Resolution No. 7980Y r ( r
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P.YI
Pr -A
RESOLUTION NO. 7980
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
VERNON ESTABLISHING THE TRANSMISSION REVENUE
BALANCING ACCOUNT ADJUSTMENT IN ACCORDANCE WITH
VERNON'S TRANSMISSION OWNER TARIFF AND PROVIDING
FOR TARIFF SHEET CHANGES TO IMPLEMENT THE
ADJUSTMENT
WHEREAS, on August 29, 2000, the City Council of the City of
Vernon adopted Resolution No. 7608 establishing the Transmission
Revenue Requirement ("TRR") associated with Vernon's high voltage (over
200 kV) transmission facilities and entitlements (all located outside
the City) for the purpose of becoming a Participating Transmission
Owner with the California Independent System Operator ("ISO"); and
WHEREAS, the TRR and Transmission Owner Tariff ("TO Tariff")
were filed with the Federal Energy Regulatory Commission ("FERC") on
August 30, 2000, as supplemented on August 31, 2000, in FERC Docket No.
EL00-105-000; and
WHEREAS, the FERC issued its decision on October 27, 2000,
requesting the City of Vernon to make certain changes to its TRR and TO
Tariff; and
WHEREAS, on November 7, 2000, the City Council of the City of
Vernon adopted Resolution No. 7659 which approved and authorized for
filing with FERC a Compliance Filing prepared by Albert E. Clark, the
City's Consultant, and a new TO Tariff incorporating the changes in the
TRR and TO Tariff suggested by FERC in its decision; and
WHEREAS, the TRR and TO Tariff were filed with the FERC on
November 9, 2000, as supplemented on November 13, 2000, in FERC Docket
No. EL00-105-001; and
WHEREAS, the FERC issued its decision on March 28, 2001,
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requesting the City of Vernon to make further changes to its TO Tariff;
and
WHEREAS, on April 24, 2001, the City Council of the City of
Vernon adopted Resolution No. 7751 which approved and authorized for
filing with FERC, consistent with the terms of the March 28, 2001 FERC
decision, a Compliance Filing, including a new TO tariff incorporating
the changes in the TRR and TO Tariff suggested by FERC in its decision;
Iand
WHEREAS, the FERC issued its decision on September 14, 2001,
approving that Compliance Filing, including the City of Vernon TO
Tariff, except for one small ministerial correction to one sheet of the
Vernon TO Tariff; and
WHEREAS, City staff prepared that ministerial change and
Vernon filed it with the FERC on September 24, 2001; and
WHEREAS, the FERC's Director, Division of Tariffs and Rates -
West, under general authority delegated by the FERC, approved Vernon's
correction in an April 5, 2002 letter order; and
WHEREAS, the City of Vernon TO Tariff provides for periodic
recalculation of the Transmission Revenue Balancing Account Adjustment
("TRBAA"); and
WHEREAS, Peter Lanzalotta, a consultant to the City, has
prepared testimony and exhibits which determine the TRBAA consistent
with the TO Tariff and support the TRBAA, along with TO Tariff tariff
sheet changes to implement the new TRBAA; and
WHEREAS, a Notice of Public Hearing was posted on June 6,
2002, notifying all interested parties that a hearing to consider
evidence to establish Vernon's new TRBAA was scheduled for June 19,
12002, at approximately 5 p.m.; and
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WHEREAS, by letter dated May 30, 2002, Bruce V. Malkenhorst,
City Administrator/City Clerk, recommended that the TRBAA and Appendix
I,to the TO Tariff implementing the TRBAA be approved and submitted to
the ISO; and
WHEREAS, City of Vernon Staff reported to the City Council
that the ISO has recently orally stated to Vernon that it prefers that
Vernon delay implementation of a new Vernon TRBAA until later in 2002
and that the ISO intends to make a tariff change filing at the FERC
that would provide, among other things, for such a later TRBAA change
by Vernon under the ISO FERC Electric Tariff, and the ISO has provided
City Staff with draft portions of certain materials it intends to file
at the FERC in connection with this proposed change to its FERC Tariff;
land
WHEREAS, the City Council has heard and considered all
evidence, both written and oral, presented in consideration of the
establishment of Vernon's new TRBAA and Appendix I to the TO Tariff
implementing the new TRBAA.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE
CITY OF VERNON AS FOLLOWS:
SECTION 1: The City Council of the City of Vernon hereby
finds and determines that the recitals contained hereinabove are true
land correct.
SECTION 2: The City Council of the City of Vernon further
finds that all persons have had the opportunity to be heard or to file
written comments to the proposed establishment of Vernon's new TRBAA
and Appendix I to the TO Tariff implementing the new TRBAA, and after
due consideration of any and all evidence submitted at the public
hearing determines that there are compelling reasons to justify the
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Now
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on
jestablishment of Vernon's new TRBAA and Appendix I to the TO Tariff
implementing the new TRBAA.
SECTION 3: The City Council of the City of Vernon hereby
approves the establishment of Vernon's new TRBAA and Appendix I to the
TO Tariff implementing the new TRBAA, to be effective July 1, 2002
except as conditioned below, described in the testimony and exhibits
prepared by Mr. Peter Lanzalotta, a copy of which is attached hereto as
Exhibit "A" and made a part hereof, pursuant to the TO Tariff and
consistent with the FERC decisions in FERC Docket No. EL00-105,
concerning that TRR and TO Tariff.
SECTION 4: The City Council of the City of Vernon directs
that the timing of implementation of Vernon's new TRBAA and Appendix I
to the TO Tariff be contingent on approval by the FERC of that timing,
so long as Vernon is kept financially whole.
SECTION 5: The City Council of the City of Vernon hereby
authorizes the submittal of the Prepared Direct Testimony of Peter J.
Lanzalotta on behalf of the City of Vernon to the FERC and the City
Clerk, or his designee, is hereby directed to send a certified copy of
this resolution to the City's counsel for regulatory matters to
linitiate the filing:
Channing D. Strother, Esq.
McCarthy, Sweeney& Harkaway
2175 K Street, NW, Ste. 600
Washington, D.C. 20037
SECTION 6: The City Council of the City of Vernon hereby
directs that its legal counsel represent to the FERC that Vernon
pledges its continued cooperation to work with the ISO to implement its
new TRBAA and Appendix I to the TO Tariff, so long as Vernon is kept
financially whole, at the time and in the manner that the FERC
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determines is most appropriate, but is compelled to make its filing at
this time by the terms of the current Vernon TO Tariff and by the terms
of the current ISO Tariff, as approved by the FERC.
SECTION 7: The City Clerk of the City of Vernon shall
certify to the passage of this resolution, and thereupon and thereafter
the same shall be in full force and effect.
APPROVED AND ADOPTED this 26th day of June, 2002.
LEONIS C. MA BURG, Mayor
ATTEST:
BRUCE V. MALKENHORST, City Clerk
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STATE OF CALIFORNIA )
) ss
COUNTY OF LOS ANGELES )
I, BRUCE V. MALKENHORST, City Clerk of the City of Vernon, do
hereby certify that the foregoing Resolution, being Resolution No.
7980, was duly adopted by the City Council of the City of Vernon at an
adjourned regular meeting of the City Council duly held on Wednesday,
June 26, 2002, and thereafter was duly signed by the Mayor of the City
of Vernon.
(SEAL)
BRUCE V. MALKENHORST, City Clerk
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EXHIBIT
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EXHIBIT V - 1
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UNITED STATES OF AMERICA
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BEFORE THE
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FEDERAL ENERGY REGULATORY COMMISSION
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CITY OF VERNON, CALIFORNIA ) DOCKET NO. ER02-
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Prepared Direct Testimony of
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Peter J Lanzalotta
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on behalf of the
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City of Vernon, California
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May, 2002
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Q.
Please state your name, affiliation and business address.
25
A.
Peter J. Lanzalotta, Lanzalotta & Associates LLC, 9762 Polished Stone,
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Columbia, Maryland 21046.
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Q.
Please describe your educational background.
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A.
I am a graduate of Rensselaer Polytechnic Institute, where I received a Bachelors
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of Science degree in Electric Power Engineering. In addition, I hold a Masters
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degree in Business Administration with a concentration in Finance from Loyola
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College in Baltimore.
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Q.
Please describe your professional experience.
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A.
I am a Principal of Lanzalotta & Associates LLC, which was formed in January
r City of Vernon, California,
Docket No. ER02-
Exhibit No. V-1
Page 2 of 8
1 2001. Prior to that, I was a partner of Whitfield Russell Associates, with which I
2 had been associated since March 1982. My areas of expertise include electric
3 system planning and operation, cost of service study, and utility rate design. I am
4 a registered professional engineer in the states of Maryland and Connecticut. My
5 prior professional experience is described in Exhibit No. V-2, which is attached
6 hereto.
7
8 I have been involved with the planning and operation of electric utility systems
9 and with utility regulatory matters, including cost of service, cost allocation, and
10 rate design, as an employee of and as a consultant to a number of privately- and
11 publicly -owned electric utilities, regulatory agencies, developers, and electric
12 loads over a period exceeding thirty years.
13
14 Q. Have you qualified to offer expert testimony in any judicial or quasi-judicial
15 proceedings?
16 A. Yes, I have presented expert testimony before the FERC and before regulatory
17 commissions and other judicial and legislative bodies in 16 states, the District of
18 Columbia, and the Provinces of Alberta and Ontario. My clients have included
19 utilities, regulatory agencies, ratepayer advocates, independent producers,
20 industrial consumers, the United States Government, and various city and state
21 government agencies. The proceedings in which I have testified are listed in
22 Exhibit No. V-3.
23
24 Q. What is the purpose of your testimony?
25 A. The purpose of my testimony is to present Vernon's Transmission Revenue
26 Balancing Account Adjustment C TRBAN) proposed to become effective July 1,
27 2002.
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29 Q. Can you summarize your testimony?
30 A. Yes. The Vernon TRBAA is a rate -making mechanism that is part of Vernon's
1)
City of Vernon, California
Docket No. ER02-
Exhibit No. V- l
Page 3 of 8
1 TO Tariff, as approved by the FERC. The balance in the Vernon TRBA as of
2 December 31, 2001, including interest, is $42,340. For 2002, wheeling revenues
3 are projected to be a credit of $432,883 while usage/congestion revenues are
4 projected to be a credit of $30,153. Finally, receipt in 2002 of transmission
5 credits payable, but not paid, in 2001 was projected to be a credit of $107,891.
6 Taken together, these items sum up to a TRBAA for the twelve months starting
7 July 1, 2002 of a credit, or negative, balance of $528,587.
8
9 Q. What is the TRBAA?
10 A. The TRBAA is a ratemaking mechanism designed to ensure that all Transmission
11 Revenue Credits ("TRCs") are flowed through to transmission customers. The
12 California ISO Tariff describes the annual TRBAA, in Appendix F, Schedule 3,
13 Section 6.1(b), as "... a dollar amount based on projected Transmission Revenue
14 Credits as adjusted for the true up of the prior year's difference between projected
15 and actual credits."
