By Deb Murphy
The time limit on the interconnection request for Los Angeles Department of Water and Power’s solar ranch east of Manzanar expired. As a result the project lost its spot in line to hook up to LADWP’s Inyo-Rinaldi Transmission Line.
DWP’s solar site sits to the east of Manzanar
Before the withdrawal on March 12, the Southern Owens Valley Solar Ranch was ninth on the Priority Queue List. The Northland Power project, located near Independence, was withdrawn from its 20th position on the list on April 1.
According to LADWP’s Hope Street Public Information Office, the request time line expired “while DWP worked with the community on interests and options on SOVSR and examined a variety of alternatives for the project (size, specific locations, etc.)”
The statement adds “LADWP will continue to examine the viability of this renewable project and many others, especially in light of the new state goals of 50 percent renewables by 2030 (the former state goal was 40 percent….)”
The Large Generator Interconnection Procedure, a 123-page document that contains the rules and studies required for renewable energy projects wishing to gain access to LADWP’s transmission lines, indicates that withdrawal “shall result in the loss of Interconnection Customer’s Queue Position.”
There are still unanswered questions, the primary one being “is the SOVSR officially dead?”
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The following is a response to questions submitted from Amanda Parsons ,Senior Public Relations Representative :
Yes, The SOVSRP was the ninth position on the queue.
The “particular rules” are the provisions of the LGIP. The ‘time limits” are as provided for in the LGIP. In general ,an interconnection customer must follow the timeframes laid out in the LGIP. i.e. must execute various study agreements in the provided-for timeframes and must respond to inquires or requests for technical information within reasonable timeframes. Withdrawals are also governed by the terms of the LGIP. An interconnection customer can withdraw its request at any time prior to executing an interconnection agreement, If an Interconnection Customer fails to perform or adhere to the LGIPN procedures, then they may be deemed withdrawn by the Transmission Provider . If this happens the Interconnection Customer has 15 days to cure the deficiency and have to be reinstated in the previous queue position. LADWP, as the Transmission Provider, only posts withdrawn requests after the cure period has expired. As such ,any interconnection request posted as withdrawn cannot be reinstated . We can reenter the queue at any time but it will not be the same position.
The “particular rules” are the provisions of the LGIP. The Transmission Provider follows the provisions of the LGIP regardless ,whether the Interconnection Customer is DWP or a third party . There is no conflict of interest because the same rules are applied to a third party as they are to a DWP sponsored interconnection.
The project has been removed from the queue. The Department reserves the right to renew exploration into the SOVSRP at a later date . LADWP will continue to examine the viability of this renewable project for a commercial operation date estimated to be between 2024-2027.
These four answers above indicate for all practical purposes the SOVSRP is dead and is not going to go forward in the immediate future . The idea of “Industrial” generation of renewable energy in the Owens Valley will always remain as long as the Lands are empty and DWP has a responsibility to provide renewable energy to the City. Much can change in the next 10 or so years with regards to all of this, but those who have sought to do solar right, who have sought to preserve the Owens Valley, that vigilance can never change .We will keep an eye on the Queue List as that will be the first indication of any unannounced DWP proposed project.
Many will distrust or hate the idea that ” Partnering to Protect the Owens Valley” must ultimately include the LADWP, but it is way past time to begin that dialog with City.
The true significance of the recent announcement of the withdrawals by Northland and LADWP from the transmission queue list is that the County’s new REGPA regulations are already having an impact at least with respect to Northland Power, which cited the recent Board of Supervisors’ actions as one of several reasons they withdrew their application from the Planning Department.
While it is hoped that the new REGPA regulations will have some “influence” on LADWP, there is still no guarantee that will happen in a way that opponents of the SOVSR project hope. There is a need for continued vigilance and optimism, but no one opposing the City’s project should allow themselves to be overly joyful. The City of Los Angeles hardly needs my reminder of using their city-owned land-rights or water-rights as bargaining chips. They have been doing so for decades. With Governor Brown’s call for an increase from the current 33% of renewable energy requirement to 50%, and the passage of AB 327 which can easily make that a possibility, it is doubtful, if not unrealistic, that any utility company is going to willingly give up any property rights or any resources at their disposal to meet that newly proposed goal.
The hope for the withdrawal by the City in the transmission queue as a sign that the SOVSR project is dead is premature at best, as is hope that the arcane rules and regulations that govern the transmission queue will provide a poison pill that brings it to a halt, Rules and regulations can be changed and politicians can “fast-track” just about anything they perceive as in their own interest. Money still talks, especially in politics…and my hope is that the OVC and other opponents of the SOVSR remain steadfast in their opposition so that maybe, just maybe in this instance, money and powerful interests do not override commonsense and what is in the public’s and environment’s best interest.
The LADWP SOVSRP can not Interconnect to the Inyo-Rinaldi Transmission Line if there is no available capacity . As of the start of construction the Beacon Solar Project 250 Mega Watts has taken up the capacity. Beacon will be completed probably before the Barren Ridge Section of the Transmission Line upgrade, so for now there is zero capacity for any proposed project in the Owens Valley until the upgrade is completed .
The SOVSRP also has to have a Queue position to be Interconnected . They may not have had one for the Manzanar Rewards Location and now what Queue position they asserted was for the SOVSRP has been withdrawn . Questions have been given to the Public affairs Office of the LADWP asking for definitive answers asking DWP to explain “time limit”, “particular rules” and provide documentation and answers to questions regarding a reinstatement of a Queue List position. We do not see any language in the LGIP that pertains to that process.
I would disagree a bit with the idea that LA City Land is private property. LA City land seems to have a “royal” status. They seem like they make their own rules to some extent and in addition I don’t think that DWP is regarded all that well, as sad as that sounds. Northland Power was on private property and was subject to Inyo County Zoning Regulation. Not so for the City of Los Angeles.
One more crazed thought . There is a difference in awareness between the words, Properties and Lands . Property can be bought and sold . You develop properties but Lands have a stewardship component . Lands are not readily bought, sold and developed . Properties are . Properties are measured and valued by the foot, but lands are measured in miles . The lands of the Inyo become more valuable with each passing generation and the way the world is going, lands are diminishing and disappearing and all we have left are properties. However, thanks to DWP in the Owens valley we still have lands, we still have lands to preserve for all of time. People with foresight these days ,just like William Muholland back 100 years ago know the value of Lands. Please remind DWP about that valuation and please don’t remind DWP Charles that there are bargaining chips .Tell em that chips are best with guacamole, strictly for properties. Lets not let anyone bargain our lands away.
Good explanation Philip. The expiration on the transmission queue might portend an end to the SOVSR project, but it clearly does not emphatically do so. Unless we hear in clear and unambiguous language from the Los Angeles Department of Water and Power that the project is being abandoned, no one should rest easy. “Clear and unambiguous” are not two terms often associated with LADWP.
The state’s ever-increasing demands on major power generators in the state to provide sources of renewable energy, primarily solar generation, will keep SOVSR on the table for no other reason than as a “bargaining chip.” The simple fact is, the land on which the solar ranch is proposed is considered private property…and there is still quite a bit of support in this country for private property rights. In the end, this issue most likely will only end if it becomes clearly in the interests of the City of Los Angeles to “let it go” and that most likely they will, and perhaps should, expect some form of “quid pro quo.” What form it takes remains to be seen.
The importance of our local media and news reporters somehow get little credit for the Community response to the SOVSRP. Not acknowledging them, assigning to them due credit in the previous post for their part in all the issues of the SOVSRP is a typical, take for granted, lame attitude on my part and even worse on this web site . Thank you Sierra Wave .
The Generation Interconnection Priority Queue List is on the LADWP www,oatioasis.com/ldwp/ website . You need to choose the “Generation Interconnection” link which pulls up the Queue list spread sheet , the LGIA ( Large Generation Interconnection Agreement, and the LGIP ( Large Generation Interconnection Procedures) The terminology and the Regs are a challenge to digest. Basically an entity public or private is allowed the opportunity to generate electricity and interconnect (connect ) to the Transmission Line, no matter who owns it. There is a substantial application fee and a series of site specific required engineering studies leading ultimately to what is called an executed LGIA . The studies include titles like the Scoping Meeting, the Feasibility Study ,the SIS (System Impact Study) etc. Transmission Lines have a limited capacity so there is the Priority Queue List which is first come first served with no guarantee that a Project will be able to Interconnect to the Transmission Line.
The SOVSRP (Southern Owens Valley Solar Ranch Project ) is Q09 on the spread sheet . The application date was November 3, 2009. This LADWP project, DWP being both the IC (Interconnection Customer) and the TP (Transmission Provider) is rated at 200 MW (mega watts) and the plan was to interconnect to the Inyo-Rinaldi Transmission LIne . There is question at this time if there is a current available capacity of 250MW as DWP has broken ground on the Beacon Solar Project (250 MW) off highway 14, just south of Red Rock Canyon but that begins a complicated story into all of this. If there is no capacity in the Transmission Line then Projects can not be interconnected to sell it’s generated electricity . So we are all wondering what is the definitive reason that LADWP has withdrawn this Project from this vital Priority Queue list , They can’t interconnect without the Queue position and the queue position means nothing if there is no capacity in the Transmission Line . And there is more to this long story . The southern 1/3 of the Inyo -Rinaldi Transmission Line has been approved for an upgrade in capacity to a total of 3000 MW. This project named the Barren Ridge-Rinaldi upgade when completed will once again give the northern section of the Inyo -Rinaldi Line capacity suspected to be in the 200 MW range . So indeed why has this vital Queue position been withdrawn by DWP?
In another hidden complication to this story the SOVSRP was initially slated to be located in either Owenyo or in the area just north of Owens Lake. The required site specific engineering studies, which have been acquired through the freedom of Information process, indicate that the studies were for these two locations . When DWP chose to change location to the Manzanar Rewards Site they did so without the appropriate site specific studies. This is not allowed per section 4 of the LGIP and if they desire the new location they are required by the LGIP to apply anew and the Project would then be at the bottom of the Queue List. Maybe they thought that it would escape attention. Who would ever figure out this complicated regulatory process. Add to this the excellent local Community response to the project and it’s Draft EIR and the willingness of the Inyo County to comment their limited opposition even though a term sheet had been agreed to in principal. That term sheet was never completed . And add to this the Manzanar Community in Los Angeles raising awareness of the Manzanar experience and also opposing this blight in the viewshed of the Historic Site. Manzanar I have learned is not just about Japanese Americans interned , it is about the civil rights of all of us . Manzanar is about how never again can there be this injustice in our United States. So there are multiple possible reasons for this withdrawal of the SOVSRP from the Queue list . It is now time for the City of Los Angeles to come clean and officially announce that the SOVSRP is no longer part of it’s renewable energy plan.
Northland Power has taken that step, has withdrawn it’s project from the Queue list ,has notified Inyo County and I’ve been told the County is currently terminating the environmental review process.
The timing of these events with the annual Manzanar Pilgrimage this weekend , the presentation at a OVC event by Bruce Embrey of the Manzanar Committee titled “Partnering to Protect Owens Valley” at the Mountain Light Gallery I think 4-7 pm Saturday could only be improved by some much needed rain and snow just like in a Hollywood Movie . These events to date are still in transition and although welcomed progress there is still much work to attend to on the environmental front with the challenges of this 4th year drought and the seeming endless enterprises and ideas to fill the empty environs of the Inyo with a lot more than human footprints. The great wonders of the Eastern Sierra include the fact that it is still relatively empty thanks to fate, environmental stewardship and the DWP . I wonder how much longer it will take before we all share in a common recognition of just how valuable, how priceless are the vastness and the wonders of these lands of the Inyo .