Comments on Draft Decision

The draft decision of the ALJ in this matter was mailed to the parties in accordance with Section (311(g)(1) of the Public Utilities Code and Rule 77.7 of the Rules of Practice and Procedure. Comments were filed on March 1, 2001 by the City and County of San Francisco, ISO, ORA, PG&E, Ridgetop, SCE and SDG&E. Based on those comments, we have made several editorial changes, clarifications and minor corrections to staff'' report (Attachment 1). However, we do not make substantive changes to the recommendations contained in the staff report, with two exceptions. In light of comments by the ISO and SCE, it appears that the Victerville-Lugo upgrade (Project #31 in the draft decision) cannot be built by summer 2001, and may involve additional costs to the Los Angeles Department of Water and Power. In Addition, the Cortina-Colusa upgrade (Project #25 in the draft decision) will not be completed until 2002. As a result, we have removed them from the list of Phase 1 upgrades, but may consider them further during Phase 2. We also clarify that utilities are to file Advice Letters to increase their distribution revenue requirements, without modifying current rates, to reflect the costs of the upgrades authorized today, consistent with the language of AB 970.

Finding of Fact

The staff recommendations for transmission upgrades presented in Attachment 1, as summarized in Table 2, are reasonable and necessary improvements to the utilities' transmission systems.

Conclusions of Law

1. The transmission projects listed in Table 2 are high priority candidates for relieving transmission constraints on the electric system by summer, 2001. The utilities should proceed expeditiously with their implementation.

2. The utilities should continue submitting monthly status reports on these transmission projects as well as interconnections with new generation facilities.

3. In order to proceed with needed transmission upgrades as expeditiously as possible, this order should be effective today.

INTERIM ORDER

IT IS ORDERED that:

1. Pacific Gas and Electric Company, San Diego Gas & Electric Company and Southern California Edison Company, collectively referred to as "the utilities" shall develop the transmission projects recommended by staff and listed in Table 2.

2. The utilities shall file monthly status report on the transmission upgrade projects included in their filings and in Table 2. For each project, the report shall include information on the status of the notice of construction, if applicable, and the status of construction. The report shall also include information on whether a completed transmission upgrade project has resolved the transmission constraint it was intended to address. In addition, as discussed in this decision, the utilities shall report progress on remedial action schemes taken to improve transmission access and the system's ability to meet electricity demands. With regard to the generation projects that are underway in response to the Independent System Operator's solicitation, the monthly reports shall also include status information regarding the completion of interconnection studies and whether the projects involve utility-constructed facilities that would need to come before the California Public Utilities Commission (Commission). The reports shall be filed with the Commission's Docket Office on the first of each month, and be served on all appearances and the state service list in this proceeding. The utilities shall continue this monthly reporting until December 31, 2001, unless otherwise directed by the Assigned Commissioner or Administrative Law Judge.

3. As discussed in this decision, the utilities shall increase their distribution revenue requirements, without modifying current rates, to reflect the costs of the upgrades authorized today by filing Advice Letters for this purpose. The Advice Letters shall be filed within 30 days of the effective date of today's decision, and copies shall be served on all appearances and the state service list in this proceeding.

This order is effective today.

Dated , at San Francisco, California.

Attachment 1

RELIEVING TRANSMISSION CONSTRAINTS

An Overview in Response to AB 970

Energy Division

California Public Utilities Commission

March 12, 2001

CONTENTS

Executive Summary

Background

Short-Term Transmission System Constraints and Projects

Long-Term System Constraints and Projects

Tables and Maps

Appendix A How the Transmission / Distribution System Operates

Appendix B Methodology /Limitations of this Report

Appendix C Constraint Summaries

Appendix D Project Summaries

Appendix E Electrical Glossary EXECUTIVE SUMMARY

AB 970 requires the California Public Utilities Commission to identify constraints in California's transmission and distribution system and to take actions to remove them.

This report identifies constraints, and utility projects underway or planned to mitigate them either by 2001 or between 2002-2005.*

This report identifies 51 constraints on California's transmission and distribution system that either exist now, or will exist by summer 2001. This report also identifies an additional 107 constraints that will affect the system's reliability from 2002 to 2005.

This report recommends that in year 2001, utilities should complete 31 projects, costing $120 million, to address 38 of the 51 constraints. Twenty-seven of these projects should be completed by summer 2001. (The other four have later completion dates.) These projects increase system capacity to allow more energy to flow to consumers, improve system reliability by making the system more stable, and/or allow access to a wider range of generation sources, some of which may supply cheaper power.

These projects increase capacity by more than 3,000 megawatts (MW). Benefits are not strictly additive, however, because most of the projects affect a specific local area rather than the system as a whole and relieving one constraint can shift power flows to other parts of the system that may become new constraints. On the other hand, many projects provide benefits, such as a reduced chance of outages or an improvement in local voltage, that are not measurable in megawatts. The benefits of individual projects, including capacity increases where relevant, are discussed in more detail in two sections of this report, Short-Term Transmission System Constraints and Projects and Long-Term System Constraints and Projects, and in Appendix D.

Most projects are on PG&E's transmission system. The extent to which the projects improve transmission system reliability will depend in part on demand for electricity, weather, and the amount of new generation added in California before summer 2001.

Currently, the state has no process for conducting comprehensive analysis of California's transmission and distribution system that considers costs and benefits of various options to improve reliability. Accordingly, this report recommends the Commission initiate a process for such analysis and recommends further study of several specific issues that will affect the state's transmission system in the longer term:

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* This report was originally released on February 13, 2001, and revised in response to comments.

399.15. Notwithstanding any other provision of law, within 180 days of the effective date of

In addition, Section 4 of AB 970 allows air pollution control districts to issue expedited permits for power plants if: the power plant will be interconnected to the grid in a manner that the Public Utilities Commission, in consultation with the Electricity Oversight Board, has determined will allow the power plant to provide service to a geographical area of the state that is urgently in need of generation in order to provide reliable electric service.

· identifies constraints on California's transmission system that exist now or will appear by 2005.

· evaluates specific transmission projects that can relieve those constraints for summer 2001.

· identifies projects designed to relieve constraints planned for completion 2002-2005.

PG&E Territory

All but 5 of the 31 recommended projects are to reduce or remove the normal overload, stability, RMR, contingency, and economic transmission system constraints in PG&E's territory. Unlike SCE and SDG&E, PG&E's capital investment strategy has been to build local generation rather than transmission. PG&E cut back its infrastructure investments during the l990s and made limited investments in redundant distribution-related facilities. Therefore, many of PG&E's current projects were discussed internally years ago, but not built. PG&E has over the last three years doubled its transmission investment.

The ISO has identified several projects that will increase the redundancy of PG&E's system. While greater redundancy should improve system reliability, this report does not assess the cost-effectiveness of these projects or whether the investments would be better spent on other transmission projects or on distribution. This is an important issue for subsequent study.

SCE Territory

SCE spent more than PG&E on transmission, relied less on local generation, and more made investments on redundant system components to relieve stability and contingency constraints.

SDG&E Territory

SDG&E followed an intermediate strategy, depending on local generation, but making more investments in redundant system components to relieve contingency overload, and bulk power constraints.

Contingency Overloads

Contingency overloads occur when nearby equipment fails during peak periods. Some contingency overloads threaten system stability. Such equipment failures can cut power supplies directly (if the only transformer serving a substation shuts down) or cause power to re-route itself and overload other equipment still in service (as when one of two transmission lines into a substation fail). Since equipment is in service most of the time, such overloads are much less likely than normal overloads, but can occasionally interrupt service to customers.

Transmission studies have identified three areas where overloads or frequency problems are expected in year 2001 if outage contingencies occur during peak periods. PG&E has proposed three projects18 to address these previously unsolved problems at a cost of about $19 million. The ISO has approved all three projects, and they are expected to be completed by summer 2001.

2 In response to a data request, the ISO provided a list of 11 economic constraints 3 In addition to the two projects discussed here, this report recommends several projects we that do not appear on the project list posted on the ISO's website as of February 2, 2001. However, we have confirmed that all of those projects do appear on a new version of the ISO's list that has not yet been posted. 4 PG&E plans to add 100 MVARS of capacitor to Martin Station. We recommend that PG&E replace two existing 25 MVAR capacitors by two 50 MVAR capacitors. 5 Path 15 connects the southern part of PG&E's territory (including Morro Bay and Diablo 6 See Table 5. Path 15 was congested at least a few hours in every month of the year 2000. 7 Such conditions reduce the ability of a transmission conductor to shed heat generated by 8 Projects numbered 1, 4, 13, 14, 15, 17, 22, 23, 24, 25. 9 Los Medanos Energy Center (formerly Pittsburg District Energy Facility), generating 500 10 Project 28. Capacity has been limited to 2800 MW, since larger flows would damage 11 Generally speaking, operating reserves are electric generators that are not generating 12 Phone conversation with Armando Perez, Director of Grid Planning, California ISO. 13 The ISO classifies these load centers as RMR areas when two conditions apply. First, the 14 This raises the issue of why the ISO did not sign contracts to guarantee statewide reserves

15 # 7, Oakhurst Area Reinforcement (Exchequer Powerhouse); # 20,Janes Creek-Humboldt

16 Distribution substations are the link between the high voltage transmission system and the

17 Fulton 60 kV Line reinforcement Project; Coyote Valley Distribution Substation Project;

18 Grant-East Shore 115 kV Breaker Project; Lakewood Area Transmission Reinforcement

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