STAKEHOLDER COMMENTS TEMPLATE Submitted by Company Date Submitted Matthew Freedman The Utility Reform June 22, 2016 Network [email protected] 415-929-8876 x304 Please use this template to provide written comments on the Clean Energy and Pollution Reduction Act Senate Bill 350 (SB350) Study initiative posted on April 25, 2016. Please submit comments to [email protected] by close of business Materials related to this study are available on the ISO website at: http://www.caiso.com/informed/Pages/RegionalEnergyMarket/BenefitsofaRegionalEner gyMarket.aspx Please use the following template to comment on the key topics addressed in the workshop. 1. Are any of the study results presented at the stakeholder workshop unclear, or in need of additional explanation in the study’s final report? Comment: See the attached document for TURN’s preliminary comments on the preliminary study results. 2. Please organize comments on the study on the following topic areas: a. The 50% renewable portfolios in 2030 b. The assumed regional market footprint in 2020 and 2030 c. The electricity system (production simulation) modeling d. The reliability benefits and integration of renewable energy resources e. The economic analysis f. The environmental and environmental justice analysis Comment: See the attached document for TURN’s preliminary comments on the preliminary study results. 3. Other Comment: See the attached document for TURN’s preliminary comments on the preliminary study results. 2 TABLE OF CONTENTS I. STUDY RESULTS THAT REQUIRE ADDITIONAL EXPLANATION AND DISCLOSURE ................ 1 A. Excessive application of confidentiality by CAISO ............................................................... 1 B. CAISO responses to data requests are incomplete ............................................................. 2 C. Additional modeling is needed based on inputs proposed by stakeholders ....................... 2 II. 50% RENEWABLE PORTFOLIO ASSUMPTIONS FOR 2030 .................................................... 3 A. The study fails to acknowledge that even the most aggressive assumptions for reliance on out of state renewable resources can be met without regional expansion under the existing RPS program ................................................................................................................. 3 B. Existing western renewable resources could substitute for new development ................. 7 C. Curtailment assumptions are contradictory and implausible ............................................. 8 D. Assumed costs of solar are significantly inflated and not consistent with current market offerings or projected industry trends ..................................................................................... 10 E. Transmission costs associated with Scenario 3 understate impacts for California customers ................................................................................................................................. 11 F. New transmission can be constructed to enable additional out-of-state renewable generation under current practice ........................................................................................... 12 III. SELECTION OF BASE SCENARIOS AND SENSITIVITIES ........................................................ 13 A. The SB 350 energy efficiency goals should be included as an input to all base cases ...... 13 B. Assumption that regionalization will yield 5,000 MW of “Beyond RPS” Wyoming and New Mexico wind is critical to study’s estimates of benefits but is not plausible ........................... 14 1. Importance of “Beyond RPS Wind” Assumption ........................................................... 14 2. CAISO modeling shows that developing the 5,000 MW as merchant wind would be unprofitable under regional expansion ................................................................................ 17 3. The costs of new transmission needed to integrate 5,000 MW of incremental wind power have not been acknowledged or modeled ............................................................... 18 4. It is not reasonable to assume that 0 MW of “beyond RPS” wind are developed absent regional expansion ............................................................................................................... 20 5. Last-minute addition of “Beyond RPS Wind” input raises serious concerns about the integrity of the study process ............................................................................................... 22 IV. ASSUMED REGIONAL MARKET FOOTPRINT IN 2020/2030 ................................................ 23 A. SB 350 study fails to make a compelling case for PacifiCorp-CAISO integration in 2020 . 23 V. PRODUCTION SIMULATION MODELING ........................................................................... 25 A. TEAM analysis of benefits to California ratepayers requires additional scrutiny. ............ 25 1. Uncertain assumptions regarding units under California Ownership or Control .......... 26 2. Congestion Costs Assumed Away .................................................................................. 26 3. Differences in Market Prices among Scenarios Raises Questions ................................. 28 VI. ECONOMIC ANALYSIS ...................................................................................................... 29 A. CAISO analysis showing “job” benefits are most pronounced under a status quo scenario with greater exports was not disclosed in the public release materials .................................. 29 B. Assumed economic impacts on communities are not reflective of the manner in which savings and costs would actually be distributed ...................................................................... 30 VII. FAILURE TO MODEL TRANSMISSION ACCESS CHARGES IS A MAJOR OMISSION ................ 31 COMMENTS OF THE UTILITY REFORM NETWORK ON THE PRELIMINARY SB 350 STUDY RESULTS In the following sections, TURN offers the following preliminary comments on the SB 350 study results released by CAISO. Due to the many issues that are raised by the selected study parameters, preferred input assumptions, and partial results, TURN’s observations and critiques are included in the following six sections that roughly (but do not exactly) correspond to the organization in the CAISO comment template. I. STUDY RESULTS THAT REQUIRE ADDITIONAL EXPLANATION AND DISCLOSURE A. Excessive application of confidentiality by CAISO The CAISO made some of its consultants’ data and workpapers available to interested stakeholders on June 3 and June 10. The CAISO chose to label many of these files as “confidential” and required stakeholders to sign a Non-Disclosure Agreement (NDA) to gain access. TURN signed the NDA, reviewed all of these “confidential” files, and does not believe that the contents of many of files – and possibly any of the files – merit confidential treatment. The overuse of confidentiality by CAISO in this process bodes poorly for the designation of similar material offered to stakeholders in a regional ISO. The excessive application of confidentiality appears widespread. For example, one file contains only projected hourly “Locational Marginal Prices” (LMPs) in 2030, which represent forecasted wholesale electric energy prices at various locations on the transmission grid.1 TURN cannot comprehend the rationale for designating such information as confidential, particularly in light of the fact that a chart containing hourly LMP data was included in the CAISO’s public presentation of its results.2 No information proprietary to power market participants – whether buyers or sellers – are included in this LMP file. Moreover, no information contained in this file 1 This file is named “Brattle SB 350 Study_06-10-2016 data release (hourly LMPs and duration curves)_CONFIDENTIAL.xlsx”. Contact the CAISO at [email protected] for access to public and confidential data files. 2 Presentation, May 24, 2016 – Senate Bill 350 Study: Preliminary Results (May 24 Presentation), p. 161, available at http://www.caiso.com/Documents/Presentation-May24_2016-SenateBill350Study-PreliminaryResults.pdf. TURN also provides some aggregated data from this file below. appears to be reasonably considered as Critical Energy Infrastructure Information (CEII). TURN believes that the bulk of the data contained in other files – possibly all of it – should also be made fully available to the public. B. CAISO responses to data requests are incomplete TURN has submitted four separate data requests to CAISO and its consultants requesting specific workpapers and data along with additional questions seeking clarification of some assumptions that were not adequately described in the study materials. While TURN appreciates that the CAISO has responded to some of these requests quickly, the responses to some questions are incomplete or otherwise non-responsive. CAISO convened a call to discuss some additional materials relating to the TEAM analysis the day before comments were due from stakeholders and a response to questions submitted by TURN was provided the day comments were due. The primary reason for these inadequate and late responses appears to be the extremely compressed schedule adopted by CAISO (despite protests from a wide array of stakeholders) that limits the time available for consultants to review and respond to data requests. Despite this constraint, TURN is disappointed that some answers do not adequately respond to the questions posed.3 C. Additional modeling