BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U 902E) for Approval of SB 350 Transportation Electrification Proposals. A And Related Matters. A A SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) RESPONSE TO THE PUBLIC ADVOCATES OFFICE AND THE UTILITY REFORM NETWORK PETITION FOR MODIFICATION OF DECISION ANNA VALDBERG ANDREA L. TOZER Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Andrea.Tozer@sce.com Dated: December 31, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U 902E) for Approval of SB 350 Transportation Electrification Proposals. A And Related Matters. A A SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) RESPONSE TO THE PUBLIC ADVOCATES OFFICE AND THE UTILITY REFORM NETWORK PETITION FOR MODIFICATION OF DECISION I. INTRODUCTION Pursuant to Rule 16.4(f) of the California Public Utilities Commission s ( Commission s ) Rules of Practice and Procedure, Southern California Edison Company ( SCE ) submits its response to The Public Advocates Office ( CalPA ) and The Utility Reform Network ( TURN ) Petition for Modification ( PFM ) of Decision ( D. ) on the Transportation Electrification Standard Review Projects ( TE SRPs ) filed by San Diego Gas & Electric Company ( SDG&E ), Southern California Edison Company ( SCE ), and Pacific Gas and Electric Company ( PG&E ) in Application ( A. ) , A , and A

3 II. DISCUSSION The Commission reasonably concludes in D that SCE s proposed cost allocation methodology which recovers costs associated with its TE SRPs through distribution rates is just and reasonable. In their PFM, TURN and CalPA express their disagreement with the Commission, arguing that modifying D is essential due to new circumstances and events: [s]pecifically the investor-owned utilities ( IOUs ) have filed several new TE applications, which seek cost recovery through distribution rates using distribution allocation factors. 1 Notably, TURN and CalPA, do not contest the level of SCE s proposed investment which is necessary to achieve California s ambitious climate goals but instead object to the relative amount that particular customer classes should pay. TURN and CalPA s protest is unwarranted. As the Commission appropriately determined, 2 SCE s cost allocation proposal is consistent with long-standing cost-allocation ratemaking jurisprudence fundamentally rooted in cost-causation principles. 3 Nothing related to SCE s approved TE SRPs or their cost recovery has materially changed since the Commission issued D TURN and CalPA s alleged new circumstances are, in fact, unrelated to the decision the PFM seeks to modify. Further, if the Commission did wish to consider TURN and CalPA s arguments, the appropriate forum would be the General Rate Case ( GRC ) Phase 2, and not by modifying a decision in a closed proceeding. As such, the Commission should deny the PFM. 1 PFM, pp D , p. 123 ( We agree with the utilities that the costs associated with their SRPs are related to the distribution system and are appropriately recovered through distribution rates. ). 3 Testimony of Southern California Edison Company in Support of its Application for Approval of its 2017 Electrification Proposals, at pp ; available at E/A SCE-01-Various-TE%20Testimony%20Errata%20Clean%20Verison.pdf. 2

4 A. The Commission should deny the PFM as TURN and CalPA have not demonstrated why costs properly functionalized as distribution should be recovered on an equalcents-per-kwh basis. TURN and CalPA argue that D should be modified to allocate all utility TE expenditures using an equal-cents-per-kwh allocation factor, such as through a Public Purpose Programs ( PPP ) charge. 4 TURN and CalPA argue that this should be done for three reasons: (1) TE investments are not traditional distribution system assets, (2) TE programs benefit all ratepayers, so all ratepayers should pay equally for TE costs, and (3) using the equal-cents-perkwh allocation method is consistent with other utility programs that generate broad societal benefits. Although SCE agrees that TE programs benefit all ratepayers, SCE disagrees with the assertion that TE investments are not distribution system assets. Further, TURN and CalPA have not demonstrated why such costs should be recovered on an equal-cents-per-kwh basis. The costs of TE SRPs should, in fact, be recovered based on the distribution allocator because the expenditures are for distribution assets and associated labor and non-labor costs. Indeed, 71 percent 5 of the requested funding for the TE SRPs is directly related to distribution capital assets, or O&M-related costs to field and support distribution assets. SCE does agree with TURN and CalPA s assertion that TE programs benefit all ratepayers. 6 Distribution assets in general benefit all ratepayers. Nonetheless, SCE revenues are functionalized by category on a system basis, which determines the revenue allocator used. SCE expenditures are not bucketed by individual expenses pertaining to specific rate classes to create unique revenue requirements for the purposes of revenue allocation. Revenue allocation is conducted at the functionalized level prior to the rate design process, with the purpose of aligning cost recovery with the drivers of those costs. The principal of cost causation is a 4 PFM, p % is SCE s total approved spend less Transit and School Bus and DAC rebates as a ratio of total approved spend. 6 PFM, p. 2. 3

5 longstanding standard of the Commission guidance with respect to rate design. SCE does not agree that expenditures made for the benefit of all customers should be recovered in an arbitrarily different fashion that advantages one group of customers at the expense of others. The potential for such an arbitrary result (in this case, benefiting residential customers at the expense of non-residential customers), underscores the importance of utilizing consistent revenue allocations based on the functional nature of the cost items. In D , the Commission determined that SCE had properly functionalized TE-related costs in the Distribution function. 7 TURN and CalPA have not presented new information demonstrating the distribution infrastructure to be installed under the utility TE SRPs is in any way different from the infrastructure installed for other distribution-related projects involving transformation, ducts, structures, cables, and distribution-related labor. For these reasons, the Commission should deny TURN and CalPA s PFM. B. The cost drivers associated with TE investments are the same as those for traditional distribution assets. TURN and CalPA argue that distribution cost allocation is only appropriate for traditional distribution system assets driven by growth in the number of customers or increases in feeder or substation peak demands. TE investment, they argue, does not fall into this category. 8 This narrow perspective on the functionalization of TE investment is backwardlooking and fails to recognize that facilities installed for TE investment are similar to those facilities that are used to provide distribution service, for example, in typical residential developments. TURN and CalPA interpret the primary drivers of distribution marginal costs in a manner that is inconsistent with current Commission decisions. In GRC proceedings prior to the D , pp PFM, p. 8. 4

6 GRC Phase 2, SCE determined distribution marginal costs strictly on the basis of customer growth and facilities costs related to peak demand growth. However, the methodology that SCE proposed, and that was subsequently adopted, in its 2018 GRC Phase 2 included the contribution of circuit loading as a determinant of distribution peak capacity costs. By adding the element of circuit loading to marginal costs determination, SCE added a cost driver directly influenced by TE participation in Demand Response programs, and general electric vehicle charging patterns. SCE contends that TE load also has an impact on feeder and substation peak demands: in a positive direction through the use of grid management programs and practices; and in a negative direction with non-time-sensitive charging. 9 In their PFM, TURN and CalPA also fail to recognize that TE investment influences growth in the number of customers served. TURN and CalPA claim the presence of a customer growth driver in the cost element, makes distribution allocation appropriate. The cost associated with customer growth is driven by the number of existing service accounts connected to the utility, or by the number of service accounts newly connected to the utility in the test year, or over a specified period of time. Regardless of the measure used to determine growth, it is clear TE investment will create business customer and load growth. 10 TURN and CalPA even state in their pleading TE investments are meant to encourage new EV load, 11 which, in the majority of applications, translates to an increase in the number of service accounts connected to the utility by virtue of taking service on SCE s newly developed EV rates. It is evident that, even if the Commission were to agree with TURN and CalPA s definition regarding the appropriateness 9 Cost elements of non-time-sensitive charging, or grid elements, irrespective of customer or load growth components, were also adopted in SCE s GRC Phase 2 decision. See D , discussion beginning at p This increase in business customer and load growth will increase the share that business customers pay for this program over time. Contrary to the PFM s statement (p. 9) that Given the nascence of the EV market, it is too soon to tell whether there will be a correlation with customer growth or peak demand growth at the margin, while the degree of growth may be as yet unknown, incremental, or marginal, customer and load growth is all but assured. 11 PFM, p. 8. 5

7 of distribution allocation, TE investment would fall into the same category as traditional distribution system assets. C. TURN and CalPA s PFM should be considered in a General Rate Case rather than through a PFM under the Commission s rules and rate design policy. To the extent the Commission wants to consider the TURN and CalPA proposal for recovering program revenues on an equal-cents-per-kwh basis, such as through the PPP charge, the Commission should do so in SCE s 2021 GRC Phase 2 proceeding. The Commission has only recently adopted the Revenue Allocation Settlement agreement in SCE s 2018 GRC Phase 2 (D ), where parties, including TURN and CalPA, agreed to a rate group revenue allocation applicable to distribution-related costs. Parties entered into the agreement with the knowledge that distribution-related costs recovered during the attrition years would be allocated on the basis of the agreed-to, capped distribution revenue allocation factors. The settled GRC Phase 2 allocations already protect residential customers from any disproportionately high impact through the application of average rate caps and floors that limit the amount of distribution revenue allocated to each rate group. This allocation included forecasted distribution revenues and was part of the settlement agreed to by both CalPA and TURN. It would be disingenuous to all parties involved if the allocation of distribution-related costs were to change during the term of the 2018 GRC Phase 2 settlement agreement. Furthermore, addressing revenue allocation methodologies in disparate proceedings outside of a GRC Phase 2 has the potential of leading to inconsistent results across the proceedings for revenues that are functionally the same. Litigating these allocations more than once is also an inefficient use of Commission and party resources. Revenue allocation proceedings serve the purpose of consolidating multiple issues related to functionalized revenue allocation by gathering the parties most knowledgeable with these issues to argue the merits of the various proposals rather than just that subset of parties involved in this instant proceeding. Should the Commission wish to address these issues in SCE s 2021 GRC Phase 2, a more 6

8 balanced solution would likely result as that outcome would be informed by a more thorough and comprehensive review by all parties interested in and affected by TURN and CalPA s proposal. III. CONCLUSION SCE appreciates the opportunity to provide its response. For the foregoing reasons, SCE respectfully requests that the Commission deny TURN and CalPA s PFM. Respectfully submitted, ANNA VALDBERG ANDREA L. TOZER By: /s/ Andrea L. Tozer Andrea L. Tozer Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Andrea.Tozer@sce.com December 31,

9 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U 902E) for Approval of SB 350 Transportation Electrification Proposals. Application And Related Matters. Application Application CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) RESPONSE TO THE PUBLIC ADVOCATES OFFICE AND THE UTILITY REFORM NETWORK PETITION FOR MODIFICATION OF DECISION , on all parties identified on the attached service list(s) for A Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. A true copy was also sent via to the following individuals at the following addresses: Transmitting a copy via to ALJ Michelle Cooke at mlc@cpuc.ca.gov as she has requested no paper copies. Placing the copies in sealed envelopes and causing such envelopes to be delivered by U.S. Mail to the offices of the Commissioner(s) or other addressee(s). ALJ Sasha Goldberg CPUC 505 Van Ness Avenue San Francisco, CA Executed this December 31, 2018, at Rosemead, California. /s/ Kelly Morikawa Kwong Kelly Morikawa Kwong Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

10 Page 1 of 12 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A SDG&E - FOR APPROVAL FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: DECEMBER 24, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties JAY FRIEDLAND NORMAN HAJJA ZERO MOTORCYCLES RECARGO, INC., CA 00000, CA FOR: ZERO MOTORCYCLES FOR: REGARCO, INC. JOE HALSO EDWARD L. HSU ASSOCIATE SR COUNSEL SIERRA CLUB SOUTHERN CALIFORNIA GAS COMPANY 1536 WYNKOOP ST., STE WEST 5TH STREET, GT14E7 DENVER, CO LOS ANGELES, CA FOR: SIERRA CLUB FOR: SOUTHERN CALIFORNIA GAS COMPANY ADRIANO MARTINEZ THOMAS ASHLEY AT LAW SR. DIR - GOVN'T AFFAIRS & PUBLIC POLICY EARTHJUSTICE GREENLOTS 800 WILSHIRE BLVD., SUITE N. LA BREA AVE., 6TH FL LOS ANGELES, CA LOS ANGELES, CA FOR: EAST YARD COMMUNITIES FOR FOR: GREENLOTS ENVIRONMENTAL JUSTICE AND CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE KATHERINE STAINKEN MINH LE POLICY DIR. GEN. MGR. - OFFICE OF SUSTAINABILITY PLUG IN AMERICA COUNTY OF LOS ANGELES 6380 WILSHIRE BLVD., STE NORTH EASTERN AVENUE LOS ANGELES, CA LOS ANGELES, CA

11 Page 2 of 12 FOR: PLUG IN AMERICA FOR: COUNTY OF LOS ANGELES TERRY O'DAY JESSALYN ISHIGO VP ENVIRONMENTAL BUSINESS DEVELOPMENT OFF. EVGO SERVICES LLC AMERICAN HONDA MOTOR CO., INC WEST OLYMPIC BLVD 1919 TORRANCE BLVD. LOS ANGELES, CA TORRANCE, CA FOR: EVGO SERVICES LLC FOR: AMERICAN HONDA MOTOR CO., INC. MAX BAUMHEFNER WAYNE NASTRI EO - MANAGEMENT DISTRICT NATURAL RESOURCES DEFENSE COUNCIL SOUTH COAST AIR QUALITY 111 SUTTER ST., 21ST FL COPLEY DRIVE SAN FRANCISCO, CA DIAMOND BAR, CA FOR: NATURAL RESOURCES DEFENSE COUNCIL FOR: SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT ANDREA TOZER DONALD KELLY SR. EXE. DIRECTOR SOUTHERN CALIFORNIA EDISON COMPANY UTILITY CONSUMERS' ACTION NETWORK 2244 WALNUT GROVE AVE / PO BOX KENYON ST., STE. 401 ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: UTILITY CONSUMERS' ACTION NETWORK (UCAN) LISA MCGHEE DESMOND WHEATLEY OPERATIONS MGR. CEO SAN DIEGO AIRPORT PARKING CO. ENVISION SOLAR INTRERNATIONAL, INC KURTZ ST EASTGATE DRIVE SAN DIEGO, CA SAN DIEGO, CA FOR: SAN DIEGO AIRPORT PARKING COMPANY FOR: ENVISION SOLAR INTERNATIONAL, INC. JOHN W. LESLIE, ESQ JOHN A. PACHECO SR. COUNSEL DENTONS US LLP SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT., CP32, CA SAN DIEGO, CA FOR: SHELL ENERGY NORTH AMERICA (US), FOR: SAN DIEGO GAS & ELECTRIC COMPANY L.P. SACHU CONSTANTINE STEPHEN G. DAVIS DIR. OF POLICY CEO CENTER FOR SUSTAINABLE ENERGY OXYGEN INITIATIVE 9325 SKY PARK COURT, SUITE ENTERPRISE SAN DIEGO, CA ALISO VIEJO, CA FOR: CENTER FOR SUSTAINABLE ENERGY (CSE) FOR: EXYGEN INITIATIVE (FORMERLY KNGRID) MICHAEL CHIACOS TADASHI GONDAI ENERGY PROGRAM DIR. DIR OF LEGAL AFFAIRS COMMUNITY ENVIRONMENTAL COUNCIL NATIONAL ASIAN AMERICAN COALITION 26 W. ANAPAMU ST., 2ND FLR. 15 SOUTHGATE AVE., STE. 200 SANTA BARBARA, CA DALY CITY, CA FOR: COMMUNITY ENVIRONMENTAL COUNCIL FOR: THE NATIONAL ASIAN AMERICAN COALITION AND THE NATIONAL DIVERSITY COALITION

12 Page 3 of 12 DAVID SCHLOSBERG MILA A. BUCKNER DIR - ENERGY MARKET OPER EMOTORWERKS ADAMS BROADWELL JOSEPH & CARDOZO 846 BRANSTEN ROAD 601 GATEWAY BLVD., STE SAN CARLOS, CA SOUTH SAN FRANCISCO, CA FOR: ELECTRIC MOTORWERKS, INC. FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES TOVAH TRIMMING AUSTIN M. YANG DEPUTY CITY LEGAL DIVISION CITY AND COUNTY OF SAN FRANCISCO ROOM DR. CARLTON B. GOODLETT PL, RM VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CITY & COUNTY OF SAN FRANCISCO FOR: ORA ELISE TORRES JAMES BIRKELUND STAFF PRESIDENT & GEN. COUNSEL THE UTILITY REFORM NETWORK SMALL BUSINESS UTILITY ADVOCATES 785 MARKET STREET, SUITE MARKET STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: SMALL BUSINESS UTILITY ADVOCATES CHRISTOPHER WARNER LARISSA KOEHLER PACIFIC GAS AND ELECTRIC COMPANY SENIOR 77 BEALE STREET, B30A ENVIRONMENTAL DEFENSE FUND SAN FRANCISCO, CA MISSION STREET, 28TH FLOOR FOR: PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA FOR: ENVIRONMENTAL DEFENSE FUND EVELYN KAHL DANIEL ROCKEY PARTNER BUCHALTER, A PROFESSIONAL CORPORATION BRYAN CAVE LEIGHTON PAISNER LLP 55 SECOND STREET, SUITE 1700 THREE EMBARCADERO CENTER, 7TH FLOOR SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CLEAN ENERGY FUELS FOR: LYFT, INC. IRENE K. MOOSEN BEAU WHITEMAN AT LAW SR. MGR., EV INFRASTRUCTURE LAW OFFICE OF IRENE K. MOOSEN TESLA MOTORS, INC. 53 SANTA YNEZ AVENUE 3500 DEER CREEK ROAD SAN FRANCISCO, CA PALSO ALTO, CA FOR: LOCAL GOVERNMENT SUSTAINABLE FOR: TESLA, INC. ENERGY COALITION (LGSEC) CHRIS KING A J HOWARD GLOBAL CHIEF REGULATORY OFFICER OLIVINE, INC. SIEMENS SMART GIRD SOLUTIONS 2010 CROW CANYON PLACE, STE E 3RD AVE., STE. 400 SAN RAMO, CA FOSTER CITY, CA FOR: OLIVINE, INC. FOR: SIEMENS HOWARD V. GOLUB JIMMY O'DEA, PH.D

13 Page 4 of 12 VEHICLES ANALYST BEST BEST & KRIEGER LLP UNION OF CONCERNED SCIENTISTS 2001 NORTH MAIN STREET, SUITE TH STREET, STE. 340 WALNUT CREEK, CA OAKLAND, CA FOR: CITY OF LONG BEACH CALIFORNIA, A FOR: UNION OF CONCERNED SCIENTISTS MUNICIPAL CORPORATION, ACTING BY AND THROUGH ITS BOARD OF HARBOR COMMISSIONERS JOEL ESPINO ALEX MORRIS LEGAL COUNSEL SR. DIR., POLICY & REGULATORY AFFAIRS THE GREENLINING INSTITUTE CALIFORNIA ENERGY STORAGE ALLIANCE TH STREET, 2ND FL ALLSTON WAY, SUITE 210 OAKLAND, CA BERKELEY, CA FOR: THE GREENLINING INSTITUTE FOR: CALIFORNIA ENERGY STORAGE ALLIANCE (CESA) GREGORY MORRIS RYAN SCHUCHARD DIRECTOR POLICY DIR. GREEN POWER INSTITUTE CALSTART 2039 SHATTUCK AVENUE, STE CANAL BLVD., NO. G BERKELEY, CA RICHMOND, CA FOR: THE GREEN POWER INSTITUTE FOR: CALSTART CHRISTINA JAWORSKI JAMES HALL SR. ENVIRONMENTAL PLANNER GENERAL MOTORS LLC SANTA CLARA VALLEY TRANSP. AUTHORITY TH STREET 3331 NORTH FIRST ST., BLDG B-2 SACRAMENTO, CA SAN JOSE, CA FOR: GENERAL MOTORS LLC FOR: SANTA CLARA VALLEY TRANSPORTATION AUTHORITY (VTA) MICHAEL PIMENTEL SCOTT BLAISING LEGISLATIVE / REGULATORY ADVOCATE CALIFORNIA TRANSIT ASSOCIATION BRAUN BLAISING SMITH WYNNE P.C L STREET 915 L STREET, STE SACRAMENTO, CA SACRAMENTO, CA FOR: CALIFORNIA TRANSIT ASSOCIATION FOR: MARIN CLEAN ENERGY AND SONOMA CLEAN POWER SCOTT BLAISING STEVEN P. DOUGLAS COUNSEL SR. DIR - ENVIRONMENTAL AFFAIRS BRAUN BLAISING SMITH WYNNE P.C. ALLIANCE OF AUTOMOBILE MANUFACTURERS 915 L STREET, SUITE L STREET, STE SACRAMENTO, CA SACRAMENTO, CA FOR: CITY OF LANCASTER FOR: ALLIANCE OF AUTOMOBILE MANUFACTURERS TANNER KELLY LYNN HAUG DEWEY SQUARE GROUP, LLC TH STREET, SUITE 20 ELLISON SCHNEIDER HARRIS & DONLAN LLP SACRAMENTO, CA CAPITOL AVE., STE. 400 FOR: ELECTRIC VEHICLE CHARGING SACRAMENTO, CA ASSOCIATION (EVCA) FOR: CHARGEPOINT, INC.

14 Page 5 of 12 LAURA FERNANDEZ BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 915 L STREET, STE SACRAMENTO, CA FOR: SILICON VALLEY CLEAN ENERGY AUTHORITY Information Only ANGIE BOAKES BARBARA R. BARKOVICH ELECTRIC MOBILITY GENERAL MGR. CONSULTANT SHELL INT'L. PETROLEUM CO., LIMITED BARKOVICH & YAP, INC., CA 00000, CA BONNIE DATTA CASE COORDINATION SR. DIR - AMERICAS & ASIA PACIFIC PACIFIC GAS AND ELECTRIC COMPANY SIEMENS, CA 00000, CA CATHERINE BUCKLEY PACIFIC GAS AND ELECTRIC COMPANY, CA COLEY GIROUARD ASSOCIATE, PUC PROGRAM ADVANCED ENERGY ECONOMY, CA CURT BARRY DAVE PACKARD SENIOR WRITER CHARGEPOINT, INC. INSIDE WASHINGTON PUBLISHERS, CA 00000, CA DONALD LIDDELL EBCE REGULATORY DOUGLASS & LIDDELL EAST BAY COMMUNITY ENERGY, CA 00000, CA ETHAN SPRAGUE FREEWIRE TECHNOLOGIES, AA JANE KRIKORIAN SUPERVISOR, ADVOCACY & ADMINISTRATION UTILITY CONSUMERS' ACTION NETWORK, CA JOHN SAVAGE PACIFIC GAS AND ELECTRIC COMPANY, CA KAVYA BALARAMAN STAFF WRITER / REPORTER CALIFORNIA ENERGY MARKETS, CA KINSHUK CHATTERJEE CENTER FOR SUSTAINABLE ENERGY MARISSA WILLIAMS AIR POLLUTION SPECIALIST

15 Page 6 of 12, CA CALIFORNIA AIR RESOURCES BOARD, CA PAUL D. HERNANDEZ RACHEL KELLER PUBLIC POLICY & GOV. RELATIONS CASE COORDINATOR ENVOY TECHNOLOGIES INC. PACIFIC GAS AND ELECTRIC COMPLANY, CA 00000, CA REGULATORY CLERK BRAUN BLAISING SMITH WYNNE, PC, CA SAM HOUSTON CLEAN VEHICLES ANALYST UNION OF CONCERNED SCIENTISTS, CA SEPHRA NINOW TONY RAFATI ASSOCIATE DIR - REGULATORY POLICY MANAGER- CLEAN TRANSPORTATION CENTER SUSTAINABLE ENERGY SAN DIEGO GAS & ELECTRIC, CA 00000, CA MRW & ASSOCIATES, LLC DAVIS WRIGHT TREMAINE LLP, CA 00000, CA EDWARD LOVELACE, PH.D JONATHAN ARNOLD CHIEF TECHNOLOGY OFFICER DEUTSCHE BANK SECURITIES INC. XL HYBRIDS 60 WALL STREET 145 NEWTON STREET NEW YORK, NY BOSTON, MA GREGORY REISS JAMIESON WARD CENTENUS GLOBAL MANAGEMENT, LP CENTENUS GLOBAL MANAGEMENT, LP 437 MADISON AVENUE, SUITE 19B 437 MADISON AVENUE - SUITE 19B NEW YORK, NY NEW YORK, NY JOSEPH LOPES CATHERINE M. WILMARTH PRINCIPAL CONSULTANT DNV GL - ENERGY ALLIANCE OF AUTOMOBILE MANUFACTURERS 15 GLEN STREET, SUITE 201B 803 7TH ST NW, SUITE 300 GLEN COVE, NY WASHINGTON, DC FOR: ALLIANCE OF AUTOMOBILE MANUFACTURERS KAY DAVOODI LARRY ALLEN ACQ-UTILITY RATES AND STUDIES OFFICE DEPARTMENT OF THE NAVY NAVAL FACILITIES ENGINEERING COMMAND HQ 1322 PATTERSON AVE., SE STE PATTERSON AVE.,SE-BLDG. 33. STE1000 WASHINGTON, DC WASHINGTON, DC FOR: FEA FOR: FEA DAN FENG JASON SYMONDS

16 Page 7 of 12 SR. ENGINEER DNV GL DNV GL 1560 WILSON BLVD., STE WILSON BLVD., STE. 800 ARLINGTON, VA ARLINGTON, VA BLAKE ELDER MAURICE BRUBAKER CLEAN ENERGY SPECIALIST BRUBAKER AND ASSOCIATES, INC. EQ RESEARCH PO BOX HARRISON OAKS BLVD., STE. 100 ST LOUIS, MO CARY, NC JOE MOCK MEGHA LAKHCHAURA SOUTHERN CALIFORNIA GAS COMPANY DIR 555 W. FIFTH ST., GT14D6 EVBOX INC. LOS ANGELES, CA S HEWITT STREET, LACI LOS ANGELES, CA BREA CHILDS SARA GERSEN LITIGATION ASSISTANT STAFF EARTHJUSTICE EARTHJUSTICE 800 WILSHIRE BLVD., SUITE WILSHIRE BLVD., STE LOS ANGELES, CA LOS ANGELES, CA LUJUANA MEDINA CASE ADMINISTRATION REGULATORY MANAGER SOUTHERN CALIFORNIA EDISON COMPANY ENERGYRSC 2244 WALNUT GROVE AVENUE, PO BOX 800 ROSEMEAD, CA LOS ANGELES, CA CASE ADMINISTRATION ANNETTE TRAN SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY AFFAIRS 8631 RUSH STREET, GO4, 2ND FL. SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA WALNUT GROVE AVE. ROSEMEAD, CA COURTNEY COOK DAVID CROYLE PARALEGAL EXECUTIVE DIRECTOR UTILITY CONSUMERS' ACTION NETWORK UTILITY CONSUMERS' ACTION NETWORK 3405 KENYON STREET, SUITE KENYON STREET, STE. 401 SAN DIEGO, CA SAN DIEGO, CA EDWARD LOPEZ JOE KAATZ EXECUTIVE DIRECTOR STAFF UTILITY CONSUMERSâ ACTION NETWORK UNIVERSITY OF SAN DIEGO SCHOOL OF LAW 3405 KENYON ST. SUITE ALCALA PARK SAN DIEGO, CA SAN DIEGO, CA FOR: ENERGY POLICY INITIATIVES CENTER MARCIE MILNER CHRISTOPHER A. SUMMERS VP - REGULATORY AFFAIRS REGULATORY BUSINESS MGR. SHELL ENERGY NORTH AMERICA (US), L.P. SAN DIEGO GAS & ELECTRIC 4445 EASTGATE MALL, SUITE CENTURY PARK CT., CP32F SAN DIEGO, CA SAN DIEGO, CA 92123

17 Page 8 of 12 DEAN A. KINPORTS JENNIFER WRIGHT REGULATORY CASE MGR. REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA SAN DIEGO, CA RANDY SCHIMKA JEREMY WAEN SAN DIEGO GAS & ELECTRIC COMPANY MGR. - REGULATORY AFFAIRS 8674 CENTURY PARK CT, MS CP42K PENINSULA CLEAN ENERGY SAN DIEGO, CA WOODSIDE RD. REDWOOD CITY, CA SUE MARA MARC MONBOUQUETTE CONSULTANT SR.MGR - REG & GOV'T AFFAIRS RTO ADVISORS, LLC EMOTORWERKS 164 SPRINGDALE WAY 846 BRANSTEN ROAD REDWOOD CITY, CA SAN CARLOS, CA STEVE TABER MARC D. JOSEPH ENERGY MARKETS AT LAW EMOTORWERKS ADAMS, BROADWELL, JOSEPH & CARDOZO 846 BRANSTEN ROAD 601 GATEWAY BLVD., STE SAN CARLOS, CA SOUTH SAN FRANCISCO, CA FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES RACHAEL KOSS BILLY BLATTNER SAN DIEGO GAS & ELECTRIC COMPANY ADAMS BROADWELL JOSEPH & CORDOZO 601 VAN NESS AVE., STE GATEWAY BLVD., STE SAN FRANCISCO, CA SOUTH SAN FRANCISCO, CA ANTHONY MANZO DANIELLE DOOLEY LEGAL DIVISION ENERGY SAFETY & INFRASTRUCTURE BRANCH ROOM 5125 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JOSHUA HUNEYCUTT ERIC BORDEN ENERGY POLICY ANALYST PROCUREMENT STRATEGY AND OVERSIGHT BRANC THE UTILITY REFORM NETWORK AREA 785 MARKET STREET, STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MARCEL HAWIGER MILES MULLER LEGAL FELLOW THE UTILITY REFORM NETWORK NATURAL RESOURCES DEFENSE COUNCIL 785 MARKET STREET, SUITE SUTTER STREET, 21ST FL. SAN FRANCISCO, CA SAN FRANCISCO, CA BUCHALTER DOCKET JOHANNA FORS

18 Page 9 of 12 BUCHALTER REGULATORY AFFAIRS 55 SECOND STREET, SUITE 1700 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE STREET, B10A SAN FRANCISCO, CA KAREN SHEA LISA M. RAYMOND CASE MGR., CUSTOMER PROGRAM BUCHALTER PACIFIC GAS AND ELECTRIC COMPANY 55 SECOND STREET, SUITE BEALE STREET, B9A SAN FRANCISCO, CA SAN FRANCISCO, CA MICHAEL ALCANTAR MIKE CADE AT LAW BUCHALTER, A PROFESSIONAL CORPORATION BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, SUITE SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA BUCHALTER, A PROFESSIONAL CORPORATION LILLIAN RAFII 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, STE SAN FRANCISCO, CA FRANCESCA WAHL ADENIKE ADEYEYE SR. POLICY ASSOCIATE, BUS. DEVELOPMENT SR. RESEARCH & POLICY ANALYST TESLA, INC. EARTHJUSTICE 444 DE HARO STREET, STE CALIFORNIA ST., STE. 500 SAN FRANCISCO, CA SAN FRANCISCO, CA MALOU SANA PAUL R. CORT BRYAN CAVE LLP EARTHJUSTICE THREE EMBARCADERO CENTER, 7TH FLOOR 50 CALIFORNIA ST., STE. 500 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: LYFT, INC. THOMAS W. SOLOMON EMILY P. SANGI AT LAW WINSTON & STRAWN LLP DAVIS WRIGHT TREMAINE LLP 101 CALIFORNIA STREET 505 MONTGOMERY ST., STE. 800 SAN FRANCISCO, CA SAN FRANCISCO, CA RACHELLE CHONG RITA LIOTTA COUNSEL FEDERAL EXECUTIVE AGENCIES LAW OFFICES OF RACHELLE CHONG 1 AVENUE OF THE PALMS, STE WEST PORTAL AVENUE, STE. 110 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: FEA SARAH VAN CLEVE HOWARD V. GOLUB ENERGY POLICY ADVISOR BEST BEST & KRIEGER LLP TESLA, INC NORTH MAIN STREET, SUITE DEER CREEK ROAD WALNUT CREEK, CA PALO ALTO, CA FOR: CITY OF OAKLAND, CALIFORNIA, A MUNICIPAL CORPORATION, ACTING BY AND THROUGH ITS BOARD OF PORT OF HARBOR

19 Page 10 of 12 COMMISSIONERS DONNELL CHOY MELISSA BRANDT DEPUTY PORT SR. DIR - PUBLIC AFFAIRS & GEN. COUNSEL PORT OF OAKLAND EAST BAY COMMUNITY ENERGY 530 WATER STREET, 4TH FL BROADWAY, STE 3000 OAKLAND, CA OAKLAND, CA PAUL D. HERNANDEZ RACHEL GOLDEN POLICY MGR. SR. CAMPAIGN REP. CENTER FOR SUSTAINABLE ENERGY SIERRA CLUB TH STREET, STE WEBSTER, STE OAKLAND, CA OAKLAND, CA DAVID MARCUS TAM HUNT 1541 JUANITA WAY CONSULTING BERKELEY, CA SHATTUCK AVENUE, SUITE 402 FOR: COALITION OF CALIFORNIA UTILITY BERKELEY, CA EMPLOYEES FOR: THE GREEN POWER INSTITUTE C. C. SONG PHILLIP MULLER REGULATORY ANALYST SCD ENERGY SOLUTIONS MARIN CLEAN ENERGY 436 NOVA ALBION WAY 1125 TAMALPAIS AVE. SAN RAFAEL, CA SAN RAFAEL, CA FOR: MCE JOHN NIMMONS ANNE SMART COUNSEL VP, PUBLIC POLICY JOHN NIMMONS & ASSOCIATES, INC. CHARGEPOINT, INC. 175 ELINOR AVE., STE. G 254 EAST HACIENDA AVENUE MILL VALLEY, CA CAMPBELL, CA ANTHONY HARRISON NEWONDA NICHOLS DIR - PUBLIC POLICY PROGRAM MGR., UTILITY SOLUTIONS CHARGEPOINT CHARGEPOINT, INC. 254 E. HACIENDA AVENUE 254 EAST HACIENDA AVE. CAMPBELL, CA CAMPBELL, CA RENEE SAMSON ART DOUWES DIR - UTILITY SOLUTIONS OPERATIONS MGR. CHARGEPOINT, INC. VTA BUS MAINTENANCE ENGINEERING 245 HACIENDA AVENUE 3331 NORTH FIRST STREET, BUILDING B-1 CAMPBELL, CA SAN JOSE, CA JAMES WILHELM STEVEN S. SHUPE SR. MECHANICAL ENGINEER GENERAL COUNSEL VTA BUS MAINTENANCE ENGINEERING SONOMA CLEAN POWER AUTHORITY 3331 NORTH FIRST STREET, BUILDING B-1 50 SANTA ROSA AVE., 5TH FL. SAN JOSE, CA SANTA ROSA, CA AUDRA HARTMANN PRINCIPAL DELANEY L. HUNTER MANAGING PARTNER

20 Page 11 of 12 SMITH, WATTS & HARTMANN GONZALEZ, QUINTANA, HUNTER & CRUZ, LLC 925 L STREET, SUITE L STREET, STE SACRAMENTO, CA SACRAMENTO, CA FOR: SANTA CLARA VALLEY TRANSPORTATION AUTHORITY JOHN SHEARS ANDREW B. BROWN RENEWABLE TECHNOLOGIES THE CENTER FOR ENERGY EFFICIENCY AND ELLISON SCHNEIDER HARRIS & DONLAN LLP TH ST., SUTE CAPITOL AVE., STE. 400 SACRAMENTO, CA SACRAMENTO, CA FOR: CEERT RONALD LIEBERT CATHIE ALLEN AT LAW DIR - REGULATORY AFFAIRS ELLISON SCHNEIDER HARRIS & DONLAN LLP PACIFICORP 2600 CAPITOL AVENUE, STE NE MULTNOMAH ST., STE 300 SACRAMENTO, CA PORTLAND, OR ELI MORRIS ETTA LOCKEY PACIFICORP SR. COUNSEL 825 NE MULTNOMAH, STE PACIFICORP PORTLAND, OR NE MULTNOMAH ST., STE PORTLAND, OR State Service MATTHEW WILLIAMS MICHELLE COOKE AIR POLLUTION SPECIALIST ADMINISTRATIVE LAW JUDGE CALIFORNIA AIR RESOURCES BOARD CALIFORNIA PUBLIC UTILITIES COMMISSION, CA 00000, CA ALAN BACH AUDREY NEUMAN ENERGY SAFETY & INFRASTRUCTURE BRANCH PROCUREMENT STRATEGY AND OVERSIGHT BRANC AREA ROOM 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA BENJAMIN GUTIERREZ CAROLYN SISTO ELECTRICITY PRICING AND CUSTOMER PROGRAM PROCUREMENT STRATEGY AND OVERSIGHT BRANC AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA CHLOE LUKINS DAVID PECK ENERGY SAFETY & INFRASTRUCTURE BRANCH PRESIDENT PICKER ROOM 4102 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA

21 Page 12 of 12 FOR: ORA FIDEL LEON DIAZ JENNIFER KALAFUT ENERGY SAFETY & INFRASTRUCTURE BRANCH COMMISSIONER PETERMAN AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JOSEPH A. ABHULIMEN JUNAID RAHMAN ENERGY SAFETY & INFRASTRUCTURE BRANCH RISK ASSESSMENT AND ENFORCEMENT ROOM 4209 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA LIAM WEAVER NATHAN CHAU ENERGY SAFETY & INFRASTRUCTURE BRANCH ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA RICK TSE SARA M. KAMINS ELECTRIC SAFETY AND RELIABILITY BRANCH PROCUREMENT STRATEGY AND OVERSIGHT BRANC AREA 2-D AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA SASHA GOLDBERG TIM G. DREW DIVISION OF ADMINISTRATIVE LAW JUDGES ENERGY SAFETY & INFRASTRUCTURE BRANCH ROOM 5021 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA NOEL CRISOSTOMO AIR POLUTION SPECIALIST CALIFORNIA ENERGY COMMISSION TH STREET SACRAMENTO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS