Comments on July 6, 2022 stakeholder call discussion

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

ACP-California supports the use of the higher electrification levels for the 2022-23 TPP. We appreciate the CAISO and agencies working collaboratively to update the assumptions for the 2022-23 TPP to better reflect high levels of electrification. We hope that these higher levels of electrification will be used and considered across all various proceedings and initiatives, such that future resource portfolios (such as those within the IRP) can be developed to accommodate higher levels of electrification and the portfolios and load assumptions can be integrated into the TPP earlier in the planning cycle.

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

ACP California has no comments at this time other than to express appreciation for the CEC’s work in developing these forecasts for use in the 2022-23 TPP.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

ACP-California appreciates the CPUC’s interest in exploring a policy-driven sensitivity portfolio designed around the lower GHG emission limit (30 MMT) and the use of high electrification demand assumptions in the 2022-2023 TPP. This sensitivity will help the agencies, CAISO, and other stakeholders understand what transmission build out is required in order to implement the necessary transition to a higher electrification future. We also express our appreciation, in advance, to CAISO for completing this additional work in the 2022-23 TPP. The work for this sensitivity will be a significant undertaking, especially given the level of study work CAISO has indicated it plans to perform for this sensitivity case and we are grateful to CAISO’s team for conducting this important work.

While we appreciate the sensitivity case, ACP-California urges the involved agencies to provide as much assistance as possible in making the high electrification future studied in the TPP actionable by CAISO in the near-term. We applaud the California Public Utilities Commission (CPUC) for helping provide information so that CAISO can study the high electrification and lower GHG emissions future, but urge faster action in the IRP and TPP processes to move the identified projects forward toward approval. In addition, ACP-California encourages the CPUC to act in concert with recommending these aggressive levels of electrification in the 2022-2023 TPP by planning for this increase across other relevant proceedings.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

ACP-California supports the updates to the 2022-2023 study plan assumptions and looks forward to continued engagement with the CAISO on ways to leverage the TPP towards more actionable processes and, ultimately, toward approval of transmission projects that will be needed to meet the state’s clean energy policy objectives. In order to have adequate resources online to meet these goals (and the likely higher levels of electrification), it is important that the CAISO be empowered to set as many concrete policy directives as possible in the final plan.

ACP-California notes that it will be critical to move information from the IRP and LSE IRP plans/filings into the TPP as early as possible going forward. This November, individual LSEs will make IRP filings which will contain a portfolio that meets each LSE’s proportional share of a target of 38 MMT of GHG emissions in 2030 and a target of 35 MMT by 2035. While these portfolios cannot be integrated into the 2022-23 TPP (as we recognize most of the study work for the 2022-23 TPP will be complete or mostly complete in November), it will be critical for:

1. The CAISO to consider these individual LSE portfolios in determining whether to accelerate approval of any of the transmission projects that are identified in the sensitivity cases conducted during the 2022-23 TPP; and
2. The CPUC to ensure that these individual LSE portfolios of resources are accounted for in the base case portfolios of resources that it transmits to the CAISO for study in the 2023-24 TPP, as it is crucial that their full consideration not be postponed an additional year.

ACP-California also supports CAISO’s plans to study out-of-state (OOS) wind and geothermal resources in both the base and sensitivity portfolios in a way that accounts for transmission planning deliverability (TPD) that has already been allocated through the CAISO queue, as stated on slide 12 of CAISO’s July 6 presentation. Furthermore, and as directed in the July 1 CPUC/CEC transmittal letter, CAISO should study, identify, and explain opportunities to provide Maximum Import Capability (MIC) expansion and incremental transmission capacity necessitated by these long lead-time imported resources.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

Again, ACP-California would like to emphasize the need for this sensitivity study to help drive actionable, concrete opportunities and potential project approvals, if warranted, especially in light of the individual LSE IRP filings references above.  

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

ACP California has no comments at this time other than to express our support and appreciation for this special study and continue to request a focus on offshore wind replacement resources and associated transmission build out as part of this study effort.   

7. Please provide any additional comments that your organization has:

ACP-California is the voice of the clean power industry in California, focusing on California’s market and policies for a reliable and affordable transition to 100% clean energy. We appreciate the opportunity to comment on the electrification goals and assumptions for the 2022-23 TPP and look forward to continuing to engage with the CAISO and other stakeholders on the 2022-23 TPP and associated activities.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on the following joint agency presentations, that is, California Public Utilities Commission (CPUC), California Energy Commission (CEC), and the California Independent System Operator (CAISO) made on a stakeholder call on July 6, 2022.

• CAISO: 2022-2023 Transmission Planning Process Studies Update;
• CPUC: Higher Levels of Electrification for use in the 2022 2023 TPP and High Electrification Sensitivity Portfolio; and
• CEC: High Electrification Scenario and the Additional Transportation Electrification Demand Forecast.

BAMx is impressed with the cooperation the three Agencies exhibited on a timely basis. However, as explained below, BAMx has some questions that need to be answered. Although we are entirely supportive of the direction proposed, we are concerned about making any decisions on new infrastructure without a complete assessment of the implications of the new studies proposed.

Need to Provide Clarification on Reconciliation Between Higher Load Forecast and Baseline Resource Portfolio

BAMx appreciates the CPUC Energy Division (ED) staff's efforts to develop higher levels of the electrification resource portfolio in response to the stakeholder requests in the CPUC Integrated Resource Planning proceeding.[2] BAMx understands that CPUC has requested the CAISO to use a higher level of electrification load forecast for not only the Sensitivity portfolio in the 2022-23 TPP but also for the Baseline (also referred to as "Base") case portfolio that will be used for reliability policy and economic assessments. BAMx understands that the baseline portfolio included in the CAISO Final Study Plan[3] was based on using the 2021 IEPR California Energy Demand forecast adopted by the CEC on January 26, 2022. BAMx questions how the same resource portfolio will now be used along with the higher level of electrification load. Presumably, the Baseline resource portfolio needs to be updated to match the resources with the higher level of electrification load. However, the CAISO's Update to the Final Study Plan did not reference the update to Baseline Portfolio.[4] BAMx requests the CPUC and CAISO to reconcile the higher electrification load forecast and the Baseline resource portfolio.

Need For Better Understanding of How Sensitivity Portfolio Compares to Baseline Portfolio

Figure 1 below compares the Li Battery storage assumed in the Base and Sensitivity portfolios in 2032 and 2035, respectively. Intuitively, the Li Battery storage amounts selected in the Sensitivity portfolio are higher than those in the Base portfolio in all RESOLVE resource areas for the following two reasons. First, the Sensitivity portfolio assumes the 30 million metric tons (MMT) scenario, which is more aggressive in meeting the Greenhouse Gas (GHG) reduction target than the 38 MMT assumed in the Base portfolio. Second, the Sensitivity portfolio is for the later year, i.e., 2035, than the year 2032 for the Base portfolio. However, it appears that the Sensitivity portfolio selects disproportionately higher battery storage resources in Northern and Southern California PG&E areas than in the remaining areas. Figure 1 shows that the Sensitivity portfolio (blue bar) has more than three and half times the capacity in the Base portfolio (orange bar) for these two areas. BAMx believes that the transmission capability estimates provided by the CAISO in the RESOLVE model have played a key role in RESOLVE selecting more resources in these two areas over others. Please confirm if that is the case.

BAMx is aware that these resources will be mapped using the CPUC-developed Resource-to-Busbar mapping methodology.[5] However, the CAISO could determine that some amount of reshuffling or remapping of these battery storage resources is necessary as those resources could be more effective in certain locations than others and serve as a mitigation alternative to building new transmission. In such cases, the CAISO should be able to reshuffle or remap the battery storage in consultation with the CPUC. 

Figure 1: A Comparison of Base and Sensitivity Portfolio, by RESOLVE Resource Area: Li Battery Storage

When we compared the renewable resources assumed in the Base and Sensitivity portfolios in years 2032 and 2035, respectively, as shown in Figure 2 below, we found that there are several resource areas where no additional resources were selected in the Sensitivity Portfolio. Most of these areas are either wind or geothermal areas, which seem to have constraints in building additional resources. However, we are unclear about why no additional distributed solar was selected in the Sensitivity Portfolio incremental to the Base Portfolio.

Figure 2: A Comparison of Base and Sensitivity Portfolio, by RESOLVE Resource Area: Renewable Resources

The Mapping_bySub tab of the Resource to Busbar Mapping spreadsheet[6] comprising the resource build identified for the proposed Sensitivity portfolio indicates that CPUC is asking CAISO to study the Morro Bay call area wind interconnecting to the Diablo Canyon substation directly unless a proposed new Morro Bay substation is needed. If the CAISO follows up on this assumption for the Sensitivity portfolio, it should do the same for the Base portfolio. Please confirm that the CAISO will be remapping the 1,588MW of offshore wind from the Morro Bay substation to the Diablo Canyon substation in the Base portfolio.

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

[2] CPUC, “Higher Levels of Electrification for Use in the 2022-23 TPP,” CAISO Stakeholder Meeting, July 6, 2022, pp.5-6.

[3] https://docs.cpuc.ca.gov/SearchRes.aspx?docformat=ALL&docid=451412947

[4] CAISO, Agenda and Overview,” 2022 2023 Transmission Planning Process Update, 2022-2023 Transmission Planning Process Stakeholder Meeting, July 6, 2022, p.8.

[5] Methodology for Resource-to-Busbar Mapping & Assumptions for The Annual TPP, CPUC Energy Division

December 2021.

[6] BusbarMapping_30_MMT_HESensitivity_Dashboard_07_01_22.xlsx

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

BAMx appreciates the CEC staff's tremendous efforts in developing the Interagency High Electrification (IAHE) and Additional Transportation Electrification (ATE) load forecasts.[1] BAMx found the detailed hourly load forecast data posted by the CEC to be beneficial as it provided the incremental impact of Light and Medium-Heavy electric vehicles (EV) on the projected loads by IOU-areas and CAISO-wide footprint with hourly granularity.[2] BAMx notes that no such comparable load forecast is available for the SB100 Core statewide high electrification load projections, which the CAISO used in its 20-Year Transmission Outlook (May 2022). To meaningfully assess the potential transmission that will be identified in the CAISO 2022-2023 TPP with those identified in the CAISO 20-Year Transmission Outlook, it is pertinent that the stakeholders have the opportunity to compare the ATE load forecast with the SB100 Core statewide high electrification load forecast. BAMx requests the CEC to, at minimum, carve out the CAISO-wide load forecast from the Statewide SB100 Core high electrification load forecast. Furthermore, the ATE hourly load forecast is available only for the 1-in-2 load conditions. We request the CEC to provide the ATE load forecast for 1-in-5 and 1-in-10 Net Electricity Peak Demand by Agency and Balancing Authority, as the CAISO will use it to perform the reliability and policy-driven studies in the 2022-2023 TPP. 

