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Harvey Payne
Rancho Penasquitos Concerned Citizens
13355 Midland Road, Ste. 140
San Diego, CA 92064
Telephone: 858-391-1017
Fax: 858-513-7569
E-mail: hpayne3@gmail.com
2
RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
I. INTRODUCTION
Commissioner Grueneich’s Alternative Proposed Decision (GAPD). RPCC is grateful that the
GAPD recognized that the Coastal link system upgrades proposed by RPCC would save
ratepayers a significant amount of money and would also significantly lessen the environmental
impacts, not to mention the impact on the communities the Coastal link was scheduled to
traverse. There are, however, two important issues surrounding the Coastal link that need
clarification so that a final decision on implementing the Coastal link system upgrades provides
clear direction to SDG&E on how to implement the upgrades and what the costs are. Therefore,
1. Clarifying the nature and extent of the Coastal link system upgrades; and
2. Determining the proper cost associated with the Coastal link so as to make sure
RPCC will explain in detail below why there are ambiguities existing concerning these
issues and how this Commission can clear up these ambiguities in a final decision.
At page 91 of the GAPD, the GAPD adopts RPCC’s alternative, as defined in RPCC’s
Phase II reply brief. RPCC’s Phase II reply brief describes RPCC’s Coastal link system
upgrades as follows:
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
3. Re-conductor the 69kV circuit of the Sycamore – Scripps transmission line, but
only if this Commission finds it prudent for SDG&E to have cancelled another
4. Either the installation of a 230/138 kV, 392 MVA transformer at Encina, but only
if the CAISO will not approve a remedial action scheme designed to bring up
Recall that SDG&E unilaterally changed the scope of RPCC’s proposed system upgrades
between phase I and phase II when SDG&E updated its power flow topology after phase I. The
updated topology included two projects that had an impact on RPCC’s alternative. One project
eliminated the necessity of re-conductoring the Poway – Pomerado 69 kV transmission line. The
re-conductoring of the Poway - Pomerado line was originally within the scope of RPCC’s Phase
I system upgrades. 1
The second project that had an impact was actually the cancellation of a project that had
been previously approved by the CAISO (a second Sycamore – Miramar 69 kV line). As a result
of this project being cancelled, SDG&E claimed that a new line now overloaded under CAISO
reliability criteria with RPCC’s Coastal link system upgrades (Sycamore – Scripps 69 kV).
Therefore, SDG&E added the Sycamore – Scripps re-conductor into RPCC’s alternative and
1
As a result, the DEIR studied the re-conductoring of this line.
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
took out the Poway – Pomerado line from RPCC’s alternative within Phase II of the Sunrise
hearings. 2
RPCC took issue with SDG&E cancelling the second Sycamore to Miramar 69 kV
project between phase I and phase II, which resulted in a line that was now “chargeable” to the
cost of RPCC’s alternative. That is why RPCC wrote that the Commission should decide
whether it was prudent for SDG&E to have cancelled this project. Now that the GAPD has
adopted RPCC’s transmission system upgrade alternative, the importance of the additional costs
being charged to RPCC versus SDG&E is of no consequence. The analysis shows the Sycamore
– Scripps line needs to be re-conductored. RPCC has never argued the power flow analysis
shows otherwise. However, the background on this issue and the importance of this discussion
will become more evident when the cost of the Sycamore - Scripps line is discussed below.
The portion of RPCC’s alternative that does require further clarification is:
4. Either the installation of a 230/138 kV, 392 MVA transformer at Encina, but only
if the CAISO will not approve a remedial action scheme designed to bring up Encina
This is a $33,834,105 issue to ratepayers, and it is unclear how much attention this
specific issue has been given within the grand scheme of things. SDG&E estimates the cost to
install a new 230/138 kV transformer at Encina to be $33,834,105. 3 On the other hand, the costs
of implementing a remedial action scheme to bring up Encina generation to solve CAISO criteria
violation on the Sycamore – Chicarita 138kV transmission line, are slight. This issue appears
2
See the transcript beginning at p. 4653:7 for the discussion of the changes unilaterally made by SDG&E between
phase I and phase II.
3
See Ex. SD-33C or SD-35, Attachment 3-5.
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
throughout the record and was briefed by RPCC and SDG&E in both Phase I and Phase II. It is
unclear from the GAPD whether the GAPD is adopting the installation of a new transformer.
The GAPD simply states it is adopting RPCC’s Coastal link system upgrades as defined within
RPCC’s phase II Reply brief. However, as to this issue, RPCC left the $33.8 million dollar
decision within the Commission’s hands. At footnote 265, the GAPD references this issue, but
does not otherwise make an explicit decision. Implicitly, the GAPD adopts the installation of a
transformer because the costs associated with RPCC’s alternative ($84 million) include the
installation of the $34 million dollar transformer. RPCC believes the final decision should be
clear on the issue of whether the RPCC system upgrade includes a new transformer at Encina or
not.
Lastly, on the issue of scope, the GAPD at paragraph number one of the Order states that
the CPCN is granted to build the transmission line along the FEIR Superior Southern Route. The
FEIR Superior Southern Route evaluated RPCC’s Coastal link system upgrades, but at some
locations and/or maps within the FEIR, appears to have mistakenly left the Poway – Pomerado
69 kV line in as part of the analysis/description. 4 Because of this oversight, and because the
FEIR does not always consistently describe the Coastal link system upgrades, the a finding of
fact paragraph needs to be added to address any confusion that could come about by simply
relying on the FEIR description of the route as the scope of what SDG&E would be building.
The GAPD uses the Compliance Exhibit at p.9 to calculate the appropriate costs to the
project for the adoption of the Coastal link system upgrades. 5 The $84 million in costs
4
In general, the FEIR is not consistent in describing the scope of the Coastal link system upgrades, but what is clear
is that the analysis of each component of the system upgrades was analyzed.
5
GAPD at p.270, footnote 706.
6
RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
associated with RPCC’s system upgrades was derived from Attachment 3-5 of SDG&E’s Phase
II testimony. The $84 million includes $34 million for the Encina transformer. The $84 million
also includes the costs to re-conductor the Sycamore – Pomerado 69 kV circuits and the costs to
Sycamore Canyon. At issue is the fact that SDG&E dramatically altered the scope of the work
that would be necessary to re-conductor these two lines after the close of Phase II evidence.
Since then, SDG&E has never been forthcoming with the new costs. This issue was briefed
extensively within RPCC’s Phase II reply brief. Most of this briefing is reiterated below because
it is directly on point:
“Not surprisingly, SDG&E spends no time discussing the costs of their proposed
Coastal link as compared to RPCC’s alternative. Within SDG&E’s single paragraph within this
subsection, SDG&E notes that RPCC’s alternative would cost approximately $84 million, per
Exhibit SD-35, Attachment 3-5 to SDG&E’s direct testimony. What SDG&E did not tell this
Commission, or RPCC for that matter, within SDG&E’s Phase II brief, is that SDG&E has
changed the scope of work required for both the Sycamore – Scripps 69 kV re-conductor and the
completed. The changes are so dramatic, that the costs must have also changed dramatically.
SDG&E, however, provides no new costs and fails to even point out this important development
since the close of Phase II hearings, despite providing this information to the Energy Division
Since the cost estimate changes are estimated to be heavily weighted in RPCC’s
favor, the integrity of the information SDG&E has provided within these proceedings continues
to be questionable.
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
these lines are the result of the Energy Division and their consultants inquiring into the unilateral
change to RPCC’s alternative that SDG&E made after the DEIR was released (between Phase I
and Phase II), which added a completely new line to be re-conductored (Sycamore – Scripps 69
kV). The Energy Division sent a data request to SDG&E asking SDG&E to explain the scope of
work necessary for this re-conductor and the reason for changing RPCC’s alternative. The
6
There also appears to be a map(s) showing where the two lines run, produced by SDG&E and/or Aspen, attached
to the response. This map is not included here.
7
The Sycamore – Pomerado 69 kV Circuits 1 and 2 were always a part of RPCC’s alternative and were in fact
analyzed within the DEIR.
8
RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
• At Scripps (remove 1.5 mi of 1750 AL kcmil, install bundled 3000 CU, using existing
ducts and new underground drops).
• At Rue Biarritz (remove 0.2 mi of 1750 AL kcmil, and install bundled 3000 CU in new
trench and change out existing wood cable poles to Steel cable poles).
• At Sycamore Canyon Substation (remove 0.1 mi of 1750 AL kcmil, install bundled 3000
CU).
• A new trench with single 1750 AL kcmil will be installed at Sycamore Canyon Substation
to accommodate a relocation of existing 69kV circuit TL6920.
Upgrades of associated Substation breakers and disconnects would occur within SDG&E’s
Scripps and Sycamore Substation.
The reconductor of the Scripps-Sycamore 69 kV line was identified by SDG&E Transmission
Planning through powerflow analysis performed in support of Phase 2 testimony. See
SDG&E’s March 28, 2008 Rebuttal Testimony, Chapter 6, Footnote 1 and SDG&E’s response
to RPCC data request 17, question 1, subpart (j) for additional details.
RPCC surmises that when the Energy Division saw that the scope of work
necessary for the Sycamore – Pomerado re-conductor had changed dramatically (replacement of
existing poles for new poles) as compared the analysis performed within the DEIR; the scope of
work for the newly added re-conductor of the Sycamore – Scripps line was substantial
(replacement of existing poles for new poles); and given that the Sycamore – Scripps line had not
been analyzed within the DEIR at all, the Energy Division asked SDG&E to take another look at
whether the re-conductor of these lines could be accomplished without the significant impacts of
removing and replacing poles. If this could not be accomplished, SDG&E was potentially facing
9
RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
with a solution that did not require the replacement of poles and merely re-conductored these
lines with a single conductor capable of carrying a higher current, instead of the original Phase II
scope of work which would have installed a bundled conductor (which increases the weight and
therefore effects the carrying capacity of the existing transmission poles). SDG&E then
It is also important to note that SDG&E had changed the scope of work to the
Sycamore – Pomerado circuits between Phase I and Phase II analysis as well. Within Phase I,
SDG&E described the scope of work, within their Phase I cost estimate, as “Reconductor from
from single 1033 kcmil ACSR and single 1750 kcmil AL to single 900 kcmil ACSS and single
3000 kcmil CU. Few pole replacements.” 8 SDG&E then changed this scope of work to bundled
conductor with pole replacements in Phase II, as described above, only to change it back again to
what appears to be the exact same Phase I scope of work (as described within their response on
May 23, 2008). This disturbing fact illustrates that SDG&E appears to have purposely attempted
8
See Exhibit R-4, page 5, bottom row, last column.
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
to make RPCC’s alternative look as expensive as possible in Phase II hearings, while ignoring,
Further, despite providing a new scope of work on May 23, 2008, seven days
before the Phase II Opening Brief was due, SDG&E failed to notify RPCC of this substantial
change and made no mention of it within the Phase II Opening Brief. The magnitude of the
change from a cost estimate standpoint is well over $10 million dollars. RPCC is able to make
an educated estimate at the cost savings because of cost estimate for the same scope of work
$5,900,000. 9 The comparative figure given by SDG&E in Phase II per their Exhibit SD-35,
Attachment 3-5 is $8,963,022. This is over a three million dollar difference for a two mile line
on costs to construct, alone. Add in the 30% contingency applied by SDG&E to this line in
Phase II and you subtract almost another $1 million. Subtract AFUDC and escalation amounts
and you are over $5 million in cost differential for the Sycamore – Pomerado line alone.
Given that the scope of work for the Sycamore – Scripps line is now the same as
the Sycamore – Pomerado line, and given that the Sycamore – Scripps line is approximately five
miles long (2 and ½ times longer than the Sycamore – Pomerado line), one can logically deduce
that the cost savings attributable to not removing and replacing poles for the Sycamore – Scripps
line is going to exceed the $5 million dollar cost savings estimated for the Sycamore – Pomerado
line. Therefore, the total cost savings is likely to be well in excess of $10 million dollars. The
result is that RPCC’s alternative provides even greater cost savings to CAISO ratepayers.” 10
9
See Exhibit R-4, page 5, bottom row, second column.
10
Counsel for RPCC told SDG&E it would be raising this issue within its comments. Therefore, it will be
interesting to see if SDG&E provides comments on this issue.
11
RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
WHY IS THIS IMPORTANT? First, CAISO ratepayers are entitled to accurate cost
estimates and should not have to pay more than what it costs to build this line. Further, this
Interestingly, SDG&E clearly believes that the GAPD does not accurately reflect the
costs of the Coastal link. Debra Reed said as much within her oral argument comments and
SDG&E has since met ex parte with Commissioner Peevey and Bohn staff to explain that the
Coastal link cost estimate associated with SDG&E’s project was estimated to be $33 million too
high within the GAPD, therefore lowering the cost cap on this project. Commissioner Peevey
bought into this argument because his APD reflects a new number associated with SDG&E’s
coastal link ($156 million instead of $189 million). SDG&E, however, does not complain about
the $84 million number associated with the RPCC Coastal link system upgrades, even though
SDG&E knows the costs have changed for the two re-conductorings consistent with the RDEIR
analysis above. SDG&E, where are the new cost estimates for these two lines? Why hasn’t
SDG&E been forthcoming with this information? This is what this Commission should be
asking SDG&E, especially in light of the fact that SDG&E thinks the GAPD otherwise applies
RPCC will await SDG&E’s comments on their reasoning behind why a $156 million
dollar figure is the proper estimate as compared to the $189 million dollar estimate the GAPD
adopted and will address the accuracy of SDG&E’s assertions within RPCC’s reply comments.
IV. CONCLUSION
Due to SDG&E’s unilateral decision to change RPCC’s alternative between phase I and
phase II, there appears to have been some confusion within the FEIR in describing the scope of
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
RPCC’s alternative. A finding of fact paragraph can adequately address the ambiguity by
finding that the Poway – Pomerado line is not a part of the Coastal link system upgrades.
The discussion within the decision itself concerning the Encina transformer should clarify
whether the decision incorporates the 230/138 kV transformer at Encina or not as part of the
SDG&E should be ordered to provide an updated cost estimate for the re-conductoring of
the Sycamore – Pomerado circuits and the Sycamore – Scripps circuit. This Commission should
also analyze whether a $156 million dollar estimate is the most recent, accurate estimate for
SDG&E’s projected cost of their Coastal link portion of the project so as to accurately come up
/s/Harvey M. Payne
Rancho Penasquitos Concerned Citizens
By: Harvey M. Payne
13
RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
FINDINGS OF FACT:
The Final EIR/EIS Superior Southern Route does not include, as part of the Coastal link
system upgrades, a re-conductoring of the Poway – Pomerado 69 kV transmission line.
FINDINGS OF LAW:
None
14
RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
CERTIFICATE OF SERVICE
I, Harvey M. Payne, hereby certify that I have this day served a copy of:
on all known parties with an e-mail address on the service list in proceeding A.06-08-010, by
electronic mail, consistent with the attached list of e-mail addresses. I also caused the above
described document to be filed electronically with the Commission and mailed copies to
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
Podgorsky@wrightlaw.com,
thompson@wrightlaw.com,
ssiegel@biologicaldiversity.org,
ssiegel@biologicaldiversity.org,
sara@calparks.org,
nwhang@manatt.com,
sptp@msk.com,
thomas.burhenn@sce.com,
dwood8@cox.net,
dlindsay@sunbeltpub.com,
mwells@parks.ca.gov,
scotmartin478@msn.com,
david.lloyd@nrgenergy.com,
conniebull@cox.net,
dj0conklin@earthlink.net,
edwrdsgrfx@aol.com,
pwhalen2@cox.net,
oakhollowranch@wildblue.net,
jhfark@pacbell.net,
denis@vitalityweb.com,
hikermomma1@yahoo.com,
gbarnes@sempra.com,
fortlieb@sandiego.gov,
jwalsh@sempra.com,
mcalabrese@sandiego.gov,
shawn.hagerty@bbklaw.com,
liddell@energyattorney.com,
mshames@ucan.org,
cadowney@san.rr.com,
ko'beirne@semprautilities.com,
hpayne3@gmail.com,
kritchey@san.rr.com,
jleslie@luce.com,
dhogan@biologicaldiversity.org,
sjkeene@iid.com,
barbschnier@yahoo.com,
AirSpecial@aol.com,
wblattner@semprautilities.com,
mflorio@turn.org,
wolff@smwlaw.com,
map@cpuc.ca.gov,
ttf@cpuc.ca.gov,
norman.furuta@navy.mil,
bpowers@powersengineering.com,
jaugustine@biologicaldiversity.org,
rcox@pacificenvironment.org,
bcragg@goodinmacbride.com,
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
richard.raushenbush@lw.com,
vprabhakaran@goodinmacbride.com,
jeffgray@dwt.com,
dietrichlaw2@earthlink.net,
dkates@sonic.net,
jsanders@caiso.com,
jdh@eslawfirm.com,
btorgan@parks.ca.gov,
ktobias@parks.ca.gov,
steven@iepa.com,
kmills@cfbf.com,
elizabeth.klein@lw.com,
janice.schneider@lw.com,
julie.greenisen@lw.com,
michael.gergen@lw.com,
kelly@kellyfuller.net,
Henry.Martinez@ladwp.com,
randy.howard@ladwp.com,
cfaber@semprautilities.com,
rkeen@manatt.com,
Case.Admin@sce.com,
darell.holmes@sce.com,
margandona@calwild.org,
donnatisdale@hughes.net,
mjumper@sdihf.org,
rebeccap@environmentalhealth.org,
ddowney@nctimes.com,
jharry.jones@uniontrib.com,
patricia_fallon@sbcglobal.net,
dandbcarey@julianweb.com,
celloinpines@sbcglobal.net,
vmp@sbcglobal.net,
skyword@sbcglobal.net,
colobiker@gmail.com,
nparinello@gmail.com,
cpuc@92036.com,
dwvoss@cox.net,
WSK@astro.caltech.edu,
carolyn.dorroh@cubic.com,
jwmitchell@mbartek.com,
jwmitchell@mbartek.com,
soliviasmom@gmail.com,
oldjulianco@integrity.com,
wolfmates@cox.net,
Csmmarket@aol.com,
joe@ranchitarealty.com,
cesposit@sdcoe.k12.ca.us,
bgendron@nethere.com,
kimmerlys@yahoo.com,
gedrown@mindspring.com,
gecko_greens@juno.com,
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
Reneeandbear@aol.com,
dan@energysmarthomes.net,
deanna.spehn@sen.ca.gov,
sfr@sandag.org,
jason.ohta@lw.com,
patricia.guerrero@lw.com,
sierraclubintern@yahoo.com,
mmitrosky@sierraclubsandiego.org,
kmkiener@cox.net,
jimbellelsi@cox.net,
srogers647@aol.com,
usdepic@gmail.com,
bruce.bigelow@uniontrib.com,
onell.soto@uniontrib.com,
gcourser@hotmail.com,
centralfiles@semprautilities.com,
Irene.stillings@energycenter.org,
jennifer.porter@energycenter.org,
sabrina.ozturk@sdcounty.ca.gov,
sephra.ninow@energycenter.org,
tblair@sandiego.gov,
Dahvia.Lynch@sdcounty.ca.gov,
jfirooz@iesnet.com,
sanrocky@aol.com,
Thomas_Zale@blm.gov,
up@undergroundpower.us,
c@californiabotanicalhabitat.com,
swilson@pcta.org,
Lnastro@parks.ca.gov,
bruce.foster@sce.com,
Diane.Fellman@fpl.com,
wolff@smwlaw.com,
rcox@pacificenvironment.org,
bbirdsall@aspeneg.com,
dtk5@pge.com,
jay2@pge.com,
kmsn@pge.com,
mspe@pge.com,
placourciere@thelenreid.com,
Cassandra.sweet@dowjones.com,
dhuard@manatt.com,
jwoodruff@nextlightrp.com,
jfieber@flk.com,
cem@newsdata.com,
regrelcpuccases@pge.com,
robin.harrington@fire.ca.gov,
joe.paul@dynegy.com,
hzaininger@aol.com,
phil@auclairconsulting.com,
editorial@californiaenergycircuit.net,
mrw@mrwassoc.com,
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RPCC Comments to Alternative A.06-08-010
Proposed Decision (Grueneich)
dmarcus2@sbcglobal.net,
sweissman@law.berkeley.edu,
bjolley@herumcrabtree.com,
kent@wkpalmerton.com,
ziad@zglobal.biz,
e-recipient@caiso.com,
david@branchcomb.com,
PGS@IEEE.org,
lonwhouse@waterandenergyconsulting.com,
ddfreeman@yahoo.com,
abb@eslawfirm.com,
Audra.Hartmann@Dynegy.com,
Darren.Boutton@gov.ca.gov,
jreede@energy.state.ca.us,
KMCDO@parks.ca.gov,
kellie.smith@sen.ca.gov,
kdw@woodruff-expert-services.com,
rlauckhart@globalenergy.com,
alan.comnes@nrgenergy.com,
daniel@wildroseenergy.com,
mrx@cpuc.ca.gov,
bcb@cpuc.ca.gov,
dhn@cpuc.ca.gov,
dsh@cpuc.ca.gov,
gxh@cpuc.ca.gov,
hmm@cpuc.ca.gov,
jjj@cpuc.ca.gov,
xjv@cpuc.ca.gov,
jlo@cpuc.ca.gov,
jmh@cpuc.ca.gov,
kwh@cpuc.ca.gov,
lau@cpuc.ca.gov,
ljw@cpuc.ca.gov,
mjd@cpuc.ca.gov,
nms@cpuc.ca.gov,
rae@cpuc.ca.gov,
rwh@cpuc.ca.gov,
wsc@cpuc.ca.gov,
sjl@cpuc.ca.gov,
saw@cpuc.ca.gov,
tdp@cpuc.ca.gov,
tbo@cpuc.ca.gov,
slee@aspeneg.com,
Claufenb@energy.state.ca.us,
darren.bouton@gov.ca.gov,
mpryor@energy.state.ca.us,
prichins@energy.state.ca.us,
trf@cpuc.ca.gov,
jgrau@energy.state.ca.us,
tmurphy@aspeneg.com,
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