A06!08!010 (sunrise) Gea Motion For Party Status 11-20-08
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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of San Diego Gas & Electric Company (U 902 E) for a Certificate of Public Convenience and Necessity for the Sunrise Powerlink Transmission Project.
Application 06-08-010 (Filed August 4, 2006)
MOTION OF THE GEOTHERMAL ENERGY ASSOCIATION FOR PARTY STATUS
November 20, 2008
John McCaull Western States Representative Geothermal Energy Association 538 Broadway, Suite B Sonoma, CA 95476 Telephone: 707/935-6885 Facsimile: 707/935-6885 Email: [email protected]
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of San Diego Gas & Electric Company (U 902 E) for a Certificate of Public Convenience and Necessity for the Sunrise Powerlink Transmission Project.
Application 06-08-010 (Filed August 4, 2006)
MOTION OF THE GEOTHERMAL ENERGY ASSOCIATION FOR PARTY STATUS The Geothermal Energy Association (GEA) respectfully moves for party status in this proceeding, Application (A.) 06-08-010. This Motion is filed pursuant to Rule 1.4 of the Commission’s Rules of Practice and Procedure. 1 I. DESCRIPTION OF THE GEOTHERMAL ENERGY ASSOCIATION The Geothermal Energy Association (GEA) is a trade association composed of companies that support the expanded use of geothermal energy and the development of geothermal resources worldwide for electrical power generation and direct-heat uses. GEA participating companies have offices or operations in many states and in numerous countries throughout the world. To accomplish its goals, GEA advocates for public policies that will promote the development and utilization of geothermal resources. In 2007, GEA opened a Western States office. GEA has been actively involved in regulatory and policy-making proceedings in California related to expansion of renewable energy production, implementation of the
1
Rule 1.4 of the Commission’s Rules of Practice and Procedure permits a person to become a party to a proceeding by, among other things, filing a motion to become a party. A person filing such a motion must disclose the identity of the persons or entities in whose behalf the motion is made and the interest of such persons or entities in the proceeding. The motion must also show that the party’s contentions will be reasonably pertinent to the issues already presented.
renewable portfolio standard, renewable energy transmission planning and the regulatory and public process related to implementation of AB 32 (The Global Warming Solutions Act of 2006).
GEA serves on the Stakeholder Steering Committee of the Renewable Energy
Transmission Initiative and the Technical Committee of the Western Governor’s Association Western Renewable Energy Zone Project. Through these transmission planning processes, GEA has actively represented the interests of its industry members. This experience has also created a direct and growing interest in individual certificate of public convenience and necessity (CPCN) applications, such as this one on the Sunrise Powerlink Project. II. GEA’S INTEREST IN THIS PROCEEDING On October 31, 2008, the Commission mailed a Proposed Decision and an Alternate Proposed Decision in this proceeding.
The Proposed Decision denies San Diego Gas and
Electric Company’s (SDG&E’s) request for a CPCN to build the Sunrise Powerlink Transmission Project (Sunrise). The Alternate Proposed Decision approves the CPCN, but adds conditions to that approval. Specifically, the Alternate Proposed Decision requires SDG&E to file a compliance plan that, among other things, must “specify the renewable generation that will be developed and delivered on Sunrise.” 2 In meeting this condition, SDG&E is required to provide significant detail about these projects, including expected binding commitments, project description, and project construction schedule. 3 Because GEA represents geothermal renewable electric generation producers in the Imperial County area, GEA has a direct interest in these conditions and believes it can provide valuable input through comments and reply comments on the Alternate Proposed Decision and 2 3
Alternative Proposed Decision, Ordering Paragraph 2, at p. 284. Alternative Proposed Decision, Ordering Paragraph 2, subparts (a) – (c), at pp. 284-285.
2
the Proposed Decision and the further rulings and additional Alternate Proposed Decision (President Peevey) that have now been issued in this proceeding. Further, only when this Alternate Proposed Decision was issued and became the subject of an oral argument and an allparty meeting over the last few weeks did the GEA became fully aware of the impact of conditions that may be imposed by the Commission in authorizing the Sunrise Powerlink transmission line. GEA, therefore, seeks party status to provide these written comments and participate on any further all-party meetings or oral argument on these proposed decisions, as well as any and all other related Commission actions and future phases of this proceeding. Because GEA’s interest in this proceeding has emerged as a result of the conditions proposed by the Alternate Proposed Decision, GEA’s motion is timely and its contentions will be reasonably pertinent to the issues already presented in this proceeding. Finally, GEA’s participation in this proceeding will not prejudice any existing party. III. CONTACT INFORMATION On behalf of the GEA, the following name and information should be included in the “Party” portion of the service list for A.06-08-010: John McCaull Western States Representative Geothermal Energy Association 538 Broadway, Suite B Sonoma, CA 95476 Telephone: 707/935-6885 Facsimile: 707/935-6885 Email: [email protected]
3
IV. CONCLUSION The GEA clearly has a pertinent and substantial interest in, and would be affected by, the Proposed Decision and Alternate Proposed Decision mailed in this application on October 31, 2008, and the further Alternate Proposed Decision mailed on November 18, 2008. Until the first Alternate Proposed Decision was issued, the GEA did not know that conditions would be imposed that would directly affect its interests. The GEA has, therefore, timely sought to become a party to this application and respectfully moves the Commission to grant the GEA party status in A.06-08-010 to permit the GEA to submit written comments on these proposed decisions and the further Alternate Proposed Decision and fully participate in all aspects of this proceeding from this date forward. Respectfully submitted, November 20, 2008
/s/
4
JOHN MCCAULL John McCaull Western States Representative Geothermal Energy Association 538 Broadway, Suite B Sonoma, CA 95476 Telephone: 707/935-6885 Facsimile: 707/935-6885 Email: [email protected]
CERTIFICATE OF SERVICE I, John McCaull, am over the age of 18 years and employed in the City of Sonoma, in Sonoma County. My business address is 538 Broadway, Suite B, Sonoma, CA 95476. On November 20, 2008, I served the within document MOTION OF THE GEOTHERMAL ENERGY ASSOCIATION FOR PARTY STATUS, in A.06-08-010 (Sunrise Powerlink), with service on the A.06-08-010 service list in the manner prescribed by the Commission’s Rules of Practice and Procedure and with additional and separate delivery of paper copies by U.S. Mail to Assigned Commissioner Grueneich and Assigned ALJ Vieth, at Sonoma, California. Executed on November 20, 2008, at Sonoma, California.
/s/
JOHN MCCAULL John McCaull
Application 06-08-010 (Filed August 4, 2006)
MOTION OF THE GEOTHERMAL ENERGY ASSOCIATION FOR PARTY STATUS
November 20, 2008
John McCaull Western States Representative Geothermal Energy Association 538 Broadway, Suite B Sonoma, CA 95476 Telephone: 707/935-6885 Facsimile: 707/935-6885 Email: [email protected]
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of San Diego Gas & Electric Company (U 902 E) for a Certificate of Public Convenience and Necessity for the Sunrise Powerlink Transmission Project.
Application 06-08-010 (Filed August 4, 2006)
MOTION OF THE GEOTHERMAL ENERGY ASSOCIATION FOR PARTY STATUS The Geothermal Energy Association (GEA) respectfully moves for party status in this proceeding, Application (A.) 06-08-010. This Motion is filed pursuant to Rule 1.4 of the Commission’s Rules of Practice and Procedure. 1 I. DESCRIPTION OF THE GEOTHERMAL ENERGY ASSOCIATION The Geothermal Energy Association (GEA) is a trade association composed of companies that support the expanded use of geothermal energy and the development of geothermal resources worldwide for electrical power generation and direct-heat uses. GEA participating companies have offices or operations in many states and in numerous countries throughout the world. To accomplish its goals, GEA advocates for public policies that will promote the development and utilization of geothermal resources. In 2007, GEA opened a Western States office. GEA has been actively involved in regulatory and policy-making proceedings in California related to expansion of renewable energy production, implementation of the
1
Rule 1.4 of the Commission’s Rules of Practice and Procedure permits a person to become a party to a proceeding by, among other things, filing a motion to become a party. A person filing such a motion must disclose the identity of the persons or entities in whose behalf the motion is made and the interest of such persons or entities in the proceeding. The motion must also show that the party’s contentions will be reasonably pertinent to the issues already presented.
renewable portfolio standard, renewable energy transmission planning and the regulatory and public process related to implementation of AB 32 (The Global Warming Solutions Act of 2006).
GEA serves on the Stakeholder Steering Committee of the Renewable Energy
Transmission Initiative and the Technical Committee of the Western Governor’s Association Western Renewable Energy Zone Project. Through these transmission planning processes, GEA has actively represented the interests of its industry members. This experience has also created a direct and growing interest in individual certificate of public convenience and necessity (CPCN) applications, such as this one on the Sunrise Powerlink Project. II. GEA’S INTEREST IN THIS PROCEEDING On October 31, 2008, the Commission mailed a Proposed Decision and an Alternate Proposed Decision in this proceeding.
The Proposed Decision denies San Diego Gas and
Electric Company’s (SDG&E’s) request for a CPCN to build the Sunrise Powerlink Transmission Project (Sunrise). The Alternate Proposed Decision approves the CPCN, but adds conditions to that approval. Specifically, the Alternate Proposed Decision requires SDG&E to file a compliance plan that, among other things, must “specify the renewable generation that will be developed and delivered on Sunrise.” 2 In meeting this condition, SDG&E is required to provide significant detail about these projects, including expected binding commitments, project description, and project construction schedule. 3 Because GEA represents geothermal renewable electric generation producers in the Imperial County area, GEA has a direct interest in these conditions and believes it can provide valuable input through comments and reply comments on the Alternate Proposed Decision and 2 3
Alternative Proposed Decision, Ordering Paragraph 2, at p. 284. Alternative Proposed Decision, Ordering Paragraph 2, subparts (a) – (c), at pp. 284-285.
2
the Proposed Decision and the further rulings and additional Alternate Proposed Decision (President Peevey) that have now been issued in this proceeding. Further, only when this Alternate Proposed Decision was issued and became the subject of an oral argument and an allparty meeting over the last few weeks did the GEA became fully aware of the impact of conditions that may be imposed by the Commission in authorizing the Sunrise Powerlink transmission line. GEA, therefore, seeks party status to provide these written comments and participate on any further all-party meetings or oral argument on these proposed decisions, as well as any and all other related Commission actions and future phases of this proceeding. Because GEA’s interest in this proceeding has emerged as a result of the conditions proposed by the Alternate Proposed Decision, GEA’s motion is timely and its contentions will be reasonably pertinent to the issues already presented in this proceeding. Finally, GEA’s participation in this proceeding will not prejudice any existing party. III. CONTACT INFORMATION On behalf of the GEA, the following name and information should be included in the “Party” portion of the service list for A.06-08-010: John McCaull Western States Representative Geothermal Energy Association 538 Broadway, Suite B Sonoma, CA 95476 Telephone: 707/935-6885 Facsimile: 707/935-6885 Email: [email protected]
3
IV. CONCLUSION The GEA clearly has a pertinent and substantial interest in, and would be affected by, the Proposed Decision and Alternate Proposed Decision mailed in this application on October 31, 2008, and the further Alternate Proposed Decision mailed on November 18, 2008. Until the first Alternate Proposed Decision was issued, the GEA did not know that conditions would be imposed that would directly affect its interests. The GEA has, therefore, timely sought to become a party to this application and respectfully moves the Commission to grant the GEA party status in A.06-08-010 to permit the GEA to submit written comments on these proposed decisions and the further Alternate Proposed Decision and fully participate in all aspects of this proceeding from this date forward. Respectfully submitted, November 20, 2008
/s/
4
JOHN MCCAULL John McCaull Western States Representative Geothermal Energy Association 538 Broadway, Suite B Sonoma, CA 95476 Telephone: 707/935-6885 Facsimile: 707/935-6885 Email: [email protected]
CERTIFICATE OF SERVICE I, John McCaull, am over the age of 18 years and employed in the City of Sonoma, in Sonoma County. My business address is 538 Broadway, Suite B, Sonoma, CA 95476. On November 20, 2008, I served the within document MOTION OF THE GEOTHERMAL ENERGY ASSOCIATION FOR PARTY STATUS, in A.06-08-010 (Sunrise Powerlink), with service on the A.06-08-010 service list in the manner prescribed by the Commission’s Rules of Practice and Procedure and with additional and separate delivery of paper copies by U.S. Mail to Assigned Commissioner Grueneich and Assigned ALJ Vieth, at Sonoma, California. Executed on November 20, 2008, at Sonoma, California.
/s/
JOHN MCCAULL John McCaull
