has no comments at this time.  

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

LS Power has no comments at this time.  

9. Provide your organization’s comments on chapter 8 Transmission Project List.

LS Power has no comments at this time.  

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Marin Clean Energy (MCE) thanks and commends the California Independent System Operator (CAISO) for its extensive work dedicated to developing the Draft 2022-2023 Transmission Plan and the careful focus on laying the essential groundwork for California to aggressively progress towards achieving its clean energy and reliability needs. In support of these efforts, MCE’s comments on the Draft Transmission Plan specifically address elements of the Draft Transmission Plan’s Policy-Driven Need Assessment and the Economic Planning Study.

With regard to the Policy-Driven Need Assessment, MCE encourages the CAISO to include an additional scenario covering the hours of highest solar production to maximize and optimize solar generation’s ability to charge energy storage assets.

With regard to the Economic Planning Study, MCE encourages the CAISO take a number of specific actions, described in more detail in Prompt 5, below, that MCE understands will unlock the feasibility and net benefits associated with Alternatives 2, 3, 4, & 5.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

MCE provides no comments in response to this prompt at this time.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

MCE provides no comments in response to this prompt at this time.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

MCE Recommendation: Modify the Policy-Driven Need Assessment to include a scenario that covers the hours of highest solar production to maximize and optimize solar generation’s ability to support energy storage charging and serving load.

Discussion: The Policy-Driven Need Assessment has two objectives: (1) to support Resource Adequacy (RA) deliverability status for the renewable generation and energy storage resources identified in the portfolio as requiring that status; and (2) to support the economic delivery of renewable energy during all hours of the year.  MCE’s understanding is that the study uses the same system need scenarios as the reliability assessment, which are: (1) Highest System Need (“HSN”, HE19-HE22 summer); and (2) Secondary System Need (“SSN”, HE15-HE18 summer).  MCE is concerned that the scenarios underestimate the contribution of solar resources to transmission flows in hours outside of the highest and secondary system needs, which is inconsistent with the second objective of the Policy-Driven Need Assessment. 

MCE urges the CAISO to consider modifying the Policy-Driven Need Assessment to include a scenario that covers the hours of highest solar production. Including such a scenario will ensure that solar production can be maximized to support energy storage charging and serving load with carbon free solar generation to meet the electrification goals of other sectors of the economy, such as transportation.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

MCE Recommendation:

• Update the base case in the Economic Planning Study for the PG&E Panoche/Oro Loma area to have the disconnect switch at Firebaugh in the open position from April through October (and possibly through November);
• Re-evaluate the SPS impact on the Oro Loma – Poso 70 kV congestion with the Firebaugh switch position corrected;
• Publish the economic benefit results for Alternative 2;
• Re-evaluate the economic benefits for each Alternative with the Firebaugh switch position corrected; and
• Further clarify how CAISO determined that the reconductoring work described in Alternative 3 costs $173,000,000 (MCE provides further explanation of this issue in Subsection D, below).

Discussion: The base case CAISO used in its Economic Planning Study for the PG&E Panoche/Oro Loma area is incongruous with the existing and planned day-to-day operating situation in the area. This incorrect modeling led CAISO to improperly conclude that (a) Alternative 2, using the Remedial Action Scheme (RAS), causes reliability issues, and (b) all Alternatives do not provide net benefits. When the appropriate base case is used, however, the study will show that all alternatives provide net benefits. Moreover, it will show that Alternative 2 (using the RAS) also provides reliability benefits.  Therefore, MCE recommends the CAISO report the economic benefit results of Alternative 2.

As stated above, to improve the Economic Planning Study, MCE requests CAISO take the following actions to ensure that the study appropriately reflects the existing and planned day-to-day operating situation in the PG&E Panoche/Oro Loma area:

• Update the base case in the Economic Planning Study for the PG&E Panoche/Oro Loma area to have the disconnect switch at Firebaugh in the open position from April through October (and possibly through November);
• Re-evaluate the SPS impact on the Oro Loma – Poso 70 kV congestion with the Firebaugh switch position corrected;
• Publish the economic benefit results for Alternative 2;
• Re-evaluate the economic benefits for each Alternative with the Firebaugh switch position corrected; and
• Further clarify how CAISO determined that the reconductoring work described in Alternative 3 costs $173,000,000 (MCE provides further explanation of this issue in Subsection D, below).

By taking the aforementioned actions, MCE’s analysis indicates the economic planning study will yield the following results in the PG&E Panoche/Oro Loma area:

• Alternative 2 is shown to not cause reliability issues, and therefore is a feasible solution;
• Alternatives 2, 3, 4, and 5 provide positive net benefits; and
• At a minimum, Alternatives 2 and 3 provide positive net benefits that justify the implementation cost.

1. The Firebaugh disconnect switch needs to be modeled in the open position from April through October (and possibly through November).

PG&E adjusts disconnect switch positions throughout the year in what it calls “summer setups” to achieve local system reliability and load serving.  CAISO’s base case appropriately recognizes PG&E’s use of summer setup on the lines of the two 70 kV corridors in the PG&E Panoche/Oro Loma area. However, the period in which it modeled the 70 kV corridor between Oro Loma and Mendota as open was much shorter than the historical and planned period (modeled one month rather than seven months). This modeling error significantly impacts the results of the analysis and needs to be corrected.

PG&E regularly operates with the disconnect switch at the Firebaugh substation open for the entire summer.  With this disconnect switch open, the 70 kV corridor between Oro Loma and Mendota is open.  According to Transmission Outage Reports from 2022, the Firebaugh disconnect switch was open from May through October 2022.[1]  Also, according to recent Transmission Outage Reports, PG&E plans to operate with the Firebaugh disconnect switch open from May through December 2023.[2]  PG&E also now refers to this open position as “new normal open.” The study needs to reflect this “new normal open” switch positioning in its base case to more accurately reflect the benefits of Alternatives 2, 3, 4, & 5.

2. A RAS that trips local solar generation under the contingency condition is a feasible solution and therefore needs to be considered.

With the corrected Firebaugh disconnect switch position discussed above, the RAS solution that CAISO describes in the study cannot cause the Oro Loma – Poso 70 kV overloads because the location of the tripped generation and remaining load is isolated from the identified overloaded path.

CAISO relies on its results in Table G.10-15 to support its conclusion that the RAS solution is infeasible.  It shows that the occurrences of congestion on Oro Loma – Poso 70 kV increase due to the RAS operation.  However, the results are likely erroneous and misleading because they include time periods in which the Firebaugh switch is inappropriately modeled as closed.

Additionally, the CAISO cannot rely on its results in Table G.10-15 to support its conclusion by only observing the results in April and May--a time during which it modeled the Firebaugh switch as open.  The results are not presented at the appropriate level of granularity to draw a negative conclusion during times when the disconnect switch was modeled as open. Table G.10-15 shows that the occurrences of congestion in April and May increase by a total of one occurrence in Alternative 2 compared to the base case. However, the Firebaugh disconnect switch is modeled as open from mid-month April to mid-month May. It is highly likely that additional congestion was incurred in the periods of time when the switch was inappropriately closed (beginning of April and the end of May).  The table only reports the sum of occurrences over the full month of April and the full month of May which include the time periods when the switch was inappropriately closed.

If the base case is corrected with the Firebaugh disconnect switch open, MCE expects minimal impact on the Oro Loma – Poso 70 kV congestion and should provide significant improvement on the Le Grand – Chowchilla 115 kV congestion shown in Table G.10-14 as well as the full 115 kV path from Newhall to Le Grand.

A RAS that trips local solar generation under the contingency condition is an alternative that is feasible, and MCE requests this alternative be considered by the CAISO as part of the Economic Planning Assessment.

3. Each alternative provides positive net benefits relative to the corrected base case.

Notably, CAISO ran a case in which the Firebaugh switch position is correctly modeled as open from April through October (Alternative 1). Once the net benefit results for Alternatives 3 through 5 are correctly compared to Alternative 1 (as the true base case), each option provides positive net benefits. At a high level, the results provided in the table below indicate that the CAISO, at a minimum, should re-evaluate the net benefits relative to the corrected base case.

4. The published reconductoring cost appears to be higher than suggested by PG&E’s Unit Cost Guide

The CAISO estimates the cost of reconductoring the 115 kV lines in the Panoche/Oro Loma area at $173,000,000.  The reconductoring project would include the 115 kV lines between the Oro Loma and Wilson 115 kV buses and between the Newhall and Le Grand 115 kV buses. However, there is insufficient detail to understand and verify these estimates and conclusions.

These upgrades would require approximately 85 circuit miles of reconductoring activity on existing wooden poles through the flat, rural, and agricultural central valley of California.  There should be no cost adders for hilly, forested, or mountainous terrain.  Likewise, there should be no cost adders for urban/suburban population density.  Based on PG&E’s 2022 Unit Cost Guide, such a project would cost $960,000 per mile, or approximately $82,000,000. Even if the existing wooden poles are upgraded to lattice towers, the project would cost $1,519,000 per mile, or approximately $129,000,000. The discrepancy between these estimates based on publicly available information and the figure CAISO published warrants further elaboration from CAISO on its reported $173,000,000 project cost. Given a positive net benefit for the reconductoring project with the corrected base case, this project’s cost estimate is a more important factor that requires more details on the cost calculations.

5. The CAISO should provide the cost estimate for the RAS implementation.

As discussed previously, the RAS is a feasible solution for this CAISO area provided the capital cost estimate for the RAS implementation will enable a more comprehensive and complete assessment of the benefits, feasibility, and implementation costs of the opportunities described in the Economic Plan Assessment.

Further, given the Federal Energy Regulatory Commission’s (FERC) April 20, 2023 Ruling in ER22-2362-000 addressing CAISO’s ambient-adjusted line rating tariff definition to improve transparency and accuracy of line ratings pursuant to FERC Order 881 & 881-A, MCE requests the CAISO indicate whether and when it plans to re-evaluate the Panoche/Oro Loma area in light of this Ruling and the CAISO’s movement towards dynamic line ratings by Summer 2025.

[1] Outage ID 11656801

[2] Outage ID 13305482

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

MCE provides no comments in response to this prompt at this time.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

MCE provides no comments in response to this prompt at this time.  

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

MCE provides no comments in response to this prompt at this time.  

9. Provide your organization’s comments on chapter 8 Transmission Project List.

MCE provides no comments in response to this prompt at this time.  

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

The Center for Energy Efficiency and Renewable Technologies (CEERT) and Environmental Defense Fund (EDF) appreciate the manner in which the stakeholder call discussion was organized and managed.  The CAISO presentations were very informative and the question and answer process added constructively to the understanding of the draft Transmission Plan. A forward-leaning California-focused Transmission Plan is essential to advance progress the to a zero-carbon future for California. 

Recent federal climate legislation, including the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) can provide significant tax and financial incentives for the development of zero-carbon generation and energy storage systems in California.  This legislation also creates unique opportunities for transmission development. The opportunity to further decarbonize California at the lowest possible ratepayer cost hinges upon adequately leveraging this investment cycle. However, without a more robust transmission system the opportunity to develop these clean energy resources could be lost or delayed.  While the magnitude of investment to expand the California transmission system is large, there will be opportunities to leverage federal resources to lessen the impact on California energy consumers by reducing development risks and reducing the cost of capital. 

Overall, CEERT and EDF are very pleased with the leadership of the CAISO in moving the transmission planning process forward by advancing a focused zonal approach to resource development

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

Chapter One of the 2022-2023 Transmission Plan explains in a clear and compelling fashion the rapidly escalating need to deploy large quantities of new clean energy resources to meet the greenhouse gas reduction targets set by California energy policymakers. CEERT and EDF strongly agree with the CAISO’s decision to adopt a zonal focus as the long-term strategy to coordinate resource planning and development.  The zonal approach is consistent with the memorandum of understanding recently agreed to between the California Public Utilities Commission (CPUC), the California Energy Commission (CEC) and the CAISO.

Tightening the connection between integrated resource planning (supply forecast), the integrated energy policy report (demand forecast) and transmission planning (the ability to move power from generation to load) is critical. This coordination which provides guidance on procurement to California’s load serving entities is necessary given the magnitude of investment and development that is required.  This Transmission Plan should also alleviate some of the delay experienced in the CAISO interconnection process by creating more system deliverability for new clean energy projects and increasing overall system transfer capability that will ease some of the customer cost pressure by reducing the need for other more costly network upgrades.

Alignment of the Transmission Planning Process with the 20-Year Transmission Outlook

CEERT and EDF are pleased to see the effort to align the 2022-2023 Transmission Plan with the CAISO 20-Year Transmission Outlook.  The 20-Year Transmission Outlook has been helpful in informing stakeholders of the direction the CPUC-CEC busbar mapping process has used to meet the state’s longer-term greenhouse gas reduction goals. We look forward to the state agencies using the next 20-Year Transmission Outlook to further guide busbar mapping decisions so there is tighter alignment between resource portfolios used in the Transmission Planning Process and California’s long-term vision.  CEERT and EDF strongly support the CAISO commitment to updating its informational 20-Year Transmission Outlook in parallel with the 2023-2024 Transmission Planning Process that will identify additional actionable transmission projects.

