BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Assess Peak Electricity Usage Patterns and Consider Appropriate Time Periods for Future Time-of-Use Rates and Energy Resource Contract Payments. R (Filed December 17, 2015) SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON PROPOSED DECISION OF ADMINISTRATIVE LAW JUDGE MCKINNEY FADIA RAFEEDIE KHOURY R. OLIVIA SAMAD Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: November 21, 2016

2 SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON PROPOSED DECISION OF ADMINISTRATIVE LAW JUDGE MCKINNEY TABLE OF CONTENTS SECTION PAGE I. INTRODUCTION...1 II. III. IV. ALL TOU RATE OPTIONS INCLUDING THE GRANDFATHERED TARIFFS WITH EXISTING TOU PERIODS SHOULD BE COST-BASED...3 THE PD SHOULD BE MODIFIED TO ENCOURAGE ADMINISTRATIVELY EFFICIENT MEANS TO GRANDFATHER SOLAR TOU CUSTOMERS...5 CORRECTION TO PD S CHARACTERIZATION OF GRANDFATHERING OF TOU PERIODS FOR NEM 2.0 CUSTOMERS...6 V. PROSPECTIVE RENEWABLE GENERATION CUSTOMERS SHOULD BE PROVIDED WITH INFORMATIONAL MATERIALS ON POTENTIAL CHANGES TO TOU PERIODS...7 i

3 SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON PROPOSED DECISION OF ADMINISTRATIVE LAW JUDGE MCKINNEY TABLE OF AUTHORITIES AUTHORITY PAGE CPUC Decisions D D , 4, 5 D PASSIM CPUC Rulemakings R , 7 ii

4 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Assess Peak Electricity Usage Patterns and Consider Appropriate Time Periods for Future Time-of-Use Rates and Energy Resource Contract Payments. R (Filed December 17, 2015) SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON PROPOSED DECISION OF ADMINISTRATIVE LAW JUDGE MCKINNEY I. INTRODUCTION Pursuant to California Public Utilities Commission ( Commission ) Rule of Practice and Procedure 14.3, Southern California Edison Company ( SCE ) respectfully submits these Opening Comments to the November 1, 2016, Proposed Decision ( PD ) of Administrative Law Judge ( ALJ ) Jeanne McKinney. The PD adopts nine policy guidelines or principles to be used by the Investor Owned Utilities ( IOUs ) in the design, implementation, and modification of the time intervals reflected in their revised base Time-of-Use ( TOU ) time periods and rates. 1 SCE appreciates the collaborative and exploratory efforts of the Energy Division, Commission staff and the parties to this proceeding. The guidelines adopted for the development of new TOU periods represent a shared understanding of complex marginal cost issues that will be explored further in each IOU s 1 PD, Conclusion of Law 4 and Ordering Paragraph 1; pp ; and Appendix 1. 1

5 rate design proceedings. SCE generally agrees that the guidelines adopted for development and the implementation of new TOU rate design elements and periods are fair and reasonable. Although the IOUs recommendation to not grandfather 2 behind-the-meter ( BTM ) solar customers was not adopted by the PD, as an apparent compromise between the IOU s position and the position taken by solar parties, the PD deems that a five-year transition period 3 for grandfathering-eligible customers 4 is reasonable and consistent with the Commission s approach taken in D and D The PD properly declines to adopt the solar representatives recommendation for a ten-year grandfathering period, 5 explaining that unreasonably long grandfathering prolongs the period during which such customers receive less accurate, and less cost-based, TOU pricing signals. 6 SCE believes that extending service for some customers on grandfathered TOU tariffs, instead of transferring all customers to tariffs with more accurate TOU periods that are adopted by the Commission, will dilute price signals and promote inefficient use of the electrical system. Nonetheless, if the Commission adopts the PD s recommendation, the PD should be modified as follows: The PD should be clarified to ensure no misunderstanding that TOU rate elements, but not TOU time periods, in the grandfathered TOU tariffs are subject to change based on marginal costs and other relevant changes applied to any other optional TOU tariffs. 2 To grandfather is to allow certain customers to stay on an existing TOU tariff with the same TOU period definitions after the existing TOU tariff is closed to new customers. See PD, p The five-year transition protection allows the customer to maintain the same TOU periods for five years beginning on the date the customer s system begins operations. See PD, p Grandfathering-eligible customers are defined as customers who complete interconnection agreements before the implementation of the new TOU periods and are within their five-year transition protection period when the new TOU periods are implemented. See PD, pp PD, pp See also SEIA s November 15, 2016 Notice of Oral and Written Ex Parte Contact. 6 PD, p

6 The PD should be modified to encourage the IOUs to propose administratively efficient methods in Phase 2 of their GRCs or appropriate rate design window proceedings to implement the requirements of Ordering Paragraph 5. A statement in the PD, which mischaracterizes the description of conditions for five-year grandfathering with respect to NEM 2.0 customers based on Decision (D.) , should be corrected to indicate that it applied only to SDG&E customers, and that a different effective date for grandfathering applied to SCE and PG&E NEM 2.0 customers. The Commission should develop guidelines for educational materials to be distributed to all prospective renewable generation customers, outlining either (1) the respective IOUs pending proposal, if applicable; or (2) the year of the next regularly scheduled update to TOU periods, to be provided to all customers who submit a form authorizing the release of their interval usage data to renewable generation vendors, in Phase 2 of Rulemaking (R.) II. ALL TOU RATE OPTIONS INCLUDING THE GRANDFATHERED TARIFFS WITH EXISTING TOU PERIODS SHOULD BE COST-BASED In Section 3.1, the PD finds it appropriate for the IOUs to establish a set of base TOU periods and to offer cost-based 7 optional TOU rates with different TOU periods to promote customer acceptance. The PD explicitly states that such optional rates should be cost-based, should reflect the differences in marginal costs by TOU period 8 and that [t]his approach will ensure that different [optional] rates will not send conflicting price signals. 9 7 PD, p PD, p PD, p

7 It is critical that the time-varying rates for all TOU tariff options, including the grandfathered TOU time-period tariffs, align with marginal costs. This is consistent with current practice 10 and will ensure that grandfathered TOU options still reflect the costs to serve the customers on that rate. 11 A tariff with grandfathered TOU time periods does not exempt customers served on that tariff from rate element changes based on rate design principles reiterated in pages of the PD namely, that rates should be based on marginal cost and cost causation principles, and should encourage economically efficient decision-making. 12 The same approach has applied in the Commission s prior decisions regarding grandfathering of TOU tariffs in D and D , which is to retain for five years the TOU time periods for existing optional TOU tariffs, subject to the addition of minimum bills or other changes to the TOU tariff, such as revised rates and TOU tier differentials consistent with marginal costs. 13 Consistent with this concern, SCE proposes the following changes to the PD: 14 The addition of a new Finding of Fact 36: Rate elements for different TOU options, including options with current TOU periods for grandfatheringeligible customers, should reflect up-to-date marginal costs. 10 As described in Attachment A of SCE s April 6, 2016 Response to ALJ s March 16, 2016 Request for Supplemental Information, time-varying charges for optional rates with non-standard TOU periods are developed by aggregating the hourly marginal generation costs determined in the General Rate Case (GRC) Phase 2 proceeding into the specific TOU period definitions. In other words, the hourly marginal generation cost-basis is the same for all rate options. 11 PD, p PD, pp , citing rate design principles 2, 3, and 9, as adopted in R D provides that NEM 2.0 customers may continue to take service for a 20-year period under the NEM successor tariff, which is a rider to the customer s underlying tariff. However, it also states that to avoid any misunderstanding, we reiterate our observation in D that customers do not have entitlement to the continuation of any particular underlying rate design, or particular rates. D , pp D , at page 155, states rates and rate structures change periodically, mostly gradually, through periodic revenue requirement and revenue allocation proceedings, but occasionally abruptly, as the Commission found necessary in D Proposed text deletions are in bold strikethrough (abcd). Proposed text additions are in bold doubleunderline (abcd) 4

8 Appendix 1, Policy Guideline 9: TOU rates should be designed around the Base TOU periods and should reflect up-to-date marginal costs, but may be modified to take into account customer acceptance, preferences, understanding, ability to respond and similar factors. III. THE PD SHOULD BE MODIFIED TO ENCOURAGE ADMINISTRATIVELY EFFICIENT MEANS TO GRANDFATHER SOLAR TOU CUSTOMERS The PD acknowledges that continued grandfathering of TOU tariffs will become more complex as customers transition to the new TOU periods. 15 SCE shares this concern. As SCE noted in its Comments and Reply Comments on the May 3, 2016 Scoping Memo, maintaining multiple rate options with different TOU periods and with different individual customer transition dates is administratively burdensome, costly to implement, and will confuse customers. Given this concern, SCE believes the PD should be modified to encourage the IOUs to pursue, in their respective rate design proceedings, 16 administratively efficient ways to implement the grandfathering requirements outlined in Ordering Paragraph 5 and coordinate those grandfathering requirements with similar requirements adopted in D and D For example, the IOUs may propose (1) to consolidate grandfathered TOU tariffs and offer a single TOU tariff, per rate class, with the current TOU periods; or (2) a single date each year on which to migrate grandfathered customers to the new TOU periods. 17 Thus, SCE proposes the following change to Ordering Paragraph 5: 15 PD at p In the IOUs Pending Rate Design proceedings or any subsequent rate design proceedings. 17 As an example, a customer whose system becomes operational on October 1, 2016 is grandfatheringeligible and is permitted to maintain the current TOU periods until October 1, The IOUs may propose to migrate that customer, along with any other customer whose five-year transition period ended in 2021, on January 1, This would ensure that each eligible customer would receive at least five-years of service on the current TOU periods, but eliminate the need to migrate each customer individually on the exact date in which their five-year transition period ends. 5

9 Each of Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), and San Diego Gas & Electric Company (SDG&E) shall ensurepropose, in their respective rate design proceedings, administratively efficient ways to implement the grandfathering requirements from this and other decisions such that residential, commercial and industrial customers with behind-the-meter solar be permitted to maintain time-of-use rate periods for a minimum of five years. This five-year protection applies only to qualified customers who complete interconnection agreements before implementation of new time-of-use periods through tariffs authorized by the Commission in (A.) (SDG&E), A (PG&E), and A (SCE). The five year period begins on the date the customer s system becomes operational. This protection does not apply to customers already permitted to stay on a TOU rate for five years pursuant to D IV. CORRECTION TO PD S CHARACTERIZATION OF GRANDFATHERING OF TOU PERIODS FOR NEM 2.0 CUSTOMERS SCE notes that Section of the PD contains an error when describing the conditions for the five-year TOU period grandfathering for residential NEM 2.0 customers adopted in D Specifically, the PD notes that D ordered the IOUs to provide residential customers who complete their interconnection applications for the NEM successor tariff within a period of 120 days after the TOU rates become the default rate for residential customers with the opportunity to remain on the TOU rate they have chosen for up to five years. 18 However, footnote 111 of D clarifies that this condition applies only to SDG&E. For SCE and PG&E, D requires that In order to provide greater certainty for residential customers on the NEM successor tariff who complete their interconnection application for the NEM successor tariff prior to the 18 PD, p. 46, emphasis added. 6

10 implementation of default TOU rates for residential customers, a NEM successor tariff residential customer who takes any TOU rate (including a TOU pilot rate) prior to the implementation of default residential TOU rates has the option to stay on that TOU rate for a period of five years from the date the customer commences the TOU rate. 19 Thus, page 46 of the PD should be corrected to accurately reflect the requirements established by D V. PROSPECTIVE RENEWABLE GENERATION CUSTOMERS SHOULD BE PROVIDED WITH INFORMATIONAL MATERIALS ON POTENTIAL CHANGES TO TOU PERIODS SCE agrees with the PD s conclusion that customers who invest in renewable generation after the implementation of the TOU periods in the pending rate design cases 20 should be made aware that a plan is in place to regularly review and update TOU periods. Moreover, SCE believes that customers considering renewable generation prior to the resolution and implementation of the IOUs TOU proposals should be made aware that there are pending proposals before the Commission. SCE recommends that guidelines for such educational materials, outlining either (1) the respective IOUs pending proposal, if applicable; or (2) the year of the next regularly scheduled update to TOU periods, should be provided to all customers who submit a form authorizing the release of their interval usage data to renewable generation vendors, and be developed in the consumer protection phase (Phase 2) of R Such a measure will guarantee that all customers who invest in renewable technologies going forward take this information into account when making their investment decisions, and will mitigate the need for additional protections and subsidies going forward. 19 D p. 93, emphasis added. 20 PD, p

11 Respectfully submitted, FADIA RAFEEDIE KHOURY R. OLIVIA SAMAD /s/ R. Olivia Samad By: R. Olivia Samad Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) November 21,

12 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Assess Peak Electricity Usage Patterns and Consider Appropriate Time Periods for Future Time-of-Use Rates and Energy Resource Contract Payments. R (Filed December 17, 2015) 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) OPENING COMMENTS ON PROPOSED DECISION OF ADMINISTRATIVE LAW JUDGE MCKINNEY on all parties identified on the attached service list(s) for *. 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 hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s). ALJ Jeanne McKinney CPUC 505 Van Ness Avenue San Francisco, CA Executed this 21 st day of November, 2016, 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

13 CPUC - Service Lists - R Page 1 of 9 11/21/2016 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO ASSESS FILER: CPUC LIST NAME: LIST LAST CHANGED: NOVEMBER 7, 2016 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties DONALD KELLY MARC D JOSEPH EXE DIR ADAMS BROADWELL JOSEPH & CARDOZO UTILITY CONSUMERS ACTION NETWORK, CA 00000, CA FOR: COALITION OF CALIFORNIA UTILITY FOR: UCAN EMPLOYEE JOHN W. LESLIE, ESQ. DANIEL W. DOUGLASS PARTNER DENTONS US LLP DOUGLASS & LIDDELL 4766 PARK GRANADA, SUITE 209, CA CALABASAS, CA FOR: SHELL ENERGY NORTH AMERICA (US), FOR: NEST LABS, INC. L.P. OLIVA SAMAD DONALD C. LIDDELLL SENIOR SOUTHERN CALIFORNIA EDISON COMPANY DOUGLAS & LIDDELL 2244 WALNUT GROVE AVENUE / PO BOX ND AVE. ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: CALIFORNIA ENERGY STORAGE ALLIANCE (SCE) OLIVIA SAMAD IS REP JOHN A. PACHECO KATHERINE RAMSEY CLEAN COALITION SAN DIEGO GAS & ELECTRIC COMPANY 16 PALM CT 8330 CENTURY PARK CT., CP32 MENLO PARK, CA 94025

14 CPUC - Service Lists - R Page 2 of 9 11/21/2016 SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: CLEAN COALITION MATTHEW FREEDMAN EVELYN KAHL STAFF COUNSEL THE UTILITY REFORM NETWORK ALCANTAR & KAHL LLP 785 MARKET STREET, 14TH FL 345 CALIFORNIA ST., STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION LARISSA KOEHLER JEANNE B. ARMSTRONG ENVIRONMENTAL DEFENSE FUND GOODIN MACBRIDE SQUERI & DAY LLP 123 MISSION STREET, 28TH FLOOR 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ENVIRONMENTAL DEFENSE FUND FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION SEAN P. BEATTY GAIL L. SLOCUM WEST REGION GEN. COUNSEL AT LAW NRG ENERGY, INC, PACIFIC GAS AND ELECTRIC COMPANY 100 CALIFORNIA STREET, SUITE BEALE STREET, B30A / PO BOX 7442 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: NRG ENERGY, INC. FOR: PACIFIC GAS AND ELECTRIC COMPANY CHRIS S. KING JOSEPH F. WIEDMAN EMETER, A SIEMENS BUSINESS 4000 E. THIRD AVE., 4TH FLOOR KEYES & FOX LLP FOSTER CITY, CA TH STREET, SUITE 1305 FOR: ON BEHALF OF EMETER, A SIEMENS OAKLAND, CA BUSINESS FOR: THE ENERGY FREEDOM COALITION OF AMERICA, LLC (EFCA) MELISSA W. KASNITZ GREGG MORRIS CENTER FOR ACCESSIBLE TECHNOLOGY DIR ADELINE STREET, STE. 220 THE GREEN POWER INSTITUTE BERKELEY, CA SHATTUCK AVE., SUTE. 402 FOR: CENTER FOR ACCESSIBLE TECHNOLOGY BERKELEY, CA FOR: THE GREEN POWER INSTITUTE C. C. SONG JORDAN PINJUV REGULATORY ANALYST GEN. COUNSEL MARIN CLEAN ENERGY CALIFORNIA INDEPENDENT SYSTEM OPERATOR 1125 TAMALPAIS AVE. 250 OUTCROPPING WAY SAN RAFAEL, CA FOLSOM, CA FOR: MARIN CLEAN ENERGY (MCE) FOR: CALIFORNIA ISO MATTHEW SWINDLE BRAD HEAVNER CEO & FOUNDER POLICY DIR. NLINE ENERGY, INC. CALIFORNIA SOLAR ENERGY INDUSTRIES 5170 GOLDEN FOOTHILL PARKWAY TH ST., NO.820 EL DORADO HILLS, CA SACRAMENTO, CA FOR: NLINE ENERGY, INC. FOR: CALIFORNIA SOLAR ENERGY INDUSTRIES ASSOCIATION

15 CPUC - Service Lists - R Page 3 of 9 11/21/2016 ROBERT LIEBERT KAREN N. MILLS ELLISON, SCHNEIDER & HARRIS LLP ASSOCIATE COUNSEL 2600 CAPITOL AVE., STE. 400 CALIFORNIA FARM BUREAU FEDERATION SACRAMENTO, CA RIVER PLAZA DRIVE FOR: CALIFORNIA MANUFACTURERS & SACRAMENTO, CA TECHNOLOGY ASSN. FOR: CALIFORNIA FARM BUREAU FEDERATION Information Only 0 WAHL BARBARA R. BARKOVICH DEP. DIR. - POLICY & ELECTRICITY MARKETS CONSULTANT SOLARCITY CORPORATION BARKOVICH & YAP, INC., CA 00000, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION DAVID MARCUS, CA KA YING CHEU PACIFIC GAS AND ELECTRIC COMPANY, CA KAREN SHEA KATY MORSONY PACIFIC GAS AND ELECTRIC COMPANY ALCANTAR & KAHL, CA 00000, CA MARC D. JOSEPH MERRIAN BORGESON ADAMS BROADWELL JOSEPH & CARDOZO NATURAL RESOURCES DEFENSE COUNCIL, CA 00000, CA NELLIE TONG NORA SHERIFF SENIOR CONSULTANT DNV KEMA ENERGY & SUSTAINABILITY ALCANTAR & KAHL, CA 00000, CA OWEN SANFORD SOLARCITY, CA SEPHRA A. NINOW REGULATORY AFFAIRS MGR. CENTER FOR SUSTAINABLE ENERGY, CA SUSAN GLICK MRW & ASSOCIATES, LLC SENIOR MGR., PUBLIC POLICY SUNRUN, INC., CA 00000, CA KAREN TERRANOVA BRANDON SMITHWOOD

16 CPUC - Service Lists - R Page 4 of 9 11/21/2016 ALCANTAR & KAHL SOLAR ENERGY INDUSTRIES ASSOCIATION TH STREET, NW, SUITE 400, CA WASHINGTON, DC DAVID P. LOWREY KELLY CRANDALL DIRECTOR, REGULATORY STRATEGY EQ RESEARCH, LLC COMVERGE, INC LINCOLN STEET, SUITE TH STREET, SUITE 2300 DENVER, CO DENVER, CO DANIEL RAMIREZ LON W. HOUSE, PH.D ANALYST WATER AND ENERGY CONSULTING ENERGY STRATEGIES, LLC N. ORACLE RD., STE SOUTH STATE STREET, STE 200 ORO VALLEY, AZ SALT LAKE CITY, UT DANIEL DOUGLASS ANDRE RAMIREZ SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVE PARK GRANADA, SUITE 209 ROSEMEAD, CA CALABASAS, CA FOR: ALLIANCE FOR RETAIL ENERGY MARKETS / DIRECT ACCESS CUSTOMER COALITION / WESTERN POWER TRADING FORUM CASE ADMINISTRATION FADIA RAFEEDIE KHOURY SOUTHERN CALIFORNIA EDISON COMPANY DIR & MANAGING 2244 WALNUT GROVE AVE. / PO BOX 800 SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA WALNUT GROVE AVENUE ROSEMEAD, CA FOR: OLIVIA SAMAD IS REP AT SCE OLIVIA SAMAD STEVEN C. NELSON SR. SAN DIEGO GAS & ELECTRIC COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 488 8TH AVE., 9TH FL WALNUT GROVE AVENUE SAN DIEGO, CA ROSEMEAD, CA DAVID CROYLE MARCIE A. MILNER EXECUTIVE DIRECTOR VP - REG AFFAIRS UTILITY CONSUMERS' ACTION NETWORK SHELL ENERGY NORTH AMERICA (US), L.P KENYON STREET, STE EASTGATE MALL, STE. 100 SAN DIEGO, CA SAN DIEGO, CA FOR: UCAN FOR: SHELL ENERGY NORTH AMERICA (US), L.P. CENTRAL FILES CYNTHIA FANG SAN DIEGO GAS AND ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT-CP31E 8330 CENTURY PARK COURT, CP32E SAN DIEGO, CA SAN DIEGO, CA DANA GOLAN WILLIAM FULLER SAN DIEGO GAS & ELECTRIC COMPANY CALIF. REGULATORY AFFAIRS 8330 CENTURY PARK CT., CP421 SAN DIEGO GAS & ELECTRIC COMPANY

17 CPUC - Service Lists - R Page 5 of 9 11/21/2016 SAN DIEGO, CA CENTURY PARK COURT, 32CH SAN DIEGO, CA JASON M. ACKERMAN JEANNETTE OLKO CITY OF MORENO VALLEY BEST BEST & KRIEGER, LLP FREDERICK STREET 3390 UNIVERSITY AVENUE, 5TH FLOOR MORENO VALLEY, CA RIVERSIDE, CA BRIAN KORPICS ANTHONY HARRISON STAFF ATTY & POLICY MGR. MGR. - REGULATORY AFFAIRS THE CLEAN COALITION STEM, INC. 16 PALM CT. 100 ROLLINS RD. MENLO PARK, CA MILLBRAE, CA SUE MARA ERIC BORDEN CONSULTANT ENERGY POLICY ANALYST RTO ADVISORS, LLC THE UTILITY REFORM NETWORK 164 SPRINGDALE WAY 785 MARKET STREET, STE REDWOOD CITY, CA SAN FRANCISCO, CA CASE ADMINISTRATION JAMES FINE, PH.D PACIFIC GAS AND ELECTRIC COMPANY SR. ECONOMIST 77 BEALE STREET ENVIRONMENTAL DEFENSE FUND SAN FRANCISCO, CA MISSION ST., 28TH FL. SAN FRANCISCO, CA SHERIDAN PAUKER ELIAH GILFENBAUM REGULATORY COUNSEL DEPUTY DIR WILSON SONSINI GOODRICH & ROSATI SOLARCITY ONE MARKET PLAZE, SPEAR TOWER, STE DE HARO STREET SAN FRANCISCO, CA SAN FRANCISCO, CA MARC KOLB DAVID J. MILLER SOLARCITY EXE DIR - SR. LEGAL COUNSEL 444 DE HARO STREET, SUITE 100 AT&T SERVICES, INC. SAN FRANCISCO, CA BUSH STREET, ROOM 310 SAN FRANCISCO, CA MICHELLE CHOO THOMAS SELHORST ASSISTANT SENIOR PARALEGAL AT&T SERVICES, INC. AT&T CALIFORNIA, INC. 430 BUSH STREET, NO BUSH STREET, 3RD FLOOR, NO. 14 SAN FRANCISCO, CA SAN FRANCISCO, CA ANNA MURVEIT BRIAN CRAGG CALIFORNIA EMVIRONMENTAL ASSOCIATES 423 WASHINGTON ST. 4TH FL. GOODIN, MACBRIDE, SQUERI & DAY, LLP SAN FRANCISCO, CA SANSOME ST., STE. 900 SAN FRANCISCO, CA BRIAN THEAKER DIR - REGULATORY AFFAIRS DIANE FELLMAN VP - REGULATORY & GOVERNMENT AFFAIRS

18 CPUC - Service Lists - R Page 6 of 9 11/21/2016 NRG ENERGY, INC. NRG WEST REGION 100 CALIFORNIA, STE CALIFORNIA ST., STE. 650 SAN FRANCISCO, CA SAN FRANCISCO, CA MEGHA LAKHCHAURA CALIFORNIA ENERGY MARKETS DIR. PUBLIC POLICY 425 DIVISADERO ST. SUITE 303 SUNRUN INC SAN FRANCISCO, CA MARKET STREET SAN FRANCISOC, CA CHARLES R. MIDDLEKAUFF MEGAN M. MYERS PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, B30A, PO BOX 7442 LAW OFFICES OF SARA STECK MYERS SAN FRANCISCO, CA TH AVENUE SAN FRANCISCO, CA ANDREW YIP RICK COUNIHAN MGR - BUS. DEVELOPMENT (RBNA/PJ-BGT) NEST LABS, INC. ROBERT BOSCH LLC 3400 HILLVIEW AVENUE 4009 MIRANDA AVENUE, STE. 200 PALO ALTO, CA PALO ALTO, CA BONNIE DATTA MICHAEL ROCHMAN SIEMENS USA MANAGING DIR E. THIRD AVENUE SCHOOL PROJECT UTILITY RATE REDUCTION FOSTER CITY, CA GATEWAY BLVD., STE. 235 CONCORD, CA FOR: SPURR MATTHEW BARMACK KATHY TRELEVEN DIR. - MARKET & REGULATORY ANALYSIS KATHY TRELEVEN CONSULTING CALPINE CORPORATION 103 BANDOL CT DUBLIN BLVD., SUITE 100 SAN RAMON, CA DUBLIN, CA DAVE BEYER YAP CATHERINE SR. CIVIL ENGINEER AT LAW EAST BAY MUNICIPAL UTILITY DISTRICT BARKOVICH & YAP, INC. 375 ELEVENTH STREET PO BOX OAKLAND, CA OAKLAND, CA ALISON SEEL NANCY RADER ASSOCIATE EXECUTIVE DIR. SIERRA CLUB CALIFORNIA WIND ENERGY ASSOCIATION 2101 WEBSTER ST., STE SHATTUCK AVE., NO. 17 OAKLAND, CA BERKELEY, CA TOM BEACH CARLOS LAMAS-BABBINI PRINCIPAL SR. PROGRAM EXE. CROSSBORDER ENERGY IPKEYS POWER PARTNERS, LLC 2560 NINTH STREET, SUITE 213A 58 MOUNT TALLAC COURT BERKELEY, CA SAN RAFAEL, CA 94903

19 CPUC - Service Lists - R Page 7 of 9 11/21/2016 PHILLIP MULLER JOHN NIMMONS PRESIDENT COUNSEL SCD ENERGY SOLUTIONS JOHN NIMMONS & ASSOCIATES, INC. 436 NOVA ALBION WAY 175 ELINOR AVE., STE. G SAN RAFAEL, CA MILL VALLEY, CA C.SUSIE BERLIN DELPHINE HOU LAW OFFICES OF SUSIE BERLIN CALIF. INDEPENDENT SYSTEMS OPERATOR 1346 THE ALAMEDA, SUITE 7 NO OUTCROPPING WAY SAN JOSE, CA FOLSOM, CA JOHN GOODIN CAROLYN KEHREIN CALIFORNIA ISO ENERGY MANAGEMENT SERVICES 250 OUTCROPPING WAY ENERGY USERS FORUM FOLSOM, CA CELEBRATION WAY WOODLAND, CA DOUGLAS DAVIE CAMILLE STOUGH, ESQ. VICE PRESIDENT BRAUN BLAISING MCLAUGHLIN & SMITH PC WELLHEAD ELECTRIC COMPANY, INC. 915 L STREET, STE BERCUT DRIVE, STE. C SACRAMENTO, CA SACRAMENTO, CA DAN GRIFFITHS JOSHUA NELSON ASSOCIATE BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. BEST BEST & KRIEGER LLP 915 L STREET, SUITE CAPITOL MALL, STE SACRAMENTO, CA SACRAMENTO, CA JUSTIN WYNNE KEVIN WOODRUFF WOODRUFF EXPERT SERVICES BRAUN BLAISING MCLAUGHLIN & SMITH, P.C TH STREET, SUITE L STREET, SUITE 1480 SACRAMENTO, CA SACRAMENTO, CA FOR: TURN MATTHEW KLOPFENSTEIN REBECCA FRANKLIN REGULATORY ADVOCATE GONZALEZ, QUINTANA & HUNTER, LLC ASSOCIATION OF CALIF. WATER AGENCIES 915 L STREET, STE K STREET, STE. 100 SACRAMENTO, CA SACRAMENTO, CA FOR: NLINE INC. RICK WALTMAN SCOTT BLAISING AT LAW COUNSEL BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. BRAUN BLAISING MCLAUGHLIN & SMITH P.C. 915 L STREET, SUITE L STREET, SUITE 1480 SACRAMENTO, CA SACRAMENTO, CA STEVEN KELLY ANDREW B. BROWN POLICY DIRECTOR AT LAW INDEPENDENT ENERGY PRODUCERS ASSCIATION ELLISON SCHNEIDER & HARRIS LLP 1215 K STREET, STE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA

20 CPUC - Service Lists - R Page 8 of 9 11/21/2016 LYNN HAUG MIKE CADE AT LAW INDUSTRY SPECIALIST ELLISON, SCHNEIDER & HARRIS, LLP ALCANTAR & KAHL 2600 CAPITOL AVENUE, SUITE SW SALMON STREET, SUITE 1100 SACRAMENTO, CA PORTLAND, OR State Service SCOTT MURTISHAW AARON LU ENERGY ADVISOR CPUC - EXEC DIV ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA 4-A, CA VAN NESS AVENUE SAN FRANCISCO, CA BENJAMIN GUTIERREZ ERIC DURAN ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOREST KASER GREGORY HEIDEN PROCUREMENT STRATEGY AND OVERSIGHT BRANC LEGAL DIVISION AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JEANNE MCKINNEY LEE-WHEI TAN DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5113 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MATTHEW A. KARLE NATHAN BARCIC ELECTRICITY PRICING AND CUSTOMER PROGRAM INFRASTRUCTURE PLANNING AND PERMITTING B ROOM 4108 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA NATHAN CHAU PAUL DOUGLAS ELECTRICITY PRICING AND CUSTOMER PROGRAM INFRASTRUCTURE PLANNING AND PERMITTING B AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA RAJAN MUTIALU ROBERT LEVIN

21 CPUC - Service Lists - R Page 9 of 9 11/21/2016 DEMAND RESPONSE, CUSTOMER GENERATION, AN ENERGY DIVISION AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA SEAN A. SIMON TRACI BONE COMMISSIONER RANDOLPH LEGAL DIVISION AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA WHITNEY RICHARDSON LYNN MARSHALL CONSULTANT DEMAND RESPONSE, CUSTOMER GENERATION, AN CALIFORNIA ENERGY COMMISSION AREA 4-A TH STREET, MS VAN NESS AVENUE SACRAMENTO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS