Douglass & Liddell is an association of legal professionals with more than a half century of collective experience in regulatory and transactional work for the energy industry, with a particular emphasis on the development of competitive markets in California and the West.

Our firm has been a prominent voice in all electricity restructuring proceedings for parties advocating competition and free markets. We have helped producers, suppliers, and end users navigate the labyrinth of California energy regulations and obtain cost-effective and reliable energy supplies. Our experienced and highly qualified practitioners focus on energy issues on a full-time basis, unlike large law firms where energy may be a sideline or an occasional practice area. We take pride in being actively engaged in energy industry developments that may affect our clients and alerting them on a real-time basis so they may respond decisively.

SAMPLE REPRESENTATIONS

• The firm was responsible for the drafting of a petition filed at the Public Utilities Commission in December of 2006 asking that it institute a rulemaking and investigation into how the direct access market can be reopened in California. With the support of 185 governmental, educational, healthcare, commercial and industrial parties, the petition noted that the fundamental right of choice has now been denied to all but a few existing direct access customers for over five years and that other California end-users need to have the ability to choose their electricity provider restored as expeditiously as possible, In conjunction with that petition, the firm has helped to organize and serves as counsel to the Alliance for Cooperative Energy Solutions, or ACES, which will be spearheading the movement for the restoration of consumer choice in California. We are also advising current and potential commercial and industrial buyers and sellers that want to prepare for reinstatement.
• The firm recently helped Stirling Energy Systems successfully negotiate 20-year power purchase agreements with Southern California Edison and San Diego Gas & Electric to develop the world's two largest solar power projects in the desert region of southern California. Under the agreement with Edison, Stirling will deliver 500 MW of solar power from the SES Solar One project, with an option to expand to 850 MW. Under the agreement with SDG&E, Stirling will deliver 300 MW from the SES Solar Two project, with the ability to expand to 900 MW. Together, the two projects will dwarf the combined capacity of all existing solar power plants. Most importantly for California, the projects should enable Edison and SDG&E to each achieve their state-mandated 20% renewable power procurement goals.
• The firm represents the largest advocacy organization of electric service providers in California, the Alliance for Retail Energy Markets. The Alliance serves as a regulatory advocacy group for both ESPs and the customers they serve, as an active participant in all regulatory proceedings at the California Public Utilities Commission that affect direct access rights. We successfully advocated for a cap on direct access exit fees, for rejection of a proposal to suspend direct access retroactively and for an equitable sharing of DWR bond costs among all customers, so that direct access customers were not disproportionately burdened by these charges.
• We assisted in the founding of the Western Power Trading Forum, which is a broadly based membership organization dedicated to enhancing competition in Western electric markets. WPTF provides a voice through which members can influence the development of market structures throughout the region. The membership of WPTF includes energy service providers, scheduling coordinators, generators, federal power agencies and municipal utilities, all of which are active participants in the restructured California electricity market. With the assistance of the firm, WPTF is actively engaged in regulatory proceedings at the Federal Energy Regulatory Commission and the California Public Utilities Commission.
• Douglass & Liddell founded and represents the Direct Access Customer Coalition (DACC). DACC is a regulatory alliance of commercial, industrial and governmental customers who have opted for direct access for some or all of their loads. DACC membership includes the California State Universities, Wal-Mart, Kinder-Morgan, BreitBurn Energy, Cargill, Safeway, Federated/Macy's, Oakley, Albertson's Target, etc.
• The firm represents Transwestern Pipeline Company in proceedings before the Public Utilities Commission. This requires the firm to keep abreast of all major natural gas regulatory proceedings affecting Pacific Gas & Electric Company, Southern California Gas Company and San Diego Gas & Electric Company.
• The firm represents several electricity and natural gas customers with regard to various contractual and regulatory matters. As an example, we successfully petitioned the Public Utilities Commission to modify a Commission Resolution which had unfairly burdened customers who received service under the interruptible tariffs and economic development rate programs of Southern California Edison Company during the electricity price crisis of 2000-2001. On behalf of a manufacturer of plastic bottles, the firm successfully advocated that customers under these rates should be permitted to opt out from these rates, retroactive to the original December 7, 2000 date of issuance of the Resolution, with all liquidated damages under the minimum charge provision waived. This action included forming a coalition of similarly situated customers and meeting with Commission representatives to explain why the petition should be granted. We also recently assisted a Southern California Irrigation District to transfer its direct access electricity account from a municipal utility to a retail energy service provider.
• We are currently advising developers participating and planning to participate in electric utility power supply requests for proposals in California. The firm represents several of the leading North American energy efficiency service companies and renewable energy power plant developers with ongoing design-build energy efficiency, outsourcing, demand response and energy infrastructure management projects. The firm also represents clients that are pursuing distributed generation projects in California.
• On behalf of a major supermarket chain, the firm successfully petitioned the Public Utilities Commission to permit direct access customers who open new facilities to include those facilities under their existing direct access contracts. Formerly, the direct access suspension rules did not permit the addition of new facilities, but the firm successfully advocated that a change to the rules could be made without violating the Commission's earlier "standstill" rules concerning direct access. We also are advising several commercial clients in taking advantage of the opportunity presented by the rule change.
• The firm has represented green field power plant developers in the development and construction of eighteen power plants in North America and three in Argentina, including negotiation of construction, O&M, gas supply and transportation and electricity sales agreements. This representation also included negotiations with federal and state governments for various required permits.
• As electric restructuring was starting in California, the electric utilities issued their proposed rules for competition. The rules were vastly dissimilar from one another, requiring a customer with statewide facilities or an electric service provider to have to learn and comply with three separate sets of rules in order to participate in the direct access market. The firm founded the Direct Access Alliance, which advocated and achieved a single set of uniform rules for the State of California. The Alliance later merged with a stakeholder group to form the Western Power Trading Forum.

CPUC - Service Lists - R0201011
... PROFESSIONAL CORPORATION OCCIDENTIAL ENERGY MARKETING, INC. PARKER,MILLIKEN, ... DONALD C. LIDDELL P. C. ATTORNEY AT LAW DOUGLASS & LIDDELL SOUTHERN CALIFORNIA ...

CPUC - Service Lists - R0310003
... DANIEL W. DOUGLASS A PROFESSIONAL CORPORATION DOUGLASS & LIDDELL 201 SOUTH LAKE ... S. LONDON ASSOCIATION OF BAY AREA GOVERNMENTS JODY LONDON CONSULTING 101 8TH ...