state of california and related actions. application 18 …...application 18-10-010 southern...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Pacific Gas and Electric Company (U39E) in Compliance with Ordering Paragraph 37, Resolution E-4906.

Application 18-10-008

And Related Actions.

Application 18-10-009 Application 18-10-010

SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) REPLY BRIEF

ANNA VALDBERG ROBIN Z. MEIDHOF

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (626) 302-6054 Facsimile: (626) 302-6693 E-mail: [email protected]

Dated: April 3, 2020

1


STATE OF CALIFORNIA





SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) REPLY BRIEF

Pursuant to California Public Utilities Commission (CPUC or Commission) Rule of

Practice and Procedure 13.11 and Ordering Paragraph (OP) 10 of the Administrative Law

Judge’s Ruling issued on January 10, 2020 (January Ruling),1 Southern California Edison

Company (SCE) respectfully submits this reply brief.

I.

INTRODUCTION

SCE is committed to enforcing the Commission’s Demand Response Prohibited

Resources Policy (PR Policy), which seeks to eliminate the use of fossil-fueled back-up

generators to provide demand response (DR). While acknowledging that questions remain about

whether it is cost-effective or necessary to require the installation of any measuring devices on

customers’ prohibited resources to ensure compliance with the PR Policy, SCE has taken the

middle ground approach of supporting the recommendations of the Verification Administrator

(VA) to require an amendment to the current Verification Plan to include the random installation

of interval meters on 10% of Scenario 2 customers. In addition, SCE has shared its support for

1 Administrative Law Judge’s Ruling Canceling Evidentiary Hearings, Establishing Briefing Schedule

and Providing Instruction on Admission of Testimony and Exhibits (January 10, 2020).

2

every recommendation provided by the independent third-party VA, because SCE is committed

to working with the Commission and affected stakeholders to ensure the PR Policy is cost-

efficient and effective, while also ensuring that customers continue to enroll in DR programs

which this State relies on more and more for grid reliability.

SCE agrees with San Diego Gas & Electric (SDG&E) that the fundamental questions the

Commission should ask when making a final decision in this proceeding are:

(1) How much additional compliance with the PR Policy can the Commission expect by requiring the installation of metering equipment on all Scenario 2 PRs; and

(2) Does this additional compliance justify the costs and burden of installing,

maintaining, and administering a comprehensive metering program?2

Notwithstanding arguments to the contrary, the record in this proceeding does not support any

requirements that would exceed what Nexant has recommended because this proceeding is quasi-

legislative and has not authorized the additional funding that would be required to go above what

was implemented by the Verification Administrator in 2019. Rather, the record in this

proceeding supports adopting Nexant’s recommendations for the minimum requirements of the

metering equipment to demonstrate customer compliance or non-compliance for the remaining

three years of the IOUs’ DR funding cycle (2020-2022).

II.

DISCUSSION

The Public Advocates Office (Cal Advocates) Opening Brief starts from the faulty

premise that "allowing the use of prohibited resources for demand response events without

reductions in incentive payments violates Section 451".3 First, the Commission does not allow

Scenario 3 customers to earn incentive payments if they must use a PR to reduce load during DR

events for safety, health, or operational reasons.4 Second, the Commission does not permit the

2 SDG&E Opening Brief, p. 3.

3 Cal Advocates Opening Brief, p. 3.

4 See Resolution E-4906, at p. 29.

3

use of PRs for DR events for Scenario 2 customers and the attestation is the first step to enforce

that prohibition. The installation of measuring devices on 10% of Scenario 2 customers was a

second step to enforce the PR Policy. The annual audit is a third step. This three-prong

approach as applied for 2019 was a reasonable, thoughtful, and cost-efficient approach to enable

the enforcement of the Commission's PR Policy. As evidenced by this three-prong approach to

enforcement of the PR Policy, Cal Advocates’ argument that the Commission "has not

implemented controls to ensure that its DR programs are not encouraging or enabling the use of

fossil fuel generation"5 is without merit and should be accorded no weight.

