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SDG_Es 040408 Responses to CBD-SC - San Diego Gas _ Electric

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					                            SUNRISE POWERLINK A.06-08-010
                              SDG&E’S 4/4/08 RESPONSE TO
                               CBD-SC DATA REQUEST #1

                   BEFORE THE PUBLIC UTILITIES COMMISSION
                        OF THE STATE OF CALIFORNIA



In the Matter of the Application of San              Application No. A- 06-08-010
Diego Gas & Electric Company (U-902-E)
for a Certificate of Public Convenience and
Necessity For the Sunrise Powerlink
Transmission Project




 SAN DIEGO GAS AND ELECTRIC COMPANY’S OBJECTIONS AND RESPONSES
    TO THE CENTER FOR BIOLOGICAL DIVERSITY AND SIERRA CLUB’S
 MARCH 26, 2008 DATA REQUESTS TO SAN DIEGO GAS & ELECTRIC COMPANY



                                              E. Gregory Barnes
                                              James F. Walsh
                                              SAN DIEGO GAS & ELECTRIC
                                              COMPANY
                                              101 Ash Street
                                              San Diego, CA 92101
                                              Telephone: (619) 699-5019
                                              Facsimile: (619) 699-5027
                                              E-mail: gbarnes@sempra.com


                                              Richard W. Raushenbush
                                              Janice M. Schneider
                                              Jason M. Ohta
                                              LATHAM & WATKINS
                                              505 Montgomery Street, Suite 1900
                                              San Francisco, CA 94111
                                              Telephone: (415) 391-0600
                                              Facsimile:    (415) 395-8095
                                              E-mail: richard.raushenbush@lw.com
                                              Attorneys for Applicant
                                              SAN DIEGO GAS AND ELECTRIC
                                              COMPANY




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SDG&E’S OBJECTIONS AND RESPONSES TO CBD’S MARCH 26, 2008 DATA
REQUESTS

DATA REQUEST NO. 1

Please identify the SDG&E witness in Phase II that is qualified to respond to questions about the
environmental policies of SDG&E.


OBJECTION AND RESPONSE TO DATA REQUEST NO. 1

SDG&E objects to this data request. CBD’s request is vague, ambiguous and overbroad in its
reference to “environmental policies.” Furthermore, the information sought here is beyond the
scope of Phase 2 proceedings as defined by ALJ Weissman’s December 11, 2007 scheduling
order (“Order”). Specifically, ALJ Weissman identified specific areas of testimony appropriate
for Phase 2 proceedings, which are:
        1.    A comparison of different modeling efforts, and economic and reliability analyses
as informed by the proposed alternatives and mitigation measures in the draft EIR/EIS;

        2.    Cost-benefit analyses of the proposed project and project alternatives as informed
by the proposed alternatives and mitigation measures in the draft EIR/EIS, and by different
modeling efforts;

       3.      Material factual inaccuracies or deficiencies in the draft EIR/EIS;

      4.      The effect of project alternatives on system reliability and the ability to deliver
renewable energy to SDG&E customers;

       5.      The adequacy of SDG&E’s Electromagnetic Field mitigation plan; and

       6.      The project cost cap.

Order at 1-2. After analyzing CBD’s data request, SDG&E believes it does not seek information
relevant to the above-identified specific areas of examination for Phase 2 proceedings.

Without waiving its objections, SDG&E responds as follows: SDG&E has not presented Phase 2
direct testimony on its “environmental policies” generally and thus no witness is prepared to
testify generally about SDG&E’s “environmental policies.”




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                               SDG&E’S 4/4/08 RESPONSE TO
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DATA REQUEST NO. 2

Please provide all documents and data documenting and/or discussing:

   a) wildlife electrocutions on SDG&E power lines and associated infrastructure;

   b) avian collisions into SDG&E power lines and associated infrastructure; and

   c) All other wildlife injuries or deaths associated with the construction, operation, and
      maintenance of SDG&E owned or operated power lines.

This request is not limited to incidents that led to fires or power outages. Please include
locations and dates for each incident documented in this request, the species name, and how the
death or injury was discovered.


OBJECTION AND RESPONSE TO DATA REQUEST NO. 2

SDG&E objects to this data request. CBD’s request is irrelevant, unduly burdensome and
overbroad in its reference to “power lines.” CBD’s request does not differentiate between
Sunrise specific issues (e.g., high voltage transmission lines, proposed locations identified in the
DEIR, etc.) and all “power lines.” Furthermore, the information sought here is beyond the scope
of Phase 2 proceedings as defined by ALJ Weissman’s December 11, 2007 scheduling order
(“Order”). Specifically, ALJ Weissman identified specific areas of testimony appropriate for
Phase 2 proceedings, which are:

        1.    A comparison of different modeling efforts, and economic and reliability analyses
as informed by the proposed alternatives and mitigation measures in the draft EIR/EIS;

        2.    Cost-benefit analyses of the proposed project and project alternatives as informed
by the proposed alternatives and mitigation measures in the draft EIR/EIS, and by different
modeling efforts;

       3.      Material factual inaccuracies or deficiencies in the draft EIR/EIS;

      4.      The effect of project alternatives on system reliability and the ability to deliver
renewable energy to SDG&E customers;

       5.      The adequacy of SDG&E’s Electromagnetic Field mitigation plan; and

       6.      The project cost cap.

Order at 1-2. After analyzing CBD’s data request, SDG&E believes it does not seek information
relevant to the above-identified specific areas of examination for Phase 2 proceedings.

Without waiving its objections, SDG&E responds as follows: The documents provided were
compiled from SDG&E’s database regarding reported electric transmission and distribution line
outages from 2003-2007. These reports attempt to assign a cause to the outage and may note the
presence of a bird nest or possibly a dead animal carcass in the vicinity of the noted problem.
Since not all outages involve wildlife fatalities or electrocutions, nor all wildlife contacts cause


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                                SDG&E’S 4/4/08 RESPONSE TO
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an outage, these records are compared to Avian Mortality Forms completed by a “troubleman”
investigating the incident. The resulting comparative information provides the most accurate
accounting of wildlife mortality caused by contact or collision with an SDG&E facility. This
information is further refined by dividing it into distribution and transmission related fatalities.
SDG&E maintains these records in the ordinary course of business for 5 years.




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DATA REQUEST NO. 3

Please provide the following documents cited on Dr. Ramey’s CV in the witness identification
package presented by SDG&E on March 20, 2006:

Andaloro and Ramey (1981). “The relocation of Bighorn Sheep in the Sierra Nevada Mountains
of California.” Environmental Field Program Publication #7, UC Santa Cruz.

Ramey (2002) The science and adventure of bighorn conservation. Museum Monthly 3(7):1-2.


RESPONSE TO DATA REQUEST NO. 3

SDG&E has electronically provided the documents requested above.




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DATA REQUEST NO. 4

Please provide the following documents cited on Dr. Newman’s CV in the witness identification
package presented by SDG&E on March 20, 2006:

   a. Newman, J, C. Sutter, D. Perri, and M. Morgante. 2005. Quantitative Risk Assessments
      for Proposed Wind Turbine Projects: Utilization and Avoidance/Mortality Model. In
      Proceedings of the Onshore Wildlife Interactions with Wind Developments: Research
      Meeting V. Lansdowne, VA November 3- 4, 2004. Prepared for the Wildlife
      Subcommittee of the National Wind Coordinating Committee by RESOLVE, Inc.,
      Washington, DC, Susan Savitt Schwartz, ed. 120 pp.

   b. World Bank Environmental Assessment Sourcebook on transmission line environmental
      assessment.


RESPONSE TO DATA REQUEST NO. 4

For subsection (a), this document may be viewed at
http://www.nationalwind.org/events/wildlife/2004-2/proceedings.pdf

For subsection (b), CBD may purchase the Sourcebook at
http://publications.worldbank.org/ecommerce/catalog/product-detail?product_id=194233&




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DATA REQUEST NO. 5

Dr. Newman’s qualification statement identifies “Avian Interaction with Power Lines,
Government and Industry (Nationwide) - Principal Scientist and protect manager for more than
25 siting environmental assessments for power lines in the US and Internationally.” For each of
the 25 environmental assessments, please provide the project name, date, location, cover sheet,
and section of the environmental assessment that pertains to collisions and electrocutions.


RESPONSE TO DATA REQUEST NO. 5

Dr. Newman has prepared a list of his “environmental assessments”. However, the majority of
documents included on this list are either subject to confidentially agreements between Dr.
Newman and various third-parties or not in Dr. Newman’s possession. SDG&E has
electronically provided Dr. Newman’s documents that were not subject to the previous
limitations.




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DATA REQUEST NO. 6

For each of the following experts identified by SDG&E, please identify and provide all
documents which the expert relies upon to support his/her direct testimony, the statement in the
testimony which the document supports, and the page number(s) from the document supporting
the testimony.

       a. John Messina

       b. Jim Whalen

       c. Jim Newman

       d. Rob Ramey

       e. Lynn Trexel


RESPONSE TO DATA REQUEST NO. 6

On April 1, 2008, SDG&E and CBD met and conferred regarding this data request. CBD agreed
that SDG&E’s experts were only required to “identify and provide all documents which the
expert relies upon to support his/her direct testimony” to the extent any existed. Additionally,
with respect to Lynn Trexel, CBD further agreed to narrow the scope of its request to any new
documents relied up by Ms. Trexel for her direct testimony that would update SDG&E’s data
request responses regarding property rights within the Anza Borrego Desert State Park.
SDG&E’s response is provided below:

(a) John Messina – Mr. Messina did not rely on any documents to support his direct testimony,
which is based on his experience and professional judgment.

(b) Jim Whalen – Mr. Whalen did not rely on any documents to support his direct testimony,
which is based on his experience and professional judgment.

(c) Jim Newman – Dr. Newman did not rely on any documents to support his direct testimony,
which is based on his experience and professional judgment.

(d) Rob Ramey – Dr. Ramey relied upon his experience and professional judgment and the
documents that support his direct testimony have been electronically provided.

(e) Lynn Trexel – None.




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DATA REQUEST NO. 7

Please admit that to reduce statewide Greenhouse Gas (GHG) emissions to 1990 levels by 2020,
California state policy seeks a reduction in GHG emissions associated with energy generation. If
you do not admit to this statement, please provide a complete explanation of your reasons.

RESPONSE TO DATA REQUEST NO. 7
Admitted.




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DATA REQUEST NO. 8
Please admit that no energy efficiency programs are part of the application in this proceeding.

RESPONSE TO DATA REQUEST NO. 8
SDG&E is seeking a CPCN for the construction of the Sunrise Powerlink Transmission Project.
SDG&E is not seeking approval of an energy efficiency programs as part of this Application.
SDG&E’s analysis of the need for the Sunrise Powerlink Transmission Project included
evaluation of energy efficiency programs.


Dated: April 4, 2008                             LATHAM & WATKINS LLP
                                                   Richard W. Raushenbush
                                                   Janice M. Schneider
                                                   Jason M. Ohta

                                                     /s/ Jason M. Ohta

                                                     Jason M. Ohta
                                                     Attorneys for SAN DIEGO GAS AND
                                                     ELECTRIC COMPANY




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