Southern California Edison (SCE), the developer of the Tehachapi Renewable Transmission Project (TRTP), supports the proposed decision by an administrative law judge (ALJ) with the California Public Utilities Commission (CPUC) denying a request to underground a 3.5-mile portion of the project through the city of Chino Hills, Calif., but the utility is also critical of the regulators for hearing the matter in the first place (Docket No. A07-06-031).
“SCE strongly supports the [proposed decision’s] conclusion that Chino Hills’ request for undergrounding should be denied because the substantial increase in cost is not warranted and would harm customers, and that Chino Hills is not unique vis-à-vis other similarly situated communities,” the utility wrote in 24 pages of comment on the proposed decision submitted July 1.
However, the utility said considering the matter in the first place “improperly sidesteps” a commission rule that requires evidence of new facts before a petition for modification can be granted. In fact, the failure to demonstrate changed facts or circumstances warranting a modification and “the attempt to re-litigate issues that have already been considered and rejected” are grounds to reject a petition for modification, SCE noted.
The utility asserted that Chino Hills presented no new facts, and it took issue with the city’s oft-repeated assertion that, when constructed, the “visual and economic impact” of the overhead towers was far greater than anticipated.
“The photographs submitted by Chino Hills are consistent with photographs and simulations in the final [environmental impact report],” SCE wrote. “That the approved structures are now constructed is not a materially changed fact that would justify granting the extraordinary relief of demolishing the almost completed overhead structures and undergrounding the transmission line, unnecessarily costing ratepayers hundreds of millions of dollars.”
The utility also called the city’s expressed concerns over the width of the right-of-way a “red herring,” noting that distance from the 200-foot towers to the residences is the more relevant factor, and that residents in other communities are “just as close if not closer to structures of similar height as in Chino Hills.”
In its comments, the utility asked that the CPUC modify the proposed decision to clarify that the city of Chino Hills submitted “no new facts that would warrant modifying” the final project approval granted in December 2009. Such language, SCE argued, would “avoid the unintended consequences that such a significant change in policy and application of [PUC] Rule 16.4 may have on the certainty of future commission orders.”
Although concurring that undergrounding the portion of Segment 8A through Chino Hills would substantially increase the project cost, SCE said the actual cost of removing the overhead structures that have already been erected and placing the transmission line underground would be even higher than the proposed decision estimates, “which further underscores that undergrounding should not be implemented.”
The proposed decision focused on the underground alignment identified as UG5, and focused on an estimated cost of constructing that segment of $296m. In addition to its prediction that the actual cost of UG5 would be substantially higher due to the need to add reactive compensation and increased environmental costs, SCE stated that UG5 would be “insufficient for prudent transmission planning.”
The alignment identified as UG2 would be SCE’s preferred alternative for an underground alignment and would cost $533m to construct, the utility said. SCE asked that the proposed decision’s analysis consider the costs and feasibility of UG2, and that the proposed decision be clarified to reflect those higher costs.
The utility also restated its concern that ordering that a portion of the line be built underground would put the projected in-service date at risk.
“The commission should consider that undergrounding would create a substantial risk of delay, as it is highly unlikely that [the line segment] could be completed in time to meet an in-service date of late 2015 or early 2016,” SCE wrote.
The proposed decision by ALJ Jean Vieth and an alternate proposed decision by CPUC President Michael Peevey favoring undergrounding were made public on June 11, satisfying the required 30-day review period before proposed decisions may be acted upon. Both proposed decisions appear on the agenda for the CPUC’s July 11 meeting at its San Francisco headquarters.
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).