UCAN's 8th Set of Data Requests

Data requests for Gridview sensitivity cases

1. For each of the sets of Gridview sensitivity cases requested below, please run Gridview for both 2010 and 2015 for revised versions of Cases 100, 101, and 104. Supply outputs in the format of revised Tables IV-2 (showing results for cases 100 and 101, and comparing them) and VI-6 (showing results for cases 100 and 104, and comparing them). Also supply all of the same underlying Gridview outputs and workpapers as previously supplied for each line of the existing Tables IV-2 and VI-6, and any unique Gridview inputs, change files, or command files associated with each set of inputs.

a) A set of cases using the same input assumptions that SDG&E used for Cases 100, 101, and 104 respectively, except that all generators are assumed to bid at variable cost instead of strategically, as those terms are used on p. IV-52.

b) A set of cases using the same input assumptions that SDG&E used for Cases 100, 101, and 104 respectively, except that the WECC generation additions on Table IV-11 are modified to include the South Bay replacement project located in San Diego, with the same on-line date as the Sunrise power line, and the revised Case 100 has no CT additions in 2010-2015.

c) A set of cases using the same input assumptions that SDG&E used for Cases 100, 101, and 104 respectively, except that the Imperial Valley generation assumptions in Table IV-14 are modified to:

i. Reduce "Solar Thermal" to 260 Mw in 2010 (but keep it at 900 Mw in 2015)
ii. Reduce "SS08 geo" and "SS09 geo" to zero Mw in 2010 (but keep them at 200 Mw each in 2015)
iii. Remove "SS11 geo", "SS12 geo", "SS13 geo", and "SS14 geo"
iv. Change "El Centro 3" from a 44 Mw steam project to a 128 Mw combined cycle project for both 2010 and 2015.

d) A set of cases using the same input assumptions that SDG&E used for Cases 100, 101, and 104 respectively, except that the WECC generation additions in Tables IV-11, -12, and -13 are modified as follows:

i. "Afton CC" changed from 506 Mw to 272 Mw
ii. "Reeves Repowr_CC" changed from 384 Mw to 204 Mw
iii. "Desert Rock Power," "Four Corners," "Springerville 4," and "Generic Baseload" coal are removed from the "Arizona, New Mexico, West Texas, Nevada, WAPA L.C." region
iv. "MT First Mw" deleted entirely and "So. MT G&T_Gt Falls deleted in 2010 (but kept in 2015) in the "Rocky Mountain Area"
v. "Rawhide GT5" modeled as a simple cycle instead of a combined cycle

e) A set of cases combining all of the changes identified in subparts b-d (but not a) above.

2. Please re-answer all data requests which were either not previously answered or require new answers based on the passage of time and the new data in the 8/4/06 filing (including the PEA). In your new answers, please indicate which of the previously provided answers are still correct with regards to the 8/4/06 filing, and provide new or corrected answers for those responses which need to be changed to reflect the 8/4/06 filing. At a minimum, UCAN believes the following data requests will require new or amended answers:

a) From UCAN data request 1, in addition to the supplemental response to question 20 supplied on 9/11, supplemental responses should be supplied for questions 1-3, 7 (response should go beyond the CEC list previously supplied, since the CEC does not include wind projects or projects under 50 Mw), 8-9, 19, 22-25, 30-33, 44d (statement that modeling did not produce any hours when 4000 Mw of imports occurred), 47, 54e ($20.4 million figure does not occur in the cited reference), 76 (with "Desert Southwest" defined per SDG&E's previous response to UCAN data request set 7, question 116, and with the clarification that the question is asking for both 2010 and 2015 LMPs), 78, 81, 83 (with separate answers for each of the years 2010 and 2015), 84, 88 (with particular regard to the Bannister-San Felipe line and the San Felipe substation, which the 8/4/06 filing indicates are assumed to be built only in the Sunrise scenario, and not in the CC and CT scenarios), 89, 92, 97.

b) From UCAN data request 2: SDG&E has not yet answered questions 25, 45, or 109 at all; basically all the questions regarding the 12/05 filing will need revised answers. Questions regarding Cases 00 and 1 in data request 2 should now be answered for each of cases 100, 101, and 104 in the 8/4/06 filing. References to various tables in the December 2005 filing should now be answered for the corresponding tables in the 8/4/06 filing.

