before the public utilities commission of the state of ... · sce also requests authorization to...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) Requesting Authorization to Implement Residential Default Time-Of-Use Rates and Increase Fixed Charges.

Application No. 17-12-____

2018 RESIDENTIAL RATE DESIGN WINDOW APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) REQUESTING AUTHORIZATION TO

IMPLEMENT RESIDENTIAL DEFAULT TIME-OF-USE RATES AND INCREASE FIXED CHARGES

FADIA RAFEEDIE KHOURY CONNOR J. FLANIGAN

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6411 Facsimile: (626) 302-3990 E-mail: [email protected]

Dated: December 21, 2017

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STATE OF CALIFORNIA



2018 RESIDENTIAL RATE DESIGN WINDOW APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) REQUESTING AUTHORIZATION TO

IMPLEMENT RESIDENTIAL DEFAULT TIME-OF-USE RATES AND INCREASE FIXED CHARGES

I.

INTRODUCTION

Pursuant to Articles 1 and 2 of the Rules of Practice and Procedure of the California

Public Utilities Commission (Commission or CPUC), and in accordance with the Commission’s

Decision (D.) 15-07-001 ordering each investor-owned utility (IOU) to submit a Residential Rate

Design Window (RDW) application no later than January 1, 2018,1 Southern California Edison

Company (SCE) respectfully files this application requesting that the Commission approve its

proposal to implement residential default time-of-use (TOU) rates for specified eligible

customers, to implement seasonally differentiated tiered rates, and to increase SCE’s current

fixed charges for non-CARE and CARE2 customers, as described herein. SCE’s application is

supported by testimony, preliminarily identified as Exhibits SCE-01 and SCE-02, which is being

served concurrently with this application.

1 D.15-07-001, p. 301. 2 California Alternate Rates for Energy (CARE).

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II.

EXECUTIVE SUMMARY

SCE respectfully requests authorization to transition approximately 3.3 million eligible

residential customers to default TOU rates, beginning in October 2020. SCE’s transition plan

accounts for the installation, testing, and stabilization phases of its new technology platform, the

Customer Service Re-Platform (CSRP), which is scheduled to take place in 2019 and 2020.

SCE proposes a 15-month default period, during which residential customers will be placed on

the lowest cost of one of two default TOU rates, TOU-D-4-9PM or TOU-D-5-8PM. These

“TOU lite” default rates are the same as those approved for SCE’s March 2018 Default TOU

Pilot and consistent with up-to-date TOU time periods and guidance provided by D.17-01-006.

SCE will select one of these two proposed rates as the standard default TOU rate for new

customers at the time of service turn on, based on the first set of results from the Default TOU

Pilot expected in July 2018. Per D.17-09-036, CARE and FERA eligible customers in hot

climate zones will be excluded from being defaulted onto TOU rates.

SCE also requests authorization to implement seasonally-differentiated tiered rates for all

residential customers, concurrent with the start of default TOU rollout in October 2020.

As directed by the Commission in D.15-07-001, SCE explored the potential benefit of moving

residential customers to seasonal tiered rates, and concluded that this is a prudent next step

towards introducing customers to rates with greater relation to actual costs to serve. SCE’s

seasonal tiered rates also feature a moderated price signal, similar to the proposed default TOU

rates.

Finally, SCE proposes to increase the non-CARE fixed charge of $0.94 per month for

single-family homes to about $7.50 per month and to increase the CARE fixed charge of $0.75

per month to about $5.00 per month, each expressed in 2017 dollars. Under this proposal,

consistent with D.17-09-035, SCE will no longer differentiate fixed charges by dwelling

type. SCE’s proposed increases comply with Section 739.9(f), which capped fixed charges on

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default rates and at least one optional tiered rate beginning in 2015 at $10 and $5 per month for

non-CARE and CARE customers but allowed for adjustments consistent with the annual increase

in the Consumer Price Index (CPI) beginning in 2016. SCE proposes to adjust its $7.50 and

$5.00 fixed charges by actual annual CPI increases from 2017 to 2021 when the increased fixed

charges are proposed to be implemented.

III.

ORGANIZATION OF SCE’S TESTIMONY

SCE’s testimony served separately to support this application has been preliminarily

marked for identification as Exhibits SCE-01 and SCE-02.

Exhibit SCE-01 is comprised of 16 chapters, summarized as follows:

Chapter I – Introduction and Summary summarizes SCE’s proposal;

Chapter II – Customer Service System Re-Platform summarizes the CSRP project and

explains its impact on default TOU rollout;

Chapter III – Timeline and Order of Transition to Default TOU details SCE’s proposal to

transition eligible residential customers to default TOU over a 15-month period, beginning in

October 2020, and the order of transitioning these customers;

Chapter IV – Default TOU Rate Design Proposal describes SCE’s proposal to implement

two default TOU rates during the transition period, and to select one of these two rates as the

standard rate for new customers who select no particular rate at the time of turn on;

Chapter V – Default TOU Eligibility describes certain residential customer segments

included or excluded from default TOU under Public Utilities Code Section 745 and the relevant

Commission decisions in the Residential Rate Reform Rulemaking (R.) 12-06-013, D.16-09-016

and D.17-09-036;

Chapter VI – TOU Pilot Studies That Influence Default TOU Rollout describes recent

results from SCE’s ongoing Opt-in TOU Pilot and outlines key study milestones associated with

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SCE’s upcoming March 2018 Default TOU Pilot that will inform TOU rollout, including the

selection of the standard default TOU rate at the time of new customer turn on;

Chapter VII – Forecast GHG Reductions and Cost Savings Resulting From Default TOU

describes SCE’s analysis of the effect of residential default TOU on GHG emissions;

Chapter VIII – Community Choice Aggregation (CCA) Customers explains SCE’s plan

to engage CCAs in its service area to gauge their level of participation in default TOU and

address key topics prior to default TOU implementation;

Chapter IX – Bill Protection explains SCE’s bill protection plan for customers migrated

onto, or opting into, default TOU and the estimated cost of bill protection credits;

Chapter X – Proposed Rate Changes details SCE’s proposal to implement seasonally-

differentiated tiered rates in coordination with the rollout of default TOU rates and its proposal to

implement a CARE and FERA line item discount structure for enrolled CARE and FERA

customers on tiered and TOU rates;

Chapter XI – Customer Bill Impacts From SCE’s Proposed Default TOU Rates sets forth

the estimated percentage of customers expected to benefit or not benefit and the percentage

change they are expected to see in annual bills when moving from: (1) the current tiered rate to

the seasonal tiered rate; (2) the current tiered rate to TOU-D-4-9PM or TOU-D-5-8PM; or (2) the

seasonal tiered rate to TOU-D-4-9PM or TOU-D-5-8PM.

Chapter XII – Customer Experience summarizes SCE’s Marketing, Education, and

Outreach (ME&O) strategy for TOU implementation and associated costs;

Chapter XIII – Operations provides information about SCE’s operational plans for

implementing default TOU, specifically customer contact center staffing, training and estimated

costs, and billing system and IT cost estimates;

Chapter XIV – Budget sets forth SCE’s forecast cost estimate;

Chapter XV – Cost Recovery explains SCE’s proposal for recording and recovering

costs; and

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Chapter XVI – Governance and Controls explains how SCE will develop, track, and

report operational metrics for TOU implementation.

Exhibit SCE-02 is comprised of seven chapters, summarized as follows:

Chapter I – Summary of SCE’s Fixed Charge Proposal and Background summarizes

SCE’s proposals related to fixed charges, minimum bills, and compliance with statutory

requirements and Commission decisions;

Chapter II – Rate Design Principles and Commission Support for Fixed Charges explains

how SCE’s fixed charge proposal will help mitigate the intra-class subsidy from high-usage to

low-usage residential customers and is revenue neutral, and also summarizes the Commission’s

long history of support for residential fixed charges;

Chapter III – Fixed Charge Cost Components describes SCE’s proposal to adopt marginal

customer cost components for the calculation of residential fixed charges;

Chapter IV – Marginal Customer Cost Methods provides the rationale and basis for the

Commission to adopt the Rental method as the appropriate method to calculate customer costs to

establish a fixed charge;

Chapter V – Fixed Charge Proposal explains SCE’s proposed fixed charges and

minimum charges, and discusses why the fixed charge proposals comply with statutory

requirements and Commission decisions;

Chapter VI – Implementation of Fixed Charges discusses certain implementation issues

associated with SCE’s fixed charge proposal (e.g., showing that SCE’s billing and information

systems are ready to implement fixed charges and a customer education/outreach plan); and

Chapter VII – Cost Recovery for Fixed Charge ME&O Expenditures explains SCE’s

proposal for recording and recovering costs.

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IV.

