20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM

BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

APPLICATION FOR PRELIMINARY PERMIT

SAN VICENTE PUMPED STORAGE PROJECT

SUBMITTED BY:

San Diego County Water Authority

4677 Overland Avenue , California 92123

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TABLE OF CONTENTS

Page

INITIAL STATEMENT 1

EXHIBIT 1 – DESCRIPTION OF PROPOSED PROJECT 10

1.0 Introduction, Background, and Project Configuration 10 2.0 11 3.0 Transmission Line and Interconnection 13 4.0 Project Capacity 13 5.0 Public Lands 14 6.0 Other Information 15

EXHIBIT 2 – STUDY PLAN 16 1.0 General Requirement 16 1.1 Project Studies 16 1.2 New Roads 22 2.0 New Construction Work Plan 22 2.1 Field Studies Impacts 22 2.2 Proposed Schedule 22 2.3 New Dam Construction 24 3.0 Waiver 24 4.0 Statement of Costs and Financing 24 4.1 Estimated Costs 24 4.2 Financing 24 4.3 Proposed Market for Power Generation 24

EXHIBIT 3 – PROJECT MAPS/DRAWINGS 26

Figure 1 Location Map Figure 2 Regional Map of Water Authority Service Area Figure 3 Project Study Area Figure 4 FERC Project Boundary Area Figure 4a Upper Alternatives Configuration Figure 5 & Reservoir Raise Plan Figure 6 Typical Site Profile Figure 7 SDG&E Sunrise Powerlink Figure 8 Land Ownership Map Figure 9 New Saddle – Upper Reservoir Figure 10 Transmission Line and Interconnection Alignment

ATTACHMENT 1 – Legal Authority of Applicant as a Municipality (County Water Authority Act)

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INITIAL STATEMENT

BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION APPLICATION FOR PRELIMINARY PERMIT

1.0 The San Diego County Water Authority (Water Authority) applies to the Federal Energy Regulatory Commission (FERC) for a preliminary permit for the proposed San Vicente Pumped-Storage Project (Project), as described in the attached exhibits. This application is made in order that the applicant may secure and maintain priority of application for a license for the Project under Part I of the Federal Power Act while obtaining the data and performing the acts required to continue with project development work including completing a preliminary environmental site screening, resource agency and native American consultations, desktop geotechnical study, inlet/outlet location optimization study, reservoir water quality modeling, refinement of project configuration via additional engineering studies, and continued power market and financial analysis to support an application for a license.

2.0 Location of the proposed project is:

State or Territory: State of California County: County of San Diego Township or Nearby Town: Alternative A: Poway, Alternatives B and D: Lakeside, Alternative C: Ramona Stream or Other Body of Water:

3.0 The exact name, business address and telephone number of the applicant is:

San Diego County Water Authority 4677 Overland Avenue San Diego, CA 92123 (858) 522-6600

The exact name and business address of each person authorized to act as agent for the applicant and this application are:

Mike Swiger Maureen Stapleton Partner General Manager Van Ness Feldman, LLP San Diego County Water Authority 1050 Thomas Jefferson Street NW 4677 Overland Avenue Seventh Floor. San Diego, CA 92123 Washington, DC 20007 (858) 522-6781 (202) 298-1891

4.0 The San Diego County Water Authority is a municipal entity under California's County Water Authority Act and is claiming preference under Section 7(a) of the

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Federal Power Act. Copies of applicable State laws and other legal authority evidencing that the applicant is a municipality are provided in Attachment 1.

5.0 The proposed term of the requested permit is for a period of 36 months.

6.0 Name of Existing Dam: San Vicente Dam Owner: City of San Diego Address: 202 C Street San Diego, CA 92101-3861

IN ACCORDANCE WITH THE CODE OF FEDERAL REGULATIONS (CFR), TITLE 18, PART 4, SECTION 4.32(a), THE FOLLOWING INFORMATION IS PROVIDED:

1.0 Identification of every person, citizen, association of citizens, domestic corporation, municipality, or state that has or intends to obtain and will maintain any proprietary right necessary to construct, operate, or maintain the Project includes:

San Diego County Water Authority 4677 Overland Avenue San Diego, CA 92123 Maureen Stapleton, General Manager (858) 522-6781

City of San Diego, City Administration Building 202 C Street San Diego, CA 92101-3861 Kevin Faulconer, Mayor Elizabeth Maland, City Clerk (619) 236-6330

City of Poway 13325 Civic Center Drive, P.O. Box 789 Poway, CA 92074-0789 Dan Singer, City Manager (858) 668-4500

San Diego County Board of Supervisors County Administration Center 1600 Pacific Highway San Diego, CA 92101 Dianne Jacob, Supervisor (619) 531-5522

Barona Band of Mission Indians Tribal Council Barona Tribal Office 1095 Barona Road Lakeside, CA 92040

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Clifford LaChappa, Tribal Chairman (619) 443-6612

Although all of the above have certain rights relating to the reservoirs associated with the Project, only the San Diego County Water Authority will have and maintain all the proprietary rights necessary to construct, operate, and maintain the Project itself.

2.0 Names and mailing addresses:

2.1 Counties in which any part of the Project, or any Federal facilities that would be used by the Project, would be located:

County of San Diego, Department of Planning and Development Services Mark Wardlaw, Director 5201 Ruffin Road, Suite B San Diego, CA 92123 (858) 694-3810

2.2 Cities, town or similar local political subdivision within 15 miles of the Project and having a population of more than 5,000, or in which part of the Project, or any Federal facilities that would be used by the Project, would be located: Cities:

City of El Cajon 200 East Main Street El Cajon, CA 92020 Douglas Williford, City Manager (619) 441-1716

City of Escondido 201 North Broadway Escondido, CA 92025 Clay Philips, City Manager (760) 839-4631

City of 8130 Allison Avenue La Mesa, CA 91941 David Witt, City Manager (619) 463-6611

City of Lemon Grove 3232 Main Street Lemon Grove, CA 91945 Graham Mitchell, City Manager (619) 825-3800

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City of Poway 13325 Civic Center Drive, P.O. Box 789 Poway, CA 92074-0789 Dan Singer, City Manager (858) 668-4500

City of San Diego City Administration Building 202 C Street San Diego, CA 92101-3861 Kevin Faulconer, Mayor Elizabeth Maland, City Clerk (619) 236-6330

City of Santee 10601 Magnolia Avenue Building #1 Santee, CA 92071 Pedro Orso-Delgado, Acting City Manager (619) 258-4100

Unincorporated Communities:

Alpine – Alpine Community Planning Group P.O. Box 819 Alpine, CA 91903 (619) 445-2110

Eucalyptus Hills – Lakeside Community Planning Group P.O. Box 2040 Lakeside, CA 92040 (619) 561-5949

Flinn Springs – Lakeside Community Planning Group P.O. Box 2040 Lakeside, CA 92040 (619) 561-5949

Lakeside – Lakeside Community Planning Group P.O. Box 2040 Lakeside, CA 92040 (619) 561-5949

Ramona – Ramona Planning Group 15873 Highway 67 Ramona, CA 92065 (760) 803-2001

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2.3 Irrigation districts, drainage districts or similar purpose political subdivisions in which part of the Project, or any Federal facilities that would be used by the Project, would be located or that own, operate, maintain or use any Project facilities:

City of San Diego City Administration Building 202 C Street San Diego, CA 92101-3861 Kevin Fauconer, Mayor Elizabeth Maland, City Clerk (619) 236-6330

Lakeside Water District 10375 Vine Street Lakeside, CA 92040 Brett Sanders, General Manager (619) 443-3805

Padre Dam Municipal Water District 9300 Fanita Parkway Santee, CA 92071 Allen Carlisle, General Manager (619) 448-3111

Ramona Municipal Water District 105 Earlham Street Ramona, CA 92065 David Barnum, General Manager (760) 789-1330

San Diego County Water Authority 4677 Overland Avenue San Diego, CA 92123 Maureen Stapleton, General Manager (858) 522-6781

2.4 State and Federal Agencies that may be interested in, or affected by, the application are:

California Department of Fish & Wildlife South Coast Regional Office 3883 Ruffin Road Ed Pert, Regional Manager San Diego, CA 92123 (858) 467-4201

U.S. Army Corps of Engineers, L.A. District Regulatory Division – Carlsbad Field Office 6010 Hidden Valley Road, Suite 105 2014 Page 6 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM

Carlsbad, CA 92011 (760) 602-4829

U.S. Environmental Protection Agency Southern California Field Office 600 Wilshire Blvd., Suite 1460 Los Angeles, CA 90017 (213) 244-1800

U.S. Fish & Wildlife Service Carlsbad Field Office 2177 Salk Avenue, Suite 250 Carlsbad, CA 92008 (760) 431-9440

U.S. Bureau of Land Management Palm Springs – South Coast Field Office 1201 Bird Center Drive Palm Springs, CA 92262 (760) 833-7100

2.5 Indian Tribes that may be affected by the Project are:

Barona Band of Mission Indians 1095 Barona Road Lakeside, CA 92040 Clifford LaChappa, Tribal Chairman (619) 443-6612

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Exhibits and Attachments

EXHIBIT 1 DESCRIPTION OF PROPOSED PROJECT

EXHIBIT 2 STUDY PLAN

EXHIBIT 3 PROJECT MAPS/DRAWINGS

ATTACHMENT 1 – Legal Authority of Applicant as a Municipality (County Water Authority Act)

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EXHIBIT 1 DESCRIPTION OF PROPOSED PROJECT

1.0 INTRODUCTION, BACKGROUND, AND PROJECT CONFIGURATION

Introduction The San Diego County Water Authority (Water Authority) is pursuing a hydroelectric license from the Federal Energy Regulatory Commission (FERC) for the proposed San Vicente Pumped Storage Project (Project). This will be the Water Authority’s second closed-loop pumped storage project since the County Water Authority Act was modified.

In September 2000, the Governor of California signed Senate Bill 552 (SB552), which substantially granted the Water Authority new entitlement to enter the electric and natural gas wholesale markets. SB552 modified the County Water Authority Act (Section 45-5.1) to allow hydroelectric power generated by the Water Authority’s water delivery system to be sold to any retail electric provider. The bill also authorized the Water Authority to purchase federal power, construct, own, and operate electric power generation facilities to service its or its member agencies’ needs, and to purchase and transport natural gas. A copy of County Water Authority Act (as of January 1, 2008) is provided in Attachment 1.

Background The Water Authority’s first pumped storage project was Olivenhain/Hodges. In October 2000, the Water Authority filed a preliminary permit for the Olivenhain/ Pumped Storage Project under FERC Project Number 11860-0000. This Project is located in the vicinity of the northern end of the City of San Diego, within the County of San Diego. The permit was approved by FERC in February 2001, and the Water Authority proceeded to develop plans for the project through completion of final design. The 40-MW Olivenhain/Hodges Pumped Storage Project construction is complete and it is commercially operational. The facility was issued a license exemption by FERC on December 2003 and has been operation since 2012.

Project Configuration The Water Authority’s second pumped storage project would be located at San Vicente Reservoir. The Project includes both integration of nearby existing infrastructure and construction of new facilities. The existing infrastructure includes the newly expanded San Vicente Dam and Reservoir, with a storage capacity of 242,000 acre-feet - which would serve as the pumped storage operation’s lower reservoir - and the nearby SDG&E Sunrise Powerlink Transmission Line. New infrastructure would include (dimensions and quantities are approximate):

 Three to four saddle dams (upper reservoir) o 30 feet x 1,000 feet x 40 feet (H x L x W) o 50 feet x 470 feet x 30 feet o 50 feet x 470 feet x 30 feet o 200 feet x 700 feet x 50 feet  One Upper reservoir less than 9,000 acre-feet in storage capacity  Three-mile pipeline/tunnel, 22 feet in diameter

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 One subsurface pump house with two vertical variable speed reversible pump turbine/motor/generator units (rated 250 MW each). The dimensions of the pump house cavern are:

o 237 feet to 266 feet long o 85 feet to 92 feet wide o 131 feet to 178 feet tall

 Inlet/outlet structure  Electrical switchyard.

For a 500 megawatt (MW) conceptual development, the upper reservoir near will be connected to an underground powerhouse via an up to 30-foot diameter, 800-foot deep, vertical shaft and 22 feet-foot diameter, 12,300-foot long power tunnel sloping down at a seven (7) percent grade. The power tunnel will bifurcate into two, 300-foot long, 22-foot diameter steel-lined penstocks, which will enter the powerhouse at each of the two pump-turbine units. From the powerhouse, the draft tubes from each unit (with an approximate length of 300 feet) will manifold into one 26-foot diameter, 2,200 foot long tailrace tunnel, which will extend underground for approximately 3,300 feet at approximately 7.8 percent grade to the San Vicente Reservoir. Conceptual drawing of a typical site profile is provided in Figure 6.

2.0 RESERVOIRS

Two reservoirs are required for this closed-loop operation. The existing expanded San Vicente Reservoir would serve as the lower reservoir and is located in Lakeside, CA. One new reservoir will serve as the upper reservoir for the Project. Four Alternative Sites for the upper reservoir are being evaluated as shown in Figure 4a.

Existing Lower Reservoir Water stored in the San Vicente Reservoir is a combination of natural runoff and water imported from the Water Authority’s aqueduct system. In a typical year, imported water accounts for up to 80 percent of the volume of water in San Vicente Reservoir. Discharges from the dam currently serve as drinking water to the City’s customers. San Vicente Reservoir is connected to the Water Authority’s First and Second Aqueducts. The First Aqueduct delivers water to San Vicente Reservoir. Pipelines south of San Vicente Dam deliver water to the City of San Diego’s El Monte Pipeline, which delivers water to the City of San Diego’s Alvarado Water Treatment Plant, and can also supply water to nearby El Capitan Reservoir via the City of San Diego’s El Capitan Pipeline under certain hydraulic conditions. The San Vicente Pipeline delivers water from San Vicente Reservoir, west, to the Second Aqueduct. San Vicente Reservoir can also be filled via the San Vicente Pipeline.

The expanded San Vicente Reservoir will serve as the lower reservoir for the proposed facility. Its storage capacity is 242,000 acre-feet and 1,600 acre surface area. San Vicente Dam and Reservoir, built in 1943, is owned and operated by the City of San Diego (City), one of the Water Authority’s member agencies. In 1998, the Water Authority and City entered into an Agreement for the Joint-Use of San Vicente Reservoir

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whereas the City retained its original ownership of the dam, reservoir, and original 90,000 acre-feet in storage capacity and allowed the Water Authority to raise the dam and expand the reservoir’s storage capacity. In July 2014, the Water Authority completed the raising of San Vicente Dam, and as part of the terms of the agreement the Water Authority owns the additional 152,000 acre-feet of expanded reservoir storage capacity. This additional storage is part of the Water Authority’s Emergency Storage and Carryover Storage Project (ESP/CSP). The ESP/CSP is a system of reservoirs, interconnected pipelines and pumping stations throughout San Diego County designed to make water available to the San Diego region in the event of an interruption in imported water deliveries. The Water Authority facilities associated with the ESP will allow delivery of San Vicente Reservoir water to Water Authority member agencies during a water supply emergency. These existing facilities consist of an Interconnect Pipeline, San Vicente Pump Station, Surge Control Facility, San Vicente Tunnel Pipeline, and Moreno-Lakeside Pipeline.

Now that the San Vicente Dam Raise is complete, the maximum normal pool elevation of the expanded reservoir is 766 feet above MSL and the reservoir will serve the City’s customers in its daily operations and the Water Authority’s regional customers in emergencies and times of drought. In normal daily operations, the City will maintain the reservoir level at a minimum normal operating level of 650 feet above MSL. In the rare event of regional emergencies, the reservoir level may fluctuate by 120 vertical feet or between elevations 650 feet and 778 feet Above MSL. The fluctuating reservoir level is being considered in the on-going studies for locating the inlet/outlet structure for a pumped storage project.

A plan view of the San Vicente Reservoir is provided in Figure 5. Key facilities of the Project consist of the raised dam, outlet works, downstream control facility, outlet pipeline, saddle dams, access roads, and First Aqueduct flow control structures. The feasibility of the Project is primarily attributed to the relatively low incremental costs of adding facilities to those that the applicant has already constructed. The applicant believes the attractiveness of the Project hinges on the ability to use the newly completed facilities.

New Upper Reservoir The lower reservoir’s environmental analysis, permitting, design and construction are complete. Therefore, the applicant now seeks a preliminary permit for the Project so that it may continue with the economic and financial studies, environmental and engineering studies focused on the upper reservoir and inlet/outlet structure; and secure and maintain priority of application for a license under Part I of the Federal Power Act for the Project.

Four sites as shown in Figure 4a are being evaluated for the new upper reservoir for the Project.

Alternative Site A is located near Iron Mountain, approximately three miles northwest of the San Vicente Reservoir. This site’s full pond elevation is approximately 2,110 feet above mean sea level (MSL). The water surface area at full pond is approximately 93 acres.

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Alternative Site B is located near Foster Canyon, approximately one-half mile northwest of the San Vicente Reservoir. This site’s upper reservoir’s full pond elevation is approximately 1,490 feet above MSL. The water surface area at full pond is approximately 100 acres.

Alternative Site C is located approximately 0.8 miles northeast of the San Vicente Reservoir. This site’s full pond elevation is approximately 1,600 feet above MSL. The water surface area at full pond is approximately 60 acres.

Alternative Site D is located approximately 1.8 miles southeast of the San Vicente Reservoir. This site’s full pond elevation is approximately 1,800 feet above MSL. The water surface area at full pond is approximately 80 acres.

3.0 TRANSMISSION LINE AND INTERCONNECTION

The Project will be interconnected to the existing San Diego Gas & Electric’s (SDG&E) Sunrise Powerlink 500KV transmission line located approximately one-half mile from the Project as shown in Figure 10. A 230 KV transmission line would extend from each of the upper reservoir sites to the northern end of San Vicente Reservoir and would range from one-half mile (Site A) to three miles (Site B) in length depending on which of the four upper reservoir alternatives selected. The transmission lines connecting the reservoirs would be housed subsurface, in a cable tunnel. A 230 KV transmission line would extend from the northern end of San Vicente Reservoir and extend approximately five miles to at the 230 KV Sycamore Substation and interconnect with the 500 KV Sunrise Powerlink.

4.0 PROJECT CAPACITY

The applicant proposes to further investigate potential power development in the range of 240 to 500 MW. The amount of annual electric generation from the Project will depend on many factors, including: project size, location of the upper reservoir, expectation for the on-peak to off-peak energy price differential and ancillary services market price, and operating constraints.

The Economic and Financial Study demonstrated that all four sites meet the 500 MW, 2,800 to 4,000 MW-Hours daily generation criteria with 8 hours of storage. The daily generation would be up to 4,000 MW-hours with 8 hours of storage. The Project also has the capability to generate continuously at different power levels from 100-500 MW. If the Project began generating at full load (500 MW) without any weekday pump-back operations, the upper reservoir would contain sufficient storage to facilitate a cyclic operation of alternating pumping for four hours and generating for four hours throughout the day. The annual generation is expected to be at least 1,022,000 MW-Hours.

The Project will be operated as an energy storage facility, meeting peak electric loads with pump-back operations normally occurring at night, on weekends, or more likely as excess renewables become available during the day.

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The Project would also be used to generate energy to meet emergency conditions when other generation plants in the system fail to operate. This spinning reserve, black start, and other generating capability of the Project will provide increased security to the power grid in the San Diego area. Pumped storage is considered a preferred resource for meeting reserve needs because of its fast-start capability, reliability, and low environmental impacts.

5.0 PUBLIC LANDS

The Project study boundary, as shown on Figure 3 and 4, encompasses both public and private lands. The primary feature within the study area is the San Vicente Reservoir. The reservoir currently provides terminal storage for the Water Authority’s First and Second Aqueducts and is used primarily for emergency water storage and local water supply impoundment, with secondary uses for recreation and flood control. Expansion of the San Vicente Reservoir provided additional capacity to meet emergency storage needs for the region. The Pumped Storage Project itself will be owned and operated by the Water Authority in partnership with the City of San Diego. The four alternative upper reservoir sites are all located within the County of San Diego. Alternative A is located within the City of Poway, Alternative B is located in the Lakeside community; Alternative C is located in the Ramona community, and Alternative D is located in Lakeside community. The four alternative sites are also within several water utility districts: the San Diego County Water Authority, the Lakeside Water District, and the Ramona Municipal Water District. Land use designations for the four reservoir sites are generally open space as shown in Figure 8.

The area within a half-mile radius of Alternative A is vacant, with the exception of the eastern edge of the study area. Alternative A is a part of Iron Mountain and its surrounding area that was deeded from the Bureau of Land Management (BLM) to the City of Poway in 1985. The BLM agreement requires the City of Poway to improve the land for recreational purposes. At this time, there is one improved loop trail from State Highway 67 to Iron Mountain. The site is located on a parcel that is designated Open Space-Resource Management (OS-RM) in the Poway General Plan. In addition, Alternative A is a part of the Old Coach Road / Mt. Woodson / Iron Mountain Resource Conservation Area (RCA). This RCA is also known as Iron Mountain Preserve. RCAs have been established by the County of San Diego to conserve and enhance native vegetation and wildlife.

There is no development on the Alternative B site due to minimal access to this area. Development close to the site is extremely limited. Alternative B is located in the County of San Diego with future land uses guided by the Lakeside Community Plan. This plan designates the site as Multiple Rural Use, which allows one dwelling unit (DU) on parcels of 4, 8, or 20 acres depending on slope characteristics on the site. Alternative B is located within the County’s San Vicente Reservoir RCA.

Alternative C and D sites are undeveloped and immediately surrounded by undeveloped land. United State of America Barona Indian Reservation is approximately 0.2 mile east of the site. Alternative C is located in the County of San Diego with future land uses guided by the Ramona Community Plan. Alternative D is located in the County of San Diego with future land uses guided by the Lakeside

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Community Plan. United State of America Public Domain approximately 48 acres just southerly of Alternative D and adjacent to the study area. This plan designates the site as Multiple Rural Use, which allows one dwelling unit (DU) on parcels of 4, 8, or 20 acres depending on slope characteristics on the site.

No portion of the land within the study boundary is United States Bureau of Land Management (BLM) land. No portion of the land within or in the vicinity of the study boundary is included in or has been designated for study for inclusion in the National Wild and Scenic Rivers System.

No portion of the land within the study boundary is designated as wilderness area, recommended for designation as wilderness area or is designated as wilderness study area under the provisions of the Wilderness Act.

6.0 OTHER INFORMATION

The Project is located in the SDG&E service territory and is adjacent to the service areas of Southern California Edison, Imperial Irrigation District (IID), and Comision Federal de Electricidad (CFE). The SDG&E service territory and power demand continues to grow. This implies that additional plans need to be incorporated in the form of new resources, purchases, and Demand Side Management (DSM), or a combination of these. Currently, the region is heavily dependent upon purchased power from other regions to meet its capacity needs. The import strategy has required the system to increase amounts of spinning reserve with attendant emissions and system stability risks. In addition to the needs in the San Diego region alone, the Project could be interconnected through SDG&E with a number of adjacent electric systems, including Southern California Edison, IID, CFE, and other Southern California systems. This project provides the ability to integrate renewable energy sources by storing the excess renewable energy production and balancing the grid during peak demands.

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EXHIBIT 2 STUDY PLAN

1.0 GENERAL REQUIREMENT

1.1 Project Studies

The proposed study plan outlines the studies conducted or to be conducted, including field studies, with respect to the Project. The studies described are intended to meet the requirements of the application for a license for the Project, and will be conducted in accordance with appropriate local, State, and Federal agency requirements.

It is the intent of the applicant to review any existing and available studies that may provide information related to the Project. As mentioned previously, San Vicente Reservoir is included in the Emergency Storage Project (ESP) of the Water Authority, and for its Carryover Storage Project (CSP). Many of the engineering, environmental, and economic studies that have been performed as part of the ESP and CSP will also be applicable to the study plan for this application.

Existing Agreements and Completed Lower Reservoir Studies A number of significant studies have been performed, and important agreements put into place, in support of the Project. Agreements include:

 A 1998 Joint-Use Agreement between the City of San Diego and the San Diego County Water Authority forms the basis for land acquisition, design, construction, operation, and maintenance for the joint use of San Vicente Dam and Reservoir as a component of the region’s ESP. The Joint-Use Agreement allows the Water Authority to raise San Vicente Dam and to obtain permanent storage rights to the entire storage created through this dam raise, including the right to raise the dam more than required for the ESP.

 In 2003, Principles of Understanding were developed with respect to the San Vicente Dam Raise Project to: a) establish basic principles for development of reservoir regulating plans, b) clarify and refine the rights and obligations of the Parties under the 1998 Joint-Use Agreement, and c) establish protocols for cooperation between the City of San Diego and the Water Authority during implementation of the ESP.

 In 2008, Principles of Understanding were developed with respect to the San Vicente Dam Raise Project to: a) establish basic principles for development of reservoir regulating plans, b) clarify and refine the rights and obligations of the Parties under the 1998 Joint-Use Agreement, and c) establish protocols for cooperation between the City of San Diego and the Water Authority during implementation of the CSP.

 In 2014, Memorandum of Understanding Between San Diego County Water Authority and City of San Diego for The San Vicente Pumped Storage Project Economic and Financial Study.

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 In 2014,Feasibility Study Agreement Between The City of San Diego and The San Diego County Water Authority for the San Vicente Pumped Storage Project

All the environmental studies, geotechnical studies, engineering studies, permitting, water quality studies, cultural and biological studies, construction documents, and other documents have been completed for the expanded San Vicente Reservoir and are available as resources for this Project.

Completed Upper Reservoir Studies In October 2013, an economic and financial study, power market analysis, and financial analysis began and the study was completed in February 2014. It assessed future power market conditions, established project financing requirements, evaluated potential Project revenues, and allowed a comparison of alternative power generation technologies. The study:

 Evaluated design, costing, and scheduling of pumped storage facility capital and operations and maintenance costs;  Identified potential economies of scale and alternative project configurations;  Identified regulatory approvals and associated requirements and workflows;  Modeled all four upper reservoir alternatives based on the design configurations and cost data to determine potential capacity factors and associated gross revenues;  Identified alternative-specific power exchange information regarding the potential for pumped storage facility generation to offset Water Authority power consumption;  Identified back-up or standby power requirements, costs, and transmission service costs critical to ensuring the reliability of pumped storage project generation to serve Water Authority loads;  Determined the types of ancillary services the Project could provide;  Defined power purchase agreement and project energy delivery considerations; and characterized alternative pumped storage project funding scenarios;  Evaluated Southern California's current power market and establishment of current and future peaking capacity needs in the Project area;  Estimated costs for producing on-peak energy, as well as potential revenues based on prevailing and projected rates for on-peak and off-peak energy and power; and  Evaluated alternative sources of power generation for comparison purposes.

The studies indicated that each of the four upper reservoir project alternatives at 500 MW is technically, economically, and financially viable. The Water Authority is therefore proceeding with project development and selection of a preferred upper reservoir location.

Studies and Work Under Way The City currently treats and disposes into the Pacific Ocean at the Point Loma Wastewater Treatment Facility approximately 180 million gallons of wastewater from the City and 15 other cities and water districts from a 450 square mile area with a population of over 2.2 million people. The City has been working with the United States

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Environmental Protection Agency (EPA) for many years to ensure that its wastewater treatment meets federal standards. Efforts to date include a water recycling/reclamation program which includes two water reclamation plants with a total capacity of 45 million GPD. The City currently has a waiver from EPA from the requirement to provide secondary treatment. However, it is on notice that future waiver requests will not be favorably reviewed and therefore must recycle additional water for beneficial uses. In this context, in late 2007 the City initiated the Indirect Potable Reuse (IPR)/Reservoir Augmentation Demonstration Project (Demonstration Project), the purpose of which was to evaluate the feasibility of using advanced treatment technology to produce potable recycled water. Assuming treatment proved to be feasible, the City would consider piping the advanced treated water through a new 23-mile-long pipeline to San Vicente reservoir, where it would be blended in the reservoir with other raw water and later, after further treatment at the City’s surface water treatment plants, would enter into the City’s domestic water supply distribution system (augmentation option). The City began studies and work on pilot projects on IPR and in April 2013, the City Council reviewed and approved the report, and voted in favor of moving forward with implementation of potable reuse based on the alternative of piping the water to the reservoir for augmented treatment (the “IPR Project”) at San Vicente.

Further modeling is now needed to determine how the design and exact location of the pumped storage project inlet/outlet structure and the pump house should be configured in order to ensure that it does not interfere with the success of the IPR Project. This study will enable the Water Authority to identify a specific location and conceptual design for these pumped storage project features, as well as the best location for the upper reservoir. The modeling and inlet/outlet study will be the basis for screening of the upper reservoir alternatives in order to narrow the range of reasonable alternatives for analysis under the California Environmental Quality Act and the National Environmental Policy Act.

In June 2014, the Water Authority’s Board of Directors appropriated an additional $1.2 million for these tasks, which will be completed in late 2014/early 2015.

Therefore, The Water Authority has procured a professional services contractor that is currently working on an inlet/outlet study with scope as follows.  Determine the inlet/outlet locations for each of the four upper reservoir alternatives that meet the functionality of both the pumped storage and reservoir operations;  Refine tunnel and penstock alignments, facility sizing, powerhouse layout and evaluation of headworks, switchyard, power transmission routes, and other components;  Refine the capital and operating cost estimates. These estimates will inform the Financial/Project Delivery Study; and  Include this information in the final report.

This work will also help to inform the reservoir modeling being performed to coordinate the projects. Both the inlet/outlet study and the reservoir modeling are scheduled to be complete in February/March 2015.

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Planned Studies  When the location of the pumped storage inlet/outlet structure in the lower reservoir is finalized, the next phase of studies/work will commence in February/March 2015 and be completed by late 2015 and include: o Screening of the four upper reservoir location alternatives that will: . Develop an initial, written plan for performing a defensible alternatives analysis to meet the requirements of the NEPA, CEQA and section 404(b)(1) of the Clean Water Act; . Develop a screening process (decision model) to be used to objectively compare alternatives; . Perform assessments to develop inputs for the screening process. Assessments shall consist of data acquisition, engineering studies, permitting level designs, and permitting level cost estimates of components that form various alternatives; . Perform decision analysis to rank alternatives based on input data. Perform sensitivity analyses of the results; and . Prepare a Technical Memorandum to document the alternatives analysis, from its development through to conclusions and recommendations. o Consultation with regulatory and wildlife agencies, tribes and members of the public. o Geotechnical desktop studies: . Entails evaluating existing geotechnical studies and determining boring locations o Power Market Study that will: . Build upon the economic and financial study in terms of assessing the power market supply and demand forecast; . Determine how the supply and demand forecast affects the Project's operations and the types of services that the Project would provide; . Assess how renewables policies and legislation and regulation influence the Project's operations; and . Include information in final report. o Financial/Project Delivery Method Study that will: . Coordinate with and use inputs from the inlet/outlet study and power market study consultants to create scenarios for each potential project delivery options and run scenarios in the proforma financial model to determining financial viability (net present value, internal rate of return, payback period, etc.). Prepare executive summary that describes the proforma financial model report; . Recommend and provide justification for project financing options; . Collaborate with inlet/outlet study and power market study consultants on assumptions to be included in the Monte Carlo Analysis Decision-Making software. Model each of the four project delivery options. Prepare an executive summary that describes the Monte Carlo Analysis Decision-Making software report; and . Include information in final report. o Geotechnical desktop studies 2014 Page 19 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM

o Prepare an interconnection request application for the Project and submit to the California Independent System Operator (CAISO) during the April 2015 application window.  A subsequent engineering study will be conducted on the remaining alternatives after the initial screening. The study will be a more detailed engineering study that will advance the preliminary design, CEQA/NEPA document, and FERC licensing. The study will: o Evaluate tunnel and penstock alignments, facility sizing, powerhouse layout and evaluation of headworks, switchyard, power transmission routes, size and location of upper reservoir saddle dams, and other components; o Gather geological, geotechnical, hydraulic and hydrological information. All information gathered would be used in optimizing the Project configuration, modeling project operations, updating the existing San Vicente Reservoir operating plan, estimating construction costs and developing a project implementation schedule; o Update aerial photography and site mapping as required to develop the necessary horizontal and vertical control and establish topographic base maps; o Perform biological and cultural surveys; o Determine boring locations based on planned infrastructure (dam foundation, reservoir location, pipeline/tunnel alignment) and biological and cultural surveys; o Perform geological reconnaissance and mapping, subsurface investigations using geophysical surveys, core drilling and test pits, borrow area investigations, geological hazards analysis, seismotectonic studies, groundwater and seepage studies, and geological construction considerations; o Establish geotechnical design criteria for structures located on the surface and underground, including engineering properties of soils and rock, foundation bearing capacities, static and seismic loadings, liquefaction potential, and underground excavation support; o Determine the viability of constructing an onsite quarry in terms of adequate, sufficient material that would be processed for the roller compacted concrete upper reservoir saddle dams; o Prepare conceptual designs and layouts for inlet/outlet facilities, tunnels, shafts, powerhouse, pumping/generating equipment, access roads, substations, power transmission lines, and recreational facilities; o Prepare Project cost estimates, including estimated quantities and unit prices, estimated costs for major equipment items, estimated costs for specialized construction activities, estimated costs for land acquisition and permitting, and estimated annual costs for Project operation and maintenance; and o Update San Vicente Reservoir operating plan with pumped storage considerations.  Environmental studies related to pumped storage operations and the four alternative upper reservoir sites would be conducted to complement available data and to comply with the requirements of the application for a license for the Project.

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These studies, to be developed in consultation with resource agencies, Indian tribes, and interested members of the public, will be conducted to: evaluate potential impacts on water use, water quality, plants, fish and wildlife; evaluate historical and archaeological resources; assess socio-economic factors; evaluate geologic and soil resources; evaluate recreational and aesthetic resources; and analyze land use. Proposed environmental studies include: o Development of regional maps showing the Project location and setting, land descriptions and proximity to highways, railway lines, reservoirs, lakes, rivers, parks, forests, farming areas, communities, and major commercial centers; o Study of climatic and hydrologic characteristics, stream flows, groundwater conditions, water-use patterns, existing water rights, water quality issues, and recommended mitigation measures for potential impacts; o Assessment of potential impacts to plants, fish, and wildlife and document plant communities, families, and species; inventory of wildlife habitat and populations and identification of Federal and State listed threatened or endangered species in the Project area; identification of fish habitat, estimate of fish populations, and identification of potential impacts to game and non-game fish species; o Identification of historical or cultural resources to develop an inventory of archaeological sites in the Project area; o Socioeconomic studies to identify impacts to local residents and nearby communities; establishment of a demographic database including population, employment, per capita income, housing, schools, community services, traffic patterns, local government jurisdiction, and budgets; evaluation of impacts to land ownership, public access, public services, property values, and tax revenues; o Investigation of geologic and soil conditions and characterization of the physical and engineering properties of the soils and rock; preparation of a geologic history and geologic map identifying major physiographic units, rock types, locations of active faults, shear zones and landslides; preparation of a preliminary erosion and sediment control plan for disturbed soils in excavations and spoil disposal areas; o Documentation of existing recreational uses and identification of potential future recreation opportunities; documentation of potential impacts and benefits to recreational uses from the proposed Project; o Studies to identify visual impacts of the Project on scenic quality and sensitive viewpoints. Recommendations for mitigation measures to minimize visual impacts will be made accordingly; and o Land use studies to identify existing designated land uses including residences, commercial and industrial facilities, recreation areas, utility and transportation facilities, agricultural, range, preservation areas, and timberlands; determination of land ownership and review of land management plans; preparation of a map showing land jurisdiction, existing and future land uses, and any special management areas; identification of potential impacts to existing land uses and recommended mitigation measures.

It is anticipated that the engineering and environmental studies will commence in mid- to late 2015.

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1.2 New Roads

Existing access roads would be utilized to the maximum extent possible. Field studies will be performed using existing access in a manner such that ground disturbance is minimized. Access to the four alternative upper reservoir sites and the location for the pump house will be considered as part of the engineering and environmental studies.

The applicant plans to continue to work diligently to prepare an application for a license for the Project, as described below.

2.0 NEW DAM CONSTRUCTION WORK PLAN

The existing San Vicente Dam constitutes the lower reservoir. For a new upper reservoir, three to four new gravity saddle dams would need to be constructed to fill in the low points in the topography. The new dams (Figure 9) are estimated to be:

o 30 feet x 1,000 feet x 40 feet (H x L x W) o 50 feet x 470 feet x 30 feet o 50 feet x 470 feet x 30 feet o 200 feet x 700 feet x 50 feet

To minimize impacts to the area and to reduce construction duration, roller compacted concrete (RCC) is planned for constructing the dams, the construction method used to raise San Vicente Dam. Because the general geology of the area was studied during the San Vicente Dam Raise project, it is anticipated that an onsite quarry would be constructed to process the materials used in the RCC. An onsite quarry would minimize truck traffic to and from the site that would otherwise occur as a result of purchasing sand and aggregate from an outside source and trucking off waste. The approach was effective for the San Vicente Dam Raise project.

2.1 Field Studies Impacts

Biological and cultural resource mapping of the screened upper reservoir alternatives will be conducted to identify biological and cultural resources. Studies to site the upper dam, reservoir, and pipeline/tunnel connecting the lower and upper reservoirs would be conducted so as to avoid impacts to wetlands and floodplains and minimize impacts to uplands. Any potential impacts to upland could be mitigated either by restoring the area with native plants, or through the use of credits in the Water Authority’s existing mitigation banks. Existing roads would be used to access the site.

2.2 Proposed Schedule

The proposed Project schedule is as follows in Table 1 with the field activities for new dam and reservoir construction noted with an asterisk (*). The orange activities are complete, blue activities in progress, and green activities planned. This is a planning- level schedule. Thus, dates are approximate and it does not include all activities necessary to implement the Project.

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2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

ID Activity Start Finish H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2

1 San Vicente Dam Raise Construction Apr‐09 Jul‐14

2 Fill Reservoir to Expanded Capacity Aug‐14 Dec‐17

3 Board Award Contract for Economic & Financial Study Oct‐13 Oct‐13 X

4 Conduct Economic and Financial Study Oct‐13 Feb‐14

5 Board Award Inlet/Outlet Study Aug‐14 X

6 Complete Inlet/Outlet Study Sep‐14 Dec‐14

7 Complete Reservoir Modeling Sep‐14 Feb‐15

8 Complete CAISO Interconnect Request Application Feb‐15 Apr‐15

9 Submit CAISO Interconnect Request Application Apr‐15 X

10 Complete Geotechnical Desktop Study Mar‐15 Jun‐15

11 Complete Preliminary Site Screening Mar‐15 Dec‐15

12 Complete Resource Agency/Tribe Consultation Mar‐15 Dec‐15

13 Complete Power Market Study Mar‐15 Dec‐15

14 Complete Financial/Project Delivery Study Mar‐15 Dec‐15

15 Complete Biological and Cultural Studies Jul‐15 Aug‐15 *

16 Complete Geotechnical Fieldwork/Borings Sep‐15 Nov‐15 *

17 Revegetate/Restore Boring Areas Nov‐15 Dec‐15 *

18 Monitor and Maintain Revegetated Areas Jan‐16 Jun‐16 *

19 Complete Detailed Engineering Studies Dec‐15 Jun‐16 *

20 Complete Conceptual Design Dec‐15 Mar‐16

21 FERC Licensing Process Dec‐15 Dec‐18

22 CEQA/NEPA Process Dec‐15 Dec‐18

23 Land Acquisition Dec‐15 Dec‐18

24 Complete Design Dec‐15 Dec‐18

25 Award Construction Contract Jan‐19 X

26 Construction Jan‐19 Dec‐21

27 Commercial Operations Dec‐21 X

Table 1: Planning‐Level Schedule of Proposed Project Activities

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2.3 New Dam Construction

Reconnaissance studies are anticipated to confirm the geology for the screened reservoir alternatives. Anticipated studies include:  Biological and cultural studies for the reservoir, dam, and tunnel areas.  Borings will be performed in the reservoir area to confirm that there is sufficient material of the appropriate quality for processing into materials for RCC.  Borings at the proposed dam foundation to confirm the depth to hard rock.  Borings along the pipeline/tunnel alignment.

Borings will be planned for locations that avoid impacts to wetlands and cultural impacts, as well as impacts to the floodplain.

3.0 WAIVER

As indicated in Subpart I (Application for Preliminary Permit) Section 4.81 Paragraph (c)(3) of 18CFR, the Commission "... may waive the requirements of Paragraph (c)(2) pursuant to 385.207 of this Chapter, upon showing by the applicant that the field studies, tests, and other activities to be conducted under this permit would not adversely affect cultural resources or endangered species and would cause only minor alterations or disturbances of lands and waters, and that any land altered or disturbed would be adequately restored." The studies, as proposed, meet these requirements, and therefore, a waiver is requested.

All of the field studies, tests, and other activities to be conducted under this permit will require state and/or local permits which will ensure that the studies do not adversely affect cultural resources or federal or state listed species, and will entail minimum disturbance of lands and waters. Existing roads will be used. Any potential impacts could be mitigated either by restoring the area or through the use of credits in the Water Authority’s existing mitigation banks. Thus, Water Authority requests to the extent it may be necessary, waiver of the requirements of this paragraph (c)(2).

4.0 STATEMENT OF COSTS AND FINANCING

4.1 Cost Estimate The estimated cost of carrying out or preparing the studies, investigations, tests, surveys, maps, plans and specifications identified in this exhibit is Approximately $15,000,000 to $20,000,000 (excluding construction).

4.2 Financing Funding to carry out or prepare the studies, investigations, tests, surveys, maps, plans and specifications identified in this exhibit will be provided by the applicant's own resources.

4.3 Proposed Market for Power Generation Markets for power generated by the applicant are the California Independent System Operator and adjoining balancing authorities and utilities. Existing utilities in the Project area include San Diego Gas & Electric (SDG&E) and Southern California Edison (SCE). 2014 Page 24 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM

The California Energy Commission’s 2007 California Energy Demand 2008-2018 Report has projected the following future electricity demands:

2013 2016__ SDG&E 4,784 MW 4,970 MW

2013 2016__ SCE 24,059 MW 24,934 MW

It is clear that major future generation expansion needs are forecast for the area, which includes the increase of renewable energy generation to meet the State’s mandated Renewable Portfolio Standard. The proposed Project can help to meet future capacity needs, as well as provide benefits of integrating the increasing renewable generation and grid reliability.

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EXHIBIT 3 PROJECT MAPS/DRAWINGS

Figure 1 Location Map

Figure 2 Regional Map of Water Authority Service Area

Figure 3 Project Study Area

Figure 4 FERC Project Boundary Area

Figure 4a Upper Reservoir Alternatives Configuration

Figure 5 San Vicente Dam & Reservoir Raise Plan

Figure 6 Typical Site Profile

Figure 7 SDG&E Sunrise Powerlink

Figure 8 Land Ownership Map

Figure 9 New Saddle Dams – Upper Reservoir

Figure 10 Transmission Line and Interconnection Alignment

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PROJECT: SAN VICENTE PUMPED-STORAGE LOCATION MAP FIGURE 1

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PROJECT: SAN VICENTE PUMPED-STORAGE REGIONAL MAP OF WATER AUTHORITY SERVICE AREA FIGURE 2

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ALTERNATIVE A

NOT TO SCALE

ALTERNATIVE B ALTERNATIVE C BARONA INDIAN RESERVATION

ALTERNATIVE D

STUDY AREA BOUNDARY

LAKESIDE

LEGEND

Barona Indian Reservation Lakeside Community Plan Ramona Community Plan City of Poway

PROJECT: SAN VICENTE PUMPED-STORAGE PROJECT STUDY AREA FIGURE 3

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ALTERNATIVE A IRON MOUNTAIN RESERVOIR FERC BOUNDARY ALTERNATIVE A ELEV. 2110 FEET POWER TUNNEL NEW ACCESS ROAD

NEW ACCESS ROAD

EQUIPMENT BUILDING/ TRANSFORMER YARD POWERHOUSE BELOW

MAIN ACCESS TUNNEL TAILRACE TUNNEL INTAKE/OUTLET STRUCTURE NEW ACCESS ROAD ALTERNATIVE B FERC BOUNDARY ALTERNATIVE C FERC BOUNDARY UPPER RESERVOIR ALTERNATIVE C MAX. ELEV. 1600 FEET STATE HIGHWAY 67 MAIN ACCESS ROAD EQUIPMENT BUILDING/ FOSTER CANYON RESERVOIR TRANSFORMER YARD ALTERNATIVE B AND PORTAL AREA ELEV. 1490 FEET SAN VICENTE ALTERNATIVE D POWER TUNNEL RESERVOIR ELEV. 650 FEET POWERHOUSE FERC BOUNDARY TAILRACE TUNNEL INTAKE/OUTLET NEW ACCESS ROAD STRUCTURE

PROJECT: APPROX. SCALE (feet) SAN VICENTE PUMPED-STORAGE 5,000 0 5,000 FERC PROJECT BOUNDARY AREA FIGURE 4

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SanDiegoCountyWaterAuthority|SanVicentePumpedStorageProject

FigureTS2SiteConfigurationandInterconnectLocation

BLACK&VEATCH|TechnicalSummary VX 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM

Cross Section of San Vicente Dam

800 Total Dam Raise: 750 +150,000 +117 Feet acre-feet 700

NOT TO SCALE N O

I 650

T Original Dam: A 90,000 220 Feet V 600 acre-feet E

L 550 E

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San Vicente Reservoir High Water Mark

San Vicente Dam Total Dam Raise: +117 Feet

Existing San Vicente Reservoir

PROJECT: SAN VICENTE DAM & RESERVOIR RAISE PLAN FIGURE 5

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NOT TO SCALE San Vicente Reservoir Anza-Borrego Desert State Park

LEGEND

SOURCE: San Diego Gas & Electric PROJECT: SAN VICENTE PUMPED-STORAGE SDG&E SUNRISE POWERLINK FIGURE 7

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SanDiegoCountyWaterAuthority|SanVicentePumpedStorageProject



Figure71LandOwnershipMap

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SanDiegoCountyWaterAuthority|SanVicentePumpedStorageProject



Figure21InterconnectLocation

BLACK&VEATCH|ProjectConfiguration TX 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM

ATTACHMENT 1 LEGAL AUTHORITY OF APPLICANT AS A MUNICIPALITY

20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM 20141016-5175 FERC PDF (Unofficial) 10/16/2014 2:27:10 PM Document Content(s) SDCWA Application for Preliminary Permit 2014-10-16.PDF...... 1-72