c) From UCAN data request 3, questions 3-8, with references to cases 0, 1, and 2-3 of the 12/05 filing now taken to refer to cases 100, 101, and 104 of the 8/4/06 filing.

d) From UCAN data request 4: SDG&E has not yet responded to questions 1-4, 14, 31, or 35 in this April 2006 data request. In answering this data request, SDG&E should answer all questions regarding specific scenarios in the 12/05 filing both with regard to those scenarios and also with regard to the corresponding scenarios in the 8/06 filing so that UCAN can understand what changes have occurred. Thus, questions regarding cases 0 and/or 00 should now be answered for both those cases and the new case 100; questions regarding case 1 should now be answered for both case 1 and the new case 101; and questions regarding cases 2 and/or 3 should now be answered for both cases 2 and/or 3, and also case 104.

e) From UCAN data request 5: SDG&E has not yet responded to questions 4, 28, 33-35, 40c, 41c, or 50 in this April 2006 data request. In answering this data request, SDG&E should answer all questions regarding specific scenarios in the 12/05 filing both with regard to those scenarios and also with regard to the corresponding scenarios in the 8/06 filing so that UCAN can understand what changes have occurred. Thus, questions regarding cases 0 and/or 00 should now be answered for both those cases and the new case 100; questions regarding case 1 should now be answered for both case 1 and the new case 101; and questions regarding cases 2 and/or 3 should now be answered for both cases 2 and/or 3, and also case 104.

3. Please provide a quantitative description of all the changes between the graph on p. I-16 of the 12/05 filing and the graph on p. I-21 of the 8/4/06 filing, which both show forecasted RMR costs with and without Sunrise.

4. Please provide a quantitative description of the causes of each of the changes between the values in the graph on p. I-16 of the 12/05 filing and the graph on p. I-21 of the 8/4/06 filing.

5. In SDG&E's economic modeling, please indicate:

a) What was the highest Mw level of imports to the SDGE service area which occurred?
b) In what year, day, and hour did it occur?
c) In 2010, in the case with Sunrise, in how many hours did imports to SDG&E exceed 2850 Mw?
d) In 2015, in the case with Sunrise, in how many hours did imports to SDG&E exceed 2850 Mw?
e) In 2010, in the CT case, in how many hours did imports to SDG&E reach 2850 Mw?
f) In 2015, in the CT case, in how many hours did imports to SDG&E reach 2850 Mw?
g) In 2010, in the CC case, in how many hours did imports to SDG&E reach 2850 Mw?
h) In 2015, in the CC case, in how many hours did imports to SDG&E reach 2850 Mw?

6. In SDGE's 8/4/06 analysis, Case 100 has 506 Mw of new combustion turbine resource additions (Table IV-18). SDG&E explains that its reference case adds CTs in order to avoid a capacity shortfall of up to 482 Mw (in 2016) which would otherwise occur (Appendix IV, Table IV-17, p. IV-11). For each year from 2010-2016, inclusive, please indicate how many hours per year of capacity shortage would occur in the CT case (Case 100) if no new San Diego Area CTs were added in 2010-16 and if the annual peak hour loads were at the 90/10 levels shown in Tables IV-17 and IV-18.

7. In SDG&E's economic modeling, please indicate how many hours per year have loads within the following margins of the annual peak load:

a) Hours within 192 Mw of peak load in 2010.
b) Hours within 251 Mw of peak load in 2011.
c) Hours within 289 Mw of peak load in 2012.
d) Hours within 323 Mw of peak load in 2013.
e) Hours within 365 Mw of peak load in 2014.
f) Hours within 413 Mw of peak load in 2015.
g) Hours within 482 Mw of peak load in 2016.

8. With regard to p. 3 of the amended application and p. I-6, please:
a) Define "large electric service areas."
b) Indicate how many 500 KV lines terminate within the SMUD service area.
c) Indicate how many 500 KV lines terminate within the "Greater Bay Area" Local Reliability Area, as defined by the CAISO?
d) Confirm that the "Greater Bay Area" Local Reliability Area has a peak load more than twice SDG&E's peak load.

9. The PEA has maps and discussions referring to current and proposed wilderness areas in Anza-Borrego Desert State park. For each such map and reference, please clarify how much of the areas in question are current wilderness areas and how much are proposed.

10. With regard to footnote 7 on pp. 4-5 of the amended application and fn. 13 on p. I-7, which refer to loads on 7/22/06 and 7/24/06:

a) What was SDG&E's 90/10 forecast for 2006 peak loads?
b) What was the CEC's 90/10 forecast for 2006 peak loads?
c) Please provide a comparison of actual temperatures on 7/22/06 and 7/24/06 to those underlying the CEC and SDG&E 90/10 weather forecasts?
d) What was SDG&E's peak load on 7/24/06?
e) How much SDG&E distribution load was forced out of service during the peak load hour on each of the days 7/22/06 and 7/24/06?
f) How much SDG&E distribution load was forced out of service during each of the annual peak load hours in 2000-2005, inclusive?
g) How many Mw of capacity were scheduled to be imported into the SDG&E service area during each hour of 7/22/06 and 7/24/06. Please provide a disaggregation of the hourly figures showing schedules over each of the three import paths available to SDG&E (south of SONGS, SWPL, Path 45 from Tijuana)?
h) What were actual measured hourly Mw flows into the SDG&E service area during each hour of 7/22/06 and 7/24/06. Please provide a disaggregation of the hourly figures showing flows over each of the three import paths available to SDG&E (south of SONGS, SWPL, Path 45 from Tijuana)?

11. Please provide the actual generation or other capacity supplied during each hour of 7/22/06 and 7/24/06 from each of the generators or other resources (e.g., distributed generation, demand reduction programs) listed under the year 2006 in Table IV-17, and from each of the categories shown in bold type on Table IV-17 (e.g., Utility-Owned Resources, Bilateral Contracts, DWR contracts, Merchant Capacity, Demand Reduction Items).

12. Please supply the unloaded capacity available during each hour of 7/22/06 and 7/24/06 from each of the generators or other resources (e.g., distributed generation, demand reduction programs) listed under the year 2006 in Table IV-17, and from each of the categories shown in bold type on Table IV-17 (e.g., Utility-Owned Resources, Bilateral Contracts, DWR contracts, Merchant Capacity, Demand Reduction Items).

13. With regard to the reference to "developers of conventional power plants" on p. 6 of the amended application, please indicate which geographical areas this reference applies to. In particular, does SDG&E claim that Sunrise "offers developers of conventional power plants an incentive to build new, efficient, generating capacity" within:

a) The SDG&E service area?
b) The SCE service area?
c) The PG&E service area?
d) Arizona?

14. Please reconcile the different schedule dates shown on p. 12 of the amended application (right-of-way acquisition upon issuance of CPCN, construction start 7/08, construction completion 7/10), Appendices A and B of the amended application (right-of-way acquisition starts 2/07, construction starts 4/08, construction apparently complete by 2/10 when testing and energization begin), p. 18 of the amended application (CPCN issued 8/07), and p. I-26 (CPCN in 9/07, pre-construction starts 10/07, construction starts 4/08, construction complete 2/10).

15. Volume 2 - Part 1, Chapter I consists of 27 pages of testimony, 6 pages of SDGE-IID agreements signed by Mr. Avery for SDG&E, and a 72 page CAISO document. Mr. Avery is listed as the sponsoring witness for Chapter I. Please confirm that Mr. Avery will be available for cross-examination as to the content of the CAISO document or, in the alternative, indicate which SDG&E witness will be sponsoring this document.

16. Please list the "more than 30" 500 KV lines of SCE and LADWP which are referred to on p. I-6.

17. Please identify the "customers and community leaders" with who SDG&E met in 2004, as reported on p. I-9, and provide:

a) Copies or records of all communications from SDG&E to those "customers and community leaders."

b) Copies or records of all "recommendations" which SDG&E was able to "elicit" (p. I-9) from those "customers and community leaders."
c) Copies or records of any other communications received from by SDG&E as a result of its 2004 public education program.

d) Copies of all internal SDG&E documents describing the "public education program for the Sunrise Powerlink" which began in 2004 and its results.

e) The cost of the public education program and the source of funding for those costs (ratepayer, shareholder, other).

f) The dates and locations, attendance by SDG&E employees, and attendance by others at any meetings held as part of the "public education program for the Sunrise Powerlink" which began in 2004.

18. Please state whether SDG&E believes that, if South Bay retirement would cause violation of CAISO reliability criteria, the CAISO has the authority to prevent South Bay retirement?

19.Does SDG&E believe that, if the CAISO believes that South Bay retirement would cause violation of CAISO reliability criteria, the CAISO will act to prevent South Bay retirement?

20. Table IV-22 shows that if Sunrise is built, San Diego Local Reliability Requirements will be more than met, with a cushion ranging from 808 Mw in 2010 down to 518 Mw in 2016 (p. IV-29 of Appendix IV). Please indicate, for each year from 2010-2016, inclusive:

a) How much would "N-1" Import capability be reduced below the 3500 Mw shown in Table IV-22 if the Sycamore Canyon-Penasquitos part of the Sunrise project was not built?

b) What would the "Surplus of Combined Capability over Net Peak Demand (90/10)" shown on the bottom of Table IV-22 be if the Sycamore Canyon-Penasquitos part of the Sunrise project was not built?

c) How much would "N-1" Import capability be reduced below the 3500 Mw shown in Table IV-22 if only one of the two proposed Central-Sycamore Canyon 230 KV lines were built as part of the Sunrise project?

d) What would the "Surplus of Combined Capability over Net Peak Demand (90/10)" shown on the bottom of Table IV-22 be if only one of the two proposed Central-Sycamore Canyon 230 KV lines were built as part of the Sunrise project?

e) How much would "N-1" Import capability be reduced below the 3500 Mw shown in Table IV-22 if neither the Sycamore Canyon-Penasquitos part of the Sunrise project nor one of the two proposed Central-Sycamore Canyon 230 KV lines were built as part of the Sunrise project?

f) What would the "Surplus of Combined Capability over Net Peak Demand (90/10)" shown on the bottom of Table IV-22 be if neither the Sycamore Canyon-Penasquitos part of the Sunrise project nor one of the two proposed Central-Sycamore Canyon 230 KV lines were built as part of the Sunrise project?

21. Please define the geographical area to which the term "desert southwest" applies:

a) As used on p. I-16.
b) As used on p. I-22.

22. Will the Sunrise project increase transfer capability of the transmission system from Arizona to California at all?

23. Please list all WECC path ratings that SDG&E expects to increase as a result of the Sunrise project, and describe the status of any SDG&E applications to WECC for changes to those path ratings.

24. SDG&E asserts that the Sunrise project "will provide economical access to neighboring areas with existing and potential (sic) for significant development of renewable energy resources" (p. I-17). Please indicate quantitatively, for each of the years 2010 and 2015:

a) What will be the average dollar cost to transmit a Mwh of renewable energy from the Imperial Valley to the SDG&E service area if Sunrise is built?

b) What will be the average dollar cost to transmit a Mwh of renewable energy from the Imperial Valley to the SDG&E service area if Sunrise is not built?

c) How much will the average dollar cost to transmit a Mwh of renewable energy from the Imperial Valley to the SDG&E service area change if Sunrise is built?

d) How much will the average dollar cost to transmit a Mwh of renewable energy from SDG&E's contracted wind generation in the Tehachapi area to the SDG&E service area change if Sunrise is built?

e) How much will the average dollar cost to transmit a Mwh of renewable energy from the Banning Pass wind generation area to the SDG&E service area change if Sunrise is built?

f) How much will the average dollar cost to transmit a Mwh of renewable energy from the Palo Verde area in Arizona to the SDG&E service area change if Sunrise is built?

g) Please describe the source of the answers to the previous questions (e.g., Gridview modeling) and provide all workpapers used to calculate your answers.

25. SDG&E asserts that "increasing the ability to import power from the Imperial Valley will allow SDG&E to meet the renewable resource goals at a cost that will not be burdened by high levels of congestion." (p. I-18) Please indicate how many gwh per year of Imperial Valley generation SDG&E will need to import in 2010 to meet its 2010 goal of "supplying 20% of SDG&E's bundled customer energy requirements with renewable energy sources" (p. I-18), taking into account the other renewable energy sources which are already part of SDG&E's renewable resource plans?

26. Please specify how much will Sunrise reduce the average congestion cost in 2010 (in dollars per Mwh) of energy imports from the Imperial Valley to SDG&E bundled customers?

27. Please specify how many gwh per year of Imperial Valley generation would SDG&E need to import in 2015 to supply 30% of its bundled energy customer energy requirements from renewable energy sources, taking into account the other renewable energy sources which are already part of SDG&E's renewable resource plans?

28. Please specify how much Sunrise will reduce the average congestion cost in 2015 (in dollars per Mwh) of energy imports from the Imperial Valley to SDG&E bundled customers?

29. SDG&E states that Sunrise "will ultimately be essential to delivering this renewable power to the San Diego load area" (p. I-19).

a) In what year will Sunrise first be physically essential to delivering renewable energy to the San Diego load area?

b) In SDG&E's modeling, how many gwh of renewable energy are produced in the Imperial Irrigation District load area in 2010 in Case 101 (with Sunrise)?

c) In SDG&E's modeling, how many gwh of renewable energy are produced in the Imperial Irrigation District load area in 2010 in Cases 100 and 104 (without Sunrise)?

d) In SDG&E's modeling, how many gwh of renewable energy are produced in the Imperial Irrigation District load area in 2015 in Case 101 (with Sunrise)?
e) In SDG&E's modeling, how many gwh of renewable energy are produced in the Imperial Irrigation District load area in 2015 in Cases 100 and 104 (without Sunrise)?

30. SDG&E asserts that delays in Sunrise will cause the Stirling project to deliver its output to the existing grid, which will "cause additional congestion at the Miguel substation, increasing energy costs to consumers." Please indicate, for each of the years 2010 and 2015:

a) Does SDG&E's modeling assume Stirling generation occurs and is delivered to the Imperial Valley substation in cases 100 and 104 (the no-Sunrise cases)?

b) Please quantify the "additional congestion at the Miguel substation" due to the Stirling project in cases 100 and 104 as compared to case 101.

c) Please indicate the monthly LMP for energy delivered to the Imperial Valley substation and for energy withdrawn at the Miguel substation.

31. Please describe how the actual delivered price of Stirling generation will be determined under the SDG&E-Stirling contract (e.g., market priced, pre-determined contract price, indexed contract price, cost-based price, priced at busbar with seller bearing transmission costs, priced at busbar with buyer bearing transmission costs, etc.).

32. Please provide a copy of the SDG&E-Stirling agreement which was approved by the CPUC in December 2005.

33. To the extent that Stirling contract terms differ from the Gridview modeling of Imperial Valley solar generation, please explain what actions (if any) SDG&E took in its modeling to reflect actual contract terms.

34. SDG&E's testimony refers to "other renewable resources ... under contract to SDG&E" (top of p. I-20). Please indicate:

a) In 2010, how many Mw of "other renewable resources" from the Imperial Valley besides 300 Mw from Stirling will SDG&E need to meet its 2010 20% RPS goal?

b) In 2015, how many Mw of "other renewable resources" from the Imperial Valley besides 900 Mw from Stirling would SDG&E need to meet a 30% RPS goal for that year?

35. Please provide any workpapers underlying your answers to the various subparts of this question.

a) In SDG&E's Case 101 modeling, in what month of 2010 does the Sunrise project come on line?

b) In SDG&E's Gridview modeling for cases 100, 101, and 104, please provide the monthly capacity values for Imperial Valley solar generation in each of the years 2010 and 2015.

c) In SDG&E's Gridview modeling for cases 100, 101, and 104, please provide the monthly energy generation for Imperial Valley solar generation in each of the years 2010 and 2015.

d) In SDG&E's Gridview modeling for cases 100, 101, and 104, please provide the monthly capacity values for Imperial Valley geothermal generation in each of the years 2010 and 2015.

e) In SDG&E's Gridview modeling for cases 100, 101, and 104, please provide the monthly energy generation for Imperial Valley geothermal generation in each of the years 2010 and 2015.

36. SDG&E testifies that Sunrise will provide an incentive for "developers of conventional power plants ... to build new, efficient generating capacity" (p. I-22). Does SDG&E agree that increased supply, in standard economic theory, results from increased prices for sellers?

37. For each of the years 2010 and 2015, for each of cases 100, 101, and 104, please provide the annual average LMP at the following substations:

a) Marketplace
b) Hassayampa
c) Imperial Valley (500 KV if different from 230 KV)
d) Four Corners (500 KV if different from 345 KV)
e) Miguel (230 KV if different from 500 KV)

38. SDG&E testimony discusses the possibility of Citizens ceasing to be part of the project or ceasing to be a PTO (p. I-24). SDG&E's modeling shows revenue requirements associated with Citizens' and IID's portions of the project dropping to zero in 2040, after 29.5 years (Table IV-10). Please explain:

a) What is SDG&E's basis for assuming only 30 years of costs for the Greenpath Southwest part of the project?

b) What steps has SDG&E taken to secure "perpetual rights" (p. I-24) to IID's proposed portion of the project?

c) What steps has SDG&E taken to avoid "incurring inequitable rates on IID's portion" (p. I-24) of the project?

d) What would be an "equitable rate" for IID to charge for its portion of the project after year 30?

39. What agreements, if any, exist between Citizens and either SDG&E and IID as to Citizen's obligation to participate in the project, to become a PTO, and to remain a PTO for any specified term?

40. Please provide a copy or description of any such agreements of which SDG&E is aware.

41. Please identify with specificity when and with whom does SDG&E intend to negotiate for "step-in rights or other rights that will provide access to IID's portion of the 500 KV line at reasonable rates" (p. I-24)?

42. How and by whom will the reasonableness of the results of any such negotiation be determined?

43. Is SDG&E requesting approval of participation in Sunrise by Citizens and IID prior to negotiation and CPUC review of agreements to provide it with either "perpetual rights to 95-100% of the transfer capability of the line" (p. I-24) and/or "step-in rights or other rights that will provide access to IID's portion of the 500 KV line at reasonable rates" (p. I-24)?

44. SDG&E admits that the timing of Sunrise is a relevant question (p. I-27, first line). Please provide, for each of the years 2010 and 2015, the calculated benefits of the project compared to Case 100, and the revenue requirements associated with it, both expressed in nominal dollars (not 2005 or 2006 dollars, or levelized dollars).

45. SDG&E admits that the timing of Sunrise is a relevant question (p. I-27, first line). Please provide, for each of the years 2011-2014, inclusive, SDG&E's interpolated values for the benefits of the project compared to Case 100, and its calculated values for the revenue requirements associated with it, both expressed in nominal dollars (not 2005 or 2006 dollars, or levelized dollars).

46. SDG&E admits that the timing of Sunrise is a relevant question (p. I-27, first line). Please provide, for each of the years 2016-2049, inclusive, SDG&E's extrapolated values for the benefits of the project compared to Case 100, and its calculated values for the revenue requirements associated with it, both expressed in nominal dollars (not 2005 or 2006 dollars, or levelized dollars).

47. SDG&E admits that the timing of Sunrise is a relevant question (p. I-27, first line). Please confirm that for each year the project is deferred, SDG&E's calculated nominal dollar benefits for the deferred year would change to zero, calculated annual nominal dollar benefits for each of the years in which the project remained would be unchanged, and there would be new benefits for the year which was 41 years after the pre-deferral commercial operation date but within 40 years of the deferred commercial operation date. (If you do not so confirm, please indicate what your answers to parts a-c of this question would be if the start date of Sunrise were 2011, 2012, 2013, 2014, or 2015 instead of 2010.)

48. SDG&E admits that the timing of Sunrise is a relevant question (p. I-27, first line). Please provide the annual nominal dollar revenue requirements for Sunrise assuming its commercial operation were deferred 1 year, 2 years, 3 years, 4 years, or 5 years. To the extent that Tables IV-9 or IV-10 already provide annual nominal revenue requirements for Sunrise with an on-line date of 2010, this question simply asks for restated Table IV-9 or IV-10 in the event of Sunrise being deferred 1, 2, 3, 4, or 5 years.

49. Please explain what "long-term financial commitments" (p. IV-15 of Appendix IV) SDG&E needs in order to proceed with AMI.

50. Please provide updated versions of each Table in Chapter II of SDG&E's 8/4/06 filing which would be changed by inclusion of all CPUC-adopted "energy savings goals" as referenced on p. 3 of the 9/21/06 ALJ ruling ordering workshops on modelling assumptions.

51. UCAN's 8/29 data requests 6-16 and 6-17 asked for information about 5 specific utilities, but SDG&E's 9/24 responses only answered the questions for one utility. Please provide responses for the other four.

52. UCAN's 8/29 data request 6-20a and 6-95a asked yes/no questions, but SDG&E's 9/24 responses gave neither a yes nor a no. As a result, the answer is ambiguous. Please provide "yes" or "no" response and, if necessary, an explanation for the yes or no response.

53. UCAN's 8/29 data request 6-39c asked for information from a 2001 study, but SDG&E's 9/24 response gave data from a 2006 CAISO study. Please provide a complete answer to the question as asked in 6-39c.

