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Documenti di Professioni
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RANDALL W. KEEN
S. NANCY WHANG
Manatt, Phelps & Phillips, LLP
11355 West Olympic Boulevard
Los Angeles, California 90064
Tel: (310) 312-4000
Fax: (310) 914-5721
E-mail: rkeen@manatt.com
nwhang@manatt.com
PUCService@manatt.com
Pursuant to Rule 14.3 of the California Public Utilities Commission’s (the “Commission”)
Rules of Practice and Procedure and Public Utilities Code Section 311(d), the City of Santee
(“Santee” or the “City”) hereby respectfully submits comments on the Proposed Decision of ALJ
Vieth, Alternate Proposed Decision of Commissioner Grueneich, and Alternate Proposed Decision
I. BACKGROUND
On October 31, 2008, the Commission mailed the Proposed Decision of Administrative
Law Judge (“ALJ”) Vieth entitled “Decision Denying a Certificate of Public Convenience and
Necessity for the Sunrise Powerlink Transmission Project” (the “PD”). The same day, the
“Decision Denying a Certificate of Public Convenience and Necessity for the Sunrise Powerlink
Transmission Project” (the “Grueneich APD”). On November 18, 2008, the Commission issued
the Alternate Proposed Decision of President Peevey entitled “Decision Granting a Certificate of
Public Convenience and Necessity for the Sunrise Powerlink Transmission Project.” (the “Peevey
1
APD”)1 (the PD, Grueneich APD, and the Peevey APD shall be collectively referred to as the
“Decisions.”)
The Decisions primarily address three matters: (1) reviewing if and how the Sunrise
Powerlink Transmission Project (the “Sunrise Project”) meets the statutory requirements for the
issuance of a certificate of public convenience and necessity (CPCN); (2) determining whether the
Sunrise Project and alternatives is justified and necessary to facilitate California’s renewables
portfolio standard; and (3) evaluating the environmental impacts of the Sunrise Project pursuant to
the California Environmental Quality Act (“CEQA”). The City’s comments primarily address the
factual and legal error in the Decisions concerning the ENPEX Project that is a part of the All
The City is located in eastern San Diego County, northeast of the City of San Diego, and
adjacent to Marine Corps Air Station Miramar (“MCAS Miramar”). The City was incorporated in
December, 1980, and is the eleventh largest of San Diego County’s cities, with a population of
The City does not have a formal position on the Sunrise Project or the proposed
transmission route alternatives. However, the City opposes the inclusion of the San Diego
component of the ASGA in the Final Environmental Impact Report / Statement’s (“FEIR/S”). The
ENPEX Project: (1) is not feasible and therefore is not a viable alternative; (2) conflicts with the
1
Comments to the Peevey APD are due on December 8, 2008. For the sake of efficiency, the City incorporates herein
comments on the Peevey APD. However, since the time to file full comments to the Peevey APD has not elapsed, the
City hereby reserves the right to provide additional comments on the Peevey APD in accordance with the
Commission’s Rules of Practice and Procedure.
2
City’s long-standing General Plan and approved projects, namely the recently approved Fanita
Project, a 1,400 unit residential development; (3) would block a key wildlife mitigation corridor
approved by federal, state and local agencies; and (4) would create significant, unmitigated
environmental impacts that are not fully studied in the FEIR/S. In addition, the ENPEX Project
will be a behemoth consisting of a 750 megawatt natural gas-fired power plant project with the
potential for an additional 750 megawatt expansion plant, and given the proposed (though ever
changing) location for the ENPEX Project, it will be in the City’s proverbial backyard.
Due to the serious and unmitigated harm the ENPEX Project poses to the City, the City
actively engaged in this proceeding by participating in the public meetings, submitting comments
on the Draft and Re-circulated EIR/S, and filing testimony, briefs, and now comments with the
Commission. Specifically, on April 14, 2008, the City submitted into the record and ALJ
Weissman accepted the Direct Testimony of Gary Halbert, which cited the reason and basis for the
City’s opposition to the ENPEX Project.2 No party elected to cross-examine Mr. Halbert nor was
testimony submitted to contradict Mr. Halbert’s direct testimony. On May 30, 2008, the City
submitted its Opening Brief and on June 13, 2008, the City submitted its Reply Brief.
The City recognizes the significant effort and attention, as well as thoughtful consideration,
provided by the Decisions on matters crucial to the evaluation of the need for, the renewables
development relating to, and the environmental impacts of the Sunrise Project. However, the City
believes that in conducting its environmental review, the Decisions treat all of the ASGA similarly
in that they do not give the proper weight to the undisputed testimony submitted by the parties to
this proceeding regarding the ENPEX Project, and do not consider other factors essential to
evaluating the feasibility of the ENPEX Project. The City believes that when the ENPEX Project
2
See generally Direct Phase 2 Testimony of Gary Halbert (“Halbert Testimony”), City of Santee.
3
is considered in light of the testimony and evidence submitted by the parties, the Commission will
and should find that it should properly be excluded from the ASGA. Accordingly, the City
The Decisions specifically differ materially on the consideration of the ASGA. The
Grueneich APD and the Peevey APD rightfully reject the ASGA, and by implication the ENPEX
Project, as a feasible alternative to the Sunrise Project. The rejection of the ASGA will provide
greater consistency, advance California’s greenhouse gas reduction goals, and also support the
City’s position – a position that was neither opposed by the applicant, San Diego Gas & Electric
(“SDG&E”), nor any other party to this proceeding. Accordingly, if the ENPEX Project remains
in the ASGA, the City recommends that the Commission adopt either the Grueneich APD or
Peevey APD as the Final Decision. In contrast to the Grueneich and Peevey APDs, the PD
unnecessarily certifies the FEIR/S, thereby inferring that the ENPEX Project, a hypothetical
project, is feasible. The PD should be modified so that the FEIR/S is not certified. This would not
A. Environmental Review.
The ENPEX Project is one component of the ASGA identified in the FEIR/S. The City
believes, as described more fully above and in its testimony, comments and briefs filed in this
proceeding, that the ENPEX Project is not feasible, will have substantial and unmitigated
environmental impacts and that the DEIR/S previously and the FEIR/S currently fails to properly
account for these impacts.3 In Section 17.4, the Decisions appear to dismiss concerns about the
viability of the ENPEX Project (among the other ASGA) by stating that these concerns are “over-
3
See generally, Opening Phase 2 Brief of the City of Santee (“Santee Brief”), 4-12.
4
stated.”4 The treatment of the ENPEX Project in the Decisions is troubling.
The Decisions recognize that the projects identified in the FEIR/S’s ASGA serve “as
proxies for a wide range of potential development scenarios,” and because they are proxies, “no
one project in this alternative is essential to the feasibility of the whole of” the ASGA.5 In other
words, the Decisions recognize that the ASGA, including the ENPEX Project, are uncertain
alternatives, and may be substitutes for as-yet-unidentified projects. While acknowledging this
uncertainty, the Decisions also create some uncertainty by stating that the ENPEX Project is not
necessarily infeasible. As support for the ENPEX Project’s potential feasibility, the Decisions cite
to the fact that the ENPEX Project is “in CAISO’s interconnection queue” and lay part of the
blame on “SDG&E’s refusal to sign a power purchase contract with that project’s proponents
despite their lowest cost bid in SDG&E’s solicitation.”6 However, the support offered in the
Decisions for ENPEX’s potential feasible are overstated for three reasons.
First, the significance of ENPEX Project’s place in the California Independent System
would be more knowledgeable about the CAISO interconnection queue and its significance than
CAISO. But, even CAISO’s own expert, Robert Sparks, testified that there are “significant
questions” regarding whether the ENPEX Project will be built – even though the ENPEX Project is
ostensibly in the CAISO queue – and that, under both CAISO and the Commission’s planning
rules, it would not be reasonable to assume that ENPEX could be constructed by 2010, if at all.7
CAISO also stated that for its grid planning purposes, CAISO only considers generation
projects that “are under construction when assessing the need for transmission system additions in
4
PD, 228, Grueneich, APD, 231, and Peevey APD, 240.
5
PD, 221, Grueneich APD, 224, and Peevey APD, 232.
6
PD, 228, Grueneich, APD, 231, and Peevey APD, 240.
7
Direct Testimony of Robert Sparks/CAISO, 4-6.
5
5 year planning cases.”8 (emphasis added.) For 10-year planning cases, CAISO only considers
generation projects that “are under construction or have received regulatory approval.”9
(emphasis added.) Because the ENPEX Project is neither under construction nor received
regulatory approval, for planning purposes the CAISO could not assume that the ENPEX Project
would be online within the next 5-10 years.10 Testimony offered by CAISO indicates that the
interconnection queue has diminished significance in assessing the ENPEX Project’s feasibility,
especially when compared to the project’s other logistical and regulatory hurdles.
Essential to the viability of any generation project of the ENPEX Project’s size is the filing
of the application for certification (“AFC”) with the California Energy Commission (“CEC”).11
There is no indication that the ENPEX Project’s proponent has filed a current AFC with the
CEC.12 However, this critical fact is not mentioned, let alone discussed, in the Decisions. The fact
that no AFC has been submitted for the ENPEX Project is particularly revealing, merits greater
weight, and warrants a detailed discussion regarding the impact upon the ENPEX Project’s
Further, the ENPEX Project was not identified or used by the any of the parties or the
Commission to establish the analytical baseline for in-area fossil resources’ modeling.13 This
omission is significant. It can be inferred, especially given the evidence discussed herein, that the
8
Phase 2 Opening Brief of the California System Operator Corporation, 31-32.
9
Id.
10
Id.
11
Energy Facility Licensing Process, Developers Guide of Practices & Procedures, CEC Staff Report, November
2000, 4. A copy of the staff report can be found at http://www.energy.ca.gov/siting/documents/2000-12-07_700-00-
007.PDF.
12
The California Energy Commission’s Status of All Projects updated on November 19, 2008. A copy of the energy
facility status spreadsheet can be found at http://www.energy.ca.gov/sitingcases/all_projects.html. See also, Draft
EIR/S at E.6-9.
13
PD, 47-48, Grueneich APD, 47-48, and Peevey APD, 53-54.
14
See also infra, II.B, 7.
6
Second, the Decisions seem to pay little heed to the undisputed evidence in the record.15
During the proceeding, SDG&E and CAISO presented evidence that various regulatory approvals
and construction would prevent the ENPEX Project from coming online within the necessary
timeframe.16 The City also presented evidence on the ENPEX Project’s inherent infeasibility.17
This evidence was not contradicted.18 Importantly, the ENPEX Project’s proponents did not
participate in this proceeding and certainly have not disputed the evidence presented by SDG&E,
CAISO or the City with regard to the ENPEX Project. However, the Decisions do not appear to
take the undisputed testimony into account sufficiently, and the City requests that such evidence
with regard to the ENPEX Project be given its proper weight in the Final Decision.
Third, the Decisions state that the ENPEX Project’s biggest hurdle to development is
SDG&E’s refusal to sign a power purchase contract with the ENPEX Project’s proponents. In
support, the Decisions cite to the FEIR/S General Response GR-1.19 But, with regard to this
accusation, General Response GR-1 relies heavily on comments filed by the ENPEX Project’s
sponsor ENPEX Corporation, an entity who was not a party to this proceeding, who did not submit
any testimony or evidence in this proceeding, and who was not subject to the Commission’s Rules
of Practice and Procedure Rule 1.1, which forbids any party from “mislead[ing] the Commission
or its staff by an artifice or false statement of fact or law.”20 By relying so heavily on the FEIR/S’s
General Response GR-1, the Decisions inadvertently give more credibility to comments filed by a
15
PD, 222-224, Grueneich APD, 225-227, and Peevey APD, 233-237.
16
PD, 222-224, Grueneich APD, 225-226, and Peevey APD, 233-236.
17
PD, 225, Grueneich APD, 228, and Peevey APD, 236.
18
PD, 222-224, Grueneich APD, 225-227, and Peevey APD, 233-237.
19
Moreover, the FEIR/S’s General Response GR-1 expressly admits that “the [ENPEX Project] has been under
development by ENPEX [Corporation] since 2000 and [] the development status is unclear.” See FEIR/S, General
Response, GR-1, 2-7. In other words, the FEIR/S admits that even after 8 years of “development,” which ostensibly
refers to the ENPEX’s project’s interconnection queue status, the ENPEX Project’s viability and status remains
“unclear.” The ENPEX Project cannot reasonably be considered feasible.
The Peevey APD also refers to the Draft EIR/S E.6. The City addressed the issues raised in the Draft EIR/S through
its Opening Brief, its comments to the Draft EIR/S and the Re-circulated EIR/S, and through the comments herein.
20
FEIR/S General Response GR-1, p. 2-7.
7
non-party than to undisputed testimony offered by SDG&E, CAISO and the City; all of whom,
when submitting testimony and otherwise participating in the proceeding, were subject to Rule 1.1.
This undisputed testimony indicates that the ENPEX Project is not a reasonably viable project in
The City supports the ommission of the ENPEX Project from the analytical baseline for in-
area fossil resources assumptions in Section 6.7 of the Decisions.21 The City notes that the
ENPEX Project was omitted even though the Decisions expressly acknowledge that it is one of
only “three combined cycle generation facilities proposed for construction in SDG&E’s service
territory,” and the ENPEX Project is purportedly in some stage of development.22 The fact that the
ENPEX Project was omitted from the analytical baseline calculation is telling and further supports
the City’s contention that the ENPEX Project is not realistic in the near future, and should not be
Even though the ENPEX Project was not considered as a part of the analytical baseline and
merely serves as a “proxy” for viable projects, despite the significant environmental impacts posed
by the ENPEX Project and despite recognizing that the ASGA “would greatly increase GHG
impacts compared to Sunrise,” the PD concludes that the FEIR/S is a “comprehensive document”
with adequate and accurate analysis of the environmental impacts of the Sunrise Project and all
alternatives.23 The City does not support the PD’s conclusion and believes that it is not supported
by the record, including testimony submitted by the City. Furthermore, the City believes that the
21
PD, 46-48, Grueneich APD, 47-79, and Peevey APD, 53-55.
22
PD, 27, Grueneich APD, 28, and Peevey APD, 34.
23
PD, 46-48, 170, & 247.
8
PD unnecessarily certifies the FEIR/S, and by implication the ENPEX Project as a component of
the ASGA. If the PD intends to deny the Sunrise Project, the City requests that the PD be
In contrast, the Grueneich APD and Peevey APD finds that the FEIR/S alternatives,
including the ASGA “are not feasible” when considered against other considerations, namely
California’s greenhouse gas reduction goals, and rejects the ASGA.24 Because the Grueneich APD
and Peevey APD finds the ASGA “infeasible,” the City supports both the Grueneich and Peevey
APDs.
IV. CONCLUSION
The City does not have a formal position on the Sunrise Project or the proposed
transmission alternatives. However, the City opposes the inclusion of the ENPEX Project as a
component of the ASGA because, among other issues described more fully above, the ENPEX
Project is not feasible, conflicts with the City’s General Plan, and will cause serious and
unmitigated environmental impact. Despite these significant problems, the Decisions include the
ENPEX Project in the ASGA. The City believes that the undisputed testimony submitted by the
parties to this proceeding, and other relevant factors require the ENPEX Project to be removed
from the ASGA. If the ENPEX Project is kept with the ASGA, then the City recommends
adoption of the Grueneich or Peevey APD as the Final Decision, or the City requests that the PD
24
Grueneich APD, 251, 253, and Peevey APD, 259, 262
9
be modified so that the FEIR/S is not certified.
Respectfully submitted,
RANDALL W. KEEN
S. NANCY WHANG
Manatt, Phelps & Phillips, LLP
11355 West Olympic Boulevard
Los Angeles, California 90064
Tel: (310) 312-4000
Fax: (310) 914-5721
E-mail: rkeen@manatt.com
nwhang@manatt.com
PUCService@manatt.com
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CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing OPENING COMMENTS OF THE CITY
DECISION on all known interested parties of record in A.06-08-010 to each party named in the
official service list via e-mail to those whose email address is listed in the official service list and
via first class mail with postage prepaid to those whose email address is not available.
11
Service List
Podgorsky@wrightlaw.com vprabhakaran@goodinmacbride.com
thompson@wrightlaw.com jeffgray@dwt.com
ssiegel@biologicaldiversity.org dietrichlaw2@earthlink.net
ssiegel@biologicaldiversity.org dkates@sonic.net
sara@calparks.org jsanders@caiso.com
nwhang@manatt.com jdh@eslawfirm.com
sptp@msk.com btorgan@parks.ca.gov
thomas.burhenn@sce.com ktobias@parks.ca.gov
dwood8@cox.net steven@iepa.com
dlindsay@sunbeltpub.com kmills@cfbf.com
mwells@parks.ca.gov elizabeth.klein@lw.com
scotmartin478@msn.com janice.schneider@lw.com
david.lloyd@nrgenergy.com julie.greenisen@lw.com
conniebull@cox.net michael.gergen@lw.com
dj0conklin@earthlink.net kelly@kellyfuller.net
edwrdsgrfx@aol.com Henry.Martinez@ladwp.com
pwhalen2@cox.net randy.howard@ladwp.com
oakhollowranch@wildblue.net cfaber@semprautilities.com
jhfark@pacbell.net rkeen@manatt.com
denis@vitalityweb.com Case.Admin@sce.com
hikermomma1@yahoo.com darell.holmes@sce.com
gbarnes@sempra.com margandona@calwild.org
fortlieb@sandiego.gov donnatisdale@hughes.net
jwalsh@sempra.com mjumper@sdihf.org
mcalabrese@sandiego.gov rebeccap@environmentalhealth.org
shawn.hagerty@bbklaw.com ddowney@nctimes.com
liddell@energyattorney.com jharry.jones@uniontrib.com
mshames@ucan.org patricia_fallon@sbcglobal.net
cadowney@san.rr.com dandbcarey@julianweb.com
ko'beirne@semprautilities.com celloinpines@sbcglobal.net
hpayne3@gmail.com vmp@sbcglobal.net
kritchey@san.rr.com skyword@sbcglobal.net
jleslie@luce.com colobiker@gmail.com
dhogan@biologicaldiversity.org nparinello@gmail.com
sjkeene@iid.com cpuc@92036.com
barbschnier@yahoo.com dwvoss@cox.net
AirSpecial@aol.com WSK@astro.caltech.edu
wblattner@semprautilities.com carolyn.dorroh@cubic.com
mflorio@turn.org jwmitchell@mbartek.com
wolff@smwlaw.com jwmitchell@mbartek.com
map@cpuc.ca.gov soliviasmom@gmail.com
ttf@cpuc.ca.gov oldjulianco@integrity.com
norman.furuta@navy.mil wolfmates@cox.net
bpowers@powersengineering.com Csmmarket@aol.com
jaugustine@biologicaldiversity.org joe@ranchitarealty.com
rcox@pacificenvironment.org cesposit@sdcoe.k12.ca.us
bcragg@goodinmacbride.com bgendron@nethere.com
richard.raushenbush@lw.com kimmerlys@yahoo.com
12
gedrown@mindspring.com phil@auclairconsulting.com
gecko_greens@juno.com editorial@californiaenergycircuit.net
Reneeandbear@aol.com mrw@mrwassoc.com
dan@energysmarthomes.net dmarcus2@sbcglobal.net
deanna.spehn@sen.ca.gov sweissman@law.berkeley.edu
sfr@sandag.org bjolley@herumcrabtree.com
jason.ohta@lw.com kent@wkpalmerton.com
patricia.guerrero@lw.com ziad@zglobal.biz
sierraclubintern@yahoo.com e-recipient@caiso.com
mmitrosky@sierraclubsandiego.org david@branchcomb.com
kmkiener@cox.net PGS@IEEE.org
jimbellelsi@cox.net lonwhouse@waterandenergyconsulting.com
srogers647@aol.com ddfreeman@yahoo.com
usdepic@gmail.com abb@eslawfirm.com
bruce.bigelow@uniontrib.com Audra.Hartmann@Dynegy.com
onell.soto@uniontrib.com Darren.Boutton@gov.ca.gov
gcourser@hotmail.com jreede@energy.state.ca.us
centralfiles@semprautilities.com KMCDO@parks.ca.gov
Irene.stillings@energycenter.org kellie.smith@sen.ca.gov
jennifer.porter@energycenter.org kdw@woodruff-expert-services.com
sabrina.ozturk@sdcounty.ca.gov rlauckhart@globalenergy.com
sephra.ninow@energycenter.org alan.comnes@nrgenergy.com
tblair@sandiego.gov daniel@wildroseenergy.com
Dahvia.Lynch@sdcounty.ca.gov mrx@cpuc.ca.gov
jfirooz@iesnet.com bcb@cpuc.ca.gov
sanrocky@aol.com dhn@cpuc.ca.gov
Thomas_Zale@blm.gov dsh@cpuc.ca.gov
up@undergroundpower.us gxh@cpuc.ca.gov
c@californiabotanicalhabitat.com hmm@cpuc.ca.gov
swilson@pcta.org jjj@cpuc.ca.gov
Lnastro@parks.ca.gov xjv@cpuc.ca.gov
bruce.foster@sce.com jlo@cpuc.ca.gov
Diane.Fellman@fpl.com jmh@cpuc.ca.gov
wolff@smwlaw.com kwh@cpuc.ca.gov
rcox@pacificenvironment.org lau@cpuc.ca.gov
bbirdsall@aspeneg.com ljw@cpuc.ca.gov
dtk5@pge.com mjd@cpuc.ca.gov
jay2@pge.com nms@cpuc.ca.gov
kmsn@pge.com rae@cpuc.ca.gov
mspe@pge.com rwh@cpuc.ca.gov
tmurphy@aspeneg.com wsc@cpuc.ca.gov
Cassandra.sweet@dowjones.com sjl@cpuc.ca.gov
dhuard@manatt.com saw@cpuc.ca.gov
jwoodruff@nextlightrp.com tdp@cpuc.ca.gov
jfieber@flk.com tbo@cpuc.ca.gov
cem@newsdata.com slee@aspeneg.com
regrelcpuccases@pge.com Claufenb@energy.state.ca.us
robin.harrington@fire.ca.gov darren.bouton@gov.ca.gov
joe.paul@dynegy.com mpryor@energy.state.ca.us
hzaininger@aol.com prichins@energy.state.ca.us
13
trf@cpuc.ca.gov
jgrau@energy.state.ca.us
Parties
ARNOLD B. PODGORSKY MICHAEL J. THOMPSON
WRIGHT & TALISMAN, P.C. ATTORNEY AT LAW
1200 G STREET, N.W., SUITE 600 WRIGHT & TALISMAN, PC
WASHINGTON, DC 20005 1200 G STREET, N.W., STE 600
FOR: THE NEVADA HYDRO COMPANY WASHINGTON, DC 20005
FOR: THE NEVADA HYDRO COMPANY
14
RAMONA, CA 92065 MUSSEY GRADE ROAD ALLIANCE
PO BOX 683
RAMONA, CA 92065
15
SAN DIEGO, CA 92131 PO BOX 7745
SAN DIEGO, CA 92167
16
JUDITH B. SANDERS JEFFERY D. HARRIS
ATTORNEY AT LAW ATTORNEY AT LAW
CALIFORNIA INDEPENDENT SYSTEM OPERATOR ELLISON, SCHNEIDER & HARRIS LLP
151 BLUE RAVINE ROAD 2015 H STREET
FOLSOM, CA 95630 SACRAMENTO, CA 95811-3109
KEVIN LYNCH
IBERDROLA RENEWABLES INC
1125 NW COUCH ST., SUITE 700
PORTLAND, OR 97209
Information Only
ELIZABETH KLEIN JANICE SCHNEIDER
LATHAM & WATKINS, LLP LATHAM & WATKINS, LLP
555 11TH STREET NW, STE. 1000 555 11TH STREET NW, STE 1000
WASHINGTON, DC 20004 WASHINGTON, DC 20004
17
ROSEMEAD, CA 91770 ROSEMEAD, CA 91770
18
19412 KIMBALL VALLEY RD. RAMONA, CA 92065
RAMONA, CA 92065
19
SAN DIEGO, CA 92110
BRUCE V. BIEGELOW ONELL SOTO
STAFF WRITER SAN DIEGO UNION TRIBUNE
THE SAN DIEGO UNION TRIBUNE PO BOX 120191
PO BOX 120191S SAN DIEGO, CA 92112-0191
SAN DIEGO, CA 92112-0191 FOR: SAN DIEGO UNION TRIBUNE
20
BRUCE FOSTER DIANE I. FELLMAN
SENIOR VICE PRESIDENT DIRECTOR, REGULATORY AFFAIRS
SOUTHERN CALIFORNIA EDISON COMPANY FPL ENERGY PROJECT MANAGEMENT, INC.
601 VAN NESS AVENUE, STE. 2040 234 VAN NESS AVENUE
SAN FRANCISCO, CA 94102 SAN FRANCISCO, CA 94102
21
3006 SHEFFIELD AVE OAKLAND, CA 94612
OAKLAND, CA 94602
22
DANIEL SUURKASK
WILD ROSE ENERGY SOLUTIONS, INC.
430 8170 50TH STREET
EDMONTON, AB T6B 1E6
CANADA
State Service
MARCUS NIXON BILLIE C. BLANCHARD
CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION
PUBLIC ADVISOR OFFICE ENERGY DIVISION
320 WEST 4TH STREET SUITE 500 AREA 4-A
LOS ANGELES, CA 90013 505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
23
AREA 2-A ROOM 5215
505 VAN NESS AVENUE 505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214
41337604.2
24