The first 20-Year Transmission Outlook used a specific resource portfolio developed by the CEC for its analysis of SB 100 resource requirements.  This CEC Starting Point Scenario assumed statewide natural gas power plant retirements of 15,000 MW by 2040.  The power flow studies used for the 20-Year Transmission Outlook identified multiple constraints resulting from new generation developed in the Westlands and Kern areas of the Central Valley.  These constraints were affected by the assumption that only 2,000 MW of gas-fired generation would be available in the greater Bay Area.

The following peak summer overloads during normal operation were observed:

Manning to Gates 500 kV line - 163% overload

Los Banos to Manning #1 and #2 500 kV lines - 152% overload

Los Banos to Tesla 500 kV line - 138% overload

Los Banos to Tracy 500 kV line - 117% overload

Los Banos to Moss Landing 500 kV line - 116% overload

Moss Landing to Las Aguilas 230 kV line - 133% overload

Westley to Los Banos 230 kV line - 119% overload

Panoche to  Los Banos 230 kV line - 119% overload

The lower Central Valley from Merced County in the north to Kern County in the south

has the potential for the development of 30 GW or more of solar and battery projects. To enable the development of this magnitude of projects there will need to be a focused effort to upgrade the 500 kV and 230 kV lines in the Central Valley.  There are four major substations in the lower Central Valley – Los Banos, Manning, Gates, and Midway. A fifth substation is needed between the Gates and Midway substations to enable the interconnection of significant new clean energy capacity in the Central Valley. In addition, Path 15 transfer capability will need to increase to enable the reliable delivery of that energy to load centers in the north and south.

SB 887 Request for Information about Transmission Projects to Reduce Reliance on Gas Generation in Local Capacity Areas

CEERT and EDF also appreciate the CAISO’s responsiveness to the Legislative request for information regarding transmission projects that can reduce dependence on gas-fired resources as articulated in SB 887. As noted in the draft Transmission Plan, it is the CPUC’s responsibility to provide a more specific resource portfolio that reduces the reliance on gas-fired resources in local capacity areas by no later than 2035 that the CAISO can use in its transmission planning process.  To support the SB 887 goals, we strongly urge CAISO to share with the CPUC and stakeholders any lessons learned in this Transmission Plan regarding improvements in the CPUC resource portfolios, such as the upgrades to the bulk grid that will enable the delivery of energy from clean resources to load during stressed system conditions as local constraints are addressed.  

We believe that beyond local resources and new transmission into load pockets, there is a need to discuss the north-south balance of resources in the portfolios so that Path 26 and Path 15 congestion do not also impede major load centers in the north from accessing clean energy resources. As part of the understanding these lessons learned, we also encourage CAISO to suggest if additional legislative guidance may be required to achieve the faster reduction of reliance on gas resources in local capacity areas.

Pacific Transmission Expansion Project

We wish to highlight the observation made in the draft Transmission Plan that the Pacific Transmission Expansion Project, an HVDC project that would strengthen the connection between Northern California and the Los Angeles Basin, would reduce the need for gas-fired generation in the LA Basin area.  This transmission project has been highlighted for the potential to deliver Central Coast offshore wind to the LA Basin, and when paired with increased access to solar and storage in the Central Valley can help provide a firm set of resources to reduce the operation of gas-fired resources in this local area.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

CEERT and EDF believe the process the CAISO used to identify reliability projects is reasonable.  We appreciate that the CAISO evaluated both the base case resource portfolio and the sensitivity case portfolio in making its recommendation as to which projects are needed to meet load growth and to adapt to evolving grid conditions.

We observe that 16 of the 24 recommended reliability projects are located in the PG&E service area requiring an estimated investment of approximately $1.109 billion. We are concerned that PG&E may encounter difficulties in financing and managing this quantity and magnitude of reliability projects.  It has been widely reported that PG&E is currently experiencing significant delays in connecting hundreds of new customers’ facilities to the grid across the state. This is unacceptable and CAISO should think creatively about alternatives to resolve the situation.

Unfortunately, these delays are part of a larger trend. As discussed at the recent CAISO-hosted quarterly Transmission Forum, for 14 PG&E transmission projects, three show an in-service delay of three or more months and nine projects show as delay of six months or more.  Only two projects were on schedule.  The significant amount of proposed reliability projects in PG&E’s service territory risks further adding to PG&E’s backlog and delaying other needed transmission projects. 

Given PG&E’s continuing inability to carry out its responsibilities to maintain and enhance system reliability and promote the delivery of clean energy to the grid, we recommend that the CAISO and the CPUC evaluate alternative means for timely implementation of needed grid infrastructure, including allowing independent transmission developers and generators to carry out the construction of transmission upgrades and interconnection facilities.

CAISO may also want to explore the use of a competitive solicitation process. This is one important way the CAISO can avoid adding to PG&E’s backlog of transmission projects. Given the type of transmission assets that are open to competitive solicitation, we further recommend that the scope of such projects be explicit to upsize upgrades to better prepare for future needs.

This exploration of alternatives will either send a signal to PG&E to improve its performance or it will open up opportunities to other providers who can do better. Either way, CAISO needs to communicate its concerns about PG&E’s performance so state energy policy makers can understand the potential for ratepayer benefit in both reliability and affordability.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

Overall, CEERT and EDF are pleased with the policy-driven needs assessment.  As with the reliability assessment, we appreciate that the CAISO took into consideration the sensitivity portfolio since it will become the base portfolio in the 2023-2024 Transmission Plan, with some adjustments to busbar mapping of future resources.  

We observe that the sensitivity portfolio for the PG&E Fresno planning zone (8,399 MW) is significantly larger than for the base case portfolio in that zone (2,699 MW).  Likewise, for the PG&E East Kern planning zone, the resources in the sensitivity portfolio (9,533 MW) greatly exceed the resources in the base case portfolio (2,332 MW).  It does not appear the sensitivity was addressed in these zones, especially not to the degree seen in Southern California.  We seek further clarification on why that might be and what issues the CPUC and stakeholders may need to address ahead of the next TPP cycle.

The planning for the sensitivity portfolio, which will become the 2023-2024 base case portfolio, will require the development of a new gathering substation in the Central Valley similar to the Manning substation that was identified in the 2021-2022 Transmission Plan.  Likewise, transmission upgrades will be required to delivery power from the Central Valley to the Greater Bay Area and the LA Basin Area.  We recognize the CAISO is not addressing all future needs in this Transmission Plan and that it will carry out its long-term vision across multiple TPP cycles, but we seek additional informational about the differences between the resources in the north and south so that stakeholders can be more informed heading into future planning processes. The parallel consideration of the 20-Year Outlook gives us this guidance and we continue to encourage the CAISO to act decisively.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

The Chapter 4 Economic Planning Study identifies the Path 26 corridor as an area with large recurring congestion costs.  Congestion largely occurs when power flows are from south to north and will increase as more resources are developed in Southern California. One of the two mitigations that was evaluated was the proposed Pacific Transmission Expansion Project (PTEP) from Diablo Canyon to the LA Basin area.

The results of the CAISO analysis show that PTEP reduced Path 26 corridor congestion but that Path 15 corridor congestion increased with the project.  This finding suggest that policy-driven upgrades to Path 15 that would be required to meet the sensitivity portfolio will also be needed together with the PTEP to improve the economic transfer of power from south to north.  We encourage CAISO's future economic studies of Path 26 congestion to be paired with studies that alleviate Path 15 congestion as well.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

Generally, CEERT and EDF believe that improved interregional transmission planning and coordination is needed in the western interconnect.  We believe that there will be an opportunity for closer coordination between CAISO and Northern Grid, as both regions evaluate the potential for offshore wind development and the need for transmission to bring that power to the regional market.  We recommend that the CAISO work with Northern Grid and WestConnect to identify beneficial interregional projects into the 2023-2024 transmission planning process.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

We appreciate the need for a periodic frequency response study as the quantity of inverter-based resources increase in the CAISO footprint.  We believe the study methodology used by the CAISO is reasonable and that looking at 2027 and 2035 as test years was appropriate.  The finding that an increase in Battery Energy Storage Systems (BESS) across California will improve frequency response is logical.  Similarly, the finding that the frequency nadir will be greater in 2035 than in 2027 is also not surprising and will require more reliance on BESS units. 

At the stakeholder conference questions were asked about the potential added value of grid forming inverters.  The CAISO’s answer was that grid forming inverters were not necessary for meeting frequency response through 2035 but could be valuable for overall and longer-term grid performance.  There appears to be an opportunity for further evaluation of the value of grid forming inverters in subsequent transmission plans.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

CEERT and EDF very much appreciate the CAISO’s special study regarding the electric system’s dependence on the Aliso Canyon Gas Storage Facility and the identification of transmission alternatives that could reduce that dependence. The CAISO is correct to observe that Aliso Canyon supports core and non-core gas customers, including CAISO and LADWP generation located in the LA Basin and elsewhere in Southern California. As a consequence of the 2015 leak at Aliso Canyon, the CPUC capped the inventory level at the facility and is seeking to further reduce dependence on the facility.

Fundamental limitations on the Southern California Gas Company’s pipeline network make it physically incapable to operate all natural gas fired electric generators in the LA basin without signficant gas storage. It can take approximately 9 hours for gas to get from the California border to the generators in the LA basin. If there is a need for rapid gas movement to respond to system needs then gas in storage is the only realistic fossil based alternative to maintaining system reliability. While we are not commenting at this time on the future of the Aliso Canyon facility, we point out that the current strategy of natural gas fired generation with a large gas storage field is vulnerable. The CAISO should continue investigate both transmission and  non-wires alternatives that can reduce reliance on large quanities of gas storage in Southern California. 

We appreciate that the CAISO evaluated various transmission projects needed to maintain and improve reliability in the LA Basin with the curtailment of a significant amount of gas-fired generation. While the study results were intended to provide information to policymakers they are helpful in charting out the need for additional transmission in the region.

We understand that further guidance is needed from the CPUC on the ongoing need for the Aliso Canyon gas storage facility.  Nonetheless, it is clear from the special study that the Pacific Transmission Expansion Project (PTEP) which will connect the LA Basin area with clean energy resources in northern California is part of a more comprehensive strategy to reduce reliance on Aliso Canyon.  For this reason, the CAISO should consider inclusion of PTEP in the 2022-2023 Transmission Plan.  

9. Provide your organization’s comments on chapter 8 Transmission Project List.

CEERT and EDF fully support all of the reliability-driven and policy-driven transmission projects included in the 2022-2023 Transmission Plan.  We believe that the amount of investment required to effectuate this plan is reasonable, although we support exploration of ways to reduce the cost of capital that will be used for the overall investment portfolio.

We appreciate the careful analysis that went into the evaluation of options for the Southern California Edison/San Diego Gas & Electric southern area reinforcement.  We support the three recommended large-scale projects in the area: North Gila – Imperial 500 kV line; the Imperial Valley- North of SONGS 500kV line and substation; and the North of SONGS – Serrano 500 kV line.

However, we recognize that there may be environmental and permitting challenges related to the Imperial Valley – North of SONGS 500 kV line.  We would encourage the CAISO to take an approach in the competitive solicitation for this project that allows developers to propose alternatives that could de-risk the permitting challenges this project faces, which could include the undergrounding of sections of the project and the use of high voltage DC cables and converter stations as a cost-effective solution. 

We believe that the CAISO can advance the southern reinforcement solution by leveraging the knowledge and innovation from multiple potential project developers. 

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

Middle River Power, LLC (“MRP”) appreciates the opportunity to submit these comments on the CAISO’s Draft 2022-2023 Transmission Plan.

MRP greatly appreciates that the CAISO recognizes the need to proactively accelerate transmission development is support of the highly aggressive resource buildout underway in support of California’s decarbonization goals.  California’s ability to achieve its decarbonization goals hinges critically on the rapid electrification of major parts of California’s infrastructure and economy.   At the same time, California needs to ensure that the reliability of its electric delivery system is not compromised.   To that end, MRP supports the accelerated buildout of both reliability-driven and policy-driven transmission projects the CAISO proposes in the draft Transmission Plan.  Given the massive buildout that will be needed to accomplish state policy goals, however, MRP respectfully asks if the proposed transmission buildout is sufficient, or whether some proposed projects – specifically, the prposed new Kramer – Lugo 500 kV, line, which was not selected (the Kramer – Lugo 230 kV upgrades were selected instead) should be selected to provide both for the greatest amount of optionality to accommodate the coming massive new resource buildout in addition to better providing reliability through greater constraint relief in the North of Lugo area.   As the CAISO is well aware, transmission development takes a very long time, especially relative to the timeline for new generating resource development. Given that it is difficult, if not impossible, for transmission development to play “catch up” with generation development, especially the magnitude of genration development needed to achieve California's policy goals,  MRP respectfully encourages the CAISO, as part of its new proactive approach to transmission development, to ensure that the proposed transmission development is sufficiently far ahead of generating resource development to keep California on track with its aggressive decarbonization goals.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

The Natural Resources Defense Council (NRDC) appreciates the opportunity to respond to the draft 2022-2023 Transmission Plan (Draft Plan) issued by the California Independent System Operator (CAISO) on April 3, 2023. NRDC is a public interest organization that advances policies to further a low-carbon grid and reduce harmful emissions from fossil-fuel generation, in part, through comprehensive and strategic transmission planning. 

