BEFORE THE PUBLIC UTILITIES COMMISSION OF … project arrangement, the Commission’s decision states that the transfer capability of DPV2 would have been expanded from 1,200 to 2,340

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

In the Matter of the Application of SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) for a Certificate of Public Convenience and Necessity Concerning the Devers-Palo Verde No. 2 Transmission Line Project

))))))

Application No. 05-04-015 (Filed April 11, 2005)

REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO RESPONSES ON PETITION FOR MODIFICATION OF

DECISION NO. 07-01-040

MICHAEL D. MACKNESS JULIE A. MILLER

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-4017 Facsimile: (626) 302-2610 E-mail: [email protected]

Dated: June 23, 2008

REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E)TO RESPONSES ON PETITION FOR MODIFICATION OF


TABLE OF CONTENTS

Section Title Page

I. INTRODUCTION ..................................................................................................... 1

II. SCE’S REPLY TO TURN’S RESPONSE ................................................................ 2

A. TURN Calls DPV2 A Relative Bargain For Ratepayers ............................... 2

B. Background On The DSWTP ........................................................................ 2

C. Proposed Language To Clarify That SCE Is Not Seeking To Construct the DSWTP.......................................................................................................... 4

III. SCE’S REPLY TO DRA’S RESPONSE................................................................... 6

A. Contrary to DRA’s Assertions, the Commission May Grant SCE’s Petition on an Ex Parte Basis ...................................................................................... 6

B. DPV2 Will Allow California to Access Proposed Renewable Energy Projects in the Blythe Area ............................................................................ 8

C. Midpoint is Needed to Interconnect Generation in the Blythe Area and DPV2 Is Needed to Bring the Power to Load Reliably ............................... 10

D. DPV2 Benefits Ratepayers .......................................................................... 12

IV. CONCLUSION........................................................................................................ 12

ATTACHMENT A – SCE’S REQUESTED CHANGES TO THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDERING PARAGRAPHS IN D.07-01-040

ATTACHMENT B – DECLARATION OF ROBERT J. LUGO

ATTACHMENT C – DECLARATION OF DANA M. CABBELL

ATTACHMENT D – JUNE 12, 2008, LETTER FROM MR. YAKOUT MANSOUR OF CAISO

ATTACHMENT E – MAY 16, 2008, CEO REPORT FROM YAKOUT MANSOUR OF CAISO

DM1535032 1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

In the Matter of the Application of SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) for a Certificate of Public Convenience and Necessity Concerning the Devers-Palo Verde No. 2 Transmission Line Project. _________________________________________

))))))

Application No. 05-04-015 (Filed April 11, 2005)

REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO RESPONSES ON PETITION FOR MODIFICATION OF


Pursuant to Rule 16.4(g) of the Rules of Practice and Procedure of the California Public

Utilities Commission (“Commission”), and as authorized by Administrative Law Judge Sullivan

by telephone conversation on June 16, 2008, Southern California Edison Company (“SCE”)

replies to the responses to SCE’s petition for modification of Decision No. (“D.”) 07-01-040.

This decision granted SCE a Certificate of Public Convenience and Necessity (“CPCN”) to

construct the Devers-Palo Verde No. 2 Project (“DPV2”).

I.

INTRODUCTION

On May 14, 2008, SCE filed a Petition for Modification to construct DPV2 in phases.

SCE requested that the CPUC authorize SCE to construct DPV2 facilities to allow access to

potential new generation in the Blythe area. On June 13, 2008, The Utility Reform Network

(“TURN”) and the Division of Ratepayer Advocates (“DRA”) filed a Response to SCE’s

Petition. CAISO filed an ex parte notice on June 12, 2008, with the Commission with a letter

from Yakout Mansour, President and Chief Executive Officer of CAISO that supported SCE’s

request.

DM1535032 2

II.

SCE’S REPLY TO TURN’S RESPONSE

A. TURN Calls DPV2 A Relative Bargain For Ratepayers

TURN eloquently summarizes its support for SCE’s Petition:

“TURN supported Edison’s initial application in this proceeding, based on evidence indicating that DPV2 would be a cost-effective addition to the electrical grid, and shares this Commission’s disappointment that regulatory approval of the Arizona portion of the project has not been forthcoming. TURN also generally supports SCE’s petition here to begin construction of the California portion of the line as a first stage, given the substantial interest in interconnecting with the DPV2 line that has been expressed by renewable energy developers, as well as some gas-fired projects.”1

“Compared with the other major transmission projects that have proposed in California to access new renewable generation (e.g.,Tehachapi, Sunrise), DPV2 appears to be a relative bargain in terms of the costs to ratepayers, even with the additional cost of over $100 million for inclusion of the Midpoint Substation.Moreover, the potential for the ultimate completion of the Arizona portion of the project offers the opportunity to maximize the use of the line not only for new renewable generation but also for imports of excess power from the Palo Verde hub.2

TURN, however, contacted SCE and suggested that it may be helpful to explain more fully, for

the benefit of parties who may not have been in the hearings, some background on the Desert

Southwest Transmission Project (“DSWTP”) and DPV2.

B. Background On The DSWTP

During DPV2 Phase 2 hearings, SCE was in discussions on a joint project arrangement

with another transmission project, called the DSWTP.3 The DSWTP is a proposed a 500 kV

1 TURN Response, p. 1. 2 Id.3 SCE, Tr. 6/417.

DM1535032 3

transmission line that would allow power from proposed new generation near Blythe to

interconnect with SCE’s Devers-Palo Verde No. 1 line (“DPV1”) and DPV2 at a new Midpoint

Substation or at SCE’s Devers substation. The majority of the new 118 mile 500 kV

transmission line would parallel DPV2 between Blythe and Devers Substation.4 The purpose of

the DSWTP transmission line was to bring generation from the Blythe area to SCE’s load

centers.

As described in the Commission’s Final EIR/EIS5, a Final EIR/EIS for DSWTP has been

completed and the BLM Record of Decision was published on September 15, 2006. The

DSWTP route from Blythe to Devers is in the same corridor as DPV2. A joint project would

have meant that only one 500 kV line would need to be built, instead of two 500 kV transmission

lines. The joint project would have required the construction of a 500 kV substation near Blythe

to connect and integrate the two proposed transmission projects. There was a slight difference

between SCE’s preferred location for the Midpoint Substation and the DSWTP preferred

location. Ultimately, the Commission determined both locations to be comparable and equally

environmentally preferable.6

SCE did not seek Commission approval of the Midpoint Substation at that time because

SCE was still in discussions on the joint project arrangement.7 Had SCE and DSWTP reached a

joint project arrangement, the Commission’s decision states that the transfer capability of DPV2

would have been expanded from 1,200 to 2,340 MW, through upgrading series capacitors on the

line.8 SCE would still turn over 1,200 MW of transfer capability to CAISO and the remainder of

the transfer capability would have been managed by Imperial Irrigation District (“IID”).9

If DPV2 had been constructed without the Midpoint Substation, SCE would have later

requested the Commission to authorize SCE to build the substation. Typically, a permit to

4 SCE, Tr. 6/416. 5 Ex. 35, Final EIR/EIS, Vol. 1, p. C-20. 6 See, Petition, p. 8. See also, Ex. 36, Final EIR/EIS, Vol. 2, Section E.2.1.3, p. E-12. 7 Ex. 35, Final EIR/EIS, Vol. 1, pp. C-22 to C-23. 8 D.07-01-040, mimeo., pp. 73-74. 9 Id.

DM1535032 4

construct is used to request Commission authorization to construct a substation. The permit to

construct involves only environmental impact issues. In hearings, SCE stated that there were

ongoing discussions that could have some impact on the cost, but that once SCE filed for

authorization to construct Midpoint, it would expect expedited relief as the environmental impact

of the Midpoint Substation was fully evaluated in the Final EIR/EIS, as well as in the

September 16, 2006, Record of Decision. The transcripts and the Commission’s decision reflects

the discussion.10

At this time, SCE and DSWTP are no longer in discussions on a joint project

arrangement. As TURN correctly states, the construction of Midpoint Substation in this Petition

is not part of the ‘integration’ of DPV2 and the DSWTP.

