state of california...angela whatley attorneys for southern california edison company 2244 walnut...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Order Instituting Rulemaking Concerning Energy Efficiency Rolling Portfolios, Policies, Programs, Evaluation, and Related Issues.

Rulemaking 13-11-005

SOUTHERN CALIFORNIA EDISON COMPANY'S ( U 338-E) OPENING COMMENTS ON ADMINISTRATIVE LAW JUDGE’S RULING SEEKING COMMENTS

REGARDING NATURAL RESOURCE DEFENSE COUNCIL MOTION

ANNA VALDBERG ANGELA WHATLEY Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-3618 E-mail: [email protected]

Dated: September 1, 2020

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STATE OF CALIFORNIA



SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON ADMINISTRATIVE LAW JUDGE’S RULING SEEKING COMMENTS

REGARDING NATURAL RESOURCE DEFENSE COUNCIL MOTION

Pursuant to the Assigned Commissioner Administrative Law Judge’s Ruling on July 31,

2020 (Ruling), Southern California Edison Company (SCE) appreciates the opportunity to

submit the following comments and responses to the questions set forth in the Ruling.

I.

INTRODUCTION

The Ruling invites parties to provide comments on the April 24, 2020 motion filed by

Natural Resources Defense Council (NRDC), regarding the California Energy Efficiency

Coordinating Committee (CAEECC) Energy Efficiency Portfolio Filing Process Working Group

Report (Report) and respond to 22 questions in the Ruling. The report contains consensus

recommendations to improve the energy efficiency portfolio and budget approval

implementation process.

SCE participated in drafting the proposal and supports each of the consensus

recommendations found in the report.

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II.

DISCUSSION

SCE supports revisions to the rolling portfolio business plan process in order to achieve

EE policy goals. The current annual budget advice letter (ABAL) process, which was initially

intended to be ministerial, is now used to review EE portfolios and budgets on an annual basis.

This detailed level of annual review places a high burden on Energy Division (ED) and program

administrator (PA) resources, as well as on other parties, while doing little to facilitate long term

planning or funding stability.

The CAEECC Proposal for Improvements to the Energy Efficiency (EE) Portfolio and

Budget Approval and Implementation Process (CAEECC proposal or proposal) allows for a

more reasonable and less cumbersome approach to approving the EE portfolios and enhances the

effectiveness and efficiency of regulatory oversight. The proposal’s 4-year process that aligns

cost effectiveness, savings goal measurements and policy decisions will allow for greater

stability in the EE marketplace. At the same time, enhanced EE Annual Reporting, monitoring

through enhanced stakeholder engagement, and trigger-based filings will maintain Commission

oversight while avoiding the inefficiencies of the ABAL process. This consensus proposal is the

optimal overall approach to balance the interests at stake in this process. For example, this

proposal aims to balance frequent enough updates to engineering values and EM&V and

providing stability and certainty to program implementers. While updating technical values less

frequently means that the data may lag slightly, the benefit is reduced risk for implementers and

a lower cost of delivering savings.

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III.

RESPONSES TO RULING QUESTIONS

1. What are the major challenges or benefits associated with the current

Rolling Portfolio cycle length and budget authorization structure?

The CAEECC 4-year working group Prospectus is correct that the current process is

“ineffective in balancing meaningful oversight with timely, predictable portfolio authorization.”1

The Business Plan covered 10 years with multiple updates to potential and goals, avoided costs,

and technical inputs making a 10-year forecast difficult and essentially unreliable in the later

years. Additionally, the current ABAL process is administratively inefficient, requiring

significant time and resources for the Program Administrators (PAs) to develop each year and a

significant amount of Commission and other stakeholders resources to review the ABAL filings.

The CAEECC proposal will provide meaningful oversight, accurate forecasting, and portfolio

stability. Importantly, the four-year cycle aligns a mid-cycle true up with every other year

Potential and Goals (P&G) updates which is administratively efficient.

In addition, the current process has a disconnect between the way in which the P&Gs are

currently set and how the portfolio is implemented and evaluated. In particular, the P&Gs are set

using one set of avoided costs and engineering assumptions, but the EE Portfolio is assessed

using an older set of avoided costs and engineering assumptions. This asymmetry increases the

potential for EE Portfolios that are either not cost-effective or not able to meet the goals set by

the Commission. Additionally, this approach may result in regulatory inefficiency as

demonstrated by refiling and litigation of revised Business Plans when cost effectiveness or

savings goals are not met. The CAEECC proposal strikes the right balance of provide portfolio

stability while incorporating timely updates of potential and goals, avoided costs, and

engineering assumptions.

1 See NRDC Motion, Appendix B: CAEECC‐Hosted Energy Efficiency Portfolio Filing Processes Working Group Prospectus, p. 23, [hereinafter Appendix B].

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2. If you perceive challenges with the current cycle length and budget

authorization structure, do you agree that the proposal in the NRDC motion

remedies those challenges? Why or why not?

Yes, the proposal strikes the right balance in maintaining portfolio oversight by ED and

other stakeholders while providing the PAs and implementers reasonable certainty and flexibility

to meet the State’s goals for EE.

In particular, the proposal will remedy several challenges through its goals of:2

• CPUC commitment to long‐term funding availability for all cost‐effective

EE;

• Reasonableness of savings and budget forecasts;

• Meaningful oversight of PA budgets and activities;

• Reduced administrative burden; and

• Flexibility for PAs and program implementers to respond to market and

policy fluctuations.

SCE commends the CAEECC working group for working with interested stakeholders

throughout the process to incorporate diverse viewpoints into a framework that resolves the

challenges inherent in the current regulatory model.

2 NRDC Motion Attachment A: Proposal for Improvements to the EE Portfolio and Budget Approval and Implementation Process, p. 4, [hereinafter Attachment A].

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3. One of the objectives of the current 10-year budget authorization was to

provide long-term funding certainty for the energy efficiency programs and

to support long-term planning activities by the California Energy

Commission and the California Independent System Operator. Do you

believe that shortening the budget authorization cycle may negatively impact

these objectives? Why or why not?

No. The proposal states that “if there is a delay in regulatory approval of the subsequent

application cycle, the PA would continue to implement their programs with the current approved

budgets at the average yearly budget of the currently approved four-year cycle until such time as

the CPUC decides on the application.”3 This certainty that funding will not lapse even if

consideration of an application takes longer than expected results in sufficient budget certainty to

support planning activities by the CEC and CAISO.

4. Instead of the proposal in the NRDC motion, would more incremental

modifications to the current Rolling Portfolio better address identified

challenges with the current structure? For instance, would replacing annual

budget advice letters, with Tier 2 budget advice letters submitted every two

years aligned with biennial goal updates, resolve current challenges identified

with the Rolling Portfolio process? Why or why not?

As stated above, the CAEECC proposal strikes the right balance of providing ED and

other stakeholders appropriate regulatory oversight while providing the PAs certainty and

flexibility to meet the State’s goals for EE. While a biennial ABAL could partially address some

of the issues outlined in the CAEECC prospectus, the CAEECC proposal is broader than simply

changing the ABAL process. For example, adopting the CAEECC proposal would also achieve

the critical alignment of technical inputs and avoided costs between portfolio goal setting and

3 Attachment A, Section 5.2, Page 9.

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portfolio assessment. Moving to a biennial budget advice letter without addressing the current

misalignment of the goal setting and assessment process would continue to result in ABALs and

EE portfolios failing to yield the results of the P&G consistent with procuring all cost-effective

energy efficiency. The CAEECC proposal also updates the CAEECC stakeholder engagement

approach associated with the application process to make most effective use of stakeholders’

insights and increase the likelihood of finding the best solutions to the most challenging

problems. Simply switching to biennial goals would not address these other items.

5. What is the appropriate oversight role of Commission staff during energy

efficiency program implementation (i.e., mid-cycle between CPUC budget

authorization points)? Does the proposal in the NRDC motion ensure this

level of oversight? Please support your answer.

The proposal maintains current reporting requirements for ongoing portfolio data

including quarterly data CEDARS reporting and EE Annual Reports. The CAEECC proposal

recommends enhancements to the EE Annual Reports that include descriptions of upcoming

portfolio, program, and solicitation initiatives in light of current performance and provides an

opportunity for the Commission to provide regulatory oversight. Furthermore, PAs will present

EE Annual Report data to CAEECC for discussion along with input on any necessary directional

changes.4

Section 4.4 of the proposal includes provisions for trigger-based filings when a PA makes

certain changes to its portfolio mid-cycle. These filings will provide an additional venue for

CPUC oversight and approval.

As described in the CAEECC proposal, the Commission’s oversight role during program

implementation will include review of EE Annual Reports and quarterly data reports in

4 Id. at Section 4.3, p. 6.

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CEDARS to assess whether PAs are triggering any additional filing requirements and to verify

that the PA has signaled its intent to make the necessary trigger-based filing(s).5

6. Do you agree that a program administrator is not “on-target” if they are not

reasonably able to meet their savings goals by 20 percent and cost-

effectiveness target by 10 percent, or would you propose different thresholds

to determine whether a program administrator is “on-target?” Please

explain your recommendation.

SCE agrees with the proposal’s definition of “on-target”6 and the associated percentages.

This definition provides a balance that allows for year-to-year variation in program activity while

requiring a reasonable likelihood of meeting multiyear goals.

SCE clarifies that exceeding the savings or cost effectiveness goals by 20 percent or 10

percent respectively should not be considered as criteria for a PA being “off-target” because

savings and cost effectiveness goals are minimum levels. It would not be reasonable to require a

PA to make corrective actions as a result of exceeding goals. SCE recommends that the adopted

version of the CAEECC proposal clarify that a PA only meets an “off-target” trigger if it is

below (not above) the savings or cost effectiveness goals by 20 percent or 10 percent

respectively.

5 Attachment A, at Section 7.0, p. 12. 6 Id. at Section 4.4, p. 7, n.4 “On-target” is defined as a PA is reasonably able to demonstrate its ability

to meet savings goals (+/- 20%) and cost effectiveness goals (+/- 10%) by the end of the four-year cycle.

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7. What is the expected outcome of having program administrators submit a

Tier 2 advice letter if they are not “on-target” to meet their savings goals, or

cost-effectiveness thresholds? Is Energy Division staff expected to review the

program administrator’s proposed mitigation measures and approve

changes? If so, what are the standards of review, or criteria? If not, is there

an alternative cycle length and budget authorization structure that would

address these challenges? Please support your recommendation.

The expected outcome of the trigger-based interim filing requirement is that PAs will

recognize trends observed in their portfolios, bring these observations and proposed solutions

addressing these trends and observations to CAEECC for feedback and review, and then submit

a Tier 2 advice letter containing the solutions with CAEECC feedback which is then reviewed

for reasonableness and approved by ED staff. Implementing the solutions and changes as

reviewed and approved by ED staff will result in improvements to the portfolio and place it back

on track to achieve goals by the end of the 4-year cycle.

In D.18-05-041,7 the Commission authorized ED staff to determine that PA Annual

Budget Advice Letters meet specific criteria including savings and cost effectiveness goals.

Similar to the current ABAL process, SCE recommends that PA-forecasted TRC and savings

goals claims be subject to ED staff verification.8 Additionally, ED staff should be authorized to

review the reasonableness of a PA’s mitigation measures and approve changes to the PA’s

portfolio to ensure that the portfolio will reasonably meet goals by the completion of the 4-year

term. In place of the workshop process used during the transition period,9 the PAs should engage

with CAEECC prior to submitting any trigger-based filings. As described in the CAEECC

7 D.18-05-041, pp 132-137. 8 Cost-effectiveness threshold policy decisions are currently under consideration in R.13-011-005

Potential and Goals Ruling (dated March 12, 2020). The CAEECC proposal is agnostic to the particular threshold (i.e. TRC of 1.25 or 1.0) and can accommodate either of these values.

9 D.18-05-041, p 135.

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Proposal,10 the objective of this process is to collaborate, solve challenges, and incorporate the

best solutions ahead of the filing.

8. How should staff or the Commission remedy a situation where the program

administrator does not provide adequate corrective actions in the Tier 2

advice letter?

If, in the judgment of Commission staff, a Program Administrator is unable to

demonstrate reasonable corrective actions, that are expected to bring its portfolio back on target

without exceeding the authorized 4-year portfolio budget, the PA should be directed by

Commission staff to file a new business plan application under the same logic used in the current

process.11

9. Should progress towards cycle goals and cost-effectiveness be assessed

quarterly, yearly, annually, or in some other increment? Please address why

the recommended increment is the most appropriate point, given the need to

balance natural portfolio fluctuations and the time requirements of

remediation efforts.

The CAEECC proposal provides several opportunities for assessing progress toward

goals. In particular, the proposal recommends that the enhanced Annual Report be the primary

vehicle for the PAs to provide updates on the progress to date and trajectory of the entire four-

year cycle. Specifically:

[t]he Annual Report will also present a prospective overview in narrative format that will include future plans to meet and/or exceed the cumulative four‐year energy savings goals and the four-year C/E requirement, and other CPUC approved REN‐specific energy savings targets and non‐energy related metrics. The prospective overview will include any

10 Attachment A Section 8.3.3, p. 17. 11 D.18-05.041, p 57.

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program adaptations, additional solicitations, or other strategies that may be necessary to help ensure attainment of the four‐year energy savings goals and the portfolio C/E requirement.12

These annual reports are the primary vehicle for stakeholders to assess that PAs are

making sufficient progress toward the goals and/or making adequate adjustments if sufficient

progress is not being made.

In addition to the annual report, PAs will continue to file the existing monthly and

quarterly reports in CEDARS. These reports are publicly available and provide details on each

PA’s portfolio budgets, expenditures, and savings progress.

The CAEECC proposal also provides a new process by which the Commission and

stakeholders can provide feedback via “semi-annual data driven updates on EE portfolio progress

at the CAEECC.”13 These updates will allow the PAs to receive meaningful input from

CAEECC stakeholders to help address portfolio challenges.

Lastly, the CAEECC proposal provides for several trigger-based filings as a result of

program closure, additional budget needed, or if the portfolio is not on target to meet the 4-year

savings goals or cost-effectiveness targets. These trigger-based filings would occur any time the

trigger is met and would require either an Advice Letter or Application, allowing the

Commission to appropriately provide additional oversight. These changes will provide PAs the

flexibility to administer their programs through changing market conditions, while allowing

stakeholders and the Commission oversight to determine that sufficient progress is being made

toward meeting goals.

10. Should this process be based on a periodical “bus stop” basis, or on a more

“as needed” basis? Please explain your answer.

See response to Question 9 above – the CAEECC proposal includes periodic assessment

with the potential to trigger additional action.

12 Attachment A, Section 4.3, p. 6. 13 Id.

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11. What is the oversight role for Energy Division in enforcing a trigger event,

and how should the remediation Tier 2 advice letter be triggered: via Annual

Report/ submission to the California Energy Data and Reporting System

(CEDARs), via updates to technical inputs, either/both, or other? Please

provide details to support your recommendation.

Because the criteria for each triggering event described in the proposal is objective,

Program Administrators are responsible for recognizing when criteria are met and submitting the

resulting required advice letter. If a PA fails to recognize when criteria are met, the ED should

compel the PA to submit the appropriate filing.

Interim filings triggered by a portfolio which is found to be “off-target” should be

identified and acknowledged in a PA’s EE Annual Report. While natural fluctuations will occur

in portfolios throughout a program year, the PAs should have the opportunity to make

adjustments and bring the portfolio back on target. For example, if a PA projects that in the first

year they will achieve 20 percent of their 4-year savings goal, then the EE Annual Report must

also project expected savings for the subsequent three years, and if the projection shows that the

portfolio will achieve less than 60 percent of the savings in the subsequent year for a total of 80

percent for the entire 4-year period, then the PA has activated the trigger. As a result, the PA

must then file a trigger-based Tier 2 Advice Letter outlining the corrective actions required to

bring the portfolio back on target. These steps could include, but are not limited to, proposing

fund shifts, program closures, and/or new solicitations. ED will track the annual report,

stakeholder workshops, and other regulatory reports to ensure that the triggers have not been

met.

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12. The investor owned utilities (IOUs) are required to reach specific percentage

targets for the proportion of their portfolios to be administered by third

parties (ultimately, at least 60 percent). Because the IOUs cannot change

program implementation plans for a third-party contract, the lever for a

program administrator to ensure their portfolio is on target is to

add/decrease effort in high-/poor-performing activities, respectively.

Considering this, how can an appropriate level of oversight for program

cancellation occur without impeding IOUs’ ability to stay on target?

Third party programs are subject to the contracts signed between the PA and the third

party. The Commission exercises its oversight for third party program cancelation when it

reviews and approves contracts valued above $5 million or a term longer three years or longer at

the conclusion of the solicitation process.

To manage decreasing and poor performing programs, IOUs should be allowed to retain

the operational implementation of its contracts to avoid impeding an IOU’s ability to meet its

savings targets. For example, if a program is achieving its savings targets while

underperforming on cost-effectiveness, IOUs should have the ability to manage the portfolio

needs while remaining in the bounds of the CPUC-approved contract. D.16-08-019 expressed a

preference for pay for performance provisions in IOUs’ third-party contracts,14 which will

further enable portfolio management by allowing funds to be shifted away from underperforming

third party programs. The EE Annual Report includes details on progress of the IOUs’ goal

achievement and is an appropriate venue for the Commission to assess the reasonableness of the

IOUs’ efforts and ability to meet the required savings and cost-effectiveness objectives. The

IOUs’ current contracting and fund shifting abilities are sufficient to increase output for high

performing programs and to solicit for replacement or additional programs when necessary to

meet portfolio goals. SCE expects that there will continue to be additional opportunities for

14 See D.16-08-019 pp. 61, 75 and D.18-01-004, p. 42.

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IOUs to improve the performance of their portfolios through additional solicitations for third

party programs. To streamline supplementing portfolios with additional third-party programs,

the Commission may wish to consider an assessment of the current two-stage solicitation process

to evaluate if a single stage process may be more efficient to meet targeted portfolio needs and

fill additional gaps.

13. The Rolling Portfolio leveraged annual budget advice letters for oversight of

program closures at a high level (e.g., is the closure justified given the

constraint on the program administrator to meet required portfolio cost-

effectiveness and savings goals; and did the program administrator develop

and communicate a transition plan appropriate to avoid cliffs or gaps in the

market). The NRDC motion proposes a program administrator would be

required to submit a Tier 2 advice letter for every program closure.

a) What would staff’s standard of review for program closure advice

letters be?

b) Does this approach leave flexibility that the program administrator

would need to meet its overall portfolio cost-effectiveness target and

savings goals?

The standard of review for program closures should be unchanged from the current

standard applied to the ABAL process.15 Similarly, the same information that is currently

provided for programs the PA proposes to terminate should be supplied in the Tier 2 advice

letters for program closures including any transition plans necessary to avoid gaps in the market.

This approach provides greater flexibility than the current process by allowing program

15 See D.18-05-041, p. 128.

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realignments and closures on an “as needed” basis instead of on the annual schedule in the

current ABAL process.

SCE clarifies that the process described in the CAEECC proposal should only apply to

the PA administered programs. Third party programs would be adjusted or terminated per the

terms of the contracts, most of which are reviewed and approved by the Commission prior to

implementation.

14. The July 3, 2020 amended scoping ruling proposes the Commission issue a

guidance decision addressing the NRDC motion in February or March of

2021. If the Commission issues a guidance decision in early 2021, what

specific areas, inputs, portfolio direction should the Commission prioritize

including in the guidance decision?

The overall goal of a guidance decision should be to provide a stable framework on

which PAs can develop their business plans due on September 1, 2021. As described in the

CAEECC proposal,16 SCE recommends the Commission prioritize issues that would impact the

successful implementation of a 4-year EE portfolio including providing updated guidance and

policy concerning avoided costs, potential and goals, and other ex‐ante technical parameters such

as engineering values (e.g., DEER, eTRM, work papers) and industry standard practice (ISP)

baselines. When considering policy updates in these areas, the Commission should consider how

the update cadence could impact the move to a 4-year portfolio cycle. In other words, if the new

business plans filed on September 1, 2021 are to be the start of a 4-year cycle, inputs used for

forecasts, mentioned above, during that 4-year cycle should be aligned and made effective

concurrently as new business plans are implemented. The Commission’s guidance decision

should also address when future updates to policy will take place and, similarly, the guidance

decision should align policy updates with the new 4-year cycle, if adopted.

16 Attachment A, Section 4.2, p. 6.

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In addition to action on the CAEECC 4-year application proposal, SCE recommends that

the Commission take action on the policy issues in the March 12 Potential and Goals Ruling,17 so

that PAs can develop applications and portfolios with these key policy considerations already

resolved. Other issues identified in the July 3, 2020 amended scoping ruling will have less

impact on portfolio design that will be presented in PA business plans to be filed September 1,

2021 and should be addressed by the Commission as soon as practicable after the priority issues

SCE identified above are resolved by the Commission.

15. The NRDC motion identifies information to be included in the program

administrators’ applications. Given the information provided in the

applications, what should be the Commission’s standard of review, or

criteria, to determine reasonableness of the applications? Should the

Commission provide a detailed review of each program proposed, or focus on

portfolio-level metrics, or evaluate sector-level strategies? Or should this

review focus on other information provided?

Similar to the General Rate Case proceedings, the IOU EE Portfolio Applications are

Cost of Service filings and should be reviewed under a similar reasonableness standard. Thus,

SCE recommends that the Commission first review the reasonableness of the portfolio level

metrics so that portfolio metrics are aligned with Potential and Goals, and other Commission

adopted EE policies and guidance. Next, SCE recommends that the Commission review the

reasonableness of the sector level strategies so that these strategies reasonably support the overall

portfolio metrics. Finally, SCE recommends that the Commission review the reasonableness of

the specific programs in each sector to determine that the programs in these sectors are necessary

to support the sector level strategies and portfolio metrics. This program-level reasonableness

review should include a review of the reasonableness of the forecast costs for each program.

17 See, Administrative Law Judge’s Ruling Inviting Responses to Potential and Goals Policy Questions, March 12, 2020.

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Consistent with the CAEECC proposal, this reasonableness review can be accomplished by the

PAs providing appropriately detailed testimony and workpapers to support the program by

program forecast costs similar to any other cost of service proceeding before the Commission.

16. What additional information should be included in the applications to

facilitate the Commission’s reasonableness review? For instance, should the

applications include portfolio and sector metrics, and implementation plans

for every new or revised program proposed?

SCE recommends that the Commission issue new guidance for Portfolio applications

building upon the current 10-year rolling portfolio process found in D.15-10-02818 and The

Business Plan Guidance Document,19 but streamlined to reflect the new majority third-party

implemented paradigm. In addition to existing requirements, applications should also include a

portfolio plan which describes the PAs approach to achieving EE, equity, and GHG goals in

detail by setting strategic objectives by sector which are supported by tactics which tie back to

achieving the objectives. This section should also describe the metrics and milestones that will

be used to measure each activity.

SCE supports the CAEECC proposal which states that that PAs should also be required to

demonstrate the reasonableness of budgets, savings, and cost effectiveness forecasts by

providing “detailed testimony to ensure a robust and sufficient record”20 to support the details of

proposed expenditures, and supporting workpapers and exhibits, for each year of the four-year

cycle. Budgets for both program implementation and portfolio administration costs should be

approved by the CPUC for each year of the four-year cycle.

18 See D.15-10-028, pp.46-58. 19 See Business Plan Guidance Document dated May 2, 2016, available at https://4930400d-24b5-474c-

9a16-0109dd2d06d3.filesusr.com/ugd/0c9650_17039cf0febd483ca48440bb6ef41d66.pdf. 20 Attachment A, Section 4.1, pp. 5- 6.

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To avoid funding cliffs in the event of a delay in approval of a subsequent application

cycle budget, the proposal recommends that funding should continue at the average yearly

budget of the previous four-year cycle until the CPUC decides on the new application.21

17. For the purpose of approving budgets and assessing cost-effectiveness, what

should be the distinction (if any) between program administrator and

program implementor costs?

a) What is the rationale behind the Commission reviewing program

administrator and program implementor costs separately, when

historically program administrators have been ultimately responsible

for developing contracts with program implementors and reporting

cumulative program costs?

As the PAs move to greater percentages of programs that are proposed, designed, and

delivered by third parties, it is worth reconsidering how budgets and expenses are tracked and

reported. During the CAEECC working group, parties recommended that costs be budgeted and

tracked separately for program administrator and program implementer costs. This shift of the

IOU’s role from being a portfolio implementer to primarily a portfolio administrator necessitates

a rethinking of the ways in which costs are allocated and assessed for reasonableness. SCE

supports this change to allow stakeholders to provide meaningful feedback on each PA’s

portfolio.

b) If reviewed separately, should both program administrator and

program implementer costs be capped at 10 percent cumulatively?