NRDC supports CAISO’s efforts to anticipate and develop the large amount of transmission we need to match the rapid transition to carbon-free generation per California’s clean energy policies and ensure that transmission growth is done cost-effectively. As noted in the draft, the projected need for new clean resources has increased dramatically over the past few years. And this need will continue to rise beyond the 70 GW of resources that the CPUC has already projected is needed by 2033.  

The rapid increase in the identified need for new transmission is reflective of that increased resource growth. The $9.3 billion in transmission projects identified as needed in this report are a critical component of California’s emerging clean energy future.  

We provide these general comments on the transmission planning process and Draft Plan, with some specific comments on offshore wind considerations. We do not offer comments on the specific projects identified in the Draft Plan. However, we strongly support the scope of this increasingly ambitious approach. Given the impending threat of climate change there is a need for decisive and ambitious action to meet the moment. In summary, NRDC is supportive of the elements of the Transmission Plan that are anticipatory of growing transmission needs and focus directly on the need for reliability-driven and policy-driven projects. 

We strongly agree with the more strategic and proactive approach to transmission planning reflected in this draft. In order to meet the historic build out of clean energy resources, we need to move away from the slower and more laissez faire approach of the past. As the draft notes, this will allow for more rapid deployment and lower costs of generation and transmission resources.  

The joint agency MOU signed by the ISO, CEC and CPUC was an important step toward this approach and it is clearly already paying dividends. While significant challenges will arise, we urge the CASIO to continue to make progress in this regard.  

The initiative to reform and improve the interconnection process is an important component of this effort. The very large number of projects in the interconnection queue is reflective of the tremendous amount of clean energy resources that we have in the west. But in order to move effectively and expeditiously, the CAISO will need to prioritize and focus the resources allocated to review of proposed generation. Identification of specific geographic zones for development and prioritization of interconnection requests in those zones provides an effective way to maximize the value of transmission investments and expedite interconnection of resources.   

One area where more work is needed is the development of transmission to interconnect offshore wind resources. Offshore wind is an essential component to achieving California’s decarbonization goals and, to reach the necessary buildout, additional megawatts of offshore wind transmission should continue to be planned for given the long lead time to build transmission and the opportunity to improve long-term cost-savings and operational efficiencies. Interconnection of that resource poses unique challenges, particularly for the north coast/Humboldt call area.  

The draft Transmission Plan acknowledges the importance of the OSW resource and identifies some of the challenges and opportunities but defers approval of transmission solutions to the subsequent transmission planning cycle. Similarly, review of the Pacifica Transmission Expansion Project is also deferred pending further discussions with LADWP.  

We recognize that development of transmission solutions for offshore wind is challenging. It is essential that it be closely coordinated with the buildout of a large and relatively novel resource (as well as with a major expansion of port capacity).   

We urge the CAISO to make this a key focus of next year’s transmission plan (and likely subsequent plans). In particular, we urge expeditious identification and approval of needed projects to interconnect and deliver OSW in future Transmission Plans to facilitate and support further ramp down of remaining fossil gas generation in the LA basin. Close coordination and collaboration with the CEC and CPUC, along with LADWP and other entities will be key to successful design and implementation of a solution.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

New Leaf Energy, Inc. (“New Leaf Energy”), an independent developer of solar and energy storage, appreciates the opportunity to comment on the California Independent System Operator’s (“CAISO”) 2022-2023 Draft Transmission Plan, dated on April 3, 2023. The culmination of months of work by CAISO staff and leadership, the Draft Transmission Plan reflects that thoughtful effort.

In these comments, New Leaf Energy offers the following feedback on the Draft Transmission Plan:

• New Leaf Energy applauds the CAISO’s support for policy-driven transmission investments at scale, much more of which will be needed in the years to come for California to meet its climate goals.
• New Leaf Energy urges the CAISO to approve Gates 500/230 kV Bank #13, a particularly high-impact upgrade in Pacific Gas & Electric Company (“PG&E”) territory, in this planning cycle, as a necessary extension of the approved Manning Substation Project.
• New Leaf Energy is concerned about the CAISO’s assumptions about anticipated energy storage discharge serving as mitigations in PG&E territory, given that deliverability will likely be required for those energy storage resources to be commercially viable.
• New Leaf Energy supports the CAISO’s approval of the Borden-Storey reconductoring project in the 2022-2023 Transmission Plan, but urges the CAISO to scrutinize PG&E’s estimated in-service date.

New Leaf Energy will expand further on each item below.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

New Leaf Energy has no comment at this time.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

New Leaf Energy has no comment at this time.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

1. THE DRAFT TRANSMISSION PLAN’S PROPOSED INVESTMENT IS A STRONG START TO MEET THE STATE’S GROWING NEED FOR TRANSMISSION.

At a high level, New Leaf Energy is heartened by the Draft Transmission Plan’s proposal to approve over $7.5 billion of policy-driven upgrades. The CAISO is now initiating the expansion of its grid that will be necessary to meet California’s ambitious climate goals. The base portfolio that the California Public Utilities Commission (“CPUC”) recommended for the 2023-2024 Transmission Planning Process (“TPP”) includes the buildout of 86 gigawatts (“GW”) of new resources by 2035.^[1] The investments identified in this Draft Transmission Plan are a strong start to a decade ahead that will see the transformation of California’s energy system.

2. GATES 500/230 kV BANK #13 IS A HIGH-IMPACT AND COST-EFFECTIVE NETWORK UPGRADE THAT MERITS RECONSIDERATION IN THIS YEAR’S TRANSMISSION PLAN.

New Leaf Energy urges the CAISO to modify the Draft Transmission Plan to approve the Gates 500/230 kilovolt (“kV”) Bank #13 in PG&E’s Fresno Planning Area in this planning cycle. Although a need was not identified in the 2032 base case, it was identified in the 2035 sensitivity case in the current TPP and in the 2035 base case in the 2023-2024 TPP.^[2] However, it is a necessary companion to the Manning Substation Project, which the CAISO approved in its 2021-2022 Transmission Plan.[3] The analysis that New Leaf Energy submitted with its December 5, 2022 comments in this initiative (confidentially, as the specific data were covered by CAISO's Market Participant Portal Non-Disclosure Agreement), demonstrated that the Gates 500/230 kV Bank #13  upgrade would add a significant amount of deliverability at comparatively low cost and would be critical to realizing the benefits of the Manning Substation Project.^[4] The Gates 500/230 kV Bank #13 is a good “bang for your buck” investment for the CAISO to reconsider in this planning cycle.

New Leaf Energy is not alone in proposing that the CAISO approve the Gates 500/230 kV Bank #13, nor is it a new idea. Many stakeholders have highlighted the uniquely cost-effective value proposition of approving this project over the years. In the 2021-2022 TPP cycle, such observations were offered by the CPUC Public Advocates Office,^[5] the California Wind Energy Association (“CalWEA”),^[6] ACP-California,^[7] and the Large-scale Solar Association (“LSA”) and Solar Energy Industries Association (“SEIA”).^[8]

Moreover, approving the Gates 500/230 kV Bank #13 upgrade after approving the Manning Substation Project would ensure that Cluster 14 projects will be able to request the transmission plan deliverability (“TPD”) it generates at their soonest opportunity for an allocation. According to the April 13, 2023 Interconnection Process Enhancements (“IPE”) Track 1 Draft Tariff Language, Cluster 14 projects will receive their Phase II study reports on January 31, 2024 and TPD allocation results will be posted on May 31, 2024.[9] If the CAISO Board does not approve the Gates 500/230 kV Bank #13 project this TPP cycle, it will be excluded from the 2024 TPD study results. That will force Cluster 14 projects to wait longer for deliverability allocations, delaying contract opportunities and potentially commercial online dates.

3. CAISO MUST SCRUTINIZE ASSUMPTIONS REGARDING ENERGY STORAGE AS A TRANSMISSION CONSTRAINT MITIGATION AND CONSIDER THE NEED FOR SUCH RESOURCES TO HAVE DELIVERABILITY.

The CAISO’s April 11, 2023 response to New Leaf Energy’s December 5, 2022 comments regarding the use of battery energy storage (“BESS”) to mitigate deliverability constraints stated that “[t]he ISO is not proposing new BESS beyond what is included in the CPUC portfolios to mitigate off-peak deliverability constraints.”^[10] However, the Draft Transmission Plan indicates that energy storage will be utilized to resolve on-peak deliverability constraints in the sensitivity portfolio, not only the off-peak constraints as indicated in the response. In fact, there are 12 such occurrences in the Greater Bay and North of Greater Bay Areas, and another 12 in the Greater Fresno Area, where on-peak deliverability constraints in the sensitivity portfolio that could potentially be mitigated by “[p]ortfolio energy storage in charging mode” are identified.^[11]

New Leaf Energy is encouraged that the CAISO continues to consider energy storage solutions to transmission constraints yet is concerned that there is insufficient consideration of the Network Upgrades that will be needed to make these resources commercially feasible – especially since the 2023-2024 Transmission Plan will likely hew closely to the 2022-2023 Transmission Plan’s sensitivity portfolio.^[12]

There are two primary pathways through which energy storage is being developed today: (1) as Resource Adequacy (“RA”) capacity or (2) as a non-transmission solution.

In the first (and vastly more common) use case, the energy storage must have deliverability to be economically viable. Without deliverability, energy storage resources would be limited to only merchant energy and ancillary services market participation, which has not yet proven to offer sufficient value or revenue certainty to support project financing. The load-serving entities (“LSEs”) are simply not seeking to procure Energy Only energy storage resources. New Leaf Energy is concerned that the CAISO anticipates relying so heavily on energy storage to mitigate transmission constraints without concurrently investing in the Network Upgrades that will likely be required for those projects to be developed economically.

In the second use case, more guidance is needed from the CAISO to clearly articulate its technical and operational expectations of energy storage non-transmission solutions and to clarify how they relate to deliverability requirements, as New Leaf Energy has expressed throughout this stakeholder initiative. Without finalizing a non-transmission solution framework for energy storage resources, future solicitations are doomed to follow in the footsteps of the failed Kern-Lamont procurement.

As noted in the Draft Transmission Plan, the CAISO’s 2020-2021 Transmission Plan recommended procurement of a 95 MW, 4-hour energy storage resource as mitigation on the Kern-Lamont 115 kV system, but that area has no deliverability available for new projects and no new upgrades to provide that deliverability were approved in that TPP cycle.^[13] Thus, no new projects could meet the requirements, and PG&E notified the CPUC in late 2022 that no viable offers remained and the solicitation would be closed.^[14] If storage resources needed to provide non-transmission solutions are also required to have deliverability, sufficient upgrades to enable that deliverability must be identified and adopted.

4. PG&E’S ESTIMATED IN-SERVICE DATE FOR THE BORDEN-STOREY NETWORK UPGRADE MERITS GREATER SCRUTINY AND MAY BE INCOMPATIBLE WITH STATE POLICY.

New Leaf Energy strongly supports the inclusion of the Borden-Storey 230 kV 1 and 2 line reconductoring project in the Draft Transmission Plan. Borden-Storey is a policy-driven upgrade in PG&E’s Fresno Planning Area that is estimated to cost between $25 and $50 million.^[15] It is directly impeding the deliverability of a great number of queued projects. Without the approval of this upgrade, the number of generators being denied TPD is bound to increase significantly with the inclusion of Cluster 14 in future TPD allocation cycles. 

However, New Leaf encourages the CAISO to scrutinize more closely the proposed in-service dates on upgrades supplied by the utility, especially this particular upgrade. PG&E’s in-service date of 2032 for approximately five miles of reconductoring in relatively unpopulated and geographically flat terrain appears excessive. By contrast, Southern California Edison (“SCE”) estimates show a 2034 in-service date – only two additional years beyond the Borden-Storey estimate – for a brand-new, 145-mile 500 kV transmission line that has no established right of way. Without additional scrutiny of PG&E’s estimated timelines, the state is in jeopardy of not meeting its policy goals.

5. CONCLUSION

New Leaf Energy thanks the CAISO for its thorough work on the 2022-2023 Draft Transmission Plan and for its consideration of these comments.

^[1] CPUC Decision 23-02-040 (issued February 28, 2023), p. 48, available at: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M502/K956/502956567.PDF. 

[2] CAISO Slides for 2022-2023 Transmission Planning Process Stakeholder Meeting (April 11, 2023), p. 83, available at: http://www.caiso.com/InitiativeDocuments/Presentation-2022-2023-Transmission-Planning-Process-Apr112023.pdf.

[3] CAISO 2021-2022 Transmission Plan – Board Approved (March 17, 2022), available at: http://www.caiso.com/InitiativeDocuments/ISOBoardApproved-2021-2022TransmissionPlan.pdf.

^[4] New Leaf Energy, Inc. Comments on November 17, 2022 Stakeholder Meeting in the 2022-2023 Transmission Planning Process Stakeholder Initiative (December 5, 2022), available at: https://stakeholdercenter.caiso.com/Comments/AllComments/6cdb6ed2-f22c-4064-96e1-739c8db239ef#org-312b97ac-359b-423a-9e85-1bbf6e934635.

^[5] Comments of the California Public Utilities Commission Public Advocates Office on the September 27-28, 2021 Stakeholder Call Discussion (October 12, 2021), available at: https://stakeholdercenter.caiso.com/Comments/AllComments/45170b95-9925-4512-b251-5a520e0548b7#org-5f911fb1-1a80-4a3f-ae4e-07ca254b8d45.