SUMMARY OF SCE’S APPLICATION

A. Default TOU Timeline

SCE respectfully requests authorization to default eligible residential customers to default

TOU rates beginning in October 2020 and concluding approximately 15 months later, a period

defined as the initial default TOU migration, or IDTM period. SCE’s default TOU

implementation timeline accounts for risks associated with replacing its obsolete information

technology (IT) billing and customer care system with a more modern, stable, and agile customer

technology platform, through the CSRP project.3 Here, CSRP will directly affect the feasibility

and timing of residential default TOU rates. Specifically, CSRP’s testing and stabilization

process requires a major “system freeze” that will prevent SCE from undertaking any significant

new transactions, such as defaulting residential customers onto TOU rates, from Q2 2019

through Q3 2020. Because of this restriction, SCE must defer implementation of default TOU

for all residential customers until after CSRP stabilizes in October 2020.

During the IDTM period, SCE plans to apply default TOU rates to approximately 3.3

million eligible residential customers, the majority of whom would be subject to a default TOU

rate during the six-month period from October 2020 through March 2021. SCE will then pause

default TOU migration during the hotter weather months of April 2021 through September 2021.

During this paused period, new customers that turn-on or transfer service will be placed on the

TOU standard rate unless they choose another rate, or it is determined they would not qualify for

a standard TOU rate. SCE will resume defaulting eligible customers in October 2021 with the

transition to default TOU concluding by the end of 2021. This second round of customers

eligible for default TOU will include those customers who turned on service just prior to the start

3 SCE’s CSRP project is pending in its General Rate Case (GRC) Application (A.) 16-09-001.

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of the ITDM period, who became eligible for default TOU by having access to at least 12 months

of metered interval data during the summer months of 2021.

B. Proposed Default TOU Rate Structures and Default TOU Rate Selection Process

SCE seeks approval of two default “TOU light” rates, TOU D 4-9PM and TOU-D-5-

8PM. Both rates were approved for SCE’s Default TOU Pilot in Resolution E-4847.

Among other features, these rate structures have TOU on-peak time periods consistent with the

guidance provided by D.17-01-006, in R.15-12-012. Schedule TOU-D-4-9PM reflects the same

TOU time periods, seasons, and weekday/weekend definitions that SCE proposed for all of its

non-residential customers which, if approved by the Commission, are expected to be

implemented in February 2019. Schedule TOU-D-5-8PM is similar to TOU-D-4-9PM, but

includes a three hour on-peak period of 5:00 pm to 8:00 pm, instead of the five-hour 4:00 pm to

9:00 pm on-peak period SCE proposed for non-residential customers.

SCE requests authorization to retain both default TOU rates, to transition eligible

customers to the “lowest cost” default TOU rate during the IDTM. Based on initial findings

from its March 2018 Default TOU Pilot, SCE also intends to select one of the two default TOU

rates as the standard default TOU rate for all customers turning on or transferring service.

SCE proposes to inform the Commission in July 2018 of its initial Default TOU Pilot findings

and final recommendation for selecting the standard default TOU rate.

C. Bill Protection

Section 745(c)(4) provides that residential customers shall not be subject to, i.e., enrolled

on, default TOU rates unless they receive at least one year of bill protection. SCE’s proposed

bill protection plan exceeds this statutory requirement and other Commission requirements.

Specifically, SCE proposes to modify Resolution E-4847 and D.17-09-036 regarding extending

the bill protection rules applied to its Default TOU Pilot for the period from the end of the

Default TOU Pilot until the commencement of the IDTM period in October 2020 and regarding

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existing TOU customers who choose to opt-in to either of SCE’s proposed default TOU rates

during the IDTM period.

SCE also proposes to modify the Residential Rate Implementation Memorandum

Account (RRIMA), to (1) include the costs associated with transitioning residential customers to

default TOU rates, and (2) to discontinue recording bill protection credits to the RRIMA,

consistent with Draft Resolution E-4847, but instead directly reflect the cost of bill protection

credits in the distribution and generation subaccounts of SCE’s Base Revenue Requirement

Balancing Account (BRRBA).

D. Seasonally Differentiated Tiered Rates and CARE/FERA Line Item Discount

SCE proposes to implement seasonally differentiated tiered rates concurrently with the

start of the IDTM period, in October 2020. SCE’s proposal is consistent with the Commission’s

directive in D.15-07-001 that the IOUs explore these rates for the future and propose them in the

next applicable GRC Phase 2 or RDW.4 Seasonal tiered rates will provide more accurate price

signals to all customers as they have a greater relation to cost of service than current, non-

seasonally tiered rates. The seasonal tiered rates also feature a moderated seasonal price signal

similar to the seasonal signal provided by SCE’s TOU rate structures.

Effective January 1, 2020, SCE proposes to present bills for both tiered, non-TOU rates

and TOU rates for CARE and FERA customers that clearly indicate as a single line item the

discounts received by CARE and FERA residential customers. SCE makes this proposal ahead

of the Commission’s directive for the IOUs to investigate CARE program changes,5 and to assist

4 D.15-07-001, p.121. 5 Id., p. 298 stated that as part of Phase 3 of R.12-06-013, the Commission would consider CARE

restructuring under AB 327. The October 15, 2015 Scoping Memorandum established an initial schedule for Phase 3 of R.12-06-013, which was modified by the June 23, 2017 ALJ Ruling that directs the Working Group to provide consensus CARE restructuring recommendations submitted as a supplement to the 2018 RDW filings by January 31, 2018. On December 13, 2017, at the request of ED staff, SCE submitted a motion on behalf of the Working Group requesting the assigned ALJs to suspend the CARE restructuring track schedule due to delays.

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customer understanding and ability to replicate the calculation of their CARE bills.

This proposal is not expected to cause bill impacts, but provides a standardized structure to

compare non-CARE/FERA and CARE/FERA tiered rates against non-CARE/FERA and

CARE/FERA TOU rates.

E. Estimated Costs and Cost Recovery

SCE’s forecasted costs total approximately $112 million, with bill protection representing

the largest component at an estimated $63 million. SCE also requests Commission confirmation

that it can use the Residential Rate Implementation Memorandum Account (RRIMA) to record

incremental costs associated with implementing residential default to TOU rates through the

period covered by SCE’s 2018 GRC with annual recovery of such costs in the Energy Resource

Recovery Account (ERRA) Review proceedings. Costs recorded in RRIMA, but not recovered

in ERRA, will be identified and recovered through SCE’s future GRC (i.e., 2021).

Consistent with Resolution E-4847, SCE proposes to record and recover bill protection

credits for the Opt-in TOU Pilot, the Default TOU Pilot, and the October 2020 default through

the generation and distribution subaccounts of SCE’s Base Revenue Requirement Balancing

Account (BRRBA). Generation revenue shortfalls will be recovered from all of SCE’s

residential generation customers and distribution revenue shortfalls will be recovered from all of

SCE’s residential distribution customers.

F. Fixed Charge Proposal

SCE proposes to increase the current non-CARE fixed charge of $0.94 per month to

$7.48 per month and to increase the current CARE fixed charge of $0.75 per month to $5.05 per

month, each expressed in 2017 dollars. These fixed charges reflect the application of the real

economic carrying cost (RECC or Rental) method to the cost categories adopted in D.17-09-035

that do not require differentiation by customer size and include only costs for meters, ongoing

revenue cycle services and O&M, and the minimum observed costs for final line transformers

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and service drops. As prescribed by D.17-09-035, these marginal costs of customer access to the

grid are not adjusted by the equal percentage of marginal cost (EPMC) scalar.

G. Integrated Timeline

The table below depicts SCE’s integrated timeline for this application, and includes key

default TOU, related research, ME&O, and rate design implementation events that occur

between 2017 and 2021. The Default TOU Timeline “swim lane” shows SCE-specific

regulatory events related to this application. The customer research swim lane shows the timing

of the customer surveys that may affect such things as the confirmation of the standard default

TOU rate as well as ME&O tactics. The ME&O swim lane illustrates when default TOU related

communications are scheduled to occur. The rate design implementation swim lane shows the

timing of when rate design proposals made in this application are proposed to become effective.

Lastly, the red band illustrates the start of the CSRP-related freeze that will limit SCE’s ability to

make customer systems and operational changes.

Default TOU Integrated Timeline

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V.

STATUTORY & PROCEDURAL REQUIREMENTS

A. Statutory and Other Authority – Rule 2.1

SCE submits this application pursuant to D.15-07-001, D.17-09-035, D.17-09-036,6 the

Commission’s Rules of Practice and Procedure, and the California Public Utilities Code.

Specifically, California Public Utilities Code Section 454(a) provides in pertinent part:

(a) Except as provided in Section 455, no public utility shall change any rate or so alter any classification, contract, practice, or rule as to reflect in any new rate, except upon a showing before the commission and a finding by the commission that the new rate is justified.

Section 454(b) provides in pertinent part:

(b) The commission may adopt rules it considers reasonable and proper for each class of public utility providing for the nature of the showing required to be made in support of proposed rate changes, the form and manner of the presentation of the showing, with or without a hearing, and the procedure to be followed in the consideration thereof.

SCE’s request complies with Rules 1.5 through 1.11 and 1.13 of the Commission’s Rules

of Practice and Procedure, which specify the procedures for, among other things, filing

documents, as well as Rules 2.1, 2.2, and 3.2.

Rule 2.1 of the Commission’s Rules of Practice and Procedure requires that all

applications: (1) clearly and concisely state authority or relief sought; (2) cite the statutory or

other authority under which that relief is sought; and (3) be verified by the applicant.

The relief being sought is summarized in Sections II and IV above, and is further

described in SCE’s supporting testimony (Exhibits SCE-01 and SCE-02) served concurrently

with this application.

6 As noted above, SCE’s application proposes to modify a specific bill protection rule adopted in D.17-09-036 and Resolution E-4847.

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The statutory and other authority for this request includes, but is not limited to, California

Public Utilities Code Sections 451, 454, 454.3, 491, 701, 702, 728, 729, 739, 745, Article 2 and

Rule 3.2 of the Commission’s Rules of Practice and Procedure, and prior decisions, orders, and

resolutions of this Commission.

This application has been verified by an SCE officer as provided in Rules 1.11 and 2.1.

The remainder of Rule 2.1, as well as Rules 2.2 and 3.2, set forth further requirements

that are addressed separately below.

B. Legal Name and Correspondence – Rules 2.1(a) and 2.1(b)

Pursuant to Rule 2.1 of the Commission’s Rules of Practice and Procedure, the full legal

name of the applicant is Southern California Edison Company (SCE). SCE is a corporation

organized and existing under the laws of the State of California, and is primarily engaged in the

business of generating, purchasing, transmitting, distributing and selling electric energy for light,

heat and power in portions of central and southern California as a public utility subject to the

jurisdiction of the California Public Utilities Commission. SCE’s properties, which are located

primarily within the State of California, consist mainly of hydroelectric and thermal electric

generating plants, together with transmission and distribution lines and other property necessary

in connection with its business.

SCE’s principal place of business is 2244 Walnut Grove Avenue, Rosemead, California,

91770; its post office address is Post Office Box 800; and its telephone number is (626)

302-1212.

SCE’s attorney in this matter is Connor Flanigan. Correspondence or communications

regarding this application should be addressed to:

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Connor J. Flanigan Senior Attorney Southern California Edison Company P.O. Box 800 2244 Walnut Grove Avenue Rosemead, CA 91770 Telephone: (626) 302-6411 Facsimile: (626) 302-3990 E-mail: [email protected]

Case Administration Southern California Edison Company 8631 Rush Street Rosemead, CA 91770 Telephone: 626-302-6906 Facsimile: 626-302-5060 E-mail: [email protected]

C. Proposed Categorization, Need for Hearings, Issues To Be Considered, Proposed

Schedule, and Relevant Safety Considerations — Rule 2.1(c)

Commission Rule 2.1(c) requires that all applications shall state “the proposed category

for the proceeding, the need for hearing, the issues to be considered, and a proposed schedule.”

1. Proposed Category

Rule 1.3(e) of the Commission’s Rules of Practice and Procedure defines

“ratesetting” proceedings as “proceedings in which the Commission sets or investigates rates for

a specifically named utility (or utilities), or establishes a mechanism that in turn sets the rates for

a specifically named utility (or utilities).” This application will include the setting and

investigation of rates, and includes SCE’s proposal for a “mechanism” that will influence the

setting of rates in future applications. Therefore, for purposes of Rule 2.1, SCE proposes that

this proceeding be categorized as ratesetting.

2. Need for Hearings

The need for hearings in this proceeding, and the issues to be considered in such

hearings, will depend in large part on the degree to which other parties contest SCE’s requests.

SCE’s proposed procedural schedule below leaves room for holding evidentiary hearings, if they

are necessary; however, the need for hearings will be determined by the assigned ALJs.

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3. Issues to be Considered, Including Relevant Safety Considerations

In general, the issues to be considered are discussed in Sections II and IV above

and in more detail in SCE’s supporting testimony served concurrently with this application.

D.16-01-017 approved an amendment to Rule 2.1(c) of the Commission’s Rules of Practice and

Procedure (Title 20, Division 1, of the California Code of Regulations) to require all applications

to identify all relevant safety considerations implicated by the application. One of SCE’s core

values is to protect public and employee safety.

The Commission recently issued D.17-09-036 in the Section 745 Track in R.12-

06-013 determining that economically vulnerable customers (i.e., CARE and FERA eligible

customers) in SCE’s hot climate zones should be excluded from SCE’s Default TOU Pilot due to

potential hardship, including health and safety impacts resulting from reduced air conditioning

use.7 The Commission further determined that absent good cause for change, these customers

will also be excluded from the full rollout to default TOU rates.8 As explained in Chapter V of

SCE’s supporting testimony, Exhibit SCE-01, SCE proposes to exclude these customers from the

full rollout to default TOU rates. Thus, this rate design application does not pose or bear on risks

to public safety.

4. Procedural Schedule

SCE recommends the following procedural schedule for this application, which

provides for a final Commission decision by December 2018:

SCE files Application December 21, 2017 Protests / Responses to Application Late January, 2018 Reply to Protests / Responses Early February, 2018 Prehearing Conference Mid-February, 2018 Scoping Memo Late February, 2018

7 D.17-09-036, p. 22. 8 Id., OP 2.

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ORA and Intervenor Testimony Due May, 2018 Rebuttal Testimony Due Late June, 2018 Supplemental Testimony Due9 Evidentiary Hearings

July, 2018 July, 2018

Concurrent Opening Briefs Early-to-mid August, 2018 Reply Briefs Late August, 2018 ALJs issue Proposed Decision November 1, 2018 Comments to Proposed Decision 20 days after service of PD Replies to Comments to Proposed Decision 5 days after opening comments on PD filed Commission issues Final Decision December 1, 2018

D. Organization and Qualification to Transact Business – Rule 2.2

In compliance with Rule 2.2 of the Commission’s Rules of Practice and Procedure,10 a

copy of SCE’s Certificate of Restated Articles of Incorporation, effective on March 2, 2006, and

presently in effect, certified by the California Secretary of State, was filed with the Commission

on March 14, 2006, in connection with Application No. 06-03-020, and is incorporated herein by

this reference pursuant to Rule 2.2 of the Commission’s Rules of Practice and Procedure.

A copy of SCE’s Certificate of Determination of Preferences of the Series D Preference

Stock filed with the California Secretary of State on March 7, 2011, and presently in effect,

certified by the California Secretary of State, was filed with the Commission on April 1, 2011, in

connection with Application No. 11-04-001, and is by reference made a part hereof.

A copy of SCE’s Certificate of Determination of Preferences of the Series E Preference

Stock filed with the California Secretary of State on January 12, 2012, and a copy of SCE’s

Certificate of Increase of Authorized Shares of the Series E Preference Stock filed with the

California Secretary of State on January 31, 2012, and presently in effect, certified by the

9 This testimony will identify SCE’s selected standard default TOU rate for new customers at the time of turn on, based on initial results of the Default TOU Pilot.

10 Rule 2.2 requires the applicant, in this case SCE, to submit a copy of its organizing documents and evidence of its qualification to transact business in California, or to refer to that documentation if previously filed with the Commission.

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California Secretary of State, were filed with the Commission on March 5, 2012, in connection

with Application No. 12-03-004, and are by reference made a part hereof.

A copy of SCE’s Certificate of Determination of Preferences of the Series F Preference

Stock filed with the California Secretary of State on May 5, 2012, and presently in effect,

certified by the California Secretary of State, was filed with the Commission on June 29, 2012,

in connection with Application No. 12-06-017, and is by reference made a part hereof.

A copy of SCE’s Certificate of Determination of Preferences of the Series G Preference

Stock filed with the California Secretary of State on January 24, 2013, and presently in effect,

certified by the California Secretary of State, was filed with the Commission on January 31,

2013, in connection with Application No. 13-01-016, and is by reference made a part hereof.

A copy of SCE’s Certificate of Determination of Preferences of the Series H Preference

Stock filed with the California Secretary of State on February 28, 2014, and presently in effect,

certified by the California Secretary of State, was filed with the Commission on March 24, 2014,


A copy of SCE’s Certificate of Determination of Preferences of the Series J Preference

Stock filed with the California Secretary of State on August 19, 2015, and presently in effect,

certified by the California Secretary of State, was filed with the Commission on October 2, 2015,


A copy of SCE’s Certificate of Determination of Preferences of the Series K Preference

Stock, filed with the California Secretary of State on March 2, 2016, and presently in effect,

certified by the California Secretary of State, was filed with the Commission on April 1, 2016, in

connection with Application No. 16-04-001, and is by reference made a part hereof.

A copy of SCE’s Certificate of Determination of Preferences of the Series L Preference

Stock filed with the California Secretary of State on June 20, 2017, and presently in effect,

certified by the California Secretary of State, was filed with the Commission on June 30, 2017,

in connection with Application No. 17-06-030, and is incorporated herein by this reference.

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Certain classes and series of SCE’s capital stock are listed on a “national securities

exchange” as defined in the Securities Exchange Act of 1934 and copies of SCE’s latest Annual

Report to Shareholders and its latest proxy statement sent to its stockholders has been filed with

the Commission with a letter of transmittal dated March 17, 2017, pursuant to General Order

Nos. 65-A and 104-A of the Commission.

E. Balance Sheet and Income Statement – Rule 3.2.(a)(1)

Appendix A to this application contains copies of SCE’s Balance Sheet and Income

Statement for the period ending September 30, 2017, the most recent period available.

F. Statement of Presently Effective and Proposed Rates – Rules 3.2(a)(2) and 3.2(a)(3)

SCE’s current rates and charges for electric service are in its electric tariffs and schedules

on file with the Commission and available on SCE’s website.11 These tariffs and schedules are

filed with and made effective by the Commission in its decisions, orders, resolutions, and

approvals of advice letter filings pursuant to Commission General Order 96-A. In this

application, SCE is not directly requesting to increase rates. However, if approved, the proposed

implementation plan will eventually impact rates as rate design changes are implemented.

Specific impacts to rates have not been determined at this time. Requests to increase rates will

be made in future rate increase applications and information about rate impacts will be provided

at that time.

G. Description of SCE’s Service Territory and Utility System – Rule 3.2(a)(4)

Because this application is not a general rate case application, this requirement is not

applicable.

11 SCE’s current tariffs are available online at http://on.sce.com/25KXt0T.

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H. Summary of Earnings – Rule 3.2.(a)(5)

In compliance with Rule 3.2(a)(5), Appendix B hereto contains a copy of SCE’s

summary of earnings, updated in December 2015, the most recent period available.

I. Depreciation – Rule 3.2(a)(7)


applicable.

J. Capital Stock and Proxy Statement – Rule 3.2(a)(8)


applicable.

K. Statement Pursuant to Rule 3.2(a)(10)

Rule 3.2(a)(10) requires that the “application of electrical … corporations shall separately

state whether or not the increase reflects and passes through to customers only increased costs to

the corporation for the services or commodities furnished by it.” SCE’s application does not

seek recovery of incremental revenues. However, the recovery of bill protection credits occurs

through reallocation of charges assessed on residential customers. To the extent this causes

affected customers’ rates to increase, this request is not limited to passing through to customers

“only increased costs to the corporation for the services or commodities furnished by it.”

L. Service of Notice – Rule 3.2(b), (c) and (d)

As required by California Public Utilities Code Section 454, a notice stating in general

terms the proposed change will be provided to customers in their monthly bills. SCE has

reviewed a draft of its proposed customer notice with the Commission’s Public Advisor.

19

As required by Rule 3.2(b), a notice stating in general terms the proposed rate change

will be mailed to the designated officials of the State of California, and the cities and counties

affected by the rate increase proposed in this application as listed in Appendix C hereto.

Pursuant to Rule 3.2(c), notice will be published in a newspaper of general circulation in

each county in SCE’s service territory within which the rate changes would be effective.

The cities and counties affected by the rate increase proposed in this application are shown in

Appendix C hereto.

Finally, pursuant to Rule 3.2(d), notice will be furnished to customers affected by the

potential rate changes proposed in this application by including such notice with the regular bills

mailed to those customers and by electronically linking to such notice for customer that receive

their bills electronically.

M. Index of Exhibits and Appendices to This Application

SCE’s submission in support of this application include the following, which are

incorporated herein by reference:

Appendices to Application

Appendix A: Balance Sheet and Income Statement

Appendix B: Summary of Earnings

Appendix C: List of Cities and Counties

Exhibits to Application

Exhibit SCE-01: Testimony of Southern California Edison Company Regarding Implementation of Residential Default Time-of-Use Rates

Exhibit SCE-02: Testimony of Southern California Edison Company Regarding Increased Fixed Charges

N. Service List

Though the official service list has not yet been established in this new proceeding, SCE

is serving this application and supporting testimony on the official service list of R.12-06-013

20

given its aim to consolidate the application with that pending proceeding where all relevant

stakeholders have been engaged.

VI.

CONCLUSION

SCE respectfully requests that the Commission approve SCE’s request for approval of its

proposals as outlined in this application and supporting testimony.

Respectfully submitted, FADIA RAFEEDIE KHOURY CONNOR J. FLANIGAN

/s/ Connor J. Flanigan By: Connor J. Flanigan

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6411 Facsimile: (626) 302-3990 E-mail: [email protected]

December 21, 2017

VERIFICATION

I am an officer of the applicant corporation herein, and am authorized to make this

verification on its behalf. I am informed and believe that the matters stated in the foregoing

document are true.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 21, 2017, at Rosemead, California

/s/ Caroline Choi By: Caroline Choi

Senior Vice President, Regulatory Affairs

SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

Appendix A

Balance Sheet and Income Statement

A-1

SOUTHERN CALIFORNIA EDISON COMPANY

(h) A balance sheet as of the latest available date, together with an income statement covering the period from close of last year for which an annual report has been filed with the Commission to the date of the balance sheet attached to the application.

STATEMENT OF INCOMENINE MONTHS ENDED SEPTEMBER 30, 2017

(In millions)

OPERATING REVENUE 9,061$

OPERATING EXPENSES: Purchase power and fuel 3,742 Other operation and maintenance 1,918 Depreciation, decommissioning and amortization 1,528 Property and other taxes 279 Other operating income (8)

Total operating expenses 7,459

OPERATING INCOME 1,602

Interest and other income 111 Interest expense (436) Other expenses (28)INCOME BEFORE INCOME TAX 1,249INCOME TAX 34NET INCOME 1,215

Less: Preferred and preference stock dividend requirements 94

NET INCOME AVAILABLE FOR COMMON STOCK 1,121$

A-2


BALANCE SHEETSEPTEMBER 30, 2017

ASSETS(in millions)

UTILITY PLANT:Utility plant, at original cost 43,869$ Less- accumulated provision for depreciation and decommissioning 9,173

34,696 Construction work in progress 2,841Nuclear fuel, at amortized cost 129

37,666

OTHER PROPERTY AND INVESTMENTS:Nonutility property - less accumulated depreciation of $91 73Nuclear decommissioning trusts 4,415Other investments 49

4,537

CURRENT ASSETS:Cash and equivalents 61Receivables, less allowances of $55 for uncollectible accounts 1,087Accrued unbilled revenue 351Inventory 229Prepaid taxes 209Derivative assets 36Regulatory assets 445Other current assets 270

2,688

DEFERRED CHARGES:Regulatory assets 8,028Other long-term assets 229

8,257

53,148$

A-3


BALANCE SHEETSEPTEMBER 30, 2017

CAPITALIZATION AND LIABILITIES(in millions)

CAPITALIZATION:Common stock 2,168$ Additional paid-in capital 668Accumulated other comprehensive loss (18)Retained earnings 9,930

Common shareholder's equity 12,748 Preferred and preference stock 2,245Long-term debt 10,426

Total capitalization 25,419

CURRENT LIABILITIES:Short-term debt 329Current portion of long-term debt 579Accounts payable 1,100Accrued taxes 92Customer deposits 276Derivative liabilities 3Regulatory liabilities 1,281Other current liabilities 1,098

4,758

DEFERRED CREDITS:Deferred income taxes and credits 10,966Derivative liabilities 0Pensions and benefits 944Asset retirement obligations 2,675Regulatory liabilities 5,858Other deferred credits and other long-term liabilities 2,528

22,971

53,148$

Appendix B

Summary of Earnings

Appendix C

List of Cities and Counties


STATE OF CALIFORNIA



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 2018 RESIDENTIAL RATE DESIGN WINDOW APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) REQUESTING AUTHORIZATION TO IMPLEMENT RESIDENTIAL DEFAULT TIME-OF-USE RATES AND INCREASE FIXED CHARGES on all parties identified on the attached service list for R.12-06-013. Service was effected by transmitting copies via e-mail to all parties who have provided an e-mail address and by placing copies in sealed envelopes and causing such envelopes to be delivered via overnight courier to the offices of the Commissioner(s) or other addressee(s).

Interim Chief ALJ Anne Simon California Public Utilities Commission Division of ALJs 505 Van Ness Avenue, Room 5115 San Francisco, CA 94102

Executed on December 21, 2017, at Rosemead, California.

/s/ Olivia Gutierrez Olivia Gutierrez Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY

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

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Parties

BRAD HEAVNER C.C. SONG CALIFORNIA SOLAR ENERGY INDUSTRIES ASSN. REGULATORY ANALYST EMAIL ONLY MARIN CLEAN ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY FOR: CALIFORNIA SOLAR ENERGY INDUSTRIES EMAIL ONLY, CA 00000 ASSOCIATION (CALSEIA) FOR: MARIN CLEAN ENERGY

MARGIE GARDNER NORA SHERIFF CAL. ENERGY EFFICIENCY INDUSTRY COUNCIL ATTORNEY EMAIL ONLY ALCANTAR & KAHL EMAIL ONLY, CA 00000 EMAIL ONLY FOR: CALIFORNIA ENERGY EFFICIENCY EMAIL ONLY, CA 00000 INDUSTRY COUNCIL FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOC./ENERGY PRODUCERS USERS COALITION

SACHU CONSTANTINE SCOTT BLAISING DIR - POLICY BRAUN BLAISING MCLAUGHLIN P.C. CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: LOCAL ENERGY AGGREGATION NETWORK FOR: CENTER FOR SUSTAINABLE ENERGY

STEPHANIE C. CHEN KEVIN T. FOX THE GREENLINING INSTITUTE KEYS & FOX LLP EMAIL ONLY 1580 LINCOLN STREET, STE. 880 EMAIL ONLY, CA 00000 DENVER, CO 80203 FOR: THE GREENLINING INSTITUTE FOR: SUNRUN, INC.

Page 1 of 17CPUC - Service Lists - R1206013

12/21/2017https://ia.cpuc.ca.gov/servicelists/R1206013_80447.htm

CHAIRMAN / PRESIDENT DANIEL W. DOUGLASS LAT. BUS. CHAMBER OF GREATER L.A. ATTORNEY 634 S. SPRING STREET, STE 600 DOUGLASS & LIDDELL LOS ANGELES, CA 90014 4766 PARK GRANADA, SUITE 209 FOR: LATINO BUSINESS CHAMBER OF GREATER CALABASAS, CA 91302 LOS ANGELES FOR: WESTERN POWER TRADING FORUM/ALLIANCE FOR RETAIL ENERGY MARKETS/DIRECT ACCESSS CUSTONER COALITION

DANIEL W. DOULGASS CONNOR FLANIGAN DOUGLASS & LIDDELL ATTORNEY 4766 PARK GRANADA, STE. 209 SOUTHERN CALIFORNIA EDISON COMPANY CALABASAS, CA 91302 2244 WALNUT GROVE AVE. FOR: NEST LABS, INC. ROSEMEAD, CA 91770 FOR: SOUTHERN CALIFORNIA EDISON COMPANY

DONALD C. LIDDELL DON KELLY ATTORNEY EXE. DIR. DOUGLASS & LIDDELL UTILITY CONSUMERS' ACTION NETWORK 2928 2ND AVENUE 3405 KENYON STREET, SUITE 401 SAN DIEGO, CA 92103 SAN DIEGO, CA 92110 FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: UTILITY CONSUMERS' ACTION NETWORK (CESA) (UCAN)

MICHAEL SHAMES, ESQ. STEVEN C. NELSON SAN DIEGO CONSUMERS' ACTION NETWORK CHIEF REGULATORY COUNSEL 6975 CAMINO AMERO SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA 92111 8330 CENTURY PARK COURT, CP32D FOR: SAN DIEGO CONSUMERS' ACTION NETWORK SAN DIEGO, CA 92123 FOR: SAN DIEGO GAS & ELECTRIC COMPANY (SDG&E)

MARK E. WHITLOCK, JR. CATHY ZHANG EXE. DIR. EXECUTIVE DIRECTOR ECUMENICAL CTR. FOR BLACK CHURCH STUDIES CHINESE AM. INSTITUTE FOR EMPOWERMENT 46 MAXWELL ST 15 SOUTHGATE AVE., STE. 200 IRVINE, CA 92618 DALY CITY, CA 94015 FOR: ECUMENICAL CENTER FOR BLACK CHURCH FOR: CHINESE AMERICAN INSTITUTE FOR STUDIES (JT. PARTY) EMPOWERMENT (JT. PARTY)

FAITH BAUTISTA JOSEPH F. WIEDMAN PRESIDENT / CEO SR. REGULATORY & LEGISLATIVE ANALYST NATIONAL ASIAN AMERICAN COALITION PENINSULA CLEAN ENERGY AUTHORITY 15 SOUTHGATE AVE, STE. 200 400 COUNTY CENTER, SIXTH FL. DALY CITY, CA 94015 REDWOOD CITY, CA 94063 FOR: NATIONAL ASIAN AMERICAN COALITION FOR: PENINSULA CLEAN ENERGY AUTHORITY (PCE)

MARC D JOSEPH ERICA SCHROEDER MCCONNELL ADAMS BROADWELL JOSEPH & CARDOZO, PC SHUTE, MIHALY AND WEINBERGER, LLP 601 GATEWAY BLVD., STE. 1000 396 HAYES STREET SOUTH SAN FRANCISCO, CA 94080 SAN FRANCISCO, CA 94102 FOR: COALITION OF CALIFORNIA UTILITY FOR: INTERSTATE RENEWABLE ENERGY EMPLOYEES (CCUE) COUNCIL, INC.



WILLIAM MAGUIRE HAYLEY GOODSON CALIF PUBLIC UTILITIES COMMISSION STAFF ATTORNEY LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM 4107 785 MARKET ST., STE. 1400 505 VAN NESS AVENUE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-3214 FOR: TURN FOR: ORA

SHERYL CARTER CHRISTOPHER J. WARNER NATURAL RESOURCES DEFENSE COUNCIL ATTORNEY 111 SUTTTER ST., 20TH FLR. PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94104-4540 77 BEALE STREET, MC B30A, RM 3145 FOR: NATURAL RESOURCES DEFENSE COUNCIL SAN FRANCISCO, CA 94105 FOR: PACIFIC GAS AND ELECTRIC COMPANY

LARISSA KOEHLER NICOLE JOHNSON SENIOR ATTORNEY REGULATORY ATTORNEY ENVIRONMENTAL DEFENSE FUND CONSUMER FEDERATION OF CALIFORNIA 123 MISSION STREET, 28TH FLOOR 150 POST ST., STE. 442 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94108 FOR: ENVIRONMENTAL DEFENSE FUND FOR: CONSUMER FEDERATION OF CALIFORNIA

BRIAN CRAGG JEANNE ARMSTRONG ATTORNEY ATTORNEY AT LAW GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY GOODIN, MACBRIDE, SQUERI & DAY, LLP 505 SANSOME STREET, SUITE 900 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: INDEPENDENT ENERGY PRODUCERS FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION ASSOCIATION

SARA STECK MYERS CHRIS S. KING ATTORNEY AT LAW CHIEF POLICY OFFICER 122 28TH AVENUE EMETER, A SIEMENS BUSINESS SAN FRANCISCO, CA 94121 4000 E. THIRD AVE., 4TH FLOOR FOR: CENTER FOR ENERGY EFFICIENCY AND FOSTER CITY, CA 94404 RENEWABLE TECHNOLOGY FOR: EMETER, A SIEMENS BUSINESS

CHRIS CONE DAVID WOOLEY POLICY MANAGER OF COUNSEL EFFICIENCY FIRST CALIFORNIA KEYES & FOX LLP 1000 BROADWAY, STE. 435 436 14TH STREET, STE. 1305 OAKLAND, CA 94607 OAKLAND, CA 94612 FOR: EFFICIENCY FIRST CALIFORNIA FOR: SOLARCITY CORPORATION

MARK FULMER TIM LINDL MRW & ASSOCIATES, LLC COUNSEL 1814 FRANKLIN STREET, SUITE 720 KEYES & FOX LLP OAKLAND, CA 94612 436 14TH STREET, STE. 1305 FOR: MRW & ASSOCIATES, LLC OAKLAND, CA 94612 FOR: THE ALLIANCE FOR SOLAR CHOICE

MELISSA W. KASNITZ ANDY KATZ CENTER FOR ACCESSIBLE TECHNOLOGY LAW OFFICES OF ANDY KATZ



3075 ADELINE STREET, SUITE 220 2150 ALLSTON WAY , STE. 400 BERKELEY, CA 94703 BERKELEY, CA 94704 FOR: CENTER FOR ACCESSIBLE TECHNOLOGY FOR: SIERRA CLUB

BRAD BORDINE TIM MCRAE DISTRIBUTED ENERGY CONSUMER ADVOCATES SILICON VALLEY LEADERSHIP GROUP 516 WHITEWOOD DRIVE 2001 GATEWAY PLACE, STE. 101E SAN RAFAEL, CA 94903 SAN JOSE, CA 95110 FOR: DISTRIBUTED ENERGY CONSUMER FOR: SILICON VALLEY LEADERSHIP GROUP ADVOCATES

STEVEN S. SHUPE JORDAN PINJUV GENERAL COUNSEL COUNSEL SONOMA CLEAN POWER AUTHORITY CALIFORNIA INDEPENDENT SYSTEM OPERATOR 50 SANTA ROSA AVE., 5TH FL. 250 OUTCROPPING WAY SANTA ROSA, CA 95404 FOLSOM, CA 95630 FOR: SONOMA CLEAN POWER AUTHORITY (SCPA) FOR: CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION (CAISO)

WAYNE AMER ERIC EISENHAMMER PRESIDENT COALITION OF ENERGY USERS MOUNTAIN UTILITIES (906) 4010 FOOTHILLS BLVD., STE 103 NO. 115 PO BOX 205 ROSEVILLE, CA 95747 KIRKWOOD, CA 95646 FOR: COALITION OF ENERGY USERS FOR: MOUNTAIN UTILITIES

ROBERT CASTANEDA SCOTT BLAISING PROTEUS, INC. ATTORNEY 1830 N. DINUBA BLVD. BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. VISALIA, CA 95814 915 L STREET, STE. 1480 FOR: PROTEUS, INC. SACRAMENTO, CA 95814 FOR: CITY OF LANCASTER

CHASE KAPPEL LAURA TAYLOR ELLISON SCHNEIDER HARRIS & DONLAN LLP ATTORNEY 2600 CAPITOL AVE., SUITE 400 BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. SACRAMENTO, CA 95816 915 L STREET, STE. 1480 FOR: VOTE SOLAR SACRAMENTO, CA 95822 FOR: SILICON VALLEY CLEAN ENERGY AUTHORITY

KAREN NORENE MILLS ATTORNEY CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO, CA 95833 FOR: CALIFORNIA FARM BUREAU FEDERATION

Information Only

AARON (YICHEN) LU AHMAD FARUQUI PROGRAM COORDINATOR THE BRATTLE GROUP CITY OF SAN DIEGO EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000



EMAIL ONLY, CA 00000

ANDREW BROWN ANDY BLAUVELT ELLISON SCHNEIDER HARRIS & DONLAN LLP MULTIFAMILY AFFORDABLE SOLAR HOMES EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: THE MULTIFAMILY AFFORDABLE SOLAR HOMES COALITION

BARBARA BARKOVICH BRIAN GEISER CONSULTANT EMAIL ONLY BARKOVICH & YAP EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

CARMELITA L. MILLER CASE COORDINATION LEGAL COUNSEL PACIFIC GAS AND ELECTRIC COMPANY THE GREENLINING INSTITUTE EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

DAMON FRANZ DAVID HUANG DIRECTOR - POLICY & ELECTRICITY MARKETS LEGAL FELLOW TESLA, INC. THE GREENLINING INSTITUTE EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

ELI HARLAND EVELYN KAHL CALIFORNIA ENERGY COMMISSION COUNSEL ENERGY RESEARCH & DEVELOPMENT DIV. ALCANTAR & KAHL LLP EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

FRANCOIS CARLIER GAIL L. SLOCUM CODA STRATEGIES PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

GEOFF MCLENNAN HANNA GRENE EMAIL ONLY CENTER FOR SUSTAINBLE ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

JACK F. PARKHILL JEREMY WAEN EMAIL ONLY SR. REGULATORY ANALYST EMAIL ONLY, CA 00000 MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY, CA 00000

JOELLE STEWARD JOHN W. LESLIE, ESQ. PACIFICORP DENTONS US LLP EMAIL ONLY EMAIL ONLY EMAIL ONLY, OR 00000 EMAIL ONLY, CA 00000



JOSH BODE KAREN SHEA NEXANT PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MARCUS COLE MARY HOFFMAN ZIMMER PARTNERS SOLUTIONS FOR UTILITIES, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MATTHEW FREEDMAN MCE REGULATORY THE UTILITY REFORM NETWORK MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MELISSA P. MARTIN NAT TREADWAY SENIOR REGULATORY COUNSEL DISTRIBUTED ENERGY FINANCIAL GROUP STATESIDE ASSOCIATES EMAIL ONLY EMAIL ONLY EMAIL ONLY, TX 00000 EMAIL ONLY, VA 00000

OWEN SANFORD PATTI LANDRY TESLA, INC. REGULATORY ANALYST EMAIL ONLY PACIFIC GAS & ELECTRIC COMPANY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

PAUL D. HERNANDEZ RICK AS. WALTMAN CENTER FOR SUSTAINABLE ENERGY UNIVERSITY OF SAN DIEGO SCHOOL OF LAW EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

ROGER LEVY SCOTT ENGSTROM LEVY ASSOCIATES EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

SEAN P. BEATTY SEPHRA A. NINOW, J.D. DIRECTOR - WEST REGULATORY AFFAIRS REGULATORY AFFAIRS MGR. NRG WEST CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

SHALINI SWAROOP STEPHEN GEORGE REGULATORY COUNSEL NEXANT MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

STEPHEN LUDWICK SUSANNAH CHURCHILL ZIMMER PARTNERS SOLAR POLICY ADVOCATE



EMAIL ONLY VOTE SOLAR EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

TADASHI GONDAI MRW & ASSOCIATES, LLC SR. ATTORNEY / DIR OF LEGAL AFFAIRS EMAIL ONLY NATIONAL ASIAN AMERICAN COALITION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

BENJAMIN AIRTH DAVID MARCUS CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000-0000 EAMIL ONLY, CA 00000-0000

KAREN TERRANOVA NANCY BROCKWAY ALCANTAR & KAHL NBROCKWAY & ASSOCIATES EMAIL ONLY 10 ALLEN STREET EMAIL ONLY, CA 00000-0000 BOSTON, MA 02131

PAUL CHERNICK SUSAN GELLER RESOURCE INSIGHT SENIOR RESEARCH ASSOCIATE 5 WATER ST. RESOURCE INSIGHT ARLINGTON, MA 02476 5 WATER ST. ARLINGTON, MA 02476

ABRAHAM SILVERMAN MICHAEL PANFIL ASSIST. GEN. COUNSEL - REGULATORY ENVIRONMENTAL DEFENSE FUND NRG ENERGY, INC. 257 PARK AVENUE SOUTH, FLOOR 16 211 CARNEGIE CENTER DRIVE NEW YORK, NY 10010 PRINCETON, NJ 08540 FOR: NRG HOME

PATRICK JOBIN JAMES (JIM) VON RIESEMANN CREDIT SUISSE SECURITIES (USA) LLC MIZUHO SECURITIES USA, INC. ONE MADISON AVENUE 320 PARK AVENUE, 12TH FLOOR NEW YORK, NY 10010 NEW YORK, NY 10022

ARMAN TABATABAI GREGORY REISS RESEARCH MILLENNIUM MANAGEMENT LLC MORGAN STANLEY 666 FIFTH AVENUE, 8TH FLOOR 1585 BROADWAY, 38TH FL. NEW YORK, NY 10103 NEW YORK, NY 10036

DAN DELUREY PAUL M. PIETSCH DEMAND RESPONSE AND SMART GRID COALITION RESEARCH COORDINATOR 1301 CONNECTICUT AVE., NW, STE. 350 DRSG COALITION WASHINGTON, DC 20036 1301 CONNECTICUT AVE., NW, STE. 350 FOR: DEMAND RESPONSE AND SMART GRID WASHINGTON, DC 20036 COALITION

RUTH HUPART KATHERINE HOFFMASTER SOLAR ELECTRIC POWER ASSOCIATION SR. REGULATORY AFFAIRS ANALYST



1220 19TH STREET, NW, STE. 800 NEXTERA ENERGY RESOURCES WASHINGTON, DC 20036 700 UNIVERSE BLVD., FEJ/JB JUNO BEACH, FL 33405

DAVID P. LOWREY KELLY CRANDALL DIRECTOR, REGULATORY STRATEGY EQ RESEARCH, LLC COMVERGE, INC. 1400 16TH ST., 16 MARKET SQR., STE. 400 999 18TH STREET, SUITE 2300 DENVER, CO 80202 DENVER, CO 80202

RICK GILLIAM EDWARD JACKSON VOTE SOLAR DIR - REVENUE REQUIREMENTS 1120 PEARL STREET LIBERTY UTILITIES (CALIFORNIA) BOULDER, CO 80302 9750 WASHBURN ROAD / PO BOX 7002 DOWNEY, CA 90241-7002

SHEILA LEE CASE ADMINISTRATION REGULATORY, CONTROLS AND SOLICITATIONS SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE, PO BOX 800 6042 N. IRWINDALE AVENUE, SUITE A ROSEMEAD, CA 91770 IRWINDALE, CA 91702

RAQUEL IPPOLITI RUSSELL GARWACKI PROJECT ANALYST SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. 2244 WANUT GROVE AVENUE ROSEMEAD, CA 91770 ROSEMED, CA 91770

SPENCER EDMISTON NGUYEN QUAN CORPORATE FINANCIAL PLANNING MGR - REGULATORY AFFAIRS EDISON INTERNATIONAL GOLDEN STATE WATER CO. - ELECTRIC OP. 2244 WALNUT GROVE AVENUE 630 EAST FOOTHILL BOULEVARD ROSEMEAD, CA 91770 SAN DIMAS, CA 91773 FOR: GOLDEN STATE WATER COMPANY / BEAR VALLEY ELECTRIC

DAVID CROYLE ANNLYN FAUSTINO EXECUTIVE DIRECTOR REGULATORY & COMPLIANCE UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY 3405 KENYON STREET, STE. 401 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA 92110 SAN DIEGO, CA 92118

CENTRAL FILES HORACE TANTUM SDG&E / SOCALGAS MARKETING MGR., RESCH & ANALYTICS 8330 CENTURY PARK COURT, CP31-E SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA 92123 8326 CENTURY PARK CT., CP62E SAN DIEGO, CA 92123

JOHN A. PACHECO MICHELLE SOMERVILLE ATTORNEY REGULATORY BUSINESS MGR SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT., CP32 8330 CENTURY PARK COURT SAN DIEGO, CA 92123 SAN DIEGO, CA 92123



ROLAND MULLEN SABRINA BUTLER MARKETING MGR. AND RESEARCH SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 9305 LIGHWAVE AVE. 8690 BALBOA AVENUE, CPA03 SAN DIEGO, CA 92123 SAN DIEGO, CA 92123

SANDRA BAULE CHARLES R. MANZUK RATE REFORM MGR, CUSTOMER SVC. DIR. - RATES & REVENUE REQUIREMENTS SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8335 CENTURY PARK CT., CP12F 8330 CENTURY PARK CT, CP31E SAN DIEGO, CA 92123 SAN DIEGO, CA 92123-1530

CYNTHIA FANG DANA GOLAN SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32E 8330 CENTURY PARK CT., CP421 SAN DIEGO, CA 92123-1530 SAN DIEGO, CA 92123-1530

STEVE RAHON WILLIAM FULLER DIR., TARIFF & REGULATORY ACCTS CALIF. REGULATORY AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY (902) SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32C 8330 CENTURY PARK COURT, 32CH SAN DIEGO, CA 92123-1548 SAN DIEGO, CA 92123-1548

JANETTE OLKO JEFF HIRSCH ELECTRIC UTILITY DIVISION MANAGER JAMES J. HIRSCH & ASSOCIATES CITY OF MORENO VALLEY 12185 PRESILLA ROAD 14325 FREDERICK ST., STE. 9 SANTA ROSA VALLEY, CA 93012-9243 MORENO VALLEY, CA 92552

MONA TIERNEY-LLOYD CATHY DEFALCO, EJD, C.P.M. SR. DIR., WESTERN REGULATORY AFFAIRS ENERGY MGR. - REGULATORY ENERNOC, INC. CITY OF LANCASTER PO BOX 378 44933 FERN AVENUE CAYUCOS, CA 93430 LANCASTER, CA 93534

AARON J. LEWIS ROBERT GNAIZDA COUNSEL OF COUNSEL NATIONAL ASIAN AMERICAN COALITION 15 SOUTHGATE AVE., STE. 200 15 SOUTHGATE AVE., STE. 200 DALY CITY, CA 94015 DALY CITY, CA 94015

EDWARD G. CAZALET SUE MARA CEO CONSULTANT TEMIX, INC. RTO ADVISORS, LLC 101 FIRST STREET, STE. 552 164 SPRINGDALE WAY LOS ALTOS HILLS, CA 94022 REDWOOD CITY, CA 94062

DAVID A. SILBERMAN NIRIT ERIKSSON GENERAL COUNSEL SAN MATEO COUNTY COUNSEL'S OFFICE SAN MATEO COUNTY COUNSEL'S OFFICE 400 COUNTY CENTER, 6TH FL. 400 COUNTY CENTER, 6TH FL. REDWOOD CITY, CA 94063 REDWOOD CITY, CA 94063 FOR: PENINSULA CLEAN ENERGY AUTHORITY FOR: PENINSULA CLEAN ENERGY AUTHORITY



MARC D. JOSEPH MILA A. BUCKNER ADAMS BROADWELL JOSEPH & CARDOZO ATTORNEY 601 GATEWAY BLVD., SUITE 1000 ADAMS BROADWELL JOSEPH & CARDOZO SOUTH SAN FRANCISCO, CA 94080 601 GATEWAY BLVD., STE. 1000 SOUTH SAN FRANCISCO, CA 94080

HILARY STAVER ADAM GERZA REGULATORY & LEGISLATIVE ANALYST SULLIVAN SOLAR POWER OF CALIFORNIA, INC. SILICON VALLEY CLEAN ENERGY AUTHORITY 169 11TH STREET 333 W. EL CAMINO REAL, STE. 290 SAN FRANCISCO, CA 94103 SUNNYVALE, CA 94087 FOR: SILICON VALLEY CLEAN ENERGY AUTHORITY (SVCE)

ERIC BORDEN MARCEL HAWIGER ENERGY POLICY ANALYST STAFF ATTORNEY THE UTILITY REFORM NETWORK THE UTILITY REFORM NETWORK 785 MARKET STREET, STE. 1400 785 MARKET ST., STE. 1400 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94103

MERRIAN BORGESON MICHAEL SULLIVAN SR. SCIENTIST, ENERGY PROGRAM FREEMAN SULLIVAN & CO. NATURAL RESOURCES DEFENSE COUNCIL 101 MONTGOMERY ST., 15TH FLOOR 111 SUTTER ST., 20TH FL. SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104

ALLEN F. SMITH CATHERINE TARASOVA PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS & ELECTRIC COMPANY 77 BEALE STREET, ROOM 978 77 BEALE ST., RM. 1053, MC B10A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

CHARLES R. MIDDLEKAUFF DEREK JONES PACIFIC GAS AND ELECTRIC COMPANY NAVIGANT CONSULTING, INC. LAW DEPT. ONE MARKET ST., SPEAR TOWER, SUITE 1200 77 BEALE STREET, B30A / BOX 7442 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

JAMIE FINE JANE OLIVEIRA SR. ECONOMIST PACIFIC GAS & ELECTRIC COMPANY ENVIRONMENTAL DEFENSE FUND 77 BEALE STREE B10B 123 MISSION ST., 28TH FLOOR SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: ENVIRONMENTAL DEFENSE FUND

MARGOT EVERETT SHIREY A. WOO SENIOR DIRECTOR ATTORNEY PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE ST., B10B 77 BEALE STREET, B30A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

TONY ROBERTS ANDY SCHWARTZ CONSUMER FEDERATION OF CALIFORNIA TESLA, INC.



150 POST STREET, STE. 442 444 DE HARO ST., STE. 101 SAN FRANCISCO, CA 94106 SAN FRANCISCO, CA 94107

CHARLIE BUCK ELIAH GILFENBAUM MGR, MARKET DEV. & REGULATORY AFFAIRS DEPUTY DIR ORACLE / OPOWER TESLA, INC. WEST DIVISION 444 DE HARO STREET, STE. 101 680 FOLSOM STREET, 3RD FLOOR SAN FRANCISCO, CA 94107 SAN FRANCISCO, CA 94107

FRANCESCA WAHL SERJ BERELSON SR. ASSOCIATE, BUS. DEVELOPMENT OPOWER TESLA, INC. 680 FOLSOM STREET, 3RD FLOOR 444 DE HARO STREET, STE. 101 SAN FRANCISCO, CA 94107 SAN FRANCISCO, CA 94107

CASSANDRA SWEET VIDHYA PRABHAKARAN REPORTER ATTORNEY DOW JONES NEWSWIRES DAVIS WRIGHT & TREMAINE LLP 201 CALIFORNIA ST. 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: CALIFORNIA PACIFIC ELECTRIC COMPANY, LLC

VIDHYA PRABHAKARAN BRIAN ORION ATTORNEY LAWYERS FOR CLEAN ENERGY DAVIS WRIGHT & TREMAINE LLP 656A CLAYTON STREET 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94117 SAN FRANCISCO, CA 94111

CALIFORNIA ENERGY MARKETS STEVE HAERTLE 425 DIVISADERO ST STE 303 PACIFIC GAS & ELECTRIC COMPANY SAN FRANCISCO, CA 94117-2242 77 BEALE STREET, ROOM 967, MC B9A SAN FRANCISCO, CA 94120

STEPHEN M. BARRAGER MELISSA BRANDT BAKER STREET PUBLISHING, LLC PACIFIC GAS & ELECTRIC OCMPANY 2703 BRODERICK STREET PO BOX 770000, MC B10A SAN FRANCISCO, CA 94123 SAN FRANCISCO, CA 94177

RICK COUNIHAN MARC KOLB NEST LABS, INC. TESLA, INC. 3400 HILLVIEW AVENUE 3055 CLEARVIEW WAY PALO ALTO, CA 94304 SAN MATEO, CA 94402

BONNIE DATTA KERRY HATTEVIK SIEMENS USA REG. DIR.- WEST GOVERNMENTAL AFFAIRS 4000 E. THIRD AVENUE NEXT ERA ENERGY RESOURCES LLC FOSTER CITY, CA 94404 829 ARLINGTON BLVD. EL CERRITO, CA 94530

MATTHEW BARMACK MELISSA BRANDT DIR. - MARKET & REGULATORY ANALYSIS EAST BAY COMMUNITY ENERGY



CALPINE CORPORATION 1111 BROADWAY, SUITE 3000 4160 DUBLIN BLVD., SUITE 100 OAKLAND, CA 94607 DUBLIN, CA 94568

CATHY YAP JASON B. KEYES BARKOVICH & YAP, INC. ATTORNEY PO BOX 11031 KEYES & FOX LLP OAKLAND, CA 94611 436 14TH STREET, STE. 1305 OAKLAND, CA 94612

MATTHEW VESPA REKHA RAO SR. ATTORNEY NEXTILITY SIERRA CLUB 2015 SHATTUCK AVE., 5TH FLOOR 2101 WEBSTER ST., STE. 1300 BERKELEY, CA 94704 OAKLAND, CA 94612

ALEX MORRIS JIN NOH DIR - POLICY & REGULATORY AFFAIRS SR. CONSULTANT STRATEGEN CONSULTING STRATEGEN CONSULTING 2150 ALLSTON WAY, STE. 210 2150 ALLSTON WAY, STE.210 BERKELEY, CA 94709 BERKELEY, CA 94709

TOM BEACH ANDREW G. CAMPBELL PRINCIPAL EXEC.DIR.- ENERGY INSTITUTE AT HAAS CROSSBORDER ENERGY UNIVERSITY OF CALIFORNIA, BERKELEY 2560 NINTH STREET, SUITE 213A 2547 CHANNING WAY BERKELEY, CA 94710 BERKELEY, CA 94720-5180

NATHANIEL MALCOLM JASON SIMON REGULATORY LAW CLERK DIR - POLICY STRATEGY MARIN CLEAN ENERGY ENPHASE ENERGY 1125 TAMALPAIS AVE. 1420 N. MCDOWELL BLVD. SAN RAFAEL, CA 94901 PETALUMA, CA 94954

JENNIFER HOLMES C. SUSIE BERLIN INDEPENDENT CONSULTANT LAW OFFICES OF SUSIE BERLIN PO BOX 4235 1346 THE ALAMEDA, STE. 7, NO. 141 SANTA CRUZ, CA 95063 SAN JOSE, CA 95126

JIMI NETNISS SCOTT VAN VUREN MODESTO IRRIGATION DISTRICT MODESTO IRRIGATION DISTRICT 1231 11TH STREET 1231 11TH STREET MODESTO, CA 95354 MODESTO, CA 95354

BRIAN THEAKER WILLIAM MARCUS DIRECTOR - MARKET AFFAIRS MCPM ECONOMICS NRG ENERGY, INC. 618 COURT ST., STE. C 3161 KEN DEREK LANE WOODLAND, CA 95695 PLACERVILLE, CA 95667 FOR: TURN

CAMILLE STOUGH, ESQ. CURT BARRY BRAUN BLAISING MCLAUGHLIN & SMITH PC SENIOR WRITER 915 L STREET, STE. 1480 CLEAN ENERGY REPORT



SACRAMENTO, CA 95814 717 K STREET, SUITE 503 SACRAMENTO, CA 95814

DAN GRIFFITHS JUSTIN WYNNE ATTORNEY ATTORNEY BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 915 L STREET, SUITE 1480 915 L STREET, SUITE 1480 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CALIFORNIA MUNICIPAL UTILITIES ASSOCIATION (CMUA)

KEVIN WOODRUFF NANCY SARACINO CONSULTANT MANAGING ATTORNEY WOODRUFF EXPERT SERVICES WESTERN ENERGY & WATER 1127 - 11TH STREET, SUITE 514 500 CAPITOL MALL, STE. 2350 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814

REGULATORY CLERK SARAH KOZAL BRAUN BLAISING SMITH WYNNE ATTORNEY 915 L STREET, STE. 1480 WESTERN ENERGY & WATER SACRAMENTO, CA 95814 500 CAPITOL MALL, STE. 2350 SACRAMENTO, CA 95814

STEVEN KELLY RONALD LIEBERT POLICY DIRECTOR ATTORNEY AT LAW INDEPENDENT ENERGY PRODUCERS ASSCIATION ELLISON, SCHNEIDER & HARRIS 1215 K STREET, STE. 900 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA 95814 SACRAMENTO, CA 95816 FOR: CALIFORNIA MANUFACTURERS & TECHNOLOGY ASSN

LYNN HAUG ANN L. TROWBRIDGE ELLISON, SCHNEIDER & HARRIS L.L.P. ATTORNEY 2600 CAPITOL AVENUE, SUITE 400 DAY CARTER & MURPHY LLP SACRAMENTO, CA 95816-5931 3620 AMERICAN RIVER DR., STE. 205 SACRAMENTO, CA 95864

BOB DODDS CALIFORNIA PACIFIC ELECTRIC COMPANY, LLC 933 ELOISE AVENUE 933 ELOISE AVENUE SOUTH LAKE TAHOE, CA 96150 SOUTH LAKE TAHOE, CA 96150 FOR: CALIFORNIA PACIFIC ELECTRIC COMPANY, LLC

SARA BIRMINGHAM CATHIE ALLEN SOLAR ENERGY INDUSTRIES ASSOCIATION REGULATORY AFFAIRS MGR. 3300 NE 157TH PLACE PACIFICORP PORTLAND, OR 97230 825 NE MULTNOMAH ST., STE 2000 PORTLAND, OR 97232

SARAH WALLACE NKECHI OGBUE SENIOR ATTORNEY MGR - REGULATORY AFFAIRS PACIFICORP ECOBEE, INC. 825 NE MULTNOMAH, STE. 1800 250 UNIVERSITY AVE. SUITE 400 PORTLAND, OR 97232 TORONTO, ON M5H 3E5



FOR: PACIFICORP CANADA

State Service

BENJAMIN GUTIERREZ JESSICA T. HECHT CALIFORNIA PUBLIC UTILITIES COMMISSION ALJ ORA - ECPCP CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

NOEL OBIORA PATRICK DOHERTY ATTORNEY CALIFORNIA PUBLIC UTILITIES COMMISSION CPUC ENERGY DIV. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

PAUL S. PHILLIPS SCOTT MURTISHAW CPUC ENERGY ADVISOR ENERGY DIV CPUC - EXEC DIV EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

SHANNON O'ROURKE TIM DREW CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

TORY FRANCISCO WHITNEY RICHARDSON CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION ENERGY DIVISION - RESIDENTIAL PROGRAMS ENERGY DIVISION - RETAIL RATES EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

ZAIDA C. AMAYA AVA N. TRAN CALIFORNIA PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION - RESIDENTIAL PROGRAMS ENERGY EFFICIENCY BRANCH EMAIL ONLY AREA 4-A EMAIL ONLY, CA 00000 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

CHERIE CHAN CHRISTOPHER HOGAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

CODY NAYLOR DAVID PECK CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION UTILITY & PAYPHONE ENFORCEMENT BRANCH PRESIDENT PICKER AREA ROOM 4108 505 VAN NESS AVENUE 505 VAN NESS AVENUE



SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

DEVLA SINGH DEXTER E. KHOURY CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION CARRIER OVERSIGHT AND PROGRAMS BRANCH ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 3-F ROOM 4209 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

ENRIQUE GALLARDO ERIC DURAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM 4011 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA

GABRIEL PETLIN JAMES SIMMONS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN WATER BRANCH AREA 4-A ROOM 4209 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JAMIE ORMOND JEANNE MCKINNEY CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION MARKET STRUCTURE, COSTS AND NATURAL GAS DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM 5113 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JEORGE S. TAGNIPES JOANNA GUBMAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH COMMISSIONER RANDOLPH AREA 4-A AREA 4-A 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 MARNA ANNING CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM UTILITY & PAYPHONE ENFORCEMENT BRANCH ROOM 4209 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

MARZIA ZAFAR MASOUD FOUDEH CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION



POLICY & PLANNING DIVISION DEMAND RESPONSE, CUSTOMER GENERATION, AN ROOM 5119 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

MATTHEW A. KARLE MICHELE KITO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM PROCUREMENT STRATEGY AND OVERSIGHT BRANC ROOM 4108 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

NATHAN BARCIC NATHAN CHAU CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

NEHA BAZAJ RAJAN MUTIALU CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN POLICY & PLANNING DIVISION AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

ROBERT LEVIN S. PAT TSEN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM 5005 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

SEAN A. SIMON SOPHIA PARK CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER RECHTSCHAFFEN DIVISION OF ADMINISTRATIVE LAW JUDGES AREA 4-A ROOM 5024 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

STEPHEN C. ROSCOW STEPHEN ST. MARIE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES POLICY & PLANNING DIVISION ROOM 5109 ROOM 5119 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

VALERIE KAO YULIYA SHMIDT CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES COMMISSIONER RECHTSCHAFFEN AREA ROOM 4209 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214



ZHEN ZHANG LYNN MARSHALL CALIF PUBLIC UTILITIES COMMISSION CONSULTANT LEGAL DIVISION CALIFORNIA ENERGY COMMISSION ROOM 5130 1516 9TH STREET, MS-20 505 VAN NESS AVENUE SACRAMENTO, CA 95814 SAN FRANCISCO, CA 94102-3214

MATT COLDWELL PATRICK SAXTON CALIFORNIA ENERGY COMMISSION ADVISOR TO COMM. ANDREW MCALLISTER ELECTRICITY ANALYSIS OFFICE CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS-20 1516 NINTH ST., MS-37 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814

ROBERT RIDGLEY TIFFANY MATEO ENERGY COMMISSION SPECIALIST I MECHANICAL ENGINEER CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS-26 BLDG & COMPLIANCE OFFICE, EFFICIENCY DIV SACRAMENTO, CA 95814-5512 1516 NINTH STREET, MS-26 SACRAMENTO, CA 95814-5512

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

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