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UNITED STATES OF AMERICA BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Southern California Edison Company ) Docket No. ER13-1216-001

PREPARED DIRECT TESTIMONY AND EXHIBITS OF

JORGE CHACON

ON BEHALF OF

SOUTHERN CALIFORNIA EDISON COMPANY

DECEMBER 5, 2013




SUMMARY OF THE PREPARED DIRECT TESTIMONY OF

JORGE CHACON

(EXHIBIT NO. SCE-5)

The direct testimony of Mr. Chacon provides his understanding of Section 25.1 of the CAISO Tariff, the reasons that Southern California Edison Company (“SCE”) has only provided CalWind Resources, Inc. (“CalWind”) a generator interconnection agreement that reflected the existing generating capacity of its Pajuela Peak Project, and the impacts on other generators were SCE to treat CalWind as if it had a right to 37.5 MW of interconnection capacity.

Mr. Chacon first explains why Section 25.1 ensures reliability and safety by requiring generators whose capability and electrical characteristics are changing to submit an Interconnection Request, which allows such impacts to be studied and analyzed. Exh. SCE-5 at 3-7. Mr. Chacon also describes why it would not be prudent for SCE to allow CalWind to increase the size of its project by about 17 MW without additional analysis. Id. at 8-12. He explains that the existing Pajuela Peak Project has been modeled at only 22 MW since at least 1999. Id. at 12-13. Mr. Chacon also describes some of the communications he had with CalWind regarding SCE’s position regarding CalWind’s claimed right to 37.5 MW of interconnection capacity. Id. at 13-16. He also notes that SCE previously (in the 1990s) informed CalWind that it was not entitled to 37.5 MW of interconnection capacity. Id. at 15-16; see also Exh. SCE-8. Finally, Mr. Chacon explains the impacts of an assumption that CalWind has a right to a greater amount on interconnection capacity. Such an assumption would impact other queued generators by rendering their study results erroneous. Id. at 16-18.

LIST OF EXHIBITS

Exhibit Description

SCE-5 Direct Testimony

SCE-6 Affidavit of Jorge Chacon & Attachments previously submitted in Dkt. No. ER13-1216

SCE-7 January 3, 2013 SCE-CAISO-CalWind Meeting Minutes

SCE-8 1999 Letters from SCE to CalWind

Dkt. No. ER13-1216-001 Exh. SCE-5

Page 1 of 18




PREPARED DIRECT TESTIMONY OF JORGE CHANCON

I. INTRODUCTION 1

Q: Please state your name, business address, and title for the record. 2

A: My name is Jorge Chacon and my business address is 3 Innovation Way, 3

Pomona, California 91768. I am the Generation Interconnection Planning 4

Manager in the Transmission and Distribution Business Unit at Southern 5

California Edison Company (“SCE” or “Company”). 6

Q: Briefly describe your educational and professional background. 7

A: I obtained my Bachelor of Science degree in Electrical Engineering from 8

California State Polytechnic University, Pomona, in 1997. I joined SCE as an 9

Engineer Trainee in the Research Department in 1997. In 1998, I transferred 10

to the Transmission Interconnection Planning Department as a Transmission 11

Planner. During the next five years, my primary responsibilities involved 12

planning the high voltage transmission system in order to meet load growth 13

requirements. In April 2002, I left SCE and joined a consulting firm where my 14

primary responsibilities were to provide technical support to a number of 15

Dkt. No. ER13-1216-001 Exh. SCE-5

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utilities including SCE. In November 2003, I returned to SCE’s Transmission 1

Interconnection Planning Department as a senior transmission planner with 2

primary responsibilities for developing new large scale transmission projects 3

including the Tehachapi Renewable Transmission Project. In February 2007, I 4

was promoted to Project Manager with primary responsibilities for managing 5

the planning of new large scale transmission projects. In November 2011, I 6

became the manager of the Generation Interconnection Planning Group. 7

Q: Have you submitted testimony to the Commission previously? 8

A: I have submitted affidavits in a variety of cases and have submitted testimony 9

