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jerrybrockman

02/19/24 1:39 PM

#49341 RE: NorthPeak22 #49340

Spot on. That is 100% correct. The key word is, “when.” The legal definition of,”when,” is:the time in which something is done or comes about.
If they wanted a specific start time, then the specific date would have been placed in lieu of when.

Good work.

Mr. C

02/19/24 2:08 PM

#49343 RE: NorthPeak22 #49340

I wouldn’t assume open ended or any changes to the commencement date for non-FTA/4028. Especially since it was clearly defined in the previous paragraph for order FTA/3393.

Two separate permits. The amendment changed both from 20-year permits to 2050 terminating permits.

The amendment does change the FTA/3393 start date, but the commencement date for Non-FTA/4028 was not changed and reverts to the original commencement guidelines, since nothing further was clearly defined.

Hence, why the DOE site on that link that shows all the start dates still references 6/1/2024 and order 4028, not 3393. This is where the confusion has been.

Both permits got the same extension, but one had commencement conditions changed and the other not.