BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA. Order Instituting Rulemaking Regarding Building Decarbonization.

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Building Decarbonization. R SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY COMMENTS ON THE ORDER INSTITUTING RULEMAKING REGARDING BUILDING DECARBONIZATION ANNA VALDBERG R. OLIVIA SAMAD Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Olivia.Samad@sce.com Dated: March 26, 2019

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Building Decarbonization. R SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) REPLY COMMENTS ON THE ORDER INSTITUTING RULEMAKING REGARDING BUILDING DECARBONIZATION I. INTRODUCTION Pursuant to Rule 6.2 of the California Public Utilities Commission s (Commission s) Rules of Practice and Procedure, Southern California Edison Company (SCE) respectfully submits these Reply Comments on the February 8, 2019 Order Instituting Rulemaking Regarding Building Decarbonization (the OIR). In Summary, SCE notes the following: SCE agrees with CalPA that allowing single-fuel electric utilities to bid on BUILD and/or TECH program administration may be appropriate and beneficial. SCE treats all customers in a nondiscriminatory manner and disagrees with the Joint Community Choice Aggregators assertion to the contrary. SCE disagrees with The National Fuel Cell Research Center s assertion that broader building decarbonization policy development is outside the scope of this proceeding. SCE agrees with parties that development of policy for biomethane is valuable and recommends that this topic be addressed in another rulemaking. 1

3 II. DISCUSSION A. A Single-Fuel Electric Utility is an Eligible Administrator for BUILD and TECH Under the Definition Given in SB 1477 The California Public Advocates Office (CalPA) asks the Commission to consider whether single-fuel electric utilities meet the definition of a third-party for the purposes of these programs such that a single-fuel electric utility would be eligible to respond to a program administration solicitation. 1 SCE agrees with CalPA that allowing single-fuel electric utilities to bid on BUILD and/or TECH program administration may be appropriate and beneficial to achieving program goals at reasonable costs to ratepayers. As noted in SCE s opening comments, SB 1477 lists two options for administering the BUILD and TECH pilot programs: (1) each gas corporation, and (2) a third party, including the California Energy Commission. The statute contains no further limitations on what constitutes a third party for the purpose of administering the BUILD and TECH pilot programs. Therefore, SCE is eligible under SB 1477 to administer the pilots and should be allowed to compete to do so. B. SCE Treats All Customers In a Nondiscriminatory Manner The Joint Community Choice Aggregators incorrectly claim that IOUs have a strong incentive to game the system and this motivation also creates a strong incentive to administer programs in a manner that favors IOU customers that also receive bundled electric service from the IOUs at the expense of other customer groups, including CCA customers. 2 This assertion is incorrect. SCE treats all of its customers in a nondiscriminatory manner, including both bundled and CCA customers. Further, SCE adheres to the code of conduct requirements in D that governs SCE s interactions with CCAs. 3 Finally, all SCE customers deserve equal access to 1 Cal PA Comments on OIR Regarding Building Decarbonization, at p Comments of the Joint Community Choice Aggregators on the Preliminary Scoping Memo, at p D , at p. 8. 2

4 clean air and equal access to programs that can help them make clean energy choices and manage their energy bills. C. Broader Building Decarbonization Policy Development is Appropriate in the Scope of This Proceeding The National Fuel Cell Research Center asserts that [b]roader Building Decarbonization Policy Development is outside the scope of this proceeding because the legislature did not direct the Commission to undertake the development of a statewide building decarbonization strategy in SB The Commission has correctly determined that the programs created by SB 1477 are pilot programs that can be used to raise awareness of building decarbonization technologies and applications, test program and policy designs, and gain the practical implementation experience and knowledge necessary to develop a larger scale approach. 5 Because the pilot programs created by SB 1477 will not be sufficient to completely transform the market for building decarbonization technologies, the Commission is right to develop a policy framework that can guide future decisions about programs and investments to achieve the State s greenhouse gas emission reduction goals through building decarbonization. D. Development of Policy For Biomethane is Valuable and Should Be Completed in Another Rulemaking This rulemaking states that Building decarbonization has received less attention to date; we use the term herein to include both actions to reduce the emissions and impacts from natural gas use in buildings, as well as to electrify certain building end uses. 6 Several parties commented that biomethane, hydrogen, and/or other gaseous fuels should be added to the scope of this rulemaking. Reducing the emissions and health impacts from natural gas use in buildings through the substitution of renewable biomethane or other alternative gaseous fuels is an 4 Opening Comments of the National Fuel Cell Research Center on Order Instituting Rulemaking Regarding Building Decarbonization, at p OIR, at p OIR, at p. 4. 3