in Docket No. ER07-1034. 10

Q: What is the purpose of your testimony? 11

A: The purpose of my testimony is to: 12

1. Provide my understanding of Section 25.1 of the CAISO Tariff 13

and some background regarding the parties’ dispute; 14

2. Explain from an engineering and planning perspective SCE’s 15

position that it could only provide CalWind Resources, Inc. 16

(“CalWind”) a generator interconnection agreement that reflected 17

the existing generating capacity of its Pajuela Peak Project and 18

would have to study and queue any greater amount of capacity; 19

and 20

3. Describe the impacts on other generators were SCE to treat 21

CalWind as if it had a right to 37.5 MW of interconnection 22

capacity. 23

Dkt. No. ER13-1216-001 Exh. SCE-5

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II. APPLICATION OF THE INTERCONNECTION CONVERSION 1

PROCESS TO CALWIND’S PAJUELA PEAK PROJECT 2

A. BACKGROUND 3

Q: Ms. Myers has testified that Section 25.1.2 of the California Independent 4

System Operator Corporation Tariff (“CAISO Tariff”) provides that an 5

already-interconnected generator that seeks FERC-jurisdictional 6

interconnection service can only avoid having to submit an 7

Interconnection Request if it submits an affidavit representing the total 8

capability and electrical characteristics of the Generating Unit will be 9

substantially unchanged and that representation is verified. Did CalWind 10

submit an affidavit under the Section 25.1.2 procedure? 11

A: Yes, and Ms. Myers has included it as Exhibit No. SCE-2 (“CalWind 12

Affidavit”). I am one of the persons at SCE responsible for verifying the 13

information in such affidavits. 14

Q: Before we discuss your role regarding SCE’s review of the CalWind 15

Affidavit, can you explain your understanding of the purpose of the “total 16

capability and electrical characteristics of the Generating Unit will be 17

substantially unchanged” test in CAISO Tariff Section 25.1.2? 18

A: The CAISO Tariff provisions recognize that if an already-interconnected 19

generator is not changing its capability or characteristics, the conversion from 20

Dkt. No. ER13-1216-001 Exh. SCE-5

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state to FERC jurisdiction should typically be a matter of paperwork,1 i.e., 1

entering into a replacement agreement. If there are changes in total capability 2

or electrical characteristics, unless such changes would have negligible impacts 3

that do not require further analysis, an Interconnection Request must be 4

submitted. The reason an Interconnection Request must be submitted if a 5

change is occurring is that such request allows SCE and the CAISO to start the 6

interconnection study process, which is used to determine the impacts of the 7

change on the electric system. The nature of the impacts depends to some 8

extent on existing generators and new generators currently seeking 9

interconnection via both the FERC- and state-jurisdictional interconnection 10

processes. 11

Q: Can you provide an example of how the substantially unchanged test 12

would be applied? 13

A: If an existing Generating Unit already interconnected to the electric grid 14

decided to repower in conjunction with the conversion, the application of the 15

substantially unchanged test would involve comparing all electrical aspects of 16

the existing generating project against those of the repowered project. 17

Generally, a repowered project could be converted without the need to perform 18

1 If a generator is participating in CAISO markets post-conversion, metering and telemetry requirements also may be imposed that must be addressed. CAISO Tariff Section 25.1 does not address such issues.

Dkt. No. ER13-1216-001 Exh. SCE-5

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detailed system impact studies if there are no expected impacts to: power flow 1

(i.e., the project is remaining the same net size), post-transient voltage and 2

transient stability (i.e., the project is deploying similar technology), or short-3

circuit duty (i.e., the project has similar electrical characteristics). In contrast, 4

a repowered project that increases its net size, changes project technology, or 5

changes electrical characteristics would not meet the test. It would need to 6

have a detailed study performed to identify potential power flow impacts 7

and/or identify potential post-transient voltage, transient stability, and/or short-8

circuit duty impacts. 9

Increases in generating project size would not pass the “substantially 10

unchanged test.” An increase in size would mean an increase in power flows 11

which could create adverse impacts that translate to reliability problems not 12

previously identified in any current study. A change in project technology 13

likely would not meet the test because the use of a different technology could 14

result in voltage stability or short-circuit duty impacts not previously identified 15

in any current study which utilized the previous project models. In general, the 16

addition of new facilities, i.e., facilities that currently do not exist, usually rises 17

to the level of a “substantial change” as none of the existing base case models 18

reflect such new facilities. As a consequence, a study is necessary to ensure 19

system reliability and to maintain the safety of SCE personnel. 20

Dkt. No. ER13-1216-001 Exh. SCE-5

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Q: Do you think Section 25.1.2 is a reasonable provision from an engineering 1

and planning perspective? 2

A: Yes. If a generating project exists and wishes to convert from a state-3

jurisdictional interconnection to a FERC-jurisdictional interconnection and the 4

owner or operator makes no change to such existing interconnected project, 5

which presumably is appropriately modeled into the starting base case, then 6

there is no need to perform a detailed study, such as a system impact study, 7

because the project’s impacts are already known and embedded into the base 8

case models. However, if the generating project is changing and the changes 9

are not modeled in the base cases, then a detailed study must be undertaken to 10

identify if there are any impacts associated with such change. By requiring a 11

generator that cannot meet the test to submit an Interconnection Request, such 12

studies will be performed that appropriately take into account all active 13

generating projects currently seeking interconnection via the interconnection 14

process that have an equal or higher queue position. 15

Q: Under the “substantially unchanged” standard, how would you treat an 16

affidavit submitted under Section 25.1.2 that indicated that there was to 17

be an increase in generating capacity, as compared to the existing 18

generating capacity that already was interconnected? 19

A: As noted above, I would consider effectively any increase in the generating 20

capacity to mean that the total capability and electrical characteristics of the 21

Dkt. No. ER13-1216-001 Exh. SCE-5

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Generating Unit will not be substantially unchanged. The increase in the net 1

capacity increases the power flows on the system which may have a 2

detrimental impact not previously identified. Such impacts include the 3

potential for line and transformer bank loadings in excess of maximum 4

allowable loading limits under normal operating conditions. 5

Q: Do you mean a 1 kW increase in capacity would be a substantial change? 6

A: I do not believe it fruitful to debate whether there should be a de minimis 7

exception for very small increases. The facts here involve a proposed increase 8

of about 17.5 MW above the current capacity of the Pajuela Peak Project and a 9

15 MW increase above the capacity at the site that was in place until late 10

March 2013. 11

Q: Does any decrease in capacity likewise result in substantial change? 12

A: As demonstrated by this very case, no. CalWind evidently decreased Pajuela 13

Peak’s capacity between March 28, 2012 and March 29, 2013 by about 2 MW 14

by physically removing a few wind turbines. That change does meet the 15

substantially unchanged test. In general, the system was robust enough to 16

support a generating project with a net capacity of 21.795 MW, including the 17

now removed turbines, and remains robust enough to support the remaining 18

19.355 MW in net capacity. None of the remaining turbines were changed so 19

there was no material impact associated with the removal of these few existing 20

generation units. 21

Dkt. No. ER13-1216-001 Exh. SCE-5

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B. SCE’S POSITION REGARDING THE CONVERSION 1

Q: Describe your role generally in the interconnection conversion process as 2

applied to the Pajuela Peak Project. 3

A: I am the manager of the Generation Interconnection Group, which evaluates all 4

the generation requests into the Antelope, Bailey, and Windhub 66 kV 5

systems. I oversee all the generation conversion assessments, including the 6

Pajuela Peak Project. 7

Q: When did you first become aware that there was an issue regarding the 8

correct quantity of interconnection capacity to reflect in the Generator 9

Interconnection Agreement (“GIA”) for CalWind’s Pajuela Peak Project, 10

which had requested a conversion? 11

A: I became aware that there was an issue regarding the correct quantity in 12

approximately May of 2012. At that time, I understood that CalWind, which 13

owned the Pajuela Peak Project, was claiming in an affidavit that it had a 14

“power purchase capacity” of 21.795 MW and a 22.36 MW gross capacity. 15

CalWind claimed that it was entitled to a GIA that would allow it to 16

interconnect up to 37.5 MW of generating capacity. I understood CalWind 17

was making this claim based on a power purchase agreement (“PPA”) and 18

Interconnection Facilities Agreement (“IFA”) dating back to the 1980s. In 19

effect, CalWind believed that it had “reserved” 37.5 MW of interconnection 20

capacity for the Pajuela Peak Project. CalWind stated in the CalWind 21

Dkt. No. ER13-1216-001 Exh. SCE-5

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Affidavit that it did not believe it was required to submit an Interconnection 1

Request unless its project exceeded 37.5 MW. See Exh. SCE-2 at 2. 2

Q: Could you verify based on the CalWind Affidavit that the total capability 3

and electrical characteristics of the Pajuela Peak Project would be 4

substantially unchanged? 5

A: No. The CalWind Affidavit implied that CalWind might increase the size of 6

the existing generating project to 37.5 MW. Indeed, CalWind provided SCE 7

information confirming such expansion plans. I have explained why such an 8

increase must be studied to ensure safety and reliability and would not pass the 9

substantially unchanged test. 10

Q: Based on your knowledge of the existing transmission facilities in the 11

relevant region, could a 37.5 MW Pajuela Peak Project have been safely 12

and reliably interconnected in the 1980s, i.e., when it was first planned? 13

A: Based on my review of documents, it appears that CalWind never constructed 14

necessary facilities on its side of the point of change in ownership to allow it to 15

interconnect a generating project of that size; although the facilities on the SCE 16

side of the interconnection would have allowed a generator of that size to 17

interconnect at the time. The relevant facilities that are installed include a 66 18

kV dead-end structure, a 66 kV line span that comes across the fence from the 19

customer-owned facilities, a 66 kV line that connects to the existing Cal 20

Cement-Monolith-Rosamond-Windfarm 66 kV line, a 66 kV line drop, a 66 21

Dkt. No. ER13-1216-001 Exh. SCE-5

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kV circuit breaker, 66 kV line disconnects, corresponding line protection, and 1

metering. These facilities are shown as the SCE’s Arbwind Substation in the 2

figure included as Attachment 2 to the Affidavit that I previously submitted in 3

this case. I am including that Affidavit and its Attachments as Exhibit No. 4

SCE-6, 5

Notably, these are the exact same facilities that SCE would have 6

installed had CalWind sought to interconnect a project of the size that was 7

actually constructed – which project had a net capacity of 21.795 MW (until 8

March 2013). The exact size of the generator was not particularly relevant to 9

the specific facilities needed to support the interconnection of Pajuela Peak to 10

the 66 kV system. The very same set of equipment would have been installed 11

for a project ranging from 10 MW to 68 MW due to the lumpy nature of 12

equipment size (i.e., equipment ratings). In other words, the limiting factor at 13

SCE’s Arbwind Substation is a 600 Amp disconnect, which equates to 14

approximately 68 MVA, meaning that a 68 MW generator could have been 15

interconnected at the time using the same equipment if downstream capacity 16

was available. 17

Dkt. No. ER13-1216-001 Exh. SCE-5

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Q: Putting aside the CAISO Tariff, if SCE planned for a 37.5 MW generator 1

to be interconnected in the 1980s, why can’t CalWind increase the size of 2

Pajuela Peak to 37.5 MW without the need for further analysis? 3

A: Such analysis is required because, at some point after a generating project is 4

built, SCE eventually updates its models to reflect the size of the actual project 5

that is constructed. And, that happened with regard to Pajuela Peak; the model 6

was evidently changed due to the fact that the project built was not 37.5 MW. 7

As an interconnection planner, I would expect that SCE, for some time period, 8

was expecting that the final phase of the project would be finished and that it 9

planned its system accordingly. But, at least since 1999, up to the date when 10

SCE was informed that the Pajuela Peak Project actually would be reduced in 11

size (to a net capacity of 19.355 MW), SCE and the CAISO had modeled the 12

project as a 21.795 MW project, a figure that is often rounded off to 22 MW. 13

As a result of this change in assumption, capacity that was previously assumed 14

to be used by Pajuela Peak was released for use by other generators. 15

Q: Do you know when the model was changed to reflect the smaller-sized 16

project? 17

A: Today, an update to the model is made upon submittal of final as-built 18

information from the interconnection customer. But, having only joined the 19

company in the late 1990s, I do not know the process used to update models if 20

a generating project’s size was smaller than originally planned back in the late 21

Dkt. No. ER13-1216-001 Exh. SCE-5

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1980s, early 1990s. I am aware, as a result of this litigation, that the progress 1

of qualifying facilities was monitored by the Company in conjunction with 2

requirements that such entities meet milestones to retain their interconnection 3

priority. 4

Q: Given that the Pajuela Peak Project was modeled at about 22 MW for 5

more than a decade, what concerns would you have if CalWind simply 6

increased the size of the plant without any additional analysis? 7

A: The increase in the net capacity would increase the power flows which creates 8

the potential for line and transformer bank loadings in excess of the maximum 9

allowable loading limits under normal operating conditions. Such an overload 10

would potentially create the need to disconnect equipment in order to operate 11

the system within allowable limits. Such requirement could result in 12

burdensome reliance on system operator intervention and could increase risk of 13

local cascading outages if operator action was not performed timely. Also, any 14

changes to the electric representation driven by changes to generating units 15

might result in adverse impacts to short-circuit duty and system voltage 16

performance. These types of impacts could result in unplanned and 17

uncontrolled loss of sensitive customer load demand at two large cement plants 18

as well as a high-security prison facility served in the local area. 19

Dkt. No. ER13-1216-001 Exh. SCE-5

Page 13 of 18

Q: Do SCE and CAISO documents demonstrate that the modeling 1

assumption being used was that the Pajuela Peak Project was about 22 2

MW? 3

A: Yes. Attached as Exhibit No. SCE-6 is the Affidavit that I previously 4

submitted in this case describing and providing examples of the documents that 5

I found relating to the historic assumptions about Pajuela Peak. As discussed 6

in the Affidavit, the fact that SCE, for more than a decade, had been modeling 7

Pajuela Peak at 22 MW should have been fully understood by CalWind. 8

Q: Did you attend a meeting to discuss the situation regarding the 9

appropriate capacity for the GIA? 10

A: I attended a meeting with the relevant parties on January 3, 2013 at which the 11

issue of the appropriate interconnection capacity quantity was discussed. The 12

minutes are attached as Exhibit No. SCE-7. I would note that neither legal 13

counsel nor SCE regulatory personnel were present. By the time of the 14

meeting there already had been some back and forth regarding the appropriate 15

quantity of MW. I relayed at that meeting that one “problem” with simply 16

providing CalWind a GIA for 37.5 MW was “queued-behind projects.” By 17

that, I meant that SCE had long modeled CalWind’s Pajuela Peak Project as an 18

approximately 22 MW net capacity generator and that studies analyzing other 19

generator interconnection requests included that assumption. Downstream 20

system limitations impact the amount of additional capacity that could be 21

Dkt. No. ER13-1216-001 Exh. SCE-5

Page 14 of 18

interconnected without the installation of additional facilities. Generators in 1

the queue were now assumed to have a need to use certain facilities, such that 2

an increase in the size of Pajuela Peak would require analysis to see if 3

additional facilities were required. In particular, SCE explained at that meeting 4

which already-queued projects were assumed to have a need for transformer 5

bank capacity that would impact CalWind’s cost responsibility for an 6

additional transformer bank that could be triggered if a certain quantity of such 7

queued projects remained in the queue. 8

Q: But isn’t it SCE’s position that existing Generating Units are what 9

matters? Why is SCE setting aside capacity for generators based on the 10

fact that they are in queue if such generators do not exist? 11

A: Once an Interconnection Customer submits a completed Interconnection 12

Request, its generation project would be included in models analyzing it and 13

other generators that are in the same cluster. Also, analysis of later clusters or 14

