Comments on Draft 20-Year Transmission Outlook

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

ACP-California greatly appreciates both CAISO’s vision and the significant efforts it took to complete the 20-Year Transmission Outlook. This is the type of forward-looking analysis that the state needs as it begins to plan for the transition that will be necessary to achieve SB100, retain reliability, and build resilience. The 20-Year Outlook provides a high-level understanding of the transmission backbone that will be needed to support the grid in the long-term, as the clean energy transition enters the next phase. It also provides a critical piece of information for other state agencies to consider and utilize as they undertake their own planning efforts and provides CAISO with useful information on the likely future build out of the transmission system as CAISO looks to approve more near-term transmission projects and upgrades. Notably, CAISO can utilize the 20-Year Outlook to assess whether, of a suite of transmission alternatives, one might provide strategic long-term value and/or whether the size/voltage of a project that is being considered should be increased to better accommodate likely future system needs, which will ultimately help reduce overall ratepayer costs.

CAISO’s 20-Year Outlooks provides a welcome longer-term assessment of the transmission that will be needed to achieve the transition to clean energy. This longer-term view is something that is not achieved via the current Integrated Resource Planning (IRP) process, which has tended to focus on nearer-term needs and had a more myopic focus on reducing transmission expansions. ACP-California strongly encourages the CAISO to work with the CPUC to incorporate 20-year outlook guidance into future cycles of the IRP planning process to better connect procurement and transmission efforts.  The next phase of resource build-out required to meet reliability and SB100 needs will require additional transmission build. It is critical to begin looking further into the future to anticipate what transmission will be needed, optimize the transmission that is required, and more cohesively consider likely generation and transmission build out scenarios, to inform a “least regrets” transmission expansion strategy. The 20 Year-Outlook provides the first step in that process.

It will be critical to ensure that this vital piece of work can be incorporated into and further considered within longer-term actionable processes to help put the state on a proactive path to authorizing transmission and procurement. CAISO should consider how it can utilize the results of the 20-Year plan in future TPP cycles and how the results may influence CAISO’s policy-driven transmission planning processes. In particular, the results of the 20-year Outlook could be used to help assess whether additional or expanded transmission upgrades may be necessary in upcoming TPPs in light of the longer-term expectations of the system. To that end, one suggested refinement in developing the Final 20-Year Outlook is to add the estimated time to complete the upgrades to the existing CAISO footprint shown in Table 5.4-2, since this information could be valuable for prioritizing projects in future TPP cycles.

ACP-California hopes that the 20-Year Outlook is the beginning of improved interagency coordination in the state and of a longer-term, more forward-looking approach to transmission evaluations and approvals.  This work represents an important step for the state as it enters the next phase of the clean energy transition.

2. Comment on chapter 1 Introduction:

NA

3. Comment on chapter 2 Coordination with State Agencies:

NA

4. Comment on chapter 3 Process and Inputs:

NA

5. Comment on chapter 4 Integration of Resources:

NA

6. Comment on chapter 5 High-Level Assessment:

NA

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on the Draft CAISO 20-Year Transmission Outlook (20-Year Outlook, hereafter), dated January 31, 2022.  The comments and questions below also address the material presented at the CAISO Stakeholder meeting on February 7, 2022. BAMx acknowledges the significant effort of the CAISO staff to develop the 20-Year Outlook.

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

In order to understand the TAC impact of the projects the CAISO management may recommend for approval as part of the current planning process, BAMx developed a High Voltage Transmission Access Charge (HV TAC) forecast for the period of 2023-2036. The HV TAC is expected to be approximately $47/MWh in 2036 relative to the existing $16.60MWh, a 190% increase in the 14-year timeframe. These HV TAC projections show the extraordinary impact building and paying for the projects proposed by the plan would have on the ever-increasing CAISO-wide HV TAC. Hopefully, it will motivate decision-makers concerning the construction of these facilities to avoid approving excessive transmission projects and be careful about the selected transmission cost recovery options.

BAMx strongly supports the CAISO analysis that distinguishes between those costs that are presumed to be recovered through the CAISO TAC and those that do not. BAMx supports concepts like the subscriber model. Besides reducing the impact on the TAC, it promotes cost causation as a recovery mechanism for those projects needed to deliver out-of-State (OOS) and offshore wind (OW) generation projects. BAMx believes such a mechanism ensures Load Serving Entities (LSEs) choose to buy power from the most cost-effective projects. Concerning OOS transmission projects, the 20-Year Outlook observes that the Sunzia and TransWest Express (TWE) projects are being developed on a subscriber basis. That is, without the need for recovery of costs through the TAC, to provide transmission service to resources seeking access to California markets.[2] BAMx believes that the subscriber model could apply to the remaining OOS projects. Besides promoting cost causation cost recovery for OOS projects, it also fosters cost recovery via OOS entities that may benefit from installing these projects.

BAMx requests that the CAISO provide valuable input on transmission cost, scope, and related environmental impact to the Bureau of Ocean Energy Management (BOEM) and encourage them to take those aspects into account as they refine their findings concerning Call areas which they prioritize for offshore leasing and development activities.

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

[2] 20-Year Outlook, p.55.

2. Comment on chapter 1 Introduction:

The 20-year outlook provides:

• A process to develop transmission information responsive to supporting and informing the CPUC’s Integrated Resource Planning processes, the CEC’s Integrated Energy Policy Report and the joint agencies’ SB100 efforts.[1]
• Longer-term context for and framing of issues in the 10-Year Transmission Plan

BAMx notes that the 20-Year outlook is not a tariff-based project approval process that focuses on project approvals. Instead, it is meant to engage with stakeholders in a more informal discussion.[2] Therefore, we should not draw any concrete conclusions based upon the need for transmission development identified by looking at one specific future, i.e., SB100 Starting Point scenario, envisioned in the 20-year outlook.

[1] Senate Bill (SB) 100 establishes a policy that renewable and zero-carbon resources supply 60

percent of California’s retail sales and electricity procured to serve all state agencies by 2030,

and 100 percent by 2045.

[2] 20-Year Outlook, p. 5.

3. Comment on chapter 2 Coordination with State Agencies:

BAMx supports the joint agency coordination efforts in selecting the best options to meet the State’s goals as laid out by SB 100, but emphasizes the need for transmission cost containment mechanisms to manage the sky-rocketing CAISO-wide transmission access charge (TAC) as outlined below.

4. Comment on chapter 3 Process and Inputs:

No comments at this time.

5. Comment on chapter 4 Integration of Resources:

BAMx acknowledges and appreciates the significant efforts undertaken by the CAISO in mapping solar resources to the specific substations within each of the transmission zones identified in the SB100 Starting Point scenario.

6. Comment on chapter 5 High-Level Assessment:

Need to Incorporate All Transmission Cost

The 20-Year Outlook has done a tremendous job at providing the cost estimates associated with different types of transmission, including upgrades to the existing CAISO footprint, OW integration, and OOS wind integration. However, we believe the 20-Year Outlook is missing the costs associated with some system upgrades required for starting point generation interconnection, such as the Wheeler Ridge –Kern 230 kV DCTL Project and the Kramer –Victor –Lugo Path Upgrade Project.[1] More importantly, the 20-Year Outlook does not distinguish between “gen-tie” facilities and network facilities in accessing OW.

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

Need to Fully Understand the Extent of TAC Impact

The 20-Year Outlook does not include an estimate of future HV TAC at this time. Given the need to show the TAC impact of the projects the CAISO has recommended for approval as part of the current planning cycle, BAMx developed an HV TAC forecast for 2023-2036, as shown in the figure below. In this analysis, BAMx used the last version of the CAISO’s TAC Estimating model developed for 2020-2021 Transmission Planning Process (TPP) and updated the model to include the CAISO January 01, 2022, TAC Rates (updated as of February 8, 2022). BAMx first added the projects CAISO has recommended for approval as part of the 2021-2022 Draft Transmission Plan.^[2] BAMx then incrementally added the transmission projects identified in the 20-Year Outlook[3], namely $10.4 billion of upgrades to the existing CAISO footprint, $8.11 billion for OW integration and approximately $9.95 billion for OOS wind integration[4].

The 20-Year Outlook has identified the transmission cost for the SunZia project as $2.6 billion. However, half of the project, i.e., 1,500 MW share of the 3,000 MW, is subject to the subscriber model. Therefore, only the remaining half of the project funded by the CAISO TAC, i.e., $1.3 billion, should be considered. Also, as the Draft Plan states that the TransWest Express (TWE) project is being developed on a subscriber basis, without the need for the CAISO transmission plan approval, to provide transmission service to resources seeking access to California markets.[5] In particular, out of the three segments of the TWE project, only half of the two segments would use a subscriber model. In other words, out of nearly $2.18 billion, nearly $1.71 billion would ultimately be recovered from the CAISO ratepayers.[6] Therefore, BAMx’s TAC projections assume the capital costs associated with the SunZia and TWE projects as $1.3 billion and $1.71 billion, respectively.

BAMx developed a preliminary HV TAC forecast for 2023-2036, as shown in Figure 1 below. In this analysis, BAMx used the last version of the CAISO’s TAC Estimating model developed for the 2020-2021 TPP, and updated the model to include the CAISO January 01, 2022, TAC Rates (updated as of February 8, 2022). The newly added capital expenditures associated with the transmission projects was based on the transmission projects found to be needed in the 2021-2022 TPP as per the Draft Plan[7] and for transmission development to integrate the resources in the SB100 Starting Point scenario as included in the 20-Year Outlook.[8]

Figure 1: Transmission Capital Expenditures and HV TAC Projections with CAISO 20-Year Outlook: 2023-2036

As shown in Figure 1 above, the HV TAC is expected to be as high as approximately $47/MWh in 2036 relative to the existing $16.60MWh, a 190% increase in the 14-year timeframe.[9] These HV TAC projections show the extraordinary impact these projects will have on the ever-increasing CAISO-wide HV TAC and further justify the need to avoid approving excessive transmission projects while identifying mechanisms, such as the subscriber model to soften the rapid TAC impact.

Need to Look into Transmission Cost Containment Mechanisms

As stated above,  BAMx strongly supports the subscriber model to access OOS and OW. The economics of the OOS transmission should be based upon the Seller’s ability to access existing transmission or purchase transmission from developers of that transmission. To perform a systematic comparison of the transmission cost impact of the OOS transmission, the following transmission cost allocation principles should be applied. The fundamental principle for cost allocation is that it should be allocated in a way that is commensurate with benefits. In particular, the LSEs within the Local Regulatory Authorities (LRAs) approving resource procurement that are benefiting from the OOS resources should pay for that transmission delivering those resources to the CAISO border. BAMx believes that having the supplier build in its cost of delivering its product to the CAISO will also improve its ability to deliver its product to the WECC-wide grid optimally. This mechanism ensures that buyers of the remote generation will have the transmission costs outside of the CAISO captured in the power purchase agreement (PPA) pricing. This will also help accomplish the first principle of FERC Order 1000, that is, costs are allocated in a way that is roughly commensurate with benefits. Broadly, LSEs voluntarily procuring resources using transmission should pay for the cost of delivery. Besides promoting cost causation cost recovery for OOS projects, it also fosters cost recovery via OOS entities that may benefit from having these projects built.

BAMx believes that the subscriber model should be applied to the remaining OOS projects and would have a tremendous positive impact in containing the ever-growing TAC. For example, as shown by Figure 2 below, if all transmission projects to access OOS wind envisioned in the 20-year outlook are subject to the subscriber model, nearly $9.95 billion of transmission costs will not be recovered via CAISO-wide TAC. As a result, the projected CAISO-wide HV TAC in 2036 would reduce from $47/MWh to $40/MWh.

Figure 2: Transmission Capital Expenditures and HV TAC Projections Subjecting All OOS Transmission Projects to Subscriber Model: 2023-2036

And as we explore the need for the transmission to access OW, State policy-makers and decision-makers need to apply the subscriber model for transmission to access OW, which should also positively affect containing the TAC.

CAISO Should Promote Considering Transmission Cost and Environmental Impact To Influence the Process of Prioritizing Offshore Wind Call Areas

Development of wind energy areas on the Outer Continental Shelf (OCS) typically begins with the federal BOEM identifying potential OW planning areas or wind energy areas (WEAs), and then identifying and reaching out to stakeholders that may be affected in the vicinity of the potential WEA.[10] The Task Force and stakeholder outreach process is used to refine the potential lease areas prior to issuance of the Call for Nominations and Information (Call) that is published in the Federal Register. The Call allows developers to document the interest in obtaining wind energy lease areas and for the public to comment on the areas and their potential concerns. The Call for the California planning areas was issued in October 2018, and multiple developers, local and state agencies, concerned industries and NGOs responded and provided their interests or concerns. Since that time, BOEM has continued its stakeholder outreach efforts and has conducted environmental analyses that will be used to support the next step, the preparation of a National Environmental Policy Act (NEPA) Environmental Assessment (EA) that has to be completed prior to a lease auction and before the formal federal permitting process can begin.[11]

In the past, there have been efforts to examine multiple transmission pathways to access the most viable routes from Central Coast and North Coast projects.[12] However, they have not been as robust as the CAISO 20-Year Outlook that not only captures the multiple transmission pathways to access both Humboldt and Morro Bay/Diablo area OW resources, but also identify the additional in-CAISO infrastructure upgrades that are required to accommodate the OW. In particular, the CAISO’s findings illustrate how dramatically different transmission costs could be. The CAISO has estimated the 6,000MW of resources in the Diablo – Morro Bay OW area trigger the need for only $0.11 billion of transmission upgrades, whereas only 4,000MW of offshore wind in the Humboldt Bay would require as high as $5.8-$8.0 billion of transmission upgrades.[13]

BAMx requests that the CAISO provide valuable input on transmission cost, scope, and related environmental impact to the BOEM and encourage them to take those aspects into account as they refine their findings concerning Call areas which they prioritize for offshore leasing and development activities.

[1] 20-Year Outlook, pp. 37-38.

[2] Draft Plan, pp.377-378.

[3] 20-Year Outlook, p. 57

[4] The amounts identified in 20-Year Outlook, p. 55-56 for TransWest Express were reduced by $400 million, where the cost estimate for SunZia was reduced by $1.3 billion.

[5] Draft Plan, p.7.

[6] Draft Plan p. 306.

[7] Draft Plan, pp.377-378.

[8] 20-Year Outlook, p. 54-56.

[9] This preliminary HV TAC forecast (first Y-axis) assumes a sample schedule for transmission upgrades (second Y-axis), as shown in Figure 1. It does not consider high electrification load projection by 2040 assumed in the 20-Year Transmission Outlook.

[10] Offshore Wind Industry Responses to Questions from Staff of the California Public Utilities Commission

(Prepared by Offshore Wind California, American Clean Power – California, and Individual Companies)

March 2021, p.13.

[11] Ibid.

[12] Offshore Wind Industry Responses to Questions from Staff of the California Public Utilities Commission

(Prepared by Offshore Wind California, American Clean Power – California, and Individual Companies)

March 2021, pp.23-26.

[13] 20-Year Outlook, p. 55

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

The California Community Choice Association[1] (CalCCA) applauds the California Independent System Operator’s (CAISO’s) development of the 20-year Transmission Outlook. This work will be critical in ensuring the state is prepared to meet Senate Bill (SB) 100[2] goals that require renewable energy and zero-carbon resources to supply 100 percent of electric retail sales to end-use customers by 2045. CalCCA commends the CAISO on its collaboration with other agencies, particularly around land use mapping. In the next Transmission Planning Process (TPP) cycle and future iterations of the 20-year Transmission Outlook, the CAISO should consider transmission needed to import out-of-state geothermal resources from Nevada into California.

[1]          California Community Choice Association represents the interests of 23 community choice electricity providers in California: Apple Valley Choice Energy, Central Coast Community Energy, Clean Energy Alliance, Clean Power Alliance, CleanPowerSF, Desert Community Energy, East Bay Community Energy, Lancaster Choice Energy, Marin Clean Energy, Orange County Power Authority, Peninsula Clean Energy, Pico Rivera Innovative Municipal Energy, Pioneer Community Energy, Pomona Choice Energy, Rancho Mirage Energy Authority, Redwood Coast Energy Authority, San Diego Community Power, San Jacinto Power, San José Clean Energy, Santa Barbara Clean Energy, Silicon Valley Clean Energy, Sonoma Clean Power, and Valley Clean Energy.

[2]             Senate Bill 100 California Renewables Portfolio Standard Program: Emissions of Greenhouse Gases: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100.

2. Comment on chapter 1 Introduction:

CalCCA has no additional comments at this time.

3. Comment on chapter 2 Coordination with State Agencies:

CalCCA commends the CAISO on its collaboration with the California Public Utilities Commission (CPUC) and the California Energy Commission (CEC) in the Integrated Resource Plan (IRP), SB 100, and Integrated Energy Policy Report (IEPR) processes. In particular, CalCCA supports the 20-year Transmission Outlook’s consideration of key environmental and land use impacts provided by the CEC. By incorporating these considerations into transmission planning, the CAISO, the CPUC, and the CEC can help steer projects to less sensitive areas and avoid potentially serious delays or cancellations of transmission projects needed to integrate future resource procurement.

4. Comment on chapter 3 Process and Inputs:

CalCCA has no additional comments at this time.

5. Comment on chapter 4 Integration of Resources:

In these comments, CalCCA reiterates its comments to the Draft 2021-2022 Transmission Plan on sufficiently considering the opportunities provided by out-of-state long-lead-time resources, which state:

It is critical the TPP reflects current geographic and market information to allow for the development of significant amounts of cost-effective resources in line with CPUC procurement requirements and to avoid stranded resource investments. CalCCA’s Reply Comments[1] to the CPUC’s Proposed Decision Adopting the 2021 Preferred System Plan[2] urged the CPUC to update the Preferred System Plan (PSP) Core Portfolio to reflect the availability and location of cost-effective resources (i.e., “long-lead-time resources” that can fulfill the CPUC’s Mid-term Reliability (MTR) requirements), including geothermal resources, in Nevada.

The 20-Year Outlook includes roughly 2 gigawatts (GW) of geothermal from IID, but only 320 megawatts (MW) of geothermal in southern Nevada.  The busbar mapping in the Decision Adopting the 2021 Preferred System Plan[3] increases the amount of geothermal in southern Nevada to 440 MW.  At a minimum, the CAISO should reflect this increase in their 2022-2023 TPP and in the next iteration of the 20-Year Transmission Outlook.  However, given the timeframe of the 20-Year Transmission Outlook, the CAISO should include the full potential for growth in Nevada geothermal that far exceeds 440 MWs. CalCCA requested the CPUC update the PSP to plan for at least 2,000 MW of further incremental renewable resources imported from Nevada. The CAISO should study the full 2,000 MWs requested by CalCCA in its comments to the PSP in the 2022-2023 TPP cycle and the next iteration of the 20-year Transmission Outlook allow the CAISO to evaluate necessary import expansion or transmission upgrades needed to deliver Nevada geothermal resources to California.

Given the significant resource development opportunities out of state, the CAISO should also provide additional transparency on how transmission upgrades identified in the TPP will affect maximum import capability (MIC) needed for load-serving entities (LSEs) to show resources out of state as resource adequacy (RA). LSEs must secure MIC at the right nodes to be able to use out-of-state resources like Nevada geothermal to provide RA capacity.  Understanding how the TPP and 20-year plan will affect import capability at specific nodes would significantly improve LSEs’ ability to make decisions around contracting and arranging transmission for potential projects to serve California load as RA.  This transparency will minimize the risk of planned projects failing to materialize and minimize costs associated with the uncertainty around available MIC.

[1]             California Community Choice Association Reply Comments on the Proposed Decision Adopting 2021 Preferred System Plan, Jan 19, 2022 (Rulemaking (R.) 20-05-003): https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M443/K010/443010067.PDF.

[2]             Proposed Decision Adopting 2021 Preferred System Plan, Dec 22, 2021 (R.20-05-003): https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=434547053.

[3]             Decision Adopting 2021 Preferred System Plan, Attachment A Modeling Assumptions 2022-2023 TPP, Feb 10, 2022 (R.20-05-003): https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M451/K485/451485713.PDF.

6. Comment on chapter 5 High-Level Assessment:

CalCCA has no additional comments at this time.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

CESA strongly supports the CAISO’s development and publication of the Draft 20-Year Transmission Outlook, which will provide greater insight and direction on not only the costs and magnitude of the opportunities and challenges ahead, but also inform how the CAISO, along with the California Public Utilities Commission (CPUC) and California Energy Commission (CEC), need to reform their processes, frameworks, and tools to meet long-term decarbonization goals. In sum, our comments highlight areas of potential follow-on effort and clarifications to the assumptions and details of the outlook study, as well as seeking ways to make the Draft 20-Year Transmission Outlook more actionable in the future rather than merely conceptual.

2. Comment on chapter 1 Introduction:

CESA appreciates the CAISO’s analysis of transmission needs to support a longer-term timeframe (20 years), beyond what is typically examined in the Transmission Planning Process (TPP). As the CAISO explains, the analysis focuses on potential project approvals that are overlooked in the tariff-based project approval process.[1] However, in recognizing this, CESA recommends that the CAISO consider how the 20-year transmission outlook results could be something more than a “directional” study and be implemented in practice with actual project approvals and transmission buildout. This may come in the form of modified tariff authority to approve projects on a longer-term forward-looking timeframe, or it could fall within the current tariff authority and come in the form of more aggressive near-term (i.e., 10-year) outlook and resource portfolios from the California Public Utilities Commission (CPUC) Integrated Resource Planning (IRP) process.

On this latter option, in other words, a more aggressive 2030 (or other 10-year in future years) portfolio could be submitted by the CPUC in order to identify and build policy-driven needs to reflect the transmission infrastructure needed to accommodate longer-term resource portfolio needs. Even though the larger portfolios are not needed until after the 10-year timeframe, the CAISO can avoid rapid transmission buildout needs and identify the need to approve and build larger transmission upgrades that will likely have long lead times and more readily accommodate future generation and energy storage in the 2032-2045 time period. Otherwise, the current TPP framework will focus on smaller transmission upgrades and/or put the state in a difficult situation of ramping up resource and transmission buildout on an incremental and year-by-year basis,[2] which may be sub-optimal in the long term. CESA understands that some of this coordination and alignment between procurement and planning processes will be considered in Phase 2 of the Interconnection Process Enhancements (IPE) Initiative, such as in terms of how generator and energy storage interconnection can leverage the transmission upgrades built to support these policy-driven needs.

Furthermore, CESA observes that the 20-Year Transmission Outlook focused on the high-voltage bulk transmission, with future consideration of local transmission needs as well.[3] CESA wholly agrees and underscores the importance of closing this gap in the IRP and longer-term Senate Bill (SB) 100 portfolio modeling processes, which focus on system-level needs and currently overlook local resource needs. By falling short in this regard, CESA is concerned that total resource costs are not minimized or optimized to procure identify, map, and allocate resources in a way that can support system and local reliability needs from the same resource. Without such co-optimization, system-level transmission needs may be inflated beyond what is necessary while procurement for new-build generation and energy storage resources could be duplicative through siloed procurement from system needs separate from local needs. While the CAISO can only study what the CPUC submits to them in the form of resource portfolios, CESA also notes that natural gas retirements may also not be optimized without the selection and optimal allocation of generation, battery storage, and long-duration energy storage (LDES) resources.

[1] Draft 20-Year Transmission Outlook at 5.

[2] Ibid at 6.

[3] Ibid at 3.

3. Comment on chapter 2 Coordination with State Agencies:

CESA supports the continued collaboration across the state agencies, which will play a critical role in ensuring that forecasting, resource procurement, and transmission infrastructure buildout are coordinated and aligned in ways to realize what is needed to meet the state’s SB 100 goals and objectives. Many of our comments and recommendations related to cross-agency coordination is addressed in our response to Question 2.

4. Comment on chapter 3 Process and Inputs:

Given the lack of granularity of the system-level outputs of the CPUC’s IRP and Joint SB 100 study process, the CAISO discussed how load forecasts and resource additions were allocated to support an assessment of transmission investments needed to meet 20-year forward needs. Overall, while appreciative of the CAISO’s methodological overview and recognizing the challenges in this process, CESA believes that improved and more granular inputs from the CEC and CPUC are needed to better guide the CAISO and to facilitate a transition for this 20-Year Transmission Outlook from a conceptual plan to one that is actionable with project approvals and buildout. Most likely, this issue would fall outside of the CAISO’s process alone, so we support continued follow-on effort through the Joint Agencies’ SB 100 study process.

First, on the allocation of the high electrification load projection in 2040, the CAISO describes an “across-the-board” scaling of the load consistently across all busbars.[1] Using what was available to the CAISO, CESA understands that a more granular consideration to better reflect likely outcomes of end-use electrification by location or zone, but this is a clear area of improved coordination with the CEC and the distribution utilities – the latter who currently use the CEC’s IEPR forecast to disaggregate system forecasts for distribution planning purposes.[2] A feedback loop of sorts for approaches to disaggregate system forecasts for both load and behind-the-meter generation and storage should be fed back to the system level for the purposes of transmission modeling.

Second, for the mapping of battery energy storage resources, the CAISO started with the allocation already applied for the 2021-2022 TPP base case and then allocated the remaining unallocated battery energy storage (representing the incremental additions in the 2030-2040 period) that “expands upon the approach from the 2021-2022 TPP base case.”[3] Clarification is needed on the battery energy storage mapping method, where it is unclear if the CPUC’s storage busbar mapping methodology (updated as of July 26, 2021) apply to these incremental unallocated resources, or if the sub-bulleted method applies where storage is co-located in transmission zones where renewable resources are concentrated and storage is otherwise allocated based on system needs identified in the study.[4] In other words, CESA is currently unclear on whether the 20-Year Transmission Outlook mapped the remaining unallocated 2030-2040 battery energy storage resources by extrapolating the CPUC’s most recent busbar methodology, which prioritized available transmission headroom and commercial interest, and then allocated storage resources on a rank order of substations in Local Capacity requirement (LCR) areas, disadvantaged communities (DACs), non-attainment status areas, and high-curtailment areas. By contrast, the sub-bullets list co-location with renewables in transmission zones or allocation based on system needs, where it is unclear whether this is incremental to the CPUC existing methodology or in place of the CPUC methodology. CESA requests that the 20-Year Transmission Outlook detail the allocation methodology rather than merely citing or having to cross-reference a method from a separate planning process.

Regardless, given that energy storage represents a location-flexible asset class on the most part, CESA raises a number of questions regarding the methodology that warrants further review, such as around the following:

• Commercial interest: If this criterion applies, it is unclear whether, how, or the degree to which the current interconnection queue is reflective of optimal needs on a 20-year outlook basis since it is likely responsive to mid-term and potentially 10-year resource procurement needs. Commercial interest may be an appropriate criterion for a 10-year outlook, but it is worthwhile exploring whether different priority criterion should apply on a 20-year basis. As evidenced from the discussion in the IPE Initiative, the current Queue Cluster (QC) 14 supercluster appears to have generated a significant pileup of applications that may not necessarily be tied to existing or available transmission headroom, suggesting that there is some level of “strategic” coordination of resource interconnection and transmission planning that needs to be worked out or better signaled through more transparent or helpful transmission planning data.
• Co-location with renewables: CESA does not dispute the economic incentives in place through the Federal Investment Tax Credit (ITC), the cost savings of sharing facility costs and deliverability, and the system benefits of reducing congestion, but it is unclear on whether and how this approach[5] co-optimizes for LCR need, and/or whether this criterion is duplicative of the commercial interest criterion. In addition, follow-on efforts should be responsive to the potential adoption of a standalone energy storage ITC, which, if adopted, should be reflected in future revisions to the 20-Year Transmission Outlook.
• Duration: CESA understands that battery energy storage resources selected through RESOLVE in the IRP and SB 100 study processes have their duration optimized via the capacity expansion modeling. This means that battery storage resources can have differing durations across study years. For the purposes of mapping for long-term transmission needs, it may be helpful to understand how the duration of these battery energy storage resources selected in the IRP and SB 100 studies factor into the transmission mapping process, if at all. This may inform the characteristics of resources in particular locations that could impact resource retirements and optimize transmission buildout investments.

Third, similar to the specifications requested for battery energy storage resources, CESA requests more detail and specification around the mapping methodology for LDES resources, such as whether and the degree to which the battery energy storage mapping methodology applies. In addition, one of the challenges of the LDES selection in the IRP and SB 100 study processes is that pumped hydroelectric storage (PHS) is used as a proxy for LDES, which has locational constraints and is detailed in the 20-Year Transmission Outlook as accounting for “geologic and technological factors” in addition to system needs.[6] However, the use of PHS as a proxy should not be used to assume LDES is locationally constrained, particularly for the “unconstrained LDES” that is currently unassigned for the purposes of this outlook report. Rather, the allocation criteria should focus on system and local need. CESA also seeks clarification on whether mapping could also be guided by projects currently in the CAISO interconnection queue, which is cited as 2,400 MW PHS, but to our knowledge, there should be additional non-PHS LDES projects in the current queue as well that warrants attention and mapping in the 20-Year Transmission Outlook.

[1] Ibid at 16.

[2] See R.14-08-013 where disaggregation methodologies were adopted.

[3] Ibid at 21.

[4] It is unclear if the “study” is referring to the 20-Year Transmission Outlook or some other study, and what “system need” entails.

[5] Draft 20-Year Transmission Outlook at 36.

[6] Ibid at 21.

5. Comment on chapter 4 Integration of Resources:

CESA has no comment at this time on Chapter 4 related to the mapping of solar, wind, and geothermal resources.

6. Comment on chapter 5 High-Level Assessment:

The high-level assessment in the 20-Year Transmission Outlook details how the resource deliverability study methodology – i.e., high system need (HSN), secondary system need (SSN), and off-peak – would apply to identify the transmission buildout required to support future generation needs.[1]  CESA strongly supports this high-level assessment, which captures how energy storage would rationally operate, charging during the SSN and off-peak periods and discharging during the HSN period. Notably, as CESA understands it, the assumptions for the HSN and SSN cases have been modified as it relates to energy storage operations, which is no longer assumed to be discharging during the SSN periods and only studied for discharge and on-peak deliverability during the HSN periods. Given these improvements and better alignment with expected and rational storage operations, we request the CAISO to incorporate similar assumptions for energy storage operations in the upcoming 2022-2023 TPP cycle to inform policy-driven assessments.

As a further refinement in future revisions of this outlook, CESA also notes that the CAISO has adopted an off-peak deliverability status (OPDS) assessment methodology; when combined with the CPUC’s consideration of slice-of-day (SOD) reform, it opens up the possibility of studying and identifying long-term transmission needs of renewable generation with OPDS and energy storage resources that are more flexibly located without necessarily hybridizing or co-locating energy storage behind the same point of interconnection (POI). There may be efficiencies gained in some circumstances.

[1] Ibid at 35.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

• CPUC staff appreciates the CAISO conducting this important study and looks forward to collaborating with the CAISO and CEC on next steps such as a roadmap or project prioritization approaches. We believe that understanding least regret pathways will be crucial to achieving state policy goals while minimizing ratepayer costs.
• CPUC staff encourages the CAISO to include additional details/estimates regarding the studied transmission to allow for effective application of this study.
• CPUC staff requests that the CAISO share the geographic allocation of the 37,000 MW of battery storage and the 4,000 MW of long duration energy storage (LDES) included in the starting portfolio.
• CPUC staff commends the CAISO’s high-level explanation of the alternatives and possible sequencing of transmission build as the amount of offshore wind resources expand and the location of such resources are better identified.

2. Comment on chapter 1 Introduction:

CPUC staff appreciates the CAISO conducting this important study and looks forward to collaborating with the CAISO and CEC on next steps such as a roadmap or project prioritization approaches. CPUC staff encourages the CAISO to include additional details/estimates regarding the studied transmission to allow for effective application of this study.

The executive summary states “The transmission additions are significant investments, and for a number of these additions, lead times of eight to 10 years are reasonable or even optimistic.” The question that needs to be answered next is considering the long lead times, how do we ensure that the necessary transmission is online by 2040? Sequencing of the transmission development will be necessary and will likely have to begin in the near future.

In May 2021[1], CPUC staff provided suggestions on how to ensure the final product is useful including "a roadmap that could easily be used over the coming years to assess whether we are roughly on track to meet SB 100.” Organizations can collaboratively use the 20-Year Outlook information to develop appropriate next steps, such as utilization of this information to inform resource planning, and prioritization of transmission development. Below are two examples of potential prioritization approaches:

•  Prioritization of most urgent transmission: This can take into consideration
  • Timing of planned resource build out
  • Expected duration of the transmission development
  • Dependencies between transmission projects (E.g. CAISO footprint[2] upgrade X may need to be online before the 5th GW of OOS resources is injected into CAISO)
• Prioritization of least regret projects: Identification of transmission improvements that can be considered least regrets based on a range of SB 100 scenarios (E.g. CAISO footprint Y is necessary if 10 GW of OOS resources are injected, but is also necessary if only 6 GW of OOS resources are injected).

In order to ensure the above can be accomplished, CPUC staff encourages the CAISO to include the following in the final report:

• estimates of project construction time
• estimates on how much these projects could expand transmission capacity in the areas/transmission constraints they impact
• interdependencies between projects
• any other information that can assist with sequencing

CPUC staff looks forward to collaborating with the CAISO, the CEC, and other stakeholders to develop the above-described prioritization approaches. We believe that understanding least regret pathways will be crucial to achieving state policy goals while minimizing ratepayer costs.

[1] Available at the CAISO Stakeholder Center under “view comments” for the 5/14 web meeting,  https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/20-Year-transmission-outlook

[2] As used in the “20-Year Outlook” draft. See Table ES-1 for an example.

3. Comment on chapter 2 Coordination with State Agencies:

CPUC staff requests that the CAISO share the geographic allocation of the 37,000 MW of battery storage and the 4,000 MW of long duration energy storage (LDES) included in the starting portfolio.

• Section 3.1.4 explains that of the 37,000 MW of selected battery energy storage, 9,368 MW was already allocated in the IRP resource portfolio for the 2021-22 TPP base case and was carried over into the 20-Year Outlook Study without any changes. The remaining 27,632 MW of battery storage not already allocated by the CPUC IRP portfolio was to be allocated by the CAISO in the following manner: Co-locating in transmission zones where renewable resources are concentrated.

• Allocating battery storage based on system needs identified in the study.

The final allocation of stand-alone and co-located batteries by resource zone should be included in the final report. If battery storage was allocated to a certain location based on transmission needs identified in the study that should be noted, as well as any information regarding the specific transmission need.

Similarly, the geographic allocation of the unassigned 1,600 MW of the total 4,000 MW of LDES should be shared. Section 3.1.5 explains that “1,600 MW of location unconstrained LDES that is unassigned should be assigned to transmission zones based on a combination of geologic and technological factors and system needs.”

4. Comment on chapter 3 Process and Inputs:

 No response at this time.

5. Comment on chapter 4 Integration of Resources:

CPUC staff commends the CAISO’s high-level explanation of the alternatives and possible sequencing of transmission build as the amount of offshore wind resources expand and the location of such resources are better identified.

The CAISO’s long-term assessment of possible offshore wind interconnection to the California grid identifies (at a high level) an orderly progression of transmission build as the amount of offshore wind resources increases and the locations of additional BOEM wind energy areas of the north coast are better defined. The CAISO further identifies alternative transmission concepts that utilize various technologies. The CAISO also considers advantages of potential configurations like increased transfer capacity with the Pacific Northwest region.

With the sensitivity analysis in this year’s TPP along with the focus on offshore wind development within this 20-year Transmission Outlook, the CAISO has provided helpful information and sufficient assumptions to conduct more useful capacity expansion modeling within the IRP process.  We appreciate the CAISO’s approach for this kind of long-range transmission planning: identifying alternatives, considering a broad range of benefits, recognizing uncertainty and framing the range and scale and cost of transmission that will be needed to realize various levels of offshore wind development. CPUC staff commends the explanation and looks forward to deeper analyses of offshore wind and related transmission needs for integrating renewables into the California grid.  

6. Comment on chapter 5 High-Level Assessment:

Please see response under Question 2.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) provides the following comments on the Draft 20 Year Transmission Outlook.  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 appreciates the significant effort that CAISO Staff put into the development of the 20-Year Transmission Outlook (20-Year Outlook).  This long-term assessment is a valuable addition to California Independent System Operator’s (CAISO) transmission planning process.  As detailed in the questions below, Cal Advocates recommends the CAISO:

• Expand the scope of the 20-Year Outlook to include the financial impact of the proposed $30.5 billion in high voltage transmission project investments on ratepayers;
• Clarify in its update whether the $30.5 billion estimate includes all of the incremental development costs approved (but not yet included in TAC rates) in the current and previous CAISO Transmission Planning Process (TPP) cycles;
• Expand the discussion on the out-of-state transmission options to include regional transmission planning and cost allocation issues; and
• Add the integration of grid forming inverter (GFMI) requirements and associated costs into future updates to the 20-Year Outlook. 

[1] Cal. Pub. Util. Code § 309.5.

2. Comment on chapter 1 Introduction:

Cal Advocates recognizes that the CAISO 20-Year Outlook provides a long-term view of transmission needed to reliably meet California’s clean energy goals and ambitious climate change goals.^[1]

In its 20-Year Outlook, the CAISO identified three major categories of expected upgrades and associated transmission development costs to the CAISO system:

• Substation upgrades, High Voltage Direct Current (HVDC) lines, and 230 kilovolt (kV) and 500 kV Alternating Current (AC) lines (estimated cost of $10.74 billion);
• Out-of-State (OOS) wind integration consisting of 500 kilovolt (kV) AC lines and HVDC lines (estimated cost of $11.65 billion); and
• Offshore Wind (OSW) integration consisting of 500 kV AC lines and HVDC lines (estimated cost of $8.11 billion).

The proposed projects in these three categories have a total estimated cost of $30.5 billion in transmission investments.

Cal Advocates recommends the CAISO expand the scope of the 20-Year Outlook to include the impact of the $30.5 billion estimate on the CAISO High Voltage Transmission Access Charge (TAC) that ratepayers within the CAISO’s balancing authority would bear. 

The CAISO states it will provide an update on its 20-Year Outlook.[2] Cal Advocates recommends the update clarify whether the $30.5 billion estimate includes all the incremental development costs approved (but not yet included in TAC rates) in the CAISO’s current and previous Transmission Planning Process (TPP) cycles. Adding this information will help provide perspective to forecasted TAC rate increases going forward.

Cal Advocates recommends that in future updates of the 20-Year Outlook, the CAISO expand discussion of OOS wind integration to include regional transmission planning and cost allocation issues.  The CAISO notes in the 20-Year Outlook that the Federal Energy Regulatory Commission (FERC) opened an Advanced Notice of Proposed Rulemaking (ANOPR)^[3] to improve its regional transmission planning and cost allocation requirements.^[4]  The CAISO is an active participant in this ANOPR, and submitted comments acknowledging that the existing interregional coordination process is not meeting expectations.^[5]  In its comments, the CAISO also discusses some of the negative financial impacts to ratepayers that can occur due to poor planning, specifically: “Failure to align transmission development and state-directed resource procurement/development can (1) cause overbuilding (unnecessarily increasing costs to ratepayers) and stranded investment (associated with underutilized facilities), and (2) potentially jeopardize receipt of any necessary state siting approvals.”^[6],[7]  Approaches undertaken to achieve the state’s aggressive climate change goals should minimize negative financial impacts to ratepayers.  Therefore, Cal Advocates recommends that the CAISO modify the scope of its 20-Year Outlook to include financial impacts to ratepayers within the CAISO’s balancing authority.

[1]“The 20-Year Outlook is not a tariff-based project approval process that focuses on project approvals. Instead, it is meant to engage with stakeholders in more informal yet meaningful discussion.” Draft 20-Year Transmission Outlook, January 31, 2022.

[2] Draft 20-Year Transmission Outlook, January 31, 2022, p. 3.

[3] Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, FERC, July 15, 2021 (proceeding: RM21-17-000). Hereafter: FERC ANOPR.

[4] “The Federal Energy Regulatory Commission (Commission) is issuing an Advance Notice of Proposed Rulemaking (ANOPR) presenting potential reforms to improve the electric regional transmission planning and cost allocation and generator interconnection processes.” FERC ANOPR, p. 1.

[5] “The CAISO also acknowledged that the interregional coordination process has not met expectations and that there are opportunities to remove certain barriers, foster collaboration with state regulators, and promote more rigor in, and reporting on, interregional coordination efforts.”

[6]  Comments of the California System Operator Corporation on Advance Notice of Proposed Rulemaking, CAISO, October 12, 2021, p. 58. Hereafter: CAISO ANOPR Comments

[7] “It would promote more optimal, streamlined, efficient, and cost-effective transmission development and limit ratepayer cost exposure for network upgrades associated with sub-optimally sited generation.” CAISO ANOPR Comments, p. 53.

3. Comment on chapter 2 Coordination with State Agencies:

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

4. Comment on chapter 3 Process and Inputs:

Cal Advocates has no comments on these topics at this time.

5. Comment on chapter 4 Integration of Resources:

The 20-Year Outlook considers the need for transmission that supports a cumulative generation capacity increase of 90,000 megawatts (MW) of solar, wind, and Battery Energy Storage Systems (BESS).  Cal Advocates recommends the CAISO add the requirements and associated costs to integrate grid forming inverters (GFMIs) into future updates to the 20-Year Outlook.  The Western Electricity Coordinating Council (WECC), Electric Power Research Institute (EPRI), and National Renewable Energy Lab (NREL) have started conducting studies to identify GFMI requirements and costs.  Successful implementation of GFMIs will grow in importance as inverter-based resources, such as solar, wind, and BESS, make up an increasingly larger portion of the state's resource portfolio.

As part of considering GFMI in long-term transmission planning, Cal Advocates recommends the CAISO conduct modeling for control system instability of inverter-based resources under projected resource scenarios.  This modeling is required to better understand the extent that GFMI will be required in a potentially low short circuit strength or low inertia electric transmission system^[1],[2] resulting from a high penetration of inverter-based resources.  The implementation requirements for GFMI, along with its associated costs should be included in transmission cost estimates for inverter-based resources considered in future updates to the 20-Year Outlook.

Additionally, with the decommissioning of various natural gas power plants and the Diablo Canyon Power Plant over the next 10 to 15 years, the CAISO should perform detailed frequency and voltage regulation studies along with the existing thermal overload power flow studies conducted in the 20-Year Outlook to verify if voltage and frequency stabilization functions traditionally provided by synchronous generators can be replaced by inverter-based resources with or without GFMIs.  Going forward, Cal Advocates recommends CAISO to incorporate the findings of these studies into future updates to the 20-Year Outlook.

[1] Integrating Inverter-Based Resources into Low Short Circuit Strength Systems. Reliability Guideline. North American Electric Reliability Corporation. December 2017.

[2] Grid-Forming Inverter Based Resources Workshop. Western Electricity Coordinating Council. October 13, 2021.

Grid Forming Inverters: EPRI Tutorial. EPRI, Palo Alto, CA: 2020. 3002018676.

Lin, Yashen, Joseph H. Eto, Brian B. Johnson, Jack D. Flicker, Robert H. Lasseter, Hugo N. Villegas Pico, Gab-Su Seo, Brian J. Pierre, and Abraham Ellis. 2020. Research Roadmap on Grid-Forming Inverters. Golden, CO: National Renewable Energy Laboratory. NREL/TP-5D00-73476. https://www.nrel.gov/docs/fy21osti/73476.pdf.

Integrating Inverter-Based Resources into Low Short Circuit Strength Systems. Reliability Guideline. North American Electric Reliability Corporation. December 2017.

6. Comment on chapter 5 High-Level Assessment:

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

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

California Western Grid Development LLC Comments on the 20-YEAR TRANSMISSION OUTLOOK

California Western Grid Development, LLC (“California Western Grid”) hereby submits comments on the January 31, 2022, Draft: 2021-2022 Transmission Plan (“21-22 Transmission Plan”); and 20-YEAR TRANSMISSION OUTLOOK (“20-YEAR OUTLOOK”). California Western Grid is developing the proposed Pacific Transmission Expansion Project (“PTE Project” or “PTEP”)[1]and appreciates the opportunity to submit comments on the important issues addressed in those reports.

We applaud the CAISO on its first ever 20-Year OUTLOOK and commend the CAISO for collaborating on it with the California Public Utilities Commission (“CPUC”) and California Energy Commission (“CEC”).[2] This 20-YEAR OUTLOOK fills a need that has hampered the CAISO’s ability to plan and approve the long-lead time transmission that is necessary to deliver new remote clean energy to the major urban load centers located on the coast. And, in this regard, the 20-YEAR OUTLOOK must be read in conjunction with the March 2021 Joint Agency Report to the legislature (“Joint Agency Report”)[3] that determined the amount of new clean energy needed over the longer term to implement SB 100 as well as the types of clean energy needed.

The Joint Agency Report was prepared and filed with the Legislature in 2021 by the CPUC, CEC and California Air Resources Board (“CARB”). The Joint Agency Report concludes that we must triple the resources available to the CAISO grid to meet SB 100 goals.[4]  The Joint Agency Report also identified the types of clean resources needed to meet this enormous need. This identification of the public policy requirement for new clean energy has, in turn, allowed the CAISO to identify the transmission needed to deliver these resources from the remote areas where they exist, or can be developed, to the urban load centers on the coast that are currently transmission constrained. Importantly, the combination of the Joint Agency Report that identifies the SB 100 Public Policy Need and the 20-YEAR OUTLOOK allows the CAISO for the first time to plan and approve the specific long-lead time transmission needed for the CAISO to meet its tariff obligation to plan and approve transmission to meet State Public Policy requirements.[5] 

Up until now, the CAISO lacked a clear picture of the magnitude and timing of the long-term SB 100 State Public Policy need. And the portfolios of resources previously provided to the CAISO were limited to resources needed over a 10-year period. In contrast the Joint Agency Report provides the long-range forecast of resources needed to meet the State SB 100 Public Policy requirements that, in turn, allows the CAISO in its 20-YEAR OUTLOOK to identify the long-lead time transmission that can accommodate those resources. For example, the CAISO’s 20-YEAR OUTLOOK concluded that the PTE HVDC line from Diablo to LA is one of the projects that will be needed.[6]

Importantly, the CAISO, starting in the 2022-2023 Transmission Planning Process (“TPP”), will be able to plan and approve the specific long-lead time transmission facilities that are needed to deliver new clean energy to transmission constrained areas like the Los Angeles Basin (“LA”) that are currently required to rely completely on local fossil units.

In the 21-22 Transmission Plan the CAISO has set the stage by approving $1.5 billion of significant public policy  transmission  projects along with  two HVDC projects in the San Francisco Bay Area that are above and beyond the short-term transmission solutions that have been relied on in the past.[7]  As the CAISO indicated in its 20-YEAR OUTLOOK, the 21-22 Transmission Plan is a “transitional” plan[8] leading to a new era of longer-term transmission planning that is essential to implement SB 100 and other State Public Policy Requirements.

Now, in the 2022-2023 TPP the CAISO, for the first time, can turn to long-lead time projects needed in areas like LA that are transmission constrained. The CAISO has confirmed once again that the long 10 year or more lead- time needed to plan, approve, permit, and construct transmission requires that the CAISO act now to plan and approve new transmission identified in its 20-YEAR OUTLOOK to ensure that it is available when needed. [9]  California Western Grid requests that the CAISO review and approve transmission projects identified in its 20-year transmission outlook beginning in the 22-23 TPP (and subsequent TPPs) to accommodate the resource needs reflected in the Joint Agency Report. Approving high priority long lead time transmission projects in the 2022-23 TPP is essential to allow an orderly transition to California’s zero carbon future.

The SB 100 and other important State Public Policies are transformative and extremely challenging. The CAISO 20-year outlook created in collaboration with the State agencies is a critical step forward to meet the challenge. California Western Grid appreciates the work of the CAISO and the State agencies and stands ready to assist as needed or appropriate.

Respectfully submitted,

Martin Walicki

On behalf of California Western Grid                

[1] 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, potentially allowing for the replacement of up to 1,993 MWs of thermal plant generating capacity.  The PTE Project is more fully described in Section 4.8.2 of the 21-22 Transmission Plan pp. 278-279.

[2][2] 20-YEAR OUTLOOK pp. 1 and 11.

[3] https://www.energy.ca.gov/news/2021-03/california-releases-report-charting-path-100-percent-clean-electricity

[4] Joint Agency Report at Highlights.

[5] Section 24.4.6.6 of CAISO Tariff.

[6] 20-YEAR OUTLOOK pp. 48-49.

[7] 21-22 Transmission Plan at Table 8.2-2 pp. 377-378.

[8] 20-YEAR OUTLOOK pp. 6-7.

[9] Letter from Elliot Mainzer, Pres. & CEO of CAISO to Assemblymen Chad Mayes and Jordan Cunningham and Senator Melissa Hurtado (Aug. 18, 2021). “[W]e we must keep in mind that it can take ten plus years to plan and build new infrastructure so the time to act is now.” See also, CAISO Comments on Preliminary [CPUC] Scoping Memo, Rulemaking 20-05-003 (Filed May 7, 2020) p. 4.

2. Comment on chapter 1 Introduction:

We applaud the CAISO on its first ever 20-Year OUTLOOK and commend the CAISO for collaborating on it with the California Public Utilities Commission (“CPUC”) and California Energy Commission (“CEC”).[2] This 20-YEAR OUTLOOK fills a need that has hampered the CAISO’s ability to plan and approve the long-lead time transmission that is necessary to deliver new remote clean energy to the major urban load centers located on the coast. And, in this regard, the 20-YEAR OUTLOOK must be read in conjunction with the March 2021 Joint Agency Report to the legislature (“Joint Agency Report”)[3] that determined the amount of new clean energy needed over the longer term to implement SB 100 as well as the types of clean energy needed.

The Joint Agency Report was prepared and filed with the Legislature in 2021 by the CPUC, CEC and California Air Resources Board (“CARB”). The Joint Agency Report concludes that we must triple the resources available to the CAISO grid to meet SB 100 goals.[4]  The Joint Agency Report also identified the types of clean resources needed to meet this enormous need. This identification of the public policy requirement for new clean energy has, in turn, allowed the CAISO to identify the transmission needed to deliver these resources from the remote areas where they exist, or can be developed, to the urban load centers on the coast that are currently transmission constrained. Importantly, the combination of the Joint Agency Report that identifies the SB 100 Public Policy Need and the 20-YEAR OUTLOOK allows the CAISO for the first time to plan and approve the specific long-lead time transmission needed for the CAISO to meet its tariff obligation to plan and approve transmission to meet State Public Policy requirements.[5] 

3. Comment on chapter 2 Coordination with State Agencies:

We applaud the CAISO on its first ever 20-Year OUTLOOK and commend the CAISO for collaborating on it with the California Public Utilities Commission (“CPUC”) and California Energy Commission (“CEC”).[2] This 20-YEAR OUTLOOK fills a need that has hampered the CAISO’s ability to plan and approve the long-lead time transmission that is necessary to deliver new remote clean energy to the major urban load centers located on the coast.

4. Comment on chapter 3 Process and Inputs:

We applaud the CAISO on its first ever 20-Year OUTLOOK and commend the CAISO for collaborating on it with the California Public Utilities Commission (“CPUC”) and California Energy Commission (“CEC”).[2] This 20-YEAR OUTLOOK fills a need that has hampered the CAISO’s ability to plan and approve the long-lead time transmission that is necessary to deliver new remote clean energy to the major urban load centers located on the coast.

5. Comment on chapter 4 Integration of Resources:

Up until now, the CAISO lacked a clear picture of the magnitude and timing of the long-term SB 100 State Public Policy need. And the portfolios of resources previously provided to the CAISO were limited to resources needed over a 10-year period. In contrast the Joint Agency Report provides the long-range forecast of resources needed to meet the State SB 100 Public Policy requirements that, in turn, allows the CAISO in its 20-YEAR OUTLOOK to identify the long-lead time transmission that can accommodate those resources. For example, the CAISO’s 20-YEAR OUTLOOK concluded that the PTE HVDC line from Diablo to LA is one of the projects that will be needed.[6]

Importantly, the CAISO, starting in the 2022-2023 Transmission Planning Process (“TPP”), will be able to plan and approve the specific long-lead time transmission facilities that are needed to deliver new clean energy to transmission constrained areas like the Los Angeles Basin (“LA”) that are currently required to rely completely on local fossil units.

6. Comment on chapter 5 High-Level Assessment:

The SB 100 and other important State Public Policies are transformative and extremely challenging. The CAISO 20-year outlook created in collaboration with the State agencies is a critical step forward to meet the challenge. California Western Grid appreciates the work of the CAISO and the State agencies and stands ready to assist as needed or appropriate.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

CalWEA very much appreciates this holistic planning effort.  To identify an efficient plan, it is essential to plan simultaneously for all system needs.  To further promote efficiency in transmission planning, the CAISO should also take the opportunity to reform its study methodology to reflect the evolution from fossil fuels to clean resources that require updated planning tools.

It is important to recognize that a 20-year plan will almost certainly remain conceptual, given a multitude of uncertainties that will unfold in that timeframe.  Nevertheless, improvements can and should be made so that the final 20-year Transmission Outlook is the best representation possible of current understandings and expectations.

To make real progress towards the long-term plan, it will be essential to develop a stronger bridge between 20-year planning and the annual 10-year TPP cycle than is provided in the draft Outlook, one that provides a firm basis for moving forward with elements of the 20-year transmission plan in the near term. CalWEA outlines a plan to make such progress below. 

2. Comment on chapter 1 Introduction:

Chapter 1 appropriately highlights the need for CAISO to “get in front” of the acceleration of clean energy development.  The chapter states that the 20-year outlook provides a baseline to “establish expectations for longer-term planning.  What is missing is any roadmap for making progress on that baseline in the near-term, which is necessary to truly “get in front” of resource development by building the transmission necessary to enable achievement of the transition to clean energy. In response to question 6 below, CalWEA recommends and describes such a roadmap, while recognizing that, as stated in Chapter 1, “resource planning decisions and procurement decisions will differ over the years ahead from the assumptions used to establish this baseline.”

3. Comment on chapter 2 Coordination with State Agencies:

 No comments.

4. Comment on chapter 3 Process and Inputs:

1. It is not clear why the 2040 Starting Point (“SP”) Scenario differs so much from the resources in the SB 100 resource plan.  Our understanding is that, for example, the SB 100 2045 scenario included 3.2 GW of long-duration storage (vs. 4 GW in the SP Scenario), 4.3 GW of wind (vs. 2.2 GW in the SP Scenario) and 7.6 GW of OOS wind (vs.12 GW in the SP Scenario). 

We are particularly puzzled by the fact that in-state wind and utility solar do not grow between 2031 and 2040.  Also, the 2040 in-state wind figure is significantly lower than the 3.5 GW of additional wind included in the CPUC’s recently adopted Preferred System Plan by 2025.

CAISO should better explain how it arrived at these figures. The report should also include the comparable figures from the SB 100 2040 RESOLVE model in Table 3.1-3.

2. As noted in section 3.1.1, the SB 100 Core scenario includes 33 GW of behind the meter PV.  The Outlook report should note that, unlike the other resources included in the SB 100 resource scenario, BTM PV was not evaluated in the SB 100 RESOLVE model on its merits.  Rather, 33 GW of BTM PV was hard-wired into the model. Thus, compared to other resources, this resource level is particularly subject to change.  Indeed, that figure will be significantly affected by a pending CPUC decision on its net energy metering policy.
3. Similarly, the Outlook report should note that the SB 100 RESOLVE model artificially capped the amount of offshore wind at 10 GW. Cost-effective levels could be higher.
4. The report should revise the assumed locations for the 10 GW of offshore wind. While these locations remain uncertain, it appears fairly likely that development will not occur off the coast at Diablo Canyon given that, while the U.S. Navy has acceded to development off Morro Bay, it has not yet acceded to offshore wind development off the coast at Diablo Canyon due to its military operations there and, in fact, has historically expressed very strong reservations about the impact that such development would have on its military operations.[1] Therefore, the Diablo Canyon offshore wind capacity should be located off the North Coast. We note that additional offshore wind off the North Coast should make transmission development in Northern California more cost-effective on a per-MW basis.  It is also possible that Morro Bay 500-kV switchyard could accommodate as much as 4 GW. 
5. All of these assumptions should be improved as much as possible for the final 2022 20-Year Outlook, along with the development of three distinct resource futures discussed below in response to question 6.

[1] See, e.g., “Outreach on Additional Considerations for Offshore Wind Energy off the Central Coast of California.” https://www.boem.gov/sites/default/files/documents/renewable-energy/state-activities/UPDATED-NOA-Outreach-on-Additional-Considerations_0.pdf 

5. Comment on chapter 4 Integration of Resources:

 No comments (but please see our comments regarding offshore wind, above).

6. Comment on chapter 5 High-Level Assessment:

1. CalWEA supports the storage assumption in the on-peak deliverability assessment.  In assessing the  scenarios, CAISO has made one significant change to the methodology it uses to determine deliverability:  it has assumed that energy storage resources are fully charged, but not producing in the peak consumption study, which corresponds to the Secondary System Need (SSN) test in the CAISO’s on-peak deliverability assessment. CalWEA applauds this modification, which recognizes that when solar generation is abundant, flexible resources are likely to have low output, or even negative (charging) output, to get ready for later hours when fast net-load ramping requirements (corresponding to the HSN scenario) come about.  This realistic assumption will promote more efficient grid utilization although, as explained next, it does not go far enough.

2. Further modifications to CAISO’s deliverability assessment should be made. While we very much appreciate that CAISO has made its on-peak deliverability assessment more realistic, we encourage CAISO consider eliminating the peak consumption (SSN-equivalent) study altogether.   Using the SSN scenario has little to do with delivering resources to load when RA capacity is really needed – during the evening net-peak-load condition (represented by the HSN scenario). The SSN scenario is, instead, focused on avoiding renewable generation curtailment during times of high production from variable energy resources when gross load is also expected to be high but when system need for RA capacity is not critical at all.  Hence, applying the SSN condition will make resources that can offer capacity at the time of high system need for capacity to be deemed Energy Only, thus depriving the state legitimate sources of RA capacity. 

It is important that, as we plan for a major transformation of the grid, we promote the efficient use of the grid, which will significantly reduce the upgrades and associated costs required to interconnect the same amount of capacity.  CalWEA has explained at length elsewhere why the eliminating the SSN test, as well as reforms to the HSN test, are central to that goal.[1]  This reformed methodology should be applied in this and future 20-year outlooks, as we reimagine the future grid. Instead, the methodology – albeit with an important modification -- continues to use a methodology that was designed around fossil and nuclear fuels rather than the resources and technologies that we are now designing the grid for.  The $30 billion estimated cost of the plan could be lowered with more appropriate planning assumptions and a reformed deliverability methodology.

3. Out-of-state transmission assumptions.  CalWEA agrees with the CAISO’s assumption (stated in response to a question on the February 7 stakeholder call) that OOS transmission project costs should be included in the analysis, even if covered by developers, to promote apples-to-apples comparisons among alternatives.  As stated by CAISO, ratepayers will pay for these transmission costs one way or another, and total costs should be included in the CPUC’s assessment of total resource costs in its IRP analyses. This should be explained in the final Outlook report.  (In all cases, however, OOS Tx developers should carry the risk of development costs.) 

4. System upgrade detail.  The estimated interconnection costs for offshore wind and out-of-state wind are identified as $8.11B and $11.65B, respectively. At the same time, many of the transmission system upgrades totaling $10.74B are also attributed, in part, to the delivery of offshore wind and out-of-state wind. It would be useful if the CAISO could provide more information regarding the resource mix driving these system upgrades.

5. Roadmap to near-term progress.  CalWEA appreciates that this conceptual 20-year plan will provide improved inputs for resource planning processes conducted by the CPUC and CEC.  To that end, it is important that the report be adjusted to reflect more accurate and realistic assumptions (as discussed in response to question 4) as much as possible.

As importantly, however, this 20-year planning effort should be aimed more firmly at advancing, in the near-term, elements of the plan that will almost certainly be needed to achieve the state’s SB 100 goals. Along these lines, the draft Outlook states only that “The expanded planning horizon is intended to provide… a longer-term context and framing of pertinent issues in the CAISO’s ongoing annual 10-Year Transmission Plan.” (At p. 56.)   This is an insufficient response to, as the draft Outlook states, the “unprecedented need for new renewable resources over the next 10 to 20 years.”

While any single 20-year plan must realistically remain conceptual, given a multitude of uncertainties that will unfold in that timeframe, incremental, but real, progress towards the long-term plan could and should still be made.  To do that, some upgrades should be selected in each annual TPP cycle that will build towards the 20-year plan. To identify those upgrades, CalWEA recommends that the CAISO work with the CPUC and CEC to develop a least-regrets (essentially no-regrets) 20-year planning process in which three significantly different, but plausible, 2040 resource scenarios be created for which actual (rather than conceptual) transmission plans are independently developed. Those upgrades that are common to all three scenarios should move forward in the annual TPP cycle for presentation to the CAISO board for approval. Those upgrades that are common to two out of the three scenarios should be closely monitored as part of annual TPP cycle as replacement (potentially more costly replacement) solutions to address reliability, economic and/or policy upgrades that are identified in the TPP.  This least-regrets process would ideally be outlined in the final 2022 20-year Outlook and apply in the subsequent IRP and TPP cycles.

A clear process that will lead to the selection and approval of incremental upgrades needs to be included in this plan if the state is to make near-term and steady progress towards integrating the clean energy required to meet the very challenging SB 100 targets.

[1] See CalWEA’s October 18, 2021, joint submission with the California Energy Storage Alliance to the CAISO’s Policy Initiatives Catalog, also available here .

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

Comments in attached letter.

2. Comment on chapter 1 Introduction:

Comments in attached letter.

3. Comment on chapter 2 Coordination with State Agencies:

Comments in attached letter.

4. Comment on chapter 3 Process and Inputs:

Comments in attached letter.

5. Comment on chapter 4 Integration of Resources:

Comments in attached letter.

6. Comment on chapter 5 High-Level Assessment:

Comments in attached letter.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

On behalf of Defenders of Wildlife, we respectfully submit these comments in response to the draft 20 Year Transmission Outlook (draft Outlook) and the February 7, 2022 (Workshop).  Defenders is committed to achieving a low carbon energy future, a future that centers on the health of California communities, our economy, and the environment.  We are pleased to see the California Independent System Operator (CAISO) undertake a 20 Year Transmission Outlook as part of their work to plan for SB 100 implementation and appreciate the thoughtful discussion during the Workshop.  Transmission must be integrated into planning for SB 100 to match resource build with the grid build.

Moving forward, we recommend future workshops on the 20-Year Transmission Outlook be held as standalone workshops instead of tagged on at the end of the transmission planning process workshops.  Standalone workshops would provide much needed time to focus on the analysis and outputs in the 20 year horizon.

2. Comment on chapter 1 Introduction:

Thank you for the informative executive summary and introduction.

3. Comment on chapter 2 Coordination with State Agencies:

We appreciate the Joint Agency workshops that have been held over the past year on SB 100.  Continued coordination and collaboration will be (or are) essential to meeting SB 100 goals and the accompanying transmission required.  We recommend that quarterly public workshops be scheduled with the Joint Agencies and include California Natural Resources Agency (CNRA), California Department of Fish and Wildlife (CDFW) and the Governor's Office of Planning and Research (OPR).  CNRA, CDFW and OPR can provide essential input on moving beyond the interconnection queue to consider appropriate locations more clearly for generation and future transmission investments that drive forward public policy and take "…into full consideration the economic and environmental costs and benefits of renewable energy and zero-carbon resources." (CA Public Utility Code Section 454.53(b)(2)).  Coordination with CNRA will also aid coordination of generation and transmission planning with California's 30x30 efforts and agricultural land retirement that will occur as the Sustainable Groundwater Management Act is implemented.

4. Comment on chapter 3 Process and Inputs:

Consideration of land use and environmental opportunities and constraints is foundational to enable effective transmission planning that reduces risks of unintended impact, conflict, and disputes and ensures timely build-out.  The integration of the CEC generated environmental screening process allows real-world consideration of environmental and land use implications for build out and should be applied to generation technologies and pumped hydro storage.  We strongly support further development and integration of the screening process and tools. 

5. Comment on chapter 4 Integration of Resources:

Mapping of Solar Resources - Inyokern and North Kramer Solar

The projections for 2,162 MW for Inyokern and North Kramer shown in Table 3.1-5 and on page 29 is not realistic.  At 7 acres/MW, the land needed to generate 2,162 MW would be 15,132 acres.  Of that, 8,134 acres would be needed for North of Kramer.  The DRECP designated North of Edwards Development Focus Area (DFA) north of Kramer overlaps a core population of Mohave ground squirrels that California Department of Fish and Wildlife (CDFW) intends to protect due to its importance for maintaining populations and connectivity to other populations.  The DFA is closed to solar energy applications and development pending a review by Bureau of Land Management (BLM) and CDFW to determine if Mohave ground squirrel conservation should be the priority designation (BLM letter September 14, 2021 attached).

The Inyokern – North of Kramer transmission zone includes the Indian Wells Valley (tying into the Inyokern Substation) and North of Kramer (tying into the Kramer Substation).  The Indian Wells Valley also supports a core population of Mohave ground squirrels south of Inyokern and as such has significant development constraints. 

We recommend CAISO and the CEC consult with BLM and CDFW on solar development projections for the Inyokern – North Kramer area.

Offshore Wind

Consistent with SB 100 planning scenarios, the CEC's 2021 Starting Point scenario identified 10,000 MW of offshore wind (OSW) but did not allocate it out to specific regions.  The draft Outlook has allocated 6 GW of OSW energy to the Central Coast and 4 GW of OSW energy to the North Coast.  This allocation is inconsistent with sea space availability.  The Central Coast is constrained by Department of Defense (DoD) operations areas and marine sanctuaries that limit offshore wind development such that 6 GW of OSW energy could be unrealistic.  Further, the CEC is in the process of developing the OSW development feasibility study and goal identification required by AB 525.  We recommend the CAISO consult with the CEC and the Bureau of Ocean Energy Management to update this OSW allocation. 

6. Comment on chapter 5 High-Level Assessment:

Kramer – Victor – Lugo Path Upgrade Project

As discussed in Question 5, the Starting Point scenario of 2,162 MW of solar resources in the Inyokern and North of Kramer area is unrealistic.  We recommend that the proposed new 230 kV line from Kramer to Victor and upgrades to the existing Kramer – Victor and Victor – Lugo 230 kV lines be re-evaluated.

Offshore Wind

The CEC's AB 525 feasibility studies and goal identification will be completed by June 1, 2022 and will provide additional guidance on California OSW development.  We recommend the OSW transmission development scenario and cost estimates be re-evaluated after consultation with the CEC and BOEM.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

EDF-R appreciates CAISO’s publishing of the draft 20-Year Transmission Outlook, it is clear that an enormous amount of effort went into the study work, and the result is a valuable piece of analysis that will assist California in charting the path to serve 100 percent of electricity retail sales and state loads from renewable and zero-carbon resources in California by 2045.

The 20-Year Transmission Outlook is an informational report that does not direct or suggest approval for any new transmission. In order for any of the transmission identified in the report to be approved for construction the California Public Utilities Commission (CPUC) and California Energy Commission (CEC) will need to direct the CAISO to study a basecase of a similar scale through an official process. The process outlined in the joint agencies alignment plan is designed to inform the CAISO’s 10-year rolling study window in the Transmission Planning Process. EDF-R suggests that given the magnitude of the transmission projects identified in the plan that the 10-year study window may not be sufficient to get enough transmission online in time.

It is surprising but true that transmission projects regularly take more than 10 years to construct. Projects are delayed for many reasons; permitting challenges, procurement challenges, and schedule impacts attributable labor and procurement shortages. In this case an ounce of prevention is worth a pound of cure, and in order to meet the moment EDF-R suggests the Joint Agencies work together to find or create a study process that can generate appropriate approvals for these large transmission projects right away to allow for sufficient time for study, approval, engineering, and procurement.

2. Comment on chapter 1 Introduction:

.

3. Comment on chapter 2 Coordination with State Agencies:

.

4. Comment on chapter 3 Process and Inputs:

.

5. Comment on chapter 4 Integration of Resources:

.

6. Comment on chapter 5 High-Level Assessment:

.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

The Outlook demonstrates the challenges that California will face in achieving 100% zero carbon electric production by 2045.  Because of longer term perspective it will be important to be able to access different potential futures, including different potential generation resources.  We acknowledge that CAISO is not ultimately responsible for the portfolio mix but emphasize the importance of being able to respond to developments of various potential resource mixes.  To that end, we note that the long-term portfolios, while assuming 10,000 MW of offshore wind by 2040, fail to account for potential substantive geothermal imports outside the currently producing geothermal regions.  Because of the significantly reduced environmental impacts and footprint of geothermal versus wind and the lack of a proven technology to build 10,000 MW of floating wind turbines off the California coast, further assessment of out-of-state geothermal potential should at least be seriously considered.  For example, the USGS Assessment of Moderate- to High-Temperature Geothermal Resources in the US estimates that there is a 95% chance that at least 508 MW of traditional geothermal in Idaho, 1,511 MW in Nevada, and 426 MW in Utah. Those numbers only include discovered and undiscovered hydrothermal reservoirs. If you include Enhanced Geothermal System potential, those numbers shoot off the charts. 

Geothermal has the additional advantage of being a firm resource, not dependent on weather variability that can deliver a base load or dispatchable resource, providing at least twice the total amount of energy per MW of transmission capacity utilized compared to variable wind and solar generation.

The potential for new geothermal technological development should also be considered.  For instance, the CEC has recently funded a pilot of closed loop technology for generating geothermal electricity without requiring bringing the resource to the surface conserving water and maintaining pressure in the geothermal resource.

2. Comment on chapter 1 Introduction:

No comment

3. Comment on chapter 2 Coordination with State Agencies:

No comment

4. Comment on chapter 3 Process and Inputs:

The Starting Point analysis identifies 2,332 MW of geothermal energy located in the Salton Sea area (2,012 MW) and in Southern Nevada.  As noted in the response to Question 1, the assessment fails to account for the potential of an additional 2,000 MW or more from outside California.

5. Comment on chapter 4 Integration of Resources:

The firmness of geothermal generation requires much less transmission capacity to deliver the same amount of clean GHG-free energy as intermittent resources, without the need for substantial energy storage to mitigate intermittency.  The ongoing development of new geothermal technologies will facilitate reliance on significantly more predictable and consistent resource deliveries to consistently and predictably serve load or charge storage.

6. Comment on chapter 5 High-Level Assessment:

As Table 5.2.2 of the Outlook notes, geothermal resources modeled can provide 1,870 MW during peak, net peak and off-peak hours. 

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

Golden State Clean Energy (“GSCE”) is very appreciative of the California ISO’s leadership in undertaking its first 20-Year Transmission Outlook to support a crucial missing element in the SB 100 report process. Our comment discusses our takeaways from the Draft 20-Year Transmission Outlook and next steps that the ISO and California energy agencies can take to begin acting on the 20-year outlook to ensure orderly development of California’s infrastructure needs. Orderly development could be promoted by a long-term plan to phase the expected development of Central Valley and Central Coast energy infrastructure and by ensuring that future IRP mapping sufficiently aligns with the 2021 SB 100 Joint Agency Report and the 20-Year Transmission Outlook.

GSCE has firmly supported the 20-Year Transmission Outlook process. We believe the 20-year outlook has already provided benefits by informing the 2021-2022 transmission planning process. And the results are evident, as the Draft 2021-2022 Transmission Plan proposes new additions that will support the transition to a grid that better supports the growth of renewables needed to meet long-term policy goals.

The draft 20-year outlook has confirmed what many assumed to be the case, that significant new transmission infrastructure will be needed for California to meet its SB 100 goals and much of it will need to be planned for Central Valley solar. The 20-year outlook is incredibly valuable because it creates the first ISO-sponsored blueprint for this infrastructure need. This will allow California energy agencies and the ISO to start moving beyond SB 100 planning and into an action and development stage.

While the initial 20-year outlook and its impact on this year’s transmission plan is a good start, the ISO should immediately begin discussing how to facilitate the orderly development of transmission upgrades identified in the 20-year outlook. Transitioning from planning to development will allow the ISO to capture the value proposition of the 20-year outlook, and GSCE finds this especially true of the potential near- and long-term benefits that Central Valley solar and storage resources can provide.

GSCE urges the ISO to ensure future IRP-TPP busbar mapping discussions with the CPUC are sufficiently planning for the development of 30,000 MW of Central Valley solar in alignment with the 20-year outlook and SB 100 report planning targets. This should involve updating the transmission inputs in the IRP to consider the 20-year outlook results and busbar mapping sufficient future resources to the Central Valley. We have been concerned that IRP-TPP resource planning and mapping in the Central Valley has not been sufficiently aligned with the more complete policy picture painted by the SB 100 report and its longer planning horizon.

As an enhancement to traditional IRP-TPP thinking, the ISO should create a plan for how the development in the 20-year outlook could be done in phases.  A phasing plan could facilitate orderly development of planned generation in areas like the Central Valley through many annual TPP cycles while facilitating interconnection of significant new storage-paired renewable resources that can support grid reliability in the near-term. For a phased transmission development plan to work in tandem with generator interconnection to help California efficiently reach its SB 100 goals, a separate interconnection queue for the Central Valley and other policy resource zones could help drive orderly, holistic development in these areas (e.g., a unique transmission upgrade funding process focused on the long-term transmission needs and involving a new deposit and application process). Such a process could provide a framework that satisfies some of FERC’s current planning desires as expressed in the 2021 transmission and generation interconnection ANOPR.[1]  This could also address some of the ISO’s concerns raised in the 2021 IPE initiative regarding policy-driven studies in the TPP that are not coordinated with interconnection requests seeking to utilize the transmission capacity being developed.

GSCE recognizes that crucial progress was made in the 2021-22 TPP cycle, including recommending a new Manning Substation. GSCE supports this new substation and the ISO’s thinking that led to it being recommended for approval. But more of this type of planning is needed, and the ISO can do this by creating more linkage between the 20-year outlook and IRP-TPP planning. The ISO should examine expediting upgrades that will complement the Manning Substation along the same timeline as the new substation, namely new high voltage lines such as a new 500 kV Diablo-Gates line that can facilitate Central Coast offshore wind and a Manning-Moss Landing 500 kV line that can provide the Bay Area with greater access to renewables and storage.[2] 

[1] FERC docket RM21-17-000.

[2] Draft 2021-2022 Transmission Plan, at 232 (discussing the Diablo-Gates line); Draft 20-Year Transmission Outlook, at 48 (discussing the Manning-Moss Landing line).

2. Comment on chapter 1 Introduction:

No comment. 

3. Comment on chapter 2 Coordination with State Agencies:

No comment. 

4. Comment on chapter 3 Process and Inputs:

No comment. 

5. Comment on chapter 4 Integration of Resources:

No comment. 

6. Comment on chapter 5 High-Level Assessment:

No comment. 

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

GLW commends the CAISO for this forward-looking study intending to provide a comprehensive assessment of mid-range needs.

In these comments, GLW offers input primarily on what is a missed opportunity to study very cost-effective, and quick to build, incremental transmission upgrades in the GLW footprint, which could allow the interconnection and deliverability of over 2 GWs of additional renewables at a fraction of the cost of most alternative options identified.   

2. Comment on chapter 1 Introduction:

GLW has no overall comments on the intent of the CAISO’s 20-year study. As indicated in our September 2021 TPP comments, the specific Starting Point portfolio that had buildout assumptions in the GLW area is overly restricted by legacy transmission limitations that the CAISO will already remedy through upgrades recommended in this 2021-22 TPP cycle.  GLW recognizes that land use availability in the GLW region is not something the CEC has historically opined on. Yet GLW has, and can again, provide extensive data on the availability of land for renewable buildout.  One element of land use availability relating to Nevada is the significant presence of land under the jurisdiction of the Bureau of Land Management (BLM).  The BLM recently announced a public comment period for draft guidance to promote the use of wind and solar energy on public lands. The proposed policy direction would reduce acreage rental rates and megawatt capacity fees to provide additional financial and regulatory predictability for existing and new solar and wind energy projects authorized on public lands.  This effort further supports the efficiency and reasonableness of expanding the assumed commercial interest and capability of GLW to support significant renewable generation development.[1] 

Keeping the GLW resource levels in the portfolios limited at historical levels is counter-productive to the goals of finding the most cost-effective solutions to SB100 renewable goals.

Similarly, in these comments, GLW comments on cost-effective upgrades that are being overlooked by virtue of the legacy portfolio siting.

[1] See, https://www.blm.gov/programs/energy-and-minerals/renewable-energy

3. Comment on chapter 2 Coordination with State Agencies:

Consistent with our comments in response to chapter 1 above, the report does not give sufficient attention to the Nevada portion of the CAISO, and as a result, the siting in that region has been overly constrained.  While GLW was able to present at one of the workshops and comment at all of the workshops, the joint agency process does not incorporate any of GLW’s input. GLW solar was incorrectly viewed as an out-of-state resource in the SB100 Starting Point akin to how Wyoming and New Mexico wind is treated without any appreciation for the fact that GLW renewables are on the CAISO grid. Further, the Starting Point portfolio simply set the Southern Nevada resources at a level where they had been in the prior cycle’s IRP build.  (See the September 13, 2021 Starting Point portfolio document p. 13 for details on the treatment and basis for the selection of the Southern Nevada portfolio resources. << https://efiling.energy.ca.gov/EFiling/GetFile.aspx?tn=237167&DocumentContentId=70349>>.) This reflects the fact that the agencies are not fully recognizing that future expansion in SNV is highly probable and very cost-effective.  GLW encourages the agencies to consider GLW’s comments within the SB100 process and the CAISO’s 20-year study process.

Specifically, GLW continues to seek assumptions in these studies that do not limit buildout in the GLW area to what is currently possible given existing transmission, but rather to recognize that additional resources can be developed with cost-effective upgrades, and to base the portfolios – including any 20-year study portfolios – on the potential renewables rather than the historically sited renewables in a manner consistent with resource zones internal to California.

4. Comment on chapter 3 Process and Inputs:

The CAISO’s 20-year plan recognizes that “diverse resources,” including geothermal, “require transmission development.”

Presuming that the development of all additional geothermal will be built in the Imperial region (Id.) seems inconsistent with prudent planning that typically involves some level of geographic diversity when feasible.  We appreciate the CPUC’s recent recognition of the need for geographic diversity of geothermal development and the likelihood that geothermal will grow in Southern Nevada. We look forward to the next CAISO analysis having some growth assumptions with respect to CAISO Southern Nevada renewables.

5. Comment on chapter 4 Integration of Resources:

GLW has no additional comments relative to chapter 4.

6. Comment on chapter 5 High-Level Assessment:

The CAISO has identified a large number of projects potentially needed under the Starting Point assumptions, and GLW appreciates that the CAISO is thinking ahead for projects like these to support the renewable development.

That said, consistent with our comments above, we believe it is inefficient to not identify additional projects that could support substantial additional renewable development for a fraction of the cost of other projects the CAISO identified in the 20-year study. Table 5.4-2 identifies a number of projects necessary to support the Starting Point portfolio, including $11 billion in upgrades to the CAISO system, $8 billion to support offshore wind, and $12 billion worth of projects for out of state wind.

With the GLW system over 2,000 MWs of additional wind, solar or geothermal energy could be interconnected and fully deliverable for an incremental cost of $0.26 billion, and it could be built out within 36 months. (GLW has submitted a paper with these comments detailing this incremental buildout assessment.)  It seems sensible to include this GLW project in the mix.  Constructing the portion of the GLW Upgrades from Trout Canyon to Sloan Canyon at 500 kV standards and operating at 230 kV until the additional capacity is required is a very cost-effective way of enabling future capacity.  We urge the CAISO, as well as the CEC and CPUC, to recognize this upgrade opportunity, to study in 2022-2023 TPP cycle, and to include it in any broader SB100 integration studies and future 20-year transmission planning studies. 

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

Hydrostor appreciates the work that the CAISO, along with the CPUC and CEC, have undertaken in relation to the Draft 20-Year Transmission Outlook and look forward to engaging further with the CAISO on this important initiative. 

That said, we believe that additional work could be undertaken by the CAISO, along with the CPUC and CEC, going forward:

1. The inputs and assumptions for the portfolio of resources do not reflect the range of long duration energy storage technologies available.

While Hydrostor acknowledges that the CAISO notes that “[t]his initial portfolio is not an endorsement of any particular resource” (p. 2 of Appendix A), the adoption of such a portfolio in itself already sends important signals to developers, financiers and may become unintentionally embedded as part of regulatory proceedings.  It is noted that the 2021 SB 100 Reports modelled long duration energy storage as pumped hydroelectric energy storage (p. 6 of Appendix A).  However, as Hydrostor has noted in many filings within the CPUC IRP proceeding (Rulemaking 20-05-003 and predecessor proceedings), there are a wide range of long duration energy storage resources which may differ in terms of siting flexibility, capital and operating costs, scale necessary for economic deployment and round-trip efficiency and pumped hydro should not be used as the sole proxy for this class of resource.  The CAISO notes that the long duration energy storage may need to be assigned based on “a combination of geologic and technological factors" (p. 7 of Appendix A) which presumably is due to pumped hydro’s limited siting flexibility. 

Indeed, there are a number of non-pumped hydro long duration energy storage technologies currently active in the CAISO interconnection queue, including Hydrostor’s Advanced Compressed Air Energy Storage.  Such resources can offer distinct advantages over pumped hydro including siting flexibility and improved environmental attributes, particularly lower water usage compared to pumped hydro.  The CPUC acknowledged this active development when undertaking busbar mapping of long duration energy storage by noting in their “Modeling Assumptions for the 2022-2023 Transmission Planning Process” released as part of the Preferred System Plan Decision that “the 500 MWs mapped to the Whirlwind substation aligns with a storage project in the CAISO queue that utilizes compressed air technology” (p. 68 of that report).

The CEC has funded important work related to long duration energy storage (by parties such as UC Merced and others) and it may be worthwhile to fully update the RESOLVE model to accommodate other long duration energy storage technologies as candidate resources. 

The CAISO notes that it and other “agencies will work together with stakeholders and other California BAAs to continue assessing LDES opportunities, including locational factors for different technology types” (p. 7 of Appendix A).  Hydrostor looks forward to participating in these discussions.

2. The rationale for some of the modifications from the “2040 SB 100 Core Scenario” to the “2040 Starting Point Scenario” are unclear and lack appropriate justification. 

While the CAISO based its work on the CEC’s 2040 SB 100 Core Scenario, there were a number of adjustments made to the portfolio (as outlined in Table 2 of Appendix A) that lack clear justification.  While increasing natural gas retirements (from 4,722 MW of retirements to 15,000 MW of retirements) can be justified on environmental grounds, it is unclear why battery energy storage increased nearly 5,000 MW while long duration energy storage remained unchanged from the “2040 SB 100 Core Scenario” to the “2040 Starting Point Scenario”.  One would imagine that long duration energy storage’s improved ELCC’s (vs. battery energy storage) would make it a better replacement for natural gas generation.  Greater details on this assumption should be provided.  Further, as noted in Comment 1 above, pumped hydro should not be the sole proxy for long duration energy storage and, if the notional cap of 4,000 MW of long duration energy storage reflects this (i.e. there’s only 4,000 MW of new pumped hydro potential left in California), this should be revisited.

3. A more comprehensive view of reliability needs to be undertaken.

It appears that the CAISO modelled the system under (1) peak consumption (Secondary System Need / SSN); (2) Net Peak (Highest System Need / HSN); (3) Off-peak.  What this analysis fails to account for is potential multi-day periods of low renewable output (i.e. the “dark doldrums”) combined with reduced natural gas capacity.  We believe that such an analysis may show that long duration energy storage requirements are greater than shown currently.

4. The analysis fails to account for the role that storage, including long duration energy storage, could play in reducing transmission upgrades and overall system costs.

The upgrades identified in the 20-Year Transmission Outlook are all traditional transmission upgrades.  We believe it may be worthwhile for the CAISO to fully consider the role that storage, including long duration energy storage, may play in reducing required transmission upgrades and overall system costs including storage as a transmission asset.  For example, we note that significant wind (out-of-state and off-shore) is proposed in the “2040 Starting Point Scenario”.  Long duration energy storage, such as Advanced Compressed Air Energy Storage, paired with these resources could either reduce overall transmission needs or ensure transmission infrastructure is fully utilized (e.g. not overbuilt).

5. Planning for 2045 may be a useful exercise.

We note that the 15,000 MW of natural gas retirements assumed represents “approximately 50 percent of natural gas power plant capacity assumed in the 2021 SB 100 Report scenarios” (p. 5 of Appendix A).  To the extent that the remaining natural gas capacity is to be retired by 2045, the CAISO should be actively planning for that scenario now.  We understand that the SB 100 requires that renewable energy and zero-carbon resources supply 100 percent of electric retail sales to end-use customers by 2045 which may allow for some natural gas capacity to stay online; however, the amount required remains unclear and environmental objectives would point to as small amount as possible.  Planning for the 2045 SB 100 end state (vs. 2040 or five years earlier) may be a more fruitful exercise to be undertaken by the CAISO. 

6. How the 20-Year Transmission Outlook factors into other processes and discrete outcomes remains unclear.

Developers are spending millions in California to advance projects to assist the State in its decarbonization objectives.  While we appreciate that the 20-Year Transmission Outlook is an effort to “engage with stakeholders in [a] more informal yet meaningful discussion” regarding transmission development, it should not distract the CAISO from moving to resolve important issues facing developers including Deliverability constraints.  Conversely, if the 20-Year Transmission Outlook is intended to inform discrete changes, that too should be better explained.

Again, Hydrostor appreciates the work that the CAISO has undertaken with respect to the 20-Year Transmission Outlook and looks forward to engaging further with the CAISO, particularly on the important role that long duration energy storage can play.

(Note that Hydrostor was not able to participate in the stakeholder call on February 7, 2022 but a review of the posted presentation indicates that it appears to be a fair summary of the draft report posted on January 31, 2022.)

2. Comment on chapter 1 Introduction:

Please see Question 1 for overall comments related to the 20-Year Transmission Outlook.

3. Comment on chapter 2 Coordination with State Agencies:

Please see Question 1 for overall comments related to the 20-Year Transmission Outlook.

Hydrostor appreciates the efforts undertaken by the CAISO in this initiative.  However, as mentioned in our Comment 6 of Question 1, it remains unclear what the eventual outcome of this 20-Year Transmission Outlook may take.  For example, Figure 1.3-1 shows the 20-Year Transmission Outlook influencing the 2021-2022 TPP and CPUC IRP processes.  It remains unclear what role exactly this report will play in overall planning processes. 

4. Comment on chapter 3 Process and Inputs:

Please see Question 1 for overall comments related to the 20-Year Transmission Outlook.

As noted in Question 1, Hydrostor has strong concerns regarding both the inputs and assumptions used to develop the “2040 SB 100 Core Scenario” – where pumped hydro was used as the sole candidate resource for long duration energy storage – as well as the modifications to get from the “2040 SB 100 Core Scenario” to the “2040 Starting Point Scenario”.

5. Comment on chapter 4 Integration of Resources:

Please see Question 1 for overall comments related to the 20-Year Transmission Outlook.  In particular, we believe that the CAISO may be well served to take a more comprehensive view of reliability including consideration of multi-day periods of low renewable output (i.e. the dark doldrums) when combined with retired natural gas generation. 

6. Comment on chapter 5 High-Level Assessment:

Please see Question 1 for overall comments related to the 20-Year Transmission Outlook.  In particular, the CAISO may wish to take a renewed look at the role that storage, including storage as a transmission asset, could play in reducing overall transmission costs or improving transmission utilization. 

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

LineVision is a Grid-Enhancing Technology (GET) company that provides electric utilities with the real-time monitoring and analytics needed to secure the future of the grid. LineVision’s patented non-contact sensors collect critical information to unlock additional capacity on existing lines, provide insight into conductor health, and detect anomalies and risks.  Based on experience working with some of the leading electric utilities around the world including National Grid, Xcel, and Dominion, LineVision supports the effort made by CAISO, in collaboration with the California Public Utilities Commission (CPUC) and California Energy Commission (CEC), to draft a 20-Year Transmission Outlook and appreciates the opportunity to provide responses to the specific chapters below.

Given California’s climate goals to have renewable energy and zero-carbon resources supply 100 percent of electric retail sales to end-use customers by 2045, it is critical to pursue options that will help ensure that California ratepayers see the lowest rate-impact possible from this transition.  This includes implementing technology solutions that help ensure existing infrastructure is being utilized at its maximum capacity so that we can put more clean electricity on existing assets.

LineVision’s sensor-based platform provides multiple value solutions among three application categories: Line Aware, LineRate, and Line Health:

• LineAware provides utility and grid operators with situational awareness, which helps to inform operators with clearances and horizontal motion data, triggering alerts on exceedances
• LineRate provides Dynamic Line Ratings (DLR), which increase the capacity on lines with Forecasted and Real-Time DLR and Ambient Adjusted Ratings (AAR+)
• LineHealth provides utility and grid operators with Asset Health Monitoring, which helps improve maintenance strategies by creating a digital twin to determine conductor health

Here in California, we are pleased to be working with the Sacramento Municipal Utility District (SMUD), which is using our LineAware and LineRate applications to help evaluate DLR to increase line capacity, reduce hydro curtailment, reduce power imports, and advance SMUD's Zero Carbon Vision.

California’s transition to clean electric power is estimated to require $30.5bn investment in high-voltage bulk transmission infrastructure by 2040 to bring together a potential 121GW of new battery storage and renewable energy production. Given the scale of investment needed, we encourage stakeholders to look at the most cost-effective solutions to meet California’s clean energy objectives, which includes addressing transmission line ratings and increasing situational awareness of the grid in real-time, helping grid operators to detect risk of line slap, clearance violations, icing, storm damage, or other asset health issues.

The need to ensure we are getting the most out of our existing grid by addressing the accuracy and transparency of transmission line ratings was recently affirmed by FERC with Order 881, issued on December 16, 2021.[1]  Order 881 requires the implementation of ambient-adjusted and seasonal ratings while also opening a separate proceeding (Docket No. AD22-5-000) to further consider DLR issues. Unlike ambient-adjusted or seasonal ratings, DLR not only account for real-time ambient conditions such as air temperature and wind conditions, but also solar heating intensity and/or on transmission line conditions such as tension or sag.

LineVision believes that ambient-adjusted ratings are a first step to DLR, as under DLR approaches, the use of additional data (beyond ambient temperature data) can allow DLRs to reflect transfer capability even more accurately. Furthermore, FERC noted that deploying DLR sensors can help bring additional benefits by helping to “improve operational and situational awareness by helping transmission operators to better understand real-time transmission line conditions and potential anomalies, such as possible clearance violations or galloping.”[2]

Accurate line ratings increase the efficiency of the transmission system and enable the increased use of low-cost renewable generation dispatch. DLR can serve as a rapidly deployable source of transmission capacity for renewables that might be stuck in an interconnection queue or subject to curtailment as new transmission projects move through a longer-term process that is often subject to regulatory/permitting challenges and delays.

[1] FERC Order No. 881, Managing Line Ratings, Docket No. RM20-16-000; https://www.ferc.gov/news-events/news/ferc-rule-improve-transmission-line-ratings-will-help-lower-transmission-costs

[2] Federal Energy Regulatory Commission, 18 CFR Part 35, Docket No. RM20-16-000, Managing Transmission Line Ratings

2. Comment on chapter 1 Introduction:

As the 20 Year Outlook notes, significant investment will be needed to meet California’s clean energy goals. However, there is a significant opportunity to first unlock the capacity that exists on today’s grid.

The Department of Energy’s (DOE) Building a Better Grid Initiative highlights a new $2.5B revolving fund to facilitate the construction of high capacity new, replacement, or upgraded transmission lines.[1]  When evaluating proposed projects within the transmission facilitation loan program, DOE has stated that priority and favorable evaluations will be provided to projects that include DLR as a part of their new transmission line proposals.

As stakeholders work to develop and deploy new transmission lines in CAISO’s footprint, the utilization of DLR should be mandatory in order to help equip transmission owners and grid operators with the most advanced technology solutions to provide better situational awareness and real-time visibility, which help increase the resilience of the system overall.  

While the acceleration of clean energy resources to meet state policy goals and reliability needs will stress all aspects of the resource planning, procurement, engineering, supply chain and construction processes, another critical challenge facing California is the increasing risk of severe wildfires.  According to Cal Fire, all but two of the 20 biggest wildfires in state history have occurred since 2000, with nine happening in 2020 and 2021.[2]  As California has created maps to show elevated and extreme fire risk areas, the ability for DLR sensors to monitor sections of lines in these elevated risk areas and provide real-time information and predictive alerts related to conductor motion, including sag and blowout, at critical locations is a vital tool for wildfire mitigation purposes.

Results from deploying LineVision systems on existing transmission infrastructure have demonstrated that we can safely and reliably increase powerline capacity by as much as 40% while providing critical situational awareness and real time visibility to grid operators. This means that utilities can effectively double the current rate of renewable integration on our existing grid; a summation confirmed in a study conducted by the Brattle Group.[3]

Lastly, another issue to consider is the ability for DLR to play a solution in the interconnection process for the large numbers of solar and wind projects that are being proposed in CAISO's territory.  Despite the state’s clean energy goals, curtailments of solar-powered electricity generation have increased in the CAISO footprint.[4] Transmission customers often know what constraints are leading to congestion or curtailment; those customers should be able to request a utility implement DLR to alleviate a known constraint, especially if they are willing to pay for the application.

[1] https://www.energy.gov/articles/doe-launches-new-initiative-president-bidens-bipartisan-infrastructure-law-modernize

[2] https://twitter.com/CALFIRE_PIO/status/1481366558739947528

[3] https://watt-transmission.org/unlocking-the-queue/

[4] https://www.eia.gov/todayinenergy/detail.php?id=49276

3. Comment on chapter 2 Coordination with State Agencies:

Given the scope of California’s climate goals, the need for agency collaboration and stakeholder engagement is critically important.  We commend CAISO for offering this 20-year transmission outlook in collaboration with the CPUC and CEC.

New York is another state with similarly bold climate goals through the State’s Climate Leadership and Community Protection Act (CLCPA), which requires (1) a 40 percent reduction in GHG emissions from 1990 levels by 2030 and an 85 percent reduction by 2050; (2) a renewable electric generation target of 70 percent by 2030 and a 100 percent emissions-free electric supply by 2040; and (3) the addition of 9 Gigawatts (GW) of offshore wind generation to the energy portfolio by 2035.[1] New York is also looking to identify the investments needed to meet CLCPA goals, including the technology applications that may present low-cost solutions to traditional grid investments.

As part of the 2020-2021 enacted State Budget, New York State announced passage of the Accelerated Renewable Energy Growth and Community Benefit Act (Act).  The Act instructed the State to conduct a Power Grid Study to inform transmission and distribution system investments that will be necessary to achieve the clean energy goals of the CLCPA. 

As part of the Power Grid Study process, the New York Public Service Commission noted that there are several well-developed transmission technologies, including DLR, that the Utilities should consider applying when designing local transmission and distribution investments.  The Commission further noted that DLR has such a significant track record in other jurisdictions that further research may not be necessary in advance of widespread deployment.[2]

National Grid will be upgrading over 1,000 circuit miles of transmission across its Upstate NY service area to unbottle current and planned renewable generation and ensure delivery to customers; DLR technology is one of the key tools being utilized by National Grid to achieve this goal.

[1] https://climate.ny.gov/

[2] State of New York Public Service Commission; Case 20-E-0197; Order on Power Grid Study Recommendations; Jan 20, 2022

4. Comment on chapter 3 Process and Inputs:

The objective of CAISO’s 20-Year Transmission Outlook is to explore longer-term grid requirements and options for meeting the state’s climate goals in a reliable manner. As these requirements are studied, we believe that CAISO should reinforce a transmission planning loading order that prioritizes lowest cost/lowest carbon options first. In any proposed transmission planning loading order, optimization of the grid (via the utilization of low-cost tools such as GET’s) would be considered first, then grid reinforcement, and then grid expansion.

Technology solutions like DLR are not currently modeled in long term transmission planning, which is why the framework for a transmission loading order emphasizing least cost/least carbon solutions will be key in helping resolve planning-level constraints in a cost-efficient manner.  If we look internationally, we can see implementation of such transmission planning loading order principles. Transmission operator TransNetBW has their NOVA principle which emphasizes “grid optimization first, then grid strengthening before any further grid expansion.”[1] 

Transmission planning and capacity will also be key to delivering an electrified future. California recently became the first state in the nation to register 1 million plug-in vehicles[2]; the need for DLR is great as the electrification of transportation in California accelerates. A recent study from the Princeton Adlinger Center concluded that the grid will need to double by 2035 and triple by 2050 to support the required renewable integration and load growth from electrification.[3] DLR will be a critical solution to ensure that California’s existing grid capacity is maximized as load growth from electrification enhances the ability of the electric grid to provide a critical commodity for the transportation sector.

[1] https://www.transnetbw.com/en/world-of-energy/nova-principle

[2] https://news.bloomberglaw.com/environment-and-energy/california-is-first-u-s-state-to-hit-1-million-plug-in-cars

[3] https://www.princeton.edu/news/2020/12/15/big-affordable-effort-needed-america-reach-net-zero-emissions-2050-princeton-study

5. Comment on chapter 4 Integration of Resources:

Given the vast amounts of solar and wind resources that will need to be interconnected in CAISO’s footprint, the need for technology solutions like DLR is key within the various transmission zones, noting that DLR tends to be most beneficial on congested, thermally limited lines and on neighboring or contingent lines.

Here are some examples of how LineVision was able to demonstrate grid benefits in other RTO/ISO regions.

In PJM, LineVision was involved in a DLR pilot study on the 345kV Cook-Olive transmission line, located in AEP territory spanning from southwest Michigan to northern Indiana. In the first phase, LineVision designed sensors were installed to measure power flow, conductor position/sag, and weather conditions in order to calculate DLR’s on the line. The results of the first phase highlighted that Cook-Olive’s DLR was significantly greater than static ratings.[1]

In Phase two, LineVision, AEP and PJM worked to quantify the financial impact of DLR by identifying a line similar to Cook-Olive that was heavily congested with a straight transmission path. Working with AEP and PJM, the analysis determined that $11.1 million of congestion on the target line was eliminated with DLR.  However, several downstream 230kV lines saw an increase in congestion, resulting in a net of $4.2 million of congestion reduction. This pilot led to the recommendation to equip multiple circuits in a congested area with DLR.[1] The implementation of DLR was shown to have provided a net economic benefit to the grid.

Another example can be found in the Southwest Power Pool. AEP had identified a 2.1mile line for a rebuild project, which would cost ~$4 million over a 3-year construction timeline. LineVision installed 1 system unit to create 1 monitored location at a cost of $50,000 and 0.5 day install. Using the LineRate application, LineVision found that extra capacity was available during periods of market congestion and that redispatch and renewable curtailments were not necessary as DLR was above the static rating 99.9% of the time over 4 summer months. [2]

[1] S. Murphy; N. Dumitriu; N. Pinney; J. Marmillo; B Mehraban. “Simulating the Economic Impact of a Dynamic Line Rating Project in a Regional Transmission (RTO) Environment.” CIGRE US National Committee 2018 Grid of the Future Symposium

[2] N Pinney et Al. An Analysis on the Economic Impacts of Dynamic Line Ratings on a Congested Transmission Line in Southwest Power Pool. CIGRE Grid of the Future 2018.

[1] Marmillo, J.; Mehraban, B; Murphy, S; Pinney, N. A Non-Contact Sensing Approach for the Measurement of Overhead Conductor Parameters and Dynamic Line Ratings. CIGRE US National Committee 2017 Grid of the Future Symposium

6. Comment on chapter 5 High-Level Assessment:

The ability for offshore wind resources to play a critical role in future generation scenarios is also a prominent use case for the utilization of DLR.  As the electricity produced by offshore wind turbines travels back to land through a series of underwater cable systems, it connects onshore to a transmission substation where it is converted into extremely high voltage, between 155,000 and 765,000 volts, for long distance transmission on the transmission grid.

Of the 10,000 MW of offshore wind in the SB100 starting point scenario – 6,000 MW offshore wind resources in the Central Coast area can be interconnected to the existing 500kV system in the Diablo/Morro Bay Area.  As noted in the outlook, the 4,000 MW of offshore wind resources in the North Coast area will require some significant 500kV and HVDC facilities to interconnect to the existing 500 kV system to integrate the offshore wind into the CAISO grid, as the transmission system in the north coast area is predominantly 115 kV and 60 kV.

Given that wind speed is the most significant factor affecting line capacity, DLR can play a critical role in ensuring that the new offshore wind generation in both the Central and North Coast areas is maximized on the infrastructure that is needed to connect the offshore generation to the transmission grid.

A US Department of Energy report demonstrated that a 3 ft/sec increase in wind speed perpendicular to the conductor will increase its carrying capacity by 44%, indicating that significant increases in transmission capacity can be realized by utilizing DLR.[1]

In conclusion, LineVision appreciates CAISO’s interest and consideration of stakeholder feedback on the draft 20 Year Outlook.  LineVision welcomes the opportunity to work with the CAISO, CPUC, and CEC staff and other stakeholders to advance policy solutions like DLR that will help enable a more dynamic, resilient, and cost-effective transmission outlook for California.

[1] U.S Department of Energy, "Dynamic Line Rating Systems for Transmission Lines Topical Report," in Smart Grid Demonstration Program, 2014.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

 LS Power appreciates CAISO taking the initiative to conduct this 20-year study that evaluates long term system needs. LS Power encourages CAISO to continue with this effort and update this study periodically so that a “bookend” for future transmission plan is always available and can be used to align the recommendations of future projects.

Given the significant level of transmission build needed to integrate clean energy resources, LS Power also encourages CAISO to act in the near-term to start approving projects in its annual TPP. CAISO could look at shovel-ready projects as a low-risk starting point for new transmission infrastructure.

2. Comment on chapter 1 Introduction:

 No comments at this time.

3. Comment on chapter 2 Coordination with State Agencies:

 No comments at this time.

4. Comment on chapter 3 Process and Inputs:

 No comments at this time.

5. Comment on chapter 4 Integration of Resources:

As noted in this chapter, 3,900 MW of out-of-state (OOS) wind in the SB100 Starting Point scenario would require additional transmission development beyond the projects that are already identified. LS Power urges CAISO to act in the near-term to approve transmission projects, including OOS projects, to ensure California is able to meet the SB100 clean energy policy objectives. Transmission development is a long and arduous process and therefore actions need to be taken now in order to be successful in developing the grid of 2040 as contemplated in this study. The first step begins with approving shovel-ready projects, such as SWIP North, as low hanging fruit that are low risk projects given the significant level of transmission build needed to integrate clean energy resources.

6. Comment on chapter 5 High-Level Assessment:

 No comments at this time.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

Please see attachment

2. Comment on chapter 1 Introduction:

Please see attachment

3. Comment on chapter 2 Coordination with State Agencies:

Please see attachment

4. Comment on chapter 3 Process and Inputs:

Please see attachment

5. Comment on chapter 4 Integration of Resources:

Please see attachment

6. Comment on chapter 5 High-Level Assessment:

Please see attachment

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

NGIV2, LLC, the Project Sponsor of the North Gila – Imperial Valley #2 Project, appreciate the efforts of the CAISO to organize and perform the high-level assessment of a long-term 20-Year Transmission Outlook.  NGIV2 also appreciate the broader inter-agency coordination required to complete the Draft 20-Year Transmission Outlook and the NGIV2 appreciated being approached to participate in the workshop in mid 2021.  We believe that the addition of the North Gila – Imperial Valley #2 Project will play a key role in meeting the broader reliability and transmission capacity benefits for the region.  The current estimated timeframe for the North Gila – Imperial Vally #2 Project to be in-service is December 2026.

2. Comment on chapter 1 Introduction:

No comments.

3. Comment on chapter 2 Coordination with State Agencies:

No comments.

4. Comment on chapter 3 Process and Inputs:

No comments.

5. Comment on chapter 4 Integration of Resources:

No comments.

6. Comment on chapter 5 High-Level Assessment:

As noted in the results, the addition of the North Gila – Imperial Valley #2 transmission line will help to relieve both N-0 and N-1 overloads on the existing North Gila – Imperial Valley transmission line.  We note that the reference in the second figure under Figure 5.4-2 should reference the North Gila – Imperial Valley #2.  Lastly, we are revising the cost estimates for the Project and expect that the $0.5B is overestimated and the current estimates are closer to less than $400M (2026 dollars).

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

Northern California Power Agency (NCPA) appreciates the opportunity to comment on the Draft 20-Year Transmission Outlook, which estimates $30.5 billion of new transmission investment will be needed to integrate resources to achieve SB 100’s “Starting Point” scenario.

The Bay Area Municipal Transmission group (BAMx) estimates, in comments it filed in this stakeholder initiative on February 22, 2022, that CAISO’s High Voltage Transmission Access Charge (HV TAC) will grow from $16/MWh today to $47/MWh in 2036 based on projects that CAISO may approve.

CAISO has a duty to ensure its rates are just and reasonable, and must plan new transmission to achieve state and local policy objectives at the least cost. Given the scenarios contemplated by the 20-Year Outlook, NCPA urges CAISO to refocus its efforts on cost containment.

As part of that effort, NCPA believes the 20-Year Outlook would benefit from further analysis and greater stakeholder review.  In particular, two areas for further analysis are warranted:

First, CAISO should evaluate alternative cost allocation mechanisms for new transmission—in particular, for out-of-state transmission.  The 20-Year Outlook seems to assume that the full cost of new, interregional transmission projects will be allocated to California ratepayers. FERC and the Courts require that costs for transmission be allocated roughly commensurate with their benefits. The 20-Year Outlook should evaluate cost allocation alternatives that comply with that requirement.

Second, CAISO should evaluate alternative scenarios based on different load forecasts. The SB100 Core Scenario load projection, on which the 20-Year Outlook is based, assumes a “high electrification” scenario. But if costs for transmission triple, as is projected, basic economics suggests that more customers will seek out alternatives to relying on the transmission grid—e.g., greater reliance on microgrids, additional energy efficiency and conservation measures, and other alternatives. If the “high electrification” load scenario is not realized, the $30.5 billion in new transmission will be unneeded, but captive ratepayers will still be forced to pay those costs.  The 20-Year Outlook therefore should evaluate how the SB100 goals could be achieved under alternative load forecast scenarios.

As BAMx showed in its comments, the HV TAC will nearly triple by 2036.  This will have a significant impact on ratepayers and NCPA urges CAISO to subject the 20-year Transmission Outlook to careful review, especially of alternative cost allocation mechanisms and load forecast scenarios.

2. Comment on chapter 1 Introduction:

Please see item 1. 

3. Comment on chapter 2 Coordination with State Agencies:

Please see item 1. 

4. Comment on chapter 3 Process and Inputs:

Please see item 1. 

5. Comment on chapter 4 Integration of Resources:

Please see item 1. 

6. Comment on chapter 5 High-Level Assessment:

Please see item 1. 

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

N/A

2. Comment on chapter 1 Introduction:

Offshore Wind California (“OWC”) is a trade group of more than 40 companies, including offshore wind developers, technology providers, and consultancies committed to the responsible development of offshore wind power in California. OWC appreciates the opportunity to comment on the California Independent System Operator Corporation’s (“CAISO”) draft 20-year Transmission Outlook (“Draft Outlook”). 

The National Renewable Energy Laboratory (“NREL”) reports that California has 200 gigawatts (“GW”) of technical potential for generating offshore wind power.[1] The Joint Agency Senate Bill 100 (“SB 100”) report in March 2021 concluded that to reach its goal of 100% clean energy by 2045 California will need to develop a diverse portfolio of renewable energy that includes offshore wind. The “SB 100 Core Scenario” called for 10 GW of offshore wind by 2045, or as much as the model would allow.[2]

Offshore wind power can provide clean, reliable energy that complements the state’s solar and other renewable resources and helps keep the lights on for Californians around the clock.  Building offshore wind power capacity will create thousands of high-wage jobs, create new domestic supply chains, enable California to cost-effectively meet its 100% clean energy goals and also help the state manage its growing climate risks. These benefits can be achieved while protecting marine life and ocean resources.

Realizing the full benefits of offshore wind development off the California coast will require sustained federal and state support for deployment at scale. Economies of scale will be key to driving down costs, delivering competitively priced clean power, and encouraging industries and jobs to locate in our state.  

OWC Supports the Draft Outlook

The CAISO’s inaugural 20-year outlook planning process for new transmission investment represents a material step toward cost-effectively meeting California’s clean energy needs. OWC and its members are pleased to see a long-term, strategic transmission planning approach. The CAISO’s long-range transmission planning effort demonstrates its commitment to help achieve a re-imagined grid.

Planning Scenarios

OWC particularly applauds the CAISO’s inclusion of offshore wind in its planning scenarios.[3] Floating offshore wind has advanced significantly to become a proven technology in recent years and California is poised to leverage this new industry for the benefit of the state’s residents.

Process for Updating Draft Outlook

OWC supports the process that the CAISO has outlined for refining and updating its Draft Outlook,[4] and appreciates the CAISO’s work to make the Draft Outlook available in time for the California Public Utilities Commission (“CPUC”) to take account of this valuable analysis in its February 10, 2022 Decision Adopting 2021 Preferred System Plan in the Integrated Resource Planning (“IRP”) proceeding.[5]

Continued Information, Collection, Analysis and Revision

OWC appreciates the CAISO’s statement of its intention, following finalization of the draft plan in March, to examine the findings of SB 100 processes, collect information from other sources, and “provide industry an update on the 20-Year Outlook activities and communicate intentions going forward, by year end.”[6]

The process of continued information collection, analysis, and revision that the CAISO has outlined is particularly important with respect to offshore wind planning due to rapid technological change in this area and California’s policy responses to that change. Recent years have seen remarkable innovation and cost reduction in offshore wind and transmission technology, particularly with respect to the floating foundation technology that makes wind farms off the California coast possible.

                                                          * * *

OWC appreciates the opportunity to provide comments on the CAISO’s Draft Outlook and looks forward to continuing to support the CAISO’s efforts.

[1] See 2020 Offshore Wind Resource Assessment of the California Pacific Outer Continental Shelf (October 2020) https://www.nrel.gov/docs/fy21osti/77642.pdf.

[2] 2021 SB 100 Joint Agency Report, Achieving 100 Percent Clean Electricity in California: An Initial Assessment (2021) https://www.energy.ca.gov/publications/2021/2021-sb-100-joint-agency-report-achieving-100-percent-clean-electricity.

[3] CAISO 20-Year Transmission Outlook at 23-25.

[4] CAISO 20-Year Transmission Outlook at 15.

[5] Decision 22-02-004.

[6] See CAISO Draft 20-Year Transmission Outlook Presentation (February 7, 2022) http://www.caiso.com/InitiativeDocuments/Presentation-Draft2021-2022TransmissionPlan-Feb072022.pdf.

3. Comment on chapter 2 Coordination with State Agencies:

Policy Developments and Agency Coordination

California policy makers have responded positively to the emergence of floating wind as a new source of renewable energy. Assembly Bill 525 (“AB 525”), enacted in September 2021, requires a California Energy Commission (“CEC”)-led assessment of maximum feasible offshore wind capacity plus planning goals for 2030 and 2045 by June 1, 2022, and a strategic plan by June 30, 2023. The CEC has been the lead state agency on the California Intergovernmental Renewable Energy Task Force to provide state agency and stakeholder input on plans for offshore wind development. Efforts are now underway by CEC and state permitting agencies to streamline state permitting and coordinate, to the extent possible, with federal environmental review and permitting.

More recently, on February 17, 2022, Sen. Robert Hertzberg introduced Senate Bill 1174 (“SB 1174”), which is designed to accelerate the development of power lines needed to connect offshore wind farms and other energy sources to the electric grid. The CPUC also recently adopted Decision 22-02-004 in its IRP proceeding, making use of the California Independent System Operator Corporation’s (“CAISO”) draft analysis of the 8.3 GW offshore wind sensitivity case,[1] acknowledging the possibility of a near-term increase in 2032 offshore wind deployment set out in the preferred system plan;[2] and affirming the California Public Utilities Commission’s (“CPUC”) intention to engage with stakeholders on the establishment of an appropriate entity to conduct offshore wind procurement.[3]

Timeline and Processes

OWC understands and appreciates the CAISO’s interest in getting feedback in order to revise and update CAISO’s draft 20-year Transmission Outlook (“Draft Outlook”). OWC encourages the CAISO to consider that the Bureau of Ocean Energy Management (“BOEM”) offshore wind development process could take as long as seven years from lease auction to commencement of operations. Large scale in-state transmission development projects to interconnect offshore wind involve lengthy permit and planning requirements. An accelerated feasibility review of offshore wind transmission projects and initiation of work on approved projects can help ensure that needed transmission and generation are completed on a timetable that aligns with the goals of SB 100.

OWC also encourages the CAISO to follow and engage with the CEC’s work on offshore wind siting in connection with the studies required by AB 525 and as BOEM works toward designating additional call areas off the California Coast. These agency findings concerning the viability of additional areas in waters off Central and Northern California may have important implications for the focus of future offshore wind transmission planning and may require the CAISO to accelerate consideration of North Coast transmission solutions.

                                                          * * *

OWC appreciates the opportunity to provide comments on the CAISO’s Draft Outlook and looks forward to continuing to support the CAISO’s efforts.

[1] See D.22-02-004 at 123.

[2] See D.22-02-004 at 142-143.

[3] See D.22-02-004 at 143-144.

4. Comment on chapter 3 Process and Inputs:

N/A

5. Comment on chapter 4 Integration of Resources:

N/A

6. Comment on chapter 5 High-Level Assessment:

N/A

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

Pacific Gas and Electric Company (“PG&E”) applauds the California Independent System Operator (“CAISO”) on its inaugural 20-Year Transmission Outlook report (“Transmission Outlook”).  PG&E considers this recurring effort as highly valuable for policy makers, planners, and stakeholders as the State moves towards a clean energy future. While PG&E considers the initial Transmission Outlook a good starting point, PG&E offers the following recommendations to improve the next iteration of the Transmission Outlook: 

• An important component of the Senate Bill (“SB”)100 quadrennial report is “[a]n evaluation . . . of any anticipated financial costs and benefits to electric . . . utilities, including customer rate impacts . . . .”¹ The recently released draft Transmission Outlook provides a missing piece for the SB100 report, namely the cost of potential transmission projects. While this is much appreciated, as noted in the Transmission Outlook, the analysis does not include local transmission needs² (and therefore the cost estimates do not contemplate local transmission additions). PG&E recognizes this is the first iteration of a new long-term transmission outlook process and encourages CAISO to include an analysis of and cost estimates for local transmission needs to achieve SB100 goals in future efforts. 

• Although the current version of the Transmission Outlook does not address whether the system will operate reliably, recognizing this is a first effort, PG&E recommends CAISO include a comprehensive reliability assessment as part of the next 20-year assessment. In comments at the start of the Transmission Outlook process, PG&E recommended a thorough study plan that CAISO could use to achieve this, including recommendations for addressing congestion in local areas. PG&E recommends the CAISO incorporate those suggestions for the next transmission outlook assessment. 

• PG&E further recommends that the CAISO consider local capacity reliability needs as part of its Transmission Outlook analysis.  PG&E notes the CAISO recognizes that more work needs to be done to consider long-term local reliability needs in the draft Transmission Outlook.³  PG&E looks forward to seeing a more holistic analysis that considers the impacts of local reliability requirements on transmission system operations in future long-term transmission outlook assessments. 

PG&E appreciates that CAISO took into account PG&E’s previous comments and included an electrification load forecast in the base case assumption for the Transmission Outlook study.  This was a great first step, but PG&E believes the electrification load forecast needs to continue improving for use in future iterations.  Additionally, detailed technical studies (such as system strength, transient stability, voltage stability, and control interaction with other Inverter Based Interconnection Requests (“IBRs”) and Flexible Alternating Current Transmission System (“FACTS”) devices) are still needed in future iterations to provide a comprehensive view of the potential transmission deficiency and required mitigation solutions to support future resource interconnection and integration. PG&E also recommends the CAISO consider alternatives in a larger spectrum to mitigate risks from a significant project delay, or feasibility issues due to environmental challenges, construction difficulties, regulatory complexities, and other issues from connecting offshore wind resources and planning and building transmission projects across multiple states. 

• Lastly, PG&E recommends that the CAISO in the next Transmission Outlook assessment consider charging constraints in the evaluation of CAISO system transmission upgrades, including those identified in interconnection studies and Local Capacity Technical (“LCT”) studies. The CAISO’s interconnection process for energy storage performed under the Generator Interconnection and Deliverability Allocation Procedures (“GIDAP”) will only consider discharge mode consistent with CPUC counting rules for deliverability studies. The reliability studies performed under GIDAP consider charging mode but do not require upgrades for transmission congestion constraints that can be mitigated with congestion management. Additionally, the charging constraints that are assumed to be mitigated by congestion management in interconnection studies appear to be at odds with the Local Capacity Requirements (“LCR”) methodology that the CAISO is proposing to use as its back-stop procurement authority to ensure reliability. The CAISO should consider modifications to the Transmission Planning Process (“TPP”) to account for reliability mitigation of charging constraints. 

[1] SB100 legislation, Section 5, amending PUB 454.53(d)(2)(C).

[2] Transmission Outlook, p. 3; p. 15 (noting that some attention was given to local area needs for the LA Basin and Greater SF Bay Area).

[3] Ibid.

2. Comment on chapter 1 Introduction:

[Intentionally left blank]

3. Comment on chapter 2 Coordination with State Agencies:

[Intentionally left blank]

4. Comment on chapter 3 Process and Inputs:

[Intentionally left blank]

5. Comment on chapter 4 Integration of Resources:

[Intentionally left blank]

6. Comment on chapter 5 High-Level Assessment:

[Intentionally left blank]

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

No comments at this time.

2. Comment on chapter 1 Introduction:

POET applauds the inclusion of a forward-looking initiative to supplement CAISO’s existing 10-year transmission planning horizon and offers the following comments regarding the purpose of the 20-year Transmission Outlook. As an organization committed to advancing ocean-based climate solutions such as offshore wind, hydrogen, and carbon dioxide removal among others, POET has emphasized the need for large scale infrastructure planning in its own activities and recognizes the substantial challenge in realizing the full potential of these solutions. For this reason, forward-looking planning is essential, and POET observes that CAISO has responded to this need thoroughly and thoughtfully with its 20-year outlook supplement to the 2021-2022 Transmission Planning Process.

3. Comment on chapter 2 Coordination with State Agencies:

No comments at this time.

4. Comment on chapter 3 Process and Inputs:

POET supports the inclusion of the Del Norte (6.6 GW), and Cape Mendocino (6.2 GW) resource areas for the purposes of an outlook assessment in addition to the detailed study of transmission needs for the 1.6 GW Humboldt Call Area. Additional assessment work is necessary to define the developable potential in the greater Del Norte area, which POET suggests could be described as bounded by the existing Humboldt Call Area on the south end and the Rogue seafloor canyon near Gold Beach, Oregon on the north end.

While the total extent of developable area is not known, a confluence of factors that are generally positive for commercial viability do exist in the Del Norte area. For this reason, POET is focusing the activities of its Pacific Offshore Transmission Solutions Forum initiative on the greater Del Norte area, which exhibits potentially favorable seafloor conditions, excellent wind resource quality, and multiple potential transmission connection points including an existing Bonneville Power Administration 230 kV transmission corridor extending to Gold Beach.

Furthermore, the geographic layout of this area may lend itself to an offshore grid to facilitate interconnection of multiple projects, as CAISO suggests in section 5.4.2 of the 20-year Outlook. In addition to refinement of Del Norte resource capacity assumptions, inputs from coordination activities with neighboring transmission systems will be critical to creation of a workable offshore grid concept. POET intends to provide greater detail about suggested coordination activities in future comment opportunities to the CAISO.

While resource quality decreases in areas further to the north, significant additional potential exists that will likely become economically viable as the industry matures and technology continues to improve. If desired, these resources could either be directly connected to the CAISO system via coordination with facilities that are constructed to interconnect Del Norte area resources or transferred into the Pacific Northwest system and thereby would become available as an additional out-of-state wind option with associated transmission upgrades.     

5. Comment on chapter 4 Integration of Resources:

No comments at this time.

6. Comment on chapter 5 High-Level Assessment:

CAISO’s identification in the high-level offshore wind assessment of the need to consider both an offshore grid and increasing transfer capacity between California and the Pacific Northwest are vital aspects that should be further explored in future planning cycles. The geographic orientation of the Del Norte area may lend itself to an offshore grid with multiple planned shore connection points, one or more of which could create new interties with the Pacific Northwest.

Because POET’s mission is to advance climate solutions, it seeks to promote consideration of large-scale infrastructure investments that enable the maximum quantity of renewable energy to come online. In this case, not only would these transmission facilities interconnect offshore wind, they may also facilitate supplementary energy transfers between regions. These transfers could support integration of greater quantities of solar in California, flexibility services offered by Pacific Northwest hydroelectric generators and emerging nonemitting technologies in both regions such battery storage and hydrogen-fueled generation.

Resilience of transmission systems in both regions may also be improved by construction of new interregional facilities, and POET is supportive of assessing voluntary minimum interregional transfer capability targets to motivate progress toward this objective. Should the regions determine that reinforcement of existing California-Pacific Northwest connections via multiple redundant paths is consistent with both decarbonization and resilience objectives, POET suggests that a minimum standard may be voluntarily adopted by the relevant transmission planning entities.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

see attached 

2. Comment on chapter 1 Introduction:

see attached 

3. Comment on chapter 2 Coordination with State Agencies:

see attached 

4. Comment on chapter 3 Process and Inputs:

see attached 

5. Comment on chapter 4 Integration of Resources:

see attached 

6. Comment on chapter 5 High-Level Assessment:

see attached 

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

SDG&E appreciates CAISO’s efforts to forecast investments needed to achieve California’s 2045 goals. Such an effort is necessary due to the long lead times associated with transmission development.  This allows for more complete cost comparison and consideration of technology now emerging which might take years to become practical for consideration.

However, it may be necessary to advance approval timeframe of these transmission projects. Given that loads and resources will gradually materialize on the electric grid to reach the levels forecasted, some of the investments will be needed sooner. Since it can take more than 10 years to build long-lead transmission projects, relying on the traditional 10-year TPP framework means that we might already be behind. Therefore it may be important to approve many of the transmission projects with longer lead times identified in the 20-Year Transmission Outlook before they are identified in the 10-year TPP.

2. Comment on chapter 1 Introduction:

<No Comment>

3. Comment on chapter 2 Coordination with State Agencies:

SDG&E applauds CAISO’s process which mimics the larger IRP/TPP interface to the extent possible at this early stage. SDG&E encourages a thorough review of the capabilities and limitations of all solutions being considered. Additionally, it may be prudent to consider a more formal process (perhaps involving a tariff update) that allows for revisiting this process every 2 years. This will ensure that the latest assumptions and policies are incorporated into the 20-Year Transmission Outlook. A further suggestion may be to alternate between a 15-year and 20-year analysis in addition to the TPP where we will have the ability to approve projects in the 15-year process. This allows for long term transmission needs to be identified while

Due to the scale of the transmission solutions identified in the 20-Year Transmission Outlook, it may be prudent to start thinking about when to consider initial permitting activities. This will require narrowing down some of the transmission projects being discussed, but there may be a subset of core projects that will be the foundation of the future transmission plan. Engaging other regulatory agencies early around these core projects may help reduce the administrative burden and impact on schedule down the road.

4. Comment on chapter 3 Process and Inputs:

<No Comment>

5. Comment on chapter 4 Integration of Resources:

<No Comment>

6. Comment on chapter 5 High-Level Assessment:

SDG&E appreciates the projects being proposed and considered in this 20-year outlook. As this plan develops and matures, it will be important to maintain comprehensive assessments on the feasibility and usefulness of these projects. Reviewing practical capabilities of these projects, for example whether they fully enable delivery of resources to load centers will be important for prudent planning of the system. It would be beneficial for CAISO to work with the PTOs to fine tune and explore the proposed transmission projects and maximize their feasibility and viability. The PTOs would be able to provide valuable feedback regarding roadblocks and challenges associated with implementing these projects.

SDG&E notes the prevalence of HVDC technology in the proposed mitigation. Due to the long lead times associated with HVDC project development, it may be prudent to consider specifics behind these projects early. Considerations such as the type of HVDC technology will greatly affect the capabilities/benefits that the project can provide, as well as the cost and construction schedule.

SDG&E encourages CAISO to use the 20-year outlook as a basis for developing the Transmission Capability Estimates that feed into the IRP process. The advantage of using the 20-year outlook is a more holistic view of the final goals. The current method that is based on the TPP may provide results that are beneficial in the short term (10-year horizon) but are ultimately inefficient long term (20-year+ horizon)

Finally, assumptions around battery modelling should be revised to ensure that all realistic issues are identified early. Out of the 40GW of batteries assigned, only 9GW are being mapped whereas the remainder are assumed to be co-located. This is a very specific scenario that may lead to gaps in the reliability issues that are identified. SDG&E maintains that a more realistic solution may be to model this after the ratio of collocated batteries found in today’s interconnection queue. This provides a less specific scenario where we can plan for a broader set of outcomes.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

Southwestern Power Group (SWPG) and Pattern Energy appreciate the long-term vision and proactive planning required to complete CAISO’s Draft 20-Year Transmission Outlook. This unprecedented study provides a much-needed roadmap to achieve California’s SB100 goals reliably that is not provided by the current Integrated Resource Planning (IRP) and Transmission Planning Process (TPP) outputs. SWPG/Pattern also appreciate the inter-agency coordination required to complete the Draft 20-Year Outlook and hope that the study itself will foster even stronger coordination among the agencies going forward.

SWPG/Pattern also encourage CAISO to consider how it can utilize the results of the 20-Year plan in future TPP cycles. In particular, the results of the 20-year Outlook could be used to help assess whether additional policy-driven transmission upgrades may be necessary in upcoming TPPs in light of the longer-term expectations of the system. To that end, one suggested refinement in developing the Final 20-Year Outlook is to add the estimated time to complete the upgrades to the existing CAISO footprint shown in Table 5.4-2, since this information could be valuable for prioritizing projects in future TPP cycles. (more under question #6 below on Chapter 5)

2. Comment on chapter 1 Introduction:

No comments.

3. Comment on chapter 2 Coordination with State Agencies:

No comments.

4. Comment on chapter 3 Process and Inputs:

No comments.

5. Comment on chapter 4 Integration of Resources:

No comments.

6. Comment on chapter 5 High-Level Assessment:

Section 5.4 Transmission Development Alternatives describes various transmission solutions including upgrades to the existing CAISO footprint that will be needed to integrate the SB100 Starting Point scenario. These upgrades and associated cost estimates are summarized in Table 5.4-2. Due to the long-term planning needed, SWPG/Pattern highly recommend that in the Final 20-Year Outlook CAISO also include the estimated time to complete the upgrades to the existing CAISO footprint since they are under CAISO’s control, so they can be appropriately prioritized in current and future TPP cycles.

For projects that are not under CAISO’s direct control such as the out-of-state (OOS) wind transmission projects, CAISO could list the planned in-service dates provided by the project developers in the July 22, 2021, SB100 workshop or request this information from the developers if not provided in the workshop.

As an example SWPG/Pattern are developing the SunZia Transmission Project of which Line 1 will deliver up to 3,000 MW of OOS wind from New Mexico mostly to the Palo Verde hub with planned in-service date of December 2025. The injection of 3,000 MW of OOS wind at Palo Verde is noted in Section 5.4.1 on page 46, and inclusion of the December 2025 in-service date could be informative for future TPP cycles. Similarly, the planned in-service dates of other OOS transmission projects could help inform and prioritize future upgrades in the TPP.  

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

1. TRANSCANYON

TransCanyon, a joint venture between Berkshire Hathaway Energy’s subsidiary BHE U.S. Transmission and Pinnacle West Capital Corporation’s subsidiary Bright Canyon Energy, is an independent developer of electric transmission in the western United States. TransCanyon’s mission is to develop, build, own and operate electric transmission infrastructure for the benefit of all utility customers. TransCanyon is led, managed, and operated by professionals with significant experience in developing, building, owning and operating transmission infrastructure in the western United States.

2. TRANSCANYON’S CROSS-TIE TRANSMISSION PROJECT

The Cross-Tie Transmission Line (Cross-Tie) is a proposed 213-mile, 1500 MW, single-circuit 500kV HVAC transmission project that will be constructed between central Utah and east-central Nevada to strengthen the electrical interconnection between the PacifiCorp and the NV Energy transmission systems while supporting interregional power transfers by linking the Rocky Mountain area to the Great Basin area. The project also facilitates CAISO meeting California’s RPS and GHG requirements by increasing transmission capability for CAISO to access Wyoming wind and Utah solar, and for CAISO to export excess solar energy to Utah and Wyoming. Cross-Tie will connect PacifiCorp’s proposed Clover 500kV substation in central Utah with NV Energy’s Robinson Summit 500kV substation in east-central Nevada, which will effectively link the Gateway South Project (PacifiCorp) with the Desert Southwest by utilizing the existing One Nevada Line (NV Energy/Great Basin Transmission, LLC), the planned Greenlink Projects (NV Energy) and the Harry Allen - Eldorado 500kV line (CAISO). The Cross-Tie Project has an estimated cost of $667mm (before the benefits of investment tax credits that would be passed to customers) and a construction period from 2023 through proposed in-service in the fourth quarter of 2026.             

3. TRANSCANYON’S COMMENTS ON THE DRAFT 2021-2022 TRANSMISSION PLAN

TransCanyon appreciates the CAISO’s decision to begin looking at what transmission improvements may be needed over the next twenty years to facilitate the development of a very large portfolio of resources to enable California to meet its long-term energy policy goals. From the 2040 starting point portfolio significant major transmission projects will be required to integrate both the off-shore and out-of-state wind in the portfolio. Such large-scale transmission will take significantly longer that ten years to develop making such twenty-year analysis necessary. TransCanyon is pleased that CAISO has recognized that there are several transmission projects under development that can be utilized to access out-of-state wind resources, including TransCanyon’s Cross-Tie 500kV Project. TransCanyon encourages the CAISO to continue the analysis of this twenty-year timeframe to further determine how these projects under development can increase their viability. TransCanyon stands ready to assist the CAISO in any way it can as we move forward with the 2022-2023 Transmission Planning Process and hopefully more analysis of the twenty-year timeframe.

4. NOTICE AND COMMUNICATION

Service of notices, orders, and other communications and correspondences in this proceeding should be directed to TransCanyon at the address set forth below:

Jason R. Smith

President

TransCanyon
400 East Van Buren Street, Suite 350

Phoenix, AZ 85004
Tel: 602 250 2668

Email:Jason.Smith@TransCanyon.com

5. CONCLUSION

TransCanyon appreciates the opportunity to participate in the CAISO 2021-2022 Transmission Planning Process and applauds the CAISO efforts to begin to plan twenty years out in the future to support a reliable and efficient system to enable California to meet its future reliability, policy and economic goals. TransCanyon looks forward to working with the CAISO to further examine the transmission improvements that may be required to facilitate the large portfolios of new resources that will be required in the twenty-year timeframe to meet California’s aggressive policy goals and to see how the TransCanyon Cross-Tie Project can help to meet these future needs.

2. Comment on chapter 1 Introduction:

See response to question #1 or attached comment letter.

3. Comment on chapter 2 Coordination with State Agencies:

See response to question #1 or attached comment letter.

4. Comment on chapter 3 Process and Inputs:

See response to question #1 or attached comment letter.

5. Comment on chapter 4 Integration of Resources:

See response to question #1 or attached comment letter.

6. Comment on chapter 5 High-Level Assessment:

See response to question #1 or attached comment letter.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

See attachment.

2. Comment on chapter 1 Introduction:

See attachment.

3. Comment on chapter 2 Coordination with State Agencies:

See attachment.

4. Comment on chapter 3 Process and Inputs:

See attachment.

5. Comment on chapter 4 Integration of Resources:

See attachment.

6. Comment on chapter 5 High-Level Assessment:

See attachment.

1. Please provide your organization’s overall comments on the Draft 20-Year Transmission Outlook Feb 7, 2022 stakeholder call discussion:

WECC congratulates CAISO on the release of its first ever '20-year Transmission Outlook' study. WECC supports a long-term integrated planning approach that combines both reliability and policy objectives. WECC encourages CAISO to continue its work and reach across the seams to coordinate efforts with other jurisdictions and entities to validate its findings. WECC recognizes the challenges with long-term planning across a diverse interconnection and stands ready to collaborate, coordinate, and facilitate discussions with stakeholders to address these important and pressing matters.

2. Comment on chapter 1 Introduction:

N/A

3. Comment on chapter 2 Coordination with State Agencies:

N/A

4. Comment on chapter 3 Process and Inputs:

N/A

5. Comment on chapter 4 Integration of Resources:

N/A

6. Comment on chapter 5 High-Level Assessment:

N/A