^[6] Comments of the California Wind Energy Association on February 7th Stakeholder Call Discussion, 2021-2022 Transmission Planning Process (February 22, 2022), available at: https://stakeholdercenter.caiso.com/Comments/AllComments/03164824-5b8f-4086-93a3-b7d2903f0b1f.

^[7] Comments of ACP-California on the September 27-28, 2021 Stakeholder Call Discussion (October 12, 2021), available at: https://stakeholdercenter.caiso.com/Comments/AllComments/45170b95-9925-4512-b251-5a520e0548b7#org-326b1bbe-9ab5-41a4-a88f-46f4ec3a86b8.

^[8] Comments of LSA/SEIA on February 7th Stakeholder Call Discussion, 2021-2022 Transmission Planning Process (February 22, 2022), available at: https://stakeholdercenter.caiso.com/Common/DownloadFile/9cda62be-ed4e-4d40-8fac-0a82ef16911e.

[9] Interconnection Process Enhancements (“IPE”) Track 1 Draft Tariff Language (April 13, 2023), available at: https://stakeholdercenter.caiso.com/StakeholderInitiatives/Interconnection-process-enhancements-2023.

[10] CAISO Responses to Stakeholder Comments on the 2022-2023 Transmission Planning Process Stakeholder Meeting of November 17, 2022 (posted April 11, 2023), p. 68-69, available at: http://www.caiso.com/InitiativeDocuments/ISO-Responses-to-Comments-2022-2023-Transmission-Planning-Process-Nov172022.pdf.

^[11] Draft Transmission Plan, pp. 65-66, 70-71.

[12] CPUC Decision 23-02-040 (issued February 28, 2023), Ordering Paragraph 13, available at: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M502/K956/502956567.PDF.

^[13] Draft Transmission Plan, p. 53.

^[14] PG&E Advice Letter 6801-E (December 28, 2022), p. 3, available at: https://www.pge.com/tariffs/assets/pdf/adviceletter/ELEC_6801-E.pdf.  

^[15] Draft Transmission Plan, p. 68.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

New Leaf Energy has no comment at this time.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

New Leaf Energy has no comment at this time.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

New Leaf Energy has no comment at this time.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

New Leaf Energy has no comment at this time.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

New Leaf Energy has no comment at this time.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

On behalf of NGIV2, LLC, Grid United, LLC, Citizens Energy, and the Imperial Irrigation District, we believe that the CAISO has developed a substantive transmission plan that will greatly support the reliability, economic and policy objectives of the CAISO and the regional interconnected transmission system. We commend the CAISO staff on the tremendous effort to prepare this draft plan.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

We collectively support the cumulative assumptions behind the 2022-23 TPP, including the long-term views beyond 10 years and more aggressive targets to reduce greenhouse gas emissions for the long-term as well.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

We collectively have commented previously on the reliability improvements in the San Diego and greater Imperial Valley region. Specifically, we are supportive of the Miguel-Sycamore Canyon 230kV loop into Suncrest and 500/230kV transformer additions at Miguel and Suncrest. These should also help to increase the overall import capability for the SDGE area.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

We collectively concur that the significant transmission reinforcements needed for all areas, and especially for the Southern Area, will enable the additional access to regional renewable resources (including geothermal from the Imperial Valley, out of state wind and solar, etc.). We are in agreement that the second North Gila – Imperial Valley 500kV line is a critical link for achieving the policy level objectives for the Southern Area.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

None at this time.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

We appreciate CAISO’s evaluation of NGIV2 as an ITP and its inclusion in the CAISO plan as a regional project. While WestConnect did not identify the project as fulfilling a regional need as per their study methodology, there are benefits for the broader southwest region because of NGIV2, especially during extreme weather scenarios. As CAISO would probably agree, conventional transmission planning scenarios are typically not set up to simulate extreme weather scenarios (lack of local resources) and the quantify the insurance like benefit an interregional tie brings by providing the ability to import or export energy from diverse geographical resources.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

None at this time. However, we would like to note that previous studies have shown a reduction in LCR requirements for the greater San Diego/Imperial Valley region with the addition of the NGIV2 Project.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

We are collectively supportive of the conclusions of the informational Special Study and recognize that a few of the recommended policy level projects are key components for mitigating the regional reliability concerns identified with this Special Study.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

None at this time.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Northern California Power Agency (NCPA) supports the comments submitted by the Bay Area Municipal Transmission group (BAMx) on April 25, 2023, in response to the draft CAISO 2022-2023 Transmission Plan, dated April 3, 2023.

In the Executive Summary section of the draft CAISO 2022-2023 Transmission Plan, CAISO states that it has found the need for a total of 46 transmission projects, that would result in a total investment of an estimated $9.3 billion.  These costs will ultimately be paid by California ratepayers.  The CAISO further states in the Executive Summary section of the draft CAISO 2022-2023 Transmission Plan that these costs translate to approximately 0.5 cents per kWh over the life of the projects.  In consideration of the significant costs the proposed 46 transmission projects would impose on California ratepayers, NCPA requests CAISO to supplement the Executive Summary section of the draft CAISO 2022-2023 Transmission Plan to include additional information focused on the costs and impacts these investments will have on California ratepayers.  The draft plan indicates that CAISO is targeting to include an estimate of future HV TAC rates impact resulting from the approved projects in the report presented to the ISO Board of Governors.  NCPA requests that CAISO make that information available to stakeholders as soon as possible, rather than waiting until the May Board of Governors meeting.  Inclusion of this additional information as soon as possible will to ensure decision makers that rely on the final CAISO 2022-2023 Transmission Plan have access to clear and transparent rate impact information.  For example, as further described in the comments submitted by BAMx, the HV TAC would increase to $24.50/MWh in 2036 based on the recommended project approval described in the draft CAISO 2022-2023 Transmission Plan, resulting in a staggering 63% increase in such rate over a thirteen year period, as compared to the existing level of $15/MWh for HV TAC.  NCPA specifically requests that CAISO include the information and graphic described as Figure 8.1 of the BAMx comments (Transmission Capital Expenditures and HV TAC Projections (Base and Draft Plan Recommended Approvals): 2023-2036) in the Executive Summary section of the draft CAISO 2022-2023 Transmission Plan, to ensure stakeholders and decision makers have a more complete and transparent understanding of how these investments will impact the rates paid by California ratepayers. 

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

No comment at this time.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

No comment at this time.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

NCPA opposes the CAISO approving projects based on the sensitivity portfolio. The CAISO stated at the April 11, 2023, stakeholder meeting that the sensitivity portfolio will be the same as the base case for the 23-24 TPP cycle. NCPA disagrees with this approach. The Kern-Lamont-Stockdale 115 kV constraint shows a FCDS capability exceedance of a 198 MW in the 2035 sensitivity case, however the exceedance is 0 MW in the 23-24 TPP base case. Similarly, the Victor to Lugo 230 kV constraint shows a FCDS capability exceedance of 440 MW in the 2035 sensitivity case, but is significantly reduced to 86 MW in the 23-24 TPP base case. The CAISO should only approve projects contained in the base case, and not projects contained in the informational sensitivity study.  NCPA believes the CAISO is rushing to approve projects such as the Trout Canyon – Lugo 500 kV Line (costing the ratepayers $2B), the Trout Canyon – Sloan Canyon 500kV upgrade (costing the rate payers $242M), or the mitigations for the Serrano–Barre corridor constraint without allowing adequate time for CAISO or stakeholders to assess the ultimate need for such projects. Where possible, the CAISO should recommend projects using existing corridors and right-of-ways instead of proposing to construct in a new corridor, as is the case for the Trout Canyon – Lugo 500 kV Line.

If CAISO does approve these projects in the final 2022-2023 Transmission Plan, NCPA urges CAISO to continually reassess the need for those projects in future planning cycles as underlying project assumptions change.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

No comment at this time.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

No comment at this time.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

“BESS…when charging have a large headroom” – This statement might be true if the word “charging” is changed to “charged”. The concern is that if this analysis is not conducted with sufficient rigor, including modeling required for charging energy availability, the resulting system vulnerabilities will lead to expenditure on resources that are not able to respond to system transients when needed. Equating “headroom” to the difference between PMax and PMin is equivalent to saying that an automobile with a 1-ton payload capacity can accept a 2,000- pound load when it is already carrying 800 pounds. This equivalency is only possible if every machine being relied upon for frequency response is operating at PMin continuously.

We are also concerned the CAISO studies may not have sufficiently evaluated and been reconciled against the WECC study result from 2021, which showed Under Frequency Load Sheading protection triggered for a “loss of 2 Palo Verde units” event. This is especially important when the presentation on slide 61 simply concludes that, “IBRs…will have frequency response capabilities”. These capabilities will exist only if the IBRs have been tested for and if the response of the individual IBRs has been confirmed to meet the coordination requirements between limiter and protection system responses required by NERC Standard PRC-019. Since this lack of coordination was one of the root causes observed by FERC, NERC and ERCOT in Odessa Texas in 2021 during conditions of a mild transient (200 MW load clearing in less than three cycles), our concern is amplified by a double Palo Verde outage which is greater than 13 times this mild transient magnitude. NCPA recommends the CAISO improve its evaluation of the system through comparison to actual events to better predict how the system will react under stress.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

No comment at this time.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

Currently, there are one hundred and twenty-six (126) previously approved projects from as early as 2003 that have not reached construction completion to date. In the current (22-23) draft plan, CAISO proposes to approve an additional forty-six (46) projects of which only four (4) are eligible for competitive solicitation. While escalating load forecast, specifically the high transportation electrification scenarios, are clearly driving the need for transmission investments, NCPA cautions the CAISO and request that plan focus on realistic and achievable goals for transmission buildouts, to ensure the new projects proposed in the draft plan are considered in proper sequence as compared to previously approved projects that have not yet achieved construction completion. 

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

PG&E greatly appreciates the work that CAISO has done to prepare the 2022-23 Draft Transmission Plan and the opportunity to provide these comments.  PG&E provides the below comments on specific projects.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

North of Mesa Upgrades
PG&E supports the Mesa Spare Transformer Installation project but requests the CAISO, in its board-approved transmission plan, to clarify the size of the energy storage solution needed at the Mesa 230 kV substation.  In the 2020-2021 Transmission Plan, the CAISO determined that a 50 MW 4-hour battery energy storage system (BESS) solution was the preferred mitigation plan to address the maintenance window at the Mesa substation.  Subsequently, the CPUC in Decision 22-02-004 ordered PG&E to issue a solicitation to procure a 50 MW 4-hour BESS at the Mesa 115 kV substation.  In the Draft 2022-2023 Transmission Plan, the discussion on page 52 states that the CAISO concurs with PG&E’s proposed change of interconnection from the 115 kV to the 230 kV system but appears to have revised the needed BESS procurement at 95 MW in size.  PG&E requests the CAISO to confirm whether the BESS size needed is still 50 MW or has increased to 95 MW.  In addition, PG&E requests the CAISO to confirm that the BESS solution at the 230 kV interconnection, coupled with the system spare transformer installation, will address the maintenance planning requirements and no further BESS solution at the 115 kV interconnection should be pursued.

Wheeler Ridge Junction Project
PG&E supports the CAISO’s recommendation to take off-hold the previously approved Wheeler Ridge Junction Project given the significant projected increase in load and also generation interest in the area.  Since the previously CAISO-approved BESS solution on the Kern-Lamont 115 kV system no longer meets the reliability needs of the load pocket, and the previously identified constraint and new constraints can be solved by the Wheeler Ridge Junction Project with the scope change, PG&E requests the CAISO to confirm that the 95 MW 4-hour BESS on the Kern-Lamont 115 kV system should no longer be pursued. 

In addition, PG&E requests the CAISO update the Draft Transmission Plan to reflect several minor edits to clarify the detailed description of the project's scope.  PG&E plans to provide these edits separately. 

Expanded Scope of Tulucay-Napa #2 Line Capacity Increase Project
PG&E appreciates that CAISO is recommending the Expanded Scope of Tulucay-Napa #2 Line Capacity Increase Project for approval.  PG&E’s cost estimate for the scope expansion is $2.3M-$4.6M.  The original scope cost estimate from the 2019-20 Transmission Plan is $5M- $10M. Therefore, the total cost of the expanded project will be $7.3M-$14.6M, however it is reported as $2.3M- $4.6M in the Draft Transmission Plan on page 40.  PG&E requests the CAISO update the total cost in the Draft Transmission Plan.

Lone Tree – Cayetano – Newark Corridor Series Compensation
PG&E in general supports the approval of “Lone Tree – Cayetano – Newark Corridor Series Compensation" project.  However, since the addition of the series compensation on the Cayetano-Lone Tree and Las Positas-Newark 230 kV lines will change the power flow pattern in that area and divert the flow to the other lines in the system, PG&E recommends that CAISO perform more detailed studies to evaluate the complete impact of the project to ensure no unintended issues are created by this project.

The expected in-service date for the project will be 2027.  In the interim, PG&E looks forward to continuing working with CAISO on the operating action plans to ensure that the identified reliability issues can be temporally addressed.  In addition, PG&E looks forward to working with CAISO in defining the additional reliability studies that should be performed to continue testing this solution in the next TPP cycle. 

Pittsburg 115 kV Bus Reactor 
PG&E appreciates that CAISO recommends the Pittsburg 115 kV Bus Reactor project for approval. PG&E performed a high-level cost and feasibility analysis for this project and the estimated cost is $13M-$26M. PG&E is performing further studies for power flow and bus flow analysis to determine the associated switches and bus work mentioned on page 50 in the Draft Transmission Plan. PG&E will continue working with the CAISO on the more detailed scope based on the additional studies.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

Reduce Overall Series Compensation on the Table – VACA – Collinsville – Tesla 500 kV Path
The Draft Transmission Plan states on page 64 that, “…to mitigate the Collinsville-Pittsburg constraint, it is recommended to reduce the overall series compensation on the Table Mountain-Vaca-Collinsville-Tesla 500 kV path.”  PG&E requests the CAISO share more details on its studies that identified the constraints and verified the mitigation recommendations. Since the recommended mitigation could change the 500 kV backbone impedance and flow patterns, PG&E is seeking to understand the studies that revealed the potential system impacts as well as the proposed scope of the solution.  Further, once the scope of this is known, PG&E will need to investigate the feasibility and cost for the recommended series compensation change.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

PG&E Fresno Henrietta 115 kV Congestion Mitigation with SPS 
For the PG&E Fresno Henrietta 115 kV congestion in the economic assessment in the 2022-2023 planning cycle, on page 118 in the Draft Transmission Plan, CAISO presented a SPS alternative to open the GWF-Contadina 115 kV line under the Helm-Mc Call and Henrietta Tap2 – Mustang 230kV lines N-2 contingency. PG&E is looking forward to working with CAISO to investigate the feasibility of the SPS solution or other potential transmission solutions.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

Mesa 230/115 kV Spare Transformer
PG&E supports the CAISO’s recommended Mesa Spare Transformer Installation project for approval.  PG&E’s estimated cost of the spare transformer project is $12M-$24M; however, Table 8.2-1 on page 165 in the Draft Transmission Plan reports the project cost as $50.48M which is higher than the PG&E estimate.  PG&E requests the CAISO to update the estimated cost in Table 8.2-1.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Pattern Energy appreciates and supports many aspects of the draft 2022-2023 Transmission Plan (“Plan”).  This plan does a good job looking forward and anticipating the transmission needs necessary to support California’s clean energy demands, including those associated with the electrification of the transportation and building sectors.    

Pattern Energy appreciates the inclusion of out-of-state resources in this draft plan and the identification of the “in-state” transmission upgrades necessary to make such resources deliverable to California Load Serving Entities (“LSEs”).  These transmission upgrades will enable the delivery of diverse clean energy resources that will cost-effectively contribute to California’s resource adequacy needs without increasing carbon emissions.    

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

Pattern Energy appreciates the proactive nature of this transmission plan and the coordinated work between the CAISO, CPUC, and CEC. 

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

Pattern Energy supports the treatment of the out-of-state (OOS) wind resources in the policy-driven needs assessment.  Including the sensitivity case for OOS wind in this transmission plan appropriately recognizes that similar needs are already being identified in the base-case for the 2023-24 transmission planning process.  Proactively “right-sizing” these upgrades to meet all of the forecast needs will benefit ratepayers over the next decade.  Indeed, the volumes of New Mexico wind identified in the sensitivity case are consistent with and supported by the commercial reality unfolding on the ground today. 

Pattern also appreciates the inclusion of OOS resources in the maximum import capability (MIC) analysis.  The upgrades identified in this analysis will provide for the delivery of diverse clean energy resources that will cost-effectively contribute to California’s resource adequacy needs. 

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

Section 6.1.2.1 provides important information on the status of MIC for OOS resources seeking to provide resource adequacy (RA).  Pattern Energy appreciates this analysis and the identification of the upgrades necessary to increase MIC.  In order to facilitate the timely and full utilization of the identified upgrades, and because LSEs are often contracting for RA resources multiple years in advance, Pattern would support the ISO allowing LSE’s to reserve MIC more than one-year in advance.  Such a policy would allow generation to be contracted with California’s LSEs simultaneously, or even in advance of, the transmission upgrades themselves.  In the meantime, while upgrades are being permitted and constructed, Pattern would similarly support the ISO providing as much information as possible about the availability of “partial” and/or “interim” MIC in order to facilitate the contracting and development of RA resources while upgrades are being completed. 

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) provides these comments on the California Independent System Operator’s (CAISO) draft 2022-2023 Transmission Planning Process (TPP).  Cal Advocates is an independent consumer advocate with a mandate to obtain the lowest possible rates for utility services, consistent with reliable and safe service levels, and the state’s environmental goals.[1]

1. CAISO should assign each project a unique identifier.

Cal Advocates recommends that CAISO assign each project a unique identifier to streamline data management.  The addition of a unique identifier to each project will allow stakeholders to identify and track projects more easily and would reduce confusion about which projects are being referred to across TPP documents.  Cal Advocates also recommends that the same unique identifier be used in future TPP cycles.  For example, if CAISO introduces a project in one year’s TPP, and then in the next year's TPP recommends that the project be put on hold, the same unique identifier should be used for that project in both TPPs.  This would increase transparency and streamline project analysis over time.

2. CAISO should provide a high-voltage and low-voltage cost breakdown for projects that need both high and low-voltage upgrades. 

Cal Advocates appreciates the detail and analysis CAISO provided in the Panoche 115 kilovolt (kV) Circuit Breaker Replacement and 230 kV Bus Upgrade project.  The description of this project on page 51 of the draft TPP indicates how much of the project’s cost estimates are allotted to the 115 kV circuit breaker replacement and the 230 kV bus upgrade.  Cal Advocates recommends that this breakdown of cost allocation for projects at multiple voltages be applied to all projects with multiple voltages.  This change would improve the accuracy of cost analysis for high voltage (HV) transmission access charge (TAC) and low voltage (LV) TAC cost estimates.

[1] California (Cal) Public (Pub.) Utilities (Util). Code § 309.5.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

1. CAISO Should Provide Detailed Cost Estimates

Cal Advocates recommends that the CAISO provide more details on the project cost estimates for the proposed projects for approval and further study.  Currently, the provided project costs only include a cost estimate or a range total, but no information on the cost for the different project scope items or sources for the cost estimates. The CAISO or the project sponsor should provide costs based on the annual Participating Transmission Owner Per Unit Cost Guides for the specific project items such as substations, transformers, series capacitors, and per mile of new transmission lines as well as project contingencies.

Cal Advocates also recommends that CAISO develop a project cost review process similar to the process conducted by Southwest Power Pool (SPP).  For the past 10 years, SPP has relied on a review process to track project costs starting from the project estimation phase to construction on a quarterly basis.  If a project’s quarterly report reveals that its costs have exceeded 10% of the original project cost, the project is reviewed to ensure that the escalations are appropriate,[1] and if the project cost is over 20% of the original costs, the board can suspend the project or order that the project not be constructed.[2]  SPP officials have stated that this process has helped lead to projects that are being priced below their original cost estimates.[3]

2. CAISO Should Evaluate Line Enhancing Technologies as Project Alternatives

Cal Advocates also recommends that the CAISO consider more than one project alternative for all proposed projects and that CAISO consider at least one grid enhancing technology or non-wires project alternative, such as increasing an existing line’s capacity.  This would be consistent with the Federal Energy Regulatory Commission’s (FERC) request that public utility transmission providers consider whether adding dynamic line ratings or advanced power flow control devices to existing transmission facilities could meet the same transmission need more efficiently or cost-effectively than a new transmission facility.[4]

     C. Cal Advocates requests an update on CAISO’s Generator Deliverability Methodology Review initiative.

Cal Advocates anticipated that the Issue Paper for this initiative would be published in the first quarter of 2023.[1]   Cal Advocates requests the CAISO clarify when it will publish this Issue Paper through its Daily Briefing or other means.

[1]  CAISO Deliverability Challenges An ISO Update, CAISO, December 12, 2022 at p. 11 Update-Paper-Generation-Deliverability-Methodology-Review-Dec132022.pdf (caiso.com).

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

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

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

[4] FERC Docket RM21-17-000, April 21, 2022, Item 274 at p. 217.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

Please refer to Public Advocates Office Comments on the September 28, 2022 Stakeholder Call Discussion on the proposed reliability projects filed on October 12, 2022.[1]

[1] Public Advocates Office comments on the September 28, 20220 stakeholder call discussion, 2022-2023 Transmission Planning Process, October 12, 2022.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

Cal Advocates raises the following issues regarding the proposed 22 policy projects: 1) cost estimates for all the project components are not provided, and those that have been provided are not supported with detailed information, and 2) non-wire alternatives such as dynamic line rating and advanced flow devices were not considered as lower cost alternatives. Evaluating lower cost alternatives should also be considered specifically if projects are not cost-effective, such as the proposed Southern California Edison Company (SCE) Lugo-Victor-Kramer 230 kV upgrade.

Additionally, the California Public Utilities Commission’s (CPUC) Integrated Resource Planning (IRP) proceeding did not evaluate and co-optimize the following transmission projects with generation selection: 1) the three proposed Southern Area Reinforcement Projects (Imperial Valley-North of SONGS 500 kV Line and Substation, North of SONGS-Serrano 500 kV, and Serrano-Del Amo Mesa 500 kV Transmission Reinforcement project), 2) the Trout Canyon-Lugo 500 kV Line, or 3) the revised GLW/VEA Area Upgrade referred as the Trout Canyon Sloan Canyon Project 500 kV Upgrade.

To ensure that the latter two projects - Trout Canyon-Lugo and Trout Canyon-Sloan Canyon - represent optimal investments, the CASIO and the CPUC should consider not approving these projects in this cycle and re-assessing them in the IRP proceeding with the assumption that the Southern Area Reinforcement Projects are in place. As detailed below, because the Southern Area Reinforcement projects could provide access to resources similar to those that would be accessed by the Trout Canyon-Lugo and Trout Canyon-Sloan Canyon Projects, this deferral should not adversely impact California's progress toward its renewable energy goals.

To explain, the Southern Area Reinforcement projects, along with other upgrades, will provide access to Imperial Valley solar and geothermal.[1] The Trout Canyon-Lugo 500 kV Line and Trout Canyon-Sloan Canyon 500 kV Upgrade are also proposed to access solar and geothermal, but in southern Nevada.[2] It may be the case that the optimal outcome would be to utilize the sizeable new transmission capacity created by the Southern Area Reinforcement projects to access the needed solar and geothermal to support the state’s 2035 resource portfolio instead of the Trout Canyon-Lugo 500 kV Line and the Trout Canyon-Sloan Canyon 500 kV Upgrade. To ensure that these projects represent optimal investments, the CAISO and the CPUC should not approve these projects in this cycle and allow the CPUC in its IRP proceeding to assess the impact and need for the Trout Canyon-Lugo 500 kV Line and Trout Canyon-Sloan Canyon 500 kV Upgrade in the context of the Southern Area Reinforcement Projects. 

Cal Advocates also recognizes that the Trout Canyon-Lugo 500 kV Line and the Trout Canyon-Sloan Canyon 500 kV Upgrade are not identified to be needed to support the 2022-2023 TPP base case portfolio. Therefore, CAISO’s approval of these projects in this TPP cycle would not be consistent with the CAISO’s Tariff.[3]

The proposed Trout Canyon – Lugo 500 kV Line and Trout Canyon-Sloan Canyon 500 kV Upgrade would also have a serious financial impact on ratepayers. The cumulative estimated cost of these projects is $2.52 billion, which, over a 40-year lifespan, could result in an impact to ratepayers of over $250 million annually.[4] The Trout Canyon-Lugo 500 kV Line would also need to establish a new corridor across the California desert. Permitting is recognized as one of the biggest risks to transmission development [5], and it is likely that the proposed project’s $2 billion cost will escalate significantly. 

The CPUC has encouraged the CAISO to get a “head start” on this sensitivity case, given the upcoming portfolios.[6] However, the CAISO and the CPUC have also created a set of processes meant to ensure that decisions about resource planning and transmission investments are optimized and made with the most up-to-date information. These processes should be applied to the Trout Canyon-Lugo 500 kV Line and Trout Canyon – Sloan Canyon 500 kV Upgrade before ratepayers are asked to bear the burden of them.

1. CAISO Should Confirm Whether the Lugo-Victor-Kramer 230 kV Upgrade is Right-Sized and the Lowest Cost Option

This upgrade is estimated to cost $482 million.  However, it has several components and a breakdown of costs for each component is not provided.  CAISO’s economic assessment of this project, and the alternative studied, states that the economic benefits of this project and the alternative studies do not offset the costs.[7]  The alternative project upgrade studied involved a new substation, two new transformers, and a new line.  Furthermore, grid enhancing technologies (GETS) were not considered despite the fact that GETS can enhance the capacity of existing lines at lower cost than totally rebuilding lines i.e., reconductoring.  The assessment should evaluate whether GETS could lower the cost of any of the proposed project components.

Cal Advocates requests that CAISO not approve this project as scoped this year since it is not cost-effective for ratepayers and may need further scope refinements based on the current 2035 portfolio. The project can be easily reviewed in a subsequent transmission planning process, and Cal Advocates requests that the CAISO continue to study the most cost-effective ways to address the congestion and renewable curtailment in the SCE NOL area in this year’s TPP cycle. This study should evaluate whether installing line capacity-increasing technologies to existing lines would address the identified issues as cost-effectively as the proposed new upgrades consistent with FERC’s recommendation in RM21-17-000.

[1] Draft Plan, p. 3.

[2] Draft Plan, p. 3.

[3] “Transmission solutions that are included in the baseline scenario, but which are not included in any of the stress scenarios or are included in an insignificant percentage of stress scenarios, generally will be Category 2 transmission solution, unless the CAISO find sufficient analytic justification exists to designate them as Category 1 transmission solutions.” (CAISO Section 24 Comprehensive Transmission Planning Process, Fifth Replacement FERC Electric Tariff, February 11, 2023, Section 24.4.6.6.)

[4] Estimates made using the CAISO Transmission Access Charge Forecast Model, assuming a 12% Return on Equity.

[5] Linares, Corina. Permitting is transmission’s biggest risk, but also an opportunity. Power-Grid.com. August 2016. Available at https://www.power-grid.com/executive-insight/permitting-is-transmission-s-biggest-risk-but-also-an-opportunity/#gref.

[6] Decision 23-02-040. Rulemaking 20-05-003. February 23, 2023. Pp.50-51. Available at https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M502/K956/502956567.PDF.

[7] Appendix F at F-80.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

At this time, Cal Advocates does not have any comments on this issue.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

At this time, Cal Advocates does not have any comments on this issue.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

The Draft Plan’s informational discussion on the impact of reduced reliance on Aliso Canyon Gas Storage should be updated to include the most recent forecast information from the CEC.

Chapter 7 of the Draft 2022-23 Transmission Plan presents the CAISO’s Information Only, Transmission Reliability Study of the LA Basin and San Diego-Imperial Valley Local Capacity Areas with Reduced Reliance on Aliso Canyon Gas Storage.[1]  This informational Aliso Canyon study utilizes the 2021 Integrated Energy Policy Report’s (IEPR) “1-in-10 AAEE [Additional Achievable Energy Efficiency Scenario] 2 & AAFS [Additional Achievable Fuel Substitution Scenario] 4 demand with Additional Transportation Electrification (ATE) forecasts” and takes 2032 for its study year.  The informational Aliso Canyon special study finds that the assumed Aliso-related curtailments of thermal generation would cause “extensive thermal overloading” in Southern California during summer peak conditions, but would not cause any “transmission reliability concerns” during winter peak conditions.[2]  The draft TPP includes one caveat on this winter peak finding, noting that the winter peak grows to 73% of the summer peak in 2035, up from 67% in the 2032 study year of the informational Aliso Canyon study.[3]  

Cal Advocates recommends the CAISO insert an additional caveat in its discussion of the informational Aliso Canyon study to address new information from the 2022 IEPR Update.  The latest demand forecasts from the 2022 IEPR Update include a winter peak that is higher both in absolute megawatts (MW) and relative to the corresponding summer peak.  The 2022 IEPR Local Reliability Scenario[4] includes a 2035 coincident CAISO winter peak of 50,306 megawatts (MW), which is 85% of the 2035 Local Reliability Scenario summer peak of 59,107 MW.[5]

[1] 2022-23 Draft Plan at p. 151 et seq.

[2] 2022-23 Draft Plan at p. 155.

[3] 2022-23 Draft Plan at p. 155.

[4] As of the 2022 IEPR Update, the “Local Reliability Scenario” succeeds the mid-baseline forecast with the AAEE 2 and AAFS 4 forecasts, with some additional updates.

[5] California Energy Commission, California Energy Demand Update, 2022-2035, webpage.  Available at https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-report/2022-integrated-energy-policy-report-update-2.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

At this time, Cal Advocates does not have any comments on this issue.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

A. Per the CAISO’s Tariff and FERC regulations, the Draft Plan should be revised to state that the majority of the Beatty 230 kV project and portions of the Serrano–Del Amo–Mesa 500 kV Transmission Reinforcement Project will undergo a competitive transmission procurement process. 

FERC Order No. 1000 required transmission providers to remove a right to construct projects within their service territory, provided that those projects “are evaluated at the regional level and selected in the regional transmission plan.”[1]  The CAISO’s Tariff, which complies with FERC Order No. 1000, states that facilities that are over 200 kV and that are not additions, upgrades, or improvements to existing facilities are eligible for competitive transmission procurement.[2]

 Most of the facilities that are part of the Beatty 230 kV project meet the Tariff’s criteria for competitive procurement.[3]  The eligible facilities consist of a new 230-kV Johnnie Corner Substation, a 32-mile Beatty-Lathrop 230 kV line, a new 30-mile Johnnie Corner-Valley Switch-Lathrop line, and a second Johnnie Corner-Innovation and Johnnie Corner-Vista-Pahrump 230 kV line.[4]  Although these 230 kV lines will be built next to the existing 138 kV lines, they are neither upgrades nor improvements to those lines; they are entirely new facilities. The competitively procured Ten West Link line is, like these lines, being built alongside existing facilities and is increasing the transfer capacity of an existing corridor.[5]

Similarly, the Serrano–Del Amo–Mesa 500 kV Transmission Reinforcement Project includes a new 500 kV switchyard at Del Amo with three new 500/230 kV transformers, a new 2-mile line section into the Mesa substations, a 13-mile 500 kV line to Serrano, and two new approximately 13-mile lines (Del Amo-Mesa and Del Amo-Serrano).[6]  All facilities described in this and the preceding paragraph should, pursuant to the CAISO’s Tariff and FERC Order No. 1000, be eligible for competitive procurement.

 The fact that these facilities are part of projects that include elements that are not eligible for competitive procurement should not exempt them from competitive procurement. It is common for incumbent transmission providers to be responsible for facilities that are associated with competitively procured projects. For example, Pacific Gas and Electric Company (PG&E) and Silicon Valley Power will be responsible for protective equipment that is necessary to integrate new HVDC projects that are being competitively procured pursuant to the CAISO’s 2021-22 Transmission Plan.[7]

 As the CPUC’s Energy Division has noted, competitive procurement can yield significant ratepayer benefits.[8] A 2019 Report found that competitive procurement led to cost savings of 29% between 2013 and 2019 in CAISO territory and that nationwide, competitive procurement led to off prices that were an average of 40% below initial cost estimates.[9]

To help mitigate the sizable ratepayer impact of the Draft Plan and to comply with existing FERC and CAISO regulations, the Draft Plan should be revised to state that the facilities listed above will undergo competitive procurement.  

B. The financial impact of these projects on customer rates should be reduced.

Cal Advocates estimates that the cumulative impact of all reliability and policy projects proposed in the 2022-2023 TPP will increase the HV transmission access charge (TAC) rate to $25.40 per megawatt-hour (MWh) by 2036.  This is a 75% increase from the current  HV TAC rate.  Figure 1 below shows the impact that the approved 2022-2023 TPP projects could have on the HV TAC rate in comparison to the existing approved projects.

Table 1.  Cal Advocates’ estimated HV TAC Forecast with and without the 2022-2023 approved TPP projects. See the attached Excel file “Cal Advocates HV TAC estimate 2022-2023 TPP” tab “2022-2023 approved projects” for the calculation methodology.

California ratepayers are already bearing the burden of transmission costs through high rates that continue to increase.  For the projects listed in the 2022-2023 TPP, there needs to be an evaluation of the cost impacts and mitigations in order to keep this additional infrastructure affordable for California ratepayers.  The TPP states that only 4 out of the 45 projects will be competitively bid. In addition to putting more projects up for competitive bidding, the CAISO should investigate other methods of reducing transmission costs, in order to avoid unnecessary HV TAC rate increases and reduce costs for California ratepayers.

In this and the previous transmission planning cycle, the CAISO has embarked on a transformational expansion of the transmission system to accommodate California’s renewable energy goals.[1] The recommendations above will help reduce costs to ratepayers, who are already burdened with high electricity costs.

[1] The CAISO approved 6 policy-driven projects at about $1.5B in the last transmission plan, and this plan includes a proposed 22 policy-driven projects at about $7.5B in 2023. All of the CAISO’s transmission plans are available at http://www.caiso.com/planning/Pages/TransmissionPlanning/Default.aspx.

[1] Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities, Order No. 1000, 136 FERC ¶ 61,051 (2011) at 102. Available at https://www.ferc.gov/electric-transmission/order-no-1000-transmission-planning-and-cost-allocation.

[2] Section 24.4.10 of the CAISO Tariff. states that “A Participating Transmission Owner will have the responsibility to construct, own, finance and maintain any Local Transmission Facility.” Appendix A of the CAISO Tariff defines local transmission projects as those that operate at a voltage below 200 kilovolts (kV) and are located entirely within the footprint of a Participating Transmission Owner’s footprint or service territory. (See http://www.caiso.com/rules/Pages/Regulatory/Default.aspx.)

[3] The incumbent transmission owner should be responsible for the 138 to 230 kV expansion of the existing Beatty, Lathrop, Valley Switch, and Vista substations that are part of the Beatty 230 kV Project, but the remainder of the project should undergo competitive procurement.

[4] 2022-23 Draft Plan at p.78.

[5] “The proposed route of Ten West largely follows the existing Devers-Palo Verde (“DPV”) 500 kV transmission line and utilizes the established utility corridor.” (Application of DCR Transmission, LLC, for Certificate of Public Convenience and Necessity for the Ten West Link Project. A.15-04-013. October 12, 2016. P.2. Available at https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M168/K810/168810324.PDF.)

[6] 2022-23 Draft Plan at p.97.

[7] “The protection equipment in the Newark and NRS substations will be provided by PG&E and SVP respectively.” (Transmission Competitive Solicitation Questions Log. Question/Answer Matrix. 2021-22 TPP – Phase 3. P. 5. Available at http://www.caiso.com/InitiativeDocuments/ISOResponsestoCommentsMatrix-2021-2022TranmissionPlanningProcessCompetitiveSolicitation.pdf.)

[8] Initial Comments of the California Public Utilities Commission in FERC RM21-17-000. October 12, 2021. Available at https://elibrary.ferc.gov/eLibrary/docinfo?accession_number=20211012-5697.

[9] Cost Savings Offered by Competition in Electric Transmission. The Brattle Group. April 2019. P.29. Available at https://www.brattle.com/wp-content/uploads/2021/05/16726_cost_savings_offered_by_competition_in_electric_transmission.pdf.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Dear Mr. Billinton:

The California Environmental Justice Alliance (CEJA) and Sierra Club appreciate the opportunity to submit these comments. Collectively, we lead the Regenerate California Campaign, where we share a vision for California’s most impacted communities to have access to clean energy, good jobs, and clean air.

We appreciate the ISO’s efforts in the 2022-2023 Draft Transmission Plan (“Draft TP”) to facilitate the construction of more than 40 gigawatts (GW) of clean energy. This will put us on a path towards adding the 70 GW of clean energy needed by 2032 consistent with the California Public Utility Commission’s increased electrification sensitivity study projection. Proactive transmission and clean energy procurement is critical to cleaning up the grid, maintaining reliability, and safeguarding affordability.

As we have noted in other venues, such as the Integrated Resource Planning (IRP) proceeding at the California Public Utilities Commission (CPUC), there are more than 160 gas-fired power plants in California, with more than half of them located in environmental justice (EJ) communities. Many of the power plants in EJ communities are peakers that operate to address local resource adequacy (RA) needs. These peaker plants are needed because of grid constraints stemming from underinvestment in EJ communities. The same grid constraints are simultaneously a barrier to the development of local clean energy resources for EJ communities. The results are continued underinvestment, severely impaired air quality due to polluting sources, outages, and unmitigated harms from extreme weather events. 

To address these impacts, investment in transmission and clean energy procurement must be locally targeted to EJ communities where grid challenges continue to keep power plants online, particularly in the San Joaquin Valley and the Los Angeles regions, where severe air pollution persists and disproportionately impacts EJ communities. While the investments in the Draft TP are necessary, there is an emphasis on out-of-state imports to meet California’s systemwide demand, in place of in-state investments to relieve local grid constraints and unlock in-state development.

For example, of the $7 billion for transmission considered in this Draft TP, only $70 million is allocated to support local clean energy development in the San Joaquin Valley – an area that the State has acknowledged for more than a decade is prime for clean energy development, with a potential of about 30 GW of incremental renewable power. This area also has many aging and weak transmission lines that can be upgraded to reduce ongoing grid constraints and improve local air quality in the region, by reducing our reliance on local gas plants.

We further appreciate the ISO’s consideration of some upgrades to increase transmission capacity into local capacity areas, particularly some that may reduce local RA needs to reduce gas-fired resources. However, further reducing and eliminating gas-fired generation that is providing local RA needs requires more than increasing transmission capacity into the area – it also requires, as we mention, local resource development and improvements to the local power system. Senate Bill (SB) 887 called for the CPUC, the CEC, and the ISO to do both:

(4)(A) Providing resource projections that, combined with transmission capacity expansions, are expected to substantially reduce, no later than 2035, the need to rely on nonpreferred resources in local capacity areas.

(B) The resource projections in subparagraph (A) shall include consideration of cost-effective and feasible alternatives to transmission capacity expansions, including the use of energy storage resources, renewable energy resources, or zero-carbon resources that are located within the local capacity areas.

SB 887 also calls for prioritization of investments in EJ communities to support transmission and clean energy procurement that will reduce reliance on gas plants:

(4) Reducing the use of nonpreferred resources in disadvantaged communities has been a priority for those communities, and they would benefit from increased access to electricity from new renewable energy resources and zero-carbon resources delivered to serve in-city loads.

The Draft TP discusses the request from the CPUC regarding SB 887 but cites previous studies, such as the 2018-2019 and 2019-2020 transmission plan, that were narrowly focused on economic benefits. This approach is inconsistent with SB 887, as the need to reduce our reliance on gas plants should be looked at more broadly than just economic benefits. A policy and comprehensive benefits-driven approach is more appropriate than solely an economic one, as reducing local gas plant use in EJ communities in tandem with clean energy and transmission procurement brings other societal and equity benefits, such as climate, resilience, and public health. This approach would also be consistent with the environmental and social justice values espoused by the CPUC, CEC, and the ISO. One key example of the need to collaborate with and prioritize EJ communities is the subsea Pacific Transmission Expansion Project. Where this proposed subsea cable for new offshore wind connects to the grid must be designed with input from the EJ communities most affected by new generation off the Central Coast as well as those EJ communities where wind will most support reliability and retirement of gas-fired generation. 

Taking a more policy- and comprehensive benefits-driven approach would not be new to the ISO. This has been done before, such as when preferred resources, like battery storage and transmission, to replace gas peaker plants were studied and implemented in the Oakland Clean Energy Initiative and the Moorpark and Santa Clara Sub-Areas Study. With the Memorandum of Understanding (MOU) established between the CPUC, CEC, and the ISO to tighten the linkage between resource and transmission planning activities, interconnection processes and resource procurement, the MOU parties must act on their environmental and social justice values by prioritizing EJ communities in this unprecedented investment in order to ensure equitable deployment of resources. We strongly recommend that the 2023-2024 Transmission Planning Process increase coordination to ensure that the resource projections required under SB 887 are reflected in the Transmission Planning Process and the portfolios by the CPUC. Some misalignment between these processes is evidenced by the split of resources between Northern and Southern California and the ISO’s utilization of outdated procurement portfolios by load-serving entities. 

Furthermore, local clean energy development must take into account the protection of California's internationally treasured wildlife, landscapes, productive farmlands, and diverse habitats and identify the appropriate least conflict areas for energy and transmission development. Busbar mapping should be aligned with land use planning to realistically evaluate the development potential for land surrounding a substation and increase viability of development. 

Lastly, ratepayer impact should be considered for enhanced local clean resource development as an alternative to developing the resources elsewhere, consistent with California Public Utilities Code § 454.57(e)(4)(B) as cited above. This should include the full ratepayer cost of transmission over time including operation, maintenance, financing and returns on equity, not just the initial capital infrastructure cost. In consideration of broader effects on equity and EJ communities, there should also be consideration of localized benefits associated with reduced emissions, as well as the jobs and revenues created from local clean resource development.

We have a unique opportunity to ensure that the implementation of a 30 MMT by 2030 target with the unprecedented level of investment in new clean energy and transmission resources puts California on a pathway to an equitable transition that deploys both clean energy and phases out gas-fired generation in EJ communities. If we don’t do this wth equity at the forefront, we risk worsening existing inequities and losing out on critical community benefits, such as enhanced climate resilience, improved air quality, and reliability for EJ communities that need these benefits the most and should be the first to benefit in our clean energy transition.

Thank you for your consideration of these comments. We look forward to working with you on these processes.

Sincerely,

Ari Eisenstadt

Regenerate California Campaign Manager

California Environmental Justice Alliance

Marven Norman

Policy Coordinator

Center for Community Action and Environmental Justice 

Sofi Magallon

Environmental Justice Policy Advocate 

Central Coastal Alliance United for a Sustainable Economy 

Shana Lazerow

Legal Director

Communities for a Better Environment 

Teresa Cheng

Senior Campaigns Representative

Sierra Club 

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

SEIA appreciates the opportunity to comment in support of the Draft 2022-2023 Transmission Plan (Transmission Plan). The proactive planning employed in this year’s Transmission Plan will support the increased renewable resource integration and deliverability needed to maintain system reliability and achieve state clean energy goals. SEIA is especially supportive of the map detailing transmission planning zones and capacity; increased data transparency like this provides invaluable insight for developers and will encourage resource development in areas with available or planned transmission capacity. 

SEIA appreciates the changes adopted in this Transmission Plan consistent with the principles captured in the Memorandum of Understanding to better coordinate the state processes driving transmission planning, resource interconnection, and resource procurement. The interaction between transmission planning and the CAISO interconnection process is a key issue for SEIA and is an important component of the ongoing Interconnection Process Enhancements (IPE) stakeholder initiative. Since the IPE discussions are ongoing, SEIA recommends CAISO soften or remove the language under the Executive Summary that states, “To bring this more coordinated approach full circle, the ISO will also give priority to interconnection requests located within those same zones in its generation interconnection process” (Transmission Plan 1). This sentence as written suggests the outcome of the IPE has been predetermined by CAISO. 

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

Southern California Edison (SCE) commends the CAISO on the development and results of the Draft 2022-2023 Transmission Plan. SCE strongly supports the CAISO’s proactive and coordinated approach to identify and plan for the required transmission investment to comprehensively meet the future needs of the CAISO-controlled transmission grid. The interwoven nature of resource planning, transmission planning, interconnection processing, and resource procurement activities necessitates this integrated approach the CAISO used in the development of the 2022-2023 Transmission Plan.  The CAISO’s strategic and preemptive method should be fruitful in bringing online the exponential growth in generation resources as the industry continues to transition towards a carbon-free electric grid and to meet California’s clean energy goals.

The Draft Transmission Plan is headed in the right direction to strengthen the reliability of the grid and to increase resource deliverability as the grid continues to decarbonize and customers increase their consumption of electricity.  The total of 24 identified reliability projects, with estimated costs of roughly $1.76 billion is the scale of investment needed to mitigate reliability concerns associated with both significant load growth and challenges related to the integration of renewable generation.  The total of 22 policy-driven projects, with estimated costs of approximately $7.53 billion, should facilitate the timely interconnection of the resources identified in the CPUC’s renewable generation portfolios to reduce greenhouse gas emissions.  The four projects eligible for competitive solicitation – Trout Canyon-Lugo 500 kV line; Imperial Valley-North of San Onofre Nuclear Generating Station (SONGS) 500 kV line and substation; North of SONGS-Serrano 500 kV line; and North Gila-Imperial Valley 500 kV line – are needed transformational baseline transmission projects to access not only intrastate renewable resources, but also to import out of state renewable resources.

As the detailed design is developed for the incumbent and competitive projects, flexibility will be needed, since rerouting and/or undergrounding may be required to optimize Rights-of-Ways (ROWs), which could drive consideration of the use of High Voltage Direct Current (HVDC) technology when undergrounding at higher voltage levels (>230 kV).  SCE urges the CAISO to recognize that the project costs (both incumbent and competitive) are conceptual and will likely increase with more defined project scope, particularly for the large transmission projects that will require new ROW and licensing.

The Draft 2022-2023 Transmission Plan is in alignment with SCE’s Pathway 2045 goals.  The total of $9.3 billion identified as needed transmission investment in the Draft Transmission Plan’s 10-year outlook trends towards Pathway 2045’s up to $75 billion in required grid investments from 2030 to 2045 to integrate bulk renewable generation and storage and serve the load growth associated with transportation and building electrification. Per Pathway 2045, transmission upgrades will be required for generation interconnection within the state and the doubling of CAISO’s import capability to source out-of-state renewables.  As we experience the ongoing steep escalation in the base portfolios studied over the past several Transmission Planning Process (TPP) cycles from 10 GW in the 2020-2021 TPP, to 27 GW in the 2021-2022 TPP, and 40 GW in the 2022-2023 TPP, to 70 GW in the 2023-2024 TPP, SCE is optimistic the CAISO’s identified needed transmission investment to safely and reliably operate the grid and integrate renewable resources will soon intersect or closely approximate the up to $75 billion in transmission investment identified in Pathway 2045.  

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

SCE supports the two significant course changes identified in the 2022-23 TPP, and acknowledges the changes were needed to align the TPP with California’s clean energy goals.

• • “The 2022-2023 Transmission Plan reflects two significant course changes from previous years’ plans, and these changes are present throughout the document. First, the ISO has reshaped the Plan to provide the proactive zonal transmission planning foundation for transformational changes the ISO is pursuing in close coordination with the California Public Utilities Commission (CPUC) and the California Energy Commission (CEC) to tighten linkages between resource and transmission planning activities, interconnection processes and resource procurement. Second, the Plan acts on and responds to the rapid escalation in the projected resource requirements over the next 10 to 15 years to meet California’s clean-energy needs. The projected incremental resource requirements in this year’s Plan, for example, climbed fourfold compared to the 2020- 2021 Plan prepared only two years ago, and the pace is climbing in next year’s plan as well.”

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

SCE supports the proposed approvals of the five reliability projects identified within its system: Serrano 4AA 500/230kV Transformer Bank Addition; Sylmar Transformer Replacement; Antelope – Whirlwind 500kV Line Upgrade Project in SCE’s Main system planning area; the Coolwater 1A 230/115kV Bank Project; and the Control 115kV Shunt Reactor Project in SCE’s North of Lugo area.  SCE is working to finalize the proposed scope of the Eldorado Short Circuit Duty Project which will be submitted to CAISO by mid-August 2023.

SCE also notes that the Serrano 4AA 500/230kV Transformer Bank Addition project scope was submitted prior to CAISO recommending approval of the South Area Reinforcement project. The South Area Reinforcement project necessitates two additional new 500 kV positions at Serrano 500 kV, which will likely require further modifications to Serrano 500/230 kV Substation. SCE is evaluating the impact accordingly, and SCE looks forward to executing on the necessary upgrades that are identified and meeting any associated reliability need dates.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

SCE commends the CAISO for its rigorous and thorough assessment, in conjunction with the staff of the CEC and the CPUC. The portfolio supports the transition towards the renewable energy and greenhouse gas reduction targets, while at the same time maintaining grid reliability, which will also serve to ensure deliverability and alleviate potential curtailment.   

In SCE’s Northern Interconnection Area, SCE supports the planned Windhub CRAS and related initiatives that are necessary to mitigate the area constraints to on-peak deliverability. 

In SCE’s North of Lugo Interconnection Area, SCE supports CAISO’s proposed approval of the Lugo-Victor-Kramer 230kV Upgrade Project as proposed.  As CAISO notes in Appendix H, this project effectively has three subsections, and these subsections can be constructed in a phased manner as any applicable approvals are obtained.   As such, SCE believes that executing on the Lugo-Victor-Kramer project on each subsection individually will be in the best interests of California’s ratepayers, the reliability of the electric system, and will provide enhanced deliverability for local generators in the area.

In SCE’s Metro Interconnection Area, SCE supports CAISO’s proposed approval of the Southern Area Reinforcement set of projects (as noted below), and the Mesa – Mira Loma 500 kV Underground Third Cable Project to remove the TPP-identified area constraints.

In SCE’s Eastern Interconnection Area, SCE supports the proposed approval of these projects:

• Devers – Red Bluff 500kV 1 and 2 Upgrade
• Devers to Valley 500kV Line 1 Upgrade
• Serrano – Alberhill – Valley 500kV Line 1 Upgrade
• Colorado River – Red Bluff 500kV Line 1 Upgrade
• San Bernardino – Etiwanda 230kV Line 1 Upgrade
• San Bernardino – Vista 230kV Line 1 upgrade
• Vista – Etiwanda 230kV Line 1 upgrade, and
• Mira Loma – Mesa 500kV underground Third Cable.

These projects will all serve to remove the TPP-identified area constraints. SCE notes that each transmission line project will be designed and constructed to applicable SCE standards, leveraging the maximum capability identified for the respective voltage level of the facility.  Further, SCE would like to point out that the costs and in-service dates associated with these projects are all based upon pre-planning engineering assumptions that are conceptual in nature. Thus, the actual costs and expected in-service dates may change based upon the specific licensing-related approvals that are required for each project.  Additionally, the costs do not include expenditures necessary to obtain rights of way, any necessary land acquisition expenditures, additional licensing, permitting and/or environmental costs which may be required.

Southern Area Reinforcement – Competitive Projects

SCE notes that in general and to the extent possible, it would be in the best interests of California’s ratepayers to be flexible in the scope and design of these large competitive projects.  Large savings can be achieved by utilizing and optimizing existing rights-of-ways, and project alternatives, where feasible, and should be considered when CAISO’s Board of Governors approves the 2022-2023 Transmission Plan.  SCE notes that based upon its 500kV AC underground line experience, underground AC use can present technical challenges compared to the use of DC technology at voltages greater than 230kV, which also has benefits related to short circuit duty and voltage control issues.

For all the competitive projects outlined as part of the Southern Area Reinforcement, SCE notes that any bid specifications related to new facilities should have as much technical detail as possible to reduce uncertainty. For example, a 500kV transmission line’s specification should ensure that adequate system protection, telecommunications requirements, capacity, and diversity are identified to meet applicable line protection, RAS, and future generation interconnections needs. Being ambiguous on these points could lead to differing approaches, which could trigger additional scope if not fully understood and covered in the bid specification. Specificity around series capacitor requirements, for those lines that will require them are also necessary, not only technical specifications, but also requirements on quantity and general vicinity of capacitor locations.  Additionally, it has been noted that the specification for the competitive projects identifies an ambient temperature of 50°C. When it relates to rating of line facilities, there are also other factors, such as wind speed, solar irradiance, etc., as such CAISO will also need to include those to facilitate consistency of proposed designs. SCE proposes all bids should be comparable to the greatest extent possible, with the inclusion of a requirement within the specification document that all equipment components must abide by all applicable sourcing restrictions (such as those issued by federal agencies relating to potential foreign adversaries).  In addition, the competitive solicitation should state the year in which the cost estimates are to be in and what year the bids are made (such as all bids in 2023 nominal year or operating year constant dollars).  Further, and most importantly, if any of the competitive projects traverse High Fire Risk Areas, or other unique geographies, the bidder must use design and construction standards required to mitigate for wildfire ignition risk in such areas and demonstrate their ability to meet all state of California wildfire obligations.  The above comments are general in nature and are meant to apply to all the Southern Area Reinforcement projects, additionally, more specific comments on each project are included below.

The Imperial Valley – North of SONGS 500kV Line and Substation – SCE would appreciate if the CAISO could elaborate on the rationale as to why the North of SONGS Substation has been bundled with a transmission line project, when it could be a stand-alone project. The Substation could be competitively bid as the first tranche by CAISO, and after its location is determined, the transmission line projects connecting to the Substation could be issued as a second tranche and provide a more accurate bid. Due to the geography in the region, any uncertainty of the location can significantly impact the portions of the bids for transmission lines that will connect to the North of SONGS Substation.  Further, with the requirement for the North of SONGS Substation to loop in three of four SCE 230 kV lines that go north from the San Onofre Nuclear Generating Station (SONGS) switchyard, SCE recommends sufficient space and capability be included in the specification for future expansion, such as looping in the fourth line, or adding a fourth 500/230 kV transformer. Other factors to be considered for the substation should include adequate line getaways for all voltages and requirements to meet the projected future short circuit levels.

The North of SONGS – Serrano 500kV AC Line - SCE commends the CAISO for its work in determining that a line between these two stations is the preferred approach to mitigate any problems in this area. 

The Serrano – Del Amo – Mesa 500kV Transmission Reinforcement – SCE appreciates and supports CAISO’s proposed approval for this project and believes it will bring significant reliability and deliverability benefits to the LA Basin, all while helping meet the state’s policy goals. SCE looks forward to advancing the project to a more detailed design phase. 

The Trout Canyon – Lugo 500kV Line project – SCE appreciates the efforts on the part of CAISO to propose approval of this project. 

Finally, SCE notes that while the analysis of proposed and alternative projects was extensive, it did not include explicit considerations of WECC Path Rating impact or short circuit duty impact on existing facilities. SCE requests the CAISO clarify and augment how the aforementioned studies/processes would be applicable to the various projects. As many of the proposed projects directly impact SCE facilities or are in close proximity to them, there is a high likelihood that they could trigger additional short-circuit mitigation needs or affected system impacts.  SCE plans to examine this in future transmission reliability studies and appreciates the CAISO’s proactive approach to recommend approval with enough time to work through the necessary processes.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

SCE notes that the Lugo-Victor-Kramer 230kV projects help to alleviate congestion in the North of Lugo area of SCE’s service territory and assist in resource deliverability.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

SCE has no comment currently.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

SCE commends CAISO for conducting various Other Studies to provide additional information on such topics as local capacity requirements and deliverability, Long Term Congestion Revenue Rights, and frequency changes as the grid moves from a synchronous to an inverter-based influx of proposed generation units.  SCE is supportive of these and any additional studies that CAISO conducts as part of its future TPPs.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

SCE appreciates that CAISO has performed Special Reliability Studies and provided those results to the utilities on an information only basis for them to better understand looking at the impact of the Aliso Canyon Gas Storage retirement and the high electrification demand scenarios, so that these can be utilized in the utility’s transmission planning and how the resource needs will be impacted by these scenarios. However, additional work is required to better understand the impacts of the retirement on the electric supply given the various comments provided during this cycle, such as the applicability of certain assumptions and additional detail to understand impacts on the existing natural gas generation facilities. SCE encourages CAISO to continue performing Special Reliability Studies as the more information and data that arises from such studies, the better the utilities’ projects can meet the future needs of the system in accordance with the conclusions of such studies to maintain system reliability in such scenarios.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

SCE supports that the CAISO is looking at the future of the electric system and utilizing a longer time frame in its future planning cycles.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

As an overall comment Southwestern Power Group (SWPG) appreciates the dramatically increased number and size of transmission projects included in this cycle’s Draft Plan compared to previous cycles, which we believe is justified based on California’s carbon reduction goals, increased electrification, and resulting unprecedented expected increase in renewable generation that will need to be delivered to load.

SWPG’s comments are focused on the treatment of out-of-state (OOS) wind and the upgrades needed to accommodate increasing amounts of imported energy including the high-quality New Mexico wind in the Draft Transmission Plan.

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

Section 3.6 Out-of-State Wind addresses both the base and sensitivity portfolio amounts of OOS wind, but notes that the base portfolio for the 2023-24 transmission plan reflects the same volumes and sources of OOS wind as the current plan’s sensitivity case. SWPG supports the study of and preparation for the volumes of OOS wind in the sensitivity portfolio totaling 4,832 MW, 2,328 MW of which from NM, since they are more in line with commercial development activity than the current plan’s base case showing 1,500 MW, 438 MW of which from NM. SWPG also appreciates the fact that these resources have been included in the policy analysis and alternative analysis as expanding the maximum import capability (MIC) of the paths to import OOS wind to determine the CAISO internal transmission needs required. For many years now SWPG has advocated for study of the increased MIC and internal transmission needs to accommodate future expected amounts of OOS wind at the levels currently being studied, so we are happy to see the volumes being studied in the current draft plan.

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

Section 6.1.2.2 addresses the MIC expansion requests that have been studied through both TPP and GIP deliverability studies. SWPG’s expansion request at Palo Verde was found not to trigger an expansion probably due to the amount of remaining import capability forecasted at Palo Verde. SWPG appreciates the fact that the CAISO has now implemented the MIC expansion request process and can provide such feedback to requestors through the TPP.

SWPG would also suggest a process to reserve import capability more than one year in advance of the year in which an LSE might need the MIC. We understand that such a process change is outside the scope of the TPP but we simply point out that under the current paradigm, an expansion request could help ensure that adequate import capability exists at a given intertie but for long-lead transmission projects would not allow the LSE customers to reserve such MIC until one year prior to the in-service date of the project which presents a commercial risk in that LSEs often need to enter into RA contracts for imported resources multiple years in advance of the resource’s in-service date.

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

1. Please provide your organization’s overall comments on the Draft 2022-2023 Transmission Plan April 11, 2023 stakeholder call discussion.

On behalf of the Nature Conservancy (TNC) of California and Defenders of Wildlife, thank you for the opportunity to comment on the Draft 2022-2023 Transmission Plan and stakeholder call. We commend the enhanced coordination demonstrated among California’s energy agencies, as envisioned in the December 2022 Memorandum of Understanding. Across interagency processes, we support and advocate for integration of the State’s land use planning efforts into transmission and resource planning. Application of these tools and resources to energy-related decision-making is valuable and necessary to respond to the challenge of rapidly escalating projected resource requirements and to meeting SB 100 goals affordably, on time, and while protecting California’s important biodiversity and habitat.

The comments below reflect the following key points and recommendations; we:

• Applaud the use of environmental criteria in the underlying modeling assumptions and busbar mapping dashboards, including a focus on avoiding high conservation value lands. We recommend clarifying how environmental criteria are being applied across projects, such as the summary provided on the Greater Kramer area in the modeling assumptions section 6.2E. Environmental criteria should continue to be updated as the CEC’s Draft Land Use Screens are finalized, especially in light of potential new updates, such as climate resilience layers. We look forward to the release of the new Land Use Screens as a critical input for this process. 

• Further, urge the energy agencies to consider transmission permitting feasibility as criteria for protecting California’s ratepayers and unique biodiversity and, thus, enabling faster deployment of least regrets transmission. In lieu of specific permitting feasibility metrics, environmental criteria can serve as an important indicator of permitting feasibility for projects under consideration.

• Highlight the need to consider which lands are more likely to transition use due to the Sustainable Groundwater Management Act (SGMA), in addition to the important information already being considered (such as conservation value, commercial interest, and solar resource potential). 

• Demonstrate that while zonal and regional-level transmission planning may be sufficient for system-level modeling, geospatial data can help to identify instances where there is not enough transmission capacity for solar resource potential and high-confidence commercial interest on low impact lands. We recommend several projects for further study. 

2. Provide your organization’s comments on chapter 1 Overview of the Transmission Planning Process.

We applaud the proactive, targeted, and zonal planning-based approach outlined in Chapter 1 that the CAISO is adopting to face rapidly scaling resource requirements and growing reliability and affordability challenges. Continually integrating the latest land use information from busbar mapping will directly support this vision by steering planning to least regret options and, specifically, helping to avoid unnecessary conflicts, delays, and costs to ratepayers. 

A note on permitting feasibility - Environmental factors, in addition to indicating important habit and lands throughout the state, are a strong proxy for permitting feasibility, which has significant implications for costs to ratepayers. For example, during the workshop, Mike Florio noted that a critical stretch of a $2.288 billion project the ISO is recommending - the Imperial Valley–North of SONGS 500 kV Line and Substation project as a part of the south area reinforcement - is likely to face permitting challenges due to its complex location. If the CAISO Board approves this investment and it gets stuck in permitting, it will represent a notable risk of cost increase to ratepayers.

A note on climate resilience - Given the associated costs and significance of reliability for new transmission and transmission upgrades, it is advisable that system risk is considered in the confirmation of new projects. Climate resilience layers are being considered as part of the CEC’s Draft Land Use Screens, and should be brought forward into the 2022-2023 Transmission Plan as an evaluative criteria on the suitability of planned investments. 

Recommendation summary: We urge the energy agencies to continue to integrate information from the CEC Draft Land Use Screens and related busbar mapping into the 2022-2023 TPP and to share how related information is shaping updates to the TPP. We also request that how environmental criteria are weighted or considered in the underlying methodology be clarified. We note that some environmental fields of the busbar mapping workbook contain values ‘NA.’

3. Provide your organization’s comments on chapter 2 Reliability Assessment.

We do not submit comments on Chapter 2. 

4. Provide your organization’s comments on chapter 3 Policy-Driven Need Assessment.

We applaud the zone-based approach the CAISO has adopted as an important framework for proactive, transparent planning with stakeholders.

SGMA and land use transition: We urge the energy agencies - from busbar mapping through the project selection represented in TPP - to consider land use transition as an important factor that will directly shape transmission capacity expansion. Several studies, statewide processes, and regional initiatives have highlighted that 500,000-900,000 acres of land in the San Joaquin Valley could move out of production due to the Sustainable Groundwater Management Act. TNC recently conducted an internal analysis with E3 and Montara Mountain Energy reviewing alignment of current and planned transmission capacity, solar resource potential, and high-likelihood commercial interest on low biodiversity value land in the San Joaquin Valley. We found there is strong alignment between current and planned transmission projects and low impact land that is likely to retire. Specifically, existing and planned transmission in the San Joaquin Valley has a 90% overlap with high-confidence commercial interest in the region, and low impact land that is more likely to retire has a nearly 80% overlap with 2035 mapped resources. This highlights that planned transmission in the San Joaquin Valley is highly reliant on how quickly a regional land use transition takes place, driven by land retirement that will make former agricultural land available for renewable energy projects. The energy agencies and other stakeholders should closely watch the region’s development and look for opportunities to facilitate fallowed agricultural land hosting renewable energy resources. (Study context: the study considers transmission projects for which the CAISO and CPUC TPP analyses have transmission information, interconnection requests that have phase I and II studies conducted, low impact land identified based on TNC’s Power of Place West study, and land that may be more likely to retire as mapped by Bryant et al.) 

Geospatially identified transmission needs: TNC’s analysis suggests that some substations located in low impact areas in the San Joaquin Valley would be valuable to study for further upgrades, as solar resources and high-confidence commercial interest exceed planned transmission. These include Borden, Henrietta, Mustang, Storey, Vestal, and Warneville, which align to recent findings by CEERT and Gridlab. Helm, Le Grand, and Tranquility may also represent substations in or near areas of low impact land more likely to retire due to SGMA. 

5. Provide your organization’s comments on chapter 4 Economic Planning Study.

We do not submit comments on Chapter 4. 

6. Provide your organization’s comments on chapter 5 Interregional Transmission Coordination.

We do not submit comments on Chapter 5. 

7. Provide your organization’s comments on chapter 6 Other Studies and Results.

We do not submit comments on Chapter 6. 

8. Provide your organization’s comments on chapter 7 Special Reliability Studies and Results.

We do not submit comments on Chapter 7.

9. Provide your organization’s comments on chapter 8 Transmission Project List.

We do not submit comments on Chapter 8.