Documents
Resources
Learning Center
Upload
Plans & pricing Sign in
Sign Out
Your Federal Quarterly Tax Payments are due April 15th Get Help Now >>

BEFORE THE CALIFORNIA PUBLIC UTILITIES COMMISSION

VIEWS: 0 PAGES: 43

									                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   SUMMARY
 2
 3      California Public Utilities Commission Jurisdictional Responsibility
 4      and Legal Requirements of Protest of Rule 21 Interconnection Standards
 5          In keeping with the California Public Utilities Commission Rules of
 6   Practice and Procedure Article 2.5 Rule 4, and Article 3 Rule 9-12, the Solar
 7   Development Cooperative hereby timely submits for filing our Protest of the
 8   (1) Interim Decision 00-11-001 Adopting New Rule 21 Interconnection Standards filed
 9   by the Commissioners on November 2, 2000, (2) Draft Decision Adopting
10   Interconnection Standards mailed by ALJ Cooke on November 20, 2000 (3)
11   Southern California Edison Advice 1495-E on AB918 and (4) 1498-E on
12   Interconnection Standards 00-11-001, (5) San Diego Gas & Electric Advice 1268-E
13   AB918, and (6) 1269-E Interconnection Standards 00-11-001, (7) Pacific Gas and
14   Electric Company Advice 2053-E AB91, and (8) 2056-E Interconnection Standards
15   00-11-001. SDC response to AB918 Advice Letters was delayed due to discovery
16   of an important document revealing major and material defraud of consumers.
17          I.        SDC/Smith provides Notice herein that the interconnection
18   advantage and domination of DG by fossil fuels in Rule 21 unrealistically
19   establishes a statute void of material consideration of the diverse needs and
20   characteristics of the many types of DG technologies. It does not address the
21   reality of consumer protection and education for small to mid-size DG
22   renewables consumers required by state agencies by law. CPUC/CEC/
23   CEOB/Utility proceedings traditionally perpetuate an imbalanced agenda
24   through wrongful suppressive collaboration by these state agencies with fossil fuel
25   associates materially affecting millions of dollars of energy deployment. Rule 21
26   requires revision with plans for immediate consumer notification and restitution
27   to timely and judicially balance the competitive playing field for small to mid-size
                   2000 Eileen M. Smith, M.Arch. Founder & CEO Since 1992   4
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                    PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   DG renewables up to 1 MWp before final approval of Rule 21 can be legally
 2   allowed.
 3           II.        On November 22, 2000, SDC first became aware of the California
 4   State Photovoltaic Program Consultant Report prepared by the Jet Propulsion
 5   Laboratory and published by the California Energy Commission [CEC] March 1978.6
 6   This historic document compared with the CEC 1996 Energy Technology Status
 7   Report7 establishes the existence of extreme and intentional fraud on the part of
 8   the CPUC/CEC/ CEOB/Utilities collaborating with fossil fuel associates in an
 9   ongoing pattern that began twenty years ago of illegal administrative collusion
10   to suppress or distort information, cause price fixing, spread propaganda about
11   the market readiness, affordability of building-integrated photovoltaics [BI-PV] and
12   other forms of dishonest industry discouragement resulting in oppressive
13   anticompetitive illegal suppression of needed life-preserving building-integrated
14   photovoltaics [BI-PV] from the mainstream market.                   Rule 21 Section 7 Dispute
15   Resolution is in material dispute with consumer interests, customer protection, antitrust
16   laws and the United States Constitution where Utilities are for-profit businesses
17   protected by CPUC related proceedings continue to suppress PV and protect oil cartels.
18       III. Net Metering and related renewable energy incentives are not being
19   appropriately managed with substantial detriment to this already extremely
20   limited point of purchases credit. Lack of consumer education coupled with refusal
21   by the CPUC to address oil cartel oppression of photovoltaics including their
22   refusal to fund consumer education about BI-PV technology even though BP-
23   Amoco has taken over nearly 70% of the BI-PV manufacturing world-wide since
24   their fraudulent takeover of the Solarex Corporation in 1984. This lack of
     6
       California State Photovoltaic Program Consultant Report of the California Energy Commission, by Jet
     Propulsion Laboratory, March 1978
     7
       1996 Energy Technology Status Report, published by California Energy Commission
                       2000 Eileen M. Smith, M.Arch. Founder & CEO Since 1992              5
                               3535 East Coast Highway #216 Corona del Mar, CA 92625
                   949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   ratepayer notification which could be done through the monthly bills greatly
 2   reduces consumer understanding of their DG renewables options. This problem
 3   is further compounded by the hostile attitude of Utility attorneys demonstrated
 4   throughout this proceeding related to Net Metering calling it freeloading, and the
 5   propaganda from the CPUC/ECE and CEOB regarding the affordability and
 6   market readiness of BI-PV. Small DG renewables like BI-PV are consumer-owned
 7   products and have been told over and over again that deployment can only occur
 8   where accurate information is timely provided to a large portion of consumers.
 9   AB970 illegally provides incentives favoring fossil fuel and large remote site
10   energy deployment for the SDG&E crisis where customer-owned BI-PV would
11   be the most ideal electricity generation choice to meet related consumer needs.
12   AB918 provides extreme abridgement of legislation where DG gas turbines who
13   sell to the Utility are allowed under the guise of direct access (DA) not to provide
14   this important incentive to their customers where it is already greatly limited to
15   0.1% of a UDC’s output. Further, there has been no material reason provided as
16   to why the CPUC/CEC/CEOB/UDCs cannot increase the size limit for Net
17   Metering to 1MWp.         DG renewables are furthered hindered to the lack of timely
18   Ruling on SDC/Smith’s Emergency Motion Mandating A Focus on BI-PV and Fuel
19   Cells to Reduce the Impact of the SDG&E Energy Crisis. The Emergency Motion was
20   filed on September 11, 2000 with a request for a 30-day response or Ruling.
21   CPUC has made no response, and the two comments submitted by UDCs did not
22   indicate any material breach would occur with affirmation of this Motion. CPUC
23   wrongfully has even delayed response over the 90-day time limit for regular
24   motions greatly hindering a fair or competitive market opportunity for DG
25   renewables, and especially where the due date for applications to AB970 is December 14,
26   2000. AB970 reduced its size limit to 250 kWp, but there is no reason why it
                   2000 Eileen M. Smith, M.Arch. Founder & CEO Since 1992              6
                           3535 East Coast Highway #216 Corona del Mar, CA 92625
               949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                    PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   could not include DG renewables projects from 1 kWp to 1 MWp. The CPUC/
 2   CEC/CEOB/UDCs continually take legislation for renewables and feed related
 3   funding to the fossil fuel industry on a silver platter in the name of green gas.
 4   This must stop! It is a fraudulent an inappropriate use of green legislation.
 5   NOTICE
 6           (1)        This Notice and Protest is filed by the Solar Development Cooperative in
 7   tacit procuration requiring immediate official response or Ruling within ten (10) working
 8   days ammending Section 7 Dispute Resolution of Rule 21 to assure parties furthering
 9   renewables BI-PV DG technology a choice of HEALTHY and SAFE venues to
10   competitively resolve disputes and intervene on behalf of California ratepayers to reduce
11   the impact of the predicted SDG&E energy shortage Summer 2001 without illegal fossil
12   fuel domination of this process suppressing consumer choice in related incentive
13   programs and the interconnection Priority Protocol Process of Rule 21.
14           (2)        SDC/Smith requires immediate response by the CPUC within ten days
15   in tacit procuration to Section II of the Issues In Protest herein notifying the parties of
16   this proceeding that the CPUC/CEC/CEOB/Utilities and fossil fuel associates8 have
17   Wrongfully Defrauded9 Potential and Actual BI-PV Consumers, the public and the energy
18   Industry for 20 Years regarding the Market Readiness and Affordability of building-
19   integrated photovoltaics. Those not intentionally a party of this negligence should have
20   been aware of the fraudulent information wrongfully published by the
21   CPUC/CEC/CEOB/Utilities and fossil fuel associates in opposition to viable historic data,
22   and should have taken immediate action to document and/or stop such malfeasance.
23           (3)        SDC/Smith provides Notice herein that the interconnection advantage and
24   domination of DG by fossil fuels in Rule 21 unrealistically establishes a statute void of
     8
       Electric Power Statistics 1997/1998, Energy Information Association, Table 1.
     http://www.geocities.com/rulemaking/nonutility.htm
     9
       Ibid 4
     CPUC Rulemaking 99-10-025 Phase I and Phase II Evidentiary Hearing Transcripts, SDC/Smith Cross-
     Examination, June and September, 2000
                       2000 Eileen M. Smith, M.Arch. Founder & CEO Since 1992              7
                               3535 East Coast Highway #216 Corona del Mar, CA 92625
                   949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   material consideration of the diverse needs and characteristics of the many types of DG
 2   technologies. It does not address the reality of consumer protection and education for
 3   small to mid-size DG renewables consumers required by state agencies by law.
 4   CPUC/CEC/CEOB/Utility proceedings traditionally perpetuate an imbalanced agenda
 5   through wrongful suppressive collaboration by these state agencies with fossil fuel
 6   associates materially affecting millions of dollars of energy deployment. Rule 21 requires
 7   revision with plans for immediate consumer notification and restitution to timely and
 8   judicially balance the competitive playing field for small to mid-size DG renewables up
 9   to 1 MWp before final approval of Rule 21 can be legally allowed.
10           Ruling is required on outstanding SDC Motions in Rulemaking 99-10-025
11   and Investigation 00-08-003 unless material reasons for further delay are
12   provided. On September 11, 2000, SDC filed an Emergency Motion Mandating
13   Immediate Deployment Focused on Renewable Technologies of BI-PV and Fuels Cells to
14   Reduce the Impact of the SDG&E Energy Crisis. SDC requested a 30-day time limit
15   for review and Ruling. After nearly 90 days no response has been provided in
16   material breach of CPUC Rules of Procedure.                   No reason(s) for delay or
17   contesting this Motion have been filed that indicates an affirmative Ruling would
18   adversely or materially effect any party of this proceeding. Considering the
19   December 14, 2000 deadline for AB970 applications that are already hindered by
20   fossil fuel domination, if CPUC Ruling or written response is not provided
21   within ten days, by law all recommendations of SDC’s Emergency Motion10
22   regarding AB97011 Program per this Notice will become law by tacit procuration.




     10
        SDC Emergency Motion Mandating Immediate Deployment of BI-PV and Fuel Cells (AB970) to Reduce
     Impact of SDG&E Energy Crisis, CPUC Rulemaking 99-10-025, Investigation 00-08-003, Sept 11, 2000
     http://www.geocities.com/RULEMAKING/EMSMOTGREENTEAM.doc
     11
        AB 970 Electricity Peak Load Efficiency Grant Funding Program
     http://www.energy.ca.gov/contracts/index.html#ab970
                    2000 Eileen M. Smith, M.Arch. Founder & CEO Since 1992              8
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1          This notice filed in tacit procuration requires immediate response to the
 2   allegations and recommendations herein providing a written plan for obviating
 3   these illegal wrongs within ten (10) days. Where timely response is not provided,
 4   by the laws of the State of California such lack of action on the part of the CPUC
 5   will establish full agreement with all issues and claims established within this
 6   Notice and Protest. CPUC and their agents will be found fully liable to all claims
 7   made herein and be held fully responsible for facilitating the recommendations
 8   and related programs included and addressed herein.
 9




10




                   2000 Eileen M. Smith, M.Arch. Founder & CEO Since 1992              9
                           3535 East Coast Highway #216 Corona del Mar, CA 92625
               949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                   PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


                                                                    300 kWp BI-PV Rooftop Installed 1984
                                                                          Georgetown University
                                                                          Intercultural Center for
                                                                           Mediation and Peace

                                                                         A foundation for mediation and peace
                                                               needs two-way communications. Ninety percent of
                                                               the people who work in this building do not know
                                                               it is generating electricity. 99% of the people cross-
                                                               examined in Phase I and Phase II Evidentiary
                                                               Hearings in Rulemaking 99-10-025 had never heard
                                                               of this historic project. This demonstration needs
                                                               to be registered as a National Landmark. Where is
                                                               a return on the dollar when no one knows about it?

 1                                              ISSUES IN PROTEST
 2
 3   I.      Section 7 Dispute Resolution Requirement for CPUC to have Initial
 4           Jurisdiction for Any Complaint is Unconstitutional Pursuant to the
 5           14th Amendment of the US Constitution Assuring Equal Protection Under the
 6           Law even for a Class of One.
 7           A.        CPUC Jurisdiction Provides Illegal Advantage to Utilities/Oil Cartels
 8           SDC strongly and totally contests and formally Protests, herein, any
 9   administrative Rule or statute that would mandatorily require California Public
10   Utilities Commission initial review of any complaint, dispute or issue regarding
11   Interconnection Standards as is outlined in Section 7 of Rule 21. No such
12   requirement could exist in a truly competitive and democratic market because it
13   is unconstitutional, and highly anticompetitive where Utilities are for-profit.12



     12
       CPUC Rulemaking 98-12-015 Motion for Discovery Antitrust Abuses of Enron, Amoco & British Petroleum,
     http://www.geocities.com/Eureka/1905/DISCOVERY.doc
     CEC Siting Committee Workshop for DG, December 6, 1999 http://www.energy.ca.gov/realaudio/archive/1999-12-
     08am.ram
     http://www.energy.ca.gov/realaudio/archive/1999-12-08pm.ram
     CEC Staff Analysis CA Air Resources Board
     CEC Global Climate
                   102000 Eileen M. Smith, M.Arch.   Founder & CEO Since 1992              10
                              3535 East Coast Highway #216 Corona del Mar, CA 92625
                  949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1                    “A person who is not traditionally a member of a protected class or
 2           group is protected under the laws of US Constitution, even where they are not
 3           joined by others, through the provisions of the 14th Amendment “class of one”
 4           where one who is treated differently from others in a similar situation with no
 5           rational or legal basis for the different treatment. Anyone who claims to have
 6           been singled out for adverse, irrational government action may bring a
 7           lawsuit based on violations of the Equal Protection Clause “class of one”.
 8           Equal protection clause purports to secure every person within the state
 9           against “intentional and arbitrary discrimination”.13
10           Historically, the CPUC/CEC/CEOB/Utility agendas, proceedings, workshops,
11   decisions and infusions of capital wrongly favor Utility and oil cartel interests. Mandatory
12   initial review of any dispute or complaint by the CPUC as set forth in Section 7 Dispute
13   Resolution materially abridges the 14th Amendment right to Equal Protection Under the Law for
14   a group or a Class of One. SDC/Smith Protests this requirement on behalf of electricity
15   consumers, and all citizens of the United States of America, the State of California, the very
16   diverse market of energy consumers, various related business interests, fair trade
17   commerce laws and UDC customers with the intent to protect the inherent freedoms of our
18   Nation.14
19           In support of this official Protest, SDC/Smith directs parties to review our Witness
20   Qualifications Statement in Phase II Written Testimony 15 and the Rebuttal16 to SDG&E’s
21   Motion to Strike over 50% of SDC/Smith’s Phase I Written Testimony.17 SDC/Smith’s


     13
        The American Presidency, Fourteenth Amendment, http://gi.grolier.com/presidents/aae/side/14amend.html
     14
        CPUC I.00-08-003 Investigation SDG&E Rate Hikes/Energy Shortage, [No wrongdoing found?]
     http://www.geocities.com/RULEMAKING/EMSMOTGREENTEAM.doc
     15
        Phase II Testimony and Answer to Questions, CPUC Rulemaking 99-10-025, Oct 2000
     http://www.geocities.com/RULEMAKING/Phase2.doc http://www.geocities.com/RULEMAKING/Phaseiit.doc
     16
        CPUC Rulemaking 99-10-025 SDC/Smith Rebuttal to SDG&E’s Motion to Strike Phase I Written Testimony,
     April 30, 2000 http://www.geocities.com/RULEMAKING/Rebuttal.doc
     17
        CPUC Rulemaking 99-10-025, Phase I Written Testimony, http://www.geocities.com/Eureka/1905/PHASEI.doc
                  112000 Eileen M. Smith, M.Arch.   Founder & CEO Since 1992              11
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                   PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
              California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
                Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                  Draft Decision Adopting Interconnection Standards November 20, 2000
               New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                     Pro Forma Tariff to Implement Net Energy Metering Provisions in
                       Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1    Motion for Discovery18 in Rulemaking 98-12-015 provides further background material to
 2    and our historic association with Enron Corporation, Amoco and British Petroleum dba
 3    Solarex Corporation suppressing SDC/Smith’s attempts to deploy BI-PV into the
 4    mainstream market since 1993.
 5         B. CPUC/CEC/CEOB/Utilities historically do not provide guidance, training,
 6            resources or non-prejudicial treatment for consumers and small for-profit
 7            business intervention in CPUC proceedings resulting in extreme and
 8            unconscionable hardship, therefore Section 7 strongly violates the 14th
 9            Amendment
10            Early in 1998, SDC/Smith consulted with BBD/Needham, the agency in charge
11    of the CPUC’s consumer education materials announcing customer choice in
12    deregulation. At their suggestion, we attempted to find a decision-maker at the CPUC.
13    We sustained several months of phone tag with Valerie Beck. When we finally talked to
14    her the first week of May 1998, she said she had no idea who to contact at the CPUC
15    related to our goal to include renewable DG technology in the last round of consumer
16    education materials. SDC/Smith immediately made a written complaint with
17    recommendations in a formal letter to Doug Long dated May 15, 1998 and sent follow-
18    up e-mails on May 20, 1998 to Michelle Cooke as Commissioner Duque’s assistant and
19    the Public Advisor’s office.19




      18
         CPUC Rulemaking 98-12-015, Solar Development Cooperative’s Motion for Discovery Regarding Antitrust
      Abuses of Enron/Amoco/BP Suppressing BI-PV Technology Since Fraudulent Takeover of Solarex Corp in 1984,
      California Public Utilities Commission Rulemaking 98-12-015, July 20, 1999
      http://www.geocities.com/Eureka/1905/DISCOVERY.doc
      19
         SDC Phase II Brief CPUC Rulemaking 99-10-025,
      http://www.geocities.com/SolarDevelopment/PHASEIIBRIEF.doc
     http://www.geocities.com/SolarDevelopment/DOUGLONG.doc
     http://www.geocities.com/SolarDevelopment/COOKE.doc
                    122000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              12
                              3535 East Coast Highway #216 Corona del Mar, CA 92625
                  949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1           Our complaint is and was focused on the barriers perpetuating the lack of self-generation
 2   building-integrated photovoltaics [BI-PV] technology in the competitive energy market with
 3   specific request to formally mitigate the following issues:
 4               (1) lack of consumer education about self-generation technology in the CPUC
 5                   deregulation consumer education program
 6                (2) the oppressive antitrust suppression by Amoco, Enron and British Petroleum
 7                   suppressing building-integrated photovoltaics from the mainstream market since
 8                   Amoco’s fraudulent takeover of the Solarex Corporation in 198420
 9           SDC/Smith’s initial two-page letter of complaint with attachments specifying the
10   advantages of including self-generation renewables technology in the CPUC consumer
11   education materials, and the potential disadvantages of leaving this important DG
12   renewables information out of the customer education materials describing consumer choices in
13   the competitive electricity market.21 SDC/Smith’s complaint was submitted in writing to
14   Doug Long twenty-seven very long, traumatic and difficult months ago.
15           Two letters, one from Michelle Cooke on May 20, 1998 and the other from Michael
16   McNamara Chief of Market Development for the Office of Ratepayer Advocates on May 28,
17   1998 specifically directed SDC/Smith to resolve the issues of our complaint in the proposed



     20
        Charging Ahead, John Berger, PhD, chapter: Pretty Polly, 1998
     Protecting Solar Access: A Guidebook for California Communities, by Martin Jaffe, American Planning
     Association, published by the California Energy Commission, March 1980 Contact: 500-80-013
     Solar Access: A Local Responsibility, by Joe Sogge published by the California Energy Commission
     The Solar Rights Act, 1978 Chapter 1154, 1978 California Statutes, sponsored by Assemblyman Levine
     The Solar Control Act, Chapter 1366, 1978 California Statutes, sponsored Assemblyman Imbrecht
     The Solar Directory 1974, published by Berkeley Press, University of California at Berkeley
     Ibid 4
     California State Photovoltaic Program Consultant Report by the Jet Propulsion Laboratory published by
     California Energy Commission 1978 http://www.geocities.com/SolarDevelopment/
     CPUC Rulemaking 99-10-025 Solar Development Cooperative’s Motion to Strike Least Cost Statements, July 23,
     2000 http://www.geocities.com/RULEMAKING/MOTSTRIKLEASTCOST.htm
     21
        California Prepares for Blackouts, by Fred Bayles, USA Today, August 1, 2000
     http://www.geocities.com/RULEMAKING/BLACKOUTS.htm
                  132000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              13
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   distributed generation [DG] Rulemaking.22 We had no idea what a Rulemaking was or that
 2   it would not officially start for nearly a year. Our complaint to the CPUC has still not been
 3   formally addressed or resolved by the CPUC staff or Commissioners who maliciously and
 4   knowingly induced SDC/Smith with promise of compensation and dispute resolution
 5   through a lengthy, expensive, degrading and abusive Rulemaking proceeding to meet their
 6   own special needs for public participants with full knowledge of the dangers and demands
 7   therein, and further knowing that they would not formally address the issues of
 8   SDC/Smith’s complaint. This malicious fraud represents unconscionable negligence!
 9           Solar Development Cooperative raised concerns related to our complaint in
10   consumer protection and renewables hearings at the CEC December 11, 199723 and June 3,
11   199824 and before the CPUC25 on October 12, 1998 with further testimony before the
12   California Energy Commission on December 7, 1998.26                       We wrote a follow-up letter to
13   Michael McNamara February 199927 because we had not received any information
14   regarding the DG Rulemaking where we were told our complaint would be formally
15   resolved. Mr. McNamara did not answer our e-mail and has not ever spoken with or met
16   with SDC/Smith despite our numerous attempts to contact him. On March 13, 1999,
17   SDC/Smith discovered on the CPUC website a Notice indicating the Opening Comments
18   for the DG Rulemaking were due on March 17, 1999. SDC/Smith filed Opening Comments

     22
        SEE APPENDIX B HEREIN
     CPUC Rulemaking 99-10-025 Phase II Brief, Appendix, page 56
     ,http://www.geocities.com/SolarDevelopment/PHASEIIBRIEF.doc
     23
        SDC Testimony Before the California Energy Commission For Renewables Program Management With Special
     Request to Differentiate Between Demand-site Photovoltaics Consumer Using Building-integrated Photovoltaics
     (BI-PV) and Remote-Site Photovoltaics, December 11, 1997
     http://www.geocities.com/Eureka/1905/CECHEARING.html
     24
        Testimony before California Energy Commission Consumer Education Trust Fund Hearing, June 3, 1998
     http://www.geocities.com/Eureka/1905/CECHEARJune3.html
     25
        California Public Utilities Commission, http://www.geocities.com/Eureka/1905/CPUCOCT12.html
     26
      Renewables Program Committee Workshop Hearing on Consumer Education Subaccount,
     December 7th, 1998 10:00 AM http://www.geocities.com/Eureka/1905/CECDEC7.doc
     27
       SDC E-mail Letter to Michael McNamara, Dir Market Development, ORA, February 15, 1999
     http://www.geocities.com/Eureka/1905/MCNAMARA.doc
                   142000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              14
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   presenting the two major complaints were raised in our letter of May 15, 1998. No formal
 2   hearing or resolution of SDC’s complaint,28 nor an avenue to assure timely consumer
 3   education and appropriate regulation of oil cartel suppression of BI-PV technology from the
 4   mainstream market.
 5           There is ongoing evidence in the record of the unnecessary and unconscionable
 6   hardship SDC/Smith has been forced to endure to participate in the DG proceedings.
 7   Further evidence of hazing and unnecessary abuse will be provided where this process is
 8   forced into a Superior Court action against the CPUC/CEC/ CEOB/Utilities and oil cartel
 9   associates jointly, wrongfully and illegally favoring fossil fuel deployment in distributed
10   generation29 where DG BI-PV have been market ready and affordable for 20 years.
11           After 18 months Michelle Cooke as Administrative Law Judge for the DG
12   Rulemakings and later the Commission Decision April 2000 claimed the CPUC would not
13   pay SDC/Smith any intervenor compensation because (1) SDC/Smith does not have an electric
14   bill in our name, (2) SDC/Smith is allegedly not representing residential consumers (which we very
15   much are representing), and (3) SDC/Smith might realize some future financial benefit. Non-
16   profit organizations, allegedly representing consumer rights, are regularly paid $100 to
17   $350 an hour for hardship compensation in CPUC proceedings. Many of these individuals are
18   involved in for-profit activities realizing further financial benefits from their intervenor roles,
19   today. On the last day of the Phase II Evidentiary Hearings, ALJ Cooke insisted that
20   SDC/Smith must pay $12,000 for the 2,000-page transcript despite the ongoing record in

     28
        CPUC Decisions Rulemaking 98-12-015 and 99-10-025, (1) SDC’s Motion for Discovery
     http://www.geocities.com/Eureka/1905/DISCOVERY.doc and (2) CPUC Final Decision 98-12-015 Consumer
     Education issues, October 25, 1999, (3) April 2000 Commission Decision Denies SDC Intervenor Compensation
     http://nic.cpuc.ca.gov/dg-r9910025/index.htm
     29
        Southern California Edison Ratemaking California Public Utilities Commission proceeding for authority to
     establish direct access service fees for competitive and regulated services, filed by SCE, June 23, 1999
     http://www.geocities.com/rulemaking/DIRECTACCESA9906040.htm
     Assembly Bill 918 Advice Letters SDG&E 1268-E (U 902-E), PG&E 2053-E (U 39 E) and 1495-E (U 338-E)
      Joint Agency Full Panel Hearing, CPUC Rulemaking 98-12-015, June 1, 1999
     http://www.energy.ca.gov/realaudio/archive/1999-06-01-am.ram
     http://www.energy.ca.gov/realaudio/archive/1999-06-01-pm.ram
                   152000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              15
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   R.98-12-015 and R.99-10-025 that we did not have the resources to research and prepare the
 2   papers for these proceedings. If we had $12,000 to spend, it would be used to educate the
 3   public about BI-PV technology, related incentives and CPUC Rulemakings. ALJ Cooke threatened
 4   to call the police if SDC/Smith did not agree to pay for the transcript.
 5           SDC/Smith told ALJ Cooke, and the transcriptionist manager not to send the transcripts
 6   unless they were sent gratis because we would not further jeopardize the credit of SDC for these
 7   proceedings, and did not have the money budgeted to purchase them. They sent the transcripts with
 8   no notice that they were not charging for them. SDC/Smith immediately sent them back and then
 9   wrote a letter to the transcriptionist with a copy to ALJ Cooke, Senator Sher and Governor Davis
10   indicating SDC would not pay for these transcripts, and not to send them back unless there was a
11   letter indicating SDC/Smith would not be charged for them. An E-mail from the transcriptionist
12   came indicating SDC/Smith would not be charged for the transcripts, which were being resent. They
13   arrived three days before the Phase II Brief was due.30 We managed to get our Phase II Brief filed
14   on the due date of October 27, 2000, but everyone else waited until November 13, 2000. Ongoing
15   lack of orientation, guidance and consideration of the extreme hardship small business and
16   individual intervenors face who need to Intervene in CPUC proceedings establishes clear and
17   unreasonable disadvantage making Section 7 of Rule 21 further illegal beyond the 14th Amendment
18   Rights to Equal Protection because it grossly violates antitrust laws as well. UDCs and oil cartels
19   are allegedly for-profit businesses and ongoing request for information establishes further
20   venerability for small business and individuals in inefficient and hostile CPUC proceedings
21   protecting UDCs and oil cartels.31


     30
        CPUC Rulemaking 99-10-025, SDC/Smith’s Phase II Brief,
     http://www.geocities.com/SolarDevelopment/PHASEIIBRIEF.doc
     31
        Letter from Ms. Boyd, SCE March 19, 1998 http://www.geocities.com/SolarDevelopment/BOYDSCE.gif
     Letter from Tom Dossey, Qualifying Facilities, March 9, 2000
     http://www.geocities.com/SolarDevelopment/DOSSEY.gif
     http://www.geocities.com/SolarDevelopment/DOSSEY2.gif
     CPUC Rulemaking 98-12-015 SDC/Smith Opening Comments March 17, 1999
     http://www.geocities.com/Eureka/1905/OPENING_COMMENTS.doc
     CPUC Rulemaking 98-12-015 SDC/Smith Response Comments May 17, 1999
     http://www.geocities.com/Eureka/1905/SDCRESPONSE_COMMENTS.doc
                  162000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              16
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
             California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1            Nearly two years after ALJ Cooke instructed SDC/Smith to raise the issues of
 2    antitrust abuse in the DG Rulemakings, she made a Ruling refuting her original
 3    directions32 by claiming CPUC does not regulate oil cartels in CPUC proceedings. This is a
 4    fraudulent statement not supported by statute, and is easily proven false by viewing the
 5    many proceedings at the CPUC which daily regulate oil cartels.33
 6             SDC/Smith was led to believe the DG Rulemaking, a process we were not familiar
 7    with, was the only avenue to formally resolve our complaints. SDC/Smith could have been
 8    involved in the DG Rulemaking and been provided a separate proceeding to expeditiously
 9    resolve the formal complaints made in writing to CPUC.
10            Section 7 Dispute Resolution in the Interim Decision and Draft Decision to Adopt
11    the Interconnection Standards and Section G in the UDC’s Advise Letters establishes
12    complete anarchy with extreme and unconstitutional control of the Rule 21
13    interconnection agreements and any related issue in dispute. Demand by CPUC to
14    dictate initial jurisdiction of any complaint or dispute to the satisfaction of the Commission
15    is unethical, unrealistic, unconstitutional and illegal. Utility Distribution Companies are
16    not non-profit service providers. UDC’s are highly competitive for-profit monopoly businesses
17    with the special interests of their stockholders foremost on their agenda as is clearly established
18    throughout the record of Rulemaking 98-12-015 and 99-10-025.34 Consumers and the
19    competitive marketplace must be protected from unreasonable jurisdictional requirements.
20                    “The CPUC shall have initial jurisdiction to interpret, add, delete or modify any
21            provision of this Rule or of any agreements entered into between the Electrical
22            Corporation and the Electricity Producer to implement this tariff (‘the implementing

     32May 20, 1999 SDC e-mail to Michelle Cooke CPUC staff for Commissioner Duque, and her reply directing
     SDC/Smith to raise the antitrust issues of complaint in DG Rulemaking, and emphasizing the CPUC, by law
     cannot show favoritism to any energy technology in a competitive market.
     http://www.geocities.com/SolarDevelopment/COOKE.doc
      33
        California Public Utilities Commission, http://www.cpuc.ca.gov
      34
        CPUC Rulemaking 99-10-025 Phase I and Phase II Issues Evidentiary Hearings Transcripts, SDC/Smith Cross
      Examination, June and September 2000
                   172000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              17
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1           agreements’) and to resolve disputes regarding the Electrical Corporation’s performance
 2           of its obligations under its electric rules and tariffs, the implementing agreements, and
 3           requirements related to the interconnection of the Electricity Producer’s Facilities
 4           pursuant to this Rule.”35
 5           The record in Rulemaking 98-12-015 and 99-10-025 clearly documents SDC/Smith’s
 6   very difficult and potentially tragic experience with the Commission in attempting to
 7   mitigate a serious complaint.36 CPUC Staff mislead SDC/Smith and took advantage of this
 8   and small company struggling in an extremely suppressed industry. CPUC staff
 9   fraudulently induced SDC/Smith to raise antitrust issues against powerful global oil
10   cartels. On April 2, 1999, two weeks after SDC/Smith filed our Opening Comments
11   BP/Amoco made a $28 billion take over of the entire Arco Corporation. Amoco/Enron had
12   used Solarex patents to sue Arco Solar from 1988-199137 claiming patent enfringement. The
13   CPUC either colloborated with BP/Amoco to facilitate this oppression delaying timely
14   consideration of the extreme material issues raised formally before them or they turned
15   tail and ran for some unknown reason. Either way they significantly endangered the
16   health and safety of SDC/Smith as a venerable participant raising a very serious and
17   consequential complaint before the CPUC, and they suppressed states evidence that there
18   was a serious oil cartel takeover problem dramatically slowing the mainstream deployment
19   of BI-PV. In 1978, concerns about oil cartel takeovers by small and large PV manufacturing
20   companies were raised in the California State Photovoltaic Program CEC Consultant Report.38




     35
        Interim Decision Adopting Interconnection Standards, Decision 00-11-001 Nov 2, 2000 Sec. 7
     http://www.geocities.com/rulemaking/14thAMENDMENT.html
     36
        Solar Development Cooperative filings for Rulemaking I, CPUC R.98-12-015. Rulemaking II, CPUC 99-10-025,
     http://www.geocities.com/Eureka/1905/EMSPAPERS.html
     37
        CPUC Rulemaking 99-10-025, SDC Motion for Discovery, July 30, 1999
     http://www.geocities.com/Eureka/1905/DISCOVERY.doc
     38
        California State PhotovoltaicProgram, Jet Propulsion Lab, California Energy Commission 1978
     http://www.geocities.com/SolarDevelopment/TABECONTPV1978CEC.doc
                  182000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              18
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
             California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   How long will it take before the state is held accountable for perpetuating this oppressive
 2   fraud?
 3            The Erin Brokovitch39 story (ca. 1964) was recently made into a motion picture. This
 4   historic documentary establishes clear and compelling evidence that PUC staff and
 5   Commissions traditionally misuse their authority and privilege to illegally delay official
 6   review of important complaints, requested adjudication and needed disbursal of
 7   information when dealing with venerable individuals and groups.
 8            SDC/Smith contacted the CPUC with a positive intent to collaborate in educating
 9   customers about renewable DG to protect the rights of consumers in deregulation to
10   own and install a solar electric generator with Net Metering.
11            The CPUC acts with significant insensitivity to venerable participants and
12   complainants. CPUC have been irresponsible in too many instances to allow approval of
13   the extreme and unconscionable hardship, and unreasonable liability in the proposed Rule 21
14   contracts for venerable BI-PV residential and commercial DG consumers up to 1 MWp. There are
15   no contracts for consumer interconnection to the grid to receive electricity for customers up to
16   1MWp. Further attempts by the private for-profit Utilities to gain stranded costs for alleged lost
17   revenue where DG is successfully deployed reveals the extreme oppressive misconceptions y at work
18   within this industry. All of the comments SDC/Smith submitted in the numerous Interconnection
19   Workshops were wrongfully and illegally removed without quasi-legislative due process of law before
20   the Draft Decision was filed.40



     39
        Erin Brokovitch Story (ca1964), Motion Picture Utility poisoned ground water, which killed people for years until
     young single mother started investigation, which resulted in damages. Brokovitch had to have numerous petitions
     and a review by a very arrogant and discouraging Utility review board before case could go to court. When a
     retired Utility employee attended a town meeting about the groundwater contamination, a document that was
     allegedly shredded surfaced to prove Utility staff had been aware of danger for years, but proceeded with plant
     anyway making people very sick and killing some.
     http://www.amazon.com/exec/obidos/ASIN/B00003CXFV/qid=975538221/sr=2-2/103-9173722-4127043
     40
        CPUC Rulemaking 99-10-025 Prehearing Conference, December 1, 1999
     http://www.geocities.com/Eureka/1905/PREHEARING9910025.doc
                   192000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              19
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
             California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1           The record for the DG Rulemakings 98-12-015 and 99-10-025; and numerous comments in the
 2   Interconnection Workshops indicated a photovoltaic system up to 1 MWp would not cause any surge
 3   problems for the grid, but could be venerable to grid surges. The Georgetown University Intercultural
 4   Center with a 300 kWp BI-PV41 roof installed in 1984 has no reports of problems where the system has
 5   adversely effected the grid or other consumers. UDCs must be held liable for grid damage to PV
 6   systems, which do not cause harm to the grid.
 7            The lack of expeditious or any resolution to SDC’s written complaints of May 15 and 20th,
 8   1998 with ongoing hazing over the past two years, with no pay for the thousands of hours of
 9   research, writing, testimony, travel and accommodations coupled with realistic consideration of the
10   recently publicized facts of the Erin Brokovitch Story make it absolutely impossible for SDC/Smith
11   to approve Section 7 Dispute Resolution for Rule 21 demanding complaints by and disputes with
12   venerable DG renewables market participants mandatorily be raised initially before the CPUC,
13   allowing jurisdiction at their whim with the alleged right to consider such matters whenever and
14   however CPUC decides to with or without notifying the party. Such requirement is in gross
15   violation of the 14th Amendment42 guaranteeing Equal Protection Under the Law even for a
16   ‘class of one’ and for all Citizens of the United States of America.
17                    “No complaint shall be entertained by the Commission, except upon its own
18           motion, as to the reasonableness of any rates or charges of any gas, electrical, water,


     CPUC Rulemaking 99-10-025 Letter of Concern to Commissioner Bilas, Dec 10, 1999 [No Response!]
     http://www.geocities.com/Eureka/1905/BILAS.doc
     CPUC Rulemaking 99-10-025 Systems Planning Workshop, December 15, 1999
     http://www.geocities.com/Eureka/1905/DCWORKSHOP.doc
     CPUC Rulemaking 99-10-025 Non-technical Straw Doc Proposal for a Revised Rule 21
     “Generating Facility Interconnections” San Francisco, California February 16, 2000
     http://www.geocities.com/Eureka/1905/NOTESHEARING.doc
     CPUC Rulemaking 99-10-025, Distribution System Planning and Operations Workshop Report
     SDC Writing Assignment Due on February 9, 2000 as Established During Workshop on January 26, 2000
     http://www.geocities.com/Eureka/1905/SPOCPUC.doc
     CPUC Rulemaking 99-10-025, CEQA Air Quality Streamlining Workshop, April 11, 2000
     http://www.geocities.com/Eureka/1905/CEQUA.doc
     41
        Georgetown University Intercultural Center in Washington, DC 300 kWp BI-PV rooftop
     http://www.geocities.com/Eureka/1905/GEORGETOWN.html
     42
        14th Amendment of the United States Constitution, (1868) http://deoxy.org/lib/14th.htm
                   202000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              20
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                     PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
               California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
                 Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                   Draft Decision Adopting Interconnection Standards November 20, 2000
                New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                      Pro Forma Tariff to Implement Net Energy Metering Provisions in
                        Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1              or telephone corporation, unless it be signed by the mayor of the president or
 2              chairman of the board of trustees or a majority of the council, commission, or other
 3              legislative body of the city or city and county within which the alleged violation
 4              occurred, or by not less than 25 actual or prospective consumers or purchasers of
 5              such gas, electric, water, or telephone service (See P.U. Code Sec. 1702).”43
 6              SDC/Smith’s recommendations in the Interconnection Standards Workshops as
 7   referenced and linked herein at Appendix C were accepted into the formal draft document,
 8   but all of SDC/Smith’s comments protecting small DG renewables consumers up to 1MWp were
 9   omitted from the document before the draft decision was made without due process of law.
10   Due process is not just reserved for oil cartels and Utilities.
11              The alleged excuse of concensus is not ethical in a quasi-legislative proceeding where
12   public have not been properly notified, the majority of the parties are not consumers, and
13   obviously have a majority agenda to perpetuate a monopoly of fossil fuel domination for
14   large remote-site and 1-20 MWp or larger DG in the industry. The meetings are further
15   dominated by Utility staff whose interest is their stockholders not small DG consumers or
16   their constitutional rights. They want their monthly bingo guaranteed from millions of
17   captured customers whose freedoms are being suppressed.
18              As the only small solar energy business involved throughout this distributed
19   generation proceeding, which had no BI-PV manufacturers present in contrast to the
20   eight involved in 1978 CEC Consultant Report, removal of SDC/Smith’s language and
21   issues revising Rule 21 was highly illegal. SDC/Smith was informally barred from the
22   Summer Workshop allegedly because the e-mail announcement bounced back
23   indicating our address was full. Six months later Cris Cooley, the paid for-profit
24   consultant who said he couldn’t contact me called to argue about why he had not
25   contacted SDC about the Summer Workshop. It is obvious in his leaving a somewhat

     43
          CPUC Rules of Practice and Procedure, http://nic.cpuc.ca.gov/rules/000402_rules-04.htm
                     212000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              21
                               3535 East Coast Highway #216 Corona del Mar, CA 92625
                   949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   hostile message on SDC’s voicemail that he could use the phone and might easily have
 2   called to let us know about the Summer Interconnections Workshop on Rule 21.
 3          Administrative alienation and threats, omission of our comments, unreasonably
 4   suppressive and hostile response to our testimony, and our attempts to establish fact in
 5   cross-examination, the disappearance of original documents filed before the CPUC, and
 6   the lack of formal reasoned consideration of our original complaints and subsequent
 7   filings in the proceeding we found ourselves a party to [or elsewhere] was ongoing
 8   throughout the DG Rulemakings coupled with berating demands to meet the rigorous
 9   schedule of adjudication with no resources. There was ongoing hazing and veiled
10   threats SDC/Smith must conform to CPUC staff agendas and related inconsistent
11   Decisions.
12          Residential and small to mid-size consumers or a small renewable energy
13   business simply cannot afford to participate in such time-consuming, expensive and
14   endless proceedings or activities to resolve disputes. They simply do not have the
15   resources or time to sustain such a difficult mediation environment even with costly
16   legal representation where the CPUC takes twenty-seven months to entertain a straight-
17   forward complaint. SDC/Smith sustained this process to assure we were fully-
18   appraised of the hurdles our DG BI-PV clients/customers could face. We cannot
19   recommend contracting with a UDC after this experience until the extreme liability
20   demands for small to mid-size DG BI-PV and the demand to provide CPUC initial
21   jurisdiction are removed from Rule 21. Present and historic CPUC administration
22   provides extreme favoritism and advantage to CPUC/CEC/CEOB/Utilities and fossil
23   fuel associates’ interests, which fully dictated development of Rule 21 Interconnection
24   Standards.
25   C.     Documented misrepresentation and coercion by state agencies, Utilities
26          and oil cartels endangers individual and small businesses in CPUC
27          proceedings
                222000 Eileen M. Smith, M.Arch. Founder & CEO Since 1992 22
                           3535 East Coast Highway #216 Corona del Mar, CA 92625
               949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1           Witness Qualification Statement in SDC’s Written Testimony44 for Phase II Issues
 2   clearly describes the misleading conditions under which SDC/Smith was fraudulently
 3   induced to become involved in the Distributed Generation Rulemakings. These staff
 4   knew very well from experience the proceeding would be a lengthy expensive process,
 5   and thereby negligently and intentionally caused extreme hardship, endangerment,
 6   physical harm and trauma to SDC/Smith by staff misrepresentation, ongoing hazing,
 7   and lack of orientation or expeditious resolution to our two material complaints. A
 8   person could reasonably expect a more responsible and accountable attitude for human
 9   life from state agencies.
10           There is clear and compelling evidence of an ‘orchestrated’ and ongoing campaign
11   of official and unreasonable harassment motivated by ‘sheer malice’ demonstrated
12   against SDC/Smith as a representative of a small solar energy business protecting
13   consumer rights is documented throughout the DG Rulemakings that strongly and
14   unnecessarily abridge our constitutional rights. The lack of responsible action on the
15   part of the CPUC to educate the public about the consumer right to choose DG BI-PV in
16   deregulation is for no other reason than self-serving special interests and malice. It is
17   difficult to understand how the Federal Energy Regulatory Commission could review the
18   record of the past two years, including numerous hearings to further gas pipeline
19   agendas, and still claim they find no misconduct by the UDCs45 where people are losing
20   their homes and businesses due to extreme and unnecessary rate hikes padding oil cartel
21   and UDC pockets! Ratepayers will not tolerate this abuse of power.46
22           The damages to SDC/Smith personally, professionally, physically, and
23   economically the past two years are extreme. Responsible progressive government
24   management needs to be put into place. In addition to SDC/Smith’s real and punitive
     44
        California Public Utilities Commission Rulemaking 99-10-025 Phase II Written Testimony
     http://www.geocities.com/RULEMAKING/Phase2.doc
     45
        CPUC Investigation 00-08-003 of the SDG&E Electricity Crisis with extreme rate hikes, August 2000
     46
        Davis demands energy refunds, price caps; OC Register, Nov 15, 2000 fp
                   232000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              23
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   damages, millions of citizens of the State of California have been deprived of their right
 2   to know about their DG BI-PV choices in deregulation, and to supportive cooperation
 3   facilitating the legislated incentives for renewables DG. Existing and potential BI-PV
 4   manufacturers have unnecessarily suffered under the tyranny and threat of abusive oil
 5   cartel takeovers. This concern that was formally communicated to
 6   CPUC/CEC/CEOB/Utilities by Silicon Material, Inc. in the Jet Propulsion Laboratory
 7   Consultant Report published by the CEC in 1978.47 It has not only been ignored by state
 8   agencies, but related tyranny and oppression of a competitive photovoltaic marketplace
 9   has been furthered by CPUC/CEC/CEOB and UDC propaganda claiming PV is NOT
10   market ready or affordable in recent publications48 when it has been for twenty years
11   according to CEC’s own documents from 1978. These state agencies have continued to
12   limit information to consumers and refuse to provide reliable cooperative service to
13   small up to mid-size DG renewables consumers’ initial inquiry to dispute resoultion.
14   They endanger venerable market participants and charge them with the responsibility to
15   regulate oil cartel and UDC fraud and oppressive mismanagement. SDG&E openly calls
16   Net Metering free-loading in their written testimony and cross-examination. The UDCs
17   have communicated their clear goal not to consider small to mid-size DG Renewables in
18   Systems Planning49 because they do not intend to facilitate a competitive market
19   through consumer education or infrastructure. It is obviously not in their company’s
20   interest. This extreme favoritism of for-profit UDCs violates CPUC code of ethics, the
21   California and National Constitution, and fair commerce laws.


     47
        California State Photovoltaic Program, California Energy Commission Consultant Report, March 1978, Jet
     Propulsion Laboratory Contract 5030-188; Table E-1 Summary of Telephone Contacts w/Eight California Solar
     Array Manufacturers, Desirable State Government Actions/Remarks/Silicon Material, Inc./ Concern: Provide R&D
     Funds. Low Interest Loans. Gov’t Contracts w/No Interest, Concern: Oil Company Takeover, page E-6
     http://www.geocities.com/SolarDevelopment/TABECONTPV1978CEC.doc
     48
        1996 Energy Technology Status Report, California Energy Commission,
     CPUC Rulemaking 99-10-025 Phase II Evidentiary Hearing, Exhibit 134, Distributed PV Systems 28.1
     49
        Systems Planning and Operations Management Workshops, December 1999 to March 2000
     http://www.geocities.com/Eureka/1905/RULEMAKINGII.html
                  242000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              24
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1           The organizations that allegedly manage the State of California energy industry have continually
 2   demonstrated significant collaboration with oil cartels and Utilities to facilitate major deployment of
 3   fossil fuel DG, while illegally, fraudulently and oppressively furthering policies and propaganda to
 4   suppress mainstream deployment of building-integrated photovoltaics [BI-PV], and consequently
 5   SDC/Smith’s business; thereby causing intentional energy shortages with the intent to wrongfully force
 6   taxpayer and ratepayer support of gas pipeline construction.50 Gas pipeline deployment and ongoing
 7   fuel costs are not revealed in AB970 incentive comparisons.
 8           The Solar Development Cooperative published our 15-year $4 billion business plan
 9   in 199451 and shared related information including the need for PV-grade silicon with
10   numerous parties of these government organizations. Our interest in deployment of BI-PV
11   is significant. We have spoken and been published at BI-PV conferences around the
12   world.52 We are the only intervenor in this proceeding whose comments have been
13   published in a national trade magazine.53 Residential consumers with sincere, but limited
14   interest at stake cannot legally be forced through lengthy abusive dead-end CPUC
15   proceedings to have their complaints or disputes with a UDC or oil cartel manufacturer
16   addressed.
17           Section 7 of CPUC Rule 21 dispute resolution process dramatically and illegally abridges
18   the constitutional right to Equal Protection Under the Law even as a ‘class of one’ for millions of
19   venerable ratepayers whose protection is guaranteed by the 14th Amendment.




     50
        Annual Energy Outlook 2000, Department of Energy
     California Energy Outlook 2000,CEC, Docket # 99-CEO-I and 00-CEO-VOL-II
      http://www.energy.ca.gov/energyoutlook/index.html
     California Public Utilities Commission, proceedings 1994-2000 http://www.cpuc.ca.gov
     51
        BI-PV NewsLETTER, Solar Development Cooperative, January 1997
     52
        Eileen M. Smith, M.Arch. Publications http://www.geocities.com/Eureka/1905/EMSPAPERS.html
     53
        DG or Not DG, Public Utilities Fortnightly, August 2000, OffPeak, pg 70
      http://www.geocities.com/Rulemaking/DGPUREAD.jpg
     http://www.geocities.com/Rulemaking/DGPUREADSMALL.jpg
                  252000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              25
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   II. CPUC/CEC/CEOB/Utilities/Oil Cartels Defrauded BI-PV Consumers 20 Years
 2           SDC/Smith founded our business to assure timely mainstream deployment of quality
 3   building-integrated photovoltaics supported by a reliable service industry in the United States
 4   and global marketplace. We did not pursue our business to get involved in regulating oil
 5   cartels or state agencies. The founder is an architect consultant, and our primary
 6   interest is in designing solar electric systems that blend beautifully and successfully into
 7   the built environment to generate clean electricity with minimal effort, maintenance or
 8   undue liability for DG BI-PV system owners. We have been involved in many
 9   interesting events the past nine years, globally. In addition to world travel, the two peak
10   moments in the history of our business, which significantly influenced our progress, are:
11   (1) discovery in 1994 of the 300 kWp BI-PV system installed on the roof of the
12   Intercultural Center at Georgetown University in 198454; and (2) discovery November
13   22, 2000 of the California State Photovoltaics Program, California Energy Commission
14   Consultant Report55 prepared by the Jet Propulsion Laboratory in March 1978. [Appendix
15   A]
16           In 1978 there were eight California BI-PV manufacturers.56 Today, all of the
17   California BI-PV manufacturers from 1978 do not exist, are well-hidden or have been
18   sued out of business or taken over. Two have disappeared as a result of abusive
19   litigation by Amoco/BP/Enron including Arco Solar57 and Advanced Photovoltaic
20   Systems. A global mail order company for BI-PV founded in the 1970s, Real Goods
21   located in Ukiah, California North of San Francisco is one of the few California PV
     54
        Georgetown University Intercultural Center 300 kWp BI-PV Rooftop installed 1984 Washington, DC
     http://www.geocities.com/Eureka/1905/GEORGETOWN.html
     55
        California State Photovoltaics Program, CEC, Consultant Report by Jet Propulsion Laboratory 1978
     http://www.geocities.com/SolarDevelopment/CALSTATEPVPROGRAM1978.html
     56
        California State Photovoltaic Program Consultant Report, JPL for CEC, 1978
     http://www.geocities.com/SolarDevelopment/TABECONTPV1978CEC.doc
     http://www.geocities.com/SolarDevelopment/TAE2PV1978CEC.doc
     57
        Solarex [dba Amoco/Enron] v. Arco Solar, Inc. 121 FRD 163 (1988) Ddel, 805 Fsupp 252 Fed Digest
     http://www.e5.org/pages/ccgar499.htm
                  262000 Eileen M. Smith, M.Arch.   Founder & CEO Since 1992              26
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   companies left from that era. In February, Real Goods took the domain name of
 2   SolarDevelopment to lure naïve consumers to their site and sell them stock in the name of
 3   the Solar Development Cooperative58 taking advantage of our years of global marketing
 4   and hard work. They could have just added this as a Meta Tag in their RealGoods
 5   website, however this is the third time Real Goods and their associates have attempted to
 6   put SDC/Smith out of business since 1993. Does Real Goods represent innovation or
 7   suppression? Their, not so grassroots oil baron accounting firm Deloitte and Touché, attempted
 8   to put SDC/Smith out of business in 1993 a year after we opened. They refused to pay a bill they
 9   said in writing to our attorney was legitimate; they just weren’t going to pay us knowing we had
10   related bills outstanding. In 1997, when an activist friend of John Schaffer, the founder of Real
11   Goods, told him SDC was curious about whether there was any connection between Deloitte
12   and Touché, Real Goods, and the lack of competition in the BI-PV industry, globally. John
13   Schaffer began sending degrading and threatening e-mails to SDC/Smith instead of assuring us
14   of any upstanding reasons they may have for using Deloitte and Touché for their accounting
15   firm. We finally copied our request to stop harassing us with obnoxious e-mails to NREL. The
16   e-mails stopped!
17           It is further curious that April 2, 1999, two weeks after we raised the complaint of
18   antitrust abuse in the CPUC DG Rulemaking as commanded by Ms. Cooke and Mr.
19   McNamara in their May 1998 letters; BP/Amoco made a $28 billion takeover of the
20   entire Arco Corporation and most of the Alaskan pipeline. Gas prices soared.
21   Engineers that SDC has been in touch with since the 1997 IEEE PV Specialists
22   Conference in Anaheim indicated the lawsuit between Amoco/Enron dba Solarex and
23   Arco Solar from 1988 to 1991 was very ugly. Money was no issue and settlement was
24   NOT an option! They wanted Arco Solar out of business.                         Engineers from United

     58
       Real Goods’s fraudulent misuse of the Solar Development Cooperative domain name luring naïve consumers to
     their website with our business name to sell stock, February 2000, discovered August 2000
     http://www.solardevelopment.com
                  272000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              27
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   Solar [sued 1993-97] and Advanced Photovoltaic Systems [sued 1995-97 and then taken
 2   over by BP Solar] that were also sued by Amoco/Enron dba Solarex provided a similar
 3   description of tyranny in relation to the lawsuits alleging enfringement Amoco had
 4   fraudulently taken control of in 1984. A sales manager with BP/Solar stated March
 5   1999 during a workshop training session at the APS Factory they had taken over in
 6   Fairfield that BP-Amoco intended to take over as many PV manufacturers as they
 7   could. “We don’t like to share!”, he said. BP/Amoco’s board did not approve the Arco
 8   Co. merger until March 31, 2000. And yet, the CPUC/CEC/CEOB/Utilities and fossil
 9   fuel proponents demand SDC/Smith to believe BP/Amoco would never do anything
10   underhanded, and is furthering, not suppressing a competitive BI-PV industry in the
11   global market. SDC/Smith announced a $4 billion business plan by 2010 in 1994.
12   BP/Amoco is doing $1 B.59
13           The State of California is allegedly the leader of photovoltaic deployment. Are they
14   innovators equally suppressed by oil cartel and Utility monopoly oppression, or are they the
15   oppressor? State agency collusion with fossil fuel market power to suppress BI-PV through
16   oppressive fraud has been obvious throughout the DG Rulemakings.60 In the 1978 California
17   Photovoltaic Program Consultant Report published by the CEC, the Jet Propulsion Laboratory, a




     59
        Business and Industry Global Climate Change Strategies Workshop, CEC, December 8, 1999
     http://www.energy.ca.gov/realaudio/archive/1999-12-08-am.ram
     http://www.energy.ca.gov/global_climate_change/1999-12-08_GCC_TRANSCRIPT.pdf
     60
        Ratesetting Wickland Pipelines, LLC; Commissioner Assigned: Carl W. Wood on September 13, 1999
       ALJ Assigned: William R. Stalder on September 13, 1999
       http://www.geocities.com/RULEMAKING/GASPIPEVIOLA9908050.htm
     UC-REGULATORY/MARKET STRUCTURE Investigation on the Commission's own motion to consider the costs
     and benefits of various promising revisions to regulatory and market structure governing California's natural gas
     industry and to report to the California Legislature on the Commission's findings.
     http://www.geocities.com/RULEMAKING/GASPUCREGI9907003.htm
     Staff Report: Competition and Consumer Protection Perspectives on Electric Power Regulatory Reform, United
     States Federal Trade Commission, July 2000; Existing Market Power In Generation
     http://www.geocities.com/RULEMAKING/FTCSTAFFREPORT.htm#EXISTING
                   282000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              28
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                     PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
               California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
                 Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                   Draft Decision Adopting Interconnection Standards November 20, 2000
                New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                      Pro Forma Tariff to Implement Net Energy Metering Provisions in
                        Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   very reputable source of information and a combustion engine and photovoltaics expert,
 2   predicted BI-PV would be fifty cents watt by 1986.61
 3              Slave labor was abolished in this Nation through significant efforts over a
 4   Century ago,62 attempting to reinstate it through fraudulent misrepresentation is highly
 5   innappropriate. It is obvious the only interest in having SDC/Smith involved in the
 6   hearings was for serving the state requirements alleging fair representation. Despite the
 7   energy crisis and energy shortages allegedly due to air conditioning demand,63 and the
 8   fact that BI-PV was established as market ready and affordable by the CEC in 1978, the thrust
 9   of the DG Rulemakings, Rule 21 and energy deployment by State organizations is fossil
10   fuel natural gas claiming BI-PV is not affordable or market ready.64 These fraudulent claims
11   that were published in CEC’s 1996 Energy Technology Status Report and furthered at the
12   June 1, 1999 Joint Agency Full Panel Hearing by Mr. Kulkarni, and throughout the DG
13   proceedings are fraudulent and self-serving.65                    BI-PV generates electricity the strongest
14   at peak air conditioning demand. It is the ideal energy choice to resolve the multifaceted
15   energy crisis in California. The largest importer of US photovoltaics in the world is
16   Germany. 66 These exported products could produce up to twice the daily value of
17   electricity in Southern California as they do in Germany. Where the
18   CPUC/CEC/CEOB/Utilities and their partners in crime keep pushing the fraudulent
19   claim that BI-PV is not affordable or market ready, California consumers will have 90% of

     61
          Cal State Photovoltaic Program Consultants Report of the CEC, by the Jet Propulsion Laboratory 1978,
     5030-188 Figure D-2 LSSA Price Goals/Achievements, page D-4
     http://www.geocities.com/SolarDevelopment/DEPLOYPV1978CEC.doc
     62
        By the time slavery was abolished in 1865 they had been joined by thousands of other women
     http://www.gendergap.com/military/USmil3.htm .
     63
        California readies for blackouts, by Fred Bayles, USA TODAY, fp
     http://www.geocities.com/RULEMAKING/BLACKOUTS.htm
     64
        CPUC Rulemaking 98-12-015 Joint Agency Full Panel Hearing June 1, 1999
     1996 Technology Status Report, California Energy Commission, [Mr. Kulkarni indicated this was the source of his
     claim at the Hearing on June 1, 1999 indicating BI-PV was not market ready or affordable!]
     65
        CPUC DG Proceedings Transcripts, Hearings and Decisions, 1992 to 2000 [R.98-12-015, R.99-10-025]
     66
        Renewable Energy Annual Report, Table 32, Energy Information Administration 1998
     http://www.eia.doe.gov/cneaf/solar.renewables/data/summary/table32.txt
                     292000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              29
                               3535 East Coast Highway #216 Corona del Mar, CA 92625
                   949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   their electricity generated by and dependent on escalating fossil fuel resources by the
 2   year 2010. 64% of the electricity consumed in California is already fossil fuels with 46%
 3   natural gas and a small, but significant portion of that large amount of electricity is co-
 4   generation DG.
 5           The entire DG Rulemaking should have been focused on small to mid-size
 6   renewables DG to develop a truly competitive marketplace AND INDUSTRY for these
 7   important technologies. There are already numerous proceedings directed exclusively
 8   and, thereby illegally, to fossil fuel deployment.67 90% of the projects funded under the
 9   CEC Rebate offering up to 50% off of a renewables DG system have been photovoltaic
10   projects. BI-PV is popular, practical, clean, easy to install, quiet, recyclable and provides 20 to 50
11   years of electricity where a system is well-maintained. There is a huge luxury home and
12   commercial industry in California that can readily afford and enjoy BI-PV, today! What we
13   cannot afford is oppressive war and tyranny furthering deployment of out-dated
14   destructive energy generation.68
15                    “1. Antitrust Enforcement The FTC has had substantial involvement in the
16           electric power industry through the PacifiCorp/Peabody convergence merger (5) and
17           in evaluating the competitive aspects of mergers between natural gas and electric
18           power utilities. (6) The United States Department of Justice (DOJ) has taken the lead
19           on most mergers that solely involve electric utilities. (7) In addition to merger
20           matters, the Commission has responsibility to prevent unfair methods of competition,
21           which may be especially acute as the electric power industry moves toward
22           competition.”69


     67
        Letter from Michelle Cooke, May 20, 1998; CPUC may not show favoritism to technologies.
     http://www.geocities.com/SolarDevelopment/COOKE.doc
     68
        CEQA Streamlining Air Quality Resources Board, CEC Workshop, April 2000
     http://www.geocities.com/Eureka/1905/CEQUA.doc
     69
        Staff Report: Competition and Consumer Protection Perspectives on Electric Power Regulatory Reform, July
     2000; US Federal Trade Commission
                  302000 Eileen M. Smith, M.Arch.   Founder & CEO Since 1992              30
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1           When SDG&E struck 50% of our Phase I Testimony,70 ALJ Cooke allowed the
 2   entire request to strike the record without one referral to our 49-page Rebuttal.71
 3   The information struck included photographs of DG BI-PV technology and
 4   discussion of various Phase I Issues including the impacts of pollution furthered by
 5   oppressive ownership and control of DG technologies.
 6                   September 11, 2000 SDC filed Emergency Motion to Mandate Renewables DG
 7   to Reduce Impact of SDG&E price hikes and energy shortages that are putting consumers out of
 8   their homes and closing their businesses according to testimony at the August 30, 2000
 9   hearings72. Despite lack of resources or compensation by the
10   CPUC/CEC/CEOB/Utilities, and significant and unnecessary hardship SDC managed to
11   attend 99% of the hearings and workshops for both DG Rulemakings to attempt to
12   resolve our complaint. From what we have discovered, we could not possibly
13   recommend initial jurisdiction of the CPUC for disputes or complaints if this is what
14   our customers would face as DG consumers. We were involved throughout the two DG
15   Rulemakings despite ongoing harassment, hazing and threats by CPUC and UDC staff,
16   and their fossil fuel associates. These problems are documented in our papers filed
17   within the Rulemakings and related correspondence. Enron and their associates
18   moderated and managed the documents for Rule 21 while Enron was denounced by
19   Amnesty International in the Wall Street Journal73 February 5, 2000 for police abuse




     70
        CPUC Rulemaking 99-10-025 SDC/Smith Phase I Written Testimony, April 11, 2000
     http://www.geocities.com/Eureka/1905/PHASEI.doc
     71
        CPUC Rulemaking 99-10-025 SDC/Smith Rebuttal to SDG&E’s Motion to Strike SDC’s Phase I Written
     Testimony, April 30, 2000 http://www.geocities.com/RULEMAKING/Rebuttal.doc
     72
        Emergency Motion to Mandate Deployment of DG & Fuel Cells for SDG&E Energy Crisis in Cooperation with
     AB970, CPUC Rulemaking 99-10-025, Sept 11, 2000
     www.geocities.com/Rulemaking/EMSMOTGREENTEAM.doc
     73
        SDC Response Comments to CEQA Streamlining, CEC Workshop, April 2000
     http://www.geocities.com/Eureka/1905/CEQUA.doc
                  312000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              31
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   against protestors of their project in India.74 SDC was strategically barred from Summer
 2   Interconnection Workshops finalizing the language for Rule 21.
 3           In light of the new evidence provided by the California State Photovoltaic Program
 4   a report by the respected Jet Propulsion Laboratory a leader in combustion technology
 5   and published by the California Energy Commission in 1978 with excerpts linked herein at
 6   Appendix A showing documented concerns about potential oil cartel takeovers
 7   expressed by Silicon Material, Inc.;75 SDC/Smith STRONGLY PROTESTS the
 8   requirement in the Draft Rule 21 as outlined in the Interim Decision, Draft Decision and
 9   SCE’s Advice 1498-E to force consumers to mitigate ANY interconnection complaints or
10   disputes first with the CPUC. Americans cannot afford twenty more years to
11   mainstream BI-PV technology!
12           A competitive energy industry or ratepayers are not to blame for price hikes,
13   corruption, and energy shortages. Make the CPUC/CEC/CEOB/UDC staff and their
14   fossil fuel associates who are mismanaging our energy industry accountable for their
15   actions, today! Deregulation is a healthy initiative where a truly competitive
16   marketplace is phased in by responsible management of the needs for new
17   technology deployment, and thereby proceedings exclusively focused on the
18   legislated agenda of clean renewable energy in deregulation. Ratepayers should not
19   be forced to pay for the market power and fraud being furthered by California state
20   agencies.76
21           In light of the obvious fraud documented throughout the historic data presented
22   herein, and the 28 month delay to resolve our complaints, SDC/Smith requires by tacit


     74
        Advent of the Headrick Solar-Voltaic DomeTM Power Station, 13th EU PV Solar Energy Conference, October
     1995; SDC/Smith applauded India for totally rejecting the 2000 MWp power plant.
     http://www.geocities.com/Eureka/1905/ADVHS-VDPS95.html
     75
        Cal State Photovoltaic Program, March 1978, Figure D-2, page D-4
     http://www.geocities.com/SolarDevelopment/DEPLOYPV1978CEC.doc
     76
        Davis demands energy refunds, price caps; OC Register, Nov 15, 2000 fp
                   322000 Eileen M. Smith, M.Arch. Founder & CEO Since 1992              32
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   procuration the CPUC, CEC, CEOB, and the Utilities submit a response outlining a
 2   plan to mitigate their malefescence in the appropriate jurisdiction within ten days of
 3   this Notice and Protest to immediately adjudicate this extreme and unconscionable
 4   fraud suppressing the life-preserving technology of BI-PV from the mainstream through
 5   published propaganda, threat, conspiracy, price fixing and ongoing violation of the
 6   CPUC Code of Ethics wherein those accountable may reduce liability and criminal
 7   charges in exchange for sorting out and preventing further tragedy for the Citizens of
 8   the State of California, the United States and the global citizenry.
 9   III.    Section 6.3 Net Generation Metering for Renewables Technology
10   A. Lack of Timely Inclusion of DG Renewables In Consumer Education Campaigns
11           The Renewable Energy incentives program established under AB1890 clearly
12   charges the CPUC with the responsibility to educate the public about distributed and self-
13   generation technology being provided incentives under the CEC buydown program.
14   While the CEC does provide limited consumer education in response to inquiries, the
15   CPUC provided a large consumer education program that did not include one word
16   about DG renewables technologies. CPUC needs to immediately remedy this
17   negligence with notification to all ratepayers within their monthly bill before approving
18   Rule 21 or AB970 incentives to avoid unfair competition and technology favoritism.
19           Further negligence is established in the record where the CPUC/CEC/
20   CEOB/Utilities are depended upon by consumers for technology information in the
21   energy industry, and these state agencies are responsible for consumer education about
22   renewables DG and they actually write and publish documents that fraudulently
23   misrepresent the market ready status and affordability of BI-PV technology.77 Throughout


     77
       Phase II Evidentiary Hearing Transcript, Rulemaking 99-10-025; Solar Development Cooperative’s Cross
     Examination of Mr. Smith, Southern California Edison; Mr. Biewald, energy expert from Cambridge, Massachusetts
     for UCAN, TURN, NRDC; David Townley, New Energy, September 2000 pages 1700, 1704 line 12, 1705 lines 1-28,
     1706, 1707 lines 14-28, 1708 lines 1-28, 1709, 1710 lines 1-9, 1732 PV Time of day benefit, 1736, 1737 lines 1-14,
                   332000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              33
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
             California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   the Phase II transcript energy experts respond to SDC/Smith cross-examination
 2   indicating that BI-PV has been market ready and affordable for a large market for twenty
 3   years.78 The negligent fraud published in the 1996 Energy Technology Status Report, and
 4   furthered at the Joint Agency Hearing for CPUC Rulemaking 98-12-015 has emphasis added
 5   and proven with the discovery of the 1978 California State Photovoltaic Program79 wherein
 6   the Jet Propulsion Laboratory indicates BI-PV was market ready in 1978 and would be
 7   fifty cents watt by 1986. [Appendix A] Where these experts design, plan and execute deep
 8   space missions, it is doubtful that their prediction is erroneous where a competitive BI-PV
 9   market is allowed to evolve. We consider the fact that PV is a silicon semiconductor. The past
10   twenty years significant research and advancements in satellite PV and computer silicon whose
11   raw materials are 900% more expensive than PV-grade silicon. It is very curious that
12   related reductions in price for PV have not been realized and that state agencies
13   continue to avoid their responsibility to educate the public about these technologies.
14   States agencies cannot arbitrarily suppress PV.
15            If the these state agencies have a substantial conflict of interest to meet this responsibility,
16   then it needs to be formally documented and such responsibility needs to be transferred to
17   another agency with as much funding and support as fossil fuels are provided by the
18   traditional state agencies to assure a truly competitive marketplace.
19   B. SDC’s Emergency Motion AB970 Reduce SDG&E Energy Crisis: 90 Days No Reply?
20   Sept. 12, 2000, SDC/Smith filed Emergency Motion to Reduce SDG&E Energy Crisis.
21            SDC/Smith formally requested timely response within 30 days to our filing due to the
22   urgency of the need to install BI-PV DG to reduce the impact of the SDG&E energy crisis, and


     1757 line 28, 1758 lines 1-28, 1760 lines 1-28, 1761 line 18, 1764 line 25; and other places in the record that are
     not specified here.
     1996 Energy Technology Status Report, CEC
     California Photovoltaic Program Consultant Report, JPL 5030-188 CEC 1978
     78
        CPUC Rulemaking 99-10-025, Phase II Evidentiary Hearings, Cross-Examination by SDC/Smith: Mr. Smith
     ORA, Mr. Biewald, Mr. Townley of New Energy, etc. September 2000
     79
        Cal State Photovoltaics Program, CEC 1978
                   342000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              34
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   the AB970 program solicitations, which are due December 14, 2000. This Emergency Motion
 2   provides important expansion of Net Metering incentives instead of reducing Net Metering like
 3   is proposed in fraudulent bills like AB918. We requested low to no interest loans for DG from
 4   1kWp to 1MWp, and consumer education about their customer options in DG renewables.
 5   This Motion was filed in cooperation with AB970 incentives and the ICE-T program proposed
 6   by the Solar Energy Industries Association in August. SDC/Smith literally urged the CalSEIA to
 7   become involved in the CPUC Rulemakings on DG. They finally submitted formal input at
 8   the January 12, 2000 Systems Planning Workshop at the CPUC corporate offices in San
 9   Francisco.
10          SDC/Smith is in full support of CalSEIA contributions and recommendations to the
11   CPUC Rulemaking even though we may have a more commercial perspective, and advance
12   programs and recommendations beyond their non-profit scope of interest. There are
13   numerous gas turbine and Utility interests filing comments and recommendations throughout
14   the DG Rulemakings. SDC/Smith, and finally CalSEIA after a year and one-half are the only
15   two intervenors actively working to protect the rights of consumers to generate their own
16   renewables BI-PV DG electricity.
17           The lack of immediate response to our EMERGENCY MOTION again demonstrates the
18   disrespectful attitude by CPUC staff toward the interests of venerable participants in CPUC
19   proceedings. The Net Metering Utility prejudice documented in Phase I Written Testimony
20   and Cross-Examination calling it free-loading and the numerous proceedings easily facilitated
21   for various special interests again demonstrates favoritism being furthered in CPUC
22   proceedings for Utilities and fossil fuel companies.
23          As is stated in our Summary herein, the CPUC must respond within ten days in tacit
24   procuration or by law the matters of SDC’s Emergency Motion, already 90 days delayed, will become
25   law, and thereby must be facilitated by state agencies and their Utility affiliates.
26   C. Net Metering Needs to Be Expanded to 1MWp and 1% Aggregate Output

                  352000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              35
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1          AB970 incentives for the Innovative Efficiency and Renewables Peak Reduction Program
 2   favors large DG deployment with the first size limits at 500 kW per project. The program
 3   hearing on October 16, 2000 was recorded, but none of the public comments were included.
 4   There was a bit of hostility toward SDC/Smith attempting to sort out who and how these
 5   incentives could be used to assist clients wanting to purchase BI-PV systems. This shows,
 6   again, that these state agencies are very difficult to influence, and that their programs favor
 7   fossil fuel deployment. BI-PV renewables DG is ideal for systems from 1 kWp to 300 kWp.
 8   AB970 made a last minute reduction to the size of eligible systems to 250 kWp. Why are they
 9   limiting these projects to such large sizes? Further, where these limited incentives are only
10   allowed for large BI-PV systems, it would be reasonable to increase Net Metering incentive
11   eligibility for systems up to 1MWp. Net Metering up to 1MWP would not increase the
12   aggregate output limit, but would allow a larger market with more resources for immediate
13   commercial installations of BI-PV systems. This extreme limiting of BI-PV DG incentives where
14   CPUC has incorporated the changes of AB918 is obviously intentional, uncooperative and illegal in
15   light of the energy crisis we are facing in California. There is no reason that the CPUC could not
16   under their own volition create a separate Net Metering program to compliment the AB970
17   program. There is ongoing flexibility and cooperation with oil cartel and gas deployment
18   interests. Why do the state agencies continually fight the needs of DG renewables
19   deployment? Considering the issues addressed in Sections I and II, it may be wise to revisit
20   the goals set out by Commissionor Lynch which would very much support an additional or
21   expanded Net Metering program for renewables DG that would compliment the AB970
22   incentives. This issue needs to be addressed by citing statutes indicating CPUC cannot
23   establish a Net Metering program of any type proposed.
24   D. Language Guaranteeing Net Metering for Longest Warranty in DG System Omitted
25          SDG&E’s attorney Sakarious calls Net Metering freeloading in his Phase I Testimony.
26   And, what is a request for payment to private UDCs for alleged lost revenues due to successful

                 362000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              36
                           3535 East Coast Highway #216 Corona del Mar, CA 92625
               949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   deployment of DG renewables? Cross-examination testimony attempted to explain that Net
 2   Metered systems weren’t paying their own way, while other Utility testimony is urging that
 3   they be paid stranded costs for lost revenues where DG is successfully deployed. Considering
 4   the limit is 0.1%, it is obvious these large protected monopolies need a huge handicap to succeed
 5   in business in competition.
 6           Venerable pioneering consumers financing BI-PV systems rely on Net Metering
 7   incentives. Their interests should be the priority for state agencies, not UDC stakeholders. Net
 8   Metering should be guaranteed by a cooperative Utility for twenty years or for the life of the
 9   longest warranty in their system. Where the present 0.1% limit is reached, this savings incentive
10   program, which involves no cash outlay, would amount to seventy-eight cents per customer per
11   year over twenty years. Only $1.5 billion has been paid in photovoltaic research since 1975.
12   That is $60 million a year and includes research for satellite PV technology. According to a
13   recent newsletter,80 $1.5 billion has been spent in the past four years on research for a cure for
14   Parkinson’s disease that has been traced to fossil fuel pollution exposure with numerous cases
15   reported by those in battle in Desert Storm and World War II.
16           SDC/Smith’s language creating protections for consumers to have Net Metering for the life of
17   the longest warranty in their system was wrongfully removed before the Draft Decision without due
18   process of law.81 The comments were submitted with concensus that they would be included. David
19   Townley of New Energy was in charge of writing the document for the Systems Planning
20   workshop and his associate Bruno Galliard; a representative from Enron was in charge of
21   writing documents for the Interconnection Standards Workshops.


     80
        Newsworthy Notes, October vol106 and Nov 2000 vol 107, Parkinson’s Resource Organization
     www.parkinsonsresource.org copsca@gte.net
     81
        CPUC Rulemaking 99-10-025 Interconnection Standards Workshop December 1999 to March, 2000 Non-
     technical Straw Doc Proposal for a Revised Rule 21 SDC/Smith’s Revisions to Rule 21
     “Generating Facility Interconnections” San Francisco, California February 16, 2000
     http://www.geocities.com/Eureka/1905/NOTESHEARING.doc

                   372000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              37
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   When SDC/Smith questioned this administrative oversight due to Mr. Townley claiming BI-
 2   PV is dangerous, our inquiry privately and then before the group was met with orchestrated
 3   hazing by Valarie Beck, and ongoing by Mr. Townley and his associates.
 4    AB918 Wrongfully Denies Net Metering to Direct Access ESP Consumers
 5            AB918 taking away the mandated requirement for ESPs to provide Net Metering for
 6   DG renewables systems refutes the purpose of the Net Metering program. Any company that
 7   is buying and selling electricity to consumers must, by law provide Net Metering as a choice to
 8   qualified systems.
 9          Such legislative interference on behalf of gas turbine DG ESPs with no response or
10   assistance to increase DG B I-PV to 1MWp to reduce the impact of the energy crisis is highly
11   unethical, unrealistic, unconstitutional, and criminally illegal where the interests of the
12   CPUC/CEC/CEOB and UDCs are obviously not in line with residential or small to mid-size
13   BI-PV DG consumers interconnected to the grid, and especially not those qualified the Net
14   Metering credit. AB918 illegally attempts to escape this incentive.
15   E. Contract Liability Unconscionable Barrier for Residential to Mid-size PV and Fuel Cell
16          Consumers
17          One size doe not fit all! The Interconnection Standards liability is unreasonable and
18   imbalanced for small to mid-size BI-PV renewables DG up to 1MWp.                             These customers are
19   actually more venerable than normal electricity consumers interconnected to the grid because
20   they have costly DG systems that could be adversely damaged by the powerful grid system
21   that is not appropriately managed.             Throughout the record for the DG Rulemakings,
22   technicians indicate there is little risk to the grid or other consumers where a BI-PV DG
23   systems is interconnected. BI-PV technology does not surge, and there are no documented
24   cases where a DG BI-PV system has adversely affected the grid.                        The provision in Rule 21 that
25   limits UDC liability for damage to a DG BI-PV system is unrealistic and unethical.                       Further,
26   the contract provision that provides extreme liability to a DG BI-PV system abridges

                 382000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              38
                           3535 East Coast Highway #216 Corona del Mar, CA 92625
               949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   constitutional rights where any related dispute or complaint must have initial jurisdiction with
 2   the CPUC. Such demand by the CPUC is highly unethical, unconstitutional and
 3   anticompetitive. It further abridges fair commerce and consumer protection laws.
 4          CPUC privilege to initial review was developed to assure reliability of the grid system
 5   as it grew over the past 100 years. With mass familiarity with electricity generation and
 6   related systems, it is not necessary or legal to provide such privilege to the CPUC, which
 7   traditionally protects the private UDC monopoly from its adversaries and competitors. It
 8   becomes further unethical to expect such favoritism and privilege where in a competitive
 9   diverse market the CPUC-managed generation will continue to decrease unless their role in
10   the industry adapts to the realities of the changes upon the horizon providing numerous
11   diverse DG technology opportunities.
12          Even in rare and extreme cases where people are dying due to UDC negligence like in
13   the Erin Brokovitch story (ca 1964), only through substantial hard work, expense, and good
14   fortune was a party able to gain regulatory assistance to prevail damages for people dying
15   from negligence under the tyranny of an extremely intimidating biased PUC adjudication.
16   How could one ethically expect a homeowner to prevail in defending themselves against
17   allegations by a UDC that their 2kWp system caused millions of dollars of damage on a grid?
18   The liability language is not realistic. It is further a risk where the CPUC refuses to provide
19   any ongoing consumer education about their DG choices and the technological diversity of DG
20   renewables.
21   FINDING OF FACT
22          I.        In a competitive energy industry with distributed generation, these past industry
23   demands of the protected UDC must be given up to a more balanced adjudication of the issues
24   in other venues. Revealing a complaint first before the CPUC provides unfair advantage to an
25   already venerable consumer or small business. The CPUC continually refused to address and
26   respect the reality of the issues we brought before them. They continue to impose further and

                  392000 Eileen M. Smith, M.Arch.   Founder & CEO Since 1992              39
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                       PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
               California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
                 Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                   Draft Decision Adopting Interconnection Standards November 20, 2000
                New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                      Pro Forma Tariff to Implement Net Energy Metering Provisions in
                        Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   extreme hardship for individual consumers and small business in this case. The only people
 2   who may be able to survive this type of dispute resolution demanding CPUC review before
 3   finding an outside source to mitigate, is a large company or oil cartel
 4              Oil cartels and Utilities are most likely to prevail in any initial review before CPUC
 5   jurisdiction because they have the extreme advantages of familiarity, size and resources
 6   compared to an individual consumer or small business. Fossil fuel associates were allowed to
 7   dominate and control the writing of the Systems Planning and Interconnection Workshops.
 8   Section 7 Dispute Resolution demanding initial CPUC jurisdiction is in violation of the 14th
 9   Amendment right to Equal Protection Under the Law.
10              Unfair competition with an imbalance of input in the CPUC proceeding is further
11   established by the CPUC’s intentional lack of consumer and public notification about the far-
12   reaching DG Rulemakings in the television news or newspaper; and with their lack of
13   attention to their legislated responsibility to educate the consumer about DG technologies in
14   the competitive market.
15              II.        CPUC/CEC/CEOB and Utility experts are or should be aware of the 1978
16   California State Photovoltaic Program Consultant Report by the Jet Propulsion Laboratory. In such
17   case that they have been aware of this document, they are committing extreme fraud by
18   publishing documents that refute the fact that BI-PV is market ready and affordable. Acro Solar
19   was selling BI-PV at $9 to $11 watt in 1978, and Spectrolab proposed a $1-2 million investment
20   to sell BI-PV at $2 to $5 watt in 1978.82 As SDC/Smith established in cross-examination, the
21   only issue of least cost that state agencies or the UDCs should concern themselves with is the
22   true and actual cost of interconnection as compared to non generating customers unless a
23   company is price fixing or involved in other types of suppressive cost issues. Consumers have a right
24   to buy whatever they want at whatever price they want. Consumers do not want to be forced
25   to be gouged by fossil fuel and Utility monopolies for technologies that are substantially

     82
          Cal State PV Program Consultant Report, JPL 5030-188, CEC 1978
                       402000 Eileen M. Smith, M.Arch.   Founder & CEO Since 1992              40
                                  3535 East Coast Highway #216 Corona del Mar, CA 92625
                      949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1   against their values. CPUC/CEC/CEOB wrongfully avoid their responsibility to protect the
 2   BI-PV industry from extremely oppressive market power suppressing BI-PV for twenty years!
 3   The record shows that CPUC Staff and UDC energy expert witnesses are negligently
 4   unprepared to make statements regarding BI-PV technologies due to lack of awareness of their
 5   own organization’s historic publications, and the historic 300 kWp project on the Intercultural
 6   Center at Georgetown University. ‘Sempra Asks for Permission to Pollute’ was reported the front
 7   page of an Oceanside newspaper recently. SDC/Smith provides notice to the CPUC that
 8   ratepayers have asked for twenty years for permission not to pollute!                          CPUC needs to
 9   comply with this request!
10          III. Net Metering and related renewable energy incentives are not being appropriately
11   managed with substantial detriment to this already extremely limited point of purchase credit.
12   Lack of consumer education coupled with refusal by the CPUC to address oil cartel oppression
13   of photovoltaics including their refusal to fund consumer education about BI-PV technology
14   even though BP-Amoco has taken over nearly 70% of the BI-PV manufacturing world-wide
15   since their fraudulent takeover of the Solarex Corporation in 1984. CPUC has wrongfully
16   delayed Ruling on SDC/Smith’s Emergency Motion while incorporating AB918 limiting Net
17   Metering. Net Metering laws must be protected, and AB918 must be annulled. Direct Access
18   ESPs must provide Net Metering to any customer requesting it, by law.
19          AB970 becomes a means for streamlining pollution where it is wrongfully focused on
20   fossil fuel generation of gas turbines.
21          Net Metering size increased up to 1MWp needs to be provided so clean energy can be
22   deployed by large companies where AB970 has a 250 kW limit. These companies can more
23   easily finance their projects and protect their interests than venerable residential consumers
24   wanting to purchase BI-PV DG.




                 412000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              41
                           3535 East Coast Highway #216 Corona del Mar, CA 92625
               949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                 PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
            California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
              Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                Draft Decision Adopting Interconnection Standards November 20, 2000
             New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                   Pro Forma Tariff to Implement Net Energy Metering Provisions in
                     Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1           CPUC has show in Rulemaking 98-12-015 and 99-10-025 extreme and illegal favoritism
 2   to further the gas interests of oil cartels with fraudulent suppression of BI-PV technology in
 3   violation of CPUC statutes as were quoted by ALJ Cooke in her May 20, 1998 letter to SDC.83
 4   REVIEW OF NOTICE IN TACIT PROCURATION
 5           SDC/Smith herein files this Notice and Protest in tacit procuration requiring the CPUC
 6   make formal and immediate notice within ten working days outlining a plan to notify all
 7   California ratepayers about their DG renewable choices and related incentives within 30 days
 8   or be actually and materially liable for demonstrating extreme favoritism to remote-site and DG
 9   fossil fuel technology, which is primarily deployed by large companies in lieu of ratepayers. 84
10   This negligence has emphasis added with the discovery of the 1978 California State Photovoltaic
11   Program proving the 1996 Energy Technology Status Report fraudulently claims BI-PV is not
12   market ready or affordable.
13           SDC/Smith demands by tacit procuration that the CEC immediately within 30 days
14   notify all ratepayers of the material misrepresentations and discrepancy in their published
15   documents claiming BI-PV DG renewable are not market ready or affordable when they have been
16   market ready and affordable for twenty years according to their 1978 documents and numerous energy
17   experts SDC/Smith cross-examined in Phase II Testimony.
18           Further, SDC/Smith demands by tacit procuration the CEC submit within ten days a
19   strategic plan to publish of an updated Energy Technology Status Report reflecting the real
20   problems with deployment of BI-PV DG. The document must include the issue of oil cartel
21   suppression, as this issue has been a large barrier to market development since the concern
22   surfaced in the 1978 California State Photovoltaic Program.




     83
       E-mail Letter from Michelle Cooke May 20, 1998 http://www.geocities.com/SolarDevelopment/COOKE.doc
     84
       Phase II Transcript, Rulemaking 99-10-025; Solar Development Cooperative’s Cross Examination of Mr. Smith,
     Southern California Edison; Mr. Wiebald, energy expert from Cambridge, Massachusetts, David Townley, New
     Energy, September 2000
                  422000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              42
                            3535 East Coast Highway #216 Corona del Mar, CA 92625
                949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1          The California State PV Program shows there were more California PV manufacturing
 2   companies in 1978 than there are now despite price decreases, a California energy shortage,
 3   Earth Day and extreme rate hikes. The CPUC needs to provide a separate proceeding to
 4   explore how they will remedy this tragic wrong furthered by the California state agencies
 5   suppressing BI-PV for twenty years.
 6          CPUC needs to respond within ten days to the Emergency Motion Mandating BI-PV and
 7   fuel Cells to reduce the SDG&E Energy Crisis. CPUC Ruling is illegally over the 90 day time
 8   limit, and has materially effected related opportunities where SDC requested a reply within 30
 9   days. SDC requested an increase of New Metering to 1MWP and a total of 1% aggregate output with
10   low-interest to no-interest loans for DG renewables as was legislated in AB970, as well as an increase in
11   consumer education about DG renewables .
12          CPUC cannot legally allow Direct Access ESPs not to provide Net Metering. AB918
13   shows extreme prejudice and favoritism toward fossil fuel companies wanting to deploy
14   electricity, but not respect legislated incentives in the industry.
15                                                       Respectfully submitted,
16
17

18                                                       Eileen M. Smith, M.Arch.
19                                                       Founder & CEO Since 1992
20                                                       SOLAR DEVELOPMENT COOPERATIVE
21                                                       3535 East Coast Highway #216
22                                                       Corona del Mar, CA 92625
23
24
25                                                       949-862-5826 Extension 1
26                                                       http://www.geocities.com/Eureka/1905
27                                                       scdres@yahoo.com
28
29
30                                              APPENDIX A

                 432000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              43
                           3535 East Coast Highway #216 Corona del Mar, CA 92625
               949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
           California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
             Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
               Draft Decision Adopting Interconnection Standards November 20, 2000
            New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                  Pro Forma Tariff to Implement Net Energy Metering Provisions in
                    Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1
 2   California State Photovoltaic Program California Energy Commission Consultant Report, by
 3   the Jet Propulsion Laboratory, March 1978
 4   http://www.geocities.com/SolarDevelopment/INTERLIBLOAN.doc
 5   http://www.geocities.com/SolarDevelopment/CALSTATEPVPROGRAM1978.html
 6   http://www.geocities.com/SolarDevelopment/COVERPV1978CEC.doc
 7   http://www.geocities.com/SolarDevelopment/JPLPV1978CEC.doc
 8   http://www.geocities.com/SolarDevelopment/TOCPV1978CEC.doc
 9   http://www.geocities.com/SolarDevelopment/APENDPV1978CEC.doc
10   http://www.geocities.com/SolarDevelopment/FIGSPV1978CEC.doc
11   http://www.geocities.com/SolarDevelopment/TABPV1978CEC.doc
12   http://www.geocities.com/SolarDevelopment/APENDIXDPV1978CEC.doc
13   http://www.geocities.com/SolarDevelopment/DECMGMTANAPV1978CEC.doc
14   http://www.geocities.com/SolarDevelopment/DEPLOYPV1978CEC.doc
15   http://www.geocities.com/SolarDevelopment/TAE2PV1978CEC.doc
16   http://www.geocities.com/SolarDevelopment/TABECONTPV1978CEC.doc
17
18
19
20
21
22
23
24
25
26

                 442000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              44
                           3535 East Coast Highway #216 Corona del Mar, CA 92625
               949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                    PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
               California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
                 Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                   Draft Decision Adopting Interconnection Standards November 20, 2000
                New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                      Pro Forma Tariff to Implement Net Energy Metering Provisions in
                        Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1    APPENDIX B
 2
 3   SDC EXHIBIT 3: Letters to and from Doug Long and Michelle Cooke, May 20, 1998
 4           http://www.geocities.com/SolarDevelopment/DOUGLONG.doc
 5           http://www.geocities.com/SolarDevelopment/COOKE.doc
 6   SDC EXHIBIT 4: Letter Michael McNamara, May 28, 1998
 7           http://www.geocities.com/SolarDevelopment/MCNAMARA.gif
 8           http://www.geocities.com/SolarDevelopment/MCNAMARA2.gif
 9           http://www.geocities.com/SolarDevelopment/EMSMCNAMARA.gif
10           http://www.geocities.com/SolarDevelopment/EMSMORSE.gif
11           http://www.geocities.com/Eureka/1905/MCNAMARA.doc
12   SDC EXHIBIT #134: Public Policy Institute of California, Statewide Survey
13           http://www.geocities.com/SolarDevelopment/PPIC.gif
14   SDC EXHIBIT 6: SDC Industry Matrix Motion to Compel Discovery July 20, 1999 (page 6)
15           http://www.geocities.com/Eureka/1905/DISCOVERY.doc
16
17
18    APPENDIX C
19
20    CPUC Rulemaking 99-10-025 Prehearing Conference, December 1, 1999
21    http://www.geocities.com/Eureka/1905/PREHEARING9910025.doc
22    CPUC Rulemaking 99-10-025 Letter of Concern to Commissioner Bilas, Dec 10, 1999 [No Response!]
23    http://www.geocities.com/Eureka/1905/BILAS.doc
24    CPUC Rulemaking 99-10-025 Systems Planning Workshop, December 15, 1999
25    http://www.geocities.com/Eureka/1905/DCWORKSHOP.doc
26    CPUC Rulemaking 99-10-025 Non-technical Straw Doc Proposal for a Revised Rule 21
27    “Generating Facility Interconnections” San Francisco, California February 16, 2000
28    http://www.geocities.com/Eureka/1905/NOTESHEARING.doc
29    CPUC Rulemaking 99-10-025, Distribution System Planning and Operations Workshop Report
30    SDC Writing Assignment Due on February 9, 2000 as Established During Workshop on January 26, 2000
31    http://www.geocities.com/Eureka/1905/SPOCPUC.doc
32    CPUC Rulemaking 99-10-025, CEQA Air Quality Streamlining Workshop, April 11, 2000
33    http://www.geocities.com/Eureka/1905/CEQUA.doc
34    Georgetown University Intercultural Center in Washington, DC 300 kWp BI-PV rooftop
35    http://www.geocities.com/Eureka/1905/GEORGETOWN.html
36    14th Amendment of the United States Constitution, (1868) http://deoxy.org/lib/14th.htm
37
38
39
40
41
42
43                                               CERTIFICATE OF DELIVERY

                     452000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              45
                               3535 East Coast Highway #216 Corona del Mar, CA 92625
                   949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com
                  PROTEST of the SOLAR DEVELOPMENT COOPERATIVE
             California Public Utilities Commission RULEMAKING 99-10-025 Interconnection Standards Rule 21
               Interim Decision 00-11-001 Adopting Interconnection Standards Nov. 2, 2000
                 Draft Decision Adopting Interconnection Standards November 20, 2000
              New Electric Rule 21, “Interconnection of Distributed Generation” Nov 17, 2000
                    Pro Forma Tariff to Implement Net Energy Metering Provisions in
                      Accordance with Assembly Bill 918 Advice Letters Nov 7, 2000


 1
 2           Eileen M. Smith representing the Solar Development Cooperative hereby certifies
 3   that on this 4th Day of December 2000, the document herein PROTEST AND NOTICE OF
 4   THE PROPOSED RULE 21 IN TACIT PROCURATION by the SOLAR DEVELOPMENT
 5   COOPERTIVE was served online to the service list for the California Public Utilities
 6   Commission [CPUC] Rulemaking 99-10-025, and filed by e-mail as is allowed with the
 7   California Energy Commission. The document herein was hand-delivered with an original
 8   and four copies for filing with the CPUC Outreach Office in San Francisco on December 5,
 9   2000.
10                                                         Respectfully submitted,
11
12

13                                                         Eileen M. Smith, M.Arch.
14                                                         Founder & CEO Since 1992
15                                                         SOLAR DEVELOPMENT COOPERATIVE
16                                                         3535 East Coast Highway #216
17                                                         Corona del Mar, CA 92625
18
19                                                         949-862-5826 Extension 1
20                                                         http://www.geocities.com/Eureka/1905
21                                                         scdres@yahoo.com
22




                   462000 Eileen M. Smith, M.Arch.  Founder & CEO Since 1992              46
                             3535 East Coast Highway #216 Corona del Mar, CA 92625
                 949-862-5826 Extension 1 http://www.geocities.com/Eureka/1905 scdres@yahoo.com

								
To top