The goal of the 20 year study should be to identify the most cost-effective combination of new generation resources and transmission upgrades needed to meet the region's public policy goals safely and reliably. The study should not be limited to exploring transmission solutions.

The study should explore whether generation portfolios different from those defined in IRPs can meet the region's needs more cost-effectively by optimizing transmission expansion.  For example, it may be more cost-effective to concentrate generation development in specific locations and make targeted transmission upgrades than to attempt smaller transmission upgrades to multiple locations with generation potential.

This study is informational in its nature. To quote CAISO 20-year transmission outlook “the objective of the 20-Year Transmission Outlook is to provide a long-term conceptual plan of the transmission grid in 20 years, meeting the resource and electric load needs aligned with state agency input on integrated load forecasting and resource planning”

We recommend the study done in several phases

• WPP engineers to perform initial reliability studies and to identify the transmission constraints
• WPP work with regional Transmission Planners to validate the initial study results, and whether there are projects currently planned to address the identified transmission constraints

As far as solutions, we propose to consider other objectives beyond Reliability Standards

• Minimizing environmental impact, e.g. through optimization of existing transmission corridors
• Maximizing resiliency to extreme events, such as temperature extremes, wild fires, and particularly earthquakes