Submitted by Edison International
Achieving an 85% GHG emissions reduction and reaching net zero by 2045 requires bold, immediate action from all stakeholders across the public and private sectors. In 2021, Edison International published Mind the Gap with dozens of recommendations for policies to achieve 2030 emissions targets, based on the foundational Pathway 2045 analysis. This paper builds upon those policy recommendations and broadens the lens to include planning and technology considerations, identifying nearterm priority action areas across the electric system from bulk power to local resources.
REIMAGINE SYSTEM PLANNING
California must reimagine how it plans the electric system to efficiently interconnect clean energy resources and enable operational flexibility. The state needs a planning process that is integrated across domains (including generation, transmission, distribution and local resources) and objectives (including affordability, reliability, load growth and climate adaptation) to ease the process of interconnecting resources and enable a more resilient, cost-effective system.
Interconnection challenges have increased as more solar, wind and storage developments vie to connect to a transmission grid that must grow much faster. The volume of interconnection applications has more than tripled in recent years14. More than ever before, clarity is urgently needed to ensure the most cost-effective upgrades are built in time to interconnect new resources.
At the transmission level, California has begun to reimagine its system planning through proposed reforms to the CAISO generator interconnection processxi and through increased collaboration around zonal planning among the CAISO, CPUC and CECxii. State agencies and system operators should build on these efforts by:
By attracting viable clean generation to areas with existing or planned transmission capacity, the state can simplify interconnection and transmission upgrade studies and promote timely transmission buildout at the scale required to meet our 2045 goals.
At the distribution level, integrated planning is necessary to optimally determine grid investments — considering evolving customer roles and expectations, new customer and grid technologies and significantly increased loads from electrification. The following are essential:
A holistic, systemwide view of planning is also needed to optimize investments and improve grid efficiency. This requires consideration of multiple forecasts that capture a range of realistic load growth possibilities. Investment planning must include DERs and load flexibility to increase optionality, minimize the risk of insufficient capacity and complement development of large-scale generation resources and new transmission infrastructure.
California should look beyond CAISO’s borders to advance system reliability and affordability. Expanding CAISO into a regional transmission organization would give all participating Western regions access to an expanded set of clean resources to serve power needs during extreme weather or grid constrained events. Regionalization would also create a larger, more efficient market that would likely unlock more affordable sources of electricity and put downward pressure on customer rates.
xi. CAISO 2023 Interconnection Process Enhancements
xii. The CPUC, CEC, and CAISO signed a memorandum of Understanding in December 2022 which outlines their collaborative, zonal approach to transmission planning and generation development; SB 319, which was approved by the CA Legislature and sent for the Governor’s approval in September 2023, proposes to strengthen this collaborative approach
ADVANCE EMERGING GENERATION TECHNOLOGIES
To reliably achieve net-zero emissions and SB 100 electric sector targets, the power supply resource mix needs to evolve significantly. In particular, changes in the profile and magnitude of system demand will drive an increased requirement for firm generation capacity. While solar and battery energy storage are experiencing strong growth in California’s power grid, the day-today variability and seasonal production characteristics of solar mean they alone cannot meet future demand increases (such as for stormy winter mornings). Diversity of both resource type and location (with some resources close to load centers) will be essential to ensure the system remains both flexible and reliable.
California cannot afford to delay investing in the development of emerging technologies. Each has a complex journey from its current state to commercial feasibility, so the state must find innovative ways to accelerate development and deployment, reducing affordability impacts and risks of missing climate goals. Given best available estimates today, Countdown to 2045 calls for 19 GW of floating offshore wind and 8 GW of clean, firm generation.
Offshore wind: California must grow a robust offshore wind industry to develop novel technology for floating turbine platforms and sea floor anchors, undersea transmission, specialized ports and vessels for installation and maintenance and a customized supply chain consisting of facilities that today take half a decade or more to construct1.
Clean, firm generation: California will need to support a variety of nascent technologies:
While each emerging clean generation resource must overcome specific challenges, California should support measures to de-risk the development of all clean, firm technologies. State agencies may consider incentives or other mechanisms to help commercialization and reduce costs to California energy consumers.
xiii. The Inflation Reduction Act of 2022 raised 45Q tax credits, which incentivize investments in carbon capture and storage, from $50/ton to $85-$180/ton for point source and direct air capture respectively.
xiv. Some estimates show <5% of a total ~60 GW potential is being utilized today. Source: Williams et. Al. study from the U.S. Geological Survey.
xv. Permitting of new nuclear power plants in the state only allowed if the CEC determines that the federal government has established a permanent site for the disposal of nuclear fuel (Source: CA Legislative Analyst’s Office)
xvi. Gen III+ refers to improvements on current reactors (i.e., light-water); Gen IV are new/emerging reactor designs (e.g., liquid sodium)
REFORM PROCESSES AND REGULATIONS TO ACCELERATE TRANSMISSION INFRASTRUCTURE BUILDOUT
Since transmission infrastructure is the backbone of California’s clean energy transition, urgent actions to accelerate its deployment must be given elevated priority, without waiting for developments with system planning or DERs.
The current grid infrastructure deployment process cannot keep pace with California’s goals. Today, on average, greenfield transmission projects take 10-12 years to complete, with the permitting stage alone taking at least two to four years. Inefficient and undefined review timelines, redundant processes, excessive intervention periods and overlapping agency oversight have made permitting a significant bottleneck in transmission buildout. SCE’s Tehachapi Renewable Transmission Project, for example, took six years to complete the permitting phase since the project had to obtain approval from the CPUC, U.S. Forest Service and nearby local communities.
Regulatory and policy reform in four key areas can help accelerate transmission buildout to the pace required:
These are important reforms that must continue to be instituted by regulators, policymakers and local governments. There is also a role for utilities to play. As grid operators, utilities should assure transmission lines are safely operating at maximum capacity and pursue upgrades to expand the value of existing rights of way in lieu of greenfield development. Additionally, utilities should pursue technology to make the transmission deployment process more efficient, such as automated line stringing devices, and continuing to evaluate grid enhancing technologies. Finally, utilities must engage communities early and regularly throughout the permitting review process.
xvii. California Environmental Quality Act (CEQA) requires identification of significant environmental impacts of a project and plans to avoid or mitigate them, if feasible. One year time limits for CEQA reviews generally aligns with NEPA review time limits included in the U.S. Fiscal Responsibility Act of 2023.
xviii. Under current law (GO 131-D), the CPUC must redetermine if a CAISO-approved transmission project is needed and issue a Certificate of Public Convenience and Necessity (CPCN), which can last 3 years.
PREPARE DISTRIBUTION GRID FOR LOCAL RESOURCES
Structural advances to the way the distribution grid is designed, built and operated will be necessary to meet the coming requirements. Countdown to 2045 shows this includes nearly doubling the throughput while utilizing 2x more distributed solar and 10x more distributed energy storage. At the same time, the existing grid must be modernized, overall grid resiliency must increase in response to the rising frequency of extreme weather events and it must meet escalating customer expectations for service reliability.
Customers and electrification developers play a crucial role in all stages of this distribution grid evolution. They must:
Distributed Energy Resources (DERs) are complementary to the bulk power resources discussed above; in aggregate, they provide flexibility that can reduce burdens on generation and transmission resources and can also provide more localized benefits for distribution grid reliability. Maximizing the value of these resources requires:
The foundational architecture of the distribution grid must be updated to optimally meet imminent needs. One key challenge is significant load growth within communities that are already built out and served by distribution infrastructure that is reaching physical capacity. The best solutions may incorporate new designs, such as higher distribution voltages, direct current and mesh distribution systems that can increase the capacity, reliability and resiliency of the grid, as well as increase coordination and integration with “at-the-meter” and “behind-the-meter” technologies. To support this evolution:
As described in “Reimagine system planning” above, integrated system planning is necessary to achieve this future state. Furthermore, utilities must enable flexible resources to optimally satisfy all requirements of the distribution system, including customer affordability, system reliability and resiliency, grid capacity readiness and further reductions in electric sector GHG emissions.
The four near-term priority action areas described here are critical to achieving California’s net-zero target by 2045 while improving the feasibility and affordability of an 85% reduction in GHG emissions. A supportive economic and regulatory environment is also essential. It requires sending the right market signals to allow private entities, including developers, utilities and investors, to risk capital and continue funding aggressive growth with increased certainty. The clean energy workforce needs statewide investment to expand at an unprecedented pace.
If done collaboratively, affordably and equitably, this transition can unlock significant and long-lasting economic growth, creating a virtuous cycle that fuels further development and prosperity for California.
Achieving California’s 2045 net-zero policy demands meticulous planning, transformative reforms and continuous innovation. The findings are clear: electric infrastructure buildout, including transmission and distribution, must happen rapidly and at an unprecedented scale as electricity demand will nearly double by 2045. Reforms in planning and permitting processes are imperative. Additionally, clean, firm generation will need to supplement wind and solar to maintain a reliable grid. It will be crucial for California to encourage commercialization and scale-up of emerging technologies. Optionality in achieving carbon neutrality is also key to maximizing savings and minimizing costs to all Californians, especially as technologies that are yet to be proven today will likely be relied upon.
Realizing California’s 2045 net-zero goals requires a statewide plan supported by urgent, coordinated and decisive actions. Here at Edison International, we are committed to helping California reach this goal and we are ready to collaborate with all stakeholders to address the challenges ahead.
1. 2035 and Beyond: Offshore Wind, University of California, Berkeley (Aug. 2023): Table 4. http://2035report.com/offshorewind/wp-content/uploads/2023/07/GridLab_2035-Offshore-Wind-Technical-Report.pdf
Edison International (NYSE:EIX), through its subsidiaries, is a generator and distributor of electric power and an investor in energy services and technologies, including renewable energy. Headquartered in Rosemead, Calif., Edison International is the parent company of Southern California Edison, one of the nation’s largest electric utilities.
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