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Procedure, the Independent Energy Producers Association (IEP) provides the following
Pursuant to the Administrative Law Judge’s Ruling Granting Limited Party Status of
Independent Energy Producers (dated November 12, 2008), IEP limits its comments on
the APD to the issue of commitments proposed by the APD to ensure San Diego Gas &
Electric Company (SDG&E) uses a significant portion of the capacity of the Sunrise
Powerlink on SDG&E providing sufficient assurances to the Commission that the Final
Imperial Valley renewable generation to the California market, including San Diego. In
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addition, the APD specifies that, if SDG&E agrees to such a condition, SDG&E shall
submit a plan to the Commission, in the form of an application filed in this proceeding
within 90 days of the effective date of the final decision. The application is to describe
how SDG&E will ensure that Sunrise Powerlink will be used to deliver substantial
amounts of Imperial Valley renewable generation. The application, becoming the formal
basis for SDG&E to submit its “Sunrise Compliance Plan,” would, among other things,
explain how SDG&E would ensure, through binding commitments, that substantial
amounts of Imperial Valley renewable generation will be developed and delivered via
Sunrise Powerlink starting on the day Sunrise is placed in service; and, specify the
renewable generation that will be developed and delivered on the Sunrise Powerlink in
sufficient detail for the Commission to understand the viability of the generation, the
anticipated capacity factor of the generation, and the process by which the generation will
renewable resource zones as quickly as possible. The evidence suggests that the Sunrise
that the Sunrise Powerlink should be approved, then IEP is concerned that the APD may
result in additional delays because the APD requires an additional Application be served
by SDG&E in 2009 to enable the Commission and interested parties the opportunity to
review SDG&E’s Compliance Plan. This may result in additional delay as the SDG&E
filed Compliance Plan is reviewed, debated, etc. IEP is concerned that this procedural
step may hinder real progress on constructing transmission to interconnect to the Imperial
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Valley renewable resource area.
approving the Sunrise Powerlink, additional language in the approved Final Decision
committing the utility to an open, transparent, competitive Renewable Request for Offer
(Renewable RFO), to be fully completed by December 31, 2009. Any such renewable
RFO should result in firm commitments for viable, renewable resources that can become
Transmission Line (or soon thereafter) to help SDG&E achieve its stated goal of 33% of
RFO will facilitate the timely development and interconnection of renewable generation
to use the Sunrise Powerlink. It will help ensure that the Sunrise Powerlink, upon
energization, is used for the purposes intended by the Commission (i.e. 33% RPS build-
out) and supported by SDG&E in public comments. The 2009 Renewable RFO should
be planned and conducted in a manner to incent viable renewable projects, i.e. those
capable and prepared to interconnect upon energization of the transmission line (i.e.
and completed with binding commitments with renewable resources by no later than
December 31, 2009, (b) that the RFO include transparent consideration of project
milestones and project viability measures, and (c) that the conduct of the renewable RFO
be wholly consistent with Commission policy wherein the Commission has found that
“all long-term procurement should occur via competitive procurements, rather than
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through preemptive actions by the IOU, except in truly extraordinary circumstances.” 1
Regarding transparent project milestones and viability measures, IEP recommends that
the Commission direct the utility to work with the renewable development community
and finalize the identification of such important measures to the Commission by March
SDG&E has not made significant progress by December 31, 2009 toward constructing
and energizing the line by 2012, IEP suggests that the Commission consider third-party
for accessing Imperial Valley renewables as a means to achieving RPS goals, it would be
assuming third-party transmission developers may be ready and able to provide a timely
1
Decision (D.) 07-12-052, pp. 208-209 (emphasis in original).
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Respectfully submitted this 20th day of November, 2008 at San Francisco,
California.
Steven Kelly
Policy Director
1215 K Street, Suite 900
Sacramento, California 95814
Telephone: (916) 448-9499
Facsimile: (916) 448-0182
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CERTIFICATE OF SERVICE
I, Melinda LaJaunie, certify that I have on this 20th day of November 2008
website, via email to those listed with email and via U.S. mail to those without
correct. Executed this 20th day of November 2008 at San Francisco, California.
2970/010/X105009.v1
Service List – A.06-08-010
(Updated November 18, 2008)
ANDREW B. BROWN CLAY E. FABER WILLIAM F. DIETRICH
abb@eslawfirm.com cfaber@semprautilities.com dietrichlaw2@earthlink.net
2.
Service List – A.06-08-010
(Updated November 18, 2008)
PAT/ALBERT BIANEZ SCOT MARTIN TOM MURPHY
patricia_fallon@sbcglobal.net scotmartin478@msn.com tmurphy@aspeneg.com
3.
Service List – A.06-08-010
(Updated November 18, 2008)
WALLY BESUDEN
PRESIDENT
SPANGLER PEAK RANCH, INC
PO BOX 1959
ESCONDIDO, CA 92033
WILLIAM TULLOCH
28223 HIGHWAY 78
RAMONA, CA 92065
KIMBELRY SCHULZ
10303 CANINITO ARALIA NO 96
SAN DIEGO, CA 92131
GREGORY T. LAMBRON
LAMBRON LAKESIDE RANCH, LLC
PO BOX 15453
SAN DIEGO, CA 92175-5453
LYNDA KASTOLL
REALTY SPECIALIST
BUREAU OF LAND MANAGEMENT
EL CENTRO FIELD OFFICE
1661 SOUTH 4TH STREET
EL CENTRO, CA 92243
NANCY J. SARACINO
ATTORNEY
CALIFORNIA INDEP. SYSTEM
OPERATOR CORP.
151 BLUE RAVINE ROAD
FOLSOM, CA 95630
PUC/X104919.v1
4.