XVI. Integrated Generation and Transmission System Planning, Timing, Planning, Flexibility

PG&E suggests that an iterative process between resource planning and transmission planning is needed, so both can be planned in an orderly manner. However, it is PG&E's position that until the locations, timing and characteristics of the new resources can be identified and incorporated into the resource mix, it is not possible to definitively identify the transmission needed to accommodate them. PG&E adds that it is not desirable to plan transmission based on speculation that certain resources may develop. PG&E argues that to do so would waste ratepayer money and distract attention from developing transmission projects whose need is more immediate.

SCE believes that transmission and deliverability issues should be considered during the individual RFP solicitations in the economic evaluation of the individual bids.

SDG&E believes that its LTPP emphasizes the need for a diverse portfolio of supply- and demand-side options, as well as transmission, in order to balance lowest cost with reduced volatility and risk.

CEERT alleges that only SDG&E presented a credible renewable procurement plan integrating both resource and transmission planning. UCS found that each of the utilities' LTPs should be supplemented to add specific and detailed information on transmission upgrades. UCS further adds that the CAISO's grid planning process is a complement to, but not a substitute for, the Commission's oversight of the utilities' procurement responsibilities. NRDC states that the CAISO's transmission economic assessment methodology (the TEAM being examined in Phase 5 of our Transmission Investigation described in A.2.8 above) should complement more robust utility LTPs, but should not substitute for the integrated analysis necessary in the LTPs.

TURN found that the issue of integration of generation and transmission planning in long-term procurement planning was not explored in any real depth in this proceeding but notes that the Commission is exploring this issue in R.04-01-026 and Phase 5 of I.00-11-001. UCAN found the integrated analysis to be lacking. ORA urges the Commission to insist that the IOUs include consideration of generation alternatives in the "need" determination for proposed transmission lines.

NRDC believes that the IOUs should be directed to thoroughly compare "non-wires" alternatives to transmission projects in an integrated fashion and include more detailed information in future LTPPs about alternatives to the proposed transmission projects that were considered.

The Commission agrees that the issue of integration of generation and transmission planning was not fully explored in this proceeding. The Commission also agrees that the utilities' LTPPs did not fully integrate generation and transmission planning. However, as discussed earlier, we note that the Commission intends to explore this issue more fully in R.04-01-026.