Transmission

Public Advocates Office (the Office) represents ratepayers in transmission proceedings to determine if an electrical corporation satisfies the requirement for Permit to Construct (PTC) and Certificate of Public Convenience and Necessity (CPCN) applications and that the utility makes a “showing that the present or future public convenience and necessity requires or will require such construction.”

For PTC applications, the Office focuses its review on transmission projects to ensure the project is environmentally sound and that project costs are reasonable. In CPCN applications for major transmission lines, the Office focuses on issues relating to the determination of “need” for a proposed project, including cost-effectiveness, long-term planning, reliability requirements, and compliance with state policy and related California Public Utilities Commission (CPUC) directives. 

 


Statewide Transmission Issues

California Independent System Operator (CAISO) Transmission Planning Process

The California Independent System Operator (CAISO) Transmission Planning Process (TPP) is an annual process that takes two years. In conducting the TPP, the CAISO works with participating transmission owners, neighboring balancing authorities, sub-regional planning entities, and other stakeholders. In TPP, the CAISO considers local, sub-regional, and regional transmission situations, load growth, generation development and plant retirements. The TPP consists of the following three steps:


  1. Development of CAISO unified planning assumptions and study plan, 
  2. Technical studies and the CAISO Board Approval of transmission solutions,  
  3. Contract awards to develop the identified transmission solutions.  

 

The Public Advocates Office participates in CAISO’s TPP.

 

After a project is approved by the CAISO’s TPP, the utility may file the project as an application at the CPUC, requesting to recover transmission projects costs from ratepayers. For Example, for the CAISO 2017-2018 TPP, the Office Recommended Consistency Between Local Capacity Technical Criteria and Transmission Planning Standards, which the CAISO is considering in the 2018-2019 TPP.


Pacific Gas and Electric Company (PG&E)

South of Palermo 115 kV Power Line Reinforcement Project (A.16-04-023)

On April 28, 2016, PG&E filed Application 16-04-023 at CPUC. In this application, PG&E proposed to re-conductor approximately 59.5 miles of 115 kilovolt (kV) transmission lines for the Palermo—Rio Oso transmission system. This project would cost ratepayers more than $109 million.


On June 1, 2016, the Office filed a protest to this application and identified the discrepancies of PG&E’s application with CAISO’s study results, including the length of transmission lines that need to be re-conductored, and the per unit cost for the re-conductoring.

The Commission issued Decision 18-05-014 on May 5, 2018, granting PG&E its request.

Estrella Substation and Paso Robles Area Reinforcement Project (A.17-01-023)

On January 25, 2017, PG&E and NextEra Energy Transmission (NEET) West filed joint Application 17-01-023 with the CPUC. Under this application, NEET West proposed to construct a 230 kilovolt (kV) transmission line as part of the Estrella Substation, including the 230 kV switchyard, and the 230/70 kV transformers. Under the same application, PG&E proposed to construct the 70 kV component of the Estrella Switchyard and approximately 10 miles of 70 kV transmission lines.

Based on CAISO’s estimate, the project cost will not be more than $45 million. However, based on the applicant’s cost estimate, the project cost will be more than $100 million.

On March 6, 2017, the Office filed a protest to this joint application. The Office identified issues such as the need for the project, project alternatives, and lack of project coordination agreement between PG&E and NEET West.

The Commission issued Decision 18-07-038 on July 26, 2018, extending the statutory deadline for the proceeding to August 31, 2020 to allow the Commission's Energy Division time to complete the environmental impact report (EIR) for the project. Stakeholders and parties will have an opportunity to comment on the draft EIR after it's completed.


Southern California Edison Company (SCE)

Valley—Ivyglen Transmission Line Project and Alberhill System Project (A.07-01-031 and A.09-09-022)

On January 16, 2007, SCE filed Application (A.) 07-01-031 for a Permit to Construct (PTC) the Valley-Ivyglen (VIG) project. The proposed VIG project consists of the construction of 27 miles of transmission lines. SCE estimates the project cost to be $174 million.

On September 30, 2009, SCE filed A. 09-09-022 to construct the Alberhill System Project (ASP). ASP consists of the Alberhill 500 kV Substation, 3.3 miles of double-circuit 500 kV transmission lines to loop in the Alberhill Substation to the Valley-Serrano 500 kV transmission line, and 25 miles of 115-kV transmission lines. SCE estimates the cost for the ASP would be approximately $464 million.

Total estimated cost of the above two projects is $638 million.

 
On November 5, 2009, the Public Advocates Office filed a protest to A.09-09-022. In its protest, the Office advocated that ASP should be filed as a Certificate of Public Convenience and Necessity (CPCN) instead of as a Permit to Construct (PTC) application to enable the Commission to evaluate the need and cost of the project.

 

In April 2017, the CPUC issued the Draft Environmental Impact Report (DEIR). On July 20, 2016, the Office filed comments to the Draft Environmental Impact Report (DEIR). In the DEIR comments, the Office proposed to consider the two projects together and proposed five alternatives for the Commission’s consideration.

On June 8, 2017, the Office lobbied the CPUC Commissioners and proposed to consolidate the following four projects into one: Valley—Ivyglen Project, Alberhill System Project, Riverside Reliability Transmission Project, and Circle City Project, in order to save ratepayer money while improving power supply reliability at the same time. The Office proposed three options to consolidate these four projects .

 

On August 28, 2017, the Office filed testimony advocating for the consolidation of the VIG project and the ASP project into one project and provided three options for the Commission to consider. Based on the Office’s cost estimate, the consolidated project cost would cost less than $250 million, saving ratepayers over $400 million.

 

The Office participated in evidentiary hearings held by the Commission on October 17 and 18, 2017 for this proceeding. The Office filed opening brief on November 30, 2017 and reply brief on January 4, 2018. In addition, the Office filed reply comments on the Administrative Law Judge (ALJ) proposed decision on April 30, 2018, supporting the ALJ's proposal to approve the Ivyglen project and to deny the Alberhill project. The Office also filed reply comments to the Commission's alternate proposed decision (APD) on July 24, 2018, supporting the Commission's proposal to approve the Ivyglen project, but opposed the APD's proposal to deny the Alberhill project without prejudice. The Commission issued a final decision (D.18-08-026) on this proceeding on August 31, 2018, approving the Ivyglen project and denying the Alberhill project, without prejudice. This decision allows SCE to file an application for the Alberhill project in the future if it elects to do so.    

Riverside Transmission Reliability Project (A.15-04-013)

On April 15, 2015, SCE filed A.15-04-013 at the CPUC. In its application, SCE proposed to construct a 220 kilovolt (kV) substation and approximately 10 miles of double-circuit 220 kV transmission lines. SCE’s cost estimate for the project is $235 million, however, based on CAISO’s recommendation in 2006, the project cost estimate was $52.5 million.

On May 22, 2015, the Office filed a protest to the application and noted that the project may not be needed and that the cost estimation may not be just and reasonable.

On June 8, 2017, the Office lobbied the CPUC Commissioners and proposed to consolidate the following four projects into one: Valley—Ivyglen Project, Alberhill System Project, Riverside Reliability Transmission Project, and Circle City Project, in order to save ratepayer money while improve power supply reliability. The Office proposed three options to consolidate these four projects.

On August 15, 2017, CPUC issued a ruling, directing SCE, Riverside Public Utilities, and CAISO to prepare a joint report to identify the lower voltage designs or interim remedies to the proposed project, in order to address any reliability concerns. SCE's filed its proposed low voltage designs for this project on August 15, 2017.

 

The Commission's Energy Division issued its Draft Subsequent Environmental Impact Report (DSEIR) for this project on April 2, 2018. The Office filed comments on the DSEIR on May 17, 2018 and recommended that the Riverside project and SCE's proposed Circle City substation project (A.15-12-007) be consolidated. The Office proposal would meet the project objectives of SCE's proposed Riverside and Circle City substation projects and would result in less cost and less environmental impact by eliminating the construction of  two substations.

 

The Public Advocates Office is awaiting further Commission action on this proceeding.

Circle City Substation and Mira—Jefferson Transmission Line Project (A.15-12-007)

On December 4, 2015, SCE filed A.15-12-007 at CPUC. In its application, SCE proposed to construct Circle City 66 kilovolt (kV) Substation, and approximately 21 miles of 66 kV transmission lines.

On January 6, 2016, the Office filed a protest to the application and noted that the project may not be needed and that the project be consolidated with the Riverside Transmission Reliability Project.

On June 8, 2017, the Office lobbied the CPUC Commissioners and proposed to consolidate the following four projects into one: Valley—Ivyglen Project, Alberhill System Project, Riverside Reliability Transmission Project, and Circle City Project, in order to save ratepayer money while improve power supply reliability. The Office proposed three options to consolidate these four projects.

The Commission's Energy division issued a Draft Environmental Impact Report (DEIR) for this project in May 2018 and recommended a lower voltage and less costly design alternative to the SCE's proposed project. The Office concurred with the DEIR recommendation. The final EIR is anticipated to be issued in November 2018.

 

Eldorado-Lugo-Mohave (ELM) Series Capacitor Project (A. 18-05-007)

On May 2, 2018, SCE filed Application (A. 18-05-007) with the CPUC for a Permit to Construct (PTC) authorizing construction of its proposed 500 kilovolt (kV) Eldorado-Lugo-Mohave (ELM) Series Capacitor Project to integrate renewable generation and relieve area deliverability constraints. SCE proposes to construct the new 500 kV series capacitors at the middle of the Eldorado-Lugo 500kV line and at the middle of the Lugo-Mohave 500kV line. In addition, SCE proposes to install 235 miles of optical ground wire (OPGW). SCE's ELM project would take place between the existing Eldorado, Lugo, and Mohave substations located south of Las Vegas, in Hesperia, and in Laughlin, respectively.

 

SCE's cost estimate for the project is approximately $225 million.

 

On June 1, 2018, the Public Advocates Office filed a protest to the ELM application. The Public Advocates Office advocated for the rejection of SCE's ELM application and recommended that SCE resubmit its ELM application as a Certificate of Public Convenience and Necessity (CPCN).

 

On July 5, 2018, the Public Advocates Office filed a response to SCE's reply to the Public Advocates Office's protest of SCE's ELM application.

 

On August 24, 2018, the Public Advocates Office participated in the Pre-Hearing Conference for A. 18-05-007, SCE's ELM application.

 

The Public Advocates Office filed its opening brief on SCE's ELM application on October 12, 2018 and reply brief on October 26, 2018 and is awaiting further Commission action on this matter.


San Diego Gas and Electric Company (SDG&E)

TL (Tie Line) 695 and TL 6971 Re-conductor Project (A. 16-04-022)

On April 25, 2016, SDG&E filed A.16-04-022 with the CPUC. This Permit to Construct (PTC) application is to construct TL 695 and TL 6971 Re-conductor Project. SDG&E proposing replace existing conductor, remove existing wood pole structures, and install new steel pole structures along an approximately 10-mile long, 69 kilovolt (kV) power line in northern San Diego County and southern Orange County.

On May 31, 2016, the Office filed protest to the application.

 

The Commission issued a decision (D.18-03-019) for the proceeding on March 22, 2018 approving SDG&E proposed project.

 

 

NextEra Energy Transmission (NEET) West

Suncrest Dynamic Reactive Power Compensation Project (A. 15-08-027)

On August 31, 2015, NEET West filed A.15-08-027 with the CPUC for a Certificate of Public Convenience and Necessity (CPCN) to construct a 300 Megavolt Ampere Reactive (MVAR) Static Var Compensator (SVC) at SDG&E’s Suncrest Substation in order to provide voltage support for the delivery of renewable generation from the Imperial Valley area. NEET West proposed to construct the 300 MVAR SVC approximately one mile away from the Suncrest Substation, and a one-mile long underground cable to interconnect the SVC to the 230 kV bus in the Suncrest Substation.

NEET West’s cost estimation for the project cost is approximately $50 million.

On October 5, 2015, the Office filed a response to the application. The Office advocated for the construction of the SVC equipment within SDG&E’s Suncrest Substation footprint, which is estimated to save ratepayers at least $5 million.

On February 8, 2016, the Office filed comments to CPUC’s Notice of Preparation of an Environmental Impact Report. On January 10, 2017, the Office filed comments on the Draft Environmental Impact Report. On May 16, 2017, the Office filed prepared testimony. On July 18, 2017, the Office filed rebuttal testimony.

On August 29-30, 2017, the Office participated in the evidentiary hearings. The Office also participated in the additional evidentiary hearings held November 17, 2017.


The Office filed opening brief on this proceeding on March 5, 2018 and reply brief on April 4, 2018 and reemphasized the need to contruct the SVC equipment within SDG&E's Suncrest Substation footprint to save at lease $5 million of ratepayers' funds.


The Commission issued a decision (D.18-08-028) on this proceeding on August 23, 2018 and extended the statutory deadline in this proceeding to November 26, 2018.


The Office participated in the oral arguments held by Commission on this proceeding on September 18, 2018 and is awaiting the Commission's final decision on this proceeding.

 

Delaney Colorado River Transmission Ten West Link Project (A. 16-10-012)

Background

The Delaney Colorado River Transmission LLC (DCRT) Ten West Link Project filed this application with the California Public Utilities Commission (CPUC) to build a 500 kiloVolt (kV) transmission line approximately 114 miles long. Of the 114 miles, approximately 17 miles would be in California and the remainder in Arizona. The California Independent System Operator (CAISO) approved the Ten West Link Project in its 2015 transmission planning and solicitation process, primarily as an economic project.

 

DCRT estimates the Ten West Link Project will cost approximately $280 million and would be completed within 38 months. DCRT proposes the cost of the project would be paid by California ratepayers.

The Public Advocates Office Position

The Public Advocates Office is currently evaluating DERT's application and filed a protest to the application on November 28, 2016. The Public Advocates Office is actively participating in the proceeding and is analyzing the need, cost, and potential alternatives to the Ten West Link Project.

 

Current Proceeding Status

DCRT filed the application for the Ten West Link Project with the CPUC in October 2016. The Bureau of Land Management (BLM) is the lead environmental agency for the project and released its Draft Environmental Impact Statement (DEIS) for the project on August 31, 2018. Comments on the DEIS are due November 27, 2018.

 

DCRT held three public meetings on the project in Phoenix, Arizona; Quartzsite, Arizona; and in Blythe, California in October 2018. Further Commission action is pending on this proceeding.

 

Click here to view the current scoping ruling and schedule.

 

Other Resources

Click here to view the CPUC's docket information for A.16-10-012.

Click here to view the CPUC CEQA review project overview page.

Click here to view the Bureau of Land Management (BLM) project environmental review website.