BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA. And Related Matters. Application Application

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company (U39E) for Approval of Demand Response Programs, Pilots and Budgets for Program Years Application And Related Matters. Application Application PRE-HEARING CONFERENCE STATEMENT OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) ANNA VALDBERG ROBIN Z. MEIDHOF Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Dated: January 3, 2019

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company (U39E) for Approval of Demand Response Programs, Pilots and Budgets for Program Years Application And Related Matters. Application Application PRE-HEARING CONFERENCE STATEMENT OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) I. INTRODUCTION Pursuant to the November 30, 2018 Administrative Law Judge s Ruling (ALJ Ruling) Noticing Prehearing Conference and Asking for Prehearing Conference Statements, Southern California Edison Company (SCE) hereby provides its prehearing conference (PHC) statement. In Opening Briefs in this proceeding, several parties, including SCE, requested the California Public Utilities Commission (Commission) consider alternative baselines, once approved by the Federal Energy Regulatory Commission (FERC). 1 In Decision (D.) , the Commission concluded that new alternative baselines are necessary for demand response 1 See D , Decision Adopting Demand Response Activities and Budgets for 2018 through 2022, p

3 [DR] programs and in particular, the residential option of the Capacity Bidding Program. 2 D directed the investor-owned utilities (IOUs) 3 to file in this proceeding a copy of the FERC tariff that approves wholesale baselines proposed by the California Independent System Operator (CAISO), once approved. 4 The baselines were accepted by FERC on October 24, 2018, and the IOUs filed the CAISO tariff amendment in this proceeding on November 8, On November 30, 2018, ALJ Hymes issued the ALJ Ruling, which directs parties to file PHC statements answering four questions regarding the issues, process, and timeline for adopting new baselines for DR. SCE hereby provides its responses to those questions. II. SCE RESPONSES TO THE QUESTIONS IN THE ALJ RULING a. What issues should the Commission consider in determining whether to revise the current baseline? Now that FERC has accepted the use of three new baseline methodologies, including the control group, 5-in-10, and weather-matching methodologies, those baselines should be considered as potential baselines to apply to retail DR programs. However, SCE has identified several implementation and operational issues that must be resolved in order to realize the potential benefits provided by using alternative baselines. First, because the three new baselines were developed by the Baselines Analysis Working Group (BAWG) convened by the CAISO, the BAWG analyzed these baselines at the aggregate (wholesale market resource) level, and therefore, the baselines may not apply at the disaggregated level that is necessary for measuring individual customer performance in a retail 2 Id., p The IOUs are SCE, Pacific Gas and Electric Company, and San Diego Gas & Electric Company. 4 Id., p See Joint Utilities Filing of FERC Tariff Amendment to Implement Energy Storage and Distributed Energy Resource Requirements [i.e., Baseline Methodologies], in Compliance With Decision , filed November 8,

4 DR program. A new study may be required to determine whether the baselines can be used at the disaggregated level. In addition, it is unclear whether the Commission envisions each customer having a choice of baseline to use to measure their performance, whether the IOU or Aggregator would choose a baseline methodology for each customer, whether the IOU or Aggregator would choose a baseline methodology for a program that every customer enrolled in that program would be obligated to use, or some other approach. SCE generally supports flexibility for customers and the IOUs to select the baseline that works best for their program, however, allowing for multiple baselines for each tariffed DR program would require costly systems changes and increased work to manage customers baseline selections. A related issue concerns the interplay between retail and wholesale baselines. If SCE uses a certain baseline for a DR program or customers within a DR program, must it also use the same baseline for wholesale settlement with the CAISO? This could significantly increase the market integration complexities (e.g., resource registration, bidding, and settlements) by fragmenting the DR resources, and introducing differences across them even within a single program. Furthermore, the CAISO recognizes baselines at the aggregated resource level, not by each customer location registered within a resource. Therefore, if a small number of customers select a certain baseline, SCE may end up with islanded DR megawatts that do not meet the minimum resource size for integration with the CAISO market. It is also unclear whether the Commission envisions moving all retail DR programs to a baseline construct. Currently, SCE s Capacity Bidding Program and Smart Energy Program are the only tariffed DR programs that utilize a baseline to determine customer performance and receipt of incentives. Would all programs now use some sort of baseline, including direct load control programs such as the Summer Discount Program and capacity-only programs, such as the Base Interruptible Program, or would the baselines apply only to DR programs with energy payments? 3

