BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Gas Company (U904G) and San Diego Gas & Electric Company (U902G) for Low Operational Flow Order and Emergency Flow Order Requirements. And Related Matter: Triennial Cost Allocation Proceeding Phase 1 Application of Southern California Gas Company (U 904 G) and San Diego Gas & Electric Company (U902G) for Authority to Revise their Natural Gas Rates Effective January 1, Application Application (Consolidated) REPLY IN SUPPORT OF THE JOINT PETITION FOR MODIFICATION OF DECISIONS AND , AS MODIFIED BY D OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E) JANET S. COMBS REBECCA MEIERS-DE PASTINO Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) rebecca.meiers.depastino@sce.com Dated: September 10, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Gas Company (U904G) and San Diego Gas & Electric Company (U902G) for Low Operational Flow Order and Emergency Flow Order Requirements. Application And Related Matter: Triennial Cost Allocation Proceeding Phase 1 Application of Southern California Gas Company (U 904 G) and San Diego Gas & Electric Company (U902G) for Authority to Revise their Natural Gas Rates Effective January 1, Application (Consolidated) REPLY IN SUPPORT OF THE JOINT PETITION FOR MODIFICATION OF DECISIONS AND , AS MODIFIED BY D OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E) Pursuant to Rule 16.4(g) of the Commission s Rules of Practice and Procedure, with the permission of Administrative Law Judge Kelly given via on September 10, 2018, Southern California Edison Company (SCE) Replies to the parties who filed Responses 1 to SCE and SCGC s petition the Commission to temporarily modify, on an expedited basis, Decision (D.) , and D , as modified by D (collectively the Decisions), which respectively developed the low and high Operational Flow Order (OFO) rules in Southern California Gas Company (SoCalGas) Tariff Rule 30, Paragraph G. 2 Although the PFM was filed by both SCE and SCGC, this Reply is solely SCE s. 1 The responding parties were the California Independent System Operator (CAISO), the CAISO s Department of Market Management (DMM), WPTF, NRG and SoCalGas/SDG&E. 2 SCE and SCGC filed the PFM in the above captioned proceedings at the Commission s direction. In addition, at the Commission s instruction, SCE and SCGC served the PFM on all parties to the above captioned proceedings, as well as all the parties to Order Instituting Investigation (I.)

3 I. INTRODUCTION The PFM asks the CPUC to take immediate action to protect electric customers from substantial increases in power costs that unnecessarily result from the impact of SoCalGas/SDG&E s noncompliance charge structure and that do not correlate to customer benefits or enhance system reliability. As discussed below, SoCalGas/SDG&E s Response demonstrates either a fundamental misunderstanding of the system or a disregard for costs electric customers are unnecessarily incurring. The Commission should share SCE s objective to protect customers and reject the arguments of responding parties like WPTF, whose responses advocate for the business interests of market participants, not customers. The Commission should also reject the CAISO s and SoCalGas/SDG&E s unsupported request to delay determination. Delay is inappropriate given the evidentiary record SCE produced demonstrating that the noncompliance charge structure is driving the massive price increases, but not addressing reliability concerns, and that the changes to the OFO noncompliance charge amounts the PFM requests will not negatively impact reliability. Neither SoCalGas/SDG&E nor the CAISO produced evidence creating reasonable doubt about SCE s position, much less affirmative evidence that the present prices of the noncompliance charge are necessary to protect reliability or that but for the penalty, the gas system would have failed on the days discussed in the PFM. By contrast, the CAISO s Department of Market Management (DMM) supplemented the record with compelling evidence buttressing SCE s position. Importantly, the Commission should keep in mind that SCE is not asking to eliminate the OFO noncompliance charge structure and agree it is important for reliable system operation. Rather, SCE proposes discrete modifications to the noncompliance charge in each stage. SCE agrees it is important to retain the OFO system. SoCalGas/SDG&E s claim that the substantial increases in power costs are the product of SCE s business practices also lacks merit. The DMM agrees with SCE that the massive increases in prices are the downstream consequence of restricted storage and transmission capacity on SoCalGas/SDG&E s system paired with the current amount of the daily balancing noncompliance charge. Rather than assist the

4 Commission with any affirmative evidence or alternative recommendations on how to solve this serious problem facing electric system customers, SoCalGas/SDG&E claim SCE provided insufficient evidence. The expert witness declaration of Rob Grimm in support of the PFM provided the Commission with considerable evidence that SoCalGas/SDG&E s superficial response largely left uncontested or unaddressed. For instance, evidence SCE produced that SoCalGas/SDG&E and the CAISO fail to address demonstrates that PG&E is not suffering the similar gas price increases despite using the same noncompliance charges in a system that is not constrained by a lack of storage and pipeline capacity. The evidence also shows that SCE cannot modify its behavior based on the OFOs SoCalGas/SDG&E issues because of the timing constraints and imbalance tolerances discussed in the PFM. SoCalGas/SDG&E claim SCE should have engaged in business maneuvers to mitigate exposure to high prices. SoCalGas/SDG&E s arguments demonstrate a lack of understanding of or a disregard for the lack of options available to market participants. Regardless, these increased costs will likely persist, if not increase, in the winter. These customers deserve and are entitled to a remedy without further delay. In sum, for the reasons discussed in the PFM and below, SCE has met its burden to prove the temporary measures it requested should be implemented immediately and maintained until the Commission can assess if a replacement OFO noncompliance charge structure is necessary given the significant constraints on the SoCalGas/SDG&E system, or until the storage and gas transmission system is substantially operational and capable of delivering sufficient gas to SoCalGas/SDG&E s customers after Cycle 1 schedules have been finalized. II. THE COMMISSION SHOULD GRANT THE PFM A. The Commission Should Summarily Reject SoCalGas/SDG&E s Procedural Arguments The Commission should summarily reject SoCalGas/SDG&E s procedural arguments. SoCalGas/SDG&E are aware that SCE originally filed the content of the PFM in I because the

5 current situation is a real-time test case for the scenarios the Commission is developing in Phase 1 of that proceeding, and for the outcome of Phase 2 of the proceeding. SoCalGas/SDG&E disagreed the content of the PFM was within the scope of that proceeding. The Commission s Energy Division therefore asked SCE and SCGC to refile in the above captioned matters. SCE and SCGC s complied. In addition, to ensure that all interested parties would receive notice, SCE served the PFM on all parties to the above captioned matters, as well as to I Accordingly, all interested parties have had notice and an opportunity to be heard. With regard to the number of days afforded to parties to respond, all but one who was not originally served in I were in possession of the content of the PFM for as much time as parties are afforded to respond to a PFM under the Commission s Rules of Practice and Procedure. Given that SoCalGas/SDG&E claims SCE failed to produce adequate evidence in support of the PFM, it cannot credibly claim the record was so complex that the time in which it had to respond was inadequate. Finally, SoCalGas/SDG&E s asserts that the tariff modifications do not indicate the temporary nature of the relief, and suggests that the relief is permanent, not temporary, because the restricted storage and transmission capacity are the present reality. The requested relief is temporary and it need not be expressly stated in the tariff for the Commission to have the jurisdiction and authority to restore the tariff to its original noncompliance charge structure if system conditions improve. In sum, no purported procedural flaw (there were none) prejudiced any interested party. B. The Commission Should Conclude the Current OFO Noncompliance Charge Amount is Influencing Prices Without a Corresponding Reliability Benefit Due to Constraints on the SoCalGas/SDG&E System SoCalGas/SDG&E assert that the OFO rules were designed to deal with a constrained system and these current system conditions only reinforce the need for an impactful range of increasing OFO charges to provide the System Operator effective tools 3 As discussed below, the OFO Rules were not implemented under conditions similar to those that exist today. The theory that increasing stages of noncompliance 3 Id. at p. 5.

6 charges will incentivize customers to act in a certain way is predicated upon the assumption that gas customers have options to increase gas supplies and will do so given the proper price incentive. The Declaration of Rob Grimm in support of the PFM explains precisely why opportunities to modify behavior based on OFOs are not available because of SoCalGas/SDG&E s system and timing constraints, as well as imbalance tolerances. As background, the OFO concept was developed by PG&E as part of its initial Gas Accord filing in The Commission subsequently adopted the low and high OFO rules in the Decisions at issue here. A factor underlying D , which adopted the low OFO rules, was the insufficient gas storage to ensure reliable deliveries to [SoCalGas/SDG&E s] customers during times of system stress. 4 The Decision also speculated that the new low OFO procedures could result in customer cost savings, and perhaps resolve disparities between northern and southern California. 5 To that end, the OFO rules were developed with the expectation that the OFO prices would be the highest price option available to customers, which would influence their compliance with the OFO. Stated differently, the OFO rules would set the ceiling for gas prices. The conditions that exist today are producing the opposite effect. The market is assessing the degree of gas shortage by the level of the OFO noncompliance charge set by the Gas System Operator, and the prices climb from there. In other words, the OFO charge is setting a floor, not the ceiling. This is happening because SoCalGas/SDG&E s gas system today is far more constrained than it was at the time of that decision. As result, the OFO noncompliance charge is driving up prices, as opposed to producing customer savings, and as discussed below, are amplifying, not resolving, the disparities between the two territories. It is therefore appropriate for the Commission to revisit if the noncompliance charge for each stage is appropriate under current conditions. SCE provided the Commission with a sufficient evidence to support its contention that the current noncompliance charges, paired with the unique system constraints, are driving prices up without a corresponding reliability benefit. The DMM agrees with the PFM that the massive increases in prices are 4 D at p Id. at p. 13.

7 the downstream consequence of restricted storage and transmission capacity on SoCalGas/SDG&E s system paired with the current amount of the noncompliance charges. 6 The Declaration of Rob Grimm in support of the PFM showed that PG&E experienced markedly different outcome on the same dates during the same heat wave in PG&E s service territory. 7 The difference in prices in the two territories cannot be explained by different sources of gas because PG&E and SDG&E receive gas from similar sources. 8 The only material difference that explains the disparity in gas prices in the two systems is that PG&E is not struggling with reduced storage and transmission capacity. 9 Given the system constraints and unnecessarily high gas prices, SCE disagrees that higher noncompliance charges will alleviate these current system conditions and somehow create more gas system capacity. That being said, SCE does not dispute that the OFO rules are important, which is precisely why the PFM does not asked the Commission to eliminate the OFO rules; rather the PFM proposes discrete modifications to the noncompliance charge in Stages 4 and 5. Rather than assist the Commission with any affirmative evidence or alternative recommendations on how to solve the serious problem facing electric system customers, SoCalGas/SDG&E incredibly claim SCE provided insufficient evidence. 10 The record speaks for itself. In stark contrast to the evidence supplied in the PFM, neither SoCalGas/SDG&E nor the CAISO came forward with any evidence creating reasonable doubt about the PFM s position, much less affirmative evidence that the present noncompliance charge amounts are necessary to protect reliability or that but for the penalty, the gas system would have failed on the days discussed in the PFM. Nor did they attempt to explain the disparate gas price outcomes in PG&E s and SoCalGas/SDG&E s territories. The evidence shows the Commission has good cause to impose the proposed effective temporary solution. It should not delay implementing it. 6 DMM Response at pp Grimm Decl. at Id. at In a presentation on July 31, 2018, the CPUC reported that as of July 12, 2018, SoCalGas Northern path capacity was reduced by 45% and the Southern path capacity was reduced by 42%. Technical Workshop on the Aliso Canyon Scenarios Framework, The Energy Division, California Public Utilities Commission, July 31, 2018, at p SoCalGas/SDG&E Response at pp. 2, 7-9.

8 C. If the Commission Adopts Grants the PFM, the OFO Rules Will Continue to Send Appropriate Signals to the Market Although the PFM proposes to have an identical noncompliance charge for Stage 3 and Stage 4, daily imbalance tolerance for Stage 4 is +/-5% compared with +/-15% for Stage 3. Noncompliance charge is not the only signal to the market of changing conditions that require a participants to modify their behavior. 11 The numeric identifier for each stage is an independent signal to the market. Thus, even though the noncompliance charge will not increase from Stage 3 to Stage 4, the market will see the OFO stage increasing from Stage 3 to a Stage 4. A Stage 4 OFO will therefore continue to signal to the market that gas conditions are worse than if SoCalGas/SDG&E had issued a Stage 3 OFO. The daily imbalance tolerances combined with the flat noncompliance charge for Stages 3 and 4 should provide shippers adequate incentive to balance. 12 The CAISO uses similar types of signals for tight supply conditions on high temperature days, such as Flex Alerts, restricted maintenance operations, alerts, warnings, and Stage 1, 2 and 3 Emergencies. Moreover, the PFM s proposal retains SoCalGas/SDG&E s ability to call a curtailment watch, system wide curtailment, and/or declare an Emergency Flow Order (EFO). Finally, as DMM s Response stated, Over the last two and half years the CAISO and SoCalGas have developed a variety of other tools to manage limited gas supplies due to restricted storage and transmission capacity. 13 This close coordination between CAISO and SoCalGas/SDG&E also supports gas and electric system reliability. D. The Commission Should Disregard WPTF s Market-Related Concerns That Have No Bearing on Customer Rates or System Reliability WPTF encourages the Commission to delay modifying the OFO noncompliance charges and consider other options because marketers and other entities have taken financial positions based on the 11 Arguably, there are already not sufficient signals because there is so little transparency to the market regarding why a certain stage OFO is being declared and what variables SoCalGas/SDG&E are factoring in its decisionmaking. 12 Grimm Decl. at DMM Response at p. 8.

9 current market and regulatory conditions and may suffer severe short-term losses if those conditions change. 14 In other words, WPTF asks the Commission to subordinate the interests of electric customers to the interests of market participants who have gambled on being able to profit from the volatility in the market caused by the current OFO noncompliance charges being applied in system with constrained storage and transmission capacity. The Commission should reject any position that favors sophisticated market participants who make business decisions fully appreciating the risk that all utility tariffs are subject to change at any time with Commission approval, over the interests of retail customers who are largely powerless under these circumstances. It is appropriate for the Commission to make the interests of retail customers paramount to market participants. First, Section 451 of the California Public Utilities Code requires the Commission to be concerned with just and reasonable customer rates. Second, CAISO market participants have an alternative venue and mechanism at FERC, which also uses a just and reasonable standard, to recover increased gas costs and to include the OFO costs in real-time bids. 15 Moreover, the position advanced by WPTF arguably supports the granting of the PFM because it demonstrates the validity of the contention that the OFO rules are driving unnecessary and massive price increases in the market WPTF Response at pp. 3, 8. NRG Response at pp. 3 and 6 argues that it has suffered financial losses that it may be able to recover in another venue and that these modifications may in fact produce higher prices. SCE provided ample evidence for the Commission to conclude the relief requested will not produce such results. The DMM agreed. But if that were to occur, the Commission has the jurisdiction and authority to act quickly to address that issue. Regardless, NRG, unlike electric customers, has another venue in which its issues can be addressed. 15 NRG s and CAISO s Responses indicated NRG may request reimbursement from FERC for unrecovered gas costs. See e.g., CAISO Response at p WPTF Response simultaneously advances irreconcilable positions. WPTF claims modifying the non-compliance charge will increase volatility by causing marketers to leave the system, which will result in less liquidity and even higher prices. But if modifying the rules causes higher prices, it will actually increase volatility to the benefit of certain market participants. Regardless, the objective of the OFO noncompliance charge is to incentivize behavior that enhances the reliability of the gas system. There is no evidence the volatility is enhancing reliability.

10 E. SCE Is Not the Cause of the Substantial Increases in Power Costs Customers Have and Will Likely Continue to Incur if the PFM is Not Granted SoCalGas/SDG&E suggest the substantial increases in power costs retail electric customers are experiencing are a crisis of SCE s own making because SCE purportedly should have procured firm backbone transmission service. 17 SoCalGas/SDG&E s position suggests it fundamentally misunderstands how the system works. As explained in the PFM, the timing constraints are such that all electric generators served by SoCalGas/SDG&E and connected to the CAISO grid are challenged by having to procure gas within 5% tolerances before knowing what their initial gas burns will be from CAISO schedules. As a result, unless all generators are prepared to over-deliver gas each day, an outcome SoCalGas/SDG&E would not want, most generators must submit supply bids that include the potential for noncompliance charge penalty-priced gas in their bid curves to the CAISO. It only takes one generator s bid to clear the market to set the very high power prices like the ones recently observed. Such very high power prices have a direct impact on all electricity customers. As for having the foresight to purchase firm transmission backbone service, to successfully deliver border gas to city gate, would require all generators to have been able to forecast which pipeline systems on the SoCalGas/SDG&E system were going to be constrained. In addition to not knowing that information, the CAISO market does not reimburse generators for firm backbone transmission service they do not use. It is therefore unreasonable to expect SCE to procure firm backbone transmission service for which they may not be fully compensated in the CAISO market bids. As noted above, it is important to recognize that the Commission adopted the OFO rules with the assumption that gas shippers could make arrangements to deliver sufficient flowing supplies because the gas storage and backbone transmission system were fully deliverable. Because of the current limitations of SoCalGas/SDG&E s system, noncore shippers no longer can purchase injection/withdrawal rights for storage. The combination of having no access to storage and limited transmission capacity on 17 SoCalGas/SDG&E Response at pp

11 SoCalGas/SDG&E s system has reduced the ability to access backbone transmission service in the daily markets. There simply is not enough firm backbone capacity to purchase in advance to meet the needs of all core and all noncore electric generation customers. Some generation necessarily will be exposed to the high city gate price. Moreover, SoCalGas/SDG&E provide no data or other evidence demonstrating the gas price would have been lower if SCE held the limited firm backbone capacity. Because power prices are based on the highest cleared power purchase, there is no basis to expect that the CAISO price would have been different. As a result, SCE customers would have still been exposed to these high power prices. Finally, because there is an actual physical constraint on the system, SCE must be prudent when electing to purchase backbone transmission service from the receipt point to city gate to ensure flowing supplies would be delivered across SoCalGas/SDG&E s constrained system to meet noncore gas demands. The inability to purchase storage rights combined with the outages on SoCalGas/SDG&E s system has created a situation in which noncore shippers are fully exposed to the OFO penalty structure. Retail electric customers should not needlessly incur increased rates associated with hundreds of millions of dollars in above-normal gas and wholesale electricity prices because OFO noncompliance charges are not creating a ceiling for gas prices as a result of being applied during a period of unprecedented gas system constraints. F. The Commission Should Deny SoCalGas/SDG&E s Proposed Compromise Position SoCalGas/SDG&E advance the compromise position that if the Commission adopts the PFM s temporary proposal, it should also grant SoCalGas/SDG&E s Advice Letters 5232 and 2633-G, respectively, which seek to permanently modify the calculation of the Schedule G-IMB Standby Procurement Charge associated with shipper under-delivery. 18 Specifically, the Advice Letters propose to index the charge to 150% of the highest daily city gate price, as opposed to the current 150% of the highest daily border price. 18 SoCalGas/SDG&E Response at pp

12 Although SCE protested the Commission granting any portion of the Advice Letters, and disagrees that the Advice Letters are more critical issue, 19 if the Commission grants this PFM, SCE can support using city gate instead of border. However, if that change is implemented, SCE contends it is not appropriate for the Commission to continue to allow the charge to be 150% of the highest daily city gate price. 100% of the highest daily city gate price is adequate. There is no arbitrage value in accumulating imbalances if market participants must pay 100% of the city gate daily price. By contrast, using 150% of city gate with a static $5 Stage 4 and Stage 5 noncompliance charge merely trades one price driver for another, and may create perverse incentives for market participants to ignore high OFOs. In sum, the Commission should grant the PFM and if it agrees to the modify the G-IMB tariff, it should allow SoCalGas/SDG&E to use the city gate, instead of the border, index, but only 100%, not 150%, of city gate. III. CONCLUSION For the foregoing reasons, SCE respectfully requests the Commission immediately institute the expedited and temporary relief requested in the PFM. 19 Id. at p. 10. The negative impacts on customer rates are the critical issue.

13 Respectfully submitted, JANET S. COMBS REBECCA MEIERS-DE PASTINO By: /s/ Rebecca Meiers-De Pastino Rebecca Meiers-De Pastino Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) September 10, 2018

14 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Gas Company (U904G) and San Diego Gas & Electric Company (U902G) for Low Operational Flow Order and Emergency Flow Order Requirements. And Related Matter: Triennial Cost Allocation Proceeding Phase 1 Application of Southern California Gas Company (U 904 G) and San Diego Gas & Electric Company (U902G) for Authority to Revise their Natural Gas Rates Effective January 1, Application Application (Consolidated) 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 REPLY IN SUPPORT OF THE JOINT PETITION FOR MODIFICATION OF DECISIONS AND , AS MODIFIED BY D OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E) on all parties identified on the attached service lists A and A Service was effected by one or more means indicated below: Transmitting the copies via to ALJ Gerald F. Kelly and all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by U.S. Mail to the offices of the Commissioner(s) or other addressee(s). ALJ Gerald F. Kelly California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue Room 5023 San Francisco, CA Executed this September 10, 2018, at Rosemead, California. /s/ Jean Reyes Jean Reyes, Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

15 CPUC - Service Lists - A Page 1 of 6 9/10/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A SOCAL GAS AND SDG&E FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: AUGUST 30, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties NORA SHERIFF KYLE O. STEPHENS ASSOCIATE GENERAL COUNSEL ALCANTAR & KAHL SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD, LVA-110, CA LAS VEGAS, NV FOR: INDICATED SHIPPERS FOR: SOUTHWEST GAS CORPORATION CATHERINE MAZZEO JOHNNY J. PONG ASSISTANT GENERAL COUNSEL SENIOR COUNSEL SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD 555 WEST FIFTH ST., STE LAS VEGAS, NV LOS ANGELES, CA FOR: SOUTHWEST GAS CORPORATION FOR: AND SAN DIEGO GAS COMPANY NORMAN A. PEDERSEN MATTHEW DWYER HANNA AND MORTON LLP 444 SOUTH FLOWER STREET, SUITE 1500 SOUTHERN CALIFORNIA EDISON COMPANY LOS ANGELES, CA WALNUT GROVE AVE. / PO BOX 800 FOR: SOUTHERN CALIFORNIA GENERATION ROSEMEAD, CA COALITION FOR: SOUTHERN CALIFORNIA EDISON COMPANY REBECCA MEIERS-DE PASTINO JOHN W. LESLIE SR. SOUTHERN CALIFORNIA EDISON COMPANY DENTONS US LLP 2244 WALNUT GROVE AVENUE / PO BOX EXECUTIVE DRIVE, STE. 700 ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SHELL ENERGY NORTH AMERICA (US),

16 CPUC - Service Lists - A Page 2 of 6 9/10/2018 (SCE) L.P. DARRYL J. GRUEN MARCEL HAWIGER STAFF LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM MARKET ST., STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: ORA ROBERT FINKELSTEIN EVELYN KAHL GENERAL COUNSEL AT LAW THE UTILITY REFORM NETWORK ALCANTAR & KAHL, LLP 785 MARKET ST., STE CALIFORNIA ST., STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: INDICATED SHIPPERS JONATHAN D. PENDLETON MONICA SCHWEBS COUNSEL MORGAN LEWIS BOCKIUS LLP PACIFIC GAS AND ELECTRIC COMPANY ONE MARKET, SPEAR STREET TOWER 77 BEALE STREET, MC B30A SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALPEAK POWER, LLC FOR: PACIFIC GAS AND ELECTRIC COMPANY VIDHYA PRABHAKARAN RONALD LIEBERT AT LAW DAVIS WRIGHT TREMAINE LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 505 MONTGOMERY STREET, SUITE CAPITOL AVENUE, STE. 400 SAN FRANCISCO, CA SACRAMENTO, CA FOR: CITY OF LONG BEACH FOR: CALIFORNIA MANUFACTURERS AND TECHNOLOGY ASSOCIATION Information Only ALICIA AGUILAR BRIAN THEAKER LEGAL SECRETARY/PARALEGAL DIR - REGULATORY AFFAIRS HANNA AND MORTON LLP NRG ENERGY, INC., CA 00000, CA FOR: SOUTHERN CALIFORNIA GENERATION COALITION CASE COORDINATION CONOR DOYLE PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA DAVID B. PECK GREGORY S. G. KLATT EXE DIV. CALIFORNIA PUBLIC UTILITIES COMMISSION DOUGLASS & LIDDELL, CA 00000, CA 00000

17 CPUC - Service Lists - A Page 3 of 6 9/10/2018 IGOR GRINBERG KATIE JORRIE REGULATORY AFFAIRS DAVIS WRIGHT TREMAINE, LLP PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA MRW & ASSOCIATES, LLC DAVIS WRIGHT TREMAINE LLP, CA 00000, CA KAREN TERRANOVA JACOB POLLOCK ALCANTAR & KAHL CALPEAK POWER, LLC 9405 ARROWPOINT BLVD., CA CHARLOTTE, NC BRETT BINGHAM ISHWAR SAINI MACQUARIE ENERGY LLC VP - MKTS & REGULATORY AFFAIRS 500 DALLAS STREET, STE MACQUARIE ENERGY LLC HOUSTON, TX DALLAS STREET, STE HOUSTON, TX JAKE ANDERSON KIRBY BOSLEY MACQUARIE ENERGY LLC JP MORGAN VENTURES ENERGY CORP. 500 DALLAS STREE, STE LOUISIANA STREET, SUITE 1000 HOUSTON, TX HOUSTON, TX PAUL GENDRON VALERIE ONTIVEROZ JP MORGAN VENTURES ENERGYCORP. REGULATORY MGR / CALIFORNIA 700 LOUISIANA STREET, SUITE 1000 SOUTHWEST GAS CORPORATION HOUSTON, TX SPRING MOUNTAIN ROAD, LVB-105 LAS VEGAS, NV PRISCILA C. KASHA PRISCILA C. KASHA DEPUTY CITY ATORNEY DEPUTY CITY LOS ANGELES DEPT. OF WATER & POWER LOS ANGELES DEPT. OF WATER & POWER 11 NORTH HOPE STREET, ROOM N. HOPE STREET, RM. 340 LOS ANGELES, CA LOS ANGELES, CA RODNEY A. LUCK ROBERT L. PETTINATO LOS ANGELES DEPT. OF WATER & POWER L.A. DEPT. OF POWER & WATER-NAT. GAS GRP 111 NORTH HOPE STREET, ROOM NORTH HOPE STREET, ROOM 1150 LOS ANGELES, CA LOS ANGELES, CA ELIZABETH LA COUR JASON W. EGAN MARKET STRUCTURE, COSTS AND NATURAL GAS 320 West 4th Street Suite W. FIFTH STREET, STE GT14E7 Los Angeles, CA LOS ANGELES, CA JEFF SALAZAR JEFFREY B. FOHRER SENIOR COUNSEL 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA W. FIFTH STREET, GT-14E7

18 CPUC - Service Lists - A Page 4 of 6 9/10/2018 LOS ANGELES, CA JOSEPH MOCK RONALD VAN DER LEEDEN REGULATORY CASE MGR. DIR. - REGULATORY AFFAIRS 555 WEST 5TH ST., STE 1400, GT14D6 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA LOS ANGELES, CA GREGORY HEALY RONALD S. CAVALLERI REGULATORY CASE MGR. REGULATORY AFFAIRS 555 WEST FIFTH STREET, GT14D6 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA LOS ANGELES, CA FOR: AND SAN DIEGO GAS COMPANY RASHA PRINCE DAN BERGMANN DIRECTOR, REGULATORY AFFAIRS CONSULTANT IGSERVICE 555 WEST 5TH STREET, GT14D SANTA FE AVENUE LOS ANGELES, CA VERNON, CA FOR: CITY OF VERNON TOM ROTH MICHAEL ALEXANDER ROTH ENERGY COMPANY ALEXANDER CONSULTING 545 S. FIGUEROA STREET, SUITE EAST RODELL PLACE LOS ANGELES, CA ARCADIA, CA MICHAEL S. ALEXANDER LEESA NAYUDU LEPRECHAUN CONSULTING GROUP PASADENA DEPARTMENT OF WATER & POWER 45 EAST RODELL PLACE 150 SOUTH LOS ROBLES AVE., STE. 200 ARCADIA, CA PASADENA, CA STEVEN ENDO VALERIE PUFFER PASADENA DEPARTMENT OF WATER & POWER GLENDALE WATER & POWER 150 S. LOS ROBLES, SUITE N. GLENDALE AVENUE, LEVEL 4 PASADENA, CA GLENDALE, CA CHRIS CHWANG HIMANSHU PANDEY BURBANK WATER AND POWER ASST. POWER PRODUCTION SUPERINTENDENT 164 WEST MAGNOLIA BLVD. BURBANK WATER & POWER BURBANK, CA W. MAGNOLIA BLVD. BURBANK, CA CASE ADMINISTRATION CARRIE ANNE DOWNEY SOUTHERN CALIFORNIA EDISON COMPANY LAW OFFICES OF CARRIE ANNE DOWNEY 2244 WALNUT GROVE AVE. / PO BOX YNEZ PLACE ROSEMEAD, CA CORONADO, CA JEFF MALONE MARCIE A. MILNER CALPEAK POWER LLC VP - REG AFFAIRS 7365 MISSION GORGE ROAD, SUITE C SHELL ENERGY NORTH AMERICA (US), L.P. SAN DIEGO, CA EASTGATE MALL, STE. 100

19 CPUC - Service Lists - A Page 5 of 6 9/10/2018 SAN DIEGO, CA CENTRAL FILES NOE R. GUTIERREZ SAN DIEGO GAS & ELECTRIC COMPANY IMPERIAL IRRIGATION DISTRICT 8330 CENTURY PARK CT, CP31-E 333 EAST BARIONI BLVD. SAN DIEGO, CA IMPERIAL, CA SUSAN D. WILSON ANAND DURVASULA DEPUTY CITY CITY OF RIVERSIDE COMMISSIONER RANDOLPH 3900 MAIN STREET, 7TH FLOOR ROOM 4107 RIVERSIDE, CA VAN NESS AVENUE SAN FRANCISCO, CA BELINDA GATTI JONATHAN BROMSON MARKET STRUCTURE, COSTS AND NATURAL GAS LEGAL DIVISION AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA RACHEL PETERSON HERBERT EMMRICH THE UTILITY REFORM NETWORK COMMISSIONER RANDOLPH 785 MARKET STREET, SUITE 1400 AREA 4-A SAN FRANCISCO, CA VAN NESS AVENUE SAN FRANCISCO, CA KATY MORSONY AMIE BURKHOLDER BUCHALTER, A PROFESSIONAL CORPORATION ALCANTAR & KAHL LLP 55 SECOND STREET, STE CALIFORNIA STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA BUCHALTER, A PROFESSIONAL CORPORATION CALIFORNIA ENERGY MARKETS 55 SECOND STREET, SUITE DIVISADERO ST STE 303 SAN FRANCISCO, CA SAN FRANCISCO, CA MIKE CADE RALPH E. DENNIS INDUSTRY SPECIALIST DENNIS CONSULTING BUCHALTER 2140 VIA MEDIA COURT 55 SECOND STREET, 16TH FL. BENICIA, CA SAN FRANCISCO, CA CATHERINE E. YAP BARKOVICH & YAP, INC. PO BOX OAKLAND, CA State Service

20 CPUC - Service Lists - A Page 6 of 6 9/10/2018 JEAN SPENCER NILS STANNIK ENERGY DIV. ORA CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION, CA 00000, CA GERALD F. KELLY ANA M. GONZALEZ DIVISION OF ADMINISTRATIVE LAW JUDGES DIVISION OF ADMINISTRATIVE LAW JUDGES 320 West 4th Street Suite 500 ROOM 2106 Los Angeles, CA VAN NESS AVENUE SAN FRANCISCO, CA JENNIFER KALAFUT KELLY C. LEE COMMISSIONER PETERMAN ENERGY SAFETY & INFRASTRUCTURE BRANCH ROOM 5303 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA NATHANIEL SKINNER RICHARD A. MYERS ENERGY SAFETY & INFRASTRUCTURE BRANCH MARKET STRUCTURE, COSTS AND NATURAL GAS AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

21 CPUC - Service Lists - A Page 1 of 6 9/10/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A SOCAL GAS AND SDG&E FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: AUGUST 30, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties NORA SHERIFF KYLE O. STEPHENS ASSOCIATE GENERAL COUNSEL ALCANTAR & KAHL SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD, LVA-110, CA LAS VEGAS, NV FOR: INDICATED SHIPPERS FOR: SOUTHWEST GAS CORPORATION CATHERINE MAZZEO JOHNNY J. PONG ASSISTANT GENERAL COUNSEL SENIOR COUNSEL SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD 555 WEST FIFTH ST., STE LAS VEGAS, NV LOS ANGELES, CA FOR: SOUTHWEST GAS CORPORATION FOR: AND SAN DIEGO GAS COMPANY NORMAN A. PEDERSEN MATTHEW DWYER HANNA AND MORTON LLP 444 SOUTH FLOWER STREET, SUITE 1500 SOUTHERN CALIFORNIA EDISON COMPANY LOS ANGELES, CA WALNUT GROVE AVE. / PO BOX 800 FOR: SOUTHERN CALIFORNIA GENERATION ROSEMEAD, CA COALITION FOR: SOUTHERN CALIFORNIA EDISON COMPANY REBECCA MEIERS-DE PASTINO JOHN W. LESLIE SR. SOUTHERN CALIFORNIA EDISON COMPANY DENTONS US LLP 2244 WALNUT GROVE AVENUE / PO BOX EXECUTIVE DRIVE, STE. 700 ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SHELL ENERGY NORTH AMERICA (US),

22 CPUC - Service Lists - A Page 2 of 6 9/10/2018 (SCE) L.P. DARRYL J. GRUEN MARCEL HAWIGER STAFF LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM MARKET ST., STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: ORA ROBERT FINKELSTEIN EVELYN KAHL GENERAL COUNSEL AT LAW THE UTILITY REFORM NETWORK ALCANTAR & KAHL, LLP 785 MARKET ST., STE CALIFORNIA ST., STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: INDICATED SHIPPERS JONATHAN D. PENDLETON MONICA SCHWEBS COUNSEL MORGAN LEWIS BOCKIUS LLP PACIFIC GAS AND ELECTRIC COMPANY ONE MARKET, SPEAR STREET TOWER 77 BEALE STREET, MC B30A SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALPEAK POWER, LLC FOR: PACIFIC GAS AND ELECTRIC COMPANY VIDHYA PRABHAKARAN RONALD LIEBERT AT LAW DAVIS WRIGHT TREMAINE LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 505 MONTGOMERY STREET, SUITE CAPITOL AVENUE, STE. 400 SAN FRANCISCO, CA SACRAMENTO, CA FOR: CITY OF LONG BEACH FOR: CALIFORNIA MANUFACTURERS AND TECHNOLOGY ASSOCIATION Information Only ALICIA AGUILAR BRIAN THEAKER LEGAL SECRETARY/PARALEGAL DIR - REGULATORY AFFAIRS HANNA AND MORTON LLP NRG ENERGY, INC., CA 00000, CA FOR: SOUTHERN CALIFORNIA GENERATION COALITION CASE COORDINATION CONOR DOYLE PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA DAVID B. PECK GREGORY S. G. KLATT EXE DIV. CALIFORNIA PUBLIC UTILITIES COMMISSION DOUGLASS & LIDDELL, CA 00000, CA 00000

23 CPUC - Service Lists - A Page 3 of 6 9/10/2018 IGOR GRINBERG KATIE JORRIE REGULATORY AFFAIRS DAVIS WRIGHT TREMAINE, LLP PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA MRW & ASSOCIATES, LLC DAVIS WRIGHT TREMAINE LLP, CA 00000, CA KAREN TERRANOVA JACOB POLLOCK ALCANTAR & KAHL CALPEAK POWER, LLC 9405 ARROWPOINT BLVD., CA CHARLOTTE, NC BRETT BINGHAM ISHWAR SAINI MACQUARIE ENERGY LLC VP - MKTS & REGULATORY AFFAIRS 500 DALLAS STREET, STE MACQUARIE ENERGY LLC HOUSTON, TX DALLAS STREET, STE HOUSTON, TX JAKE ANDERSON KIRBY BOSLEY MACQUARIE ENERGY LLC JP MORGAN VENTURES ENERGY CORP. 500 DALLAS STREE, STE LOUISIANA STREET, SUITE 1000 HOUSTON, TX HOUSTON, TX PAUL GENDRON VALERIE ONTIVEROZ JP MORGAN VENTURES ENERGYCORP. REGULATORY MGR / CALIFORNIA 700 LOUISIANA STREET, SUITE 1000 SOUTHWEST GAS CORPORATION HOUSTON, TX SPRING MOUNTAIN ROAD, LVB-105 LAS VEGAS, NV PRISCILA C. KASHA PRISCILA C. KASHA DEPUTY CITY ATORNEY DEPUTY CITY LOS ANGELES DEPT. OF WATER & POWER LOS ANGELES DEPT. OF WATER & POWER 11 NORTH HOPE STREET, ROOM N. HOPE STREET, RM. 340 LOS ANGELES, CA LOS ANGELES, CA RODNEY A. LUCK ROBERT L. PETTINATO LOS ANGELES DEPT. OF WATER & POWER L.A. DEPT. OF POWER & WATER-NAT. GAS GRP 111 NORTH HOPE STREET, ROOM NORTH HOPE STREET, ROOM 1150 LOS ANGELES, CA LOS ANGELES, CA ELIZABETH LA COUR JASON W. EGAN MARKET STRUCTURE, COSTS AND NATURAL GAS 320 West 4th Street Suite W. FIFTH STREET, STE GT14E7 Los Angeles, CA LOS ANGELES, CA JEFF SALAZAR JEFFREY B. FOHRER SENIOR COUNSEL 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA W. FIFTH STREET, GT-14E7

24 CPUC - Service Lists - A Page 4 of 6 9/10/2018 LOS ANGELES, CA JOSEPH MOCK RONALD VAN DER LEEDEN REGULATORY CASE MGR. DIR. - REGULATORY AFFAIRS 555 WEST 5TH ST., STE 1400, GT14D6 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA LOS ANGELES, CA GREGORY HEALY RONALD S. CAVALLERI REGULATORY CASE MGR. REGULATORY AFFAIRS 555 WEST FIFTH STREET, GT14D6 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA LOS ANGELES, CA FOR: AND SAN DIEGO GAS COMPANY RASHA PRINCE DAN BERGMANN DIRECTOR, REGULATORY AFFAIRS CONSULTANT IGSERVICE 555 WEST 5TH STREET, GT14D SANTA FE AVENUE LOS ANGELES, CA VERNON, CA FOR: CITY OF VERNON TOM ROTH MICHAEL ALEXANDER ROTH ENERGY COMPANY ALEXANDER CONSULTING 545 S. FIGUEROA STREET, SUITE EAST RODELL PLACE LOS ANGELES, CA ARCADIA, CA MICHAEL S. ALEXANDER LEESA NAYUDU LEPRECHAUN CONSULTING GROUP PASADENA DEPARTMENT OF WATER & POWER 45 EAST RODELL PLACE 150 SOUTH LOS ROBLES AVE., STE. 200 ARCADIA, CA PASADENA, CA STEVEN ENDO VALERIE PUFFER PASADENA DEPARTMENT OF WATER & POWER GLENDALE WATER & POWER 150 S. LOS ROBLES, SUITE N. GLENDALE AVENUE, LEVEL 4 PASADENA, CA GLENDALE, CA CHRIS CHWANG HIMANSHU PANDEY BURBANK WATER AND POWER ASST. POWER PRODUCTION SUPERINTENDENT 164 WEST MAGNOLIA BLVD. BURBANK WATER & POWER BURBANK, CA W. MAGNOLIA BLVD. BURBANK, CA CASE ADMINISTRATION CARRIE ANNE DOWNEY SOUTHERN CALIFORNIA EDISON COMPANY LAW OFFICES OF CARRIE ANNE DOWNEY 2244 WALNUT GROVE AVE. / PO BOX YNEZ PLACE ROSEMEAD, CA CORONADO, CA JEFF MALONE MARCIE A. MILNER CALPEAK POWER LLC VP - REG AFFAIRS 7365 MISSION GORGE ROAD, SUITE C SHELL ENERGY NORTH AMERICA (US), L.P. SAN DIEGO, CA EASTGATE MALL, STE. 100

25 CPUC - Service Lists - A Page 5 of 6 9/10/2018 SAN DIEGO, CA CENTRAL FILES NOE R. GUTIERREZ SAN DIEGO GAS & ELECTRIC COMPANY IMPERIAL IRRIGATION DISTRICT 8330 CENTURY PARK CT, CP31-E 333 EAST BARIONI BLVD. SAN DIEGO, CA IMPERIAL, CA SUSAN D. WILSON ANAND DURVASULA DEPUTY CITY CITY OF RIVERSIDE COMMISSIONER RANDOLPH 3900 MAIN STREET, 7TH FLOOR ROOM 4107 RIVERSIDE, CA VAN NESS AVENUE SAN FRANCISCO, CA BELINDA GATTI JONATHAN BROMSON MARKET STRUCTURE, COSTS AND NATURAL GAS LEGAL DIVISION AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA RACHEL PETERSON HERBERT EMMRICH THE UTILITY REFORM NETWORK COMMISSIONER RANDOLPH 785 MARKET STREET, SUITE 1400 AREA 4-A SAN FRANCISCO, CA VAN NESS AVENUE SAN FRANCISCO, CA KATY MORSONY AMIE BURKHOLDER BUCHALTER, A PROFESSIONAL CORPORATION ALCANTAR & KAHL LLP 55 SECOND STREET, STE CALIFORNIA STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA BUCHALTER, A PROFESSIONAL CORPORATION CALIFORNIA ENERGY MARKETS 55 SECOND STREET, SUITE DIVISADERO ST STE 303 SAN FRANCISCO, CA SAN FRANCISCO, CA MIKE CADE RALPH E. DENNIS INDUSTRY SPECIALIST DENNIS CONSULTING BUCHALTER 2140 VIA MEDIA COURT 55 SECOND STREET, 16TH FL. BENICIA, CA SAN FRANCISCO, CA CATHERINE E. YAP BARKOVICH & YAP, INC. PO BOX OAKLAND, CA State Service

26 CPUC - Service Lists - A Page 6 of 6 9/10/2018 JEAN SPENCER NILS STANNIK ENERGY DIV. ORA CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION, CA 00000, CA GERALD F. KELLY ANA M. GONZALEZ DIVISION OF ADMINISTRATIVE LAW JUDGES DIVISION OF ADMINISTRATIVE LAW JUDGES 320 West 4th Street Suite 500 ROOM 2106 Los Angeles, CA VAN NESS AVENUE SAN FRANCISCO, CA JENNIFER KALAFUT KELLY C. LEE COMMISSIONER PETERMAN ENERGY SAFETY & INFRASTRUCTURE BRANCH ROOM 5303 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA NATHANIEL SKINNER RICHARD A. MYERS ENERGY SAFETY & INFRASTRUCTURE BRANCH MARKET STRUCTURE, COSTS AND NATURAL GAS AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS