VII. Response of SDG&E to SSRC's Arguments
SDG&E disputes SSRC's contention that it is overbuilding the Pala Substation Expansion to accommodate its proposed 500-kV Valley-Rainbow transmission line. SDG&E asserts that the second 28 MVA transformer bank is planned for an unspecified future time to meet future load and the Pala Substation Expansion is needed on its own merit and its timing and configuration are unaffected by whether the Valley-Rainbow project is ever built.
SDG&E points out that the future projects which may result in the ultimate build-out of the Pala Substation are uncertain and speculative, and such projects are not a reasonable foreseeable consequence of the Pala Substation Expansion, but are instead dependent upon the evolution of future service and system reliability needs. Therefore, SDG&E argues that because the initial development of the Pala Substation Expansion has independent utility and would achieve an immediate and valuable local and state purpose and need, and because approval of the project does not commit the Commission or SDG&E to develop any facilities that may eventually be needed to meet future service and/or reliability needs (e.g., a third 69-kV tie line), any such development projects being separately subject to GO 131-D(III)(B), the Draft Mitigated Negative Declaration is not required to assess the substation buildout potential beyond the initial development. (Del Mar Terrace Conservancy, Inc. v. City Council, 10 Cal.App.4th 712, 732-737; 12 Cal.Rptr. 785 (1992).)
Regarding SSRC's "potential, second substation" argument, SDG&E submits that its Application, PEA, Supplement to Application,2 Reply to SSRC's Protest and SDG&E witness Snow's testimony at the prehearing conference clearly differentiate and identify the independent utility of the Pala Substation Expansion and the Valley-Rainbow transmission line project. Snow testified that the future Rainbow Substation or its alternative (as part of the Valley-Rainbow transmission line project) may become the nearest and most likely source for a third 69-kV tie line, if in the future such a line becomes necessary. Except for the potential for a future third 69-kV tie line between the proposed Rainbow Substation (or its alternative) and the Pala Substation, there is no relationship between the two projects.
2 In its Supplement to Application, at p. 3, SDG&E states: "..., the SDG&E owned Pala property is more than 200 acres in size. As discussed on page 54 of the PEA, the Eastern portion of the property is being considered as the preliminary secondary choice for a 500/230-kV substation yard for the Valley/Rainbow 500 k-V Interconnection Project. These are two separate projects and if that portion of the property were to become the primary choice for the 500/230-kV substation, it would be addressed in the CPCN process for the Valley Rainbow Interconnect Project."