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17 Section 5.2 of the Vernon TO Tariff identifies the items to be reflected in the
18 TRBAA and sets forth the procedure for revising the TRBA on an annual basis, as
19 follows:
20 5.2 Transmission Revenue Balancing Account Adjustment
21 ("TRBAA") The Participating TO shall maintain a Transmission
22 Revenue Balancing Account ("TRBA") that will ensure that all
23 Transmission Revenue Credits and the refunds, specified in Sections 6 and
24 8 of Appendix F, Schedule 3 of the ISO Tariff, flow through to
25 transmission customers.
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27 The TRBAA shall be equal to: TRBAA = TRCF + TRCT+ I .
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29 TRCT = The balance representing the prior period difference
30 between the projected Transmission Revenue Credits and
3
a
City of Vernon, California
Docket No. ER02-
Exhibit No. V-1
Page 4 of 8
1 the actual credits.
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3 TRCF = The forecast of Transmission Revenue Credits for the
4 following calendar year.
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6 I = The interest balance for the TRBA, which shall be
7 calculated using the interest rate pursuant to Section
8 35.19(a) of FERC's regulations under the Federal Power
9 Act (18 CFR Section 35.19(a)). Interest shall be calculated
10 based on the average TRBA principal balance each month,
11 compounded quarterly.
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13 Q. How are Transmission Revenue Credits ("TRCe) defined?
14 A. TRCs are defined in Section 3.25 of the Vernon TO Tariff as follows:
15 3.25 Transmission Revenue Credit. The net of: 1) the revenues received
16 by the Participating TO from the ISO for Wheeling service, Usage
17 Charges (excluding any Usage Charges received by the Participating TO
18 as an FTR Holder) and from the sale of an FTR; and 2) the shortfall or
19 surplus resulting from any cost differences between Transmission Losses
20 and Ancillary Service requirements associated with Existing Rights and
21 the ISO's rules and protocols.
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23 Q. What are the results of your calculation of Vernon's TRBAA to be effective July
24 1, 2002?
25 A. A summary of the elements of the Vernon TRBAA is shown in Exhibit No. V-4.
26 It shows that the balance in the Vernon TRBA as of December 31, 2001,
27 including interest, is $42,340. Wheeling revenues are projected to be a credit of
28 $432,883 while usage/congestion revenues are projected to be a credit of $30,153.
29 Finally, receipt in 2002 of transmission credits payable, but not paid, in 2001 was
30 projected to be a credit of $107,891. Taken together, these items sum up to a
0
1
City of Vernon, California
Docket No. ER02-
Exhibit No. V-1
Page 5 of 8
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TRBAA for the twelve months starting July 1, 2002 of a credit, or negative,
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balance of $528,587.
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It is worth noting that all of,the Vernon transmission facilities that are reflected in
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Vernon's transmission rates and the TRBAA are high voltage facilities.
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Therefore, there is no need to allocate TRCs, or other TRBAA components,
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between high voltage and low voltage rates.
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I will review the derivation of the elements of the Vernon TRBAA using the
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components of the TRBAA, as stated in Section 5.2 of the Vernon TO Tarrif and
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listed above, as a reference. The TRBAA is equal the sum of : TRCF + TRCT+
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I.
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Q.
How was the balance of $42,340 in the Vernon TRBAA as of December 31, 2001
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determined?
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A.
This balance represents the sum of the TRCT and the I components.
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TRCT
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Q.
What does TRCT represent?
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A.
TRCT represents a balance that reflects the prior period difference between the
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projected TRCs and the actual credits. The prior period in this case is calendar
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year 2001.
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A summary of the determination of the December 31, 2001 balance in the Vernon
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TRBA is shown in Exhibit No. V-5. The TRCT component reflects the
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previously projected 2001 TRCs for Vernon of $364,048, or $30,377 per month,
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as reflected on Line No. 11 of Exhibit No. V-5, adjusted for actual payable TRCs
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reflecting 1) congestion refunds payable to the transmission owner ("TO"), i.e.,
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Vernon, and reflecting 2) high voltage wheeling revenue payable to the TO. This
5
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City of Vernon, California
Docket No. ER02-
Exhibit No. V-1
Page 6 of 8
1 adjustment is reflected in Lines 12-15 of Exhibit No. V-5 and produces the Under
2 (Over) Collection figures for the monthly payable TRC balances reflected in Line
3 15 of Exhibit No. V-5. These monthly balances are carried forward from month
4 to month in Line 17 of Exhibit No. V-5. Interest is calculated monthly (the I
5 component) on the under (over) payment and is compounded quarterly into the
6 monthly payable TRC balances, pursuant to Section 5.2 of the Vernon TO Tariff.
7 The interest calculation for payable TRC balances is shown in Lines 19-23 of
8 Exhibit V-5.
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10 These payable TRC balances are then adjusted to reflect the fact that transmission
11 revenues that were payable to the TO in 2001 were sometimes not actually paid to
12 the TO in 2001. These payable revenues that were not paid in 2001 are reflected
13 in Lines 31-37 of Exhibit No. V-5, under "Exclusions From 2001 TRBA" and are
14 subtracted from the payable TRC balances at the end of the year. Interest is
15 calculated monthly on the Exclusion balance and is compounded quarterly into
16 the monthly Exclusion balances. The interest calculation for the monthly
17 Exclusion balances is shown in Lines 39-44 of Exhibit V-5.
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19 I - Interest
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21 Q. What does the I component of the TRBAA formula reflect?
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23 A. As discussed above, the I component reflects interest on payable balances and on
24 unpaid payable balances. As provided in Section 5.2 of Vernon's TO tariff,
25 monthly interest carrying costs are calculated using the 18 CFR § 35.19(a) interest
26 rates and calculation method. These interest rates reflect the prime rate values
27 published in the Federal Reserve Bank's "Selected Interest Rates" and, for each
28 month in a quarter, the average rate for the three months preceding the quarter is
29 applied, as provided for in 18 CFR § 35.19(a). The Commission publishes notice
30 of these rates quarterly.
A
City of Vernon, California
Docket No. ER02-
Exhibit No. V-1
Page 7 of 8
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2 The calculation of interest is reflected in Exhibit V-5 and is included as an
3 integral part of the calculation of the year-end 2001 TRBA balance. It is not
4 reflected as a separate line item in Exhibit V-4.
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6 TRCF
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8 Q. What does TRCF stand for?
9 A. TRCF stands for the forecast of TRCs for the following calendar year, in this case,
10 2002. These forecast TRCs reflect projected wheeling revenues and projected
11 usage/congestion revenues for 2002.
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13 Q. How were the projected wheeling revenues and usagetcongestion revenues
14 developed?
15 A. Wheeling revenues, which correspond to account 384, are projected to be a credit
16 of $432,883 while usage/congestion revenues, which correspond to accounts 204
17 and 254, are projected to be a credit of $30,153. A summary of the 2001 monthly
18 accruals to these accounts is shown in Exhibit No. V-9. The annual accrual in
19 2001 for account 384 regarding wheeling revenues is $432,883, while the annual
20 accruals in accounts 204 and 254 regarding day -ahead and hour -ahead interzonal
21 congestion refunds are $23,936 and $6,217, respectively, totaling $30,153.
22
23 These values reflect preliminary 2001 invoice amounts, as adjusted to final
24 invoice amounts, as shown in Exhibit V-10. These historical 2001 values were
25 used to estimate expected values for these accounts in 2002. The 12-month
26 ` projected values for 2002 are as reflected in Exhibit No. V-6.
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28 Q. Are there any other components of forecast revenue credits for 2002?
29 A. Yes. Forecast revenue credits for 2002 also include a component to reflect TRCs
30 that were payable in 2001 but were not paid in 2001. Payment of these revenues
7
City of Vernon, California
Docket No. ER02-
Exhibit No. V-1
Page 8 of 8
1 is projected to occur in 2002.
2
3 Q. How were the receipts in 2002 of transmission revenues payable, but not paid, in
4 2001 determined to be a credit of $107,891.
5 A. This was part of the ,calculation of the December 31, 2001 TRBA balance, which
6 is summarized in Exhibit No. V-5. The development of the transmission revenues
7 that are payable is discussed above. These revenues are adjusted to reflect the
8 monthly relationship between credits and charges on Vernon's ISO account.
9 Because there are monthly charges that Vernon owes to the ISO, these are used to
10 proportionately reduce the transmission revenues payable to Vernon, resulting in
11 the adjusted credits shown in Exhibit No. V-8.
12
13 These adjusted credits are then reduced to reflect actual payments received in
14 2001, as shown in Exhibit No. V-7. A portion of the total ISO payments are
15 allocated to accounts 204, 254, and 384 based on the relationship of the sum of
16 the adjusted credits in each of these accounts to the total invoice amount. The
17 remaining unpaid amounts are shown at the bottom of Exhibit No. V-7. These
18 unpaid amounts are reflected in the Exclusions portion of Exhibit No. V-5, where
19 they are used to reduce the "overcoffection" reflected in the authorized
20 revenuetcredits portion of the exhibit.
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22 Q. Does this conclude your prepared direct testimony?
23 A. Yes.
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R
AFFIDAVIT OF
PETER J. LANZALOTTA
State of Maryland )
ss.
County of Howard )
Peter J. Lanzalotta, being duly sworn, deposes and states that the foregoing Direct
Testimony prepared on behalf of the City of Vernon, California, and the attached exhibits, were
prepared by him or at his direction and under his supervision, that he would respond in the same
manner as shown therein if asked the questions therein, and that the facts contained therein are
true and correct to the best of his knowledge, information, and belief.
• /
SUBSCRIBED AND SWORN TO before me, this 22nd day of May, 2002.
`tom_
NOTAA PUBLIC in and for
the State of Maryland. My
commission expires 6 - o /- 0
NOTARIAL SEAL
City of Vernon, California
Docket No. ER02-
Exhibit No. V-2
Page 1 of 2
2 Prior Experience of Peter J. Lanzalotta
3
4 Mr. Lanzalotta has more than twenty-five years experience in electric utility
5 system planning, power pool operations, distribution operations, electric
6 service reliability, load and price forecasting, and market analysis and
7 development. Mr. Lanzalotta has appeared as an expert witness on utility
8 reliability, planning, and operation matters in more than 50 proceedings in 13
9 states, the District of Columbia, and the Provinces of Alberta and Ontario.
10 He has developed evaluations of electric utility system cost, value, reliability,
11 and condition. He has participated in negotiations between utilities and
12 customers or regulators in more than ten states regarding transmission access,
13 the need for facilities, electric rates, electric service reliability, the value of
14 electric system components, and system operator structure under wholesale
15 competition.
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17 Prior to his forming Lanzalotta & Associates LLC in 2001, he was a Partner
18 at Whitfield Russell Associates for fifteen years and a Senior Associate for
19 approximately four years before that. He holds a Bachelor of Science in
20 Electric Power Engineering from Rensselaer Polytechnic Institute and a
21 Master of Business Administration with a concentration in Finance from
22 Loyola College of Baltimore.
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24 Prior to joining Whitfield Russell Associates in 1982, Mr. Lanzalotta was
25 employed by the Connecticut Municipal Electric Energy Cooperative
26 ("CMEEC) as a System Engineer. He was responsible for providing
27 operational, financial, and rate expertise to Coop's budgeting, ratemaking and
28 system planning processes. He participated on behalf of CMEEC in the
29 Hydro-Quebec/New England Power Pool Interconnection project and
30 initiated the development of a database to support CMEEC's pool billing and
31 financial data needs.
kya
33 Prior to my CMEEC employment, He served as Chief Engineer at the South
34 Norwalk (Connecticut) Electric Works, with responsibility for planning, data
35 processing, engineering, rates and tariffs, generation and bulk power sales,
36 and distribution operations. While at South Norwalk, He conceived and
City of Vernon, California
Docket No. ER02-
Exhibit No. V-2
Page 2 of 2
1 implemented, through Northeast Utilities and NEPOOL, a peak -shaving plan
2 for South Norwalk and a neighboring municipal electric utility, which resulted
3 in substantial power supply savings. He programmed and implemented a
4 computer system to perform customer billing and maintain accounts
5 receivable accounting. He also helped manage a generating station overhaul
6 and the undergrounding of the distribution system in South Norwalk's
7 downtown.
8
9 From 1977 to 1979, Mr. Lanzalotta. worked as a public utility consultant for
10 Van Scoyoc & Wiskup and separately for Whitman Requart & Associates in
11 a variety of positions. During this time, he developed cost of service, rate
12 base evaluation, and rate design impact data to support direct testimony and
13 exhibits in a variety of utility proceedings, including utility price squeeze
14 cases, gas pipeline rates, and wholesale electric rate cases.
15
16 Prior to that, He worked for approximately 2 years as a Service Tariffs
17 Analyst for the Finance Division of the Baltimore Gas & Electric Company
18 where he developed cost and revenue studies, evaluated alternative rate
19 structures, and studied the rate structures of other utilities for a variety of
20 applications. He was also employed by BG&E in Electric System Operations
21 for approximately 3 years, where his duties included operations analysis,
22 outage reporting, and participation in the development of BG&E's first
23 computerized customer information and service order system.
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25 Mr. Lanzalotta is a member of the Institute of Electrical & Electronic
26 Engineers, the National Society of Professional Engineers, the Association of
27 Energy Engineers, the National Fire Protection Association, the American
28 Solar Energy Society, and the Financial Management Association. He is also
29 registered Professional Engineer in the states of Maryland and Connecticut.
City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 1 of 10
Proceedings in Which
Peter I Lanzalotta
HaC Testified
1
1.
In re! Public Service Company of New Mexicn, Docket Nos. ER78-337
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and ER78-338 before the Federal Energy Regulatory Commission,
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concerning the need for access to calculation methodology underlying filing.
4
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2.
In ree Baltimore Gas and Electric Company,, Case No. 7238-V before the
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Maryland Public Service Commission, concerning outage replacement power
7
costs.
8
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3.
In re- Hairdan Lighting & Pnwer Company, Texas Public Utilities
10
Commission Docket No. 4712, concerning modeling methods to determine
11
rates to be paid to cogenerators and small power producers.
12
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4.
In ree Nevada Power Company., Nevada Public Service Commission,
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Docket No. 83-707 concerning rate case fuel inventories, rate base items, and
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O&M expense.
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5.
In re- Virginia Fitw-tric & Power Company, Virginia State Corporation
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Commission, Case No. PUE820091- concerning the operating and reliability-
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based need for additional transmission facilities.
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6.
In re! Public Service Electric & Gas Company, New Jersey Board of
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Public Utilities, Docket No. 831-25, concerning outage replacement power
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costs.
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7.
In re! Philadelphia Electric Com= any, Pennsylvania Public Utilities
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Commission, Docket No. P-830453, concerning outage replacement power
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costs.
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City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 2 of 10
Proceedings in Which
Peter I Lanzalotta
Has Testified
8. In ree Cincinnati Go. & Electric Company, Pablic Utilities Commission of
Ohio, Case No. 83-33-EL-EFC, concerning the results of an
operations/fuel-use audit conducted by Mr. Lanzalotta.
9. In re- Kancac City Power and Light Company, before the State
Corporation Commission of the state of Kansas, Docket Nos. 142,099-U and
120,924-U, concerning the determination of the capacity, from a new
base -load generating facility, needed for reliable system operation, and the
capacity available from existing generating units.
10. In reo Philadelphia F,lectric Company,; Pennsylvania Public Utilities
Commission, Docket No. R-850152, concerning the determination of the
capacity, from a new base -load generating facility, needed for reliable system
operation, and the capacity available from existing generating units.
11. In re!• ARC Methnd Prnposed for Applicatinn to Puhlic Service
CamUnnv of Calarnda, before the Public Utilities Commission of the State
of Colorado, on behalf of the Federal Executive Agencies ("FEA"),
concerning a production cost allocation methodology proposed for use in
Colorado.
12. In re- numiecne Light Comp nX, Docket No. R-870651, before the
Pennsylvania Public Utilities Commission, on behalf of the Office of
Consumer Advocate, concerning the system reserve margin needed for
reliable service.
13. In res Pennsylvania Power Camnanvy, Docket No. I-7970318 before the
Pennsylvania Public Utilities Commission, on behalf of the Office of
Consumer Advocate, concerning outage replacement power costs.
City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 3 of 10
Proceedings in Which
Peter J. Lanzalotta
Has Testified
1
14.
In ree Commonwealth Edisnn Company,, Docket No. 87-0427 before the
2
Illinois Commerce Commission, on behalf of the Citizen's Utility Board of
3
Illinois, concerning the determination of the capacity, from new base -load
4
generating facilities, needed for reliable system operation.
5
6
15.
In re• Central Illinnis Public Service Company, Docket No. 88-0031
7
before the Illinois Commerce Commission, on behalf of the Citizen's Utility
8
Board of Illinois, concerning the degree to which existing generating capacity
9
is needed for reliable and/or economic system operation.
10
11
16.
In re- Illinois Power Cmmpany, Docket No. 87-0695 before the State of
12
Illinois Commerce Commission, on behalf of Citizens Utility Board of
13
Illinois, Governors Office of Consumer Services, Office of Public Counsel
14
and Small Business Utility Advocate, concerning the determination of the
15
capacity, from a new base -load generating facility, needed for reliable system
16
operation, and the capacity available from existing generating units.
17
18
17.
In re- Florida Power Corporation, Docket No. 860001-EI-G {Phase II},
19
before the Florida Public Service Commission, on behalf of the Federal
20
Executive Agencies of the United States, concerning an investigation into fuel
21
supply relationships of Florida Power Corporation.
22
23
18.
In re! Potomac Electric Power Company, before the Public Service
24
Commission of the District of Columbia, Docket No. 877, on behalf of the
25
Public Service Commission Staff, concerning the need for and availability of
26
new generating facilities.
27
City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 4 of 10
Proceedings in Which
Peter J. Lanzalotta
Hay, Testified
19. In reo Snnth Carolina Electric & Gas Company before the South Carolina
Public Service Commission, Docket No. 88-681-E, On Behalf of the State of
Carolina Department of Consumer Affairs, concerning the capacity needed
for reliable system operation, the capacity available from existing generating
units, relative jurisdictional rate of return, reconnection charges, and the
provision of supplementary, backup, and maintenance services for QFs.
20. In reo Commonwealth Edison Company,, Illinois Commerce Commission,
Docket Nos. 87-0169, 87-0427, 88-0189, 88-0219, and 88-0253, on behalf of
the Citizen's Utility Board of Illinois, concerning the determination of the
capacity, from a new base -load generating facility, needed for reliable system
operation.
21. In ree I1linois Power Company, Illinois Commerce Commission, Docket
No. 89-0276, on behalf of the Citizen's Utility Board Of Illinois, concerning
the determination of capacity available from existing generating units.
22. In re- Jersey Central Power & bight Companx, New Jersey Board of
Public Utilities, Docket No. EE88-121293, on behalf of the State of New
Jersey Department of the Public Advocate, concerning evaluation of
transmission planning.
23. In ree Canal F,leeb is Comp nX, before the Federal Energy Regulatory
Commission, Docket No. ER90-245-000, on behalf of the Municipal Light
Department of the Town of Belmont, Massachusetts, concerning the
reasonableness of Seabrook Unit No. 1 Operating and Maintenance expense.
City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 5 of 10
Proceedings in Which
Peter I Lanzalotta
Na% Testified
1
24.
In re• New Hampshire Electric Cooperative Rate Plan _PrOjImal, before
2
the New Hampshire Public Utilities Commission, Docket No. DR90-078, on
3
behalf of the New Hampshire Electric Cooperative, concerning contract
4
valuation.
5
6
25.
In re! Connecticut I.ig_ht & Power Company, before the Connecticut
7
Department of Public Utility Control, Docket No. 90-04-14, on behalf of a
8
group of Qualifying Facilities concerning O&M expenses payable by the QFs.
9
10
26.
In re! Duke Power Company, before the South Carolina Public Service
11
Commission, Docket No. 91-216-E, on behalf of the State of South Carolina
12
Department of Consumer Advocate, concerning System Planning, Rate
13
Design and Nuclear Decommissioning Fund issues.
14
15
27.
In re!• jersey Central Power & I Aght Compan , before the Federal Energy
16
Regulatory Commission, Docket No. ER91-480-000, on behalf of the
17
Boroughs of Butler, Madison, Lavallette, Pemberton and Seaside Heights,
18
concerning the appropriateness of a separate rate class for a large wholesale
19
customer.
20
21
28.
Tn r�Polomac Electric Power_Comnany, before the Public Service
22
Commission of the District of Columbia, Formal Case No. 912, on behalf of
23
the Staff of the Public Service Commission of the District of Columbia,
24
concerning the Application of PEPCO for an increase in retail rates for the
25
sale of electric energy.
26
27
29.
Commonwealth of Pennsylvania. oce of Representatives, General
28
Assembly House Bill No. 2273. Oral testimony before the Committee on
29
Conservation, concerning proposed Electromagnetic Field Exposure
30
Avoidance Act.
31
r
t
City of Vernon, California
Docket No. ER02
Exhibit No. V-3
Page 6 of 10
Proceedings in Which
Peter J. Lanzalotta
Hnc Testified
1
30.
In re! Hearings nn the 1990 Onfigrin BLydra De mand\Snppl an, before
2
the Ontario Environmental Assessment Board, concerning Ontario Hydro's
3
System Reliability Planning and Transmission Planning.
4
5
31.
In re! Mani Electric Company., Docket No. 7000, before the Public
6
Utilities Commission of the State of Hawaii, on behalf of the Division of
7
Consumer Advocacy, concerning MECO's generation system, fuel and
8
purchased power expense, depreciation, plant additions and retirements,
9
contributions and advances.
10
11
32.
In ree Hawaiian F,lectric Campy, Inc... Docket No. 7256, before the
12
Public Utilities Commission of the State of Hawaii, on behalf of the Division
13
of Consumer Advocacy, concerning need for, design of, and routing of
14
proposed transmission facilities.
15
16
33.
In re- Cnmmnnwealth Edison Company, Docket No. 94-0065 before the
17
Illinois Commerce Commission on behalf of the City of Chicago, concerning
18
the capacity needed for system reliability.
19
20
34.
In re• Cnmmnnwealth Edison Company, Docket No. 93-0216 before the
21
Illinois Commerce Commission on behalf of the Citizens for Responsible
22
Electric Power, concerning the need for proposed 138 kV transmission and
23
substation facilities.
24
25
35.
In re! Cnmmnnwealth Vdicnn Company' Docket No. 92-0221 before the
26
Illinois Commerce Commission on behalf of the Friends of Illinois Prairie
27
Path, concerning the need for proposed 138 kV transmission and substation
28
facilities.
29
30
36.
In re! Cnmmnnwealth F,dicnn Company,; Docket No. 94-0179 before the
31
Illinois Commerce Commission on behalf of the Friends of Sugar Ridge,
32
concerning the need for proposed 138 kV transmission and substation
City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 7 of 10
Proceedings in Which
Peter I Lanzalotta
Has Testified
l facilities.
2
3 37. In re! Pnhlic Service Comlianv of Colorado, Docket Nos. 95A-531EG and
4 95I-464E before the Colorado Public Utilities Commission on behalf of the
5 Office of Consumer Counsel, concerning a proposed merger with
6 Southwestern Public Service Company and a proposed performance -based
7 : rate -making plan.
8
9 38. In reeve South Cnrnlinn Flectrie R Gas C amlIany,, nuke Power Company.
10 and Carolina Power & Light Comte, Docket No. 95-1192-E, before the
11 South Carolina Public Service Commission on behalf of the South Carolina
12 Department of Consumer Advocate, concerning avoided cost rates payable to
13 qualifying facilities.
14
15 39. In re! I aiyrence A Raker v Truckee Donner Public Tltility Dim=
16 Case No. 55899, before the Superior Court of the State of California on
17 behalf of Truckee Donner Public Utility District, concerning the
18 reasonableness of electric rates.
T
20 40. In re! Black Hills Power & Light Com,pany, Docket No. OA96-75-000,
21 before the Federal Energy Regulatory Commission on behalf of the City of
22 Gillette, Wyoming, concerning the Black Hills' proposed open access
23 transmission tariff.
24
25 41.
26 Cnm ap nv for Approvals of the Restructuring Plan Under Section 2806,
27 Docket Nos. R-00974008 and R-00974009 before the Pennsylvania PUC on
28 behalf of Operating NUG Group, concerning miscellaneous restructuring
29 issues.
30
31 42. In re! New Iersey State Restructuring Proceeding for consideration of
32 proposals for retail competition under BPU Docket Nos. EX94120585U;
City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 8 of 10
Proceedings in Which
Peter I Lanzalotta
Has Testified
1 E097070457; E097070460; E097070463; E097070466 before the New
2 Jersey BPU on behalf of the New Jersey Division of Ratepayer Advocate,
3 concerning load balancing, third party settlements, and market power.
4
5 43. In rp• Arbitration Proceeding in City of hicagn v_ f'nmmnnwealth
6 Fdisnn for consideration of claims that franchise agreement has been
7 breached, Proceeding No. 51Y-114-350-96 before an arbitration panel board
8 on behalf of the City of Chicago concerning electric system reliability.
9
10 44. In rp• Transalta ITtilities f'nrnnration, Application No. RE 95081 on
11 behalf of the ACD companies, before the Alberta. Energy And Utilities Board
12 in reference to the use and value of interruptible capacity.
13
14 45. In re! Consolidated F,disnn Company, Docket No. EL99-58-000 on behalf
15 of The Village of Freeport, New York, before FERC in reference to remedies
16 for a breach of contract to provide firm transmission service on a non-
17 discriminatory basis.
18
19 46. In rpe FSRI Alherta Ltd__ Application No. 990005 on behalf of the Firm
20 Customers, before the Alberta. Energy And Utilities Board concerning the
21 reasonableness of the cost of service plus management fee proposed for 1999
22 and 2000 by the transmission administrator.
23
24 47. In re! Roth Carolina Electric & Gas C omnany, Docket No. 2000-0170-E
25 on behalf of the South Carolina Department of Consumer Affairs before the
26 Public Service Commission of South Carolina concerning an application for a
27 Certificate of Environmental Compatibility and Public Convenience and
28 Necessity for new and repowered generating units at the Urquhart generating
29 station.
30
31 48 In re! RGF, Case No. 8837 on behalf of the Maryland Office of People's
32 Counsel before the Maryland Public Service Commission concerning
City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 9 of 10
Proceedings in Which
Peter I Lanzalotta
l
proposed electric line extension charges.
2
3
49.
In re- PEPCO, Case No. 8844 on behalf of the Maryland Office of People's
4
Counsel before the Maryland Public Service Commission concerning
5
proposed electric line extension charges.
6
7
50.
In re- GmPnwer Andercnn LI.C- Docket No. 2001-78-E on behalf of the
8
South Carolina Department of Consumer Affairs before the Public Service
9
Commission of South Carolina concerning an application for a Certificate of
10
Environmental Compatibility and Public Convenience and Necessity for new
11
generating units at the GenPower Anderson LLC generating station.
12
13
51.
In re• Pike County_ight & Power Cmm1pane , Docket No. P-00011872, on
14
behalf of Pennsylvania Office of Consumer Advocate before the Pennsylvania
15
Public Utility Commission concerning the Pike County request for a retail rate
16
cap exception.
17
18
52.
In re! Pntamac Electric Power Company and_ .one-e ix, Case No. 8890,
19
on behalf of the Maryland Office of People's Counsel before the Maryland
20
Public Service Commission concerning the proposed merger of Potomac
21
Electric Power Company and Conectiv.
22
23
53.
In re! Smith Cnrnlina Electric & (Tac C.mmpanocket No. 2001-420-E
24
on behalf of the South Carolina Department of Consumer Affairs before the
25
Public Service Commission of South Carolina concerning an application for a
26
Certificate of Environmental Compatibility and Public Convenience and
27
Necessity for new generating units at the Jasper County generating station.
28
29
54.
In ref Connecticut Light & Power Company. ocket No. 217 on behalf of
30
the Towns of Bethel, Redding, Weston, and Wilton, Connecticut before the
31
Connecticut Siting Council concerning an application for a Certificate of
32
Environmental Compatibility and Public Need for a new transmission line
City of Vernon, California
Docket No. ER02-
Exhibit No. V-3
Page 10 of 10
Proceedings in Which
Peter I Lanzalotta
Hag Te%tified
l facility between Plumtree Substation, Bethel and Norwalk Substation,
2 Norwalk.
3
4
City of Vernon, Califomia
Docket No. ER02-
Exhibit No. V-4
A B C D E
F
G
1
CITY OF VERNON
2
TRANSMISSION
REVENUE
BALANCING
ACCOUNT ADJUSTMENT
(TRBAA)
3
4
5
IDESCRIPTION
TOTAL
6
7
Balance in TRBA on December 31,
2001
$42,340
8
including interest
9
10
Forecast Wheeling Revenues
($432,883)
11
12
Forecast Usage/Congestion Revenues
($30,153)
13
14
1 Receipt of
Prior Year
Transmission Credits from ISO
($107,891)
15
16
TRBAA
($528,587)
17
18
19
20
Source
21
Line 7
Line 52, V - 5
22
Line 10
Line 17, V - 6
23
Line 12
Line 17, V - 6
24
Line 14
Line 50, V - 5
25
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City of Vemon, California
Docket No. ER02-
Exhibit V-6
A I B I C D E
1
CITY OF VERNON
2
12 - MONTH FORECAST TRANSMISSION CREDITS
3
Effective 7/1 /02
4
5
6
Wheeling
UsagelCongestion
7
Item
Credits
Credits
8
9
2001 Credits - Account 204
$0.00
($23,936.31)
10
11
2001 Credits - Account 254
$0.00
($6,217.14)
12
13
2001 Credits - Account 384
($432,882.59)
$0.00
14
15
2001 Credits- Total of Above
($432,882.59)
($30,153.45)
16
17
Projected Credits
($432,882.59)
($30,153.45)
18
19
20
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City of Vernon California
Docket No. ER02-
Exhibit No. V-10
A B C D E F ' G
H
1
2
Transmission Credits Detail
3
4
Service Month
Payment Due
Invoice #
Invoice Amount
204'
254'
384
5
6
Preliminary Invoice
7
8
Jan-01
Apr-01
14536
($991,999.12)
($918.20)
($37.94)
($48,102.51)
9
Feb-01
May-01
101
Mar-01
Jun-01
15279
($1,810,711.00)
($142.32)
($675.66)
($59,528.15)
11
Apr-01
Jun-01
15666
($634,981.64)
($22,025.66)
($2,333.27)
($34,219.60)
12
Apr-01
Jul-01
15808
($107,840.26)
13
May-01
Aug-01
15976
($205,669.76)
$0.00
$0.00
($35,090.39)
14
Jun-01
Aug-01
16318
($932,408.04)
$0.001
$0.00
($33,636.18)
15
Jul-01
Oct-01
168M
($804,920.47)
($262.50)
($5.10)
($54,592.37)
16
Aug-01
Nov-01
17168
($728,357.84)
($585.60)
($47.28)
($59,658.91)
171
Sep-01
Dec-01
17418
($700,787.
($36,954.12)
18
Oct-01
Jan-02
17638
($562,869.40)
($3,054.36)
($11,593.92)
19
Nov-01
Feb-02
17864
($768,115.37)
($9,806.59)
20
Dec-01
Mar-02
18241
($567,273.39)
($3,773.58)
21
22
23
Adjustments
24
Jan-01
Apr-01
14735
$5,147.77
25
Feb-01
May-01
15111
($2.03)
($63.53)
($51,190.99)
26
Mar-01
Jun-01
27
Apr-01
Jun-01
28
Apr-01
Jul-01
158M
$91.90
29
May-01
Aug-01
30
Jun-01
Aug-01
31
Jun-01
Sep-01
16563
$23.95
32
JUI-01
Oct-01
33
Aug-01
Nov-01
34
Sep-01
Dec-01
35
Oct-01
Jan-02
36
Nov-01
Feb-02
18024
$1.10
37
Dec-01
Mar-02
38
39
40
Final Invoice Amounts
41
42
Service Month
Pa meat Due
204`
254`
384
43
Jan-01
Apr-01
($918.20)
($37.94)
($42,954.74)
44
Feb-01
May-01
($2.03)
($53.53)
($51,190.99)
45
Mar-01
Jun-01
($142.32)
($675.66)
($59,528.15)
46
Apr-01
Jun-01
($22,025.66)
($2,333.27)
($34,127.70)
47
May-01
Aug-01
$0.00
$0.00
($35,090.39
481
Jun-01
Aug-01
$0.00
$0.00
($33,612.23)
49
Jul-01
Oct-01
($262.50)
($5.10)
($54,592.37)
50
Aug-01
Nov-01
($585.60)
($47.28)
($59,658.91)
51
Sep-01
Dec-01
$0.00
$0.00
($36,954.12)
52
Oct-01
Jan-02
$0.00
($3,054.36)
($11:593.92)
53
Nov-01
Feb-02
$0.00
$0.00
($9,805.49)
54
Dec-01
Mar-02
$0.00
$0.00
1 M.773.58)
551
TOTAL
($23,936.31)
($6,217.14)
($432,882.59
56
57
1 Only revenues associated with Transmission ownership are included. FTR revenues are not included.
58
ISOINVOICES Exh Fin 4-10 TRBA 5 22 02
Transmission Owner Tariff (cont.)
APPENDIX I
Transmission Revenue Requirement and TRBAA
The Vernon Base Transmission Revenue Requirement is S10,216,178.
The TRBAA is a negative $528,587 for the 12-month period effective July 1, 2002.
All of Vemon's transmission facilities and Entitlements placed under the ISO's Operational
Control are High Voltage Facilities as defined by the ISO Tariff.
The TRBAA will be recalculated annually consistent with the ISO Tariff, approved by the
Vernon City Council, and provided to the ISO.
Authorized by City of Vernon
Ordinmmce No. 9_Q4
Issued on: Resolutiam No._ Effective: July 1, 2002
First Revised Sheet No. 22
Sapeweding Ori&d Sheet No. 22
SUPPORTING
DOCUMENTS
May 29, 2002
TO: Bruce V. Malkenhorst, City Administrator
FROM: Kenneth J. DeDario, Director of Utilities K.P-W`
SUBJECT: Transmission Revenue Requirements
On August 29, 2000 Council established the Transmission Revenue Requirement (TRR)
associated with Vernon's high voltage transmission for the purpose of becoming a
Participating Transmission Owner with the ISO. The TRR and Transmission Owner (TO)
Tariff were approved by FERC on September 14, 2001. The TO Tariff requires the
establishment of the new Transmission Revenue Balancing Account Adjustment (TRBAA).
Mr. Peter Lanzalotta, an experienced FERC consultant with the firm of Lanzalotta &
Associates LLC was retained to assist in preparing and recommending the TRBAA to be
filed with FERC. The TRBAA will be recalculated annually consistent with the TO Tariff.
I recommend approval of the TRBAA as recommended by Mr. Lanzalotta and which is
fully explained in the attached testimony. I also recommend approval of the attached
j Appendix I to the TO Tariff which implements the TRBAA.
If you have any questions, please contact me. Thank you for your consideration.
KJD:ah
Attachments
Transmission Owner Tariff (cont.)
APPENDIX I
Transmission Revenue Requirement and TRBAA
The Vernon Base Transmission Revenue Requirement is $10,216,178.
The TRBAA is a negative $528,587 for the 12-month period effective July 1, 2002.
All of Vernon's transmission facilities and Entitlements placed under the ISO's Operational
Control are High Voltage Facilities as defined by the ISO Tariff.
The TRBAA will be recalculated annually consistent with the ISO Tanfl approved by the
Vernon City Council, and provided to the ISO.
Authorized by City of Vernon
Ordinance No. 940
Issued on:
Resolution No._ Effective: July 1, 2002
First Revised Sheet No. 22
Superseding Original Sheet No. 22
NOTICE OF PUBLIC HEARING
The City of Vernon will conduct a Public Hearing which
you may attend.
PLACE: Vernon City Hall
City Council Chambers
4305 Santa Fe Avenue
Vernon, CA 90058
DATE AND TIME: Wednesday, June 5, 2002, at 5:00 p.m.,
or as soon thereafter as the matter may
be heard
PURPOSE: To consider evidence to establish
Vernon's new Transmission Revenue
Balancing Account Adjustment for its
high voltage (over 200 kV) transmission
facilities and entitlements (all
located outside the City) pursuant to
Vernon's Transmission Owner Tariff
Any interested person may attend and may make an oral
presentation to the City Council at the time of the
hearing, or may present written comments prior to the
hearing.
If you challenge the approval of the establishment of
Vernon's new Transmission Revenue Balancing Account
Adjustment or any provision thereof in court, you may be
limited to raising only those issues you or someone else
raised at the hearing described in this notice or in
written correspondence delivered to the City of Vernon at,
or prior to, the meeting.
Information may be obtained by contacting the office
of the City Clerk at the above address.
The hearing may be continued or adjourned to a stated
time and place without further notice.
Dated: 3 „062
CE V. MALKENHOR T,
City Administrato /City Clerk
LANZALOTTA & ASSOCIATES LLC
PUBLIC UTILITY CONSULTANTS
9762 POLISHED STONE
COLUMBIA, MARYLAND 21046
Phone: (240) 456-0899
Facsimile: (240) 456-0898
E-Mail: petelam®lanzalotta.com
PETERJ. LAIVZ LOTTA
Principal
May 22, 2002
To: Jorge Somoano
City of Vernon, CA
From: Peter J. Lanzalotta
Re: Transmittal of Direct Testimony, Exhibits, and Original Affidavit
in TRBAA FERC Proceeding
Jorge:
Enclosed is an unbound original of my prepared direct testimony, my
notarized affidavit, my exhibits, and a front and back cover for use in the FERC
proceeding to address Vernon's TRBAA. If you wish, I can modify the cover,
prepare additional covers, or prepare complete bound copies. Please advise.
Sincerely,
Peter J. Lanzalotta
NOTICE OF PUBLIC HEARING
The City of Vernon will conduct a Public Hearing which
you may attend.
PLACE: Vernon City Hall
City Council Chambers
4305 Santa Fe Avenue
Vernon, CA 90058
DATE AND TIME: Wednesday, June 19, 2002, at 5:00 p.m.,
or as soon thereafter as the matter may
be heard
PURPOSE: To consider evidence to establish
Vernon's new Transmission Revenue
Balancing Account Adjustment for its
high voltage (over 200 kV) transmission
facilities and entitlements (all
located outside the City) pursuant to
Vernon's Transmission Owner Tariff
Any interested person may attend and may make an oral
presentation to the City Council at the time of the
hearing, or may present written comments prior to the
hearing.
If you challenge the approval of the establishment of
Vernon's new Transmission Revenue Balancing Account
Adjustment or any provision thereof in court, you may be
limited to raising only those issues you or someone else
raised at the hearing described in this notice or in
written correspondence delivered to the City of Vernon at,
or prior to, the meeting.
Information may be obtained by contacting the office
of the City Clerk at the above address.
The hearing may be continued or adjourned to a stated
time and place without further notice.
Dated: June 6, 2002
BRUtt V. MALKENHORST,
City Administrator/City C erk
AFFIDAVIT OF POSTING
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES) ss
CITY OF VERNON )
I, Gloria J. Orosco, Chief Deputy City Clerk of the City of Vernon do
hereby certify that I did, on thee of LM� 2002, have posted
one (1) copy of:
NOTICE OF PUBLIC HEARING, to be held June 5, 2002, regarding the
establishment of Vernon's new Transmission Revenue Balancing
Account Adjustment pursuant to Vernon's Transmission Owner
Tariff.
On the bulletin board in the lobby of the City Hall of the City of
Vernon located at 4305 Santa Fe Avenue, all in said City, there being
no newspaper of general circulation printed and published in the City
of Vernon. ')
Date: 6/�
� &) ".
Gloria J. Or sco
Chief Deputy City Clerk
State of California )
) ss
County of Los Angeles)
On �-L to ) ��Z before me, PaKwA �II�iSy1
Per onally appeared Gloria J. Orosco
Personally known to me
wee) to be the person (-s� whose name (4a-) is/tee- subscribed to the
instrument and acknowledged to me that-1-te/she/tUey-executed the
same in 4+i-s/her/t,h4e3x authorized capacity, and that by h-is/her/}h�T
signaturelra) on the instrument the person( -Er), or the entity upon
behalf of which the person(s) acted, executed the instrument.
WITNESS my hand and official seal
=ELA GIRflN
_ Commission i# 1328374
Notary Public - California y
Angeles na Cou
JqPMyComm. E�ires Nov 4, 2005
W
LAW Offlas
LAWRENCE W. BIERLEIN
MCCARTHY, SWEENEY & HARKAWAY, P.C.
FACSIMILE
DOUGLAS M. CANTER
SUITE 600
(202) 393-5727
JOHN M. CUTLER, JR.
ANDREW P. GOLDSTEIN
2175 K STREET, N.W.
EMAIL
STEVEN J. KALISH
WASHINGTON, D. C. 20037
MSHOMSHPC.COM
RICHARD D. LIEBERMAN
CHANNING D. STROTHER, JR.
(202) 393-5710
WEBSITE
OF COUNSEL
W Hm://W W.MSHPC.COM
KAREN R. O'BRIEN
May 31, 2002
BY HAND DELIVERY
Mr. Donald J. Gelinas
Associate Director
Office of Markets, Tariffs and Rates
Federal Energy Regulatory Commission
Dockets, Room lA
888 First Street, N.E.
Washington, D.C. 20426
Re: Fact -Finding Investigation of Potential Manipulation of Electric and Natural Gas
Prices Docket No. PA02-2-000
Dear Mr. Gelinas:
Herewith the City of Vernon, California ("Vernon"), submits its response to the
May 21, 2002 requests for admission and requests for production of documents.
Consistent with the instructions accompanying those requests, enclosed is one
copy of this response. Consistent with those instructions, these responses are made under
the accompanying affidavit of Kenneth J. DeDario, Vernon's Director of Utilities, which
appears as the last page of the of responses.
As stated in Vernon's previous responses in this docket, Vernon does not waive
jurisdiction or other statutory rights by, gladly, responding to these Commission requests.
Respectfully submitted,
t
Channing th*Jr.
Attorney for
City of Vernon, California
Enclosure
.-V
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Fact -Finding Investigation of Potential )
Manipulation of Electric and Natural Gas ) Docket No. PA02-2-000
Prices )
RESPONSES OF THE
CITY OF VERNON, CALIFORNIA TO
MAY 21, 2002 REQUESTS
DIRECTED TO:
MR. DONALD J. GELINAS
ASSOCIATE DIRECTOR
OFFICE OF MARKETS, TARIFFS AND RATES
DATED: MAY 31, 2002
Y
Request for Admission
A. Admit or Deny: The company engaged in activities referred to as "wash,"
"round trip" or "sell/buyback" trading. This trading involves the sale of an
electricity product to another company together with a simultaneous
purchase of the same product at the same price.
Response: Deny.
B. If you so admit, provide transaction by transaction details for all such
transactions your company engaged in, including, but not limited to, the
following:
1. Indicate the methods and rationale used to arrive at the
value or compensation of such transactions.
2. Indicate whether any such transactions were reported to
Platt's, Bloomberg, or any organization that monitors,
publishes or reports trading data (including bid -and -ask
data) or publishes or reports prices or forward indices.
3. Identify all such transactions referred to in question 3 that
were so published or reported, or were disseminated in any
manner.
4. Identify all traders that participated in such transactions, by
name and position within your company, if employed by
you, or by name and affiliation if they were not or are not
presently employed by your company.
5. Identify how such transactions were executed (e.g.,
whether an electronic platform was use to initiate the sale,
with the buy transaction subsequently arranged through a
broker or by telephone).
6. Describe all policies and procedures implemented to
prevent future transactions of this type.
Response: Not applicable.
Prepared by: Jorge C. Somoano, Vernon Assistant Director of Resource
Management
Under Supervision of: Kenneth J. DeDario, Vernon Director of Utilities
May 31, 2002
2
C
II. Request for Production of Documents
To the extent your company engaged in "wash," "round trip," or "sell/buyback"
type transactions, provide the following documents:
A. Provide copies of all communications or correspondence, including e-mail
messages, instant messages, or telephone logs, between your company
and any other company (including your affiliates or subsidiaries) that refer
or relate to this activity.
Response: Not applicable.
B. Provide copies of all material, including, but not limited to, opinion letters,
memoranda, communications (including a -mails and telephone logs), or
reports, that address or discuss your company's knowledge of, awareness
of, understanding of, or employment or use of any of any such
transactions in the U.S. portion of the WSCC during the period 2000-2001.
Response: Not applicable.
Prepared by: Jorge C. Somoano, Vernon Assistant Director of Resource
Management
Under Supervision of: Kenneth J. DeDario, Vernon Director of Utilities
May 31, 2002
3
FACT-FINDING INVESTIGATION OF POTENTIAL MANIPULATION OF
ELECTRIC AND NATURAL GAS PRICES, DOCKET NO. PA02-2-000
CITY OF VERNON, CALIFORNIA RESPONSE TO
MAY 21, 2002 REQUEST OF COMMISSION
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Fact -Finding Investigation of Potential )
Manipulation of Electric and Natural ) Docket No. PA02-2-000
Gas Prices )
AFFIDAVIT OF VERNON DIRECTOR OF UTILITIES
KENNETH J. DEDARIO AS TO
VERNON RESPONSE TO MAY 21, 2002 REQUEST
STATE OF CALIFORNIA
SS.
COUNTY OF LOS ANGELES
Kenneth J. DeDario, being duly sworn, deposes, states, and certifies that he is the City of
Vernon, California ("Vernon") Director of Utilities and that the foregoing Vernon response to
the May 21, 2002 request in the above docket are true and accurate to the best of his
knowledge, information, and belief formed, after a thorough investigation was diligently
conducted, under his supervision and control, into the trading activities of Vernon employees
and agents in the United States portion of the WSCC during the years 2000 and 2001, as to
the subjects of those requests.
Kenneth J. DeDario
SUBSCRIBED AND SWORN TO
before me, this Sc{"day of May 2002.
NOTARY PUBLI
in and for the State of California.
My commission expires L_ sCCla
NOTARIAL SEAL
Z�
LAWRENCE W. BIERLEIN
DOUGLAS M. CANTER
JOHN M. CUTLER, JR.
ANDREW P. GOLDSTEIN
STEVEN J. KALISH
RICHARD D. LIEBERMAN
CHANNING D. STROTHER, JR.
OF COUNSEL
KAREN R. O'BRIEN
BY HAND DELIVERY
Mr. Donald J. Gelinas
Associate Director
LAW OFFICES
MCCARTHY, SWEENEY & HARKAWAY, P.C.
FACSIMILE
SURE 600
(202) 393-5721
2175 K STREET, N.W.
E-MAIL
WASHINGTON, D. C. 20037
MSHOMSHPC.COM
(202) 393-5710
WEBsITE
HTTP:#www.MSHPC.COM
May 31, 2002
Office of Markets, Tariffs and Rates
Federal Energy Regulatory Commission
Dockets, Room IA
888 First Street, N.E.
Washington, D.C. 20426
Re: Fact -Finding Investigation of Potential Manipulation of Electric and Natural Gas
Prices Docket No. PA02-2-000
Dear Mr. Gelinas:
It has come to our attention that there was a typo on page 14 of Vernon's original
responses to the May 8, 2002 requests. Hopefully, the meaning of that portion of that
response, because of its context, was clear. Nevertheless, I herewith provide a corrected
page, along with a redline of the correction.
Also herewith is the original of Mr. DeDario's affidavit for the original responses.
This replaces the fax version provided earlier.
Enclosures
Respectfully submitted,
y
Channing . Strother, Jr.
Attorney for
City of Vernon, California
,✓
FACT-FINDING INVESTIGATION OF POTENTIAL MANIPULATION OF
ELECTRIC AND NATURAL GAS PRICES, DOCKET NO. PA02-2-000
CITY OF VERNON, CALIFORNIA RESPONSES TO
MAY 8, 2002 REQUESTS OF COMMISSION
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Fact -Finding Investigation of Potential )
Manipulation of Electric and Natural ) Docket No. PA02-2-000
Gas Prices )
AFFIDAVIT OF VERNON DIRECTOR OF UTILITIES
KENNETH J. DEDARIO AS TO
VERNON RESPONSES TO MAY 8, 2002 REQUESTS
STATE OF CALIFORNIA
ss.
COUNTY OF LOS ANGELES
Kenneth J. DeDario, being duly sworn, deposes, states, and certifies that he is the City of
Vernon, California ("Vernon") Director of Utilities and that the foregoing Vernon responses to
the May 8, 2002 requests in the above docket are true and accurate to the best of his
knowledge, information, and belief formed, after a thorough investigation was diligently
conducted, under his supervision and control, into the trading activities of Vernon employees
and agents in the United States portion of the WSCC during the years 2000 and 2001, as to
the subjects of those requests.
SUBSCRIBED AND SWORN TO
before me, this 22d day of May 2002.
NOTARY PUBLIC ----
in and for the State of California.
My commission expires �iy,,a
NOTARIAL SEAL
SHARON L. JOHNSON
Commission # 1225 '-' i
z Notary Public - California
Los Angeles County.
MY Comm. Expires Jun 21, 2003
Kenneth J. DeDario
FACT-FINDING INVESTIGATION OF POTENTIAL MANIPULATION OF
ELECTRIC AND NATURAL GAS PRICES, DOCKET NO. PA02-2-000
CITY OF VERNON, CALIFORNIA RESPONSES TO
MAY 8, 2002 REQUESTS
Vernon's investigation, however, did reveal that Vernon on a number of
occasions in the hour ahead market, scheduled energy that was above its
expected real time loads. Each of those instances is described in the
separately bound narrative response to this Request No. K.2. All related
documents are also provided. Vernon seeks confidential treatment for this
response and the documents on the grounds that the information
contained therein is commercially sensitive. The narrative and the
documents are submitted herewith in a sealed envelop, appropriately
designated as "privileged" pursuant to 18 C.F.R. § 388.112.
Also, generators and entities with existing transmission contracts were
able to increase generation or import during real time resulting in
uninstructed imbalance energy. Vernon's investigation reveals that on a
number of occasions Vernon had excess uninstructed energy as a result
of real time activities. These instances cannot fall within the definition of
"inc-ing load" because introduction of this energy in real time involved no
reference to projected or actual loads by Vernon to the Cal ISO, and the
Enron "inc-ing" strategy appears to refer solely to overstating load.
Because these real time activities do not affect load schedules, they were
not set out individually in this response.
Vernon's investigation also reveals that on certain occasions in the day
ahead market Vernon scheduled energy above Vernon's expected real
time load, beyond an amount needed to avoid real time short falls.
Vernon considers these instances to be far removed from the "inc-ing
load" strategy referred to in the Enron memos. These day ahead
schedules of load that exceeded the actual load did produce uninstructed
imbalance energy. Out of an abundance of caution, and in order to be as
responsive to the Commission's requests as possible, Vernon needs to
look at each hour individually and requires more time to complete this part
of its investigation. However, it should be noted that there were
substantial number of days during 2001 when Vernon's day ahead
schedule was higher than Vernon desired. This was not caused by any
Vernon desire to have excess uninstructed imbalance energy, especially
when the ISO was not creditworthy. Rather Vernon was trying to minimize
any short position with the Cal ISO since the cost for being short was very
high and because the liquidity of the market diminished substantially with
the termination of the CALPX. At times, Vernon found itself with
commitments for excess energy that was difficult to sell especially during
certain hours of the day. The end result was that due to prior committed
purchases on a take or pay basis and the reduction of load during 2001,
-14-
FACT-FINDING INVESTIGATION OF POTENTIAL MANIPULATION OF
ELECTRIC AND NATURAL GAS PRICES, DOCKET NO. PA02-2-000
CITY OF VERNON, CALIFORNIA RESPONSES TO
MAY 8, 2002 REQUESTS
Vernon's investigation, however, did reveal that Vernon on a number of
occasions in the hour ahead market, scheduled energy that was above its
expected real time loads. Each of those instances is described in the
separately bound narrative response to this Request No. K.2. All related
documents are also provided. Vernon seeks confidential treatment for this
response and the documents on the grounds that the information
contained therein is commercially sensitive. The narrative and the
documents are submitted herewith in a sealed envelop, appropriately
designated as "privileged" pursuant to 18 C.F.R. § 388.112.
Also, generators and entities with existing transmission contracts were
able to increase generation or import during real time resulting in
uninstructed imbalance energy. Vernon's investigation reveals that on a
number of occasions Vernon had excess uninstructed energy as a result
of real time activities. These instances cannot fall within the definition of
"inc-ing load" because introduction of this energy in real time involved no
reference to projected or actual loads by Vernon to the Cal ISO, and the
Enron "inc-ing" strategy appears to refer solely to overstating load.
Because these real time activities do not affect load schedules, they were
not set out individually in this response.
Vernon's investigation also reveals that on certain occasions in the day
ahead market Vernon scheduled energy above Vernon's expected real
time load, beyond an amount needed to avoid real time short falls.
Vernon considers these instances to be far removed from the "inc-ing
load" strategy referred to in the Enron memos. These day ahead
schedules of load that exceeded the actual load did produce uninstructed
imbalance energy. Out of an abundance of caution, and in order to be as
responsive to the Commission's requests as possible, Vernon needs to
look at each hour individually and requires more time to complete this part
of its investigation. However, it should be noted that ' there were
substantial number of days during 2001 when Vernon's day ahead
schedule was higher than Vernon desired. This was not caused by any
Vernon desire to have excess uninstructed imbalance energy, especially
when the ISO was not creditworthy. Rather Vernon was trying to minimize
any short position with the Cal ISO since the cost for being short was very
high and because the liquidity of the market diminished substantially with
the termination of the CALPX. At times, Vernon found itself with
commitments for excess energy that was difficult to sell especially during
certain hours of the day. The end result was that due to prior committed
purchases on a take or pay basis and the reduction of load during 2001,
-14-
LAWRENCE W. BIERLEIN
DOUGLAS M. CANTER
JOHN M. CUTLER, JR.
ANDREW P. GOLDSTEIN
STEVEN J. KALISH
Ie1CHARD D. LIEBERMAN
CHANNING D. STROTHER, JR•
OF COUNSEL
KAREN A. O'BRIEN
BY HAND DELIVERY
Mr. Donald J. Gelinas
Associate Director
LAW OFFICES
MCCARTHY, SWEENEY & I"HARKAWAY, P.C.
FAcsIMILE
SUITE 600
(202) 393-5721
2175 K STREET, N.W.
E-MAIL
WASHINGTON, D. C. 20037
MSHOMSHPC.COM
(202) 393-5710
W�SSITE
HTTP://W W W.MSHPC.COM
May 31, 2002
Office of Markets, Tariffs and Rates
Federal Energy Regulatory Commission
Dockets, Room IA
888 First Street, N.E.
Washington, D.C. 20426
Re: Fact -Finding Investigation of Potential Manipulation of Electric and Natural Gas
Prices, Docket No. PA02-2-000
Dear Mr. Gelinas:
Herewith the City of Vernon, California ("Vernon"), submits its supplemental
response with respect to the May 8, 2002 request K.2.
Consistent with the instructions accompanying the requests, enclosed is one copy
of this response. Consistent with those instructions, this supplemental response is made
under the accompanying affidavit of Kenneth J. DeDario, Vernon's Director of Utilities,
which appears as the last page of the response.
As stated in Vernon's previous responses in this docket, Vernon does not waive
jurisdiction or other statutory rights by, gladly, responding to these Commission requests.
Vernon seeks confidential treatment for the attachments to this supplemental response.
Respectfully submitte
l
Channin trother, Jr.
Attorney for
City of Vernon, California
Enclosure
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Fact -Finding Investigation of,Potential )
Manipulation of Electric and Natural Gas ) Docket No. PA02-2-000
Prices )
SUPPLEMENT TO RESPONSE OF THE
CITY OF VERNON, CALIFORNIA TO
MAY 8, 2002 REQUEST K.2
DIRECTED TO:
MR. DONALD J. GELINAS
ASSOCIATE DIRECTOR
OFFICE OF MARKETS, TARIFFS AND RATES
DATED: MAY 31, 2002
M
FACT-FINDING INVESTIGATION OF POTENTIAL MANIPULATION OF
ELECTRIC AND NATURAL GAS PRICES, DOCKET NO. PA02-2-000
CITY OF VERNON, CALIFORNIA SUPPLEMENTAL RESPONSE TO
MAY 8, 2002 REQUEST NO. K.2
K.2. If you so admit, provide a narrative description of each specific time in which
the company engaged in such activity and provide complete details of those
transactions, including the dates of the transactions, counter parties, prices
and volumes bought or sold, corresponding schedules, and any congestion
payments received. Also, provide all documents that refer to or relate to such
activities.
Supplemental Response:
As Vernon stated in its original response to Request No. K.2, at the time that
response was submitted, Vernon had not been able to complete the investigation
mandated by the May 8, 2002 requests, as that investigation relates to Vernon
activities in the day ahead market. Vernon diligently pursued completion of that
investigation and is now able to complete its response to Request No. K.2 on the
informed basis mandated by the requests.
As Vernon previously responded, Vernon's investigation confirms that Vernon did
not engage in any of the strategies described in the Enron memoranda.
Out of an abundance of caution and without characterization of the particular
activities as variants of "Inc-ing Load" or any other Enron strategy, Vernon provides
the Commission with the attached information concerning certain Vernon schedules
and uninstructed imbalance energy with the CA ISO. Vernon requests confidential
treatment of these attachments and associated materials on the grounds that
information contained therein is commercially sensitive and its disclosure would
harm Vernon. As to some of the attached materials, Vernon may also be under a
contractual obligation to protect against public disclosure. Consistent with 18 CFR
§388.112 , Vernon has individually marked these materials with the logo "Contains
Privileged Information —Do Not Release and provides them in a sealed envelope
similarly marked.
Prepared by: Jorge C. Somoano, Vernon Assistant Director of Resource
Management
Under Supervision of: Kenneth J. DeDario, Vernon Director of Utilities
May 31, 2002
-1-
FACT-FINDING INVESTIGATION OF POTENTIAL MANIPULATION OF
ELECTRIC AND NATURAL GAS PRICES, DOCKET NO. PA02-2-000
CITY OF VERNON, CALIFORNIA SUPPLEMENTAL RESPONSE TO
MAY 8, 2002 REQUESTS OF COMMISSION
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Fact -Finding Investigation of Potential )
Manipulation of Electric and Natural ) Docket No. PA02-2-000
Gas Prices )
AFFIDAVIT OF VERNON DIRECTOR OF UTILITIES
KENNETH J. DEDARIO AS TO SUPPLEMENTAL
VERNON RESPONSE TO MAY 8, 2002 REQUESTS
STATE OF CALIFORNIA )
SS.
COUNTY OF LOS ANGELES )
Kenneth J. DeDario, being duly sworn, deposes, states, and certifies that he is the City of
Vernon, California ("Vernon") Director of Utilities and that the foregoing Vernon
supplemental response to the May 8, 2002 requests in the above docket are true and accurate
to the best of his knowledge, information, and belief formed, after a thorough investigation
was diligently conducted, under his supervision and control, into the trading activities of
Vernon employees and agents in the United States portion of the WSCC during the years
2000 and 2001, as to the subjects of those requests.
J.
Kenneth J. DeDario
SUBSCRIBED AND SWORN TO
before me, this tZ-4 day of May 2002.
NOTARY PUBLICC___l
in and for the State of California.
My commission expires - zap
NOTARIAL SEAL
Contains Privileged Information —Do Not Release
Confidential Narrative Portion of Vernon Supplement to Response to K.2 of May
8, 2002 Requests in Docket No. PA02-02
Vernon provides herewith a computer diskette containing Vernon's hourly uninstructed
imbalance energy balances with the ISO for the 2000-2001 period. These data show that
during the period in which the PX was in operation, January 1, 2000 through January 31,
2001, Vernon was a net purchaser of uninstructed imbalance energy but thereafter,
February 1, 2001 through December 31, 2001, Vernon was a net seller of uninstructed
imbalance energy.
As a part of its investigation of the period January 1, 2000 through January 31,
2001, Vernon reviewed its daily schedules with the ISO to identify those hours in which
its day ahead resource schedule exceeded its net load forecast by more than 10 MW. The
10 MW criteria was used because the FERC had ordered it for the initially approved, later
disapproved, ISO underscheduling penalty (i.e., the greater of 5% or 10 MW). Vernon
found that in approximately 1% of the hours in that 13-month period, its day ahead
schedule exceeded its load forecast by more than 10 MW. This is shown for each hour in
Attachment A. Due to the multiple transactions associated with the day ahead schedules,
Vernon did not attempt to break out which supply may have been associated with the
particular excess schedules. For example, in order to illustrate the difficulty, Attachment
B provides the load forecast and resource schedules for HE 2000 on January 7, 2000.
For the February 1 2001 through December 31, 2001 period, Vernon's
investigation revealed that the demise of the PX, in combination with the fixed take -or -
pay contracts entered into by Vernon, caused Vernon to be excess. The data for this
period on the diskette provided herewith reflects these circumstances.
May 31, 2002
rorcastea
Date
Hour Ending
Load
Losses
Net Resources
Net Long Position
1 /7/2000
2000
140
1.3
152
10.7
1 /7/2000
2100
137
1.3
152
13.7
1 /7/2000
2200
136
1.3
152
14.7
1 /17/2000
700
136
1.275
151
13.725
1 /26/2000
2000
149
1.3
162
11.7
1 /26/2000
2100
146
1.3
162'
14.7
2/18/2000
2100
137 '
1.285
151`
12.715
2/18/2000
2200
136
1.285
151=
13.715
2/25/2000
2000
140
1.285
156
14.715
2/25/2000
2100
137
1.285
156
17.715
2/25/2000
2200
136
1.285
156
18:715
2/26/2000
2300
106 _
0.7
118
11.3
2/26/2000
2400
104
0.7
118
13.3
3/23/2000
2000
142
1.225
159
15.775
3/23/2000
2100
138
1.225
159
19.775
3/29/2000
2100
138
1.975
150 -
10.025
3/29/2000
2200
137
1.975
150
11.025
4/3/2000
700
136
1
150
13
4/6/2000
2100
144
2.35
158
11.65
4/6/2000
2200
142
2.35
158
13.65
4/11 /2000
2000
146
1.25
160
12.75
4/11/2000
2100
144
1.25
160
14.75
4/11 /2000
2200
142 -
1.25
160`.
16.75
4/12/2000
2000
146
1.25
160
12.75
4/12/2000
2100
144
1.25
160
14.75 `
4/12/2000
2200
142
1.25
160
16.75
4/13/2000
2000
146
1.25
160
12.75
4/13/2000
2100
144 -
1.25
160
14.75
4/13/2000
2200
142
1.25
160
16.75
5/8/2000
700
140
0.875
155
14.125
5/9/2000
1800
162
0.625
180
17.375
5/9/2000
1900
154 `
0.625
175
20.375
5/9/2000
2000
152
0.625
170'
17.375
5/9/2000
2100
153 ''
0.625
170
16.375
5/9/2000
2200
151
0.625
170
18.375
6/2/2000
700
156 "
0.75
170
13.25
6/2/2000
800
168`_
0.75
185
16.25
6/2/2000
900
175
- 0.75
190
14.25
6/2/2000
1000
182
0.75
195
> 12.25-
6/2/2000
1100
186
0.75
200
13.25
6/2/2000
1200
185
0.75`
200'=
14.25
6/2/2000
1300
184'
0.75
200'
15.25
6/2/2000
1400
183
0.75
200
16.25
6/2/2000
1500
177
0.75
192
14.25
6/2/2000
1600
170
0.75
185"
14.25
6/2/2000
1700
164
0.75
180
15.25
6/2/2000
1800
158
0.75
173
14.25
6/2/2000
1900
152
0.75
167
14.25
6/2/2000
2000
148
0.75
163
14.25
ATTACHMENT A
CONTAINS PRIVILEGED INFORMATION
--DO NOT RELEASE
6/2/2000
2100
145
0.75
160
14.25
6/2/2000
2200
142
0.75
157
14.25
7/1/2000
700
132
0.3
152
19.7
7/1/2000
800
135
0.3
152
16.7
7/1/2000
900
136
0.3
152
15.7
7/1/2000
1000
137
0.3
152
14.7
7/1/2000
1100
137
0.3
152
14.7
7/1/2000
1200
136
0.3
152
15.7
7/1/2000
1300
132
0.3
152
19.7
7/1/2000
1400
130
0.3
142
11.7
7/1/2000
1500
128
0.3
142
13.7
7/1/2000
1600
126
0.3
142
15.7
7/1/2000
1700
123
0.3
142
18.7
7/1/2000
1800
120
0.3
142
21.7
7/1/2000
1900
118
0.3
142
23.7
7/1/2000
2000
117
0.3
152
34.7
7/1/2000
2100
117
0.3
152
34.7
7/1/2000
2200
116
0.3
152
35.7
8/24/2000
600
148
0.25
175
26.75
8/24/2000
700
163
0.375
190
26.625
8/24/2000
2400
145
0.25
170
24.75
8/25/2000
600
143
0.25
170
26.75
8/25/2000
700
161
0.25
190
28.75
8/26/2000
400
124
0.25
135
10.75
8/26/2000
500
122
0.25
135
12.75
8/26/2000
600
120
0.25
135
14.75
8/26/2000
2300
107
0.25
130
22.75
8/26/2000
2400
106
0.25
130
23.75
8/29/2000
600
148
0.175
172
23.825
8/29/2000
700
163
0.3
187
23.7
9/5/2000
"Unable to reconstruct data for this date
10/19/2000
700
159
2.05
172
10.95
11/13/2000
100
105
0.925
137
31.075
11/13/2000
200
106
0.925
137
30.075
11/13/2000
300
107
0.925
137
29.075
11/13/2000
400
109
0.925
137
27.075
11/13/2000
500
115
0.925
137
21.075
11/13/2000
600
134
0.925
147
12.075
1 /26/2001
200
126.63
0.3
137
10.07
1 /26/2001
400
125.42
0.3
137
11.28
1 /26/2001
2400
125.23
0.3
137
11.47
1 /30/2001
300
126.05
0.3
137
10.65
1 /30/2001
400
124.17
0.3
137
12.53
1 /31 /2001
300
126.05
0.3
137
10.65
1 /31 /2001
400
124.17
0.3
137
12.53
Contains Privileged Information —Do Not Release
Attachment B to Vernon May 31, 2002 Supplemental Response to
May 8, 2002 Request No. K.2, FERC Docket No, PA02-02
January 7, 2000 HE 2000
Load forecast 140 MW (losses 1.3 MW)
Supplier SCPPA APS AZUSA ECI PX (NET) AEP (1) AEP (2) AEP (3) TOTAL
Resource 11 25 10 50 -10 25 25 16 152
From the above the forecasted long position for the hour was 10.7 MW.
May 31, 2002
LAW OFFICES
LAWRENCE W. BIERLEIN
MCCARTHY, SWEENEY & HARKAWAY, P.C.
FACSIMILE
DOUGLAS M. CANTER
SUITE 600
(202) 393-5721
JOHN M. CUTLER, JR.
2175 K STREET, N.W.
E-MAIL
ANDREW P. GOLDSTEIN
STEVEN J. KALISH
WASHINGTON, D. C. 20037
MSHOMSHPC.COM
RICHARD D. LIEBERMAN
(202) 393-5710
WEBSITE
CHANNING D. STROTHER, JR.
HTTP:/AMW W.MSHPC.COM
OF COUNSEL
KAREN R. O'BRIEN
May 31, 2002
Martin H. Goyette, Esq.
Deputy Attorney General
State of California
Department of Justice
1515 Clay Street, 20th Floor
Oakland, CA 94612
NOTE: INCLUDES REQUEST TO HOLD
RESPONSES IN CONFIDENCE
Re: Fact -Finding Investigation of Potential Manipulation of Electric and
Natural Gas Prices, FERC Docket No. PA02-2-000
Dear Mr. Goyette:
Provided herewith are additional responsive material my client, the City of
Vernon, California, submitted to the FERC by hand delivery today.
As previously, portions of Vernon's responses provided herewith in a sealed
envelope bearing the phrase "Contains Privileged Information —Do Not Release," were
filed with the FERC in that manner, to be protected from disclosure pursuant to 18 C.F.R.
§ 388.112. We request the same level of confidential treatment and protection from
disclosure at your office. These materials include commercially sensitive data the
disclosure of which could harm Vernon's competitive interests. These materials may
also contain commercially sensitive information that Vernon is contractually obligated to
third parties to protect from disclosure.
We understand your May 14, 2002 letter to be a commitment to protect such
materials from disclosure. If our understanding is in error, or if we need to take any
additional steps to ensure confidential treatment, please contact me right away, prior to
opening the envelope containing the sealed materials.
Martin H. Goyette, Esq.
Deputy Attorney General
State of California
Department of Justice
May 31, 2002
Page 2
Please also contact me with any other concerns.
Sincerely,
Channing D. Strother, Jr.
Attorney for
City of Vernon, California
Enclosures (as stated above)
cc: Eduardo Olivo, Esq., City Attorney, City of Vernon
NOTICE OF PUBLIC HEARING
The City of Vernon will conduct a Public Hearing which
you may attend.
PLACE: Vernon City Hall
City Council Chambers
4305 Santa Fe Avenue
Vernon, CA 90058
DATE AND TIME: Wednesday, December 4, 2002, at 5:00
p.m., or as soon thereafter as the
matter may be heard
PURPOSE: To consider evidence to establish
Vernon's new Transmission Revenue
Balancing Account Adjustment for its
high voltage (over 200 kV) transmission
facilities and entitlements (all
located outside the City) pursuant to
Vernon's Transmission Owner Tariff
Any interested person may attend and may make an oral
presentation to the City Council at the time of the
hearing, or may present written comments prior to the
hearing.
If you challenge the approval of the establishment of
Vernon's new Transmission Revenue Balancing Account
Adjustment or any provision thereof in court, you may
limited to raising only those issues you or someone else
raised at the hearing described in this notice or in
written correspondence delivered to the City of Vernon at,
or prior to, the meeting.
Information may be obtained by contacting the office
of the City Clerk at the above address.
The hearing may be continued or adjourned to a stated
time and place without further notice.
Dated: November 27, 2002
BRUCE V. MALKENHORST,
City Administrator/City Clerk
AFFIDAVIT OF POSTING
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES )ss.
CITY OF VERNON )
I, Gloria J. Orosco, Chief Deputy City Clerk of the
City of Vernon, do hereby certify that I did, on the 6th day of
June, 2002, post three (3) copies of:
NOTICE OF PUBLIC HEARING, to be held June 19, 2002,
(see attached copy) regarding the establishment of Vernon's new
Transmission Revenue Balancing Account Adjustment pursuant to
Vernon's Transmission Owner Tariff.
One in each of the following place
northwest corner of 38th Street and Santa Fe
northeast corner of Leonis Boulevard and Pac
on the bulletin board in the lobby of the Ci
of Vernon, located at 4305 Santa Fe Avenue,
there being no newspaper of general circulat
published in the City of Vernon.
Dated: June 10, 2002
GpDria J. Oroyco
Chief Deputy City Clerk
State of California )
)ss.
County of Los Angeles )
6'//7)1On11
2002, before me, ���u�C
Notai4y Public, personally appeared Gloria J. Orosco, personally
known to me -(oz knewn to rae en the basisef -,t, s f.,e
ev elenee to be the person whose name is subscribed to the
within instrument and acknowledged to me that she executed the
same in her authorized capacity, and that by her signature on
the instrument the person, or the entity upon which the person
agted, executed the instrument.
SS my hand and o ficial seal. MANUELACAR
Commission 0 1328374 I
Notary Public - California
Los Angels County
My Comm. Expims Nov 4, 2006
STATE OF CALIFORNIA. )
COUNTY OF LOS ANGELES)
CITY OF VERNON )
AFFIDAVIT OF POSTING
fx
I, Gloria Molleda, Deputy City Clerk, of the City
certify that I did, on thep-(IA of NO-V",/-2002,
of:
- - -,-Ijjy
NOTICE OF PUBLIC HEARING - To consider evidence to establish
Vernon's new Transmission Revenue Balancing Account Adjustment
for its high voltage (over 200 kV) transmission facilities and
entitlements (all located outside the City) pursuant to Vernon's
Transmission Owner Tariff.
On the bulletin board in the lobby of the City Hall of the City of
Vernon located at 4305 Santa Fe Avenue, all in said City, there being
no newspaper of general circulation printed and published in the City
of Vernon.
Date: U 12-0 1 OZ
Gloria Molleda
Deputy City Clerk
State of California )
) ss
County of Los Angeles) On a� before me, j4dAye4 61MI
Personally appeared Gloria Molleda
Personally known to me
-ev-i44viee) to be the person (z') whose name (sfi is/..tee subscribed to the
within instrument and acknowledged to me that /she/my- executed the
same in 1.4-e/her/t,r authorized capacity, and that by -1t---�s/her/-t4re�
signature(.& on the instrument the person(a�, or the entity upon
behalf of which the person(er acted, executed the instrument.
W NESS my hand and official seal
MAk7i1ELA G1RON
Commission* 1328374J�
z
y, Notary Public - Califomia
Los Angeles County
omn. Expires Nov 4,
AFFIDAVIT OF POSTING
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES) ss
CITY OF VERNON )
I, Sergio Canales, Engineering Aide, of the City of Vernon do hereby
certify that I did, on the ,?A of MOV44W2002, post two (2) copies
of:
NOTICE OF PUBLIC HEARING - To consider evidence to establish
Vernon's view Transmission Revenue Balancing Account Adjustment
for its high voltage (over 200 kV) transmission facilities and
entitlements (all located outside the City) pursuant to Vernon's
Transmission Owner Tariff.
One in each of the following places, to wit: at the northwest corner
of 38th Street and Santa Fe Avenue; the northeast corner of Leonis
Blvd. and Pacific Blvd., all in said City, there being no newspaper of
general circulation printed and published in the City of Vernon.
Date: /(' �7 D Z /U�4
ergio Canales
Engineering Aide
State of California )
) ss
County of Los Angels)
On �� 3, ZbbZ before me, Ro"e�A 61m,,
Personally appeared Sergio Canales
Personally known to me (dawn-4e-��re cf gatisfartnry
e-vi aere_ ) to be the person (set whose name (.9-) is/as-e subscribed to the
instrument and acknowledged to me that he/;:he�thr executed the
same in his/-t� authorized capacity, and that by his/ham/e-ice
signature(-e-) on the instrument the person(&), or the entity upon
behalf of which the person(4) acted, executed the instrument.
WITLESS my hand and official seal
MANUELA GIRON
Commission # 1328374 Z
:ocz Notary Public - California i
Z Los Angeles County
My Comm. Expires Nov 4, 2005