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transmission-linesSAN DIEGO, Calif. – The Imperial Irrigation District (IID) today filed civil litigation in U.S. District Court, Southern District of California, against the California independent system operator (CAISO). for its deliberate and systematic marginalization of IID, its ratepayers and all renewable energy generators seeking to develop projects in the district’s service area. Through its actions over many years, CAISO has exercised its monopoly power to manipulate the import capability values, or deliverability, it assigns to IID to stifle competition, create uncertainty in the marketplace and effectively take over IID’s energy balancing authority area.

“IID takes no pleasure in turning to the courts to obtain relief from CAISO’s anti-competitive practices toward the district in doling out access – and deliverability – to its transmission grid,” said IID General Manager Kevin Kelley, “but we have been left with no other recourse.”

CAISO, which controls at least 80 percent of the state’s electric transmission system, has placed IID and its renewable energy generators at a competitive disadvantage in vying for power purchase agreements. The result, Kelley said, has been to saddle IID’s ratepayers with stranded transmission investment costs and handcuff economic development in both Imperial and Riverside counties.

By using the concepts of resource adequacy and maximum import capability interchangeably, CAISO has blocked access to renewable energy projects interconnecting to IID’s transmission grid. The dispute between the agencies extends back to 2011, when CAISO approved IID’s upgrades to the Path 42 project that would send clean, renewable energy from Imperial and Riverside counties to the rest of California. IID subsequently expended nearly $35 million in completing its segment of the project.

However, in the summer of 2014, CAISO used the loss of San Onofre Nuclear Generating Station as a pretext for reducing future deliverability from IID into the CAISO system to zero, stranding the district’s investment in the Path 42 project and leaving it with no practical means of recovering its costs, other than to join the CAISO as a participating transmission owner.

Imperial County has long been recognized for its vast renewable energy resources; at the same time, its unemployment rate is triple that of the state average, which is why county leaders naturally look to California’s green economy to bring about positive change.

Desert Sunlight solar farm

Overhead transmission lines funnel power underground to a nearby substation at the Desert Sunlight solar farm. The project is expected to be fully operational in early 2015. (Photo: Crystal Chatham/The Desert Sun)

“Our region has and will continue to play a vital role in helping the state meet its “clean energy” goals,” said Ralph Cordova, the county’s executive officer. “IID’s ability to deliver green power is critical if we are to further develop our resources.”

The average power line, experts say, costs about $1 million per mile to build. Some are even more expensive: San Diego Gas & Electric’s Sunrise Powerlink transmission line, which carries electricity from the Imperial Valley to San Diego County, cost more than $16 million per mile, for a total price tag of nearly $2 billion.

Regulators say they “never intended to map specific transmission routes in the renewable energy plan, which would guide development through 2040.” The plan, they point out, doesn’t mandate specific energy projects, and it’s hard to know where to put transmission lines without first knowing where energy developers want to build.


The IID service area includes several geothermal fields including the Salton Sea.

But for a renewable energy blueprint so dependent on new transmission, the plan contains remarkably little detail about where those power lines might go. And if recent transmission projects are anything to go by, some of those lines could be just as controversial as the renewable energy projects they’re meant to support.

“The abundance of renewable energy resources found only in this region will go untapped if CAISO continues to manipulate the deliverability it assigns to IID,” Kelley said.

Following is testimony from IID General Manager Kevin Kelley at the California State Assembly Select Committee on Renewable Energy Development and Restoration of the Salton Sea. Serving as a panelist during the June 24 meeting, he provided testimony regarding the challenges and opportunities of renewable energy procurement in relation to the IID balancing authority and its transmission network.

For more information or to view a copy of the full complaint, please visit Imperial Irrigation District : CAISO Civil Litigation

View / Download

IID Summary of Civil Action Against CAISO 7-16-2015 [PDF]

Full Complaint With Exhibits 7-16-2015 [PDF]






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