SDGE CPUC ED DR1 10-12-06 Submission 1 website CPUC ED DR1 10-12 … · SUNRISE POWERLINK PROJECT...

SUNRISE POWERLINK PROJECT (A.06-08-010) SDG&E Response to Data Request Number 1

Submittal #1, October 12, 2006

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GENERAL

GEN-1 In order for the EIR/EIS team to be aware of access problems for surveys or site visits, please provide a listing of property owners (including phone numbers) along the Proposed Project route and SDG&E alternatives retained in the PEA, where SDG&E does not have right-of-entry.

Response: Attachment GEN-1 includes a list of property owners, with phone numbers, addresses and assessors parcel numbers (APN), for the Proposed Project and alternative routes in the Central Link and Inland Valley Link indicating where SDG&E does not currently have right-of entry. A similar list will be submitted for the Coastal and Desert Links (including the Anza Borrego Desert Alternative Link) on October 31, 2006. GEN-3 a. Please provide GIS files including all existing transmission line structures within

the proposed ROW (current data includes only structures to be added or removed).

Response: Existing transmission line structures are being provided in GIS shapefile format as part of this response. Existing structure locations are proprietary and not to be distributed for public information or use.

b. For all towers, provide a data table identifying the tower type and tower height.

Response: Attachment GEN-3 provides a table that identifies type and height of existing structures. SDG&E is providing information on the existing 69 kV tie lines in its Eastern territory. Provided tie line information is for the following: TL625, 626, 629, 637, 678, 685, 686, 6904, 6914, 6917, 6923, and 6931 including the locations of all the interconnected substations.



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PROJECT DESCRIPTION

PD-1 a. Please clarify whether the preliminary structure locations provided in the Proposed Project GIS database are final for purposes of impact assessment.

Response: The structure locations provided in the PEA were intended to be final for impact assessment. However, additional field verification is in progress to confirm the structure locations.

b. We recognize that slight modifications to tower locations may be required during project construction in response to conditions or resources encountered in the field (maximizing tower stability while minimizing environmental issues). Please describe the process that would be used to determine revised structure locations during construction, if necessary.

Response: After land surveying has been complete, structure locations will first be confirmed by importing the survey data into transmission line design software (PLS-CADD). Using this software, transmission engineers will verify the structure locations and, if necessary, make adjustments due to clearance issues, utility conflicts, environmental constraints or other physical limitations. After completing this work, surveyors will stake the revised structure locations. The staked locations will then be reviewed in the field by transmission engineers, construction contractors, biologists and archeologists to confirm the structures are in an acceptable location. If additional adjustments are required, alternate locations will be identified in the field and the locations surveyed. The survey data for the alternate locations will be imported into PLS-CADD to confirm the location after which the locations will be staked and field verified as described above. The final structure locations will be staked after all parties reviewing parties have reviewed and accepted the locations. PD-2 The PEA does not provide details on the transmission hardware that will be installed

as part of the Proposed Project. Please provide detailed information regarding the composition, type and dimensions of conductors to be used for each circuit. Also, describe conductor spacing parameters for each type of line and structure.

Response:

500 kV Transmission Conductors

For the 500-kV line segment, a bundle of three 1033.5 kcmil ACSR/AW conductors are proposed. ACSR/AW is composed of one or more layers of hard-drawn concentrically stranded 1350 aluminum wire with a stranded high-strength aluminum clad steel core. This cladding provides greater protection against corrosion than other types of steel core wire. A bundle of three conductors was selected to provide sufficient current carrying capacity and reduce audible noise and radio interference.

Each conductor has a 45/7 aluminum/steel stranding, a diameter of 1.212 inches, and a weight of 1.135 lb/ft. The conductors will be assembled in a triangular bundle with eighteen inches between each conductor.



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230 kV Transmission Conductors

A bundle of two 900 kcmil ACSS/AW conductors is proposed for the overhead 230-kV line segments. ACSS/AW conductor is an aluminum-steel composite conductor resembling ACSR/AW in appearance, stranding and overall diameter. ACSS/AW uses 1350-0 (fully annealed) aluminum strands rather than the traditional 1350-H19 hard drawn aluminum used in standard ACSR/AW. Since the aluminum strands are fully annealed, the conductor strength and sag characteristics are essentially derived from the steel core wires. ACSS/AW can be operated at temperatures of 200°C or more without loss of strength. Compared to an equal size ACSR/AW, ACSS/AW has a significantly higher ampacity, a lower creep elongation and a lower elastic modulus. It also has a lower breaking strength, but can be strung at tensions that are higher percentages of its breaking strength than standard ACSR/AW, due to its self-damping characteristics.

Each conductor has a 54/7 aluminum/steel stranding, a diameter of 1.162 inches, and a weight of 1.111 lb/ft. The conductors will be assembled in a horizontal bundle with eighteen inches between the conductors.

ACSR/AW was selected for the 500 kV segment based primarily on noise and electrical interference considerations. ACSS/AW was selected for the 230 kV segment based on current carrying capacity. Both conductors are standard sizes used by SDG&E.

Three bundles (phases) are required to complete a transmission circuit. The spacing between phases is determined by electrical spacing parameters provided by CPUC General Order 95. These parameters include minimum distances between the conductors and ground, crossing structures, the supporting structure, and other conductors. The values increase with line voltage. These considerations are reflected in the dimensions provided in the attached structure diagrams. PD-3 a. The transmission structure figures (Figure 2.3-2A through 2.3-2k) in the PEA do

not show ground wires or fiber optic cables. Will overhead ground wires be installed as part of the Proposed Project? If so, please provide information on the number of ground wires per type of line and their approximate spacing. In addition, identify their placement on the applicable PEA structure illustrations.

Response: Ground wires will be installed on all 230- and 500-kV transmission structures. All 230 kV structures will have a single wire installed at the structure peak. The wire will be a fiber optic shield wire (OPGW). An OPGW was selected to provide data transfer capabilities between SDG&E facilities. This data is required for system monitoring. The OPGW also provides lightning protection for the transmission conductors.

All 500 kV structures will support two ground wires, also installed at the structure peaks. One of the wires will be an OPGW. The other wire will be an aluminum clad stranded steel wire. Refer to structure diagrams provided with the response for PD-2 for the location of the ground wires and OPGW.



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b. Would fiber optic cables be installed on transmission structures? If so please identify the location of the fiber optic cable on each type of structure.

Response: See response to PD-3a. PD-4 What other associated hardware would be needed for the Proposed Project other

than conductors, insulators and ground wires? Please also explain the function of the additional hardware on the transmission structures.

Response: In addition to the structures, conductors, and insulators, other hardware to be installed on the towers consist of components that are part of the insulator assembly and used to support the conductors and ground wires. These pieces are steel and aluminum and include clamps, shackles, links, plates, and other pieces that are assembled to support the wires. In addition, a grounding system will be installed at each structure. The grounding system consists of copper ground rods that are embedded in the ground in very close proximity to the structure foundations and connected to the structure by a buried copper lead.

No hardware not associated with the transmission of electric power is planned to be supported on the towers. There may be aerial marker spheres or structure lighting installed in specific locations as required by the Federal Aviation Administration, U.S. Border Patrol, Department of Defense, or other agencies. PD-5 In order to evaluate the potential impacts associated with operation and maintenance

(O&M) activities, we need to understand these projected O&M activities for the Proposed Project. Please provide additional information on the frequency of O&M procedures. How often would ground and aerial patrols be conducted for aboveground structures, underground structures, vegetation maintenance, washing the insulators, etc.? What are the labor and equipment requirements for patrols?

Response: Attachment PD-5 provides a table of projected labor and equipment requirements and frequency of operations and maintenance activities associated with the Proposed Project. PD-6 Please provide a detailed list of labor force required per month for each segment

(i.e., Desert Link, Anza Borrego Desert State Park, Central Link, Inland Link, Coastal Link, substation, and other system upgrades) of the Proposed Project. Provide this information in Excel spreadsheet format with corresponding graphs.

Response: Attachment PD-6 includes a spreadsheet and corresponding graphs that provide estimated labor for each Link.



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PD-7 An earlier version of the PEA indicated that the Proposed Project would require a

large repeater station near the Central Substation. Although the repeater station was removed from the text in the August 4, 2006 version of the PEA, it was included in Table 2.3-1 (Sunrise Powerlink Project Plan of Service). Please confirm whether a microwave repeater site is not part of the Proposed Project.

Response: A repeater station will not be required at or near the Central Substation. PD-9 Please clarify the radius of vegetation clearing around all transmission support

structures. There is a discrepancy between pages 2-60 and 2-61 of the PEA. Page 2-60 states that SDG&E would maintain a 30 foot minimum working space around all transmission structures. Page 2-61 states that a ten foot radius is cleared around a pole or structure footing. Please clarify this discrepancy.

Response: SDG&E maintains a 10 foot radius of vegetation clearance around transmission structures per Public Resources Code, section 4292. The 30 foot minimum working space clearance is not related to vegetation management and is an error in the PEA. PD-10 It is our understanding that steel poles, lattice towers, and H-frame towers would

each require different amounts of clearance during construction due to the different construction techniques. Please provide a range or a specific amount of disturbance that would result at each structure type (e.g., xxx square feet for a 500 kV lattice tower; xxx square feet for a tubular steel pole).

Response: SDG&E assumed the following average area of permanent disturbance, by structure type, for the assessment of impacts within the Proponent’s Environmental Assessment:

• Lattice - 79 square feet • Pole - 64 square feet • H-Frame - 77 square feet

PD-11 Section 2.5.4.1.2 of the PEA states that typically the underground circuits would be

constructed in a vertical configuration, but at some locations transitioning to a horizontal configuration may be required to clear substructures in highly congested areas. Please provide an illustration of a typical 230 kV double circuit duct bank with a horizontal configuration that would be used for the underground portions of the Proposed Project, if necessary.

Response: The following diagram is a cross sectional view of a 230 kV single circuit (2 conductors per phase) horizontal duct bank layout. Since two conductors per phase are being used, this typically double circuit layout would be used as single circuit layout. SDG&E is not planning to use the horizontal layout for the Sunrise Powerlink Project; however, the horizontal layout



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maybe considered should conflicts with other facilities and obstructions require this configuration and as the design of the underground route shows a need for such layout.



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ALTERNATIVES

The EIR/EIS Team is evaluating a wide range of alternatives to the Proposed Project. No decision has been made as to which specific alternatives may be carried forward for analysis in the EIR/EIS; however, additional information is required in order for us to complete the screening process allowing this determination to be made. Also, we are requesting “preliminary engineering” on certain components that we believe are almost certain to require EIR/EIS analysis. For the following questions, we will first state the alternative for which we require information, then present the question(s) themselves.

Alternatives Avoiding Anza-Borrego Desert State Park by Collocating with Segments of the SWPL

Any alternative that avoids ABDSP requires collocation with the existing 500 kV SWPL for a longer segment than that proposed by SDG&E in its Proposed Project route. The following questions are presented in order for us to clearly understand SDG&E’s stated concern about the reliability of this collocation. Section Response: The CAISO filed comments on 10/12/06 regarding the potential alternative routes that would parallel SWPL (this filing is included in Attachment ALT-CAISO). The CAISO states that those alternatives are inferior to the proposed route and fail to satisfy reliability criteria. ALT-3 Provide a table that lists each outage on the SWPL since it was constructed. For

each outage, include the following columns: date of outage, cause of the outage, and the amount of time the line was out of service.

Response: Attachment ALT-3 provides the SWPL outage history and causes. Note that the attachment to this response is CONFIDENTIAL and is submitted under the provisions of General Order 66-C and PU Code Section 583, and therefore is not included on the Sunrise Website. ALT-4 What is the width of the existing ROW for the SWPL between Imperial Valley

Substation and a point along the SWPL just south of Barrett Substation. If the ROW width varies, please provide width by milepost, starting at the Imperial Valley Substation.

Response: Attachment ALT-4 includes maps that graphically depict the right-of-way (ROW) width associated with the existing Southwest Powerlink (SWPL) 500 kV transmission line, including the identification of specific locations where the ROW changes.



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ALT-6 SDG&E has previously pointed out “pinch points” where environmental constraints exist along the SWPL corridor. Please answer the following questions about these locations:

c. PEA Supplement map Attachment ALT 1 also points out locations of designated critical habitat along the SWPL. How would the extent of impact to this habitat compare with impacts to critical habitat for the proposed route?

Response: The Proposed Project would impact approximately 404.4 acres, as provided in the Proponent’s Environmental Assessment. Along the existing Southwest Powerlink (SWPL) 500 kV transmission line, approximately 431.2 acres would be impacted. However, an alignment parallel to SWPL would impact designated critical habitat unique to a greater number of species and this would need to be considered with regard to surveying and any implications associated with mitigation.



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ALT-8 What is the capacity of the existing SWPL (in MW) and what has been its utilization, on an annual average basis, over the past five years?

Response:

Line Segment Continuous Rating

(MVA) Emergency Rating a/

(MVA) TL50001 (Imperial Valley-Miguel 2364 2727 TL50002 (North Gila-Imperial Valley) 2000 2700 HAA-NG (Hassayampa-North Gila) 2000 2700

a/ Thirty minute rating.

The annual average of recorded powerflows on the Southwest Powerlink are provided on the following table.

Recorded Powerflows on the Southwest Powerlink

Annual Average Hourly Powerflow

(MW per Hour)

Year Palo Verde – North Gila a/ North Gila –Imperial Valley b/

Imperial Valley – Miguel c/

2005 644 514 1078

2004 655 550 909

2003 644 606 792

2002 Telemetered hourly flow data not available or reliable in a sufficient number of hours

791 623

2001 Telemetered hourly flow data not available or reliable in a sufficient number of hours

683 563

a/ Measured at North Gila substation.

b/ Measured at North Gila substation.

c/ Measured at Imperial Valley substation.



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Alternatives Through Cleveland National Forest

The most feasible non-ABDSP routes that were considered by SDG&E appear to be Alternatives C and D, which both follow existing 69 kV transmission lines and pass through portions of the Cleveland National Forest. Answers to the following questions will allow us to understand these routes and their potential constraints.

Substation Options. The Proposed Project includes a 500/230 kV substation at a point approximately 30 miles from the eastern border of San Diego County. We are evaluating several potential locations for a 500/230 kV substation at similar points along an alternative route that would parallel the SWPL. These substation locations could be used in conjunction with portions of the C, D, and C-D alternative routes (as well as other routes developed by the EIR/EIS Team). Converting the project to a 230 kV line near the SWPL would allow greater flexibility in line siting when designing a north-south transmission line route that would connect with the Proposed Project route to the north. Please provide the information requested below for each of the 500/230 kV substation options described.

ALT-9 Low-Profile Substation Design. On other projects, we have seen utilities use a “low-profile” substation design in order to minimize the visibility of substation equipment. An example is the PG&E 230 kV Cayetano Substation recently constructed near Livermore, Alameda County on North Livermore Road. Describe the possibility of using such a design for a 500/230 substation, and explain how such a substation would vary (in design, cost, and profile) from the proposed design of the Central East Substation.

Response: The PG&E Cayetano Substation is a 230/23kV distribution substation configured with a three element ring bus and underground cable termination. SDG&E has also installed low profile distribution substations up to 138kV in visually sensitive areas. The concept of low profile design hinges on using underground line and equipment terminals instead of overhead line drops in order to eliminate some of the high profile structures. The proposed Central substation is a 500/230kV, bulk power, transmission substation with breaker-and-half bus design, series compensation capacitor, seven single phase 500/230/12kV transformers (including a spare unit), two 230kV shunt capacitors and 12kV tertiary reactors. In order to configure this substation into low profile the following design changes must be incorporated: • Install 500kV transition, overhead to underground, getaway structures • Convert all the 500kv and 230kV overhead drops to underground cable risers; at the

equipment and at the buses • Shield structures and static lines must be installed to protect the facilities from lightning

induced surges • The proposed project has a 500kV sparing bus. Provide underground terminations between

the spare transformer and each of the phases • The underground facilities will include ducts, cable, bushings and surge protection as

required The overall substation foot-print will not change significantly. The drive aisles width may increase slightly to allow better access to the equipment. The height of the 500kV and 230kV buses will not change. The equipment profile will stays the same. The 85-135 feet dead-end structures will be replaced with approximately 35 feet cable riser structures and bushings.



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Reliability is an essential component for this project. This project is located in a high seismic zone; therefore, stringent design criteria will be followed to minimize failures and outages due to seismic activities. Underground systems, although feasible, would use rigid components, such as bushings and possibly rigid bus, that have not performed well during seismic events in the past. Historically, overhead strain bus design and overhead terminations have a better performance history than underground systems using rigid components. Underground systems also have much longer down time to restore or repair if damaged. In addition, underground facilities are approximately 8-10 times more expensive to install and at least 5 times more expensive to repair. ALT-12 What is the expiration date of the 69kV ROW within the Cleveland National Forest

along the route “C” and "D" alternatives?

Response: SDG&E has easements or Special Use Permits for the following 69kV lines that fall within the Cleveland National Forest along the “C” and “D” alternatives:

Pine Valley – Laguna Junction (Glencliff) 69kV line circuit TL 626, 50 year easement expires 8/19/2008 (2.52 miles)

Boulder Creek Line - 69kV line circuit TL626, Special Use Permit (expired 8/8/94) currently under renewal in Master Permit through USFS Cleveland National Forest (5.86 miles)

Cameron Substation Line – 69kV line circuit TL6923, Special Use Permit (expired 8/8/94) currently under renewal in Master Permit through USFS Cleveland National Forest (1.197 miles)

Glencliff to Boulevard Line – 69kV line circuit TL629, Special Use Permit (expired 8/8/94) currently under renewal in Master Permit through USFS Cleveland National Forest (5.143 miles)

Santa Ysabel Valley Alternatives Given the high visibility of the proposed route through the Santa Ysabel Valley, the EIR/EIS Team will carefully consider alternatives to this route segment, including the potential for using the existing SDG&E 69 kV route parallel to Hwy 79 and the SDG&E alternative that would move the 230 kV line to the west. Questions include: ALT-24 The Routing Study (page 75) states that use of the existing 69 kV route for the new

230 kV line was not considered because of the San Ysabel Mission and Nature Conservancy Lands. Please provide a detailed map illustrating the width of SDG&E’s existing easement and existing tower locations for the segment of the 69 kV line that parallels SR 79 between its intersection with SR 76 to the north and SR 78 to the south. The map should illustrate the boundaries of the Mission property and the Nature Conservancy Lands.

Response: Attachment ALT-24 depicts SDG&E’s existing 69 kV transmission line, including structure locations and the right-of-way (ROW), in the area of the Santa Ysabel Mission. The boundaries of the Mission and Nature Conservancy Lands are also illustrated.



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ALT-25 PEA Section 3.4.3 (last paragraph before Section 3.4.4 on page 3-62) states that two route segments were reversed before submittal of the PEA with respect to their “proposed” and “alternative” status based on meetings with County of San Diego and San Dieguito River Park staff. The concerns of the County staff were based on visual impacts on recreational users. In order for EIR/EIS Team to understand how the proposed route in this area was selected, please describe:

(a) the parcels that would have been affected by the route to the west in comparison to the parcels affected by the route as currently proposed,

Response: The Proposed Project (N46-N68-N20A-N20B) has a total of 36 affected parcels, representing 7 private ownership entities (the Auerbach Family [4 parcels], the Batchelder Family [4 parcels], the Cauzza Family [13 parcels], The Cumming Family [5 parcels], the Hawthorne Family [4 parcels], the Tulloch Family [4 parcels], and the Wood Family [one parcel]), and no publicly owned parcels. The Alternate Alignment (N46-N76-N20B) has a total of 28 affected parcels, representing 4 private ownership entities (the Boeckmann Family [4 parcels], the Cauzza Family [5 parcels], the Tulloch Family [4 parcels], and the Wood Family [3 parcels]), in addition to parcels owned by the County of San Diego (5 parcels), San Dieguito River Park Joint Powers Authority (1 parcel), San Dieguito River Valley Regional Open Space Park (4 parcels), and a United States of America Indian Reservation (2 parcels).

(b) the difference in recreational use between the two areas, and Response: The Proposed Project (N46-N68-N20A-N20B) traverses through the San Dieguito River Valley Regional Open Space Park for approximately 1.5 miles and does not traverse any other preserve, reserve, open space, or park. The Alternate Alignment (N46-N76-N20B) traverses through the San Dieguito River Valley Regional Open Space Park for approximately 0.8 miles and traverses through the Santa Ysabel Open Space Preserve for approximately 0.6 miles and then parallels it for approximately 2.7 miles.

(c) the traffic volume on Highway 79. Response: The Proposed Project (N17-N18-N46-N68-N20A-N20B) is adjacent to SR79 from N17 to N18 and N68 to N20A near Santa Ysabel and crosses SR79 at N18. The Alternative Alignment (N18-N68 and N46-N76-N20B) is adjacent to SR79 from N18 to N68.

• North of N17 at the intersection of San Felipe Road (S2) and SR79, during the highest traffic volume month in 2005, the volume was 3900.

• Near N18, at the junction of SR76 and SR79, during the highest traffic volume month in 2005, the volume was 3600.

• East of the Proposed Project corridor northeast of N20A and at the junction of SR78 and SR79, during the highest traffic volume month in 2005, the volume was 3400.

This data was collected from an analysis done by Caltrans in 2005. REFERENCES

http://www.dot.ca.gov/hq/traffops/saferesr/trafdata/2005all/docs/rt071-80.htm.



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UCAN Alternatives

In its September 7, 2006 statement in the CPUC’s Sunrise proceeding, UCAN presents several alternatives (pages 2-3). Please respond to the following questions on these suggestions.

ALT-27 Please explain the potential environmental benefits and environmental/engineering constraints of the “Mexico Light” alternative and the ability of “Mexico Light” to achieve project objectives. Provide sufficient detail on each environmental discipline that a comparison can be made with the proposed route.

UCAN describes “Mexico Light” as follows: The “Mexico Light” alternative would consist of a very short segment of new 230 KV transmission from either the TDM and/or Intergen generators to the CFE grid. This new transmission would normally be operated open. The existing cross-trip for loss of SWPL would be amended so that, in the event of loss of the IV-Miguel segment of SWPL, the TDM and/or Intergen plants would no longer trip off completely, and the Tijuana-Otay Mesa circuit would no longer be opened. Instead, the TDM/Intergen to CFE circuit(s) would be closed, and the generators would continue to operate.

Response: The 230 kV CFE alternative shifts potential environmental impacts from the United States to Mexico and does not reduce significant impacts associated with the Proposed Project. Furthermore, environmental justice issues would likely be a major concern associated with the federal actions required under this alternative as outlined below. This alternative also has several regulatory issues that make it infeasible as follows:

• Obtaining a U.S. Presidential Permit.

o The DOE serves as the lead federal agency for Presidential Permits for transmission line Projects which cross the border. The Presidential Permit process can vary from six months to several years, depending on issues associated with the Project and the status of other permits.

• Obtaining environmental permits/approvals from the various Mexican government agencies.

o The enabling legislation for environmental protection in Mexico is the 1988 General Law on Ecological Balance and Environmental Protection (LGEEPA). The multiple Mexican permits and approvals required would likely delay the required 2010 in service date.

• Ultimate ownership of the facilities (SDG&E or CFE) and the associated determination of cost recovery.

• Ownership of an international transmission facility is a complex issue and will require extensive discussions and negotiations with CFE and the CPUC.

ALT-28 Please explain the potential environmental benefits and environmental/engineering constraints of the “SONGS Upgrade” and “SONGS Medium” options as project alternatives and the ability of these options to achieve project objectives. Provide sufficient detail on each environmental discipline that a comparison can be made with the proposed route.



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UCAN describes the “SONGS Upgrade” as follows: The existing SCE-SONGS lines that form the north-of-SONGS transmission path pass SDG&E’s Talega Substation. Looping one of those lines into the Talega Substation would require no more than one mile of new transmission line, plus two new termination positions at Talega, and would create a 6th south-of-SONGS line. The existing SCE system north of SONGS can already handle flows of up to 2850 MW into the SDG&E system. Similarly, a six-line south-of-SONGS path should be able to handle 2850 MW after losing one of the six lines, because a five-line south-of-SONGS path can handle 2850 MW today under N-0 conditions.

UCAN describes “SONGS Medium” as follows: A variation on the “SONGS Upgrade” would involve either a second Talega-Escondido line or a 4th SONGS-San Luis Rey line. This alternative would consist of SONGS light (looping an SCE-SONGS line into Talega) plus a new 230 kV line, either Talega-Escondido #2 or SONGS-San Luis Rey #4.

Response: UCAN’s “SONGS Medium” transmission alternative does not achieve certain objectives that are required to meet the projected needs of consumers within the San Diego area and the other regions of the CAISO control area. Therefore, an environmental assessment was not developed or conducted. These technical deficiencies are discussed in SDG&E’s responses to questions 5, 11, 38, 39, 40, 41, 46 and 47 of UCAN data request #6 (attached, titled: UCAN DR6 CPUC Responses 10-12-06).

No Project Alternative ALT-30 CPUC recently ordered IOUs to procure 3,700 MW of new generation to come on

line beginning in 2009 (D. 06-07-029 on July 20, 2006, R. 06-02-013). Although only PG&E and SCE were ordered to issue RFOs for this new generation, the CPUC could conceivably in the future order such procurements for SDG&E. Please expand the description of the No Project Alternative to illustrate what level of new generation would need to be procured by SDG&E in each year from 2010 to 2015 to meet Resource Adequacy requirements and RPS goals, in the absence of the Sunrise Powerlink Project.

Response: The requirements SDG&E has to meet resource adequacy requirements for its bundled customers is described under SDG&E’s response to question 45 UCAN data request #7 (attached, titled: UCAN DR7 Q45). The references to case 100 and case 104 in this data request response refer to scenarios without the Sunrise Powerlink.

The ability of SDG&E to meet its RPS goals in the absence of the Sunrise Powerlink project is discussed in section III.D of SDG&E’s August 4, 2006 Sunrise Powerlink Transmission Project Purpose and Need, Volume 2 – Part 1. Also, see SDG&E’s response to question 2 of the Energy Working Group’s first data request (attached, titled: EWG Q2).



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General Alternatives Questions

ALT-38 In order for us to understand the power flow and capacity situation at Imperial Valley Substation, please provide the following information:

a. On a month-by-month basis through 2005 and 2006, where was power coming from and where was it going (approximate # of MW on each transmission line entering and leaving the substation).

Response: The following tables use recorded hourly powerflows to compute net monthly powerflows at the Imperial Valley substation.

This data should not be considered complete because data for a number of hours in each month for the various lines is missing or unreliable as a result of metering and telemetry issues. Such missing and unreliable data is treated as a 0 MW read for purposes of producing the data shown on the following table.

Note that the hourly powerflows for each line are netted across the entire month, i.e., inflows and outflows during particular hours within a given month will offset each other. The resulting net monthly inflow or net monthly outflow may not, therefore, be a good measure of the extent to which a particular transmission line is being operated at or near its maximum capability at any point during the month.

Note that the data provided on the tables mentioned above, is CONFIDENTIAL and submitted under the provisions of General Order 66-C and PU Code Section 583; and therefore are not included on the Sunrise Website.

b. Specifically illustrate the amount of power coming in from Mexico.

Response: Refer to the rows on the above tables entitled “La Rosita – Imperial Valley 230 kV line” and “230 kV lines connecting the Intergen and TDM generating plants to Imperial Valley substation”. Note that former 230 kV line connects to the CFE control area while the latter 230 kV lines are effectively within the CAISO control area (even though the generating plants are physically located in Mexico).

c. Are any new transmission lines in the planning process or otherwise being evaluated between Mexico and the Imperial Valley, or between Imperial Valley and points further east, such as North Gila?

Response: No.

In-Basin Generation Alternative

ALT-41 Does SDG&E/Sempra have contracts to purchase power from the existing South Bay Power Plant? If so, please provide contract terms. What has been the output (in MW) of the existing plant since 2004? Please provide the contract terms ($/mwh) for any existing contracts for South Bay Power Plant output.



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Response: SDG&E does not have contracts to purchase power from the existing South Bay Power plant. Since SDG&E is not the plant owner and has no rights to the plant’s output, SDG&E does not know what the output of the existing plant has been since 2004. ALT-42 With respect to the proposed repower of South Bay (South Bay Replacement

Project) now in the permitting process by LS Power, does SDG&E/Sempra plan to procure power from the new plant, with its anticipated capacity of up to 620 MW?

Response: At this time SDG&E has no plans to procure power from the proposed “South Bay Replacement Project”. ALT-43 What is the status of construction and ownership of the 510 MW Otay Mesa Power

Plant? When is construction expected to be completed, and when will operation begin? How will the plant be operated?

Response: Construction activity is on hold pending completion of commercial contracts between SDG&E and Calpine per the recent letter of intent approved by the CPUC on September 7, 2006. Calpine must submit to the Bankruptcy Court a request for approval to transfer certain assets to Otay Mesa Energy Center, LLC. Bankruptcy Court approval is expected before December, 2006. Upon approval Calpine will contract with engineering, procurement and construction entities and secure project financing by May 1, 2007. Construction is slated to be completed such that commercial operation can begin May 1, 2009.

ALT-44 A proposed power plant has been identified on federal land at the Naval Air Station Miramar, which was identified in federal law HR4656. This plant is known as ENPEX or San Diego Community Power. If available, please provide information on the developer of this project, whether they have requested interconnection with SDG&E, what the size of the project would be, and how it would tie into the SD&GE system. Would the Sycamore Canyon Substation have to be expanded? If so, how would this expansion occur (in which directions, and by how much acreage)? Has a system impact study been prepared for the project?

Response: Available public information on proposed generation projects that have requested interconnection to the CAISO grid can be found on the CAISO website at http://www.caiso.com/14e9/14e9ddda1ebf0.pdf. Note that queue position #8 lists a generation project with a Point of Interconnection at “SDGE – Sycamore Canyon Substation” and indicates that the associated System Impact Study is “Complete”. Pursuant to Federal regulations, other non-public information associated with a new generator interconnection request may not be disclosed without the consent of the entity seeking interconnection.



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Non-Wires Alternatives

ALT-45 The PEA in “System Alternatives Considered and Eliminated” eliminates each of five options because each individually would not provide sufficient demand reduction or generation to replace the power that SRPL could provide. Describe an alternative in which these options (energy efficiency, demand response [including implementation of Advanced Metering], in-area generation, distributed generation, and rooftop solar) were implemented together as a package, and explain whether these options in combination would then provide adequate energy sources or savings.



Page 18 of 21

Response: In estimating the economic benefits of adding the Sunrise Powerlink, SDG&E has already incorporated all of the energy efficiency, distributed generation and solar rooftop photovoltaic impacts that can reasonably be anticipated through year 2016. The projected energy efficiency, distributed generation and solar rooftop photovoltaic impacts collectively act to reduce the amount of San Diego area generation that would otherwise have to be subjected to costly Reliability Must Run (RMR) contracts in order to mitigate the ability of generation owners to exercise local market power in the San Diego area.

These impacts are common across the three cases SDG&E used to estimate the economic benefits of the Sunrise Powerlink: The in-area gas-turbine build-out reference case (case 100), the with Sunrise Powerlink case (case 101), and the in-area combined cycle case (case 104). These impacts can be seen as line items on the tables attached to SDG&E’s response to question 75 of UCAN data request #7 (attached, titled: UCAN DR7 Q75). They are further described in Appendix II of SDG&E’s August 4, 2006 Sunrise Powerlink Transmission Project Purpose and Need, Volume 2 – Part 1 under the headings “Energy Efficiency”, “Distributed Generation” and “Rooftop Solar”.

Given that SDG&E has already included the maximum practical amount of impacts from these programs, SDG&E is unable to articulate an alternative to the Sunrise Powerlink that would include even larger energy efficiency, distributed generation and rooftop solar photovoltaic impacts.

With respect to demand response programs, SDG&E notes that the CAISO has recently agreed to accept 29 MW of projected demand response impacts for purposes of determining the amount of in-area generation that is needed to satisfy the CAISO’s Local Area Reliability Service (LARS) requirements for the San Diego area in the year 2007. (See page 40 of Attachment ALT-45, dated August, 2006 and entitled “Report of Gary DeShazo, 2007 Local Area Reliability Service”.) This requirement is the starting point for the CAISO’s determination of which in-area generating units will be subjected to RMR contracts. Assuming the two programs which comprise the 29 MW of impacts are sustainable, it is possible that the CAISO would continue to accept this level of demand reduction through the end of the ten-year planning horizon (2016).

If SDG&E’s proposed Automated Metering Infrastructure (AMI) program were accepted by the CPUC with adequate and sustained funding, it is possible that the CAISO could be convinced to count the program’s projected demand reduction impacts in determining local RMR requirements. SDG&E has estimated that at the “10th percentile value” the AMI program could reduce customer demand by 66 MW in year 2009, 124 MW in year 2010, growing to 181 MW in year 2016. (The potential annual impacts are shown on the third page of Table IV-18, on the third page of Table IV-19 and on the third page of Table IV-20 in Appendix IV of SDG&E’s August 4, 2006 Sunrise Powerlink Transmission Project Purpose and Need, Volume 2 – Part 1.)

Even if the potential AMI program impacts are combined with the 29 MW of CAISO-accepted demand response programs, the resulting “project alternative” would not close the projected local area reliability deficiency in the San Diego area in year 2010 and beyond. This projected deficiency is shown on Table II-3 of Appendix II in SDG&E’s August 4, 2006 Sunrise Powerlink Transmission Project Purpose and Need, Volume 2 – Part 1. For example, in year 2010, there is a projected deficiency of 192 MW. The combined demand response program impacts discussed above would meet only 153 MW of the year 2010 deficiency (29 MW + 124 MW). The projected deficiency by year 2016 is 482 MW. The combined demand response program impacts discussed above would meet only 210 MW of the year 2016 deficiency (29 MW + 181 MW).



Page 19 of 21

SDG&E has already evaluated in-area generation alternatives to the Sunrise Powerlink. These are the in-area gas turbine build-out reference case and the in-area combined cycle case. Both of these alternatives include enough in-area generation to fully satisfy the CAISO’s local area reliability requirements through the year 2016. And, in both cases, the Sunrise Powerlink is shown to be significantly more economic. (Refer to response 17 of SDG&E’s September 1, 2006 supplement to its application, which was filed with the CPUC in response to the CPUC’s August 16, 2006 deficiency letter, for an explanation of these comparisons.)

Including the combined demand response program impacts discussed above with the in-area gas-turbine build-out reference case or the in-area combined cycle case would not satisfy any local area reliability needs because these needs are already satisfied by the amount of generation that is assumed to be added in each of the in-area generation scenarios. As stated above, since SDG&E has already included the maximum practical amount of impacts from these programs, there is no basis upon which to conduct an analysis of whether theoretical increases in energy efficiency, distributed generation and demand response program impacts, in combination with the in-area generation alternatives, would be less or more economical than building the Sunrise Powerlink. Note that even if were possible to devise such a combination alternative, one potential outcome of such an assessment would be that it makes sense to both build the Sunrise Powerlink and to pursue these programs on a long term basis.



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VISUAL RESOURCES VIS-1 Please identify the location of existing 500 kV H-Frame towers that are similar to

those proposed for the Sunrise Project in ABDSP. The EIR/EIS’ visual resources specialist would like to see such towers in the field in order to evaluate the PEA simulations and potentially to prepare additional simulations.

Response: Attachment VIS-1 depicts the H-Frames are on Nevada Power Company's 500-kV Harry Allen-Northwest Transmission Line. The line includes lattice, delta pole, and H-frame construction. The H-frames are located in Las Vegas, Clark County, T 19 S, R 61 E, section 6 and T 19 S, R 60 E section 1. Also, there are H-frames in the city of North Las Vegas, Clark County T 19 S, R 61 E sections 9 and 16.



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CULTURAL RESOURCES

CULT-1 We have previously made this request, and would like to develop a schedule for SDG&E’s compliance with this request. Please provide by October 9 a current schedule for completion of the cultural resources survey work. The schedule should provide anticipated dates for completion of specific segments and for submittal of new site records and shape files depicting both new site locations and newly surveyed areas. An updated schedule should be submitted each week as surveys continue to be done.

Response: Data that will include site record forms, and/or site tables/paragraphs, and GIS shapefiles for work completed up to August 25, 2006 will be submitted on or before October 31, 2006. Data and information regarding the location and description of cultural sites is proprietary and not to be distributed for public use or information.

Public Lands Surveys

Surveys on public lands (ABDSP, VID lands, BLM lands, County Parks) will be complete on or before October 30, 2006. Public lands comprise approximately 50% of the routes analyzed in the Proponent’s Environmental Assessment.

Private Lands Surveys

An estimated completion date for surveys on private lands is dependent on the obtaining of right-of-entry.

Final Cultural Report

Approximately two months after the field survey is complete, the report will be issued. Once the surveys on public lands has been completed and surveys on private lands where permission to access has been granted, a status report that summarizes the findings to that date will be issued.

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