Staff/CALPAR--1

On page 6, lines 4-5 of Exhibit No. CAL-10, Mr. Shockey asserts that you simply can't generate more output with less fuel, without deviating from thermodynamic laws.

a)  Please explain why it is not possible that a unit could consume more fuel at lower output due to excessive inefficiency at lower operating points.

b)  Please list the thermodynamic laws to which Mr. Shockey is referring and explain how they dictate the result he asserts.

Staff/CALPAR--2

On page 8, lines 8-10 of Exhibit No. CAL-10, Mr. Shockey states that the RMR data produces a curve that an incremental heat curve should look like i.e., with a gradually increasing slope.

a)  Please explain why actually measured heat/output data should necessarily produce an upward sloping curve.

b)  Is it Mr. Shockey's contention that if actual measurements of heat/output data do not produce a gradually increasing slope for the heat curve that the data must be flawed?  Could a failure of the data to conform to Mr. Shockey's expectations be due to the idiosyncracies of the machine?

Staff/CALPAR-3

On page 9, lines 19-20 of Exhibit No. CAL-10, Mr. Shockey claims that SCE's divested peakers typically operate only at or near full load.

a)  Is this because these units can only operate at one output level or because they are very inefficient at any other operating level?  Please explain.

b)  If the units can be operated at only one level, please explain why.

c)  Does Mr. Shockey agree that if a unit can operate at only one level, minimum fuel costs should be included in the incremental heat rate for that unit?  Please explain.

Staff/CALPAR-4

On page 6, lines 13-16 of Exhibit No. CAL-10, Mr. Shockey refers to input/output data submitted to EPA as part of the CEMS program.

a)  Please describe the nature of the input/output data SCE submitted to the EPA when SCE owned the gas-fired units.  

b)  If SCE submitted heat rate data to the EPA that differs from what it put in its RMR contracts, please explain why.

Staff/CALPAR-5

With respect to the heat rates and units referenced in Attachments 9 through 12 of Exhibit No. CAL-10.

a)  Do the heat rates Mr. Shockey is recommending include minimum load fuel costs?

b)  If the answer to (a) is yes, please explain why Mr. Shockey believes it is reasonable to include minimum load fuel costs in the heat rates to be used for these units when calculating MMCP.  

c)   If the answer to (a) is yes, does Mr. Shockey believe it is only reasonable to use minimum load costs for these units, for some other units or for all units?  Please explain.

d)   Does Mr. Shockey believe that his recommended heat rates comply with the ISO's instructions for heat rate data submission as shown on page 1 of Exhibit No. ISO-6?  For example, has Mr. Shockey provided heat rate data for at least two points or excluded start-up and minimum load costs?  Please explain.

e)  Given the problems with the data provided by the generator owner/operators, why not just use the manufacturers' design heat rate curves for these units?

f)  Please provide a copy of the manufacturers' design curves referred to in the Attachments and the  manufacturers' design curves for all other SCE units currently owned by SCE or sold by SCE..

h)  In developing heat rate data for these units, please explain why it is not necessary to measure the data under controlled conditions 

i)   In developing heat rate data for these units, please explain how Mr. Shockey believes the heat rate data should have been developed by the owner/operator in order to compile reliable heat rate numbers.