UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
`Calpine Energy Services, L.P.
`Calpine Construction Finance Company, L.P.
`Calpine Energy Solutions, LLC
`Calpine Gilroy Cogen, L.P.
`Calpine King City Cogen, LLC
`Calpine PowerAmerica – CA, LLC
`CES Marketing IX, LLC
`CES Marketing X, LLC
`Champion Energy, LLC
`Champion Energy Marketing LLC
`Champion Energy Services, LLC
`Creed Energy Center, LLC
`Delta Energy Center, LLC
`Geysers Power Company, LLC
`Gilroy Energy Center, LLC
`Goose Haven Energy Center, LLC
`Johanna Energy Center, LLC
`Los Esteros Critical Energy Facility, LLC
`Los Medanos Energy Center, LLC
`Metcalf Energy Center, LLC
`North American Power and Gas, LLC
`North American Power Business, LLC
`O.L.S. Energy-Agnews, Inc.
`Otay Mesa Energy Center, LLC
`Pastoria Energy Facility L.L.C.
`Pine Bluff Energy, LLC
`Power Contract Financing, L.L.C.
`Russell City Energy Company, LLC
`South Point Energy Center, LLC
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`Docket No. ER10-2042-___
`Docket No. ER10-1942-___
`Docket No. ER17-696-___
`Docket No. ER10-1941-___
`Docket No. ER19-1127-___
`Docket No. ER10-1938-___
`Docket No. ER10-1934-___
`Docket No. ER10-1893-___
`Docket No. ER10-3051-___
`Docket No. ER10-2985-___
`Docket No. ER10-3049-___
`Docket No. ER10-1888-___
`Docket No. ER10-1885-___
`Docket No. ER10-1884-___
`Docket No. ER10-1883-___
`Docket No. ER10-1878-___
`Docket No. ER20-1699-___
`Docket No. ER10-1876-___
`Docket No. ER10-1875-___
`Docket No. ER10-1873-___
`Docket No. ER11-4369-___
`Docket No. ER16-2218-___
`Docket No. ER12-1987-___
`Docket No. ER10-1947-___
`Docket No. ER12-2645-___
`Docket No. ER10-1863-___
`Docket No. ER10-1862-___
`Docket No. ER12-2261-___
`Docket No. ER10-1865-___
`
`NOTIFICATION OF CHANGES IN STATUS
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`Pursuant to Section 35.42 of the regulations of the Federal Energy Regulatory Commission
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`(the “Commission”),1 the above-captioned subsidiaries of Calpine Corporation (“Calpine”) with
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`market-based rate authority (the “Indicated Calpine MBR Sellers”) hereby submit this notification
`
`
`18 C.F.R. § 35.42 (2021).
`
`1
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`