C. Proposed Language To Clarify That SCE Is Not Seeking To Construct the DSWTP

TURN points out that it may be helpful to clarify, for the benefit of the parties who were

not in hearings, that SCE is not seeking to avoid environmental review required by D.07-01-040

as related to the integration of DSWTP. Specifically, TURN cites the following language in

D.07-01-040:

“Neither SCE’s PEA nor the Final EIR/EIS for DPV2 addressed environmental impacts that would occur if DPV2 were integrated with the Desert Southwest project with system upgrades that would increase the transfer capability of DPV2 above 1,200 MW. We view possible integration of DPV2 and the Desert Southwest project as speculative at this time, and find that the Final EIR/EIS addressed the Desert Southwest project adequately. However, we note that an increase in the transfer capability of DPV2 may have impacts such as increases in corona noise and EMF that were not addressed in the Final EIR/EIS. We do not authorize SCE to construct the Midpoint substation at this time. If SCE and IID reach agreement regarding integration of DPV2 and the Desert Southwest transmission project, SCE must address environmental and other impacts of the proposed upgrade to DPV2 in any filing

10 D.07-01-040, mimeo., p. 74. See, e.g., Tr. 6/415- 419 and 449-452.

DM1535032 5

requesting Commission authorization to construct the Midpoint substation.”11

TURN notes that the decision includes similar language in Conclusion of Law 13,12 and

Ordering Paragraph (“OP”) No. 7.13 SCE agreed to provide clarifying language in response to

TURN’s Reply.

In this Petition, SCE is not seeking to integrate DPV2 and the DSWTP, and not seeking

to increase the transfer capability to 2340 MW. SCE is seeking to construct the Midpoint

Substation to provide a point of interconnection for the numerous proposed generation projects

in the Blythe area requesting to interconnect with SCE’s DPV1 and DPV2 lines. The Midpoint

Substation has already undergone environmental review in the Final EIR/EIS, and in the

September 16, 2006, BLM Record of Decision. Accordingly, the Commission may order SCE to

construct the Midpoint Substation without further environmental analysis.

To make this clearer, SCE’s suggests the following language:

Modify Ordering Paragraph No. 7, page 114-115 and the Corresponding Language in Conclusion of Law 13 (p. 110) As Follows:

7. If SCE requests Commission authorization to construct the Midpoint Substation or any other facilities related to integration of DPV2 and the Desert Southwest transmission project, SCE shall address environmental and other impacts of upgrades to DPV2 that would be undertaken to integrate DPV2 and the Desert Southwest transmission project.

To:

7. If SCE requests Commission authorization to construct the Midpoint Substation or any other facilities related to integration of DPV2 and the Desert Southwest transmission project, SCE shall address environmental and other impacts of upgrades to DPV2 that would be undertaken to integrate DPV2 and the Desert Southwest transmission project.

11 D.07-01-040, mimeo., p. 74. 12 D.07-04-010, mimeo., Conclusion of Law No. 13, p. 110. 13 Id., mimeo., OP No. 7, pp. 114-115.

DM1535032 6

7a. SCE’s Petition for Modification requests authorization to construct the Midpoint substation for the purposes of interconnecting the new generation projects that have been proposed in the area.

7.b. The proposed construction of Midpoint is not part of the potential integration of DPV2 and the DSWTP. SCE is authorized to construct the Midpoint Substation. The Midpoint Substation has already undergone environmental review and SCE’s request does not trigger the need for any additional environmental review.

III.

SCE’S REPLY TO DRA’S RESPONSE

A. Contrary to DRA’s Assertions, the Commission May Grant SCE’s Petition on an Ex

Parte Basis

SCE was surprised by DRA’s response. SCE met with DRA shortly after filing the PTM.

DRA indicated no problems at that time. SCE understood that DRA would not seek hearings,

and would like SCE’s petition to move forward a paper (ex parte) basis.

Although DRA does not explicitly request hearings, DRA states that it is concerned that

the Commission may be interested in examining the cost-effectiveness of a “California-only”

project. DRA states that there is no evidence in the record justifying allowing SCE to construct

the California portion of DPV2, before the Arizona project receives regulatory approval.14 DRA

recommends the Commission deny SCE’s Petition without prejudice, and allow SCE to resubmit

it after it receives, or does not receive, a permit from the Federal Energy Regulatory Commission

(“FERC”), or the Arizona Corporations Commission (“ACC”) for the DPV2 facilities in

Arizona.

As stated in SCE’s Petition, SCE’s request is due to the ACC decision denying a permit

to construct DPV2 facilities in Arizona. During the CPUC’s hearings, SCE did not expect that

14 DRA Response, p. 2.

DM1535032 7

the ACC would deny SCE’s request for permit to construct the facilities in Arizona, and SCE

shares in TURN’s and the Commission’s disappointment.

SCE believes the Commission may grant SCE’s request based on the existing record, and

the recent interconnection requests have made its case even more compelling. The substantial

numbers of renewable, pumped storage interconnection requests are in addition to the

conventional gas-fired generation interconnection requests that were discussed in the

Commission hearings, and make the need to construct the Midpoint Substation and DPV2

facilities in California compelling.

DRA loses sight of the fact that SCE is required by Federal law to interconnect with these

generators. The Energy Policy Act of 1993, and FERC’s Large Generator Interconnection

Procedures, which are incorporated into the CAISO Tariff, obligates SCE to interconnect these

generation resources. Simply put, Midpoint Substation is required to interconnect, and DPV2 is

required to deliver the power to load reliably.

DRA states that, on its face, SCE does not appear to seek a significant modification to

D.07-01-040.15 SCE agrees.

SCE is not seeking a significant modification of D.07-01-040. The Commission can

grant SCE’s requested relief based on the existing record. The Commission may grant SCE’s

petition to begin constructing the DPV2 facilities in phases on an ex parte basis. DPV2 has a

blend of renewable, ratepayer and reliability benefits, as discussed below. The Commission can

look comprehensively at the big picture and approve SCE’s request to construct the project in

phases based on the benefits, discussed below.


DM1535032 8

B. DPV2 Will Allow California to Access Proposed Renewable Energy Projects in the

Blythe Area

DRA states that it is concerned that SCE will build a “bridge to nowhere”.16 DRA’s

suggests that the fact that a renewable project is in the CAISO queue does not mean it will be

developed.17 DPV2 will not become a ‘bridge to nowhere’. DPV2 will be looped into the

Midpoint Substation with DPV1, as was described in the Final EIR/EIS, and will become part of

the SCE transmission network and the CAISO-Controlled Grid. Thus, DPV2 and Midpoint will

be used and useful. Moreover, SCE has already received a substantial number of interconnection

requests by proposed generators in the Blythe Area. At the time that SCE filed its Petition, on

May 14, 2008, SCE had received interconnection request representing 6228 MW, including

5128 MW of new renewable generation and 1210 MW of new conventional gas-fired generation

in the Blythe area.

SCE has now received interconnection requests representing 10,896 MW, including

8386 MW of new renewable generation, in addition to 1210 MW of new conventional gas-

fired generation and 1300 MW of hydroelectric pumped storage generation that is

proposed in the Blythe area, as supported by the revised declaration of Mr. Robert Lugo

(Attachment B) and shown in Table 1, below.

16 DRA Response, p. 6. 17 DRA Response, p. 6.

DM1535032 9

Table 1 New Generation Interconnection Requests In The Blythe Region

(MW)Renewable Midpoint 4629 Julian Hinds-Eagle Mountain Area 3757 Total Renewable 8386 Conventional & Pumped Storage MW Midpoint 2510 Total Requests to Interconnect Midpoint (4629 + 2510) 7139 Julian Hinds-Eagle Mountain Area 3757

Total 10896

California has among the most aggressive renewable goals in the country. The lack of

transmission is the major barrier to the development of a significant amount of new renewables.

