[USA] Avangrid, CIP announce first power from Vineyard Wind 1 has been delivered to New England grid

On January 3, 2024, Avangrid and Copenhagen Infrastructure Partners (CIP) announced that power from the first turbine of the Vineyard Wind project was delivered to the New England grid for the first time.[1] As part of the initial commissioning process, on January 2, 2024, the turbine delivered approximately 5 MW of power, with additional testing expected to happen both on and offshore in the coming weeks. Vineyard Wind is an 806 MW project consisting of consist of 62 wind turbines and located 15 miles off the coast of Martha’s Vineyard, Massachusetts. The project began offshore construction in late 2022, achieved steel-in-the-water in June 2023, and completed the nation’s first offshore substation in July 2023. Power from the project interconnects to the New England grid in Barnstable and is transmitted by underground cables that connect to a substation further inland on Cape Cod. Avangrid and CIP jointly own Vineyard Wind. The project is being developed and constructed by Avangrid and Vineyard Offshore, CIP’s affiliate development company working on U.S. offshore projects. The developers expect to have five turbines operating at full capacity early in 2024.

[1] https://www.vineyardwind.com/press-releases/2024/1/3/cip-avangrid-announce-first-power-from-nation-leading-vineyard-wind-1-project

[USA] BOEM approves sixth commercial-scale offshore wind project

 On November 21, 2023, the Bureau of Ocean Management (BOEM) announced that it has approved the Empire Wind offshore wind project, the sixth approval of a commercial-scale offshore wind energy project under the Biden administration.[1] The president aims to deploy 30 GW of offshore wind energy capacity by 2030. BOEM has committed to advancing 16 offshore wind projects by 2025. Empire Wind US LLC, a joint venture of Equinor and BP, will develop two offshore wind facilities: Empire Wind 1 and Empire Wind 2. The projects will be about 12 nautical miles (nm) south of Long Island, New York, and have a capacity of 2,076 MW. BOEM estimates that the projects will support over 830 jobs annually during construction and about 300 jobs annually during operations. The Record of Decision includes measures aimed at avoiding, minimizing, and mitigating the potential impacts that may result from the project. Those measures include a commitment from Empire Wind to establish fishery mitigation funds to compensate commercial and for-hire recreational fishers for any losses directly arising from the project.

[1] https://www.doi.gov/pressreleases/biden-harris-administration-approves-sixth-offshore-wind-project

[USA] DOE, Interior release plan for developing offshore wind transmission in the Atlantic

On September 19, 2023, the Department of Energy (DOE) and the Department of the Interior released “An Action Plan for Offshore Wind Transmission Development in the U.S. Atlantic Region.” [1] The DOE’s Grid Deployment and Wind Energy Technologies Offices and the Interior’s Bureau of Ocean Energy Management (BOEM) developed the action plan and outlines immediate actions needed to connect Atlantic offshore wind projects to the electric grid. It also details longer-term efforts to support needed transmission over the next several decades.

The plan includes several key recommendations broken down by timelines. Prior to 2025, the plan calls for establishing collaborative bodies that span the Atlantic region and recommends clarifying some of the building blocks of transmission planning, including updating reliability standards and identifying where offshore transmission may interconnect with the onshore grid. It also seeks to address costs through voluntary cost assignments and tax credits. In the 2025 to 2030 timeframe, the plan recommends coordination with states to plan for an offshore transmission network and with industry to standardize requirements for HDVC technology. From 2030 to 2040, it calls for establishing a national HDVC testing and certification center to ensure compatibility when interconnecting multiple HVDC substations to form an offshore grid network. The DOE and multiple Atlantic states have started on the recommendations, forming an Offshore Wind Transmission State Collaborative.

[1] https://www.doi.gov/pressreleases/biden-harris-administration-releases-roadmap-accelerate-offshore-wind-transmission-and

[USA] DOE wind studies project strong growth

On August 24, 2023, the Department of Energy (DOE) released three annual wind reports—Land-Based Wind Market Report, Offshore Wind Market Report, and Distributed Wind Market Report—showing that wind power is one of the fastest-growing and lowest-cost sources of electricity in the U.S. and is poised for rapid growth.[1] The reports found that wind power accounted for 22% of new electricity capacity installed in 2022, second only to solar energy. Since the passage of the Inflation Reduction Act (IRA) in August 2022, forecasts for land-based wind energy installed in 2026 have increased nearly 60% from about 11,500 MW to 18,000 MW. In addition, there have been at least eleven announcements of manufacturing facilities that plan to open, re-open, or expand to serve the land-based wind industry. The advanced manufacturing production tax credit in the IRA is estimated to reduce the cost of offshore wind blades by 27% and steel towers by 18%.

[1] https://www.energy.gov/articles/us-department-energy-projects-strong-growth-us-wind-power-sector

[USA] Report: Offshore wind could supply 25% of U.S. power by 2050

According to a report released on August 1, 2023, by the University of California, Berkeley’s Center for Environmental Public Policy, the U.S. could develop enough offshore wind to provide up to 25% of the nation’s energy supply by 2050 without spiking the wholesale cost of electricity.[1] The “2035 and Beyond: Abundant, Affordable Offshore Wind Can Accelerate Our Clean Electricity Future” report shows that over 4,000 GW of offshore wind potential is available along the U.S. coastline, including the Great Lakes. The report finds that increasing the offshore wind ambition and a significant increase in the solar and onshore wind resource deployments could help achieve the U.S.’s net-zero goals while keeping the electricity prices affordable and the grid reliable. The report also found that the Inflation Reduction Act (IRA), which included incentives for offshore wind, will help cut the cost of offshore wind in the coming years.

The Berkeley study was released alongside a policy report from Energy Innovation that charts the policy pathway needed to realize offshore wind’s potential and analysis of the supply chain and transmission needs and accompanying employment benefits. Increasing ambition for offshore wind development could inject up to $1.8 trillion of investment into the U.S. economy and employ approximately 390,000 workers in the sector in 2050.

[1] https://gspp.berkeley.edu/research-and-impact/centers/cepp/projects

[USA] NYISO Board selects transmission project to deliver offshore wind energy from Long Island

On June 20, 2023, the New York Independent System Operator (NYISO) announced that its Board of Directors had selected the Propel Alternate Solution 5 transmission project to meet the Long Island Offshore Wind Export Public Policy Transmission Need (Long Island Need).[1] The New York State Public Service Commission (PSC) initially declared the Long Island Need in March 2021, launching an effort by NYISO’s team of experts, the New York State Department of Public Service, developers, and stakeholders to address transmission needs in and around Long Island.

Propel Alternate Solution 5 will deliver at least 3,000 MW of offshore wind power from Long Island to the rest of New York. The project will add three new underground cables connecting Long Island with the rest of the state and a 345 kV transmission backbone across western/central Long Island. Through a partnership called Propel NY, the New York Power Authority and New York Transco will develop the project. Propel Alternate Solution 5 is expected to be in service by May 2030, with an estimated cost of $3.26 billion. According to NYISO’s analysis, the project's potential economic benefits are comparable to or greater than the project cost over 20 years. NYISO expects the project to bring the state closer to its 9,000 MW of offshore wind energy goal by 2035.

[1] https://www.nyiso.com/-/press-release-%7C-nyiso-board-selects-transmission-project-to-deliver-offshore-wind-energy

[USA] Port of Long Beach proposes offshore wind manufacturing facility

On May 9, 2023, the Port of Long Beach in California released plans to build an offshore wind turbine manufacturing facility.[1] The port is seeking state and federal dollars to fund the $4.7 billion project, which would be capable of assembling floating wind turbines as tall as the Eiffel Tower. The location, about 20 miles south of Los Angeles International Airport, is uniquely suited for building the largest such facility of any U.S. seaport. Port officials presented a detailed design for the project, called Pier Wind, to the Los Angeles Board of Harbor Commissioners on May 8 and released it more widely on May 9. The port aims to start construction in 2027, completing phase one in early 2031 and finishing two additional phases by 2035. Each turbine could generate 20 MW of electricity. The project would help California meet its goal of producing 25 GW of offshore wind power by 2045 and contribute toward lowering the national cost of offshore wind power by 70% by 2035.

[1] https://polb.com/port-info/projects/#pier-wind

[USA] New Jersey initiates process for second offshore wind transmission solicitation

On April 26, 2023, the New Jersey Board of Public Utilities (NJBPU) requested that PJM Interconnection include New Jersey’s current public policy of 11 GW of offshore wind by 2040 into the grid operator’s Regional Transmission Expansion Planning (RTEP) using their State Agreement Approach (SAA).[1] The SAA is a transmission-building tool established by PJM to allow states in its territory to plan and pay for their own power lines, preventing a more complex development plan involving cost-sharing with other states. The SAA was used previously by New Jersey for another set of transmission projects. SAA 2.0 will solicit proposals to develop an additional 3.5 GW needed at the Deans 500 kV substation to reach the state’s new 11 GW goal. Transmission developers will be allowed to propose cost-effective alternative points of interconnection as well. The Deans 500 kV substation was identified for SAA 2.0 due to its location near load centers, accessibility to offshore wind lease areas, and its capability to accommodate the desired injection.

[1] https://nj.gov/bpu/newsroom/2023/approved/20230426.html

[USA] Report: Immediate transmission planning for offshore wind could save up to $20 billion

According to a Brattle Group report released on January 24, 2023, federal agencies, states, and grid operators must begin collaborative planning to identify cost-effective transmission solutions to bring offshore power online.[1] The report, titled The Benefit and Urgency of Planned Offshore Transmission, finds that starting a collaborative planning process immediately will reduce costs, reduce environmental and community impacts, increase grid reliability, and help achieve climate and clean energy goals. Leveraging existing studies in the United States and Europe, the study estimates that the benefits of proactive transmission planning for the potential 100 GW of U.S. offshore wind generation developments over the next 2-3 decades include at least $20 billion in transmission cost savings; 60-70% fewer shore crossings and necessary onshore transmissions upgrades; and 50% fewer miles of marine transmission cable installations. Proactive planning would also result in more competition, increased consumer savings, enhanced reliability and resilience, and more investments in the local clean energy economy.

The report comes as the Biden administration has set a 2030 goal of 30 GW of offshore wind deployment as a milestone to 110 GW by 2050. 11 coastal states have already set procurement targets, with figures exceeding 50 GW through 2035 and more than 75 GW by 2045. However, it can take at least a decade to plan and build major new transmission lines as a result of current processes. Because of this, the report urged working immediately to standardize offshore transmission technologies, improve existing planning processes, utilize federal support and funding, and coordinate cross-state. The report was commissioned by industry stakeholders, including the American Clean Power Association (ACP), American Council on Renewable Energy (ACORE), Clean Air Task Force (CATF), GridLab, and the Natural Resources Defense Council (NRDC).

[1] https://cleanpower.org/resources/the-benefit-and-urgency-of-planned-offshore-transmission/

[USA] First offshore wind lease auction on West Coast generates $757 million

According to the Bureau of Ocean Energy Management (BOEM), the first offshore wind lease auction on the West Coast drew bids from 5 companies totaling $757.1 million.[1] The lease sale, announced in October 2022 and held over two days in December 2022, offered five lease areas covering 373,268 total acres off central and northern California. The leased areas have the potential to produce over 4.6 GW of floating offshore wind energy. The provisional winners include RWE Offshore Wind Holdings, California North Floating, Equinor Wind US, Central California Offshore Wind, and Invenergy California Offshore.

The sale included a 20% bidding credit for bidders who committed to funding workforce training or supporting the development of a domestic supply chain for the floating wind energy industry. This credit is expected to result in over $117 million in investments for these critical programs or initiatives. The auction included 5% credits for bidders who committed to entering community benefit agreements (CBAs). Under the lease stipulations, leaseholders are required to engage with local stakeholders that may be affected by their lease activities.

[1] https://doi.gov/pressreleases/biden-harris-administration-announces-winners-california-offshore-wind-energy-auction

[USA] BOEM announces 8 new offshore wind areas

On November 16, 2022, the Bureau of Ocean Energy Management (BOEM) announced eight draft Wind Energy Areas (WEAs) off the Atlantic coast as part of the Biden administration’s goal of deploying 20 GW of offshore wind energy capacity by 2030.[1] The draft WEAs would cover about 1.7 million acres offshore Delaware, Maryland, Virginia, and North Carolina. BOEM identified these WEAs through a process that considers possible impacts on local resources and ocean users. The proposed areas represent a subset of the original 3.9 million acres of the Call Area that the Department of the Interior announced for public comment in April 2022. The agency is now seeking comments on potential conflicts with the draft areas, such as commercial fishing and marine habitat areas. Comments will be accepted through December 16, 2022. The draft WEAs may be reduced after the BOEM considers input from the Defense Department, the Coast Guard, NOAA Fisheries, and private ocean users like commercial fishers and environmental groups.

[1] https://www.boem.gov/newsroom/press-releases/boem-identifies-draft-wind-energy-areas-central-atlantic-public-review-and

[USA] Dominion and stakeholders reach agreement on potential cost overruns for offshore wind project

On October 28, 2022, Dominion Energy Virginia, the office of Virginia Attorney General Jason Miyares (R), Walmart, Sierra Club, and Appalachian Voices reached an agreement on how to handle potential cost overruns or overproduction for the utility’s 2.6 GW Coastal Virginia Offshore Wind (CVOW) project.[1] The CVOW project, located 27 miles off the coast of Virginia Beach, is expected to be completed in late 2026 and cost $9.6 billion. In the Virginia State Corporation Commission’s (SCC) August 2022 Final Order approving the development of the project, regulators included a performance guarantee, which would require the utility to pay for any power it buys elsewhere if the project generates less than the expected 42% average annual capacity factor. According to Dominion, the SCC’s mandate would jeopardize the project’s viability.

If approved by the SCC, the settlement agreement would replace the performance guarantee with a cost-sharing approach for unforeseen costs that exceed the project’s budget. Under the agreement, the utility’s shareholders would pay 50% of any costs in the $10.3 billion to $11.3 billion range and would be responsible for 100% of any prudently incurred costs from $11.3 billion to $13.7 billion. There is no voluntary cost-sharing agreement for any costs that exceed $13.7 billion. Dominion would not be required to guarantee future energy production levels or factors beyond its control as outlined in the SCC’s August order. Instead, the utility would explain the factors contributing to any shortfall in expected energy production in a future SCC proceeding.

[1] https://news.dominionenergy.com/2022-10-28-Dominion-Energy-Virginia,-Office-of-Attorney-General,-Walmart,-Sierra-Club-and-Appalachian-Voices-File-Settlement-Agreement-for-Coastal-Virginia-Offshore-Wind

[USA] PPL and Elia Group announce partnership to propose solutions to integrate offshore wind into New England grid

According to an October 24, 2022, press release, PPL Corp. and Elia Group have agreed to propose transmission solutions to efficiently integrate future offshore wind capacity into New England’s onshore grid.[1]  The two companies signed a memorandum of understanding (MOU) to work together to develop, build, and operate transmission assets. The partnership combines PPL’s experience in building and operating large-scale onshore transmission through its PPL Translink subsidiary with Elia Group’s track record in building and operating offshore transmission, including high-voltage direct current (HVDC) networks, through its WindGrid subsidiary. Later in October 2022, PPL and Windgrid plan to jointly respond to a September 2022 request for information (RFI) issued by five New England states[2], which seeks input on the transmission system changes and upgrades needed to integrate future renewable energy resources into their grids.

Through its subsidiaries in Belgium and Germany, Elia Group has connected 14 wind farms (3,500 MW by the end of 2022) to its onshore grid. It is also currently operating three HVDC subsea cable interconnectors. In addition, the company is developing the world’s first energy islands that will link wind farms and HVDC interconnectors to multiple European countries. Overall, the company’s transmission system has a reliability rate of 99.99%. For its part, PPL has invested more than $9 billion in transmission in the United States over the past decade.

[1] https://pplweb.mediaroom.com/2022-10-24-PPL-and-Elia-Group-subsidiaries-announce-agreement-to-develop-and-propose-innovative-transmission-solutions-to-connect-future-offshore-wind-capacity-to-onshore-grid-in-New-England

[2] Massachusetts, Connecticut, Rhode Island, Maine, and New Hampshire

[USA] Interior announces first offshore wind lease sale on the west coast

On October 18, 2022, the Department of the Interior announced that the Bureau of Ocean Energy Management (BOEM) will hold its first offshore wind energy lease sale on the west coast.[1] The lease sale will take place on December 6, 2022, for areas on the Outer Continental Shelf (OCS) off central and northern California. It will be the first U.S. sale to support potential commercial-scale floating offshore wind energy development. The press release states that the sale will be critical for achieving the Biden administration’s goal of deploying 30 GW of offshore wind by 2030 and 15 GW of floating offshore wind by 2035. To date, BOEM has held ten competitive lease sales and issued 27 active commercial wind leases in the Atlantic Ocean.

BOEM will offer five OCS lease areas, which total approximately 373,268 acres and have the potential to produce over 4.5 GW of offshore wind energy. The sale will include three lease areas off central California and two lease areas off northern California. It also includes several lease stipulations designed to promote the development of a robust domestic supply chain, advance flexibility in transmission planning, and create good-paying union jobs. Stipulations include bidding credits for bidders who enter into community benefit agreements or invest in workforce training or supply chain development, requirements for winning bidders to make efforts to enter into project labor agreements, and requirements for engagement with tribes, underserved communities, ocean users, and agencies.

[1] https://www.doi.gov/pressreleases/biden-harris-administration-announces-first-ever-offshore-wind-lease-sale-pacific

[USA] Entergy Louisiana, Entergy New Orleans, and Diamond Offshore announce MOU on future offshore wind development in the Gulf of Mexico

Entergy Louisiana, Entergy New Orleans, and Diamond Offshore Wind announced on September 23, 2022, that they had signed a memorandum of understanding (MOU) regarding the evaluation and potential development of wind power generation in the Gulf of Mexico. [1] According to the press release, the MOU could put Entergy in a position to develop a new source of clean power for customers and also the region’s economic development. The agreement provides a legal framework for Entergy and Diamond Offshore Wind to work toward the development of potential offshore wind demonstration projects located in Louisiana waters and will focus on the evaluation of grid interconnectedness to determine the ideal size and locations for future offshore wind developments. In January 2022, Louisiana Governor John Bel Edwards (D) submitted the Climate Action Plan, which included a goal to achieve 5 GW of offshore wind generation by 2035. The companies said the development of wind energy in the Gulf of Mexico would accelerate the state’s role as a leader in renewable energy development and fit in with the governor’s plan.

[1] https://www.entergynewsroom.com/news/entergy-louisiana-entergy-new-orleans-diamond-offshore-wind-seek-evaluate-offshore-wind/

[Japan] Pattern Energy closes financing on Japan’s largest offshore wind power+storage project, begins construction

On September 9, 2022, Pattern Energy Group and its affiliate in Japan, Green Power Investment Corporation (GPI), announced it had completed financing and begun full construction of its 112 MW Ishikari Offshore Wind project. Ishikari Offshore Wind is located about 3 km from the shore of Ishikari Bay in Hokkaido, Japan, and will feature a battery storage component with 100 MW x 180 MWh of capacity. The project and associated battery storage are expected to reach commercial operation in December 2023. The project has a 20-year power purchase agreement (PPA) with Hokkaido Electric Power Network for 100% of the power output. Ishikari Offshore Wind will utilize 14 Siemens Gamesa 8.0 MW wind turbines. The turbines are designed to meet local codes and standards regarding typhoons, seismic activities, 50 Hertz operation, and operation in high and low ambient temperatures. The turbines and associated supporting structures received ClassNK certification, which confirms that they meet the technical standards required by the Japanese government to approve construction.

Including Ishikari Offshore Wind, Pattern Energy has eight renewable energy facilities in Japan, either in operation or under construction. The other facilities include three onshore wind power facilities and two solar power facilities in operation, and three wind power facilities under construction.

[USA] New England states launch effort to connect offshore wind to the grid

On September 1, 2022, five New England states—Massachusetts, New Hampshire, Connecticut, Rhode Island, and Maine— launched an effort to help connect offshore wind projects and other carbon-free resources to the power grid over the next three decades.[1] In a joint request for information (RFI), the states requested comments on how to limit the costs of transmission for consumers, where new power lines should be located, and how environmental justice and equity impacts should be considered. The states hope to speed up the process for building new power lines and related infrastructure and to make use of funding programs established by the Bipartisan Infrastructure Law (BIL). Although Vermont, the only state in New England without a coastline, is not participating in the joint initiative, it will remain an observer and supports the objectives of the initiative.

Currently, the New England states have about 8.3 GW of offshore wind under construction or in the permitting process. However, the RFI cited a 2020 study conducted by ISO New England (ISO-NE) that indicated the region could only add up to 5.8 GW of offshore wind without major new transmission reinforcements on land. “Any significant quantity of offshore wind beyond that amount may not be able to interconnect into the regional grid without significant transmission upgrades,” the RFI said. “In addition, the most easily accessible interconnection points along the southern New England coast are already at or beyond their full capacity with those offshore wind projects under contract or review.” Comments on the RFI are due October 14, 2022.

[1] https://newenglandenergyvision.files.wordpress.com/2022/09/transmission-rfi-notice-of-proceeding-and-scoping.pdf

[USA] Dominion threatens to abandon 2.6 GW offshore wind project

In a rehearing request filed with the Virginia State Corporation Commission (SCC) on August 22, 2022, Dominion Energy Virginia said it will abandon its planned 2.6 GW offshore wind farm if regulators do not reverse their decision to set a performance guarantee requirement for the project.[1] The 2.6 GW Coastal Virginia Offshore Wind project will include 176 wind turbines located about 27 miles off the coast of Virginia Beach and has an expected capital cost of $9.8 billion. On August 5, 2022, the SCC approved the project with a rate rider for recovering the cost of the project and related onshore transmission facilities. Under this decision, Dominion’s customers must be held harmless for any shortfall in energy production below the project’s expected 42% average annual capacity factor, measured on a three-year rolling average. According to the utility’s filing, “There is no precedent in the record of any utility being forced to take on an obligation of this nature to guarantee a capacity factor for its generating units over their entire life or, equally importantly, to insure against the risk of events beyond the utility’s control and its reasonable or unreasonable conduct.”

The SCC accepted Dominion’s rehearing request on August 24, 2022, and said the utility could begin recovering costs related to the project using a special rate rider. Opposing parties in the proceeding must respond to the rehearing request by September 13, 2022. The utility can reply to these submissions by September 22, 2022.

[1] https://scc.virginia.gov/docketsearch/DOCS/7ndt01!.PDF

[USA] California adopts target of 25 GW of offshore wind by 2045

On August 10, 2022, the California Energy Commission (CEC) voted to adopt offshore wind energy preliminary planning targets of 2,000 MW to 5,000 MW by 2030 and 25,000 MW by 2045.[1] The upper end of the 2030 target range could come from a full build-out of Morro Bay Wind Energy Area (WEA) or a combination of a partial build-out of the Morro Bay WEA and Humboldt WEA. CEC staff proposed the goals in response to Assembly Bill 525, which was signed into law in September 2021 and required the CEC to develop planning goals and a strategic plan for offshore wind energy deployment in the state. The planning goals are an increase over the initial proposed goal of 10,000 MW to 15,000 MW goal by 2045. The increase follows a letter from Governor Newsom (D) urging regulators to establish a goal of at least 20 GW of offshore wind by 2045.[2] The new goal is the largest in the U.S. and exceeds New York’s plan to install 9,000 MW of offshore wind by 2035, previously the largest long-term target. CEC staff noted that the preliminary planning goals were designed to be potentially achievable but aspirational.

[1] https://www.energy.ca.gov/filebrowser/download/4361

[2] https://www.gov.ca.gov/wp-content/uploads/2022/07/07.22.2022-Governors-Letter-to-CARB.pdf?emrc=1054d6

[USA] California considers target of 3 GW of offshore wind by 2030

In a draft report released on May 6, 2022, by the California Energy Commission (CEC), CEC staff recommend building 3 GW of offshore wind by 2030 and between 10 GW and 15 GW by 2045.[1] Given that the offshore wind industry could see technology developments and subsequent cost declines, the draft report suggests the potential of up to 20 GW between 2045 and 2050. This amount is the largest long-term offshore wind goal, surpassing New York’s 9 GW target for 2035. The draft report stems from the 2021 Assembly Bill 525, which directed the CEC to establish offshore wind planning goals for 2030 and 2045. The legislation also required the agency to develop a strategic plan for offshore wind resources by mid-2023.

The CEC said that it is in the process of identifying suitable sea space in federal waters, which could change the outlined planning goals. The road map also noted that one point of uncertainty is the availability of federal tax credits in the future. Currently, offshore wind projects that start construction before 2025 can receive the 30% investment tax credit (ITC), but after 2025 Congress would need to extend the ITC. According to the draft report, the ITC could bring the cost of projects from the $60-$70 MWh range down to $40-$50 per MWh.

[1] https://efiling.energy.ca.gov/GetDocument.aspx?tn=242970&DocumentContentId=76566