5 Further, while SCE recognizes that several parties emphasize the importance of aligning retail and wholesale baselines, SCE cautions against focusing on perfect alignment of the distinct retail and wholesale baselines over focusing on the intended purpose of baselines, which is to accurately measure DR performance. SCE recommends convening a working group to build on the work of the BAWG and to resolve the remaining operational ambiguities and issues. Alternatively, a workshop or series of workshops could be held to achieve the same purpose. b. Will these issues result in the need for an evidentiary hearing? The issues SCE has identified are primarily operational issues. SCE does not anticipate a need for evidentiary hearing to present evidence or resolve factual disputes. c. Is testimony needed or is a workshop followed by comments and reply comments the appropriate approach? SCE proposes that a working group be established to continue the work conducted by the BAWG and to seek to apply the new baselines to DR programs with energy payments. Alternatively, a workshop and comment process may suffice. SCE does not anticipate that testimony will need to be filed. However, depending on the policy approach and operational changes envisioned by the Commission, SCE may need to implement changes to its systems and operations, which may require additional funding. In this case, testimony may be necessary. d. This proceeding has a statutory deadline of July 17, Do you feel the Commission can adopt a baseline for demand response programs by this deadline? SCE expects that resolution of the operational issues described above, as well as other issues identified by parties, will require more time beyond July 17, With the Commission s guidance, it is possible that the operational issues can be further refined via a working group and implemented via the advice letter/resolution process. As discussed above, depending on the direction envisioned by the Commission, additional funding may be required, requiring testimony and likely extending the proceeding beyond the statutory deadline. 4

6 III. CONCLUSION SCE appreciates the opportunity to provide its responses to the questions posed in the ALJ Ruling. SCE looks forward to discussing these issues further at the PHC currently scheduled for January 10, Respectfully submitted, ANNA VALDBERG ROBIN Z. MEIDHOF /s/ Robin Z. Meidhof By: Robin Z. Meidhof Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Rosemead, California Telephone: (626) January 3,

7 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company (U39E) for Approval of Demand Response Programs, Pilots and Budgets for Program Years And Related Matters. A A A CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of PRE-HEARING CONFERENCE STATEMENT OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) all parties identified on the attached service list(s) for A , et al. Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by US Mail to the offices of the Commissioners(s) or other addresses(s). ALJ Nilgun Atamturk CPUC 505 Van Ness Avenue San Francisco, CA ALJ Kelly A. Hymes CPUC 505 Van Ness Avenue San Francisco, CA Executed January 3, 2019, at Rosemead, California. /s/ Sandra Sedano Sandra Sedano Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

8 Page 1 of 8 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR APPOVAL O FILER: LIST NAME: LIST LAST CHANGED: DECEMBER 28, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties ERIKA DIAMOND DAVID P. LOWREY ENERGYHUB DIRECTOR, REGULATORY STRATEGY 232 3RD STREET, SUITE 201 COMVERGE, INC. BROOKLYN, NY TH STREET, SUITE 2300 FOR: ENERGYHUB DENVER, CO FOR: COMVERGE, INC. DANIEL W. DOUGLASS ROBIN MEIDHOF SR. DOUGLASS & LIDDELL SOUTHERN CALIFORNIA EDISON COMPANY 4766 PARK GRANADA, SUITE WALNUT GROVE AVENUE CALABASAS, CA ROSEMEAD, CA FOR: NEST LABS, INC. FOR: SOUTHERN CALIFORNIA EDISON COMPANY JANE KRIKORIAN, J.D. E. GREGORY BARNES SUPERVISOR - ADMIN AND ADVOCACY UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY 3405 KENYON STREET, SUITE CENTURY PARK COURT, BLDG 3. CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: UCAN FOR: SAN DIEGO GAS & ELECTRIC COMPANY MONA TIERNEY-LLOYD ROSANNE O'HARA SR. DIR., WESTERN REGULATORY AFFAIRS ENEL X NORTH AMERICA, INC. LEGAL DIVISION PO BOX 378 ROOM 5039 CAYUCOS, CA VAN NESS AVENUE FOR: ENEL X NORTH AMERICA, INC. SAN FRANCISCO, CA (FORMERLY ENERNOC, INC.) FOR: ORA

