BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 1139
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          Date of Hearing:   June 23, 2014

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
                     SB 1139 (Hueso) - As Amended:  May 27, 2014

           SENATE VOTE  :   21-11
           
          SUBJECT  :   Energy: California Renewables Portfolio Standard  
          Program

           SUMMARY  :   Mandates that retail sellers procure a proportionate  
          share of a statewide total of 500 megawatts of electricity  
          generated by baseload geothermal powerplants constructed after  
          January 1, 2015. Specifically,  this bill  :   

          1)Stipulates that no later than June 30, 2015, the California  
            Energy Commission (CEC) shall determine the proportionate  
            share of the 500 megawatts of electricity that each retail  
            seller is required to procure based on the forecast of retail  
            sales for the year 2018.

          2)Requires that no later than January 1, 2016, each retail  
            seller shall file with the California Public Utilities  
            Commission (PUC) a plan for complying with the mandate. 

          3)Specifies that plans shall require each retail seller to  
            procure at least one-half of its proportionate share by  
            December 31, 2019 and the full allotment by December 31, 2024.  
            Plans may authorize a retail seller to aggregate its  
            proportionate share with the proportionate share of another  
            retail seller in order to minimize administrative and  
            contracting costs.

          4)States that CEC shall review and approve, modify, or reject  
            plans filed by retail sellers.

          5)States that electricity procured pursuant to this mandate  
            shall not count toward meeting the requirements of the  
            California Renewable Portfolio Standard (RPS).

          6)Stipulates that electricity procured pursuant to this mandate  
            shall be procured to reasonably minimize costs.

           EXISTING LAW  :








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          a)Requires that all rates for any service or product charged by  
            an electrical corporation be just and reasonable. (Public  
            Utilities Code � 451)

          b)Establishes short-term and long-term goals electricity  
            procurement guidelines for electrical corporations which are  
            filed with the PUC for approval. (Public Utilities Code  
            �454.5)

          c)Requires, pursuant to the California Renewables Portfolio  
            Standard, requires investor-owned utilities (IOUs), community  
            choice aggregators (CCAs), and energy service providers (ESPs)  
            (collectively defined as retail sellers), and publicly-owned  
            utilities (POUs), to increase purchases of renewable energy  
            such that at least 33% of total retail sales are procured from  
            renewable energy resources by December 31, 2020. In the  
            interim each entity would be required to procure an average of  
            20% of renewable energy for the period of January 1, 2011  
            through December 31, 2013 and 25% by December 31, 2016.  
            (Public Utilities Code � 399.11 et seq.)

          d)Defines as RPS eligible, electric generation resources from  
            biomass, solar thermal, photovoltaic, wind, geothermal, fuel  
            cells using renewable fuels, small hydroelectric generation of  
            30 megawatts (MWs) or less, digester gas, landfill gas, ocean  
            wave, ocean thermal, tidal current, and municipal solid waste  
            conversion that uses a non-combustion thermal process to  
            convert solid waste to a clean-burning fuel.  (Public  
            Resources Code � 25741)

          e)Establishes the Geothermal Resources Development Account into  
            which federal revenues are deposited to fund grants to  
            eligible local jurisdictions and private entities for projects  
            and activities that promote development geothermal energy  
            resources, mitigate any adverse impacts caused by geothermal  
            development, or help local jurisdictions offset the costs of  
            providing public services necessitated by geothermal  
            development. (Public Resources Code � 3800 et seq.)

          FISCAL EFFECT  :   Unknown.

           COMMENTS  :   According to the author, "geothermal is a renewable,  
          abundant and affordable source of clean energy.  Increasing  
          reliance on this power source will help our state reach its goal  








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          of reducing greenhouse gas emissions while securing grid  
          reliability. 

          For economically depressed regions throughout our great state,  
          this energy policy translates into hundreds of high paying jobs  
          and investments toward meaningful economic development. SB 1139  
          has the potential to generate over $38M per year in revenue to  
          assist our local communities. Furthermore, one of the mineral  
          byproducts of geothermal brine, which is lithium, creates an  
          indigenous resource, opening new market opportunities and paving  
          the way for a low-carbon future. 

          All of these benefits, resilience, and reliability to our  
          current energy system for a small procurement of less than 1% of  
          the current energy portfolio. This bill creates the kind of  
          smart development we desperately need in California to produce  
          new skilled construction and operation jobs, hedge against fuel  
          price increases and reduce greenhouse gas and fossil fuel  
          emissions."

           1)Background  : Geothermal energy is thermal energy generated and  
            stored in the Earth. It is a clean, renewable resource that  
            provides energy in the United States and around the world  
            through a variety of applications and types of resources.  
            Large-scale geothermal plants utilizing deep resource  
            temperatures between ~200F and 700F have been producing  
            commercial power in the United States since the 1960s.  
            California has 25 Known Geothermal Resource Areas (KGRAs), 14  
            of which have temperatures of 300 degrees Fahrenheit or  
            greater. 

            Electricity can be generated from high temperature geothermal  
            resources by using the thermal (heated) water and steam to  
            move turbines that in turn run electrical generators and  
            produce electricity. There are several types of geothermal  
            power plants that can be used to generate electricity,  
            including dry steam, flash or double flash, and binary cycle  
            power plants.

            The most developed of the high-temperature geothermal resource  
            areas in the state is the Geysers. Located north of San  
            Francisco, the Geysers was first tapped as a geothermal  
            resource to generate electricity in 1960. It is one of only  
            two locations in the world where a high-temperature, dry steam  
            resource is found that can be directly used to move turbines  








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            and generate electricity.

            Other major geothermal electrical production locations in the  
            state include the Salton Sea area in Imperial County, the Coso  
            Hot Springs area in Inyo County, and the Mammoth Lakes area in  
            Mono County. It is estimated that the state has a potential  
            for more than 4,000 megawatts of additional power from  
            geothermal energy, using current technologies. 

           2)Geothermal projects in California  : According to the CEC's  
            website, in-state electric generation has not grown. In fact,  
            between 2001 and 2013 generation averaged 13,000 gigawatt  
            hours. As of 2013, generation was estimated at 12,485 gigawatt  
            hours.  Installed in-state generation capacity for geothermal  
            over the same time period ranged between 2,600 - 2,700  
            megawatts.
                
             The PUC's analysis notes a report from the Geothermal Energy  
            Association which includes data on the quantity and capacity  
            of geothermal projects (on the supply-side) under development  
            in California. The report indicates there are approximately 31  
            geothermal projects under development for a total capacity of  
            an estimated 1,100 megawatts.  It is unknown when these  
            projects will be completed and fully operational.

            By the end of 2013, an estimated 17,400 MWs of RPS-eligible  
            renewable energy capacity were operating in California of  
            which approximately 15,500 MWs were sold to a utility or the  
            market (wholesale) and an additional 1,900 MWs was  
            self-generation.  Of the 15,500 MWs of wholesale generation,  
            46 projects are geothermal resources and represent 2,782 MWs  
            of capacity which is 4.4% of generation capacity. However,  
            geothermal produces approximately 25% of the renewable  
            electricity supplied to California retail customers.  

               The distribution of the 46 online projects which serve  
               California load is:  

                        Imperial County, 20 projects; 705 MWs;
                        Inyo County, 3 projects; 302 MWs;
                        Lake County, 6 projects; 418 MWs;
                        Mono County, 4 projects; 54 MWs;
                        Sonoma County, 12 projects; 1,238 MWs; and
                        State of Nevada, 1 project; 65 MWs.









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               Projects under development include eight projects totaling  
               618 MWs have received environmental permits but are not yet  
               operational.

            This bill does not allow existing geothermal resources to  
            count toward the 500MW procurement mandate. Calpine  
            Corporation, owner and operator of 725 MW at The Geysers  
            (geothermal energy resource located in Lake and Sonoma  
            Counties) claims this measure jeopardizes its ability to  
            recontract approximately 650 MW of existing geothermal  
            capacity due to expire between 2017 and 2021.  Furthermore,  
            Calpine notes that it has made investments to develop and  
            permit two geothermal projects at The Geysers with project  
            labor agreements for each.

           3)Programs that promote specific renewable technologies : This  
            bill mandates that no later than December 31, 2024, the IOUs  
            procure a proportionate share of a statewide total of 500 MW  
            of electricity generated by baseload geothermal powerplants  
            constructed after January 1, 2015.  Opponents to this measure  
            argue that it is bad public policy to mandate procurement of a  
            preferred renewable resource.  However, there are many  
            "carve-out" programs for certain renewable technologies  
            created by the Legislature.  These policies were envisioned to  
            incentivize market transformation for emerging technologies  
            where ratepayer funds may return long-term benefits to all  
            Californian's. The CPUC's analysis notes that geothermal  
            technology, on the other hand, has been commercially available  
            for decades and may not reasonably be considered an emerging  
            technology. See information below detailing the many  
            "carve-out" programs for specific renewable technologies:

                     Self-Generation Incentive Program (SGIP) provides  
                 financial incentives for customer installation of energy  
                 storage devices, wind turbines, fuel cells, combined heat  
                 power generators, pressure reduction turbines, and waste  
                 heat capture applications. Incentives are paid for up to  
                 3 megawatts of capacity.  Approximately 483 projects  
                 totaling 1,583 megawatts have been developed to date in  
                 this program. 
                 Authorized capacity is based on available funding. (AB  
                 970, Ducheny, 2000)

                     California Solar Initiative (CSI) provides  
                 California's electric utility customers incentives for  








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                 on-site solar electric systems on homes, businesses and  
                 public sites.  Since its creation, 135,588 projects  
                 totaling 1,500 megawatts have been developed. Authorized  
                 capacity is 3,000 MW. (SB 1, Murray, 2006)

                     Community Renewable Program provides mechanism where  
                 customers can procure renewable generation for their home  
                 or business. Authorized capacity is 600 MW. Most of this  
                 will not count toward the investor-owned utilities (IOUs)  
                 RPS requirements. (SB 43, Wolk, 2013)

                     The Energy Storage Procurement Framework and Design  
                 Program adopted in October 2013 requires 1,325 megawatts  
                 of storage to be procured by the IOUs by 2020 with  
                 installations no later than 2024. Storage itself is not  
                 explicitly a renewable technology, but it could be  
                 combined with renewable technologies. (AB 2514, Skinner,  
                 2009)

                     The Bioenergy Feed-in Tariff program requires the  
                 IOUs to procure a combined total of 250 megawatts from  
                 bioenergy projects. Procurement must be from projects  
                 that are 3 megawatts or smaller that achieve operation  
                 after June 1, 2013. No projects have been developed to  
                 date. (SB 1122, Rubio, 2011)

                     Combined Heat and Power (CHP), referred to as  
                 cogeneration, is the simultaneous generation of useful  
                 heat and electricity from a single fuel source. Two  
                 projects, for a combined total of 103.68 megawatts have  
                 been developed thus far. Authorized capacity is 3,000 MW.  
                 (AB 1613, Blakeslee, 2009)

                     The Feed-in tariff (FiT)/Renewable Market Adjusting  
                 Tariff (Re-MAT) program is a simplified procurement  
                 mechanism for small renewable generators (3 megawatts or  
                 less) to sell power to a utility at predefined terms and  
                 conditions. This program applies to the IOUs. The first  
                 program period of FiT/ReMAT program began in October  
                 2013. No projects have been developed to date.   
                 Authorized capacity is 500 MW. (SB 32, Negrete-McLeod,  
                 2009)

                     The Renewable Auction Mechanism (RAM) is a  
                 simplified market-based procurement mechanism for  








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                 renewable generation projects greater than 3 MW and up to  
                 20 MW.  The program requires PG&E, SCE, and SDG&E to  
                 procure a combined total of 1,330 MW of renewable energy  
                 over a three year period.  The first RAM auction  
                 contracts were approved in April 2012.  No projects have  
                 been developed to date. Authorized capacity is 1,000 MW  
                 (CPUC Decision D.10-12-048)

                     IOUs are required to offer Net Energy Metering until  
                 they reach a cap of 5% of the electrical corporations'  
                 peak capacity. NEM projects are also exempt from  
                 interconnection studies and costs.

           1)Race to achieve 33% RPS: Utilities Report Card:  Due to the RPS  
            and prices for renewable generation that are increasingly  
            competitive with natural gas generation, renewable  
            technologies are providing much larger amounts of electricity  
            in California. However, due to the performance characteristics  
            of the technologies, heavy reliance on intermittent and  
            variable renewable resources (wind energy is available when  
            the wind blows and solar energy is available when the sun  
            shines) must be balanced with generation and/or storage. The  
            majority of RPS procurement has been intermittent and variable  
            renewable resources.  
                
            The PUC Legislative analysis notes that since the inception of  
            the RPS program, the IOUs have contracted for 390 megawatts  
            with new geothermal capacity located within California. Of the  
            390 megawatts, one 50 megawatt project achieved commercial  
            operation, one 30 megawatt project is delayed in meeting its  
            commercial operation date, and nine contracts totaling 310  
            megawatts of project capacity have been terminated. 
                
             The table below is based on data reported by Pacific Gas &  
            Electric Company (PG&E), San Diego Gas & Electric Company  
            (SDG&E), and Southern California Edison (SCE) in the most  
            recent compliance reports. With forecasts extended out to  
            2020, the data for all three large IOUs generally show a large  
            shift toward solar PV and wind, with a corresponding decrease  
            in geothermal and biopower. SDG&E shows the most dramatic  
            trend from 2011 to 2020, with a large shift from 0.1% solar PV  
            to 51.9%, and a decrease in geothermal from 23.2% to 0%. The  
            other IOUs display similar, although not as dramatic trends.

            The percentages below represent the percentage of  








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            megawatt-hours, by technology each utility has contracted with  
            to meet RPS goals. The data shows that by 2020 the IOUs  
            estimated they will procure geothermal resources at half of  
            today's levels.



             
           

             ---------------------------------------------------------------- 
            |       RPS Procurement: August 1, 2013 Compliance Reports       |
             ---------------------------------------------------------------- 
             --------------------------------------------------------------- 
            |           |      PG&E       |     SDG&E      |      SCE       |
             --------------------------------------------------------------- 
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Energy   |  2011   |  2012   |  2020   |  2011   |  2012   |  2020   |  2011   |  2012   |  2020   |
            |source   |         |         |         |         |         |         |         |         |         |
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Biopower |  24.4%  |  23.9%  |  11.1%  |  16.8%  |  25.0%  |  2.8%   |  5.5%   |  4.1%   |  0.5%   |
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Geotherma|   25%   |  26.0%  |  10.2%  |  23.2%  |  28.1%  |  0.0%   |  46.8%  |  43.4%  |   20%   |
            |l        |         |         |         |         |         |         |         |         |         |
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Small    |  18.2%  |  12.4%  |  9.2%   |  0.0%   |  0.0%   |  0.3%   |  5.1%   |  3.2%   |  3.3%   |
            |Hydro    |         |         |         |         |         |         |         |         |         |
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Conduit  |  0.0%   |  0.0%   |  0.0%   |  0.5%   |  0.6%   |  0.1%   |  0.8%   |  1.0%   |  0.5%   |
            |Hydro    |         |         |         |         |         |         |         |         |         |
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Solar    |  1.4%   |  8.0%   |  33.4%  |  0.1%   |  0.1%   |  51.9%  |  0.7%   |  1.1%   |  33.1%  |
            |Photovolt|         |         |         |         |         |         |         |         |         |
            |aic      |         |         |         |         |         |         |         |         |         |
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Solar    |  0.0%   |  0.0%   |  14.4%  |  0.0%   |  0.0%   |  0.0%   |  5.7%   |  5.8%   |  3.2%   |
            |Thermal  |         |         |         |         |         |         |         |         |         |
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Wind     |  31.0%  |  29.7%  |  21.8%  |  59.4%  |  46.2%  |  44.9%  |  35.4%  |  41.5%  |  39.5%  |
             --------------------------------------------------------------------------------------------------- 
            |Ocean/Tid|  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |
            |al       |         |         |         |         |         |         |         |         |         |
            |---------+---------+---------+---------+---------+---------+---------+---------+---------+---------|
            |Fuel     |  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |  0.0%   |0.0%     |
            |Cells    |         |         |         |         |         |         |         |         |         |








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             --------------------------------------------------------------------------------------------------- 
             
          2)Is there a need for more baseload power  ? Proponents of this  
            bill argue that California could benefit from the additional  
            procurement of new geothermal power as it supplies the state  
            with baseload renewable power.  Recent events such as the  
            retirement of the San Onofre Nuclear Generating Station  
            (SONGS) and Once Through Cooling (OTC) Power Plants, and older  
            inland gas plants create a need for more energy supply and  
            reliability in the state - particularly Southern California  
            region. Retirement of these projects may create the need to  
            replace this generation in order to manage the state's energy  
            demands. However, geothermal facilities may not be located in  
            areas where transmission can provide power into the area  
            affected by the SONGs and OTC closures.

               According to May 19, 2014 letter replying to a protest of  
               Southern California Edison's RPS portfolio, SCE stated:

                    SCE is genuinely and justifiably concerned that in  
                    2020, SCE will not have enough baseload generation to  
                    manage the increasing amounts of intermittent  
                    renewable generation provided by wind and solar."

           3)Geothermal costs in comparison to other renewable  
            technologies  : According to the CPUC Legislative analysis, for  
            geothermal projects approved since 2003 pursuant to the RPS  
            program, the weighted average post-time of delivery (TOD)  
            adjusted price is $8.84 cents per megawatt hour. The weighted  
            average post-TOD adjust price paid by the three IOUs in 2013  
            was 7.03 cents/kilowatthour.

            Recent market data from the IOUs 2013 RPS solicitation shows a  
            significant difference in the average price for contracts  
            offered to the IOUs across technologies. Particularly, the  
            average price for a new solar photovoltaic project was  
            approximately $73 per megawatt hour compared to the average  
            price for a new geothermal project of approximately  
            155/Megawatt-hour.  One geothermal developer claims the PUC's  
            evaluation process fails to properly take into account the  
            benefits and costs of all fuels (renewables and gas).  It has  
            a bid under consideration between $0.09 and $0.10 per kWh.

            Even with the high upfront capital costs, proponents of this  
            measure argue that geothermal is a competitive renewable  








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            energy source that essentially generates around the clock.  A  
            contributing factor to this price difference may be that the  
            CPUC mandates a value of zero for any costs related to  
            integrating renewable resources to the grid.

           4)Opportunities for geothermal development  : The author and  
            sponsors claim roughly 50 percent of California's identified  
            geothermal resources are not being utilized. The Salton Sea  
            Known Geothermal Resource Area (SSKGRA), in particular,  
            provides one of the greatest opportunities for geothermal  
            energy development in the United States.  According to the  
            Geothermal Energy Association, the Imperial Irrigation  
            District forecasts estimate 2,900 megawatts of geothermal  
            generation are ultimately possible at the Salton Sea field.   
            Other regions of the state show promise as well, particularly  
            in Northern California.

           5)If you build it, they will come  : Parties opposed to the  
            measure claim there are deliverability barriers for  
            transmitting geothermal resources from Imperial Valley to the  
            Los Angeles basin. According to Imperial Irrigation District  
            (IID), its system can accommodate the exportation of 200 MW of  
            renewable resources should a project be ready to go on-line  
            today. For a mid-term outlook, IID Path 42 upgrades are  
            underway and are scheduled to be completed by May 2015 which  
            will increase the transmission deliverability from IID to the  
            California Independent System Operator (CAISO) by 900MW. In  
            addition, IID claims it is currently in the process of  
            implementing its Strategic Transmission Expansion Plan (STEP)  
            that will increase the deliverability of energy from IID to  
            CAISO at the Imperial Valley substation by another 800 MW by  
            the end of 2018. The first phase of IID's STEP will also  
            include a 184 mile 500 kV DC line running from the Salton Sea  
            allowing for export of an additional 1,100 MW between 2021 and  
            2024, if approved by CAISO.

           6)If you don't plan for it, it won't get built.  Geothermal  
            developers complain that if the procurement process precludes  
            consideration of geothermal then the state has effectively  
            decided that it will not procure from geothermal resources.

          7)Mandate should count toward RPS goals  : This bill would exclude  
            procurement from these new geothermal facilities from counting  
            toward the state's RPS program. However, geothermal is an  
            RPS-eligible resource and procurement of this resource should  








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            count towards the state's RPS mandate.  This is inconsistent  
            with existing state policy.  Therefore,  the committee may wish  
            to amend the bill to authorize the PUC to determine whether  
            the procurement mandate should count toward the RPS program  .  

           8)Cost containment provisions are missing from this bill  : There  
            is a potential that mandated generation would undermine  
            competitive bidding in the procurement process. The PUC is  
            currently conducting a proceeding to establish cost  
            containment for generation procured through the RPS program.  
            Therefore,  the committee may wish to add a provision in the  
            findings and declaration section expressing the intent that  
            the Legislature would agree if the PUC imposed the same RPS  
            cost containment for geothermal procurement pursuant to this  
            statute.
                
           9)Support and opposition.  Supporters state development of 500 MW  
            of geothermal power will deliver numerous benefits to  
            California, including a reduction in greenhouse gas emissions  
            without negatively impacting system reliability. Further  
            argued is that the expansion of geothermal will "create tens  
            of thousands of high-paying construction jobs in area [sic] of  
            the state suffering from some of the highest rates of  
            employment", and that the plants will generate millions in tax  
            revenues and lease payments. Other supporters claim this bill  
            will provide greater balance to the state's energy portfolio  
            by increasing renewable base load generation.  
           
            Opponents argue that this bill burdens ratepayers with high  
            energy costs relative to the market, disregards current  
            renewable energy policy, ignores a competitive solicitation  
            process, and unevenly applies a statewide policy. Others claim  
            it would allow geothermal developers to bypass market  
            competition, and thus adversely impact the ability for  
            California to meet its renewable energy goals while ensuring  
            just and reasonable rates. Yet others state that requirements  
            in the bill would be costly and almost impossible to  
            implement.
                
           
          REGISTERED SUPPORT / OPPOSITION:

           Support 
           
          Audubon California








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          Calexico Chamber of Commerce Board of Directors
          California Chapters of the National Electrical Contractors  
          Association (NECA)
          California Coalition of Utility Employees (CCUE)
          California Labor Federation
          California Legislative Conference of the Plumbing, Heating and  
          Piping Industry (CLC)
          California State Association of Electrical Workers
          California State Council of Laborers
          California State Pipe Trades Council
          Calipatria Chamber of Commerce
          Center for Energy Sustainability at San Diego State's  
          University's Imperial Valley Campus
          City of Holtville
          Coachella Valley Water District (CVWD)
          Defenders of Wildlife
          Geothermal Energy Association
          Geothermal Resources Council (GRC)
          GreenFire Energy, Inc.
          Imperial County Board of Supervisors
          Imperial County Building Construction Trades Council
          Imperial County Workforce Development Office
          Imperial Irrigation District (IID)
          Imperial Valley Economic Development Corporation (IVEDC)
          Imperial Valley Small Business Development Center
          Individual Letters (5)
          LightSource Renewables
          MidAmerican Geothermal
          MidAmerican Renewables
          Nature Conservancy
          Ormat
          Salton Sea Action Committee
          Salton Sea Authority
          Simbol Materials
          State Building and Construction Trades Council, AFL-CIO
          Western Line Constructors
          Western States Council of Sheet Metal Workers

           Opposition 
           
          California Biomass Energy Alliance California (CBEA) (unless  
          amended)
          California Chamber of Commerce 
          California Manufacturers & Technology Association (CMTA)
          California Public Utilities Commission (CPUC) (unless amended)








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          Calpine Corporation (unless amended)
          EDF Renewable Energy 
          Independent Energy Producers Association (IEP)
          Office of Ratepayer Advocates (ORA)
          Pacific Gas and Electric Company (PG&E)
          PacifiCorp (unless amended)
          San Diego Gas & Electric Company (SDG&E) (unless amended)
          Southern California Edison (SCE)
          The Utility Reform Network (TURN)



           Analysis Prepared by  :    DaVina Flemings / U. & C. / (916)  
          319-2083