Similarly, SCE is committed to encouraging the use of clean energy and advancing the

Commission's and the State's clean energy initiatives as evidenced by the issuance of its 2017

whitepaper, The Clean Power and Electrification Pathway (Pathway),6 which presented SCE’s

commitment to identify, implement, and encourage “new flexible policy tools and significant

funding to spur customer choice for clean electrification” that will result in cost-effective and

much-needed measures to reduce GHG emissions. Consistent with SCE’s Pathway, SCE

removed any offending customers from its DR programs as required by SCE’s tariffs and the

Commission’s PR Policy. Any statement by Cal Advocates suggesting that SCE might

encourage or enable the use of GHG-emitting resources by its DR customers is without merit.

A. The Extreme Measures Called for by Cal Advocates and Sierra Club are

Unsupported by the Record

Statements by both Cal Advocates and Sierra Club that the 2019 Metering Test Year Pilot

and Annual Audit “definitively show that data loggers and interval meters are the only tools that

5 Cal Advocates Opening Brief, p. 3.

6 The Pathway was followed by the issuance of another whitepaper in 2019, Pathway 2045, a data-driven analysis of the steps that California must take to meet the 2045 goals to clean our electricity grid and reach carbon neutrality. Both whitepapers are available at https://www.edison.com/home/our-perspective/pathway-2045.html.

4

can effectively monitor PRs”7 and “at a reasonable cost”

8 are unsupported. Moreover, statements

that “some participants are willing to cheat and engage in improper behavior to receive DR

incentives”9 are alarming, and attempt to paint a broad brush of non-compliance on a population

that was determined to be more than 98% compliant. The 2019 Test Year Metering Pilot

identified noncompliance in just 1.7% of the observed customers10 and therefore, it is

unwarranted to apply that fraction of non-compliance with sweeping strokes to all DR customers

as the basis to demand that the Commission impose a draconian monitoring regime.

There is no disagreement in the record that the VA identified just one instance of a Type

II violation by one AP-I customer that ran its PR during a DR event. And yet, Sierra Club makes

a hyperbolic claim that SCE’s AP-I “program is also a likely source of violations of the

Prohibition, given the noncompliance documented by the Metering Pilot and Nexant’s

Verification Report” and “the program with the lowest incentive levels has the most known

instances of noncompliance.”11

Sierra Club’s Opening Brief does not cite the two Nexant reports

when it makes these claims, because the reports do not support these statements. There were not

multiple violations in the AP-I program and descriptors like “most instances” and plural

“violations” cannot be reconciled with the evidentiary record before this Commission that

showed one customer in violation.

For the reasons above, the Commission should carefully consider how much weight to

apply to the arguments put forth by Sierra Club and Cal Advocates when those arguments are not

supported by the record – or, in the case of Cal Advocates, when the record provides evidence

that appears to have been overlooked. For example, Cal Advocates argues that "the Metering

7 See Sierra Club Opening Brief, p. 3; see also Cal Advocates Opening Brief, p. 18.

8 Id.

9 See Sierra Club Opening Brief, p. 5.

10 See Pacific Gas and Electric Company (PG&E) Opening Brief, at p. 16 “The monitoring pilot therefore identified noncompliance in 1.7% of the observed customers.”

11 See Sierra Club Opening Brief, at pp. 16-17.

5

Pilot Report does not identify how many of the 34 service accounts that had meters or loggers

successfully installed were called for a demand response event during the course of the Metering

Pilot.”12

Cal Advocates goes further by relying on this statement as the basis to make several

arguments including, “the Commission has no way of knowing: (1) whether Nexant's results are

derived from demand response event operations, (2) what proportion of the 34 service accounts

were never observed during a demand response event, (3) whether such results can and should be

extrapolated to all Scenario 2 customers, and (4) if the results should be extrapolated to all

Scenario 2 customers, how this should be calculated and to what degree of accuracy."13

The Commission must ignore these arguments put forth by Cal Advocates because they

are belied by the December 5, 2019 Metering Pilot Results – Workshop Presentation which is

publicly available on the Commission's website.14

This Workshop Presentation was also

circulated on December 4, 2019 by the Energy Division to the service lists R.13-09-011, A.17-

01-012 et al, and A.18-10-008 et al, and Cal Advocates is a party in each of those proceedings.

Contrary to the assertions above, the Commission has all of the necessary information. First,

Nexant’s Workshop Presentation shows that 37 customers were dispatched at least once for an

event across 19 unique demand response event days.15

Nexant’s Workshop Presentation

explains that of the 155 customer event hours, 27 event hours were associated with PR use, but

only 3 hours were associated with a PR which was improperly used for DR.16

Nexant’s

Workshop Presentation also confirmed that the Metering Pilot concluded prior to the onset of

2019 PSPS outages.17

For ease of reference, the Table from Nexant’s December 5, 2019

12 See Cal Advocates Opening Brief, at p. 15.

13 Id.

14 Demand Response Workshops, available at https://www.cpuc.ca.gov/General.aspx?id=7032.

15 See p. 21 of Nexant’s Metering Pilot Report - Workshop Presentation.

16 Id.

17 Id.

6

Workshop Presentation is provided below and it shows in detail the number of Metering Pilot

customers participating in DR events in 2019.18

B. The Verification Plan Implemented in 2019 is Working and Should Be Continued

for the Remainder of the DR Budget Cycle

Sierra Club’s Opening Brief describes how the VA identified 26 of 221 customer

attestations that had inaccurate or missing information and Sierra Club then suggests this

supports the argument that “customer attestations are a poor tool for confirming compliance.”19

There is a disconnect in this argument. These violations were largely identified as Type I

(administrative) violations that could easily be corrected as permitted by IOU tariffs, and no PR

18 See p. 19 of Nexant’s Metering Pilot Report – Workshop Presentation.


7

was used as a result of these Type I violations.20 In fact, in SCE’s territory, some attestations

were corrected to indicate the customers no longer owned any PR devices on site.21 Sierra Club

fails to acknowledge that the Verification Plan worked as intended, because the VA identified

Type I errors and helped to ensure an update to attestations as appropriate.

C. The Cost Data in the Record Does Not Support a Determination That It Would Be

Reasonable for Metering Equipment to Be Installed on All Scenario 2 Customers.

The costs put forth by Cal Advocates distort the data responses provided by the VA and

improperly rely solely on PG&E information, much of which is redacted, and which should not

be used with equal application to SCE and SDG&E. First, Cal Advocates argue that the

Commission should not consider the estimated added costs of Nexant’s projected influx and

outflux of DR program participants.22

This argument is based on Cal Advocates’ incorrect

assumption that “Nexant bases its assertion on SCE’s program enrollment data for all service

accounts rather than those service account with prohibited resources.”23 Cal Advocates then

spends several pages and Tables trying to improperly scale the data in Nexant's table.24

To be

clear, the SCE data response in which Nexant provided the table refers solely to customers who

selected Scenario 2 on their attestation. Any attempt by Cal Advocates to provide different

numbers or scaling for the Commission distorts the record. As explained in SCE’s Opening

Brief, SCE experienced a 26% increase in Scenario 2 attestations for 2020,25 and Nexant’s

20 See Resolution E-4906, p. 97 at OP 25 describing a Type I Violation as “Minor clerical or

administrative errors that may be resolved with an updated attestation and do not involve the use of a prohibited resource to reduce load during a DR event.”

21 See Nexant’s 2019 Audit Verification Report at p. 9 [A-12] (“A total of 12 Scenario 2 SAs or Accounts responded to Nexant that the Scenario 2 disposition is in error and that the site is actually a Scenario 1 site. Updated attestations have been received for all 12 SAs and Nexant has verified with the relevant AQMDs that there are no permitted PRs at those locations.”)

22 See Cal Advocates Opening Brief, at p. 19 citing Exhibit Cal Advocates-04, Nexant Response to Question 13 at p. 11.

23 Id.

24 See Cal Advocates Opening Brief, pp. 20-24.

25 See SCE Opening Brief, at p. 11.

8

projections for influx of DR program participation are aligned with that.26

Cal Advocates’

Tables 12 and 13 should be disregarded because they do not accurately demonstrate that

installing measuring devices on “a census fleet will not dramatically increase the cost of the

Commission’s ban on prohibited resources.”27

Second, PG&E’s analysis by load reduction per class warrants attention, because it

highlights how Cal Advocates improperly argues that costs for meters are reasonable for all

customers and would cause little impact, thus ignoring that customers earn different incentives

based on their load shed.28

In addition, any costs should be transparent to both current DR

participants and potential future DR customers. SCE does not have visibility into the incentives

data that Cal Advocates relies so heavily on from PG&E’s customers. Moreover, it is

inappropriate to apply any PG&E incentives data to the customers in SCE’s (or SDG&E’s)

service territory.

