In the latest round of filings and counter filings over the stretch of the Tehachapi Renewable Transmission Project (TRTP) planned to cross the city of Chino Hills, Calif., project developer Southern California Edison (SCE) is warning that, even under the most favorable circumstances, there is significant risk the project will not meet its planned 2015 in-service date (Docket No. A07-06-031).
The utility made that prediction in its Nov. 9 response to a motion filed with the California Public Utilities Commission (CPUC) on Nov. 2 by the city of Chino Hills, in which the city asked the commission order SCE to submit a report identifying what needed to be done to meet a Dec. 31, 2015 commercial operation date.
SCE expressed concern that the current procedural schedule will not likely result in a commission decision on whether the transmission line should be placed underground until late in the third quarter of 2013. Further, SCE said the process from a commission decision ordering undergrounding to in-service operation is projected to take approximately 39 months.
“If a final commission decision modifying the CPCN is issued in the third quarter of 2013, the project would not be operational until late in 2016 or some time in 2017, and certainly would not be in-service by the end of 2015,” the utility said.
SCE said even an accelerated schedule will put the project’s 2015 in-service date at risk.
“Even with heroic efforts and under the most favorable assumptions that there will be no difficulties in completing the design of and constructing a first-in-the-nation 500-kV transmission line underground through hilly territory and under difficult conditions, there is a significant risk that the project simply cannot be completed until well past 2015,” the company said.
In addition, SCE said it has been working on a design that will “accommodate full functionality of the existing right-of way … consistent with the design and capability approved by the California Independent System Operator (CAISO)” to provide room for anticipated future growth.
“Should, however, the commission order that the full capability design be discarded in favor of a different design approach … then additional delay to the completion of the project would be introduced into the project planning process to accommodate such a re-design,” the company added.
While promising to make reasonable efforts to accomplish the timely completion of whatever design is ultimately ordered, SCE cautioned against excess optimism.
“The commission should not accept Chino Hills’ wishful premise that a 2015 in-service date is likely or even feasible in an undergrounding scenario, even with the expedited procedural schedule and advanced materials procurement activities suggested by Chino Hills,” the utility said.
SCE said it was amenable to changes that would accelerate the process and would provide engineering estimates more quickly if so ordered, but noted, “the reality is that complying with such an order would require a heroic effort on SCE’s part, fraught with significant risk. Given the many uncertainties, there is simply no guarantee that a December 2015 completion date is remotely possible, notwithstanding the best of efforts (and luck),” the utility said in its filing.
Further, while the city of Chino Hills asked that SCE be ordered to expedite its engineering estimates and other documentation, SCE is asking that Chino Hills also be held to a shortened schedule.
Instead of giving Chino Hills until March 2013 to respond to documents SCE must submit to the CPUC by Dec. 3, the utility asked that the city be required to submit interim rebuttal testimony by Jan. 11, 2013, to give parties advance notice of the issues the city plans to raise.
“SCE respectfully requests that the commission direct that Chino Hills present its issues at the earliest possible opportunity, and not wait until its final round of testimony only weeks before the start of evidentiary hearings,” the company said. In addition, SCE asked the CPUC move the deadline for testimony by other interested parties from its current date of April 5, 2013, to Jan. 25, 2013.
The company also asked that the current three-day schedule for evidentiary hearings, set to start in April 2013, be extended to a full week and run from April 22 through 26.
SCE asked the CPUC to reject the city’s requests for the utility to be ordered to submit a proposal for recovering costs incurred for evaluating the undergrounding of segment 8A should the CPUC ultimately decide to allow the project to remain above ground, along with justification about why such cost recovery should be allowed. SCE called both requests “inappropriate,” and noted that, “Any prudently incurred project costs would be subject to the FERC-approved rate recovery mechanisms set forth in the CAISO Tariff.”
SCE is a subsidiary of Edison International (NYSE:EIX).