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Category:Legal-Correspondence
MONTHYEARML23192A0192023-07-0303 July 2023 7-3-23 Petitioners Excerpts of Record Index (9th Cir.)(Case No. 23-852) ML23192A0212023-07-0303 July 2023 7-3-23 Petitioners Excerpts of Record Volume 1 (9th Cir.)(Case No. 23-852) ML23192A0232023-07-0303 July 2023 7-3-23 Petitioners Excerpts of Record Volume 2 (9th Cir.)(Case No. 23-852) ML23192A0252023-07-0303 July 2023 7-3-23 Petitioners Excerpts of Record Volume 3 (9th Cir.)(Case No. 23-852) ML23161A0012023-06-0606 June 2023 6-6-23 Respondents Motion to Extend the Time to File the Certified Index (9th Cir.)(Case No. 23-852) ML23144A2482023-05-17017 May 2023 5-17-23 Motion to Intervene Filed by Pge (9th Cir.)(No. 23-852) ML23136A0132023-05-10010 May 2023 5-10-23 Slompf Mediation Questionnaire (9th Cir.)(Case No. 23-852) ML21067A4142021-03-0808 March 2021 3-8-21 Mandate from 9th Circuit - Public Watchdogs V NRC 9th Cir 20-70899(Filed) ML18337A0642018-11-26026 November 2018 Court Mandate - 11-26-2018 - Foe V NRC - DC Cir 16-1004 ML16314B6872016-11-0909 November 2016 Intervenors' Request for Documents and Records from the Nuclear Relation to Geology and Seismicity ML16057A1982016-02-25025 February 2016 Federal Respondent'S Response to Opposition to Petitioner'S Motion to Hold the Case in Abeyance 2-25-16 ML16043A4972016-02-11011 February 2016 Petitioners Certificate Parties 2-11-16 ML15012A5462014-12-12012 December 2014 14-1213(D.C.Cir.) Certified Index of Record (Filed) ML15007A5122014-12-0101 December 2014 Petitioner'S Filing of the Underlying Decision from Which the Petition Arises ML12137A0242012-05-15015 May 2012 Diablo Canyon - May Hearing File Update ML1030200242010-10-28028 October 2010 San Luis Obispo Mothers for Peace V. USNRC; No. 08-75058 - Oral Argument Scheduled for November 4, 2010 Before Judges Reinhardt, Thomas & Chief Judge Restani of the International Court of Trade ML0717601352007-05-0303 May 2007 5/3/2007 - Petitioner'S Reply to Respondents' Opposition to Motion for Attorneys Fees and Costs Between San Luis Obispo Mother for Peace V. USNRC and Pacific Gas & Electric Co; No. 03-74628 ML0717601492007-02-14014 February 2007 2/14/2007 - Corrected Petitioners Motion for Attorney'S Fees and Costs, Errata Sheet and Additional Declarations; No. 03-74628 ML0703305102006-11-17017 November 2006 No. 06-466; Letter from the Honorable William K. Suter Granting the Extension of Time ML0703304402006-11-16016 November 2006 No. 06-466; Letter to the Honorable William K. Suter Petition for a Writ of Certiorari ML0703304422006-10-25025 October 2006 Corrected Letter from the Honorable William K. Suter for the Extension of Time No. 06-466 ML0703304442006-10-23023 October 2006 Letter from William K. Suter, Clerk Response to the Petition for a Writ of Certiorari Granting Extension of Time ML0703305212006-10-20020 October 2006 Letter to the Honorable William K. Suter, Regarding Pacific Gas & Electric Company V. San Luis Obispo Mother for Peace, Et At. S. Ct No. 06-466 ML0703305182006-10-20020 October 2006 Letter to U.S. Supreme Court Docket No. 06-466 Requesting a 29-Day Extension of Time for Filing an Opposition to the Petition for Certiorari ML0622301182006-07-0606 July 2006 Reply to Petitioners' Response to Government'S Motion for Extension of Time within Which to File a Petition for Rehearing or Rehearing En Banc, Dated 07/06/2006 ML0622301172006-07-0505 July 2006 Petitioners' Response to Us Nrc'S Motion for Extension of Time to File Petition for Rehearing, Dated 07/05/2006 ML0622301232006-06-29029 June 2006 Federal Respondents' Motion for Extension of Time in Which to File a Petition for Rehearing En Banc, Dated 06/29/2006 ML0622301222006-06-0202 June 2006 Petition for Review of an Order of the Nuclear Regulatory Commission, Filed 06/02/2006 ML0533202202005-11-17017 November 2005 Federal Respondents' Fifth Filing Under Frap 28J, Dated 11/17/05 ML0531801412005-11-0909 November 2005 Federal Respondents' Fourth Filing Under Frap 28J, Dated 11/9/05 ML0533202592005-10-11011 October 2005 Federal Respondents' Second Filing Under Frap 28J, Dated 10/11/05 ML0503101152005-01-12012 January 2005 Original Mandate Transmitted to NRC, Dated 01/12/05 ML0436502262004-11-24024 November 2004 Letter to Court Clerk from G. Kim Clarification of a Post-Oral Argument Letter, Dated 11/24/04 ML0436502302004-11-19019 November 2004 Letter to Court Clerk from R. Mcdiarmid Information of e-mail Messages, Dated 11/19/04 ML0436502382004-11-15015 November 2004 Facsimile Message to Courtroom Deputy Clerk from G. Kim Oral Argument Schedules 11/19/04 ML0436502342004-11-15015 November 2004 Letter to Court Clerk from R. Mcdiarmid Oral Argument for 11/19/04, Dated 11/15/04 ML0421802322004-07-30030 July 2004 Errata Re Eighth and Final Fee Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for Winston & Strawn ML0421702892004-07-26026 July 2004 Final Application of Pricewaterhousecoopers Llp for Allowance and Payment of Compensation and Reimbursement of Expenses (September 1, 2002 Through February 28, 2003) ML0421004272004-07-21021 July 2004 Notice of Motion and the California Power Exchange Corporation Motion for Authority to Amend Prepetition Claim, Memorandum of Points and Authorities, Declaration of Marc S. Cohen in Support Thereof ML0421004302004-07-20020 July 2004 Notice of Application & California Power Exchange Corporation'S Application for Payment of Professional Compensation & Reimbursement of Expenses Under 11 U.S.C. 503(b)(3) & (4); Memorandum of Points and Authorities; Declarations of Cohen, R ML0420202962004-07-12012 July 2004 Eighth and Final Application for Allowance of Fees and Expenses of Winston & Strawn Llp (August 16, 2001 Through April 12, 2004) ML0420302692004-07-12012 July 2004 Ninth Interim and Final Application of FTI Consulting Inc. for Allowance and Payment of Compensation and Reimbursement of Expenses (April 11, 2001 Through April 12, 2004); Declaration of Thomas E. Lumsden in Support Thereof ML0420203032004-07-12012 July 2004 Exhibits in Support of Motion of the City of Palo Alto for Order Directing Payment of Reasonable Attorneys' Fees and Costs Pursuant to Section 503(b)(3)(D), 503(b)(3)(F) and 503(b)(4) ML0421004192004-07-0404 July 2004 Appendix of Exhibits in Support of the California Power Exchange Corporation'S Application for Payment of Professional Compensation and Reimbursement of Expenses Under 11 U.S.C. 503(b)(3) and (4) ML0416706302004-06-0707 June 2004 Modesto Irrigation District'S Response to Debtor'S Objection to Claim ML0416005722004-05-28028 May 2004 Rothschild Inc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1, 2004 - April 12, 2004 ML0416005602004-05-28028 May 2004 Deloitte & Touche Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses (March 1, 2004 to April 12, 2004) ML0416001862004-05-28028 May 2004 Cooley Godward Llp'S Thirty-Fifth Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1, 2004 - April 12, 2004 ML0415902522004-05-28028 May 2004 Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for April 1 Through April 12, 2004 ML0415603342004-05-27027 May 2004 Howard, Rice, Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for April 1, 2004 Through April 12, 2004 2023-07-03
[Table view] Category:Legal-Correspondence/Maintenance
MONTHYEARML0533202202005-11-17017 November 2005 Federal Respondents' Fifth Filing Under Frap 28J, Dated 11/17/05 ML0531801412005-11-0909 November 2005 Federal Respondents' Fourth Filing Under Frap 28J, Dated 11/9/05 ML0533202592005-10-11011 October 2005 Federal Respondents' Second Filing Under Frap 28J, Dated 10/11/05 ML0503101152005-01-12012 January 2005 Original Mandate Transmitted to NRC, Dated 01/12/05 ML0436502262004-11-24024 November 2004 Letter to Court Clerk from G. Kim Clarification of a Post-Oral Argument Letter, Dated 11/24/04 ML0436502302004-11-19019 November 2004 Letter to Court Clerk from R. Mcdiarmid Information of e-mail Messages, Dated 11/19/04 ML0436502382004-11-15015 November 2004 Facsimile Message to Courtroom Deputy Clerk from G. Kim Oral Argument Schedules 11/19/04 ML0436502342004-11-15015 November 2004 Letter to Court Clerk from R. Mcdiarmid Oral Argument for 11/19/04, Dated 11/15/04 ML0421802322004-07-30030 July 2004 Errata Re Eighth and Final Fee Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for Winston & Strawn ML0421702892004-07-26026 July 2004 Final Application of Pricewaterhousecoopers Llp for Allowance and Payment of Compensation and Reimbursement of Expenses (September 1, 2002 Through February 28, 2003) ML0421004272004-07-21021 July 2004 Notice of Motion and the California Power Exchange Corporation Motion for Authority to Amend Prepetition Claim, Memorandum of Points and Authorities, Declaration of Marc S. Cohen in Support Thereof ML0421004302004-07-20020 July 2004 Notice of Application & California Power Exchange Corporation'S Application for Payment of Professional Compensation & Reimbursement of Expenses Under 11 U.S.C. 503(b)(3) & (4); Memorandum of Points and Authorities; Declarations of Cohen, R ML0420302692004-07-12012 July 2004 Ninth Interim and Final Application of FTI Consulting Inc. for Allowance and Payment of Compensation and Reimbursement of Expenses (April 11, 2001 Through April 12, 2004); Declaration of Thomas E. Lumsden in Support Thereof ML0420203032004-07-12012 July 2004 Exhibits in Support of Motion of the City of Palo Alto for Order Directing Payment of Reasonable Attorneys' Fees and Costs Pursuant to Section 503(b)(3)(D), 503(b)(3)(F) and 503(b)(4) ML0420202962004-07-12012 July 2004 Eighth and Final Application for Allowance of Fees and Expenses of Winston & Strawn Llp (August 16, 2001 Through April 12, 2004) ML0421004192004-07-0404 July 2004 Appendix of Exhibits in Support of the California Power Exchange Corporation'S Application for Payment of Professional Compensation and Reimbursement of Expenses Under 11 U.S.C. 503(b)(3) and (4) ML0416706302004-06-0707 June 2004 Modesto Irrigation District'S Response to Debtor'S Objection to Claim ML0416001862004-05-28028 May 2004 Cooley Godward Llp'S Thirty-Fifth Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1, 2004 - April 12, 2004 ML0416005722004-05-28028 May 2004 Rothschild Inc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1, 2004 - April 12, 2004 ML0416005602004-05-28028 May 2004 Deloitte & Touche Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses (March 1, 2004 to April 12, 2004) ML0415902522004-05-28028 May 2004 Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for April 1 Through April 12, 2004 ML0415603342004-05-27027 May 2004 Howard, Rice, Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for April 1, 2004 Through April 12, 2004 ML0415603072004-05-26026 May 2004 FTI Consulting Inc. Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for April 1, 2004 to April 12, 2004 ML0415508302004-05-26026 May 2004 Steefel, Levitt & Weiss'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1-12 2004 ML0415603352004-05-25025 May 2004 Innisfree M&A Incorporated'S Fourth Interim Cover Sheet Application for Allowance and Payment of Compensation and Reimbursement of Expenses for the Period January 1, 2004 - April 12, 2004 ML0415902482004-05-25025 May 2004 Milbank, Tweed, Hadley & Mccloy Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for April 1, 2004 Through April 12, 2004 ML0415404112004-05-24024 May 2004 Winston & Strawn Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1.2004 Through April 12 2004 ML0414900892004-05-21021 May 2004 Heller Ehrman White & Mcauliffe Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1, 2004, Through April 12, 2004 ML0415903242004-05-21021 May 2004 Public Policy Advocates Llc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for April 1, 2004 Through April 12, 2004 ML0414701812004-05-20020 May 2004 Legc, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1. 2004 to April 12 200 ML0413203762004-04-30030 April 2004 Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for March 1 Through March 31, 2004 ML0412705072004-04-30030 April 2004 Steefel, Levitt & Weiss'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period March 1-31, 2004 ML0413303832004-04-30030 April 2004 Rothschild Inc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period March 1, 2004 - March 31, 2004 ML0413303802004-04-30030 April 2004 Howard, Rice, Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for March. 2004 ML0413203702004-04-30030 April 2004 FTI Consulting Inc. Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for March 1, 2004 to March 31, 2004 ML0413202012004-04-30030 April 2004 Cooley Godward Llp'S Thirty-Fourth Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period March 1, 2004 - March 31, 2004 ML0413203752004-04-30030 April 2004 Heller Ehrman White & Mcauliffe Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period March 1, 2004, Through March 31, 2004 ML0412700262004-04-29029 April 2004 Winston & Strawn Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period, March 1. 2004 Through March 31. 2004 ML0412700412004-04-27027 April 2004 Keker & Van Nest'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period March 1, 2004 to March 31, 2004 ML0414701802004-04-23023 April 2004 Milbank, Tweed, Hadley & Mccloy Llp'S Cover Sheet - Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for March 2004 ML0412102292004-04-22022 April 2004 Lecg, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period 03/01-31/2004 ML0414701852004-04-15015 April 2004 Public Policy Advocates Llc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for March 1, 2004 Through March 31, 2004 ML0414102072004-04-12012 April 2004 Keker & Van Nest'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period April 1, 2004 to April 12, 2004 ML0410703992004-03-31031 March 2004 FTI Consulting Inc. Cover Sheet Applications for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for February 1, 2004 to February 29, 2004 ML0409804962004-03-31031 March 2004 Cooley Godward Llp'S Thirty-Third Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period February 1, 2004 - February 29, 2004 ML0409704632004-03-30030 March 2004 Howard, Rice, Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for February, 2004 ML0409704442004-03-30030 March 2004 Deloitte & Touche Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses (February 1, 2004, to February 29, 2004) ML0409704382004-03-29029 March 2004 Lecg, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period February 1, 2004 to February 29, 2004 ML0409703622004-03-29029 March 2004 Skadden, Arps, Slate, Meagher & Flom Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period February 1, 2004 Through February 29, 2004 ML0409805892004-03-26026 March 2004 Milbank, Tweed, Hadley & Mccloy Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for February 2004 2005-11-09
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Text
1 JAMES L. LOPES (No. 63678) ~(~
JEFFREY L. SCHAFFER (No. 91404) 2 SARAH M. KING (No. 189621)
FALK RICE, HOWARD, NEMEROVSKI, CANADY, 3 & RABKIN A Professional Corporation 4 Three Embarcadero Center, 7th Floor San Francisco, California 94111-4065 5 Telephone: 415/434-1600 Facsimile: 415/217-5910 6
Attorneys for Debtor and Debtor in Possession 7 PACIFIC GAS AND ELECTRIC COMPANY 8
.9 UNITED STATES BANKRUPTCY COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN FRANCISCO DIVISION 12 In re No. 01 30923 DM
,13 PACIFIC GAS AND ELECTRIC Chapter 11 Case HOMAR COMPANY, a California corporation, Date: February 8, 2002 cPxt 1 Debtor. Time: 2:30 p.m.
Place: 235 Pine St., 22nd Floor 16 San Francisco, -California Federal I.D. No. 94-0742640 Judge: Hon. Dennis Montali 17 18 19 DECLARATION OF GARRETT TIMOTHY GRIDER IN SUPPORT OF 20 DEBTOR'S MOTION FOR ORDER APPROVING CONSTRUCTION OF TRI-VALLEY PROJECT 21 22 23 24 25 26 27 &, ~[4 r_ý -I\
28 DECL. OF G. GR.DER ISO OF DEBTORS MOT. FOR APPROVING CONSTRUCTION OF TRI-VALLEY PROJECT WD 012402/1-1419948/gff'9694SVV4
1 I, Garrett Timothy Grider, declare as follows:
2
- 1. I am a Project Manager at Pacific Gas and Electric Company ("PG&E") of 3
major transmission, substation and distribution projects. I have been employed by PG&E 4
for over 20 years, 15 years of which were with project cost controls and 8 years in project 5
management. I am the Project Manager for the Tri-Valley 2002 Capacity Increase Project 6
("Tri-Valley Project"). I make this Declaration based upon my personal knowledge of 7
project management, project cost control, and upon my review of PG&E's records 8
concerning the matters stated herein. If called as a witness, I could and would testify 9
competently to the facts stated herein.
10
- 2. The purpose of the Tri-Valley Project is to build electric transmission and 11 distribution facilities to meet the projected electric demand in the cities of Dublin, 12 Livermore, Pleasanton, and San Ramon, and in portions of unincorporated Alameda and 13 HOVARD S14 Contra Costa Counties near these cities (collectively the "Tri-Valley area").
- 3. The electric distribution system in the Tri-Valley area currently consists of 15 both 12 kilovolt ("kV") and 21 kV systems. The 12 kV system is served off the 60 kV 16 system and supplies the Vasco, Livermore, Radum, Parks and Sunol substations, which at 17 peak conditions are loaded at capacity.
18
- 4. The Tri-Valley area is currently served by both 230 kV and 60 kV 19 transmission facilities. Nine 230 kV transmission lines run along the perimeter of the Tri 20 Valley area with 230 kV distribution substations at San Ramon and Las Positas. Four 60 kV 21 transmission lines run through the center of the Tri-Valley area and converge at the Vineyard 22 and Radum 60 kV distribution substations. The 60 kV transmission facilities at peak 23 conditions are currently operating at or above their maximum load-serving capability.
24
- 5. Electric load in the Tri-Valley area is expected to double over the next 15 to 25 20 years, growing at a rate of 27 megawatts ("MW") per year, due to (in part) several major 26 residential and commercial developments that currently are in the planning, approval, or 27 construction phases.
28 DECL. OF G. GRIDER ISO OF DEBTOR'S MOT. FOR AUTH. TO CONSTRUCT TRI-VALLEY PROJECT WD 012402/1-1419948/gff'969452/v4 1
- 6. To support the load growth, the California Independent System Operator 2
("ISO") has found that substantial additions to PG&E's transmission and distribution 3
systems will be required to be in place by summer 2003 and 2004 to meet demand and 4
ensure system reliability.
5
- 7. PG&E has designed the Tri-Valley Project to solve the projected 6
transmission and distribution deficiencies in the Tri-Valley area. The Tri-Valley Project is 7
composed of a Northern and Southern Component.
8
- 8. To complete the Northern Component of the Tri-Valley Project, PG&E 9
will: construct two new 230/21 kV distribution substations, one in North Livermore and the 10 other in North Dublin, along with the necessary distribution circuits; and construct 11 approximately 8.2 miles of 230 kV double circuit transmission line (5.4 miles of 12 underground and 2.8 miles of overhead) from the Contra Costa-Newark No. 2 circuit to the 13 R)E new distribution substations.
CAN .14 WIC 9. To complete the Southern Component of the Tri-Valley Project, PG&E will: convert the Vineyard substation from 60 kV to 230 kV service along with constructing AJid .gb 15 16 the necessary distribution circuits; and construct 5.7 miles of 230 kV underground double 17 circuit transmission line from the Contra Costa-Newark No. 2 230 kV circuit to Vineyard 18 substation.
19
- 10. PG&E originally scheduled construction on the Tri-Valley Project to begin 20 in in June 2001 so that the Project would become.operational in June 2002. Due to delays 21 proceedings of the California Public.Utilities Commission ("CPUC"), the Tri-Valley Project 22 currently is behind schedule. To meet the operational deadlines of summer 2003 and 2004, 23,:
pre-constructio iIactivities must beginno later than March 1, 2002 and construction must 24;.. funds to begin'no laterthan June 1, 2002. If this Court-grants PG&E the authority to expend 25 2002 on the
-....construct the Tri-Valley Project, PG&E intends to start construction on June 1, 26 on "Vr/ai'd:substation,.August 1, 2002 on the North Livermore substation and June 1, 2003 27 the North Dublin substation.
28 PROJECT "DECL.OF G. GRIDER ISO OF DEBTOR'S MOT. FOR APPROVING CONSTRUCTION OF TRI-VALLEY WD O1240211-14199481gff/969452/v4 1 11. PG&E currently estimates that it will cost approximately $135.8 million to 2 construct the Tri-Valley Project. The overall Tri-Valley Project has an estimated negative 3 net present value ("NPV") of -$99.4 million (-$71.5 million for transmission cost 4 components and -$27.9 million for distribution cost components), and a present value of 5 revenue requirements ("PVRR") of $167.8 million ($120.7 million for transmission cost 6
components and $47.1 million for distribution cost components) over the 20-year study 7
period.
8 12. If this Court grants PG&E the authority to expend funds to construct the 9 Tri-Valley Project, PG&E is expected to include the cost of the Tri-Valley Project's 10 transmission facilities in PG&E's base utility revenue requirements and seek authorization 11 12 by the Federal Energy Regulatory Commission ("FERC") to earn a rate of return on such costs. PG&E is expected to include the cost of the Tri-Valley Project's distribution facilities Y 13 M_ in PG&E's base utility revenue requirement and seek authorization by the CPUC to earn a
'CAMM' 14 MR rate of return on such costs.
. 15 13. In October 1999, PG&E's Board of Directors approved an appropriation of 16 $81 million to fund the Tri-Valley Project.
17 14. In November 1999, PG&E submitted Application No. A.99-11-025 (the 18 "Application") to the CPUC for a Certificate of Public Necessity and Convenience (a 19 "CPCN") to construct the Tri-Valley Project.
20 15. In January and February 2001, PG&E submitted written and oral testimony 21 of witnesses testifying to, among other things, the current and projected electric demand in 22 the Tri-Valley area, the need for the Tri-Valley Project to ensure system reliability under 23 state and federal standards, the proposed locations of the Project's transmission lines and 24 facilities, the estimated cost of construction based on the preliminary design and the PG&E 25 proposed locations for the Tri-Valley Project improvements, and the estimated costs of 26 various alternative Project routes being evaluated by the CPUC.
27 16. On January 27,2000, the ISO Governing Board approved the Tri-Valley 28 DECL. OF G. GRIDER ISO OF DEBTOR'S MOT. FOR APPROVING CONSTRUCTION OF TRI-VALLEY PROJECT WD 012402/1-1419948/gff/969452/v4 L-r LVVL _J. .dI I~ nir V MUI% IA LLLVI
~
I" ai vnfii.
1~
Project as the preferred transmission alternative to address the identified reliability concerns on the ISO Grid,
- 17. In February 2001, the CPUC held several weeks of hearings regarding the Tri-Valley Project
- 18. On July 24, 2001, the CPUC issued a proposed draft decision.
6 19. On October 11, 2001, the California Public Utilities Commission ("CPUC")
7 issued Decision No. 01-10-029, which grants PG&E a CPCN to construct the Tri-Valley Project. Attached hereto as Exhibit A is a true and correct copy of Decision No. 0 1-10-029.
c9 20. To PG&E's knowledge, the CPUC has not granted a CPCN for any other 10 project to provide the electric transmission and distribution capacity required to serve the projected loads in the Tri-Valley area.
12 21. On November 27, 2001, PG&E's Management Committee proposed to the Board of Directors authorization of updated capital expenditures in the aggregate amount of S 13 M015M 14 $135.9 million to construct the CPUC-approved Tri-Valley Project. On December 19,2001,
.15 the Board of Directors approved the revised capital expenditure amount, subject to 16 Bankruptcy Court approval.
16 17 22. Attached hereto as Exhibit B is a true and correct copy of PG&E's 18 Application for Rehearing of Decision No. 01-10-029.
19 23. As of the date hereof, the CPUC has not ruled on the Rehearing Application.
21' I declare under penalty of perjuryuwnder the laws of the United States of America 22 that the foregoing is true and correct. Executed this 240 day of January, 2002, at Walnut 23 Creek, California.
25.
26, Garrett Timro"...i.en 27 28 D)ECL. oP 0. GRIDER ISO OF D6-3TOR'S , POR APPROVINO CONSTRUCTION OF TKI-VALLEY PROJECT t'O WD 013021l/96945v3 Exhibits are not attached to the service copies of this document.
You may obtain copies of the Exhibits in one of the following ways: through the "Pacific Gas & Electric Company Chapter 11 Case" link accessible through the Bankruptcy Court's website (www.canb.uscourts.gov), or by written request to Howard, Rice, Nemerovski, Canady, Falk & Rabkin, Attn: Racquel Lopez, Three Embarcadero Center, 7th Floor, San Francisco, California 94111-4065 WD 071801/I-1419901/gff/932202/vl