Sunday, July 6, 2014

Coolwater-Lugo Transmission Line: A Horse Following the Cart

Southern California Edison (SCE) is suggesting that interconnection of Abengoa's Mojave Solar project is the primary reason it needs to build the nearly 75 mile Coolwater-Lugo transmission line through the Lucerne Valley, according to the Daily Press, even though Abengoa told the California Energy Commission (CEC) and Bureau of Land Management (BLM) in 2010 that these transmission lines would not be necessary.   Misrepresenting the need for new transmission lines during the CEC and BLM review of the project would have allowed Abengoa to downplay the costs and environmental impacts associated with approving the project.  The Coolwater-Lugo transmission line is likely to cost ratepayers at least 509 million dollars, and bring bulldozers and transmission towers to mostly undisturbed desert.

Without the Abengoa Mojave Solar project as an excuse,  SCE probably could address other distribution needs - such as relieving the transmission bottleneck at Kramer Junction - by upgrading existing lines, or building new lines along existing transmission corridors.  Alternatively, Abengoa could sell its electricity to LADWP, which also has transmission lines near the project site.

Abengoa Gambling on Transmission Approval

Abengoa may have misrepresented the need for new transmission when it sought approval from the CEC and BLM for its Mojave Solar project.  According to a document submitted by SCE to the Federal Energy Regulatory Commission (FERC) in 2011, Abengoa told SCE that it may not be able to complete the Mojave Solar project without SCE's new transmission line.   However, in documents submitted to the CEC in 2009 and 2010, Abengoa identified upgrades to existing transmission lines as sufficient to deliver power to Pacific Gas and Electric (PGE) - the northern California utility that agreed to purchase power from the Mojave Solar project - and specifically denied that the Coolwater-Lugo line would be necessary (see page 92 of the CEC's final decision - PDF).  Although power from the Abengoa Mojave Solar project is destined for northern California, SCE owns the transmission lines that will connect the project to the grid.
Abengoa and SCE on Record

The screenshot below is from page 92 of the CEC's September 2010 final decision on the Abengoa Mojave Solar project (AMS).  It states that Abengoa (the applicant) told the CEC that it could meet its obligations to PGE without the Coolwater-Lugo transmission line. 

The next two screenshots are from  a Federal Energy Regulatory Commission (FERC) document recording statements from SCE and Abengoa that the Mojave Solar project is not viable without the Coolwater-Lugo transmission project.  This document was issued by FERC in March 2011, but based on submissions from SCE and Abengoa from late 2010 and early 2011.  FERC ruled in favor of allowing SCE to pass along the costs of the Coolwater-Lugo transmission line to ratepayers.  The Coolwater-Lugo line is the delivery "network upgrade" portion of the "South of Kramer" project.  (FERC Docket EL11-10)


Abengoa filed the following document with the CEC in early 2010, indicating that despite transmission congestion, it could proceed with the Mojave Solar project by upgrading existing transmission infrastructure.

According to the CEC's final decision from September 2010,  the CEC acknowledged that the Abengoa Mojave Solar project would create a burden on existing transmission lines.  The document indicates - based on testimony from Abengoa - that the company chose "alternative 2," which would mostly involve upgrades to existing transmission infrastructure and participating in a congestion management program that would curtail the project's electricity delivery when existing lines were overloaded.

Probably because Abengoa signaled that the Coolwater-Lugo transmission line was not necessary for it to meet its obligations to PGE, the BLM also issued a Finding of No Significant Impacts (FONSI) approving the solar project's interconnection to existing infrastructure.   The BLM did not analyze the impacts of building the Coolwater-Lugo line when it reviewed the Abengoa solar project, but now SCE is suggesting the line is necessary to deliver the power to PGE.  If Abengoa had identified the Coolwater-Lugo line as necessary when the project was initially being reviewed, the new transmission line would have been analyzed as a connected action.

It is likely Abengoa will have to curtail generation during peak periods if the Coolwater-Lugo line is not built, but Abengoa knew this when it testified to the CEC that no new transmission lines were necessary to build the project.  If the company was gambling that the Coolwater-Lugo transmission line would be approved, it seems to have done so at great risk to its investors and was disingenuous toward California and Federal stakeholders.

At this point, SCE's use of the Abengoa Mojave Solar project as a key reason for building the Coolwater-Lugo transmission line is inconsistent with facts presented to the CEC and BLM.  SCE should either eliminate the Abengoa Mojave Solar project from its rationale (correcting the record with FERC and the California Public Utilities Commission), or Abengoa should petition the CEC to amend its initial approval.  Most likely, neither will happen and SCE will pass along millions of dollars of cost to ratepayers that was never supposed to be necessary, and destroy pristine desert.

Other Alternatives Available

SCE has examined eight other action alternatives to building the Coolwater-Lugo line, but it has ruled all of them out because they do not meet its objectives or would cost the utility company too much money.  SCE cited the need to connect the Abengoa Mojave Solar project as a reason to rule out six of the eight alternatives.

Alternatives include re-wiring existing transmission lines between Kramer Junction and Hesperia (Lugo), installing new transmission lines and towers between Kramer Junction and Hesperia, or building new transmission lines between Kramer Junction and the Antelope Valley (Llano).  All of these options could utilize existing transmission corridors.

SCE also claims the need to connect other unidentified large renewable energy projects as a reason to build the Coolwater-Lugo line.  At this time, there are no solar energy zones in the vicinity of Lugo and Coolwater substations.  Any wind projects between northern Lucerne Valley and Barstow would likely conflict with the Departments of Defense's flight and radar testing programs.  Moreover, the Granite Wind project near Apple Valley was cancelled, probably in part because of golden eagles in the area.  So, other than the Abengoa Mojave Solar project, there is no identifiable and timely need to connect other large projects to the grid.

SCE also cites the need to serve electricity to a growing Victor Valley as a reason to build the project.  Although SCE does not offer specifics, it also does not suggest alternatives for meeting this demand.  Smaller solar projects are being built in the Victor Valley that can serve local demand, and energy conservation and rooftop solar can help offset the need for an expensive new transmission line.

Abengoa and SCE are betting on a regulatory system that prioritizes industry profit above the need for a sustainable and smart renewable energy future.  Abengoa seems to be confused regarding its need for new transmission lines, and SCE seems eager to profit from new transmission lines.  Hopefully California and Federal regulators will wise up and demand a more efficient and sustainable alternative to the Coolwater-Lugo transmission line.

If Abengoa cannot deliver the project's energy to PGE, then perhaps it can re-negotiate its power purchase agreement and sell the energy to the Los Angeles Department of Water and Power (LADWP).  According to documents submitted by Abengoa to CEC in 2009, a 500kv LADWP transmission line runs next to the Abengoa Mojave Solar project and interconnection could occur without the extensive (and expensive) upgrades required by SCE and PGE.

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