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Expert Testimonies

Clients call on ZGlobal for Expert Witness Services to provide objective assessments in response to disputes. Most times these disputes center around divergent opinions that require comprehensive understanding of the dispute, rules, regulations, and/or contract language that govern actions, and the environment that ultimately resulted in the need to rely on subject matter experts to provide clarity to the situation.

Comprehensive Expertise and Fact-Based Testimony

We are a dynamic team of consultants, engineers, and analysts that offer a wide breadth of services and comprehensive expertise. We focus on delivering scientifically, fact-based, analysis in a clear, timely, and professional manner. Our practical experience, analytical skills and our diverse team of experts is able to provide expert witness services in all aspect of energy related disciplines.

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FEDERAL ENERGY REGULATORY COMMISSIONS AND FEDERAL COURTS

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  1. Document Title: California Solar Ranch, LLC vs Aera Energy, LLC.
    On behalf of AERA Energy , Brian Rahman of ZGlobal provided expert witness testimony in a binding arbitration regarding the development of an over $1 Billion solar facility on 6,100 acres of land in Kern County.

    Docket Number: 1100088728
    Date: November 2018

     

  2. Document Title: State of Nebraska Supreme Court Decision MEAN vs City of Sidney
    Docket Number: Neb. Rev. Stat. 70-1301 et seq. (Reissue 2009)
    Date: October 2018

     

  3. Document Title: On Behalf of the Imperial Irrigation District, Imperial Irrigation District v. California Independent System Operator Corporation. Provided testimony of Transmission Operation Between the two Balancing Authority. By Rahman, B.; USDC-Southern District 
    Docket Number: 3:15-cv-01576-AJB-AGS
    Date: November 2017

     

  4. Document Title: Utilization of Electric Storage Resources for Multiple Services When Receiving Cost-Based Rate Recovery                                               
    Docket Number: PL17-2-000                                                                                                     Date: January 2017

     

  5. Document Title: On Behalf of Tesoro Refinery in Martinez, CA, Expert Witness Testimony for the reliability of their 80 MW load. In the United States District Court, Northern District of California (San Francisco Division). Detail reliability and interconnection analysis and testimony by Rahman, B.
    Case Number: Case No. 14 CIV 00930 (JCS)
    Date: July 2016

     

  6. Document Title: Tres Amigas Super-substation. Tres Amigas LLC has petitioned the Federal Energy Regulatory Commission for two key rulings that it says will determine whether the potentially pathbreaking project goes forward. One decision would allow Tres Amigas to charge generators competitive rates rather than cost-based charges to move power over a triangular network of high-voltage direct-current lines it plans to build near Clovis, N.M., 1 mile from the Texas border. Terminals at each point of the triangle would be access points into the three separately synchronized grids -- the Eastern Interconnection east of the Rocky Mountains, the Western Electricity Coordinating Council (WECC) west of the Rockies, and the Electric Reliability Council of Texas (ERCOT), the statewide grid that Texas maintains to prevent federal regulation of its utility industry
    Docket Number: ER15-2647-000
    Date: December 2015

     

  7. Document Title: On Behalf of Desert Southwest Power LLC, Petition for Declaratory Order Allowing Incentive Rate Treatment of Desert Southwest Power LLC, ZGlobal performed a cost benefit analysis for the Project which consist of 118 mile single-circuit alternating current 500 kV transmission line. According to Desert Southwest, the Project will connect 1,200 to 1,500 megawatts (MW) of new generation
    Docket Number: EL10-54-000
    Date: March 2010

     

  8. Document Title: On Behalf of Western Grid Development; Western Grid Requests Commission finding that its proposed energy storage device projects are wholesale transmission facilities, as well as Commission approval of certain incentive rate treatments for the Projects under Federal Power Act (FPA). Testimony by Alaywan, Z, Harris, P and Perez, A.  
    Docket Number: EL10-19-000                                                                                            
    Date: November 2009

     

  9. Document Title: On Behalf of Transbay Cable, An Economic Benefit Evaluation of the TransBay Cable, comprehensive economic and reliability evaluation of the TransBay Cable, a 230kV cable across the San Francisco Bay, Trans Bay Cable LLC, Cost of Service Rate Filing. Testimony by Alaywan, Z. 
    Docket Number: ER10-116-000, TBC3
    Date: October 2009

     

  10. Document Title: Ancillary Service Must Offer Obligation and Resource Adequacy Standard Capacity Product. Testimony by Rahman, B.
    Docket Number: ER 09-1064-000
    Date: April 2009 

     

  11. Document Title: On Behalf of the CAISO, Prices and Charges on Settlement Statements. Testimony by Vangelatos, C.
    Docket Number: EL09-38-000
    Date: March 2009

     

  12. Document Title: On Behalf of Opti Solar LLC, Opti solar generation interconnection, Testimony by Alaywan, Z.
    Docket Number: ER08-1317-000 000
    Date: October 2008

     

  13. Document Title: On Behalf of SMUD, Agreements Governing the Transmission Operation and Rates, Terms and Conditions of Service over the 3,200 MW the Pacific-AC Intertie ("PACI")”, Declaration submitted to FERC. Testimony by Alaywan, Z
    Docket Number: ER07-882-000, ER07-967-000
    Date: July 2007

     

  14. Document Title: Post-Technical Conference Response of the California Independent System Operator Corporation on Business Practice Manual Issues. Testimony by Rahman, B.; submitted to FERC 
    Docket Number: ER06-615-012 ER 07-1257-000
    Date: March 2007

     

  15. Document Title: Long-Term Firm Transmission Rights in Organized Electricity Markets, Testimony by Rahman, B.
    Docket Number: RM06-8-000 and AD05-7-000
    Date: March 2007

     

  16. Document Title: On Behalf of SMUD regarding Seams between CAISO and adjacent Balancing Authorities Market Redesign and Technology Upgrade Proposal (MRTU); testimony by Alaywan, Z.
    Docket Number: ER06-615-001; ER06-615-002; ER02-1656-027; ER02-1656-029; ER02-1656-031
    Date: September 2006 

     

  17. Document Title: On Behalf of CAISO; Investigation of Wholesale Rates of Utility Sellers of Energy and Ancillary Services in the Western Systems Coordinating Council” testimony By Rahman, B.; MRTU Director to FERC                              
    Docket Number: EL01-68-017, ER02-1656-030, ER02-1656-009, Docket No. ER06-615-000
    Date: March 2006

     

  18. Document Title: On Behalf of CAISO California Independent System Operator Corporation Electric Tariff Filing to Reflect Market Redesign and Technology Upgrade (nodal market) - Testimony by Rahman, B.
    Docket Number: ER06
    Date: February 2006

     

  19. Document Title: Instituting a Transmission Revenue Requirement for Transmission outside California, Testimony by Alaywan, Z.
    Docket Number: El-03-15-000
    Date: December 2004

     

  20. Document Title: Introducing the Generation Payment under CAISO Market, Attachment Outlining the proposed payments for generators under CAISO markets, Testimony by Alaywan, Z.
    Docket Number: ER04-938
    Date: September 2004

     

  21. Document Title: Instituting a Decremental Reference Price in CAISO Markets, Testimony by Alaywan, Z.
    Docket Number: ER-04-938-001
    Date: September 2004

     

  22. Document Title: Introducing the Scheduling Protocols of the Cities of Anaheim and Riverside, Testimony by Alaywan, Z.
    Docket Number: EL03-15-000 and EL03-20-000
    Date: April 2004

     

  23. Document Title: Arbitration Findings and Award in Cities of Anaheim et al. v. the ISO & Southern California Edison regarding “Allocation of Transmission Cost” Testimony by Rahman, B. 
    Docket Number: EL03-54-000
    Date: April 2004

     

  24. Document Title: Reliability Must Run contracts between CAISO and generators, Testimony by Alaywan, Z. 
    Docket Number: ER 03-683-003
    Date: August 2003

     

  25. Document Title: Introducing the Reliability Must Run Tariff, Testimony by Alaywan, Z
    Docket Number: ER98-495-000, ER98-1614, ER98-2145; Duke Energy Moss Landing ER98-2668, ER98-4300, ER98-2669-000 and ER98-4296-000
    Date: January 2000

     

  26. Document Title: Introducing the Downward Energy Regulation Bids Design and Auction under Amendment No.11 of the CAISO Tariff, Testimony by Alaywan, Z.
    Docket Number: Docket(s) EC96-19-039; ER96-1663-040
    Date: January 2000

     

  27. Document Title: Modification of the Ancillary Service Market Design, Amendment No. 14 of the CAISO Tariff; Testimony by Alaywan, Z.
    Docket Number: Docket No ER99-1971
    Date: September 1999

     

  28. Document Title: Instituting the Rational Buyer changes to the ancillary Service Auction under Amendment No.20 of the CAISO Tariff; Testimony by Alaywan, Z.
    Docket Number: ER99-3879-000
    Date: August 1999

     

  29. Document Title: Introducing the Intra Zonal Congestion Management and Pricing under Amendment No.18 of the CAISO Tariff, Testimony by Alaywan, Z.
    Docket Number: ER99-3301-000
    Date: July 1999

     

  30. Document Title: Introducing the Reliability Must Run Tariff, Docket No ER98-441, Testimony by Alaywan, Z.
    Docket Number: ER98-1019-000 and El Segundo Power, ER98-2550-000
    Date: December 1998 

     

  31. Document Title: Introducing the Firm Transmission Rights Market and Auction under Amendment No. 9 of the CAISO Tariff. Testimony by Alaywan, Z.          
    Docket Number: ER 98-3594-001
    Date: December 1998

     

  32. Document Title: Design of the California Real-Time Energy and Ancillary Services Markets, Testimony by Alaywan, Z.
    Docket No: Docket No. ER98-2843-009      
    Date: November 1998

     

  33. Document Title: Grid Management Charge and Settlements for ISO Markets, Testimony by Vangelatos, C. 
    Docket Number: ER99-473-000
    Date: October 1998 

     

  34. Document Title: Creation of New Congestion Zone (ZP26) in the California Market, Testimony by Alaywan, Z. 
    Docket Number: ER-03-683 
    Date: August 1998

     

  35. On behalf of the State of California, the California Attorney General, and the State Department of Justice, in the matter of widespread market manipulation that occurred in the California wholesale markets between May 1, 2000 and June 20, 2001; San Diego Gas & Electric Company, Complainant, v. Sellers of Energy and Ancillary Services into Markets Operated by the California Independent System Operator Corporation and the California Power Exchange, Respondents. Testimony by Alaywan on August 13-16, 2013, Z.  and McIntosh, J.; Docket Nos. EL00-95-000; EL00-95-045; EL00-95-075; EL00-98-000; EL00-98-042; EL00-98-063. Docket No. EL01-10-085. Specifically, testified in Federal Court that led to the settlements of the dispute between the State of California and Powerex. On August 18, 2013, the two parties settled, and the State of California received a settlement of $750 million.
     

  36. On behalf of ISO, provided testimony to California Attorney General which led to settlements of $1.52 billion settlement with Enron to resolve market manipulation and price gouging claims against the architect of gaming strategies that powered the plundering of California ratepayers during the Energy Crisis of 2000-01. The 10 settlements have a combined value of $4.9 billion. Of that total, an estimated $3.64 billion represents ratepayer relief. July 15, 2005. 
     

 

THE STATE OF CALIFORNIA

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  1. On behalf of Western Grid Development LLC, ZGlobal filed the Pacific Transmission Expansion Project (PTEP) as an alternative to the local capacity requirements in the 2030 LT LCR Study. The PTEP is a 2,000 MW controllable HVDC subsea transmission cable with four voltage source converter stations connecting the Diablo Canyon switchyard to Goleta, Redondo Beach and Huntington Beach substations in Southern California. ZGlobal's Christine Vangelatos filing included the CAISO's prior year determination that the PTEP “reduces the western LA basin LCR requirement for by 1,889 MW, thereby allowing 1,889 MW of reduction in gas-fired generation. Attached is the filing and presentation, here. October 8, 2020.                                                                                                                                                

  2. ZGlobal provided expert witness testimony on behalf of New Sun Energy before the Oregon PUC related to treatment of network upgrade costs. ZGlobal leveraged our extensive experience with generator interconnections across the WECC and performed supplemental research to support New Sun Energy objections to existing treatment of Network Upgrades. Specifically, we identified the lack of refunding upgrade costs for upgrades that inherently benefit the bulk transmission system. The testimony of Zglobal's Brian Rahman included references to multiple other utilities and balancing areas that provide a refund or transmission service credits for network upgrades. Testimony included arguments for refunding as well as the need for expanding the study results and information provided to generators seeking interconnection so that they are provided the “full picture” to allow for educated business decisions. October 2020, Testimony before Oregon PUC on behalf of New Sun Energy.                                                                                                

  3. On behalf of Western Grid Development LLC, ZGlobal filed comments with the California PUC regarding the proposed Electric Resource Portfolios decision to inform integrated resource plans submitted as part of the 2020-2021 transmission planning process. WGD requested that the CPUC provide the policy guidance necessary for the CAISO to plan for transmission to reduce LCRs. Specifically, WGD requested the CPUC in its ruling on the proposed decision include that Senate Bill 100 to create a state public policy requirement that all reasonable steps should be taken to achieve a zero-carbon resource portfolio by 2045, including, reducing LCRs to allow for the closure of gas-fired generation. California PUC - Rulemaking 16-02- 007 March 12 and 16, 2020.                                                                   â€‹

  4. ZGlobal provided expert witness testimony on behalf of Tesoro Refining related to lost production and financial damages. ZGlobal performed a comprehensive review of PG&E operating procedures and design standards associated with the failure of the Tidewater Substation leading to a total loss of power at the refinery. ZGlobal identified both design standard and operating procedure violations that significantly contributed to the power failure as well as a failure to communicate the disabling of critical protection system functionality. ZGlobal leveraged our extensive experience with system operations, substation design, and highly complex protective relays and equipment to provide written testimony, rebuttal response as well as verbal testimony before the US District Court.  This work and associated testimony resulted in a financial award to Tesoro associated with financial damages caused by the outage. January 2020, Tesoro Refining v. PG&E Tesoro Refining and Marketing Company LLC v. Pacific Gas & Electric Company, Case No. 14 CIV 00930 (JCS); In the United States District Court, Northern District of California.                                                  

  5. On behalf of AREA Energy, Brian Rahman of ZGlobal provided expert witness testimony in a binding arbitration in regard to the development of an over $1 Billion solar facility on 6,100 acres in Kern County. After several months and contentious proceeding, the judge ruled in favor of ZGlobal's client. Formed in June 1997 and jointly owned by affiliates of Shell and ExxonMobil, AREA specializes in tapping heavy oil and other unconventional light reservoirs. AREA produces about 125,000 barrels of oil and 32 million cubic feet of natural gas each day and has proved oil and gas reserves. AREA Energy is one of California’s largest oil and gas producers, accounting for nearly 25% of the state’s production. August to October, 2018. Testimony by Rahman, B.                                                                                    

  6. On behalf of Nevada Hydro, perform a life cycle economic and reliability cost benefit analysis for the Lake Elsinore Advanced Pump Storage (LEAPS) project. This 500 MW Hydro-pump is located near the decommissioned San Onofre Nuclear plant in Southern California. A petition for declaratory Order was filed to FERC on March 9, 2018, Testimony by Alaywan, Z, Docket No. EL18-113-000.                                                                                                                   

  7. ZGlobal was retained by the California PUC to provide an independent analysis and proposed alternatives to the proposed West of Devers Transmission Project. The proposed project would replace or upgrade the existing 220 kilovolt (kV) transmission lines and associated facilities between Devers, El Casco, Vista, and San Bernardino substations in Riverside and San Bernardino Counties, increasing the capacity of the West of Devers corridor from the present 1600 megawatt (MW) to approximately 4800 MW. Decision 16-08-017, August 29, 2016; Application A.13-10-020.                                                                              

  8. On Behalf of SMUD, United States Court of Appeals, district of Columbia Circuit Nos. 07-1208, 07-1216; 07-1217; 07-1513; 08-1298, 08-1311. Regarding charges of marginal loss charges in Locational Marginal Pricing on non-jurisdictional utilities, July 23, 2010. Testimony by Alaywan, Z.                                                                                                                  

  9. In the Matter of the Application of Southern California Edison Company (U338-E) for a Certificate of Public Convenience and Necessity Concerning the Antelope-Pardee 500 kV (Segment 1) Transmission Project as Required by Decision 04-06-010”, Testimony by Alaywan, Z; California PUC Application 04-12-007.                                                                        

  10. On behalf of ISO, provided testimony to California Attorney General which led to settlements of $1.52 billion settlement with Enron to resolve market manipulation and price gouging claims against the architect of gaming strategies that powered the plundering of California ratepayers during the Energy Crisis of 2000-01. The 10 settlements have a combined value of $4.9 billion. Of that total, an estimated $3.64 billion represents ratepayer relief. July 15, 2005.                                                                                                                            

  11. On Behalf of the CAISO, Scenario Analysis (Planning Criteria), CPUC AB -970 Data Request, Southern California Long-Term Transmission Study…to provide a means to improve current management of Intra-Zonal Congestion and mitigate local market power; and (2) to make data-sharing changes to the ISO Tariff to Allow the ISO to share Generator Outage information with entities operating Transmission and distribution systems affected by the Outage”, Testimony by Alaywan, Z.; Docket No. ER03-683-003, August 5, 2003.                       

  12. Actual Operating Conditions during the Energy Crisis; Several Testimony by Alaywan, Z to State Senators Committee on Energy and Senate Staff, November 2002.                                  

  13. On Behalf of the CAISO, Testimony in Front of the California State Senate Sub-Committee on Energy" provided insight on electric operation during the energy crisis, October 2000. On behalf of the CAISO, filed the “Facilitating the congestion Management Market in California”, Testimony by Alaywan, Z.  Docket ER98-3760.                                                            

  14. The State of California and The Public Utility commission on the case of the City of Roseville, Silicon Valley Power, and the Northern California Power Agency participate with the ISO through the metered subsystem program. Testimony by Alaywan, Z.                            

  15. State Senator Dunn hearing on 1/21/03. Issues include C66 protocol discussion, the fictitious load, and the MD02 update. (Stock #1207-S; $9.16 - includes tax s/h) (2/03), How to finance these price increases. (Stock #1082-S; $5.93 –includes tax s/h) (4/01).  Testimony by Alaywan, Z.                                                                                                                                         

  16. State Senate Select Committee Investigations and reposts regarding California Energy Crisis –This is the first hearing held on April 18, 2001 in Sacramento, CA by the Senate Select Committee to Investigate Price Manipulation of the Wholesale Energy Market. Testimony by Alaywan, Z.                                                                                                                  

  17. On behalf of the State of California Governor’s office, testified in front of a panels of FERC, CPUC, SCE, PG&E, SDGE and California Large customers that CAISO systems and Market are ready to open on 3/31/1998.  Three weeks Testimony by Alaywan, Z. Certification from the panels was unanimously obtained and CAISO went into operation on 3/31/1998.


 

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