BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF ...liob.cpuc.ca.gov/docs/Reply Comments of...

March 28, 2005

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

REPLY COMMENTS OF SOUTHERN CALIFORNIA GAS COMPANY (U 904 G) TO COMMENTS OF THE EAST LOS ANGELES COMMUNITY UNION AND THE MARAVILLA FOUNDATION ON THE STANDARDIZATION PROJECT TEAM'S

PROPOSED REVISIONS TO THE LIEE PROGRAM POLICY AND PROCEDURES AND WEATHERIZATION INSTALLATION STANDARDS MANUALS

Georgetta J. Baker Attorney for Southern California Gas Company 101 Ash Street HQ13 San Diego, CA. 92101 Phone: (619) 699-5064 Fax:

(619) 699-5027 E-mail : [email protected]

Order Instituting Rulemaking on the R 04-01-006, A. 04-06-038 ; A . 04-07-002 ; Commission's Proposed Policies and Programs Governing Post-2003 Low Income A. 04-07-010 ; A. 04-07-011 ; A . 04-07-012 ;

Assistance Programs . A. 04-07-013 ; A. 04-07-014 ; A . 0407015 ;

A . 04-07-020 ; A. 04-07-027 ; A . 0407050

I . Introduction

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

REPLY COMMENTS OF SOUTHERN CALIFORNIA GAS COMPANY (U 904 G) TO COMMENTS OF THE EAST LOS ANGELES COMMUNITY UNION AND THE MARAVILLA FOUNDATION ON THE STANDARDIZATION PROJECT TEAM'S PROPOSED REVISIONS TO THE LIEE PROGRAM POLICY AND PROCEDURES

AND WEATHERIZATION INSTALLATION STANDARDS MANUALS

Pursuant to "Administrative Law Judge's Ruling Regarding Revisions to Low-

Income Energy Efficiency Program and Policy Manual and Weatherization Installation

Standards Manual," dated February 11, 2005 ("February Ruling"), Southern California

Gas Company ("SoCaIGas") responds to the above-referenced comments that the East

Los Angeles Community Union and the Maravilla Foundation ("Maravilla") (collectively,

"TELACU"), filed herein on March 14, 2005.' Since Commissioner Grueneich's Ruling of

March 25, 2005,2 directs the Standardization Team to withdraw its recommendations

and take further steps to seek public input, SoCaIGas here provides this response only

to the assertions that TELACU made that are specific to SoCaIGas' DAP program.

Specifically, SoCaIGas responds to TELACU's incorrect assertions that : (1)

changes made in 2004 to SoCaIGas' Direct Assistance Program ("DAP") relative to

Pursuant to the Assigned Commissioner's Ruling Approving a Work plan, Budget and Schedule for Phase 5 of the Low Income Energy Efficiency (LIEE) Standardization Project, dated October 22, 2004, as extended by the Executive Director, San Diego Gas & Electric Company ("SDG&E"), on behalf of the LIEE Standardization Project Team, ("Standardization Team") filed proposed revisions to the LIEE Program Policy and Procedures ("P&P") Manual and Weatherization Installation Standards ("WIS") Manual (collectively, "Manuals") . 2 Assigned Commissioner's Ruling Directing the Standardization Team to Withdraw and Refile Its Proposal Related to Phase 5 of the Low Income Energy Efficiency Standardization Project .

Order Instituting Rulemaking on the R 04-01-006, A. 04-06-038 ; A. 04-07-002 ; Commission's Proposed Policies and Programs Governing Post-2003 Low Income A. 04-07-010 ; A. 04-07-011 ; A. 04-07-012 ;

Assistance Programs . A. 04-07-013 ; A. 04-07-014 ; A. 0407015;

A. 04-07-020 ; A. 04-07-027 ; A. 0407050

furnace repairs and replacements require prior Commission approval and contravene

DAP policies and procedures, and (2) related business controls that SoCalGas

implemented in 2004 reduce services to low income customers. In the February Ruling,

the Commission stated very clearly that parties are being given the opportunity to

comment on the "Low Income Energy Efficiency (LIEE) Standardization Project Team

Request for Approval of Revisions to the LIEE Program and Policy Manual and

Weatherization Installation Standards Manual filed in this proceeding on January 18,

2005 ." Therefore, in the context of the February Ruling, SoCalGas believes that this is

not the appropriate venue in which to take issue with any contractual checks and

balances a particular utility has put into place to ensure that LIEE services are effectively

provided and managed .

II . Discussion

A.

2004 DAP Revisions to Furnace Repair and Replacement Protocols Do Not Require Prior Commission Approval Because They Are Consistent with Commission Directives and Utility Practice

Contrary to TELACU's assertions (mimeo at 2), the program changes and

business controls implemented by SoCalGas in 2004 for DAP furnace repair and

replacements do not require Commission approval and do not contravene DAP policies

and procedures . The revisions were put into place to address contractor performance

concerns and to make SoCalGas' program consistent with Commission direction and

requirements .

The Commission in recent years has indicated its desire to achieve statewide

"standardization" of the DAP program offered by the investor-owned utilities ("IOUs" or

"Utilities") . One aspect of the standardization effort is to provide comprehensive services

to DAP participants by providing each eligible household with every feasible measure

offered under the program, which has been supported by the Commission . SoCalGas'

provision of "comprehensive LIEE services" requires that contractors provide

participating customers with all feasible services/measures (e .g ., weatherization,

appliances and carbon monoxide testing) and that all contractors offer furnace repair

and replacement services along with the weatherization services as appropriate . This

requirement was implemented in 2004 to bring SoCalGas' program (which previously

had allowed furnace services to be provided separately from other program services) in

line with the statewide standardized policies adopted by the Commission and

implemented by the IOUs.4 Providing "comprehensive services" is also consistent with

the requirements of Assembly Bill 1393, enacted in October 1999, which added Section

381 .5 to the Public ("Pub.") Utilities ("Util .") Code . Pub. Util . Code Section 381 .5 states

that it is the Legislature's intent to ensure "that high quality, low income energy efficiency

programs are delivered to the maximum number of eligible customers at a reasonable

cost ."

TELACU states that it is unaware of any Commission decision, opinion, or

directive which says that "fewest number of visits" is a Commission goal . Decision ("D.")

01-05-033 clearly articulates the Commission's policy on providing "comprehensive

services" in the LIEE program in an efficient manner as follows :

We expect utility administrators to work closely with these agencies so that weatherization teams are deployed in a manner that protects the low-income customer from being approached by multiple service providers with uncoordinated programs . 5

s In D. 03-11-020, Finding of Fact 32, the Commission states, "the LIEE program is unique in that it entails the provision of a comprehensive set of energy efficiency measures spanning both building envelope infiltration reduction and appliance repair and replacement." In addition, Pub . Util . Code Sections 381 .5 and 2790 require that utility DAP programs provide all feasible measures and that high quality, low income energy efficiency services are delivered to the maximum number of eligible customers at a reasonable cost . 4 The IOUs include SDG&E, SoCalGas, Pacific Gas & Electric, Southern California Edison . s D. 01-05-033, at 39 .

SoCalGas' policy requiring contractors to provide comprehensive services by

installing all feasible measures using a coordinated approach and limiting the number, of

visits does not limit or prevent customers from receiving program services and is

consistent with the Commission's standardized statewide LIEE program policies and

California law.

TELACU also asserts that "some of the existing and proposed program policies

of SoCalGas contradict the policy of ̀ all feasible measures"' and that "contractors should

be permitted to provide whatever services are needed ." SoCalGas disagrees .

SoCalGas' DAP program fully complies with the Commission-adopted statewide

LIEE policies and procedures and is consistent with the way PG&E, Edison, and SDG&E

operate their programs . SoCalGas' requirement that contractors provide comprehensive

services ensures that all feasible measures are installed in a systematic and coordinated

manner. Furthermore, all DAP contractors across the State are also required to comply

with the statewide policies and procedures and are not permitted to make independent

judgments on which measures they choose to provide to eligible households . The

program standards clearly spell out under what circumstances a measure is deemed

unfeasible. This is to ensure that program contractors statewide are making consistent

judgments when determining which measures are feasible to install in each eligible

household . TELACU's request to allow contractors to independently determine which

measures to install in a home is contrary to Commission policy and should not be given

any consideration .

B.

2004 DAP Revisions to Furnace Repair and Replacement Protocols Do Not Diminish or Reduce Service and Are an Appropriate Program Business Control to Ensure that Program Funds Are Properly Expended

The program procedures reinstituted by SoCalGas in 2004 for DAP furnace

repair and replacements do not reduce services to low income customers as TELACU

alleges . Rather, they ensure that ratepayer funds are appropriately spent. Repairing

instead of replacing an existing furnace when unwarranted neither harms customers nor

diminishes services . When furnace replacements are unwarranted, program funds are

expended needlessly, thereby reducing the total number of low-income customers that

can receive DAP services through SoCalGas' program .

The business controls that SoCalGas implemented were put into place to

address concerns over the excessive number of furnace replacements occurring in

comparison to the other utilities and the accuracy of the assessments being made

regarding repair work for furnaces . During 2003, SoCalGas' program was replacing

89% of the furnaces serviced and repairing only 11 %. In contrast, PG&E and SDG&E's

programs were repairing 75%-85% of the furnaces serviced . To address the differences

between the utilities' programs, SoCalGas required contractors to obtain approval from

SoCalGas before any furnaces were replaced . A separate HVAC contractor was hired

to inspect the furnaces and to determine when repairs could be made instead of

replacements . Repairs are referred to a different contractor (not the original or

inspecting contractors) to avoid any conflicts of interest . By the end of 2004, the pre-

approval process had resulted in replacing 52% of the furnaces serviced instead of the

89% noted for 2003 . This reduction translated into a program savings of $3.3 million in

2004 that otherwise would have been spent on unwarranted furnace replacements,

allowing, on average, 5,500 more low-income customers to receive program services .

Through this more efficient and appropriate use of program funds, customers had their

furnaces restored to working condition and additional low-income customers were able

to benefit from DAP funds and services .

SoCalGas also disagrees with TELACU's assertion that the pre-approval process

has caused delays in service and has created an additional "and unnecessary layer of

administration for both the contracting agency and SoCalGas." SoCalGas has worked

with the contractors to eliminate any delays in the process, and contractor invoices are

paid within an average of 30-days from the date they are approved for payment.

TELACU also states that SoCalGas' furnace pre-approval process is a form of

unnecessary micromanagement . SoCalGas strongly disagrees . As explained above, the

pre-approval process implemented by SoCalGas is to prevent the unwarranted

replacement of furnaces-and to help SoCalGas meet its obligation as program

administrator to ensure ratepayer funds are appropriately spent. SoCalGas has had a

similar procedure in place in the past for its DAP program . It is appropriate for

SoCalGas to implement such business control procedures when needed to address

concerns with contractor performance and to ensure appropriate and effective

implementation of the program . The ability to implement controls in this manner is a

necessary element of effective and prudent program management .

Ill. Conclusion

For the foregoing reasons, SoCaIGas requests the Commission to reject

TELACU's objections to the business controls that SoCalGas has implemented for its

LIEE program because procedurally, the comments exceed the scope of the February

Ruling and substantively, they are without merit.

Respectfully submitted,

March 28, 2005

Geor6etta J. Attorney for Southern California Gas Company 101 Ash Street HQ13 San Diego, CA. 92101 Phone: (619) 699-5064 Fax:

(619) 699-5027 E-mail : [email protected]

CERTIFICATE OF SERVICE

I hereby certify that I have this day served a copy of the foregoing REPLY COMMENTS OF SOUTHERN CALIFORNIA GAS COMPANY (U 904 G) TO COMMENTS OF THE EAST LOS ANGELES COMMUNITY UNION AND THE MARAVILLA FOUNDATION ON THE STANDARDIZATION PROJECT TEAM'S PROPOSED REVISIONS TO THE LIEE PROGRAM POLICY AND PROCEDURES AND WEATHERIZATION INSTALLATION STANDARDS MANUALS on all parties identified in R.04-01-006 on the attached service list by electronic mail, and by Federal Express to Commissioner Michael Peevey and Administrative Law Judge Sarah Thomas .

Dated at San Diego, California, this 28th day of March 2005 .

CALIFORNIA PUBLIC UTILITIES COMMISSION - SERVICE LISTS

CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists Proceeding : R0401006 - PUC - LOW-INCOME PRO Filer: PUC List Name : LIST Last changed: March 25, 2005

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Appearance BARBARA R . ALEXANDER CONSUMER AFFAIRS CONSULTANT 83 WEDGEWOOD DRIVE WINTHROP, ME 04364

ANDY BETTWY ATTORNEY AT LAW SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89150

VALERIE J . ONTIVEROZ ANALYST/STATE REGULATORY AFFAIRS SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89150-0002

DAVID M . NORRIS ATTORNEY AT LAW SIERRA PACIFIC POWER COMPANY 6100 NEIL ROAD RENO, NV 89520

RON GARCIA RELIABLE ENERGY MANAGEMENT, INC . 6250 PARAMOUNT BLVD .

BRIDGET A . BRANIGAN ATTORNEY AT LAW SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89150

A . BROOKS CONGDON MANAGER/PRICING & TARIFFS SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89193-8510

MELISSA FRITZ PROJECT MANAGER SIERRA PACIFIC POWER CO . PO BOX 10100 RENO, NV 89520-0026

WALLIS J . WINEGAR WINEGARD ENERGY, INC 1818 FLOWER AVE

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RICHARD ESTEVES SESCO, INC . 77 YACHT CLUB DRIVE, SUITE 1000 LAKE HOPATCONG, NJ 07849-1313

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LONG BEACH, CA 90805

CASE ADMINISTRATION CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE ., ROSEMEAD, CA 91770

SUSAN QUON SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE ROSEMEAD, CA 91770

RONALD MOORE SOCAL,WATER/BEAR VALLEY ELECTRIC 630 EAST FOOTHILL BLVD . SAN DIMAS, CA 91773

GEORGETTA J . BAKER SEMPRA ENERGY 101 ASH STREET, HQ 13

MARGARET MOORE SOUTHERN CALIFORNIA GAS COMPANY 8315 CENTURY PARK COURT CP22D SAN DIEGO, CA 92123-1550

BILLY BLATTNER SAN DIEGO GAS & ELECTRIC COMPANY 601 VAN NESS AVENUE, SUITE 2060 SAN FRANCISCO, CA 94102

DUARTE, CA 91010

LARRY R . COPE ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON 2244 WALNUT GROVE AVENUE ROSEMEAD, CA 91770

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KEITH SWITZER MANAGER - SPECIAL PROJECTS SOUTHERN CALIFORNIA WATER COMPANY 630 EAST FOOTHILL BOULEVARD SAN DIMAS, CA 91773

GEORGETTA J . BAKER ATTORNEY AT LAW SAN DIEGO GAS & ELECTRIC COMPANY 101 ASH STREET, HQ13 SAN DIEGO, CA 92101

GEORGETTA J . BAKER SOUTHERN CALIFORNIA GAS COMPANY 101 ASH STREET, HQ13

RICHARD SHAW ASSERT PO BOX 469 FILLMORE, CA 93016

BOB FINKELSTEIN ATTORNEY AT LAW THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO, CA 94102

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SAN DIEGO, CA 92101 SAN DIEGO, CA 92101-3017

YOLE WHITING JOY YAMAGATA SAN DIEGO GAS & ELECTRIC COMPANY SOUTHERN CALIFORNIA GAS COMPANY 8335 CENTURY PARK COURT 8315 CENTURY PARK COURT CP22D SAN DIEGO, CA 92123 SAN DIEGO, CA 92123-1550


MONICA L . MCCRARY CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION ROOM 5134 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

JOHN L . CLARK ATTORNEY AT LAW GOODIN MAC$RIDE SQUERI RITCHIE & DAY LLP 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94111

SUSAN E . BROWN LATINO ISSUES FORUM 160 PINE STREET, SUITE 700 SAN FRANCISCO, CA 94111

MARGARET D . BROWN ATTORNEY AT LAW PACIFIC GAS AND ELECTRIC COMPANY PO BOX 7442 SAN FRANCISCO, CA 94120-7442

DANIEL COOLEY ATTORNEY AT LAW PACIFIC GAS AND ELECTRIC COMPANY PO BOX 770000 SAN FRANCISCO, CA 94177-0001

JAMES HODGES 1069 45TH STREET SACRAMENTO, CA 95819

RAYMOND J . CZAHAR CHIEF FINANCIAL OFFICER WEST COAST GAS CO ., INC .

JEFFREY F . BECK ATTORNEY AT LAW COOPER, WHITE & COOPER ,L .L .P . 201 CALIFORNIA ST ., 17TH FLOOR SAN FRANCISCO, CA 94111

IRINA KRISHPINOVICH HEMSTREET ASSOCIATES 5760 CLINTON AVENUE RICHMOND, CA 94805

RAYMOND J . CZAHAR, C .P .A . CHIEF FINANCIAL OFFICER WEST COAST GAS COMPANY 9203 BEATTY DRIVE SACRAMENTO, CA 95826

LESLIE ALAN UEOKA VERIZON HAWAII TEL . PO BOX 2200

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MARK P . SCHREIBER ATTORNEY AT LAW COOPER, WHITE & COOPER, LLP 201 CALIFORNIA STREET, 17TH FLOOR SAN FRANCISCO, CA 94111

MARGARET DEB . BROWN ATTORNEY AT LAW PACIFIC GAS AND ELECTRIC COMPANY LAW DEPARTMENT, B30A PO BOX 7442 SAN FRANCISCO, CA 94120

JOSEPHINE WU PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MAIL CODE B9A SAN FRANCISCO, CA 94177

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MICHAEL LAMOND GENE FERRIS ALPINE NATURAL GAS OPERATING COMPANY MOUNTAIN UTILITIES PO BOX 550 PO BOX . 205 15 ST . ANDREWS ROAD, SUITE 7 KIRKWOOD, CA 95646 VALLEY SPRINGS, CA 95252


9203 BEATTY DR . SACRAMENTO, CA 95826-9702

JAMES C . PAINE ATTORNEY AT LAW STOEL RIVES LLP 900 S .W . FIFTH AVENUE, STE . 2600 PORTLAND, OR 97204

CHRISTY OMOHUNDRO VICE PRESIDENT, REGULATION PACIFICORP 825 NE MULTNOMAH BLVD ., SUITE 800 PORTLAND, OR 97232

KELLY NORWOOD AVISTA CORPORATION PO BOX 3727,MSC-29 1411 E . MISSION AVENUE SPOKANE, WA 99220

Information Only CORALETTE HANNON ATTORNEY AT LAW AARP 6705 REEDY CREEK ROAD CHARLOTTE, NC 28215

DAVID BAIRD 3833 GREENWAY DRIVE LAWRENCE, KS 66046

ANITA HART SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89150

ROGER C . MONTGOMERY VP/PRICING SOUTHWEST GAS CORPORATION

HONOLULU, HI 96841

DANIEL W . MEEK ATTORNEY AT LAW RESCUE 10949 S .W . 4TH AVENUE PORTLAND, OR 97219

KATHY MITCHELL AVISTA UTILITIES PO BOX 3727 SPOKANE, WA 99220

BRUCE FOLSOM AVISTA CORPORATION 1411 E . MISSION MSC-29, PO BOX 3727 SPOKANE, WA 99220-3727

KAY JOSLIN NATIONAL CENTER FOR APPROPRIATE TECHNO 4040 CONTINENTAL DRIVE BUTTE, MT 59702

KEVIN J . SIMONSEN ENERGY MANAGEMENT SERVICES 646 .EAST THIRD AVENUE DURANGO, CO 81301

VIVIAN SCOTT SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89150

ROGER C . MONTGOMERY VICE PRESIDENT, PRICING SOUTHWEST GAS CORPORATION


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5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89150-0002

PATRICIA FRANKLIN SIERRA PACIFIC POWER COMPANY 6100 NEIL ROAD RENO, NV 89520

MICHAEL J . STRUMWASSER STRUMWASSER & WOOCHER LLP 100 WILSHIRE BLVD . SUITE 1900 SANTA MONICA, CA 90401

JOHN FASANA SOUTHERN CALIFORNIA EDISON 2244 WALNUT GROVE AVENUE ROSEMEAD, CA 91770

DON WOOD PACIFIC ENERGY POLICY CENTER 4539 LEE AVENUE

MICHAEL SHAMES ATTORNEY AT,LAW UTILITY CONSUMERS' ACTION NETWORK 3100 FIFTH AVENUE, SUITE B SAN DIEGO, CA 92103

FRED SEBOLD RER 11236 EL CAMINO REAL SAN DIEGO, CA 92130

PO BOX 98510 LAS VEGAS, NV 89193-8510

PATRICIA WATTS FCI MANAGEMENT CONSULTANTS 5900 S EASTERN AVE ., SUITE 152 COMMERCE, CA 90040

JACK F . PARKHILL SOUTHERN CALIFORNIA EDISON PO BOX 800 ROSEMEAD, CA 91770

MARK MCNULTY 5150 RANDLETT DRIVE LA MESA, CA 91941

CENTRAL FILES SAN DIEGO GAS & ELECTRIC CP31-E 8330 CENTURY PARK COURT SAN DIEGO, CA 92123-1530


JOY C . YAMAGATA SOUTHERN CALIFORNIA GAS SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT SAN DIEGO, CA 91910

BRENDA GETTIG REGIONAL ECONOMIC RESEARCH, INC . 11236 EL CAMINO REAL SAN DIEGO, CA 92130-2650

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LA MESA, CA 91941

AMY PETERS MICHAEL BERBERET SAN DIEGO GAS AND ELECTRIC COMPANY NCS PEARSON 8330 CENTURY PARK COURT, CP32D 4536 RAMONA SAN DIEGO, CA 92009 FALLBROOK, CA 92028


CARL WOOD 10103 LIVE OAK AVE CHERRY VALLEY, CA 92223

JOE WILLIAMS CEO RICHARD HEATH AND ASSOCIATES, INC . 590 W . LOCUST AVENUE, STE 103 FRESNO, CA 93650

PAUL KERKORIAN ATTORNEY AT LAW 726 W . BARSTOW , SUITE 108 FRESNO, CA 93704

BRUCE FOSTER REGULATORY AFFAIRS SOUTHERN CALIFORNIA EDISON COMPANY 601 VAN NESS AVENUE, STE . 2040 SAN FRANCISCO, CA 94102

LONG NGUYEN PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MAILCODE B9A SAN FRANCISCO, CA 94105

CALIFORNIA ENERGY MARKETS 517-B POTRERO AVENUE SAN FRANCISCO, CA 94110

JAY LUO PACIFIC GAS & ELECTRIC COMPANY 77 BEALE STREET MAIL CODE B9A SAN FRANCISCO, CA 94117

BARBARA WILLIAMS RHA, INC . 1420 HARBOR BAY PARKWAY, STE . 145

EDDIE JIMENEZ DIRECTOR SPECIAL PROGRAMS PORTEUS INC . 1830 N . DINUMB BLVD VISALIA, CA 93291

KRISTINE LUCERO RICHARD HEATH AND ASSOCIATES, INC . 590 W . LOCUST AVENUE, SUITE 103 FRESNO, CA 93650

WILLIAM F . PARKER PRESIDENT BAY AREA POVERTY RESOURCE COUNCIL 930 BRITTAN AVENUE SAN CARLOS, CA 94070

LINDA S . DANNEWITZ P G & E 77 BEALS STREET SAN FRANCISCO, CA 94102

CALIFORNIA ENERGY MARKETS 517-B POTRERO AVE SAN FRANCISCO, CA 94110

DUANE F . LARSON PACIFIC GAS AND ELECTRIC PO BOX 770000, MAIL N6G SAN FRANCISCO, CA 94177-0001

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JANINE L . SCANCARELLI FOLGER LEVIN & KAHN LLP 275 BATTERY STREET, 23RD FLOOR SAN FRANCISCO, CA 94111

FRANCES L . THOMPSON PACIFIC GAS AND ELECTRIC COMPANY 123 MISSION STREET, RM . 1408

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ALAMEDA, CA 94502

CHRISTOPHER J . MAYER MODESTO IRRIGATION DISTRICT PO BOX 4060 MODESTO, CA 95352-4060

CAROLYN M . KEHREIN ENERGY MANAGEMENT SERVICES 1505 DUNLAP COURT DIXON ; CA 95620-4208

State Service MAXINE HARRISON CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION

SAN FRANCISCO, CA 95177

FRED WESLEY MONIER TURLOCK IRRIGATION DISTRICT PO BOX 949, 333 EAST CANAL DRIVE TURLOCK, CA 95381-0949

SCOTT BLAISING ATTORNEY AT LAW BRAUN & BLAISING, P .C . 8980 MOONEY ROAD

SPOKANE, WA 99202

MARIA JUAREZ RIVERSIDE COUNTY DEPT OF COMMUNITY ACTION

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ELK GROVE, CA 95624

STEVE TURTLETAUB LYNN VICTOR DIRECTOR OF SALES EXECUTIVE DIRECTOR DIRECTAPPS CALIFORNIA/NEVADA COMMUNITY ACTION 3013 DOUGLAS BLVD, SUITE 220 225 30TH STREET, SUITE 200 ROSEVILLE, CA 95661 SACRAMENTO, CA 95816

HOLLY NICHOLAS JAMES O'BANNON RICHARD HEATH AND ASSOCIATES, INC . RICHARD HEATH AND ASSOCIATES, INC . 1026 MANGROVE AVE ., 1026 MANGROVE AVE ., CHICO, CA 95926 CHICO, CA 95926

PACIFICORP DATA REQUEST RESPONSE CENTER 825 NE MULTNOMAH, SUITE 800 PORTLAND, OR 97232

CHRISTY OMOHUNDRO DIRECTOR OF REGULATORY POLICY PACIFICORP 825 NE MULNOMAH, SUITE 800 PORTLAND, OR 97232

MARISA DECRISTOFORO DAVID J . MEYER PACIFICORP ATTORNEY AT LAW 825 NE MULTNOMAH STREET, SUITE 800 AVISTA CORPORATION PORTLAND, OR 97232 MSC-13

1411 E . MISSION AVENUE


320 WEST 4TH STREET SUITE 500 LOS ANGELES, CA 90013

PAUL WHITE ASSISTANT EXECUTIVE DIRECTOR FRESNO COUNTY ECONOMIC OPPORTUNITIES COM 5476 W . BEDFORD

ROOM 4102 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

PHILIP S . WEISMEHL CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 5114 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

2038 IOWA AVE ., SUITE B-102 RIVERSIDE, CA 92507

ORTENSIA LOPEZ EXECUTIVE DIRECTOR EL CONCILIO OF SAN MATEO 1419 BURLINGAME AVE ., SUITE N

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AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

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SARAH R THOMAS CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 5105 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

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FRESNO, CA 93722 BURLINGAME, CA 94010

CHERYL COX DONNA L . WAGONER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION RATEPAYER REPRESENTATION BRANCH ENGINEERING, ENVIRONMENTAL STUDIES, OUST ROOM 3-B AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

EUGENE CADENASSO F . JOSEPH LEONARD CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION NATURAL GAS, ENERGY EFFICIENCY AND RESOU ENGINEERING, ENVIRONMENTAL STUDIES, CUST AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

IVY WALKER JEORGE S TAGNIPES CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENGINEERING, ENVIRONMENTAL STUDIES, CUST ENGINEERING, ENVIRONMENTAL STUDIES, CUST AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JESSICA T . HECHT JOSIE WEBB CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION TELECOMMUNICATIONS & CONSUMER ISSUES BRA ENGINEERING, ENVIRONMENTAL STUDIES, CUST

KAREN A DEGANNES CALIF PUBLIC UTILITIES COMMISSION ENGINEERING, ENVIRONMENTAL STUDIES, CUST

MANUEL RAMIREZ CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION

AREA 4-A ROOM 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214


SARVJIT S . RANDHAWA CALIF PUBLIC UTILITIES COMMISSION ENGINEERING, ENVIRONMENTAL STUDIES, AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

THERESA CHO CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION ROOM 5207 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

THOMAS W . THOMPSON CALIF PUBLIC UTILITIES COMMISSION TELECOMMUNICATIONS & CONSUMER ISSUES ROOM 4102 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

TIMOTHY DAYONOT DIRECTOR DEPARTMENT OF COMMUNICTY SERVICES PO BOX 1947 SACRAMENTO, CA 95814-0338

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TERRIE J . TANNEHILL CALIF PUBLIC UTILITIES COMMISSION

CUST ENGINEERING, ENVIRONMENTAL STUDIES, OUST AREA 4A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

THOMAS W . THOMPSON CALIF PUBLIC UTILITIES COMMISSION TELECOMMUNICATIONS & CONSUMER ISSUES BRA ROOM 4102 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

ZAIDA AMAYA-PINEDA CALIF PUBLIC UTILITIES COMMISSION

BRA ENGINEERING, ENVIRONMENTAL STUDIES, CUST 770 L STREET, SUITE 1050 SACRAMENTO, CA 95814

03/28/2005

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