IV. Alternatives to the Proposed Project and the No Project Alternative
Our evaluation of whether SCE should be granted a CPCN to construct the Tehachapi-Vincent Transmission Project would not be complete without consideration of alternatives to the proposed project. Additionally, in accordance with CEQA requirements, the Final EIR evaluates the No Project alternative. In essence, the No Project alternative examines impacts if the proposed project, or a variation thereof, is not approved and built.
A. Alternatives to the Proposed Project
Transmission of wind power from the Tehachapi and Antelope Valley areas is currently restricted by limited capacity and reliability of the existing SCE transmission system. As discussed in Section A.2 of the Final EIR, the existing Antelope-Mesa 220-kV transmission line is restrictive to wind power transmission due to limited capacity. This transmission line would overload with the addition of new power to the system, including that received from wind generation. Overloading of the Antelope-Mesa transmission line would cause widespread system instability and reliability issues.
Meanwhile, there is ongoing development of wind power generation projects in the Tehachapi region, north of Antelope Substation. Because SCE is obligated to allow connection of new wind projects to its system, upgrades must be implemented to mitigate identified overload of the Antelope-Mesa transmission line in order to maintain system reliability as required by the National Electric Reliability Council (NERC) and the Western Electric Coordinating Council (WECC) planning standards as well as the ISO planning standards.
The proposed Project would provide needed transmission capacity to mitigate the potential overload of the existing Antelope-Vincent 220-kV transmission line, and would reduce loading on the Antelope-Mesa 220-kV transmission line to within the allowable line conductor thermal limits.
The proposed Project would also increase transmission capability south of the Antelope Substation and allow power generated in the Antelope Valley and Tehachapi areas to be safely transferred, thus serving system load on the SCE grid.
The proposed Project would initially be operated at 220 kV in order to meet near-term transmission needs associated with ongoing wind development. However, the line would be built to 500-kV standards so that as renewable power loads increase, future overloading of transmission facilities would be avoided. The ISO, which manages transmission grid reliability for the State of California, has approved the proposed project using a 500-kV transmission line. The CAISO maintains that the use of 500-kV standards for the proposed project will avoid the future need to construct and/or tear down and replace multiple 220-kV facilities with 500-kV facilities to meet growing power generation and transmission needs.
Moreover, as load grows due to increased electrical demand and power is received from other sources of generation, transmission overloading would occur in the vicinity of the proposed project. The Antelope-Mesa 220-kV transmission line could experience thermal overload if current power loads are increased, which is expected to occur as Southern California's population continues to grow at projected rates.
The proposed Tehachapi-Vincent project is needed now to accommodate wind generation projects that have applications pending before Kern County or Los Angeles County, or that may submit applications in the near future. However, the proposed project is also needed in order to increase reliability of the SCE transmission grid by increasing capacity to serve demand from planned development in the Antelope Valley.
Based on the foregoing uncontroverted evidence, we conclude that the Tehachapi-Vincent Transmission Project is needed to meet the demands of electricity customers south of Antelope Substation by increasing the capacity of the SCE system to a level that would accommodate proposed or planned wind energy projects, and there is no feasible alternative to the proposed project that can meet this need.
We accordingly conclude that, even with an increasing emphasis on energy efficiency and demand response, investments in transmission projects such as the proposed Tehachapi-Vincent Transmission Project will be needed both to enable California to meet RPS goals as well as to assure the continuing reliability and safety of the transmission grid in Southern California as renewable power generation and SCE customer demands increase. We further conclude that there is no alternative to the proposed Tehachapi-Vincent Transmission Project that can meet these needs better than the proposed Tehachapi-Vincent Project.16
B. The No Project Alternative
Under the No Project alternative considered in the Final EIR, the proposed Tehachapi-Vincent Transmission Project would not be built, and the existing transmission grid and power generating facilities would continue to operate. To serve the expected continued growth in electricity consumption and peak demand within California, additional electricity would need to be generated within California or imported into California by existing transmission facilities. In the No Project alternative, there could be supply-side actions, including accelerated development of conventional, renewable, and distributed generation, or other major transmission projects. Additional energy conservation or load management could also be pursued.
Under the No Project alternative, none of the associated project activities would occur and the environmental impacts associated with the proposed project, as described in Section C of the Final EIR would not occur, and the Tehachapi-Vincent Transmission Project's objectives, purpose, and need would remain unfulfilled.17 For example, the 350 MWs of initial transmission capability, when energized to 220 kV, would not be added between the Antelope and Pardee Substations, and the improved system reliability and operating flexibility associated with the proposed project would not occur.
As discussed in Section D.3.5 of the Final EIR, in the absence of the proposed project, SCE would still be required to interconnect and integrate power generation facilities into its electric system, as required under §§ 210 and 212 of the Federal Power Act (16 U.S.C. §§ 824 [i] and [k]) and §§ 3.2 and 5.7 of the ISO's Tariff. Several wind generation projects either have applications pending before Kern County or are in the advanced planning stage and expected to submit applications in the near future. Due to their locations, these upcoming wind generation projects will need to interconnect to the SCE transmission system via Antelope Substation or some other new substation located in the vicinity to allow power to be delivered to load in the Los Angeles area. However, these wind generation projects cannot be interconnected to the SCE transmission system without additional transmission infrastructure north of Antelope Substation and an increase in transmission capacity south of the Antelope Substation. Transmission of wind power from the Tehachapi and Antelope Valley areas is currently constrained by the existing Antelope-Mesa 220 kV transmission line, which would be overloaded by the addition of new wind generation. Therefore, without upgrades to the existing system, as new wind generation facilities are added to meet RPS Program requirements and Southern California's growing power needs, SCE's system would experience system-wide power flow and reliability problems due to overloading of the existing system, such as curtailed generation, thermal overload, and blackouts.
Under the No Project alternative, although connection to the transmission systems of other power utilities (such as PG&E or Los Angeles Department of Water and Power (LADWP)) is possible, this would not meet SCE's objectives for the Tehachapi-Vincent Transmission Project and would not satisfy the requirements of D.04-06-010.
Under the No Project alternative, the following scenarios related to the electric power system in Southern California can reasonably be expected to occur in the foreseeable future:
· Initial wind projects in the Antelope Valley and Tehachapi areas would be postponed or cancelled, as additional transmission capacity would not be available, or these proposed wind projects would have to find alternate means to connect to SCE's transmission system without compromising system reliability;
· The requirement of the RPS, which requires retail sellers of electricity such as SCE and PG&E to increase their sale of electricity produced by renewable energy sources to 20 percent by 2010 may not be achieved as access to renewable energy from the Antelope Valley-Tehachapi region would either not be provided or would be delayed;
· Other renewable energy resources would need to be identified and transmission studies conducted to connect these newly identified sources to the transmission grid, which would likely further limit achievement of the RPS goal by the 2010 deadline;
· The conceptual plan recommended by the Tehachapi Collaborative Study Group (TCSG)18 would not be fully implemented. This plan is intended to collect power from Tehachapi area wind projects, interconnect facilities into the State's backbone grid, and upgrade the network to reliably deliver that power to load centers. The conceptual plan, which would allow for the transmission of over 4,000 MWs of wind power, would not be fully achieved because the initial capacity that would have been provided by the proposed Tehachapi-Vincent Transmission Project would not be achieved; and
· Transmission providers such as SCE, PG&E, or LADWP would need to accommodate the power load by upgrading existing transmission infrastructure or building new transmission facilities along a different alignment or developers of wind generation facilities would build their own transmission facilities to connect to the transmission grid.
Finally, the Final EIR does not find that the No Project alternative would be environmentally preferable to the Environmentally Superior configuration of the proposed project. As we discuss above, because of the need both to enable California to meet the RPS as well as to assure the continuing reliability and safety of the transmission grid in Southern California as renewable power generation increases and SCE customer demands increase, the No Project scenario is not a desirable alternative to the proposed Project.
16 The route alternatives to SCE's proposed project are discussed in detail in Section V below.
18 The first TCSG Report was filed in I.00-11-001 on March 16, 2005 and a second TCSG Report was filed in the successor to I.00-11-001, I.05-09-005, on April 19, 2006.