[1] “CEC Development of Higher Electrification Grid Planning Scenarios,” Michael R. Jaske, PhD

July 6, 2022, pp. 6-8.

[2] California Energy Commission : Docket Log: https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=21-IEPR-03

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

Transmission Identification Beyond the Standard Transmission Planning Horizon Should Be Treated Only for Informational Purposes

The CAISO's Final 2022-2023 Transmission Study Plans states, "A sensitivity portfolio based on a 30 MMT GHG target with the IEPR high electrification demand scenario will also be developed by the CPUC, CEC, and CAISO and studied in this transmission plan. CPUC staff currently anticipate transmitting the sensitivity portfolio by June 1, 2022. The ISO currently intends to structure the study of the sensitivity portfolio as a special study as described in section 6.6 in order to document the reliability, deliverability, and production cost analysis results in one place. Despite the proposed treatment of the sensitivity portfolio assessment as a special study for the reasons mentioned above, the results of the sensitivity study will be used the same way as any policy-driven sensitivity study in accordance with the ISO Tariff." BAMx requests the CAISO to describe how it plans to utilize the need for transmission upgrades identified in the Sensitivity portfolio for the year 2035, which will be beyond the 10-year planning horizon typically assessed in the annual transmission planning process. Based upon the number of elements needed to be resolved in the rushed effort to account for potential load impacts never studied before, BAMx recommends that any potential transmission upgrades identified in the Sensitivity portfolio incremental to the Base portfolio should be treated as informational only. 

Need to Assess Another Sensitivity Portfolio

In addition to the CPUC-proposed Sensitivity scenario expected to identify the potential transmission investments needed for a high electrification future, BAMx believes that decision-makers should be equally interested in knowing how the need for transmission investment would change if the proposed closure of the Diablo Canyon Power Plant (DCPP) is delayed. DCPP provides roughly 15% of California's carbon-free electricity, and its continued operation would likely allow for very different development and timing of the resource mix than what is anticipated in the currently proposed Base and Sensitivity portfolios.

Efforts are currently underway that look into a plausible extension of DCPP's life.[1] Recently, AB 205 was passed by the California Legislature, and promptly signed by the Governor, providing funding to potentially extend operations of DCPP and any other generation by establishing an “Electricity Supply Strategic Reliability Reserve Program.”[2] One recent study indicates that Diablo Canyon's unique 24x365 clean energy characteristics would help California decarbonize more quickly (with lower cumulative emissions), more reliably, and at a lower total cost.[3] Although some studies and newspaper articles cannot be the only basis for analyzing a plausible future as part of the TPP, delaying DCPP’s retirement appears to be a real possibility with the Governor's support.

Furthermore, we understand there is tremendous uncertainty contained within the assumptions with respect to some of the offshore, out-of-State, geothermal, and long-duration storage (LDS) resources identified in the high electrification load sensitivity scenario.[4] BAMx strongly urges the CPUC and CAISO to develop and analyze a portfolio that assumes the Diablo Canyon closure is delayed through 2035. BAMx also notes that this analysis needs to be completed before approving major infrastructure additions based upon these very informative but new and uncertain changes in load forecasting methodology.

[1] https://www.utilitydive.com/news/analysts-differ-on-feasibility-need-to-extend-diablo-canyon-california-nuclear-plant/623214/

[2] Under this fund, the State of California can procure and generate electricity to help ensure adequate resources are on the grid, and AB 205 also authorizes the Department of Water Resources (DWR) to buy and generate electricity on behalf of California, and specifically notes this can come by “extension of the operating life of existing generating facilities planned for retirement.”

[3] Brattle Group, “Retaining Diablo Canyon:

Economic, Carbon, and Reliability Implications,”, June 9, 2022. https://carbonfreeca.org/wp-content/uploads/2022/06/2022-06-09_Brattle-Report-on-Impacts-of-Diablo-Extension.pdf

[4] See “Methodology for Resource-to-Busbar Mapping & Assumptions for The Annual TPP,” CPUC Energy Division, December 2021, p.21.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

See BAMx's response to Q.1.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

  See BAMx's response to Q.1.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

Provide Missing Data and Information

Page 23 of the CAISO’s July 6^th presentation indicates that “A summary of the gas-fired generating facilities that are subject to curtailment in the absence of Aliso Canyon gas storage is included in the Backup section of this presentation.” However, there was no backup section to the CAISO’s presentation. Please provide the summary of the gas-fired generating facilities subject to curtailment in the absence of Aliso Canyon gas storage.

Need for Caution in Utilizing the Transmission Needs Identified in 20-Year Transmission Outlook and Need for More Stakeholder Engagement

CAISO indicated that are some potential transmission upgrade options that were identified in the 20-Year Transmission Outlook that may be selected depending on the reliability concerns identified in the study.[1] However, as indicated above, BAMx thinks the AB 205 provisions need to be taken into account before approving transmission additions. The elements of AB 205 that call for potentially delaying the retirement of gas generation is especially relevant to Aliso Canyon/Southern California issues. In trying to understand the relationship, we investigated the gas fired units expected to shut down under the 20-Year Transmission Outlook and the FTI Study commissioned by the CPUC as summarized in Table 1 below.

Table 1: Assumed Gas-Fired Generation Retirements: 2-Year Transmission Outlook vs. FTI Study

The 20-Year outlook assumed retirements based on multiple criteria, i.e., age, disadvantaged communities (DAC) and DAC-adjacent criteria, and reliance on Aliso Canyon.[2] It is important to recognize that only a subset, i.e., 2,000 MW of gas-fired generation in the CAISO system relying on Aliso Canyon, was assumed to be retired in the 20-Year Transmission Outlook. Given the differences, we believe the need for potential transmission under the proposed Reduced Reliance on Aliso Canyon Gas Storage Special Study in the 2022-2023 TPP would differ from those identified in the 20-Year Transmission Outlook. Therefore, BAMx requests CAISO to provide a detailed breakdown of the generation facilities that would be assumed to be retired in the Special study in the Current TPP and those that were assumed to be retired in the 20-Year Transmission Outlook as soon as possible. It would be too late to have this data for stakeholder review in the November 2022 stakeholder meeting.

Need to Identify Lower-Cost Reliability Solutions

As the decision-makers and policy-makers scrutinize the need for transmission upgrades to address the reliability impact of the absence of Aliso Canyon, they must have a complete picture of how existing generation capacity can continue to serve those reliability needs cost-effectively while satisfying the State’s goals of reducing or eliminating the use of fossil fuels. One such example is the “green” or “clean” or “decarbonized” hydrogen that could play a key role in State’s clean future. The information presented at the CEC IEPR Workshop on June 28, 2022, provides considerable insights into the hydrogen economy's uses, economics, and feasibility. BAMx realizes these investigations perhaps will produce results that are too late to identify the Southern California gas-fired resources that could remain in operation. However, this is another indication that more study work is needed before decisions are made in the current TPP to build new transmission.

[1] CAISO July 6^th Presentation, p. 26.

[2] 20-Year Transmission Outlook, May 2022, p.20.

7. Please provide any additional comments that your organization has:

No comments at this time.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

On July 1, 2022, the California Public Utilities Commission (CPUC) and the California Energy Commission (CEC) submitted a joint Transmittal Letter to the California Independent System Operator Corporation (CAISO) for the 2022-2023 Transmission Planning Process (TPP) High Electrification (HE) Portfolio, in which the CPUC and CEC requested the CAISO update its 2022-2023 TPP Study Plan to:  

1. Use the 2021 Integrated Energy Policy Report (IEPR) Additional Transportation Electrification scenario as its load assumptions for 2022-23 TPP base and sensitivity case studies;
2. Study the 30 million metric ton (MMT) HE policy-driven sensitivity portfolio transmitted  as in the 2022-23 TPP HE Sensitivity Scenario; and
3. Continue studying the deliverability needs and corresponding transmission needs related to out-of-CAISO long-lead time resources, such as out-of-state wind and geothermal resources, beyond the CAISO’s balancing area authority.[1]

As described in the sections below, California Community Choice Association (CalCCA) supports each of these recommendations. As the state continues down the path of higher levels of electrification and renewable integration, it is critical the CAISO TPP inform the state of the new transmission infrastructure needed to achieve reliability and policy objectives.

[1]             http://www.caiso.com/InitiativeDocuments/2022-2023TransmissionPlanningProcess-PortfolioTransmittalLetter.pdf.

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

CalCCA supports use of the 2021 IEPR Additional Transportation Electrification scenario as the load forecast assumptions for the 2022-2023 TPP base and sensitivity case studies. Assuming HE and EV scenarios will better align the load forecast with the state’s carbon-neutrality goals and goals that all in-state sales of new passenger cars and trucks will be zero-emission by 2035.[1]

[1]             Cal. Executive Order N-79-20.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

CalCCA supports use of the CPUC’s HE policy-driven sensitivity portfolio in the CAISO’s 2022-2023 TPP policy studies. In comments to the Preferred System Plan (PSP) in the CPUC’s Integrated Resource Planning (IRP) proceeding (R.20-05-003), CalCCA recommended the CPUC commit to using the 30 MMT scenario in the next IRP process to continue the progression of lowering the GHG target in future years.[1] Including the CPUC’s HE policy-driven sensitivity portfolio as a sensitivity study in the TPP will support this progression and allow for the necessary time to plan for a lower GHG target with HE.

This portfolio includes 600 additional megawatts (MW) of geothermal resources with the purpose of studying within the TPP, the transmission needs of interconnecting geothermal resources. CalCCA supports including additional geothermal in the sensitivity portfolio for study in the TPP, and has commented previously on geothermal resource potential in Northern Nevada that will be required to fulfill the CPUC’s requirements for clean firm resources in the mid-term reliability procurement orders.[2] Studying additional geothermal resources in the TPP as soon as possible is crucial because these resources will require the CAISO to evaluate the potential need for expanding maximum import capability (MIC) and will likely require transmission upgrades.

[1]           California Community Choice Association’s Comments on Administrative Law Judge’s Ruling Seeking Comments on Proposed Preferred System Plan, CPUC Rulemaking (R.) 21-05-003 (September 27, 2021) at 14.

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

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

CalCCA supports the CAISO’s updates to the 2022-2023 final study plan assumptions, which incorporate the CEC’s 2021 IEPR Additional Transportation Electrification scenario as the demand forecast and the CPUC’s HE policy-driven sensitivity portfolio.

CalCCA also supports the CPUC and CEC’s recommendation that the CAISO continue studying the deliverability needs and corresponding transmission needs related to long-lead time out-of-state resources, such as wind and geothermal. The ability to obtain MIC is a key contributor to load-serving entities’ (LSEs’) willingness to contract with an out-of-state resource because MIC is required for use of the resource as RA capacity. Therefore, CalCCA supports additional study of deliverability needs and corresponding transmission needs that will affect the ability of long-lead time resources to be used as RA. Because LSEs must secure MIC at the right nodes to be able to use out-of-state resources like Nevada geothermal to provide RA capacity, they must be able to understand how projects in the transmission plan will affect import capability at specific nodes. The CAISO should provide data on deliverability or other technical limitations that would impact deliverability and available MIC at specific branches to minimize the risk of uncertainty around available MIC.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

See response to #4.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

CalCCA has no comments at this time.  

7. Please provide any additional comments that your organization has:

CalCCA has no comments at this time.  

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) is an independent consumer advocate with a mandate to obtain the lowest possible rates for utility services, consistent with reliable and safe service levels, and the state’s environmental goals.[1]

Cal Advocates has no comments on the use of the California Public Utilities Commission’s (CPUC) high electrification policy-driven sensitivity portfolio for study in the 2022-2023 Transmission Planning Process (TPP) at this time.  Cal Advocates requests additional studies and clarifications from the California Independent System Operation (CAISO) on the 2022-2023 TPP, which we provide below in response to questions four through seven.

[1] Pub. Util. Code Section 309.5. 

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

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

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

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

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

Recommendations for Additional Sensitivity Studies

Diablo Canyon Retirement Extension Sensitivity

As confirmed at the July 6, 2022 CAISO Transmission Planning Update meeting, the CPUC’s base and high electrification sensitivity portfolios for study in the CAISO 2022-2023 TPP assume that the Diablo Canyon nuclear plant (Diablo Canyon plant) will retire within the 2024-2025 timeframe.[1]  The Governor of California and Pacific Gas and Electric Company (PG&E), the owner and operator of the Diablo Canyon plant, most recently announced they want to consider pursuing another path for the Diablo Canyon plant.[2]^,[3]  Delaying the retirement of the Diablo Canyon plant beyond the 2024-2025 timeframe may impact the integration plan for proposed new renewable resources such as the Morro Bay offshore wind project, and may impact the timing and need for other planned transmission upgrades.  As such, Cal Advocates requests that CAISO perform a sensitivity study that evaluates and determines the impact of delaying the planned Diablo Canyon Plant retirement timeframe to 2032.

Corrective Action Sensitivity

Regarding Cal Advocates’ request for an additional corrective action sensitivity scenario in our comments on the 2022-2023 TPP Draft Study Plan,[4]  Cal Advocates continues to see benefit in studying additional sensitivities in the TPP to ensure that transmission build-out does not outpace actual need and unnecessarily burden ratepayers, at a time when they are faced with skyrocketing electric rates.[5]

To illustrate the need for an additional sensitivity study that considers further corrective actions, during the May 18, 2022 Assembly Utilities and Energy Committee informational hearing, Mark Rothleder, CAISO Senior Vice President and Chief Operating Officer, stated that one of the solutions to building the right amount of transmission in an affordable manner is reducing  demand at certain (peak) times, which would reduce the demand for new energy and transmission. [6]   Mr. Rothleder further stated that shaping electric vehicle (EV) consumption when the system is not peaking and moving the state’s water supply when the system is not peaking helps in terms of managing the system.[7]  It may also be the case that the pace of high vehicle electrification progresses slower than predicted due to the continued growth of the gas and diesel used car market.[8]  Cal Advocates agrees with Mr. Rothleder’s comments and requests a sensitivity study that assumes further shaping of expected demand from the state’s water system and EV charging to identify the impacts on transmission needs and to potentially avoid unneccessary costs.

The CAISO has the authority to create one or more reasonable stress (sensitivity) scenarios to compare to the baseline scenario per its tariff.[9]  Creating additional scenarios would be consistent with the Federal Energy Regulatory Commission’s (FERC) April 21, 2022, RM21-17-000 Notice of Proposed Rulemaking.  This FERC rulemaking includes a proposed reform that would require transmission planners to develop four distinct long-term scenarios as part of long-term regional transmission planning processes to provide enough information to identify the most efficient and cost-effective transmission investments to meet transmission needs driven by a changing resource mix.[10]

[1] California ISO 2022-2023 Transmission Planning Process Update Meeting, Customized Energy Solutions Market IQ, July 8, 2022, p. 10.

[2] Governor Newsom Considers Keeping Diablo Canyon Nuclear Plan Open Past 2025, California Globe, April 30, 2022. https://californiaglobe.com/articles/governor-newsom-considers-keeping-diablo-canyon-nuclear-power-plant-open-past-2025/

[3] PG&E to Submit Application for Federal Funds to Keep Diablo Canyon Nuclear Plant Operating Past 2025, California Globe, July 6, 2022. https://californiaglobe.com/environment/pge-to-submit-application-for-federal-funds-to-keep-the-diablo-canyon-nuclear-plant-operating-past-2025/

[4] Public Advocates Office Comments on Draft 2022 TPP Study Plan, February 28, 2022, p. 6.

[5] Utility Costs and Affordability of the Grid of the Future, An Evaluation of Electric Costs, Rate and Equity Issues Pursuant to P.U. Code Section 913.1, (California Utility Cost - May 2021) CPUC, May 2021, pp. 38 and 41-42. Since 2009, the CAISO Transmission Access Charge (TAC) increased 255 percent. Between 2016 and 2021 alone, California’s transmission revenue requirement increased approximately 38 percent while gross load declined over the same time frame.

[6] Envisioning the Grid of 2045: How Much Transmission Is Needed?, Assembly Utilities and Energy Committee Informational Hearing, May 18, 2022, Media Archive | Assembly Internet (ca.gov) at 1:49-1:52 minutes.

[7] Envisioning the Grid of 2045: How Much Transmission Is Needed?, Assembly Utilities and Energy Committee Informational Hearing, May 18, 2022, Media Archive | Assembly Internet (ca.gov) at 1:49-1:52 minutes.

[8] A Gap in California’s Plan for the EV Future, Energy Institute Blog, James Sallee at UC Berkeley, May 9, 2022, https://energyathaas.wordpress.com/2022/05/09/13378/

[9] Fifth Replacement FERC Electric Tariff, Section 24 Comprehensive Transmission Planning Process, California Independent System Operator, March 21, 2022, p. 22.

[10]  Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, Federal Energy Regulatory Commission, RM21-17-000, April 21, 2022, pp. 108-112.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

The CPUC requested that the CAISO provide a study on Maximum Import Capability (MIC) expansions for long lead time and out-of-state energy resources while preserving existing transmission capacity allocated to projects currently in the generation interconnection queue.[1]

Cal Advocates recommends that the CAISO's MIC study include a matrix of transmission facility upgrades at specific interties and throughout the CAISO system that are triggered by modeling combinations of specific out-of-state resources selected in the CPUC’s proposed resource portfolios.  This matrix should also provide the estimated cost of incremental transmission upgrades that would be needed both at the interties and throughout the CAISO transmission system to deliver imported resources to serve load.  This matrix should be used to evaluate the intertie and transmission system upgrades, and associated costs required to accommodate specific resources from outside CAISO’s balancing area authority.

Cal Advocates also recommends CAISO clarify if changes to the MIC Baseline modeling methodology, as described in Section 6.1.3.5 of the CAISO Business Practice Manual, will be considered as part of this study.[2]  Any changes in the CAISO process for establishing MIC should be conducted in a transparent process with an opportunity for public engagement.

[1] Transmittal Letter to CAISO for 2022-23 TPP High Electrification Portfolio, CPUC, July 1, 2022, p. 3.

[2] Business Practice Manual for Reliability Requirements, California Independent System Operator, Version 66. June 1, 2022, p. 70.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

CAISO’s study plan for the reduced reliance on Aliso Canyon Gas Storage will help identify reliability concerns and evaluate potential transmission upgrade options.

Cal Advocates agrees with the CAISO on the following study scope topics:

• Exploration of local impacts from a transmission perspective and to the extent possible, to increase the MIC to allow additional imports into California as stated in CAISO's comments in the CPUC Aliso Canyon Order Instituting Investigation (I.17-02-002).[1] 

• Assessment of impacts on local reliability in the Los Angeles Basin to better understand the feasibility of increasing the MIC.  In addition, it is important to include an adequate assessment of summer peak needs and impact of battery storage resource charging.[2]

• Identification of potential reliability concerns due to curtailment of gas-fired generation in the LA Basin and San Diego-Imperial Valley Local Capacity Requirements (LCR) areas in the absence of Aliso Canyon gas storage.  In addition, it is important that the CAISO apply the National Electric Reliability Corporation (NERC), Western Electric Coordination Council (WECC), and CAISO reliability standards to the reliability study.

• Evaluation of potential transmission upgrade options to mitigate identified reliability concerns and utilizing the list of potential transmission upgrades identified in the 20-Year Transmission Outlook as a guide.

[1] CPUC Proceeding Order Instituting Investigation OII.17-02-002; Aliso Canyon Investigation, Ruling dated January 19, 2022, Administrative Law Judge’s Ruling Entering into the Record, Phase 3 Report, Requesting Comments, The CAISO’s submitted comments, dated February 16, 2022.

[2] CPUC Proceeding Order Instituting Investigation OII.17-02-002; Aliso Canyon Investigation, Ruling dated January 19, 2022, Administrative Law Judge’s Ruling Entering into the Record, Phase 3 Report, Requesting Comments, The CAISO’s submitted comments, dated February 16, 2022., pp 2-5.

7. Please provide any additional comments that your organization has:

The CAISO TPP should not rely only on the 38 million metric ton (MMT) base and 30 MMT high electrification policy-driven sensitivity portfolios to justify new transmission investments.  CAISO should also study more moderate load increase scenarios and scenarios that include a delayed Diablo Canyon retirement to better account for a range of uncertainties.  It is important that the CAISO approve a transmission buildout that does not outpace need which could result in stranded assets and unreasonable costs for ratepayers. 

If you have any questions regarding these comments, please contact Kanya Dorland at kanya.dorland@cpuc.ca.gov or Dave Peck at david.peck@cpuc.ca.gov.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

Comments of California Western Grid Development, LLC on CAISO July 6, 2022, Update on the 2022-2023 TPP.

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

We are pleased to submit these comments on behalf of California Western Grid regarding the 2022-2023 Transmission Planning Process (“TPP”) update presented on July 6, 2022 (“July 6^th Update”).

We applaud the CAISO for creating a process to plan for and address transmission needs that will be crucial for allowing the State of California to meet SB100 goals, support increased electrification and plan for reduced reliance on fossil fuels in the production of electricity. Respectfully, however, based on the July 6^th Presentation, TRED believes that the CAISO objectives may be “too little, too late.”

The move to a high electrification demand forecast is a welcome improvement. We must plan for the high electrification because it is an important state goal. Similarly, it is a large step forward for CAISO and State agencies to recognize the urgency to plan for the obvious need for new transmission especially given the l0+year lead times after the transmission is planned and approved. Even prior to the move to a high electrification portfolio, the 2021 Joint Agency Report to the legislature found that California’s clean energy portfolio for the CAISO grid needs to triple to meet SB 100 goals. Thus, the State will be procuring tens of thousands of new renewable resources in coming years which would only exacerbate the current congested grid. As a result, the State is facing a transmission crisis which, unless acted upon immediately, will threaten grid reliability, and perpetuate sub-optimal economic resource procurement decisions. Indeed, the CAISO’s recent first-of-its- kind 20-Year Transmission Outlook concludes that over $30 billion of new transmission is needed by 2040, to deliver these new clean resources to coastal load centers that are already transmission constrained and therefore dependent on fossil fuel plants. The failure to act now to plan and approve new transmission will increase the usage of existing fossil fuel plants as demand grows, negatively affecting disadvantaged communities and minorities disproportionately.

While the July 6^th Update would have been welcome news 5-10 years ago, today we already know we need huge amounts of new resources that cannot get to load centers because of the lack of transmission.   To recognize a need for even more resources due to high electrification and call for a study as to whether new transmission is needed and ignore the urgent need to start approving new transmission now is virtually inexplicable. The CAISO already studied the need for new transmission in its 20-Year Transmission Outlook and concluded that over $30 billion of transmission is needed to accomplish SB 100 goals. Continuing to delay approving long lead time transmission will lead to a massive build in the next decade that will overwhelm the supply chain for critical transmission equipment and overwhelm the California Agencies ability to process permit applications. Combined with siting challenges for new transmission it is easy to see how new transmission could take well over 10 years to complete.

It is simply disingenuous to ignore the need to start approving new transmission now if there is any intent to try to meet SB 100 goals with high electrification included in the plan. The global climate crisis and the existing burden to disadvantaged communities must be addressed now. There is no credible claim that we should simply study whether transmission is needed. The combination of Joint Agency Report to the Legislature and the CAISO’s 20-Year Transmission Outlook, along with high electrification demand leaves no credible doubt. CAISO must start approving least regrets new transmission immediately in this 2022-23 TPP cycle. A roadmap of the needed new transmission has already been identified in the CAISO’s 20-Year Transmission Outlook.

Further, the lack of transmission into LA and resulting requirement to rely on local capacity and force continued operation of Aliso Canyon Gas Storage Facility is particularly problematic. Especially when part of the solution is being promoted with the extraordinary State and Federal public policy actions being taken to advance an Offshore Wind (“OSW”) industry in California.

While OSW can be delivered to coastal locations such as Diablo Canyon, it cannot reliably reach LA because of the transmission constraints that define the LA Basin as a Transmission Constrained Local Area and preclude LA from accessing needed clean energy, including OSW, that is located outside the LA Basin. Subsea Transmission, if approved now, can be developed timely to facilitate OSW development, and allow OSW development to benefit from substantial Federal tax benefits before they sunset. The key is to start developing the needed transmission now. Indeed, CAISO approval of new transmission into LA as part of the current 2022-2023 TPP is now more essential than ever.

With the 10+ year lead time for new transmission, and the large amount of transmission needed, the CAISO and other agencies must act now to implement high voltage transmission additions which support compliance with SB 100 and prioritize areas such as Los Angeles, which has terrible air quality that is disproportionately affecting disadvantaged communities.

California Western Grid urges the CAISO to follow the roadmap in the CAISO’s 20-Year Transmission Outlook and approve significant new transmission in its 22-23 TPP focusing first on load centers like the LA Basin that has the worst air quality significantly harming disadvantaged communities. We must start now if we hope to meet California’s SB 100 goals.

Marty Walicki,  

Managing Partner

Three Rivers Energy Development, LLC                                        July 20, 2021                                                            

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

The move to a high electrification demand forecast is a welcome improvement. We must plan for the high electrification because it is an important state goal. Similarly, it is a large step forward for CAISO and State agencies to recognize the urgency to plan for the obvious need for new transmission especially given the l0+year lead times after the transmission is planned and approved.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

The CPUC's high electrification policy driven sensitivity portfolio is "too little too late".  This portfolio should have been developed several years ago.  The portfolio should be the base portfolio, not a sensitivity portfolio.  The CPUC should encourage the CAISO to identify needed transmission based on this portfolio and approve several least regrets transmission projects in this 2022-23 TPP.

While the July 6^th Update would have been welcome news 5-10 years ago, today we already know we need huge amounts of new resources that cannot get to load centers because of the lack of transmission.   To recognize a need for even more resources due to high electrification and call for a study as to whether new transmission is needed and ignore the urgent need to start approving new transmission now is virtually inexplicable. The CAISO already studied the need for new transmission in its 20-Year Transmission Outlook and concluded that over $30 billion of transmission is needed to accomplish SB 100 goals. Continuing to delay approving long lead time transmission will lead to a massive build in the next decade that will overwhelm the supply chain for critical transmission equipment and overwhelm the California Agencies ability to process permit applications. Combined with siting challenges for new transmission it is easy to see how new transmission could take well over 10 years to complete.

It is simply disingenuous to ignore the need to start approving new transmission now if there is any intent to try to meet SB 100 goals with high electrification included in the plan. The global climate crisis and the existing burden to disadvantaged communities must be addressed now. There is no credible claim that we should simply study whether transmission is needed. The combination of Joint Agency Report to the Legislature and the CAISO’s 20-Year Transmission Outlook, along with high electrification demand leaves no credible doubt. CAISO must start approving least regrets new transmission immediately in this 2022-23 TPP cycle. A roadmap of the needed new transmission has already been identified in the CAISO’s 20-Year Transmission Outlook.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

The CAISO should use the CPUC's high electrification sensitivity portfolio to identifying and approving several least regrets new transmission projects in this 2022-23 TPP.  

The CAISO already studied the need for new transmission in its 20-Year Transmission Outlook and concluded that over $30 billion of transmission is needed to accomplish SB 100 goals. Continuing to delay approving long lead time transmission will lead to a massive build in the next decade that will overwhelm the supply chain for critical transmission equipment and overwhelm the California Agencies ability to process permit applications. Combined with siting challenges for new transmission it is easy to see how new transmission could take well over 10 years to complete.

It is simply disingenuous to ignore the need to start approving new transmission now if there is any intent to try to meet SB 100 goals with high electrification included in the 'plan. The global climate crisis and the existing burden to disadvantaged communities must be addressed now. There is no credible claim that we should simply study whether transmission is needed. The combination of Joint Agency Report to the Legislature and the CAISO’s 20-Year Transmission Outlook, along with high electrification demand leaves no credible doubt. CAISO must start approving least regrets new transmission immediately in this 2022-23 TPP cycle. A roadmap of the needed new transmission has already been identified in the CAISO’s 20-Year Transmission Outlook.

The CPUC's high electrification sensitivity portfolio should be used to start identifying which of the 20-year outlook projects should be approved in the 2022-23 TPP.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

Cal Western agrees that this study is needed and looks forward to seeing the study results

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

Cal Western agrees that this study is needed and looks forward to seeing the study results

7. Please provide any additional comments that your organization has:

We have no additional comments

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

N/A

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

N/A

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

N/A

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

N/A

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

N/A

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

N/A

7. Please provide any additional comments that your organization has:

Citizens Energy Corporation (“Citizens”) appreciates the opportunity to provide comments on the CAISO’s draft 2022-2023 Transmission Planning Process (TPP) Study Plan based on the information presented at the July 6th, 2022, stakeholder meeting.

Citizens is a participant in the development of North Gila to Imperial Valley 2 project (“NGIV2”) with IID and the NGIV2 LLC project development team.  Additionally, Citizens is a current CAISO PTO through our two wholly owned operating subsidiaries, Citizens Sunrise Transmission LLC and Citizens Sycamore-Penasquitos Transmission LLC. Citizens’ existing and future investments in the CAISO grid create significant incremental financial assistance for low-income families that live in the project area, without adding to the project’s capital costs. Accordingly, we are pleased to bring the benefits of our unique business model to the NGIV2 project.

Citizens believes it is prudent to study the 30 MMT High Electrification policy-driven sensitivity portfolio in CAISO’s TPP. Citizens also agrees with and supports the comments IID and NGIV2 LLC have submitted in support of the NGIV2 project.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

GridLiance West (GLW) supports the higher levels of electrification proposed to be used in the 2022-2023 TPP.

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

GLW supports the CEC-developed high electrification scenarios.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

GLW generally supports the CPUC’s-developed high electrification policy sensitivity and acknowledges the thorough effort that was applied to mapping RESOLVE-selected resources based on land, environmental constraints, transmission and commercial interest. 

