Word Document PDF Document

a. Utility Positions

Each Party reserves all rights, claims and defenses with respect to this Agreement, the Decision, and any application for rehearing or appeal filed with respect to the Decision.37

1 California Public Utilities Commission et al., 132 FERC ¶ 61,047 at PP 65 and 67.

2 California Public Utilities Commission, 133 FERC ¶ 61,059.

3 D.11-04-033, Ordering Paragraphs 5 and 7.

4 PU Code 2841(f).

5 D.09-12-042, Attachment A, Section 3.02 and Attachment B, Section 3.02.

6 D.11-04-033 at p. 11.

7 According to EPUC, this is the date provided to them by PG&E as to when one of the generators they represent could have a completed deliverability study.

8 Protest of Fuel Cell, Inc. and California Clean DG Coalition to Advice 2485-E-B, Advice 2179-E-B and Advice 3696-E-C, June 6, 2011, at pp. 4, 5 and 6.

9 Response of San Diego Gas & Electric Company to FuelCell Energy, Inc. and California Clean DG Coalition protest of SDG&E Advice Letter 2179-E-B, June 13, 2011, at p.2.

10 Response of Southern California Edison Company to Protests to Advice 2485-E-B, June 13, 2011, at p. 1.

11 Response of San Diego Gas & Electric Company to FuelCell Energy, Inc. and California Clean DG Coalition protest of SDG&E Advice Letter 2179-E-B, June 13, 2011, at p.2.

12 Response of Southern California Edison Company to the Protests to Advice 2485-E-B, June 13, 2011, at p.11.

13 Response of San Diego Gas & Electric Company to FuelCell Energy, Inc. and California Clean DG Coalition protest of SDG&E Advice Letter 2179-E-B, June 13, 2011, at p.2.

14 PU Code Section 2841(b)(4).

15 D.11-04-033, Peevey's Attachment A to Attachment B Conformed D0912042, Standard Contract for Eligible CHP Facilities, Section 3.02 (d).

16 Response of Pacific Gas & Electric Company to the Protests of Advice 3696-E-C, June 13, 2011, at p .2.

17 Response of Southern California Edison to the Protests of Advice 2485-E-B, June 13, 2011, at p. 4.

18 Protest of Fuel Cell, Inc. and California Clean DG Coalition to Advice 2485-E-B, Advice 2179-E-B and Advice 3696-E-C, June 6, 2011, at p. 2.

19 Id., at p. 2.

20 Response of Southern California Edison to the Protests of Advice 2485-E-B, June 13, 2011, at p. 4.

21 Id.

22 Fuel Cell Energy, Inc. and California Clean DG Coalition, Comments in support of Revised Draft Resolution E-4424, October 31, 2011, at p.2.

23 See Comments of Southern California Edison Company on Revised Draft Resolution E-4424, October 31, 2011, at p.2.

24 See Comments of San Diego Gas & Electric Company on Revised Draft Resolution E-4424, October 31, 2011, at p. 2.

25 See Comments of Pacific Gas and Electric Company to Revised Draft Resolution E-4424 (on agenda November 10, 2011), October 31, 2011, at p. 1.

26 See the Joint Motion for Approval of Qualifying Facility and Combined Heat and Power Program Settlement Agreement, Attachment A, Exhibit 6, approved by D. 10-12-035.

27 See Comments of San Diego Gas & Electric Company on Revised Draft Resolution E-4424, October 31, 2011, at p. 3.

28 Southern California Edison Company, Comments on Revised Draft Resolution E-4424, October 31, 2011, at p.2.

29 Response of Southern California Edison to the Protests of Advice 2485-E-B, June 13, 2011, at p. 7.

30 Response of Pacific Gas & Electric Company to the Protests of Advice 3696-E-C, June 13, 2011, at p .9.

31 D.09-12-042 at p. 35.

32 D.10-12-055 at p. 10.

33 Response of Southern California Edison Company to the Protests to Advice 2485-E-B, June 13, 2011, at p. 9.

34 Late Filed Response of San Diego Gas & Electric Company to San Joaquin Refining protest of SDG&E Advice Letter 2179-E-B, July 5, 2011, at p. 2.

35 Response of Pacific Gas & Electric Company to the Protests of Advice 3696-E-C, June 13, 2011, at p. 10.

36 U.S. Const., Art. I, § 10 and Cal. Const., Art. I, § 9.

37 D.09-12-042, Attachment A, Standard Contract for Eligible CHP Facilities, Section 9.08(o).

38 D.09-12-042, Finding of Fact 61.

39 Protest of Fuel Cell, Inc. and California Clean DG Coaltion to Advice 2485-E-B, Advice 2179-E-B and Advice 3696-E-C, June 6, 2011, at p. 4 and 5.

40 D.10-12-055 at p. 30.

Top Of Page