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C. Luckey McDowell (admitted pro hac vice) 

SHEARMAN & STERLING LLP 

1100 Louisiana 

Suite 3300 

Houston, Texas 77002 

Tel: (713) 354-4875 

Email: Luckey.McDowell@Shearman.com 

Daniel Laguardia (CA Bar No. 314654) 

SHEARMAN & STERLING LLP 

535 Mission Street 

25th Floor 

San Francisco, CA 94105 

Tel: (415) 616-1114 

Email: Daniel.Laguardia@Shearman.com 

Counsel for Agua Caliente Solar, LLC, 

Clearway Energy, Inc., Clearway Energy Group LLC, 

MC Shiloh IV Holdings LLC, NRG Energy, Inc., 

Solar Partners II LLC, Solar Partners VIII LLC, and 

TerraForm Power, Inc.

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E Corporation, Pacific Gas & Electric 

Company, 

Debtors.

 Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered)

☐ Affects PG&E Corporation 

☒ Affects Pacific Gas and Electric Company 

☐ Affects both Debtors 

* All papers shall be filed in the Lead Case No. 

19-30088 DM. 

JOINDER BY CERTAIN PPA PARTIES 

TO NEXTERA ENERGY, INC.’S, 

LIMITED OPPOSITION TO MOTION 

OF THE UTILITY FOR LIMITED 

RELIEF FROM THE AUTOMATIC 

STAY TO APPEAL CERTAIN MATTERS 

PENDING BEFORE THE FEDERAL 

ENERGY REGULATORY 

COMMISSION 

Date: 6/26/2019 

Time: 9:30 a.m. PST 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Case: 19-30088 Doc# 2641 Filed: 06/19/19 Entered: 06/19/19 14:36:37 Page 1 of

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HNDOCS01/81356.1

Agua Caliente Solar, LLC, Clearway Energy, Inc., Clearway Energy Group LLC, 

MC Shiloh IV Holdings LLC, NRG Energy, Inc., Solar Partners II LLC, Solar Partners VIII LLC, 

and TerraForm Power, Inc. (collectively, the “PPA Parties”) hereby join NextEra Energy, Inc., 

and NextEra Energy Partners, L.P. (collectively, “NextEra”) with respect to its Limited 

Opposition to Motion of the Utility for Limited Relief from the Automatic Stay to Appeal Certain 

Matters Pending before the Federal Energy Regulatory Commission [Docket No. 2616] (the 

“Limited Objection”). In support hereof (the “Joinder”), the PPA Parties respectfully represent 

as follows: 

JOINDER 

In its Objection, NextEra points out the potential for inequitable treatment were the stay to 

be modified to permit the Debtors, but not other parties, to participate in the FERC appellate 

matters. This potential exists because the form of order proposed by the Utility (i) modifies the 

stay only with respect to the Utility and (ii) includes additional language that could be read to 

preclude other parties—including the PPA Parties—from participating in the appellate process. 

While the PPA Parties do not believe this was the Debtors’ intent, the potential for this outcome is 

too grave to risk silence. Accordingly, for these reasons and the reasons recited in the Limited 

Objection, the PPA Parties join NextEra in its Limited Objection. 

NOTICE 

Notice of this Joinder will be provided to (i) the Office of the U.S. Trustee for Region 17 

(Attn: Anthony R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Debtors; (iii) counsel 

to the Creditors Committee; (iv) counsel to the Tort Claimants Committee; (v) the Securities and 

Exchange Commission; (vi) the Internal Revenue Service; (vii) the Office of the California 

Attorney General; (viii) the California Public Utilities Commission; (ix) the Nuclear Regulatory 

Commission; (x) the Federal Energy Regulatory Commission; (xi) the Office of the United States 

Case: 19-30088 Doc# 2641 Filed: 06/19/19 Entered: 06/19/19 14:36:37 Page 2 of

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Attorney for the Northern District of California; (xii) counsel for the agent under the Debtors’ 

debtor-in-possession financing facility; (xiii) counsel to the various PPA counterparties; and 

(xiv) those persons who have formally appeared in these chapter 11 cases and requested service 

pursuant to Bankruptcy Rule 2002. The PPA Parties respectfully submit that no further notice is 

required. 

Dated: June 19, 2019 Respectfully submitted, 

/s/ C. Luckey McDowell

 

C. Luckey McDowell (admitted pro hac vice) 

SHEARMAN & STERLING LLP 

1100 Louisiana 

Suite 3300 

Houston, Texas 77002 

Tel: (713) 354-4875 

Email: Luckey.McDowell@Shearman.com

Daniel Laguardia (CA Bar No. 314654) 

SHEARMAN & STERLING LLP 

535 Mission Street 

25th Floor 

San Francisco, CA 94105 

Tel: (415) 616-1114 

Email: Daniel.Laguardia@Shearman.com

Counsel for Agua Caliente Solar, LLC, Clearway 

Energy, Inc., Clearway Energy Group LLC, MC 

Shiloh IV Holdings LLC, NRG Energy, Inc., Solar 

Partners II LLC, Solar Partners VIII LLC, and 

TerraForm Power, Inc. 

 

Case: 19-30088 Doc# 2641 Filed: 06/19/19 Entered: 06/19/19 14:36:37 Page 3 of

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CERTIFICATE OF SERVICE 

STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO 

At the time of service, I was over 18 years of age and not a party to this action. I am 

employed in the County of San Francisco, State of California. My business address is 535 

Mission Street, 25th Floor, San Francisco, CA 94105. 

On June 19, 2019, I served a true copy of the following document described as Joinder by 

Certain PPA Parties to NextEra Energy, Inc.’s, Objection to the Debtors’ Motion for Relief from 

the Stay to Participate in Appellate Proceedings with Respect to FERC Orders by electronically 

filing the document with the Clerk of the Court by using the CM/ECF system. Participants in the 

case who are registered CM/ECF users will be served by the CM/ECF system. 

I declare under penalty of perjury under the laws of the State of California that the foregoing is 

true and correct. 

Executed on June 19, 2019, at San Francisco, California. 

/s/ Ron Cheatham 

Case: 19-30088 Doc# 2641 Filed: 06/19/19 Entered: 06/19/19 14:36:37 Page 4 of

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