later-queued generators would include such queued projects. A proposed 15

generating project would be removed from models that are used if it either 16

withdraws from the process (including CAISO deeming it withdrawn) or 17

terminates its GIA. Of course, if the generator is actually completed, it 18

remains in the model. 19

Dkt. No. ER13-1216-001 Exh. SCE-5

Page 15 of 18

Q: According to the meeting minutes (Exh. SCE-7), CalWind’s consultant 1

made the point that CAISO and SCE began conducting studies using an 2

operating capacity of approximately 22 MW for its project without 3

informing the owners of Pajuela Peak Project. Do you agree with that 4

statement? 5

A: I cannot claim that either the CAISO or SCE specifically sent a notice to the 6

owners of the Pajuela Peak Project (i.e., CalWind) as to what was being 7

included in studies, but CalWind officers did attend meetings where documents 8

made it clear what SCE and the CAISO were assuming, as I described in my 9

prior affidavit and attachments. See Exh. SCE-6. I also take issue with the 10

statement because, as a result of this dispute, SCE has located documents that 11

indicate that it previously informed CalWind of the same position that it is 12

taking here – that an increase in generating capacity at Pajuela Peak above 13

21.795 MW would require a new interconnection request. Exh. SCE-8. 14

Although these letters may not have clearly stated what assumptions were 15

being made, they rather clearly indicate that CalWind has known since 1999 16

that SCE was not “reserving” 37.5 MW of interconnection capacity based on 17

any agreements in existence at the time. 18

Dkt. No. ER13-1216-001 Exh. SCE-5

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Q: Are you aware of any information that indicates that a generator with a 1

larger net capacity than 21.795 MW ever was installed and interconnected 2

at the relevant site? 3

A: I am not aware of any such information. As mentioned above and in my prior 4

affidavit (Exh. SCE-6), the facilities on CalWind’s side of the interconnection 5

would not currently support a plant much larger than the one installed due to 6

the size of the customer-owned transformer at the Arbwind substation. At the 7

meeting, CalWind did not claim that a larger generator had ever existed. 8

Q: Did the meeting result in any resolution of the matter relating to the 9

capacity size? 10

A: No. Ideas were discussed, but it soon became clear that the parties were at 11

impasse. 12

Q: Did CalWind later indicate that it intended to reduce the size of the 13

Pajuela Peak Project from 21.795 MW to less than 20 MW before it 14

planned to increase its size to 37.5 MW? 15

A: During GIA negotiations, CalWind explained that it was disabling certain 16

turbines to reduce the size of its facility further. CalWind informed SCE that it 17

intended to reduce the net generating capacity at Pajuela Peak to 19.355 MW. 18

Dkt. No. ER13-1216-001 Exh. SCE-5

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III. IMPACTS OF ASSUMING THAT CALWIND HAS A RIGHT TO 37.5 1

MW OF INTERCONNECTION CAPACITY 2

Q: If SCE had assumed that the Pajuela Peak Project’s final phase would 3

someday be completed and had modeled it at 37.5 MW, would that 4

assumption have affected generators currently in the queue or that 5

already have been constructed? 6

A: The transmission facilities that were in place prior to the completion of SCE’s 7

East Kern Wind Resource Area (EKWRA) Project were inadequate to 8

accommodate an incremental 17 MW at Pajuela Peak as well as all the existing 9

wind generation resources that are interconnected. That is, had Pajuela Peak 10

always been assumed to be 37.5 MW, some already-interconnected generating 11

projects likely would have had to bear the cost of additional upgrades (or they 12

may have chosen a different location if such upgrades were considered too 13

costly). The EKWRA Project, which is nearing completion, has created 14

additional transmission capacity which allows for additional generation 15

resources to be interconnected to the system. Such additional capacity, 16

however, has been allocated to proposed generation projects which have 17

submitted interconnection requests, as reflected in their study results. Had 18

SCE used a 37.5 MW assumption regarding the size of Pajuela Peak the study 19

results for certain generators in the queue would be quite different. In 20

particular, it is known that such a change in assumptions would impact which 21

Dkt. No. ER13-1216-001 Exh. SCE-5

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generator in queue would trigger the need for an additional transformer bank 1

capacity at the Windhub Substation. 2

Q: Can you explain that further? 3

A: If it is assumed that Pajuela Peak is a 37.5 MW project, then some of the 4

available capacity created by EKWRA would no longer be available for 5

projects seeking interconnection but instead would be allocated to Pajuela 6

Peak. Such reduction in available capacity would mean that a project in queue 7

would no longer be able to interconnect without upgrades if such project were 8

previously the last one to “squeeze in” without causing an upgrade. Also, a 9

project in queue that was previously identified as triggering an upgrade (as it 10

was later-queued than the last project to squeeze in) would no longer be the 11

triggering project for the upgrade. The result would be a shifting of cost 12

responsibility among various projects. In sum, it is quite disruptive to the 13

interconnection planning process to declare that a batch of prior studies 14

produced erroneous results. 15

Q: Is it correct to say, until the plans of already-queued generators solidify, it 16

