LS Power

LS Power addresses one point: it should not be assumed for SDG&E planning purposes that the South Bay Powerplant (South Bay) will retire on a fixed schedule at the end of 2009, while simultaneously assuming that other proposed resources will be on line by this date. South Bay can not retire until the CAISO removes the Reliabilty Must Run (RMR) designation and other conditions are met. In particular, LS Power argues that the retirement date for South Bay also depends on the operations of the Palomar facility and whether there can be enough local generation and/or transmission line capacity to import generation from outside the region to replace the generation supplied by South Bay. In addition, LS Power believes SDG&E's assumption that the Sunrise Powerlink will be completed by the end of 2009 is also too optimistic. Therefore, based on some of the factors listed above, and many others, LS Power urges SDG&E to assume that South Bay will continue to operate until there are sufficient alternatives to replace its power.