I. EMF Issues
B. EMF Management Plan for the Antelope-Pardee Transmission Project
Consistent with its obligations under G.O. 131-D, SCE included, with its application, an EMF Field Management Plan.21 In this plan, SCE proposes to incorporate various no-cost mitigation measures to reduce field levels. It also identifies, but does not propose to adopt, certain low-cost mitigation measures. The proposed plan does not analyze potential impacts across each of the various alternative route alignments identified in the Draft EIR/EIS and carried forward in the FEIR.
As discussed elsewhere in this order, we authorize SCE to construct the Antelope-Pardee Transmission Project along an alignment that differs significantly from that originally proposed by the utility. With these modifications to the Antelope-Pardee Transmission Project, SCE should amend its EMF management plan as needed to apply its no-cost EMF management techniques to the approved project.
Consistent with D.06-01-042 and D.93-11-013, we also require that SCE undertake low-cost EMF mitigation. Where such design modifications are consistent with our low-cost policy, SCE should increase tower and conductor heights by 20 feet along any portions of the transmission corridor where there are residences within 50 feet of the side of the right of way closest to the new 500 kV transmission lines. SCE has established that this design modification would reduce magnetic fields by 15% at the edge of the right of way.
In its existing study, SCE rejects this option for unspecified environmental and engineering reasons. We do not believe that the potential conflict of this low-cost EMF mitigation measure with environmental mitigation efforts would be significant. Few of the areas where EMF mitigation will occur are completely flat, and the towers and conductors would be difficult to line up due to even small elevation changes between existing and new towers. With tower heights of 150 feet, a 20-foot height increase for towers and conductors is unlikely to be noticeable to most observers.
We require that SCE apply this low-cost EMF mitigation measure where there are existing residential properties and also where development of new residences is underway at the time that SCE undertakes final project design. Consistent with guidance in D.06-01-042, we do not require that SCE attempt to determine possible future uses of undeveloped land. If applicable, SCE would not be required to raise tower heights near any residential properties that will be acquired and converted from residential use in order to allow construction of the Antelope-Pardee Transmission Project.
The cost of the adopted EMF mitigation measure may be less than SCE estimated along its proposed route. In any event, it is likely that the cost will be much less than the Commission's 4% benchmark for low-cost EMF mitigation. As described in this order, SCE may seek an increase in the approved maximum cost of the Antelope-Pardee Transmission Project if the adopted low-cost EMF mitigation measure causes the cost cap to be exceeded.
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11. The initial cost of the Antelope-Pardee Transmission (Antelope Segment 1), capped at $92.5 million, is a small fraction of the total cost of the entire project needed to bring Tehachapi wind to retail customers.
31. It is reasonable to modify SCE's preliminary EMF management plan for the project, as described in Section VI.
32. The maximum reasonable and prudent cost for the approved project is $92.5 million. The maximum reasonable and prudent cost for the Antelope-Pardee Transmission Project (Antelope Segment 1) and Tehachapi-Vincent Transmission Project (Antelope Segments 2 and 3) is $746.0 million in 2008 dollars, including pension and benefits and administrative and general expenditures, but excluding Allowance for Funds Used During Construction (AFUDC), assuming construction and operation at the full 500 kV level for the appropriate segments.
33. A reasonable estimate of AFUDC for ATP Segments 1, 2 and 3 is $77.3 million in nominal dollars.
34. Pursuant to FERC order, SCE is already receiving CWIP incentive rate treatment for Segments 1, 2, and 3 in lieu of collecting the $77.3 million in AFUDC, and will seek retail rate recovery from the Commission for those costs - anticipated to be small - that FERC does not allow to be included in CWIP.
13. SCE's preliminary EMF management plan for the Antelope-Pardee Transmission Project should be modified as described in Section VI and the project should be constructed consistent with that modified plan.
30. The Commission should approve a maximum reasonable and prudent cost of $92.5 million. The Commission should approve a maximum reasonable and prudent cost for the Antelope-Pardee Transmission Project (Antelope Segment 1) and Tehachapi-Vincent Transmission Project (Antelope Segments 2 and 3) of $746.0 million in 2008 dollars, including pension and benefits and administrative and general expenditures, but excluding AFUDC, assuming construction and operation at the full 500 kV level for the appropriate segments.
31. Cost estimates submitted to the Commission should include AFUDC or another proxy for financing costs, and should also include estimates for construction costs increases. AFUDC will not be included in the maximum cost adopted by the Commission, but will be included in the Commission's factual findings to provide full disclosure to the Commission and public regarding the potential ratepayer exposure to construction financing costs.
32. The Commission should approve this increased cost cap pursuant to Public Utilities Code Section 1005.5. In authorizing this cost cap the Commission should fully expect that SCE filings at FERC seeking cost recovery for these projects will not be in excess of the maximum costs specified herein without prior notice to the Commission regarding the reasons for any inconsistency between the authorized maximum cost and its FERC filing.
IT IS ORDERED that:
3. Modifications to SCE's preliminary electric and magnetic field (EMF) plan for the Antelope-Pardee Transmission Project are adopted as described in Section VI of this order.
4. SCE shall, as a condition of approval, build the project in accordance with these modifications.
5. Pursuant to Pub. Util. Code § 1005.5(a), the maximum cost (in 2005 dollars) determined to be reasonable and prudent for the Antelope-Pardee Project, including Allowance for Funds Used During Construction, pension and benefits, and administrative & general expenditures, is $92.5 million. Pursuant to Pub. Util. Code § 1005.5(a), the maximum reasonable and prudent cost (in 2008 dollars) for the Antelope-Pardee Transmission Project (Antelope Segment 1) and Tehachapi-Vincent Transmission Project (Antelope Segments 2 and 3) is $746.0 million, including pension and benefits and administrative and general expenditures, but excluding Allowance for Funds Used During Construction, assuming construction and operation at the full 500 kV level for the appropriate segments.
16. Southern California Edison shall not seek ratepayer funding in excess of the maximum cost specified herein in any filing at the Federal Energy Regulatory Commission without prior notice to the Commission regarding the reasons for any inconsistency between the authorized maximum cost and its FERC filing.
16. 17. Application 04-12-007 is closed.
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