PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
ID#2769
ENERGY DIVISION RESOLUTION E-3848
October 2, 2003
Resolution E-3848. Southern California Edison Company (SCE) request for approval as reasonable Amendment No. 2 to the Power Purchase Contract between Southern California Edison Company and Ormesa Geothermal (QFID No. 3010) and Contract Termination Agreement between Ormesa Geothermal II (QFID No. 3012) and Southern California Edison. Approved.
By Advice Letter 1726-E filed on August 1, 2003.
__________________________________________________________
SUMMARY
Southern California Edison Company (SCE) requests approval for Amendment No. 2 to the Power Purchase Contract between Southern California Edison Company and Ormesa Geothermal (QFID No. 3010) and Contract Termination Agreement between Ormesa Geothermal II (QFID No. 3012) and Southern California Edison as reasonable. Specifically, SCE's Restructuring Advice Letter Filing (RALF) would consolidate power purchase agreements (PPAs) for two viable adjacent geothermal Qualifying Facilities (QF) projects (the Ormesa Geothermal Project and the Ormesa Geothermal II Project), owned by the same developer, into a single restructured contract. This resolution approves SCE's request.
SCE requests that the Commission adopt a resolution at the earliest possible time, but, by no later than November 1, 2003, so that, after taking into account the 30-day period for applications for rehearing,1 a condition of finality may be achieved by the December 1, 2003 deadline agreed upon by SCE and Ormesa. SCE requests the following findings:
(1) Approve Amendment No. 2 as reasonable in all respects;
(2) Approve the Termination Agreement entered into concurrently with and pursuant to Amendment No. 2 as reasonable in all respects; and
(3) All payments made pursuant to Amendment No. 2 and the Termination Agreement are fully recoverable in SCE's retail rates subject only to review by the Commission with respect to reasonableness of SCE's administration of the QFID 3010 PPA, as amended by Amendment No. 2.
BACKGROUND
The Commission sought to encourage QF contract restructuring in its Preferred Policy Decision, D.95-12-063, as modified by D.96-01-009, by proposing an incentive mechanism to encourage the restructuring of QF contracts so that total transition costs might be reduced. Specifically, shareholders would be allowed to retain 10% of the net ratepayer benefits resulting from a renegotiation.
In D.96-12-088 (the Roadmap 2 Decision), the Commission stated its interest in "establishing a generic and possibly expedited process by which we can assess the reasonableness of [QF] contract restructuring in a manner which respects the principles outlined in our Preferred Policy Decision" (D.96-12-088, p.79).
In 1998, the Commission adopted the Restructuring Advice Letter Filing (RALF)2 process in D.98-12-066:
"The restructuring Advice Letter [filing] process attached as Attachment B to this decision, shall be adopted subject to the modifications and clarifications set forth in Section 7 of this decision." (D.98-12-066, Ordering Paragraph 1).
The Commission adopted the RALF process with modifications that were not included in Attachment B to D.98-12-066 but were instead set forth in the decision. The Commission included the following provisions in the adopted RALF process:
· "We will require that a statement of support or neutrality from ORA be attached to any restructuring Advice Letter filing. We will not limit the use of the restructuring Advice Letter in any other way, such as by dollar size or by type of QF (including affiliates of utilities). (D.98-12-066, p.27, and Conclusion of Law 9)
· "While an ORA statement must be included with the restructuring Advice Letter, any other party may file a protest to the Advice Letter in the proper timeframe. We believe the procedural safeguards set forth in Attachment B, as modified by the following discussion, will ensure fairness in addressing the protests. Energy Division will review such protests (and any responses), and prepare a Resolution for the Commission pursuant to Section 9 of Attachment B [to D.98-12-066]. However, we modify Section 9 so that Energy Division, at its discretion, may advise the utility that the matter is too complex and should be filed as an Application. Energy Division may also advise the utility to file an Application even if there are no protests, should the Division determine that there are complexities to the filing that the Division does not believe it is in the best position to resolve. The Energy Division should discuss any such recommendation with the Coordinating Commissioner for QF matters before advising the utility to file an Application." (D.98-12-066, p.17)
· "We do not adopt Section 4 in Attachment B addressing confidentiality. Confidentiality issues shall be consistent with the current practice for utility Advice Letters." (D.98-12-066, p.28).
As described in SCE AL 1726-E, the Ormesa Geothermal and Ormesa Geothermal II Projects are geothermal QFs located in Imperial County, California. SCE's power purchases from Ormesa Geothermal and Ormesa Geothermal II are currently made in accordance with the terms and conditions of the Ormesa Geothermal and Ormesa II (QFID 3012) PPAs, which were entered into pursuant to the Public Utility Regulatory Policies Act of 1978 (PURPA), FERC's regulations implementing PURPA (18 C.F.R. § 292.101 et seq. (2002)), and decisions and orders of the Commission implementing PURPA in California. These PPAs account for approximately 65.3 MW of installed electric geothermal generating capacity. SCE states that the PPAs are based on Commission-approved standard offer forms and all provide for 30-year terms. The Ormesa Geothermal agreement was entered into on July 18, 1984 and the Ormesa Geothermal II agreement (QFID 3012) on June 13, 1984. These agreements will expire in 2017 and 2018, respectively. Energy deliveries by the Projects during 2002 collectively totaled approximately 374,085,000 KWh.
NOTICE
Notice of AL 1726-E was made by publication in the Commission's Daily Calendar. Southern California Edison states that a copy of the Advice Letter was mailed and distributed in accordance with Section III-G of General Order 96-A.
PROTESTS
Advice Letter AL 1726-E was filed on August 1, 2003. The protest period ended August 21, 2003. No protests were filed.
DISCUSSION
Energy Division has reviewed both the public and confidential versions of SCE AL 1727-E. SCE AL 1727-E included information required in Section 3 of RALF, and has complied with the other RALF filing requirements. These requirements are reproduced here as Attachment 1 to E-3848. Attachment 1 is modified from the original Attachment B to D.98-12-066 to reflect determinations made in D.98-12-066.
On July 14, 2003, ORA issued a letter in support of the contract restructuring, now proposed by SCE in AL 1726-E. The RALF procedure requires a statement of support or neutrality from ORA be attached to any restructuring Advice Letter filing.
SCE does not seek any shareholder incentive as a result of this contract restructuring.
With regard to historical performance, the projects have not experienced any operational issues such as probation or deration. From 1999 through 2002, overall production from the projects decreased slightly, but increased after ORMAT's3 reacquisition of the projects, and the subsequent capital improvement program. As a geothermal QF, Ormesa is not subject to efficiency monitoring standards.
Section 3f. of the RALF procedure requires disclosure of any significant, pending legal or regulatory disputes between the utility and the QFs. Upon such request, SCE informed the Energy Division that there are no disputes of any nature between Edison and the projects.
With regard to future viability, Ormesa plans to repower some of the units with newer machinery of the same technology, and requested that Edison concur that the equipment change-out constituted a repower and not a change of prime mover. After an engineering review of Ormesa's plans, Edison ultimately concurred that the equipment change constituted a repower and would not violate the contract. During the negotiations surrounding contract consolidation, Ormesa engaged in their capital improvement program, including the replacement of the project's cooling towers. Ormesa demonstrated to Edison's satisfaction through its plans and actions that Ormesa was determined to maintain the viability of the projects either separately or as consolidated.
The primary ratepayer benefit that would result from the proposed contract restructuring is a one-time, lump sum payment by Ormesa, LLC to SCE. This payment could be received by SCE as soon as five days after Commission approval of SCE AL 1727-E. The payment amount is fixed and does not represent forecasted savings, nor is it tied to an energy index or other variable rate. Payment would be credited to SCE's 0103 Account for Purchased Power on behalf of QFID 3012, resulting in the same one-time, lump sum reduction amount eligible for inclusion in SCE's Energy Resource Recovery Account (ERRA).
Due to the relatively immediate ratepayer benefit that would accrue, the Commission should approve, as reasonable, Amendment No. 2 to the Power
Purchase Contract between Southern California Edison Company and Ormesa Geothermal (QFID No. 3010) and the Contract Termination Agreement between Ormesa Geothermal II (QFID No. 3012) and Southern California Edison. Accordingly, SCE should be allowed to recover all payments made pursuant to Amendment No. 2 and the Termination Agreement in SCE's retail rates, subject to review by the Commission with respect to the reasonableness of SCE's administration of the QFID 3010 PPA, as amended by Amendment
No. 2.
COMMENTS
PU Code section 311(g)(1) provides that this resolution must be served on all parties and subject to at least 30 days public review and comment prior to a vote of the Commission. However, since this is an uncontested matter in which the resolution grants the relief requested. Pursuant to PU Code 311(g)(2), the otherwise applicable 30-day period for public review and comment is being reduced.
FINDINGS
1. The Commission adopted the Restructuring Advice Letter Filing (RALF) process in D.98-12-066. On August 1, 2003, SCE filed Advice Letter 1726-E pursuant to the RALF process for approval to consolidate two QF contracts.
2. AL 1726-E was not protested.
3. On July 14, 2003, ORA issued a letter in support of the contract restructuring, now proposed by SCE in AL 1726-E.
4. SCE complied with RALF filing requirements.
5. SCE does not seek any shareholder incentive as a result of this contract restructuring.
6. The Ormesa QFs have not experienced any operational issues such as probation or deration, and project viability is expected to be enhanced through capital improvements.
7. There are no pending legal or regulatory disputes between SCE and the Ormesa QFs.
8. The primary ratepayer benefit that would result from the proposed contract restructuring is a one-time, lump sum payment by Ormesa, LLC to SCE. This payment would be credited to SCE's 0103 Account for Purchased Power on behalf of QFID 3012, resulting in the same one-time, lump sum reduction amount eligible for inclusion in SCE's Energy Resource Recovery Account (ERRA).
9. We should approve, as reasonable, Amendment No. 2 to the Power Purchase Contract between Southern California Edison Company and Ormesa Geothermal (QFID No. 3010) and the Contract Termination Agreement between Ormesa Geothermal II (QFID No. 3012) and Southern California Edison.
10. SCE should be allowed to recover all payments made pursuant to Amendment No. 2 and the Termination Agreement in SCE's retail rates, subject to review by the Commission with respect to the reasonableness
of SCE's administration of the QFID 3010 PPA, as amended by
Amendment No. 2.
THEREFORE IT IS ORDERED THAT:
1. Southern California Edison Company's request for approval of Amendment No. 2 to the Power Purchase Contract between Southern California Edison Company and Ormesa Geothermal (QFID No. 3010) and the Contract Termination Agreement between Ormesa Geothermal II (QFID No. 3012) and Southern California Edison, as requested in Advice Letter 1726-E, is granted.
2. SCE may recover all payments made pursuant to Amendment No. 2 and the Termination Agreement in SCE's retail rates, subject to review by the Commission with respect to the reasonableness of SCE's administration of the QFID 3010 PPA, as amended by Amendment No. 2.
This Resolution is effective today.
I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on October 16, 2003; the following Commissioners voting favorably thereon:
_________________
WILLIAM AHERN
Executive Director
Attachment 1 to Resolution E-3848
Formerly ATTACHMENT B to D.98-12-066
[Modified Here in Attachment 1 to Resolution E-3848
To Reflect Modifications Set Forth In D.98-12-066]
Revised Exhibit A
RESTRUCTURING ADVICE LETTER FILING ("RALF") PROCEDURE FOR REVIEW OF QF CONTRACT RESTRUCTURINGS
THIS ATTACHMENT B IS SUBJECT TO THE MODIFICATIONS SET FORTH IN SECTION 7 OF D.98-12-066, INCLUDING:
· "We will require that a statement of support or neutrality from ORA be attached to any restructuring Advice Letter filing. We will not limit the use of the restructuring Advice Letter in any other way, such as by dollar size or by type of QF (including affiliates of utilities). (D.98-12-066, p.27, and Conclusion of Law 9)
· "While an ORA statement must be included with the restructuring Advice Letter, any other party may file a protest to the Advice Letter in the proper timeframe. We believe the procedural safeguards set forth in Attachment B, as modified by the following discussion, will ensure fairness in addressing the protests. Energy Division will review such protests (and any responses), and prepare a Resolution for the Commission pursuant to Section 9 of Attachment B [to D.98-12-066]. However, we modify Section 9 so that Energy Division, at its discretion, may advise the utility that the matter is too complex and should be filed as an Application. Energy Division may also advise the utility to file an Application even if there are no protests, should the Division determine that there are complexities to the filing that the Division does not believe it is in the best position to resolve. The Energy Division should discuss any such recommendation with the Coordinating Commissioner for QF matters before advising the utility to file an Application." (D.98-12-066, p.17)
· "We do not adopt Section 4 in Attachment B addressing confidentiality. Confidentiality issues shall be consistent with the current practice for utility Advice Letters." (D.98-12-066, p.28).
1. The utility will submit a restructuring advice letter to the Commission's Energy Division which will contain the essential information necessary to establish the reasonableness of the proposed voluntarily negotiated QF restructuring. Each such filing, and all protests, responses and replies concerning the filing, shall indicate a postal address and (where appropriate) a FAX number or e-mail address at which the advice letter filer, protestant or respondent, agrees to receive subsequent documents and notices relevant to the advice letter. Each such filing will be reported in the Daily Calendar.
2. Service of the restructuring advice letter shall be as follows:
On or before the date a restructuring advice letter is submitted for filing, and unless otherwise directed by Commission order, the utility shall serve the restructuring advice letter (1) on the Consumer Services Division and the Office of Ratepayer Advocates (service on these parties may be made by Internet); and (2) on the utility's restructuring advice letter service list and any other third parties as specified by the Energy Division, other Commission order, or statute.
The utility's restructuring advice letter service list shall include the postal and e-mail address, as appropriate, of persons on the list. The utility shall include on the requested list any person that requests such inclusion and may periodically confirm the desire of any currently listed person to remain on the list.
After the filing of a restructuring advice letter, and pending its disposition, the utility shall promptly provide a copy of the advice letter to anyone so requesting. Such provision shall be without charge to anyone who is a current customer for utility services from the utility, or to anyone receiving the advice letter by Internet.
3. The restructuring advice letter shall contain the following categories of information, including all relevant work papers and other relevant supporting documents:
a. Identification of the QF, location of the QF's generating facility, brief description of the generating facility size, type of technology and other pertinent or unique characteristics.
b. Ownership of the QF project and related companies, including affiliate relationships of the parties involved in the transaction, if any.
c. A detailed description of the historical operational performance of the project, including historical production and compliance with performance and efficiency monitoring standards.
d. A summary of the proposed contract restructuring.
e. A summary of the ratepayer benefits.
f. A description of any significant, pending legal or regulatory disputes between the Utility and the QF, and their resolution or status.
g. An assessment of the QF's projected economic and operational viability under the existing contract.
h. A detailed description of ratepayer benefits, shareholder incentive, and sensitivity analyses.
i. A copy of the QF's existing contract, including any amendments.
j. A copy of the executed or unexecuted restructured agreement for which approval is sought and copies of all related agreements between the QF and the Utility.
4. The publicly available version of the restructuring advice letter may be redacted to delete the following types of confidential information, which redaction would be approved in advance by the Commission in its orders authorizing the use of the advice letter process:
a. The schedule of any restructuring payments to be made to the QF, including the total amount thereof.
b. The Utility's non-public projection of replacement energy and capacity costs.
c. The Utility's projection of future production by and payments to the QF under the existing contract.
d. Non-public financial and operating data provided on a confidential basis by the QF to the Utility.
e. The Utility's assessment of the QF's financial and operating viability under the existing contract.
f. The Utility's analysis of ratepayer savings under expected, best case and worst case scenarios (except that the projected range of savings under each scenario shall not itself be deemed confidential).
g. Portions of restructuring agreements that are deemed to be confidential by the parties and which, if made public, would place the Utility and/or the QF at a competitive disadvantage.
h. Other information which constitutes a protectable trade secret of a party or which, if publicly disclosed, would place the Utility or the QF at a competitive disadvantage. [Deleted per D.98-12-066, p.18]
5. The restructuring advice letter shall only take effect upon Commission approval.
6. Any person may protest or respond to a restructuring advice letter as follows:
Within 20 days after the date that the advice letter is reported in the Daily Calendar, the protest or response shall be submitted to the Energy Division and served on the same day on the utility filing the restructuring advice letter. After filing a protest, and pending disposition of the restructuring advice letter, the protestant shall promptly provide a copy of the protest to anyone so requesting.
A restructuring advice letter may be protested on one or more of the following grounds:
a. The utility did not properly serve or give notice of the restructuring advice letter;
b. The relief requested in the restructuring advice letter would violate statute or Commission order;
c. The restructuring advice letter contains material errors, or does not follow the Commission's approved methodology, if any.
In addition, a restructuring advice letter may be protested on the grounds that the proposed restructuring is unjust, unreasonable, or discriminatory, provided, however, that a restructuring advice letter is not subject to protest on these grounds where such protest would require relitigating a prior order of the Commission.
The utility filing the restructuring advice letter shall reply to each protest and may reply to any response. Any such reply shall be submitted to the Energy Division not later than five business days after the last day to serve a protest or response, and shall be served on the same day on the person making the protest or response. If there are multiple protests or responses to a restructuring advice letter, the utility's reply may be to all such protests and responses.
The Energy Division may consider a late-filed protest or response. If the Energy Division considers a late-filed protest or response, it shall notify the utility filing the restructuring advice letter, and the utility shall have five business days from the date of issuance of the notice within which to reply to the late-filed protest or response.
7. The utility filing the restructuring advice letter may make minor revisions or corrections to the filing at any time before the effective date by filing and serving a supplement or substitute sheet. The utility shall withdraw the advice letter without prejudice in order to make major revisions. Supplements, substitute sheets, and withdrawals shall be filed and served in the same manner and on the same persons as was the original advice letter.
Minor revisions do not automatically extend the protest period. The Energy Division on its own motion or at the request of any person, may issue a notice extending the protest period. Any protest during the extended period shall be confined to the substance of the revision.
8. A supplement to a restructuring advice letter may be used to make minor revisions. The following revisions are examples of what commonly, but not necessarily, qualify as minor: a modification in response to a protest; a language clarification; or a later effective date. The supplement shall bear the same identifying number as the original advice letter but shall have a letter suffix "A" for the first supplement, "B" for the second supplement, etc.
9. Upon completion of the protest, response and reply period, the Energy Division will have 40 days within which to review the proposed restructuring to determine whether the information provided under paragraph 2 above and in response to any protest establishes that the proposed restructuring is reasonable under the Commission's standards and should be approved.
"Energy Division will review such protests (and any responses), and prepare a Resolution for the Commission pursuant to Section 9 of Attachment B. However, we modify Section 9 so that Energy Division, at its discretion, may advise the utility that the matter is too complex and should be filed as an Application. Energy Division may also advise the utility to file an Application even if there are no protests, should the Division determine that there are complexities to the filing that the Division does not believe it is in the best position to resolve. The Energy Division should discuss any such recommendation with the Coordinating Commissioner for QF matters before advising the utility to file an Application." (D.98-12-066, p.17)
When such review has been completed, and within such 40-day period, the Energy Division will prepare and submit to the Commission for consideration at the Commission's next public meeting which is at least 10 days thereafter a proposed resolution either approving or rejecting the restructuring advice letter. (To facilitate this process, the utility may submit a proposed form of resolution as part of the advice letter package.) A proposed resolution approving the restructuring advice letter shall make at least the following finding:
(a) That the restructuring is reasonable;
(b) That all payments to be made pursuant to the restructuring shall be recovered by the utility through its Annual Transition Cost Proceeding or other mechanism authorized by the Commission, subject only to the utility's prudent administration of the restructuring agreement.
The Commission may then adopt the proposed resolution or modify it in whole or in part. After the Commission has acted on the resolution, its action will be reported in the Daily Calendar and the resolution will be served on the utility filing the restructuring advice letter, the affected QF and on any person filing a protest or response to the restructuring advice letter.
10. Pursuant to Public Utilities Code Sections 1731 to 1736 and Rules 85 to 86.7 of the Commission's Rules of Practice and Procedure, the utility filing the restructuring advice letter, the affected QF, or any person filing a protest to the restructuring advice letter may apply for rehearing of a resolution approving or rejecting the restructuring advice letter pursuant to paragraph 9 above. The application for rehearing shall set forth specifically the grounds on which the applicant considers the resolution to be unlawful. Other than the affected QF, a person filing a response does not have standing to apply for rehearing.
The application for rehearing shall be submitted to the Commission's Docket Office, which will assign a docket number to the application, and with the Energy Division. If the applicant is the utility filing the restructuring advice letter, it shall serve all persons filing protests or responses to the restructuring advice letter. If the applicant is the affected QF or a person filing a protest, the applicant shall serve the utility and all other persons filing protests or responses to the restructuring advice letter.
11. If the Commission's final resolution does not approve the proposed restructuring in its entirety, then the terms of the agreement between the utility and the QF will determine whether or not the restructuring effort will terminate or whether the proposed restructuring will be resubmitted for consideration through a formal application process. Also, subject to its agreement with the QF, the utility will have the right to withdraw a restructuring advice letter without prejudice at any time prior to Commission action on the draft resolution prepared by the Energy Division, or to pursue a formal application process in lieu of the advice letter procedure.
12. Nothing in the restructuring advice letter filing procedure shall preclude the utility from electing not to use the advice letter process.
STATE OF CALIFORNIA GRAY DAVIS, Governor
PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298
September 22, 2003 Commission Meeting Date: October 2, 2003 ID#2769
TO: PARTIES IN R.99-11-022 and SOUTHERN CALIFORNIA EDISON COMPANY ADVICE LETTER 1726-E, QUALIFYING FACILITY (QF) CONTRACT AMENDMENT BETWEEN THE UTILITY AND ORMESA PURSUANT TO THE RESTRUCTURING ADVICE LETTER FILING (RALF) PROCEDURE.
Enclosed is draft Resolution E-3848 of the Energy Division. It addresses Southern California Edison Company Advice Letter 1726-E for approval as reasonable Amendment No. 2 to the Power Purchase Contract between Southern California Edison Company and Ormesa Geothermal (QFID No. 3010) and Contract Termination Agreement between Ormesa Geothermal II (QFID No. 3012) and Southern California Edison.
The draft Resolution will be on the agenda at the October 2, 2003 Commission meeting. Since this is an uncontested matter in which the resolution grants the relief requested, pursuant to PU Code 311(g)(2), the otherwise applicable 30-day period for public review and comment is being reduced. The Commission may then vote on this draft Resolution or it may postpone a vote until later.
When the Commission votes on a draft Resolution, it may adopt all or part of it as written, amend, modify or set it aside and prepare a different Resolution. Only when the Commission acts does the Resolution become binding on the parties.
Parties may submit comments on the draft Resolution.
An original and two copies of the comments, with a certificate of service, should be submitted to:
Jerry Royer
Energy Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
fax: 415-703-2200
A copy of the comments should also be submitted to:
Wade McCartney
Energy Division
California Public Utilities Commission
770 L Street, Suite 1050
Sacramento, CA 95814
email: wsm@cpuc.ca.gov
Any comments on the draft Resolution must be received by the Energy Division by close of business on Friday September 26, 2003. Those submitting comments must serve a copy of their comments on (1) the entire service list attached to the draft Resolution, including the R.99-11-022 service list, (2) all Commissioners, and (3) the Director of the Energy Division, on the same date that the comments are submitted to the Energy Division.
Comments shall be limited to five pages in length plus a subject index listing the recommended changes to the draft Resolution. Comments shall focus on factual, legal or technical errors in the proposed draft Resolution. Comments that merely reargue positions taken in the advice letter or protests will be accorded no weight and are not to be submitted. There will be no reply comments on the draft resolution.
Late submitted comments will not be considered.
Don Lafrenz
Energy Division
Enclosure
Service List - Parties in SCE AL 1726-E and R.99-11-022
CERTIFICATE OF SERVICE
I certify that I have by mail this day served a true copy of Draft Resolution E-3848 on all
parties in these filings or their attorneys as shown on the attached list.
Dated September 19, 2003 at San Francisco, California.
____________________
Jerry Royer
NOTICE
Parties should notify the Energy Division, Public Utilities
Commission, 505 Van Ness Avenue, Room 4002
San Francisco, CA 94102, of any change of address to
insure that they continue to receive documents. You
must indicate the Resolution number on the service list
on which your name appears.
ROGER BERLINER MANATT, PHELPS & PHILLIPS, LLP County of Las Angeles 1501 M STREET, N.W., SUITE 700 WASHINGTON, DC 20005 |
JONATHAN M. WEISGALL V.P. LEGISLATIVE & REGULATORY AFFAIRS CALENERGY COMPANY, INC. 1200 NEW HAMPSHIRE AVE., NW, SUITE 300 WASHINGTON, DC 20036 | |
JAMES ROSS RCS CONSULTING, INC. MIDSET COGENERATION COMPANY 500 CHESTERFIELD CENTER, SUITE 320 CHESTERFIELD, MO 63017 |
DOUGLAS L. ANDERSON VICE PRESIDENT AND GENERAL COUNSEL CE GENERATION, LLC 302 SOUTH 36TH STREET, SUITE 400 OMAHA, NE 68131 | |
ANDREW N. CHAU TRACTEBEL POWER, INC. 1177 WEST LOOP SOUTH, SUITE 900 HOUSTON, TX 77027 |
DAVID M. NORRIS ASSOCIATE GENERAL COUNSEL SIERRA PACIFIC POWER COMPANY 6100 NEIL ROAD, PO BOX 10100 RENO, NV 89520 | |
HOWARD CHOY ENERGY MANAGEMENT DIVISION MANAGER COUNTY OF LOS ANGELES INTERNAL SERVICES DEPARTMENT 1100 NORTHEASTERN AVENUE LOS ANGELES, CA 90063 |
KEVIN MC SPADDEN ATTORNEY AT LAW MILBANK, TWEED, HADLEY & MC CLOY 601 S. FIGUEROA STREET, 30TH FLOOR LOS ANGELES, CA 90068 | |
DAN WOODS WHITE & CASE LLP Smurfit Stone Container Corporation,/Delta Power Co./Willamette Industries, Inc./E.F.Oxnard, Inc. 633 WEST FIFTH STREET, SUITE 1900 LOS ANGELES, CA 90071-2087 |
TANDY MCMANNES KJC CONSULTING COMPANY KRAMER JUNCTION OPERATING COMPANY 2938 CROWNVIEW DRIVE RANCHO PALOS VERDES, CA 90275 | |
SUSAN ROSSI ATTORNEY AT LAW CALIFORNIA POWER EXCHANGE CORPORATION 70 SOUTH LAKE AVE 910 PASADENA, CA 91101-4960 |
ERIC J. ISKEN ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE ROSEMEAD, CA 91770 | |
JAMES B. WOODRUFF SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE, SUITE 342, GO1 ROSEMEAD, CA 91770 |
THEODORE ROBERTS ATTORNEY AT LAW SEMPRA ENERGY SAN DIEGO GAS AND ELECTRIC COMPANY 101 ASH STREET, HQ 12B SAN DIEGO, CA 92101-3017 | |
EDWARD E. MADDOX BUSINESS DEVELOPMENT MANAGER SEAWEST WINDPOWER, INC. 1455 FRAZEE ROAD, SUITE 900 SAN DIEGO, CA 92108-4310 |
NORMAN J. FURUTA ATTORNEY AT LAW DEPARTMENT OF THE NAVY 2001 JUNIPERO SERRA BLVD., SUITE 600 DALY CITY, CA 94014-3890 | |
DIANE I. FELLMAN ATTORNEY AT LAW LAW OFFICES OF DIANE I. FELLMAN 234 VAN NESS AVENUE SAN FRANCISCO, CA 94102 |
ROBERT FINKELSTEIN ATTORNEY AT LAW THE UTILITY REFORM NETOWRK (TURN) 711 VAN NESS AVE., SUITE 350 SAN FRANCISCO, CA 94102 | |
John M Chamberlain CALIF PUBLIC UTILITIES COMMISSION CPUC OFFICE OF RATEPAYER ADVOCATES LEGAL DIVISION 505 VAN NESS AVENUE ROOM 4107 SAN FRANCISCO, CA 94102 |
EVELYN KAHL ATTORNEY AT LAW ALCANTAR & KAHL, LLP ENERGY PRODUCERS AND USERS COALITION (EPUC) 120 MONTGOMERY STREET, SUITE 2200 SAN FRANCISCO, CA 94104 | |
LINDA SHERIF ATTORNEY AT LAW ALCANTAR & KAHL LLP COGENERATION ASSOCIATION OF CALIFORNIA (CAC) and EPUC 120 MONTGOMERY STREET, STE 2200 SAN FRANCISCO, CA 94104 |
ANN C. SELTING GRUENEICH RESOURCE ADVOCATES Sonoma County Water Agency 582 MARKET STREET, SUITE 1020 SAN FRANCISCO, CA 94104-5311 | |
DIAN M. GRUENEICH ATTORNEY AT LAW GRUENEICH RESOURCE ADVOCATES 582 MARKET STREET, SUITE 1020 SAN FRANCISCO, CA 94104-5311 |
ALICE REID PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET SAN FRANCISCO, CA 94105 | |
CHARLES R. MIDDLEKAUF PACIFIC GAS AND ELECTRIC COMPANY LAW DEPARTMENT 77 BEALE STREET, B30A SAN FRANCISCO, CA 94105 |
BRIAN CRAGG. ATTORNEY AT LAW GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP CAITHNESS ENERGY/LUZ SOLAR PARTNERS LTD.,VIII&IX 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94111 | |
JAMES D. SQUERI, ATTORNEY AT LAW GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP MONSANTO CO. 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94111 |
JERRY R. BLOOM, ATTORNEY AT LAW WHITE & CASE LLP CALIFORNIA COGENERATION COUNCIL (CCC) THREE EMBARCADERO CENTER, SUITE 2210 SAN FRANCISCO, CA 94111 | |
JOSEPH M. KARP, ATTORNEY AT LAW WHITE & CASE LLP Smurfit Stone COntainer Corporation, f.k.a.Jefferson Smurfit Corporation(U.S.) THREE EMBARCADERO CENTER, SUITE 2210 SAN FRANCISCO, CA 94111 |
LINDSEY HOW-DOWNING, ATTORNEY AT LAW DAVIS WRIGHT TREMAINE LLP CALPINE CORPORATION ONE EMBARCADERO CENTER, SUITE 600 SAN FRANCISCO, CA 94111 | |
JEFFREY GRAY DAVIS WRIGHT TREMAINE Dynamis Incorporated ONE EMBARCADERO CENTER STE. 600 SAN FRANCISCO, CA 94111-3611 |
SARA STECK MYERS, ATTORNEY AT LAW ENRON WIND CORP., CENETER FOR ENERGY EFFICIENCY AND RENEWABLE TECHNOLOGIES (CEERT) 122 - 28TH AVENUE SAN FRANCISCO, CA 94121 | |
SETH HILTON, ATTORNEY AT LAW MORRISON & FOERSTER LLP EL PASO MERCHANT ENERGY, L.P. 101 YGNACIO VALLEY ROAD, SUITE 450 WALNUT CREEK, CA 94596-7032 |
NANCY RADER, EXECUTIVE DIRECTOR CALIFORNIA WIND ENERGY ASSOCIATION 1198 KEITH AVENUE BERKELEY, CA 94708 | |
R. THOMAS BEACH PRINCIPAL CONSULTANT CROSSBORDER ENERGY WATSON COGENERATION COMPANY 2560 NINTH STREET, SUITE 316 BERKELEY, CA 94710 |
PATRICK MCDONNELL AGLAND ENERGY TXU ENERGY SERVICES 2000 NICASIO VALLEY NICASIO, CA 94946 | |
JIM CROSSEN AUTOMATED POWER EXCHANGE, INC. TECHMART 5201 GREAT AMERICA PARKWAY, SUITE 552 SANTA CLARA, CA 95054 |
STEVE FELTE, GENERAL MANAGER TRI-DAM PROJECT & POWER AUTHORITY PO BOX 1158 PINECREST, CA 95364-0158 | |
ROBERT BEACH SONOMA COUNTY WATER AGENCY 739 MIRAMAR STREET WINDSOR, CA 95492 |
JOHN J. PREVOST PACIFIC LUMBER COMPANY 125 MAIN STREET SCOTIA, CA 95565 | |
DALE W. MAHON CENTRAL HYDROELECTRIC CORPORATION 9951 GRANT LINE ROAD ELK GROVE, CA 95624-1411 |
MATTHEW V. BRADY, SPECIAL COUNSEL MATTHEW V. BRADY & ASSOCIATES Central Hydroelectric Company 2339 GOLD MEADOW WAY, SUITE 230 GOLD RIVER, CA 95670 | |
DOUGLAS K. KERNER ATTORNEY AT LAW ELLISON, SCHNEIDER & HARRIS INDEPENDENT ENERGY PRODUCERS ASSOCIATION (IEP) 2015 H STREET SACRAMENTO, CA 95814 |
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MICHAEL ALCANTAR, ATTORNEY AT LAW ALCANTAR & KAHL LLP COGENERATION ASSOCIATION OF CALIFORNIA 1300 SW FIFTH AVENUE, SUITE 1750 PORTLAND, OR 97201 |
DON SCHOENBECK RCS, INC COALINGA COGENERATION COMPANY 900 WASHINGTON STREET, SUITE 780 VANCOUVER, WA 98660 | |
C. FAIRLEY SPILLMAN AKIN, GUMP, STRAUSS, HAUER & FELD, LLP 1333 NEW HAMPSHIRE AVENUE, NW WASHINGTON, DC 20036 |
KAY DAVOODI NAVY RATE INTERVENTION OFFICE WASHINGTON NAVY YARD 1314 HARWOOD STREET SE WASHINGTON NAVY YARD, DC 20374-5018 | |
MAURICE BRUBAKER BRUBAKER & ASSOCIATES PO BOX 412000 ST. LOUIS, MO 63141 |
JANET DOYLE KRAMER JUNCTION COMPANY 1636 AJAX LANE EVERGREEN, CO 80439 | |
CLIFF ROCHLIN SOUTHERN CALIFORNIA GAS COMPANY SEMPRA ENERGY 555 W. FIFTH STREET, ML 22A1 LOS ANGELES, CA 90013 |
ED J. WHELESS DIVISION ENGINEER COUNTY SANITATION DIST. OF L.A. COUNTY SOLID WASTER MANAGEMENT DEPT PO BOX 4998 WHITTIER, CA 90607-4998 | |
JOHN COSTANZO KRAMER JUNCTION COMPANY 1778 FISK COURT THOUSAND OAKS, CA 91362 |
DANIEL W. DOUGLASS ATTORNEY AT LAW LAW OFFICES OF DANIEL W. DOUGLASS 6303 OWENSMOUTH AVENUE, TENTH FLOOR WOODLAND HILLS, CA 91367-2262 | |
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CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE, R00M 370 ROSEMEAD, CA 91770 | |
JOHN W. LESLIE ATTORNEY AT LAW LUCE, FORWARD, HAMILTON & SCRIPPS, LLP Coral Energy Resourced, LLC/Engage Energy US,L.P. 600 WEST BROADWAY, SUITE 2600 SAN DIEGO, CA 92101 |
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CHRIS SMITH CORAL ENERGY RESOURCES, LLC 4320 LA JOLLA VILLAGE DRIVE SAN DIEGO, CA 92122 |
ROBERT TURNER COASTAL MERCHANT ENERGY LP PO BOX 17097 SAN DIEGO, CA 92177 | |
MITSUBISHI POWER SYSTEMS, INC. 100 BAYVIEW CIRCLE, SUITE 4000 NEWPORT BEACH, CA 92660 |
ERIC WILLS, PRESIDENT SUNRAY ENERGY, INC. 20668 PASEO DE LA CUMBRE YORBA LINDA, CA 92687 | |
JAMES L. MCARTHUR DAI OILDALE, INC 3300 MANOR DRIVE BAKERSFIELD, CA 93308 |
EDWARD G. CAZALET, CHAIRMAN AUTOMATED POWER EXCHANGE 5201 GREAT AMERICA PARKWAY SANTA CLARA, CA 94054 | |
JUDY PECK SEMPRA ENERGY UTILITIES 601 VAN NESS AVENUE, SUITE 2060 SAN FRANCISCO, CA 94102 |
KEENAN O'BRIEN PACIFIC GAS AND ELECTRIC COMPANY 245 MARKET ST., MAIL CODE: N12E SAN FRANCISCO, CA 94102 | |
WILLIAM BLATTNER ADMINSTRATOR STATE REG. RELATIONS SEMPRA ENERGY 601 VAN NESS AVENUE, SUITE 2060 SAN FRANCISCO, CA 94102 |
JACK MCGOWAN GRUENEICH RESOURCE ADVOCATES 582 MARKET STREET, SUITE 1020 SAN FRANCISCO, CA 94104 | |
JOHN PAPPAS UTILITY ELECTRIC PORTFOLIO MANAGEMENT PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, N12E SAN FRANCISCO, CA 94105 |
ROBERT T. BOYD ENRON WIND CORP. 444 SOUTH FLOWER STREET, SUITE 4545 LOS ANGELES, CA 94105 | |
TONY WAKIM KENNEDY/JENKS CONSULTANTS 622 FOLSOM STREET SAN FRANCISCO, CA 94107 |
ARTHUR V. O'DONNELL CALIFORNIA ENERGY MARKETS 9 ROSCOE STREET SAN FRANCISCO, CA 94110-5921 | |
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SHIRLEY L. WONG PACIFIC GAS AND ELECTRIC COMPANY PO BOX 770000, RM. 987 - B9A SAN FRANCISCO, CA 94177 |
ALEXANDRE MAKLER, ATTORNEY AT LAW CALPINE CORPORATION PO BOX 11749 PLEASANTON, CA 94588-1749 | |
ROBERT SZYMANSKI POWERWORKS, INC. 781 THOMAS LANE WALNUT CREEK, CA 94596 |
STEVE HUHMAN SOUTHERN COMPANY ENERGY MARKETING 1350 TREAT BLVD. SUITE 500 WALNUT CREEK, CA 94597 | |
VIDA BENAVIDES EXECUTIVE DIRECTOR C/O NAATA 4096 PIEDMONT AVE, 312 OAKLAND, CA 94611 |
ROBERT B. WEISENMILLER, PH.D. MRW & ASSOCIATES, INC. VARIOUS INTERVENORS 1999 HARRISON STREET, SUITE 1440 OAKLAND, CA 94612-3517 | |
REED V. SCHMIDT BARTLE WELLS ASSOCIATES 1889 ALCATRAZ AVENUE BERKELEY, CA 94703 |
RICHARD MC CANN M.CUBED 2655 PORTAGE BAY, SUITE 3 DAVIS, CA 95616 | |
SCOTT BLAISING ATTORNEY AT LAW BRAUN & ASSOCIATES, P.C. 8980 MOONEY ROAD ELK GROVE, CA 95624 |
TONY WETZEL THERMO ECOTEK CORPORATION 631 HANCOCK DRIVE FOLSOM, CA 95630 | |
ANDREW BROWN ELLISON & SCHNEIDER, LLP 2015 H STREET SACRAMENTO, CA 95814 |
EDWARD J. TIEDEMANN, ATTORNEY AT LAW KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD PLACER COUNTY WATER AGENCY 400 CAPITOL MALL, 27TH FLOOR SACRAMENTO, CA 95814 | |
STEVE PONDER FPL ENERGY, INC., LLC 980 NINTH STREET, 16TH FLOOR SACRAMENTO, CA 95814 |
DAVID R. BRANCHCOMB HENWOOD ENERGY SERVICES INDEPENDENT ENERGY PRODUCERS ASSOCIATION (IEP) SUITE 300 NORTH 2710 GATEWAY OAKS DRIVE SACRAMENTO, CA 95833 | |
DOUGLAS E. DAVIE PRINCIPAL CONSULTANT HENWOOD ENERGY SERVICES, INC. 2379 GATEWAY OAKS DRIVE, SUITE 100 SACRAMENTO, CA 95833 |
Maria E. Stevens CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION 320 WEST 4TH STREET SUITE 500 LOS ANGELES, CA 90013 | |
Amy C Yip-Kikugawa CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION 505 VAN NESS AVENUE ROOM 5135 SAN FRANCISCO, CA 94102 |
Bruce DeBerry CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES 505 VAN NESS AVENUE ROOM 5043 SAN FRANCISCO, CA 94102 | |
Darwin Farrar CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION 505 VAN NESS AVENUE ROOM 4107 SAN FRANCISCO, CA 94102 |
Edwin Quan CALIF PUBLIC UTILITIES COMMISSION CPUC - ENERGY DIVISION INFORMATION & MANAGEMENT SERVICES DIVISION 505 VAN NESS AVENUE ROOM 3016 SAN FRANCISCO, CA 94102 | |
Gregory A. Wilson CALIF PUBLIC UTILITIES COMMISSION CPUC - ENERGY DIVISION ELECTRIC INDUSTRY & FINANCE 505 VAN NESS AVENUE AREA 4-A SAN FRANCISCO, CA 94102 |
Pearlie Sabino CALIF PUBLIC UTILITIES COMMISSION OFFICE OF RATEPAYER ADVOCATES (ORA) ELECTRICITY RESOURCES AND PRICING BRANCH 505 VAN NESS AVENUE ROOM 4209 SAN FRANCISCO, CA 94102 | |
BILL JULIAN ATTORNEY AT LAW UTILITIES & COMMERCE STATE CAPITOL, ROOM 2117 SACRAMENTO, CA 95814 |
Wade McCartney CALIF PUBLIC UTILITIES COMMISSION NATURAL GAS, ENERGY EFFICIENCY AND RESOURCE ADVISORY 770 L STREET, SUITE 1050 SACRAMENTO, CA 95814 | |
JAMES HOFFSIS CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET MS-45 SACRAMENTO, CA 95814-5504 |
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1 Filing of a timely application for rehearing is a jurisdictional requirement for further review of Commission decision in the courts. Pub. Util. Code Section 1731(b).
2 Restructuring Advice Letter Filing ("RALF") Procedure For Review of QF Contract Restructurings.
3 ORMAT Group, an energy company based in Sparks, Nevada, purchased Ormesa Geothermal I & II in April 2002. The company owns and operates about 30 energy projects (geothermal, waste heat recovery, and solar), a total portfolio of about 200 MW. See www.ormat.com
