BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF … · 2015-06-18 ·...

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 West of Devers Upgrade Project and for an Interim Decision Approving the Proposed Transaction Between Southern California Edison and Morongo Transmission LLC

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A.13-10-020

(Filed October 25, 2013)

JOINT NOTICE OF EX PARTE COMMUNICATION OF

SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E)

AND MORONGO TRANSMISSION LLC

NANCY SARACINO Attorney for

MORONGO TRANSMISSION LLC Crowell & Moring LLP 275 Battery Street, 23rd Floor San Francisco, California 94111 Telephone: (415) 365-7433 Facsimile: (916) 990-8386 E-Mail: [email protected]

LAURA B. RENGER Attorney for

SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6984 Facsimile: (626) 302-1926 E-mail: [email protected]

Dated: June 16, 2015

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STATE OF CALIFORNIA


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A.13-10-020


JOINT NOTICE OF EX PARTE COMMUNICATION OF

SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E)

AND MORONGO TRANSMISSION LLC

Pursuant to Rule 8.4 of the Rules of Practice and Procedure of the California Public

Utilities Commission (“Commission” or “CPUC”), Southern California Edison Company

(“SCE”) and Morongo Transmission LLC hereby give notice of the following ex parte

communication.

On June 15, 2015 at approximately 1:30 p.m., SCE's Director of CPUC Regulatory

Affairs, Laura Genao, and SCE’s Principal Manager of Regulatory Policy and Affairs, Ryan

Stevenson, met with Rachel Peterson, Chief of Staff to CPUC Commissioner Randolph about

SCE’s Proposed West of Devers Upgrade Project (“West of Devers”). Also present from

Morongo Transmission LLC were Tom Tureen, Chair of Coachella Partners, and Roger Meyer,

CEO of the Morongo Band of Mission Indians. Mary Jo Borak and Billie Blanchard from the

CPUC were also in attendance. The meeting was held at the request of SCE and lasted

approximately sixty-five minutes. During the meeting, SCE presented an overview of its current

CPCN application for West of Devers. SCE also presented an overview of the project and project

schedule, and SCE and Morongo Transmission discussed agreements between SCE and

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Morongo Transmission LLC and the Morongo Band of Mission Indians. SCE shared the

presentation attached hereto as Exhibit A.

To receive a copy of this ex parte notice, please contact:

Case Administration Southern California Edison Company P.O. Box 800 Rosemead, California 91770 Email: [email protected] Facsimile: (626) 302-6962 Telephone: (626) 302-3062

Respectfully submitted on this 16th day of June, 2015, in Rosemead, California.

NANCY SARACINO

/s/ Nancy Saracino By: Nancy Saracino

Attorney for: MORONGO TRANSMISSION LLC Crowell & Moring LLP 275 Battery Street, 23rd Floor San Francisco, California 94111 Telephone: (415) 365-7433 Facsimile: (916) 990-8386 E-Mail: [email protected]

LAURA B. RENGER

/s/ Laura B. Renger By: Laura B. Renger

Attorney for: SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6984 Facsimile: (626) 302-1926 E-mail: [email protected]

EXHIBIT A

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Confidential SOUTHERN CALIFORNIA EDISON®SOUTHERN CALIFORNIA EDISON®

West of Devers Upgrade Project

Briefing Document

June 2015

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Overview West of Devers (WOD) system currently consists of five 220 kV lines built

between 1945 -1975, a portion of which crosses the Morongo Indian Reservation trust lands

CAISO determined that existing WOD 220 kV lines will not accommodate full deliverability of additional generation interconnections

Proposed Project will tear down the existing transmission facilities and construct new, higher capacity 220 kV structures and lines in the existing ~48 mile WOD corridor and provide 3,200 MW of additional transfer capability

New SCE-Morongo ROW Agreement permits SCE to operate the existing facilities and allows for the Proposed Project to be built across the Morongo Reservation

Development and Coordination Agreement (DCA) provides Morongo Transmission with an option to invest up to $400 million to lease a portion of the transfer capability in the Proposed Project’s transmission upgrades

Proposed Project is the most feasible, least-cost and less environmentally impactful option

CPUC – CEQA Lead Agency; BLM – NEPA Lead Agency; BIA – NEPA Cooperating Agency

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Project Map

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Current WOD Scope (Proposed Project): Transmission: Tear down and rebuild ~181 circuit miles of existing 220 kV T/L facilities (~ 48 corridor miles), including seven 220 kV lines: Devers-Vista #1 and #2, Devers-San Bernardino #1, Devers-El Casco, El Casco-San Bernardino , and portions of San Bernardino-Vista and San Bernardino-EtiwandaOther: Upgrade telecom, substations, and property rights along existing WOD corridorMorongo: New “southern” WOD 220 kV corridor per Morongo ROW Agreement

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Purpose and Need Existing facilities in the WOD corridor are fully subscribed

Proposed Project will increase transfer capability from 1,600 MW to 4,800 MW

CAISO 2010 Studies identified that the WOD Upgrade Project was required for renewable resources in eastern Riverside County to achieve Full Capacity Deliverability Status Facilitates permanent full deliverability of new renewable generation being developed in eastern

Riverside County 2,460 MW requesting interconnection for the Blythe and Desert Center Areas

Provide sufficient downstream transfer capability to enable the CAISO to increase the Maximum Import Capability from the Imperial Irrigation District’s (IID) area Supports increased power flows from Path 42 (IID) 2,044 MW in IID Queue

Comply with executed Generation Interconnection Agreements, signed Purchase Power Agreements, and NERC and WECC transmission reliability planning criteria

Facilitate compliance with CA Renewable Portfolio Standard (RPS) goals by 2020 Support CA GHG Reduction program, Federal energy renewable goals, Desert

Renewable Energy Conservation Plan and CA Energy Commission Integrated Energy Policy Report goals

Support power flow increase associated with the proposed Delaney-Colorado River 500 kV project

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SCE-Morongo Agreements ROW

– 50-year Grant of Easement between SCE and Morongo for existing and upgraded electric/telecommunication facilities

– $6.5M per year, $500K increase every 5 years – DOI Approved in Dec. 2013– Subject to termination by Morongo Tribe if Proposed Transaction is not approved by FERC and

CPUC

DCA – Provides Morongo Transmission with an option to lease a portion of the transfer capability of the

WOD Upgrade Project’s transmission facilities– Investment option up to $400 million– Transmission Lease option comes available at time of commercial operation (2020)– Morongo Transmission to become Participating Transmission Owner (PTO) and dedicate transfer

capability to CAISO– FERC approved joint 203 application in Sept. 2013– FERC approved Morongo Transmission’s hypothetical capital structure and 30-year levelized fixed

rate of recovery of capital requirements request in Aug. 2014

Lease– 30-year lease– SCE owns and maintains the assets– Morongo Transmission to pay its proportionate share of operating costs

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Transmission Rights Upon execution of the Lease, Morongo Transmission will be entitled to its share of the

transfer capability in the Transmission facilities for 30 years– Transfer capability share is based on the ratio of Morongo Transmission’s investment to the total

Transmission capital costs

DCA requires Morongo Transmission to become a PTO under the CAISO tariff and turn over to the CAISO operational control of its transfer capability share

– Should Morongo Transmission not execute the lease, cease to be a PTO, or upon breach of its obligations, Morongo Transmission’s entitlement in the Transmission facilities will revert back to SCE

– ROW Agreement would remain in effect should any of the above actions occur

At conclusion of the Lease, Morongo Transmission’s transfer capability share will revert back to SCE

CAISO operation of SCE’s and Morongo Transmission’s shares of the transfer capability will be seamless, given that CAISO will ensure comparable and non-discriminatory access to the Transmission Facilities for all generators and power sellers

Entire transfer capability of the Transmission facilities will be under the operational control of CAISO and available to customers within the balancing authority of the CAISO

– If SCE ceases its participation in the CASIO, Morongo Transmission will assign to SCE (or whatever entity has operational control over SCE’s transmission system) operational control over their transfer capability share

SCE will also be the interconnection agent on behalf of Morongo Transmission for all requests for generator interconnection to the Transmission facilities

– SCE will retain all ownership and transfer capability interests in all interconnection facilities and network upgrades

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Completed Milestones:– Oct. 2013 – CPCN Application Filed at CPUC– March 2014 – Plan of Development (POD) submitted to BLM– July 2014 – CPUC and BLM Scoping processes completed– Aug 2014 – Refined Engineering completed– March 2015 – CPCN Pre-hearing Conference completed

Upcoming Milestones:– Q2/Q3 2015 – Draft EIR/EIS Issued– Q3 2015 – Final EIR/EIS Issued– Q4 2015 – Biological Opinion Issued– Q4 2015 – CPUC CPCN Decision Issued– Q1 2016 – BLM ROD Issued– Q2 2016 – Construction Start– Q4 2020 – In-Service

Timely Regulatory Approvals:– Issuance of Draft EIR/EIS has been delayed (July 2015)– Targeted CPCN by Q4 2015 and ROD by Q1 2016 are at risk given delays in Draft EIR/EIS, which is

a critical-path milestone– Obtaining a CPCN in 2015 and the ROD shortly thereafter are critical to meet the Proposed Project’s

2020 in-service date

Milestone Status

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Financial Comparison

Nominal dollars, in Millions

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Major Scope ItemProposed Project

4,800 MW

System Alternative Project(Bypass Morongo Reservation)

3,600 MWTransmission (>200kV) ‐ Tear down and rebuild ~48

corridor miles (~181 circuit miles) of existing 220 kV T/L

‐ Tear down and rebuild ~15 corridor miles (~63 circuit miles) of existing 220 kV T/L

‐ Build ~7 corridor miles (~28 circuit miles) of new 220 kV T/L in new ROW‐ Build ~29 corridor miles (~34 circuit miles) of new 500 kV T/L in mostly new ROW (~5 miles in existing ROW)

Substation ‐ Upgrade existing substations ‐ Upgrade existing substations‐ Construct new 500/220 kV substation with 550 MVAR SVC (acquisition of ~100 acres for substation site)

In Service Date 2020 2023Other ‐ Based on Preliminary Design ‐ Based on Conceptual Design

Present Value of Revenue Requirements (PVRR)

$999 $1,397

PVRR / MW $0.21 $0.39

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Timeline

2013 2014 2015 20192018

[July 2014]CPUC/BLM

Scoping Process

[Oct. 2013]CPCN filed

[Q4 2015]CPUC

Approves CPCN

[Q2 2016]Start

Construction

[Q4 2020]Construction Completion

Timely Processing of Regulatory Approvals are Critical to Meeting the State’s RPS Goals

2017 2020

[Q3 2015]Final

EIR/EIS

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[Nov. 2012]ROW

Agreement & DCA Signed

[March 2014]POD filed [Q2/Q3 2015]

Draft EIR/EIS

[Q4 2015] BO

2016

[Q1 2016]BLM issues

ROD


STATE OF CALIFORNIA


A.13-10-020


CERTIFICATE OF SERVICE

I hereby certify that I have this day served a copy of JOINT NOTICE OF EX PARTE COMMUNICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E)AND MORONGO TRANSMISSION LLC on all known parties to A.13-10-020 to each person named in the official service list by:

[X] Transmitting the copies via e-mail to all parties who have provided an e-mail address

[X] Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s).

ALJ Hallie Yacknin CPUC505 Van Ness Avenue San Francisco, CA 94102

Executed this June 1 , 2015 at Rosemead, CA.

/s/, Project Analyst

SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

PROCEEDING: A1310020 - EDISON - FOR A CERT FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: JUNE 16, 2015

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LAURA RENGER CLEVELAND LEEATTORNEY CALIF PUBLIC UTILITIES COMMISSIONSOUTHERN CALIFORNIA EDISON COMPANY LEGAL DIVISION2244 WALNUT GROVE AVE., PO BOX 800 ROOM 5122ROSEMEAD, CA 91770 505 VAN NESS AVENUEFOR: SOUTHERN CALIFORNIA EDISON COMPANY SAN FRANCISCO, CA 94102-3214

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RACHEL GOLD UDI HELMANPOLICY DIRECTOR HELMAN ANALYTICSLARGE-SCALE SOLAR ASSOCIATION EMAIL ONLYEMAIL ONLY EMAIL ONLY, CA 00000EMAIL ONLY, CA 00000

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RESEARCH SR. ATTORNEYMORGAN STANLEY NEXTERA ENERGY REOSURCES, LLC1585 BROADWAY, 38TH FLOOR 700 UNIVERSE BLVD., LAW/JBNEW YORK, NY 10036 JUNO BEACH, CA 33408

LUIS ALBERTO GARCIA ALONSO JEFF SALAZARABENGOA SOLAR LLC SOUTHERN CALIFORNIA GAS COMPANY1250 SIMMS ST., UNIT 101 555 W. FIFTH STREET, GT14D6LAKEWOOD, CO 80401 LOS ANGELES, CA 90013

STEVEN HRUBY CASE ADMINISTRATIONSOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA EDISON COMPANY555 W. FIFTH ST., GT14D6 2244 WALNUT GROVE AVENUE / PO BOX 800 LOS ANGELES, CA 90013 ROSEMEAD, CA 91770

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NANCY SARACINO CALIFORNIA ENERGY MARKETSCROWELL & MORING 425 DIVISADERO ST STE 303275 BATTERY STREET, 23RD FLOOR SAN FRANCISCO, CA 94117-2242SAN FRANCISCO, CA 94111

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