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1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION California Independent System Operator Corporation In Re Transmission Control Agreement Docket No. EL SOUTHERN CALIFORNIA EDISON COMPANY'S MOTION TO INTERVENE AND COMMENTS ON THE COMPLAINT FILED BY THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION Dated: April 21, 2008 Anna J. Valdberg Attorney for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: (

2 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION California Independent System Operator Corporation In Re Transmission Control Agreement Docket No. EL Southern California Edison Company's Motion To Intervene And Comments On The Complaint Filed By The California Independent System Operator Corporation Pursuant to Rule 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission ( Commission, Southern California Edison Company ( SCE hereby seeks leave to intervene in the foregoing proceeding and to provide comments with respect to the filing made by the California Independent System Operator Corporation ( CAISO. I. DISCUSSION On April 1, 2008, the CAISO filed a complaint to revise the Transmission Control Agreement ( TCA, and to seek a waiver from the applicable provisions of the CAISO Tariff in order to allow Startrans IO L.L.C. ( Startrans to become a Participating Transmission Owner ( PTO as early as April 14, Startrans is seeking to become a PTO in connection with its acquisition of the ownership rights on the Mead-Phoenix Project ( MPP and the Mead- Adelanto Project ( MAP (jointly Mead Rights from the City of Vernon ( Vernon. The Commission has already approved the sale of Mead Rights to Startrans. 1 As such, SCE does not oppose revising the TCA to enable Startrans to become a PTO in the CAISO. 1 Startrans I0, LLC, 122 FERC 61,307 (

3 Although SCE does not oppose Startrans becoming a PTO, SCE does have certain concerns with the CAISO filing. First, as SCE and others have noted in their filings in the dockets addressing Startrans Section 203 filing and Startrans proposed Transmission Revenue Requirement ( TRR with respect to the Mead Rights, the CAISO must work to assure that the capacity now held by Startrans remains available and useable by the CAISO ratepayers. 2 Specifically, because Startrans is not acquiring the LADWP transmission contract in conjunction with Vernon s MAP rights, CAISO needs to take steps to assure that if that LADWP contract ever terminates, the termination does not increase congestion on the CAISO grid and impinge upon the CAISO ratepayers ability to use effectively the capacity acquired by Startrans. Second, Startrans unlike Vernon is a Non-Load Serving PTO that is acquiring existing transmission rights. There is, however, no clear and specific methodology in the CAISO Tariff that would enable Startrans, or any other similarly situated entity, to recover its TRR through TAC rates. In response to this problem, the CAISO has proposed that Startrans be assigned to the East Central TAC Area for TAC recovery purposes. (Filing Letter at pp There is no basis in the CAISO Tariff for the CAISO proposal, and the CAISO cannot simply assert that it will treat Startrans as being assigned to the East Central TAC Area. Rather, the CAISO Tariff in particular Appendix F, Schedule 3, Section 3.4 of the CAISO Tariff should be modified to explicitly document how Startrans will be treated for the TAC recovery purposes. In any case, SCE believes that the CAISO proposal is not sufficient to resolve the issue. Since Startrans has Existing High Voltage Facilities, its TRR must be reflected in the 2 The Commission, in fact, has left open for resolution in Docket No. ER the issues associated with the impact of the LADWP contract and its possible termination on Startrans TRR. Id at P

4 Transition Charge component of the TAC formula (see Appendix F, Schedule 3, Section 5.7. However, the Transition Charge calculation utilizes and relies upon the Gross Load of each PTO. Startrans is a Non-Load Serving PTO and has no Gross Load, so the Transition Charge calculation cannot work for Startrans without a modification to the CAISO Tariff. SCE, therefore, proposes that Section 5.7 of Schedule 3 of Appendix F of the CAISO Tariff be modified by adding the underlined language below: "The Transition Charge shall be calculated separately for each Participating TO by dividing (i the net difference between (1 the Participating TO s payment responsibility, if any, under Section 26.5 of the ISO Tariff and Section 7 of this Schedule 3; and (2 the amount, if any, payable to the Participating TO in accordance with Section 26.5 of the ISO Tariff and Section 7 of this Schedule 3; by (ii the total of all forecasted Gross Load in the PTO Service Territory of the Participating TO, including the UDC and/or MSS Operator. If greater than zero, the Transition Charge shall be collected with the High Voltage Access Charge. If less than zero, the Transition Charge shall be credited with the High Voltage Access Charge. The amount of each Participating TO s NHVTRR shall not be included in the Transition Charge calculation, nor shall any amount of HVTRR of a Non-Load-Serving Participating TO be included in the Transition Charge calculation." Finally, SCE is concerned with the CAISO s assertion that the provisions of the CAISO Tariff which provide that a six month time period is necessary to process a PTO application and set forth the dates on which an applicant can become a PTO exist to primarily to serve the convenience of the CAISO so as to permit the CAISO to integrate changes to its transmission Access Charge rates on a limited basis and to provide the applicant some certainty with respect to the outcome of the negotiations. (Filing Letter at p. 13. There is no basis for such an assertion. Continued from the previous page 3 SCE understands that CAISO will be starting a stakeholder process to address this issue

5 The time lines created in the CAISO Tariff for processing a PTO application exist as much to accommodate the needs and rights of the existing PTOs as they do for the benefit of the CAISO. PTOs are entitled to a reasonable amount of time, as set forth in the CAISO Tariff, to review any PTO Application, identify any concerns and work with affected parties to resolve these concerns without burdening the Commission with unnecessary disputes. Thus, although SCE does not oppose the waiver of the CAISO Tariff provisions in this case, it reserves the right to do so in other proceedings. II. SCE S MOTIONS TO INTERVENE SCE, a wholly owned subsidiary of Edison International, is an investor owned utility, subject to the Commission s jurisdiction. SCE s principal place of business is 2244 Walnut Grove Avenue, Rosemead, California SCE, is a PTO in the CAISO, and, therefore, is substantially affected by the outcome of this proceeding. SCE has an immediate interest in the outcome of this proceeding. SCE s interest cannot be represented by any other party and, consequently SCE respectfully requests that the Commission grant SCE permission to intervene in this proceeding. SCE hereby reserves its rights to raise additional substantive issues regarding all aspects of this proceeding, and to file additional comments, as warranted by the proceeding. in this proceeding: SCE designates the following persons for service on the Commission s service list Anna J. Valdberg James Cuillier Southern California Southern California Edison Company Edison Company 2244 Walnut Grove Avenue 2244 Walnut Grove Avenue Rosemead, CA Rosemead, CA ( ( Anna.Valdberg@sce.com James.Cuillier@sce.com - 4 -

6 III. CONCLUSION For all of the foregoing reasons, SCE respectfully requests that the Commission grant SCE s motion to intervene in this proceeding and be made a party thereto, and require that the CAISO modify the CAISO Tariff as set forth above. Respectfully submitted, /s/anna.j.valdberg By: Anna J. Valdberg Attorney for SOUTHERN CALIFORNIA EDISON COMPANY Dated: April 21,

7 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing SOUTHERN CALIFORNIA EDISON COMPANY'S MOTION TO INTERVENE AND COMMENTS ON THE COMPLAINT FILED BY THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at Rosemead, California, this 21st day of April, _/s/vicki.carr-donerson Vicki Carr-Donerson, Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (

124 FERC 61,004 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

124 FERC 61,004 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Before Commissioners: Joseph T. Kelliher, Chairman; Suedeen G. Kelly, Marc Spitzer, Philip D. Moeller, and Jon Wellinghoff.