As PG&E so diligently lays out, Cal Advocates’ and Sierra Club’s blanket determination

that the incentives are reasonably sufficient to cover costs of meter installation on all Scenario 2

customers lacks basis and overlooks the impact to many customers that may determine it is not

worth continuing to participate in DR programs because of the operational costs of the

installation and maintenance of the measuring devices which could require a shut-down of

operations and resulting loss of revenue.29

In addition, Cal Advocates’ position that “installation

of a meter or logger is a one-time cost”30 does not address the very real operational

26 Sierra Club’s assertion that there are “only 124 unique customers who would be affected by a

monitoring requirement” is now incorrect based on SCE’s growth in participation and Scenario 2 attestations for 2020.

27 See Cal Advocates Opening Brief, p. 24.

28 See PG&E Opening Brief, at pp. 9-12 (e.g., “Although Cal Advocates describes the costs of meters and loggers as a one-time cost to be compared with multiple years of incentives, the data above shows that this one-time cost could effectively wipe out the entire first year of incentives for a portion of PG&E’s customers.”).

29 See PG&E Opening Brief, at pp. 12-13.


9

implementation costs. For example: (1) How would a customer know where to buy a meter?31

(2) What is the process for an IOU or VA to approve of the meter? (3) Who would install the

meter? (4) How would the IOU, DR provider, or VA confirm an accurate installation of the

device? (5) What is the funding mechanism for these additional steps? In sum, there are

operational and administrative costs just not accounted for by Cal Advocates or Sierra Club. It is

not as simple as just asserting that these costs should be borne by Scenario 2 customers.32

The

IOUs all agree with Nexant’s determination that requiring customers to install and maintain PR

equipment would be a “barrier to program participation.”33

Similarly, Sierra Club’s purported “one-time” costs for equipment and installation and

“on-going costs”34 are without basis and selectively chosen while excluding all the other costs

that Nexant and the IOUs identified in their briefs. For example, the Nexant 2019 Test Year

Metering Pilot Report explains that actual project costs as incurred by the VA are "not

completely captured by reporting on equipment, installation, and retrieval costs."35

The average

per site costs presented by Nexant in its 2019 Test Year Metering Pilot Report do not account for

the following tasks that must be taken into consideration to accurately forecast the cost of

managing a census fleet of equipment: maintaining a list of active DR participants, customer

31 See Exhibit Cal Advocates-04, SCE Response to Question 4 at p. 4 (“SCE has an internal policy in

which SCE avoids providing endorsements of third-party vendors, contractors, or suppliers. While exceptions are made in limited circumstances, SCE would object to providing any such recommendation for purposes of the Prohibited Resources policy implementation, because SCE cannot guarantee the services of third-party contractors.”).

32 See Sierra Club Opening Brief, at p. 3 (arguing the IOUs could fairly apportion costs to Scenario 2 customers to “bear the costs of compliance verification”).

33 See SDG&E Opening Brief at p.2 at fn. 6, SCE Opening Brief at p. 9, and PG&E Opening Brief at p. 10 (“PG&E does not recommend that Demand Response participants purchase their own loggers and meters, as this would create a disincentive for participation and may create additional costs and complexity in monitoring and compliance due to variations in sites and installations from site to site.”). See also Sierra Club Opening Brief at p. 17 (agreeing that “a centralized verification program will likely be attractive to DR participants because they will not have to assume the risk of failing to properly install their monitoring equipment.”).


35 See Nexant 2019 Test Year Metering Pilot Report, at p. 17 [A-22].

10

contact and appointment scheduling, procuring equipment, training and dispatch of electricians

and technicians, installer reporting, and VA analysis and reporting.36

The administrative costs

and labor, which are not factored into the average cost per site metric, are what ultimately led to

Nexant's recommendation that not all Scenario 2 participants should be required to have

monitoring equipment installed at their site.

SCE reinforces Nexant's statement that the level of effort and coordination between the

IOUs, third party demand response providers, and the VA to maintain a census fleet of

monitoring equipment as customers join and leave the programs would be “massive and

extremely expensive.”37 The additional costs associated with administering a census fleet of

equipment are not accurately represented when only looking at the average cost per site to install

and remove equipment and is insufficient to compare against annual incentive data. Costs

should be transparent and yet, the opening briefs put forth by Cal Advocates and Sierra Club do

more to distort the record than to provide clarity into costs. In sum, it is still unclear what the

true costs of changing the current Verification Plan are. Therefore, it makes sense to make

incremental adjustments; the continuation of the 10% random sampling of measuring devices on

Scenario 2 customers is just that. It is an incremental adjustment that was tested as a pilot for

one year and should be considered for implementation for the remaining three years of the DR

funding cycle (2020-2022).

D. SCE Supports Cal Advocates’ Recommendation for the Commission to Require

Metering Devices to Capture Date, Time, and Change in Output.

SCE supports Cal Advocates’ recommendation that the Commission should require that

metering devices capture date, time, and change in output, while also complying with applicable

safety standards.38 In SCE’s Opening Briefs, SCE supported Nexant’s recommendation that

revenue grade Interval Data Recorder (IDR) meters are the default or preferred since these are

36 Id. at p. 18 [A-23].

37 See Nexant 2019 Test Year Metering Pilot Report at p. 35 [A-40].

38 See Cal Advocates Opening Brief, pp. 4-5.

11

more effective method to authenticate if and when PRs are producing power. In addition,

revenue grade IDR metering requires cabinetry that conforms to existing Electrical Service

Requirements (ESR) or meet Authority Having Jurisdiction’s (AHJ) requirements making it a

standard safer solution to the public and better withstand the elements. As referenced in

Nexant’s 2019 Test Year Metering Pilot Report, interval meters are the only way to effectively

monitor participants who use their generator to serve baseload because of their ability to capture

increases or decreases in usage. An example of this scenario was cited in the 2019 Test Year

Metering Pilot Report and explains how usage data captured by the interval meter was used to

validate compliance for baseload-serving generators that were in use during a DR event.39

Nexant was able to use the actual usage data and compare it against historical usage patterns

(proxy days) to conclusively show that these resources did not ramp up usage for the purposes of

producing DR load reductions, allowing them to remain in compliance.

E. SCE Supports PG&E’s Recommendation to Require Revenue-Grade, Three-Phase

Meters and Appropriate Cabinetry Where Appropriate.

In PG&E’s Opening Brief, they recommend that “if the Commission decides to require

demand response customers to use metering or data logger equipment, the Commission should

require the use of revenue-grade three-phase meters and appropriate cabinetry.”40 SCE supports

PG&E’s recommendation to ensure safe operating practices if meters and loggers are installed

for monitoring customer compliance or non-compliance with the PR policy. While Cal

Advocates references non-revenue grade metering costs, no party directly opposes revenue-grade

metering if monitoring equipment is required by the Commission.

39 See Nexant 2019 Test Year Metering Pilot Report, pp. 33-34 [A-38, A-39].

40 See PG&E Opening Brief, p. 6.

12

F. Allowing Alternative Verification Methods for Specific Circumstances as Proposed

by Cal Advocates Is Reasonable but Should Be Requested by Tier 2 Advice Letter.

Cal Advocates stated that in exceptional circumstances, the Commission should allow

Scenario 2 customers to adhere to alternative verification requirements, on a case-by-case

basis.41 While SCE does not support metering for all Scenario 2 customers, for the subset of

customers that are monitored as part of the PR Policy, it is reasonable to allow for alternative

verification for unique circumstances as proposed by Cal Advocates. However, the Commission

should clearly define circumstances where an alternative method should be applied (e.g., if

meters fail, for extreme circumstances, such as a fuel cell with security issue, or if existing

customer structures prevent the safe installation of meter cabinet that will house the Revenue

Grade Meter) and afford the IOUs or VA the opportunity to validate the data accuracy and

integrity of the alternative method meets minimum requirements for the Revenue Grade Meter.

Cal Advocates also argues that the Commission should authorize the IOUs to file Tier 3

advice letters detailing the reasoning for use of any alternative verification procedure.42 SCE

recommends a Tier 2 advice letter submission which will provide the Commission and relevant

stakeholders the same transparency and potentially quicker resolution.

III.

CONCLUSION

In sum, if the Commission decides to direct implementation of any measuring devices as

part of the PR Verification Plan, it should adopt Nexant’s recommendations for the minimum

requirements of the metering equipment to demonstrate customer compliance or non-compliance

with the Demand Response PR policy adopted in Decision 16-09-056. This recommendation is

reasonable and supported by the record. With respect to Scoping Issues 2 and 3, the data in the

record is not sufficient to determine cost reasonableness for implementation of measuring


42 Id.

13

devices on 100% of Scenario 2 customers because the data does not reflect the true costs to

implement monitoring, and intervenors focus solely on measuring devices cost and incentives

while excluding other pertinent information necessary to reach a determination. Per Scoping

Issue 4, the Commission should direct an amendment to the current Verification Plan to allow for

a limited, random subset (10%) of Scenario 2 customers to be monitored by measuring devices to

ensure customer compliance or non-compliance with the DR PR policy adopted in Decision 16-

09-056.

Respectfully submitted, ROBIN Z. MEIDHOF

/s/ Robin Z. Meidhof By: Robin Z. Meidhof

Attorney for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6054 Facsimile: (626) 302-6693 E-mail: [email protected]

April 3, 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) REPLY BRIEF on all parties identified on the attached service list(s) A.18-10-008, et al. Service was effected by the means indicated below:

☒ Transmitting the copies via e-mail to all parties who have provided an e-mail address.

Executed April 3, 2020 at Rosemead, California.

/S/ Laura Velarde_______ Laura Velarde Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY

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

CPUC Home

CALIFORNIA PUBLIC UTILITIES COMMISSIONService Lists

PROCEEDING: A1810008 - PG&E- APPLICATION IN FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: MARCH 10, 2020

Download the Comma-delimited File About Comma-delimited Files

Back to Service Lists Index

Parties

SARA GERSEN ROBIN Z. MEIDHOF STAFF ATTORNEY SR. ATTORNEY EARTHJUSTICE SOUTHERN CALIFORNIA EDISON COMPANY 800 WILSHIRE BLVD., STE. 1000 2244 WALNUT GROVE AVENUE / BOX 800 LOS ANGELES, CA 90017 ROSEMEAD, CA 91770 FOR: SIERRA CLUB FOR: SOUTHERN CALIFORNIA EDISON COMPANY

ROGER A. CERDA ROSANNE O'HARA SAN DIEGO GAS & ELECTRIC COMPANY CALIF PUBLIC UTILITIES COMMISSION 8330 CENTURY PARK COURT, CP32D LEGAL DIVISION SAN DIEGO, CA 92123 ROOM 5039 FOR: SAN DIEGO GAS & ELECTRIC COMPANY 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 FOR: PUBLIC ADVOCATES OFFICE

MOLLY ZIMNEY NORA SHERIFF, ESQ. ATTORNEY ATTORNEY PACIFIC GAS AND ELECTRIC COMPANY BUCHALTER, A PROFESSIONAL CORPORATION 77 BEALE STREET, B30A 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105-3493 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION

GREG WIKLER EXE. DIR CA EFFICIENCY + DEMAND MGMT. COUNCIL 1111 BROADWAY, STE. 300 OAKLAND, CA 94607

Page 1 of 4CPUC - Service Lists - A1810008

4/3/2020https://ia.cpuc.ca.gov/servicelists/A1810008_86059.htm

FOR: CA EFFICIENCY + DEMAND MANAGEMENT COUNCIL

Information Only

DARREN ROACH MRW & ASSOCIATES, LLC PACIFIC GAS & ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

ERIKA DIAMOND AL LUNA VP - UTILITY & MKT SRVCS LITIGATION ASSISTANT, CLEAN ENERGY TEAM ENERGYHUB EARTHJUSTICE 232 3RD STREET, SUITE 201 1625 MASSACHUSETTS AVE., N.W., STE 702 BROOKLYN, NY 11215 WASHINGTON, DC 20036-2243

YASMINE AGELIDIS JERILYN LOPEZ MENDOZA EARTHJUSTICE SENIOR ADVISOR 800 WILSHIRE BLVD., STE.1000 SOUTHERN CALIFORNIA EDISON COMPANY LOS ANGELES, CA 90017 8631 RUSH STREET FOR: SIERRA CLUB ROSEMEAD, CA 91770

LISA MAU NATHANAEL A. GONZALEZ POLICY / REGULATORY AFFAIRS SR. ADVISOR SOUTHERN CALIFORNIA EDISON SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. 8631 RUSH STREET ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

CASE ADMINISTRATION ESAU GUARDADO SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY CASE MGR. 8631 RUSH STREET SAN DIEGO GAS & ELECTRIC COMPANY ROSEMEAD, CA 91880 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA 92123

SHARON L. COHEN TODD SCHAVRIEN SR. ATTORNEY REGULATORY CASE ANALYST SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32D 8330 CENTURY PARK CT. CP32F SAN DIEGO, CA 92123 SAN DIEGO, CA 92123

CENTRAL FILES SAN DIEGO GAS AND ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT (CP31E) 8330 CENTURY PARK CT, CP31-E SAN DIEGO, CA 92123-1548 SAN DIEGO, CA 92123-1530

MONA TIERNEY-LLOYD SUE MARA SR. DIR - REGULATORY AFFAIRS CONSULTANT ENEL X NORTH AMERICA, INC. RTO ADVISORS, L.L.C. PO BOX 378 164 SPRINGDALE WAY CAYUCOS, CA 93430 REDWOOD CITY, CA 94062

ELIZABETH FOX KARL STELLRECHT



CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH ELECTRICITY PLANNING & POLICY BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

KELLY A. HYMES SHELLY LYSER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ADMINISTRATIVE LAW JUDGE DIVISION ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5104 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

STEPHEN CASTELLO BOBBY SILICANI CALIF PUBLIC UTILITIES COMMISSION PACIFIC GAS AND ELECTRIC COMPANY ELECTRICITY PRICING AND CUSTOMER PROGRAM 77 BEALE STREET AREA SAN FRANCISCO, CA 94105 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

JOSEPHINE WU MICHAEL CADE CASE COORDINATOR ANALYST - ENERGY & NAT'L RESOURCES PACIFIC GAS AND ELECTRIC COMPANY BUCHALTER, A PROFESSIONAL CORPORATION 77 BEALE STREET, MC B9A, RM 2364B 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

NORA SHERIFF, ESQ. SHIRLEY A. WOO COUNSEL ATTORNEY AT LAW BUCHALTER, A PROFESSIONAL CORPORATION PACIFIC GAS AND ELECTRIC COMPANY 55 SECOND STREET, STE. 1700 77 BEALE ST., MC B30A / PO BOX 7442 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105-7442 FOR: PACIFIC GAS AND ELECTRIC COMPANY

LUKE TOUGAS NINA ROBERTSON CLEAN ENERGY REGULATORY RESEARCH, LLC STAFF ATTORNEY 175 BLUXOME STREET, @102 EARTHJUSTICE SAN FRANCISCO, CA 94107 50 CALIFORNIA STREET, STE. 500 SAN FRANCISCO, CA 94111

SARA STECK MYERS MEGAN M. MYERS ATTORNEY AT LAW COUNSEL 122 - 28TH AVENUE LAW OFFICES OF MEGAN M. MYERS SAN FRANCISCO, CA 94121 110 OXFORD STREET SAN FRANCISCO, CA 94134

CASE COORDINATION JESSICA TELLEZ PACIFIC GAS AND ELECTRIC COMPANY ENERGY SUPPLY PROCEEDINGS PO BOX 770000; MC B23A PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94177 PO BOX 770000 SAN FRANCISCO, CA 94177

JENNIFER A. CHAMBERLIN BARBARA R. BARKOVICH EXEC.DIR. MARKET DEVEL. | CAISO CONSULTANT CPOWER BARKOVICH & YAP, INC.



2475 HARVARD CIRCLE PO BOX 11031 WALNUT CREEK, CA 94597 OAKLAND, CA 94611 FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION

PAUL NELSON ALISON SEEL CONSULTANT ASSOCIATE ATTORNEY BARKOVICH & YAP, INC. SIERRA CLUB PO BOX 11031 2101 WEBSTER ST., STE. 1300 OAKLAND, CA 94611 OAKLAND, CA 94612

ANA BOYD KATHERINE RAMSEY ASSOCIATE ATTORNEY STAFF ATTORNEY SIERRA CLUB SIERRA CLUB 2101 WEBSTER ST., 13TH FLOOR 2101 WEBSTER STREET, SUITE 1300 OAKLAND, CA 94612 OAKLAND, CA 94612

TOP OF PAGE BACK TO INDEX OF SERVICE LISTS



state of california and related actions. application 18 …...application 18-10-010 southern...

Documents