Only to the extent that the marketplace believes that transmission will be built will the

developers begin to expend real dollars to develop their facilities.

It requires up to 10 years to license, permit, and construct a major transmission line in

California. If California does not construct transmission in the vicinity of renewable resources in

the interconnection queue, renewable power can not be delivered to load. And if transmission is

not constructed to deliver power to load, these projects will not be able get financing.

It appears DRA would suggest California do nothing,18 which will only result in the state

missing the opportunity to stimulate a significant amount of renewable power in this region.

Renewable projects in the Blythe area will not be developed unless they can deliver their energy

to customers. The Midpoint Substation is required to interconnect with the proposed generating

project and DPV2 is needed to bring this power to load reliably, as discussed below.

18 DRA Response, pp. 6 - 7. By this, SCE refers to a statement that SCE’s petition be denied and that SCE not submit its petition until it can provide evidence of the viability of renewables. DRA also seems to suggest that the Commission wait until after the FERC or ACC deny an application to permit the facilities in Arizona, before allowing SCE to submit a Petition.

DM1535032 10

C. Midpoint is Needed to Interconnect Generation in the Blythe Area and DPV2 Is

Needed to Bring the Power to Load Reliably

SCE is required to interconnect generation in the Blythe area. Under the Federal Power

Act and CAISO tariffs, SCE is required to interconnect its system to the wholesale generation of

a third party under the Large Generator Interconnection Process.19 The Midpoint Substation and

DPV2 facilities in California are needed to mitigate the reliability concerns created by the

anticipated integration of proposed generation in the Blythe area, as supported by the revised

declaration of Mrs. Dana Cabbell (Attachment C).

On June 12, 2008, the Yakout Mansour, President and CEO of CAISO, sent President

Peevey a letter that states that DPV2 is needed to mitigate the reliability concerns created by the

anticipated addition of the proposed generation in the Blythe area:

“A phased approach is consistent with the CAISO Governing Board’s directive to SCE to proceed with permitting and construction of DPV2. This is especially true given SCE’s continuing efforts to SCE to proceed with permitting and construction of DPV2. In addition, the Midpoint Substation, which was included in the Commission’s environmental review of DPV2, has been identified by the CAISO as needed, with or without DPV2, to access potential new generation in the Blythe area, including approximately 4000 MW of new renewable generation currently in the CAISO’s interconnection queue.”

The California facilities of DPV2 also mitigate reliability concerns on the CAISO grid otherwise created by the anticipated addition of generation in the Blythe area.” (Emphasis added.)20

19 CAISO tariff Section 8. See also, CAISO tariff at: http://www.caiso.com/1bf0/1bf0e846437e0.pdf. Pursuant to the Large Generator Interconnection Procedure (LGIP) in the CAISO tariff (Section 5.7.1) an Interconnection Customer shall submit to the ISO an Interconnection Request with a deposit. The ISO will forward a copy of the Interconnection Request to the applicable Participating TO receipt and apply the deposit toward the cost of an Interconnection Feasibility Study. After a feasibility and system impact study has been performed, SCE would be required to tender to the generator a Large Generator Interconnection Agreement, and required to commence interconnection activities pursuant to that agreement.

20 See, May 12, 2008, Letter from Yakout Mansour to President Peevey (Attachment D).

DM1535032 11

CAISO has stated that SCE is required to build Midpoint Substation to interconnect with

generation in the area--with or without DPV2. CAISO believes that DPV2 facilities in

California will be required to deliver the power from the Blythe area reliably. SCE agrees.

Some background may be helpful. A switchyard or substation is required to interconnect

generation near Blythe. Without a new switchyard or substation such as Midpoint Substation,

the proposed generation projects would have to construct extensive generation tie lines to

interconnect at either the Palo Verde hub or at the Devers Substation. The Commission reviewed

the potential need to interconnect at Midpoint Substation, due to the interconnection requests of

the conventional generation being developed in the Blythe area at that time. This subject was

vetted and is discussed in the Final EIR/EIS. It was well recognized that the substation would be

needed to interconnect generation in the area (at that time, the Blythe Energy Phase 2 Project,

also known as the “Blythe 2” project).

As a matter of clarification, Caithness Energy L.L.C is the parent of the Blythe 2

(generating) Project and the DSWTP. When DRA states that a 520 MW project that has reached

the permitting stage, DRA refers to the Blythe 2 project. The existing transcripts reflect that the

CAISO was reviewing the facilities and system impact studies on the Blythe 2 project, including

the need for the Midpoint Substation and the looping in of DPV2 and DPV1 to Midpoint

Substation.21 The CAISO has approved these studies. The Commission was also aware that

BLM had already granted a Record of Decision authorizing the DSWTP to construct Midpoint

Substation, and a 500 kV transmission line from Midpoint to Devers, in order to provide

improved transmission access to proposed new generation. There is ample evidence in the

existing record for the Commission to grant SCE’s request; the sheer numbers of interconnection

requests simply make the case more compelling.

21 Tr. 6/449 - 450. During Phase 2 hearings, ALJ Terkeurst conducted a significant amount of cross-examination regarding the Midpoint substation and was aware that system impact studies had been submitted to the CAISO.

DM1535032 12

In sum, the Commission should not adopt a “Do Nothing” approach. SCE is required to

build Midpoint Substation to interconnect generation in the Blythe area with DPV1 and DPV2.

DPV2 facilities are needed to deliver power from the Blythe area reliably to load.

D. DPV2 Benefits Ratepayers

DRA found that DPV2 would be cost-effective and provide significant economic benefits

for ratepayers and that DRA’s position has not changed. In this respect, DRA and SCE agree:

“SCE states that the cost-effectiveness of the DPV2 project has not changed; DRA believes this statement be fundamentally sound.”22

DRA suggests that perhaps the Commission may be interested in a showing of a benefit-cost

analysis of the project for California assuming the Arizona portion is not built. DRA does not

state that DRA itself is interested in providing such a showing, or even believes that one should

be performed. In fact, DRA appears to be arguing that such an analysis will cause significant

delay and may not even be feasible without knowing the viability and on-line date of these

renewable projects.

As DRA is aware, SCE does not know viability of the renewable projects at this time.

SCE does not control the renewable projects. The parties could litigate viability, but a key

element to project viability depends on when transmission is available to deliver the renewable

energy to customers.

IV.

CONCLUSION

SCE requests that the Commission grant SCE’s Petition in an ex parte basis. Evidentiary

hearing should not be necessary, since there are no apparent contested issues of material fact that

have not already been addressed in D.07-01-040. The CPUC has already issued a decision


DM1535032 13

authorizing SCE to construct DPV2. The Commission should now grant SCE’s petition to allow

SCE to construct DPV2 in phases.

For all the above reasons, SCE requests that the Commission modify D.07-01-040, as set

forth in Attachment A of this Reply.

Respectfully submitted,

MICHAEL MACKNESS JULIE A. MILLER

/s/ Julie A. Miller By: Julie A. Miller

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-4017 Facsimile: (626) 302-2610 E-mail: [email protected]

Dated: June 23, 2008

DM1535032 A-1

ATTACHMENT A

SCE’S REQUESTED CHANGES TO THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDERING PARAGRAPHS IN D.07-01-040

(Revised Ordering Paragraph No. 7 per Section II.C.)

SCE shows its requested changes below. Additions are shown underlined and deletions are

shown with strikeout.

Modify Conclusion of Law No. 8, pages 108-109 as follows:

8. Project approval should be conditioned upon construction according to the following

route.

SCE shall pursue permitting the DPV2 facilities in Arizona. If SCE receives

approval to construct DPV2 in Arizona either from the Arizona Corporation

Commission or the Federal Energy Regulatory Commission, SCE will construct

the DPV2 facilities in Arizona in accordance with the permit issued for the

Arizona facilities. It is expected that in In Arizona, the DPV2 project should

depart from either the Harquahala Generating Station switchyard or a new

Harquahala Junction. If the DPV2 project departs from the Harquahala

Generating Station switchyard, it should proceed east, paralleling the existing

Harquahala-Hassayampa 500 kV line for approximately five miles to its

intersection with SCE’s existing DPV1 route at the site of the proposed

Harquahala Junction. At this point, whether the route departs from the

Harquahala Generating Station switchyard or Harquahala Junction, the route

should be the same.

At its intersection with DPV1 at Harquahala Junction, the DPV2 route should

turn north (paralleling the DPV1 line) for approximately 2.4 miles to where it

should cross I-10, and then proceed 3.7 miles to a point northeast of Burnt

Mountain. From there the route should turn west and roughly parallel the north

side of I-10 and the Central Arizona Project Canal for approximately 20 miles

DM1535032 A-2

into La Paz County, then turn southwest, crossing to the south of I-10 and

proceeding approximately 5 miles to a point where it meets the El Paso Natural

Gas Company (EPNG) pipeline. The route should parallel the EPNG pipeline

and DPV1 for approximately 56 miles, across the Ranegras Plain where a series

capacitor bank should be constructed and through La Posa Plain. The route may

follow or deviate from SCE’s proposed route in the Kofa area. The route should

cross over Arizona Highway 95 and proceed into the Dome Rock Mountains to

the summit of Copper Bottom Pass. The route should turn southwest and descend

the western slope of the Dome Rock Mountains to reach the Colorado River.

SCE is authorized to construct the DPV2 facilities in California along the

following route. The route should cross the Colorado River into California and

generally follow the DPV1 right of way to SCE’s Devers substation. The route

should pass into the Palo Verde Valley, five miles south of Blythe, California and

should proceed westerly approximately ten miles to the top of the Palo Verde

Mesa. From that point on the Mesa, the route should turn northwest and continue

to a point approximately two miles south of the I-10 and five miles southwest of

the Blythe Airport, which is the site of the proposed Midpoint-DSW Substation.

From the Midpoint Substation, the route should turn northwest to a point two

miles south of I-10 and five miles southwest of Blythe Airport At this point, the

route should turn west following the DPV1 line to a point five miles east of

Desert Center. DPV2 should either follow the DPV1 route for 10.6 miles or the

North of Desert Center route for 11.8 miles north of I-10 and Desert Center to

avoid the Alligator Rock Area ACEC. On the west side of Alligator Rock ACEC

and south of I-10, the route should continue west for another 24 miles, passing a

site where a series capacitor should be constructed, to a point in Shavers Valley

where it should turn north and cross I-10 about two miles east of the Cactus City

Rest Stop. After crossing I-10, the route should continue west-northwest, parallel

to the DPV1 line for 46 miles to the Devers substation.

The route west of the Devers substation should leave Devers in a westerly

direction paralleling SCE’s existing Devers-Valley No. 1 line for 41.6 miles. The

DM1535032 A-3

route should cross into the San Bernardino National Forest and the Santa Rosa

and San Jacinto Mountains National Monument and parallel the Devers-Valley

No. 1 line westerly and southwesterly until it terminates at SCE’s Valley

substation.

Add Additional Finding of Fact to state:

__. SCE should be authorized to construct the Midpoint Substation.

Add Additional Finding of Fact to state

__. In total, renewable projects in the current CAISO queue for the Blythe area is 8386 MWs

in capacity. The DPV2 facilities in California would accommodate output from

anticipated renewable facilities near the proposed Midpoint and Julian Hinds-Eagle

Mountain substations near Blythe, California.

Modify Ordering Paragraph No. 2, pages 112-113 as follows:

2. SCE shall, as a condition of the CPCN, build the DPV2 project in accordance with the

following route:

SCE shall pursue permitting the DPV2 facilities in Arizona. If SCE receives

approval to construct DPV2 in Arizona either from the Arizona Corporation

Commission or the Federal Energy Regulatory Commission, SCE will construct

the DPV2 facilities in Arizona in accordance with the permit issued for the

Arizona facilities. It is expected that in In Arizona, the DPV2 project should

depart from either the Harquahala Generating Station switchyard or a new

Harquahala Junction. If the DPV2 project departs from the Harquahala

Generating Station switchyard, it should proceed east, paralleling the existing

Harquahala- Hassayampa 500 kV line for approximately five miles to its

intersection with SCE’s existing DPV1 route at the site of the proposed

Harquahala Junction. At this point, whether the route departs from the

Harquahala Generating Station switchyard or Harquahala Junction, the route

should be the same.

DM1535032 A-4

At its intersection with DPV1 at Harquahala Junction, the DPV2 route should

turn north (paralleling the DPV1 line) for approximately 2.4 miles to where it

should cross I-10, and then proceed 3.7 miles to a point northeast of Burnt

Mountain. From there the route should turn west and roughly parallel the north

side of I-10 and the Central Arizona Project Canal for approximately 20 miles

into La Paz County, then turn southwest, crossing to the south of I-10 and

proceeding approximately 5 miles to a point where it meets the El Paso Natural

Gas Company (EPNG) pipeline. The route should parallel the EPNG pipeline

and DPV1 for approximately 56 miles, across the Ranegras Plain where a series

capacitor bank should be constructed and through La Posa Plain. The route may

follow or deviate from SCE’s proposed route in the Kofa area. The route should

cross over Arizona Highway 95 and proceed into the Dome Rock Mountains to

the summit of Copper Bottom Pass. The route should turn southwest and descend

the western slope of the Dome Rock Mountains to reach the Colorado River.

SCE is authorized to construct the DPV2 facilities in California along the

following route. The route should cross the Colorado River into California and

generally follow the DPV1 right of way to SCE’s Devers substation. The route

should pass into the Palo Verde Valley, five miles south of Blythe, California and

should proceed westerly approximately ten miles to the top of the Palo Verde

Mesa. From that point on the Mesa, the route should turn northwest and continue

to a point approximately two miles south of the I-10 and five miles southwest of

the Blythe Airport, which is the site of the proposed Midpoint-DSW Substation.

From the Midpoint Substation, the route should turn northwest to a point two

miles south of I-10 and five miles southwest of Blythe Airport At this point, the

route should turn west following the DPV1 line to a point five miles east of

Desert Center. DPV2 should either follow the DPV1 route for 10.6 miles or the

North of Desert Center route for 11.8 miles north of I-10 and Desert Center to

avoid the Alligator Rock Area ACEC. On the west side of Alligator Rock ACEC

and south of I-10, the route should continue west for another 24 miles, passing a

site where a series capacitor should be constructed, to a point in Shavers Valley

where it should turn north and cross I-10 about two miles east of the Cactus City

DM1535032 A-5

Rest Stop. After crossing I-10, the route should continue west-northwest, parallel

to the DPV1 line for 46 miles to the Devers substation.

The route west of the Devers substation should leave Devers in a westerly

direction paralleling SCE’s existing Devers-Valley No. 1 line for 41.6 miles. The

route should cross into the San Bernardino National Forest and the Santa Rosa

and San Jacinto Mountains National Monument and parallel the Devers-Valley

No. 1 line westerly and southwesterly until it terminates at SCE’s Valley

substation.

Modify Ordering Paragraph No. 7, page 114-115 (and the corresponding language in

Conclusion of Law 13, page 110 as follows:

7. If SCE requests Commission authorization to construct the Midpoint Substation or any other

facilities related to integration of DPV2 and the Desert Southwest transmission project, SCE

shall address environmental and other impacts of upgrades to DPV2 that would be undertaken to

integrate DPV2 and the Desert Southwest transmission project.

Should be Changed to:

7. If SCE requests Commission authorization to construct the Midpoint Substation or any other

facilities related to integration of DPV2 and the Desert Southwest transmission project, SCE

shall address environmental and other impacts of upgrades to DPV2 that would be undertaken to

integrate DPV2 and the Desert Southwest transmission project.

7a. SCE’s Petition for Modification requests authorization to construct the Midpoint substation

for the purposes of interconnecting the new generation projects that have been proposed in the

area.

7.b. The proposed construction of Midpoint is not part of the potential integration of DPV2 and

the DSWTP, which would have increased the transfer capability of the line above the 1,200 MW

proposed by SCE. SCE is authorized to construct the Midpoint Substation. The Midpoint

Substation has already undergone environmental review and SCE’s request does not trigger the

need for any additional environmental review.

DM1535032 B-1

ATTACHMENT B

DECLARATION OF ROBERT J. LUGO

I, Robert J. Lugo, declare as follows:

1. I am Manager of the Grid Interconnect and Contract Development Group of

Southern California Edison Company’s (“SCE”), Transmission and Distribution Business Unit

and have held this position since October 2002. I have personal knowledge of the facts stated

herein and, if called as a witness, could and would competently testify thereto.

2. SCE has received interconnection requests representing 8386 MW of new

renewable generation, in addition to 1210 MW of new conventional gas-fired generation and

1300 MW of hydroelectric pumped storage generation that is proposed in the Blythe area, as

shown in the table below.

New Generation Interconnection Requests In The Blythe Region

(MW)Renewable Midpoint 4629 Julian Hinds-Eagle Mountain Area 3757 Total Renewable 8386 Conventional & Pumped Storage MW Midpoint 2510 Total Requests to Interconnect Midpoint (4629 + 2510) 7139 Julian Hinds-Eagle Mountain Area 3757

Total 10896

3. Since late 2007, renewable projects representing 4629 MW of generation

requested interconnection at the Midpoint Substation, in addition to 1210 MW of conventional

gas-fired generation and 1300 MW of hydroelectric pumped storage generation also proposing

interconnection at the Midpoint Substation. In total, requests received by SCE to interconnect

with the proposed Midpoint Substation equal 7139 MW.

DM1535032 B-2

4. Additionally, 3757 MW of new renewable power projects have requested

interconnection in the Julian Hinds and Eagle Mountain area. This is an area in the desert

approximately 50 miles from Blythe, California. The Julian Hinds Substation is located

approximately twelve miles from the Eagle Mountain Substation.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Executed this 23rd day of June, 2008 at Rosemead, California.

/s/ Robert J. Lugo Robert J. Lugo

DM1535032 C-1

ATTACHMENT C

DECLARATION OF DANA M. CABBELL

I, Dana M. Cabbell, declare as follows: 1. I am the Southern California Edison Company’s Manager of Transmission Intertie

Planning. I have personal knowledge of the facts stated herein and, if called as a witness, could

and would competently testify thereto.

2. My understanding is SCE has received interconnection requests representing

8386 MW of new renewable generation, in addition to 1210 MW of new conventional gas-fired

generation and 1300 MW of hydroelectric pumped storage generation that is proposed in the

Blythe area, as stated in the Declaration of Robert J. Lugo. Pursuant to the Energy Policy Act of

1993 and FERC’s Large Generator Interconnection Procedures, SCE is obligated to interconnect

these generation resources.

3. To the extent that the generation in the Blythe area develops, the California

portion of DPV2 would be needed to deliver the power to Southern California load centers.

Midpoint Substation will be needed to allow the potential new generation in the Blythe area to

interconnect with the Southern California transmission system.

4. It is my judgment that that the added transmission capacity from DPV2 will likely

be used by a renewable power project within a reasonable period of time.

5. The facts stated in Section III.B., on the reliability benefits are true and correct to

the best of my knowledge.

6. A true and correct copy of the letter from Yakout Mansour to President Peevey,

dated June 12, 2008, is attached to SCE’s Reply (Attachment D).

7. A true and correct copy of the May 16, 2008, CEO Report by Yakout Mansour,

President and CEO of CAISO is attached to SCE’s Reply (Attachment E).

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Executed this 23rd day of June, 2008 at Rosemead, California.

/s/ Dana M. Cabbell Dana M. Cabbell

DM1535032 D-1

ATTACHMENT D

JUNE 12, 2008, LETTER FROM MR. YAKOUT MANSOUR OF CAISO

DM1535032 E-1

ATTACHMENT E

MAY 16, 2008, CEO REPORT FROM YAKOUT MANSOUR OF CAISO

151 Blue Ravine Road Folsom, California 95630 (916) 351-4400

California Independent System Operator Corporation

MemorandumTo: ISO Board of Governors From: Yakout Mansour, President and Chief Executive Officer Date: May 16, 2008 Re: Updated CEO Report

This item does not require Board action.

Below are highlights of events affecting the California ISO since the date of the last meeting with the Board of Governors (“Board”).

Operations

In late April, we released the California ISO 2008 Summer Loads and Resources Operations Preparedness Assessment Report describing a wide range of possible supply and demand conditions this summer. The scenarios are based on three main variables that can change dramatically from one hour to the next during extreme conditions and include electricity demand, plant outage rates, and import levels. Our report finds that in most scenarios, there will be adequate electricity supplies to handle a broad range of operating conditions and maintain the reliability of the power grid, however, system operations may be challenged under extreme conditions. Voluntary conservation and demand response programs will be important this summer and will continue to serve an increasingly important role in subsequent years. We are also counting on the continued success and further refinement of the state’s Resource Adequacy program.

The summer assessment uses a deterministic analysis of planning and operating reserve margins and probabilistic analysis of operating reserve margins under high, medium and low import conditions. Of the twelve deterministic scenarios, the optimistic scenario assumes virtually full utilization of the import capability of 10,000 MW. Under this scenario, the ISO expects to have about 54,853 MW of total supply including 489 MW of new generation available this summer and 2,130 MW of demand response and interruptible load programs, resulting in an operating reserve of 16.5 percent. The normal operating reserves of 7 percent is expected to be achieved under a broad variation around the base case assumption. Naturally, the risk increases under extreme and less likely conditions and no system is expected to function normally under the very extremes. The ISO conducts the extreme case analysis to quantify the risk and develop the necessary mitigation measures to minimize the impact under those conditions. Conservation and demand response continue to be the most cost-effective tools to do so. Moreover, close communication with generators to ensure generation

fleet readiness, close coordination with our neighboring states to avail the transmission grid capability for the summer, and coordination with the load serving entities are very beneficial in our readiness efforts.

We are continuing our summer preparation efforts including discussing the assessment results with state agencies and working directly with generators, transmission owners, load-serving entities and other balancing authorities in the West to prepare for adverse conditions that may result in low operating reserves. The ISO is also integrating Cal Fire into the operator training workshops and continuing to partner with “Flex Your Power NOW!” that alerts consumers when energy demand is rising.

As California transitions to a vastly different electricity system responding to renewable resource, greenhouse gas emission, and water quality goals, careful management and greater public understanding of the benefits and challenges is required. To this end, our assessment provides a comprehensive review of various conditions to frame the challenges and focus management, industry and consumers efforts on the preparation and mitigation measures that will minimize possible impacts.

I am also pleased to report the ISO and Bonneville Power Administration (“BPA”) have reached an operating agreement between our Balancing Authorities. Over the years, we’ve had excellent cooperation from BPA regarding emergency operations. I’d like to thank both the ISO and BPA staff for their work on this significant accomplishment in formalizing our relationship in the west for continued successful emergency operations under the NERC reliability standards.

