CSBPD - COUNTY OF SANTA BARBARA PLANNING AND DEVELOPMENT
CSBPD-1.
The department's previous comments from its July 2 letter are addressed below as responses CSBPD-2 through 6.
The analysis in the Initial Study assumed that the new owner would operate the plant under the same permit conditions as are currently in place, including the 200 hours per year operating restriction. The Initial Study notes on page 3.5, "This Initial Study assumes that each of the divested plants continues to operate within the parameters of its existing permits (e.g., water discharge permits and air emissions permits) because it is not reasonably foreseeable that operations would exceed those levels." Air emissions permits are considered in the development of Clean Air Plans.
This project involves the sale of the Ellwood facility but no request to increase the limitation in the permit for annual hours of operation. While a new owner might apply for a permit revision (and so could Edison if it retains the Ellwood facility), such a revision would be subject to environmental review and any substantial adverse impacts would be identified at that time.
The analysis in the Initial Study is consistent with the comment already. Plants of the type similar to Ellwood (i.e., combustion turbines) typically run 100 hours or less per year and are likely to do so in the future under any ownership scenario. Thus, it is reasonably foreseeable that the divested plants would continue to operate within the parameters of their existing permits and thus, that the Ellwood facility would continue to operate no more than 200 hours per year.
This comment was substantially addressed in the Utilities and Service Systems section of the Initial Study. As noted on page 4.12.2 of the Initial Study, "AB 1890 caused the creation of the Independent System Operator (ISO), which will coordinate the scheduling and dispatch of electricity, and will ensure that reliability of the transmission system is maintained.... Additionally, the CPUC will continue to have statutory responsibilities for system reliability." Concerning must-run status and issues, the CPUC determined in Decision 97-09-049 (page 8) that for the purposes of PU Code Section 362, Edison had met its burden of proof showing that the Ellwood facility "will be needed neither for local voltage support nor to meet applicable planning reserve criteria," and that no party to the case disputed the evidence Edison presented to support its classification of the Ellwood facility. Therefore, the Ellwood facility for the purposes of this proceeding is not a "must-run" plant.
The Initial Study assumes all the power plants targeted for divestiture will continue to be operated in the restructured industry. The ISO has tentatively accepted the Edison determination that the Ellwood facility in not a "must-run" plant. If the ISO subsequently identifies the Ellwood Energy Support Facility as a must-run plant, needed to maintain local reliability of the grid, it will negotiate with the new owner to sign a Master Must Run Reliability Agreement (MMRRA) requiring the new owner to keep the facility available during certain times. The CPUC and the Federal Energy Regulatory Commission (FERC) are in the process of finalizing the MMRRA. New owners would be required to sign and honor such contracts before assuming ownership of a must-run plant. Even without an MMRRA, the ISO will be free to use the Ellwood facility as needed to meet local load and maintain reliability and power quality, as long as the facility is available. If the Ellwood facility becomes unavailable, for whatever reason, the ISO will take action, if needed, to ensure reliability of the grid.
No change in energy use is expected as a result of the divestiture of the Ellwood peaking facility. The energy delivered through the UCSB substation and the proposed substation at Ellwood will be scheduled by the ISO which will ensure that the reliability of the transmission system (including these two substations) is maintained.
Substations deliver energy to customers (as opposed to generation facilities which produce the energy). If the proposed Ellwood substation is not built, then other substations would deliver the energy the Ellwood substation would have delivered, but there will be no impact upon, or change in demand to, the Ellwood Energy Support Facility since it is a generation facility.
Please refer to responses to CSBPD-2 and CSBPD-3. Also, the Initial Study evaluated noise/vibration (Section 4.10), air quality (Section 4.5), and EMF and other hazards (Section 4.9).
As noted in Table 2.1, the Ellwood facility operated at an average capacity factor of 0.39 percent over the five period from 1992 through 1996, or about 37 hours per year, based on Edison's Uniform Monthly Fuels and Operations Reports for the same period. The facility is used only to meet peaking needs during times of unusually high demand, which generally occur in summer months. Predicting which days the facility will operate is difficult at best because weather is generally the determining factor in making demand high enough to require use of the Ellwood facility for maintaining voltage and frequency in the region. As noted in several places in the Initial Study, such as on page 4.5.26, operation of the Ellwood facility is limited to 200 hours per year, except during emergency conditions; there is no limit on the number of days per year the facility can be operated, as long as the 200 hours per year total is not exceeded.
Dependable capacity is defined as the amount of energy the facility could safely generate at any given time, as confined by thermal limits and other operating criteria. For Ellwood, the winter dependable capacity is 53 Megawatts (MW), while the summer dependable capacity is 48 MW because air temperature is generally higher, meaning the air-cooled turbine must be kept at lower power levels to ensure thermal limits are not exceeded. The maximum capacity of any generating unit is generally the highest dependable capacity, which for Ellwood is 53 MW.