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 & Necessity for the Sunrise Powerlink Transmission Project ) ) ) ) ) ) ) ) Application No. 06-08-010 (Filed August 4, 2006)

RANCHO PEÑASQUITOS CONCERNED CITIZENS’ COMMENTS TO COMMISSIONER GRUENEICH’S ALTERNATIVE PROPOSED DECISION

Harvey Payne Rancho Penasquitos Concerned Citizens 13355 Midland Road, Ste. 140 San Diego, CA 92064 Telephone: 858-391-1017 Fax: 858-513-7569 E-mail: hpayne3@gmail.com

Dated: November 20, 2008

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TABLE OF CONTENTS & SUBJECT INDEX
I. II. INTRODUCTION………………………………………………………………………….. 3 NATURE AND EXTENT OF THE COASTAL LINK SYSTEM UPGRADES……...... 3 Recommended Change: The description of the Coastal link system upgrades needs to clarify whether the Encina transformer is part of the upgrades SDG&E is to install. Recommended Change: A findings of fact paragraph needs to be added to clarify that the scope of the Coastal link transmission upgrades does not include a Poway – Pomerado reconductoring. III. COSTS ASSOCIATED WITH THE COASTAL LINK…………………………………. 6 Recommended Change: The costs associated with the coastal link need to accurately reflect the updated (lower) costs to reconductor the Sycamore – Pomerado circuits and the Sycamore – Scripps circuit. IV. CONCLUSION……………………………………………………………………………... 12 APPENDIX OF PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW……. 14 TABLE OF AUTHORITIES (none cited)

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I.

INTRODUCTION Rancho Penasquitos Concerned Citizens (RPCC) submits the following comments to

Commissioner Grueneich’s Alternative Proposed Decision (GAPD). RPCC is grateful that the GAPD recognized that the Coastal link system upgrades proposed by RPCC would save ratepayers a significant amount of money and would also significantly lessen the environmental impacts, not to mention the impact on the communities the Coastal link was scheduled to traverse. There are, however, two important issues surrounding the Coastal link that need clarification so that a final decision on implementing the Coastal link system upgrades provides clear direction to SDG&E on how to implement the upgrades and what the costs are. Therefore, RPCC focuses its comments on two issues: 1. Clarifying the nature and extent of the Coastal link system upgrades; and 2. Determining the proper cost associated with the Coastal link so as to make sure the total cost cap for the entire project is accurate. RPCC will explain in detail below why there are ambiguities existing concerning these issues and how this Commission can clear up these ambiguities in a final decision.

II.

NATURE AND EXTENT OF THE COASTAL LINK SYSTEM UPGRADES At page 91 of the GAPD, the GAPD adopts RPCC’s alternative, as defined in RPCC’s

Phase II reply brief. RPCC’s Phase II reply brief describes RPCC’s Coastal link system upgrades as follows: 1. Installation of an additional 230/69 kV, 224MVA transformer at Sycamore Canyon substation with associated substation upgrades; 3

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Re-conductor both 69 kV circuits of the Sycamore – Pomerado transmission line; Re-conductor the 69kV circuit of the Sycamore – Scripps transmission line, but only if this Commission finds it prudent for SDG&E to have cancelled another transmission project between phases I and II of these proceedings which resulted in the need to re-conductor the Sycamore – Scripps transmission line; and

4.

Either the installation of a 230/138 kV, 392 MVA transformer at Encina, but only if the CAISO will not approve a remedial action scheme designed to bring up Encina generation to solve overloads on the Sycamore – Chicarita 138 kV transmission line under CAISO Planning Standards criteria.”

Recall that SDG&E unilaterally changed the scope of RPCC’s proposed system upgrades between phase I and phase II when SDG&E updated its power flow topology after phase I. The updated topology included two projects that had an impact on RPCC’s alternative. One project eliminated the necessity of re-conductoring the Poway – Pomerado 69 kV transmission line. The re-conductoring of the Poway - Pomerado line was originally within the scope of RPCC’s Phase I system upgrades. 1 The second project that had an impact was actually the cancellation of a project that had been previously approved by the CAISO (a second Sycamore – Miramar 69 kV line). As a result of this project being cancelled, SDG&E claimed that a new line now overloaded under CAISO reliability criteria with RPCC’s Coastal link system upgrades (Sycamore – Scripps 69 kV). Therefore, SDG&E added the Sycamore – Scripps re-conductor into RPCC’s alternative and

1

As a result, the DEIR studied the re-conductoring of this line.

