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 CPUC directives. 

 


Statewide Transmission Issues

California Independent System Operator (CAISO) Transmission Planning Process

The 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.


Pacific Gas and Electric Company (PG&E)

Contra Costa—Oakley Generation Tie Line Project (Application (A.)15-06-015)

On June 17, 2015, PG&E filed Application 15-06-015 at CPUC. Under this application, PG&E proposed to construct a generation tie line to interconnect the Contra Costa Generating Station to its transmission grid. PG&E estimated that the cost for this project will be approximately $6 million.

On July 22, 2015, the Office protested this application based on the fact this project is not needed because the Contra Costa Generating Station does not exist and will not likely be constructed in the foreseeable future.

On February 6, 2017, PG&E filed a motion to dismiss this application without prejudice. On February 17, the Office filed a response to PG&E’s motion to dismiss the application with prejudice. On September 11, 2017, the Administrative Law Judge issued a proposed decision on the application, granting PG&E’s motion to dismiss the application without prejudice. On November 1, 2017, the Commission issued a final decision dismissing the application without prejudice.

 


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 Office is awaiting the Commission to schedule a prehearing conference for this application.

 


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 kV 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 estimation, 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 Office is awaiting Commission’s issuance of the Draft Environmental Impact Report.


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 cost of the above two projects would be $638 million.

On November 5, 2009, the 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.

On July 20, 2016, the Office filed comments to the Draft Environmental Impact Report (DEIR). In the 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.

 


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 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. The Office and parties are awaiting SCE’s proposed low voltage designs for this project.

 


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 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 Office is awaiting for the Administrative Law Judge’s scoping ruling.

 


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 would replace existing conductor, remove existing wood pole structures, and install new steel pole structures along an approximately 10-mile long, 69 kV power line in northern San Diego County and southern Orange County.

On May 31, 2016, the Office filed protest to the application. The Office is awaiting the Administrative Law Judge’s scoping ruling.

 


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 protest 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. Additional evidentiary hearings have been scheduled for November 17, 2017. The Office will file briefs and reply briefs when the final environmental impact for the project is issued by the Commission.