BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ERRATA TO SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY TO PROTESTS

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) for a Certificate of Public Convenience and Necessity for the Coolwater-Lugo Transmission Project ) ) ) ) ) Application No (Filed August 28, 2013) ERRATA TO SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY TO PROTESTS BETH GAYLORD ANGELA WHATLEY TAMMY JONES SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, CA Telephone: (626) Facsimile: (626) angela.whatley@sce.com LAURA GODFREY ANNE BEAUMONT LATHAM & WATKINS LLP 600 W. Broadway, Suite 1800 San Diego, CA Telephone: (619) Facsimile: (619) laura.godfrey@lw.com Attorneys for Applicant SOUTHERN CALIFORNIA EDISON COMPANY Dated: October 31, 2013

2 I. INTRODUCTION On October 14, 2013, Southern California Edison Company (SCE) filed its reply to the various protests and responses received in this proceeding. On October 29, 2013, Critical Path Transmission filed a motion to strike portions of SCE s reply. In its motion to strike, 1 Critical Path points out that SCE s reply misquotes an excerpt from the AV Clearview Phase I Transmission Project New Alternative Evaluation (the CAISO study). 2 Upon review, SCE discovered that during the editorial process, SCE inadvertently formatted into a block quotation a paragraph that was intended to combine both quotations and paraphrases from page 4 of the CAISO study, and SCE mistakenly used an incorrect number from the CAISO study s table. To avoid any further confusion, SCE will use only a direct quote from the CAISO study to support the proposition it intended to convey in its reply, namely, that Coolwater-Lugo and the AV Clearview Phase I Proposal are not equivalent. SCE therefore submits this errata pursuant to Commission Rule of Practice and Procedure 1.12 to correct these inadvertent errors. 3 II. CORRECTIONS TO SCE S REPLY SCE submits the minor revisions to correct its unintentional errors on page 16 of its reply. As noted above, these revisions correct an inadvertent use of a block quotation instead of a paraphrase. These revisions also correct the inadvertent use of the 920 figure instead of the Critical Path Motion to Strike at 7. CAISO, AV Clearview Phase I Transmission Project - New Alternative Evaluation (Aug. 2, 2013) at 4, available at NewAlternativeEvaluation.pdf. SCE does not herein address the substantive issues raised in Critical Path s Motion to Strike and will separately file a response to the Motion, but merely wishes to immediately clarify the record in response to learning of the inadvertent errors regarding the discussion of the CAISO study findings. 1

3 figure number from the CAISO study table. For comparison purposes, SCE provides: (1) the paragraph as it originally appeared in SCE s reply which SCE agrees to remove from its reply; and (2) the corrected language using only a direct quote from the CAISO study (with additions shown in bold and underline, with deletions to footnote 32 in strikethrough). A. Original Text On Page 16 Of SCE s Reply Finally, as noted above, the AV Clearview concept is not a true alternative to Coolwater-Lugo because it does not provide the same scope of transmission upgrades. As CAISO previously explained: [AV Clearview] is not on its own an equivalent substitute for the Coolwater-Lugo 230 kv transmission line in the context of the CAISO Generation Interconnection study process. For instance, an upgrade of Lugo-Jasper 230 kv line would need to be added to the scope and cost estimate for the AV Clearview Phase 1 Proposal for it to be fairly compared to Coolwater-Lugo. If the AV Clearview Phase 1 Proposal were adopted over Coolwater-Lugo without the upgrades between Jasper and Lugo then only approximately 500 MW would be deliverable, as compared to the 920 MW of transmission capacity that Coolwater-Lugo would provide. The CAISO is responsible to provide deliverability for the entire 920 MW if the total amount were to develop. With Coolwater-Lugo, the likelihood of needing additional transmission is lower than with the AV Clearview project by itself. 32 [FN 32] CAISO, AV Clearview Phase I Transmission Project - New Alternative Evaluation (Aug. 2, 2013) at 4, available at NewAlternativeEvaluation.pdf. CAISO has forecasted that Coolwater-Lugo would provide 920 MW of new transmission capability. SCE s design for Coolwater-Lugo, as proposed to the Commission, would provide up to 1,000 MW of new transmission capability. 2

4 B. Corrected Text For Page 16 Of SCE s Reply Finally, as noted above, the AV Clearview concept is not a true alternative to Coolwater-Lugo because it does not provide the same scope of transmission upgrades. As CAISO previously explained on page 4 of the CAISO study 32 : This [CAISO] study determined that the new alternative is not on its own an equivalent substitute for the Coolwater-Lugo 230 kv line in the context of the ISO Generation Interconnection study process. An upgrade of Lugo-Jasper 230 kv line would need to be added to the scope and cost estimate for the AV Clearview Phase I alternative in order for the two alternatives to be equivalent. The C3C4 Phase II base cases were established pursuant to the Cluster 1-4 Technical Bulletin [citation omitted] which specifies an assumption that the amount of new generating capacity in each study area from the interconnection queue will not exceed the amount that will be deliverable based on the transmission system as reflected in the ISO transmission planning process. Based on the technical bulletin, 500 kv upgrades associated with providing deliverability at Pisgah substation, including a Pisgah-Lugo 500 kv line, were removed from the study assumptions because the viability of the project is highly uncertain. However, as shown in the table below, with the Coolwater-Lugo 230 kv line project looped into the planned Jasper substation approximately 720 MW of the 920 MW of the generation in the queue at Pisgah, Jasper and nearby would still be deliverable. If the AV Clearview alternative were chosen without the upgrades between Jasper and Lugo associated with the Coolwater-Lugo 230 kv line project then only 500 MW out of the 920 MW would be deliverable. The ISO is responsible to provide deliverability for the entire 920 MW if the total amount were to develop. With the Coolwater-Lugo 230 kv line project, the likelihood of needing additional transmission is lower than with the AV Clearview project by itself. 3