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`(this “Notification”) of four changes in status that occurred during the period July 1, 2021 through
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`December 31, 2022 (the “Reporting Period”). First, the Indicated Calpine MBR Sellers for which
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`the Midcontinent Independent System Operator, Inc. (“MISO”) market is a relevant market (the
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`“Calpine MISO MBR Sellers”)2 notify the Commission that a generation facility owned by one of
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`their affiliates in that market entered service during the Reporting Period. Second, the Indicated
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`Calpine MBR Sellers for which the California Independent System Operator Corporation
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`(“CAISO”) market is a relevant market (the “Calpine CAISO MBR Sellers”)3 notify the
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`Commission that generation facilities owned by certain of their affiliates in that market entered
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`service during the Reporting Period. Third, the Calpine CAISO MBR Sellers notify the
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`Commission of the expiration during the Reporting Period of a long-term power purchase
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`agreement (the “PG&E PPA”) under which 316.1 MW of generation capacity was committed to
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`an unaffiliated third party, Pacific Gas and Electric Company (“PG&E”). Fourth, the Indicated
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`Calpine MBR Sellers for which the Western Area Power Administration-Lower Colorado
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`(“WALC”) balancing authority area (“BAA”) is a relevant market (the “Calpine WALC MBR
`
`Sellers”)4 notify the Commission of certain limited deliveries within the WALC BAA during the
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`
`2
`The Calpine MISO MBR Sellers include: Calpine Energy Services, L.P. (“CES”), Calpine
`Construction Finance Company, L.P. (“CCFC”), Calpine Energy Solutions, LLC (“Calpine Solutions”),
`Calpine PowerAmerica – CA, LLC (“PowerAmerica”), CES Marketing IX, LLC (“CES Marketing IX”),
`CES Marketing X, LLC (“CES Marketing X”), Champion Energy, LLC (“Champion Energy”), Champion
`Energy Marketing LLC (“Champion Marketing”), Champion Energy Services, LLC (“Champion
`Services”), North American Power and Gas, LLC (“NAPG”), North American Power Business, LLC
`(“NAPB”), Pine Bluff Energy, LLC, and Power Contract Financing, L.L.C. (“PCF”).
`3
`The Calpine CAISO MBR Sellers include: CES, CCFC, Calpine Solutions, Calpine Gilroy Cogen,
`L.P., Calpine King City Cogen, LLC, PowerAmerica, CES Marketing IX, CES Marketing X, Champion
`Energy, Champion Marketing, Champion Services, Creed Energy Center, LLC (“Creed”), Delta Energy
`Center, LLC, Geysers Power Company, LLC, Gilroy Energy Center, LLC (“Gilroy”), Goose Haven Energy
`Center, LLC (“Goose Haven”), Johanna Energy Center, LLC, Los Esteros Critical Energy Facility, LLC,
`Los Medanos Energy Center, LLC, Metcalf Energy Center, LLC, NAPG, NAPB, O.L.S. Energy-Agnews,
`Inc., Otay Mesa Energy Center, LLC, Pastoria Energy Facility L.L.C., PCF, and Russell City Energy
`Company, LLC.
`4
`The Calpine WALC MBR Sellers include: CES, CCFC, Calpine Solutions, PowerAmerica, CES
`
`2
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`

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`Reporting Period.5 As discussed below, the changes in status reported herein do not materially
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`alter the facts upon which the Commission relied in granting market-based rate authorization to
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`the Indicated Calpine MBR Sellers.
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`I.
`
`COMMUNICATIONS
`
`Please address all correspondence, communications, pleadings, and other documents
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`related to these proceedings to the following persons:
`
`Sarah G. Novosel
`Senior Vice President, Government
`Affairs, and Managing Counsel
`Calpine Corporation
`717 Texas Avenue, Suite 1000
`Houston, TX 77002
`(202) 744-6320
`snovosel@calpine.com
`
`Neil L. Levy
`MCDERMOTT WILL & EMERY LLP
`The McDermott Building
`500 North Capitol Street, NW
`Washington, DC 20001
`(202) 756-8080
`(202) 756-8087 (facsimile)
`nlevy@mwe.com
`
`II.
`
`CHANGES IN STATUS
`A.
`
`New Generation Owned by Affiliates in the MISO Market
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`During the Reporting Period, a generation facility in the MISO market owned by one of
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`the Calpine MISO MBR Sellers’ affiliates entered service. As a result, the Calpine MISO MBR
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`Sellers have an additional affiliate that owns or controls generation in the MISO market:
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`
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`Glacier Sands Wind Power, LLC, an exempt wholesale generator (“EWG”) that
`owns and operates an approximately 184.9 MW (nameplate rating) wind-powered
`generation facility in Mason County, Illinois.6
`
`
`Marketing IX, CES Marketing X, Champion Energy, Champion Marketing, Champion Services, NAPG,
`NAPB, PCF, and South Point Energy Center, LLC (“South Point”).
`5
`These deliveries were previously discussed in an updated market power analysis recently submitted
`by the Calpine WALC MBR Sellers and various other subsidiaries of Calpine. See Updated Market Power
`Analysis, Docket Nos. ER10-1862-033, et al. (filed Jan. 3, 2022) (the “Southwest Triennial”). The Calpine
`WALC MBR Sellers are also reporting these deliveries out of an abundance of caution in order to ensure
`full compliance with Section 35.42 of the Commission’s regulations, 18 C.F.R. § 35.42 (2021), and prior
`Commission orders concerning their market-based rate authorization.
`6
`Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-198-000
`(filed July 21, 2021); Rainbow Energy Center, LLC, Notice of Effectiveness of Exempt Wholesale
`
`3
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`

