7. Does SCE's HECA Project Fit Into SCE's Overall Procurement Strategy, as Required by Resolution E-4227A?
Resolution E-4227A states that:
10. In any future application for approval of costs related to the HECA study, SCE should include an explanation of how its proposal fits into its overall procurement strategy, as directed by D.08-04-038.106
Therefore, our review of this application requires us to review this generation proposal in light of SCE's overall procurement strategy.
7.1. Positions of Parties
In testimony, SCE states that:
... SCE's participation in the HECA feasibility study advances SCE's efforts to develop a generation and procurement strategy that provides low-carbon baseload generation. In particular, the potential for obtaining power from a HECA facility is attractive to SCE ratepayers because of: 1) its timing to fill SCE's baseload need, 2) its clean generation characteristic, which is consistent with state policy objectives, 3) its in-state location with identified CO2 off-take for EOR where both the off-taker and HEI have significant experience in such technology, and 4) its fuel characteristic, which helps mitigate regulatory uncertainty as well as provide fuel diversity.107
In addition, SCE also presented testimony that it will need "at least 250 MW of baseload resources by 2015."108 SCE also notes the project both helps reduce GHG emissions109 and increases fuel diversity.110
No party presented contrary evidence, and no party discussed this issue in its briefs.
In D.08-09-041 (as corrected by D.09-01-004), this Commission notes that SCE's unmet residual procurement authorization is 145-645 MW.111 Thus, the 250 MW that the HECA project will produce is consistent with the baseload range as it appears in D.08-09-041 and with SCE's testimony of its power needs.
7.2. Discussion
The HECA project is consistent with SCE's overall procurement strategy because its timing will help fill SCE's baseload need, it produces low GHG emissions, it is located in California and provides additional fuel diversity. There is no evidence nor argument to the contrary.
106 E-4227A Finding 10.
107 Ex. SCE-1 at 4.
108 Id; amended at TR 253:3-13.
109 Id. at 7.
110 Id. at 8.
111 D.09-01-004 at 1.