54. UCAN's 8/29 data requests 6-78g and 6-78h asked for SDG&E's "best estimate", but SDG&E's 9/24 responses said SDG&E had no "official estimate." Please provide SDG&E's best estimate as requested.

55. UCAN's 8/29 data request 6-96 asked for information about the direction of the expected impact, but SDG&E's 9/24 response dealt with the magnitude of the expected impact, not its direction. Please provide a complete answer to the question as asked in 6-96.

56. SDG&E's 9/24 response to UCAN data request 6-95b indicated that "the addition of the Sunrise Powerlink will reduce RMR contract costs. SDG&E believes that a reduction in the need for RMR contracts will test the economic viability of the older, less efficient, generation within the San Diego area, creating economic pressures that will result in the retirement of some of these units." Assuming Sunrise is built as planned and provides the economic benefits identified by SDG&E in its 8/4/06 filing, please indicate, for each of the years 2010 and 2015:

a. What is SDG&E's best estimate as to how many Mw of existing SDG&E-area units are likely to retire for lack of RMR contracts?
b. What is SDG&E's best estimate as to which SDG&E-area units are likely to retire for lack of RMR contracts?
c. What is SDG&E's best estimate of the probability that no SDG&E-area units will retire for lack of RMR contracts?
d. What is SDG&E's best estimate of the range of Mw of existing SDG&E-area units that will retire for lack of RMR contracts?
e. UCAN assumes the upper end of the range identified in response to the previous subpart will be no more than 1000 Mw, based on a maximum 1000 Mw reduction due to Sunrise in the number of Mw of RMR contracts. If your answer to the previous question included an upper bound greater than 1000 Mw, please explain the basis for your answer.

57. Please provide copies of all communications between SDG&E and its Procurement PRG in the last 12 months.

58. Please provide copies of all LADWP submissions or other communications to the WECC or any WECC committee or subgroup regarding LADWP's proposed Green path project which SDG&E has copies of.

59. Please provide SDG&E's most current forecasts for the future price of RA capacity in each of the years from 2010-2016, inclusive:

a. For RA capacity within San Diego County
b. For RA capacity elsewhere in the CAISO control area
c. For RA capacity outside of the CAISO control area

60. Please provide 2010 versions of the data already supplied in SDG&E's table IV-3 for 2015.

61. For each of the last 5 years, please indicate what SDG&E's minimum annual load was, as a percentage of SDG&E's maximum annual load in that same year.

62. Please confirm whether UCAN is correct in reading SDG&E's 8/4/06 workpapers to say that "Miguel Nomogram" congestion in Case 100 is $9.24 million in 2010 but $155.8 million in 2015 for 2706 congestion hours, while "Miguel Nomogram" congestion in Cases 101 and 104 is under $0.1 million in both 2010 and 2015.

63. Please explain how Miguel congestion in Case 100 can be over $570,000 per congested hour ($155.8 million/2706 hours).

64. How many Mwh were undeliverable at Miguel because of the Miguel nomogram constraint in 2015 in Case 100?

65. What was the hourly congestion cost of the Miguel nomogram per undeliverable Mwh for Case 100 in 2015?

66. What inflation rate was assumed for the years 2031, 2032, and 2033 in SDG&E's Chapter IV workpapers?

67. How many Mw of Tehachapi wind generation were included in Gridview? To the extent the answer varies, please provide the differing answers for Cases 100, 101, and 104 and the years 2010 and 2015.

68. Please provide the information Mr. Strack was referring to at the 10/13/06 workshop when he said that from the "info I've seen, LNG won't affect" the California/Arizona natural gas price differential.

69. UCAN's notes from the 10/13/06 workshop indicate that when asked about modeling years beyond 2015, Mr. Strack of SDG&E replied, in part, "as you go out further in time, the validity of your assumptions is increasingly subject to challenge."

a. Is this an accurate quotation?
b. Does SDG&E agree with the quotation?

70. Footnote (a) on p. 25 of SDG&E's "Assumptions" handout from 10/13/06 states that 185 Mw of Imperial Valley geothermal generation are currently under construction. Please identify what project(s) comprise this 185 Mw, and state their current construction status.

71. Please indicate the approximate date when SDG&E will begin posting data responses on its web site, as it indicated it would do at the September 13th prehearing conference.