GLW raises concern with the practicality of presuming development of over 1,200 MWs of geothermal resources outside of the CAISO grid for California LSEs’ benefit. The CPUC explained that geothermal resources of 327 MWs in NVE’s control area and 900 MWs in IID’s control area were mapped manually, meaning that RESOLVE did not select these resources in these areas. While the CPUC staff did indicate that they expect this mapping would allow the CAISO to study the availability of Resource Adequacy import capability (“Maximum Import Capability”, or “MIC”), the selection of the resources in these areas did not explicitly evaluate either the cost to the LSEs of obtaining the MIC or the cost of NVE or IID wheeling costs for LSE deliveries of energy to the CAISO. GLW is concerned that the selection may not be optimal without including these MIC and wheeling costs, and that by using this portfolio the CAISO may, as a result, study transmission solutions that are not optimal. The Commission recognized in its January 2022 Decision adopting the Preferred System Portfolio (p. 172) the need to consider increasing RESOLVE’s geothermal potential in Southern Nevada, but this high electrification mapping would not at this time provide a resource mix for the CAISO to study the feasibility of such higher potentials.

GLW is hopeful that between the CPUC’s forthcoming Input and Assumptions updates, and the CAISO’s study of GLW’s economic study request of increased transmission to geothermal fields in Nevada, that the examination of benefits of transmission enhancements in this region of the CAISO will not be hampered by the CPUC’s choice to map these 1,227 MWs of geothermal to locations outside of the CAISO. GLW requests that future portfolios consider all costs of resource deliveries as part of the portfolio location selection process.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

GLW has no objections to the CAISO’s study plan assumptions.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

GLW has no comments regarding the high electrification study other than those expressed under item 3. 

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

GLW has no comment on the Aliso Canyon study plan.

7. Please provide any additional comments that your organization has:

 None

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

N/A

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

N/A

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

N/A

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

N/A

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

N/A

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

N/A

7. Please provide any additional comments that your organization has:

Imperial Irrigation District (IID) appreciates the opportunity to provide comments on the CAISO’s draft 2022-2023 Transmission Planning Process (TPP) Study Plan based on the information presented at the July 6, 2022 Stakeholder Meeting. IID stands ready to support CAISO in studying the recommendation from the California Public Utilities Commission and the California Energy Commission to evaluate deliverability and transmission needs related “to out of CAISO” long-lead resources, including wind and geothermal resources.

IID continues to participate in development of the North Gila to Imperial Valley #2 (“NGIV2”) project along with Citizens Energy and NGIV2 LLC. As stated in IID’s comments submitted to CAISO after the first stakeholder call in March 2022, IID believes the NGIV2 project will be a great transmission candidate to assist in fulfilling the objectives of the State of California.

IID would also like to share with CAISO IID’s presentation made at the June 16, 2022, meeting of the Lithium Valley Commission. The Lithium Valley Commission is a Blue-Ribbon commission established by the CEC to review, investigate, and analyze opportunities and benefits for lithium recovery in the State of California. The presentation titled ‘Role of Geothermal’ describes some of the interim and long-term transmission options being evaluated by IID to facilitate export of resources from the Imperial Valley.

The CPUC presentation titled ‘Higher Levels of Electrification for Use in the 2022-2023 TPP’ Page no. 13/22 Busbar Mapping Overview, shows 0 MW for Imperial Solar in the year 2032. We respectfully request CPUC and CAISO consider that IID’s generation interconnection queue has 1080 MW of solar.  IID would also point out that the proposed Dunes 500 kV/230 kV Substation sits in close proximity of an area designated as a Solar Energy Zone by the Bureau of Land Management. We believe a new CAISO delivery point at this location like the Dunes Substation will serve to encourage more solar and storage development on both private and public lands in the area that may not be evident from the current IID or CAISO generation interconnection queue.    

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

LS Power appreciates the ISO, CPUC, and CEC coordination efforts to ensure that the current planning process includes the most up to date study assumptions and input.

LS power supports using the more realistic level of electrification in the 2022-2023 TPP.  Given the state’s aggressive electrification goals we applaud the efforts of the CEC and CPUC in developing the load forecast and resource portfolio assumptions in a timely manner and the ISO’s flexibility in incorporating them in the current TPP cycle. 

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

The specific increase to the load forecast that will be used for the base and sensitivity case studies has not clearly been identified.  It would be helpful to understand the specific impact to the load forecast resulting from the use of the Additional Transportation Electrification (ATE) scenario instead of the 2021 IEPR forecast that the ISO originally planned to use. 

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

LS Power supports the evaluation of a high electrification sensitivity portfolio.  Lower GHG targets and higher load may come to fruition based on policy goals so it is important to understand the associated transmission implications.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

LS Power supports updating the study plan assumptions and appreciates the ISO’s flexibility in allowing this update so that the study results will more closely align with state policy goals. Given the near term needs and long lead time for infrastructure development, it is important that this change be studied in a proactive manner. 

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

LS Power supports the special study for 2035 looking at high electrification and lower GHG targets.  There is an aggressive jump between the 2032 Preferred System Plan total (40.1 GW) and the 2035 30 MMT High Electrification Sensitivity Portfolio (86.5 GW) as reflected on Slide 10 of ISO’s July 6^th presentation.   The current version of the Final Study Plan notes that the results of this sensitivity study will be used the same way as any policy driven sensitivity study.  Given the large jump between the portfolios, it would be helpful to have confirmation that the outcome of this special study will be actionable by the ISO.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

LS Power has no comments at this time.  

7. Please provide any additional comments that your organization has:

The third item requested by the CPUC and CEC in their July 1^st letter relates to the continued studying of deliverability needs and corresponding transmission needs related to Out of State (OOS) long-lead time resources.  LS Power supports continued focus on assessing incremental transmission capacity and Maximum Import Capability (MIC) expansion to support OOS generation capacity needs identified by the CPUC and CEC.  LS Power encourages the ISO to provide more explicit insight into potential MIC increases to support the OOS generation that the CPUC and CEC have identified in the IRP and IEPR, respectively. The updated study plan should include the methodology and assumptions for the study of deliverability and transmission needs related to these OOS long-lead time resources pursuant to the CPUC and CEC request.  

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

LSA assumes that this question relates to the Preferred Resource (Base) portfolio, and that Q3 below applies to the Sensitivity Portfolio.

LSA requests an explanation for why the CPUC and/or CAISO decided that no adjustment to the preferred resource (base) portfolio were needed to meet the increased load for higher levels of electrification. 

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

LSA’s main comment relates to the development of the CEC demand forecast related to the Additional Transportation Electrification (ATE) features, added to the base portfolio forecast and reflected in the sensitivity case portfolio forecast.  LSA appreciates the difficulties of forecasting vehicle charging load, given the mobility of the load and uncertainties of the timing. 

• The time-of-day elements of the forecast seem strongly related to the assumption of strong charging demand late in the day in response to TOU rate response.  If the assumption is that vehicle charge later into the evening as a response to TOU rate periods, it seems like the logical response by the CPUC and Load-Serving Entities (LSEs) could be to adjust TOU rate periods to encourage shifts to lower-demand and lower-cost times.  This could ultimately spread EV charging loads to hours when there is surplus solar energy being generated. 

• Potential residential and commercial penetration of battery technology (combined with rooftop solar), and smart charging with car batteries, would likely change the distribution of charging load as well.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

LSA also requests additional information about how one of the criteria used in the busbar mapping exercise – Commercial Interest – was incorporated into the analysis. (All slide references are to the position in the PDF slide deck, which seemed inconsistent with the page numbers on the slides.)

There were five busbar mapping criteria used:

1. Distance to transmission of appropriate voltage
2. Transmission capability limits, and cost-effective transmission upgrades
3. Land use and environmental constraints
4. Commercial development interest
5. Consistency with prior year’s TPP base case mapping

LSA’s first question is how the different criteria were balanced against each other.  For example, if an area had high “commercial development interest” but there were relatively longer distances to transmission, how would those two factors be considered in the mapping exercise?

LSA’s second question is about how the actual score for commercial development interest was determined.  For example, statements were made in the presentation that:

• The score was “based on the queue,” but the capacity in the queue far exceeds the portfolio amounts.

• The mapping process “prioritize(ed) mapping at substations with projects further along in the interconnection process” (slide 18); but

• It also included projects early in the interconnection process – or not even in that process yet, e.g. (slides 18-20):

• “Known projects in planning/development currently not in queue (OOS Wind and LDES in particular);”

• Cluster 14 projects, i.e., “significant mapping to locations with commercial interest, whose interconnection has not yet been studied;” and

• “Some long-lead-time resources” for which there was “limited commercial interest,” e.g., geothermal resources.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

LSA assumes that this question relates to the Preferred Resource (Base) portfolio, and that Q5 below applies to the Sensitivity Portfolio.

The Base Portfolio includes a significant quantity of Energy Only solar projects, but from the meeting discussion it appears that some or all of these projects (as well as those with FCDS) were studied for Off-Peak Deliverability Status.  LSA asks that the CAISO clarify the deliverability of solar projects in the study plan assumptions.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

Given the new inputs from the CEC and CPUC, the CAISO’s description of the study plans for the sensitivity study are about as expected.  However:

• LSA notes that the format of Slide 10 is helpful, but that the numbers marked with the arrows do not appear to add up.

• As noted in our comments on the Deliverability Assessment summary, there should have been additional stakeholder process activities before the CAISO decided (unannounced at the time) to use the proposed revised storage Deliverability Assessment dispatch assumptions.

In fact, LSA’s review of the newly posted On-Peak Deliverability Assessment shows incorporation of the revised High System Need (HSN) and Secondary System Need (SSN) hourly definitions.  However, despite the CAISO’s proposed “long-term” and “short-term” storage dispatch assumptions, no changes are shown to those storage dispatch assumptions.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

LSA has no comments on this proposed study.  LSA appreciates that the CAISO will be using transmission projects identified in the 20-Year Transmission Outlook for further evaluation on mitigating the need for reliance on the Aliso Canyon gas storage facility.

7. Please provide any additional comments that your organization has:

LSA appreciates the effort and focus by the agencies to calibrate more correctly towards a lower GHG target and more accurate long-term load forecast. We understand this mid-year update will require additional work for CAISO staff, and we support all endeavors to incorporate the new metrics into the 2022-23 TPP.

The current 10-year time horizon for the CAISO’s Transmission Planning Process (TPP) was selected long ago, when planning, permitting, and constructing major transmission projects could be done within that time.  Currently, the development process for high voltage transmission projects, including acquisition of rights-of-way and the environmental permitting process can take 8 to 10 years or more. For future TPPs the CAISO should consider adopting a longer planning horizon.  LSA suggests 20 years.

Recent experience – for example, with the Tehachapi Renewable Transmission Project (TRTP) and West of Devers (WoD) projects – as well as the longer lead times needed for some generation and storage technologies (offshore wind, geothermal, pumped storage) indicate that the TPP time horizon generally should be extended, for the entire effort and not just for the sensitivity case recommended here.  Sensitivity cases do not trigger CAISO approval of any transmission upgrades regardless of their outcomes, so they do not trigger any actions toward mitigating identified impacts.

Thus, LSA believes that the entire process – the CAISO’s TPP, and the CEC/CPUC activities supporting it – should be extended to reflect the longer times needed.  As LSA stated in its earlier TPP comments, the CAISO should chart a clearer path between the more limited policy-driven upgrades recommended here and the enormous transmission needs indicated in the High Electrification case, as well as the CAISO’s impressive new 20-Year Transmission Outlook. 

The danger of the current 10-year horizon for approving new transmission projects is obvious when comparing the current pace of largely piecemeal network upgrades to accommodate new renewables in the CAISO’s recent Transmission Plans with the much larger and more comprehensive approach needed to achieve the higher targets, and associated transmission needs now under consideration.

One problem with the TPP today is that CAISO decisions are binary, i.e., a project is either approved or not in the TPP, and only based on the base-portfolio results.  Once a project is approved, the PTO or other sponsor must start basic studies, design/engineering, and permitting.  Those tasks are less expensive than equipment procurement and construction, but they can take more time for a project than actual construction, and then the total elapsed time can exceed the 10-year Plan horizon.

Allowing conditional approvals based on sensitivity cases could authorize the PTO or other sponsor to begin preliminary work, to better ensure that needed transmission in-service dates can be met.  Conditional approval would authorize commencement of initial studies, design/engineering, and permitting, with Transmission Access Charge (TAC) recovery of those limited costs. 

Projects later confirmed as needed in the regular TPP would receive final CAISO approval, authorizing the PTO/sponsor to begin procurement and proceed on to construction.  Projects not receiving such TPP confirmation would not proceed further.

This process is consistent with that used for many interconnection-related upgrades facilitated through the GIDAP.  Generator Interconnection Agreements (GIAs) often provide for Interconnection Customers to issue separate Notices to Proceed for design/engineering and for construction, and the PTO would not initiate either of these tasks until receipt of the Interconnection Customer (IC) notice to Proceed (NTP).  Project approved in the GIDAP but found later not to be needed are removed from the process in the annual Reassessment process.

LSA intends to promote this concept in the upcoming TPP Enhancements initiative.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

NGIV2, LLC supports the CPUC levels for use in the current TPP.  

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

NGIV2, LLC supports the CEC higher electrification scenarios  for use in the current TPP to provide a better view of potential long-term planning system requirements.   The development of the resource portfolio by the CPUC based on the CEC's higher electrification should take a broader look at both in-state and out-of-state resources 

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

NGIV2, LLC supports the CPUC's policy-driven sensitivity portfolio, specifically targeting significant growth in both the Imperial Valley area geothermal and wind resources directed to the Palo Verde hub (i.e. New Mexico wind delivered to Palo Verde).

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

NGIV2, LLC highly supports the updates to the 2022-2023 TPP Study Plan assumptions, specifically related to recommended loads and resource scenarios, and assumptions related to out-of-state wind and geothermal resources beyond the CAISO balancing authority.   We also support the inclusion of the Evaluation Plan for the North Gila-Imperial Valley #2 Project, and look forward to working with the CAISO staff to ensure that the modeling assumptions are properly included as needed.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

NGIV2, LLC supports this sensitivity, specifically related to the LA Basin and San Diego-Imperial Valley area resource needs to support the anticipated load levels.  We look forward to reviewing the reliability assessment, production cost simulation, and potential mitigation alternative analysis in Q4 2022.   

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

In addition to access to more energy resources from the Imperial Valley and Arizona, the NGIV2 Project provides valuable geothermal capacity resources to backfill the anticipated loss of capacity provided by resources reliant on Aliso Canyon.

We note that on Slide 26 of the CAISO presentation and noted in the latest Study Plan, that it will consider the North Gila-Imperial Valley #2 Project as one of the potential transmission upgrades if found to support this special study.   However, please note that the NGIV2 Project will also include an intermediate interconnection to the IID Highline 230kV substation, and request that the CAISO use this configuration in their analysis to capture the full spectrum of benefits provided by the project.  

7. Please provide any additional comments that your organization has:

NGIV2, LLC appreciates the opportunity to provide these comments and the coordination efforts between the CPUC, CEC, the CAISO and transparencey with stakeholders.    Much like the development of the 20-Year Transmission Outlook, transmission development in the west is becoming increasingly longer from inception to in-service date with many taking 15 years.    Again, we appreciate your collective efforts to be prepared for the future with a transmission system to meet the demands of the CAISO system.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

No comment at this time.

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

No comment at this time.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

No comment at this time.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

NCPA believes the base case should not be updated and load forecast in the original study plan should be used for the base case. NCPA supports studying the high electrification scenario as a sensitivity.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

No comment at this time.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

No comment at this time.

7. Please provide any additional comments that your organization has:

Northern California Power Agency (NCPA) appreciates the opportunity to comment on the updated Final Study Plan for the 2022-2023 Transmission Planning Process.

NCPA cautions the CAISO of cost containment in case the high electrification scenarios do not materialize.

CAISO’s High Voltage Access Charge (HV TAC) is projected to triple by 2036 based on a 38 MMT preferred system plan. Notably, a 30 MMT high electrification sensitivity portfolio will require double the amount of generation as compared to the 2032 preferred system plan and NCPA is concerned about the additional cost of transmission to integrate the 2036 sensitivity portfolio.

NCPA encourages the CAISO to consider all potentially lower cost alternative methods including non-wires solutions, dynamic line ratings, and the use of the existing transmission.

We further note: existing resources are evaluating the uses, economics, and feasibility of converting existing gas fired generators to green hydrogen as highlighted by CEC’s IEPR Commissioner Workshop on Role of Hydrogen in California’s Clean Energy Future.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

Please see our comments in the attached file. Thank you.  

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

n/a

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

n/a

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

n/a

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

n/a

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

n/a

7. Please provide any additional comments that your organization has:

See our attachment.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

PG&E appreciates the efforts of the CAISO, CEC and CPUC to use higher levels of electrification for use in the 2022-2023 TPP and appreciates the opportunity to provide comments on the proposed changes to the CAISO’s study plan.

PG&E supports use of higher levels of electrification forecast compared to the CEC mid-IEPR scenario.  Specifically, for the 2022-23 IRP cycle, PG&E recommended use of the Inter-Agency Working Group (“IAWG”) High Electrification (HE) scenario forecast.  The IAWG forecast appropriately accounts for the probability of high electrification.  For consistency and to ensure an appropriate level of electrification forecast is reflected in Transmission Plans, PG&E encourages the CAISO to also use the IAWG HE forecast.  However, recognizing that there is limited time available for developing a portfolio of resources corresponding to the IAWG forecast, PG&E does not oppose the use of the Additional Transportation Electrification (ATE) forecast developed by the CEC to inform the 2022-23 TPP.

PG&E believes that planning for high electrification is consistent with the current direction of state policy developments, which renders high electrification forecasts as very probable.  Accordingly, PG&E supports an update of the system level forecast that is driven by the very real expectation of high electrification.

PG&E notes that in addition to a reasonable system level electrification forecast, location specificity is an important element of electrification forecasting.  Recognizing CEC’s efforts to use a location-specific forecast and given this is the first time such a forecast will be available with limited opportunity for the stakeholders’ inputs, PG&E recommends that the CAISO maintain flexibility for reassessing higher electrification demand-driven transmission need in future cycles.

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

As conveyed above and public comments submitted to the CEC (e.g., TN# 242741 in Docket No. 22-IEPR-03 and TN# 240924 in Docket No. 21-IEPR-03), PG&E generally supports CEC’s development of higher electrification grid planning scenarios.  Policies in discussion at CARB and other agencies could have transformational impact on transportation and building electrification.  Consequently, it is critically important that the State consider a range of scenarios that consider not only firm programs and policies, but also proposed policies when making decisions about how to prepare California’s electrical grid and other energy resources to support the State’s electrification goals.

PG&E lauds the efforts of CEC and the other inter-agency partners in developing the higher electrification grid planning scenarios, and the current scenarios mark an important advancement beyond the existing IEPR scenario set.  However, PG&E believes that more work is needed to continue to improve high electrification forecasting and will continue to engage in the CEC’s IEPR process to support the development of an electrification forecast for use in planning efforts. Moreover, as expressed in public comments TN# 242741 in Docket No. 22-IEPR-03, PG&E has a number of outstanding questions that are important for PG&E to understand regarding the assumptions and implications of the CEC’s higher electrification grid planning scenarios.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

As noted above in response to Question 1, PG&E supports use of higher levels of electrification forecast compared to the CEC mid-IEPR scenario.

However, as stated in PG&E’s opening comments on the Proposed Decision to adopt the 2021 Preferred System Plan (PSP), PG&E is concerned the PSP uses outdated LSE procurement portfolios from the 2020 IRP filings and does not take into account location-specific resource requirements as evidenced by the imbalance split of resources between Northern and Southern California.[1]  The busbar mapping results of the new 30 MMT portfolio for the 30 MMT high electrification sensitivity portfolio in 2035 shows similar issues. Only 32% of the total incremental capacity additions are in Northern California.

As it currently stands, there is a significant risk of approving unnecessary transmission upgrades because actual LSE planned procurement portfolios are different from the PSP portfolio that will be used to inform the 2022-23 CAISO TPP.

To mitigate this risk, PG&E encourages the CAISO to analyze at least one portfolio that uses a more geographically balanced split of resources before approving new transmission upgrades driven by renewable resource locations.

[1] In the 2021 PSP, the majority of new resources are in Southern California.  For example, in 2030, out of approximately 34,000 MW of cumulative incremental renewable and storage capacity additions, approximately 28,600 MW are located in Southern California.  PG&E does not believe this is a realistic assumption.  LSEs will procure resources across the CAISO system to meet other aspects of resource needs (e.g., local). 

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

PG&E supports moving to higher levels of electrification assumptions for use in the 2022-2023 TPP.  However, PG&E believes additional work will be needed to improve the alignment between the CEC’s ATE load forecast and the actual electrification load interconnection applications received by PG&E on both megawatt (MW) numbers and bus level allocation.  PG&E’s initial review of the proposed load distribution indicates that the Highway 5, Highway 99, and Highway 101 transportation corridors are not represented correctly as the total MW numbers are much lower than the currently received new electric load applications from customers.  PG&E recommends CAISO and PG&E continue working with CEC to get the ATE load forecast and load distribution more accurate in future iterations; otherwise, using inaccurate location-specific forecast could trigger unnecessary transmission capacity projects or not enough transmission upgrades in certain parts of the grid.  Further, PG&E recommends that the CAISO maintain flexibility for reassessing higher electrification demand-driven transmission need in future cycles as the ATE load forecasts evolve and are refined.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

PG&E supports performing reliability, policy, and economic studies for the 2035 high electrification sensitivity cases with the proposed high-level assumptions.  PG&E plans to provide additional input and review as the TPP process continues and the detailed 2035 base case model is finalized.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

PG&E supports CAISO’s proposed study process to consider reliability impacts in Southern California with the CPUC-identified curtailment of thermal plants due to the absence of Aliso Canyon.  PG&E continues to encourage the CAISO to consider whether there is a minimum generation level and attributes of resources needed to maintain reliability in both the LA Basin and in the closely related San Diego local area, even with potential increased transmission capacity into the local areas, as part of its analysis.

7. Please provide any additional comments that your organization has:

PG&E has no additional comments.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

Pattern supports the use of the higher electrification assumptions for the 2022-23 TPP.  We hope that these higher levels of electrification will be used and considered to plan proactively and foster coordination between state agencies and CAISO.

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

Pattern appreciates the CPUC’s interest in exploring a policy-driven sensitivity portfolio designed around the lower GHG emission limit (30 MMT) and the use of high electrification demand assumptions in the 2022-2023 TPP. This sensitivity will help the agencies, CAISO, and other stakeholders understand what transmission build out is required to implement the necessary transition to a higher electrification future. We understand that this will be a significant undertaking but we think the value of the information will yield process efficiencies and better preparedness in future cycles of the IRP and TPP.  To this end, we urge the CPUC and CEC to provide as much assistance as possible in making the high electrification future studied in the TPP actionable by CAISO in the near-term.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

No additional reponse at this time.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

Pattern supports CAISO’s plans to study long lead-time resources, including out-of-state (OOS) wind and geothermal resources in both the base and sensitivity portfolios in a way that accounts for transmission planning deliverability (TPD) that has already been allocated through the CAISO queue, as stated on slide 12 of CAISO’s July 6 presentation. As directed in the recent CPUC and CEC transmittal letter to CAISO, we urge CAISO to study, identify, and explain opportunities to expand Maximum Import Capability (MIC) and incremental transmission capacity necessitated by long lead-time imported, renewable resources.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

Pattern notes that the 30 MMT HE Sensitivity Portfolio incorporates higher amounts of almost all clean energy resources as compared to the PSP base case. We support the increase in regional wind to 4,828 MW in 2028 in the HE sensitivity case. The 4,828 MW in 2028 better aligns with commercial activity than the 1,500 MW assumed in the base case, and reflects continued development of a number of out-of-state transmission projects, which CAISO studied in its recent OOS Wind Study as part of the 2021-22 TPP. The information revealed in this sensitivity study will be critical to successful integration of these planned OOS resources and development of sufficient resources to meet a high electrification future.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

No reponse at this time.

7. Please provide any additional comments that your organization has:

We appreciate the California Public Utilities Commission (CPUC) guidance to the CAISO to study the high electrification and lower GHG emissions future, as well as the guidance to increase deliverability of renewable imports.  In concert, these three recommendations will enable a more robust and diverse resource portfolio that protects our grid from future extreme weather events and other unforeseen circumstances.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

SEIA supports incorporating higher levels of electrification in the 2022-2023 TPP. 

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

SEIA supports CEC’s development of higher electrification grid planning scenarios.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

SEIA supports the CPUC’s high electrification policy-driven sensitivity portfolio.  

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

SEIA supports CAISO’s updates to the 2022-2023 study plan assumptions. SEIA believes that the 2021 Integrated Energy Policy Report (IEPR) Additional Transportation Electrification scenario more accurately reflects the level of demand for electricity that can be expected as California continues its effort to reduce GHG emissions, especially from the transportation sector. It is important that the inputs and assumptions employed in the CAISO TPP effectively tests the current systems ability to reliably serve future load growth to identify any weaknesses that can be addressed through transmission solutions. SEIA believes this is crucial improving system reliability and better integrating renewable resources that will help meet California’s clean energy goals. 

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

SEIA supports CAISO’s study plan for the high electrification special sensitivity study. More specifically, SEIA supports using the results of the high electrification special sensitivity study to identify potential Category 1 and/or 2 transmission solutions as is currently done with the policy-driven studies. SEIA believes that proactively identifying transmission needs to support high electrification and renewable integration which, based on the high electrification resource portfolio, is imperative to reliably meet California clean energy and emissions goals.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

SEIA supports CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study. 

7. Please provide any additional comments that your organization has:

No comment.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

SCE supports the use of a high electrification scenario for the 2022-2023 TPP.  SCE believes that it is important to align the high electrification scenario forecasts between TPP and Distribution Planning Process (DPP) in the future.  

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

SCE applauds the efforts of the CEC, CPUC, and CAISO in developing a high electrification scenario for use in the TPP. SCE would like to see more stakeholder involvement in the development of the higher electrification scenario forecast in the future to ensure the forecast is well vetted to reflect both long-term likely policy impacts and near-term market trends.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

SCE appreciates CPUC’s work on new resource buildouts based on higher electrification scenarios for the 2022-2023 TPP.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

No comment.

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

No comment.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

SCE appreciates the efforts of CAISO on both the Aliso Canyon gas storage study and the recently published CAISO 20 Year Transmission Outlook. The 20 Year Transmission Outlook is a good first step to extend long-term planning beyond 10 years, which SCE believes is necessary due to the time required to design, permit, and construct the upgrades to meet California’s clean energy  policy goals. As the CAISO explores mitigations for the Aliso Canyon scenario and any other long-term needs, SCE encourages CAISO to remain open to the development of other project concepts and ideas as well. The first 20 Year Transmission Outlook was developed without significant PTO or other stakeholder feedback that should balance electrical needs with other project aspects such as feasibility, environmental impact, and constructability. Bringing all these elements together should ensure proposals for the best long-term mitigations that are cost-effective with a high probability of success. 

Additionally, SCE does caution that the conclusions of the CPUC’s Aliso Canyon electric generation impact analysis have not been vetted by other stakeholders and the actual impacts on electric generation in case of Aliso Canyon shutdown could be different than CPUC’s analysis shows.

7. Please provide any additional comments that your organization has:

No comment.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

No comments.

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

No comments.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

Southwestern Power Group (SWPG) supports the CPUC’s high electrification policy-driven sensitivity portfolio, and specifically CPUC’s inclusion of higher amounts of out-of-state wind in the sensitivity portfolio. Refer to response to questions 4 and 5 for further comments on how these additions will be studied.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

SWPG’s comments mainly pertain to how CAISO’s study plan will address long lead-time resources in both the base portfolio and even more importantly in the sensitivity portfolio with increased amounts of long lead out-of-state (OOS) resources. Specifically the sensitivity portfolio includes the addition of 4,828 MW of OOS wind in 2028 compared to the original PSP portfolio with 1,500 MW of OOS wind in 2030. The July 1 letter to the CAISO from CPUC and CEC states the following:

“Finally, we also respectfully request that CAISO study, identify and explain opportunities to provide Maximum Import Capability (MIC) expansion and incremental transmission capacity necessary for deliverability of long-lead time renewable resources, such as geothermal and out-of-state wind, beyond the CAISO’s balancing area authority, particularly those mapped in the policy driven base case and sensitivity study portfolios.”

As a developer of transmission to import OOS wind SWPG strongly supports the need for this component of the study, since the CAISO’s latest Advisory Estimates of Future RA Import Capability does not show sufficient import capability to accommodate the sensitivity portfolio’s increased 2028 imports.[1]

The CPUC/CEC letter also quotes CAISO’s final 2021-22 Transmission Plan stating that resources seeking to interconnect directly through the ISO queue far exceed current portfolio amounts and needs, and that these resources have already been allocated deliverability subject to meeting their obligations to advance through to commissioning.

On page 12 of its July 6 presentation CAISO confirms that its assessment of out-of-state (OOS) wind and geothermal resources will consider the incremental transmission needs while accounting for transmission planning deliverability (TPD) that has already been allocated through the CAISO queue, as requested in the July 1 CPUC/CEC letter.

SWPG raises the following comments/questions pertaining to these aspects of the study:

1. As CAISO studies how to provide the necessary MIC expansion and incremental deliverability to accommodate the increased imports, would the resulting incremental deliverability be reserved or held “off limits” from current or future ISO queue projects which have not yet been allocated deliverability? This question is even more critical for the sensitivity portfolio with 4,828 MW OOS wind in 2028. This topic warrants further discussion either in this TPP cycle or in the TPP Enhancements initiative.  
2. Related to #1, it would also be helpful to know if, upon conclusion of the sensitivity study CAISO plans to “commit” to the increased MIC levels needed in 2028. In other words would CAISO update the aforementioned Advisory Estimates of Future RA Import Capability document accordingly? Since the MIC allocations process currently only addresses the immediate year forward (i.e. July 2022 MIC allocations are for 2023 only), market participants would need some assurance that the higher anticipated MIC levels several years in the future would be maintained.
3. Since CAISO's Final 2021-22 Transmission Plan states that the resources seeking to interconnect through the ISO queue which have been allocated deliverability “far exceed the current portfolio amounts – and current needs”, will CAISO also consider outcomes in either the base or sensitivity study where some deliverability allocated to these resources is ultimately not utilized or needed by these resources?

[1] http://www.caiso.com/Documents/AdvisoryestimatesoffutureResourceAdequacyImportCapabilityforyears2023-2032.pdf

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

As shown on slide 10 of CAISO’s July 6 presentation, the 30 MMT HE Sensitivity Portfolio incorporates higher amounts of almost all clean energy resources as compared to the PSP base case. SWPG would specifically like to point out and support the increase in OOS wind from 1,500MW in 2030 in the original PSP to 4,828 MW in 2028 in the HE sensitivity case. The 4,828 MW in 2028 is more consistent with commercial activity and the actual out-of-state transmission projects CAISO studied in its recent OOS Wind Study as part of the 2021-22 TPP. The information revealed in this sensitivity study will be critical to successful integration of these planned OOS resources.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

No comments.

7. Please provide any additional comments that your organization has:

No comments.

1. Please provide your organization’s comments on the CPUC’s higher levels of electrification for use in the 2022-2023 Transmission Planning Process (TPP):

One of the most important efforts in California’s world-leading fight against climate change is the electrification of the transportation sector, which currently accounts for 41% of the state’s CO₂ emissions. In recognition of the importance of electrifying the transportation sector, California has set goals of having 5 million Zero-Emission Vehicles (ZEVs) on the road by 2030, and 100% of car sales being ZEVs by 2035.

Recognizing of the importance of ensuring there is sufficient capacity on the generation, transmission and distribution systems to serve the charging needs of electric vehicles (EVs) required to meet the state’s goals, the CPUC has requested to use a higher level of electrification for base case analysis in the 2022-2023 TPP.

Tesla strongly supports this request.

As a leading manufacturer of EVs and the builder/operator of the world’s largest charging network to serve EV drivers’ travel needs, Tesla has a unique perspective on the importance of building sufficient infrastructure to meet EV drivers’ travel needs, and the challenges an insufficient grid can present of building that infrastructure. Indeed, even at this early stage of transportation electrification, when we are only 20% of the way to accomplishing the state’s 2030 ZEV goal, Tesla is already experiencing long delays in obtaining new service connections for some Direct-Current (DC) fast charging stations due to insufficient Transmission and Distribution (T&D) capacity.

Moreover, as the state moves rapidly to electrify medium and heavy-duty trucks, buses and other vehicle types, as well as building end uses, we are concerned that capacity shortfalls will begin to impact the transmission and generation systems as well.

As noted in the CPUC’s presentation, parties to the Integrated Resource Planning (IRP) proceeding have pointed out that all of the Integrated Energy Policy Report (IEPR) scenarios materially underestimate likely EV load by 2030, and failure to adequately plan for electrification load could jeopardize the 2035 ZEV goal and the carbon neutrality goals.

For all of these reasons, Tesla supports the CPUC’s request to use higher levels of electrification in the 2022 – 2023 TPP.

In California’s world-leading fight against climate change, one of the most important efforts is the electrification of the transportation sector, which currently accounts for 41% of the state’s CO₂ emissions. In recognition of the importance of electrifying the transportation sector, California has set goals of having 5 million Zero-Emission Vehicles (ZEVs) on the road by 2030, and 100% of car sales being ZEVs by 2035.

In recognition of the importance of ensuring capacity on the generation, transmission and distribution system is sufficient to provide zero-emission charging energy to serve the vehicles necessary to meet the state’s goals, the CPUC has requested to use a higher level of electrification for 2022 – 2023 base case analysis.

Tesla strongly supports this request.

As a leading manufacturer of EVs and the builder/operator of the world’s largest charging network to serve EV drivers’ travel needs, Tesla has a unique perspective on the importance of building sufficient infrastructure to meet EV drivers’ travel needs, and the challenges an insufficient grid can present of building that infrastructure. Indeed, even at this early stage of transportation electrification, when we are only 20% of the way to accomplishing the state’s 2030 ZEV goal, Tesla is already experiencing long delays in obtaining new service connections for some Direct-Current (DC) fast charging stations due to insufficient Transmission and Distribution (T&D) capacity.

Moreover, as the state moves rapidly to electrify medium and heavy-duty trucks, buses and other vehicle types, as well as building end uses, we are concerned that capacity shortfalls will begin to impact the transmission and generation systems as well.

As noted in the CPUC’s presentation, parties to the Integrated Resource Planning (IRP) proceeding have pointed out that all of the Integrated Energy Policy Report (IEPR) scenarios materially underestimate likely EV load by 2030, and failure to adequately plan for electrification load could jeopardize the 2035 ZEV goal and the carbon neutrality goals.

For all of these reasons, Tesla supports the CPUC’s request to use higher levels of electrification in the 2022 – 2023 TPP.

2. Please provide your organization’s comments on the CEC’s development of higher electrification grid planning scenarios:

The Energy Commission plays a critical role in grid planning for the next decade, when a move to electrify transportation and buildings in California will happen on an unprecedented scale. Development of accurate load projections on an aggregate scale, and allocation of impacts to load busses will be a crucial part of this effort.

The significant electricity demand of light-duty electric vehicles – ranging from 1.3 kW to 350 kW – and the difficulty of predicting consumer adoption of a fast-evolving new technology have created challenges for the IEPR forecast. As a result, over the past few years, the IEPR has typically underestimated actual transportation electrification load growth. For example, the CPUC’s Independent Professional Engineer (IPE) “Post Distribution Planning Advisory Group (DPAG) Report” shows that annual growth from “known load projects” is higher than the IEPR mid-case forecast until 2030, primarily driven by EV chargers and cannabis cultivation.

Because the IEPR mid-case forecast has historically underestimated EV charging load – and is expected to continue that trend – it is imperative for the CEC to develop scenarios that capture higher levels of transportation electrification than those currently modeled in the IEPR. Beyond failing to accurately predict EV-driven load growth, the IEPR mid-case forecast falls short of the state’s EV adoption and sales targets.

For these reasons, Tesla appreciates and supports the CEC’s development of the Additional Transportation Electrification (ATE) grid planning scenario and the Interagency High Electrification (IAHE) scenario, and we agree it is appropriate to use the ATE scenario to adequately plan T&D infrastructure development to meet the state’s 2035 TE goal.

In addition to developing gross load forecasts, the Energy Commission also translates those forecasts into peak hour loads on load busses as an input to power flow models.

This load bus mapping work is critical meeting the state’s transportation electrification goals, since it is imperative that sufficient T&D capacity exists to serve the DC fast-charging needs of light, medium and heavy-duty electric vehicles along travel corridors. If sufficient capacity does not exist to serve drivers’ charging needs along these routes, passenger car drivers and commercial bus and truck operators will be reluctant to switch to electric vehicles.

As Tesla has found out through the experience of constructing our Supercharger network, building DC fast-charging sites along travel corridors presents unique challenges. First, the sites where fast-charging is needed are often in rural areas where T&D infrastructure lacks capacity to handle high-voltage charging stations. Second, the timelines under which it becomes apparent a charging station is needed, and the speed at which they can be built, is much shorter than for other more traditional load types, like a residential development or business.

For these reasons, the load bus mapping work should anticipate the need for EV charging along travel corridors – such as the I-5 running North/South and the I-80 running East/West, so that the state can be prepared for the rapid emergence of EV charging stations along these routes. This need will likely be accelerated by California’s implementation of the National Electric Vehicle Infrastructure (NEVI) program, which prioritizes DC fast-charging build-out along highway corridors.

In allocating the peak impacts of the TE forecast to busses, the CEC proposes to use proportional mapping based on 70% DMV Registration, 15% retail gasoline sales and 15% commercial electricity sales for light-duty vehicles; and 50% retail sales of diesel fuel and 50% freight activity by zip code for commercial vehicles.

While use of gasoline sales has some merit as a proxy for locations where EV charging demand will emerge, we would note that not all gasoline sales are equal as a proxy for EV charging. For example, gasoline sales in cities and suburban areas are likely to be replaced by low-voltage EV charging at homes overnight. By contrast, gasoline sales along interstate highways in rural areas are likely to be replaced by DC fast-charging stations located in those areas. For this reason, we recommend providing special weight to sales of gasoline and diesel fuel at stations in close proximity to travel corridors, in order to approximate the likely locations of future DC fast-charging sites.

3. Please provide your organization’s comments on the CPUC’s high electrification policy-driven sensitivity portfolio:

Along with concerns about insufficient T&D system capacity to serve the needs of light, medium and heavy-duty vehicles along travel corridors, Tesla is also concerned there will be insufficient capacity on the generation system to meet future TE load growth. In particular, the charging demands of heavy-duty commercial electric trucks – which can charge at a MW of power or higher – has the potential to add many MW of demand to the CAISO grid very quickly.

For this reason, we support the CPUC’s development of a High Electrification Policy-Driven Sensitivity Portfolio using the RESOLVE model. The results of this analysis provide a useful picture of the generation that will need to be added to the system by 2035 to meet the state’s policy goals, along with busbar mapping to transmission resources. Given the long interconnection timelines utility-scale resources currently face in interconnecting to the CAISO system, this sensitivity portfolio can help the state energy agencies and project developers prepare for aggressive load growth over the next 10-15 years.

4. Please provide you organization’s comments on the CAISO’s update to the 2022-2023 study plan assumptions:

As mentioned above, Tesla strongly supports the use of the 2021 Integrated Energy Policy Report (IEPR) Additional Transportation Electrification scenario as CAISO’s load assumptions for 2022-23 Transmission Planning Process (TPP) base and sensitivity case studies, as requested by the CPUC and CEC in their July 6 letter.

As the agency responsible for planning and operating the state’s transmission grid, CAISO will play a crucial role in this effort in California's efforts to electrify the transportation sector, which is currently the largest source of CO2 emission in California. Failure to adequately prepare the transmission grid for rapid electrification of the transportation sector could lead to transmission bottlenecks and delays in providing service connections for electric vehicle (EV) charging equipment, which could ultimately deter individuals and businesses from switching from internal combustion engine vehicles to EVs. For this reason, it is important that that the TPP base case assumptions accurately capture TE-driven load growth, and we are heartened that the CAISO has agreed to use the additional TE scneario for this purpose. 

5. Please provide your organization’s comments on the CAISO’s study plan for the high electrification special/sensitivity study:

Tesla strongly supports CAISO’s plan to study a “High Electrification Sensitivity Scenario” focused on the year 2035 and using the IEPR Additional TE demand scenario. Tesla agrees the end date and demand scenario make sense, as 2035 is date for the state’s 100% ZEV goal, and the Additional TE scenario features a policy-driven demand forecast.

In conducting this study, Tesla further recommends that CAISO give special consideration to transmission needs to serve DC fast-charging sites along travel corridors for light, medium and heavy-duty vehicles. We look forward to evaluating the results of the study at the September stakeholder meeting.

6. Please provide your organization’s comments on the CAISO’s study plan for the reduced reliance on Aliso Canyon gas storage special study:

Tesla has no comment on this special study

7. Please provide any additional comments that your organization has:

Tesla has no further comment