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PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

ENERGY DIVISION RESOLUTION E-4293

RESOLUTION

Resolution E-4293. Southern California Edison (SCE) Company

PROPOSED OUTCOME: This Resolution approves a new renewables portfolio standard power purchase agreement (PPA) between SCE and Echanis, LLC.

ESTIMATED COST: This Resolution approves cost recovery for a renewable energy PPA. Actual costs are confidential at this time.

By Advice Letter (AL) 2359-E filed on July 13, 2009 and AL 2359-E-A filed on October 22, 2009.

__________________________________________________________

SUMMARY

The Southern California Edison/Echanis contract complies with the Renewable Portfolio Standard (RPS) procurement guidelines and is approved

Southern California Edison (SCE) filed advice letter (AL) 2359-E requesting Commission review and approval of a new power purchase agreement (PPA) executed with Echanis, LLC (Echanis). The PPA resulted from SCE's 2008 RPS solicitation. SCE's AL 2359-E-A amended certain PPA terms and conditions to bring the PPA into compliance with the Commission's RPS standard contract terms and conditions rules.

The following table summarizes the agreement:

Generating facility

Type

Term

(Years)

Capacity

(MW)

Energy

(GWh)

Expected Online

Date

Location

Echanis

Wind, new

20

40-104

123-321

11/15/10

Oregon

Pursuant to the PPA, SCE will take delivery of the energy and green attributes at the Harney substation located in Southeast Oregon. SCE will wheel the energy to Mid-Columbia trading hub (Mid-C) using Echanis firm transmission rights and then manage the intermittent energy by either selling it and replacing it at a later date with an equivalent amount of energy for import to California, or firming and shaping the energy for import into California upon receipt. If SCE pursues the first option, SCE expects to remarket the energy at Mid-C, but may wheel it elsewhere if the economics are favorable.

While the contract price is at or below the applicable 2008 market price referent (MPR), the total cost of the contract with firming and shaping is above the MPR. Because SCE's above-MPR funds are exhausted, SCE proposes to voluntarily procure these resources above the MPR. Deliveries from this PPA are reasonably priced and fully recoverable in rates over the life of the contract, subject to Commission review of SCE's administration of the contract.

ALs 2359-E and 2359-E-A are approved without modification.

NOTICE

Notice of AL 2359-E and AL 2359-E-A was made by publication in the Commission's Daily Calendar. SCE states that a copy of each of the Advice Letters was mailed and distributed in accordance with Section 3.14 of General Order 96-B.

PROTESTS

The Utility Reform Network (TURN) and the Coalition of California Utility Employees (CCUE) filed a timely joint protest to SCE's Advice Letter 2359-E on August 3, 2009.

On August 10, 2009, SCE replied and Peter Blood responded on behalf of Echanis, LLC to the TURN/CCUE joint protest.

DISCUSSION

Overview Of RPS Program

The RPS Program administered by the Commission requires each utility to increase its total procurement of eligible renewable energy resources by at least 1% of retail sales per year so that 20% of the utility's retail sales are procured from eligible renewable energy resources no later than December 31, 2010.1

Additional background information about the Commission's RPS Program, including links to relevant laws and Commission decisions, is available at http://www.cpuc.ca.gov/PUC/energy/Renewables/overview.htm and http://www.cpuc.ca.gov/PUC/energy/Renewables/decisions.htm.

SCE requests approval of a new renewable energy contract with Echanis

The proposed long-term contract for new wind generation was negotiated as part of SCE's 2008 renewable solicitation. The wind facility will be located in the southeast of Oregon and will deliver its energy to SCE at the Harney substation. SCE will use Echanis's firm transmission rights to wheel the energy from the Harney substation to Mid-C and then manage the energy (firm and shape) from that point.

SCE proposes to satisfy the California Energy Commission's (CEC) RPS delivery guidelines2 in one of three ways:

SCE has not committed itself to one of the options, but will choose what is appropriate and most cost-effective based on the relative prices of the options as it administers the contract. In the first two cases, it is possible that no new energy will be imported to California. In the third, the energy will be wheeled and scheduled into the state.

SCE asserts that the Echanis project meets its energy portfolio needs, has minimal development risk, and has a high level of viability because Echanis has site control, the majority of permits needed for construction, and an involved financier.

While the contract price is at or below the applicable 2008 MPR, the total cost of the contract with firming and shaping will require above-MPR funds. The contract is eligible for AMFs, but SCE has exhausted its AMFs. SCE has voluntarily elected to incur these above-MPR costs.

SCE requests the Commission to issue a resolution containing:

Energy Division Review Of the Proposed PPA

Energy Division evaluated the PPA for the following criteria:

Consistency with SCE's 2008 RPS Procurement Plan

California's RPS statute requires that the Commission review the results of a renewable energy resource solicitation submitted for approval by a utility.4 The Commission reviews the results to verify that the utility conducted its solicitation according to its Commission-approved procurement plan. SCE's 2008 RPS Procurement Plan (Plan) was approved by D.08-02-008 on February 14, 2008. Pursuant to statute, SCE's Plan includes an assessment of supply and demand to determine the optimal mix of renewable generation resources, consideration of flexible compliance mechanisms established by the Commission, and a bid solicitation protocol setting forth the need for renewable generation of various operational characteristics.5

Specifically, SCE's Plan states that SCE intends to secure resources from its 2008 solicitation, as necessary, to ensure that it meets the 20% RPS goal as soon as possible, and with a reasonable margin of safety. SCE requested proposals based upon standard term lengths of 10, 15 or 20 years or a non-standard delivery term of no less than 1 month. SCE also requested proposals with a minimum capacity of 1.5 MW. SCE indicated a preference for projects:

SCE asserts that "The Echanis Contract was solicited, negotiated, and executed in a manner consistent with SCE's 2008 RFP protocol."6 SCE also states that the proposed Echanis project fits SCE's identified renewable resource needs. Echanis is a 20-year contract for new renewable generation, expected to commence deliveries in the near-term (2010). Additionally, the facility has received pre-certification as an eligible renewable energy resource from the CEC, and the CEC has confirmed that the delivery structure proposed in the advice letter is consistent with the RPS delivery guidelines set forth in the CEC's RPS Eligibility Guidebook.

The PPA is consistent with SCE's 2008 RPS Procurement Plan and resource needs.

Consistency with RPS Standard Terms and Conditions (STCs)

SCE filed supplemental AL 2359-E-A to amend the terms and conditions in the Echanis PPA to comply with D.08-04-009, as modified by D.08-08-028.

The PPA includes the Commission adopted RPS standard terms and conditions, including those deemed "non-modifiable".

Consistency with RPS Delivery Rules

Where an advice letter requests Commission approval of a PPA with a facility that does not have its first point of connection with the California transmission network, the CEC provides a written determination to the Commission addressing whether the proposed delivery structure meets the RPS delivery requirements set forth in the CEC's RPS Eligibility Guidebook.7

Appendix C to this resolution contains a letter from CEC Staff determining that the delivery structure contained in the proposed PPA meets the CEC's RPS delivery requirements as set forth in the CEC's RPS Eligibility Guidebook.

Project Viability

For SCE's 2008 RFP, SCE quantitatively evaluated and scored each bid's viability, based on a number of factors such as development issues, site control, technology maturity and seller experience. This evaluation is provided in confidential Appendix B to AL 2359-E. The following discussion summarizes the critical points of the viability analysis:

Project Milestones

The PPA identifies the project milestones, including interconnection agreement, construction start date, and commercial operation deadlines.

Site Control

Echanis has full site control.

Financability of Resource

While financing renewable energy projects is difficult in today's economic market, SCE asserts that the developer "has a strong business relationship with HSH Nordbank AG (HSNH), a leading financier of wind projects in the United States" and that HSHN's enthusiasm about the project indicates that there is low risk in financing the project.

Tax Credits

Given the recent extension of the production tax credits (PTC) for new wind facilities through 2011, the Echanis project should be eligible for the PTC. Additionally, the project should also be eligible for the option to apply for an Investment Tax Credit (ITC) in lieu of the PTC.

Sponsor's Creditworthiness and Experience

Columbia Energy Partners (CEP), Echanis's parent company, has developed a 200 MW wind project in Oregon and the company's principals have significant energy market and development experience.

Transmission Upgrades

Echanis does not expect any major transmission upgrades for the project. It has recently received the system impact study re-study and the full 104 MW has been reserved for this project.

Permitting

SCE asserts that the project is on track to obtain all permits by the expected operation date.

Equipment

Echanis is in the process of negotiating wind turbine supply contracts and is evaluating bids for other necessary equipment.

Based on the foregoing, SCE concludes that it "has assessed the Echanis project to have an extremely high level of viability with minimal development risk".8

In comments on the draft resolution, the Oregon Natural Desert Association and the Oregon Chapter of the Sierra Club identify potential areas of risk related to the environmental review of the necessary transmission.

Compliance with the Interim Greenhouse Gas Emissions Performance Standard (EPS)

California Pub. Utils. Code §§ 8340 and 8341 require that the Commission consider emissions costs associated with new long-term (five years or greater) power contracts procured on behalf of California ratepayers.

D.07-01-039 adopted an interim EPS that establishes an emission rate quota for obligated facilities to levels no greater than the greenhouse gas (GHG) emissions of a combined-cycle gas turbine powerplant. The EPS applies to all energy contracts for baseload generation that are at least five years in duration.9 Renewable energy contracts are deemed compliant with the EPS except in cases where intermittent renewable energy is firmed and shaped with generation from non-renewable resources.

The Echanis contract is a long-term contract for intermittent renewable energy. The contract is compliant with D.07-01-039, the Commission's decision implementing the EPS because it is an eligible renewable energy contract.

As described above, SCE may sell the Echanis energy and tag the green attributes with imported energy to satisfy the CEC's delivery guidelines. The firming and shaping contracts must individually meet the EPS. However, SCE has not yet entered into any firming and shaping contracts, so the Commission can not evaluate whether SCE's firming and shaping of the Echanis contract is EPS compliant. SCE must procure firming and shaping contracts consistent with Senate Bill 1368 and RPS rules.

The PPA is compliant with the interim Emissions Performance Standard requirements (EPS). If SCE uses any new imports or firming and shaping contracts, it will have to separately comply with the EPS requirements and will be subject to CPUC rules to verify the compliance.

Procurement Review Group (PRG) Participation

SCE's PRG consists of representatives from: the Division of Ratepayer Advocates (DRA), The Utility Reform Network (TURN), California Utility Employees, the Union of Concerned Scientists, the California Department of Water Resources, and the Commission's Energy and Legal Divisions.

SCE asserts that its PRG was consulted during each step of the 2008 renewable procurement process. On June 11, 2008, SCE advised the PRG of its proposed short list of bids for its 2008 RPS solicitation. On May 13, 2009, SCE briefed the PRG concerning the successful conclusion of discussions with Echanis.

Although Energy Division is a member of the PRG, it reserved judgment on the contract and associated hedging strategy until the AL was filed. Energy Division reviewed the transaction independently of the PRG, and allowed for a full protest period before concluding its analysis.

With regard to this PPA, SCE has complied with the Commission's rules for involving the PRG.

Comparison to the Results of SCE's 2008 Solicitation

The Commission's Least Cost Best Fit (LCBF) decisions direct the utilities to use certain criteria in their bid ranking and provide guidance regarding the process by which the utility ranks bids in order to "shortlist" the bids eligible for contract negotiations.10

SCE states in AL 2359-E that the benefit-to-cost ratio for the Echanis PPA, "in combination with SCE's portfolio need for near-term viable RPS projects, justified its inclusion on SCE's 2008 solicitation short list."11 SCE says that the final LCBF results for the project after contract negotiations are favorable compared to the other 2008 RPS bids.

Confidential Appendix A to this resolution provides a more detailed comparison to SCE's short list bids.

The PPA compares favorably to the results of SCE's 2008 solicitation.

Cost Reasonableness

Confidential Appendix A to this resolution includes a detailed discussion of the contractual pricing terms, including SCE estimates of the total contract costs under the PPA, including firming and shaping costs. The Echanis contract price is at or below the applicable 2008 MPR of $113.90. However, because SCE must deliver the energy to California, SCE will incur firming and shaping costs that increase the total cost of the transaction and put it above the MPR. While this project is eligible for AMFs, SCE has exhausted its AMFs. SCE says that it will voluntarily incur the above-MPR costs even though there are insufficient AMFs to cover the costs of the Echanis project.

The total expected costs of the PPA, as estimated by SCE, are reasonable based on their relation to bids received in response to SCE's 2008 solicitation.

Provided the generation is from an eligible renewable energy resource, or Seller is otherwise compliant with Standard Term and Condition 6, set forth in Appendix A of D.08-04-009 and included in the terms of the PPA, payments made by SCE under the PPA are fully recoverable in rates over the life of the PPA, subject to Commission review of SCE's administration of the PPA.

Independent evaluator (IE) Review

SCE retained an IE, Sedway Consulting, to report to SCE's procurement review group about the 2008 RPS solicitation and to ensure that the solicitation was conducted fairly and that the best resources were acquired. According to the IE Report submitted in AL 2342-E-A, Sedway Consulting performed its duties overseeing the 2008 solicitation and has provided assessment reports to the PRG and the Commission.

In its Independent Evaluator Report, Sedway Consulting concluded that SCE "...conducted a fair and effective evaluation of the proposals that it received in response to its 2008 RPS RFP and made the correct selection decisions in its short list." In addition, the IE monitored SCE's short-listing discussions, contract negotiations and meetings with management where SCE made decisions regarding bid prioritizations and negotiation positions. Sedway Consulting says that the Echanis PPA was negotiated fairly and appropriately, and the IE does not believe that there is any material issue or deficiency that would warrant the CPUC's rejection of any of this PPA.

The IE's contract-specific evaluation of the Echanis project is attached as confidential Appendix B to this resolution.

Consistent with D.06-05-039, an independent evaluator (IE) oversaw SCE's RPS procurement process.

TURN and CCUE protest the contract

TURN and CCUE urge the Commission to withhold review of the Echanis contract on three counts.

First, TURN and CCUE argue that pending RPS legislation (Senate Bill 14 and Assembly Bill 64) would modify the definition of "delivery" and which could render all or part of the output from Echanis ineligible for the RPS program. Since this protest was filed, the Governor vetoed both bills. TURN and CCUE's protest on this basis is denied.

Second, TURN and CCUE assert that the Echanis contract conflicts with a pending Commission decision that would authorize the use of tradable renewable energy credits (RECs) and would put a cap on their use. As a result, TURN and CCUE "urge the Commission to ensure that concerns over the excessive use of `REC-only' deals are given appropriate consideration". As SCE notes in its reply, the Echanis contract complies with "all of the standards for CPUC approval under the RPS legislation and the implementation of the RPS program by the CPUC and the California Energy Commission." Accordingly, TURN's and CCUE's protest on this basis is denied.

Third, TURN and CCUE claim that the Echanis project "does not benefit California's environment or economy." SCE's replies note that the CPUC has previously rejected TURN's argument that out-of-state RPS contracts do not benefit ratepayers. SCE further argues that the Legislature disagrees with the TURN and CCUE assertion since certain out-of-state facilities, such as Echanis, are considered RPS-eligible resources. Because the Echanis contract meets the RPS eligibility requirements, is reasonably priced, and meets SCE's portfolio need as stated in its procurement plan, the protest on this basis is denied.

RPS ELIGIBILITY AND CPUC APPROVAL

Pursuant to Pub. Utils. Code § 399.13, the CEC certifies eligible renewable energy resources. Generation from a resource that is not CEC-certified cannot be used to meet RPS requirements. To ensure that only CEC-certified energy is procured under a Commission-approved RPS contract, the Commission has required standard and non-modifiable "eligibility" language in all RPS contracts. That language requires a seller to warrant that the project qualifies and is certified by the CEC as an "Eligible Renewable Energy Resource," that the project's output delivered to the buyer qualifies under the requirements of the California RPS, and that the seller use commercially reasonable efforts to maintain eligibility should there be a change in law affecting eligibility.12

The Commission requires a standard and non-modifiable clause in all RPS contracts that requires "CPUC Approval" of a PPA to include an explicit finding that "any procurement pursuant to this Agreement is procurement from an eligible renewable energy resource for purposes of determining Buyer's compliance with any obligation that it may have to procure eligible renewable energy resources pursuant to the California Renewables Portfolio Standard (Public Utilities Code Section 399.11 et seq.), Decision 03-06-071, or other applicable law."13

Notwithstanding this language, the Commission has no jurisdiction to determine whether a project is an eligible renewable energy resource, nor can the Commission determine, prior to final CEC certification of a project, that "any procurement" pursuant to a specific contract will be "procurement from an eligible renewable energy resource."

Therefore, while we include the required finding here, this finding has never been intended, and shall not be read now, to allow the generation from a non-RPS eligible resource to count towards an RPS compliance obligation. Nor shall such a finding absolve any contracting party of its obligation to obtain CEC certification and/or to pursue remedies for breach of contract to ensure that only RPS-eligible generation is delivered and paid for under a Commission-approved contract. Such contract enforcement activities shall be reviewed pursuant to the Commission's authority to review the administration of such contracts.

CONFIDENTIAL INFORMATION

The Commission, in implementing Pub. Utils. Code § 454.5(g), has determined in D.06-06-066, as modified by D.07-05-032, that certain material submitted to the Commission as confidential should be kept confidential to ensure that market sensitive data does not influence the behavior of bidders in future RPS solicitations. D.06-06-066 adopted a time limit on the confidentiality of specific terms in RPS contracts. Such information, such as price, is confidential for three years from the date the contract states that energy deliveries begin, except contracts between IOUs and their affiliates, which are public.

The confidential appendices, marked "[REDACTED]" in the public copy of this resolution, as well as the confidential portions of the advice letter, should remain confidential at this time.

COMMENTS ON THIS RESOLUTION

Pub. Utils. Code § 311(g)(1) provides that this resolution must be served on all parties and subject to at least 30 days public review and comment prior to a vote of the Commission. Section 311(g)(2) provides that this 30-day period may be reduced or waived upon the stipulation of all parties in the proceeding. The 30-day comment period for the draft of this resolution was neither waived nor reduced.

SCE, Oregon Natural Desert Association (ONDA), and the Oregon Chapter of the Sierra Club (Sierra Club) filed timely comments on draft Resolution E-4293. SCE filed timely reply comments. The Harney County Court filed a timely response.

We carefully considered comments which focused on factual, legal, or technical errors and made appropriate changes and clarifications to the draft Resolution.

SCE commented that the draft Resolution finding regarding rate recovery could obligate SCE to make contractual payments that it may not be able to recover in rates. We carefully considered SCE's argument and have modified the draft Resolution accordingly.

In addition, SCE requested minor corrections to the draft Resolution's description of SCE's Procurement Review Group (PRG). SCE stated that the draft Resolution incorrectly included Aglet Consumer Alliance as a participant in SCE's PRG. The error has been corrected.

ONDA and Sierra Club both commented on the draft Resolution, which states that, according to SCE, the Echanis project "has minimal development risk, and has a high level of viability". Both comments present new information that would affect the development risk of the project, and they request the PUC to further evaluate the proposal before approving the draft Resolution. ONDA states that the Echanis project "is part of an intensely controversial package of wind power development proposals involving some of the most ecologically significant lands in southeastern Oregon, and successful completion of the project is far from assured."14

In its response, the Harney County Court disagrees with ONDA and the Sierra Club comments and asks that the Commission approve the Echanis project. The Court states, that the Echanis project it is part of a "heavily supported package of wind power development proposals involving one of the most economically disadvantaged counties in Oregon, and successful completion of the project will dramatically improve this rural county's social, economic and environmental aspects."15

SCE replies that other agencies are conducting the appropriate environmental reviews and that the permitting and transmission-related issues will be resolved as part of those processes. SCE further notes that, "The issue presented by SCE's advice letter is the appropriateness of the Echanis Contract for cost recovery under the RPS program."16 The Commission agrees with SCE. The Commission's approval of this contract for rate recovery is independent from the permitting processes for the Echanis project and associated transmission.

However, we note that a complete advice letter filing would have identified the permitting issues raised by ONDA and the Sierra Club. The Energy Division's advice letter template specifically asks the utilities to provide all information affecting the viability of the proposed project, including the status of generation and transmission permitting. In the future, SCE must discuss issues, such as the controversy identified by ONDA and Sierra Club, in its advice letter requesting approval of an RPS contract so that the Commission can do a thorough review of the proposed project.

FINDINGS AND CONCLUSIONS

1. The PPA is consistent with SCE's 2008 RPS Procurement Plan, approved by D.08-02-008.

2. The PPA is consistent with the resource needs identified in SCE's 2008 Procurement Plan.

3. The PPA includes the Commission-adopted RPS standard terms and conditions including those deemed "non-modifiable".

4. Appendix C to this resolution contains a letter from CEC Staff determining that the delivery structure contained in the proposed PPA meets the CEC's RPS delivery requirements as set forth in the CEC's RPS Eligibility Guidebook.

5. SCE asserts that there is minimal development risk and a high level of viability risk associated with the Echanis PPA.

6. The PPA is compliant with the interim Emissions Performance Standard requirements (EPS). If SCE uses any new imports or firming and shaping contracts, it will have to separately comply with the EPS requirements and will be subject to CPUC rules to verify the compliance.

7. With regard to this PPA, SCE has complied with the Commission's rules for involving the PRG.

8. The PPA compares favorably to the results of SCE's 2008 solicitation

9. The total expected costs of the PPA, as estimated by SCE, are reasonable based on their relation to bids received in response to SCE's 2008 solicitation.

10. Provided the generation is from an eligible renewable energy resource, or Seller is otherwise compliant with Standard Term and Condition 6, set forth in Appendix A of D.08-04-009 and included in the terms of the PPA, payments made by SCE under the PPA are fully recoverable in rates over the life of the PPA, subject to Commission review of SCE's administration of the PPA.

11. Consistent with D.06-05-039, an independent evaluator (IE) oversaw SCE's RPS procurement process.

12. SCE has voluntarily agreed to incur the above-MPR costs of the Echanis project that exceed SCE's cost limitation.

13. The TURN and CCUE joint protest is rejected because the project satisfies current RPS rules and eligibility guidelines, is reasonably priced and is consistent with SCE's procurement plan and resource need.

14. The comments from ONDA and Sierra Club to postpone approval of the Echanis project are denied because the Commission 's approval of this contract for rate recovery is independent from the permitting processes for the Echanis project and associated transmission.

15. Procurement pursuant to the PPA is procurement from eligible renewable energy resources for purposes of determining SCE's compliance with any obligation that it may have to procure eligible renewable energy resources pursuant to the California Renewables Portfolio Standard (Public Utilities Code Section 399.11 et seq.), D.03-06-071 and D.06-10-050, or other applicable law.

16. The immediately preceding finding shall not be read to allow generation from a non-RPS eligible renewable energy resource under this PPA to count towards an RPS compliance obligation. Nor shall that finding absolve SCE of its obligation to enforce compliance with Standard Term and Condition 6, set forth in Appendix A of D.08-04-009, and included in this PPA.

17. The confidential appendices, marked "[REDACTED]" in the public copy of this resolution, as well as the confidential portions of the advice letter, should remain confidential at this time.

18. AL 2359-E and 2359-E-A should be approved effective today.

THEREFORE IT IS ORDERED THAT:

1. Southern California Edison Company's Advice Letters 2359-E and 2359-E-A, requesting Commission review and approval of a power purchase agreement with Echanis, LLC., are approved without modification.

2. This Resolution is effective today.

I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on December 17, 2009; the following Commissioners voting favorably thereon:

MICHAEL R. PEEVEY

PRESIDENT

DIAN M. GRUENEICH

JOHN A. BOHN

RACHELLE B. CHONG

TIMOTHY ALAN SIMON

Commissioners

Confidential Appendix A

Contract evaluation

[REDACTED]

Confidential Appendix B

Independent Evaluator Report

[REDACTED]

Appendix C

CEC Letter

1 See Public Utilities (Pub. Utils.) Code § 399.15(b)(1).

2 Public Resources Code §25741(b)(2)(B) requires that the energy from out-of-state facilities is delivered to California, and the CEC has adopted eligibility guidelines about the RPS delivery rules.

3 As defined by SCE, "'RPS Legislation' refers to the State of California Renewable Portfolio Standard Program, as codified at California Pub. Utils. Code Section 399.11 et seq."

4 Pub. Utils. Code, Section §399.14.

5 Pub. Utils. Code, Section §399.14(a)(3).

6 AL 2359-E, page 6

7 Renewables Portfolio Standard Eligibility Guidebook, 3rd Edition, publication # CEC-300-2007-006-ED3-CMF (January 2008), available at http://www.energy.ca.gov/2007publications/CEC-300-2007-006/CEC-300-2007-006-ED3-CMF.PDF

8 AL 2359-E at 15.

9 "Baseload generation" is electricity generation at a power plant "designed and intended to provide electricity at an annualized plant capacity factor of at least 60%." Pub. Utils. Code § 8340(a).

10 D.04-07-029

11 Page 9

12 See, e.g. D. 80-04-009 at Appendix A, STC 6, Eligibility.

13 See, e.g. D. 80-04-009 at Appendix A, STC 1, CPUC Approval.

14 ONDA comments on draft Resolution E-4293 (November 27, 2009), page 1

15 Harney County Court response to comments on draft Resolution E-4293 (December 7, 2009), page 1

16 SCE reply comments to draft Resolution E-4293 (December 8, 2009), page 1

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