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ADVERSARY COMPLAINT OF WINDING CREEK SOLAR LLC, ET AL. 

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CAIRNCROSS & HEMPELMANN 

JOHN RIZZARDI (pro hac vice pending) 

CHRISTOPHER L. YOUNG (pro hac vice

pending) 

524 Second Avenue, Suite 500 

Seattle, WA 98104-2323 

Telephone: 206-254-4444 

Facsimile: 206-587-2308 

JRizzardi@cairncross.com CYoung@cairncross.com 

Attorneys for Plaintiff 

THOMAS MELONE (pro hac vice) 

ALLCO RENEWABLE ENERGY LIMITED 

1740 Broadway, 15th Floor 

New York, NY 100195 

Telephone: (212) 681-1120 

Facsimile: (801) 858-8818 

Thomas.Melone@AllcoUS.com 

 Attorneys for Plaintiff 

FUTTERMAN DUPREE DODD CROLEY MAIER LLP 

JAMIE L. DUPREE (158105) 

JAIME G. TOUCHSTONE (233187) 

601 Montgomery Street, Suite 333 

San Francisco, CA 94111 

Telephone: (415) 399-3906 

Facsimile: (415) 399-3838 

jdupree@fddcm.com 

jtouchstone@fddcm.com 

Local Attorneys for Plaintiff 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors,

Case No. 19-30088 (DM) 

Chapter 11

(Lead Case) 

(Jointly Administered) 

WINDING CREEK SOLAR LLC, 

FOOTHILL SOLAR LLC, HOLLISTER 

SOLAR LLC, VINTNER SOLAR LLC, 

BEAR CREEK SOLAR LLC, and ALLCO 

RENEWABLE ENERGY LIMITED 

 Plaintiffs, 

v. 

 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

 Defendant. 

Adv. Pro. No. 19-_____ (DM) 

COMPLAINT FOR DAMAGES AND 

INJUNCTIVE RELIEF 

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NATURE OF THE ACTION 

1. This case concerns the Plaintiffs’ right to sell energy and capacity from its solar 

electric generating facilities to Pacific Gas and Electric Company (“PG&E”) pursuant to section 

210 of the Public Utility Regulatory Policies Act, Pub. L. No. 95-617, 92 Stat. 3117 (“PURPA”), 

Cal. Pub. Util. Code section 399.20, and PG&E’s filed tariffs. 

2. The Plaintiffs offered to sell the energy and capacity for a 20-year term from 

various solar generating facilities to PG&E using contracts and rates published under PG&E tariffs 

that were in effect when the offers were made. Those tariffs were implemented by PG&E in order 

to comply with its independent obligations under its “must-take” obligation imposed by federal 

and state law under section 210 of PURPA and Cal. Pub. Util. Code section 399.20. When 

Plaintiffs’ made those offers a legally enforceable obligation was formed obligating PG&E to 

purchase the energy and capacity at those rates and terms. 

3. PG&E refused to execute written contracts evidencing its obligation to purchase 

the energy and capacity from those facilities for one simple reason—the PG&E tariffs included an 

unlawful attempt to cap its “must-take” obligation to purchase. 

4. The cap on PG&E’s obligation to purchase energy and capacity from Plaintiffs’ 

facilities has now been declared unlawful. See Winding Creek Solar LLC v. Peevey, 293 F. Supp. 

3d 980, 2017 U.S. Dist. LEXIS 201893 (N.D. Cal. Dec. 6, 2017) (Donato, J.) aff’d, Winding Creek 

Solar LLC v. Peterman, 932 F.3d 861 (9th Cir. 2019). Id. at 865 (a “cap on the amount of energy 

utilities must purchase from QFs is impermissible under PURPA's must-take provision. [With a 

cap], a utility could purchase less energy than a QF makes available, an outcome forbidden by 

PURPA.”) 

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5. Plaintiffs bring this action seeking damages, and in the alternative for injunctive 

relief requiring PG&E to enter into the contracts the Plaintiffs were entitled to receive but for the 

unlawful cap. 