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took out the Poway – Pomerado line from RPCC’s alternative within Phase II of the Sunrise hearings. 2 RPCC took issue with SDG&E cancelling the second Sycamore to Miramar 69 kV project between phase I and phase II, which resulted in a line that was now “chargeable” to the cost of RPCC’s alternative. That is why RPCC wrote that the Commission should decide whether it was prudent for SDG&E to have cancelled this project. Now that the GAPD has adopted RPCC’s transmission system upgrade alternative, the importance of the additional costs being charged to RPCC versus SDG&E is of no consequence. The analysis shows the Sycamore – Scripps line needs to be re-conductored. RPCC has never argued the power flow analysis shows otherwise. However, the background on this issue and the importance of this discussion will become more evident when the cost of the Sycamore - Scripps line is discussed below. The portion of RPCC’s alternative that does require further clarification is: 4. Either the installation of a 230/138 kV, 392 MVA transformer at Encina, but only

if the CAISO will not approve a remedial action scheme designed to bring up Encina generation to solve overloads on the Sycamore – Chicarita 138 kV transmission line under CAISO Planning Standards criteria.” This is a $33,834,105 issue to ratepayers, and it is unclear how much attention this specific issue has been given within the grand scheme of things. SDG&E estimates the cost to install a new 230/138 kV transformer at Encina to be $33,834,105. 3 On the other hand, the costs of implementing a remedial action scheme to bring up Encina generation to solve CAISO criteria violation on the Sycamore – Chicarita 138kV transmission line, are slight. This issue appears

2

See the transcript beginning at p. 4653:7 for the discussion of the changes unilaterally made by SDG&E between phase I and phase II. 3 See Ex. SD-33C or SD-35, Attachment 3-5.

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throughout the record and was briefed by RPCC and SDG&E in both Phase I and Phase II. It is unclear from the GAPD whether the GAPD is adopting the installation of a new transformer. The GAPD simply states it is adopting RPCC’s Coastal link system upgrades as defined within RPCC’s phase II Reply brief. However, as to this issue, RPCC left the $33.8 million dollar decision within the Commission’s hands. At footnote 265, the GAPD references this issue, but does not otherwise make an explicit decision. Implicitly, the GAPD adopts the installation of a transformer because the costs associated with RPCC’s alternative ($84 million) include the installation of the $34 million dollar transformer. RPCC believes the final decision should be clear on the issue of whether the RPCC system upgrade includes a new transformer at Encina or not. Lastly, on the issue of scope, the GAPD at paragraph number one of the Order states that the CPCN is granted to build the transmission line along the FEIR Superior Southern Route. The FEIR Superior Southern Route evaluated RPCC’s Coastal link system upgrades, but at some locations and/or maps within the FEIR, appears to have mistakenly left the Poway – Pomerado 69 kV line in as part of the analysis/description. 4 Because of this oversight, and because the FEIR does not always consistently describe the Coastal link system upgrades, the a finding of fact paragraph needs to be added to address any confusion that could come about by simply relying on the FEIR description of the route as the scope of what SDG&E would be building.

III.

COSTS ASSOCIATED WITH THE COASTAL LINK The GAPD uses the Compliance Exhibit at p.9 to calculate the appropriate costs to the

project for the adoption of the Coastal link system upgrades. 5 The $84 million in costs

4

In general, the FEIR is not consistent in describing the scope of the Coastal link system upgrades, but what is clear is that the analysis of each component of the system upgrades was analyzed. 5 GAPD at p.270, footnote 706.

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associated with RPCC’s system upgrades was derived from Attachment 3-5 of SDG&E’s Phase II testimony. The $84 million includes $34 million for the Encina transformer. The $84 million also includes the costs to re-conductor the Sycamore – Pomerado 69 kV circuits and the costs to re-conductor the Sycamore – Scripps 69 kV circuit, as well as a new 230/69 kV transformer at Sycamore Canyon. At issue is the fact that SDG&E dramatically altered the scope of the work that would be necessary to re-conductor these two lines after the close of Phase II evidence. Since then, SDG&E has never been forthcoming with the new costs. This issue was briefed extensively within RPCC’s Phase II reply brief. Most of this briefing is reiterated below because it is directly on point: “Not surprisingly, SDG&E spends no time discussing the costs of their proposed Coastal link as compared to RPCC’s alternative. Within SDG&E’s single paragraph within this subsection, SDG&E notes that RPCC’s alternative would cost approximately $84 million, per Exhibit SD-35, Attachment 3-5 to SDG&E’s direct testimony. What SDG&E did not tell this Commission, or RPCC for that matter, within SDG&E’s Phase II brief, is that SDG&E has changed the scope of work required for both the Sycamore – Scripps 69 kV re-conductor and the Sycamore – Pomerado 69 kV double circuit re-conductor, after Phase II hearings were completed. The changes are so dramatic, that the costs must have also changed dramatically. SDG&E, however, provides no new costs and fails to even point out this important development since the close of Phase II hearings, despite providing this information to the Energy Division one week before Opening briefs were due. Since the cost estimate changes are estimated to be heavily weighted in RPCC’s favor, the integrity of the information SDG&E has provided within these proceedings continues to be questionable.

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The changes to the scope of work necessary to effectuate the re-conductoring of these lines are the result of the Energy Division and their consultants inquiring into the unilateral change to RPCC’s alternative that SDG&E made after the DEIR was released (between Phase I and Phase II), which added a completely new line to be re-conductored (Sycamore – Scripps 69 kV). The Energy Division sent a data request to SDG&E asking SDG&E to explain the scope of work necessary for this re-conductor and the reason for changing RPCC’s alternative. The entirety of the data request and SDG&E’s response is as follows: 6

Data Request to SDG&E from CPUC Energy Division:
28-1 Coastal Link System Upgrade Alternative. SDG&E’s April 11, 2008 letter included the following comment on Section C: “For the Coastal Link System Upgrade Alternative, the following transmission upgrades need to be included in the FEIR/EIS: the upgrade of Sycamore - Pomerado 69 kV Circuits 1 and 2 and the upgrade of Sycamore - Scripps 69 kV line.” 7 Please define in detail the specific upgrades required for the two lines referenced (e.g., description of any ground disturbance, reconductoring, number and location of new poles or towers, or modifications to existing poles), and explain the reasons for this modification of the alternative from its previous definition.

SDG&E Response 28-1:
Sycamore - Pomerado 69 kV Circuits 1 and 2 Upgrades Upgrade of 69kV circuits TL6915 and TL6924 involves a reconductor of approximately 2 miles overhead line from single ACSR wire to bundled ACSR per circuit. All twenty-two (22) existing wood and steel structures will be replaced with either direct buried steel or foundation double circuit steel poles to handle the increased loads associated with the bundled wire. The majority of the poles will require concrete foundations. It is estimated that the design will not require any new structure locations. Existing access roads will be used to construct the upgrade. Upgrades of associated substation breakers and disconnects would occur within SDG&E’s Pomerado and Sycamore Canyon Substation Sycamore - Scripps 69 kV line Upgrades
6

There also appears to be a map(s) showing where the two lines run, produced by SDG&E and/or Aspen, attached to the response. This map is not included here. 7 The Sycamore – Pomerado 69 kV Circuits 1 and 2 were always a part of RPCC’s alternative and were in fact analyzed within the DEIR.

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Upgrade 69kV circuit TL6916 involves a reconductor of approximately 5 miles of overhead line from single ACSR wire to bundled ACSR. All forty-seven (47) existing wood and steel structures will be replaced with either direct buried steel or foundation double circuit steel poles to handle the increased loads associated with the bundled wire. The majority of the steel poles will require concrete foundations. It is estimated that the design will not require any new structure locations. Existing access roads will be used to construct the upgrade. Upgrade existing underground portions of the circuit from single to bundled Cable. • • • • At Scripps (remove 1.5 mi of 1750 AL kcmil, install bundled 3000 CU, using existing ducts and new underground drops). At Rue Biarritz (remove 0.2 mi of 1750 AL kcmil, and install bundled 3000 CU in new trench and change out existing wood cable poles to Steel cable poles). At Sycamore Canyon Substation (remove 0.1 mi of 1750 AL kcmil, install bundled 3000 CU). A new trench with single 1750 AL kcmil will be installed at Sycamore Canyon Substation to accommodate a relocation of existing 69kV circuit TL6920.

Upgrades of associated Substation breakers and disconnects would occur within SDG&E’s Scripps and Sycamore Substation. The reconductor of the Scripps-Sycamore 69 kV line was identified by SDG&E Transmission Planning through powerflow analysis performed in support of Phase 2 testimony. See SDG&E’s March 28, 2008 Rebuttal Testimony, Chapter 6, Footnote 1 and SDG&E’s response to RPCC data request 17, question 1, subpart (j) for additional details.

RPCC surmises that when the Energy Division saw that the scope of work necessary for the Sycamore – Pomerado re-conductor had changed dramatically (replacement of existing poles for new poles) as compared the analysis performed within the DEIR; the scope of work for the newly added re-conductor of the Sycamore – Scripps line was substantial (replacement of existing poles for new poles); and given that the Sycamore – Scripps line had not been analyzed within the DEIR at all, the Energy Division asked SDG&E to take another look at whether the re-conductor of these lines could be accomplished without the significant impacts of removing and replacing poles. If this could not be accomplished, SDG&E was potentially facing the recirculation of the DEIR.

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Facing the recirculation dilemma, SDG&E’s engineering department came up with a solution that did not require the replacement of poles and merely re-conductored these lines with a single conductor capable of carrying a higher current, instead of the original Phase II scope of work which would have installed a bundled conductor (which increases the weight and therefore effects the carrying capacity of the existing transmission poles). SDG&E then provided the following amended response to the data request:
SDG&E Supplemental Response 28-1, dated 5/23/08:
Reduced Transmission Scope SDG&E has performed additional analysis to supplement the previous preliminary engineering performed on this project and has determined that the Sycamore-Scripps 69 kV and Sycamore – Pomerado 69 kV reconductor can utilize a single 900 kcmil ACSS conductor and meet system needs, rather than bundled conductor, and can therefore be installed on the existing overhead transmission structures. The reconductor project scope should only entail the replacement of the conductor and not require the replacement of any overhead transmission structures. This substantially reduces the potential effects and time associated with this reconductor. The underground portion of this upgrade will remain the same as described above. The short segment (930 ft.) of underground through the Rue Biarritz area would be re-located into city streets and would eliminate existing impacts to nearby residences. The work will occur in approximately just one month and occur in segments along the short underground segment. The reduced impact scope of this reconductor project still meets the defined system needs.

It is also important to note that SDG&E had changed the scope of work to the Sycamore – Pomerado circuits between Phase I and Phase II analysis as well. Within Phase I, SDG&E described the scope of work, within their Phase I cost estimate, as “Reconductor from from single 1033 kcmil ACSR and single 1750 kcmil AL to single 900 kcmil ACSS and single 3000 kcmil CU. Few pole replacements.” 8 SDG&E then changed this scope of work to bundled conductor with pole replacements in Phase II, as described above, only to change it back again to what appears to be the exact same Phase I scope of work (as described within their response on May 23, 2008). This disturbing fact illustrates that SDG&E appears to have purposely attempted

8

See Exhibit R-4, page 5, bottom row, last column.

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to make RPCC’s alternative look as expensive as possible in Phase II hearings, while ignoring, or perhaps purposely avoiding less expensive engineering solutions. Further, despite providing a new scope of work on May 23, 2008, seven days before the Phase II Opening Brief was due, SDG&E failed to notify RPCC of this substantial change and made no mention of it within the Phase II Opening Brief. The magnitude of the change from a cost estimate standpoint is well over $10 million dollars. RPCC is able to make an educated estimate at the cost savings because of cost estimate for the same scope of work provided by SDG&E within Phase I. The Phase I “unescalated cost to construct (equipment/material/labor)”estimate to reconductor the Sycamore – Pomerado circuits was $5,900,000. 9 The comparative figure given by SDG&E in Phase II per their Exhibit SD-35, Attachment 3-5 is $8,963,022. This is over a three million dollar difference for a two mile line on costs to construct, alone. Add in the 30% contingency applied by SDG&E to this line in Phase II and you subtract almost another $1 million. Subtract AFUDC and escalation amounts and you are over $5 million in cost differential for the Sycamore – Pomerado line alone. Given that the scope of work for the Sycamore – Scripps line is now the same as the Sycamore – Pomerado line, and given that the Sycamore – Scripps line is approximately five miles long (2 and ½ times longer than the Sycamore – Pomerado line), one can logically deduce that the cost savings attributable to not removing and replacing poles for the Sycamore – Scripps line is going to exceed the $5 million dollar cost savings estimated for the Sycamore – Pomerado line. Therefore, the total cost savings is likely to be well in excess of $10 million dollars. The result is that RPCC’s alternative provides even greater cost savings to CAISO ratepayers.” 10

9

10

See Exhibit R-4, page 5, bottom row, second column. Counsel for RPCC told SDG&E it would be raising this issue within its comments. Therefore, it will be interesting to see if SDG&E provides comments on this issue.

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WHY IS THIS IMPORTANT? First, CAISO ratepayers are entitled to accurate cost estimates and should not have to pay more than what it costs to build this line. Further, this Commission is relying upon these costs estimates in setting an accurate cap. Interestingly, SDG&E clearly believes that the GAPD does not accurately reflect the costs of the Coastal link. Debra Reed said as much within her oral argument comments and SDG&E has since met ex parte with Commissioner Peevey and Bohn staff to explain that the Coastal link cost estimate associated with SDG&E’s project was estimated to be $33 million too high within the GAPD, therefore lowering the cost cap on this project. Commissioner Peevey bought into this argument because his APD reflects a new number associated with SDG&E’s coastal link ($156 million instead of $189 million). SDG&E, however, does not complain about the $84 million number associated with the RPCC Coastal link system upgrades, even though SDG&E knows the costs have changed for the two re-conductorings consistent with the RDEIR analysis above. SDG&E, where are the new cost estimates for these two lines? Why hasn’t SDG&E been forthcoming with this information? This is what this Commission should be asking SDG&E, especially in light of the fact that SDG&E thinks the GAPD otherwise applies an incorrect figure to SDG&E’s own Coastal link cost estimate. RPCC will await SDG&E’s comments on their reasoning behind why a $156 million dollar figure is the proper estimate as compared to the $189 million dollar estimate the GAPD adopted and will address the accuracy of SDG&E’s assertions within RPCC’s reply comments. IV. CONCLUSION Due to SDG&E’s unilateral decision to change RPCC’s alternative between phase I and phase II, there appears to have been some confusion within the FEIR in describing the scope of

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RPCC’s alternative. A finding of fact paragraph can adequately address the ambiguity by finding that the Poway – Pomerado line is not a part of the Coastal link system upgrades. The discussion within the decision itself concerning the Encina transformer should clarify whether the decision incorporates the 230/138 kV transformer at Encina or not as part of the Coastal link system upgrades. SDG&E should be ordered to provide an updated cost estimate for the re-conductoring of the Sycamore – Pomerado circuits and the Sycamore – Scripps circuit. This Commission should also analyze whether a $156 million dollar estimate is the most recent, accurate estimate for SDG&E’s projected cost of their Coastal link portion of the project so as to accurately come up with a final overall cost for this project.

Dated: November 20, 2008

Respectfully submitted, /s/Harvey M. Payne Rancho Penasquitos Concerned Citizens By: Harvey M. Payne

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APPENDIX OF PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW FINDINGS OF FACT: Add an additional finding of fact paragraph as follows: The Final EIR/EIS Superior Southern Route does not include, as part of the Coastal link system upgrades, a re-conductoring of the Poway – Pomerado 69 kV transmission line. Change paragraph 43 to adjust the total to reflect cost estimate changes. FINDINGS OF LAW: None

14

RPCC Comments to Alternative Proposed Decision (Grueneich) CERTIFICATE OF SERVICE I, Harvey M. Payne, hereby certify that I have this day served a copy of:

A.06-08-010

RANCHO PEÑASQUITOS CONCERNED CITIZENS’ COMMENTS TO COMMISSIONER GRUENEICH’S ALTERNATIVE PROPOSED DECISION on all known parties with an e-mail address on the service list in proceeding A.06-08-010, by electronic mail, consistent with the attached list of e-mail addresses. I also caused the above described document to be filed electronically with the Commission and mailed copies to Commissioner Grueneich and ALJ Vieth.

Dated: November 20, 2008

/s/Harvey M. Payne Harvey M. Payne

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E-mail service list in A.06-08-010
Podgorsky@wrightlaw.com, thompson@wrightlaw.com, ssiegel@biologicaldiversity.org, ssiegel@biologicaldiversity.org, sara@calparks.org, nwhang@manatt.com, sptp@msk.com, thomas.burhenn@sce.com, dwood8@cox.net, dlindsay@sunbeltpub.com, mwells@parks.ca.gov, scotmartin478@msn.com, david.lloyd@nrgenergy.com, conniebull@cox.net, dj0conklin@earthlink.net, edwrdsgrfx@aol.com, pwhalen2@cox.net, oakhollowranch@wildblue.net, jhfark@pacbell.net, denis@vitalityweb.com, hikermomma1@yahoo.com, gbarnes@sempra.com, fortlieb@sandiego.gov, jwalsh@sempra.com, mcalabrese@sandiego.gov, shawn.hagerty@bbklaw.com, liddell@energyattorney.com, mshames@ucan.org, cadowney@san.rr.com, ko'beirne@semprautilities.com, hpayne3@gmail.com, kritchey@san.rr.com, jleslie@luce.com, dhogan@biologicaldiversity.org, sjkeene@iid.com, barbschnier@yahoo.com, AirSpecial@aol.com, wblattner@semprautilities.com, mflorio@turn.org, wolff@smwlaw.com, map@cpuc.ca.gov, ttf@cpuc.ca.gov, norman.furuta@navy.mil, bpowers@powersengineering.com, jaugustine@biologicaldiversity.org, rcox@pacificenvironment.org, bcragg@goodinmacbride.com,

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RPCC Comments to Alternative Proposed Decision (Grueneich)
richard.raushenbush@lw.com, vprabhakaran@goodinmacbride.com, jeffgray@dwt.com, dietrichlaw2@earthlink.net, dkates@sonic.net, jsanders@caiso.com, jdh@eslawfirm.com, btorgan@parks.ca.gov, ktobias@parks.ca.gov, steven@iepa.com, kmills@cfbf.com, elizabeth.klein@lw.com, janice.schneider@lw.com, julie.greenisen@lw.com, michael.gergen@lw.com, kelly@kellyfuller.net, Henry.Martinez@ladwp.com, randy.howard@ladwp.com, cfaber@semprautilities.com, rkeen@manatt.com, Case.Admin@sce.com, darell.holmes@sce.com, margandona@calwild.org, donnatisdale@hughes.net, mjumper@sdihf.org, rebeccap@environmentalhealth.org, ddowney@nctimes.com, jharry.jones@uniontrib.com, patricia_fallon@sbcglobal.net, dandbcarey@julianweb.com, celloinpines@sbcglobal.net, vmp@sbcglobal.net, skyword@sbcglobal.net, colobiker@gmail.com, nparinello@gmail.com, cpuc@92036.com, dwvoss@cox.net, WSK@astro.caltech.edu, carolyn.dorroh@cubic.com, jwmitchell@mbartek.com, jwmitchell@mbartek.com, soliviasmom@gmail.com, oldjulianco@integrity.com, wolfmates@cox.net, Csmmarket@aol.com, joe@ranchitarealty.com, cesposit@sdcoe.k12.ca.us, bgendron@nethere.com, kimmerlys@yahoo.com, gedrown@mindspring.com, gecko_greens@juno.com,

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RPCC Comments to Alternative Proposed Decision (Grueneich)
Reneeandbear@aol.com, dan@energysmarthomes.net, deanna.spehn@sen.ca.gov, sfr@sandag.org, jason.ohta@lw.com, patricia.guerrero@lw.com, sierraclubintern@yahoo.com, mmitrosky@sierraclubsandiego.org, kmkiener@cox.net, jimbellelsi@cox.net, srogers647@aol.com, usdepic@gmail.com, bruce.bigelow@uniontrib.com, onell.soto@uniontrib.com, gcourser@hotmail.com, centralfiles@semprautilities.com, Irene.stillings@energycenter.org, jennifer.porter@energycenter.org, sabrina.ozturk@sdcounty.ca.gov, sephra.ninow@energycenter.org, tblair@sandiego.gov, Dahvia.Lynch@sdcounty.ca.gov, jfirooz@iesnet.com, sanrocky@aol.com, Thomas_Zale@blm.gov, up@undergroundpower.us, c@californiabotanicalhabitat.com, swilson@pcta.org, Lnastro@parks.ca.gov, bruce.foster@sce.com, Diane.Fellman@fpl.com, wolff@smwlaw.com, rcox@pacificenvironment.org, bbirdsall@aspeneg.com, dtk5@pge.com, jay2@pge.com, kmsn@pge.com, mspe@pge.com, placourciere@thelenreid.com, Cassandra.sweet@dowjones.com, dhuard@manatt.com, jwoodruff@nextlightrp.com, jfieber@flk.com, cem@newsdata.com, regrelcpuccases@pge.com, robin.harrington@fire.ca.gov, joe.paul@dynegy.com, hzaininger@aol.com, phil@auclairconsulting.com, editorial@californiaenergycircuit.net, mrw@mrwassoc.com,

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dmarcus2@sbcglobal.net, sweissman@law.berkeley.edu, bjolley@herumcrabtree.com, kent@wkpalmerton.com, ziad@zglobal.biz, e-recipient@caiso.com, david@branchcomb.com, PGS@IEEE.org, lonwhouse@waterandenergyconsulting.com, ddfreeman@yahoo.com, abb@eslawfirm.com, Audra.Hartmann@Dynegy.com, Darren.Boutton@gov.ca.gov, jreede@energy.state.ca.us, KMCDO@parks.ca.gov, kellie.smith@sen.ca.gov, kdw@woodruff-expert-services.com, rlauckhart@globalenergy.com, alan.comnes@nrgenergy.com, daniel@wildroseenergy.com, mrx@cpuc.ca.gov, bcb@cpuc.ca.gov, dhn@cpuc.ca.gov, dsh@cpuc.ca.gov, gxh@cpuc.ca.gov, hmm@cpuc.ca.gov, jjj@cpuc.ca.gov, xjv@cpuc.ca.gov, jlo@cpuc.ca.gov, jmh@cpuc.ca.gov, kwh@cpuc.ca.gov, lau@cpuc.ca.gov, ljw@cpuc.ca.gov, mjd@cpuc.ca.gov, nms@cpuc.ca.gov, rae@cpuc.ca.gov, rwh@cpuc.ca.gov, wsc@cpuc.ca.gov, sjl@cpuc.ca.gov, saw@cpuc.ca.gov, tdp@cpuc.ca.gov, tbo@cpuc.ca.gov, slee@aspeneg.com, Claufenb@energy.state.ca.us, darren.bouton@gov.ca.gov, mpryor@energy.state.ca.us, prichins@energy.state.ca.us, trf@cpuc.ca.gov, jgrau@energy.state.ca.us, tmurphy@aspeneg.com,

A.06-08-010

19

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