Raymond Lutz's comments in review of the Draft IER
Comments to Administrative Judge on 2/25/2008
Raymond Lutz, Candidate for the 77th Assembly District,
Lutz For Assembly.com.
and I am a degreed Electrical Engineer.
The Sunrise Powerlink is the wrong project at the wrong time.
Experts agree it is not needed to capitalize on renewable resources in Imperial valley.
Instead, with power generation in Mexico supplied by the new LNG terminal,
the overall gameplan of Sempra continues our addiction to imported fuel.
This is a national security issue that we must address.
The community can see through to the hidden agenda of this project, and it
has nothing to do with the needs of San Diego County or to transition to
renewable power generation.
The community can see the proposed disaster to the scenic quality of the
Anza Borrego Desert State park and the wasted money on a false solution as we
turn our economy toward a different future,
a future based on local generation and distributed solar and wind power.
The proposed 500KV Transmission Line would theoretically have a
maximum power capacity of about 1000MW. But that is a capacity that we don't need
right now. Saving or generating only 1000W per household would cover the
entire capacity. The estimated lifetime cost of $7Billion will more than cover
converting homeowners to conserve and install local production.
But SDGE and Sempra won't make more money if we turn to
distributed solar and local generation. This is a conflict of interest -- of
our interest-- if we let them continue down this path.
Sunrise Power Link is the wrong solution, and it MUST be stopped.
But the wheels of government have been greased for years by these power
monopolies, and it will take this public outcry to stop it.
I will continue to fight to stop Sunrise Powerlink.
Extracted from the IER:
The SDG&E service territory is currently served by one 500 kV circuit that imports electricity from the
Imperial Valley, Arizona, and Mexico between the Imperial Valley and Miguel Substations. The existing
500 kV lines serving the San Diego area is called the Southwest Powerlink (SWPL). Five 230 kV lines
south of San Onofre Nuclear Generating Station provide San Diego’s only other connection to the
remainder of the U.S. grid. Two 230 kV lines interconnect with Mexico, and one 230 kV line interconnects
with the Imperial Irrigation District, but SDG&E does not rely upon imports over these connections
because they occur outside of CAISO control.
Today, SDG&E’s ability to reliably import is defined by two transmission import boundaries or
constraints: the SDG&E simultaneous import limit (SIL) and non-simultaneous import limit (NSIL).9
The SIL, currently rated at 2,850 MW, is defined by SDG&E’s ability to import power into its system
at the Miguel Substation with the five 230 kV lines that make up the “South of SONGS” path (or
Path 44). The 2,850 MW SIL limit applies when all transmission facilities are in operation. When
SWPL is out of operation, the NSIL is 2,500 MW. Local generation must be used to make up any
deficit between the import limits and load.
The Sunrise Powerlink Project would greatly expand the import capability for SDG&E. The Proposed
Project would increase SDG&E’s simultaneous import limit from 2,850 MW to 4,200 MW, and the
non-simultaneous import limit would increase from 2,500 MW to 3,500 MW
HOW DOES THIS MAKE SENSE?
In one paragraph, it says that the capacity of the SRPL is
Then, it says it is
- 350 MW for the SWPL 500KV system
- 2500 MW for 5 230KV lines
- 500MW each?
THIS DOESN'T MAKE SENSE. TOTAL SIL SHOULD BE 3,850 MW.
The power capacity of the 500 KV line is implied to be 1000MW. However, the power capacity of the existing 500 KW SWPL is only shown as 350MW.
Assuming 1000MW is possible, how much conservation is required to offset the additional supply?
- Population of San Diego County = 2,941,454
- Households = 994,677 = approximately 1M households
- Power per household is 1000MW / 1M = 1KW
- Compact Flourescent: Savings of 60W to 13W = 47W; 1000/47 = 21
EACH HOUSEHOLD NEEDS TO CONSERVE ONLY 1000W TO MAKE UP THE POWER DIFFERENCE.
BY REPLACING 21 60W LIGHT BULBS TO FLOURESCENT BULBS (SAVES 47W EACH) THAT SAVES THE POWER.
ONE TYPICAL 15A CIRCUIT IN THE HOME CAN DELIVER UP TO 15A x 110V = 1650W
However, breaker would nuisance-trip when the current reached about 80% of maximum. That leaves us with 12A * 120V = 1,440W
10.5 - 14.8 Volts DC @ 530ma
NOMINAL 12V AT 530ma puts out same light as 50W incandescent.
12V*530ma = 6.36W
CHANGING TO LED LIGHTS CUTS POWER IN HALF FROM FLOURESCENT, but they are still expensive.
California Independent System Operator
Transmission and distribution losses in the USA were estimated at 7.2% in 1995 , and in the UK at 7.4% in 1998. 
Power is always partially lost by transmission.
The amount of power that can be sent over a transmission line is limited. The origins of the limits vary depending on the length of the line. For a short line, the heating of conductors due to line losses sets a "thermal" limit. If too much current is drawn, conductors may sag too close to the ground, or conductors and equipment may be damaged by overheating. For intermediate-length lines on the order of 100 km (60 miles), the limit is set by the voltage drop in the line. For longer AC lines, system stability sets the limit to the power that can be transferred. Approximately, the power flowing over an AC line is proportional to the sine of the phase angle between the receiving and transmitting ends. Since this angle varies depending on system loading and generation, it is undesirable for the angle to approach 90 degrees. Very approximately, the allowable product of line length and maximum load is proportional to the square of the system voltage. Series capacitors or phase-shifting transformers are used on long lines to improve stability. High-voltage direct current lines are restricted only by thermal and voltage drop limits, since the phase angle is not material to their operation.
If everything else remained unchanged, building new lines or upgrading the existing ones
would clearly enhance the security of the overall system. The security margin (i.e. the
difference between the power that the system is designed to handle and what actually
flows) would indeed be much higher. Even during periods of high demand, the system
would be able to withstand more than just the credible contingencies.
It is very unlikely, however that everything else would remain unchanged. Additions and
upgrades to the transmission network are immediately reflected in the models that
engineers use to evaluate the security of the system and calculate the available
transmission capacity. Unless the rules governing the usage of the system are changed,
this additional transmission capacity would be made available to all users of the
transmission network. Economic considerations dictate that this new capacity will
inevitably be used for increased power transfers from regions with inexpensive
generation to regions with a high demand. Security might be enhanced in the short run
because new economic transactions using the existing generating plants might not absorb
all the additional transmission capacity. In the long run, however, generating plants will
be built in a way that makes full use of the transmission network. At that point, the
system will again be operating at the limit dictated by the security rules and the
probability of a blackout will not have diminished. We can therefore conclude that
building new transmission lines and upgrading the existing transmission system do not
inherently enhance the security of the transmission system. On the other hand, these
investments have significant economic benefits because they relax some of the
limitations that the transmission network places on the electricity markets.
Spec for San Diego:
Lamps shall be high pressure sodium vapor, with clear glass bulbs, suitable for
use in street lighting, and designed to operate in a horizontal position. The rated
average life shall be 24,000 hours or more, and the lumen output shall be 9,500
for 100-watt lamps and 30,000 for 250-watt lamps. (95 lumens per watt, 120 lumens per watt)
In a 120 volt, 100 watt "standard" bulb with a rated light output of 1750 lumens, the efficiency is 17.5 lumens per watt. This compares poorly to an "ideal" of 242.5 lumens per watt for one idealized type of white light, or 683 lumens per watt ideally for the yellowish-green wavelength of light that the human eye is most sensitive to.
A halogen bulb is often 10 to 20 percent more efficient than an ordinary incandescent bulb of similar voltage, wattage, and life expectancy. Halogen bulbs may also have two to three times as long a lifetime as ordinary bulbs, sometimes also with an improvement in efficiency of up to 10 percent. How much the lifetime and efficiency are improved depends largely on whether a premium fill gas (usually krypton, sometimes xenon) or argon is used.
The most efficient colored LEDs have overal luminous efficacy of approx. 53 lumens/watt. The most efficient white LEDs get around 64-80 lumens/watt, with one that achieves typically 69 lumens/watt announced on 10/9/2006 to be in production. Many really good ones still only achieve about 25-45 lumens/watt.
LEDs: 45 lm/W (2006) 25 lm/W (2003)
A 20 watt fluorescent bulb of a higher light output color should make as much light as a 75 watt incandescent (1170 to 1210 lumens)
1210/20 = 60 lumens per watt.
1000 watts and 140,000 lumens. = 140 lumens per watt. efficacy of the whole fixture is 31 lumens per watt.
other light sources which have efficacies up to 180 lumens per watt
Photovoltaic Systems (PV)
By 1999, the worldwide capacity of PV had reached 1000 MW. Total of installed PV is around 6,000 MWp (Mega-watt-peak) as of the end of 2006. It is projected to reach more than 9,000 MWp by the end of 2007.
To equip 1M homes with 1000W PV systems would cost about $8K per system or less. Resulting cost of equivalent power capacity to SPL is about $8B or less.
SRPL is slated to cost $1.3 billion. Analysis suggests the true price tag will be closer to $2 billion. Over its 40 year depreciable life, the state's customers will be obligated to pay over $7 billion.
SDGE says that to produce the needed amount of renewable energy locally would require that solar panels be installed on 855,000 residential rooftops at a cost of $21 billion.
In fact, in all of San Diego County,, about 12 .6 MW of solar PV is in place in all residential and commercial installations,
What about putting the Sunrise Powerlink cost of S1 .0 B to $1 .4 B into roof top solar? If;the.state PUC allowed SDG&E to put this directly into PV panels at about
$8 per watt, then it could buy about 150 MW worth of solar. That would be about 4% of our current power demand. If the Sunrise Powerlink cost was used in San Diego as a rebate (similar to the existing state rebate program), it could pay for about 325 MW of solar. The existing state refund program has cost the state about $3.70
Energy efficiency/ conservation is even more important than new power sources. . Simple. things like switching your lights to florescent bulbs, getting rid of your old
refrigerator, planting trees on the east and west side of your home to block sun.
SDG&E's own numbers show it will need only 354 Mw of new resources by 2018. UCAN's analysis shows that SDG&E's current resource plan will fulfill all but 6 Mw of that projected need - without any transmission additions.
Bill in Calif. legislature allowing reverse metering over and above use - AB 94
(h) For eligible residential and small commercial
customer-generators, the net energy metering calculation shall be
made by measuring the difference between the electricity supplied to
the eligible customer-generator and the electricity generated by the
eligible customer-generator and fed back to the electric grid over a
12-month period. The following rules shall apply to the annualized
net metering calculation:
(1) The eligible residential or small commercial
customer-generator shall, at the end of each 12-month period
following the date of final interconnection of the eligible
customer-generator's system with an electricity distribution utility or
cooperative , and at each anniversary date thereafter, be
billed for electricity used during that 12-month period.
distribution utility or cooperative shall determine if the
eligible residential or small commercial customer-generator was a net
consumer or a net producer of electricity during that period.
(2) At the end of each 12-month period, where the electricity
supplied during the period by the electricity distribution utility or cooperative
exceeds the electricity generated by the eligible residential or
small commercial customer-generator during that same period, the
eligible residential or small commercial customer-generator is a net
electricity consumer and the electricity distribution utility or cooperative
shall be owed compensation for the eligible customer-generator's net
kilowatthour consumption over that same
12-month period. The compensation owed for the eligible
residential or small commercial customer-generator's consumption
shall be calculated as follows:
(A) For all eligible customer-generators taking service under
contracts or tariffs employing "baseline" and "over baseline"
rates or charges , any net monthly consumption of
electricity shall be calculated according to the terms of the
contract or tariff to which the same customer would be assigned to
, or be eligible for , if the customer was not
an eligible customer-generator. If those same customer-generators are
net generators over a billing period, the net kilowatthours
generated shall be valued at the same price per kilowatthour as the
distribution utility or cooperative would charge for the
baseline quantity of electricity during that billing period, and if
the number of kilowatthours generated exceeds the baseline quantity,
the excess shall be valued at the same price per kilowatthour as the
distribution utility or cooperative would charge for
electricity over the baseline quantity during that billing period.
(B) For all eligible customer-generators taking service under
contracts or tariffs employing "time of use" rates or
charges , any net monthly consumption of electricity shall be
calculated according to the terms of the contract or tariff to which
the same customer would be assigned to , or be eligible
for , if the customer was not an eligible
customer-generator. When those same customer-generators are net
generators during any discrete time of use period, the net
kilowatthours produced shall be valued at the same price per
kilowatthour as the electricity distribution utility or cooperative would charge
for retail kilowatthour sales during that same time of use period. If
the eligible customer-generator's time of use electrical meter is
unable to measure the flow of electricity in two directions,
paragraph (3) of subdivision (b) subparagraph (A) of
paragraph (1) of subdivision (c) shall apply.
(C) For all eligible residential and small commercial
customer-generators and for each billing period, the net balance of
moneys owed to the electricity distribution utility or cooperative for net
consumption of electricity or credits owed to the eligible
customer-generator for net generation of electricity shall be
carried forward as a monetary value until the end of each 12-month
period. For all eligible commercial, industrial, and
agricultural customer-generators , the net balance of
moneys owed shall be paid in accordance with the electricity distribution utility or
cooperative's normal billing cycle, except that if the
eligible commercial, industrial, or agricultural
customer-generator is a net electricity producer over a normal
billing cycle, any excess kilowatthours generated during the billing
cycle shall be carried over to the following billing period as a
monetary value, calculated according to the procedures set forth in
this section, and appear as a credit on the eligible
customer-generator's account, until the end of the annual period when
paragraph (3) shall apply.
(3) At the end of each 12-month period, where the electricity
generated by the eligible customer-generator during the 12-month
period exceeds the electricity supplied by the electricity distribution utility or
cooperative during that same period, the eligible
customer-generator is a net electricity producer and the
utility or cooperative shall retain any excess kilowatthours
generated during the prior 12-month period. The eligible
customer-generator shall not be owed any compensation for those
excess kilowatthours unless the electricity distribution utility or cooperative
enters into a purchase agreement with the eligible customer-generator
for those excess kilowatthours.
(4) The electric service provider
electricity distribution utility or cooperative shall provide
every eligible residential or small commercial customer-generator
with net electricity consumption information with each regular bill.
That information shall include the current monetary balance owed the
distribution utility or cooperative for net electricity
consumed , or the current amount of excess electricity produced,
since the last 12-month period ended. Notwithstanding this
subdivision, an electric service provider
electricity distribution utility or cooperative shall permit
that customer to pay monthly for net energy consumed.
(5) If an eligible residential or small commercial
customer-generator terminates the customer relationship with the
electricity distribution utility or cooperative, shall reconcile
the eligible customer-generator's consumption and production of
electricity during any part of a 12-month period following the last
reconciliation, according to the requirements set forth in this
subdivision, except that those requirements shall apply only to the
months since the most recent 12-month bill.
(6) If an electricity
distribution utility or cooperative providing net energy
metering to a residential or small commercial
customer-generator ceases providing that
electric service to that customer during any
12-month period, and the customer-generator enters into a new net
energy metering contract or tariff with a new electric
service provider or electricity distribution utility
or cooperative , the 12-month period, with respect to that new
electric service provider or electricity distribution utility
or cooperative , shall commence on the date on which the new
electricity distribution utility or
cooperative first supplies electric service to the
(i) Notwithstanding any other provisions of this section, the
following provisions shall apply to an eligible customer-generator
with a capacity of more than 10 kilowatts, but not exceeding one
megawatt, that receives electric
service from a local publicly owned electric utility that has elected to utilize a
co-energy metering program unless the local publicly owned electric utility
chooses to provide service for eligible customer-generators with a
capacity of more than 10 kilowatts in accordance with subdivisions
(g) and (h):
(1) The eligible customer-generator shall be required to utilize a
meter, or multiple meters, capable of separately measuring
electricity flow in both directions. All meters shall provide
"time-of-use" measurements of electricity flow, and the customer
shall take service on a time-of-use rate schedule. If the existing
meter of the eligible customer-generator is not a time-of-use meter
or is not capable of measuring total flow of energy in both
directions, the eligible customer-generator shall be responsible for
all expenses involved in purchasing and installing a meter that is
both time-of-use and able to measure total electricity flow in both
directions. This subdivision shall not restrict the ability of an
eligible customer-generator to utilize any economic incentives
provided by a government agency or the electric service
provider an electricity distribution utility or
cooperative to reduce its costs for purchasing and installing a
(2) The consumption of electricity from the local publicly owned electric
utility shall result in a cost to the eligible
customer-generator to be priced in accordance with the standard rate
charged to the eligible customer-generator in accordance with the
rate structure to which the customer would be assigned if the
customer did not use an eligible solar or wind electrical generating
facility. The generation of electricity provided to the
local publicly owned
electric utility shall result in a credit to the eligible
customer-generator and shall be priced in accordance with the generation component,
established under the applicable structure to which the customer
would be assigned if the customer did not use an eligible solar or
wind electrical generating facility.
(3) All costs and credits shall be shown on the eligible
customer-generator's bill for each billing period. In any months in
which the eligible customer-generator has been a net consumer of
electricity calculated on the basis of value determined pursuant to
paragraph (2), the customer-generator shall owe to the
electric service provider local publicly owned
electric utility the balance of electricity costs and credits
during that billing period. In any billing period in which the
eligible customer-generator has been a net producer of electricity
calculated on the basis of value determined pursuant to paragraph
(2), the local
publicly owned electric utility shall owe to the eligible
customer-generator the balance of electricity costs and credits
during that billing period. Any net credit to the eligible
customer-generator of electricity costs may be carried forward to
subsequent billing periods, provided that a local publicly owned electric
utility may choose to carry the credit over as a kilowatthour
credit consistent with the provisions of any applicable contract
or tariff, including any differences attributable to the time
of generation of the electricity. At the end of each 12-month period,
the local publicly
owned electric utility may reduce any net credit due to the
eligible customer-generator to zero.
(j) A solar or wind turbine electrical generating system, or a
hybrid system of both, used by an eligible customer-generator shall
meet all applicable safety and performance standards established by
the National Electrical Code, the Institute of Electrical and
Electronics Engineers, and accredited testing laboratories, including Underwriters Laboratories
and, where applicable, rules of the commission regarding safety and
reliability. A customer-generator whose solar or wind turbine
electrical generating system, or a hybrid system of both, meets those
standards and rules shall not be required to install additional
controls, perform or pay for additional tests, or purchase additional
(k) If the commission determines that there are cost or revenue
obligations for an electric corporation, as defined in Section 218,
that may not be recovered from customer-generators acting pursuant to
this section, those obligations shall remain within the customer
class from which any shortfall occurred and may not be shifted to any
other customer class.
Net energy metering and co-energy metering
customers shall not be exempt from the public
goods charges imposed pursuant to Article 7
(commencing with Section 381), Article 8 (commencing with Section
385), or Article 15 (commencing with Section 399) of Chapter 2.3 of
Part 1 . In its report to the Legislature, the commission shall
examine different methods to ensure that the public
charges remain nonbypassable .
-- Raymond Lutz
- 11 Jan 2007