5 appropriate policy discussion for the Commission to engage in with the large gas corporations in California. However, it is inappropriate for inclusion in a rulemaking that specifically names the large investor-owned electric distribution utilities as respondents; not all electric utilities are gas corporations. Carbon-neutral biofuels have a valuable part to play in the decarbonization of the energy system. Serious efforts to model and analyze a portfolio of GHG reducing strategies that can meet a goal of 80 percent GHG emission reductions by 2050 have found that the most costeffective use of the limited supply of carbon-neutral biomethane or other biofuels for decarbonization is to use these biofuels for hard-to-electrify end uses such as high-temperature industrial process heat and feedstocks, aviation, and maritime transportation. 7 It is important for the Commission, in coordination with CARB and the CEC to develop a clear policy framework for biomethane or other biofuels so that biomethane supply is carbon neutral and deployed to highest value uses, and that any potential stranded gas distribution assets are understood and addressed. Because the most likely long-term use of the limited supply of biomethane or other biofuels is unlikely to be in the building sector, a more appropriate venue for developing such a policy framework would be a rulemaking explicitly dedicated to the development and deployment of these fuels. As such, the scope of this building decarbonization rulemaking should not be expanded to include biomethane or other biofuels. The Commission must launch the BUILD and TECH pilot programs quickly and launch larger-scale building technology decarbonization programs soon thereafter, in order to aid in advancing the market for end use equipment in buildings in a timely manner to meet the state s 2030 GHG emission reduction goals. Discussion of issues related to biomethane in this 7 Examples include: Deep Decarbonization in a High Renewables Future, available at and United States Mid-Century Strategy for Deep Decarbonization, available at 4

6 rulemaking would be a distraction that would slow the development of an appropriate framework to transform the market for building decarbonization technologies. III. CONCLUSION SCE appreciates the opportunity to submit these comments and looks forward to collaborating with the Commission and stakeholders. Respectfully submitted, ANNA VALDBERG R. OLIVIA SAMAD By: /s/ R. Olivia Samad R. Olivia Samad Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Olivia.Samad@sce.com Dated: March 26,

7 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Building Decarbonization. R 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) REPLY COMMENTS ON THE ORDER INSTITUTING RULEMAKING REGARDING BUILDING DECARBONIZATION on all parties identified on the attached service list(s) for R 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 Colin Rizzo CPUC 505 Van Ness Avenue San Francisco, CA ALJ Julie A. Fitch CPUC 505 Van Ness Avenue San Francisco, CA Executed March 26, 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: R CPUC - OIR REGARDING FILER: CPUC LIST NAME: LIST LAST CHANGED: MARCH 25, 2019 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties MATTHEW VESPA RACHAEL KOSS STAFF ATTORNEY ADAM BROADWELL JOSEPH & CARDOZO EARTHJUSTICE 50 CALIFORNIA ST., SUITE 500, CA SAN FRANCISCO, CA FOR: COALITION OF CALIFORNIA UTILITY FOR: SIERRA CLUB EMPOYEES CARLA C. KOLEBUCK RONALD VAN DER LEEDEN ASSOC. GEN. COUNSEL DIR. - REGULATORY AFFAIRS SOUTHWEST GAS CORPORATION SOUTHERN CALIFORNIA GAS COMPANY 5241 SPRING MOUNTAIN ROAD 555 W. FIFTH STREET, GT14D6 LAS VEGAS, NV LOS ANGELES, CA FOR: SOUTHWEST GAS CORPORATION FOR: SOUTHERN CALIFORNIA GAS COMPANY GARY STERN C.C. SONG MANAGING DIR. REGULATORY & LEGISLATIVE POLICY MANAGER SOUTHERN CALIFORNIA EDISON COMPANY MARIN CLEAN ENERGY 8631 RUSH STREET 1125 TAMALPAIS AVE ROSEMEAD, CA SAN RAFAEL, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: MARIN CLEAN ENERGY SEPHRA A. NINOW, J.D. CLAY FABER ASSOCIATE DIRECTOR, REGULATORY AFFAIRS DIR - REGULATORY AFFAIRS CENTER FOR SUSTAINABLE ENERGY SAN DIEGO GAS & ELECTRIC COMPANY 3980 SHERMAN ST., SUITE CENTURY PARK CT., CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: CENTER FOR SUSTAINABLE ENERGY FOR: SAN DIEGO GAS & ELECTRIC COMPANY

9 Page 2 of 8 JEREMY WAEN HILARY STAVER MGR. - REGULATORY AFFAIRS MNGR OF REGULATORY & LEGISLATIVE AFFAIRS PENINSULA CLEAN ENERGY SILICON VALLEY CLEAN ENERGY AUTHORITY 2075 WOODSIDE RD. 333 W. EL CAMINO REAL, STE. 290 REDWOOD CITY, CA SUNNYVALE, CA FOR: PENINSULA CLEAN ENERGY FOR: SILICON VALLEY CLEAN ENERGY AUTHORITY AMY C. YIP-KIKUGAWA HAYLEY GOODSON STAFF ATTORNEY LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM MARKET ST., STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: PUBLIC ADVOCATES OFFICE ARIEL STRAUSS MERRIAN BORGESON SMALL BUSINESS UTILITY ADVOCATES SR. SCIENTIST, ENERGY PROGRAM 548 MARKET ST., SUITE NATURAL RESOURCES DEFENSE COUNCIL SAN FRANCISCO, CA SUTTER ST., 21ST FL. FOR: SMALL BUSINESS UTILITY ADVOCATES SAN FRANCISCO, CA FOR: NATURAL RESOURCES DEFENSE COUNCIL SRINIDHI S. KUMAR JENNIFER K. BERG PROGRAM MGR. ASSISTANT DIRECTOR CALIFORNIA HOUSING PARTNERSHIP BAY AREA METRO 369 PINE STREET, STE BEALE STREET SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALIFORNIA HOUSING PARTNERSHIP FOR: ASSOCIATION OF BAY AREA GOVERNMENTS TIMOTHY O'CONNOR JAMES D. SQUERI SR. ATTY & DIR ATTORNEY AT LAW ENVIRONMENTAL DEFENSE FUND GOODIN, MACBRIDE, SQUERI & DAY, LLP 123 MISSION STREET, 28TH FL 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ENVIRONMENTAL DEFENSE FUND FOR: CALIFORNIA BUILDING INDUSTRY ASSOCIATION JEANNE B. ARMSTRONG SARA STECK MYERS ATTORNEY AT LAW ATTORNEY AT LAW GOODIN, MACBRIDE, SQUERI & DAY, LLP LAW OFFICES OF SARA STECK MYERS 505 SANSOME STREET, SUITE TH AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION FOR: ENEL X NORTH AMERICA, INC ERIK JACOBSON APRIL MAURATH SOMMER DIR - REGULATORY RELATIONS EXECUTIVE & LEGAL DIRECTOR PACIFIC GAS AND ELECTRIC COMPANY WILD TREE FOUNDATION 77 BEALE ST., MD B23A / PO BOX PALOS VERDES MALL, NO. 196 SAN FRANCISCO, CA WALNUT CREEK, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: WILD TREE FOUNDATION STEPHEN CAMPBELL PROJECT MGR. NATE KINSEY REGULATORY AFFAIRS MANAGER

10 Page 3 of 8 GRID ALTERNATIVES CA EFFICIENCY & DEMAND MGMT COUNCIL 1171 OCEAN AVE., SUITE BROADWAY OAKLAND, CA OAKLAND, CA FOR: GRID ALTERNATIVES FOR: CA EFFICIENCY & DEMAND MGMT COUNCIL ALEX MORRIS NEAL M. REARDON VP - POLICY & OPERS DIR - REGULATORY AFFAIRS CALIFORNIA ENERGY STORAGE ALLIANCE SONOMA CLEAN POWER AUTHORITY 2150 ALLSTON WAY, STE SANTA ROSA AVE. 5TH FL BERKELEY, CA SANTA ROSA, CA FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: SONOMA CLEAN POWER AUTHORITY JACK BROUWER BRITTANY ILES DIR. ATTORNEY UNIVERSITY OF CALIFORNIA BRAUN BLAISING SMITH WYNNE, PC NATIONAIL FUEL CELL RESEARCH CENTER 915 L STREET, SUITE 1480 UNIVERSITY OF CALIFORNIA SACRAMENTO, CA IRVINE, CA FOR: MONTEREY BAY COMMUNITY POWER FOR: NATIONAL FUEL CELL RESEARCH CENTER FRANK HARRIS MGR OF ENERGY REGULATORY POLICY CA MUNICIPAL UTILITIES ASSOCIATION 915 L STREET, SUITE 1460 SACRAMENTO, CA FOR: CA MUNICIPAL UTILITIES ASSOCIATION Information Only AL LUNA ALEX RICKLEFS EARTHJUSTICE ENERGY COALITION, CA 00000, CA CASE COORDINATION CHRISTINE TAM PACIFIC GAS AND ELECTRIC COMPANY CITY OF PALO ALTO - UTILITIES, CA 00000, CA CHRISTOPHER SUMMERS DON ARAMBULA REGULATORY BUSINESS MANAGER DON ARAMBULA CONSULTING SAN DIEGO GAS & ELECTRIC, AA 00000, CA EVAN KUDLER HEATHER LARSON CASE MGR - REG. AFFAIRS STOPWASTE ENERGY COUNCIL PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA KAREN HERTER HERTER ENERGY KATHY PENICHE SAN DIEGO GAS & ELECTRIC

11 Page 4 of 8, CA 00000, CA KAVYA BALARAMAN MARC COSTA STAFF WRITER / REPORTER ENERGY COALITION CALIFORNIA ENERGY MARKETS, CA 00000, CA MATTHEW PLUMMER NICK THORPE STATE AGENCY REGULATIONS EARTHJUSTICE PACIFIC GAS AND ELECTRIC COMPANY, DC 00000, CA SAM WADE SAMUEL GOLDING DIRECTOR OF STATE REGULATORY AFFAIRS PRESIDENT THE COALITION FOR RENEWABLE NATURAL GAS COMMUNITY CHOICE PARTNERS, INC., CA 00000, CA STEPHEN GUNTHER TIM OLSEN CENTER FOR SUSTAINABLE ENERGY ENERGY COALITION, CA 00000, CA MRW & ASSOCIATES LLC, CA KATRINA FRITZ KM FRITZ LLC 2957 OJIBWA TRAIL TRAVERSE CITY, MI TASHIA GARRY VALERIE J. ONTIVEROZ LEGAL ASSISTANT REGULATORY MGR - CALIF. SOUTHWEST GAS CORPORATION SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV LAS VEGAS, NV AVISHA A. PATEL CHRISTOPHER M. BISSONNETTE SR. COUNSEL ACTING - ASSISTANT GEN. COUNSEL SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 WEST FIFTH STREET, GT-14E7 555 W. FIFTH STREET, GT-14G1 LOS ANGELES, CA LOS ANGELES, CA CORINNE SIERZANT JOSEPH MOCK REGULATORY AFFAIRS REGULATORY CASE MGR. SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. 5TH STREET, GT14D6 555 WEST 5TH ST., STE 1400, GT14D6 LOS ANGELES, CA LOS ANGELES, CA SHIRLEY ARAZI JON SWITALSKI REGULATORY BUSINESS MGR. EXE. DIR. SOUTHERN CALIFORNIA GAS COMPANY CALIFORNIANS 4 BALANCED ENERGY SOLUTION 555 W. FIFTH STREET, GT14D6 777 S. FIGUEROA STREET, NO. 4050

12 Page 5 of 8 LOS ANGELES, CA LOS ANGELES, CA FOR: CALIFORNIANS FOR BALANCED ENERGY SOLUTIONS (C4BES) DANIEL DOUGLASS CASE ADMINISTRATION ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVENUE 4766 PARK GRANADA, SUITE 209 ROSEMEAD, CA CALABASAS, CA CODY MORGAN TAYLOR R. OLIVIA SAMAD SOUTHERN CALIFORNIA EDISON COMPANY SR. ATTORNEY 8631 RUSH ST SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA WALNUT GROVE AVENUE ROSEMEAD, CA DONALD C. LIDDELL JOHN W. LESLIE, ESQ. ATTORNEY AT LAW ATTORNEY DOUGLASS & LIDDELL DENTONS US LLP ND AVENUE 4655 EXECUTIVE DRIVE, STE. 700 SAN DIEGO, CA SAN DIEGO, CA CENTRAL FILES ERICA L. MARTIN SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK COURT, CP32C SAN DIEGO, CA SAN DIEGO, CA EMANUEL WAGNER JEFF HIRSCH DEPUTY DIR JAMES J. HIRSCH & ASSOCIATES CALIFORNIA HYDROGEN BUSINESS COUNCIL PRESILLA ROAD VIA SERENO SANTA ROSA VALLEY, CA YORBA LINDA, CA FOR: CALIFORNIA HYDROGEN BUSINESS COUNCIL (CHBC) MONA TIERNEY-LLOYD ROCHELLE THOMAS SR. DIR., WESTERN REG. AFFAIRS ENERGY MGR. ENEL X NORTH AMERICA, INC. SAN JOAQUIN VALLEY CLEAN ENERGY PO BOX NORTH FIRST STREET, STE. 140 CAYUCOS, CA FRESNO, CA FOR: SAN JOAQUIN VALLEY CLEAN ENERGY ORGANIZATION (SJVCEO) DOUG KARPA SUE MARA PENINSULA CLEAN ENERGY CONSULTANT 2075 WOODSIDE ROAD RTO ADVISORS, L.L.C. REDWOOD CITY, CA SPRINGDALE WAY REDWOOD CITY, CA MILES MAURINO ROSS NAKASONE ASSOCIATE ATTORNEY PLANNING & REGULATORY COMPLIANCE ADAMS BROADWELL JOSEPH & CARDOZO SAN FRANCISCO PUBLIC UTILITES COMMISSION 601 GATEWAY BLVD., STE GOLDEN GATE AVE., 7TH FL. SOUTH SAN FRANCISCO, CA SAN FRANCISCO, CA 94102

13 Page 6 of 8 FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES CHRISTOPHER CLAY COLIN RIZZO LEGAL DIVISION ADMINISTRATIVE LAW JUDGE DIVISION ROOM 4300 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: PUBLIC ADVOCATES OFFICE DANIEL BUCH ELIZABETH FOX ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA 4-A AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOREST KASER HAL KANE PRESIDENT PICKER ENERGY EFFICIENCY BRANCH AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA HENRY BURTON JOANNA PEREZ-GREEN ELECTRICITY PRICING AND CUSTOMER PROGRAM ENERGY EFFICIENCY BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JULIE A. FITCH PAULA GRUENDLING ADMINISTRATIVE LAW JUDGE DIVISION INFRASTRUCTURE PLANNING AND PERMITTING B ROOM 5107 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA SARAH LERHAUPT SUZANNE CASAZZA ENERGY EFFICIENCY BRANCH COMMISSIONER RANDOLPH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA WILLIAM SANDERS IVAN R. JIMENEZ DEPUTY CITY ATTORNEY REGULATORY ATTORNEY CITY AND COUNTY OF SAN FRANCISCO SMALL BUSINESS UTILITY ADVOCATES CITY HALL, RM MARKET STREET, STE DR. CARLTON B. GOODLETT PLACE SAN FRANCISCO, CA SAN FRANCISCO, CA JAMES M. BIRKELUND PIERRE DELFORGE

14 Page 7 of 8 PRESIDENT SENIOR SCIENTIST SMALL BUSINESS UTILITY ADVOCATES NATURAL RESOURCES DEFENSE COUNCIL 548 MARKET STREET, STE SUTTER ST., 21ST FLOOR SAN FRANCISCO, CA SAN FRANCISCO, CA STEPHANIE WANG JESSIE KNAPSTEIN POLICY DIR PACIFIC GAS AND ELECTRIC COMPANY CALIFORNIA HOUSING PARTNERSHIP 77 BEALE STREET 369 PINE STREET, STE. 300 SAN FRANCISCO, CA SAN FRANCISCO, CA MICHAEL COLVIN MOLLY ZIMNEY ENVIRONMENTAL DEFENSE FUND ATTORNEY 123 MISSION ST PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE STREET, B30A SAN FRANCISCO, CA BRIAN KOOIMAN LILLIAN MIRVISS OHMCONNECT, INC. PROJECT MGR. 350 TOWNSEND ST., STE. 210 OHMCONNECT, INC. SAN FRANCISCO, CA TOWNSEND STREET, STE. 210 SAN FRANCISCO, CA ANDREW MEIMAN, PE BUCK B. ENDEMANN PRINCIPAL PARTNER ARC ALTERNATIVES K&L GATES LLP 222 SUTTER STREET, STE EMBARCADERO CENTER, STE SAN FRANCISCO, CA SAN FRANCISCO, CA ALEJANDRA M. CUNNINGHAM MEGAN M. MYERS TRANSCENDENT ENERGY, LLC ATTORNEY 2298 FULTON STREET LAW OFFICES OF SARA STECK MYERS SAN FRANCISCO, CA TH AVENUE SAN FRANCISCO, CA DEBORAH BEHLES SERJ BERELSON OF COUNSEL MGR - REG & GOV'T AFFAIRS CALIFORNIA ENVIRONMENTAL JUSTICE ALLIANC NEST LABS, INC 3400 HILLVIEW AVE., CA PALO ALTO, CA MICHAEL ROCHMAN EBCE REGULATORY MANAGING DIR. EAST BAY COMMUNITY ENERGY SCHOOL PROJECT UTILITY RATE REDUCTION 1111 BROADWAY, 3RD FLOOR 1850 GATEWAY BLVD., STE. 235 OAKLAND, CA CONCORD, CA JP ROSS SAMANTHA WEAVER EAST BAY COMMUNITY ENERGY PRINCIPAL REGULATORY ANALYST 1111 BROADWAY EAST BAY COMMUNITY ENERGY OAKLAND, CA BROADWAY OAKLAND, CA 94607

15 Page 8 of 8 BRUCE MAST ALISON SEEL PRINCIPAL SIERRA CLUB ARDENNA ENERGY, LLC 2101 WEBSTER ST, SUITE LAKE PARK AVENUE / PO BOX OAKLAND, CA OAKLAND, CA BRIAN BARNACLE JENNIFER WEST ENERGY SOLUTIONS PROGRAM MANAGER TH STREET STOPWASTE OAKLAND, CA WEBSTER ST OAKLAND, CA RACHEL BIRD TIM LINDL DIR - POLICY & BUS. DEVELOPMENT, WEST PARTNER BORREGO SOLAR SYSTEMS, INC. KEYES & FOX LLP 1814 FRANKLIN ST., STE TH STREET, SUITE 1305 OAKLAND, CA OAKLAND, CA RICHARD MCCANN AUDRA HARTMANN M.CUBED QUINTANA, WATTS & HARTMANN TH STREET 925 L STREET, SUITE 220 DAVIS, CA SACRAMENTO, CA BBSW REGULATORY BRAD HEAVNER BRAUN BLAISING SMITH WYNNE, PC (BBSW) POLICY DIRECTOR 915 L STREET, SUITE 1480 CALIFORNIA SOLAR & STORAGE ASSCIATION SACRAMENTO, CA TH ST., SUITE 820 SACRMENTO, CA DAVID PEFFER ROBERT E. RAYMER BRAUN BLAISING SMITH WYNNE, P.C. TECHNICAL DIR / SENIO ADVOCATE 915 L STREET, SUITE 1480 CALIFORNIA BUILDING INDUSTRY ASSOCIATION SACRAMENTO, CA K STREET, SUITE 1200 SACRAMENTO, CA SCOTT BLAISING TIFFANY MATEO ATTORNEY AT LAW MECHANICAL ENGINEER BRAUN BLAISING SMITH & WYNNE. P.C. CALIFORNIA ENERGY COMMISSION 915 L STREET, STE BLDG & COMPLIANCE OFFICE, EFFICIENCY DIV SACRAMENTO, CA NINTH STREET, MS-26 SACRAMENTO, CA LYNN HAUG ANN TROWBRIDGE ATTORNEY DAY CARTER & MURPHY, LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 3620 AMERICAN RIVER DRIVE, STE CAPITOL AVE., STE. 400 SACRAMENTO, CA SACRAMENTO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS