BEFORE THE PUBLIC UTILITIES CPUC OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) )

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1 BEFORE THE PUBLIC UTILITIES CPUC OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U 902 M for Approval of its Energy Storage Procurement Framework and Program As Required by Decision Application of Pacific Gas and Electric Company (U 39-E for Authorization to Procure Energy Storage Systems during the 2014 Biennial Procurement Period Pursuant to Decision Application of Southern California Edison Company (U 338-E for Approval of Its 2014 Energy Storage Procurement Plan. Application (Filed February 28, 2014 Application (Filed February 28, 2014 Application (Filed February 28, 2014 REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E ON THE PROPOSED DECISION APPROVING SAN DIEGO GAS & ELECTRIC COMPANY, PACIFIC GAS AND ELECTRIC COMPANY, AND SOUTHERN CALIFORNIA EDISON COMPANY S STORAGE PROCUREMENT FRAMEWORK AND PROGRAM APPLICATIONS FOR THE 2014 BIENNIAL PROCUREMENT PERIOD WILLIAM V. WALSH REBECCA MEIERS-DE PASTINO Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( rebecca.meiers-depastino@sce.com Dated: October 7, 2014 LIMS

2 BEFORE THE PUBLIC UTILITIES CPUC OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U 902 M for Approval of its Energy Storage Procurement Framework and Program As Required by Decision Application of Pacific Gas and Electric Company (U 39-E for Authorization to Procure Energy Storage Systems during the 2014 Biennial Procurement Period Pursuant to Decision Application of Southern California Edison Company (U 338-E for Approval of Its 2014 Energy Storage Procurement Plan. Application (Filed February 28, 2014 Application (Filed February 28, 2014 Application (Filed February 28, 2014 REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E ON THE PROPOSED DECISION APPROVING SAN DIEGO GAS & ELECTRIC COMPANY, PACIFIC GAS AND ELECTRIC COMPANY, AND SOUTHERN CALIFORNIA EDISON COMPANY S STORAGE PROCUREMENT FRAMEWORK AND PROGRAM APPLICATIONS FOR THE 2014 BIENNIAL PROCUREMENT PERIOD Pursuant to Rule 14.3(d of the Rules of Practice and Procedure of the California Public Utilities Commission (CPUC, Southern California Edison Company (SCE respectfully submits these Reply Comments on the Proposed Decision (PD Approving San Diego Gas & Electric Company (SDG&E s, Pacific Gas and Electric Company (PG&E s, and SCE s (the IOUs Storage Procurement Framework and Program Applications for the 2014 Biennial Procurement Period. I. DISCUSSION As discussed below, the CPUC should extend the Power Charge Indifference Adjustment (PCIA recovery to the duration of the energy storage (ES contract and allow the IOUs to file Tier 3 advices - 1 -

3 letters for ES contract approval. The CPUC should not, however, (1 exclude the authorized ES procurement from non-bypassable charges, (2 require the IOUs to use the Consistent Evaluation Protocol (CEP to evaluate bids, (3 broaden the ES solicitation eligibility to include commercially available technologies, or (4 standardize ES interconnection requirements. A. PCIA Recovery Should Extend for the Duration of the ES Contract Marin Clean Energy (MCE, Shell, the Alliance for Retail Energy Markets (AReM, and the Direct Access Customer Coalition (DACC argue that the CPUC should not extend the PCIA cost recovery beyond ten years. 1 Shell also argues that the IOUs should not be able to recover stranded costs through the PCIA because storage is not generation or energy procurement. 2 Those parties positions are contrary to law, fact, and CPUC precedent. As a fundamental matter, it is incorrect that the PCIA should not apply to these storage resources. ES procured for market services, as is the case here, functions as generation replacement. Because the ES contracts will allow the utility to avoid purchasing additional generation capacity and capture the value of energy and ancillary services, the contracts are properly treated as generation assets for cost recovery purposes. 3 Thus, SCE agrees with the PD that the IOUs should establish an appropriate market price benchmark for ES projects to be used in the PCIA calculations. Shell argues that the PCIA should not be used to shift the costs of an IOU s market function energy storage to departing load customers, 4 but the PCIA does precisely the opposite. As required by Section 366.2, 5 the PCIA s fundamental purpose is to maintain customer indifference by prevent[ing] any shifting of recoverable costs between customers. 6 The PCIA therefore ensures that bundled service customers on whose behalf these generation-function resources will be procured will not be able to later escape their statutory responsibility to pay their share of any above-market costs incurred on their behalf by simply leaving the utility. 1 MCE Opening Comments at pp. 2-4, Shell at p. 3, DACC and AReM at pp Shell Opening Comments at p. 4. By contrast, DACC/AReM do not dispute the fundamental premise that the PCIA applies. 3 Indeed, the CAISO also treats storage devices as generation capacity for interconnection purposes. 4 Shell Opening Comments at p Cal. Pub. Util. Code 366.2(d (1; see also Cal. Pub. Util. Code 366.1(d (1. 6 See also D

4 Moreover, removing any stranded costs arising out of these contracts from the PCIA after 10 years deviates from the CPUC s practice of applying the PCIA for the life of Renewable Portfolio Standard (RPS contracts. 7 ES contracts should be afforded the same treatment given that they are longterm contracts to support the state s policy goals, including renewable integration. Nothing in the record of this proceeding supports carving the ES contracts out of indifference calculation after 10 years. Finally, the CPUC should not defer its decision on PCIA recovery as MCE proposes. 8 SCE needs to know the cost recovery implications of ES contracts before it solicits and enters into long-term agreements. B. Authorized ES Procurement Should Not be Excluded from Non-bypassable Charges DACC/AReM argue that cost recovery from ESPs /CCAs customers through the Cost Allocation Mechanism (CAM or other non-bypassable charges should be limited to certain ES resources that are already operating or committed by the IOUs, and should not apply to incremental ES procurement authorized in this proceeding. 9 DACC/AReM argue that because ESPs/CCAs have their own target to meet, their customers should not have to pay for both the IOU s and ESP s/cca s ES procurement. The CPUC should reject this self-serving argument because it ignores the rationale underlying how the CPUC decided to allocated the ES targets. D clearly states that the CPUC set a lower target for ESPs/CCAs since all customers, including those of ESPs and CCAs, will be required to pay certain non-bypassable charges that may be used by the IOUs to develop ES systems. 10 The CPUC should thus reject DACC / AReM s argument that their target, which was deliberately set much lower than the IOUs precisely because their customers must pay such nonbypassable charges, provides any basis for their customers to avoid paying non-bypassable charges related to the IOUs ES procurement D at p. 41 (citing D at p. 632 (adopting QF CHP Proposed Settlement and noting that it " has extended the 10 year non-bypassable charge limitation in other areas, most notably with RPS ( Renewables Portfolio Standard contracts, which are recovered over the life of the PPA and thus may be recovered for a period substantially longer than 10 years. ; see also D at p. 7, citing D MCE Opening Comments at p DACC/AReM Opening Comments at pp D at p. 46 (emphasis added. 11 The CPUC should likewise reject DACC/AReM s implied argument that after accounting for the very few projects that are already operating or committed by the IOUs, the ESPs and CCAs target is equivalent to the IOUs and their customers should therefore not have to pay for any ES costs that would be normally recovered through transmission and distribution (T&D rates, the Electric Program Investment Charge (EPIC or CAM

5 DACC/AReM also argue that if the CPUC authorizes cost recovery for incremental IOU ES procurement through T&D rates, EPIC charges or CAM, the CAM calculation of net capacity costs should be established now. 12 As the PD states, CAM authorization is out of scope of this proceeding. 13 CAM cost calculation should be addressed in the proceeding in which the CPUC authorized CAM treatment for ES procurement. C. SCE s Valuation Process is Comprehensive The Joint LDES parties 14 request that the CPUC require the IOUs to use the CEP to evaluate bids and include greenhouse gas (GHG in their qualitative measures. 15 SCE s valuation process is more comprehensive than the CEP. 16 SCE considers system-wide benefits, many of which, such as GHG, are captured quantitatively; those that cannot be are qualitatively evaluated. And an independent evaluator monitors the fairness of the valuation process. D. The CPUC Should Include V1G as an Eligible ES Resource Several parties, including SCE, support the inclusion of V1G 17 as an eligible ES resource. 18 Treating EVs, including V1G, as storage (1 falls within the letter and spirit of AB 2514, (2 supports the guiding principles espoused in D , and (3 promotes optimization of the grid, integration of renewables, and reduction of GHG. E. The IOUs Should File Advice Letters for Approval of ES Contracts SCE agrees with CESA, the Independent Energy Producers Association (IEPA, the Large Scale Solar Association (LSA, PG&E, and Western Power Trading Forum (WPTF that in the interest of efficiency, the IOUs should seek approval of ES contracts by filing Tier 3 advice letters, not applications. As IEPA s comments note, 19 the CPUC has already approved a Tier 3 advice letter for 12 DACC and AReM Opening Comments at p PD at p The list of included parties is set forth in their Opening Comments. 15 Joint LDES Parties Opening Comments at pp. 6, SCE s 6/19/4 Reply to Responses to Scoping Memo Questions at pp ; SCE s 6/12/14 Responses to Supplemental Questions at pp V1G refers to smart charging electric vehicles (EVs that have unidirectional power flow, while V2G EVs have bidirectional power flow. 18 General Motors Opening Comments at pp. 1-2, PG&E Opening Comments at pp , and NRDC/EDF at pp. 1-2, IEPA s Opening Comments at p

6 approval of an ES contract with Rice Solar. The Tier 3 advice letter process will fully vet the contracts by affording all parties an opportunity to comment and requiring a vote of the CPUC on final resolution. F. Eligible ES Projects Must be More than Commercially Available LDES argues that SCE s requirement that eligible ES projects must be based on a commercialized technology is too narrow and asks the CPUC to broaden the eligibility to include commercially available technologies, which it vaguely defines as available for immediate purchase under typical business terms and deliverable within a reasonable period. 20 Because ES is a nascent technology, SCE needs the flexibility to restrict solicitation participation to technologies and applications that have passed the research and demonstration phase. The IOUs have a long and successful track record of evaluating and procuring emerging renewable technologies in a manner that significantly reduces delivery and performance risks to customers. The CPUC should reject LDES s recommendation, which might require SCE to allow risky and unproven technologies and applications to participate in its solicitations. G. The CPUC Should Not Standardize ES Interconnection Requirements The Office of Ratepayer Advocates (ORA asks the CPUC to standardize the IOUs ES interconnection requirements in the Rule 21 proceeding. 21 Neither this nor the Rule 21 proceeding are the proper venues for this issue. The Rule 21 proceeding is not an appropriate venue because (1 SCE is not contemplating any new ES interconnection requirements and (2 many of the ES projects will be FERC-jurisdictional, interconnecting through Wholesale Distribution Access Tariff (WDAT or Transmission Owner (TO tariffs. Second, the IOUs, which have different system needs and degrees of contracting experience, should be permitted, especially with this nascent technology, to have individual interconnection study requirements. II. CONCLUSION For the foregoing reasons, the CPUC should extend the PCIA recovery to the duration of the ES contract and allow the IOUs file Tier 3 advices letters for ES contract approval. The CPUC should not, however, (1 exclude the authorized ES procurement from non-bypassable charges, (2 require the IOUs 20 LDES Opening Comments at pp ORA Opening Comments at p

7 to use the CEP to evaluate bids, (3 broaden the ES solicitation eligibility to include commercially available technologies, or (4 standardize ES interconnection requirements. Respectfully submitted, WILLIAM V. WALSH REBECCA MEIERS-DE PASTINO October 7, 2014 /s/ Rebecca Meiers-De Pastino By: Rebecca Meiers-De Pastino Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: (

8 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U 902 M for Approval of its Energy Storage Procurement Framework and Program As Required by Decision Application of Pacific Gas and Electric Company (U 39-E for Authorization to Procure Energy Storage Systems during the 2014 Biennial Procurement Period Pursuant to Decision Application of Southern California Edison Company (U 338-E for Approval of Its 2014 Energy Storage Procurement Plan. Application (Filed February 28, 2014 Application (Filed February 28, 2014 Application (Filed February 28, 2014 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 the REPLY COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338 E ON THE PROPOSED DECISION APPROVING SAN DIEGO GAS & ELECTRIC COMPANY, PACIFIC GAS AND ELECTRIC COMPANY, AND SOUTHERN CALIFORNIA EDISON COMPANY S STORAGE PROCUREMENT FRAMEWORK AND PROGRAM APPLICATIONS FOR THE 2014 BIENNIAL PROCUREMENT PERIOD on all parties identified on the attached service list(s: A , et al. Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in properly addressed sealed envelopes and causing such copies to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s or other addressee(s: ALJ Colette Kersten CPUC 505 Van Ness Avenue San Francisco, CA 94102

