IV. Alternatives to the Proposed Project and the No Project Alternative
Our evaluation of whether SCE should be granted a CPCN to construct the Antelope-Pardee Transmission Project would not be complete without consideration of alternatives to the proposed project. Additionally, in accordance with CEQA requirements, the Final EIR/EIS 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 Antelope-Pardee Transmission 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 ES.1.2 of the Final EIR/EIS, 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. Furthermore, the existing transmission lines, which originate at SCE's Big Creek hydroelectric generation facilities and currently deliver power through Kern County and Magunden Substation to Antelope Substation, are also restrictive to wind power transmission due to reliability considerations.
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. As of February 2006, one active wind project, the PdV Wind Energy Project (PdV), was in the application review process with Kern County. PdV would connect up to 300 MWs of new power into SCE's system. SCE estimates that when the Antelope-Pardee Transmission Project is energized to 220 kV, it would allow for the connection of up to 350 MWs of new power without overloading the Antelope-Mesa 220-kV line. It would accomplish this by providing the capacity to transmit power from the Antelope Substation to the Pardee Substation rather than directing more power to the Antelope-Mesa line.
The PdV Project was the only active wind project with an application pending with Kern County at the time that the Antelope-Pardee Transmission Project application was filed. Based on information provided by SCE, there is not sufficient capacity in the current transmission grid to accommodate the full capacity of the renewable generation to be provided by the PdV Project once it is operational, while at the same time safeguarding the system from overload under increasing renewable power generation and loading. 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 Antelope-Pardee Transmission Project 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 Antelope-Pardee Transmission Project would initially be operated at 220 kV in order to meet current transmission needs associated with ongoing wind development and energy needs in Southern California. However, the line would be built to 500 kV standards so that as renewable power generation increases and SCE customer demands increase, future overloading of transmission facilities would be avoided. The ISO, which manages transmission grid reliability for the State of California, has approved construction of the proposed Antelope-Pardee Transmission Project using a 500 kV transmission line. The ISO maintains that the use of 500 kV standards for the Antelope-Pardee Transmission 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.
The proposed Antelope-Pardee 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, due to the location of the PdV Project and other potential wind generation projects in the Tehachapi Wind Resource Area, it is reasonably foreseeable that multiple wind generation projects will need to interconnect to the Antelope Substation to allow power to be delivered to load. Furthermore, as discussed in Section A.2.1 of the FEIR/EIS, the ISO interconnection queue indicates that a total of 2,122 MWs of wind energy generation facilities are currently in the planning stages for the Tehachapi and Mojave areas of Kern County.15 Accordingly, the Antelope-Pardee 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 Antelope-Pardee Transmission 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 Antelope-Pardee 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 Antelope-Pardee Transmission Project that can meet these needs better than the proposed Antelope-Pardee Project.16
B. The No Project Alternative
Under the No Project alternative considered in the Final EIR/EIS, the proposed Antelope-Pardee 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/EIS would not occur, and the Antelope-Pardee 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 A.3.1 of the Final EIR/EIS, 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 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 an increase in transmission capacity south of 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 Antelope-Pardee 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 Antelope-Pardee 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/EIS 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.
15 More recent information publicly available from the ISO indicates that there are more than 4,350 MW of planned generating facilities, primarily wind energy facilities, in the Tehachapi/Mohave area that are in the interconnection queue. These facilities are awaiting study of the transmission system upgrades that will be necessary in order to allow these generating facilities to interconnect to the grid and serve load.
16 The route alternatives to SCE's proposed project are discussed in detail in Section V below.
17 SCE's objectives for the proposed project are set forth in detail in Section A.3.1 of the Final EIR/EIS. In brief summary, SCE's purpose and need for the proposed project are to prevent overloading of the existing Antelope-Mesa transmission line by adding capacity between Antelope Substation and Pardee Substation and to increase the reliability of SCE's transmission grid by providing a new pathway to deliver power to load south of the Antelope Substation from generating facilities north of that substation.
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.
