Southern California Edison (SCE) is asking California state regulators to compel the city of Chino Hills, Calif., to release specific details supporting a congestion study about the consequences of delaying the construction of Segment 8A of the Tehachapi Renewable Transmission Project (TRTP) or, in the alternative, to disallow the city’s testimony (Docket No. A07-06-031).
At issue is a congestion analysis prepared by Dr. Ajit Kulkarni, a consultant with Nexant, which concluded that there would be “virtually no risk of curtailment due to transmission congestion associated with delay to the completion of Segment 8A of [the] TRTP,” according to a motion the utility filed with the California Public Utilities Commission (CPUC) on April 2.
SCE said its experts strongly dispute the city’s testimony, which was filed in rebuttal to SCE’s testimony submitted on Jan. 10 and Feb. 1 regarding its analysis of the amount of curtailment that could occur due to a delay in construction of Segment 8A of the TRTP.
While the actual testimony is not publicly available as part of the record until accepted by the administrative law judge, SCE’s motion states that the utility is unwilling to accept the city’s conclusion without supporting data, including “original inputs, modified inputs, and the reasons for modifications; constraints; key drivers; transmission topology; and solution files” used in reaching the conclusion. Without that information, SCE said, the city’s study was “developed … inside a black box.”
In its motion, SCE refers to a meeting at which Kulkarni admitted that, “adjustments to the model can be made to achieve any result desired by the modeler.” The utility further asserted that a conclusion without access to the supporting details is meaningless, that it could not meaningfully review the analysis and would therefore not have the opportunity to explain, contradict or refute the city’s conclusions without the additional information.
By commission rules, SCE has until April 12 to respond to the city’s rebuttal testimony, an interval the utility called “a small window of time to prepare rebuttal testimony responsive to the voluminous and disorganized testimony served by Chino Hills.” Nonetheless, the utility asked the CPUC to order the city to release that information by close of business April 4. As of press time April 5, no order in the matter was publicly available from the CPUC.
Alternatively, if the CPUC does not choose to order the city to comply, SCE asked that the city’s testimony about its congestion study be stricken from the record.
Calls seeking additional information from SCE and the CPUC were not returned by press time April 5. A spokesperson for the city of Chino Hills said April 5 that the city manager, who is the lead in the matter, was unavailable.
CPUC President Michael Peevey has previously stated that the commission will determine whether to require undergrounding of Segment 8A through the existing right of way in Chino Hills in July.
When completed, the 250-mile, $2.5bn, 500-kV project will be capable of moving up to 4,500 MW of renewable energy from the Tehachapi, Calif., area to population centers in Los Angeles and San Bernardino counties in California.
SCE has called the Tehachapi project “a critically important, high-voltage transmission line, the timely completion of which is essential for California’s progress toward its aggressive renewable energy goals.”
California’s renewable portfolio standard calls for 33% renewable energy by 2020.
SCE is a subsidiary of Edison International (NYSE:EIX).