PARTIES

6. Plaintiff Winding Creek Solar LLC (“Winding Creek”) is the owner and developer 

of a 1.0-megawatt solar project located at 17016 North Jack Tone Road in Lodi, California (“the 

Lodi facility”). Allco Finance Limited is the sole member of Plaintiff. 

7. Plaintiffs Foothill Solar LLC, Kettleman Solar LLC, Hollister Solar LLC, Vintner 

Solar LLC, Bear Creek Solar LLC and Allco Renewable Energy Limited are the respective owners 

and developers of the solar electric generating facilities listed on Exhibit A attached hereto. 

8. Each Plaintiff is a “qualifying small power producer” because each is the “owner” 

of a “qualifying small power production facility.” 16 U.S.C. § 796(17)(D). Each facility is a 

“qualifying small power production facility” or “QF.” 1

9. Defendant Pacific Gas and Electric Company is an investor-owned utility providing 

electric service throughout northern and central California. 

JURISDICTION AND VENUE

10. This adversary proceeding arises in and relates to PG&E’s Chapter 11 Case. The 

Court has jurisdiction to consider this adversary proceeding and over the claims against PG&E 

pursuant to 28 U.S.C. §§ 157 and 1334. This is a core proceeding under 28 U.S.C. § 157(b). The 

Plaintiffs consent to the entry of a final order by the Court in connection with this adversary 

proceeding to the extent it is later determined that the Court, absent consent of the parties, cannot 

enter final orders or judgments consistent with Article III of the United States Constitution. 

1

 “[Q]ualifying small power production facilit[ies]” under the statute and “Qualifying Facilities” 

or “QFs” under regulations of the Federal Energy Regulatory Commission (the “FERC”), see 16 

U.S.C. §796(17)(C); 18 C.F.R. §292.203. 

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STATUTORY AND REGULATORY FRAMEWORK 

11. Through the Federal Power Act, Congress occupied the field of wholesale 

electricity sales and assigned to the Federal Power Commission – now the Federal Energy 

Regulatory Commission (“FERC”) – exclusive authority to regulate that field. See 16 U.S.C. § 

824(b)(1). 

12. In 1978, Congress enacted PURPA, which amended the Federal Power Act. 

Congress’s purpose in enacting PURPA was to facilitate the development of renewable energy 

generation and to reduce the country’s reliance on fossil fuels. 

13. Prior to the enactment of PURPA, small renewable energy generators had difficulty 

finding buyers for their output because electric utilities were reluctant to purchase power from 

non-traditional generation facilities. PURPA addressed that problem by directing FERC to adopt 

rules requiring electric utilities to purchase power generated by, among others, “qualifying small 

power production facilities,” 16 U.S.C. § 824a-3(a), which include facilities designed to produce 

electricity solely through the use of a renewable fuel source, such as Plaintiffs’ facilities. 

14. Pursuant to PURPA’s directive, FERC provided in its regulations that “[e]ach 

electric utility shall purchase ... any energy and capacity which is made available from a qualifying 

facility ... [d]irectly to the electric utility.” 18 C.F.R. § 292.303(a). A utility’s obligation to 

purchase all the output of a qualifying facility that is interconnected with its distribution network 

is known as a “legally enforceable obligation,” or as the Ninth Circuit describes it—PURPA’s 

“must-take” obligation. See, Winding Creek Solar LLC v. Peterman, 932 F.3d 861, 865 (9th Cir. 

2019). Once the utility’s legally enforceable or “must-take” obligation is triggered, the utility 

becomes bound to purchase any electricity the qualifying facility produces. 

15. In California and elsewhere, state regulatory commissions have implemented 

PURPA by requiring the utility, in light of its must-take obligation, to enter into a power purchase 

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agreement with the qualifying facility, in which the utility commits to purchase the qualifying 

facility’s electricity for a defined contract term. 

16. PURPA also directed FERC to promulgate rules ensuring that “in requiring any 

electric utility to offer to purchase electric energy from any ... qualifying small power production 

facility, the rates for such purchase” shall not “exceed[] the incremental cost to the electric utility 

of alternative electric energy.” 16 U.S.C. § 824a-3(b). 

17. Pursuant to that statutory directive, FERC promulgated a regulation providing that 

“[r]ates for purchases from new capacity” – that is, from facilities constructed after PURPA’s 

enactment, § 292.304(b)(1) – “shall be in accordance with paragraph (b)(2) of this section,” that 

is, equal to, and not less than, the utility’s avoided costs. Id. § 292.304(b)(4). 

18. FERC’s regulations also detail the methodologies that must be used in determining 

a utility’s avoided costs, and provide that the qualifying facility has the option to choose which of 

two methodologies shall be used in calculating the utility’s avoided costs. Id. § 292.304(d). When 

a qualifying facility provides “energy or capacity pursuant to a legally enforceable obligation for 

the delivery of energy or capacity over a specified term, ... the rates for such purchases shall, at 

the option of the qualifying facility exercised prior to the beginning of the specified term, be based 

on either: (i) The avoided costs calculated at the time of delivery; or (ii) The avoided costs 

calculated at the time the obligation is incurred.” Id. § 292.304(d)(2) (emphasis added). 

19. The first methodology – “[t]he avoided costs calculated at the time of delivery,” id.

§ 292.304(d)(2)(i) – is known in the industry as a “short run avoided cost” (“SRAC”) rate, because 

it can be determined only at the moment that electricity is delivered. Typically, the “short run 

avoided cost” is calculated on a month-to-month basis, and depends in part upon the fluctuating 

market price of natural gas or coal. The second methodology – “[t]he avoided costs calculated at 

the time the obligation is incurred,” id. § 292.304(d)(2)(ii) – is known in the industry as a “long 

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run avoided cost” (“LRAC”) rate, because it is determined at the time the utility incurs the purchase 

obligation, and is determined for the entire duration of the contract term. A utility’s long-run 

avoided costs are typically calculated through the use of a mathematical model that projects the 

utility’s anticipated avoided costs in the future, accounting for the many variables that might affect 

those avoided costs. 

20. In this case, the PG&E tariffs specified the appropriate LRAC rate applicable at the 

time its “must-take” obligation to Plaintiffs’ arose. 

21. PURPA provides that each state’s regulatory authority “implement [FERC]’s rule 

... for each electric utility for which it has ratemaking authority.” 16 U.S.C. § 824a-3(f)(1). That 

provision constitutes a limited exception to FERC’s exclusive regulatory authority over wholesale 

electricity sales. Aside from “implement[ing]” FERC’s rules under PURPA, id., however, state 

regulatory commissions enjoy no authority to regulate wholesale electricity sales. 

California’s Implementation of PURPA 

22. AB 1969 was enacted in 2006 adding Section 399.20 to the California Public 

Utilities Code2

. Section 399.20(c)(2006) required that all California electrical corporations file a 

tariff with the Public Utilities Commission (the “CPUC”) to purchase the energy produced by an 

“electric generation facility”, which, among other things, was a facility powered by renewable 

resources (such as solar and wind) and owned by a California water or wastewater public agency. 

Such a tariff is generically referred to as a feed-in tariff or “FIT” because renewable energy 

facilities are able to sell their energy to a utility at a fixed price over a long term such as 20 years. 

Under Section 399.20(e)(2006) each utility was required to make the tariff available to public 

water or wastewater agencies. 

2

 AB 1969 (Yee) Stats. 2006, Ch. 731. 

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FACTUAL ALLEGATIONS 

23. On July 27, 2007, the CPUC issued Decision (“D.”) 07-07-027 adopting tariffs and 

standard contracts for the purchase of the electricity from public agency water and wastewater 

customers. D.07-07-027 also adopted an additional program for PG&E and Southern California 

Edison (“SCE”) only, based upon similar terms and conditions as the Section 399.20 program for 

entities that were not water/wastewater agencies (the “Pre-REMAT”).3 

24. In a series of orders in 2012 and 2013, the CPUC amended its PURPA program 

under section 399.20 and re-named it the Renewable Market Adjusting Tariff or “REMAT.” 

25. Both PURPA programs and the related PG&E tariffs—the Pre-REMAT and the 

REMAT—established the contract term—20 years—and the avoided cost prices. But both 

included the same unenforceable provision—a cap on PG&E’s obligations to purchase from QFs, 

such as Plaintiffs’. 

26. Plaintiffs were eligible for and timely submitted all the required contracts and 

information to PG&E to participate in the Pre-REMAT in 2013, triggering the “must-take” 

obligation. Plaintiffs were legally entitled to have PG&E execute the contracts for those facilities 

pursuant to the “must-take” obligation. 

27. Plaintiff Winding Creek was eligible for and also timely submitted all the required 

contracts and information to PG&E to participate in the REMAT in 2013 for its Lodi facility 

triggering the “must-take” obligation. Plaintiff Winding Creek was legally entitled to have PG&E 

execute the contract for that facility pursuant to the “must-take” obligation. 

28. But for the unlawful cap under the Pre-REMAT, Plaintiffs would have received a 

contract for each of their facilities listed on Exhibit A at the fixed 20-year rate in effect at that time. 

3

 D.07-07-027 at 61. 

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29. But for the unlawful cap under the REMAT, Plaintiff Winding Creek would have 

received a contract for its Lodi facility at a fixed 20-year base rate of $89.23 per megawatt-hour 

(as adjusted for the then time-of-use rate). 

30. PG&E’s refusal to execute those contracts was unlawful and injured Plaintiffs 

because Plaintiffs have not been able to obtain financing for and construct their facilities, and have 

lost revenue for all their facilities, and have incurred costs that would not be recoverable without 

those contracts. 

FIRST CAUSE OF ACTION 

CLAIM FOR DAMAGES UNDER PURPA, 16 U.S.C. § 824a-3 & 18 C.F.R. Part 292, 

CAL. PUB. UTIL. CODE § 399.20 AND PG&E’S TARIFFS 

31. Plaintiffs restate and incorporate by reference each and every allegation in 

Paragraphs 1 through 30 as if fully set forth herein. 

32. Plaintiffs were eligible for and timely submitted all the required contracts and 

information to PG&E to participate in the Pre-REMAT and REMAT, which, under PURPA 

Section 210, 16 U.S.C. § 824a-3, as interpreted by Winding Creek Solar LLC v. Peevey, 293 F. 

Supp. 3d 980, 2017 U.S. Dist. LEXIS 201893 (N.D. Cal., Dec. 6, 2017) (Donato, J.) aff’d, Winding 

Creek Solar LLC v. Peterman, 932 F.3d 861 (9th Cir. 2019, created a legally enforceable obligation 

for PG&E to purchase all electric power output from Plaintiffs from the time those legally 

enforceable obligations were formed at the avoided cost rate set by CPUC at the time the legally 

enforceable obligation was formed. 

33. PG&E was required by PURPA’s must-take obligation, 16 U.S.C. § 824a-3(a)(2) 

& 18 C.F.R. § 292.303(a), Cal. Pub. Util. Code § 399.20 and PG&E’S tariff to execute the contracts 

for Plaintiffs’ facilities at the rates and terms in effect at the time the Plaintiffs triggered the “musttake” legally enforceable obligation. 

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34. But for the unlawful cap under the Pre-REMAT and REMAT and PG&E’s tariffs, 

Plaintiffs would have received a contract for each of their facilities at the fixed 20-year rate in 

effect at that time. 

35. PG&E refused at the time, and has continued to this day its refusal, to execute the 

contracts for each of their facilities at the fixed 20-year rate in effect at the time, Plaintiffs’ 

triggered the ongoing and continuous “must-take” obligation. Plaintiffs relied on PG&E’s “musttake” obligation in developing and expending costs for its facilities. 

36. Under the contracts to which Plaintiffs were entitled they would have received 

revenue from electricity sales to PG&E in an amount in excess of $600 million. 

37. Plaintiffs seek damages in the amount of such lost revenue, costs incurred and, in 

the alternative, an amount equal to the lost revenue after deducting the estimated cost to build and 

operate each such facility. 

38. Plaintiffs seek the allowance of their claims in an amount equal to such damages, 

including, to the extent applicable, administrative priority expense claims. 

SECOND CAUSE OF ACTION 

CLAIM FOR INJUNCTIVE RELIEF UNDER PURPA, 16 U.S.C. § 824a-3 & 18 C.F.R. 

Part 292, CAL. PUB. UTIL. CODE § 399.20 AND PG&E’S TARIFF 

39. Plaintiffs restate and incorporate by reference each and every allegation in 

Paragraphs 1 through 38 as if fully set forth herein 

40. In the alternative to the damage remedy, Plaintiffs seek injunctive relief requiring 

PG&E to enter into contracts for the purchase of energy and capacity from Plaintiffs’ facilities or 

similar alternate facilities at the same terms and prices in effect at the time under the Pre-REMAT 

or the REMAT, as the case may be, when Plaintiffs’ triggered the ongoing and continuous “musttake” obligation. 

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41. Such injunctive relief is appropriate because absent a damage remedy under Count 

I, the Plaintiffs would suffer irreparable injury. 

42. Requiring PG&E to enter the contracts to which Plaintiffs were entitled does no 

harm to PG&E. It simply put the parties in the position from a contracting standpoint that they 

should have been in but for the illegal attempt at placing a cap on PG&E’s “must-take” obligation. 

43. Requiring PG&E to enter the contracts to which Plaintiffs were entitled serves the 

public interest. Here Congress has declared that the public interest lies in providing the maximum 

incentive for QF generation, such as Plaintiffs’ facilities. It also serves the public interest’s urgent 

need for the world to transition its energy systems away from fossil fuels. 

As Judge Goodwin wrote four years ago, 

The current state of affairs . . . reveals a wholesale failure of the legal system to 

protect humanity from the collapse of finite natural resources by the 

uncontrolled pursuit of short-term profits. . . . [T]he modern judiciary has 

enfeebled itself to the point that law enforcement can rarely be accomplished 

by taking environmental predators to court. . . . 

The third branch can, and should, take another long and careful look at the 

barriers to litigation created by modern doctrines of subject-matter jurisdiction 

and deference to the legislative and administrative branches of government. 

Alfred T. Goodwin, A Wake-Up Call for Judges, 2015 Wis. L. Rev. 785, 785-86, 788 

(2015). Since Judge Goodwin wrote those words, United Nations scientists have made 

clear that we have only a decade to take unprecedented steps to reduce fossil fuel 

consumption.4

4

 The United Nations Intergovernmental Panel on Climate Change (IPCC) Special Report: Global 

Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above preindustrial levels and related global greenhouse gas emission pathways, in the context of 

strengthening the global response to the threat of climate change, sustainable development, and 

efforts to eradicate poverty. https://www.ipcc.ch/sr15/. 

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PRAYER FOR RELIEF 

WHEREFORE, Plaintiffs pray that this Court enter an Order: 

a. Awarding damages in an amount to be proven at trial; 

b. Allowing Plaintiffs’ claims against the Debtors and their bankruptcy estates, as 

applicable, in the amount of such award of damages; 

c. In the alternative to the damage remedy, Plaintiffs seek injunctive relief requiring 

PG&E to enter into contracts for the purchase of energy and capacity from 

Plaintiffs’ facilities or similar alternate facilities at the same terms and prices in 

effect at the time under the Pre-REMAT or the REMAT, as the case may be; 

d. Awarding Plaintiffs such further relief as the Court may deem just and equitable. 

Dated: October 20, 2019 Respectfully submitted, 

 CAIRNCROSS & HEMPELMANN 

 By: /s/ John Rizzardi 

 JOHN RIZZARDI (pro hac vice pending) 

CHRISTOPHER L. YOUNG (pro hac vice 

pending) 

Email: JRizzardi@cairncross.com

CYoung@cairncross.com 

 

Dated: October 20, 2019 /s/ Thomas Melone 

 Thomas Melone (pro hac vice) 

 Attorneys for Plaintiff 

Email: Thomas.Melone@AllcoUS.com 

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EXHIBIT A 

 

LIST OF FACILITIES 

UNDER PRE-REMAT 

 

Project Owner Name of facility Project 

size 

Project Location 

(approximately)

Allco Renewable Energy 

Limited

Kettleman Solar 2 1.5MW 14241 East Kettleman 

Lane, Lodi, CA 

Allco Renewable Energy 

Limited

Vintner Solar 2 1.5MW 550 El Pomar Dr., 

Templeton, CA 

Winding Creek Solar LLC Winding Creek Solar 1.0MW 17018 North Jack Tone 

Road, Lodi, CA 

Foothill Solar LLC Hollister Solar 2 1.5MW 1830 Buena Vista Road, 

Hollister, CA 

Foothill Solar LLC Vintner Solar 3 1.0MW 552 El Pomar Dr., 

Templeton, CA 

Kettleman Solar LLC Corning Solar 1 1.5MW 112 1st St., Corning, CA 

Kettleman Solar LLC Corning Solar 2 1.5MW 108 1st St., Corning, CA 

Hollister Solar LLC Corning Solar 3 1.5MW 23007 Aitken Ave., 

Corning, CA 

Hollister Solar LLC Corning Solar 4 1.5MW 23065 Aitken Ave., 

Corning, CA 

Vintner Solar LLC Corning Solar 5 1.5MW 23157 Aitken Ave., 

Corning, CA 

Vintner Solar LLC Corning Solar 6 1.5MW 23049 Neva Ave., 

Corning, CA 

Bear Creek Solar LLC Corning Solar 7 1.5MW 23149 Neva Ave., 

Corning, CA 

Bear Creek Solar LLC Corning Solar 8 1.5MW 23008 Neva Ave., 

Corning, CA 

Allco Renewable Energy 

Limited

Corning Solar 9 1.5MW 23070 Neva Ave., 

Corning, CA 

Allco Renewable Energy 

Limited

Corning Solar 10 1.5MW 23130 Neva Ave., 

Corning, CA 

Allco Renewable Energy 

Limited

Corning Solar 11 1.5MW 23009 Florence Ave., 

Corning, CA 

Allco Renewable Energy 

Limited

Corning Solar 12 1.5MW 23061 Florence Ave., 

Corning, CA 

Allco Renewable Energy 

Limited

Corning Solar 13 1.5MW 23167 Florence Ave., 

Corning, CA 

Kettleman Solar LLC Madera County Solar 1 1.5MW 12568 California 41, 

Madera, CA 

Kettleman Solar LLC Madera County Solar 2 1.5MW 12484 California 41, 

Madera, CA 

Hollister Solar LLC Madera County Solar 3 1.5MW 12362 California 41, 

Madera, CA 

Hollister Solar LLC Madera County Solar 4 1.5MW 12257 California 41, 

Madera, CA 

Vintner Solar LLC Madera County Solar 5 1.5MW 12155 California 41, 

Madera, CA 

Vintner Solar LLC Madera County Solar 6 1.5MW 12085 California 41, 

Madera, CA 

Bear Creek Solar LLC Madera County Solar 7 1.5MW 11969 California 41, 

Madera, CA 

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Bear Creek Solar LLC Madera County Solar 8 1.5MW 11873 California 41, 

Madera, CA 

Allco Renewable Energy 

Limited

Madera County Solar 9 1.5MW 41258 Ave 12, 

Madera, CA 

Allco Renewable Energy 

Limited

Madera County Solar 10 1.5MW 41176 Ave 12, 

Madera, CA 

Allco Renewable Energy 

Limited

Madera County Solar 11 1.5MW 41128 Ave 12, 

Madera, CA 

Allco Renewable Energy 

Limited

Madera County Solar 12 1.5MW 41088 Ave 12, 

Madera, CA 

Allco Renewable Energy 

Limited

Madera County Solar 13 1.5MW 41036 Ave 12, 

Madera, CA 

Kettleman Solar LLC Chowchilla Solar 1 1.5MW 24275 Road 16, 

Chowchilla, CA 

Kettleman Solar LLC Chowchilla Solar 2 1.5MW 24309 Road 16, 

Chowchilla, CA 

Hollister Solar LLC Chowchilla Solar 3 1.5MW 24347 Road 16, 

Chowchilla, CA 

Hollister Solar LLC Chowchilla Solar 4 1.5MW 24381 Road 16, 

Chowchilla, CA 

Vintner Solar LLC Chowchilla Solar 5 1.5MW 24417 Road 16, 

Chowchilla, CA 

Vintner Solar LLC Chowchilla Solar 6 1.5MW 24451 Road 16, 

Chowchilla, CA 

Bear Creek Solar LLC Chowchilla Solar 7 1.5MW 24487 Road 16, 

Chowchilla, CA 

Bear Creek Solar LLC Chowchilla Solar 8 1.5MW 16011 Ave 24 1/2, 

Chowchilla, CA 

Allco Renewable Energy 

Limited

Chowchilla Solar 9 1.5MW 16043 Ave 24 1/2, 

Chowchilla, CA 

Allco Renewable Energy 

Limited

Chowchilla Solar 10 1.5MW 16093 Ave 24 1/2, 

Chowchilla, CA 

Allco Renewable Energy 

Limited

Chowchilla Solar 11 1.5MW 16141 Ave 24 1/2, 

Chowchilla, CA 

Allco Renewable Energy 

Limited

Chowchilla Solar 12 1.5MW 16187 Ave 24 1/2, 

Chowchilla, CA 

Allco Renewable Energy 

Limited

Chowchilla Solar 13 1.5MW 16231 Ave 24 1/2, 

Chowchilla, CA 

Kettleman Solar LLC Tracy Solar 1 1.5MW 30006 S MacArthur Dr., 

Tracy, CA 

Kettleman Solar LLC Tracy Solar 2 1.5MW 29992 S MacArthur Dr., 

Tracy, CA 

Hollister Solar LLC Tracy Solar 3 1.5MW 29960 S MacArthur Dr., 

Tracy, CA 

Hollister Solar LLC Tracy Solar 4 1.5MW 29872 S MacArthur Dr., 

Tracy, CA 

Vintner Solar LLC Tracy Solar 5 1.5MW 29838 S MacArthur Dr., 

Tracy, CA 

Vintner Solar LLC Tracy Solar 6 1.5MW 29756 S MacArthur Dr., 

Tracy, CA 

Allco Renewable Energy 

Limited

Tracy Solar 7 1.5MW 29686 S MacArthur Dr., 

Tracy, CA 

Allco Renewable Energy 

Limited

Tracy Solar 8 1.5MW 29627 S MacArthur Dr., 

Tracy, CA 

Case: 19-30088 Doc# 4324 Filed: 10/20/19 Entered: 10/20/19 07:35:47 Page 13

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ADVERSARY COMPLAINT OF WINDING CREEK SOLAR LLC, ET AL. 

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26

Allco Renewable Energy 

Limited

Tracy Solar 9 1.5MW 29565 S MacArthur Dr., 

Tracy, CA 

Allco Renewable Energy 

Limited

Tracy Solar 10 1.5MW 29514 S MacArthur Dr., 

Tracy, CA 

Allco Renewable Energy 

Limited

Tracy Solar 11 1.5MW 29462 S MacArthur Dr., 

Tracy, CA 

Allco Renewable Energy 

Limited

Tracy Solar 12 1.5MW 29358 S MacArthur Dr., 

Tracy, CA 

Allco Renewable Energy 

Limited

Tracy Solar 13 1.5MW 29280 S MacArthur Dr., 

Tracy, CA 

Case: 19-30088 Doc# 4324 Filed: 10/20/19 Entered: 10/20/19 07:35:47 Page 14

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