Montalva Update Received August 26, 2022 4:37 PM
COMES NOW, the Puerto Rico Electric Power Authority (PREPA) and PBJL Energy Corporation (“PBJL”)1 through the undersigned counsels and respectfully submits and requests as follows:
1. On July 4, 2022, the Parties filed a Motion to Inform Progress of the Feasibility Study (the “Request for Extension”) before this Honorable Puerto Rico Energy Bureau of the Public Service Regulatory Board (the “Energy Bureau”) requesting an extension of time to inform the progress of the preliminary agreement between the Parties.
2. As explained in the Request for Extension, the Parties have reached a preliminary agreement which consists of LUMA Energy LLC (“LUMA”) performing a feasibility study to determine whether the Montalva project can be safely and reliably integrated into the T&D System, considering operational and capacity constraints, among other technical criteria (the “Feasibility Study”).
3. Currently, the Parties continue communications and await answers regarding some technical and timing concerns about LUMA’s invoice for the Feasibility Study.
4. Consequently, the Parties hereby request that the Energy Bureau grant until September 13, 2022, to inform the Energy Bureau of any progress regarding the Feasibility Study.
5. It is further stated that the length of the requested period will not affect the proceedings in this case since the Parties are in consensus and this request for extension is made in good faith to reach an agreement and hopefully dismiss the case of caption.
6. All efforts and proceedings related to the Settlement Proposal are made under Puerto Rico Rule of Evidence no. 408.
WHEREFORE, the Parties respectfully request the Honorable Energy Bureau to grant until September 13, 2022, to inform the Energy Bureau of any progress regarding the Feasibility Study.
In San Juan, Puerto Rico, this 26 day of August 2022.
s/ Joannely Marrero Cruz
Joannely Marrero Cruz
jmarrero@diazvaz.law
TSPR No. 20,014
Katiuska Bolaos-Lugo
kbolanos@diazvaz.law
TSPR No. 18,888
DAZ & VZQUEZ LAW FIRM, P.S.C.
290 Jess T. Piero Ave. Oriental Tower, Suite 803 San Juan, PR 00918
Tel. (787) 395-7133
Fax. (787) 497-9664
Counsel for PREPA
CARLOS R. SOSA PADRO LAW OFFICE
PO Box 191682 San Juan, Puerto Rico 00919-1682 Tel.: (787) 250-0081; Tel/Fax: (787) 250-0078 csosalaw@gmail.com
s/Carlos R. Sosa Padr Carlos R. Sosa-Padr, Esq.
De Guzmn Law Offices
P.O. Box 362738 San Juan, PR 00936-2738 Mobile (787) 646-3597 Ph.(787) 756-2765 Fax (787) 756-4024 gdeguzman@dgglawpr.com TSPR (RUA) No. 6370 USDC-PR No. 205112
s/Guillermo F. De Guzmn-Vendrell Guillermo F. De Guzmn-Vendrell, Esq.
Counsel for PBJL