is unclear which generator(s) might be impacted? 17

A: Yes. 18

Q: Does this conclude your testimony? 19

A: Yes, it does. 20

Exhibit No. SCE-6

UNITED STATES OF AMERICA

BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION


AFFIDAVIT OF JORGE CHACON ON BEHALF OF

SOUTHERN CALIFORNIA EDISON COMPANY

I. INTRODUCTION AND SUMMARY

1. My name is Jorge Chacon and my business address is 3 Innovation Way,

Pomona, California 91768. I am employed by Southern California Edison Company

(“SCE”) as the manager of the Generation Interconnection Planning Group in SCE’s

Transmission and Distribution Business Unit. I have a Bachelor of Science degree in

Electrical Engineering from California State Polytechnic University, Pomona, which I

received in 1997. I am presently pursuing a Masters in Business Administration from the

University of La Verne.

2. I am responsible for, among other things, managing the planning of high

voltage transmission systems for SCE and managing the planning of generation

interconnections. Over the past fourteen years, I have performed transmission planning

studies regarding transmission capability in the Tehachapi area to accommodate existing

and new generation. In fact, I was the SCE transmission planner involved in studying the

part of the SCE system that is commonly referred to as the Antelope-Bailey 66 kV

Subtransmission System between 1999 and 2003.

Dkt. No. ER13-1216-001 Exh. SCE-6 Page 1 of 29

kcottrel

Typewritten Text

kcottrel

Typewritten Text

Exhibit No. 10

2

3. In light of my role regarding planning studies relating to the Tehachapi area

since early 1999, I am quite familiar with how CalWind Resources, Inc.’s (“CalWind”)

Pajuela Peak Project (“Project”) has been treated in models that have been created and in

studies that have been performed relating to both the annual Transmission Planning

Process and the interconnection of other generators and transmission planning over the

past fourteen years. During negotiations with CalWind, I indicated to various personnel

that SCE had not historically modeled the Project at 37.5 MW, but rather at the amount of

capacity actually installed, 21.795 MW, which is often rounded to 21.8 MW or 22 MW.

4. To verify SCE’s historic treatment of the Project in models used for SCE

and California Independent System Operator Corporation (“CAISO”) studies, I have

reviewed the Transmission Expansion Plans and/or the Annual Transmission Reliability

Assessments1 (collectively “Assessments”) relating to SCE’s 66 kV Antelope-Bailey

system for the period 1999-2012. The Assessments include the assumptions relied upon.2

All the Assessments indicate that the generator at the Arbwind Substation, and the only

generator there is the Pajuela Peak Project, had a capacity of 21.8 MW.3 In addition, I

have reviewed SCE’s Grid Control Center (“GCC”) one-line diagrams used for

1 The annually-produced document containing the reliability assessment of the SCE

system has had various names over the past 14 years. 2 Under the current planning protocol, Participating Transmission Owners (“PTOs”)

remain responsible for performing North American Electric Reliability Corporation (“NERC”) reliability assessments using the base cases developed by them, which are also integrated into the CAISO Balancing Authority Area-wide base cases. See CAISO Business Practice Manual for the Transmission Planning Process at § 4.12.2.

3 In some of the early Assessments, a lower “On-Line” capacity figure is listed in addition to a “Nameplate” capacity of 21.8 MW. See Attachment 1 at 1, 3.


3

operations at both SCE and the CAISO and all such diagrams indicate a capacity value of

21.8 MW. Attachment 1, portions of which contain Critical Energy Infrastructure

Information (“CEII”), contains excerpts from the relevant pages of a sampling of the

Assessments; included are the relevant pages from the 1999,4 2001,5 2003,6 2007,7 2009,8

and 20129 Assessments. The Assessments typically include 66 kV System Line

Arrangement diagrams that show the megawatts at Arbwind at “22” (i.e., 21.8 MW

rounded to the nearest whole megawatt). Attachment 2 illustrates the facilities that were

ultimately constructed for the 21.795 MW project.

5. Dariush Shirmohammadi, who was the Director of Regional Transmission

Organization South at the CAISO from 2005 to 2007, has located and included in his

Affidavit some diagrams, dated 1993 and 2001 respectively, that show 37 MW at

Arbwind. Shirmohammadi Aff. at 3-4, 5-6 (attached to Motion to Intervene and Protest

of CalWind Resources, Inc. (April 22, 2013) (“Protest”)). The existence of such

diagrams is not all that surprising in light of the original plan to construct a project of

28.5 MW and subsequent discussions at various times to expand the current Project to

37.5 MW. However, the mere existence of such diagrams does not serve as an

illustration of the MW values modeled in studies evaluating SCE system performance

4 Att. 1 at 1-2. 5 Id. at 3-4. 6 Id. at 5. 7 Id. at 7-9. 8 Id. at 10-12. 9 Id. at 13-14.


4

over the last 14 years. Indeed, Dr. Shirmohammadi never indicates the purpose of the

diagrams. There is no basis to believe these diagrams were relevant to, or used in, the

CAISO baseline deliverability study discussed by Dr. Shirmohammadi. As a matter of

fact, the values used in all studies since 1999, whether expansion plan, reliability, or

deliverability, have always modeled a project of 21.795 MW, as that was the project that

ultimately materialized and because it is impossible to properly model a resource whose

technical data is unavailable.

6. The MW figure that was used historically in modeling and analyzing the

SCE system for NERC reliability purposes relates to the purpose of Section 25.1 of the

CAISO Tariff. My understanding is that Section 25.1 permits the continued

interconnected operations of certain generators without further analysis by the CAISO or

PTO because such generators have already been assumed to be interconnected and

operating. From a reliability perspective, the actual assumptions made about such prior

interconnected operations are the technical basis for the granting of this “safe harbor.”

7. I know CalWind personnel were aware of the fact that its Project was not

being modeled at 37.5 MW because SCE has held numerous open stakeholder meetings

in support of the annual transmission plans since 1999. During the stakeholder meetings

held between 1999 and 2003, I was the assigned SCE transmission planner who presented

study results to participating stakeholders. Excerpts from a presentation given on

October 20, 2005 for its 2005 Transmission Expansion Plan are included in Attachment

3, portions of which contain CEII, as an example of the materials presented at these

stakeholder meetings. The slides that were presented during the October 20, 2005


5

stakeholder meeting that related to the Antelope-Bailey 66 kV System showed 22 MW at

Arbwind. Two CalWind representatives, Pete Levitt and Doug Levitt, were at the

meeting at which such slides were presented, as evidenced by the sign-in sheet. Att. 3 at

6.

8. Dr. Shirmohammadi notes that single line diagram included in the 1985

Interconnection Facilities Agreement between Arbutus and SCE “clearly presents that the

SCE interconnection facilities, including all the protection equipment, were designed for

37.5 MW.” Shirmohammadi Aff. at 4. The CalWind Protest (at 17) similarly indicates

that “the existing interconnection facilities were designed with the additional equipment

in mind.” I would note that because the additional facilities needed on the customer side

to support Pajuela Peak’s expansion plans are not in place (see Protest at 16-17), it is

impossible for SCE’s current facilities to be adequate to provide for such additional

expansion without some facility modifications on SCE’s side.

9. I declare under penalty of perjury that the foregoing is true and correct.

Executed this 7th day of May, at Pomona, California.

/Jorge Chacon/

Jorge Chacon


Attachment 1

PUBLIC (CEII Redacted) Dkt. No. ER13-1216-001 Exh. SCE-6 Page 6 of 29

REDACTED

(Contains Critical Energy Infrastructure Information (CEII))


REDACTED



Section 6 Page 1

SECTION 6

ANTELOPE-BAILEY 66 KV SYSTEM SUMMER AND SPRING 2007-2016

6A. INTRODUCTION

The 66 kV Antelope-Bailey system serves the Antelope Valley, Gorman and Tehachapi Pass areas. The coincident peak load forecast for these areas totals 814 MW in 2008, 970 MW in 2011 and 1188 MW in 2017 with a compound annual growth rate of 4.1%. The system is expected to have a total coincident peak wind generation of 310 MW in the Tehachapi Pass located approximately 30 miles north of the Antelope substation. Two hydro-electric stations Kern River I and Borel Powerhouse – generate a total of 34 MW along the Kern River about 40 miles further north. The most critical system conditions occur with: a) maximum load and minimum local area generation and b) maximum wind generation and minimum load.

This section presents the results of the assessment of the 66 kV Antelope-Bailey system from 2008 to 2017 as follows:

• Assumptions

• Methodology

• Study results and discussion

• Mitigations

• Conclusion

• Recommendations

6B. ASSUMPTIONS

1. Generation

The generation levels in the 66 kV Antelope-Bailey systems are listed in Table 6.1, and it presents the maximum levels for both wind and hydro generation. The maximum expected coincident wind generation totals about 310 MW. Hydro-generation is assumed at a maximum level of 34 MW (24 MW at Kern River No.1 and 10 MW at Borel).

The following generation scenarios were studied:

CAISO CONTROLLED SCE TRANSMISSION EXPANSION PLAN 2008-2017


Section 6 Page 2

• Summer conditions were studied with wind generation and hydro-generation set to minimum level (0 MW).

• The spring studies included the maximum expected coincident wind generation output of about 310 MW, as well as the maximum hydro-generation output of 34 MW.

Table 6. 1: Wind Generation

MW MVARArbwind 21.8 21.8 14.8 -4.7Canwind 65.0 65.0 60.9 -21.1Enwind 47.1 47.0 47.1 -13.5Flowind 40.8 40.6 40.8 -11.5Dutchwind 14.0 13.8 11.4 -2.8Northwind 19.4 19.0 13.0 -5.0Oakwind 21.1 21.1 21.1 -5.2Southwind 13.4 13.4 13.4 -2.1Zondwind 26.0 25.1 17.1 -7.4Breeze 12.5 10.5 7.3 -4.1Midwind 18.0 11.1 9.3 -4.5Morwind 56.0 55.5 53.9 -15.8Total Wind 355.1 343.9 310.1 -97.7Kern River 24.0 24.0Borel 10.0 10.0Total Hydro 34.0 34.0Total 389.1 377.9 310.1 -97.7

Coincident OutputLocation Nameplate On-Line

2. Substation Load

For the summer cases, coincident load levels were considered. Non-coincident substation peak loads were obtained from the latest SCE Distribution Substation Program (DSP). The non-coincident substation peak loads from the DSP were adjusted to match the peak forecast for the system for the transmission substations Antelope and Bailey (see Table 6.2).

The spring load was adjusted while keeping large non-conforming customers constant so that the total substation load matches 50% of the peak forecast for the transmission substations (Antelope and Bailey).

CAISO CONTROLLED SCE TRANSMISSION EXPANSION PLAN 2008-2017


REDACTED



Section 7 Page 1

2009 SCE Annual Transmission Reliability Assessment

SECTION 7

ANTELOPE-BAILEY 66 kV SYSTEM 2010-2019

7A. INTRODUCTION

The Antelope-Bailey 66 kV system serves the Antelope Valley, Gorman, and Tehachapi Pass areas. The coincident peak load forecast for these areas totals 688 MW in 2010, 778 MW in 2014, and 890 MW in 2019 with a compound annual growth rate of 2.6%. The system is expected to have a total coincident peak wind generation of 310 MW in the Tehachapi Pass, located approximately 30 miles north of the Antelope substation. Two hydro-electric stations, Kern River I and Borel Powerhouse, generate a total of 34 MW along the Kern River about 40 miles further north. Stressed system conditions occur with: a) maximum load and minimum local area generation and b) maximum wind generation and minimum load.

This section presents the results of the assessment of the 66 kV Antelope-Bailey system from 2010 to 2019 as follows:

Assumptions

Methodology

Study results and discussion

Mitigations

Conclusion

7B. SYSTEM CONDITIONS

1. Generation

The generation levels in the Antelope-Bailey 66 kV system are listed in Table 7.1, presenting the maximum levels for both wind and hydro generation. The maximum expected coincident wind generation totals about 310 MW. Hydro-generation is assumed at a maximum level of 34 MW (24 MW at Kern River No. 1 and 10 MW at Borel). The following generation scenarios were studied:

Summer conditions were studied with wind generation and hydro-generation set to minimum levels (2 MW).


Spring studies included the maximum expected coincident wind generation output of about 310 MW as well as maximum hydro-generation output of 34 MW.

Table 7.1 Wind Generation

MW MVARArbwind 21.8 21.8 14.8 -4.7Canwind 65.0 65.0 60.9 -21.1Enwind 47.1 47.0 47.1 -13.5Flowind 40.8 40.6 40.8 -11.5Dutchwind 14.0 13.8 11.4 -2.8Northwind 19.4 19.0 13.0 -5.0Oakwind 21.1 21.1 21.1 -5.2Southwind 13.4 13.4 13.4 -2.1Zondwind 26.0 25.1 17.1 -7.4Breeze 12.5 10.5 7.3 -4.1Midwind 18.0 11.1 9.3 -4.5Morwind 56.0 55.5 53.9 -15.8Total Wind 355.1 343.9 310.1 -97.7Kern River 24.0 24.0Borel 10.0 10.0Total Hydro 34.0 34.0Total 389.1 377.9 310.1 -97.7

Coincident OutputLocation Nameplate On-Line

2. Substation Load

A non-coincidence 1-in-10 years load forecast was obtained from the latest SCE Distribution Substation Program (DSP). The non-coincidence load forecast from the DSP was scaled accordingly to match the coincident peak load output of the Antelope-Bailey system to create the “coincident peak load” levels (see Table 7.2). The heavy summer loading was represented at 100% of coincident peak load levels. The spring loading levels was adjusted to match 50% of the heavy summer coincident loads while keeping large nonconforming customers at their constant power demands.


REDACTED



Attachment 2


FenceLine Pajuala Peak Customer SubstationSCE's Arbwind Substation

To Tap Connection

To

Future

66‐12 kV

Ban

k

Technical Details Unknown for

Future Facilities


Attachment 3

PUBLIC (CEII Redacted) Dkt. No. ER13-1216-001 Exh. SCE-6 Page 22 of 29

TRANSMISSION & INTERCONNECTION PLANNINGT&D BUSINESS UNIT

Silvia MontesSecond Stakeholders Meeting

October 20, 2005Ontario, CA

CAISO Controlled SCE Transmission2006-2015 Expansion Plan

Antelope-Bailey 66 kV System


TRANSMISSION & INTERCONNECTION PLANNINGT&D BUSINESS UNIT

1

Agenda

• System Overview• Approved Projects • Study Scope• Study Assumptions• Study Results• Next Steps


REDACTED



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Exhibit No. SCE-8

prepared direct testimony and exhibits of ......list of exhibits exhibit description sce-5 direct...

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