`

`Affiliation with the generation-owning entity described above does not represent a material
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`departure from the characteristics upon which the Commission relied in granting market-based
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`rate authorization to the Calpine MISO MBR Sellers. MISO administers organized energy,
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`ancillary services, and capacity markets, and the Calpine MISO MBR Sellers are, therefore,
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`entitled to “rely[] on Commission-approved market monitoring and mitigation to address potential
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`horizontal market power” in the MISO market.7
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`B.
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`New Generation Owned by Affiliates in the CAISO Market
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`During the Reporting Period, generation facilities in the CAISO market owned by certain
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`of the Calpine CAISO MBR Sellers’ affiliates entered service. As a result, the Calpine CAISO
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`MBR Sellers have additional affiliates that own or control generation in (or assumed to be in) the
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`CAISO market:
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`
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`
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`Edwards Sanborn Storage I, LLC, an EWG that owns an approximately 116 MW
`(nameplate rating) battery energy storage system in Kern County, California;8
`
`Edwards Sanborn Storage II, LLC, an EWG that owns an approximately 117 MW
`(nameplate rating) battery energy storage system in Kern County, California;9
`
`
`Generator Status, Docket Nos. EG21-194-000, et al. (Oct. 5, 2021) (unreported); Glacier Sands Wind
`Power, LLC, Docket No. ER21-2445-000 (Sept. 9, 2021) (unreported) (granting market-based rate
`authority).
`7
`18 C.F.R. § 35.37(c)(4) (2021). See also Refinements to Horizontal Market Power Analysis for
`Sellers in Certain Regional Transmission Org. & Indep. Sys. Operator Markets, Order No. 861, 168 FERC
`¶ 61,040 at P 7 (2019) (describing the proposed rule adopted in Order No. 861 as allowing sellers to “state
`that they are relying on [regional transmission organization/independent system operator] mitigation to
`address the potential for market power issues that they might have” ) on reh’g, Order No. 861-A, 170 FERC
`¶ 61,106 (2020).
`8
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-172-
`000 (filed June 21, 2021); Blythe Mesa Solar II, LLC, Notice of Effectiveness of Exempt Wholesale
`Generator Status, Docket Nos. EG21-164-000, et al. (Sept. 15, 2021) (unreported) (“Blythe Mesa”);
`Edwards Sanborn Storage I, LLC, Docket Nos. ER21-1373-001, et al. (June 15, 2021) (unreported)
`(“Edwards Sanborn”) (granting market-based rate authority).
`9
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-178-
`000 (filed June 21, 2021); Blythe Mesa, Docket Nos. EG21-164-000, et al. (notice of effectiveness of EWG
`status); Edwards Sanborn, Docket Nos. ER21-1373-001, et al. (granting market-based rate authority).
`
`4
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`

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`
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`
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`
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`
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`
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`
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`ES 1A Group 2 Opco, LLC, an EWG that is developing an approximately 429 MW
`(nameplate rating) combined solar-powered generation facility and battery energy
`storage system in Kern County, California;10
`
`ES 1A Group 3 Opco, LLC (Group 3 Opco), an EWG that is developing an
`approximately 260 MW (nameplate rating) combined solar-powered generation
`facility and battery energy storage system in Kern County, California;11
`
`Henrietta D Energy Storage LLC, which owns and operates an approximately
`10 MW (nameplate rating) lithium-ion battery energy storage facility located in
`Lemoore, California;12
`
`Orange County Energy Storage 2 LLC, which owns and operates an approximately
`9 MW (nameplate rating) lithium-ion battery energy storage facility located in
`Santa Ana, California;13
`
`Orange County Energy Storage 3 LLC, which owns and operates an approximately
`6 MW (nameplate rating) lithium-ion battery energy storage facility located in
`Santa Ana, California;14
`
`Sagebrush ESS, LLC, an EWG that owns an approximately 179 MW (nameplate
`rating) battery energy storage system in Kern County, California;15
`
`
`10
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-171-
`000 (filed June 21, 2021); Blythe Mesa, Docket Nos. EG21-164-000, et al. (notice of effectiveness of EWG
`status); Edwards Sanborn, Docket Nos. ER21-1373-001, et al. (granting market-based rate authority).
`11
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-173-
`000 (filed June 21, 2021); Blythe Mesa, Docket Nos. EG21-164-000, et al. (notice of effectiveness of EWG
`status); Edwards Sanborn, Docket Nos. ER21-1373-001, et al. (granting market-based rate authority).
`12
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-7-000
`(filed Oct. 16, 2020); HDSI, LLC, Notice of Effectiveness of Exempt Wholesale Generator Status, Docket
`Nos. EG21-2-000, et al. (Jan. 14, 2021) (unreported) (“HDSI”); Henrietta D Energy Storage LLC, Docket
`No. ER21-9-000 (Nov. 13, 2020) (unreported) (granting market-based rate authority).
`13
`Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-8-000 (filed
`Oct. 16, 2020); HDSI, Docket Nos. EG21-2-000, et al. (notice of effectiveness of EWG status); Orange
`County Energy Storage 2 LLC, Docket Nos. ER21-86-000, et al. (Dec. 7, 2020) (unreported) (“Orange
`County”) (granting market-based rate authority).
`14
`Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-9-000 (filed
`Oct. 16, 2020); HDSI, Docket Nos. EG21-2-000, et al. (notice of effectiveness of EWG status); Orange
`County, Docket Nos. ER21-86-000, et al. (granting market-based rate authority).
`15
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-236-
`000 (filed Aug. 27, 2021); Ford County Wind Farm LLC, Notice of Effectiveness of Exempt Wholesale
`Generator Status, Docket Nos. EG21-211-000, et al. (Nov. 4, 2021) (unreported); Sagebrush ESS, LLC,
`Docket No. ER21-2782-000 (Oct. 20, 2021) (unreported) (granting market-based rate authority).
`
`5
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`

`

`
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`
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`
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`
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`
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`Valley Center ESS, LLC, an EWG that owns a 139 MW (nameplate rating) battery
`energy storage system in Valley Center, San Diego County, California;16
`
`Clines Corners Wind Farm LLC (“Clines Corner”), which is developing and will
`own and operate an approximately 324 MW (nameplate rating) wind-powered
`generation facility in Guadalupe and Torrance Counties, New Mexico;17
`
`Duran Mesa LLC (“Duran Mesa”), which is developing and will own and operate
`an approximately 105 MW (nameplate rating) wind-powered generation facility in
`Torrance County, New Mexico;18
`
`Red Cloud Wind LLC (“Red Cloud”), which is developing and will own and
`operate an approximately 350 MW (nameplate rating) wind-powered generation
`facility in Lincoln and Torrance Counties, New Mexico;19 and
`
`Tecolote Wind LLC (“Tecolote”), which is developing and will own and operate
`an approximately 272 MW (nameplate rating) wind-powered generation facility in
`Guadalupe and Torrance Counties, New Mexico.20
`
`
`16
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-103-
`000 (filed Mar. 8, 2021); Tumbleweed Solar LLC, , Notice of Effectiveness of Exempt Wholesale Generator
`Status, Docket Nos. EG21-99-000, et al. (June 23, 2021) (unreported); Edwards Sanborn, Docket
`Nos. ER21-1373-001, et al. (granting market-based rate authority).
`17
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-123-
`000 (filed Apr. 14, 2021); West Medway II, LLC, Notice of Effectiveness of Exempt Wholesale Generator
`Status, Docket Nos. EG21-119-000, et al. (July 21, 2021) (unreported) (“West Medway II”); Tecolote,
`Docket Nos. ER21-2336-000, et al. (granting market-based rate authority). This facility is physically
`located in the Public Service Company of New Mexico (“PNM”) balancing authority area (“BAA”), but
`has been studied as residing in the CAISO market in light of firm transmission rights held by Clines Corner.
`18
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-124-
`000 (filed Apr. 14, 2021); West Medway II, Docket Nos. EG21-119-000, et al. (notice of effectiveness of
`EWG status); Tecolote, Docket Nos. ER21-2336-000, et al. (granting market-based rate authority). This
`facility is physically located in the PNM BAA, but has been studied as residing in the CAISO market in
`light of firm transmission rights held by Duran Mesa.
`19
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-125-
`000 (filed Apr. 14, 2021); West Medway II. Docket Nos. EG21-119-000, et al. (notice of effectiveness of
`EWG status); Tecolote, Docket Nos. ER21-2336-000, et al. (granting market-based rate authority). This
`facility is physically located in the PNM BAA, but has been studied as residing in the CAISO market in
`light of firm transmission rights held by Red Cloud.
`20
`See Notice of Self-Certification of Exempt Wholesale Generator Status, Docket No. EG21-126-
`000 (filed Apr. 14, 2021); West Medway II. Docket Nos. EG21-119-000, et al. (notice of effectiveness of
`EWG status); Tecolote, Docket Nos. ER21-2336-000, et al. (granting market-based rate authority). This
`facility is physically located in the PNM BAA, but has been studied as residing in the CAISO market in
`light of firm transmission rights held by Tecolote.
`
`6
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`

`

`Affiliation with the generation-owning entities described above does not represent a
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`material departure from the characteristics upon which the Commission relied in granting market-
`
`based rate authorization to the Calpine CAISO MBR Sellers. All of these facilities were accounted
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`for in the indicative market power screens submitted in the Southwest Triennial, and those screens
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`were passed.21
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`C.
`
`Expiration of the PG&E PPA
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`The PG&E PPA was a long-term agreement under which the output of the following
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`facilities (collectively, the “Peaking Facilities”) was fully committed on a firm basis to an
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`unaffiliated third party, PG&E, through December 31, 2021:22
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`
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`
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`
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`
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`
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`the Gilroy Peaking Energy Center, an approximately 135 MW (summer rating)
`natural gas-fired generation facility in Santa Clara County, California that is owned
`and operated by Gilroy;
`
`the Riverview Energy Center, an approximately 46.1 MW (summer rating) natural
`gas-fired generation facility in Contra Costa County that is owned and operated by
`Gilroy;
`
`the Lambie Energy Center, an approximately 45 MW (summer rating) natural gas-
`fired generation facility in Solano County, California that is owned and operated
`by Gilroy;
`
`the Creed Energy Center, an approximately 45 MW (summer rating) natural gas-
`fired generation facility in Solano County, California that is owned and operated
`by Creed; and
`
`the Goose Haven Energy Center, an approximately 45 MW (summer rating) natural
`gas-fired generation facility in Solano County, California that is owned and
`operated by Goose Haven.
`
`
`21
`See Southwest Triennial, Attachment A, Affidavit of Julie R. Solomon, Exhs. GH-4, GH-5, GH-6,
`GH-7 (the “Solomon Affidavit”). See also id., Exhs. GH-8, GH-9 (screens for the PNM BAA).
`22
`The output of other facilities had previously been committed under the PG&E PPA through
`December 31, 2017.
`
`7
`
`

`

`The PG&E PPA expired on December 31, 2021, and, as a result, the output of the Peaking
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`Facilities is no longer committed to PG&E.
`
`The relevant market is the CAISO market, where the Peaking Facilities are located. The
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`Calpine CAISO MBR Sellers submitted indicative market power screens for the CAISO market in
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`the Southwest Triennial.23 Those screens would still be passed if they were adjusted to account
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`for the expiration of the PG&E PPA. Specifically, the Pivotal Supplier screen would still be passed
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`if the aggregate capacity of the Peaking Facilities (316.1 MW) were added to “Seller’s
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`Uncommitted Capacity” (Line Q), as the adjusted figure (6,687.1 MW) would still be less than the
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`“Net Uncommitted Supply” (Line P) (33,692 MW).24 The Wholesale Market Share screen would
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`likewise be passed for all seasons if this capacity were added to the “Seller’s Uncommitted
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`Capacity” (Line R) figures for each season, as the market shares would range between 13.5 percent
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`and 15.6 percent, below the 20 percent threshold.25
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`D.
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`Limited Deliveries within the WALC BAA
`
`In an October 26, 2011 order, the Commission found that, notwithstanding certain screen
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`failures in the WALC BAA, subsidiaries of Calpine with market-based rate authorization had
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`“rebutted the presumption of horizontal market power and satisfy the Commission’s horizontal
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`market power standard for the grant of market-based rate authority.”26 Among other things, the
`
`
`23
`See Solomon Affidavit, Exhs. GH-4, GH-5.
`24
`See id., Exh. GH-4.
`25
`See id., Exh. GH-5. Specifically, the adjusted market shares would be (1) 13.9 percent
`(6,901.1 MW (6,585 MW plus 316.1 MW) divided by 49,679 MW) for the Winter season; (2) 13.5 percent
`(6,662.1 MW (6,346 MW plus 316.1 MW) divided by 49,204 MW) for the Spring season; (3) 15.6 percent
`(6,709.1 MW (6,393 MW plus 316.1 MW) divided by 43,135 MW) for the Summer season; and
`(4) 14.4percent (6,692.1 MW (6,376 MW plus 316.1 MW) divided by 46,405 MW) for the Fall season.
`26
`Calpine Energy Servs., L.P., 137 FERC ¶ 61,085 at P 22 (2011) (the “October 2011 Order”), on
`clarification, 145 FERC ¶ 61,191 (2013). See also Calpine Constr. Fin. Co., L.P., Docket Nos. ER10-
`2042-008, et al. (Dec. 9, 2014) (unreported) (relying on the reasoning of the October 2011 Order in
`
`8
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`

`

`Commission relied on evidence demonstrating that, during the relevant study period, less than one
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`percent of the energy generated by a generation facility in the WALC BAA owned by South Point
`
`(the “South Point Facility”) was sold in that BAA.27 The Commission stated that “should the
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`Calpine [WALC MBR Sellers] or any of their affiliates make sales in the WALC [BAA], we would
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`consider this a change in the circumstances” that would need to be reported through a change in
`
`status filing.28
`
`As discussed in greater detail in the Southwest Triennial, which is hereby incorporated by
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`reference pursuant to Section 35.19 of the Commission’s regulations,29 there have been, since
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`August 2021, occasions when power contractually sold outside the WALC BAA has been
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`delivered within the WALC BAA, and such deliveries are expected to continue in the future.30
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`Specifically, these deliveries occurred (and are expected to continue to occur) pursuant to a long-
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`term tolling agreement (the “APS PPA”) between South Point and Arizona Public Service
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`Company (“APS”). While sales under the APS PPA are made at specified points on the metered
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`boundary of, and thus outside, the WALC BAA, APS has the right to request deliveries at
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`alternative points, and South Point must make commercially reasonable efforts to accommodate
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`such requests. On various occasions beginning in August 2021, APS has requested, and South
`
`Point has made, limited deliveries at points within the WALC BAA pursuant to the APS PPA. It
`
`
`accepting updated market power analysis for the Southwest region); Calpine Energy Servs., L.P., Docket
`Nos. ER10-2042-021, et al. (Nov. 2, 2016) (unreported) (same).
`27
`See October 2011 Order, 137 FERC ¶ 61,085 at P 24.
`28
`Id. (citing 18 C.F.R. § 35.42(a)).
`29
`18 C.F.R. § 35.19 (2021). See also Reporting Requirement for Changes in Status for Pub. Utils.
`with Market-Based Rate Auth., Order No. 652, 110 FERC ¶ 61,097 at P 34 (noting that “a market-based
`rate seller may incorporate by reference in its notice of change in status any filings regarding the change in
`status made pursuant to other reporting requirements”), on reh’g, 111 FERC ¶ 61,413 (2005).
`30
`See Southwest Triennial at 33-35.
`
`9
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`

`

`is the Calpine WALC MBR Sellers’ understanding that, in all cases, APS has arranged for
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`transmission of the electricity out of the WALC BAA, consistent with the fact that APS is a load-
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`serving utility all of whose load is located outside the WALC BAA, and it is the Calpine WALC
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`MBR Sellers’ expectation that this will continue to be the case in the future.
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`As discussed in the Southwest Triennial and the affidavit of Julie R. Solomon attached
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`thereto,31 South Point should not be considered to have made “sales in the WALC [BAA]”32 as a
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`result of these limited deliveries within the WALC BAA pursuant to the APS PPA.33 Nonetheless,
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`out of an abundance of caution, the Calpine WALC MBR Sellers are reporting that such deliveries
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`have occurred and are expected to continue to occur in the future pursuant to the APS PPA.
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`III. CONCLUSION
`
`For the reasons stated above, the Indicated Calpine MBR Sellers respectfully request that
`
`the Commission accept this notification of changes in status.
`
`Respectfully submitted,
`
`
`Id., Attachment A, Julie R. Solomon (the “Solomon Affidavit”).
`October 2011 Order, 137 FERC ¶ 61,085 at P 24.
`See Southwest Triennial at 33-35; Solomon Affidavit at 4, 16.
`
`31
`32
`33
`
`10
`
`

`

`CALPINE ENERGY SERVICES, L.P.
`CALPINE CONSTRUCTION FINANCE COMPANY, L.P.
`CALPINE ENERGY SOLUTIONS, LLC
`CALPINE GILROY COGEN, L.P.
`CALPINE KING CITY COGEN, LLC
`CALPINE POWERAMERICA – CA, LLC
`CES MARKETING IX, LLC
`CES MARKETING X, LLC
`CHAMPION ENERGY, LLC
`CHAMPION ENERGY MARKETING LLC
`CHAMPION ENERGY SERVICES, LLC
`CREED ENERGY CENTER, LLC
`DELTA ENERGY CENTER, LLC
`GEYSERS POWER COMPANY, LLC
`GILROY ENERGY CENTER, LLC
`GOOSE HAVEN ENERGY CENTER, LLC
`JOHANNA ENERGY CENTER, LLC
`LOS ESTEROS CRITICAL ENERGY FACILITY, LLC
`LOS MEDANOS ENERGY CENTER, LLC
`METCALF ENERGY CENTER, LLC
`NORTH AMERICAN POWER AND GAS, LLC
`NORTH AMERICAN POWER BUSINESS, LLC
`O.L.S. ENERGY-AGNEWS, INC.
`OTAY MESA ENERGY CENTER, LLC
`PASTORIA ENERGY FACILITY L.L.C.
`PINE BLUFF ENERGY, LLC
`POWER CONTRACT FINANCING, L.L.C.
`RUSSELL CITY ENERGY COMPANY, LLC
`SOUTH POINT ENERGY CENTER, LLC
`By:
` /s/ Neil L. Levy
`
`
`
`Neil L. Levy
`David G. Tewksbury
`MCDERMOTT WILL & EMERY LLP
`The McDermott Building
`500 North Capitol Street, NW
`Washington, DC 20001
`
`
`
`Sarah G. Novosel
`Senior Vice President, Government
`Affairs, and Managing Counsel
`717 Texas Avenue, Suite 1000
`Houston, TX 77002
`
`Counsel for the Indicated Calpine MBR Sellers
`
`Dated: March 3, 2022
`
`11
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`

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`CERTIFICATE OF SERVICE
`
`I hereby certify that I have caused the foregoing document to be served upon each person
`
`designated on the official service lists compiled by the Secretary of the Federal Energy Regulatory
`
`Commission in these proceedings.
`
`Dated in Washington, D.C., this 3rd day of March, 2022.
`
` /s/ Neil L. Levy
`Neil L. Levy
`
`
`
`
`
`
`
`