OVERVIEW

Please see below for the comments from Great Basin Transmission.

Regional Loads

No response submitted.

Regional Resources

No response submitted.

Regional and Inter-regional Transmission Projects

Comments on SWIP-N modelling:

The wind generation associated with SWIP N shall be modelled at $0 hurdle rate for exports out of Northern Grid to WestConnect/CAISO and also for imports from WestConnect/CAISO into Northern Grid. This assumes a common bus arrangement at Midpoint 500 kV and no cost to transfer Generation at the northern terminus of SWIP-North to be dispatched to load south of transmission path. If a different modelling assumption is used, Great Basin would like to discuss this with NorthernGrid.

Great Basin recommends running a sensitivity with 1050 MW of wind delivered to CAISO load via a Pseudo Tie Generator arrangement. This Pseudo Tie Generator will effectively make the resource “internal” to CAISO.

Transmission capacity of existing ON-LINE path, or Midpoint to Robinson line. As noted by NVE under its recently published IRP proceeding, the transmission capacity of ON LINE path from Midpoint to Robinson is about 900 MW & in the opposite direction is about 600 MW. Also, as NVE notes all of this existing capacity is taken so no transmission is currently available. Under a TUA between NVE & LS Power, SWIP N project will also remove current transmission capacity constraints for ON LINE path. Once SWIP N is built this path should be able to transfer 2000 MW in N-S and S-N directions. This assumption should be correctly captured for SWIP N studies, i.e. the pre case would be limited for existing constraints and post case would open up these constraints. The 2000 MW N-S & S-N assumption should not be used for any other Inter Regional project modelling.

Production Cost and Power Flow Models

SWIP N will not only be a conduit for delivering Wind to CAISO and other BAAs south of Midpoint but it will also allow Load Serving Entities in NorthernGrid to access solar oversupply in California. Prior production cost modelling done by Great Basin shows a diurnal pattern, i.e. export of Wind to CAISO during evening peak when solar ramps offline in California & imports of CAISO solar oversupply during middle of the day when solar production in California is at its peak. Production cost model should be set up such that these benefits and flow patterns can be correctly captured.

CAISO Export Limit, which is a hypothetical limit, should not be enforced for this analysis or it will incorrectly skew the results.  

CAISO Export charges: There are ongoing discussions under CAISO EDAM initiative that export charges may not be applied for Extended Day Ahead Market thereby allowing more transactions between CAISO and outside BAAs. This analysis should atleast include a sensitivity with no CAISO export charges

EIM/EDAM benefits: A new path such as SWIP N will create new transmission capacity between various EIM entities that transact with CAISO. Incremental EIM & future EDAM benefits for this new path should be correctly quantified.

Analysis Methods

The 1050 MW resource is in Idaho Power queue, connecting at Midpoint 500 kV. GBT recommends it to be modelled as a Pseudo Tie generator to CAISO under a sensitivity study case.

Appropriate transmission study models shall be developed starting from the ADS seed case such that existing congestion on PACI & NOB interfaces as shown in CAISO DMM reports is captured in the baseline study. 

Cost Allocation

No response submitted.

Other

No response submitted.