9 Placing the copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to all parties for those listed on the attached non- list. Executed this October 7, 2014, at Rosemead, California. /s/ Regina Coburn Regina Coburn Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY Post Office Box Walnut Grove Avenue Rosemead, California 91770

10 CPUC - Service Lists - A Page 1 of 6 10/7/2014 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A SDG&E - FOR APPROVAL FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: OCTOBER 6, 2014 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties JAMIE L. MAULDIN JEREMY WAEN ADAMS BROADWELL JOSEPH & CARDOZO, PC REGULATORY ANALYST MARIN CLEAN ENERGY, CA FOR: COALITION OF CALIFORNIA UTILITY, CA EMPLOYEES FOR: MARIN CLEAN ENERGY KATHERINE HAMILTON ERIC C. APFELBACH POLICY DIRECTOR PRESIDENT AND CEO ENERGY STORAGE ASSOICATION ZBB ENERGY CORPORATION TH STREET, NW, SUITE 500 N93 W14475 WHITTAKER WAY WASHINGTON, DC MENOMONEE FALLS, WI FOR: ENERGY STORAGE ASSOCIATION FOR: ZBB ENERGY CORPORATION ' SULLIVAN JEFFREY A. SERFASS VP BUSINESS DEVELOPMENT MANAGING DIRECTOR ORMAT TECHNOLOGIES CALIFORNIA HYDROGEN BUSINESS COUNCIL 6225 NEIL ROAD 3438 MERRIMAC ROAD RENO, NV LOS ANGELES, CA FOR: ORMAT TECHNOLOGIES FOR: CALIFORNIA HYDROGEN BUSINESS COOUNCIL (CHBC ADAM GREEN ALEXANDER KEROS SOLARRESERVE, LLC ADVANCED VEHICLE & INFRASTRUCTURE POLICY 2425 OLYMPIC BLVD., STE. 500E GENERAL MOTORS, LLC SANTA MONICA, CA LOMITA BLVD. FOR: SOLARRESERVE, LLC TORRANCE, CA FOR: GENERAL MOTORS, LLC DANIEL W. DOUGLASS NANCY CHUNG ALLRED ATTORNEY SOUTHERN CALIFORNIA EIDSON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVE. / PO BOX OXNARD ST., STE ROSEMEAD, CA 91770

11 CPUC - Service Lists - A Page 2 of 6 10/7/2014 WOODLAND HILLS, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: WESTERN POWER TRADING FORUM JOHN W. LESLIE DONALD C. LIDDELL, PC ATTORNEY COUNSEL MCKENNA LONG & ALDRIDGE LLP DOUGLASS & LIDDELL 600 WEST BROADWAY, STE ND AVENUE SAN DIEGO, CA SAN DIEGO, CA FOR: SHELL ENERGY NORTH AMERICA (US, FOR: CALIFORNIA ENERGY STORAGE ALLIANCE L.P. (CESA HANNON J. RASOOL EDWARD G. CAZALET REGULATORY CASE ADMIN. VP AND CO-FOUNDER SAN DIEGO GAS & ELECTRIC COMPANY MEGAWATT STORAGE FARMS, INC CENTURY PARK COURT, CP32D 101 FIRST STREET, SUITE 552 SAN DIEGO, CA LOS ALTOS, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: MEGAWATT STORAGE FARMS, INC. KENNETH SAHM WHITE SUE MARA ECONOMICS & POLICY ANALYSIS DIRTECTOR CONSULTANT CLEAN COALITION RTO ADVISORS, LLC 16 PALM CT. 164 SPRINGDALE WAY MENLO PARK, CA REDWOOD CITY, CA FOR: CLEAN COALITION FOR: ALLIANCE FOR RETAIL ENERGY MARKETS (AREM / DIRECT ACCESS CUSTOMER COALITION (DACC CRAIG R. HORNE, PH.D CHRISTOPHER CLAY CHIEF STRATEGY OFFICER AND CO-FOUNDER CALIF PUBLIC UTILITIES COMMISSION ENERVAULT CORPORATION LEGAL DIVISION 1244 REAMWOOD AVENUE ROOM 4300 SUNNYVALE, CA VAN NESS AVENUE FOR: ENERVAULT CORPORATION SAN FRANCISCO, CA FOR: ORA ADAM GERZA HAYLEY GOODSON SULLIVAN SOLAR POWER OF CALIFORNIA, INC. STAFF ATTORNEY TH STREET THE UTILITY REFORM NETWORK SAN FRANCISCO, CA MARKET ST., STE FOR: SULLIVAN SOLAR POWER SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK (TURN NICOLE JOHNSON JAMES BIRKELUND REGULATORY ATTORNEY CLEAN TECH. LAW CONSUMER FEDERATION OF CALIFORNIA 548 MARKET STREET, SUITE NATOMA STREET, SUITE 200 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SMALL BUSINESS UTILITY ADVOCATES FOR: CONSUMER FEDERATIONN OF CALIFORNIA (SBUA (CFC MAX BAUMHEFNER LARISSA KOEHLER NATURAL RESOURCES DEFENSE COUNCIL ATTORNEY 111 SUTTER ST., 20TH FL. ENVIRONMENTAL DEFENSE FUND SAN FRANCISCO, CA MISSION STREET, 28TH FLOOR FOR: NATURAL RESOURCES DEFENSE COUNCIL SAN FRANCISCO, CA FOR: ENVIRONMENTAL DEFENSE FUND (EDF OLIVIA PARA SETH D. HILTON DAVIS WRIGHT TREMAINE, LLP ATTORNEY AT LAW 505 MONTGOMERY STREET, STE. 800 STOEL RIVES LLP SAN FRANCISCO, CA THREE EMBARCADERO CENTER, STE FOR: CALPINE CORPORATION SAN FRANCISCO, CA FOR: DUKE ENERGY WILLIAM ROSTOV JOSEPH M. KARP STAFF ATTORNEY ATTY AT LAW EARTHJUSTICE WINSTON & STRAWN LLP