Market Redesign & Technology Upgrade (“MRTU”) Program

Significant progress has been made in integrating all the functionalities after a planned market simulation down time in early April. We are now reasonably comfortable with the overall functionality and the quality of solutions of the full system but the system robustness is of a concern when data entry issues are encountered. When all entries are in order, the systems perform well, but any glitch seems to cause execution problems instead of recognizing the issue at the front end. Our prime vendor continues to be challenged in resolving a number of accumulated related issues on time and is causing a lag in resolving our own system integration issues which, in turn, is causing an overall progress slowdown. We remain highly reliant on the competence and responsiveness of our prime vendor. A joint action plan has been reformed to address the issues and the progress is being closely monitored on an hour-by-hour basis. The Program Management believes that the early-Fall Go-Live date provides sufficient time to resolve all the outstanding issues and time needed for the market to prepare.

We received the initial assessment of LECG who is engaged to provide third party economic testing of the quality of pricing output. Their initial assessment indicates that the results are positive and that no “show stoppers” were identified. Further,we received certifications from a review performed by SAIC to test the continuity of the Tariff, requirements and systems to ensure alignment and that no material gaps existed between the three.

In summary, we will focus greatly on the system robustness over the next several weeks in parallel with supporting the market participants’ efforts in the simulation exercise and their readiness. I would like to take this opportunity to reaffirm ourappreciation for the tremendous efforts made by the public participants to get to a point of mutual comfort with the new system. It is not easy but an effort well spent.

Page 2

Compliance with Mandatory Reliability Standards

One of the highest priorities for the ISO this year is confirming and validating compliance with mandatory reliability standards. In pursuit of this priority, the ISO is devoting resources and staff time in a corporate-wide effort to ensure thateach individual standard is not only met but that there is appropriate evidence of the ISO’s compliance. This month, the ISO retained Deloitte & Touche to conduct a gap assessment and review of documentation and evidence of compliance with NERC reliability standards. The immediate focus of Deloitte’s review will be Critical Infrastructure Protection Standards and Transmission Planning Standards. We have also expanded our internal team this month by hiring a Senior Reliability Standards Compliance Specialist for Operations in the Mandatory Standards Compliance Department. The ISO’s internal audit team is also independently evaluating evidence of compliance, and has already completed audits of eight standards this year. Finally, the ISO is emphasizing the importance of the mandatory standards compliance program by providing training in the week-long Summer Workshop attended by all ISO operators this month.

Integrated Balancing Authority Area

I have informed the Board in my previous report in May that we decided to postpone seeking your approval that was scheduled for the last meeting to give another chance to the parties to close the gap with the proposal. We continued the stakeholder process and sought the advice of independent experts including the Market Surveillance Committee (“MSC”). Although we have modified our initial proposal to address the issues identified by the independent advisors, the opposing parties have largely maintained their position. While these parties have come forward with an alternative proposal, that proposal does not comprehensively address our objectives. Therefore, in light of our need to obtain final resolution of this issue prior to MRTU start up, we are coming to the Board today seeking your approval to move forward and file the proposal at FERC. Notwithstanding our need to move forward, we continue to be hopeful that further discussions with the opposing parties can be productive and we believe that such discussions can take place in parallel with the FERC process.

Generator Interconnection Queue Reform

As the Board is aware, the volume of interconnection requests in total number and capacity is an order of magnitude higher than what the state needs and well beyond commercial and physical viability. Ironically, the study process is often criticized for not keeping pace with the volume. It is obvious to everyone, including the regulators, that the entry, processing, and exit process ought to change and soon. Setting the course for a change in future requests is relatively an easier task than the existing process. We intend to propose changes to the process starting with a filing with FERC to waive certain requirements so we can expedite the processing of the current requests followed by a more comprehensive filing at a later date to revise the tariff that will govern the process in the future. Our request for waiver, if granted, willensure that the timeline for renewable interconnections, required to meet the 20 percent Renewable Portfolio Standard (“RPS”), is that of the transmission siting and the interconnection process will not be the critical path to meeting the legislated goal.

Devers-Palo Verde No. 2, 500 kV Transmission Line Update

On February 24, 2005, the Board approved the Devers-Palo Verde No. 2 (“DPV2”) project and directed Southern California Edison Company (“SCE”) to proceed with permitting and constructing the transmission project. The approval was based on findings that DPV2 will provide significant reliability and economic benefits to ISO ratepayers, improve system reliability, and enhance operational flexibility. The California Public Utilities Commission (“CPUC”) reached a similar conclusion in granting SCE a certificate of public convenience and

Page 3

necessity to construct DPV2. The Arizona Corporation Commission, however, denied the necessary approvals for SCE to build in that state. Notwithstanding the Arizona outcome, SCE remains committed to obtaining permitting approval for DPV2 facilities in Arizona and is pursuing all available options, including applying for federal transmission line siting as set forth in Section 1221 of the Energy Policy Act of 2005.

The ISO understands SCE intends to seek authority from the CPUC to phase the construction of DPV2 by moving forward with the California facilities. In addition, SCE is seeking permission from the CPUC to construct a “Midpoint Substation” near the California/Arizona border that will loop in the existing Devers-Palo Verde No. 1 transmission line as well as provide the interim terminus for the DPV2 line. The ISO’s directive to SCE to proceed with permitting and constructing DPV2 does not preclude a phased approach and a phased approach is consistent with SCE’s continuing efforts to obtain approval of the Arizona portions of the line. In addition, the Midpoint Substation has been identified by the ISO as needed, with or without DPV2, to access potential new generation in the Blythe area, including approximately 5,000 MW of new renewable generation currently in the ISO’s interconnection queue. The California facilities of DPV2 also mitigate reliability concerns on the ISO grid otherwise created by the anticipated addition of generation in the Blythe area.

San Francisco Action Plan Update

The San Francisco Action Plan (“Plan”) was developed by the City and County of San Francisco (CCSF), the California ISO, and other stakeholders and was approved by the ISO Board of Governors in 2004. The Plan established the conditions under which existing generation at Hunters Point and Potrero would be released from Reliability Must Run (“RMR”) contracts.

The Jefferson – Martin 230 kV Line, the Potrero – Hunters Point 115 kV Line, and other projects essential to removing RMR status from the Hunters Point power plant have been completed, and the plant was retired from service in 2006. The California ISO continues to support the San Francisco Action Plan, which provides for releasing Potrero from its RMR contracts when CCSF’s new peaking generation is placed into service. The ISO has been clear, as was the California Energy Commission in its 2006 licensing decision, that the area needs in-city generation in order to remove RMR status from the Potrero units and maintain reliable electric service to the area. This remains true even with the Trans Bay Cable in service.

CCSF continues to debate whether or not the new peaking units should be built. The CCSF Board of Supervisors could reach a decision on whether to approve financing and construction of new peaking units to replace the Potrero units between the time of this writing and the Board of Governor’s meeting on May 21st. I will update this report at the Board meeting.

Executive Leadership

As I reported in my last report, Armie Perez, Vice President of Planning and Infrastructure Development elected to retire effective May 9, 2008. Armie joined the ISO in August 1997 before start-up and joined the Executive Team in July 2005. I wish Armie and his wife Sue much success and happiness in the future. Again, I offer my sincere gratitude for Armie’s service and leadership and congratulate him on his great career and respected statesmanship.

Page 4

Other

I am pleased to announce that the California ISO received top honors as the 2008 Best Places to Work in Sacramento Region at the Sacramento Workplace Excellence Leader (SWEL) Awards event in April. More than 95 companies were nominated by their employees for this unique recognition as an extraordinary employer providing exceptional benefits, programs, training and workplaces that promote employee health, safety, advancement, diversity and security. Winning the region’s top workplace award means the California ISO will serve as a corporate model for other companies, showing how innovative people strategies can help organizations achieve tremendous success. I’d like to extend my thanks to the Human Resources team for work in positioning the California ISO to the forefront of workplace leaders.

People

The California ISO has 13 new hires that joined us in March, April and May. We have 2 budgeted vacancies. We are pleased to announce the following new hires: March

Anna Pascuzzo, Administrative Assistant, General Counsel & Corporate SecretaryMonica Mouanetry, Technical Assistant, Operations

April

Chetty Mamandur, Director, Grid Operation Development, OperationsTrang Vo, Critical Systems Analyst, Corporate Services Edward Gibbs, Manager, Applications Development, Corporate ServicesJessica Jouanicot, Technical Assistant, Corporate Services

May

Chantele Napper-Miro, Organizational Development Consultant, Human Resources Rod Crownover, Director, IT Support & Operations, Corporate ServicesQiuli Yu, Market Design Engineering Specialist, OperationsYuan Li, Associate Market Design Engineering Specialist, Operations Audley Grey, Market Design Engineering Specialist, Operations Zhu Liang, Associate Market Performance Analyst, OperationsJames Bonham, Senior Contract Engineering Specialist, Operations

Financial Highlights

Preliminary year-to-date revenues through April 2008 are $61.4M, $0.4 million higher than budget. The variance is primarily due to higher Grid Management Charge (“GMC”) revenues resulting from higher scheduled inter-zonal flows and higher use of markets. Preliminary year-to-date operating expenses through the same period are $52.9M, $0.5M lower than budget. The variance is primarily due to the timing of payments of invoices in the various expense categories.

Page 5

DM1535032

CERTIFICATE OF SERVICE

I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure,

I have this day served a true copy of REPLY OF SOUTHERN CALIFORNIA EDISON

COMPANY (U 338-E) TO RESPONSES ON PETITION FOR MODIFICATION OF

DECISION NO. 07-01-040 on all parties identified on the attached service list(s). Service was

effected by one or more means indicated below:

Transmitting the copies via e-mail to all parties who have provided an e-mail address. First class mail will be used if electronic service cannot be effectuated.

Executed this 23rd day of June, 2008, at Rosemead, California.

/s/ Veronica Flores Veronica Flores

Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

PROCEEDING: A0504015 - EDISON - CPCN CONCER FILER: SOUTHERN CALIFORNIA EDISON COMPANY (U338E) LIST NAME: LIST LAST CHANGED: JUNE 16, 2008

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ATTORNEY AT LAW ATTORNEY AT LAW THE UTILITY REFORM NETWORK (TURN) SHUTE, MIHALY & WEINBERGER, LLC 711 VAN NESS AVENUE, SUITE 350 396 HAYES STREET SAN FRANCISCO, CA 94102 SAN FRANCISCO, CA 94102 FOR: CITIES OF TEMECULA, HEMET, MURRIETTA LAURENCE CHASET MARION PELEO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION LEGAL DIVISION ROOM 5131 ROOM 4107 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA MARY F. MCKENZIE DAVID T. KRASKA CALIF PUBLIC UTILITIES COMMISSION ATTORNEY AT LAW LEGAL DIVISION PACIFIC GAS AND ELECTRIC COMPANY ROOM 5136 PO BOX 7442, 77 BEALE ST, B30A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94102-3214 FOR: PACIFIC GAS AND ELECTRIC COMPANY JOSEPH F. WIEDMAN EARL NICHOLAS SELBY ATTORNEY AT LAW ATTORNEY AT LAW GOODIN MACBRIDE SQUERI DAY & LAMPREY LLP LAW OFFICES OF EARL NICHOLAS SELBY 505 SANSOME STREET, SUITE 900 418 FLORENCE STREET SAN FRANCISCO, CA 94111 PALO ALTO, CA 94301-1705 FOR: GOODIN, MACBRIDE, SQUERI, RITCHIE FOR: GLOBAL ENERGY DECISIONS, LLC & DAY, LLP LINDA Y. SHERIF GEORGE FORMAN ATTORNEY AT LAW ATTORENYS AT LAW CALPINE CORPORATION FORMAN & ASSOCIATES 3875 HOPYARD ROAD, SUITE 345 4340 REDWOOD HIGHWAY, SUITE F228 PLEASANTON, CA 94588 SAN RAFAEL, CA 94903 FOR: CALPINE CORPORATION FOR: MORONGO BAND OF MISSION INDIANS BARRY F. MCCARTHY ANTHONY IVANCOVICH ATTORNEY AT LAW CALIFORNIA INDEPENDENT SYSTEM OPERATOR MCCARTHY & BERLIN, LLP 151 BLUE RAVINE ROAD 100 PARK CENTER PLAZA, SUITE 501 FOLSOM, CA 95630 SAN JOSE, CA 95113 FOR: BAY AREA MUNICIPAL TRANSMISSION GROUP (BAMX) GRANT A. ROSENBLUM ANDREW B. BROWN SENIOR COUNSEL ATTORNEY AT LAW CALIFORNIA INDEPENDENT SYSTEM OPERATOR ELLISON SCHNEIDER & HARRIS, LLP 151 BLUE RAVINE ROAD 2015 H STREET FOLSOM, CA 95630 SACRAMENTO, CA 95811 FOR: CAISO FOR: 3M COMPOSITE CONDUCTOR PROGRAM BRUCE MCLAUGHLIN STEVE MUNSON BRAUN & BLAISING P.C. VULCAN POWER COMPANY 915 L STREET, SUITE 1420 345 SW CYBER DRIVE, SUITE 103 SACRAMENTO, CA 95814 BEND, OR 97702 FOR: CALIFORNIA MUNICIPAL UTILITIES FOR: VULCAN POWER COMPANY ASSOC.

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WASHINGTON, DC 20006 CHRISTOPHER C. KEMPLEY LAURIE A. WOODALL CHIEF COUNSEL ASSISTANT ATTORNEY GENERAL ARIZONA CORPORATION COMMISSION ENVIRONMENTAL ENFORCEMENT SECTION 1200 W. WASHINGTON STREET 1275 W. WASHINGTON PHOENIX, AZ 85007 PHOENIZ, AZ 85007 STEVE OLEA TERESA MARTIN-POTTS ASST. DIRECTOR OF UTILITIES DIVISION OFFICE OF THE ATTORNEY GENERAL ARIZONA CORPORATION COMMISSION 1275 WEST WASHINGTON STREET 1200 W. WASHINGTON STREET PHOENIX, AZ 85007 PHOENIX, AZ 85007 FOR: PAD-EES JANICE ALWARD JIM VILLA ABRILLE ARIZONA CORPORATION COMMISSION UNIT 2 1200 WEST WASHINGTON 296 MEADOW VALLEY RANCH PHOENIX, AZ 85007-2996 ELKO, NV 89801 JACK MCNAMARA EDDIE WANG ATTORNEY AT LAW GLORIOUS LAND COMPANY, LLC MACK ENERGY COMPANY SUITE 530 PO BOX 1380 13181 CROSSROADS PARKWAY N. AGOURA HILLS, CA 91376-1380 CITY OF INDUSTRY, CA 91746 JIM KRITIKSON CASE ADMINISTRATION KRITIKSON & ASSOCIATES, INC. SOUTHERN CALIFORNIA EDISON COMPANY 1997 VIA ARROYO LAW DEPARTMENT, ROOM 370 LA VERNE, CA 91750 2244 WALNUT GROVE AVENUE ROSEMEAD, CA 91770 DONALD C. LIDDELL EDWARD SANDFORD ATTORNEY AT LAW 5169 HAWLEY BLVD. DOUGLASS & LIDDELL SAN DIEGO, CA 92116 2928 2ND AVENUE SAN DIEGO, CA 92103 KEVIN O'BEIRNE JAN STRACK SAN DIEGO GAS & ELECTRIC COMPANY 8316 CENTURY PARK COURT, CP52A 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92123-1582 SAN DIEGO, CA 92123 JOHN KALISH JULIAN VESELKOV UNITED STATES BUREAU OF LAND MANAGEMENT PO BOX 580453 PO BOX 581260 NORTH PALM SPRINGS, CA 92258 PALM SPRINGS, CA 92258 GLENN ELSSMANN RENEE SWITZKY MISSION DEVELOPMENT COMPANY 1534 VIA VERDE AVENUE SUITE C PALMDALE, CA 93550 25814 BUSINESS CENTER DR. REDLANDS, CA 92374 GLORIA D. SMITH BRUCE FOSTER ADAMS, BROADWELL, JOSEPH & CARDOZO SENIOR VICE PRESIDENT 601 GATEWAY BLVD., SUITE 1000 SOUTHERN CALIFORNIA EDISON COMPANY SOUTH SAN FRANCISCO, CA 94080 601 VAN NESS AVENUE, STE. 2040 SAN FRANCISCO, CA 94102 DIANE I. FELLMAN BERNARD LAM ATTORNEY AT LAW PACIFIC GAS AND ELECTRIC COMPANY FPL ENERGY, LLC 77 BEALE STREET, MAIL CODE B10C 234 VAN NESS AVENUE SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94102



JASON YAN MICHAEL S. PORTER PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MAIL CODE B13L 77 BEALE ST., MAIL CODE 13L RM 1318 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: PACIFIC GAS AND ELECTRIC COMPANY ROBERT KARGOLL PETER BRAY PACIFIC GAS AND ELECTRIC CO. PETER BRAY AND ASSOCIATES 77 BEALE ST., MC B13L RM. 1317 3566 17TH STREET, SUITE 2 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94110-1093 BRIAN T. CRAGG MARTIN A. MATTES ATTORNEY AT LAW ATTORNEY AT LAW GOODIN MACBRIDE SQUERI RITCHIE & DAY NOSSAMAN, GUTHNER, KNOX & ELLIOTT, LLP 505 SANSOME STREET, SUITE 900 50 CALIFORNIA STREET, 34TH FLOOR SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111-4799 JEFFREY P. GRAY CALIFORNIA ENERGY MARKETS ATTORNEY AT LAW 425 DIVISADERO ST. SUITE 303 DAVIS WRIGHT TREMAINE, LLP SAN FRANCISCO, CA 94117 505 MONTGOMERY STREET, SUITE 800 FOR: CALIFORNIA ENERGY MARKETS SAN FRANCISCO, CA 94111-6533 GRANT KOLLING BARRY R. FLYNN SENIOR ASSISTANT CITY ATTORNEY FLYNN RESOURCE CONSULTANTS, INC. CITY OF PALO ALTO 5440 EDGEVIEW DRIVE 250 HAMILTON AVENUE, 8TH FLOOR DISCOVERY BAY, CA 94514 PALO ALTO, CA 94301 FOR: FLYNN RESOURCE CONSULTANTS, INC. AVIS KOWALEWSKI DAVID MARCUS DIRECTOR OF REGULATORY AFFAIRS PO BOX 1287 CALPINE CORPORATION BERKELEY, CA 94701 3875 HOPYARD ROAD, SUITE 345 PLEASANTON, CA 94588 KEITH WHITE HELENE LEICHTER 312 KELLER ST ASSISTANT CITY ATTORNEY PETALUMA, CA 94952 CITY OF SANTA CLARA 1500 WARBURTON AVE. SANTA CLARA, CA 95050 KEN SIMS DEVRA WANG ELECTRIC DIVISION MANAGER STAFF SCIENTIST SILICON VALLEY POWER NATURAL RESOURCES DEFENSE COUNCIL 1601 CIVIC CENTER DR. NO. 201 111 SUTTER STREET, 20/F SANTA CLARA, CA 95050 SAN FRANCISCO, CA 95104 FOR: NATURAL RESOURCES DEFENSE COUNCIL C. SUSIE BERLIN THOMAS S KIMBALL ATTORNEY AT LAW MODESTO IRRIGATION DISTRICT MC CARTHY & BERLIN, LLP 1231 11TH STREET 100 PARK CENTER PLAZA, SUITE 510 MODESTO, CA 95352-4060 SAN JOSE, CA 95113 WILLIAM B. MARCUS ROBIN SMUTNY-JONES JBS ENERGY, INC. CALIFORNIA ISO 311 D STREET, SUITE A 151 BLUE RAVINE ROAD WEST SACRAMENTO, CA 95608 FOLSOM, CA 95630 CALIFORNIA ISO ED CHANG LEGAL AND REGULATORY DEPARTMENT FLYNN RESOURCE CONSULTANTS, INC. 151 BLUE RAVINE ROAD 2165 MOONSTONE CIRCLE FOLSOM, CA 95630 EL DORADO HILLS, CA 95762



JEFFERY D. HARRIS ATTORNEY AT LAW ATTORNEY AT LAW ELLISON, SCHNEIDER & HARRIS LLP ELLISON, SCHNEIDER & HARRIS 2015 H STREET 2015 H STREET SACRAMENTO, CA 95814 SACRAMENTO, CA 95811-3109 ORVETT W. SHELBY J. RICHARD LAUCKHART C/O RACHELLE SHELBY LOMAS GLOBAL ENERGY 8601 BIRCH LEAF COURT 2379 GATEWAY OAKS DRIVE, STE 200 SACRAMENTO, CA 95828-5001 SACRAMENTO, CA 95833 FOR: GLOBAL ENERGY KAREN MILLS PERRY ZABALA CALIFORNIA FARM BUREAU FEDERATION 92-1479 ALIINUI DR APT D 2300 RIVER PLAZA DRIVE KAPOLEI, HI 96707-2244 SACRAMENTO, CA 95833 DANIEL SUURKASK WILD ROSE ENERGY SOLUTIONS, INC. 430 8170 50TH STREET EDMONTON, AB T6B 1E6 CANADA

AARON J. JOHNSON BILLIE C. BLANCHARD CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DRA - ADMINISTRATIVE BRANCH ENERGY DIVISION ROOM 4102 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ENERGY DIVISION BRIAN D. SCHUMACHER DIANA L. LEE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION LEGAL DIVISION AREA 4-A ROOM 4107 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 KEITH D WHITE KENNETH LEWIS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ENERGY DIVISION AREA 4-A ROOM 4012 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 ROBERT ELLIOTT ROBERT KINOSIAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION EXECUTIVE DIVISION AREA 4-A ROOM 5202 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 SCOTT CAUCHOIS SCOTT LOGAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH ELECTRICITY PLANNING & POLICY BRANCH ROOM 4103 ROOM 4209 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA

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TIMOTHY J. SULLIVAN TRACI BONE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES LEGAL DIVISION ROOM 2106 ROOM 5206 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 SUSAN LEE LON W. HOUSE ASPEN ENVIRONMENTAL GROUP WATER & ENERGY CONSULTING 235 MONTGOMERY STREET, SUITE 935 4901 FLYING C RD. SAN FRANCISCO, CA 94104 CAMERON PARK, CA 95682 FOR: CPUC ENERGY DIVISION (CONSULTANT) HENRY ZAINIGER DARRELL FREEMAN ZECO, INC. 1304 ANTRIM DR. 9959 GRANITE CREST COURT ROSEVILLE, CA 95747 GRANITE BAY, CA 95746 CLARE LAUFENBERG KAREN GRIFFIN STRATEGIC TRANSMISSION INVESTMNT PROGRAM EXECUTIVE OFFICE CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS 46 1516 9TH STREET, MS 39 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 KEVIN WOODRUFF MARK HESTERS WOODRUFF EXPERT SERVICES, INC. CALIFORNIA ENERGY COMMISSION 1100 K STREET, SUITE 204 1516 9TH STREET, MS 46 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CALIFORNIA ENERGY COMMISSION THOMAS FLYNN JUDY GRAU CALIF PUBLIC UTILITIES COMMISSION CALIFORNIA ENERGY COMMISSION ENERGY DIVISION 1516 NINTH STREET MS-46 770 L STREET, SUITE 1050 SACRAMENTO, CA 95814-5512 SACRAMENTO, CA 95814 FOR: CALIFORNIA ENERGY COMMISSION

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BEFORE THE PUBLIC UTILITIES COMMISSION OF … project arrangement, the Commission’s decision states that the transfer capability of DPV2 would have been expanded from 1,200 to 2,340