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

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company (U39-E) for Approval of Demand Response Programs, Pilots and Budgets for Program Years Application And Related Matters. Application Application SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) RESPONSE TO ADMINISTRATIVE LAW JUDGE S RULING AUTHORIZING THE FILING OF PROPOSED IMPROVEMENTS TO THE DEMAND RESPONSE AUCTION MECHANISM ANNA VALDBERG ROBIN Z. MEIDHOF Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Robin.Meidhof@sce.com Dated: January 11, 2019

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company (U39-E) for Approval of Demand Response Programs, Pilots and Budgets for Program Years Application And Related Matters. Application Application SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) RESPONSE TO ADMINISTRATIVE LAW JUDGE S RULING AUTHORIZING THE FILING OF PROPOSED IMPROVEMENTS TO THE DEMAND RESPONSE AUCTION MECHANISM On January 4, 2019, Administrative Law Judge (ALJ) Hymes issued a Ruling authorizing parties to file proposed improvements to the Demand Response Auction Mechanism (Ruling). 1 A subsequent procedural from ALJ Hymes on January 7, 2019 clarified that parties were to file, no later than January 11, 2019, a general description of the recommendation at this time and further noted that those parties who file by the deadline, shall be given an opportunity to provide a five-minute presentation of the recommended improvements during the January 16, 2019 workshop. On January 11, 2019, ALJ Hymes issued another procedural indicating her intent to direct the Docket Office to reject any filing that contains commentary on the staff 1 See Administrative Law Judge s Ruling Issuing Evaluation Report of the Demand Response Auction Mechanism Pilot, Noticing January 16, 2019 Workshop, and Denying Motion to Require Audit Reports in the Evaluation Report (ALJ Ruling), issued January 4, 2019, at p. 3. 1

3 evaluation or staff proposed improvements. Southern California Edison Company (SCE) had prepared a filing to provide its initial position on Staff s recommendations for proposed improvements but, given the latest guidance, has revised its submission to direct the Energy Division (ED or Staff) to those proposals SCE submitted in its August joint filing with PG&E. 2 SCE believes, however, that a response to the January 4, 2019 Ruling is warranted to raise an issue that has not been addressed yet, specifically a ruling on whether to include the results of SCE s independent Audit report into the record. I. DISCUSSION A. In the absence of a Commission Ruling to make the results of SCE s audit a part of this proceeding, it is unclear how parties to this proceeding can consider or comment with any vigor on the audit. SCE appreciates that the ALJ Ruling determined that the results of the two utility audits will be considered during this proceeding. 3 SCE is unclear, however, how parties to this proceeding will have an opportunity to review those results, comment with any vigor on those results, or engage in any substantive informed discussion with the utilities about those results, unless the Commission issues a ruling on SCE s Motion 4 and directs the public release of those audit results in advance of the January 16, 2019 workshop, or subsequently noticed workshops in February. Although SCE filed a Motion to submit the Audit results into this proceeding under seal pursuant to section 13.1 of the DRAM contract, it did so because it does not have the consent of the Seller that was the subject of the independent Audit to release those results. Comments provided in response to SCE s Motion argued that the Nexant Audit Report s methodology, 2 See SCE and PG&E Joint Response to ALJ s Ruling Directing Responses to Questions Regarding the DRAM Pilot, filed August 17, See ALJ Ruling, p. 4 While we do not include the two utility audits as part of the Pilot Evaluation performed by staff, the results of the two audits will be considered during this proceeding. 4 See Motion of Southern California Edison to File Audit Report under Seal, filed December 6,

4 data sources and results have not been vetted by the parties to this proceeding 5 and the Nexant Audit Report should be used in a transparent fashion as one data point among many. 6 Notably, CLECA filed comments in response to both utilities motions noting that public release of both the Nexant Audit Report and the results of PG&E s independent audit is warranted and that such release should occur prior to the January 16 workshops, so all parties may review the data and discuss the results at the workshop. 7 Olivine also filed comments indicating its position that [t]he independent audit reports should be part of the record and should help inform future, clearly necessary reforms to DRAM structure and contracts. 8 SCE supports a full, public release of the Nexant Audit Report. On December 21, 2018, SCE reached out to the Seller that was the subject of the audit and sought approval to make the results of the Nexant Audit Report public. Specifically, SCE explained that with the Seller s approval, SCE would withdraw its Motion to file the Audit under Seal. To date, the Seller that was the subject of the Audit has not responded either in the affirmative or negative to SCE s request to make the Audit results public. SCE is awaiting a Commission ruling on its Motion to file the results of the Audit in this proceeding. 5 See Response of OhmConnect, Inc. to Motion of Southern California Edison Company (U 338-E) for Inclusion of Independent Audit Report in Energy Division s Final Evaluation Report of the Demand Response Auction Mechanism, at p. 1, filed December 19, See Joint Response of Cpower, Enel X North America, Inc., and EnergyHub ( Joint DR Parties ) on Motion of Southern California Edison Company for Inclusion of Independent Audit Report in Energy Division s Final Evaluation Report, at p. 3, filed December 21, See Response of California Large Energy Consumers Association Supporting the Motion of Southern California Edison Company for Inclusion of Independent Audit Response in Energy Division s Final Evaluation Report of the Demand Response Auction Mechanism and the Motion of Pacific Gas and Electric Company for Inclusion of PG&E Summary of DRAM RFO Audit Analysis, Results as of December 4, 2018 in Energy Division s Final Evaluation Report of the Demand Response Auction Mechanism, at pp. 3-4, filed December 21, See Response of Olivine, Inc. to Motion of SCE for Inclusion of Independent Audit Results in Energy Division s Final Evaluation Report of the DRAM and the Motion of PG&E for Inclusion of PG&E Summary of DRAM RFO Audit Analysis, Results As of December 4, 2018 in Energy Division s Final Evaluation Report of the DRAM, at p. 3, filed December 21,

5 B. SCE proposes that any DRAM workshops or subsequent Energy Division recommendations must address how the Commission plans to hold third parties accountable for failing to procure supply resources that IOUs rely upon for Resource Adequacy. As stated in D , the purpose of the DRAM is to test: (a) the feasibility of procuring Supply Resources for Resource Adequacy (RA) with third party direct participation in the California Independent System Operation Corporation (CAISO) markets through an auction mechanism, and (b) the ability of winning bidders to integrate their provision of demand response (DR) into the CAISO market. The Energy Division should address, in connection with these market integration issues, whether DRAM Sellers have been complying with applicable CAISO tariffs. Section 3.4 of the DRAM contract requires a Seller to cause each of the PDRs and RDRRs in its DRAM Resource to comply with the CAISO tariff, CPUC Decisions, and Applicable Laws. Among other things, the CAISO tariff defines both PDRs and RDRRs in terms of a resource capable of measurably and verifiably providing demand response services; section 40 of the CAISO tariff describes the requirements for a Scheduling Coordinator to supply sufficient RA and the associated penalties for its failure to do so. As an RA product, demand response is an essential resource that supports grid reliability, and both SCE and the CAISO must be able to depend on the Seller s ability to provide the contracted load reduction when called upon. There is no question that compliance with Applicable Laws, as required by Section 3.4 of the DRAM contract, includes compliance with Federal Energy Regulatory Commission (FERC) market behavior rules when bidding the DRAM Resources into the CAISO markets. Accordingly, any Energy Division workshops and any future Staff recommendations must acknowledge this compliance obligation with the CAISO Tariff as part of the discussion of DR market integration. As noted in SCE and PG&E s August joint filing, SCE believes the performance standards, penalties and remedies should be reviewed in detail. SCE believes that 4

6 stronger performance standards (such as more rigorous testing and dispatch requirements), combined with stronger penalties, would help to facilitate accountability for performance. C. SCE Provides Additional Proposals for Improvements to the DRAM SCE makes the following brief proposals for additional improvements in addition to the proposals submitted in its August joint filing with PG&E: SCE recommends a 3-year extension of the DRAM procurement mechanism. SCE proposes a solicitation for a three-year period, with three one-year contract terms (consistent with how DRAM has worked to this point), accompanied by a robust review process that provides opportunity and flexibility to make adjustments as needed. In light of the issues identified in Staff s DRAM Report, the results of SCE s audit, and the fact that each DRAM has been an iterative process, any duration in excess of three years is not appropriate as it could preclude timely evaluation of the improvements that the Staff recognizes must be made. As seen in connection with the previous DRAM pilot, having a program with multiple planned solicitations means that RFOs follow each other in quick succession, with little time to pause, review effectiveness, and make adjustments. Additionally, the most critical changes needed to the DRAM construct cannot be remedied through the DRAM procurement process. Resolving those issues will require longerterm efforts to amend CPUC RA rules and CAISO tariff sections, as well as more transparency/oversight of DRAM/DRP resource verification. To suggest locking in more than three years of DRAM solicitations with those foundational elements still lacking could result in repeat problems and imprudent use of customer funds. SCE recommends discontinuation of the residential set-aside. SCE supports encouraging new residential market participants, but also believes that the residential set-aside results in inefficient bid selection and can skew evaluation results if several non-residential offers must be skipped in order to reach the required number of residential offers. While a reduced residential set-aside may partially alleviate the concern, a set-aside limited to 5

7 new market participants will introduce an even more restrictive element into the remaining residential set-aside, with the potential to skew results even further. Skipping multiple bids to pick up new market entrants could also send the wrong pricing signal to those parties, potentially leading to unpleasant surprises for any party that relies on that signal for its second round of participation in DRAM, when it is no longer considered new. SCE believes that the residential set-aside should be eliminated. SCE recommends that Demonstrated Capacity be invoiced based on dispatch results and going forward dispatches should be required on a quarterly basis. SCE recommends penalties for non-performance when Qualifying Capacity indicated on Supply Plans falls significantly below contracted capacity. SCE does not believe that such penalties should be explored in the Supply-Side Working Group (SSWG). The SSWG is established to resolve barriers to further integration of DR into the CAISO market. The question of whether penalties should be assessed for non-performance does not fall into this category, and it is unclear what benefit would be gained by adding this issue to the already long task list for the SSWG. Rather, this issue should be discussed in the DRAM workshops or a CAISO stakeholder process. SCE suggests counterparties be given the option to bid capacity + energy in future solicitations, which would create the opportunity for sellers to receive performance incentives up to 105% commensurate with other demand response contract/program settlement arrangements. This type of Capacity payment band structure, similar to those previously implemented in the Aggregator Managed Program (AMP) and SCE's LCR RFO contracts, also dictates that underperformance results in a lower capacity price ($/MW) paid to the Seller. The IOUs should be allowed to procure DRAM resources as part of their regular RA solicitations, instead of the current stand-alone auction, and to evaluate and award offers based on the standard Least Cost Best Fit criteria. Demand Response Providers should be required to submit year-ahead Supply Plans in order to allow IOUs to utilize the RA capacity in their year ahead showings. 6

8 II. CONCLUSION SCE appreciates the Commission s consideration of these matters and the opportunity to provide this response in advance of the January 16, 2019 workshop on ED s Final Evaluation of the DRAM. Respectfully submitted, ROBIN Z. MEIDHOF By: /s/ Robin Z. Meidhof Robin Z. Meidhof Attorney for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Robin.Meidhof@sce.com Dated: Janaury 11,

9 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 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) RESPONSE TO ADMINISTRATIVE LAW JUDGE S RULING AUTHORIZING THE FILING OF PROPOSED IMPROVEMENTS TO THE DEMAND RESPONSE AUCTION MECHANISM 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 11, 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

10 CPUC - Service Lists - A Page 1 of 8 1/11/2019 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR APPOVAL O FILER: LIST NAME: LIST LAST CHANGED: JANUARY 11, 2019 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties ERIKA DIAMOND DAVID P. LOWREY VP - UTILITY & MKT SRVCS DIRECTOR, REGULATORY STRATEGY ENERGYHUB COMVERGE, INC RD STREET, SUITE TH STREET, SUITE 2300 BROOKLYN, NY DENVER, CO FOR: ENERGYHUB 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 JIM BAAK SR. DIR., WESTERN REG. AFFAIRS SR. MGR. - REGULATORY AFFAIRS WEST ENEL X NORTH AMERICA, INC. STEM, INC. PO BOX ROLLINS ROAD CAYUCOS, CA MILLBRAE, CA FOR: ENEL X NORTH AMERICA, INC. FOR: STEM, INC. (FORMERLY ENERNOC, INC.)

11 CPUC - Service Lists - A Page 2 of 8 1/11/2019 ROSANNE O'HARA MARCEL HAWIGER STAFF LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM MARKET ST., STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: ORA NORA SHERIFF NICHOLAS CONNELL SR. MGR - GOV'T AFFAIRS BUCHALTER, A PROFESSIONAL CORPORATION ADVANCED MICROGRID SOLUTIONS 55 SECOND STREET, SUITE STILLMAN STREET, SUITE 200 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: ADVANCED MICROGRID SOLUTIONS ASSOCIATION (CLECA) BRIAN T. CRAGG DARREN ROACH GOODIN, MACBRIDE, SQUERI & DAY, LLP LAW DEPT. 505 SANSOME ST., STE. 900 PO BOX 7442, MC B30A SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: OHMCONNECT, INC. FOR: SARA STECK MYERS JENNIFER A. CHAMBERLIN AT LAW EXE DIR - MRKT DEVELOPMENT / CAISO TH AVENUE CPOWER SAN FRANCISCO, CA WELLINGTON COURT FOR: ON BEHALF OF JOINT DR PARTIES CLYDE, CA (COMVERGE, INC., CPOWER, ENEL X NORTH FOR: CPOWER, INC. AMERICA, INC., ENERGYHUB) JASON B. KEYES MELANIE GILLETTE PARTNER SR. POLICY DIRECTOR KEYES & FOX LLP CA EFFICIENCY+DEMAND MANAGEMENT COUNCIL TH ST., STE BROADWAY OAKLAND, CA OAKLAND, CA FOR: SOLARCITY CORPORATION FOR: CALIFORNIA EFFICIENCY + DEMAND MANAGEMENT COUNCIL (CEDMC) (FORMERLY: CALIFORNIA ENERGY EFFICIENCY INDUSTRY COUNCIL) 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

12 CPUC - Service Lists - A Page 3 of 8 1/11/2019 FOR: OLIVINE FOR: ELECTRIC MOTORWERKS, INC. JORDAN PINJUV NKECHI OGBUE COUNSEL MGR - REGULATORY AFFAIRS CALIFORNIA INDEPENDENT SYSTEM OPERATOR ECOBEE, INC. 250 OUTCROPPING WAY 250 UNIVERSITY AVE. SUITE 400 FOLSOM, CA TORONTO, ON M5H 3E5 FOR: CAISO 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 MRW & ASSOCIATES, LLC

13 CPUC - Service Lists - A Page 4 of 8 1/11/2019 DIR - GRID SOLUTIONS, PUBLIC POLICY SUNRUN INC., CA 00000, AA HERTER ENERGY CAMERON-DANIEL, P.C., CA 00000, CA BLAKE ELDER CORINNE SIERZANT CLEAN ENERGY SPECIALIST REGULATORY AFFAIRS EQ RESEARCH SOUTHERN CALIFORNIA GAS COMPANY 401 HARRISON OAKS BLVD., STE W. 5TH STREET, GT14D6 CARY, NC LOS ANGELES, CA RAFAELA DIAZ SARA GERSEN CASE MGR. - REGULATORY STAFF SOUTHERN CALIFORNIA GAS COMPANY EARTHJUSTICE 555 W. 5TH STREET, GT14D6 800 WILSHIRE BLVD., STE LOS ANGELES, CA LOS ANGELES, CA CASE ADMINISTRATION ERICA KEATING SOUTHERN CALIFORNIA EDISON COMPANY SR. MANAGER 8631 RUSH STREET SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA WALNUT GROVE AVENUE ROSEMEAD, CA NATHANAEL A. GONZALEZ DONALD C. LIDDELL SR. ADVISOR SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 8631 RUSH STREET ND AVENUE ROSEMEAD, CA SAN DIEGO, CA FOR: CALIFORNIA ENERGY STORAGE ALLIANCE COURTNEY COOK EDWARD LOPEZ PARALEGAL EXECUTIVE DIRECTOR UTILITY CONSUMERS' ACTION NETWORK UTILITY CONSUMERSâ ACTION NETWORK 3405 KENYON STREET, SUITE KENYON ST. SUITE 401 SAN DIEGO, CA SAN DIEGO, CA JOHN W. LESLIE, ESQ ANNLYN FAUSTINO REGULATORY & COMPLIANCE DENTONS US LLP SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F, CA SAN DIEGO, CA GREGORY ANDERSON JENNIFER WRIGHT CALIFORNIA REGULAROTY AFFAIRS REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA SAN DIEGO, CA ROSS R. FULTON ANDREW YIP

14 CPUC - Service Lists - A Page 5 of 8 1/11/2019 SENIOR COUNSEL DIRECTOR - BUSINESS DEVELOPMENT SAN DIEGO GAS & ELECTRIC COMPANY BOSCH BUILDING GRID TECHNOLOGIES 8330 CENTURY PARK COURT, CP32D 101 JEFFERSON DRIVE SAN DIEGO, CA MENLO PARK, CA 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 SAN FRANCISCO, CA 94105

15 CPUC - Service Lists - A Page 6 of 8 1/11/2019 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 ERIC KIM MARKET / INFRASTRUCTURE POLICY JOHN GOODIN CALIFORNIA INDEPENDENT SYSTEM OPERATOR

16 CPUC - Service Lists - A Page 7 of 8 1/11/2019 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 SAN FRANCISCO, CA SAN FRANCISCO, CA

17 CPUC - Service Lists - A Page 8 of 8 1/11/2019 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