BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) ) )

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Gas Company (U 904 G) for Authority to: (i) Adjust its Authorized Return on Common Equity, (ii) Adjust its Authorized Embedded Costs of Debt and Preferred Stock, (iii) Decrease its Overall Rate of Return, and (iv) Revise its Gas Rates Accordingly, and for Related Substantive and Procedural Relief. ) ) ) ) ) ) ) ) ) Application COST OF CAPITAL APPLICATION OF SOUTHERN CALIFORNIA GAS COMPANY (U 904 G) KIM F. HASSAN JOHNNY J. PONG Attorneys for SOUTHERN CALIFORNIA GAS COMPANY 555 West Fifth Street, GT14E7 Los Angeles, California Telephone: (213) Facsimile: (213) khassan@semprautilities.com April 20, 2012

2 TABLE OF CONTENTS I. PROCEDURAL BACKGROUND... 1 II. SUMMARY OF AUTHORIZATIONS REQUESTED... 3 A. ROE of 10.90%... 5 B. Capital Structure and Embedded Costs... 7 C. Cost of Capital Adjustment Mechanism... 7 III. STATUTORY AND PROCEDURAL REQUIREMENTS... 8 A. Compliance with Rule B. Statutory Authority - Rule C. Legal Name and Correspondence D. Articles of Incorporation - Rule E. Financial Statement, Balance Sheet, and Income Statement - Rule 3.2(a)(1) F. Present and Proposed Rates -Rules 3.2(a)(2) and (3) G. Description of Property and Equipment - Rule 3.2(a)(4) H. Summary of Earnings - Rules 3.2(a)(5) and (6) I. Index to Appendices and Exhibits to this Application J. Depreciation - Rule 3.2(a)(7) K. Proxy Statement - Rule 3.2 (a)(8) L. Service of Notice - Rule IV. CONCLUSION Appendices to Application: Appendix A - Statement of Present and Proposed Rates Appendix B - Financial Statement, Balance Sheet, and Income Statement Appendix C - Statement of Original Cost and Depreciation Reserve Appendix D - Summary of Earnings Appendix E - Service List of City, County, and State Officials i

3 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Gas Company (U 904 G) for Authority to: (i) Adjust its Authorized Return on Common Equity, (ii) Adjust its Authorized Embedded Costs of Debt and Preferred Stock, (iii) Decrease its Overall Rate of Return, and (iv) Revise its Gas Rates Accordingly, and for Related Substantive and Procedural Relief. ) ) ) ) ) ) ) ) ) Application COST OF CAPITAL APPLICATION OF SOUTHERN CALIFORNIA GAS COMPANY (U 904 G) In accordance with Rule 2.1 of the California Public Utilities Commission s ( Commission ) Rules of Practice and Procedure, Southern California Gas Company ( SoCalGas or Company ) hereby submits its test year 2013 cost of capital application ( Application ). I. PROCEDURAL BACKGROUND SoCalGas last filed a cost of capital application on May 8, In its decision adopting SoCalGas test year 1997 cost of capital, 2 the Commission set a return on equity ( ROE ) of 11.60% for all California investor-owned utilities ( IOUs ). 3 By that decision, the Commission also approved SoCalGas request for a 270 basis point increase in debt, a 330 basis 1 Application ( A. ) D adopted the capital structures, costs of debt and preferred stock, and the ROEs proposed in an all party settlement. The all party settlement was supported by SoCalGas, San Diego Gas & Electric Company ( SDG&E ), Pacific Gas and Electric Company ( PG&E ), and Southern California Edison Company ( SCE ), the Division of Ratepayer Advocates, Federal Executive Agencies, City of Los Angeles, the Cities of Burbank, Glendale, and Pasadena, and Consumers for the Public Interest. 3 The California IOUs consist of SoCalGas, SDG&E, PG&E, and SCE. 1

4 point decrease in preferred stock and a 60 basis point increase in equity, and set SoCalGas cost of capital for test year 1997 as follows: SoCalGas Cost of Capital for Test Year 1997 Component Capital Ratio Cost Weighted Cost Long-Term Debt 45.60% 7.71% 3.52% Preferred Stock 6.40% 6.35% 0.40% Common Equity 48.00% 11.60% 5.57% ROR 9.49% Since 1997, SoCalGas has operated under a cost of capital automatic adjustment mechanism called the Market-Indexed Capital Adjustment Mechanism ( MICAM ), which was adopted by the Commission in the Performance Based Ratemaking ( PBR ) proceeding in D The MICAM utilizes two factors based on movements in the 30-year United States Treasury bond yield that must both be triggered to enact a change in SoCalGas cost of capital. 5 The Company filed a petition for modification of the PBR decision to suspend its MICAM in 2002 (when the MICAM first triggered) and 2009 (when SoCalGas anticipated a second triggering event) and reevaluate the appropriateness of the Treasury bond as a benchmark. The Commission denied both petitions, but neither decision precluded SoCalGas from addressing its MICAM in the future. 6 Most recently, SoCalGas expressed its intent to re-address its MICAM in the next state-wide utility COC proceeding in its 2012 Test Year General Rate Case 4 The PBR plan did not provide for changes to SoCalGas cost of capital. However, it did provide for an adjustment in the event of a dramatic change in the Company s cost of capital through the MICAM. 5 The direct testimony of Herbert Emmrich describes in detail the mechanics of the MICAM triggering event. 6 See D and D

5 ( GRC ), 7 believing it is more appropriate to have its COC proposal addressed along with the other IOUs in a state-wide proceeding instead of on a stand-alone basis. The MICAM has triggered twice since its inception. The first trigger occurred in October As a result of that trigger, SoCalGas filed Advice Letter 3199 on October 29, to update its cost of capital, and reduced its ROE to 10.82% from 11.60%, and reduce its rate of return to 8.68% from 9.49% beginning January 1, Due to the subsequent slow economic recovery since 2008, SoCalGas MICAM triggered again in January The Application is being filed change the MICAM, and consequently a new authorized cost of capital for test year This would supersede the cost of capital that would result from the most recent MICAM triggering event, which would otherwise become effective January 1, II. SUMMARY OF AUTHORIZATIONS REQUESTED SoCalGas respectfully requests that the Commission adopt a test year 2013 cost of capital as summarized in the table below: SoCalGas Recommended Cost of Capital for Test Year 2013 Component Capital Ratio Cost Weighted Cost Long-Term Debt 45.60% 5.72% 2.61% Preferred Stock 2.40% 6.00% 0.14% Common Equity 52.00% 10.90% 5.67% ROR 8.42% 7 See Direct testimony of Herbert Emmrich in A The Company filed a supplemental Advice Letter (Advice Letter 3199-A), which replaced Advice No. 3199, in order to properly account for a gain on an interest rate swap realized in October

6 If adopted, this COC structure will decrease the Company s ROR by 0.26%, which will result in a $1.43 million revenue requirement decrease for ratepayers. 9 The seminal United States Supreme Court cases Bluefield and Hope 10 define the guiding legal principles for establishing the cost of capital for regulated public utilities. The Bluefield case established the standard for measuring just and reasonable rates: A public utility is entitled to such rates as will permit it to earn a return upon the value of the property which it employs for the convenience of the public equal to that generally being made at the same time and in the same general part of the country on investments in other business undertakings which are attended by corresponding risks and uncertainties. The return should be reasonably sufficient to assure confidence in the financial soundness of the utility, and should be adequate, under efficient and economical management, to maintain and support its credit, and enable it to raise the money necessary for the proper discharge of its public duties. 11 The Hope case expanded the guidelines for establishing a utility s cost of capital, and reiterates the financial soundness and capital attraction principles of the Bluefield case: From the investor or company point of view it is important that there be enough revenue not only for operating expenses but also for the capital costs of the business. These include service on the debt and dividends on the stock. By that standard the return to the equity owner should be commensurate with returns on investments in other enterprises having corresponding risks. That return, moreover, should be sufficient to assure confidence in the financial integrity of the enterprise, so as to maintain its credit and attract capital. 12 Based on the language in the Bluefield and Hope cases, it is clear that the Supreme Court recognizes that the allowed rate of return should be: (1) comparable to returns investors expect to earn on other investments of similar risk made at the same time in the same general part of the country; (2) sufficient to assure confidence in the company s financial integrity; and (3) adequate to maintain and support the company s credit and attract capital. 9 Appendix A contains the statement of present and proposed rates. 10 Bluefield Water Works Co. v. Public Serv. Comm n, 262 US 679 (1923); Federal Power Comm n v. Hope Natural Gas Co., 320 U.S. 591 (1944). 11 Bluefield, 262 U.S. 679, Hope, 320 U.S. at

7 A. ROE of 10.90% SoCalGas has carefully evaluated numerous factors to determine an ROE that will allow it to fulfill its utility obligations to provide safe and reliable service at reasonable rates, while providing the Company a reasonable opportunity to earn a competitive and reasonable return on its investments. The recommended ROE of 10.90% is based on an independently-derived minimum ROE recommendation of 10.50% from witness, Dr. Roger Morin, and an additional 40 basis point adjustment to account for the additional and prospective risks and policy considerations supported by the testimonies of witnesses, Cheryl Shepherd and Robert Schlax. 1. ROE Analysis Using the Financial Models The testimony of SoCalGas witness Dr. Morin provides a technical analysis of the various financial models used to establish a basis upon which to determine an ROE that strives to meet the tenets set forth in the Hope and Bluefield cases. In that regard, Dr. Morin explains and lists two appropriate proxy groups of regulated utilities for comparison and utilizes a variety of financial models in recognition that quantitative ROE analyses are generally more informative when a greater number of data points are considered. Dr. Morin identifies and uses the Discounted Cash Flow ( DCF ), the Risk Premium ( RPM ), and the Capital Asset Pricing Model ( CAPM ) methodologies to establish a proposed 10.50% ROE, 13 which is comprised of a 10.10% level from his quantitative analyses plus a 40 basis point adjustment based on four risk indicators. Dr. Morin s recommended 10.50% ROE is the basis upon which the Company applies its own ROE adjustment as sponsored by Mr. Schlax, to reflect additional prospective business and regulatory risk pressures associated with the Company s anticipated level of capital spending 5

8 (described in Ms. Shepherd s testimony), as well as other policy issues that merit additional consideration (described in Mr. Schlax s testimony). 2. SoCalGas Risk Analysis In testimony, SoCalGas witness Cheryl Shepherd discusses the Company-specific business and regulatory risks confronting SoCalGas that support the proposed ROE and overall COC. As addressed in testimony, Ms. Shepherd describes that SoCalGas business risks arise from: 1) the current economic environment; 2) capital investments; 3) competition; 4) the California business environment; and 5) changes in the natural gas industry. Ms. Shepherd describes that SoCalGas regulatory risks can be addressed by: 1) an adequate ROE; 2) cost recovery; 3) regulatory certainty and predictability; and 4) alleviation of regulatory lag. In addition, Ms. Shepherd evaluates the relative risk profile of SoCalGas vis-à-vis the other California IOUs, and also some of the specific Company business and regulatory risks in comparison to the proxy group of natural gas utilities. 3. SoCalGas Policy Considerations The testimony of Mr. Schlax supports the Company s ROE proposal of 10.90%, and describes the justification for the additional 40 basis point adjustment to account for SoCalGas additional and prospective risk and policy considerations. Mr. Schlax explains that the requested ROE will incentivize investors to fund, at reasonable rates, the significant increases in Company infrastructure investments that are required to accommodate customer growth, enhanced pipeline safety standards and the Advanced Metering Infrastructure ( AMI ) program. Mr. Schlax further explains that because SoCalGas is entering a period of large capital investment and industry transition, it will require more frequent access to the capital markets. Accordingly, to 13 Dr. Morin s ROE recommendation is also predicated on the assumption that the Commission will approve 6

9 enable continued access to the debt capital markets given the Company s new financing requirements, while keeping rates reasonable for ratepayers over the long term, the SoCalGas recommends adoption of its proposed ROE of 10.90%. B. Capital Structure and Embedded Costs As set forth in the testimony of witness Michael Foster, SoCalGas proposes a capital structure consisting of 45.60% long-term debt, 2.40% preferred stock, and 52.00% common equity. Mr. Foster explains that SoCalGas proposal to maintain its current long-term debt weighting, reduce preferred stock weighting, and increase common equity weighting will maintain the Company s strong single A credit rating. This continued rating will enable SoCalGas to secure long-term debt at reasonable rates to fund the Company s significant capital program. In addition, Mr. Foster describes SoCalGas current embedded costs of long-term debt and preferred stock and explains the basis for adjustments to the forecasts. For test year 2013, Mr. Foster calculates SoCalGas forecasted cost of debt decreases from 6.96% to 5.72%, and SoCalGas forecasted cost of preferred stock increases from 4.83% to 6.00%. C. Cost of Capital Adjustment Mechanism The testimony of Mr. Emmrich sponsors the Cost of Capital Mechanism ( CCM ) proposal, and addresses why the current MICAM should not be continued in His testimony documents the administrative history of the MICAM, discusses the mechanism s objectives and mechanics, and describes SoCalGas experience with the current MICAM. SoCalGas believes that adoption of a CCM will bring SoCalGas more in line with the other California IOUs, which operate under a CCM benchmarked against utility bonds. SoCalGas recommended capital structure. 7

10 As noted earlier, SoCalGas MICAM triggered in January 2012, thereby requiring SoCalGas to file an Advice Letter in October 2012 to update its cost of capital. Because SoCalGas is filing this Application for test year 2013, the Company requests that the Commission decision in this proceeding supersede the implementation of the MICAM triggering event, which would become effective January 1, Concurrently with this Application, SoCalGas is filing a motion for stay of the October Advice Letter filing. III. STATUTORY AND PROCEDURAL REQUIREMENTS A. Compliance with Rule 2.1 In accordance with Rule 2.1 of the Commission s Rules of Practice and Procedure, SoCalGas provides the following information concerning the proposed category for the proceeding, the need for hearing, the issues to be considered, and a proposed schedule. 1. Proposed Category of Proceeding SoCalGas proposes to categorize this Application as rate-setting inasmuch as SoCalGas proposes to establish new gas rates based on proposed changes to its rate of return reflecting adjustments to its capital costs. 2. Need for Hearing SoCalGas believes a hearing will be necessary in this proceeding because it is likely there will be questions of fact pertaining to its request to make changes to its rate of return and underlying capital costs. Accordingly, SoCalGas proposes the following procedural schedule: As an initial step to facilitate the establishment of a procedural schedule, SoCalGas has conferred with the other California IOUs regarding the proposal of common dates for selected milestones. The requested dates take into account SoCalGas hearing schedule conflicts for the periods July 31 August 17 and September 17 October 3. 8

11 Event Date Application Filed April 20, 2012 Protests/Responses Due Applicant Reply to Protests/Responses Prehearing Conference DRA/Intervenor Testimony May 23, 2012 May 25, 2012 May 30, 2012 July 13, 2012 Rebuttal Testimony August 17, 2012 Hearings August 27-31, 2012 Late-Filed Exhibits September 12, 2012 Concurrent Opening Briefs September 19, 2012 Reply Briefs September 28, 2012 ALJ Proposed Decision ( PD ) October 26, 2012 Opening Comments on PD November 15, 2012 Reply Comments November 20, 2012 Final Decision Issued November 29, Issues to Be Considered SoCalGas proposes that the Commission need only consider the following issues: a. Should the Commission modify SoCalGas currently authorized revenues for 2013, effective January 1, 2013; and, are the revenue and ROR decreases, proposed by SoCalGas fair and reasonable; b. Should the Commission authorize for SoCalGas, effective January 1, 2013, a ROE of 10.90%; 9

12 c. Should the Commission authorize, effective January 1, 2013, SoCalGas embedded cost of long-term debt of 5.72% and embedded cost of preferred stock of 6.00%; d. Should the Commission authorize, effective January 1, 2013, SoCalGas recommended capital structure of 45.60% long-term debt, 2.40% preferred stock, and 52.00% common equity; e. Should the Commission authorize for SoCalGas, effective January 1, 2013, an overall natural gas business ROR of 8.42%; f. Should the Commission authorize for SoCalGas, effective on or shortly after January 1, 2013, a revenue requirement decrease of $1.43 million, as further specified in this Application; and g. Should the Commission authorize SoCalGas proposal to replace the MICAM with its proposed CCM and permit the CCM to continue until the next scheduled COC proceeding proposed for test year B. Statutory Authority - Rule 2.1 This Application is made pursuant to Sections 451, 454, 455.5, 491, 701, 728, and 729 of the Public Utilities Code of the State of California, the Commission s Rules of Practice and Procedure, and prior decisions, orders and resolutions of the Commission, including those specifically addressed herein. C. Legal Name and Correspondence SOUTHERN CALIFORNIA GAS COMPANY is a public utility organized and existing under the laws of the State of California. SoCalGas is subject to the jurisdiction of this Commission and is engaged in the business of providing public utility gas service in southern 10

13 and central California. The location of SoCalGas principal place of business is Los Angeles, California and its address is 555 West Fifth Street, Los Angeles, California, SoCalGas attorneys in this matter are Kim F. Hassan and Johnny J. Pong. Correspondence or communications regarding this Application should be addressed to: Ronald van der Leeden Director of General Rate Case & Revenue Requirements SOUTHERN CALIFORNIA GAS COMPANY 555 West Fifth Street, GT15C2 Los Angeles, CA Phone: (213) Fax: (213) with copies to: Kim F. Hassan and Johnny J. Pong Attorneys for: SOUTHERN CALIFORNIA GAS COMPANY 555 West Fifth Street, GT14E7 Los Angeles, CA Telephone: (213) Facsimile: (213) D. Articles of Incorporation - Rule 2.2 A copy of SoCalGas current Articles of Incorporation, as amended and restated, certified by the California Secretary of State, was previously filed with the Commission in connection with A , and is incorporated herein by reference. E. Financial Statement, Balance Sheet, and Income Statement - Rule 3.2(a)(1) SoCalGas' Financial Statement and Balance Sheet and Income Statement are attached to this Application as Appendix B. 11

14 F. Present and Proposed Rates -Rules 3.2(a)(2) and (3) A statement of SoCalGas presently effective and proposed rates forth in Appendix A. SoCalGas' current rates and charges are contained in its tariffs and schedules on file with the Commission. These tariffs and schedules are filed with, and made effective by, the Commission in its decision, orders, resolutions, and approvals of advice letter filings made pursuant to Commission General Order 96-A. G. Description of Property and Equipment - Rule 3.2(a)(4) A general description of SoCalGas property was filed with the Commission on October 5, 2001, in connection with A , and is incorporated herein by reference. A statement of account of the original cost and depreciation reserve attributable thereto is attached to this Application as Appendix C. H. Summary of Earnings - Rules 3.2(a)(5) and (6) SoCalGas summary of earnings is included herein as Appendix D. I. Index to Appendices and Exhibits to this Application SoCalGas' submission in support of this Application includes the following, which are incorporated herein by reference. Appendices to Application: Appendix A - Statement of Present and Proposed Rates Appendix B - Financial Statement, Balance Sheet, and Income Statement Appendix C - Statement of Original Cost and Depreciation Reserve Appendix D - Summary of Earnings Appendix E - List of Governmental Agencies 12

15 J. Depreciation - Rule 3.2(a)(7) For financial statement purposes, depreciation of utility plant has been computed on a straight-line, remaining life basis, at rates based on the estimated useful lives of plant properties. For federal income tax accrual purposes, SoCalGas generally computes depreciation using the straight-line method for tax property additions prior to 1954, and liberalized depreciation, which includes Class Life and Asset Depreciation Range Systems, on tax property additions after 1954 and prior to For financial reporting and rate-fixing purposes, "flow through accounting" has been adopted for such properties. For tax property additions in years 1981 through 1986, SoCalGas has computed its tax depreciation using the Accelerated Cost Recovery System. For years after 1986, SoCalGas has computed its tax depreciation using the Modified Accelerated Cost Recovery Systems and, since 1982, has normalized the effects of the depreciation differences in accordance with the Economic Recovery Tax Act of 1981 and the Tax Reform Act of K. Proxy Statement - Rule 3.2 (a)(8) A copy of SoCalGas most recent proxy statement, dated May 2, 2011, was provided to the Commission on May 4, 2011, and is incorporated herein by reference. L. Service of Notice - Rule 3.2 A list of the cities and counties affected by the rate changes resulting from this Application is attached as Appendix E. The State of California is also a customer of SoCalGas whose rates would be affected by the proposed revisions. Also, a notice describing in general terms the proposed revenue decreases and rate changes will be mailed to the governmental agencies identified in Appendix E. The notice will state that a copy of this Application and related attachments will be furnished by SoCalGas upon written request. 13

16 Within twenty days following the filing of this Application, SoCalGas will publish at least once in a newspaper of general circulation in each county in which the changes proposed here will become effective, a notice, in general terms, of the changes proposed in this Application. This notice will state that a copy of this Application and related attachments may be examined at the Commission s offices and such offices of SoCalGas as are specified in the notice. A similar notice will be included in the regular bills mailed to all customers within 45 days of the filing date of this Application. SoCalGas will serve a Notice of Availability of this Application and related exhibits on parties of record in A , (SDG&E s last cost of capital proceeding) and A (SoCalGas GRC) and will post copies of such documents on its website. The service list identifying these potentially interested parties is contained in the Certificate of Service to this Application. IV. CONCLUSION WHEREFORE, SoCalGas respectfully requests that the Commission: 1. Find that SoCalGas currently authorized revenues for its Commissionjurisdictional gas business should be modified for 2013, effective January 1, 2013, and that the revenue and ROR decreases proposed herein for its gas and electric businesses are fair and reasonable; 2. Authorize for SoCalGas, effective January 1, 2013, an ROE of 10.90%; 3. Authorize for SoCalGas, effective January 1, 2013, an embedded cost of longterm debt of 5.72% and an embedded cost of preferred stock of 6.00%; 4. Authorize for SoCalGas, effective January 1, 2013, a capital structure of 45.60% long-term debt, 2.40% preferred stock, and 52.00% common equity; 14

17 5. Authorize for SoCalGas, effective January 1, 2013, an overall natural gas business ROR of 8.42%; 6. Authorize for SoCalGas, effective January 1, 2013, a total base natural gas rate revenue decrease of $1.43 million, as further specified herein; 7. Authorize the decrease in SoCalGas natural gas rates proposed in this Application to become effective for service rendered by SoCalGas on January 1, 2013 (which may be aggregated with other pending rate changes); 8. Adopt SoCalGas proposed CCM, effective January 1, 2013; and 9. Grant SoCalGas such other and further relief as the Commission finds just and reasonable. // // // 15

18 Dated this 20th day of April 2012, in Los Angeles, California. Respectfully submitted, /s/ Kim F. Hassan Kim F. Hassan Johnny J. Pong Attorneys for: SOUTHERN CALIFORNIA GAS COMPANY 555 West Fifth Street, GT14E7 Los Angeles, CA Telephone: (213) Facsimile: (213) /s/ Lee Schavrien Lee Schavrien SOUTHERN CALIFORNIA GAS COMPANY Senior Vice President - Finance, Regulatory and Legislative Affairs 16

19 VERIFICATION The undersigned states as follows: I am an officer of SOUTHERN CALIFORNIA GAS COMPANY and am authorized to make this verification for and on behalf of said corporation. The content of this document is true, except as to matters that are stated on information and belief. As to those matters, I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 20th day of April 2012, at Los Angeles, California. /s/ Lee Schavrien Lee Schavrien SOUTHERN CALIFORNIA GAS COMPANY Senior Vice President - Finance, Regulatory and Legislative Affairs

20 APPENDIX A Statement of Present and Proposed Rates

21 Natural Gas Transportation Rate Revenues (1) Southern California Gas Company January 2013 Rates SCG RD Model Cost of Capital Proceeding Present Rates Proposed Rates Changes Jan-1-12 Proposed Jan-1-12 Jan-1-13 Proposed Jan-1-13 Revenue Rate % Rate Volumes Rate Revenues Volumes Rate Revenues Change Change change Mth $/therm $000's Mth $/therm $000's $000's $/therm % D E F D E F G H I 1 CORE 2 Residential 2,483,989 $ $1,351,948 2,483,989 $ $1,350,950 ($998) ($ ) -0.1% 3 Commercial & Industrial 970,519 $ $290, ,519 $ $289,997 ($237) ($ ) -0.1% 4 5 NGV - Pre SempraWide 117,231 $ $8, ,231 $ $8,654 ($8) ($ ) -0.1% 6 SempraWide Adjustment 117,231 ($ ) ($590) 117,231 ($ ) ($590) ($1) ($ ) 0.1% 7 NGV - Post SempraWide 117,231 $ $8, ,231 $ $8,064 ($9) ($ ) -0.1% 8 9 Gas A/C 1,210 $ $81 1,210 $ $81 ($0) ($ ) -0.1% 10 Gas Engine 18,080 $ $1,600 18,080 $ $1,598 ($1) ($ ) -0.1% 11 Total Core 3,591,030 $ $1,651,935 3,591,030 $ $1,650,690 ($1,246) ($ ) -0.1% NONCORE COMMERCIAL & INDUSTRIAL 14 Distribution Level Service 982,465 $ $66, ,465 $ $66,841 ($61) ($ ) -0.1% 15 Transmission Level Service (2) 457,697 $ $8, ,697 $ $8,149 ($12) ($ ) -0.1% 16 Total Noncore C&I 1,440,163 $ $75,063 1,440,163 $ $74,990 ($73) ($ ) -0.1% NONCORE ELECTRIC GENERATION 19 Distribution Level Service 20 Pre Sempra Wide 353,995 $ $10, ,995 $ $10,539 ($12) ($ ) -0.1% 21 Sempra Wide Adjustment 353,995 ($ ) ($90) 353,995 ($ ) ($91) ($1) ($ ) 1.7% 22 Distribution Level Post Sempra Wide 353,995 $ $10, ,995 $ $10,447 ($14) ($ ) -0.1% 23 Transmission Level Service (2) 2,472,969 $ $42,507 2,472,969 $ $42,441 ($66) ($ ) -0.2% 24 Total Electric Generation 2,826,964 $ $52,968 2,826,964 $ $52,888 ($80) ($ ) -0.2% TOTAL RETAIL NONCORE 4,267,127 $ $128,031 4,267,127 $ $127,878 ($153) ($ ) -0.1% WHOLESALE & INTERNATIONAL 29 Wholesale Long Beach (2) 117,093 $ $2, ,093 $ $2,010 ($3) ($ ) -0.2% 30 SDGE Wholesale 1,230,285 $ $12,636 1,230,285 $ $12,629 ($6) ($ ) 0.0% 31 Wholesale SWG (2) 81,737 $ $1,405 81,737 $ $1,403 ($2) ($ ) -0.2% 32 Wholesale Vernon (2) 116,135 $ $1, ,135 $ $1,993 ($3) ($ ) -0.2% 33 International (2) 53,990 $ $928 53,990 $ $927 ($1) ($ ) -0.2% 34 Total Wholesale & International & SDGE 1,599,240 $ $18,977 1,599,240 $ $18,961 ($16) ($ ) -0.1% TOTAL NONCORE 5,866,366 $ $147,008 5,866,366 $ $146,840 ($169) ($ ) -0.1% Unbundled Storage $27,530 $27,511 ($20) Total (excluding BTS) 9,457,396 $ $1,826,474 9,457,396 $ $1,825,040 ($1,434) ($ ) -0.1% BTS Amount (3) 3,100 $ $124,939 3,100 $ $124,939 $0 $ % 43 SYSTEM TOTALw/SI,FAR,TLS,SW 9,457,396 $ $1,951,413 9,457,396 $ $1,949,979 ($1,434) ($ ) -0.07% EOR Revenues 156,187 $ $3, ,187 $ $3,679 ($5) ($ ) -0.1% 46 Total Throughput w/eor Mth/yr 9,613,583 9,613,583 1) These rates are for Natural Gas Transportation Service from "Citygate to Meter". The BTS rate is for service from Receipt Point to Citygate. 2) These Transmission Level Service "TLS" amounts represent the average transmission rate. 3) BTS charge is a separate rate. Core will pay through procurement rate, noncore as a separate charge.

22 APPENDIX B Financial Statement, Balance Sheet, and Income Statement

23 SOUTHERN CALIFORNIA GAS COMPANY FINANCIAL STATEMENT SEPTEMBER 30, 2011 (a) Amounts and Kinds of Stock Authorized: Preferred Stock 160,000 shares Par Value $4,000,000 Preferred Stock 840,000 shares Par Value $21,000,000 Preferred Stock 5,000,000 shares Without Par Value Preference Stock 5,000,000 shares Without Par Value Common Stock 100,000,000 shares Without Par Value Amounts and Kinds of Stock Outstanding: PREFERRED STOCK 6.0% 79,011 shares $1,975, % 783,032 shares 19,575,800 COMMON STOCK 91,300,000 shares 834,888,907 (b) (c) (d) Terms of Preferred Stock: Full information as to this item is given in connection with Application No , to which references are hereby made. Brief Description of Mortgage: Full information as to this item is given in Application No to which reference is hereby made. Number and Amount of Bonds Authorized and Issued: Nominal Par Value Date of Authorized Interest Paid First Mortgage Bonds: Issue and Issued Outstanding in % Series GG, due ,000, ,000,000 12,000, % Series HH, due ,000, ,000,000 13,625,000 Var % Series II, due ,000, ,937, % Series KK, due ,000, ,000,000 14,375, % Series LL, due ,000, ,000,000 13,750, % Series MM, due ,000, ,000,000 0 Other Long-Term Debt 4.750% SFr. Foreign Interest Payment Securities ,877,038 7,475, , % Medium-Term Note, due ,000,000 5,000, ,500

24 SOUTHERN CALIFORNIA GAS COMPANY FINANCIAL STATEMENT SEPTEMBER 30, 2011 Date of Date of Interest Interest Paid Other Indebtedness: Issue Maturity Rate Outstanding 2010 Commercial Paper & ST Bank Loans 11/01/04 08/15/11 Various 0 $0 Amounts and Rates of Dividends Declared: The amounts and rates of dividends during the past five fiscal years are as follows: Shares Dividends Declared Preferred Outstanding % 79,011 $118,516 $118,516 $118,516 $118,517 $118, % 783,032 1,174,548 1,174,548 1,174,548 1,174,548 1,174, ,043 $1,293,064 $1,293,064 $1,293,064 $1,293,065 $1,293,065 Common Stock Amount $150,000,000 $250,000,000 $200,000,000 $0 $100,000,000 [1] A balance sheet and a statement of income and retained earnings of Applicant for the nine months ended September 30, 2011 are attached hereto. [1] Southern California Gas Company dividend to parent company, Sempra Energy.

25 SOUTHERN CALIFORNIA GAS COMPANY BALANCE SHEET ASSETS AND OTHER DEBITS SEPTEMBER 30, UTILITY PLANT UTILITY PLANT IN SERVICE $9,608,036, UTILITY PLANT PURCHASED OR SOLD PLANT HELD FOR FUTURE USE COMPLETED CONSTRUCTION NOT CLASSIFIED CONSTRUCTION WORK IN PROGRESS 344,106, ACCUMULATED PROVISION FOR DEPRECIATION OF UTILITY PLANT (3,930,883,213) 111 ACCUMULATED PROVISION FOR AMORTIZATION OF UTILITY PLANT (37,103,249) 117 GAS STORED-UNDERGROUND 55,520,014 TOTAL NET UTILITY PLANT 6,039,676, NONUTILITY PROPERTY 126,658, ACCUMULATED PROVISION FOR DEPRECIATION AND AMORTIZATION OF NONUTILITY PROPERTY (100,925,804) 123 INVESTMENTS IN SUBSIDIARY COMPANIES OTHER INVESTMENTS SINKING FUNDS OTHER SPECIAL FUNDS 4,000,000 TOTAL OTHER PROPERTY AND INVESTMENTS 29,732,797 Data from SPL as of December 1, OTHER PROPERTY AND INVESTMENTS

26 SOUTHERN CALIFORNIA GAS COMPANY BALANCE SHEET ASSETS AND OTHER DEBITS SEPTEMBER 30, CURRENT AND ACCRUED ASSETS CASH 15,799, INTEREST SPECIAL DEPOSITS OTHER SPECIAL DEPOSITS WORKING FUNDS 91, TEMPORARY CASH INVESTMENTS NOTES RECEIVABLE CUSTOMER ACCOUNTS RECEIVABLE 305,844, OTHER ACCOUNTS RECEIVABLE 55,411, ACCUMULATED PROVISION FOR UNCOLLECTIBLE ACCOUNTS (5,232,482) 145 NOTES RECEIVABLE FROM ASSOCIATED COMPANIES 175,375, ACCOUNTS RECEIVABLE FROM ASSOCIATED COMPANIES (3,713,957) 151 FUEL STOCK FUEL STOCK EXPENSE UNDISTRIBUTED PLANT MATERIALS AND OPERATING SUPPLIES 27,482, MERCHANDISE OTHER MATERIALS AND SUPPLIES STORES EXPENSE UNDISTRIBUTED (1,862,607) 164 GAS STORED 161,218, PREPAYMENTS 26,415, INTEREST AND DIVIDENDS RECEIVABLE 2, ACCRUED UTILITY REVENUES MISCELLANEOUS CURRENT AND ACCRUED ASSETS 21,157, DERIVATIVE INSTRUMENT ASSETS 3,437, LONG TERM PORTION OF DERIVATIVE ASSETS - HEDGES - TOTAL CURRENT AND ACCRUED ASSETS 781,428, DEFERRED DEBITS 181 UNAMORTIZED DEBT EXPENSE 6,744, UNRECOVERED PLANT AND OTHER REGULATORY ASSETS 963,678, PRELIMINARY SURVEY & INVESTIGATION CHARGES CLEARING ACCOUNTS 2,586, TEMPORARY FACILITIES MISCELLANEOUS DEFERRED DEBITS 1,229, RESEARCH AND DEVELOPMENT UNAMORTIZED LOSS ON REACQUIRED DEBT 17,457, ACCUMULATED DEFERRED INCOME TAXES 275,719, UNRECOVERED PURCHASED GAS COSTS - TOTAL DEFERRED DEBITS 1,267,416,582 TOTAL ASSETS AND OTHER DEBITS $ 8,118,253,665 Data from SPL as of December 1, 2011.

27 SOUTHERN CALIFORNIA GAS COMPANY BALANCE SHEET LIABILITIES AND OTHER CREDITS SEPTEMBER 30, PROPRIETARY CAPITAL COMMON STOCK ISSUED (834,888,907) 204 PREFERRED STOCK ISSUED (21,551,075) 207 PREMIUM ON CAPITAL STOCK OTHER PAID-IN CAPITAL GAIN ON RETIRED CAPITAL STOCK (9,722) 211 MISCELLANEOUS PAID-IN CAPITAL (31,306,680) 214 CAPITAL STOCK EXPENSE 143, UNAPPROPRIATED RETAINED EARNINGS (1,247,938,941) 219 ACCUMULATED OTHER COMPREHENSIVE INCOME 20,831,771 TOTAL PROPRIETARY CAPITAL (2,114,720,293) 6. LONG-TERM DEBT 221 BONDS (1,300,000,000) 224 OTHER LONG-TERM DEBT (12,475,533) 225 UNAMORTIZED PREMIUM ON LONG-TERM DEBT UNAMORTIZED DISCOUNT ON LONG-TERM DEBT 2,353,122 TOTAL LONG-TERM DEBT (1,310,122,411) 7. OTHER NONCURRENT LIABILITIES 227 OBLIGATIONS UNDER CAPITAL LEASES - NONCURRENT (4,940,780) ACCUMULATED PROVISION FOR INJURIES AND DAMAGES (112,166,642) ACCUMULATED PROVISION FOR PENSIONS AND BENEFITS (649,992,078) ACCUMULATED MISCELLANEOUS OPERATING PROVISIONS ASSET RETIREMENT OBLIGATIONS (831,727,387) TOTAL OTHER NONCURRENT LIABILITIES (1,598,826,887) Data from SPL as of December 1, 2011.

28 SOUTHERN CALIFORNIA GAS COMPANY BALANCE SHEET LIABILITIES AND OTHER CREDITS SEPTEMBER 30, CURRENT AND ACCRUED LIABILITES NOTES PAYABLE ACCOUNTS PAYABLE (307,446,392) 233 NOTES PAYABLE TO ASSOCIATED COMPANIES ACCOUNTS PAYABLE TO ASSOCIATED COMPANIES (13,121,726) 235 CUSTOMER DEPOSITS (70,562,686) 236 TAXES ACCRUED (7,906,645) 237 INTEREST ACCRUED (23,233,812) 238 DIVIDENDS DECLARED (323,265) 241 TAX COLLECTIONS PAYABLE (13,537,348) 242 MISCELLANEOUS CURRENT AND ACCRUED LIABILITIES (119,969,832) 243 OBLIGATIONS UNDER CAPITAL LEASES - CURRENT (7,641,319) 244 DERIVATIVE INSTRUMENT LIABILITIES (822,519) 245 DERIVATIVE INSTRUMENT LIABILITIES - HEDGES - TOTAL CURRENT AND ACCRUED LIABILITIES (564,565,544) 9. DEFERRED CREDITS 252 CUSTOMER ADVANCES FOR CONSTRUCTION (89,543,803) 253 OTHER DEFERRED CREDITS (112,195,858) 254 OTHER REGULATORY LIABILITIES (1,470,273,501) 255 ACCUMULATED DEFERRED INVESTMENT TAX CREDITS (23,388,405) 257 UNAMORTIZED GAIN ON REACQUIRED DEBT ACCUMULATED DEFERRED INCOME TAXES - ACCELERATED ACCUMULATED DEFERRED INCOME TAXES - PROPERTY (561,823,542) 283 ACCUMULATED DEFERRED INCOME TAXES - OTHER (272,793,421) TOTAL DEFERRED CREDITS (2,530,018,530) TOTAL LIABILITIES AND OTHER CREDITS $ (8,118,253,665) $ - Data from SPL as of December 1, 2011.

29 SOUTHERN CALIFORNIA GAS COMPANY STATEMENT OF INCOME AND RETAINED EARNINGS THREE MONTHS ENDED SEPTEMBER 30, UTILITY OPERATING INCOME 400 OPERATING REVENUES 2,773,698, OPERATING EXPENSES 2,015,596, MAINTENANCE EXPENSES 95,665, DEPRECIATION AND AMORTIZATION EXPENSES 245,699, TAXES OTHER THAN INCOME TAXES 59,231, INCOME TAXES 53,334, PROVISION FOR DEFERRED INCOME TAXES 120,603, PROVISION FOR DEFERRED INCOME TAXES - CREDIT (40,621,756) INVESTMENT TAX CREDIT ADJUSTMENTS (1,882,361) GAIN FROM DISPOSITION OF UTILITY PLANT LOSS FROM DISPOSITION OF UTILITY PLANT - TOTAL OPERATING REVENUE DEDUCTIONS 2,547,626,996 NET OPERATING INCOME 226,071, OTHER INCOME AND DEDUCTIONS 415 REVENUE FROM MERCHANDISING, JOBBING AND CONTRACT WORK REVENUES FROM NONUTILITY OPERATIONS EXPENSES OF NONUTILITY OPERATIONS (96,175) 418 NONOPERATING RENTAL INCOME 255, EQUITY IN EARNINGS OF SUBSIDIARIES INTEREST AND DIVIDEND INCOME 182, ALLOWANCE FOR OTHER FUNDS USED DURING CONSTRUCTION 13,332, MISCELLANEOUS NONOPERATING INCOME (100,101) GAIN ON DISPOSITION OF PROPERTY - TOTAL OTHER INCOME 13,574, MISCELLANEOUS AMORTIZATION MISCELLANEOUS OTHER INCOME DEDUCTIONS (3,464,384) (3,464,384) TAXES OTHER THAN INCOME TAXES (97,645) INCOME TAXES 26,020, PROVISION FOR DEFERRED INCOME TAXES (2,849,646) PROVISION FOR DEFERRED INCOME TAXES - CREDIT 2,327, INVESTMENT TAX CREDITS - TOTAL TAXES ON OTHER INCOME AND DEDUCTIONS 25,400,634 TOTAL OTHER INCOME AND DEDUCTIONS 35,510,362 INCOME BEFORE INTEREST CHARGES 261,582,327 NET INTEREST CHARGES* 52,275,524 NET INCOME $209,306,803 *NET OF ALLOWANCE FOR BORROWED FUNDS USED DURING CONSTRUCTION. ($5,275,859)

30 SOUTHERN CALIFORNIA GAS COMPANY STATEMENT OF INCOME AND RETAINED EARNINGS THREE MONTHS ENDED SEPTEMBER 30, RETAINED EARNINGS RETAINED EARNINGS AT BEGINNING OF PERIOD, AS PREVIOUSLY REPORTED $1,089,601,936 NET INCOME (FROM PRECEDING PAGE) 209,306,803 DIVIDEND TO PARENT COMPANY (50,000,000) DIVIDENDS DECLARED - PREFERRED STOCK (969,798) OTHER RETAINED EARNINGS ADJUSTMENT - RETAINED EARNINGS AT END OF PERIOD $1,247,938,941

31 APPENDIX C Statement of Original Cost and Depreciation Reserve

32 SOUTHERN CALIFORNIA GAS COMPANY COST OF PROPERTY AND DEPRECIATION RESERVE APPLICABLE AS OF SEPTEMBER 30, 2011 Natural Asset Original Cost Reserve for Depr. Account No. Class No. Account as of 09/30/2011 and Amortization G Organization 76, G Franchis. & Consents 550,693 - TOTAL INTANGIBLES $ 627, G Other Land Rights 15, G Prd Gas Wells Const 5,461, G Prd Gass Wells Eqp 454,718 (55) G Field LInes 1,731, G FldMeas&RegStnEquip 536, G Prf Eqpt 482,615 - TOTAL PRODUCTION $ 8,681,486 $ (55) G UGS - Storage Rights 17,364,994 (16,543,349) G UGS-Recoverable Oil 570,804 (570,804) UNDERGROUND STORAGE RIGHTS 17,935,798 (17,114,153) G UGS-Land Ownd in Fee 4,539, G UGS - Rights of Way 25,354 (13,892) G UGS-Comp Stn St&Imp 16,607,535 (12,259,978) G UGS-Other Struc&Imp 21,252,430 (6,450,045) G UGS - Wells 215,119,070 (146,021,676) G UGS-Well-Aliso Cyn 9,388,554 (7,078,369) G UGS-Well-Honor Rancho 26,089,167 (401,862) G UGS - Wells - Native G UGS - Lines 87,981,329 (90,800,451) G UGS-Line-Aliso Cyn 2,724,103 (2,192,355) G UGS - Lines - HR 1,466,815 (9,415) G UGS - Lines - Native G UGS-Cmp Stn Eqpt P&W 120,700,831 (65,172,250) G UGS-Meas & Reg Eqpt 5,808,046 (1,617,296) G UGS - Meas & Reg Nat G UGS-Prf Eqt & Wire 109,045,473 (61,089,175) G UGS Prf Eqt-Aliso 628,857 (490,319) G UGS Prf Eqt-HR 6,034,621 (58,786) G UGS - Prf Eqpt - Nat G UGS - Other Eqpt 21,731,854 (4,996,620) G UGS - Other Eqpt-HR 1,420,644 (32,268) TOTAL UNDERGROUND STORAGE 650,564,165 (398,684,757) TOTAL UGS & UGS RIGHTS $ 668,499,963 $ (415,798,910) G Land 2,628, G Land - Kern Mojave 157, G Land Rights (SCG) 20,614,437 (14,073,803) G Comp Station-Stru&Im 13,256,675 (11,473,477) G Meas&Reg-Struc&Imp 3,634,525 (2,709,716) G Other Struct and Imp 14,957,959 (5,737,968) G Struct-Kern/Mojave 1,117,406 (498,643) G Mains 1,127,280,484 (527,599,198) G Mains - Kern/Mojave 2,697,057 (1,258,214) G Trn Mn-Deep Well And 1,452,461 (213,956) G Compressor Statn Eq 144,497,719 (87,076,775) G Cmp Stn Eq-Kern/Mjv 34,219,687 (14,851,844) G Meas & Reg Statn Eq 56,240,167 (24,334,501) TOTAL TRANSMISSION $ 1,422,754,575 $ (689,828,095)

33 G Other Equipment 3,628,366 (2,358,691) G Tel Instrumentation 465,416 (76,375) G Tel Lines G Land 28,449, G Land Rights 2,708,129 (12,264) G Struct & Imp 220,507,749 (59,395,640) G Mains - Steel 1,296,185,748 (954,709,604) G Mains - Plastic 1,799,129,738 (846,618,877) G Mains-Deep Well And 3,316, , G Meas & Reg Statn Eq 71,799,213 (50,580,872) G Services - Steel 255,741,277 (390,070,365) G Services - Plastic 1,794,693,182 (1,299,196,457) G Services - Copper 1,522,394 (1,745,489) G Stub Lbr&Non-lbr Cst 34,905,856 (8,232,529) G Meters & Regulators 414,525,199 (114,106,270) G Press & Othr Gauges 6,435,849 (4,687,010) G Elct Gauge & Othr 8,504,155 2,188, G Cust Mtr Inst Cls A 193,953,974 (103,130,480) G Cust Mtr Inst Cls B 41,009,661 (20,307,555) G Cust Mtr Inst Rotary 5,585,542 (1,705,840) G Cst Orifice Mtr Inst 1,910,798 (2,011,617) G Cust Turb Mtr Inst 7,874,919 (4,588,987) G Cust Gas Elect-GEMS 12,458,535 (10,279,976) G Gas Regulators 120,640,599 (50,458,508) G Other Equipment 11,807,484 (11,159,316) G Fuel Stns-Nat Gas 14,405,419 (9,134,668) G Street Lighting Eqpt G Land Owned in Fee 1,342, G Land Rights 74,300 - TOTAL DISTRIBUTION $ 6,353,581,610 $ (3,941,970,866) G Struct & Land Imp 124,744,325 (118,028,262) G Struct & Land Imp - GCT LHI 11,154, G Ofc F&E-Mech Eng &FF 15,569,312 1,007, G Computer Equipment 107,697,937 (55,764,353) G Cmp Sftwr 2-4 years 8,531,231 (4,905,539) G Cmp Sftwr 5-8 years 51,756,104 (24,224,576) G Cmp Sftwr 9-12 years 164,529,725 (25,276,611) G Cmp Sftwr 15 years 74,454,845 (56,827,890) G Cmp Sftwr 20 years 65,396,512 (51,096,641) G Transprtn Eq-Autos 532,002 (27,414) G Transprtn Eq-NGV 166,302 88, G Stores Equipment 93,665 (18,755) G Capital Tools-KM 128,516 (51,718) G Portable Tools 40,160,458 (18,221,323) G Shop Equipment 11,768,613 (5,656,990) G Laboratory Equipment 5,873,244 (3,639,350) G Power Operated Eq. 16,767 13, G Communication Equip. 9,046,298 1,243, G Gen Ntwk, ACD, WN/LN 69,202,042 (14,934,339) G Comn Eqt-Othr Voice 1,937,688 (807,471) G Comn Eqt-Mcrw/Rd Eqt 7,186,250 (4,670,168) G Commun. Struct. 2,208,027 (632,504) G Misc. Equipment 3,613, ,938 TOTAL GENERAL PLANT $ 775,768,598 $ (381,829,214)

34 FIN 47 Accumulated Depreciation-Gas 342,443,698 (123,478,457) FAS 143 Ad-Arc-Ventura 2,251,977 (2,251,977) FAS 143 Ad-Arc-Playa Del Rey 868,352 (42,969) FAS 143 Ad-Contra-Playa Del Rey - (447,266) FAS 143 Ad-Gas-Cost Of Removal Obligation - 1,830,360,000 TOTAL ARO'S FAS 47/FAS 143 $ 345,564,027 $ 1,704,139, GSUNC GAS STORED UNDERGROUND NONCURRENT 55,520, & NET - GAS ACCRUAL FOR RETIREMENTS TOTAL PLANT IN SERVICE $ 9,630,997,423 $ (3,725,287,809) PLANT FLEET LEASE 32,558,931 (19,976,832) TOTAL PLANT IN SERVICE (Inc. Capital Leases) $ 9,663,556,354 $ (3,745,264,640) 107 TOTAL CWIP 344,102, REG LIABILITY-COST OF REMOVAL OBLIGATION - (223,929,000) TOTAL UTILITY $ 10,007,659,017 $ (3,969,193,640) Per Balance Sheet $ 10,007,659,017 $ (3,969,193,640)

35 APPENDIX D Summary of Earnings

36 SOUTHERN CALIFORNIA GAS COMPANY SUMMARY OF EARNINGS THREE MONTHS ENDED SEPTEMBER 30, 2011 (DOLLARS IN MILLIONS) Line No. Item Amount 1 Operating Revenue $2,774 2 Operating Expenses 2,548 3 Net Operating Income $226 4 Weighted Average Rate Base $2,963 5 Rate of Return* 8.68% *Authorized Cost of Capital

37 APPENDIX E List of Governmental Agencies

38 ATTORNEY GENERAL STATE OF CALIFORNIA 1300 I STREET SACRAMENTO, CA COUNTY COUNSEL FRESNO COUNTY 2220 TULARE ST., 5TH FLOOR FRESNO, CA COUNTY COUNSEL KERN COUNTY 1415 TRUXTUN BAKERSFIELD, CA COUNTY CLERK KINGS COUNTY 1400 W. LACEY BLVD. HANFORD, CA DISTRICT ATTORNEY ORANGE COUNTY 700 CIVIC CENTER DRIVE WEST SANTA ANA, CA COUNTY CLERK RIVERSIDE COUNTY 4080 LEMON STREET RIVERSIDE, CA DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA 915 CAPITOL MALL SACRAMENTO, CA COUNTY CLERK IMPERIAL COUNTY EL CENTRO, CA CLERK OF THE BOARD KERN COUNTY 1115 TRUXTON BAKERSFIELD, CA DISTRICT ATTORNEY LOS ANGELES COUNTY 111 NO. HILL STREET LOS ANGELES, CA COUNTY OF ORANGE ATTN. COUNTY CLERK 12 CIVIC CENTER PLAZA, ROOM 101 SANTA ANA, CA COUNTY CLERK SAN BERNARDINO COUNTY 175 W. 5TH ST SAN BERNARDINO, CA COUNTY CLERK FRESNO COUNTY 2221 KERN ST. FRESNO, CA DISTRICT ATTORNEY IMPERIAL COUNTY 940 W. MAIN ST., STE. 101 EL CENTRO, CA DISTRICT ATTORNEY KINGS COUNTY 1400 W. LACEY BLVD. HANFORD, CA COUNTY CLERK LOS ANGELES COUNTY E. IMPERIAL HIGHWAY NORWALK, CA DISTRICT ATTORNEY RIVERSIDE COUNTY 2041 IOWA AVE. RIVERSIDE, CA DISTRICT ATTORNEY SAN BERNARDINO COUNTY 175 W. 5TH ST. SAN BERNARDINO, CA COUNTY CLERK SAN LUIS OBISPO COUNTY COURT HOUSE ANNEX SAN LUIS OBISPO, CA DISTRICT ATTORNEY SANTA BARBARA COUNTY 105 E. ANAPUMA ST. SANTA BARBARA, CA DISTRICT ATTORNEY SAN LUIS OBISPO COUNTY COURT HOUSE ANNEX SAN LUIS OBISPO, CA COUNTY CLERK TULARE COUNTY CIVIC CENTER VISALIA, CA COUNTY CLERK SANTA BARBARA COUNTY P.O. BOX 159 SANTA BARBARA, CA DISTRICT ATTORNEY TULARE COUNTY CIVIC CENTER VISALIA, CA DISTRICT ATTORNEY VENTURA COUNTY 800 SO. VICTORIA AVE. VENTURA, CA COUNTY CLERK VENTURA COUNTY 800 SO. VICTORIA AVE. VENTURA, CA YUCAIPA CITY YUCAIPA BLVD. YUCAIPA, CA ADELANTO CITY HALL P.O. BOX 10 ADELANTO, CA ADELANTO CITY HALL P. O. BOX 10 ADELANTO, CA AGOURA HILLS CITY HALL AGOURA CT., #102 AGOURA HILLS, CA 91301