Generators that may have executed bilateral contracts with a California utility prior to the passage of Assembly Bill 32 (AB 32) in California such that their contract does not have specific terms and conditions assigning greenhouse gas cost responsibility should be aware that the matter of whether the generator is entitled to some sort of relief is going to be decided as part of a California Public Utilities Commission rulemaking (R.11-03-012) with initial comments on the subject due today and reply comments due September 5.

Parties are not required to submit comments today in order to participate in the rulemaking regarding AB 32, but it would probably be a good idea to provide reply comments if they are interested in participating.