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 Consider Streamlining Interconnection of Distributed Energy Resources and Improvements to Rule 21. Rulemaking (Filed July 13, 2017) JOINT REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) AND (U 39-E) ON ASSIGNED COMMISSIONER S AMENDED SCOPING MEMO AND JOINT ADMINISTRATIVE LAW JUDGE RULING KEITH SAMPSON Attorney for: PACIFIC GAS AND ELECTRIC COMPANY ALEXA MULLARKY Attorney for: SOUTHERN CALIFORNIA EDISON COMPANY 77 Beale Street, B30A 2244 Walnut Grove Avenue San Francisco, California Post Office Box 800 Telephone: (415) Rosemead, California Facsimile: (415) Telephone: (626) Keith.Sampson@pge.com alexa.j.mullarky@sce.com Dated: December 10, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Streamlining Interconnection of Distributed Energy Resources and Improvements to Rule 21. Rulemaking (Filed July 13, 2017) JOINT REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) AND (U 39-E) ON ASSIGNED COMMISSIONER S AMENDED SCOPING MEMO AND JOINT ADMINISTRATIVE LAW JUDGE RULING I. INTRODUCTION Pursuant to the Assigned Commissioner s Amended Scoping Memo and Joint Administrative Law Judge Ruling, 1 Southern California Edison Company ( SCE ) and Pacific Gas and Electric Company ( PG&E ) respectfully submit these reply comments 2 to parties responses to the questions raised in the Amended Scoping Memo. 3 1 R , Assigned Commissioner s Amended Scoping Memo and Joint Administrative Law Judge Ruling, issued November 16, 2018, at pp ( Amended Scoping Memo ). 2 Counsel for PG&E have authorized counsel for SCE to file and serve these joint reply comments on their behalf. 3 Opening comments were submitted on December 3, 2018 by: (1) SCE and PG&E, jointly; (2) San Diego Gas & Electric Company ( SDG&E ); (3) California Solar & Storage Association ( CALSSA ); (4) Green Power Institute ( GPI ); (5) Clean Coalition; (6) Small Business Utility Advocates ( SBUA ); (7) The Utility Reform Network ( TURN ); and (8) Tesla, Inc. ( Tesla ). 1

3 II. RESPONSE TO ISSUES RAISED BY PARTIES A. The Rulemaking Must Adhere to the Current Schedule to Allow for Timely Interconnection Enhancements and to Support Market Clarity and Efficiency As stated in opening comments, 4 SCE and PG&E believe that the Commission should remain focused on resolving the issues that are currently within the scope of this proceeding, and adhere to the schedule set forth in the Amended Scoping Memo. SCE and PG&E are thus in agreement with TURN and SBUA, both of which recognize that resolving the issues already within the scope of the proceeding in a timely manner helps to create a stable rule environment, promotes market clarity, and ensures efficiency of Commission and stakeholder resources. 5 For these same reasons, SCE does not support CALSSA s request that the Commission re-evaluate the scoped issues between each working group as it did between Working Group Two and Working Group Three or that new issues potentially be added to the scope of Working Group Four. 6 Instead of a continuously evolving rulemaking which fosters uncertainty, wastes resources, and harms customers in the marketplace the Commission should set new issues to either be reviewed within the Interconnection Discussion Forum ( IDF ) or resolved within a future rulemaking, as appropriate. Rather than continuing to change the scope of this proceeding, and as discussed within SCE and PG&E s Joint Comments, SCE and PG&E are open to discussing whether practices 4 Joint Response of Southern California Edison (U 338-E) and Pacific Gas and Electric Company (U 39-E) to Assigned Commissioner s Amended Scoping Memo and Joint Administrative Law Judge Ruling ( SCE and PG&E s Joint Comments ), at pp See Response of the Utility Reform Network to Assigned Commissioner s Amended Scoping Memo and Joint Administrative Law Judge Ruling ( TURN Comments ), at pp. 1-2; Comments of Small Business Utility Advocates on the Assigned Commissioner s Amended Scoping Memo and Joint Administrative Law Judge Ruling ( SBUA Comments ), at pp See Response of the California Solar & Storage Association Questions in the Amended Scoping Memo ( CALSSA Comments ), at p. 1. 2