9 Page 2 of 8 MARCEL HAWIGER NORA SHERIFF STAFF THE UTILITY REFORM NETWORK BUCHALTER, A PROFESSIONAL CORPORATION 785 MARKET ST., STE SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION (CLECA) NICHOLAS CONNELL BRIAN CRAGG SR. MGR - GOV'T AFFAIRS ADVANCED MICROGRID SOLUTIONS GOODIN, MACBRIDE, SQUERI & DAY, LLP 25 STILLMAN STREET, SUITE SANSOME ST., STE. 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ADVANCED MICROGRID SOLUTIONS FOR: OHMCONNECT, INC. DARREN ROACH SARA STECK MYERS AT LAW LAW DEPT TH AVENUE PO BOX 7442, MC B30A SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ON BEHALF OF JOINT DR PARTIES FOR: (COMVERGE, INC., CPOWER, ENEL X NORTH AMERICA, INC., ENERGYHUB) JENNIFER A. CHAMBERLIN JASON B. KEYES EXE DIR - MRKT DEVELOPMENT / CAISO PARTNER CPOWER KEYES & FOX LLP 2633 WELLINGTON COURT TH ST., STE.1305 CLYDE, CA OAKLAND, CA FOR: CPOWER, INC. FOR: SOLARCITY CORPORATION SHERIDAN PAUKER ALEX MORRIS PARTNER SR. DIR., POLICY & REGULATORY AFFAIRS KEYES & FOX, LLP CALIFORNIA ENERGY STORAGE ALLIANCE TH STREET, SUITE ALLSTON WAY, SUITE 210 OAKLAND, CA BERKELEY, CA FOR: BOSCH BUILDING GRID TECHNOLOGIES FOR: CALIFORNIA ENERGY STORAGE ALLIANCE F/K/A ROBERT BOSCH, LLC (BOSCH) (CESA) ELIZABETH REID JOHN NIMMONS, ESQ. CEO AT LAW OLIVINE, INC. JOHN NIMMONS & ASSOCIATES, INC UNIVERSITY AVENUE 175 ELINOR AVE., SUITE G BERKELEY, CA MILL VALLEY, CA FOR: OLIVINE FOR: ELECTRIC MOTORWERKS, INC. MELANIE GILLETTE JORDAN PINJUV SR. POLICY DIRECTOR COUNSEL CA EFFICIENCY+DEMAND MANAGEMENT COUNCIL CALIFORNIA INDEPENDENT SYSTEM OPERATOR 1535 FARMERS LANE, SUITE OUTCROPPING WAY SANTA ROSA, CA FOLSOM, CA FOR: CALIFORNIA EFFICIENCY + DEMAND FOR: CAISO MANAGEMENT COUNCIL (CEDMC) (FORMERLY: CALIFORNIA ENERGY EFFICIENCY INDUSTRY COUNCIL)

10 Page 3 of 8 NKECHI OGBUE MGR - REGULATORY AFFAIRS ECOBEE, INC. 250 UNIVERSITY AVE. SUITE 400 TORONTO, ON M5H 3E5 CANADA FOR: ECOBEE, INC. Information Only ALEX PORTESHAWVER ANDREW HOFFMAN CENTER FOR SUSTAINABLE ENERGY LEAP, CA 00000, CA CASE COORDINATION CENTRAL FILES SDG&E, CA 00000, CA ESAU GUARDADO JONATHAN HART REGULATORY AFFAIRS CENTER FOR SUSTAINABLE ENERGY SAN DIEGO GAS & ELECTRIC, CA 00000, CA MARC KOLB PAUL NELSON GRID DEL SOL CONSULTING BARKOVICH & YAP, AA 00000, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION PRAMOD KULKARNI REMCO VAN DEN ELZEN CUSTOMIZED ENERGY SOLUTIONS, AA 00000, CA SAVI ELLIS SEAN SEVILLA PACIFIC GAS AND ELECTRIC CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA SEPHRA A. NINOW STEPHEN GUNTHER ASSOC. DIR - REGULATORY AFFAIRS CENTER FOR SUSTAINABLE ENERGY CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA STEVEN RYMSHA DIR - GRID SOLUTIONS, PUBLIC POLICY CAMERON-DANIEL, P.C.

11 Page 4 of 8 SUNRUN INC., CA 00000, AA MRW & ASSOCIATES, LLC, CA BLAKE ELDER CLEAN ENERGY SPECIALIST EQ RESEARCH 401 HARRISON OAKS BLVD., STE. 100 CARY, NC CORINNE SIERZANT RAFAELA DIAZ REGULATORY AFFAIRS CASE MGR. - REGULATORY SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. 5TH STREET, GT14D6 555 W. 5TH STREET, GT14D6 LOS ANGELES, CA LOS ANGELES, CA SARA GERSEN CASE ADMINISTRATION STAFF SOUTHERN CALIFORNIA EDISON COMPANY EARTHJUSTICE 8631 RUSH STREET 800 WILSHIRE BLVD., STE ROSEMEAD, CA LOS ANGELES, CA ERICA KEATING NATHANAEL A. GONZALEZ SR. MANAGER MGR - PROJECT / PRODUCT SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 1515 WALNUT GROVE AVENUE 8631 RUSH STREET ROSEMEAD, CA ROSEMEAD, CA DONALD C. LIDDELL COURTNEY COOK PARALEGAL DOUGLASS & LIDDELL UTILITY CONSUMERS' ACTION NETWORK ND AVENUE 3405 KENYON STREET, SUITE 401 SAN DIEGO, CA SAN DIEGO, CA FOR: CALIFORNIA ENERGY STORAGE ALLIANCE EDWARD LOPEZ JOHN W. LESLIE, ESQ EXECUTIVE DIRECTOR UTILITY CONSUMERSâ ACTION NETWORK DENTONS US LLP 3405 KENYON ST. SUITE 401 SAN DIEGO, CA 92110, CA ANNLYN FAUSTINO GREGORY ANDERSON REGULATORY & COMPLIANCE CALIFORNIA REGULAROTY AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK COURT SAN DIEGO, CA SAN DIEGO, CA JENNIFER WRIGHT ROSS R. FULTON REGULATORY CASE MGR. SENIOR COUNSEL SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA SAN DIEGO, CA 92123

12 Page 5 of 8 ANDREW YIP JIM BAAK DIRECTOR - BUSINESS DEVELOPMENT SR. MGR. - REGULATORY AFFAIRS WEST BOSCH BUILDING GRID TECHNOLOGIES STEM, INC. 101 JEFFERSON DRIVE 100 ROLLINS ROAD MENLO PARK, CA MILLBRAE, CA FOR: STEM, INC. TED KO SUE MARA DIRECTOR OF POLICY CONSULTANT STEM, INC. RTO ADVISORS, LLC 100 ROLLINS ROAD 164 SPRINGDALE WAY MILLBRAE, CA REDWOOD CITY, CA DAVID SCHLOSBERG MARC MONBOUQUETTE DIR - ENERGY MARKET OPER SR.MGR - REG & GOV'T AFFAIRS EMOTORWERKS EMOTORWERKS 846 BRANSTEN ROAD 846 BRANSTEN ROAD SAN CARLOS, CA SAN CARLOS, CA FOR: ELECTRIC MOTOR WERKS, INC. (EMOTORWERKS) BUCHALTER DOCKET CHRIS KATO BUCHALTER 55 SECOND STREET, SUITE MARKET STREET, N6G SAN FRANCISCO, CA SAN FRANCISCO, CA DAVID POSTER JESSICA TELLEZ CASE MGR., EXPERT 245 MARKET STREET SAN FRANCISCO, CA BEALE STREET, MC 23A SAN FRANCISCO, CA JOHANNA FORS JOSEPHINE WU REGULATORY AFFAIRS CASE COORDINATOR 77 BEALE STREET, B10A 77 BEALE STREET, MC B9A, RM 2364B SAN FRANCISCO, CA SAN FRANCISCO, CA MICHAEL ALCANTAR MIKE CADE AT LAW BUCHALTER, A PROFESSIONAL CORPORATION BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, SUITE SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA MONICA A. SCHWEBS, ESQ. RYAN CHAN MORGAN LEWIS & BOCKIUS LLP 245 MARKET STREET ONE MARKET PLAZA, SPEAR STREET TOWER SAN FRANCISCO, CA SAN FRANCISCO, CA SEBASTIEN S. CSAPO TESSA CARLBERG COUNSEL 245 MARKET STREET, MAIL CODE N3F SAN FRANCISCO, CA BEALE STREET, B30A

13 Page 6 of 8 SAN FRANCISCO, CA BRIAN KOOIMAN FRANCESCA WAHL OHMCONNECT, INC. DEPUTY DIR - POLICY & ELECTRICITY MKTS 350 TOWNSEND ST., STE. 210 TESLA, INC. SAN FRANCISCO, CA DE HARO ST., STE. 101 SAN FRANCISCO, CA JOHN W. ANDERSON LILLIAN MIRVISS DIR - ENERGY MARKETS PROJECT MGR. OHMCONNECT, INC. OHMCONNECT, INC. 350 TOWNSEND ST., SUITE TOWNSEND STREET, STE. 210 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: OHMCONNECT, INC. LUKE TOUGAS MARIA BELENKY CLEAN ENERGY REGULATORY RESEARCH OHMCONNECT, INC. 175 BLUXOME 350 TOWNSEND ST., SUITE 210 SAN FRANCISCO, CA SAN FRANCISCO, CA MANAL YAMOUT SHIRLEY A. WOO VP - POLICY & MARKETS AT LAW ADVANCED MICROGRID SOLUTIONS 25 STILLMAN STREET 77 BEALE ST., MC B30A / PO BOX 7442 SAN FRANCISCO, CA SAN FRANCISCO, CA MEGAN M. MYERS SARA STECK MYERS AT LAW LAW OFFICES OF SARA STECK MYERS LAW OFFICES OF SARA STECK MYERS TH AVENUE TH AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ENEL X NORTH AMERICA, INC. RICK COUNIHAN BARBARA R. BARKOVICH NEST LABS, INC. CONSULTANT 3400 HILLVIEW AVENUE BARKOVICH & YAP, INC. PALO ALTO, CA PO BOX OAKLAND, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION CHRISTINE RIKER MICHELLE VIGEN RALSTON SR. PROJECT MGR. COMMON SPARK CONSULTING ENERGY SOLUTIONS 1929 PARKER ST APT A TH STREET BERKELEY, CA OAKLAND, CA PHILLIP MULLER DELPHINE HOU PRESIDENT CALIF. INDEPENDENT SYSTEMS OPERATOR SCD ENERGY SOLUTIONS 250 OUTCROPPING WAY 436 NOVA ALBION WAY FOLSOM, CA SAN RAFAEL, CA 94903

14 Page 7 of 8 ERIC KIM JOHN GOODIN MARKET / INFRASTRUCTURE POLICY CALIFORNIA INDEPENDENT SYSTEM OPERATOR CALIFORNIA ISO 250 OUTCROPPING WAY 250 OUTCROPPING WAY FOLSOM, CA FOLSOM, CA FOR: CALIFORNIA ISO KIM PEREZ ANDREW B. BROWN CALIFORNIA ISO 250 OUTCROPPING WAY ELLISON SCHNEIDER HARRIS & DONLAN LLP FOLSOM, CA CAPITOL AVE., STE. 400 SACRAMENTO, CA State Service MARTHA GUZMAN ACEVES ALOKE GUPTA OFFICE OF COMMISSIONER GUZMAN ACEVES CPUC - EXEC. DIV. DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA 4-A, CA VAN NESS AVENUE SAN FRANCISCO, CA BRUCE KANESHIRO CAITLIN POLLOCK DEMAND RESPONSE, CUSTOMER GENERATION, AN DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA 4-A AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA DANIEL BUCH GARIMA VASHISHTHA ELECTRICITY PRICING AND CUSTOMER PROGRAM DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA 4-A AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA HELENA OH JEAN A. LAMMING ELECTRICITY PLANNING & POLICY BRANCH DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA KATHERINE J. STOCKTON KELLY A. HYMES DEMAND RESPONSE, CUSTOMER GENERATION, AN DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MARYAM MOZAFARI NATALIE GUISHAR DEMAND RESPONSE, CUSTOMER GENERATION, AN DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE

15 Page 8 of 8 SAN FRANCISCO, CA SAN FRANCISCO, CA NILGUN ATAMTURK SUDHEER GOKHALE DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5024 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA WERNER M. BLUMER YULIYA SHMIDT DEMAND RESPONSE, CUSTOMER GENERATION, AN COMMISSIONER RECHTSCHAFFEN AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS