To: California Energy Commission

From: Michael E. Boyd President CAlifornians for Renewable Energy, Inc. CARE

Subject: Commission consideration of PETITION TO AMEND THE COMMISSION DECISION for the PITTSBURG DISTRICT ENERGY FACILITY PROJECT 98-AFC-1C.

On November 24, 1999, the California Energy Commission (Energy Commission) received a petition from the Calpine Corporation. The petition, submitted under section 1769 (a) of the California Energy Regulations, requested approval to modify the description and design of the Pittsburg District Energy Facility. Specifically, the Calpine Corporation seeks approval to implement the following changes:

         Modify the process make-up water supply to allow for the use of potable water from the City of Pittsburg for process make-up water. Reclaimed water from the Delta Diablo Sanitation District and raw water from the Contra Costa Water District will be primary and secondary back-up sources, respectively.

         Add a second circuit to the 115 kV transmission line dedicated to USS-POSCO.

         Modify the fuel gas pipeline route to tie into the Delta Energy Center's gas line at the Delta project site, and include Delta's gas line to PG&E's Line 400.

         Provide back-up steam to DOW Chemical.

         Change the name of the project from Pittsburg District Energy Facility to Los Medanos Energy Center.

On March 16, 2000 Emilio Varanini III, Esq. Counsel for Southern Energy Delta filed a Petition for Reconsideration and in the Alternative for Re-opening the record in the Delta Energy Center. Intervenor Southern Energy Delta raises issues related to Calpine's proposed transmission line interconnects which where proposed by the applicant after the close of the evidentiary hearings in the Delta Energy Center.

Petitioner CARE has previously raised the issue of the PDEF being used as the alternative project to the proposed Delta Energy Center. Prior to and during the evidentiary hearings petitioner was informed that this alternative was not considered the environmentally preferred alternative because it failed to meet the project objectives of providing steam to DOW and generating capacity for USS-POSCO. The amendment to the PDEF to provide the changes cited above clearly meets these objectives. When petitioner questioned why this amendment was not included in the Commission's evaluation of the Delta Energy Center project alternatives, petitioner was informed that the evidentiary hearing on this project was closed therefore no further consideration was allowed.

Petitioner CARE is requesting that the consideration of the proposed amendments to the PDEF at the Commission's regular meeting of March 22, 2000 be continued until a later date which follows the Commission's decision on intervenor Southern Energy Delta's petition for reconsideration and in the alternative re-opening the record in the Delta Energy Center. Petitioner notified the Commission via e-mail, along with intervenor Joe Hawkins of Community Health First, that we wished the PDEF amendment process be public and that intervenors be given due opportunity for input in behalf of the public in this process. In light of the Southern Energy Delta's petition and the fact that the PDEF amendment proposes changes to the transmission line configuration as well (after the close of the Delta Energy Center's evidentiary hearings) intervenor CARE petitions the Commission to include the proposed PDEF amendments along with consideration of Southern Energy Delta's petition. If reconsideration of the Delta Energy Center is approved please include the PDEF amendments in your reconsideration. If the record is reopened in the Delta Energy Center please include the PDEF amendments as part of the evidentiary record.

Thank you for your consideration in this matter.

Michael Boyd President CARE

3-20-00

(408) 325-4690