The intent of the 10 percent administrative cap is to contain administrative costs for

energy efficiency programs and maximize benefits to ratepayers. In D.09-09-047, the

21 Id. at Section 5.2, p. 9.

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Commission set an administrative cap of 10 percent for utility-managed programs taking into

account economies of scale of a utility administering multiple programs.22 The decision

describes imposing a 10 percent administrative cost cap on third party and local government

programs as “excessively burdensome for utilities, third party contractors, and government

partners.”23 The decision goes on to direct utilities to seek to achieve a 10 percent administrative

cost target for third party and local government programs separate from utility administration

costs for the same programs.24

The current 10 percent administrative cost cap is appropriate for SCE’s administrative

expenses as a function of the overall portfolio. The shift of the majority of the portfolio being

outsourced to third-party implementers, primarily results in a shift in implementation and

marketing costs. SCE maintains a large amount of administrative activities including

administrative labor, accounting support, IT services and support, reporting databases, data

request responses, Commission financial audits, regulatory filings support, solicitations and

contracting, etc.

It is not appropriate, however, to require a new contract cap for third-party contracts or to

require a cumulative 10 percent cap for PA and implementer administrative costs. While the

portfolio is going through a transition, it is premature to set a cap on third party implementer

administrative expenses at this time. The more appropriate vehicle to protect ratepayers from

third party implementer administrative expenses is not through arbitrary cost caps, but through

market competition, pay for performance structures, where feasible, and the solicitation and

contracting process. The robust solicitation process creates competitive pressure that will

discourage excessive administrative spending. Additionally, as the PAs move toward a pay-for-

performance contracting structure, the focus should be on whether the third-party implementer

delivers the energy savings and TRC for the contracted price, not on the level of administrative

22 D.09-09-047, p. 62. 23 Id. p. 63. 24 Id.

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costs. SCE will continue to track the admin costs of third parties and is open to revisiting this in

the future when there is more data and experience with third-party implementation of EE

programs.

18. How would assessing cost-effectiveness over multiple years impact the

Commission’s current cost-effectiveness calculations? In your response,

please consider elements like assigning an avoided cost vintage to each year,

the yearly attribution of costs to savings, and whether the achievement of

cost-effectiveness targets would be assessed using a weighted average or

cumulative calculation.

Under the CAEECC proposal, the process remains largely the same as the current process

with the exception that the CAEECC proposal recommends assessing cost-effectiveness for the

whole of the four-year cycle. The PAs will calculate and report, in their annual report, each of

the four years’ cost-effectiveness individually based on the net first year savings using the

respective year’s avoided cost vintages, like cost-effectiveness calculations today. However, the

application and portfolio’s cost-effectiveness will need to be cost-effective cumulatively over the

four-year period. The summation would be done using a modest discount rate that is the same as

the one used in the avoided costs calculator. For the four year-cycle, all annual costs and

benefits would be summed using a net present value to arrive at the four-year total cost-

effectiveness. While any given year may not necessarily be cost-effective, PAs would trigger a

new filing if they project that the portfolio will not be cost-effective over the 4-year period.

An additional item for the Commission to consider is the avoided costs that will be used

for the four-year cycle. The CAEECC proposal recommends using the same avoided cost

associated with the goal setting process to also serve as the foundation for assessing portfolio

cost-effectiveness to ensure alignment between the two. The avoided cost should be updated

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along with the update to the Potential and Goals Study updates.25 The overall cost-effectiveness

of the application period should be assessed using the avoided costs from the relevant year, but

the TRC should be calculated using cumulative costs and benefits over the four-year period.

19. The proposal references misalignment resulting from changing policies and

technical values following goals adoption and challenges for program

administrators preparing budget filings when critical input values are

actively changing. Please provide specific, quantitative evidence of instances

where misalignment or difficulties occurred due to changing technical inputs.

SCE recognizes and appreciates the significant improvements in the timing of technical

inputs with recent changes made by the Commission in partnership with the IOUs. Specifically,

improvements to the implementation of engineering changes applied moving forward, rather than

retroactively. There will always be some inherent level of timing mismatch for technical inputs

in a rapidly evolving technology market.

The 2018 Potential and Goals Study is a good example of changing inputs creating

misalignment between the portfolio and programmatic ability to meet and achieve the goals set

forth. The 2018 Study was effective on September 28, 2017. The measures that were included in

the 2018 study utilized 2016 DEER values, which changed three times before the end of the

2019 program year with significant market changes. While this question focuses on technical

inputs, these technical inputs interact with avoided cost to cause a cumulative impact over the

two-year period of the P&G. Ultimately, the sum of those impacts could be further affected by

the final cost-effectiveness screen of the Potential and Goals Study. As an example, Resolution

E-4952, along with other dispositions, impacted a large portion of the savings values associated

with non-residential lighting measures (~25 percent of SCE’s potential). These savings values

25 The CAEECC proposal’s start date aligned with the first year of a P&G study, while a 2023 start would be in the last year of the 2021 P&G study resulting in two P&G updates over four year compared to one update in the CAEECC proposal.

21

were identified as eligible potential during the establishment of the goal, but then opportunities

to garner and claim savings were subsequently decreased.

SCE agrees with the need to conduct market characterizations studies and the process for

assessing standard practice designation, while being mindful of the potential impacts on the

portfolio. SCE recommends that study data should be used to inform and provide trends for

future Potential and Goals Study calculations and should be implemented during the period for

which the P&G study is developed. For example, if latest estimated market study identifies a

rapid acceleration for a high-potential item, the P&G Study could consider utilizing that

information to project future energy savings in the P&G Study rather than relying on stagnant

values. This provides stability to savings forecasts by projecting the rapid acceleration over the

4-year period rather than re-forecasting based on frequent changes in potential. SCE recognizes

that the current EE marketplace differs from 2018 and with large individual potential measures

being captured in Codes and Standards, this recommendation should not result in a significant

change in work associated with the P&G Study. This approach of aligning inputs is supported in

the CAEECC proposal26 and recognizes that additional details should assist in operationalizing

the recommendations.

26 Attachment A, Section 6, pp. 9-12.

22

20. Is it reasonable to forgo utilization of annually updated avoided cost values

to address energy efficiency portfolio process concerns described in the

proposal? Why or why not?

a) Do the benefits of utilizing a single avoided cost vintage for two years

outweigh the drawbacks of energy efficiency being out of step with

other CPUC energy programs that utilize the Avoided Cost

Calculator, such as building decarbonization (R.19-01-011), net

energy metering (R.14-07-002), energy storage (R.15-04-011) and

demand response (R.13-09-011)? What would be the impact of

misalignment between energy efficiency and the integrated resource

planning proceeding (R.16-02-007)?

The CAEECC proposal recommends a reasonable adjustment to achieve alignment

between the Potential and Goals Study and portfolio assessment. The current annual update to

the Avoided Costs provides the most frequent and discrete values aligning with the I R P.

However, this alignment becomes particularly challenging because unlike other DSM products,

Energy Efficiency is the only resource that incorporates an Avoided Cost TRC calculation into

its goal setting process.

Additionally, while the IDER proceeding Decision (D.) 19-05-019 adopted a cost-

effectiveness framework for all DERs and requires making that information available,27 each

proceeding utilizes the information differently. For example, DSM products like Demand

Response are assessed on a forecasted basis as a part of the application and do not require an

additional cost-effectiveness assessment as a part of their mid-cycle update. Other resources,

like SGIP and NEM, utilize the cost-effectiveness analysis to inform program improvement

and/or the next funding cycle . The process laid out as a part of the CAEECC proposal allows

27 D. 19-05-019, pp. 24-25.

23

for a relatively consistent operating environment to meet program and portfolio objectives, while

still utilizing updated avoided costs at a reasonable cadence. As PAs transition to a majority of

the portfolio being designed, delivered and implemented by third-parties, the CAEECC proposal

leverages the stability of the previous three-year cycle while including a modern means for

incorporating the latest avoided cost updates.

While using a single avoided cost vintage for two years may cause a lag in reflecting the

current market values, this lag is outweighed by the benefits of aligning portfolio goal setting and

assessment. The CAEECC proposal balances a reasonable cadence for updating EE benefits that

align with operational needs of a portfolio. Specifically, the proposal allows IOUs and third-

party implementers, especially in pay-for-performance contracts, to set targets and assess

achievement using consistent values.

Finally, the Integrated Resource Plan (IRP) and Integrated Energy Policy Report (IEPR)

incorporate the latest Potential and Goals study, completed every two years, into the forecast as a

load modifying resource. By aligning the P&G study and portfolio assessment, IOUs will be

able to more consistently deliver the results incorporated into the near-term IRP/IEPR forecast.

By allowing a mid-cycle update, IOUs and ratepayers reduce the risk of over/under procuring

energy efficiency in the long term, making the CAEECC adjustment reasonable.

b) Decision (D.) 19-05-019 states that minor changes include data and

input updates in addition to changes to the modeling method that

parties can reasonably agree are minor in scope or impact. Though

described as minor changes, data updates can meaningfully impact

avoided costs. Given this information, what metrics do parties use to

define avoided cost updates as either material or immaterial?

SCE recognizes that creating a threshold to define a material change is difficult, which is

why a threshold was not used to define major and minor updates. SCE recommends that the

default should be biennial updates to avoided costs and technical inputs. However, SCE also

24

realizes there are certain situations where circumstances may materially change, warranting

changes in the interim period. SCE supports the CAEECC proposal to address these changing

conditions. The CAEECC proposal states that “should the CPUC find that circumstances have

materially changed to warrant updates to avoided costs, engineering assumptions, or P&G prior

to the proposed cycle, they may issue a resolution or decision detailing the proposed change, the

impact to the goal and portfolio, and direction for how to handle the proposed change (i.e.,

update P&G or guidance to PAs and impact to the marketplace).”28 These updates should be

sufficiently material that the benefits of the update outweigh the additional administrative and

regulatory costs of making the update.

Prior to the rolling portfolio, EE portfolio cycles had a single avoided cost value used for

three years. The current process of annual updates provides greater granularity but added

complexity to the portfolio implementation. The CAEECC proposal provides reasonable middle

ground that incorporates updates into the portfolio in a cadence that aligns with the goal setting

process.

21. The proposal recommends that updates to technical inputs, engineering

(Database for Energy Efficiency Resources (DEER)) values and evaluation,

measurement and verification (EM&V) be changed to every two years as

opposed to annually.

a) How often should technical inputs and DEER values be assessed to

avoid utilizing stale, inaccurate, or out-of-date values?

Because technical inputs are subject to various studies with differing timelines, the

Commission should separate the assessment from the implementation of updating of these

values. The former could proceed as study timing dictates while incorporating these values

should be applied to the next Potential and Goals study and implemented during the P&G


25

application. The default position should be that any updates to the technical inputs, engineering

values and EM&V changes be incorporated into the next Potential and Goals Study and

implemented when the P&G study is effective. However, as stated in the answer to Question

21.b, the CAEECC proposal also has a process for the Commission to take action should there be

material changes to these technical inputs that warrant immediate action between scheduled P&G

studies.29 Additionally, SCE will continue to provide monthly, quarterly, annual reports that

provide details on each PA’s portfolio budgets, expenditures, and savings progress which would

advise stakeholders if measure savings are falling behind projections.

Independent of these considerations, a two-year window overall is reasonable as

historically PAs have multi-year cycles and have met the Commission’s requirements for

updating important parameter values.

b) If DEER values were to be updated every other year, when should

updates become effective?

SCE supports the CAEECC proposal that the DEER values should become effective once

they have been incorporated into the Potential and Goals study and the study is effective. The

current DEER update process projects forth changes to measure savings and other technical

details (i.e. a measure may project that it declines 10 percent per year for the next few years).

These projected changes should be incorporated into the Potential and Goals study. In other

words, if updated DEER values have been incorporated into the Potential and Goals Study for

the 2024 period, those DEER values would take effect on January 1, 2024. In addition to the

general reasons discussed in the answer to Question 21.a for separating assessment from

implementation of new values, updating DEER values at the beginning of the year is much less

disruptive than mid-year updates.

29 Id.

26

c) Should DEER values be frozen for some or all of the portfolio cycle?

Why or why not?

As stated above, projected DEER values should be incorporated into future Potential and

Goals Studies and should only become effective when the P&G Study is effective. This should

apply for all DEER values, not only for some portions of the portfolio. Should the Commission

find that a portion of the portfolio has had a material change before the biennial update, the

CAEECC proposal provides for the Commission to take action to resolve this condition.30

d) Would moving EM&V results from annual to every other year have

adverse effects to portfolio assessment and other processes such as

DEER updates or energy savings performance incentive (ESPI) if

maintained in its current form?

As noted above, SCE recommends continuing the existing process and schedules for

assessment of key parameters that feed DEER, ex ante values and other determinants of portfolio

management and assessment. However, these changes should not take effect until they have

been incorporated into the Potential and Goals Study and that study has become effective. These

changes should not have any adverse effect on the portfolio assessment, DEER updates, or ESPI

because they will continue to proceed as scheduled.


27

22. D.15-10-028 adopted a “bus stop” schedule for various activities of the

Rolling Portfolio. Thinking of when in the year these bus stops occur, do you

think the existing schedule should change to accommodate the process

changes proposed in the NRDC motion?

a) Please outline any necessary changes to accommodate any alternative

proposals you made in your answers above.

SCE does not anticipate any required changes to the bus stop schedules aside from a 2 -

year as opposed to a 1-year timeframe. The original CAEECC proposal was filed before the

recent Ruling that required all PAs to file new business plans on September 1, 2021. As such,

SCE recommends the following modifications to the bus stop proposed in the CAEECC

proposal. The primary change in the schedule is a shift from a 2026 start date to a 2023 start

date. The application will use the Potential and Goals from the 2021 study31 (completed

approximately May 2021) for program year 2023. The PAs will then update their portfolio goals

using the 2023 study (completed approximate May 2023) for program years 2024 and 2025.

Finally, the PAs will update their portfolio goals one last time using the 2025 study (completed

approximate May 2025) for program year 2026. PA’s will provide the true up with expected

ability to incorporate these changes in their mid-cycle 2024 Annual Report filed in May 2025.

31 2021 Potential and Goals are currently under development. Additional details are available at https://www.cpuc.ca.gov/General.aspx?id=6442464362.

28

Jan-20 Feb-20 Mar-20 Apr-20 May-20 Jun-20 Jul-20 Aug-20 Sep-20 Oct-20 Nov-20 Dec-20


2022 Goals Update 5/1


Application Decision2023 Major ACC Update

EMV 2024 Bus Stop

Draft DEER 2024 Review

DEER 2024Bus Stop 9/1




2025 Major ACC Update

2026 EM&V Bus Stop






Application Decision2027 Major ACC Update

2028 EM&V Bus Stop



(1) Annual Report improved to provide both previous year results and next year plans.(2) PA can file AL to update its portfolio budget/savings as necessary. Potential triggers: (a) poor portfolio performance (b) close programs (c) if the portfolio 4-year savings forecast deviates +/- x% from the updated Biennial Goals(3) any change to the budget that results in an increase above the approved application 4-year budget will require a new application.

CPUC Policy and Portfolio Guidance

Application Proceeding

PA Application Filing Application Proceeding

Portfolio Operation Year 1




PA Application Filing





29

IV.

CONCLUSION

SCE appreciates the opportunity to provide these comments and recommends that the

Commission adopt the CAEECC consensus proposal in NRDC’s motion.

Respectfully submitted, ANNA VALDBERG ANGELA WHATLEY

/s/ Angela Whatley By: Angela Whatley

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-3618 E-mail: [email protected]

September 1, 2020


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 SOUTHERN CALIFORNIA EDISON COMPANY'S ( U 338-E) OPENING COMMENTS ON ADMINISTRATIVE LAW JUDGE’S RULING SEEKING COMMENTS REGARDING NATURAL RESOURCE DEFENSE COUNCIL MOTION on all parties identified on the attached service list R.13-11-005. Service was effected by transmitting the copies via e-mail to, ALJ Julie A. Fitch, ALJ Valerie Kao, ALJ Peter V. Allen, and all parties who have provided an e-mail address.

Executed this September 1, 2020, at Downey, California.

/s/ Karen Abarca ________________ Karen Abarca SOUTHERN CALIFORNIA EDISON COMPANY

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

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CARMELITA L. MILLER CHARLES CORMANY LEGAL COUNSEL EXECUTIVE DIRECTOR THE GREENLINING INSTITUTE EFFICIENCY FIRST CALIFORNIA (EF CA) EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: THE GREENLINING INSTITUTE FOR: CALIFORNIA BUILDING PERFORMANCE CONTRACTORS ASSOCIATION DBA EFFICIENCY FIRST CALIFORNIA (EF CA)

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WASHINGTON, DC 20007 WASHINGTON, DC 20036 FOR: INSTITUTE FOR GOVERNANCE & FOR: NATIONAL ASSOCIATION OF ENERGY SUSTAINABLE DEVELOPMENT (IGSD) SERVICE COMPANIES (NAESCO)

ROB FALKE KRISTIN ANDERSON PRESIDENT PRESIDENT NATIONAL COMFORT INSTITUTE OCCAM'S ENERGY CONSULTING, INC. PO BOX 147 4015 W 65TH STREET, SUITE 302 AVON LAKE, OH 44012 MINNEAPOLIS, MN 55435 FOR: NATIONAL COMFORT INSTITUTE FOR: APPLIANCE RECYCLING CENTERS OF AMERICA, INC. (ARCA)

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ANGELA WHATLEY ANNA LOWE SR. ATTORNEY SENIOR REGIONAL PLANNER SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO ASSOCIATION OF GOVERNMENTS 2244 WALNUT GROVE AVE. / PO BOX 800 401 B STREET, SUITE 800 ROSEMEAD, CA 91770 SAN DIEGO, CA 92101 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO ASSOCIATION OF GOVERNMENTS (SANDAG)



FREDERICK M. ORTLIEB SEPHRA A. NINOW, J.D. DEPUTY CITY ATTORNEY DIR - REGULATORY AFFAIRS CITY OF SAN DIEGO CENTER FOR SUSTAINABLE ENERGY 1200 THIRD AVENUE, SUITE 1100 3980 SHERMAN ST., STE. 170 SAN DIEGO, CA 92101-4100 SAN DIEGO, CA 92110 FOR: CITY OF SAN DIEGO FOR: CENTER FOR SUSTAINABLE ENERGY

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STEVEN MOSS ROBERT FRIED PARTNER ATKINSON, ANDELSON, LOYA, RUUD & ROMO M.CUBED 5075 HOPYARD ROAD, STE. 210 296 LIBERTY STREET PLEASANTON, CA 94588 SAN FRANCISCO, CA 94114 FOR: INSTITUTE OF HEARING AND AIR FOR: LOCAL GOVERNMENT SUSTAINABLE CONDITIONING INDUSTRIES, INC. (IHACI) ENERGY COALITION (LGSEC)

CHARLES GOLDMAN GERALD LAHR 503 MONARCH RIDGE DR. ENERGY PROGRAMS MGR. WALNUT CREEK, CA 94597 ASSOCIATION OF BAY AREA GOVERNMENTS FOR: CHARLES GOLDMAN 101 8TH ST. OAKLAND, CA 94607 FOR: SAN FRANCISCO BAY AREA REGIONAL ENERGY NETWORK (SFBAREN)

GREG WIKLER ALISON SEEL EXE. DIR ASSOCIATE ATTORNEY CA EFFICIENCY + DEMAND MGMT. COUNCIL SIERRA CLUB 1111 BROADWAY, STE. 300 2101 WEBSTER ST., STE. 1300 OAKLAND, CA 94607 OAKLAND, CA 94612 FOR: CALIFORNIA EFFICIENCY + DEMAND FOR: SIERRA CLUB MGNT COUNCIL (FORMERLY CALIF. ENERGY EFFICIENCY INDUSTRY COUNCIL (CEEIC)

BRUCE MAST JENNIFER WEST DIR OF PROGRAMS ADMINISTRATOR BUILD IT GREEN EAST BAY ENERGY WATCH 1330 BROADWAY. STE 1702 1537 WEBSTER ST. OAKLAND, CA 94612 OAKLAND, CA 94612 FOR: BUILD IT GREEN (BIG) FOR: EAST BAY ENERGY WATCH STRATEGIC ADVISORY COMMITTEE (EBEWSAC)

JIM KELSEY KEVIN CORNISH PRESIDENT VP BUSINESS SERVICES KW ENGINEERING, INC. COHEN VENTURES, INC./ ENERGY SOLUTIONS



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MICHAEL CALLAHAN CARMEN BEST REGULATORY COUNSEL DIRECTOR OF POLICY & EMERGING MARKETS MARIN CLEAN ENERGY RECURVE ANALYTICS, INC. 1125 TAMALPAIS AVENUE 364 RIDGEWOOD AVE. SAN RAFAEL, CA 94901 MILL VALLEY, CA 94941 FOR: MARINE CLEAN ENERGY (MCE) FOR: RECURVE ANALYTICS, INC.

CORI JACKSON MAHLON ALDRIDGE PROGRAM MGR VP - STRATEGIC DEVELOPMENT CALIFORNIA ENERGY ALLIANCE ECOLOGY ACTION OF SANTA CRUZ PO BOX 1175 877 CEDAR STREET, STE. 240 NOVATO, CA 94948 SANTA CRUZ, CA 95060-3938 FOR: CALIFORNIA ENERGY ALLIANCE (CEA) FOR: ECOLOGY ACTION OF SANTA CRUZ

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MATTHEW MARSHALL KEVIN MESSNER EXECUTIVE DIRECTOR SVP, POLICY & GOV'T RELATIONS REDWOOD COAST ENERGY AUTHORITY ASSOCIATION OF HOME APPLICANCE MFG 633 3RD STREET 1512 WILLOW LANE EUREKA, CA 95501 DAVIS, CA 95616 FOR: RURAL HARD TO REACH LOCAL FOR: ASSOCIATION OF HOME APPLICANCE GOVERNMENT PARTNERSHIPSâ€™ WORKING GROUP MANUFACTURERS (RHTR)

ERIC EISENHAMMER JIM HAWLEY COALITION OF ENERGY USERS PRINCIPAL 4010 FOOTHILLS BLVD., STE 103 NO. 115 DEWEY SQUARE GROUP, LLC ROSEVILLE, CA 95747 1020 16TH STREET, SUITE 20 FOR: COALITION OF ENERGY USERS SACRAMENTO, CA 95814 FOR: MISSION: DATA

JUSTIN WYNNE LAURA FERNANDEZ ATTORNEY ATTORNEY BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. BRAUN BLAISING SMITH WYNNE, PC 915 L STREET, SUITE 1480 555 CAPITOL MALL, SUITE 570 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814



FOR: CALIFORNIA MUNICIPAL UTILITIES FOR: REDWOOD COAST ENERGY AUTHORITY ASSOCIATION (CMUA)

LAURA FERNANDEZ THOMAS A. ENSLOW ATTORNEY ATTORNEY BRAUN BLAISING SMITH WYNNE, P.C. ADAMS BROADWELL JOSEPH AND CARDOZO 915 L STREET, STE 1480 520 CAPITOL MALL, STE. 350 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CITY OF LANCASTER FOR: JOINT COMMITTEE ON ENERGY AND ENVIRONMENTAL POLICY (JCEEP)

THOMAS A. ENSLOW THOMAS A. ENSLOW ADAMS BROADWELL JOSEPH AND CARDOZO ADAMS BROADWELL JOSEPH & CARDOZO 520 CAPITOL MALL, SUITE 350 520 CAPITOL MALL, SUITE 350 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814-4715 FOR: CALIFORNIA STATE LABOR MANAGEMENT FOR: CALIFORNIA CONSTRUCTION INDUSTRY COOPERATION COMMITTEE-FOR THE LABOR MANAGEMENT COOPERATION TRUST INTERNATIONAL BROTHERHOOD OF ELECTRICAL (CCILMCT) WORKERS / THE NATIONAL ELECTRICAL CONTRACTORS ASSOCIATON (LMCC)

JOHN LARREA KAREN NORENE MILLS CALIFORNIA LEAGUE OF FOOD PROCESSORS ATTORNEY 1755 CREEKSIDE OAKS DRIVE, STE 250 CALIFORNIA FARM BUREAU FEDERATION SACRAMENTO, CA 95833 2600 RIVER PLAZA DRIVE FOR: CALIFORNIA LEAGUE OF FOOD SACRAMENTO, CA 95833 PROCESSORS FOR: CALIFORNIA FARM BUREAU FEDERATION

KATHLEEN E. CARLSON, ESQ. ROBERT MOWRIS OWNER / ATTORNEY PROFESSIONAL ENGINEER VERIFIEDÂ® INC. ROBERT MOWRIS & ASSOCIATES, INC. PO BOX 2159 PO BOX 2366 OLYMPIC VALLEY, CA 96146 OLYMPIC VALLEY, CA 96146 FOR: VERIFIEDÂ® INC. FOR: ROBERT MOWRIS & ASSOCIATES, INC.

JONATHAN BELAIS SAM SIRKIN STAKEHOLDER RELATIONS MANAGER VP - PROGRAM DEVELOPMENT NORTHWEST ENERGY EFFICIENCY ALLIANCE JACO ENVIRONMENTAL, INC. 421 SW SIXTH AVENUE 6908 SW 37TH PORTLAND, OR 97204 PORTLAND, OR 97219 FOR: NORTHWEST ENERGY EFFICIENCY FOR: JACO ENVIRONMENTAL, INC. (JACO) ALLIANCE ( NEEA )

LIA WEBSTER TOM ECKHART PRINCIPAL & SR. ENGINEER CEO FACILITY ENERGY SOLUTIONS LLC CAL-UCONS 1505 NW ELGIN AVE. 10612 NE 46TH STREET BEND, OR 97703 KIRKLAND, WA 98033 FOR: FACILITY ENERGY SOLUTIONS LLC FOR: CAL-UCONS, INC.

JACOB OSTER ENERGYSAVVY 159 SOUTH JACKSON STREET, SUITE 420 SEATTLE, WA 98102 FOR: ENERGYSAVVY



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AARON N. LU ALEX KANG SAN DIEGO GAS & ELECTRIC COMPANY ITRON EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, AA 00000

ALEX PORTESHAWVER ALEX RICKLEFS CENTER FOR SUSTAINABLE ENERGY ENERGY COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

ALICE STOVER ALLAN LEE CLEAN ENERGY EXEC. DIR., ENERGY SERVICES DIVISION EMAIL O NLY CADMUS EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, OR 00000

ALLAN RAGO ANDRA PLIGAVKO QUALITY CONSERVATION SERVICES, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

ANNETTE BEITEL ARLEEN NOVOTNEY FUTURE ENERGY ENTERPRISES-CAL.TECH. FORM ACCESS / SCF EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

BARBARA BARKOVICH BRIAN SMITH CONSULTANT PACIFIC GAS AND ELECTRIC COMPANY BARKOVICH & YAP EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

CARMEN BEST CAROL YIN INDEPENDENT ENERGY CONSULTANT YINSIGHT, INC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

CAROLINE CHEN CAROLINE M. FRANCIS STATWIZARDS LLC PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

CASE COORDINATION CASSANDRA FELICIANO PACIFIC GAS AND ELECTRIC COMPANY REGULATORY CASE MANAGER EMAIL ONLY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000



CATHIE A. ALLEN CHUCK BUCK PACIFICORP MANAGER, REGULATORY AFFAIRS EMAIL ONLY OPOWER EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

CODY COECKELENBERGH CORINNE M. SIERZANT LINCUS, INC. SOUTHERN CALIFORNIA GAS COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

CORY SCOTT CRAIG TYLER PACIFICORP TYLER & ASSOCIATES EMAIL ONLY EMAIL ONLY EMAIL ONLY, NV 00000 EMAIL ONLY, CA 00000

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

DON ARAMBULA DORREN CARUTH DON ARAMBULA CONSULTING PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, AA 00000 EMAIL ONLY, CA 00000

EILEEN HLAVKA, PH.D. ELI CAUDILL AIR POLLUTION SPECIALIST, CLEARESULT CALIFORNIA AIR RESOURCES BOARD EMAIL ONLY INDUSTRIAL STRATEGIES DIVISION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

ELI HARLAND ERIC EBERHARDT CALIFORNIA ENERGY COMMISSION ASSOCIATE DIRECTOR ENERGY SERVICES ENERGY RESEARCH & DEVELOPMENT DIV. UNIVERSITY OF CALIF. OFFICE OF THE PRES. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

FERNANDA CRAIG FRANK SPASARO PROGRAM MANAGER II -ISD-EES EMAIL ONLY INTERNAL SERVICES DEPARTMENT EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

GRACE PERALTA HALLEY FITZPATRICK RESIDENTIAL PROGRAM MANAGER PACIFIC GAS AND ELECTRIC COMPANY MCE CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

HANNA GRENE HANNAH KAYE



CENTER FOR SUSTAINBLE ENERGY FERC & ISO RELATIONS EMAIL ONLY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

IAN KEARNEY JANA KOPYCIOK-LANDE LAW CLERK SR. POLICY ANALYST WESTERN ENERGY & WATER, APC MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, AA 00000 EMAIL ONLY, CA 00000

JANE S. PETERS JAY MURDOCH RESEARCH INTO ACTION, INC. OWENS CORNING EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

JEAN SHELTON JENN KREUTZER ITRON CUSTOMER PROGRAMS MANAGER EMAIL ONLY MARIN CLEAN ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

JENNY ROECKS, PE JESSICA COHEN ENERGY EFFICIENCY POLICY & STRATEGY MANAGEMENT FOLLOW/PROGRAM MANAGER PACIFIC GAS AND ELECTRIC COMPANY L.A.COUNTY OFFICE OF SUSTAINABILITY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

JESSICA WAGGONER JOHN CAVALLI PACIFIC GAS AND ELECTRIC COMPANY ITRON EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

JOHN JONES JOSEPH LANDE BUILDING PERFORMANCE INSTITUTE, INC. CUSTOMER PERGRAMS MANAGER, MCE EMAIL ONLY MCE CLEAN ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

JUSTIN REGNIER KELLY KNUTSEN EXE. DIV SENIOR ACCOUNT MANAGER CALIFORNIA PUBLIC UTILITIES COMMISSION BRIGHT POWER EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

KIM FUENTES LAUREL ROTHSCHILD SOUTH BAY CITIES ENERGY COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

LESTER SAPITULA LINDSEY HAWES SENIOR STRATEGIC ANALYST CENTER FOR SUSTAINABLE ENERGY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY



EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

LUCY MORRIS MARC COSTA PACIFIC GAS AND ELECTRIC COMPANY ENERGY COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MARK SIPPOLA MATT BOGOSHIAN CALIFORNIA AIR RESOURCES BOARD CHIEF STRATEGY OFFICER & GEN.COUNSEL EMAIL ONLY REV EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

MATTHEW VESPA MCE REGULATORY STAFF ATTORNEY MARIN CLEAN ENERGY EARTHJUSTICE EMAIL ONLY 50 CALIFORNIA ST., SUITE 500 EMAIL ONLY, CA 00000 SAN FRANCISCO, CA 00000

MEGHAN DEWEY MERRIAN BORGESON MGR - EE POLICY / STRATEGY SR. SCIENTIST PACIFIC GAS AND ELECTRIC COMPANY NATURAL RESOURCES DEFENSE COUNCIL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MICHAEL NGUYEN MICHAEL NORBECK ENERGY COALITION PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MICHAEL YEE MIKE RUFO SOUTHERN CALIFORNIA GAS COMPANY ITRON EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MISTI BRUCERI MOHIT CHHABRA MISTI BRUCERI & ASSOCIATES, LLC SCIENTIST EMAIL ONLY NATURAL RESOURCES DEFENSE COUNCIL EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

MYRON GRAESSLE NANCY SARACINO LOCKEED MARTIN ENERGY WESTERN ENERGY & WATER, APC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, AA 00000

NIKHIL GANDHI PATRICK FERGUSON EMAIL ONLY ATTORNEY EMAIL ONLY, CA 00000 DAVIS WRIGHT TREMAINE, LLP EMAIL ONLY EMAIL ONLY, CA 00000



QUA VALLERY REBECCA HAUSHEER CUSTOMER PROGRAMS SPECIALIST EMAIL ONLY MCE EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

REGULATORY CLERK RICARDO AMON BRAUN BLAISING SMITH WYNNE, PC FOOD INDUSTRY ENERGY SPECIALIST EMAIL ONLY CALIF. INST. OF FOOD & AGRI. RESEARCH EMAIL ONLY, CA 00000 UC - DAVIS EMAIL ONLY EMAIL ONLY, CA 00000

ROBERTO DEL REAL SEAN MACKAY MAROMA ENERGY SERVICES PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

SERGIO ROJAS SHAHANA SAMIULLAH SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA EDISON COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

STEPHEN GUNTHER STEVEN KELLY CENTER FOR SUSTAINABLE ENERGY POLICY DIR EMAIL ONLY INDEPENDENT ENERGY PRODUCERS ASSOCIATION EMAIL ONLY, CA 00000 PO BOX 1287 SLOUGHHOUSE, CA 00000

SUSIE BERLIN TAMARA DZUBAY ATTORNEY AT LAW REGULATORY AFFAIRS MANAGER LAW OFFICES OF SUSIE BERLIN ECOBEE EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, AA 00000

TAMI RASMUSSEN TIM OLSEN EVERGREEN ECONOMICS ENERGY COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

VALERIE KAO WILLIAM HEBERGER ALJ DIVISION PROGRAM ANALYST CALIFORNIA PUBLIC UTILITIES COMMISSION CAEATFA EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: CA ALTERNATIVE ENERGY AND ADVANCED TRANSPORTATION FINANCING AUTHORITY (CAEATFA)

DAVIS WRIGHT TREMAINE LLP MRW & ASSOCIATES, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000



HERTER ENERGY ROBERT KASMAN EMAIL ONLY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000-0000

JEFF PERKINS BRAD KATES ERS OPINION DYNAMICS CORPORATION 120 WATER STREET, SUITE 350 1000 WINTER STREET NORTH ANDOVER, MA 01845 WALTHAM, MA 02451

ERIKA DIAMOND LAURA KIER VP - UTILITY & MKT SRVCS ENERGYHUB ENERGYHUB 232 3RD STREET 232 3RD STREET, SUITE 201 BROOKLYN, NY 11215 BROOKLYN, NY 11215

RUTH HUPART AL LUNA 1220 19TH STREET, NW, STE. 800 LITIGATION ASSISTANT WASHINGTON, DC 20036 EARTHJUSTICE 1625 MASSACHUSETTS AVE., N.W., STE. 702 WASHINGTON, DC 20036-2243

KATHERINE JOHNSON RACHEL HOLMES JOHNSON CONSULTING GROUP APPLIANCES RECYCLING CENTER OF AM., INC. 1033 LINDFIELD DRIVE 7400 EXCELSIOR BLVD. FREDERICK, MD 21702 MINNEAPOLIS, MN 55426

JACK CAMERON BEN LIPSCOMB PRESIDENT NATIONAL COMFORT INSTITUTE APPLIANCES RECYCLING CENTERS OF AM., INC 375 DEER TRAIL 7400 EXCELSIOR BLVD WHITEFISH, MT 59937 MINNEAPOLIS, MN 55426-4517

JAKE SCHLESINGER KELLY CRANDALL KEYES & FOX LLP EQ RESEARCH, LLC 1580 LINCOLN STREET, SUITE 880 1580 LINCOLN ST., STE. 800 DENVER, CO 80203 DENVER, CO 80203

DAVID C. CLARK JULIE RICHARDSON ADVISOR PRESIDENT ENERGY EFFICIENCY INC. ENERGY EFFICIENCY INC. 595 S. BLUFF ST., NO. 5 595 S. BLUFF ST., NO. 5 ST. GEORGE, UT 84770 ST. GEORGE, UT 84770 FOR: ENERGY EFFICIENCY INC. (EEI)

CYNTHIA K. MITCHELL ANDREW NIH ENERGY ECONOMICS INC. SOUTHERN CALIFORNIA GAS COMPANY 530 COLGATE COURT 555 WEST FIFTH ST., GT19A7 RENO, NV 89503 LOS ANGELES, CA 90013

ANDREW STEINBERG BENJAMIN PIIRU REGULATORY POLICY & REPORTING MGR. ENERGY EFFICIENCY POLICY & SUPPORT



SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, GT19A7 555 WEST 5TH STREET LOS ANGELES, CA 90013 LOS ANGELES, CA 90013

BRIAN K. JOHNSTON CARYN L. MANDELBAUM SOUTHERN CALIFORNIA GAS COMPANY CALIF PUBLIC UTILITIES COMMISSION 555 W. 5TH STREET UTILITY & PAYPHONE ENFORCEMENT BRANCH LOS ANGELES, CA 90013 320 West 4th Street Suite 500 Los Angeles, CA 90013

CHERYL WYNN CHRIS STEPHENS CALIF PUBLIC UTILITIES COMMISSION REGULATORY POLICY ADVISOR ENERGY EFFICIENCY BRANCH SOUTHERN CALIFORNIA GAS COMPANY 320 West 4th Street Suite 500 555 W. FIFTH ST. GT19A8 Los Angeles, CA 90013 LOS ANGELES, CA 90013

DARREN HANWAY DAVID KIM SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 WEST FIFTH ST., MAIL STOP GT19A7 555 WEST 5TH STREET LOS ANGELES, CA 90013 LOS ANGELES, CA 90013

DERRICK CLIFTON ELIZABETH BAIRES SOUTHERN CALIFORNIA GAS COMPANY REGULATORY MGR 555 W. 5TH STREET SOUTHERN CALIFORNIA GAS COMPANY LOS ANGELES, CA 90013 555 W. FIFTH ST., GT14D6 LOS ANGELES, CA 90013

ERIC S. GRESSLER ERIN PALERMO SENIOR COUNSEL SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W 5TH STREET 555 WEST FIFTH STREET, GT14E7 LOS ANGELEES, CA 90013 LOS ANGELES, CA 90013

JEFF SALAZAR JESSE JOHN MARTINEZ SOUTHERN CALIFORNIA GAS COMPANY SEMPRA UTILITIES 555 W. FIFTH STREET, GT14D6 555 W. 5TH ST LOS ANGELES, CA 90013 LOS ANGELES, CA 90013

JOSEPH MOCK JOYCE KWOK REGULATORY CASE MGR. CUSTOMER PROGRAMS & ASSISTANCE SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 WEST 5TH ST., STE 1400, GT14D6 555 WEST FIFTH STREET, GT19A7 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013

KAPIL KULKARNI KEVIN EHSANI CALIF PUBLIC UTILITIES COMMISSION EM&V SUPERVISOR ENERGY EFFICIENCY BRANCH SOUTHERN CALIFORNIA GAS COMPANY 320 West 4th Street Suite 500 555 WEST FIFTH STREET, GT19A7 Los Angeles, CA 90013 LOS ANGELES, CA 90013

LETICIA AYALA MARK HERVEY SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 WEST 5TH STREET 555 W. FIFTH STREET



LOS ANGELES, CA 90013 LOS ANGELES, CA 90013

MARK HUERTA MICHAEL DIAZ SOUTHERN CA GAS COMPANY SENIOR BUSINESS ANALYST II 555 WEST 5TH STREET SOUTHERN CALIFORNIA GAS COMPANY LOS ANGELES, CA 90013 555 WEST FIFTH STREET, GT19A7 LOS ANGELES, CA 90013

PAMELA WU PAUL DEANG REGULATORY CASE MGR. CUSTOMER PROGRAM SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, GT14D6 555 W. 5TH STREET LOS ANGELES, CA 90013 LOS ANGELES, CA 90013

RONALD VAN DER LEEDEN VANESSA GOMEZ DIR. - REGULATORY AFFAIRS REGULATORY POLICY ADVISOR SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, GT14D6 555 W. FIFTH ST. GT19A8 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013

CARLOS A. H. VAQUERANO NANCY BARBA EXECUTIVE DIR. FRONTIER ENERGY SALVADORAN AMERICAN LEADERSHIP 800 W. 6TH ST., SUITE 1250 1625 WEST OLYMPIC BLVD. LOS ANGELES, CA 90017 LOS ANGELES, CA 90015 FOR: SALVADORAN AMERICAN LEADERSHIP AND EDUCATIONAL FUND (SALEF)

NANCY BARBA SAHAR ABBASZADEH BKI ARUP 800 W 6TH STREET, NO. 1250 900 WILSHIRE BOULEVARD 19TH FLOOR LOS ANGELS, CA 90017 LOS ANGELES, CA 90017 FOR: SOCALREN

SARA GERSEN LUJUANA MEDINA STAFF ATTORNEY MANAGER EARTHJUSTICE COUNTY OF LOS ANGELES 800 WILSHIRE BLVD., STE. 1000 1100 NORTH EASTERN AVENUE LOS ANGELES, CA 90017 LOS ANGELES, CA 90063

JORGE SALAZAR KIM MOWERY SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 9240 FIRESTONE BLVD 9240 FIRESTONE BLVD DOWNEY, CA 90241 DOWNEY, CA 90241

MEGAN JIMENEZ LENA LUNA SOUTHERN CALIFORNIA GAS COMPANY SR. ENERGY PROJECT MGR. 9240 FIRESTONE BLVD SO. BAY CITIES COUNCIL OF GOVERNMENTS DOWNEY, CA 90241 20285 S. WESTERN AVE., STE. 100 TORRANCE, CA 90501

INGER GOODMAN AARON KLEMM JUST ENERGY SOLUTIONS INC. CHIEF, ENERGY & SUSTAINABILITY



6 CENTERPOINTE DRIVE, SUITE 750 CALIFORNIA STATE UNIVERSITY LA PALMA, CA 90623-2520 401 GOLDEN SHORE LONG BEACH, CA 90802-4210

GREGORY S.G. KLATT GEORGE WILTSEE ATTORNEY CLEAN POWER HOUSE, LLC DOUGLASS & LIDDELL 19809 TERRI DRIVE 4766 PARK GRANADA, STE. 209 CANYON COUNTRY, CA 91351 CALABASAS, CA 91302

BASU MUKHERJEE, P.E. AIMEE WONG PRESIDENT DSM PROJECT MANAGEMENT AND COMPLIANCE GLOBAL ENERGY SERVICES, INC. SOUTHERN CALIFORNIA EDISON 22815 LAZY TRAIL ROAD 1515 WALNUT GROVE DIAMOND BAR, CA 91765 ROSEMEAD, CA 91770

BRANDON SANDERS CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE 2244 WALNUT GROVE AVENUE, PO BOX 800 ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

CHARISSE BURNETT CODY MORGAN TAYLOR SO. CALIFORNIA EDISON COMPANY SR MGR - REGULATORY 1515 WALNUT GROVE AVENUE, 4TH FLR SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA 91770 8631 RUSH ST ROSEMEAD, CA 91770

ELIZABETH B. GOMEZ JANE LEE COLE SR. ADVISOR SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. 8631 RUSH STREET ROSEMEAD, CA 91770 ROSEMEAD, CA 91770 FOR: SOUTHERN CALIFORNIA EDISON COMPANY

JANET COMBS, ESQ. LEGAL ADMIN SR. ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. / PO BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

LISA MAU RICHARD SPERBERG SR. ADVISOR ONSITE ENERGY CORP. SOUTHERN CALIFORNIA EDISON COMPANY 2701 LOKER AVE. W., STE. 107 8631 RUSH STREET CARLSBAD, CA 92010 ROSEMEAD, CA 91770

BOB RAMIREZ MEGAN CAMPBELL DNV GL OPINION DYNAMICS CORPORATION 3605 FIFTH AVE. 7590 FAY AVENUE, STE. 406 SAN DIEGO, CA 92013 LA JOLLA, CA 92037

DONALD C. LIDDELL ANNLYN M. FAUSTINO ATTORNEY REGULATORY CASE ANALYST & SUPPORT DOUGLASS & LIDDELL SDG&E/SCGC



2928 2ND AVENUE 8330 CENTURY PARK COURT, CP31E SAN DIEGO, CA 92103 SAN DIEGO, CA 92123

BRITTNEY LEE ELAINE ALLYN REGULATORY CASE MGR. SAN DIEGO GAS AND ELECTRIC SAN DIEGO GAS & ELECTRIC COMPANY 8326 CENTURY PARK CT 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA 92123 SAN DIEGO, CA 92123

ESAU GUARDADO MICHELLE SOMERVILLE REGULATORY CASE MGR CASE MGR - REGULATORY SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK COURT, CP 32F SAN DIEGO, CA 92123 SAN DIEGO, CA 92123

ROLAND G MOLLEN SACHU CONSTANTINE SAN DIEGO GAS & ELECTRIC COMPANY DIR. OF POLICY 8690 BALBOA AVE CENTER FOR SUSTAINABLE ENERGY SAN DIEGO, CA 92123 9325 SKY PARK COURT, SUITE 100 SAN DIEGO, CA 92123 FOR: CENTER FOR SUSTAINABLE ENERGY

CENTRAL FILES ATHENA BESA SAN DIEGO GAS & ELECTRIC COMPANY CUSTOMER PROGAMS & POLICY MANAGER 8330 CENTURY PARK CT, CP31-E SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA 92123-1530 8335 CENTURY PARK COURT, CP12H SAN DIEGO, CA 92123-1569

PAUL MARCONI SHEENA TRAN DIR ICF INTERNATIONAL BEAR VALLEY ELECTRIC SERVICE 1 ADA, SUITE 100 42020 GARSTIN DRIVE / PO BOX 1547 IRVINE, CA 92618 BIG BEAR LAKE, CA 92315

MARK GAINES JEFF HIRSCH INDEPENDENT CONSULTANT JAMES J. HIRSCH & ASSOCIATES 1330 DANA PLACE 12185 PRESILLA ROAD FULLERTON, CA 92831 SANTA ROSA VALLEY, CA 93012-9243

JOHN AVINA JON GRIESSER ABRAXAS ENERGY CONSULTING,LLC CHAIR, RHTR 811 PALM STREET RURAL HARD TO REACH LOCAL GOVT SAN LUIS OBISPO, CA 93401 COUNTY OF SAN LUIS OBISPO 976 OSOS STREET, SUITE 300 SAN LUIS OBISPO, CA 93401 FOR: RURAL HARD TO REACH LOCAL GOVERNMENT PARTNERSHIPS WORKING GROUP (RHTR)

PAM BOLD DEEANN TOZLIAN CO-CHAIR / EXEC DIRC STRATEGIC PLANNING RESEARCH MGR RURAL HARD TO REACH LOCAL GOVT. RICHARD HEATH & ASSOCIATES, INC. HIGH SIERRA ENERGY FOUNDATION 590 W LOCUST AVENUE, SUITE 103 3343 N. MAIN, SUITE X6 FRESNO, CA 93650



MAMMOTH LAKES, CA 93546 FOR: RURAL HARD TO REACH LOCAL GOVERNMENT PARTNERSHIPSâ€™ WORKING GROUP (RHTR)

COREY GRACE LISA SCHMIDT RESOURCE INNOVATIONS HOME ENERGY ANALYTICS 719 MAIN STREET 13061 BYRD LN HALF MOON BAY, CA 94019 LOS ALTOS, CA 94022

JORDANA TEMLOCK KIM SPRINGER BIDGELY, INC OFFICE OF SUSTAINABILITY 110 PIONEER WAY COUNTY OF SAN MATEO MOUNTIAN VIEW, CA 94041 455 COUNTY CENTER, 4TH FL. REDWOOD CITY, CA 94063 FOR: COUNTY OF SAN MATEO

STEPHEN STOLTE NICK BROD COORDINATOR - OFFICE OF SUSTAINABILITY CLEARESULT COUNTY OF SAN MATEO 1100 GRUNDY LANE, STE. 100 400 COUNTY CENTER SAN BRUNO, CA 94066 REDWOOD CITY, CA 94063

DIANA S. GENASCI IROSS NAKASONE REGULATORY AFFAIRS PLANNING & REGULATORY COMPLIANCE SOUTHERN CALIFORNIA EDISON COMPANY SAN FRANCISCO PUBLIC UTILITES COMMISSION 601 VAN NESS AVENUE, SUITE 2030 525 GOLDEN GATE AVE., 7TH FL. SAN FRANCISCO, CA 94102 SAN FRANCISCO, CA 94102

JOANNA PEREZ-GREEN KATHLEEN BRYAN CPUC - ENERGY DEPT OF THE ENVIRONMENT 505 VAN NESS AVE. CITY AND COUNTY OF SAN FRANCISCO SAN FRANCISCO, CA 94102 1455 MARKET STREET, SUITE 1200 SAN FRANCISCO, CA 94102

CLEANPOWER SF REGULATORY AMANDA CHRISTENSON SFPUC CALIF PUBLIC UTILITIES COMMISSION 525 GOLDEN GATE AVE. ENERGY EFFICIENCY BRANCH SAN FRANCISCO, CA 94102 ROOM 7533 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

ASHLYN KONG BRIAN KORPICS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM PRESIDENT BATJER AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

CHRISTINA TOROK CHRISTINE POWELL CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH COMMISSIONER RANDOLPH ROOM 7533 ROOM 5018 505 VAN NESS AVENUE 505 VAN NESS AVENUE



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

DIANA L. LEE ERICA PETROFSKY CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION DEMAND RESPONSE, CUSTOMER GENERATION, AN ROOM 4107 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

ERIK JOHNSON HAFIZ BELLO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH ENERGY EFFICIENCY BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JACOB RUDOLPH JASON ORTEGO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH COMMISSIONER RANDOLPH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JASON SYMONDS JESSICA ALLISON CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH ENERGY EFFICIENCY BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

KE HAO OUYANG KIRSTEN HO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION UTILITY & PAYPHONE ENFORCEMENT BRANCH ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA 2-E AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

LEUWAM TESFAI SHELLY LYSER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER SHIROMA ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5137 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

SOPHIE BABKA STEPHEN CASTELLO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM 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

THERESA L. MUELLER JESSIE DENVER CHIEF ENERGY & TELECOM DEPUTY MGR - DIST. ENERGY RESOURCES PROGRAM CITY AND COUNTY OF SAN FRANCISCO CITY AND COUNTY OF SAN FRANCISCO



CITY HALL, ROOM 234 1455 MARKET STREET, STE. 1200 1 DR. CARLTON B. GOODLETT PLACE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-4682

LOWELL CHU ALYSSA BRUNER SR. ENERGY EFFICIENCY SPECIALIST STRATEGIC ANALYST CITY AND COUNTY OF SAN FRANCISCO PACIFIC GAS AND ELECTRIC COMPANY | 1455 MARKET ST., SUITE 1200 DESK: 956A SAN FRANCISCO, CA 94103 245 MARKET STREET SAN FRANCISCO, CA 94105

AMUL SATHE AMY BARR NAVIGANT CONSULTING PACIFIC GAS AND ELECTRIC COMPANY 1 MARKET ST., SPEAR TOWER STE.1200 77 BEALE STREET, MC B23A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

ANDREW LEE ANGELA TORR PACIFIC GAS AND ELECTRIC PACIFIC GAS AND ELECTRIC COMPANY 245 MARKET STREET 245 MARKET STREET, MC N13E SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

BUCHALTER DOCKET CARA GOLDENBERG BUCHALTER DIAN GRUENEICH CONSULTING, LLC 55 SECOND STREET, SUITE 1700 201 MISSION STREET, SUITE 1200 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

CHRIS KATO DAVID POSTER PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 245 MARKET STREET, N6G 245 MARKET STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

DEREK JONES DON BROOKHYSER NAVIGANT CONSULTING, INC. BUCHALTER, A PROFESSIONAL CORPORATION ONE MARKET ST., SPEAR TOWER, SUITE 1200 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

EVA CHU HENRY LIU MGR - GOVN'T & COMMUNITY PARTNERSHIPS SUPERVISOR PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 245 MARKET STREET 245 MARKET ST SAN FRANCISOC, CA 94105 SAN FRANCISCO, CA 94105

JONATHAN BURROWS JULIA LIBERZON PACIFIC GAS AND ELECTRIC CASE MGR. 77 BEALE ST PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94105 77 BEALE STREET, B9A SAN FRANCISCO, CA 94105

KAREN KRISTIANSSON KATI PECH PROGRAM MANAGER SR. STRATEGIC ANALYST BAY AREA REGIONAL ENERGY NETWORK PACIFIC GAS AND ELECTRIC COMPANY 375 BEALE STREET, SUITE 800 EMAIL ONLY SAN FRANCISCO, CA 94105 EMAIL ONLY, CA 94105



MANANYA CHANSANCHAI MARY A. GANDESBERY, ESQ. PACIFIC GAS AND ELECTRIC COMPANY ATTORNEY 245 MARKET ST PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94105 77 BEALE STREET, MS-B30A / PO BOX 7442 SAN FRANCISCO, CA 94105 FOR: PACIFIC GAS & ELECTRIC COMPNANY

MARY ANDERSON MAYA BIERY PACIFIC GAS & ELECTRIC COMPANY CASE MANAGER, EXPERT 245 MARKET STREET, N4Q PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94105 77 BEALE STREET MC B23A SAN FRANCISCO, CA 94105

MELODY AGUSTIN MICHAEL ALCANTAR PACIFIC GAS AND ELECTRIC COMPANY ATTORNEY AT LAW 245 MARKET STREET BUCHALTER, A PROFESSIONAL CORPORATION SAN FRANCISCO, CA 94105 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105

MICHAEL CADE MUSHTAQ AHMAD ANALYST NEXANT, INC. BUCHALTER, A PROFESSIONAL CORPORATION 101 SECOND STREET 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

PATTI LANDRY RACHEL SACKMAN REGULATORY ANALYST STRATEGIC ANALYST PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS & ELECTRIC COMPANY 77 BEALE STREET, B23A 245 MARKET STREET, NQ4 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

RYAN CHAN SAVANNAH ELLIS PACIFIC GAS AND ELECTRIC COMPANY ASSOC. BUSINESS ANALYST 245 MARKET STREET PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94105 245 MARKET STREET SAN FRANCISCO, CA 94105

SAVI ELLIS UJAVLLA GUPTA PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC 77 BEALE STREET 77 BEALE SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

BUCHALTER, A PROFESSIONAL CORPORATION LILLIAN RAFII 55 SECOND STREET, SUITE 1700 ATTORNEY SAN FRANCISCO, CA 94105 BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, STE. 1700 SAN FRANCISCO, CA 94105-3493

CHARLIE BUCK FRANCESCA WAHL MGR, MARKET DEV. & REGULATORY AFFAIRS DEPUTY DIR - POLICY & ELECTRICITY MKTS ORACLE / OPOWER TESLA, INC. WEST DIVISION 444 DE HARO ST., STE. 101



680 FOLSOM STREET, 3RD FLOOR SAN FRANCISCO, CA 94107 SAN FRANCISCO, CA 94107

MEGHAN DEWEY SAMUEL GOLDING PROSPER CLEAN ENERGY PRESIDENT 775 POST STREET COMMUNITY CHOICE PARTNERS, INC. SAN FRANCISCO, CA 94109 58 MIRABEL AVENUE SAN FRANCISCO, CA 94110

DAVID SIDDIQUI JILL N. JAFFE ORACLE / OPOWER NOSSAMAN LLP 475 SANSOME ST 15TH FLOOR 50 CALIFORNIA STREET, 34TH FLOOR SAN FRANCISCO, CA 94111 SAN FRNACISCO, CA 94111

KAREN MAOZ, P.E. MATTHEW SMIZER ASSOCIATE DIR. TRC NAVIGANT CONSULTING 255 CALIFORNIA STREET, SUITE 400 101 CALIFORNIA STREET, STE. 4100 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111

REBECCA BARKER TIMOTHY ALAN SIMON EARTHJUSTICE ATTORNEY 50 CALIFORNIA STREET, SUITE 500 TAS STRATEGIES SAN FRANCISCO, CA 94111 100 PINE STREET, SUITE 1250 SAN FRANCISCO, CA 94111

MARTIN MATTES IRENE K. MOOSEN NOSSAMAN LLP ATTORNEY AT LAW 50 CALIFORNIA STREET, STE. 3400 LAW OFFICE OF IRENE K. MOOSEN SAN FRANCISCO, CA 94111-4799 53 SANTA YNEZ AVENUE SAN FRANCISCO, CA 94112

GYPSY ACHONG ALEJANDRA M. CUNNINGHAM 2050 PARTNERS, INC. TRANSCENDENT ENERGY, LLC 489 DOUGLAS 2298 FULTON STREET SAN FRANCISCO, CA 94114 SAN FRANCISCO, CA 94117

CALIFORNIA ENERGY MARKETS MEGAN M. MYERS 425 DIVISADERO ST STE 303 ATTORNEY SAN FRANCISCO, CA 94117-2242 LAW OFFICES OF SARA STECK MYERS 122 - 28TH AVENUE SAN FRANCISCO, CA 94121

SARA STECK MYERS ELIZABETH M. KELLY ATTORNEY AT LAW ATTORNEY LAW OFFICES OF SARA STECK MYERS LAW OFFICE OF ELIZABETH KELLY 122 28TH AVENUE PO BOX 225037 SAN FRANCISCO, CA 94121 SAN FRANCISCO, CA 94122 FOR: ENERNOC, INC.

MICHELLE VAN TIJEN RICK COUNIHAN PACIFIC GAS AND ELECTRIC COMPANY NEST LABS, INC. 245 MARKET STREET 3400 HILLVIEW AVENUE



SAN FRANCISCO, CA 94177 PALO ALTO, CA 94304

DIAN GRUENEICH STEVEN R. SHALLENBERGER STANFORD UNIVERSITY SYNERGY COMPANIES 473 VIA ORTEGA, ROOM 387 28436 SATELLITE STREET STANFORD, CA 94305 HAYWARD, CA 94545

ANDREW MEIMAN, PE JAMES MCMAHON PRINCIPAL FOUNDING DIRECTOR ARC ALTERNATIVES BETTER CLIMATE RESEARCH/POL. ANALYSIS 144 DONALD DRIVE 138 BROOKFIELD DR. MORAGA, CA 94556 MORAGA, CA 94556-1747

DAVID DIAS FLOYD KENEIPP BUSINESS REP. TIERRA RESOURCE CONSULTANTS, INC. SHEET METAL WORKERS LOCAL 104 1200 MT. DIABLO BLVD., STE. 208 2610 CROW CANYON ROAD WALNUT CREEK, CA 94596 SAN RAMON, CA 94583 FOR: JOINT COMMITTEE ON ENERGY AND ENVIRONMENTAL POLICY (JCEEP)

JENNIFER SCHOULLIS CHRIS ANN DICKERSON MGR - BUSINESS DEVELOPMENT CAD CONSULTING APPLIED ENERGY GROUP, INC. 720B CANYON OAKS DR. 500 YGNACIO VALLEY ROAD, STE 250 OAKLAND, CA 94605 WALNUT CREEK, CA 94596

ALLAN ROBLES ERIN MALCOLM-BRANDT LUCID SENIOR MANAGER, TECHNOLOGY INTEGRATION 304 12TH STREET, SUITE 3C CENTER FOR SUSTAINABLE ENERGY OAKLAND, CA 94607 1111 BROADWAY, 4TH FLOOR, ROOM 04-183 OAKLAND, CA 94607

FRONTIER ENERGY LACEY TAN FRONTIER ENERGY FRONTIER ENERGY 1000 BROADWAY, SUITE 410 100 BRADWAY, SUITE 410 OAKLAND, CA 94607 OAKLAND, CA 94607

SAMANTHA WEAVER SERJ BERELSON PRINCIPAL REGULATORY ANALYST POLICY DIRECTOR EAST BAY COMMUNITY ENERGY CA EFFICIENCY + DEMAND MANAGMENT COUNCIL 1111 BROADWAY, 3RD FL. 1111 BROADWAY, SUITE 300 OAKLAND, CA 94607 OAKLAND, CA 94607 FOR: CALIFORNIA EFFICIENCY + DEMAND MANAGEMENT COUNCIL

MARY SUTTER ANA BOYD GROUNDED RESEARCH AND CONSULTING, LLC LEGAL ASSISTANT 6114 LA SALLE AVENUE, STE 183 SIERRA CLUB OAKLAND, CA 94611 2010 WEBSTER ST., SUITE 1300 OAKLAND, CA 94612

BRYAN BOYCE, PE CARMEN HENRIKSON



SR ENGINEER ASSOCIATE V.P., STRATEGY ENERGY SOLUTIONS TRC SOLUTIONS 449 15TH ST SUITE 400 436 14TH STREET, SUITE 1020 OAKLAND, CA 94612 OAKLAND, CA 94612

HANNAH ARNOLD JENNIFER E. CANSECO OPINION DYNAMICS HEAD OF SECTION, MARKET WEST 1999 HARRISON ST., STE. 1420 DNV GL OAKLAND, CA 94612 155 GRAND AVE., STE.500 OAKLAND, CA 94612

OLIVIA PATTERSON RACHEL GOLDEN OPINION DYNAMICS SR. CAMPAIGN REP. 1999 HARRISON ST., STE. 1420 SIERRA CLUB OAKLAND, CA 94612 2101 WEBSTER, STE. 1300 OAKLAND, CA 94612

TAMI BUHR MICHELLE VIGEN RALSTON OPINION DYNAMICS COMMON SPARK CONSULTING 1999 HARRISON ST., STE. 1420 1929 PARKER ST APT A OAKLAND, CA 94612 BERKELEY, CA 94704

STEVE KROMER DANIEL GENTER SKEE CUSTOMER PROGRAMS SPECIALIST 1911 9TH STREET B MARINE CLEAN ENERGY BERKELEY, CA 94710 1125 TAMALPAIS AVE. SAN RAFAEL, CA 94901

JOHN PROCTOR NATHANIEL MALCOLM PROCTOR ENGINEERING GROUP, LTD POLICY COUNSEL 418 MISSION AVENUE MARIN CLEAN ENERGY SAN RAFAEL, CA 94901 1125 TAMALPAIS AVENUE SAN RAFAEL, CA 94901

SHALINI SWAROOP STEPHANIE CHEN REGULATORY & LEGISLATIVE COUNSEL SR. POLICY COUNSEL MARIN CLEAN ENERGY MARIN CLEAN ENERGY 1125 TAMALPAIS AVENUE 1125 TAMPALPAIS AVENUE SAN RAFAEL, CA 94901 SAN RAFAEL, CA 94901

ELSIA GALAWISH HANK RYAN EXE DIRECTOR EXECUTIVE DIR. WESTERN HVAC PERFORMANCE ALLIANCE, INC. SMALL BUSINESS CALIFORNIA (SB CALIF.) 524 SAN ANSELMO AVENUE, STE. 109 750 - 47TH AVE., NO. 56 SAN ANSELMO, CA 94960 CAPITOLA, CA 95010 FOR: WESTERN HVAC PERFORMANCE ALLIANCE, INC. (WHPA)

JENNIFER HOLMES DEMETRA J. MCBRIDE INDEPENDENT CONSULTANT DIR. - OFF. OF SUST. & CLIMATE ACTION PO BOX 4235 SANTA CLARA COUNTY SANTA CRUZ, CA 95063 70 W. HEDDING ST., E. WING, 11TH FLR. SAN JOSE, CA 95110 FOR: LOCAL GOVERNMENT SUSTAINABLE



ENERGY COALITION

NATALIE DE LEON DAVID REYNOLDS COUNTY OF SANTA CLARA ERS 70 W. HEDDING 152 N. 3RD STREET, SUITE 520 SAN JOSE, CA 95110 SAN JOSE, CA 95112

JANET FERRARI LAUREN CASEY COMMERCIAL TEAM MANAGER CLIMATE PROTECTION ROGRAM MANAGER CONSOL SCTA/RCPA 5757 PACIFIC AVENUE, SUITE 220 490 MENDOCINO AVE., STE. 206 STOCKTON, CA 95207 SANTA ROSA, CA 95401

STEVEN S. SHUPE ANNE ARQUIT NIEDERBERGER GENERAL COUNSEL POLICY SOLUTIONS SONOMA CLEAN POWER AUTHORITY 218 FOSS CREEK CIRCLE 50 SANTA ROSA AVE., 5TH FL. HEALDSBURG, CA 95448 SANTA ROSA, CA 95404

PATRICIA TERRY SMITA GUPTA PROJECT MANAGER SR. ENERGY CONSULTANT REDWOOD COAST ENERGY AUTHORITY ITRON, INC. 633 THIRD ST 330 MADSON PLACE EUREKA, CA 95501 DAVIS, CA 95618-6599

DELPHINE HOU JORDAN PINJUV CA. INDEPENDENT SYSTEMS OPERATOR CORP SR. COUNSEL 250 OUTCROPPING WAY CALIFORNIA INDEPENDENT SYSTEM OPERATOR FOLSOM, CA 95630 250 OUTCROPPING WAY FOLSOM, CA 95630

KIM PEREZ DAVID GIBBS CALIFORNIA ISO CAEATFA 250 OUTCROPPING WAY 801 CAPITOL MALL FOLSOM, CA 95630 SACRAMENTO, CA 95814 FOR: CALIFORNIA ALTERNATIVE ENERGY AND ADVANCED TRANSPORTATION FINANCING AURTHORITY (CAEATFA)

ERIC KNOPS NICHOLAS JANUSCH, PH.D. CALIFORNIA ENERGY COMMISSION ENERGY COMMISSION SPECIALIST 1516 9TH STREET CALIFORNIA ENERGY COMMISSION SACRAMENTO, CA 95814 DEMAND ANALYSIS OFFICE 1516 NINTH STREET, MS-22 SACRAMENTO, CA 95814

PENG GONG ROBERT CASTANEDA CALIF PUBLIC UTILITIES COMMISSION PROTEUS, INC. ENERGY EFFICIENCY BRANCH 1830 N. DINUBA BLVD. 400 R Street VISALIA, CA 95814 Sacramento, CA 95814 FOR: PROTEUS, INC.

SCOTT BLAISING SCOTT KJORLIEN



ATTORNEY CALIF PUBLIC UTILITIES COMMISSION BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. ENERGY EFFICIENCY BRANCH 915 L STREET, STE. 1480 300 Capitol Mall SACRAMENTO, CA 95814 Sacramento, CA 95814

STEVE SANDERS SUSAN MILLS PROGRAM DIRECTOR CAEATFA INSTITUTE FOR LOCAL GOVERNMENT 801 CAPITOL MALL 1400 K STREET, SUITE 205 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CALIFORNIA ALTERNATIVE ENERGY AND ADVANCED TRANSPORTATION FINANCING AUTHORITY (CAEATFA)

TOVAH TRIMMING BRIAN SAMUELSON CALIF PUBLIC UTILITIES COMMISSION SENIOR ANALYST LEGAL DIVISION CALIFORNIA ENERGY COMMISSION 300 Capitol Mall 1516 NINTH STREET, MS-26 Sacramento, CA 95814 SACRAMENTO, CA 95814-5512

LYNN HAUG RONALD LIEBERT ATTORNEY ATTORNEY AT LAW ELLISON SCHNEIDER HARRIS & DONLAN LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVENUE, SUITE 400 2600 CAPITOL AVENUE, STE. 400 SACRAMENTO, CA 95816 SACRAMENTO, CA 95816

ROB NEENAN GENESIS TANG CALIFORNIA LEAGUE OF FOOD PROCESSORS CALIF PUBLIC UTILITIES COMMISSION 1755 CREEKSIDE OAKS DRIVE, SUITE 250 ENERGY EFFICIENCY BRANCH SACRAMENTO, CA 95833 180 Promenade Circle, Suite 115 Sacramento, CA 95834

ANN L. TROWBRIDGE BRAD SIMCOX ATTORNEY DIRECTOR DAY CARTER & MURPHY LLP NEXANT 3620 AMERICAN RIVER DRIVE, SUITE 205 49 STEVENSON STREET, SUITE 700 SACRAMENTO, CA 95864 SAN FRANCISCO, CA 95973

JASON GREGORY DULANE MORAN ENERGYSAVVY PRINCIPAL EVALUATION LEAD 205 SE SPOKANE ST., STE. 300 NORTHWEST ENERGY EFFICIENCY ALLIANCE PORTLAND, OR 97202 421 WE SIXTH AVE., STE 600 PORTLAND, OR 97204 FOR: NEEA

DON JONES, JR. ELI MORRIS PACIFICORP PACIFICORP 825 NE MULTNOMAH, STE. 1500 825 NE MULTNOMAH, STE. 2000 PORTLAND, OR 97232 PORTLAND, OR 97232

JOHN W. GOULD BING TSO CAL-UCONS, INC. SBW CONSULTING, INC. 5737 SW 18TH AVE. 2820 NORTHUP WAY, STE. 230 PORTLAND, OR 97239 BELLEVUE, WA 98004



FAITH DEBOLT MICHAEL BAKER SBW CONSULTING, INC. VICE PRESIDENT 2820 NORTHUP WAY, STE. 230 SBW CONSULTING, INC. BELLEVUE, WA 98004 2820 NORTHUP WAY, SUITE 230 BELLEVUE, WA 98004

SEPIDEH SHAHINFARD MICHAEL RICHARDSON SBW CONSULTING VP - GLOBAL PROGRAM OPERATIONS 2820 NORTHUP WAY, SUITE 230 TRANFORMATIVE WAVES BELLEVUE, WA 98004 1012 CENTRAL AVE. SOUTH KENT, WA 98032

JENNIFER HOLMES SHARYN BARATA ENERGY MARKET INNOVATIONS (EMI) OPINION DYNAMICS CORPORATION 83 COLUMBIA ST., STE/ 400 15122 S HORTON ROAD SEATTLE, WA 98104 ROCKFORD, WA 99030-0000

CHRIS CARRADINE CHRIS CARRADINE MGR - REGULATORY AFFAIRS MGR - REGULATORY AFFAIRS ECOBEE, INC. ECOBEE, INC. 250 UNIVERSITY AVE. SUITE 400 250 UNIVERSITY AVE. SUITE 400 TORONTO, ON M5H 3E5 TORONTO, ON M5H 3E5 CANADA

State Service

AVA N. TRAN CHRISTOPHER MYERS CPUC - ENERGY CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY OFFICE OF RATEPAYER ADVOCATES EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

FRANK ALAN REYNOLDS JENNIFER KALAFUT CPUC - ENERGY ENERGY DIVISION EMAIL ONLY CPUC EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

JEORGE S. TAGNIPES JEREMY BATTIS CPUC - ENERGY CPUC - ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

JULIE FITCH LISA PAULO ALJ DIVISION CPUC - ENERGY CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MARTHA BROOK MONA DEE DZVOVA CALIFORNIA ENERGY COMMISSION CPUC - ENERGY EMAIL ONLY EMAIL ONLY



EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

PAULA GRUENDLING PETER FRANZESE CPUC - ENERGY CPUC - ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

PETER LAI PETER SKALA CPUC - ENERGY CPUC - ENERGY EMAIL ONL Y EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

RORY COX TORY FRANCISCO CPUC ENERGY EMAIL ON LY CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

BRYAN PENA ALEXANDER MERIGAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRIC SAFETY AND RELIABILITY BRANCH ENERGY EFFICIENCY BRANCH 320 West 4th Street Suite 500 AREA Los Angeles, CA 90013 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

ALISON LABONTE AMY REARDON CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION ENERGY EFFICIENCY BRANCH AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

HAL KANE MARIA AMPARO WORSTER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH CONSUMER PROGRAMS BRANCH ROOM 7515 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

MARNA ANNING MARYAM GHADESSI CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION UTILITY & PAYPHONE ENFORCEMENT BRANCH MARKET STRUCTURE, COSTS AND NATURAL GAS AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

NILS STRINDBERG PETER BIERMAYER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH ENERGY EFFICIENCY BRANCH AREA 4-A AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214



ROBERT HANSEN SANDY GOLDBERG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH COMMISSIONER RECHTSCHAFFEN AREA 2-C ROOM 5202 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

SARAH LERHAUPT SHANNON O'ROURKE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH PRESIDENT BATJER AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

ABHILASHA WADHWA CYNTHIA ROGERS CALIF PUBLIC UTILITIES COMMISSION CALIFORNIA ENERGY COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN 1516 9TH STREET, MS-22 300 Capitol Mall SACRAMENTO, CA 95814 Sacramento, CA 95814

DEANA J. CARRILLO KEVIN FEIZI EXE. DIR CALIF PUBLIC UTILITIES COMMISSION CAEATFA ENERGY EFFICIENCY BRANCH 915 CAPITOL MALL 770 L Street, Suite 1250 SACRAMENTO, CA 95814 Sacramento, CA 95814 FOR: CALIFORNIA ALTERNATIVE ENERGY & ADVANCED TRANSPORTATION FINANCING AUTHORITY (CAEATFA)

MICHAEL KENNEY MIRIAM JOFFE-BLOCK ENERGY ANALYST - EFFICIENCY DIVISION PROGRAM MGR. CALIFORNIA ENERGY COMMISSION CAEATFA 1516 9TH STREET, MS-26 801 CAPITOL MALL SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CALIFORNIA ALTERNATIVE ENERGY AND ADVANCED TRANSPORTATION FINANCING AUTHORITY (CAEATFA); CALIF. HUB FOR ENERGY EFFICIENCY FINANCE (CHEEF)

ROBERT RIDGLEY TIFFANY MATEO ENERGY COMMISSION SPECIALIST I MECHANICAL ENGINEER CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS-26 1516 NINTH STREET, MS-26 SACRAMENTO, CA 95814-5512 SACRAMENTO, CA 95814-5512

KEVIN S. NAKAMURA CALIF PUBLIC UTILITIES COMMISSION UTILITY AUDITS BRANCH 180 Promenade Circle, Suite 115 Sacramento, CA 95834

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