2416 Cades Way Vista, California 92081 (760) 599–1813
[email protected] March 13, 2019
[email protected] California Independent System Operator Corporation 250 Outcropping Way Folsom, CA 95630 RE: Comments on the Draft 2019-2020 Unified Planning Assumptions and Study Plan Request for Economic Planning Study Dear CAISO Planners, As requested in the February 7, 2018 Market Notice from the California Independent System Operator Corporation (“CAISO”) announcing the February 28, 2018 Planning Process meeting, The Nevada Hydro Company, Inc. (“Nevada Hydro”) is herein submitting comments on the CAISO’s Draft 2018-2019 Unified Planning Assumptions and Study Plan (“Plan”). Under the CAISO open access transmission tariff (“Tariff”) Sections 24.3.2.2, 24.3.2.4, 24.3.2.5, Nevada Hydro is submitting its Lake Elsinore Advanced Pumped Storage (“LEAPS”) project (FERC Project P–14227) to the CAISO and herein requests that it be included 2019-2020 Study Plan and that this letter be considered as an Economic Planning Study Request for LEAPS. As described in detail below, Nevada Hydro requests that LEAPS be studied and included in the Plan as a “transmission” resource that will provide economic benefits reliability to the State’s ratepayers. Nevada Hydro also intends to submit this project into the 2019-2020 “Request Window” to be studies as a reliability solution. 1.0. The CAISO Tariff requires that LEAPS be treated as a transmission asset The Tariff § 24.3.3(a) provides an opportunity for stakeholder comment on the draft Plan to address three things: (1) demand response programs for inclusion in the base case, (2) generation and other non-transmission alternatives for consideration, and (3) Federal, state and local public policy requirements to be included in the plan.