12 CPUC - Service Lists - A Page 3 of 6 10/7/ CALIFORNIA ST., STE CALIFORNIA STREET SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SIERRA CLUB FOR: GRAPHITE ENERGY STORAGE PARTNERS, LLC EVELYN C. LEE TIM HENNESSY LAW DEPARTMENT PRESIDENT AND COO PACIFIC GAS AND ELECTRIC COMPANY IMERGY POWER SYSTEMS, INC. PO BOX WARM SPRINGS BLVD. SAN FRANCISCO, CA FREMONT, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: IMERGY POWER SYSTEMS, INC. TOM STEPIEN JOSEPH DESMOND CEO BRIGHTSOURCE ENERGY, INC. PRIMUS POWER 1999 HARRISON ST., STE TRUST WAY OAKLAND, CA HAYWARD, CA FOR: BRIGHTSOURCE ENERGY, INC. FOR: PRIMUS POWER LAWRENCE G. CHASET GREGORY MORRIS ATTORNEY DIRECTOR KEYES FOX & WIEDMAN LLP GREEN POWER INSTITUTE TH STREET, STE SHATTUCK AVENUE, STE 402 OAKLAND, CA BERKELEY, CA FOR: WORLD BUSINEE ACADEMY FOR: THE GREEN POWER INSTITUTE COLLEEN QUINN BILL WEAVER VP - GOV'T. RELATIONS AND PUBLIC POLICY CALIFORNIA ISO CHARGEPOINT, INC 250 OUTCROPPING WAY 1692 DELL AVENUE FOLSOM, CA CAMPBELL, CA FOR: CALIFORNIA INDEPENDENT SYSTEM FOR: CHARGEPOINT, INC. OPERATOR JORDAN PINJUV MARGARET MILLER CALIFORNIA ISO DIR - REGULATORY AFFAIRS 250 OUTCROPPING WAY BROOKFIELD ENERGY MARKETING FOLSOM, CA SAN MARCO PLACE FOR: CALIFORNIA INDEPENDENT SYSTEM EL DORADO HILLS, CA OPERATOR FOR: BROOKFIELD RENEWABLE ENERGY PARTNERS, L.P. MICHAEL BOCCADORO RUSSELL WEED AGRICULTURAL ENERGY CONSUMERS ASSN VP, BUS. DEVELOPMENT & GEN. COUNSEL 925 L STREET, STE. 800 UNIENERGY TECHNOLOGIES, LLC SACRAMENTO, CA HARBOUR POINTE BLVD, SW, STE. A FOR: AGRICULTURAL ENERGY CONSUMERS MUKILTEO, WA ASSOCIATION FOR: UNIENERGY TECHNOLOGIES, LLC Information Only ALICE HARRON BRAD HEAVNER HARRON LLC POLICY DIRECTOR CALIFORNIA SOLAR ENERGY INDUSTRIES ASSN, CA ONLY, CA CASE COORDINATION DIANE I. FELLMAN PACIFIC GAS AND ELECTRIC COMPANY VICE PRESIDENT NRG WEST REGION, CA 00000, CA ERIC CUTTER LYNN HAUG ENERGY AND ENVIRONMENTAL ECONOMICS ELLISON SCHNEIDER & HARRIS L.L.P. OINLY, CA 00000, CA 00000

13 CPUC - Service Lists - A Page 4 of 6 10/7/2014 MARC D. JOSEPH MARK HUFFMAN ADAMS BROADWELL JOSEPH & CARDOZO LAW DEPT PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA MATTHEW GONZALES MCE REGULATORY PACIFIC GAS AND ELECTRIC COMPANY MARIN CLEAN ENERGY, CA 00000, CA PATRICK FERGUSON RACHEL GOLD DAVIS WRIGHT TREMAINE, LLP POLICY DIRECTOR LARGE-SCALE SOLAR ASSOCIATION, CA 00000, CA TED KO UDI HELMAN COMPLETE SOCIETY CONSULTING HELMAN ANALYTICS, CA 00000, CA WADE A. GREENACRE DAVIS WRIGHT TREMAINE, LLP CASE MGR. PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA MRW & ASSOCIATES, LLC DOUGLAS DAVIE WELLHEAD ELECTRIC COMPANY, INC., CA 00000, CA KAREN TERRANOVA TAM HUNT ALCANTAR & KAHL COMMUNITY RENEWABLES SOLUTIONS, LLC, CA , CA PATRICK JOBIN CYNTHIA CHILDS CREDIT SUISSE SECURITIES (USA LLC CASE ADMINISTRATOR ONE MADISON AVENUE SOUTHERN CALIFORNIA EDISON COMPANY NEW YORK, NY PO BOX 800 ROSEMEA, CA KEITH W. MELVILLE MICHAEL BROWN SR. COUNSEL CLEANTECH LAW PARTNERS, PC SAN DIEGO GAS & ELECTRIC COMPANY 2932 WEST ORIOLE AVE. 101 ASH STREET, HQ 12 VISALIA, CA SAN DIEGO, CA FOR: SMALL BUSINESS UTILITY ADVOCATES KATHERINE MORSOHY MATTHEW VESPA ALCANTAR & KAHL, LLP SR. ATTORNEY 33 NEW MONTGOMERY STREET, STE SIERRA CLUB SAN FRANCISCO, CA SECOND ST,, 2ND FL SAN FRANCISCO, CA SHERIDAN J. PAUKER, ESQ. ADENIKE ADEYEYE REGULATORY COUNSEL EARTHJUSTICE WILSON SONSINI GOODRICH & ROSATI 50 CALIFORNIA ST., STE. 500 ONE MARKET PLAZA, SPEAR TOWER, STE 3300 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SIERRA CLUB ARTHUR HAUBENSTOCK DEVIN MCDONELL BINGHAM MCCUTCHEN, LLP BINGHAM MCCUTHCHEN 3 EMBARCADERO CENTER, 18TH FLOOR THREE EMBARCADERO CENTER SAN FRANCISCO, CA SAN FRANCISCO, CA MONICA A. SCHWEBS NICHOLAS BAIN BINGHAM MCCUTCHEN LLP DIRECTOR THREE EMBARCADERO CENTER GRAPHITE ENERGY STORAGE PARTNERS, LLC

14 CPUC - Service Lists - A Page 5 of 6 10/7/2014 SAN FRANCISCO, CA BATTERY ST., 26TH FL. SAN FRANCISCO, CA NOELLE R. FORMOSA ROSICELI VILLARREAL ATTORNEY EARTHJUSTICE WINSTON & STRAWN LLP 50 CALIFORNIA STREET, SUITE CALIFORNIA STREET SAN FRANCISCO, CA SAN FRANCISCO, CA JEFFREY GRAY CHARLES R. MIDDLEKAUFF ATTORNEY AT LAW PACIFIC GAS AND ELECTRIC COMPANY DAVIS WRIGHT TREMAINE 77 BEALE STREET, B30A 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALPINE CORPORATION REGULATORY FILE ROOM MEGAN M. MYERS PACIFIC GAS AND ELECTRIC COMPANY LAW OFFICES OF SARA STECK MYERS PO BOX TH AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA SARA STECK MYERS HILARY CORRIGAN ATTORNEY AT LAW CALIFORNIA ENERGY MARKETS TH AVENUE 425 DIVISADERO STREET, STE 303 SAN FRANCISCO, CA SAN FRANCISCO, CA LEAH LAVALLE ROWELL MATTHEW BARMACK CLARK STREET ASSOCIATES DIR. - CALPINE CORPORATON 228 HAMILTON AVENUE CALPINE CORPORATION PALO ALTO, CA DUBLIN BLVD., SUITE 100 DUBLIN, CA GREGORY BLUE JENNIFER L. WEBERSKI PRINCIPAL CONSULTANT GTB CONSULTING 49 TERRA BELLA DRIVE 3161 WALNUT BLVD WALNUT CREEK, CA WALNUT CREEK, CA FOR: ON BEHALF OF ENVIRONMENTAL DEFENSE FUND (EDF PAUL D. HERNANDEZ NANCY RADER ENERGY & TRANSPORTATION POLICY MANAGER EXECUTIVE DIRECTOR CENTER FOR SUSTAINABLE ENERGY CALIFORNIA WIND ENERGY ASSOCIATION TH STREET, SUITE NINTH STREET, STE. 213A OAKLAND, CA BERKELEY, CA PHILLIP MULLER JOHN NIMMONS PRESIDENT COUNSEL SCD ENERGY SOLUTIONS JOHN NIMMONS & ASSOCIATES, INC. 436 NOVA ALBION WAY 175 ELINOR AVE., STE. G SAN RAFAEL, CA MILL VALLEY, CA SARAH M. KEANE JENNIFER A. CHAMBERLIN BINGHAM MCCUTCHEN LLP DIR. REG AFFAIRS - INT. DEMAND RESOURCES 3 EMBARCADERO CENTER JOHNSON CONTROLS, INC. SAN FRANCISCO, CA CAMPISI WAY, SUITE 260 CAMPBELL, CA DOUG GRANDY BETH OLHASSO CALIFORNIA ONSITE GENERATION AGRICULTURAL ENERGY CONSUMERS ASSOC 1220 MACAULAY CIR. 925 L STREET, SUITE 800 CARMICHAEL, CA SACRAMENTO, CA JOHN SHEARS KEVIN WOODRUFF RENEWABLE TECHNOLOGIES WOODRUFF EXPERT SERVICES THE CENTER FOR ENERGY EFFICIENCY AND 1100 K STREET, SUITE TH ST., SUTE. 311 SACRAMENTO, CA SACRAMENTO, CA SCOTT BLAISING ANDREW B. BROWN ATTORNEY ATTORNEY AT LAW

15 CPUC - Service Lists - A Page 6 of 6 10/7/2014 BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. ELLISON SCHNEIDER & HARRIS LLP 915 L STREET, STE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA JEFFREY D. HARRIS BALDASSARO BILL DI CAPO ATTORNEY AT LAW DI CAPO LEGAL ADVISORS ELLISON & SCHNEIDER 777 CAMPUS COMMONS RD., STE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA ANN TROWBRIDGE SARAH ADAMS ATTORNEY BUSINESS DEVELOPMENT DAY CARTER & MURPHY LLP NW NATURAL 3620 AMERICAN RIVER DR., STE NW SECOND AVENUE SACRAMENTO, CA PORTLAND, OR FOR: AGRICULTURAL ENERGY CONSUMERS ASSOCIATION (AECA State Service ALOKE GUPTA CHRISTOPHER MYERS CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION OFFICE OF RATEPAYER ADVOCATES, CA 00000, CA MONICA TESTA ARTHUR J. O'DONNELL GRADUATE ASSISTANT CALIF PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B ROOM 4-A, CA VAN NESS AVENUE SAN FRANCISCO, CA CHRISTOPHER MYERS COLETTE KERSTEN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH EXECUTIVE DIVISION ROOM 4104 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FARZAD GHAZZAGH ZHEN ZHANG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH EXECUTIVE DIVISION ROOM 4102 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JOHN MATHIAS CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET SACRAMENTO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS