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					December 22nd, 2011

Submitted by email to the CAISO at

RE: Comments of the Large-scale Solar Association on 2011-2012 Transmission
Planning Process December 8th, 2011 meeting topics

The Large-scale Solar Association (LSA) submits these comments on several presentation and
discussion topics at the December 8th 2011-2012 Transmission Planning Process (TPP)
stakeholder meeting. At this meeting, the CAISO presented study results related to the need
for “policy-driven” (33% RPS) and economic (congestion reduction) transmission upgrades.
The CAISO will consider these results, together with those of the reliability studies conducted
earlier in the process, as it formulates proposals for new transmission upgrades in the draft
comprehensive plan to be issued in January.
LSA’s comments address the issues summarized below. These comments are further
explained in the remainder of this document.
  The CAISO should consider designating certain GIP-identified “backbone” Network
   Upgrades as “policy-driven” upgrades in the TPP, because they have been modeled in the
   base case for all clusters and are necessary for California to meet the 33% RPS goal.
  The CAISO should explain the changes made to the CREZ-capacity assumptions in its TPP
   supply portfolios and, in the future, provide more explanation of changes to the
   assumptions used in its transmission plans.
  The CAISO should reconcile its generation resource and transmission assumptions, since
   the inconsistency between them could be impacting the study results.
  The CAISO should explore problems associated with Distributed Generation (DG) further
   before recommending solutions, since the solutions could cause problems themselves.
  The CAISO should ensure that CAISO BAA generation projects in Queue Clusters 3 and 4
   (QC3 and QC4) and the RA imports enabled through the new Maximum Import Capability
   (MIC) mechanism are treated equitably.

GIP-identified Network Upgrades
LSA requests that the CAISO address - and propose solutions - to a fundamental issue
concerning the TPP and how it integrates with the Generation Interconnection Process (GIP).
Specifically, certain transmission projects have been identified as needed to interconnect
generation projects in the serial queue. While these projects have been modeled in the TPP
base case for several cycles and are relied upon by all subsequent clusters, some of these
upgrades are not progressing because the developer assigned to fund such projects is not
meeting milestones and/or is in suspension.
In order for California to meet its RPS goals, the CAISO must resolve this issue. LSA believes
that the construction of these major “backbone” upgrades should not be tied to one project
moving forward. Instead, the CAISO should consider awarding certain GIP-identified Network
Upgrades – including those for serial-study projects – “policy-driven” status, because they
have been included in the base cases, not only for interconnection studies covering thousands
of MWs of later-queued generation, but also for the reliability and economic studies that form
the foundation of the entire 2011-2012 transmission plan.

Tying such transmission projects to a particular LGIA moving foward could otherwise
seriously impact the progress of later-queued projects that depend on those upgrades for
commercial operation and/or deliverability - for example, if there are dropouts (e.g., from the
CAISO’s current Queue Management efforts) or project suspension under the LGIA. Such
delays also could also raise questions about the effectiveness and economy of the CAISO
transmission plan, which assumes that these upgrades are in service. This could then hinder
California’s ability to meet the 33% RPS by 2020.
One example of such “foundational” upgrades experiencing these delays is the Pisgah-Lugo
Transmission Project. SCE agreed to fund this project, contingent on: (1) 100% abandoned
plant approval from FERC; and (2) one developer meeting its LGIA milestones. FERC granted
abandoned plant recovery, but the developer suspended its LGIA. SCE will not fund the line
until the suspension is lifted and the generator begins to meet its milestones, which could be
two years or more from now.
This impasse (and the potential cancellation of the upgrade, should the project drop out of the
queue) could nullify study results for all five subsequent clusters. Much of this uncertainty
could be addressed by designation of the new line in the TPP as policy-driven. (If the CAISO
does not include the line in the TPP as a policy-driven upgrade, it should consider a Section
205 or declaratory order filing to FERC to ensure that this upgrade can move forward and that
SCE is fully protected with 100% abandoned plant recovery, subject to prudency review.)

TPP supply portfolios
The CAISO presentation identified some changes in CREZ resource assumptions since a July 8
stakeholder meeting to discuss portfolio composition. In order to maintain the transparency
of the TPP, the CAISO should explain the criteria used to determine that these changes, and
not others suggested by stakeholders (including LSA) should be made.
Moreover, the CAISO has not adequately explained why it continues to consider the Cost-
Constrained Portfolio to be the “base” portfolio in the TPP. The CAISO used a “hybrid”
portfolio last year as the most likely buildout for the 33% RPS, but it has not stated its reasons
for switching to the very different assumptions in the Cost-Constrained Portfolio this year.
CAISO Tariff Section requires the CAISO to create a baseline scenario reflecting the
assumptions about resource locations that are most likely to occur. As LSA pointed out in its
comments on the July 8 meeting presentations, neither the CAISO nor the CPUC (which
developed the portfolios that formed the basis for the TPP portfolios) has provided any
information suggesting that the Cost-Constrained Portfolio is the most likely scenario to occur.

Moreover, as discussed at the December 8 stakeholder meeting, the question of which
transmission upgrades are needed to achieve policy directives cannot be answered simply by
studying the Base Portfolio (Cost Constrained). The CAISO should run scenarios using all four
(or more) portfolios, including stress scenarios for each, to determine where upgrades should
be defined as Category 1 projects to accommodate the maximum portfolio need. Analysis of
only the Cost Constrained Portfolio does not necessarily stress “foundation” transmission
projects, much less determine which upgrades will be fully utilized or identify the next level of
upgrades needed to achieve policy directives.

The CAISO should also incorporate more flexibility to accommodate eventual commercial
development in each area that differs from the assumptions in the portfolios, which are, after
all, only an educated guess. The CAISO should also consider the MW in the interconnection
queue in each CREZ (on a relative and absolute basis), to better assess commercial interest
and, therefore, where development is most likely to occur.
The CAISO should then develop a plan that can be adjusted over time to accommodate the
eventual commercial development in each area – for example, considering low-cost “upsizing”
in areas where development (based on the queue) could exceed the amounts assumed in the
portfolios, or allowing for future development in areas not served in the portfolios but with
considerable generation in the queue.
More generally, on a going- forward basis, the CAISO should explain changes to the
transmission plans and their inputs, including, but not limited to, changes to the generation
resource allocations to the different CREZs. Specifically, the CAISO should provide the
  The amount of generation capacity that each transmission project would deliver from each
  The maximum capacity values of the approved transmission projects, and any updates, in
   tables similar to Table 20 in the CTPG 2010 Study report; and
  Commercial interest values (PPA approved or pending approval) from the CPUC in the
   Discounted Core CREZ totals, as has been requested in numerous venues. In the future,
   these values should be updated by the CPUC in June of each year for the prior 12 months.

Generation-transmission assumption differences
In some areas, transmission additions associated with GIP-identified upgrades are modeled,
but the associated resources are not. Since generator location can greatly affect upgrades
identified in GIP studies, this inconsistency can skew the analysis results.
For example, the resulting TPP studies could identify a transmission plan with too many or
too few transmission upgrades. This could, in turn, either delay transmission development
necessary to reach the 33% RPS Goal or increase the cost to do so.
This issue has been raised in several forums, including GIP-2 and GIP-TPP integration, and the
CAISO should address it explicitly in the upcoming draft comprehensive plan. While it may be
helpful for the CAISO to identify GIP upgrades to include in the TPP regardless of the exact
generator location, the CAISO should clearly identify where it is making these assumptions
and then make sure that they do not distort the analysis results.
Distributed Generation issues
LSA encourages the CAISO to continue investigating potential impacts from Distributed
Generation (DG). The study results identified criteria violations triggered by DG. It is still
unclear how DGs were modeled in the base cases (e.g., the exact amount and locations of DGs).
This lack of clarity was compounded by the fact that only generic models were used for DG.

Further, LSA is concerned that some of the potential solutions described in the CAISO
presentations may have other operational implications. The study did not indicate how DGs
were interconnected (i.e., whether they were intermingled with the utilities' distribution
customers) or if they were visible or controllable by the CAISO. Without visibility or
controllability, the CAISO may have to require installation of voltage-control devices at other
locations (instead of requiring the DGs to have reactive power capability), or to curtail other
generation or intertie power flows (instead of curtailing or tripping DGs).
The chart below summarizes why some of the potential mitigation solutions in the study
results might cause problems:
    PROBLEM             SUGGESTED MITIGATION                       POTENTIAL PROBLEM
 Voltage problems Required +/- reactive capability range   Installation of numerous SVCs
 Thermal          SPS to drop generation                   Tripping/curtailment of
  problems                                                 “controllable” generators
 Congestion       Congestion Management                    Major generation/path restrictions
                                                           (which should be clarified)

In short, it is too early to draw any conclusions regarding DG until sufficient studies are
conducted that include the DG amounts and locations (substations) and go beyond the use of
generic models.

Deliverability of Imports
At the December 8 meeting, the CAISO presented, for the first time, the assumptions and
results of the Target Maximum Import Capability (MIC) studies. Specifically, the SCE study
results showed that the 1,500 MW Target MIC for imports from IID (Path 42 and Dixie
Valley/El Centro-Imperial Valley) can be achieved without deliverability constraints.
However, LSA is concerned that the assumptions used to reach these results, and thus the
results themselves, may not be appropriate. LSA agrees with the concerns expressed by some
during the RA Delivery of Imports Initiative that, between different resources assumptions in
the MIC and QC3/QC4 and the timing of the studies, QC3 and QC4 generation could be
assigned the cost of upgrades to accommodate the increased imports that will be served by
the Target MIC, and that if the analysis treated all generation equitably, that upgrades might
have been identified as needed to achieve the MIC targets.
Specifically: (1) the Target MIC studies were conducted using TPP portfolios, which have a
lower amount of generation in that area than GIP studies; and (2) the TPP studies were
conducted before the QC3/QC4 Phase II Studies. Thus, the imports served by the Target MIC
likely were assumed to use existing available transmission capability before QC3/QC4
generation connecting directly to the CAISO, and the presence of those imports could trigger
additional upgrades for the QC3 and QC4 generation.

The CAISO should treat the increased imports served by the MIC and QC3/QC4 generation the
same, i.e., with the same access to existing available transmission capability. LSA requests
that the CAISO confirm this concept and incorporate it into the final conclusions of the Target
MIC analyses and the upcoming QC3/QC4 Phase II Studies.
For example, the CAISO could treat imports similar to the proposed DG modeling methodology
in the Deliverability of Distributed Generation Initiative, where the study is based on the most
recent Phase II GIP base case and not the TPP portfolios. This would prevent the imports that
would be served by the Target MIC from being sequenced ahead of the QC3 and QC4 projects.

Additional information that should be provided in the Plan
  A list of all approved transmission upgrades, as provided in Table 20 of the CTPG October
   26, 2011 Phase 2 Study Report Draft, but with updated dates showing CAISO approval
   dates, CPCN status, and expected completion dates;

  List of High and Medium potential projects, with information indicating where they moved
   from one category to the next or have been classified as a policy-driven upgrade.

  Corrected dates of the renewable transmission projects (i.e. Coolwater – Lugo 500kV
   shows 2015 in the 2010/11 TPP, but the CAISO acknowledged in the December 8 meeting
   that date is incorrect.)


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