There is not enough information available at this time to make a specific finding that any transmission project will be able to reduce the LCR need in the SONGS service territory by 2022. Partially, this is because the ISO’s 2013/2014 TPP is not yet final. Beyond this, there are various approval and permit processes – as well as public input – before construction can begin. The construction process can take several years, and is subject to significant delay. We find that there is a reasonable possibility that at least one of the transmission solutions examined by SCE and SDG&E will be operational by 2022. The least complex of these projects is the Mesa-Loop-In project, which is therefore the most likely to meet this timeframe. We find based on the record the proposed transmission solutions in the record would most likely lower LCR needs, if completed in the appropriate timeframe. While the LCR effect of such potential transmission solutions has been quantified, we conclude that it is reasonable to consider this potential as a directional indicator rather than a reduction to the LCR needs identified by the ISO. Therefore, potential transmission solutions give us more confidence that it is not necessary at this time to authorize the utilities to procure all of the resources indicated to be necessary in the ISO’s study. TURN points out that it is conceivable that future transmission planning efforts by the two utilities and the ISO will identify additional transmission projects or other measures that can meet local need more cost effectively. We agree; however, this potential is speculative based on the record in this proceeding. 3.3.8. Demand Response The revised Scoping Memo sets out assumptions for demand response resources for 2018 and 2022. The demand response assumptions are the same for
transmission models), which effectively reduces minimum local need in the SDG&E sub-area to 620 MW (1,028 MW minus 408 MW). Thus, SDG&E has identified in this Track 4 a minimum need for new local resources in the San Diego sub-area of between 620 MW and 1470 MW by 2022. Of the 620 MW minimum need, SDG&E’s procurement strategy holds 70-120 MW open to be filled with demand response and/or energy storage resources (consistent with ISO for operational characteristics that address local reliability needs). For the remaining need, SDG&E requests authority to procure 500-550 MW of long leadtime supply-side resources, including conventional generation and/or renewable resources. Redondo Beach performed its own technical studies, using power flow analysis. Redondo Beach claims that its studies used the same inputs and assumptions as the ISO. Redondo Beach recommends procurement of 1,140 MW in the LA Basin and 753 MW in the SDG&E area. For the LA Basin, Redondo Beach recommends all procurement be from preferred resources based on its studies. SCE responds that, while Redondo Beach claims that their proposal is the only solution that addresses both the Western LA Basin sub-area as well as the greater SONGS area, the record shows that Redondo Beach only studied the Western LA Basin and did not perform a study to analyze the impacts on the greater SONGS study area. We do not agree with SCE that Redondo Beach’s study is incomplete in this regard. However, significant parts of Redondo Beach’s studies rely on interpretations of N-1-1 contingencies that are at odds with the ISO’s studies; we have already determined that we will defer to the ISO on this point. While we consider Redondo Beach’s recommendations along with those of other parties, we will rely on the ISO study (as modified herein) as the better analytical tool.
No. Party Track 4 Need by Utility (Need is incremental to any authorization already provided for in the Track 1 decision) Basis for Track 4 Need By Utility SCE SDG&E SCE SDGE 1. a) CAISO 80% 1,922 MW 612 From the results of CAISO’s LCR study assuming 80% of the needed identified in the SONGS area is allocated to the LA Basin and after deducting Track 1 authorization From the results of CAISO’s LCR study assuming 80% of the needed identified in the SONGS area is allocated to the LA Basin and after deducting Track 1 authorization 1. b) CAISO 2/3rds 1,222 MW 1,177 MW From the results of CAISO’s LCR study assuming 2/3rds of the identified need in the SONGS Area is assumed to be in the LA Basin, and after deducting Track 1 authorization From the results of CAISO’s LCR study assuming 2/3rds of the identified need in the SONGS Area is assumed to be in the LA Basin, and after deducting Track 1 authorization 2. SCE 500 NA Incremental to preferred resources and transmission Needed to meet the higher reliability standards used by CAISO particularly relating to voltage support and to mitigate uncertainty in assumptions including load growth NA
3. SDG&E NA 1,320 – 1,470 MW without could be reduce to 370 – 820 MW with major new (Jontry at 10-11) NA From results of SDG&E power flow study cases which included 408 MW of load reduction or new supply by 2022 from preferred resources that currently do not exist.
10. Clean Coalition (CCC) 0 MW (at 8) 0 MW (at 8) No new conventional generation and transmission investments until full value of renewable resources assessed through public procurement and planning process. (at 8) 11. Environmental Defense Fund (EDF) EDF presented data indicating that no additional combustion resources are needed with the use of preferred resources, such as EE and demand response. EDF presented data indicating that no additional combustion resources are needed with the use of preferred resources, such as EE and demand response EDF commended SCE’s “Preferred Resources Scenario” approach, innovative pilot, and clear identification of the uncertain need for additional capacity. Recommends that the Commission refrain from rendering a decision until a comprehensive a set of analyses becomes available. (at 2-3) EDF points to the ability of demand response, including rates, as well as energy efficiency, distributed generation and other clean resources, to address the range of capacity needs currently identified by different parties.
13. Independent Energy Producers (IEP) 2,506 MW (including the Track 1 solicitation of 1,400-1,800 MW). If full 1,800 MW from Track 1 is procured, then Track 4 authorization should be 706 MW (2,506 – 1,800) (at 30) 820 MW However, if does not approve the Pio Pico then resource need would increase to 1,118 MW (820 + 298). (p. 30) Factors in SCE’s and SDG&E’s service area drive uncertainty in forecasting, which can result in under-estimating need and threatening grid, include (1) net load forecasts in local resources are subject to significant uncertainty because of energy reduction and uncertainty as to demand; (2) slow economic recovery could accelerate increasing demand; (3) some preferred resources may not prove viable skewing load forecasts; (4) new and upgraded transmission may be delayed. (at 12-14) While over-capacity might result in slightly higher costs, under-capacity would come with a very high social cost. (at 15) Track 4 authorization should be based on total resource need in Track 4 studies. (PHC Comments, at 2.) 14. National Resources Defense Council (NRDC) SCE’s local capacity need for LA Basin should be reduced by 543 MW under either CAISO or SCE models. (at 13) SDG&E’s local capacity need should be reduced by 211 MW as compared to SDG&E’s model results or 342 MW as compared to CAISO’s modeling results. (at 13) Reductions justified because energy efficiency assumptions were substantially underestimated. (at 13) Further reductions may be justified from inclusion of CAISO’s 2012/2013 transmission plan results and the CEC’s 2013 managed demand forecast results. (Testimony, at 9; Comments, at 2)
17. PG&E 3,302 MW (Table 2-1, at 2-4 of reply testimony) 1,770 MW (Table 2-1, at 2-4 of reply testimony) Figure II-1 of SCE Track 4 opening testimony, at 8. For SCE, PG&E uses the LA Basin Generation scenario and recommended additional 500 MW of procurement authorization as the identified need. Table 3 of SDG&E Track 4 opening testimony of John M. Jontry, at 12 18. Protect Our Communities (POC) NA 0 MW NA No additional authorization should be made at this time. Current CAISO N1-1 criterion is an unreasonable reliability measure to base Local Capacity Requirement need for SDG&E. In addition, the retirement of the Encina OTC should not be assumed when determining LCR need. Further, the San Diego local area must include the 1080 MW in generation assets connected to SDG&E’s Imperial Valley substation.
20. The Utility Reform Network (TURN) 500 MW (at 9) 500 MW (at 9) TURN believes there is no “grand plan” to answer the Southern California Reliability needs but that the Commission will need to incrementally consider from a series of competing measures to gradually meet such needs. (at 4-5.)
21. Vote Solar Before authorizing any additional resource procurement in Track 4, SCE should first fulfill entire Track 1 Preferred Resources (PR) procurement authorization and develop the Mesa Loop-In. Before authorizing any additional resource in Track 4, SDG&E should first fulfill entire Track 1 PR If additional resources are still needed, Vote Solar recommends using only PR and storage, phased-in over time as needed with annual solicitations; leverage Distributed Energy Resources (DER), storage & PV-DG to meet LCR in-basin and ensure reliability; use Living Pilot to test interoperability; include smart grid in Living Pilot; and ensure process is developed. Too maximize PV-DG, orient PV to west to address afternoon ramp and use intelligent inverters to provide voltage support on distribution grid; include both in Living Pilot. No need for land set aside for future generation development or options contracts for gas (though preferable to SDG&E Energy Park proposal) If additional resources are still needed, Vote Solar using only PR and storage, phased-in overtime as needed with annual leverage Energy Resources (DER), storage & PV-DG to meet LCR in-basin and ensure reliability; and develop a parallel pilot to SCE’s Living Pilot or participate in SCE’s Living Pilot. No need for Energy Park proposal.