5 No. Bus Name Type Nameplate Capacity Deliverable Capacity with Coolwater-Lugo 230 kv line project Deliverable Capacity with AV Clearview project 1 Jasper 230 kv Q135 Wind Jasper 230 kv Q552 Solar Pisgah 230 kv Q240 Solar Pisgah 230 kv Q241 Solar Total [FN 32] CAISO, AV Clearview Phase I Transmission Project - New Alternative Evaluation (Aug. 2, 2013) at 4, available at NewAlternativeEvaluation.pdf. CAISO has forecasted that Coolwater-Lugo would provide 920 MW of new transmission capability. SCE s design for Coolwater-Lugo, as proposed to the Commission, would provide up to 1,000 MW of new transmission capability. III. CONCLUSION This revision clarifies the unintentional errors pointed out by Critical Path. SCE referenced the CAISO study multiple times throughout its reply and included a URL for accessing the CAISO study in footnote 32 as the reference for the subject paragraph on page 16 of the reply, so the CAISO s actual document was readily accessible to all parties. For the convenience of the Commission and the parties, SCE has attached a corrected copy of page 16 of its reply (Attachment A) and a full copy of the CAISO study (Attachment B). If the Commission 4

6 determines it is appropriate, SCE will file a revised pleading to incorporate these corrections. SCE regrets if these inadvertent errors have caused any confusion for any party. Dated: October 31, 2013 Respectfully submitted, LAURA GODFREY ANNE BEAUMONT /s/ Laura A. Godfrey By: Laura A. Godfrey Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY LATHAM & WATKINS 600 West Broadway, Suite 1800 San Diego, CA Telephone: (619) Facsimile: (619) laura.godfrey@lw.com 5

7 ATTACHMENT A

8 FERC has clearly confirmed it does not), no particular transmission project can be guaranteed approval in the Order 1000 process AV Clearview would need to meet the CAISO tariff criteria and to be selected, among possible other bids, to build any project under the Order 1000 process. Critical Path cannot simply assume that its AV Clearview Phase 1 Proposal would be approved even if it were submitted as a project for competitive bidding, regardless of the outcome of this proceeding. 31 Finally, as noted above, the AV Clearview concept is not a true alternative to Coolwater- Lugo because it does not provide the same scope of transmission upgrades. As CAISO previously explained on page 4 of the CAISO study 32 : This [CAISO] study determined that the new alternative is not on its own an equivalent substitute for the Coolwater-Lugo 230 kv line in the context of the ISO Generation Interconnection study process. An upgrade of Lugo-Jasper 230 kv line would need to be added to the scope and cost estimate for the AV Clearview Phase I alternative in order for the two alternatives to be equivalent. The C3C4 Phase II base cases were established pursuant to the Cluster 1-4 Technical Bulletin [citation omitted] which specifies an assumption that the amount of new generating capacity in each study area from the interconnection queue will not exceed the amount that will be deliverable based on the transmission system as reflected in the ISO transmission planning process. Based on the technical bulletin, 500 kv upgrades associated with providing deliverability at Pisgah substation, including a Pisgah-Lugo 500 kv line, were removed from the study assumptions because the viability of the project Id. CAISO, AV Clearview Phase I Transmission Project - New Alternative Evaluation (Aug. 2, 2013) at 4, available at NewAlternativeEvaluation.pdf. CAISO has forecasted that Coolwater-Lugo would provide 920 MW of new transmission capability. SCE s design for Coolwater-Lugo, as proposed to the Commission, would provide up to 1,000 MW of new transmission capability. 16

9 is highly uncertain. However, as shown in the table below, with the Coolwater-Lugo 230 kv line project looped into the planned Jasper substation approximately 720 MW of the 920 MW of the generation in the queue at Pisgah, Jasper and nearby would still be deliverable. If the AV Clearview alternative were chosen without the upgrades between Jasper and Lugo associated with the Coolwater-Lugo 230 kv line project then only 500 MW out of the 920 MW would be deliverable. The ISO is responsible to provide deliverability for the entire 920 MW if the total amount were to develop. With the Coolwater-Lugo 230 kv line project, the likelihood of needing additional transmission is lower than with the AV Clearview project by itself. No. Bus Name Type Nameplate Capacity Deliverable Capacity with Coolwater-Lugo 230 kv line project Deliverable Capacity with AV Clearview project 1 Jasper 230 kv Q135 Wind Jasper 230 kv Q552 Solar Pisgah 230 kv Q240 Solar Pisgah 230 kv Q241 Solar Total In sum, Critical Path is asking the Commission to delay the approval of a vital and needed renewable transmission infrastructure project, Coolwater-Lugo, for the benefit of Critical Path s own proposal that, as it stands today, has no certain path forward, and that has not demonstrated that it will have any definite viability in the future. The Commission should decline to do so, and instead move forward with the Coolwater-Lugo Application. 17

10 D. Schedule and Process Considerations Despite CAISO s conclusion that Critical Path s AV Clearview Phase 1 Proposal is not a comparable substitute, Critical Path, HDPA, KWEA, and the City of Lancaster attempt to circumvent CAISO s determination by asking the Commission to consider the AV Clearview Transmission Phase 1 Proposal as an alternative to Coolwater-Lugo in this proceeding. 33 Critical Path improperly requests that the Commission bifurcate the proceedings to include an unnecessary and unprecedented preliminary phase of the proceeding in which the Commission would evaluate whether the AV Clearview Phase 1 Proposal should be an alternative under the California Environmental Quality Act (CEQA), which Critical Path has named a Pre-CEQA Alternatives Evaluation. 34 Critical Path and HDPA argue that the CAISO analysis demonstrates that the AV Clearview Phase 1 Proposal is an appropriate electrical alternative for consideration by the Commission. Those arguments are unsubstantiated, and the parties do not provide a project description or any evidence to support this claim. While SCE understands that that CAISO is evaluating a revised AV Clearview Phase 1 Proposal and Coolwater-Lugo for a relative comparison of how each project may support the integration of new generation resources, such evaluation will necessarily require a full reliability assessment in order to identify all impacts that need to be addressed by each project proposal. That full reliability assessment has not yet been completed by CAISO. 35 In order for the CAISO to complete its reliability assessment, SCE must determine Critical Path Protest at 6-7 (unnumbered); HDPA Protest at 3-4; City of Lancaster Protest at 3-4 (unnumbered). Critical Path Protest at 5-6 (unnumbered). See CAISO, AV Clearview Phase I Transmission Project - New Alternative Evaluation (Aug. 2, 2013) at 3 n.1, available at 18

11 the impact of the AV Clearview Phase 1 Proposal on its system. However, SCE has not yet been able to proceed with a reliability assessment on the AV Clearview Phase 1 Proposal, which is needed to integrate this proposal into the SCE transmission system, due to Critical Path s lack of response to SCE's requests for a project scoping meeting to facilitate the development of the study plan for the reliability assessment. Critical Path has simply not sufficiently defined the AV Clearview Phase 1 Proposal for it to be fully assessed in CAISO s Transmission Planning Process. As a result, CAISO has reviewed and rejected each iteration of the AV Clearview Phase 1 Proposal proffered by Critical Path in CAISO s annual Transmission Planning Process. The AV Clearview Phase 1 Proposal is preliminary with no CAISO approval, no detailed project description, and no detailed cost estimate. Because there is no detailed project description, it is impossible to complete any substantive environmental review. There is, simply put, nothing for the Commission to review, much less make a finding about the AV Clearview Phase 1 Proposal as an alternative to Coolwater-Lugo under CEQA. Further, Critical Path s reliance on the Commission s decision on San Diego Gas & Electric s (SDG&E s) Valley Rainbow as precedent for the Commission to make a pre-ceqa determination on alternatives is misplaced. 36 In the Valley-Rainbow proceeding, SDG&E filed a CPCN application to construct a reliability project consisting of several transmission lines and associated upgrades. 37 The first phase in the Valley Rainbow proceeding, which lasted more than 14 months, focused on whether the project was needed at all, and did not involve NewAlternativeEvaluation.pdf. Critical Path Protest at 2 (unnumbered) (citing D ). D at 2. 19

12 determinations regarding CEQA alternatives. As explained by the Commission in D , in this phase of the proceeding, we are only attempting to determine whether a need for the project exists, not evaluate alternatives. 38 The Commission disagreed with SDG&E s assessment of supply forecasts, demand forecasts, and appropriate time horizons and ultimately determined that the project was not needed. 39 Although Critical Path implies that the CPUC made a pre-ceqa determination on the preference between viable alternatives in the Valley Rainbow proceeding, it provides no citation to support its claim. 40 In contrast, Critical Path requests that the Commission bifurcate the Coolwater-Lugo proceeding in an unprecedented manner to review its transmission proposal and to inappropriately determine whether the AV Clearview Phase 1 Proposal should be an alternative under CEQA, prior to the initiation of the Commission s CEQA review of Coolwater-Lugo. Even if the AV Clearview Phase 1 Proposal should be considered a CEQA alternative (which it should not), that determination would be made in due course in the Energy Division s CEQA review of Coolwater-Lugo. 41 Therefore, Critical Path s request for bifurcated proceedings should be denied D at 9. D at 71. See Critical Path Protest at 3 (unnumbered). For a full discussion of why the AV Clearview Phase 1 Proposal should not be considered an alternative to Coolwater-Lugo under CEQA, see the reasons outlined in the Coolwater-Lugo PEA. Coolwater-Lugo PEA at 1-24 to

13 E. Cost Considerations In its protest, Critical Path claims Coolwater-Lugo will cost ratepayers an estimated $2 billion in revenue requirement more than the AV Clearview Phase 1 Proposal. 42 While Critical Path makes several assertions about the relative cost of Coolwater-Lugo compared to the AV Clearview Phase 1 Proposal, Critical Path does not provide the Commission with cost information sufficient to support its assertions. Indeed, Critical Path s protest does not include any dollar amounts associated with AV Clearview Phase 1 Proposal. Based on SCE s long-standing experience in developing transmission projects in Southern California, however, SCE finds Critical Path s cost-related assertions to be overly optimistic and misleading. Although further discovery would be needed to fully understand Critical Path s cost assertions, its claims have several readily apparent and fundamental flaws. First, Critical Path s presentation of revenue requirement is inconsistent with standard practice. Utilities and the Commission traditionally compare present value of revenue requirement as the method to evaluating investment options on behalf of ratepayers. By comparison, Critical Path incorrectly uses an estimated sum of nominal revenue requirement. Additionally, a proper economic analysis of purported alternatives would require each solution to provide comparable benefits. As stated previously, CAISO has determined that the AV Clearview Phase 1 Proposal does not meet the same needs met by Coolwater-Lugo and they are not equivalent. To fairly compare the Coolwater-Lugo to the AV Clearview Phase 1 Proposal, additional scope must be added to components in the AV Clearview Phase 1 Proposal. First, the upgrades from Lugo to Jasper would have to be added to the scope of the AV 42 Critical Path Protest at 9-10 (unnumbered). The City of Lancaster also claims without specificity that the AV Clearview Phase 1 Proposal will cost less than Coolwater-Lugo. City of Lancaster Protest at 3-4 (unnumbered). 21

14 Clearview Phase 1 Proposal to interconnect generation in the Lucerne Valley area. Second, SCE would have to implement additional network upgrades to safely and reliably integrate the AV Clearview Phase 1 Proposal into the transmission system. At a minimum, the AV Clearview Phase 1 Proposal would cost California ratepayers at least $300 to $400 million, in 2013 dollars and without contingency, more than Critical Path represents to account for the necessary SCE transmission system upgrades to accommodate the AV Clearview Phase 1 Proposal. ORA s claims that SCE s cost estimates and contingency are high, although it concludes that it will further examine SCE s proposed estimates. 43 BAMx also claims SCE s cost estimates and contingency are unreasonable. 44 SCE notes that its cost estimates take into account current market conditions and are based on recent projects in California that are either completed or under construction. SCE s cost estimate and contingency contained in the CPCN Application are consistent with the preliminary level of engineering at this time, and reflect the most realistic estimate of what the maximum project cost might be, if such contingencies occur. Of course if contingencies do not occur, actual costs could be lower than SCE s estimate of the maximum cost. F. Environmental Considerations In its protest, Critical Path claims that Coolwater-Lugo has substantially greater environmental impacts than the AV Clearview Phase 1 Proposal. 45 SCE does not believe this to be true, and regardless, the AV Clearview Phase 1 Proposal is too speculative at this point to make any such assertion or comparison. Because there is currently no official project route for ORA Protest at 6. BAMx Protest at 3-4. Critical Path Protest at (unnumbered). 22

15 the AV Clearview Phase 1 Proposal or even enough information to deem it a proposed project at this stage there can be no meaningful analysis regarding whether it is more or less environmentally impactful than Coolwater-Lugo. By contrast, Coolwater-Lugo has a detailed project description and a 4,500-page PEA. Of Coolwater-Lugo s 64.2 total miles, 28.2 miles will be located within existing right-of-way (ROW), and another 17.4 miles will be parallel and adjacent to existing ROW. Thus, approximately 70% of Coolwater-Lugo is within existing ROW or parallels existing ROW, and the remaining portion is in mostly desert and rural area. For the reasons discussed above, SCE does not believe the AV Clearview Phase 1 Proposal should be considered a project alternative. But even if it were considered an alternative, whether or not it is environmentally superior would be properly evaluated in due course during the Commission s CEQA process. At this time, Critical Path s statements regarding environmental impacts are speculative, premature, and unsupported by any available data. G. Timing of Coolwater-Lugo and the AV Clearview Phase 1 Proposal Critical Path s claim that the AV Clearview Phase 1 Proposal will be completed years prior to Coolwater-Lugo is unsupported. 46 As mentioned above, in spite of submitting multiple iterations of the AV Clearview Phase 1 Proposal to CAISO, Critical Path still does not have a CAISO-approved project. Further, the permitting process for the proposal, including CEQA review, has not even been initiated. It also is not clear what SCE upgrades might be triggered by the AV Clearview Phase 1 Proposal and any additional Commission permits SCE would need to obtain for those upgrades. Moreover, the AV Clearview Phase 1 Proposal, unlike Coolwater- 46 Critical Path Protest at 13 (unnumbered). 23

16 Lugo, could be subject to CEQA challenges in Superior Court, which can cause delay. Considering the current preliminary state of the AV Clearview Phase 1 Proposal and the unknown challenges ahead, Critical Path s assertion that the AV Clearview Phase 1 Proposal can be completed years before Coolwater-Lugo is an unsupported statement that is very unlikely to be accurate. IV. CONCLUSION The issues raised by the various Protests particularly with regard to the AV Clearview Phase 1 Proposal either have been addressed in SCE s Application and concurrently-filed PEA, or should not be included the scope of this proceeding. In particular, the AV Clearview Phase 1 Proposal does not meet the Coolwater-Lugo project objectives and should not be considered an alternative to the Project. Moreover, the Commission should not bifurcate this proceeding as requested by Critical Path to prematurely decide whether the AV Clearview Phase 1 Proposal should be an alternative under CEQA, as such bifurcation would not be warranted, would be improper under CEQA, and would unduly extend the Commission s review of the Coolwater- Lugo CPCN Application. Finally, the Commission should not dismiss the Coolwater-Lugo Application as suggested by ORA, as there is no prerequisite that each upgrade contemplated in a CPCN application be approved by CAISO. Such a requirement would unnecessarily delay the development of Coolwater-Lugo and create precedent that would hinder established, prudent transmission planning in California. Dated: October 14, 2013 Respectfully submitted, LAURA GODFREY ANNE BEAUMONT 24

17 /s/ Laura A. Godfrey By: Laura A. Godfrey Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY LATHAM & WATKINS 600 West Broadway, Suite 1800 San Diego, CA Telephone: (619) Facsimile: (619)

18 ATTACHMENT B

19 AV Clearview Phase I Transmission Project New Alternative Evaluation AV Clearview Phase I Transmission Project - New Alternative Evaluation August 2, 2013 California ISO/MID 1

20 AV Clearview Phase I Transmission Project New Alternative Evaluation Introduction The purpose of this supplemental study to the Transmission Plan is to evaluate a new alternative proposed by High Desert Power Authority for the AV Clearview Transmission Project. The new alternative, AV Cleaview Phase I Transmission Project (AV Clearview Phase I), was submitted to the CAISO after the Transmission Plan was finalized. The details of the previously submitted project and CAISO s evaluation are published in Section 3.4 of the Transmission Plan and that section is attached to this supplemental study. ( AV Clearview Phase I Overview The new alternative submitted by High Desert Power Authority consists of the following transmission elements: new 500/230/115 kv Yeager Substation (near SCE s Edwards 115 kv substation) two New 500/230kV Yeager Transformer Banks new double circuit 500 kv from Windhub to Yeager new double circuit 230 kv from Yeager to Kramer new 230/115 kv step-down transformer bank at Yeager new single circuit 115 kv from Yeager to SCE Edwards 115 kv substation (reliability back-up, normally open). The figure below shows the new alternative s proposed configuration. Figure 1: AV Clearview Phase I alternative California ISO/MID 2

21 AV Clearview Phase I Transmission Project New Alternative Evaluation Deliverability Assessment Results A Deliverability Assessment was performed for the new AV Clearview Phase I project alternative. The base cases were updated to include the recently approved Lugo-Eldorado series cap and terminal equipment upgrade project. The following sections discuss the results TPP Commercial Interest Portfolio Deliverability Assessment Results Using the TPP Commercial Interest portfolio case, a deliverability assessment was performed for the Coolwater-Lugo 230 kv and AV Clearview Phase I projects. The study confirmed that both the Coolwater-Lugo 230 kv and AV Clearview Phase I projects, are effective alternatives at delivering the modeled Commercial Interest portfolio renewable generation in the Kramer zone. The steady state analysis concluded that with the AV Clearview Phase I project alternative, the existing Kramer SPS could no longer be required 1. C3C4 Phase II Deliverability Assessment Results Using the C3C4 Phase II base cases, a deliverability assessment was performed for the AV Clearview Phase I project. The steady state analysis confirmed that with either the Coolwater- Lugo 230 kv project or with the AV Clearview Phase I project alternatives, a previously proposed Jasper SPS and a previously proposed Pisgah SPS are required. In addition, it was concluded by steady state analysis that the Kramer SPS could no longer be required with the AV Clearview Phase I project alternative 1. In addition to the above listed SPS s requirements, the study identified the following constraints with the new AV Clearview Phase I alternative: overload on Kramer-Coolwater 230 kv line following an N-1 outage of Kramer-Lockhart 230 kv line overload on Kramer-Lockhart 230 kv line following an N-1 outage of Kramer-Coolwater 230 kv line overload on Lugo-Jasper 230 kv line under N-0 conditions with all lines in-service. The N-1 overloads above can be mitigated by installing a new SPS to trip generation at Lockhart. The N-0 overload on Lugo-Jasper 230 kv line can be mitigated by upgrading that line. An upgrade of this line is part of the scope of work and cost for the Coolwater-Lugo 230 kv project. Therefore, the scope and cost of this upgrade also needs to be added to the scope and cost of the AV Clearview Phase I alternative. 1 Although post-transient and stability analyses were performed on the Coolwater-Lugo 230 kv alternative in the TPP studies; post-transient and stability analyses were not performed by the ISO on the new AV Clearview Phase I alternative. Performing this additional analysis on the AV Clearview alternative could identify the need for the Kramer SPS with that alternative, and therefore the existing SPS would simply need to be retained for both alternatives. California ISO/MID 3

22 AV Clearview Phase I Transmission Project New Alternative Evaluation Conclusion This study determined that the new alternative is not on its own an equivalent substitute for the Coolwater-Lugo 230 kv line in the context of the ISO Generation Interconnection study process. An upgrade of Lugo-Jasper 230 kv line would need to be added to the scope and cost estimate for the AV Clearview Phase I alternative in order for the two alternatives to be equivalent. The C3C4 Phase II base cases were established pursuant to the Cluster 1-4 Technical Bulletin QueueClusters1-4_Determination-NetQualifyingCapacity.pdf which specifies an assumption that the amount of new generating capacity in each study area from the interconnection queue will not exceed the amount that will be deliverable based on the transmission system as reflected in the ISO transmission planning process. Based on the technical bulletin, 500 kv upgrades associated with providing deliverability at Pisgah substation, including a Pisgah-Lugo 500 kv line, were removed from the study assumptions because the viability of the project is highly uncertain. However, as shown in the table below, with the Coolwater-Lugo 230 kv line project looped into the planned Jasper substation approximately 720 MW of the 920 MW of the generation in the queue at Pisgah, Jasper and nearby would still be deliverable. If the AV Clearview alternative were chosen without the upgrades between Jasper and Lugo associated with the Coolwater-Lugo 230 kv line project then only 500 MW out of the 920 MW would be deliverable. The ISO is responsible to provide deliverability for the entire 920 MW if the total amount were to develop. With the Coolwater-Lugo 230 kv line project, the likelihood of needing additional transmission is lower than with the AV Clearview project by itself. NO BUS NAME Type Nameplate Capacity Deliverable Capacity with Coolwater-Lugo 230 kv line project Deliverable Capacity with AV Clearview project 1 Jasper 230 kv Q135 Wind Jasper 230 kv Q552 Solar Pisgah 230 kv Q240 Solar Pisgah 230 kv Q241 Solar Total California ISO/MID 4

23 Attachment 1 Section 3.4 of Transmission Plan dated March 20, 2013 California ISO/MID 5

24 Attachment 1 Section 3.4 of Transmission Plan 3.4 Alternatives considered to the Coolwater-Lugo Project: AV Clearview Transmission Project The Coolwater-Lugo 230 kv transmission line was triggered by an LGIA with ISO generation project #125 in the serial group, executed in The Coolwater-Lugo 230 kv transmission line was identified in the LGIA as a delivery network upgrade needed to mitigate the overloads on the Kramer-Lugo #1 & #2 230 kv Lines. SCE s application to the CPUC for a Certificate of Public Convenience and Necessity (CPCN), for the Coolwater-Lugo project is expected in In anticipation of that filing, the CPUC has indicated that alternatives to Coolwater-Lugo supporting west Mohave renewable generation will need to be considered in the upcoming CPCN proceedings. The AV Clearview Transmission Project was suggested in comments submitted during the planning process as an alternative to the Coolwater-Lugo 230 kv transmission line. Thus, in light of the of the CPUC s stated need to meaningfully discuss alternatives in the CPCN process, the ISO decided to study AV Clearview as an alternative in preparation for the CPCN proceeding. Conducting this analysis as part of the transmission planning process provides a consistent study framework for the analysis and greater transparency to stakeholders about an alternative that might be considered in the CPCN proceeding. The Coolwater-Lugo 230 kv transmission project consists of the following transmission elements: Coolwater-Lugo 220kV Transmission Line: Install a new 59 mile 220kV transmission line including the following elements: approximately 16 circuit miles of 2B-2156 KCMIL ACSR conductor approximately 43 circuit miles of 2B-1590KCMIL ACSR conductor ½ inch steel overhead ground wire as needed approximately 59 miles of OPGW (315,000 linear feet) Coolwater Generating Station 220kV Switchyard: Install necessary equipment to terminate the new Lugo 220kV transmission line in a breaker-and-a-half configuration. Lugo Substation: Install the necessary equipment to terminate the Coolwater 220kV transmission line in a new double breaker line position arranged in a breaker-and-a-half configuration. California ISO/MID 6

25 Attachment 1 Section 3.4 of Transmission Plan North of Lugo Area Description The Coolwater-Lugo 230 kv transmission line and the AV Clearview Transmission Project alternative are located in the North of Lugo transmission system. The North of Lugo transmission system serves San Bernardino, Kern, Inyo and Mono counties. The area extends more than 270 miles north from Lugo. The North of Lugo electric transmission system is composed of 55 kv, 115 kv and 230 kv transmission facilities. In the north, it has interties with LADWP and Sierra Pacific Power. In the south, it connects to the Eldorado substation through the Eldorado-Baker-Cool Water Dunnside-Mountain Pass 115 kv line. It also connects to the Pisgah substation through the Lugo-Pisgah #1 and #2 230 kv lines. Two 500 and 230 kv transformer banks at the Lugo substation provide access to SCE s main system. The North of Lugo area can be divided into the following sub-areas: North of Control; South of Control to Inyokern; South of Inyokern to Kramer; South of Kramer; and Victor. The ISO studied the North of Lugo area under four renewable development scenarios. Table shows the relevant renewable generation amounts in each of those scenarios. More information about the renewable scenarios and the North of Lugo area studies are in Chapter 4. This section describes the alternative mitigation that was considered to mitigate identified transmission deficiencies. Table Renewable generation in the SCE system modeled to meet the 33 percent RPS net short Zone High DG (MW) Environmentally Constrained (MW) Commercial Interest (MW) Cost Constrained (MW) Kramer DG San Bernardino Lucerne Overview of AV Clearview Transmission Project Alternative The High Desert Power Authority suggested that the AV Clearview Transmission Project could serve as an alternative to the Coolwater-Lugo 230 kv Transmission Project. The stated purpose of the facility is to connect eastern transmission and resources around the Kramer/Coolwater area to the Tehachapi area. Upon request, High Desert Power Authority provided the ISO with additional information to the ISO; namely, more details about two options, which include a Baseline Case and an Expanded Case. The Baseline Case consists of the following transmission elements: new 230 kv Yeager Substation; new double circuit 230 kv from Windhub to Yeager; California ISO/MID 7

26 Attachment 1 Section 3.4 of Transmission Plan new double circuit 230 kv from Yeager to Kramer; new 230/115kV step down transformer bank at Yeager; new single circuit 115kV from Yeager to SCE Edwards 115 kv substation; new 500 kv Tucker Substation; new 1000 MW capacity underground DC line between Yeager and Tucker Substations; and loop Lugo-Vincent #1 and #2 Lines through Tucker Substation. The figure below shows the Baseline Case configuration. Figure 3.4-1: AV Clearview alternative: baseline case configuration California ISO/MID 8

27 The Expanded Case consists of the following transmission elements: Attachment 1 Section 3.4 of Transmission Plan new 500 kv Yeager Substation; new double circuit 500 kv from Windhub to Yeager; new double circuit 500 kv from Yeager to Kramer; new 500/115kV step down transformer bank at Yeager; new single circuit 115kV from Yeager to SCE Edwards 115 kv substation; new 500 kv Tucker Substation; new 2000 MW capacity underground DC line between Yeager and Tucker Substation; and loop Lugo-Vincent #1 and #2 Lines through Tucker Substation. The figure below shows the expanded case configuration. Figure 3.4-2: AV Clearview alternative: expanded case configuration California ISO/MID 9

28 Attachment 1 Section 3.4 of Transmission Plan It should be noted that the Expanded Case has been identified as a separate alternative, not as a future expansion to the Baseline Case, referencing in particular the 230 kv construction in the Yeager area. The costs set out below have similarly been provided on a two alternative basis. The figure below shows the geographical location of the AV Clearview Transmission Project alternative. Figure 3.4-3: AV Clearview alternative: geographical map Cost Comparison of AV Clearview Transmission Project Alternative and Coolwater-Lugo 203 kv Transmission Line Table shows the cost estimates of the three projects. The cost estimate for the Coolwater-Lugo project was provided by SCE, and the cost estimates for the two AV Clearview alternatives were provided by the High Desert Power Authority. The ISO has taken each cost estimate at face value. Because the ISO conducted this study for the purposes of providing information to the upcoming CPUC proceeding, the ISO expects that the cost estimates will be considered at that time. California ISO/MID 10

29 Attachment 1 Section 3.4 of Transmission Plan Table Cost estimates of AV Clearview Transmission Project Alternative and Coolwater- Lugo 203 kv Transmission Project Project Estimated Cost AV Clearview Transmission Project Alternative Baseline Case $670 million AV Clearview Transmission Project Alternative Expanded Case $1,190 million Coolwater-Lugo 230 kv Transmission Project (Note 1) $436 million Note 1: The cost presented here does not include the following elements that were originally included in the scope of work for the South of Kramer Transmission Project which included the Coolwater-Lugo 230 kv line: (1) Lugo 500/230 kv #3 transformer (this transformer is not needed for the portfolio scenarios studied) and (2) Jasper Substation Policy-Driven Powerflow and Stability Study Results Chapter 4 of this report describes the study assumptions and study methodology of the policydriven powerflow and stability study analysis performed by the ISO. Using the assumptions and study methodology described therein, the AV Clearview Transmission Project alternative was found to be a potential mitigation for the following constraints that were identified in the policydriven powerflow study for the SCE area. Commercial Interest portfolio peak scenario: case divergence following an N-2 contingency of Kramer-Lugo 230 kv lines Commercial Interest portfolio off-peak scenario: case divergence following an N-2 contingency of Kramer-Lugo 230 kv lines As described in chapter 4, both the Coolwater-Lugo 230 kv Transmission Line and the AV Clearview Transmission Project alternative were found to be effective at mitigating the above constraints Deliverability Assessment Results Chapter 4 of this report describes the study assumptions and study methodology of the policydriven deliverability assessment study analysis performed by the ISO. Using the assumptions and study methodology described therein, a deliverability assessment was performed using the Commercial Interest portfolio. This portfolio has approximately 750 MW of renewable generation modeled in the Kramer zone. As described in chapter 4, the Coolwater-Lugo 230 kv project ensures the deliverability of the 750 MW of renewable generation in the Kramer zone and the 106 MW in the Lucerne zone, in the Commercial Interest portfolio. California ISO/MID 11

30 Attachment 1 Section 3.4 of Transmission Plan In the ISO s assessment, replacing the Coolwater-Lugo project with the AV Clearview Transmission Project alternative caused overloads on the following transmission lines: Yeager-Edwards 115 kv; Edwards-Holgate 115 kv; and Holgate-Kramer 115 kv. The proposed mitigation for these overloads is to keep the Yeager-Edwards 115 kv line open. With these overloads mitigated by this operating solution, the results of the deliverability study for the AV Clearview Project show the following: Baseline Case approximately 250 MW of additional generation in the Kramer zone can be deliverable above the 750 MW already included in the Commercial Interest Portfolio. Expanded Case approximately 1,250 MW of additional generation in the Kramer and Coolwater areas can be deliverable above the 750 MW already included in the Commercial Interest portfolio. The 106 MW in the Lucerne zone are also deliverable. The Jasper substation is assumed to be built to connect this generation to the system, but the cost for Jasper substation is not included in the cost for either project alternative since it is needed to connect renewable generation in the studied portfolios regardless of which alternative is selected. Depending on the specific location of the additional generation, some level of additional deliverability beyond the amounts identified above may be achievable. As the incremental generation is beyond the amounts identified in the CPUC portfolios used for transmission planning purposes, the ISO has not attempted further refinement to these values. In the ISO s planning process, the ISO does not assess a financial benefit with accessing additional renewable generation outside of the portfolio development process led by the CPUC. If there is new information that leads the CPUC to identify additional resources that should be considered in subsequent renewable portfolio development cycles, the CPUC would take that into account in its adoption of renewable portfolios Production Simulation Study Results Chapter 5 of this report describes the study assumptions and study methodology of the economically-driven production simulation assessment study analysis performed by the ISO. Using the assumptions and study methodology described therein, the ISO performed a production simulation analysis of the AV Clearview project economic benefits. The addition of the AV Clearview Transmission Project alternative resulted in the following transmission lines being congested in the Commercial Interest portfolio: Yeager-Edwards 115 kv; Edwards-Holgate 115 kv; and California ISO/MID 12

31 Holgate-Kramer 115 kv. Attachment 1 Section 3.4 of Transmission Plan The proposed mitigation for these overloads is to keep the Yeager-Edwards 115 kv line open. With either the Coolwater-Lugo 230 kv transmission line or the AV Clearview Transmission Project, there was no congestion identified in the study area. Because both proposed network upgrades deliver renewable congestion in the study area, the addition of AV Clearview Transmission Project alternative, in lieu of the Coolwater-Lugo 230 kv line, did not produce any economic benefits that would compensate for the higher costs of the project relative to the Coolwater-Lugo 230 kv project costs Access to Windhub Substation Comments received from stakeholders have provided conflicting opinions on the viability of additional 230 kv interconnections into the Windhub substation. As the ISO focus in the development of this study is in preparation of material intended for the CPUC process, where these issues can be explored, the ISO has not pursued this matter further at this time Review of Report provided by Critical Path Transmission On February 12, 2013, Critical Path Transmission, LLC (Critical Path) submitted a report commissioned by Critical Path comparing the benefits of the AV Clearview project to the South of Kramer (sic) project with preliminary stakeholder comments responding to the draft 2012/2013 transmission plan. The ISO reviewed the report, and has provided the results of its review with our response to stakeholder comments. In summary, the ISO concluded that due to assumptions restricting the use of special protections systems in interconnecting renewable generation and other methodology differences, the bulk of the benefits quantified in the report are higher than what the project is likely to produce. As well, a number of transmission capital additions are assumed to be required in the event of the Coolwater-Lugo project, which could be eliminated by the AV Clearview project; the ISO does not agree with the assumptions that those transmission capital additions would in fact be necessary. Further, the report quantifies benefits post 2020 associated with additional renewable generation the AV Clearview project may make deliverable beyond the CPUC-identified portfolios that the Coolwater-Lugo project can also accommodate. The ISO notes that while some additional renewable capacity benefit is likely for the AV Clearview project, the quantification is higher than ISO projections, and there is a concern of potential double-counting of several of the benefits. California ISO/MID 13

32 Attachment 1 Section 3.4 of Transmission Plan Conclusion The Coolwater-Lugo 230 kv transmission line was triggered by ISO generation project #125 with an executed LGIA in the serial group as a delivery network upgrade to mitigate the overloads on the Kramer-Lugo #1 & #2 230 kv Lines. SCE s application for the CPCN for the project is anticipated in The CPUC has indicated that alternatives that support west Mohave renewable generation will need to be considered in the upcoming CPCN proceedings. Both the Coolwater-Lugo 230 kv Transmission Line and the AV Clearview Transmission Project alternative are effective at delivering the renewable generation in the Kramer zone identified in the table above from the transmission planning process renewable portfolios. The cost estimate provided for both AV Clearview alternatives are higher than the estimate provided for the Coolwater-Lugo Project. The AV Clearview project has the potential to allow the deliverability of some level of additional generation beyond the portfolio amounts identified by the CPUC for transmission planning purposes. However, the ISO found that the AV Clearview project did not produce economic transmission benefits that would offset the higher costs of the project relative to the Coolwater-Lugo 230 kv project costs. The ISO further notes that comments have been received raising concerns with cost and siting issues that the ISO considers are best addressed at the anticipated CPUC proceeding addressing the CPCN for the Coolwater-Lugo project. In response to the feedback provided by the ISO, Critical Path provided a revised project proposal on February 25, Having just received this proposal, the ISO did not have adequate time to comprehensively review it prior to finalizing its 2012/2013 Transmission Plan for the March Board meeting. However, we intend to review the latest proposal after the March Board meeting, and will make our conclusions and supporting analysis publicly available for consideration by interested parties. California ISO/MID 14

33 CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of ERRATA TO SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY TO PROTESTS on all parties identified on the attached service list(s) A Service was effected by one or more means indicated below: X X Transmitting the copies via to all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Commissioner(s) or other addressee(s). ALJ Irene K. Moosen CPUC 505 Van Ness Avenue San Francisco, CA Commissioner Michael Peter Florio CPUC 505 Van Ness Avenue San Francisco, CA X Placing copies in properly sealed envelopes and deposing such copies the United States mail with first-class postage prepaid to all parties for those listed on the attached non list. Executed this 31st day of October, 2013 at Rosemead, California. /s/ Henry M. Romero Henry M. Romero SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue P.O. Box 800 Rosemead, California 91770

34 CPUC - Service Lists - A Page 1 of 3 10/31/2013 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - FOR A CPCN FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: OCTOBER 15, 2013 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties KEVIN DAVIS TAMMY JONES CRITICAL PATH TRANSMISSION LLC ATTORNEY 9400 LURLINE AVE., STE. A1 SOUTHERN CALIFORNIA EDISON COMPANY CHATSWORTH, CA WALNUT GROVE AVE./ PO BOX 800 FOR: CRITICAL PATH TRANSMISSION ROSEMEAD, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY MARK BOZIGIAN R.REX PARRIS HIGH DESERT POWER AUTHORITY MAYOR FERN AVENUE CITY OF LANCASTER LANCASTER, CA FERN AVENUE FOR: HIGH DESERT POWER AUTHORITY LANCASTER, CA FOR: CITY OF LANCASTER DARRYL J. GRUEN C. SUSIE BERLIN CALIF PUBLIC UTILITIES COMMISSION LAW OFFICES OF SUSIE BERLIN LEGAL DIVISION 1346 THE ALAMEDA, STE. 7, NO. 141 ROOM 5133 SAN JOSE, CA VAN NESS AVENUE FOR: THE BAY AREA MUNICIPAL SAN FRANCISCO, CA TRANSMISSION GROUP FOR: DRA Information Only