UCAN

In the Matter of the Application of San Diego Gas )
& Electric Company (U 902 E) for a Certificate of )
Public Convenience and Necessity for the Sunrise ) Application 06-08-010
Transmission Project )
__________________________________________)

Pursuant to Rule 73 of the Commission's Rules of Practice and Procedure, Utility Consumers' Action Network ("UCAN") respectfully requests that the Commission take official notice of a very recent regulatory filing. Attached as Attachment A is a Power Point presentation made by an SDG&E demand-side management executive to the California Energy Commission's Efficiency Committee Load Management Standards Rates, Incentives, and Market Integration Workshop on Tuesday, June 10, 2008, just three days before the final briefs were due in this proceeding.

This presentation is notable because the information which has been provided to the Energy Commission conflicts dramatically with representations made by SDG&E to the Public Utilities Commission just one month prior. The CEC presentation proves that SDG&E has no reliability deficit until 2013, contrary to SDG&E's contention that its reliability deficit begins in 2010.

On the 12th page of the presentation, the Energy Commission is provided a chart entitled: SDG&E Demand Respnse (sic) Program 2009-2011 Forecast: Load Impacts for a Typical Event Day 1 in 2 Weather Year.

This chart indicates that for the years 2010 and 2011, it expects to have 203 Mw of demand response and 314 Mw respectively.¹ These demand response savings are significantly larger than the corresponding demand-side numbers presented to the CPUC in this proceeding. In an exhibit submitted to the Commission in early May, SDG&E indicated that it projected 111 Mw in 2010 and 208 Mw in 2011² The difference between the assertions contained in Exhibit SD-142, at page 3 and SDG&E's June 10th CEC presentation is 92 Mw in 2010³ and 106 Mw in 2011⁴ or a difference of approximately 100% in 2010 and 50% in 2011. Adding 92 Mw to SDG&E's resource mix in 2010, plus another 9 Mw for avoided losses, would reduce the 106 Mw deficit shown in Exhibit SD-142 ("San Diego Area Reliability Surplus" line) from 106 Mw down to 5 Mw⁵. Similarly, adding 106 Mw to SDG&E's resource mix in 2011, together with associated loss reductions of 11 Mw, would more than cover the deficits shown in Exhibit SD-142 ("San Diego Reliability Surplus" line) for the years 2011 and 2012 both.

In sum, this CEC document reveals that SDG&E's claimed reliability deficit of 2010 simply doesn't exist. If accepted into the record, SDG&E's own numbers would indicate that it doesn't need any new resources in 2010 through 2012 to meet its reliability needs beyond the baseline resources in Exhibit SD-142 and the demand response efforts that it currently has authorized and underway.

UCAN requests that the Commission accept this SDG&E filing at the Energy Commission into the record and substitute these numbers for those contained in Exhibit SD-142. Additionally, UCAN requests that the Commission instruct SDG&E in its response to UCAN's motion to explain the discrepancy between the two sets of numbers for the purposes of initiating a Rule 1 violation investigation against the applicant for knowingly withholding material information from the Commission.

UCAN does not seek expedited processing of this motion.

/s/
Michael Shames
On behalf of UCAN
3100 Fifth Ave. Suite B
San Diego, CA 92103

________________________________

¹ These numbers don't incorporate associated transmission loss savings

² per Ex. SD-142, p. 3, on the "Celerity," "Comverge" and "AMI" lines combined.
³ 203 - 111 = 92
⁴ 314 - 208 = 106
⁵ 106 - 92 - 9

Phone: 619-696-6966
Fax: 619-696-7477
Email: mshames [at] ucan [dot] org

I hereby certify that I have this day served a copy of the foregoing MOTION FOR OFFICIAL NOTICE BY UTILITY CONSUMERS' ACTION NETWORK on all parties identified in A.06-08-010 on the attached service list by electronic mail and by overnight mail to the assigned Commissioner(s) and Administrative Law Judge(s). Dated at San Diego, California, this 13th day of June, 2008.

/s/
Laura Impastato