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THOMAS F. KOEGEL (SBN 125852)

tkoegel@crowell.com

CROWELL & MORING LLP

3 Embarcadero Center, 26th Floor

San Francisco, CA 94111

Telephone: 415.986.2800

Facsimile: 415.986.2827

Attorneys for Creditors and Parties-in-Interest

Vantage Wind Energy LLC and KES Kingsburg, L.P.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

PG&E CORPORATION

And

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case

Case No. No. 3:19-bk-30088-DM

Chapter 11

(Lead Case)

(Jointly Administered)

JOINDER OF VANTAGE WIND ENERGY 

LLC AND KES KINGSBURG, L.P. IN 

NEXTERA’S MOTION FOR LIMITED 

RELIEF FROM STAY TO PARTICIPATE 

IN APPELLATE PROCEEDINGS WITH 

RESPECT TO FERC ORDERS

Date: June 26, 2019

Time: 9:30 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Objection Deadline: July 21, 2019

4:00 p.m. (Pacific Time)

 Affects PG&E Corporation

 Affects Pacific Gas and Electric 

Company

 Affects both Debtors

* All papers shall be filed in the Lead Case 

No. 3:19-bk-30088-DM

Case: 19-30088 Doc# 2691 Filed: 06/20/19 Entered: 06/20/19 16:56:50 Page 1 of

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Vantage Wind Energy LLC and KES Kingsburg, L.P. (“Vantage and KES”), parties in 

interest in the above-captioned cases, hereby join in the Motion for Limited Relief from Stay to 

Participate in Appellate Proceedings with Respect to FERC Orders [Docket No. 2400] (the

“Motion”) of NextEra Energy, Inc. and NextEra Energy Partners, L.P. (collectively, “NextEra”) 

(i) to permit Vantage and KES to (a) should it be necessary, seek leave from the applicable circuit 

court of appeals to intervene in any appeal of the FERC Orders (as defined in the Motion); (b) to 

the extent permitted by the applicable circuit court of appeals, participate in and prosecute to 

conclusion any appeal of the FERC Orders; (c) seek or oppose any request for rehearing,

rehearing en banc, petition for writ of certiorari; (d) participate in the briefing and argument 

relating to any and all the foregoing; and (e) participate in any proceedings on remand of the 

FERC Orders; and (ii) to generally allow all courts and administrative agencies with jurisdiction 

over the appeal or remand to enter final orders relating thereto.1 The Motion and this joinder are 

presented necessarily due to the Debtors’ Motion of the Utility for Limited Relief From the 

Automatic Stay to Appeal Certain Matters Pending Before the Federal Energy Regulatory 

Commission [Docket No. 2359] (the “PG&E Stay Motion”), seeking relief from the stay to allow 

the Debtors to pursue appellate relief from the FERC Orders, without granting the other parties in 

interest parallel relief from the stay to respond to the Debtors’ requests for such relief.

By its Motion, NextEra seeks narrowly-tailored relief to permit it to participate in the

Debtors’ anticipated appeal of the FERC Orders to the extent authorized by the applicable 

appellate court. For the same reasons as those set forth in the Motion, Vantage and KES merit the 

same relief. As intervenors in the FERC Proceedings, Vantage and KES have a substantial 

interest in the subject matter of the FERC Proceedings and a direct stake in any appeal of the 

FERC Orders. It would be fundamentally unfair to allow the Debtors to appeal the FERC Orders 

without affording Vantage and KES an opportunity to defend their interests in connection with 

any such appeal.

 1 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed 

to them in the Motion.

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Accordingly, Vantage and KES respectfully request that any order modifying the 

automatic stay as requested in the Motion and PG&E’s Stay Motion also modify the automatic 

stay as to Vantage and KES to permit Vantage and KES to participate in any appeal from the 

FERC Orders.

NOTICE

Vantage and KES respectfully submit that all required notice will be given by the 

Notification of Electronic Filing by ECF, as permitted by Paragraph 11 of the Second Amended 

Order Implementing Certain Notice and Case Management Procedures [Docket No. 1996].

Respectfully submitted, 

DATED: June 20, 2019 CROWELL & MORING LLP

By: /s/

Thomas F. Koegel

Attorneys for Creditors and Parties-in-Interest

Vantage Wind Energy LLC and KES Kingsburg, 

L.P.

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