4 that have been used in other Commission proceedings or utilized by the California Independent System Operator should be implemented in a future interconnection rulemaking. 7 B. The Interconnection Discussion Forum Supports Commission Goals by Allowing Parties to Discuss Emerging Issues and Determine the Best Process to Resolve Those Issues SCE and PG&E believe that the IDF would be an appropriate forum to discuss emerging issues and determine a process to resolve those issues. 8 SCE and PG&E thus disagree with the narrow role envisioned by CALSSA for the IDF, and do not believe that dispute resolution should be the main or only focus of the IDF. 9 The Commission itself has recognized that the IDF was developed to explore a wide variety of issues related to interconnection practices and policies[,] 10 and that the IDF can be used as a venue to encourage discussion and collaboration between the Utilities and developers. 11 Failing to utilize the IDF as intended 12 would be a lost opportunity to improve the rulemaking process. Further, the IDF is not a forum to resolve individual customer disputes, 13 but instead is a forum to discuss issues regarding individual interconnection requests that are common to 7 See SCE and PG&E s Joint Comments, at p See SCE and PG&E s Joint Comments, at pp CALSSA Comments, at p Amended Scoping Memo, at n.2 (citing Resolution ALJ-347 ( ALJ-347 ), issued October 17, 2017, at Exhibit A, Attachment A), (Emphasis added). 11 Id. at p. 8 (citing ALJ-347, at Exhibit A, Attachment A). 12 See ALJ-347 at Exhibit A, Attachment A. 13 Contrary to CALSSA s claim that [u]tilities do not have good processes for resolving disputes and that [c]ustomers and project developers are told to communicate via to group inboxes or to call general customer service numbers[,] see CALSSA Comments at p. 2, SCE and PG&E have established, effective processes to resolve disputes under Section K of their Rule 21. As of the end of the third quarter 2018 ( 3Q 2018 ), SCE has had 17 disputes initiated pursuant to Section K, the vast majority of which were successfully resolved informally; and PG&E has had five such disputes, all of which were resolved. Further, SCE and PG&E both have an Ombudsman, whose identity, role, and contact information is available on each utility s website, and who has authority to resolve disputes over missed timelines. 3

5 multiple applications or representative of recurring issues. 14 It is not surprising that a common or recurring issue appropriate for discussion and resolution in the IDF is likely to involve a review of existing practices and rules and consideration of whether refinements are warranted, all of which are policy discussions. While SCE and PG&E appreciate that the IDF does not have the authority to alter or require new interconnection policies, practices or requirements that are not otherwise established by a Commission decision or resolution via a public proceeding, SCE and PG&E nevertheless believe that the IDF provides an opportunity to work with stakeholders on issues in a nimble manner, and to identify whether any issues can be resolved by making agreed upon changes through existing tools, subject to Commission approval, or should be identified for formal rulemaking through a designated review process. As mentioned above, limiting the IDF s focus to disputes shortchanges the IDF s potential. As the Commission considers how best to utilize the IDF in this proceeding though, SCE and PG&E caution that any refinements to the frequency of IDF meetings must be supportive of the number of complex issues already slated for discussion within Working Groups Three and Four. The Commission should ensure that the IDF meetings utilize Commission and stakeholder resources efficiently and in tandem with other related interconnection Commission sponsored matters. Finally, SCE also supports comments provided by Tesla that the IDF participants should be encouraged to make a submission akin to a business case in support of dedication of time and resources to address a given issue with the goal of yielding meaningful improvements to the interconnection process and the customer and developer experience. 15 III. CONCLUSION SCE and PG&E appreciate the opportunity to provide these reply comments to the party 14 ALJ-347 at Exhibit A, Attachment A, (Emphasis added). 15 See Tesla, Inc. s Opening Comments Responding to Questions Related to the Rule 21 Working Group Process and the Interconnection Discussion Forum ( Tesla s Comments ), at p. 3. 4

6 responses to the questions raised in the Amended Scoping Memo. Respectfully submitted, ALEXA J. MULLARKY /s/ Alexa J. Mullarky By: Alexa J. Mullarky Attorney for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) On Behalf of: Southern California Edison Company (U 338-E) and Pacific Gas and Electric Company (U 39-E) Dated: December 10,

7 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Streamlining Interconnection of Distributed Energy Resources and Improvements to Rule 21. Rulemaking (Filed July 13, 2017) 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 the JOINT REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) AND (U 39-E) ON ASSIGNED COMMISSIONER S AMENDED SCOPING MEMO AND JOINT ADMINISTRATIVE LAW JUDGE RULING on all parties identified on the attached service list for R Service was effected by transmitting copies via to all parties who have provided an address and by placing a copy in a sealed envelope and causing such envelope to be delivered via United States mail with first-class postage prepaid to the offices of the ALJ. ALJ Kelly A. Hymes California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue San Francisco, CA Executed on December 10, 2018, at Rosemead, California. /s/ Jorge Martinez Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

8 Page 1 of 10 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO CONSID FILER: CPUC LIST NAME: LIST LAST CHANGED: NOVEMBER 30, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties MATTHEW W. DWYER KEITH SWITZER MGR - TARRIFFS & SPECIAL PROJECTS SOUTHERN CALIFORNIA EDISON COMPANY GOLDEN STATE WATER COMPANY 2244 WALNUT GROVE AVE. / PO BOX EAST FOOTHILL BOULEVARD ROSEMEAD, CA SAN DIMAS, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: GOLDEN STATE WATER COMPANY DAVID CHENG JACKIE PIERO STAFF DIR - POLICY THE UTILITY REFORM NETWORK NUVVE CORPORATION TH AVENUE, SUITE HISTORIC DECATUR ROAD SAN DIEGO, CA SAN DIEGO, CA FOR: THE UTILITY REFORM NETWORK (TURN) FOR: NUVVE CORPORATION JONATHAN J. NEWLANDER KENNETH SAHM WHITE SR. COUNSEL ECONOMICS & POLICY ANALYSIS DIR SAN DIEGO GAS & ELECTRIC COMPANY CLEAN COALITION 8330 CENTURY PARK CT, CP32D 16 PALM CT. SAN DIEGO, CA MENLO PARK, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: CLEAN COALITION TED KO SKY C. STANFIELD DIRECTOR OF POLICY STEM, INC. SHUTE, MIHALY & WEINBERGER, LLP 100 ROLLINS ROAD 396 HAYES STREET MILLBRAE, CA SAN FRANCISCO, CA FOR: STEM, INC. FOR: INTERSTATE RENEWABLE ENERGY COUNCIL, INC. (IREC)

9 Page 2 of 10 CHRISTA SALO LEGAL DIVISION ROOM 4107 ROOM 4107 PAUL ANGELOPULO LEGAL DIVISION FOR: ORA FOR: OFFICE OF SAFETY ADVOCATE (OSA) SERJ BERELSON IVAN R. JIMENEZ MGR - REGULATORY STRATEGY REGULATORY SUNVERGE ENERGY, INC. SMALL BUSINESS UTILITY ADVOCATES 950 MINNA STREET 548 MARKET STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SUNVERGE ENERGY, INC. FOR: SMALL BUSINESS UTILITY ADVOCATES STACY W. WALTER NICHOLAS CONNELL SR. MGR - GOV'T AFFAIRS ADVANCED MICROGRID SOLUTIONS 77 BEALE STREET, MC B30A 25 STILLMAN STREET, SUITE 200 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: FOR: ADVANCED MICROGRID SOLUTIONS (AMS) BRIAN T. CRAGG JEANNE B. ARMSTRONG GOODIN, MACBRIDE, SQUERI & DAY, LLP GOODIN MACBRIDE SQUERI & DAY LLP 505 SANSOME STREET, SUITE SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: INDEPENDENT ENERGY PRODUCERS FOR: CALIFORNIA SOLAR & STORAGE ASSOCIATION (IEP) ASSOCIATION F/K/A THE SOLAR ENERGY INDUSTRIES ASSOCIATION (SEIA) STEVE SHERR JASON B. KEYES SVP BUSINESS AFFAIRS & GEN. COUNSEL FOUNDATION WINDPOWER, LLC KEYES & FOX LLP 505 SANSOME STREET, STE TH STREET, STE SAN FRANCISCO, CA OAKLAND, CA FOR: FOUNDATION WINDPOWER, LLC FOR: TESLA, INC. SHERIDAN PAUKER TIM LINDL PARTNER COUNSEL KEYES & FOX, LLP KEYES & FOX LLP TH STREET, SUITE TH STREET, STE OAKLAND, CA OAKLAND, CA FOR: BOSCH BUILDING GRID TECHNOLOGIES FOR: SUNRUN, INC. F/K/A ROBERT BOSCH LLC ALEX MORRIS GREGORY MORRIS SR. DIR., POLICY & REGULATORY AFFAIRS DIRECTOR CALIFORNIA ENERGY STORAGE ALLIANCE GREEN POWER INSTITUTE 2150 ALLSTON WAY, SUITE SHATTUCK AVENUE, STE 402 BERKELEY, CA BERKELEY, CA FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: GREEN POWER INSTITUTE (CESA)

10 Page 3 of 10 JULIA A. LEVIN ANNE SMART EXECUTIVE DIR. VP, PUBLIC POLICY BIOENERGY ASSOCIATION OF CALIFORNIA CHARGEPOINT, INC. PO BOX EAST HACIENDA AVENUE ALBANY, CA CAMPBELL, CA FOR: BIOENERGY ASSOCIATION OF FOR: CHARGEPOINT, INC. CALIFORNIA (BAC) WILLIAM H. WEAVER DANIEL MARSH SENIOR COUNSEL MGR - RATES & REGULATORY CALIFORNIA INDEPENDENT SYSTEM OPERATOR LIBERTY UTILITIES 250 OUTCROPPING WAY 933 ELOISE AVE. FOLSOM, CA SO. LAKE TAHOE, CA FOR: CALIFORNIA INDEPENDENT SYSTEM FOR: LIBERTY UTILITIES (CALPECO OPERATOR CORPORTATION (CAISO) ELECTRIC) LLC MATTHEW MCVEE CHIEF REGULATORY COUNSEL PACIFICORP 825 N.E. MULTNOMAH ST, SUITE 2000 PORTLAND, OR FOR: PACIFICORP Information Only BRIAN THEAKER DENISE GRAB DIR - REGULATORY AFFAIRS NRG ENERGY, INC. - WEST INSTITUTE FOR POLICY INTEGRITY, CA 00000, NY DINA ABDULHADI DONALD LIDDELL POLICY ASSOCIATE DOUGLASS & LIDDELL INSTITUTE FOR POLICY INTEGRITY, CA 00000, NY ELLIS MAXWELL ERNST, CA JOHN W. LESLIE, ESQ PARTNER DENTONS US LLP, CA KAREN KHAMOU LEE TREVINO PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA MATTHEW PLUMMER MEGHA LAKHCHAURA STATE AGENCY REGULATIONS SUNRUN, INC., CA 00000, CA 00000

11 Page 4 of 10 NADIM VIRANI REGULATORY CLERK BRAUN BLAISING SMITH WYNNE, PC, CA 00000, CA RICK UMOFF SAM SCHABACKER COUNSEL & DIR - STATE AFFAIRS POLICY MANAGER SOLAR ENERGY INDUSTRIES ASSOCIATION BLOOM ENERGY, CA 00000, CA STEVEN RYMSHA TIM MASON DIR - GRID SOLUTIONS, PUBLIC POLICY POLICY DIRECTOR SUNRUN INC. LARGE-SCALE SOLAR ASSOCIATION, AA 00000, CA MRW & ASSOCIATES LLC BRIAN LYDIC INTERSTATE RENEWABLE ENERGY COUNCIL, INC, CA PO BOX 1156 LATHAM, NY LON W. HOUSE BRANDON SMITHWOOD ENERGY ADVISOR MGR. - CALIF. STATE AFFAIRS ASSOCIATION OF CALIFORNIA WATER AGENCIES SOLAR ENERGY INDUSTRIES ASSOCIATION N. ORACLE RD., STE ORO VALLEY, AZ , CA SHARON YANG NORMAN A. PEDERSEN LKP GLOBAL LAW, LLP HANNA AND MORTON LLP 1901 AVENUE OF THE STARS, SUITE SOUTH FLOWER ST. SUITE 2530 LOS ANGELES, CA LOS ANGELES, CA JOSEPH H. PARK DANIEL W. MARSH DIR - LEGAL SERVICES MGR - RATES & REGULATORY AFFAIRS LIBERTY UTILITIES (CALIFORNIA) LIBERTY UTILITIES (CALIFORNIA) 9750 WASHBURN ROAD 9750 WASHBURN ROAD DOWNEY, CA DOWNEY, CA FOR: LIBERTY UTILITIES (CALPECO ELECTRIC) LLC JESSALYN ISHIGO BRADLEY BARTZ ENVIRONMENTAL BUS. DEVELOPMENT OFF. PRESIDENT AMERICAN HONDA MOTOR, CO., INC. ABC SOLAR INCORPORATED 1919 TORRANCE BLVD HAWTHORNE BLVD. TORRANCE, CA TORRANCE, CA FOR: AMERICAN HONDA MOTOR, CO., INC. FOR: ABC SOLAR INCORPORATED FRED G. YANNEY GREGORY KLATT DOUGLASS & LIDDELL YANNEY LAW OFFICE 411 E. HUNTINGTON DRIVE, NO

12 Page 5 of MARQUARDT AVE. UNIT C-4 ARCADIA, CA CERRITOS, CA FOR: GOLDEN STATE WATER COMAPNY ON BEHALF OF BEAR VALLEY ELECTRIC SERVICE (BEAR VALLEY OR BVES) DANIEL W. DOUGLASS ALEXA J. MULLARKY DOUGLASS & LIDDELL 4766 PARK GRANADA, STE. 209 SOUTHERN CALIFORNIA EDISON COMPANY CALABASAS, CA WALNUT GROVE AVENUE / BOX 800 FOR: WESTERN POWER TRADING FORUM ROSEMEAD, CA CASE ADMINISTRATION GARY STERN SOUTHERN CALIFORNIA EDISON COMPANY MANAGING DIR RUSH STREET, GO4, 2ND FL. SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA RUSH STREET ROSEMEAD, CA KATHRYN ENRIGHT NGUYEN QUAN SOUTHERN CALIFORNIA EDISON COMPANY MGR - REGULATORY AFFAIRS 2244 WALNUT GROVE AVENUE BEAR VALLEY ELECTRIC SERVICE ROSEMEAD, CA E. FOOTHILL BLVD. SAN DIMAS, CA FOR: BEAR VALLEY ELECTRIC SERVICE (GOLDEN STATE WATER COMPANY) JOSH GERBER JOSEPH M. MCCAWLEY FOUNDER & PRINCIPAL REGULATORY CASE MGR. 33 NORTH ENERGY LLC SAN DIEGO GAS & ELECTRIC COMPANY 1050 HYGEIA AVE., NO. A CENTURY PARK COURT, CP32F ENCINITAS, CA SAN DIEGO, CA CLAY FABER PAUL MARCONI DIR - REGULATORY AFFAIRS DIR SAN DIEGO GAS & ELECTRIC COMPANY BEAR VALLEY ELECTRIC SERVICE 8330 CENTURY PARK CT., CP32D GARSTIN DRIVE, PO BOX 1547 SAN DIEGO, CA BIG BEAR LAKE, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY JEFF HIRSCH MICHAEL BROWN JAMES J. HIRSCH & ASSOCIATES CONSULTANT PRESILLA ROAD LAW OFFICE OF MICHAEL BROWN SANTA ROSA VALLEY, CA TH STREET, STE. 215 BAKERSFIELD, CA FOR: SMALL BUSINESS UTILITY ADVOCATES (SBUA) ANDREW YIP JEREMY WAEN DIRECTOR - BUSINESS DEVELOPMENT MGR. - REGULATORY AFFAIRS BOSCH BUILDING GRID TECHNOLOGIES PENINSULA CLEAN ENERGY 101 JEFFERSON DRIVE 2075 WOODSIDE RD. MENLO PARK, CA REDWOOD CITY, CA MARC MONBOUQUETTE ALIA SCHOEN

13 Page 6 of 10 SR.MGR - REG & GOV'T AFFAIRS PUBLIC POLICY MANAGER EMOTORWERKS BLOOMENERGY 846 BRANSTEN ROAD 1299 ORLEANS DRIVE SAN CARLOS, CA SUNNYVALE, CA LAURA D. BEATON ADENIKE ADEYEYE SHUTE, MIHALY & WEINBERGER LLP COMMISSIONER GUZMAN ACEVES 396 HAYES STREET ROOM 5303 SAN FRANCISCO, CA VAN NESS AVENUE FOR: INTERSTATE RENEWABLE ENERGY SAN FRANCISCO, CA COUNCIL, INC. JOSE ALIAGA-CARO JUSTIN H. FONG INFRASTRUCTURE PLANNING AND PERMITTING B TRANSPORTATION ENFORCEMENT BRANCH AREA AREA MARCEL HAWIGER BRITTNEY MARRA STAFF ASSIST. EXE. DIR THE UTILITY REFORM NETWORK SMALL BUSINESS UTILITY ADVOCATES 785 MARKET ST., STE MARKET STREET, SUITE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK (TURN) FOR: SMALL BUSINESS UTILITY ADVOCATES (SBUA) JAMES BIRKELUND AMARA HAYASHIDA PRESIDENT & GEN. COUNSEL CASE MGR. - REGULATORY AFFAIRS SMALL BUSINESS UTILITY ADVOCATES 548 MARKET STREET, STE BEALE STREET, B23 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SMALL BUSINESS UTILITY ADVOCATES HAROLD HIRSCH JOSEPHINE WU CASE COORDINATOR 245 MARKET STREET SAN FRANCISCO, CA BEALE STREET, MC B9A, RM 2364B SAN FRANCISCO, CA KELSEY PIRO KRISTIN CHARIPAR CASE MGR. CASE MGR 77 BEALE STREET 77 BEALE STREET, MC 23A SAN FRANCISCO, CA SAN FRANCISCO, CA LARISSA KOEHLER MAGGIE CHAN SENIOR REGULATORY AFFAIRS ENVIRONMENTAL DEFENSE FUND 123 MISSION STREET, 28TH FLOOR 77 BEALE ST., MC B9A / PO BOX SAN FRANCISCO, CA SAN FRANCISCO, CA FOR:

14 Page 7 of 10 MARK ESGUERRA MELICIA CHARLES SUNRUN INC. 77 BEALE STREET 595 MARKET STREET, 29TH FL. SAN FRANCISCO, CA SAN FRANCISCO, CA SARINA URIZA TYLER CAPPS NAVIGANT CONSULTING, INC. 77 BEALE ST., B9A ONE MARKET ST, SPEAR TOWER, STE 1200 SAN FRANCISCO, CA SAN FRANCISCO, CA WILLIAM CHUNG FRANCESCA WAHL PRODUCT MGR. SR. POLICY ASSOCIATE, BUS. DEVELOPMENT TESLA, INC. 77 BEALE STREET 444 DE HARO STREET, STE. 101 SAN FRANCISCO, CA SAN FRANCISCO, CA JOHN W. ANDERSON BENJAMIN C. BODELL DIR - ENERGY MARKETS OHMCONNECT, INC. GOODIN MACBRDIE SQUERI & DAY LLP 350 TOWNSEND S., SUITE SANSOME STREET, STE. 900 SAN FRANCISCO, CA SAN FRANCISCO, CA JOHN MCINTYRE LOUISE DYBLE GOODIN, MACBRIDE, SQUERI & DAY, LLP WINSTON & STRAWN 505 SANSOME ST., STE CALIFORNIA STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA MEGAN M. MYERS SARA STECK MYERS AT LAW LAW OFFICES OF SARA STECK MYERS LAW OFFICES OF SARA STECK MYERS TH AVENUE TH AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CENTER FOR ENERGY EFFICIENCY AND FOR: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE TECHNOLOGIES (CEERT) RENEWABLE TECHNOLOGIES CASE ADMINISTRATION ERIK JACOBSON DIR - REGULATORY RELATIONS, CA BEALE ST., MD B23A / PO BOX SAN FRANCISCO, CA FOR: ALLIE DETRIO RACHEL BIRD POLICY MANAGER DIR - POLICY & BUS. DEVELOPMENT, WEST ENGIE SERVICES BORREGO SOLAR SYSTEMS, INC TH STREET, SUITE ND STREET, SUITE 600 OAKLAND, CA OAKLAND, CA VIRGINIA VARNEY WILLIAM PLAXICO BORREGO SOLAR BORREGO SOLAR ND STREET, STE ND ST., STE. 600 OAKLAND, CA OAKLAND, CA 94612

15 Page 8 of 10 PHILLIP MULLER ANTHONY HARRISON SCD ENERGY SOLUTIONS DIR - PUBLIC POLICY 436 NOVA ALBION WAY CHARGEPOINT SAN RAFAEL, CA E. HACIENDA AVENUE CAMPBELL, CA RENEE SAMSON CHRISTOPHER DEVON DIR - UTILITY SOLUTIONS CALIFORNIA INDEPENDENT SYSTEM OPERATOR CHARGEPOINT, INC. 250 OUTCROPPING WAY 245 HACIENDA AVENUE FOLSOM, CA CAMPBELL, CA DELPHINE HOU ERIC KIM CALIF. INDEPENDENT SYSTEMS OPERATOR MARKET / INFRASTRUCTURE POLICY 250 OUTCROPPING WAY CALIFORNIA ISO FOLSOM, CA OUTCROPPING WAY FOLSOM, CA JILL POWERS JOHN GOODIN CALIFORNIA INDEPENDENT SYSTEM OPERATOR CALIFORNIA INDEPENDENT SYSTEM OPERATOR 250 OUTCROPPING WAY 250 OUTCROPPING WAY FOLSOM, CA FOLSOM, CA KIM PEREZ PETER KLAUER CALIFORNIA ISO CALIFORNIA INDEPENDENT SYSTEM OPERATOR 250 OUTCROPPING WAY 250 OUTCROPPING WAY FOLSOM, CA FOLSOM, CA LORENZO KRISTOV AUDRA HARTMANN CALIFORNIA ISO PRINCIPAL 250 OUTCROPPING WAY SMITH, WATTS & HARTMANN FOLSOM, CA L STREET, SUITE 220 SACRAMENTO, CA BRAD HEAVNER JOSEPH OMOLETSKI POLICY DIR. ASSOC. ENERGY SPECIALIST CALIFORNIA SOLAR & STORAGE ASSOCIATION CALIFORNIA ENERGY COMMISSION TH STREET, NO NINTH STREET, MS-45 SACRAMENTO, CA SACRAMENTO, CA FOR: CALIFORNIA SOLAR & STORAGE ASSOCIATION (CALSSA) F/K/A CALIFORNIA SOLAR ENERGY INDUSTRIES ASSOCIATION STEVEN KELLY LYNN HAUG POLICY DIR INDEPENDENT ENERGY PRODUCERS ASSOCIATION ELLISON SCHNEIDER HARRIS & DONLAN LLP 1215 K STREET, STE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA RONALD LIEBERT ANDREW B. BROWN AT LAW AT LAW ELLISON SCHNEIDER HARRIS & DONLAN LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVENUE, STE CAPITAL AVENUE, SUITE 400

16 Page 9 of 10 SACRAMENTO, CA SACRAMENTO, CA BRIAN S. BIERING JEDEDIAH GIBSON AT LAW ELLISON SCHNEIDER HARRIS & DONLAN LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVENUE, SUITE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA FOR: ON BEHALF OF BEAR VALLEY ELECTRIC SERVICE TAM HUNT, J.D. CATHIE ALLEN CONSULTING REGULATORY AFFAIRS MGR. COMMUNITY RENEWABLE SOLUTIONS, LLC PACIFICORP MOKU ST 825 NE MULTNOMAH ST., STE 300 PAHOA, HI PORTLAND, OR FOR: GREEN POWER INSTITUTE FOR: PACIFICORP State Service CALIFORNIA PUBLIC UTILITIES COMMISSION, CA BRIAN KORPICS INFRASTRUCTURE PLANNING AND PERMITTING B AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA CAROLYN SISTO CHLOE LUKINS PROCUREMENT STRATEGY AND OVERSIGHT BRANC ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA ROOM 4102 CHRISTOPHER PARKES DIANA L. LEE OFFICE OF THE SAFETY ADVOCATE LEGAL DIVISION AREA 2-D ROOM 4107 FOR: OSA FOREST KASER GABRIEL PETLIN PRESIDENT PICKER DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA AREA 4-A JOSEPH A. ABHULIMEN KELLY A. HYMES ENERGY SAFETY & INFRASTRUCTURE BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 4209 ROOM 5104

17 Page 10 of 10 LIAM WEAVER MARY CLAIRE EVANS ENERGY SAFETY & INFRASTRUCTURE BRANCH DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA AREA MATT MILEY OGEONYE ENYINWA LEGAL DIVISION WATER BRANCH ROOM 5135 ROOM 4108 REESE ROGERS SOPHIE MEYER INFRASTRUCTURE PLANNING AND PERMITTING B INFRASTRUCTURE PLANNING AND PERMITTING B AREA AREA TIM G. DREW ABTIN MEHRSHAHI MECHANICAL ENGINEER ENERGY SAFETY & INFRASTRUCTURE BRANCH CALIFORNIA ENERGY COMMISSION AREA 4-A 1516 STREET, MS VAN NESS AVENUE SACRAMENTO, CA SAN FRANCISCO, CA FILIBERTO A. PINEDA MINA BOTROS OFFICE OF THE SAFETY ADVOCATE ELECTRIC SAFETY AND RELIABILITY BRANCH 300 Capitol Mall 180 Promenade Circle, Suite 115 Sacramento, CA Sacramento, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS