Resolution No. 2016-055RESOLUTION NO. 2016-55
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
VERNON ADOPTING A NEW TRANSMISSION REVENUE
REQUIREMENT FOR 2017 IN ACCORDANCE WITH VERNON'S
TRANSMISSION OWNER TARIFF AND PROVIDING FOR TARIFF
SHEET CHANGES TO IMPLEMENT THE ADJUSTMENT
WHEREAS, the City of Vernon ("City") is a chartered municipal
corporation of the State of California that owns and operates a system
for the generation, purchase, transmission, distribution and sale of
electric capacity and energy; and
WHEREAS, the City is a Participating Transmission Owner
("PTO") with the California Independent System Operator Corporation
("ISO"), and the Federal Energy Regulatory Commission ("FERC") has
approved its existing Transmission Owner Tariff ("TO Tariff"); and
WHEREAS, the ISO reimburses the City according to the City's
current Transmission Revenue Requirement ("TRR") in return for the City
turning over to the ISO the operation and control of the City's
transmission entitlements; and
WHEREAS, each PTO must include in its TO Tariff its Gross
Load, which the ISO uses to calculate its grid -wide Transmission Access
Charge ("TAC") rates, and which is related to the City's ability to
recover its full TRR; and
WHEREAS, the City's transmission entitlements include rights
under certain contracts (each an "ETC") including (i) an agreement with
the City of Los Angeles Department of Water and Power entitled "Los
Angeles -Vernon Adelanto-Victorville-Lugo Firm Transmission Service
Agreement" (the "LAWDP ETC"); (ii) an agreement with Southern
California Edison Company ("SCE") entitled "Amended and Restated
Edison -Vernon Victorville-Lugo Firm Transmission Service Agreement"
(the "SCE Victorville-Lugo ETC"); and (iii) an agreement with SCE
entitled "Amended and Restated Edison -Vernon Mead Firm Transmission
Services Agreement" (the "SCE Mead ETC"); and
WHEREAS, the City's costs under the LADWP ETC, the SCE
Victorville-Lugo ETC, and the SCE Mead ETC have traditionally been
based upon a negotiated fixed "path -specific" rate charged by LADWP or
SCE, based on the actual costs of the specific transmission lines made
available under each ETC, multiplied by the amount of transmission
capacity guaranteed to the City under each ETC; and
WHEREAS, on August 1, 2008, SCE filed a petition with FERC
seeking to amend the pricing structure under the SCE Victorville-Lugo
ETC and the SCE Mead ETC to replace the negotiated path -specific rates
set forth in those ETCs with a "postage -stamp" rate which reflects the
blended rate SCE charges to the ISO for the actual usage of all of
SCE's transmission lines by customers of the ISO; and
WHEREAS, the postage -stamp rate which SCE charges to the ISO
is derived from SCE's TRR and, therefore, will change each time SCE
amends its TRR; and
WHEREAS, on September 30, 2008, FERC accepted, subject to
refund and hearing and settlement procedures, SCE's proposed revisions
under the SCE Victorville-Lugo ETC and the SCE Mead ETC to replace the
negotiated path -specific rates set forth in those ETCs with a postage -
stamp rate, and thus the City's costs under the SCE Victorville-Lugo
ETC and the SCE Mead ETC will vary proportionately with any changes in
SCE's TRR; and
WHEREAS, the City reached a settlement agreement (the "SCE
Settlement") with SCE to amend the SCE Victorville-Lugo ETC and the SCE
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Mead ETC to replace the path -specific rates set forth in those ETCs
with SCE's postage -stamp rate after a phase -in period that began on
August 1, 2009, during which the City's path -specific rates in those
ETCs are gradually stepped -up over three years (the "Phase -In Rates")
until the path -specific rates are equal to SCE's postage -stamp rate as
of January 1, 2013; and
WHEREAS, under the SCE Settlement, the City's costs for the
SCE Victorville-Lugo ETC and the SCE Mead ETC are equal to (i) from
August 1, 2009, until December 31, 2012, the Phase -In Rates, and
beginning on January 1, 2013, the SCE postage -stamp rate, in each case
multiplied by (ii) the amount of transmission capacity guaranteed to
the City under each ETC; and
WHEREAS, FERC approved the SCE Settlement pursuant to an
order issued September 11, 2009, 128 FERC ¶ 61,237 (2009), in FERC
Docket Nos. ER08-1343-000, ER08-1353-000, ER09-187-000, ER09-187-001,
EL09-19-000, and ER09-446-000 ("SCE Settlement Order"); and
WHEREAS, on behalf of the City, the Brattle Group, an
experienced utilities consulting firm, developed a tracking mechanism
for the City's TRR ("TRR Tracking Mechanism") to allow the City's TRR
to be adjusted annually, effective January 1 of each year, to reflect
changes in the City's costs under the SCE Victorville-Lugo ETC and the
SCE Mead ETC that change as a result of (i) the stepped -up rates
implemented between August 1, 2009 and December 31, 2012; or (ii) any
change in SCE's TRR on or after January 1, 2013; and
WHEREAS, on the basis of The Brattle Group's analysis and
evidence from City staff, which was considered during a public meeting
of the City Council held on July 13, 2009, the City, on July 15, 2009
("July 15 FERC Filing"), filed with FERC proposed revisions to its TO
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Tariff proposing stated TRRs for each of the years 2010 to 2012, which
dollar amounts were also included in the SCE Settlement ("TO Tariff
Revisions"); and
WHEREAS, the City also submitted in the July 15 FERC Filing a
request to utilize an "ETC Adjustment Clause" to adjust automatically
each year the costs the City incurs attributable to any changes in
SCE's TRR associated with SCE's High Voltage Existing Contracts Access
Charge ("HVECAC") rate; and
WHEREAS, FERC approved the City's request to utilize an ETC
Adjustment Clause to reflect annual projected changes to SCE's TRR, in
an order issued September 11, 2009, 128 FERC ¶ 61,235 (2009), in FERC
Docket No. EL09-64-000 ("TO Tariff Order"); and
WHEREAS, under the TO Tariff Order, the City's TO Tariff
revisions went into effect on August 1, 2009; and
WHEREAS, on January 6, 2015, the City approved revisions to
the template used to calculate the annual ETC Adjustment Clause; and
WHEREAS, on April 8, 2015, FERC approved the City's 2015
filing with FERC reflecting modifications to the base TRR as calculated
using the revised ETC Adjustment Clause template; and
WHEREAS, the City is required under the TO Tariff Order to
submit annual filings with FERC reflecting modifications to the base
TRR; and
WHEREAS, a Notice of Public Hearing was published on October
6, 2016, notifying all interested parties that a hearing to consider
evidence to establish the City's new TRR was scheduled for October 18,
2016, at approximately 9:00 a.m., subject to the hearing being
continued or adjourned to a stated time and place without further
notice of public hearing; and
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WHEREAS, on October 18, 2016, the City Council held a Public
Hearing in which the City Council took evidence from staff and those
other persons in attendance who wished to be heard on the calculation
of the City's new TRR under the City's amended TO Tariff; and
WHEREAS, the TRR for 2017 is shown in the amended Appendix I
to the TO Tariff, a copy of which is attached hereto as Exhibit A and
made a part hereof.
WHEREAS, the Gas & Electric Department has prepared a Report,
dated October 18, 2016, with exhibits, a copy of which is attached
hereto as Exhibit B and made a part hereof, which reiterates its
previous conclusions that the TRR and ETC Adjustment Clause mechanism
developed by The Brattle Group, approved by FERC under the amended TO
Tariff, and revised in 2015 are reasonable and which calculates the
amount derived under the ETC Adjustment Clause for 2017; and
WHEREAS, the Gas & Electric Department has recommended the
City adopt the TRR shown in the amended Appendix I to the TO Tariff,
attached as Exhibit A, to be effective on January 1, 2017; and
WHEREAS, the City Council has heard and considered all
evidence, written and oral, presented in consideration of the
establishment of the City's new TRR under the amended TO Tariff.
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
and correct.
SECTION 2: The City Council of the City of Vernon finds
that this action does not constitute a "project" pursuant to section
15378(b)(2) of the Guidelines to the California Environmental Quality
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Act ("CEQA"), because such action constitutes an administrative
activity; and even if the adoption of the proposed item did constitute
a project, it would be exempt in accordance with CEQA Guidelines
section 15061(b)(3), the general rule that CEQA only applies to
projects that may have an effect on the environment.
SECTION 3: The City Council of the City of Vernon hereby
further finds and determines that all persons have had the opportunity
to be heard or to file written comments to the proposed adoption of the
City's TRR, and after due consideration of any and all evidence
submitted at the Public Hearing, determines there are compelling
reasons to justify the adoption of the City's TRR and Gross Load, to be
effective January 1, 2017.
SECTION 4: The City Council of the City of Vernon hereby
declares that:
(a) any determination made pursuant to this Resolution
regarding the validity or reasonableness of any portion of any TRR or
TO Tariff shall apply only prospectively from the date of this
Resolution; and
(b) in no way shall this Resolution affect the City
Council's adoption or determination of any previous TRR or TO Tariff.
SECTION 5: The City Council of the City of Vernon hereby
approves, pursuant to the TO Tariff and to be effective on January 1,
2017, the establishment of the City's new TRR and Appendix I to the TO
Tariff implementing the new TRR, as described in the Gas & Electric
Report dated October 18, 2016.
SECTION 6: The City Council of the City of Vernon hereby
authorizes outside counsel to submit the City's TRR, the amended
Appendix I to the Vernon TO Tariff, and supporting documentation, such
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as the Report, and this City Council Resolution approving the new TRR,
to FERC on behalf of the City of Vernon.
SECTION 7: The City Clerk or Deputy City Clerk of the City
of Vernon shall certify to the passage, approval and adoption of this
.resolution, and the City Clerk or Deputy City Cler-Ir, of the City of
Vernon shall cause this resolution and the City Clerk's or Deputy City
Clerk's certification to be entered in the File of resolutions of the
Council of this City.
APPROVED AND ADOPTED this 18th day of October, 2016.
Name: W1111am J . Davis
ATTEST: /
Marfra E. ala
City Clk / y i y e
APPROVED AS TO FORM:
A
Katharine Mapes, Esq.
Spiegel & ylcDiarmid, LLP
Special Counsel to City
Title: Mayor
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STATE OF CALIFORNIA )
) ss
COUNTY OF LOS ANGELES )
I, Maria E . Ayala, City Clerk /. Deputy C-ty.Gl&rkl�of the City
of Vernon, do hereby certify that the foregoing Resolution, being
Resolution No. 2016-55, was duly passed, approved and adopted by the
City Council of the City of Vernon at a regular meeting of the City
Council duly held on October 18, 2016, and thereafter was duly signed
by the Mayor or Mayor Pro-Tem of the City of Vernon.
Executed this day of October, 2016, at Vernon, California.
(SEAL)
Mar a E . 4ala
City Clerk /
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EXHIBIT A
APPENDIX I
Transmission Revenue Requirement and TRBAA
The Vernon Base Transmission Revenue Requirement is $2, 73,-0473,033,164 and is comprised
of the following components:
Base TRR costs not subject to ETC Adjustment Clause: $498,480
ETC Adjustment Clause:
Forecast SCE ETC Costs: $2,5T�-.5;�002,708,400
Balance of Difference between prior year
Forecast and Actual SCE ETC Costs: ($45,37 67,924)
Interest on Difference between prior year
Forecast and Actual SCE ETC Costs: ($5,2625,792)
The ETC Adjustment Clause is: The projected SCE ETC Cost for the next calendar year,
plus the true -up (positive or negative) of the prior October through September SCE ETC
Cost with interest calculated pursuant to 18 C.F.R. § 35.19a. The ETC Adjustment
Clause will be recalculated annually and filed with the Commission with a proposed
effective date of January 1 of each year.
The TRBAA is a pos ene ag tive $44447,616 for calendar year 20167.
Vernon's Gross Load, consistent with its TRR, used by the ISO to develop the Transmission
Access Charge is 1,181,728 MWhs.
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 Tariff approved by the
Vernon City Council, and provided to the ISO.
APPENDIX I
Transmission Revenue Requirement and TRBAA
The Vernon Base Transmission Revenue Requirement is $3,033,164 and is comprised of the
following components:
Base TRR costs not subject to ETC Adjustment Clause: $498,480
ETC Adjustment Clause:
Forecast SCE ETC Costs: $2,708,400
Balance of Difference between prior year
Forecast and Actual SCE ETC Costs: ($167,924)
Interest on Difference between prior year
Forecast and Actual SCE ETC Costs: ($5,792)
The ETC Adjustment Clause is: The projected SCE ETC Cost for the next calendar year,
plus the true -up (positive or negative) of the prior October through September SCE ETC
Cost with interest calculated pursuant to 18 C.F.R. § 35.19a. The ETC Adjustment
Clause will be recalculated annually and filed with the Commission with a proposed
effective date of January 1 of each year.
The TRBAA is a negative $47,616 for calendar year 2017.
Vernon's Gross Load, consistent with its TRR, used by the ISO to develop the Transmission
Access Charge is 1,181,728 MWhs.
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 Tariff approved by the
Vernon City Council, and provided to the ISO.
CITY OF VERNON GAS AND ELECTRIC
DEPARTMENT
REPORT REGARDING THE ESTABLISHMENT OF A REVISED NEW
TRANSMISSION REVENUE REQUIREMENT ASSOCIATED WITH VERNON'S
HIGH VOLTAGE ENTITLEMENTS
October 18, 2016
The City of Vernon ("Vernon" or "City") is a Scheduling Coordinator and a
Participating Transmission Owner ("PTO") in the California Independent System
Operator Corporation ("ISO"). To participate in the ISO, PTOs are required to turn
over administrative control of their transmission facilities and entitlements to the ISO.
In return, the ISO collects revenues for each PTO pursuant to calculations that
reflect the expenses and capital costs incurred by each PTO to provide transmission
services. These calculations are known as Transmission Revenue Requirements
("TRRs").
The relationship between PTOs and the ISO is governed by a Transmission Control
Agreement ("TCA"), which sets forth specific duties and obligations of all PTOs. The
TCA requires all PTOs to file a Transmission Owner Tariff ("TO Tariff") and TRR with
the Federal Energy Regulatory Commission ("FERC"). The TCA further requires all
PTOs to file any changes in their TRRs with FERC. Each PTO must also include in
its TO Tariff its Gross Load which the ISO uses to calculate its grid -wide
Transmission Access Charge ("TAC") rates, and which is related to the City's ability
to recover its full TRR.
TRANSMISSION REVENUE REQUIREMENT
At present, the City's high voltage transmission assets consist of three long-term
contracts (known as "existing transmission contracts" or "ETCs") which provide the
City with dedicated access to high voltage transmission facilities owned by other
entities. Specifically, the City has contractual entitlements to utilize transmission
assets pursuant to one long-term transmission contract with the Los Angeles
Department of Water and Power ("LADWP") and two long-term transmission
contracts with Southern California Edison ("SCE"). The ETCs with SCE consist of
TRR Report 2017
Page 3 of 6
those ETCs have been gradually stepped -up under incrementally increasing fixed
rates (the "Phase -In Rates") until the path -specific rates are equal to the HVECAC
Rate as of January 1, 2013. FERC approved the SCE Settlement pursuant to an
order issued September 11, 2009, 128 FERC 161, 237 (2009), in FERC Docket
Nos. ER08-1343-000, ER08-1353-000, ER09-187-000, ER09-187-001, EL09-19-
000, and ER09-446-000 ("SCE Settlement Order").
On behalf of the City, The Brattle Group, an experienced utilities consulting firm,
developed a TRR tracking mechanism clause for the City's TRR ("ETC Adjustment
Clause"), which allows the City's TRR to be adjusted annually, effective January 1 of
each year, to reflect changes in the City's transmission expenses associated with
any changes implemented by SCE in the HVECAC Rate associated with the SCE
Victorville-Lugo ETC and the SCE Mead ETC.
On the basis of The Brattle Group's analysis and evidence from City staff, which was
considered during a public meeting of the City Council held on July 13, 2009, the
City, on July 15, 2009 ("July 15 FERC Filing"), filed with FERC the proposed (i)
revisions to its TO Tariff proposing the City's stated TRRs for each of the years 2010
to 2012, which dollar amounts were also included in the SCE Settlement ("TO Tariff
Revisions") and (ii) the ETC Adjustment Clause tracking mechanism.
The July 15 FERC Filing acknowledged that, to the extent that the SCE Settlement
was accepted, because the stated Phase -In Rates would be fixed, the ETC
Adjustment Clause for the term of the Phase -In Rates would be zero.
FERC approved the City's July 15 FERC Filing, including the TO Tariff Revisions,
the City's proposed calculations of the TRR for years 2010 to 2012, and the City's
request to utilize an ETC Adjustment Clause, in an order issued September 11,
2009, 128 FERC ¶ 61,235 (2009), in FERC Docket No. EL09-64-000 ("TO Tariff
Order"). The City is required under the TO Tariff Order to submit annual filings each
year with FERC reflecting annual modifications to the base TRR of the City.
TRR Report 2017
Page 5 of 6
Vernon will true up any differences in its SCE ETC costs when it makes its 2018
TRR filing.
The ETCCF for 2017 SCE ETC costs are projected to be $2,708,400 as shown in
line 8 of Exhibit 1.
The ETCCT Component
ETCCT represents a balance that reflects the difference between prior year forecast
and actual SCE ETC costs. The prior period in this case is the twelve-month period
starting October 1, 2015 and ending September 30, 2016.
A summary of the determination of the September 30, 2016 balance in the ETC
Adjustment Clause is shown in Exhibit 1. The ETCCT component reflects 1) the
previously projected 2015 SCE ETC costs of $165,760 per month, for the months
October through December 2015 and projected 2016 SCE ETC costs of $214,600
per month, for the months January through September 2016, 2) actual 2015 SCE
ETC costs of $ 172,790 per month, for the months October through December 2015
and $208,680 per month, for the months January through September 2016, and 3)
refunds received by the City —all elements as reflected on Line No. 8, 15, and 16 of
Exhibit 1. The net of these elements produce the under (or over) collection figures
reflected in Line 17 of Exhibit 1. The ending balance is the sum of the beginning
balance on October 1 and the (over)/under collection — both elements as reflected
on Line 1 and 17 of Exhibit 1. The cumulative monthly balances are carried forward
from month to month and the ETCCT component on September 30, 2016 of negative
$167,924 is shown in line 19 of Exhibit 1.
The I (Interest) Component
The Interest component reflects interest on the difference between prior year
forecast and actual SCE ETC costs. The monthly interest carrying costs are
calculated using the 18 C.F.R. § 35.19(a) interest rates and calculation method.
These interest rates are published by FERC and reflect the prime rate values
published in the Federal Reserve Bank's "Selected Interest Rates."
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TRANSMHTAL CON WUNICATION
CITY CLERK'S OFFICE
INTEROFFICE MEMORANDUM
DATE: October 20, 2016
TO: Kelly Nguyen, Director of Gas & Electric
FROM: Deborah Juarez, Records Management Assistant (n
RE: Resolution No. 2016-55 — A Resolution of the City Lncil of the City of Vernon
Adopting a New Transmission Revenue Requirement for 2017 in Accordance with
Vernon's Transmission Owner Tariff and Providing for Tariff Sheet Changes to
Implement the Adjustment
Transmitted herewith is a certified copy of Resolution No. 2016-55 referenced above, for your transmittal,
which was approved by City Council on October 18, 2016.
Please ensure that a copy of the transmittal communication is sent to my attention for the file.
Thank you.
Enclosure
Abraham Alemu
Resolution No. 2016-55
CERTIFICATE
STATE OF CALIFORNIA )
) ss
COUNTY OF LOS ANGELES)
I, Maria E. Ayala, City Clerk of the City of Vernon, County
of Los Angeles, State of California, hereby certify that the
attached is a full and complete copy of:
RESOLUTION NO. 2016-55 - A Resolution of the City Council of
the City of Vernon Adopting a New Transmission Revenue
Requirement for 2017 in Accordance with Vernon's Transmission
Owner Tariff and Providing for Tariff Sheet Changes to
Implement the Adjustment
IN WITNESS WHEREOF, I have hereunto set my hand and affixed
the official Seal of the City of Vernon, County of Los Angeles,
State of California, on this __,ZO!6"day of October 2016.
SEAL:
f�
Maria E. Aya
City lerk
STAFF REPORT
RECEIVIFED
OCT 13 2n
CITY CLERK'S OFFICE
STAFF REPORT
RECEIVED
OCT 12 2016
CITY ADMINISTRATION
GAS & ELECTRIC DEPARTMENT
DATE: October 18, 2016
TO: Honorable Mayor and City Council
FROM: Kelly Nguyen, Director of Vernon Gas & Electric W
Originator: Abraham Alemu, Electric Resources Planning & Development
Manager jointly with Spiegel & McDiarmid, Outside Counsel
RE: Establishment of New Transmission Revenue Requirement (TRR) Associated
with Vernon's High Voltage Entitlements ("TRR Report")
Recommendation
A. Find that the approvals requested in this staff report do not constitute "projects" pursuant
to section 15378(b)(2) of the Guidelines to the California Environmental Quality Act
("CEQA"), because such actions constitute administrative activities; and even if the
adoption of the proposed items did constitute projects, they would be exempt in
accordance with CEQA Guidelines section 15061(b)(3), the general rule that CEQA only
applies to projects that may have an effect on the environment;
B. Conduct a Public Hearing; and
C. Adopt the attached Resolution to thereby:
i. Approves, pursuant to the Transmission Owner Tariff, and to be effective on
January 1, 2017, the establishment of the City's new TRR Transmission Revenue
Requirement (TRR) and Appendix I to the TO Tariff implementing the new TRR,
as described in the Gas & Electric TRR Report dated on or about October 18,
2016; and
ii. Authorize outside counsel to submit the City's TRR, the amended Appendix I to
the Vernon TO Tariff, and supporting documentation such as the TRR Report, to
the Federal Energy Regulatory Commission (FERC) on behalf of the City of
Vernon.
Page 1 of 2
Background
The City of Vernon ("Vernon" or "City") is a Scheduling Coordinator and a Participating
Transmission Owner ("PTO") in the California Independent System Operator Corporation
("ISO"). To participate in the ISO, PTOs are required to turn over administrative control of their
transmission facilities and entitlements to the ISO. In return, the ISO collects revenues for each
PTO pursuant to calculations that reflect the expenses and capital costs incurred by each PTO to
provide transmission services. These calculations are known as Transmission Revenue
Requirements ("TRRs").
The relationship between PTOs and the ISO is governed by a Transmission Control
Agreement ("TCA"), which sets forth specific duties and obligations of all PTOs. The TCA
requires all PTOs to file a Transmission Owner Tariff ("TO Tariff') and TRR with the Federal
Energy Regulatory Commission ("FERC"). The TCA further requires all PTOs to file any
changes in their TRRs with FERC. Each PTO must also include in its TO Tariff its Gross Load
which the ISO uses to calculate its grid -wide Transmission Access Charge ("TAC") rates, and
which is related to the City's ability to recover its full TRR.
TRANSMISSION REVENUE REQUIREMENT
At present, the City's high voltage transmission assets consist of three long-term
contracts (known as "existing transmission contracts" or "ETCs") which provide the City with
dedicated access to high voltage transmission facilities owned by other entities. Specifically, the
City has contractual entitlements to utilize transmission assets pursuant to one long-term
transmission contract with the Los Angeles Department of Water and Power ("LADWP") and
two long-term transmission contracts with Southern California Edison ("SCE"). The ETCs with
SCE consist of one (the "SCE Victorville-Lugo ETC" described in SCE's FERC Rate Schedule
360) providing 11 MW of transmission capacity along the path between the Victorville-Lugo
midpoint and the point of interconnection with the City's internal transmission system (the "City
Gate"), and one (the "SCE Mead ETC" described in SCE's FERC Rate Schedule 207) providing
26 MW of transmission capacity along the path between the Mead 230 substation and the City
Gate.
The costs of these ETCs make up the majority of the costs recovered through the City's
TRR. Until recently, for each of the ETCs, the City paid the owner of the transmission facilities
a fixed rate which was specific to the transmission path provided under each ETC.
The attached TRR Report supports the establishment of a new transmission revenue
requirement associated with Vernon's high voltage entitlements.
Fiscal Impact
The cost of Existing Transmission Service Contracts (ETC) incurred by the City will be
recovered.
Attachments
1. Notice of Public Hearing to Establish New Transmission Revenue Requirement
2. Resolution Adopting a New Transmission Revenue Requirement
Page 2 of 2
4305 Santa Fe Avenue
Vernon, CA 90058
(323)583-8811
NOTICE OF TWO SEPARATE PUBLIC BEARINGS
The City Council of the City of Vernon will conduct two public hearings, which you may attend.
PLACE: Vernon City Hall
City Council Chambers
4305 Santa Fe Avenue
Vernon, CA 90058
DATE & Tuesday, October 18, 2016 at 9:00 a.m.
TIME: (or as soon thereafter as the matter can be heard)
SUBJECTS: (1) To consider evidence to establish Vernon's new Transmission Revenue
Balancing Account Adjustment for its high voltage (over 200 kV)
transmission entitlements (all located outside the City) pursuant to Vernon's
Transmission Owner Tariff, and (2) To consider evidence to establish
Vernon's new Existing Transmission Contract Adjustment for its high
voltage (over 200 kV) transmission entitlements (all located outside the City)
pursuant to Vernon's Transmission Owner Tariff.
REQUEST: All parties are invited to be present and to submit statements orally or in writing
before or during the applicable public hearing
REVIEW OF Subject documents are available for inspection by the public at
THE FILE: Vernon City Hall, City Cleric Department, 4305 Santa Fe Avenue, Vernon,
California 90058, Monday through Thursday, 7:00 a.m. to 5:30 p.m. and on the
City's website at: littp:/hvkvw.cityolvcrt,oil.ornfile n /public
ttt�;t:tint )s titer -council
PROPOSED Staff plans to recommend that the Vernon City Council determine
CEQA that the proposals will not have a significant effect on the environment and
FINDING: are exempt from the California Environmental Quality Act (CEQA)
If you desire to challenge the actions taken by the City Council or any portion thereof in court,
you may be limited to raising only those issues you or someone else raised at the applicable hearings
described in this notice or in written correspondence delivered to the City of Vernon during, or before, the
hearings.
The hearings may be continued or adjourned or cancelled and rescheduled to a stated time and
place without further official notice of the public hearings.
i
Dated: October 6, 2016
Kelly Nguyen, Director d V rnon Gas & Elrectric
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
VERNON ADOPTING A NEW TRANSMISSION REVENUE
REQUIREMENT FOR 2017 IN ACCORDANCE WITH VERNON'S
TRANSMISSION OWNER TARIFF AND PROVIDING FOR TARIFF
SHEET CHANGES TO IMPLEMENT THE ADJUSTMENT
WHEREAS, the City of Vernon ("City") is a chartered municipal
corporation of the State of California that owns and operates a system
for the generation, purchase, transmission, distribution and sale of
electric capacity and energy; and
WHEREAS, the City is a Participating Transmission Owner
("PTO") with the California Independent System Operator Corporation
("ISO"), and the Federal Energy Regulatory Commission ("FERC") has
approved its existing Transmission Owner Tariff ("TO Tariff"); and
WHEREAS, the ISO reimburses the City according to the City's
current Transmission Revenue Requirement ("TRR") in return for the City
turning over to the ISO the operation and control of the City's
transmission entitlements; and
WHEREAS, each PTO must include in its TO Tariff its Gross
Load, which the ISO uses to calculate its grid -wide Transmission Access
Charge ("TAC") rates, and which is related to the City's ability to
recover its full TRR; and
WHEREAS, the City's transmission entitlements include rights
under certain contracts (each an "ETC") including (i) an agreement with
the City of Los Angeles Department of Water and Power entitled "Los
Angeles -Vernon Adelanto-Victorville-Lugo Firm Transmission Service
Agreement" (the "LAWDP ETC"); (ii) an agreement with Southern
California Edison Company ("SCE") entitled "Amended and Restated
Edison -Vernon Victorville-Lugo Firm Transmission Service Agreement"
(the "SCE Victorville-Lugo ETC"); and (iii) an agreement with SCE
entitled "Amended and Restated Edison -Vernon Mead Firm Transmission
Services Agreement" (the "SCE Mead ETC"); and
WHEREAS, the City's costs under the LADWP ETC, the SCE
Victorville-Lugo ETC, and the SCE Mead ETC have traditionally been
based upon a negotiated fixed "path -specific" rate charged by LADWP or
SCE, based on the actual costs of the specific transmission lines made
available under each ETC, multiplied by the amount of transmission
capacity guaranteed to the City under each ETC; and
WHEREAS, on August 1, 2008, SCE filed a petition with FERC
seeking to amend the pricing structure under the SCE Victorville-Lugo
ETC and the SCE Mead ETC to replace the negotiated path -specific rates
set forth in those ETCs with a "postage -stamp" rate which reflects the
blended rate SCE charges to the ISO for the actual usage of all of
SCE's transmission lines by customers of the ISO; and
WHEREAS, the postage -stamp rate which SCE charges to the ISO
is derived from SCE's TRR and, therefore, will change each time SCE
amends its TRR; and
WHEREAS, on September 30, 2008, FERC accepted, subject to
refund and hearing and settlement procedures, SCE's proposed revisions
under the SCE Victorville-Lugo ETC and the SCE Mead ETC to replace the
negotiated path -specific rates set forth in those ETCs with a postage -
stamp rate, and thus the City's costs under the SCE Victorville-Lugo
ETC and the SCE Mead ETC will vary proportionately with any changes in
SCE's TRR; and
WHEREAS, the City reached a settlement agreement (the "SCE
Settlement") with SCE to amend the SCE Victorville-Lugo ETC and the SCE
- 2 -
Mead ETC to replace the path -specific rates set forth in those ETCs
with SCE's postage -stamp rate after a phase -in period that began on
August 1, 2009, during which the City's path -specific rates in those
ETCs are gradually stepped -up over three years (the "Phase -In Rates")
until the path -specific rates are equal to SCE's postage -stamp rate as
of January 1, 2013; and
WHEREAS, under the SCE Settlement, the City's costs for the
SCE Victorville-Lugo ETC and the SCE Mead ETC are equal to (i) from
August 1, 2009, until December 31, 2012, the Phase -In Rates, and
beginning on January 1, 2013, the SCE postage -stamp rate, in each case
multiplied by (ii) the amount of transmission capacity guaranteed to
the City under each ETC; and
WHEREAS, FERC approved the SCE Settlement pursuant to an
order issued September 11, 2009, 128 FERC ¶ 61,237 (2009), in FERC
Docket Nos. ER08-1343-000, ER08-1353-000, ER09-187-000, ER09-187-001,
EL09-19-000, and ER09-446-000 ("SCE Settlement Order"); and
WHEREAS, on behalf of the City, the Brattle Group, an
experienced utilities consulting firm, developed a tracking mechanism
for the City's TRR ("TRR Tracking Mechanism") to allow the City's TRR
to be adjusted annually, effective January 1 of each year, to reflect
changes in the City's costs under the SCE Victorville-Lugo ETC and the
SCE Mead ETC that change as a result of (i) the stepped -up rates
implemented between August 1, 2009 and December 31, 2012; or (ii) any
change in SCE's TRR on or after January 1, 2013; and
WHEREAS, on the basis of The Brattle Group's analysis and
evidence from City staff, which was considered during a public meeting
of the City Council held on July 13, 2009, the City, on July 15, 2009
("July 15 FERC Filing"), filed with FERC proposed revisions to its TO
- 3 -
Tariff proposing stated TRRs for each of the years 2010 to 2012, which
dollar amounts were also included in the SCE Settlement ("TO Tariff
Revisions"); and
WHEREAS, the City also submitted in the July 15 FERC Filing a
request to utilize an "ETC Adjustment Clause" to adjust automatically
each year the costs the City incurs attributable to any changes in
SCE's TRR associated with SCE's High Voltage Existing Contracts Access
Charge ("HVECAC") rate; and
WHEREAS, FERC approved the City's request to utilize an ETC
Adjustment Clause to reflect annual projected changes to SCE's TRR, in
an order issued September 11, 2009, 128 FERC ¶ 61,235 (2009), in FERC
Docket No. EL09-64-000 ("TO Tariff Order"); and
WHEREAS, under the TO Tariff Order, the City's TO Tariff
revisions went into effect on August 1, 2009; and
WHEREAS, on January 6, 2015, the City approved revisions to
the template used to calculate the annual ETC Adjustment Clause; and
WHEREAS, on April 8, 2015, FERC approved the City's 2015
filing with FERC reflecting modifications to the base TRR as calculated
using the revised ETC Adjustment Clause template; and
WHEREAS, the City is required under the TO Tariff Order to
submit annual filings with FERC reflecting modifications to the base
TRR; and
WHEREAS, a Notice of Public Hearing was published on October
6, 2016, notifying all interested parties that a hearing to consider
evidence to establish the City's new TRR was scheduled for October 18,
2016, at approximately 9:00 a.m., subject to the hearing being
continued or adjourned to a stated time and place without further
notice of public hearing; and
- 4 -
WHEREAS, on October 18, 2016, the City Council held a Public
Hearing in which the City Council took evidence from staff and those
other persons in attendance who wished to be heard on the calculation
of the City's new TRR under the City's amended TO Tariff; and
WHEREAS, the TRR for 2017 is shown in the amended Appendix I
to the TO Tariff, a copy of which is attached hereto as Exhibit A and
made a part hereof.
WHEREAS, the Gas & Electric Department has prepared a Report,
dated October 18, 2016, with exhibits, a copy of which is attached
hereto as Exhibit B and made a part hereof, which reiterates its
previous conclusions that the TRR and ETC Adjustment Clause mechanism
developed by The Brattle Group, approved by FERC under the amended TO
Tariff, and revised in 2015 are reasonable and which calculates the
amount derived under the ETC Adjustment Clause for 2017; and
WHEREAS, the Gas & Electric Department has recommended the
City adopt the TRR shown in the amended Appendix I to the TO Tariff,
attached as Exhibit A, to be effective on January 1, 2017; and
WHEREAS, the City Council has heard and considered all
evidence, written and oral, presented in consideration of the
establishment of the City's new TRR under the amended TO Tariff.
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
and correct.
SECTION 2: The City Council of the City of Vernon finds
that this action does not constitute a "project" pursuant to section
15378(b)(2) of the Guidelines to the California Environmental Quality
- 5 -
Act ("CEQA"), because such action constitutes an administrative
activity; and even if the adoption of the proposed item did constitute
a project, it would be exempt in accordance with CEQA Guidelines
section 15061(b)(3), the general rule that CEQA only applies to
projects that may have an effect on the environment.
SECTION 3: The City Council of the City of Vernon hereby
further finds and determines that all persons have had the opportunity
to be heard or to file written comments to the proposed adoption of the
City's TRR, and after due consideration of any and all evidence
submitted at the Public Hearing, determines there are compelling
reasons to justify the adoption of the City's TRR and Gross Load, to be
effective January 1, 2017.
SECTION 4: The City Council of the City of Vernon hereby
declares that:
(a) any determination made pursuant to this Resolution
regarding the validity or reasonableness of any portion of any TRR or
TO Tariff shall apply only prospectively from the date of this
Resolution; and
(b) in no way shall this Resolution affect the City
Council's adoption or determination of any previous TRR or TO Tariff.
SECTION 5: The City Council of the City of Vernon hereby
approves, pursuant to the TO Tariff and to be effective on January 1,
2017, the establishment of the City's new TRR and Appendix I to the TO
Tariff implementing the new TRR, as described in the Gas & Electric
Report dated October 18, 2016.
SECTION 6: The City Council of the City of Vernon hereby
authorizes outside counsel to submit the City's TRR, the amended
Appendix I to the Vernon TO Tariff, and supporting documentation, such
- 6 -
as the Report, and this City Council Resolution approving the new TRR,
to FERC on behalf of the City of Vernon.
SECTION 7: The City Clerk or Deputy City Clerk of the City
of Vernon shall certify to the passage, approval and adoption of this
.resolution, and the City Clerk. or Deputy City Cler-K of the City of
Vernon shall cause this resolution and the City Cleric's or Deputy City
Cleric's certification to be entered in the File of resolutions of the
Council of this City.
APPROVED AND ADOPTED this 18th day of October, 2016.
ATTEST:
City Cleric /Deputy City Clerk
APPROVED AS TO FORM:
Katharine Mapes, Esq.
Spiegel & McDiarmid, LLP
Special Counsel to City
Name:
Title: Ma
- 7 -
STATE OF CALIFORNIA )
) ss
COUNTY OF LOS ANGELES )
I, , City Clerk / Deputy City Clerk of the City
of Vernon, do hereby certify that the foregoing Resolution, being
Resolution No. , was duly passed, approved and adopted by the
City Council of the City of Vernon at a regular meeting of the City
Council duly held on October 18, 2016, and thereafter was duly signed
by the Mayor or Mayor Pro-Tem of the City of Vernon.
Executed this day of October, 2016, at Vernon, California.
(SEAL)
City Clerk / Deputy City Clerk
- 8 -
APPENDIX I
Transmission Revenue Requirement and TRBAA
The Vernon Base Transmission Revenue Requirement is $2,°''y�73,033,164 and is comprised
of the following components:
Base TRR costs not subject to ETC Adjustment Clause:
ETC Adjustment Clause:
Forecast SCE ETC Costs:
Balance of Difference between prior year
Forecast and Actual SCE ETC Costs:
Interest on Difference between prior year
Forecast and Actual SCE ETC Costs:
$498,480
$2,z 75,2Qo2,708,400
($5,371167,924)
($5�,-2Q5,792)
The ETC Adjustment Clause is: The projected SCE ETC Cost for the next calendar year,
plus the true -up (positive or negative) of the prior October through September SCE ETC
Cost with interest calculated pursuant to 18 C.F.R. § 35.19a. The ETC Adjustment
Clause will be recalculated annually and filed with the Commission with a proposed
effective date of January 1 of each year.
The TRBAA is a posi-tivenegative $44447,616 for calendar year 20167.
Vernon's Gross Load, consistent with its TRR, used by the ISO to develop the Transmission
Access Charge is 1,181,728 MWhs.
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 Tariff approved by the
Vernon City Council, and provided to the ISO.
APPENDIX I
Transmission Revenue Requirement and TRBAA
The Vernon Base Transmission Revenue Requirement is $3,033,164 and is comprised of the
following components:
Base TRR costs not subject to ETC Adjustment Clause: $498,480
ETC Adjustment Clause:
Forecast SCE ETC Costs: $2,708,400
Balance of Difference between prior year
Forecast and Actual SCE ETC Costs: ($167,924)
Interest on Difference between prior year
Forecast and Actual SCE ETC Costs: ($5,792)
The ETC Adjustment Clause is: The projected SCE ETC Cost for the next calendar year,
plus the true -up (positive or negative) of the prior October through September SCE ETC
Cost with interest calculated pursuant to 18 C.F.R. § 35.19a. The ETC Adjustment
Clause will be recalculated annually and filed with the Commission with a proposed
effective date of January 1 of each year.
The TRBAA is a negative $47,616 for calendar year 2017.
Vernon's Gross Load, consistent with its TRR, used by the ISO to develop the Transmission
Access Charge is 1,181,728 MWhs.
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 Tariff approved by the
Vernon City Council, and provided to the ISO.
W(qMl
CITY OF VERNON GAS AND ELECTRIC
DEPARTMENT
REPORT REGARDING THE ESTABLISHMENT OF A REVISED NEW
TRANSMISSION REVENUE REQUIREMENT ASSOCIATED WITH VERNON'S
HIGH VOLTAGE ENTITLEMENTS
October 18, 2016
The City of Vernon ("Vernon" or "City") is a Scheduling Coordinator and a
Participating Transmission Owner ("PTO") in the California Independent System
Operator Corporation ("ISO"). To participate in the ISO, PTOs are required to turn
over administrative control of their transmission facilities and entitlements to the ISO.
In return, the ISO collects revenues for each PTO pursuant to calculations that
reflect the expenses and capital costs incurred by each PTO to provide transmission
services. These calculations are known as Transmission Revenue Requirements
("TRRs").
The relationship between PTOs and the ISO is governed by a Transmission Control
Agreement ("TCA"), which sets forth specific duties and obligations of all PTOs. The
TCA requires all PTOs to file a Transmission Owner Tariff ("TO Tariff") and TRR with
the Federal Energy Regulatory Commission ("FERC"). The TCA further requires all
PTOs to file any changes in their TRRs with FERC. Each PTO must also include in
its TO Tariff its Gross Load which the ISO uses to calculate its grid -wide
Transmission Access Charge ("TAC") rates, and which is related to the City's ability
to recover its full TRR.
TRANSMISSION REVENUE REQUIREMENT
At present, the City's high voltage transmission assets consist of three long-term
contracts (known as "existing transmission contracts" or "ETCs") which provide the
City with dedicated access to high voltage transmission facilities owned by other
entities. Specifically, the City has contractual entitlements to utilize transmission
assets pursuant to one long-term transmission contract with the Los Angeles
Department of Water and Power ("LADWP") and two long-term transmission
contracts with Southern California Edison ("SCE"). The ETCs with SCE consist of
TRR Report 2017
Page 3 of 6
those ETCs have been gradually stepped -up under incrementally increasing fixed
rates (the "Phase -In Rates") until the path -specific rates are equal to the HVECAC
Rate as of January 1, 2013. FERC approved the SCE Settlement pursuant to an
order issued September 11, 2009, 128 FERC ¶ 61, 237 (2009), in FERC Docket
Nos. ER08-1343-000, ER08-1353-000, ER09-187-000, ER09-187-001, EL09-19-
000, and ER09-446-000 ("SCE Settlement Order").
On behalf of the City, The Brattle Group, an experienced utilities consulting firm,
developed a TRR tracking mechanism clause for the City's TRR ("ETC Adjustment
Clause"), which allows the City's TRR to be adjusted annually, effective January 1 of
each year, to reflect changes in the City's transmission expenses associated with
any changes implemented by SCE in the HVECAC Rate associated with the SCE
Victorville-Lugo ETC and the SCE Mead ETC.
On the basis of The Brattle Group's analysis and evidence from City staff, which was
considered during a public meeting of the City Council held on July 13, 2009, the
City, on July 15, 2009 ("July 15 FERC Filing"), filed with FERC the proposed (i)
revisions to its TO Tariff proposing the City's stated TRRs for each of the years 2010
to 2012, which dollar amounts were also included in the SCE Settlement ("TO Tariff
Revisions") and (ii) the ETC Adjustment Clause tracking mechanism.
The July 15 FERC Filing acknowledged that, to the extent that the SCE Settlement
was accepted, because the stated Phase -In Rates would be fixed, the ETC
Adjustment Clause for the term of the Phase -In Rates would be zero.
FERC approved the City's July 15 FERC Filing, including the TO Tariff Revisions,
the City's proposed calculations of the TRR for years 2010 to 2012, and the City's
request to utilize an ETC Adjustment Clause, in an order issued September 11,
2009, 128 FERC ¶ 61,235 (2009), in FERC Docket No. EL09-64-000 ("TO Tariff
Order"). The City is required under the TO Tariff Order to submit annual filings each
year with FERC reflecting annual modifications to the base TRR of the City.
TRR Report 2017
Page 5 of 6
Vernon will true up any differences in its SCE ETC costs when it makes its 2018
TRR filing.
The ETCCF for 2017 SCE ETC costs are projected to be $2,708,400 as shown in
line 8 of Exhibit 1.
The ETCCT Component
ETCCT represents a balance that reflects the difference between prior year forecast
and actual SCE ETC costs. The prior period in this case is the twelve-month period
starting October 1, 2015 and ending September 30, 2016.
A summary of the determination of the September 30, 2016 balance in the ETC
Adjustment Clause is shown in Exhibit 1. The ETCCT component reflects 1) the
previously projected 2015 SCE ETC costs of $165,760 per month, for the months
October through December 2015 and projected 2016 SCE ETC costs of $214,600
per month, for the months January through September 2016, 2) actual 2015 SCE
ETC costs of $ 172,790 per month, for the months October through December 2015
and $208,680 per month, for the months January through September 2016, and 3)
refunds received by the City —all elements as reflected on Line No. 8, 15, and 16 of
Exhibit 1. The net of these elements produce the under (or over) collection figures
reflected in Line 17 of Exhibit 1. The ending balance is the sum of the beginning
balance on October 1 and the (over)/under collection — both elements as reflected
on Line 1 and 17 of Exhibit 1. The cumulative monthly balances are carried forward
from month to month and the ETCCT component on September 30, 2016 of negative
$167,924 is shown in line 19 of Exhibit 1.
The I (Interest) Component
The Interest component reflects interest on the difference between prior year
forecast and actual SCE ETC costs. The monthly interest carrying costs are
calculated using the 18 C.F.R. § 35.19(a) interest rates and calculation method.
These interest rates are published by FERC and reflect the prime rate values
published in the Federal Reserve Bank's "Selected Interest Rates."
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