Document Sample
					                         UNITED STATES OF AMERICA
                                BEFORE THE

Southern California Edison Company              )                 Docket Nos. ER11-2204-000
                                                )                             ER11-2316-000
                                                )                             ER11-2177-000
                                                )                             ER11-2411-000
                                                )                             ER11-2322-000
                                                )                             EL11-10-000
California Independent System Operator          )                 Docket Nos. ER11-2318-000
Corporation                                     )
                                                )                               ER11-2368-000
                                                )                               ER11-2369-000


       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.


       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).
4        Id.

Commission here should maintain approval of the LGIAs as separate and distinct from the

Incentives Petition.


       For the reasons provided above, SCE requests that the Commission deny the Motions to


                                    Respectfully submitted,

                                    REBECCA A. FURMAN
                                    ROBERT J. SAMUELS

                                    By:   Rebecca A. Furman

                                    Attorneys for
                                    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.

                                          Michal Odorczuk
                                          Southern California Edison Company
                                          2244 Walnut Grove Avenue
                                          Post Office Box 800
                                          Rosemead, CA 91770