BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF ... · Allocate Revenues, Design Rates....

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) to Establish Marginal Costs, Allocate Revenues, Design Rates.

A.17-06-030

(Filed June 30, 2017)

SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) LATE-FILED NOTICE

OF EX PARTE COMMUNICATION

FADIA R. KHOURY RUSSELL A. ARCHER

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-2865 Facsimile: (626) 302-3990 E-mail: [email protected]

Dated: April 16, 2018

1


STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) to Establish Marginal Costs, Allocate Revenues, Design Rates.

A.17-06-030


SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) LATE-FILED NOTICE

OF EX PARTE COMMUNICATION

Pursuant to Rule 8.4(a) of the Rules of Practice and Procedure of the California Public

Utilities Commission (Commission), Southern California Edison Company (SCE) hereby gives

notice of the following notice of ex parte communication. The communication occurred on

Tuesday, April 10, 2018, at 11:30 a.m. at the offices of the Commission located at 505 Van Ness

Avenue, San Francisco, California. The communication was oral and lasted approximately 30

minutes. The attached written materials were also distributed during the meeting.

Southern California Edison Company (SCE) initiated the communication with Maria

Sotero, advisor to Commissioner Martha Guzman-Aceves. Attending the meeting for SCE were

Laura Genao, SCE’s Managing Director of Regulatory Affairs (in person), and Russell

Garwacki, Director of Pricing, Design and Research (telephonically). ///

///

///

2

SCE’s representatives discussed SCE’s proposed TOU periods, specifically noting that

SCE’s proposed TOU periods align with the state’s GHG goals and previous CPUC direction on

TOU periods, and that an expeditious decision in SCE’s pending Rate Design Window

proceeding (A.16-09-003) is necessary in order to enable the implementation of the proposed

TOU periods.

SCE is filing this notice in this docket due to a statement set forth on slide 6 of the

written materials used during the meeting and attached hereto as Exhibit A.

Respectfully submitted, FADIA R. KHOURY RUSSELL A. ARCHER

/s/ Russell A. Archer By: Russell A. Archer

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-2865 Facsimile: (626) 302-3990 E-mail: [email protected]

April 16, 2018

Exhibit A

SCE’s Proposed TOU Periods

SCE’s Proposed TOU Periods(2016 Rate Design Window - A.16-09-003)

April 2018

Ex A-1

Objectives

• Describe how SCE’s proposed TOU periods align with California’s GHG- reduction goals and previous Commission directives on establishingTOU periods

• Emphasize the need for an expeditious decision that is consistent withSCE’s proposal

2

Ex A-2

SCE’s TOU Period Proposal Aligns with California’s GHG-Reduction Goals and CPUC Directives

• Appropriately set TOU periods support cost-effective long-term investment in the decarbonization¹ ofCalifornia’s electric system by providing accurate price signals to both customers (usage) and DERproviders (supply)

• In D.17-01-006 (TOU OIR decision), the Commission established that TOU periods should be basedprimarily on utility-specific marginal costs, and be sufficiently forward-looking to promote stabilitywhile allowing considerations for customer acceptability²

3

¹California’s GHG goals call for a 40 percent reduction in GHG emissions from 1990 levels by 2030 and an 80 percent reduction by 2050.²See Policy Guideline Nos. 2, 4, 5 and 9 in D.17-01-006.

SCE’s TOU period proposal achieves these objectives

� Proposed TOU periods are based on SCE-specific marginal costs

� Forward-looking use of 2024 data supports both TOU period stability and accurate price signals

for customers and DER providers considering long-term investments that support

decarbonization (e.g., storage, EVs)

� Introduction of an extended super-off-peak (SOP) period helps address the curtailment of

renewables (duck curve), as recognized by CAISO’s recommendations, and decarbonization

goals by providing a price signal to users and suppliers that is both actionable and stable

• As opposed to a more limited overlay (3rd season) or event-based program

� Consistent TOU periods across the year and the continuation of SCE’s existing two-season

structure facilitate customer understanding and acceptance

Ex A-3

SCE’s TOU Period Proposal Addresses the CAISO Duck Curve Issues and Had the Broadest Level of Support Across Parties¹

• SCE’s proposal differs from the CAISO’s recommendation primarily regarding a potential short springseason (3rd season) in March and April

• The distinction between March/April and other winter season months may be shrinking as it is largelydependent on yearly hydro availability

• The implementation of a spring season that forward-looking cost data doesn’t support increases thelikelihood of more frequent TOU period changes

• SCE’s recommendation of a two-season structure was shared by all parties,² and SCE has already defaultednearly 400,000 residential customers onto rates consistent with our RDW proposal

4

¹SCE’s proposed TOU periods were generally supported or not opposed by CLECA, CMTA, SBUA, CFBF and AECA. ORA concurred with SCE’s seasonal definition with a one-hour difference in the peak period definition (i.e. 3-8 pm instead of 4-9 pm) while EUF recommended a 5-10 pm peak period.²Certain parties recommended that different months comprise the two seasons, but still only proposed two seasons.

• Thus far in 2018, pricing across January through March in the proposed Super Off-Peak period is fairly consistent.

Proposed Super Off-Peak Period

Ex A-4

The Implementation of SCE’s Customer Service / Billing System (CSRP) Impacts SCE’s Ability to Make Significant Changes to Its TOU Period Proposals

• SCE has repeatedly informed the Commission about SCE’s Customer Service Re-Platform (CSRP) efforts and the associated timing and implementation constraints

• SCE agreed to consolidate its updated TOU period implementation with its 2018 GRC Phase 2 implementation (proposed for Q1 2019) per the request of parties, which effectively delayed the implementation of the new TOU periods until 2019

• Given that the decision in the RDW is still pending, any deviation from SCE’s TOU period proposal cannot be implemented until after CSRP is deployed – which could result in an over two-year delay in providing proper price signals to customers and DER developers, exacerbating the State’s duck curve issues

5

Ex A-5

6

• No need for 100% TOU consistency across IOUs. The TOU-OIR decision provided latitude for the TOU periods to vary across IOUs.

� PG&E’s proposed peak periods are later than ours by an hour because they are further west than SCE.

� SDG&E has a significantly higher percentage of residential load than SCE.

• There ought to be consistency across customer groups within the same IOU jurisdiction to maximize customer understanding.

• The CPUC has already approved our Residential Pilot Default TOU rate structures and SCE has already migrated nearly 400,000 residential customers onto TOU rates that align with the proposals made in our RDW application.

� The only difference is that ½ of the residential customers were defaulted onto a narrower 5-8 pm peak period instead of a 4-9 pm peak period, otherwise the seasons and day type structures are the same.

• Other parties have already filed testimony in our 2018 GRC Phase 2 (A.17-06-030) and SCE has already begun Settlement discussions under the presumption that our proposed TOU periods will be adopted.

Final Comments

Ex A-6

Appendix

Ex A-7

CAISO and SCE Proposals

8

1a 2a 3a 4a 5a 6a 7a 8a 9a 10a 11a 12a 1p 2p 3p 4p 5p 6p 7p 8p 9p 10p 11p 12p

Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

SepOctNovDec

1a 2a 3a 4a 5a 6a 7a 8a 9a 10a 11a 12a 1p 2p 3p 4p 5p 6p 7p 8p 9p 10p 11p 12pJanFebMarAprMayJun

Jul

Aug

SepOctNovDec

On-Peak* WWeekdays WeekendsMid-Peak* Summer: Jul-Aug Summer: Jul-AugOff-Peak Winter: Sept-Feb, May-Jun Winter: Sept-JunSuper-Off-Peak Spring: Mar-Apr

*On-Peak period is labeled "Super-Peak" and Mid-Peak period is labeled "On-Peak" by CAISO

Off-Peak9pm-Noon

Off-Peak9pm-NoonSu

mm

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inte

r

Off-Peak9pm-4pm

Sum

mer

Weekends

Mid-Peak4pm-9pm

Off-Peak9pm-10am

Off-Peak9pm-10am

Super-Off-Peak10am-4pm

Off-Peak9pm-10am


Off-Peak9pm-Noon

Mid-PeakNoon-4pm

On-Peak4pm-9pm

Off-Peak9pm-Noon

Win

ter

Mid-Peak4pm-9pm

Weekdays

Off-Peak9pm-4pm

Mid-Peak4pm-9pm

Off-Peak9pm-4pm

Spri

ngW

inte

rW

inte

r

Mid-Peak4pm-9pm

Off-Peak9pm-4pm

Off-Peak9pm-4pm


Mid-Peak4pm-9pm

Off-Peak9pm-10am

Off-Peak9pm-10am

Off-Peak9pm-10am

Win

ter

Mid-Peak4pm-9pm

Off-Peak9pm-4pm

Mid-PeakNoon-4pm

On-Peak4pm-9pm

1a 2a 3a 4a 5a 6a 7a 8a 9a 10a 11a 12a 1p 2p 3p 4p 5p 6p 7p 8p 9p 10p 11p 12pJanFebMarAprMayJunJul

AugSepOctNovDec

1a 2a 3a 4a 5a 6a 7a 8a 9a 10a 11a 12a 1p 2p 3p 4p 5p 6p 7p 8p 9p 10p 11p 12pJanFebMarAprMayJunJul

AugSepOctNovDec

On-Peak WWeekdays/WeekendsMid-Peak Summer: Jun-SeptOff-Peak Winter: Oct-MaySuper-Off-Peak

Mid-Peak4pm-9pm

Win

ter

Off-Peak9pm-8am


Mid-Peak4pm-9pm

Win

ter

Off-Peak9pm-8am


Mid-Peak4pm-9pm

Off-Peak9pm-8am

Sum

mer

Off-Peak9pm-4pm

Mid-Peak4p-9p

Off-Peak9pm-4pm

Weekdays

Off-Peak9pm-8am

Sum

mer

Off-Peak9pm-4pm

On-Peak4pm-9pm

Off-Peak9pm-4pm

Weekends

Win

ter

Off-Peak9pm-8am


Win

ter

Off-Peak9pm-8am


Mid-Peak4pm-9pm

Off-Peak9pm-8am

Off-Peak9pm-8am

SCE:CAISO:

Ex A-8

CAISO and SEIA Proposals

9

1a 2a 3a 4a 5a 6a 7a 8a 9a 10a 11a 12a 1p 2p 3p 4p 5p 6p 7p 8p 9p 10p 11p 12p

Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

SepOctNovDec

1a 2a 3a 4a 5a 6a 7a 8a 9a 10a 11a 12a 1p 2p 3p 4p 5p 6p 7p 8p 9p 10p 11p 12pJanFebMarAprMayJun

Jul

Aug

SepOctNovDec

On-Peak* WWeekdays WeekendsMid-Peak* Summer: Jul-Aug Summer: Jul-AugOff-Peak Winter: Sept-Feb, May-Jun Winter: Sept-JunSuper-Off-Peak Spring: Mar-Apr

*On-Peak period is labeled "Super-Peak" and Mid-Peak period is labeled "On-Peak" by CAISO

Off-Peak9pm-Noon

Off-Peak9pm-NoonSu

mm

erW

inte

r

Off-Peak9pm-4pm

Sum

mer

Weekends

Mid-Peak4pm-9pm

Off-Peak9pm-10am

Off-Peak9pm-10am


Off-Peak9pm-10am


Off-Peak9pm-Noon

Mid-PeakNoon-4pm

On-Peak4pm-9pm

Off-Peak9pm-Noon

Win

ter

Mid-Peak4pm-9pm

Weekdays

Off-Peak9pm-4pm

Mid-Peak4pm-9pm

Off-Peak9pm-4pm

Spri

ngW

inte

rW

inte

r

Mid-Peak4pm-9pm

Off-Peak9pm-4pm

Off-Peak9pm-4pm


Mid-Peak4pm-9pm

Off-Peak9pm-10am

Off-Peak9pm-10am

Off-Peak9pm-10am

Win

ter

Mid-Peak4pm-9pm

Off-Peak9pm-4pm

Mid-PeakNoon-4pm

On-Peak4pm-9pm

SEIA:CAISO:

Ex A-9


STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) to Establish Marginal Costs, Allocate Revenues, and Design Rates.

A.17-06-030


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) LATE-FILED NOTICE OF EX PARTE COMMUNICATION on all parties identified on the attached service list(s) A.17-06-030. Service was effected by transmitting the copies via e-mail to ALJ Cooke and all parties who have provided an e-mail address, including those listed below.

Maria Sotera: Advisor to Commissioner Martha Guzman-Aceves

[email protected]

Commissioner Martha Guzman-Aceves [email protected]

Executed this April 16, 2018, at Rosemead, California.

/s/ Edith Leon________________ Edith Leon Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

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PROCEEDING: A1706030 - EDISON - TO ESTABLIS FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: APRIL 12, 2018

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Parties

MAX BAUMHEFNER DANIEL W. DOUGLASS NATURAL RESOURCES DEFENSE COUNCIL ATTORNEY EMAIL ONLY DOUGLASS & LIDDELL EMAIL ONLY, CA 00000 4766 PARK GRANADA, STE. 209 FOR: NATURAL RESOURCES DEFENSE COUNCIL CALABASAS, CA 91302 FOR: ALLIANCE FOR RETAIL ENERGY MARKETS AND DIRECT ACCESS CUSTOMER COALITION

JANE LEE COLE, ESQ. VANESSA YOUNG SR. ATTORNEY CALIF PUBLIC UTILITIES COMMISSION SOUTHERN CALIFORNIA EDISON COMPANY LEGAL DIVISION 2244 WALNUT GROVE AVE. / PO BOX 800 ROOM 4107 ROSEMEAD, CA 91770 505 VAN NESS AVENUE FOR: SOUTHERN CALIFORNIA EDISON COMPANY SAN FRANCISCO, CA 94102-3214 (SCE) FOR: ORA

HAYLEY GOODSON RITA M. LIOTTA STAFF ATTORNEY COUNSEL - DEPT OF THE NAVY THE UTILITY REFORM NETWORK FEDERAL EXECUTIVE AGENCIES 785 MARKET ST., STE. 1400 NAVAL FACILITIES ENGINEERING COMMAND SAN FRANCISCO, CA 94103 1 AVENUE OF THE PALMS, STE. 161 FOR: TURN SAN FRANCISCO, CA 94103 FOR: FEDERAL EXECUTIVE AGENCIES (FEA)

JAMES BIRKELUND EVELYN KAHL PRESIDENT BUCHALTER, A PROFESSIONAL CORPORATION SMALL BUSINESS UTILITY ADVOCATES 55 SECOND STREET, SUITE 1700 548 MARKET STREET, SUITE 11200 SAN FRANCISCO, CA 94105

Page 1 of 6CPUC - Service Lists - A1706030

4/16/2018https://ia.cpuc.ca.gov/servicelists/A1706030_84550.htm

SAN FRANCISCO, CA 94104 FOR: ENERGY PRODUCERS AND USERS FOR: SMALL BUSINESS UTILITY ADVOCATES COALITION (EPUC) (SBUA)

NORA E. SHERIFF EDWARD G. POOLE ATTORNEY ATTORNEY AT LAW BUCHALTER, A PROFESSIONAL CORPORATION ANDERSON, DONOVAN & POOLE 55 SECOND STREET, SUITE 1700 601 CALIFORNIA STREET, SUITE 1300 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94108-2818 FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: WESTERN MANUFACTURED HOUSING COMM. ASSOCIATION ASSOC.

JEANNE B. ARMSTRONG DANIEL DENEBEIM ATTORNEY ATTORNEY AT LAW GOODIN MACBRIDE SQUERI & DAY LLP CALIF. CITY COUNTY STREET LIGHT ASSOC. 505 SANSOME STREET, SUITE 900 825 SAN ANTONIO ROAD, SUITE 109 SAN FRANCISCO, CA 94111 PALO ALTO, CA 94303-4620 FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION FOR: CALIFORNIA STREET LIGHT ASSOC.

CAROLYN KEHREIN BRAD HEAVNER PRINCIPAL POLICY DIR. ENERGY MANAGEMENT SERVICES CALIFORNIA SOLAR & STORAGE ASSOCIATION 2602 CELEBRATION WAY 1107 9TH STREET, NO.820 WOODLAND, CA 95776 SACRAMENTO, CA 95814 FOR: ENERGY USERS FORUM FOR: CALIFORNIA SOLAR & STORAGE ASSOCIATION (CALSSA) F/K/A CALIFORNIA SOLAR ENERGY INDUSTRIES ASSOC. (CALSEIA)

LAURA TAYLOR MICHAEL BOCCADORO ATTORNEY PRESIDENT BRAUN BLAISING SMITH WYNNE, P.C. WEST COAST ADVISORS 915 L STREET, STE. 1480 925 L STREET, SUITE 800 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: COALITION FOR AFFORDABLE STREET FOR: AGRICULTURAL ENERGY CONSUMERS LIGHTS ( CASL) ASSOCIATION (AECA)

SCOTT BLAISING SCOTT BLAISING COUNSEL BRAUN BLAISING SMITH WYNNE P.C. BRAUN BLAISING SMITH WYNNE P.C. 915 L STREET, SUITE 1480 915 L STREET, SUITE 1480 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CITY OF LANCASTER FOR: CALIFORNIA CHOICE ENERGY AUTHORITY

ROBERT LIEBERT KAREN NORENE MILLS ATTORNEY ATTORNEY ELLISON SCHNEIDER HARRIS & DONLAN LLP CALIFORNIA FARM BUREAU FEDERATION 2600 CAPITOL AVENUE, SUITE 400 2300 RIVER PLAZA DRIVE SACRAMENTO, CA 95816 SACRAMENTO, CA 95833 FOR: CALIFORNIA MANUFACTURERS & FOR: CALIFORNIA FARM BUREAU FEDERATION TECHNOLOGY ASSOCIATION (CMTA)

Information Only



PAUL NELSON REGULATORY CLERK BARKOVICH & YAP BRAUN BLAISING SMITH WYNNE, PC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION

RICK UMOFF MRW & ASSOCIATES, LLC COUNSEL & DIR - STATE AFFAIRS EMAIL ONLY SOLAR ENERGY INDUSTRIES ASSOCIATION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

BRANDON SMITHWOOD KAY DAVOODI MGR - CALIF STATE AFFAIRS UTILITY RATES & STUDIES OFFICE - US NAVY SOLAR ENERGY INDUSTRIES ASSOCIATION 1322 PATTERSON AVE SE SUITE 1000 600 14TH STREET, NW, SUITE 400 WASHINGTON, DC 20374 WASHINGTON, DC 20005 FOR: FEA

LARRY ALLEN BLAKE ELDER UTILITY RATES & STUDIES OFFICE - US NAVY CLEAN ENERGY SPECIALIST 1322 PATTERSON AVE SE SUITE 1000 EQ RESEARCH WASHINGTON, CA 20374 401 HARRISON OAKS BLVD., STE. 100 FOR: FEA CARY, NC 27513

MAURICE BRUBAKER HUY TRAN BRUBAKER & ASSOCIATES, INC. (BAI BRUBAKER & ASSOCIATES (FEA) PO BOX 412000 PO BOX 412000 ST LOUIS, MO 63141 ST. LOUIS, MO 63141-2000 FOR: FEA

CASE ADMINISTRATION ERIN PULGAR SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 8631 RUSH STREET 2244 WALNUT GROVE AVE. ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

FADIA RAFEEDIE KHOURY RAQUEL IPPOLITI DIR & MANAGING ATTORNEY PROJECT ANALYST SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. G.O.1, RM. 348H 2244 WANUT GROVE AVENUE ROSEMEAD, CA 91770 ROSEMED, CA 91770

RUSSELL A. ARCHER WALKER A. MATTHEWS III SR. ATTORNEY SENIOR ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. / PO BOX 800 2244 WALNUT GROVE AVENUE, ROOM 390 ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

DAVID CHENG MICHAEL BROWN STAFF ATTORNEY CONSULTANT THE UTILITY REFORM NETWORK EHRLICH â€¢ PLEDGER LAW, LLP 1620 5TH AVENUE, SUITE 810 CALIFORNIA PLAZA SAN DIEGO, CA 92101 5001 CALIFORNIA AVENUE, SUITE 223 BAKERSFIELD, CA 93309-0733



FOR: SMALL BUSINESS UTILITY ADVOCATES (SBUA)

SUE MARA LILLIAN RAFII CONSULTANT REGULATORY ATTORNEY RTO ADVISORS, LLC SMALL BUSINESS UTILITY ADVOCATES 164 SPRINGDALE WAY 548 MARKET ST. SUITE 11200 REDWOOD CITY, CA 94062 SAN FRANCISCO, CA 94104

KATHERINE MORSONY MICHAEL ALCANTAR ATTORNEY ATTORNEY AT LAW BUCHALTER, A PROFESSIONAL CORPORATION BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, SUITE 1700 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: ENERGY PRODUCERS AND USERS COALITION (EPUC)

MIKE CADE BUCHALTER, A PROFESSIONAL CORPORATION BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, SUITE 1700 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

BUCK ENDEMANN MARC KOLB ATTORNEY TESLA, INC. K&L GATES, LLP 3055 CLEARVIEW WAY FOUR EMBARCADERO, STE 1200 SAN MATEO, CA 94402 SAN FRANCISCO, CA 94111

ALISON LECHOWICZ BARBARA R. BARKOVICH PRINCIPAL CONSULTANT LECHOWICZ & TSENG MUNICIPAL CONSULTANTS BARKOVICH & YAP, INC. PO BOX 3065 PO BOX 11031 OAKLAND, CA 94609 OAKLAND, CA 94611 FOR: CALIFORNIA STREETLIGHT ASSOC. FOR: CLECA

CATHY YAP RACHEL BIRD BARKOVICH & YAP, INC. DIR - POLICY & BUS. DEVELOPMENT, WEST PO BOX 11031 BORREGO SOLAR SYSTEMS, INC. OAKLAND, CA 94611 360 22ND STREET, SUITE 600 FOR: CLECA OAKLAND, CA 94612

R. THOMAS BEACH PHILLIP MULLER PRINCIPAL CONSULTANT PRESIDENT CROSSBORDER ENERGY SCD ENERGY SOLUTIONS 2560 9TH ST., SUITE 213A 436 NOVA ALBION WAY BERKELEY, CA 94710-2557 SAN RAFAEL, CA 94903 FOR: SOLAR ENERGY INDUSTRIES ASSOC

WILLIAM MARCUS BETH OLHASSO MCPM ECONOMICS WEST COAST ADVISORS 618 COURT ST., STE. C 925 L STREET, SUITE 800 WOODLAND, CA 95695 SACRAMENTO, CA 95814



ANN L. TROWBRIDGE ANNE FALCON ATTORNEY SR. ASSOCIATE DAY CARTER & MURPHY LLP EES CONSULTING, INC. 3620 AMERICAN RIVER DR., STE. 205 570 KIRKLAND WAY, NO. 100 SACRAMENTO, CA 95864 KIRKLAND, CA 98033 FOR: AGRICULTURAL ENERGY CONSUMERS ASSOCIATION (AECA)

State Service

MICHELLE COOKE BENJAMIN GUTIERREZ ADMINISTRATIVE LAW JUDGE CALIF PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM EMAIL ONLY AREA EMAIL ONLY, CA 00000 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

CHRISTOPHER HOGAN DEXTER E. KHOURY CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM 4209 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

EHREN SEYBERT ERIC DURAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER PETERMAN ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5303 ROOM 4011 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JUSTIN H. FONG LEE-WHEI TAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM 4102 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

LOUIS M. IRWIN MASOUD FOUDEH CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM DEMAND RESPONSE, CUSTOMER GENERATION, AN ROOM 4209 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

MATTHEW A. KARLE NATHAN CHAU CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4108 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

PAUL S. PHILLIPS ROBERT LEVIN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION



DEMAND RESPONSE, CUSTOMER GENERATION, AN ENERGY DIVISION AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

BRIDGET SIEREN-SMITH CALIF PUBLIC UTILITIES COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN 180 Promenade Circle, Suite 115 Sacramento, CA 95834

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