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 Application 06-08-010
Public Convenience and Necessity for the Sunrise (Filed August 4, 2006)
Powerlink Transmission Project.

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: john@geo-energy.org
 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 Application 06-08-010
Public Convenience and Necessity for the Sunrise (Filed August 4, 2006)
Powerlink Transmission Project.

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
Alternative Proposed Decision, Ordering Paragraph 2, at p. 284.
3
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 all-

party 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: john@geo-energy.org

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/ 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: john@geo-energy.org

4
 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