UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Southern California Edison Company ) Docket Nos. ER11-2204-000
California Independent System Operator ) Docket Nos. ER11-2318-000
SOUTHERN CALIFORNIA EDISON COMPANY’S
OPPOSITION TO MOTIONS TO CONSOLIDATE
Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (“FERC”
or the “Commission”) Rules of Practice and Procedure, 18 C.F.R. §§385.212 & 385.213 (2009),
Southern California Edison Company (“SCE”) requests leave to submit this Opposition to the
multiple Motions to Consolidate that have been filed in the above captioned Dockets.
Specifically, the Sacramento Municipal Utility District (“SMUD”), Transmission Agency of
Northern California (“TANC”), California Municipal Utilities Association (“CMUA”), the Cities
of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, CA (“Six Cities”), each
individually filed Motions to Consolidate (“Motions to Consolidate”). The above dockets relate
to Large Generator Interconnection Agreements (“LGIA”) by and among various
Interconnection Customers, SCE, and the California Independent System Operator Corporation
(“CAISO”). Docket EL11-10-000 represents SCE’s Petition for Declaratory Order for
Transmission Incentives (“Incentives Petition”) in relation to certain transmission projects for
which Network Upgrades to SCE’s transmission system are needed in order to reliably
interconnect renewable generation.
As described below, it is inappropriate to consolidate these dockets as it would cause
unnecessary delay in the approval of the LGIAs, as each LGIA presents unique issues for
consideration. Further, SCE’s Incentives Petition involves issues that are well beyond the scope
of any individual LGIA.
I. OPPOSITION TO MOTIONS TO CONSOLIDATE
A. Background and Summary
On November 23, 2010, SCE filed the Granite Mountain LGIA with the Commission,
requesting Commission acceptance of the LGIA in Docket No. ER11-2177. On November 30,
2010, SCE filed the Mojave Solar Project LGIA in Docket No. ER11-2204. On December 8,
2010, SCE filed the Blythe Solar Power Project LGIA in Docket No. ER11-2316. On December
9, 2010 SCE filed the Coram Brodie Wind Project LGIA in Docket No. ER11-2322. On
December 20, 2010, SCE filed the AV Solar Ranch One Project LGIA in Docket No. ER11-
2411. On December 21, 2010, SCE filed the Palen Solar Power Project in Docket No. ER11-
2455. Docket Nos. ER11-2318-000, ER11-2368-000 and ER11-2369-000 consist of the
CAISO’s filings of the same LGIAs. SCE and the CAISO are required to each individually file
these LGIAs because they are nonconforming agreements.
These LGIAs provide for the interconnection of proposed generating facilities to the SCE
transmission system. Each LGIA represents unique facts, circumstances, in-service date and
costs to interconnect the respective generating facility.
On December 10, 2010, SCE filed its Incentives Petition requesting 100% abandoned
plant cost recovery if any of the transmission projects described in the Incentives Petition had to
be abandoned for reasons outside of SCE’s control, as well as Construction Work in Progress
and confirmation that the transmission projects are network facilities.
The transmission projects in the Incentives Petition are triggered, in part, by the LGIAs
listed above, with the exception of the Coram Brodie Wind Project LGIA that did not trigger any
of the transmission facilities in the Incentives Petition.1
B. Consolidation Will Lead to Unnecessary Delay for Approval of the Needed
The Motions to Consolidate argue that there are common questions of law and fact and
that consolidation would promote administrative efficiency.2 However, as discussed below, the
Commission will not consolidate if such consolidation would not serve a useful purpose or if it
would cause unnecessary delay. United Gas Pipe Line Co., 34 FERC ¶ 61,282 (1986). Further,
the Commission has found that even though there may be elements that are similar within the
proceedings in the consolidation request, they must be examined independently and
consolidation is not appropriate as a result. Cimarron River Pipeline LLC and Northern Natural
Gas Co., 124 FERC ¶61,069 (2010).
In the dockets listed in the Motions to Consolidate, each LGIA encompasses different
issues that need to be examined. As a starting point, each LGIA involves facilities that are
needed in order to interconnect the generating facilities (both Network Upgrades and
Interconnection Facilities). The Incentives Petition revolves around the ratemaking treatment for
the Network Upgrades. The issues are separate and distinct from one another. Moreover, the
1 The Coram Brodie Wind Project LGIA references the facilities that are part of SCE’s Tehachapi Project,
which received incentive rate treatment in Docket No. EL07-62-000.
2 See, e.g. CMUA Motion to Consolidate at 3.
Coram Brodie Wind LGIA does not even involve transmission facilities that are part of SCE’s
Incentives Petition. While SCE understands (with the exception of the Coram Brodie Wind
LGIA) that there are some common issues as a result of SCE’s agreeing to finance the Network
Upgrades contingent upon SCE’s receipt of 100% abandoned plant cost recovery in its
Incentives Petition, there are significant other issues in the Incentives Petition unrelated to the
LGIAs. Similarly, each LGIA may have issues that are unrelated to either the Incentives Petition
or the other LGIAs.
Most importantly, consolidation of these dockets would inevitably lead to a delay in
approval of the LGIAs. As noted above, the first LGIA was filed on November 30, 2010 and
comments were due on that LGIA on December 14, 2010. In contrast, SCE filed its Incentives
Petition on December 10, 2010 and comments are not due until January 10, 2011. Most of these
LGIAs are related to generating projects that have received funds under the American
Reinvestment and Recovery Act (“ARRA”). As the Commission is aware, there are strict ARRA
deadlines that apply to these generation projects and the Interconnection Customers need
certainty as to whether they have an approved LGIA within the timeframes requested in the
LGIA filing letters.
Finally, the Commission has already approved LGIAs with similar terms and conditions
during the pendency of an incentive ratemaking petition.3 In those cases, the Commission was
able either to approve or conditionally approve the LGIAs separately and without consolidating
the LGIAs with the incentive ratemaking petitions.4 Similar to those proceedings, the
3 See, e.g., Southern California Edison Company, 132 FERC 61, 150(2010) (Order Approving LGIA with
Brightsource Energy), Southern California Edison Company 133 FERC 61,019 (2010), Southern California Edison
Company 133 FERC 61,200 (2010), Southern California Edison Co., 133 FERC ¶ 61,108 (2010) (granting 100%
abandoned plant and Construction Work In Progress for the Eldorado-Ivanpah Transmission Project) and Southern
California Edison Co., 133 FERC ¶ 61,107 (2010) (granting 100% abandoned plant and CWIP for both Lugo-
Pisgah and Red Bluff).
Commission here should maintain approval of the LGIAs as separate and distinct from the
For the reasons provided above, SCE requests that the Commission deny the Motions to
REBECCA A. FURMAN
ROBERT J. SAMUELS
By: Rebecca A. Furman
SOUTHERN CALIFORNIA EDISON COMPANY
January 5, 2011
CERTIFICATE OF SERVICE
I hereby certify that in accordance with Rule 2010 of the Commission’s Rules of
Practice and Procedure, I have, this day, served a copy of the foregoing document, on all persons
designated on the official service list compiled by the Secretary in this proceeding.
Dated at Rosemead, CA, this 5th day of January, 2011.
Southern California Edison Company
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, CA 91770