May 19, 2017 Advice Letters 5020-E and 5020-E-A

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1 STATE OF CALIFORNIA PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA EDMUND G. BROWN JR., Governor May 19, 2017 Advice Letters 5020-E and 5020-E-A Erik Jacobson Director, Regulatory Relations Pacific Gas and Electric Company 77 Beale Street, Mail Code B10C San Francisco, CA SUBJECT: Summary of the Approved Electric Vehicle Infrastructure and Education Program and Details of the Rate Options to Site Hosts Pursuant to Decision Dear Mr. Jacobson: Summary Energy Division has determined that Pacific Gas and Electric s (PG&E) Advice Letters (ALs) 5020-E and 5020-E-A are consistent with Decision (D.) Accordingly, Advice Letter (AL) 5020-E and AL 5020-E-A are effective February 13, Background On December 21, 2016, the California Public Utilities Commission issued Decision approving a program that modifies a proposal from PG&E to deploy light-duty, electric vehicle (EV) charging infrastructure and conduct associated education and outreach. 1 PG&E is authorized to recover through rates up to $130 million in costs associated with the approved program, which can support up to 7,500 level 2 (~220 volt) EV charging points in workplaces, disadvantaged communities and multi-unit dwellings. The decision provides for PG&E to own up to 35 percent (2,625) of the total charging points installed. PG&E will install, own and operate the make-ready infrastructure for all of the EV charging points, but it will only be able to also own and operate the EV service equipment (EVSE) at sites that are at multi-unit dwellings (MUDs) and/or located in disadvantaged communities (DACs). The utility cannot own the charging equipment at workplaces that are located outside of disadvantaged communities, and must give all site hosts the opportunity to own the charging stations. 2 D sets a target for PG&E to deploy at least 20 percent (with a stretch goal of 50 percent) of the charging infrastructure to serve MUDs, 3 and at least 15 percent (with a stretch goal of 20 percent) in DACs. 4 1 D is available at 2 D , Ordering Paragraph 1 3 D , pg D , pg. 78

2 Erik Jacobson May 19, 2017 Page 2 Where PG&E owns the charging stations, site hosts must pay a participation payment; where the site host owns the charging stations, PG&E must provide a rebate. 5 PG&E is required to conduct a request for proposal process to establish a base cost for level 2 EVSE to calculate the rebates and participation payments, based on the lowest-cost EVSE model qualified through a request for proposal process. Both the participation payments and the rebates are tiered based on customer type: PG&E Participation Payment Site Host Type Participation Payment Rebate MUD in DAC Selected EVSE cost less Base Cost 100% * Base Cost MUD outside of DAC 50% * Base Cost plus difference of selected and Base Cost 50% * Base Cost Workplace in DAC 50% * Base Cost plus difference of selected and Base Cost 50% * Base Cost Workplace outside of DAC N/A 25% * Base Cost PG&E must qualify vendors and models of EVSE through a rolling qualification process, update its list of qualified vendors at least quarterly, and make that list available to all site hosts. Site hosts that choose to own their EVSE must choose from the list of qualified vendors and models. Site hosts will be able to choose between two time-of-use (TOU) rates. Under the TOU rate-todriver option, PG&E serves electricity to the site host or its service provider, who passes the TOU price signals directly to the EV drivers charging at the stations. The TOU rate-to-host option would send TOU price signals to the hosts, which would be able to propose alternative pricing and load management tactics. PG&E is required to select operations and maintenance vendors through an RFP process, in conjunction with its PAC, and must cover the operations and maintenance costs for all sites where the utility owns the EVSE. 6 The decision directs PG&E to establish a Program Advisory Council (PAC) to provide guidance and feedback as the utility implements its EV program. The PAC is to include representatives from local and state governments, industry, labor and other stakeholders, and ratepayer and environmental advocates. The PAC will advise PG&E on the criteria necessary for load management plans, but PG&E is ultimately responsible for approving a site host s load management plan. Non-market participants of the PAC will provide guidance on PG&E s procurement of EV charging stations for the sites where the utility owns the charging equipment. 7 PG&E must file quarterly progress reports with the CPUC and the PAC, and serve those reports to all parties participating in relevant proceedings. These quarterly reports are to provide updates on all aspects of program implementation, including costs, site selection and progress on vendor 5 D , Ordering Paragraphs 1, D , Ordering Paragraphs D , Ordering Paragraphs 2, 6, 16, 17, and 20

3 Erik Jacobson May 19, 2017 Page 3 qualification. 8 In addition to these quarterly reports, PG&E is required to collect and report data and metrics as set forth in Appendix B to the Settlement filed on March 21, Pursuant to Ordering Paragraph 19 of D , PG&E filed Advice Letter 5020-E to summarize the approved program described above and detail the two TOU rate options that will be provided to site hosts under the program. 10 Protest and Reply On March 6, 2017, ChargePoint submitted a protest to PG&E Advice Letter 5020-E. In its protest, ChargePoint argued that PG&E s summary included language that does not reflect the approved program, is not appropriate for a program summary, or lacks clarity. Many of ChargePoint s proposed changes request the utility to clarify ambiguous language to better reflect what was included in D PAC non-market members advisory review and confidentiality ChargePoint protests PG&E s intent to limit its consultation regarding setting the EVSE base cost to non-market participants of its PAC. ChargePoint also raised concerns about the information that PG&E may share with the non-market participant members of its PAC, and asked the commission to ensure confidential information submitted by market participants is adequately protected in PG&E s RFP process. Utility EVSE procurement ChargePoint protested PG&E s proposed Section 11 establishing the RFP process PG&E will use to qualify vendors and EVSE models and suggested modified language. It particularly opposed PG&E s intent to conduct a one-time RFP to select the vendors and EVSE models PG&E will procure to install at sites where it will own and operate the EVSE. On March 13, 2017, PG&E responded to ChargePoint s protest and largely accepted the proposed edits therein. PAC non-market members advisory review and confidentiality PG&E states that D largely adopted its PAC proposal, with only four modifications, none of which address the limitation that only non-market participants will be consulted on the process of setting the EVSE base cost. It agrees with ChargePoint that all necessary steps must be taken to ensure confidential, competitively sensitive information and trade secrets are not directly or inadvertently disclosed and states that this underscores its intention to only discuss the RFP process with non-market participant members of the PAC. Utility EVSE procurement response PG&E did not accept ChargePoint s proposal to have the utility conduct quarterly or more frequent procurement of EVSE for the sites at which PG&E will own the EVSE. While D modified the process for qualifying eligible vendors and EVSE models available to site hosts selecting their own EVSE, it did not directly address the process through which PG&E would procure the EVSE it will own and operate at sites that choose to have the utility be the 8 D , Ordering Paragraph 20 9 D , Ordering Paragraph 22, Settlement Appendix B available at 10 D , Ordering Paragraph 19

4 Erik Jacobson May 19, 2017 Page 4 EVSE owner. PG&E states that it would be administratively burdensome and costly to conduct quarterly RFPs for equipment it will procure. Instead it intends to conduct a single RFP through which it will enter contracts with multiple third parties for multiple EVSE operating systems, network services, associated hardware and operations and maintenance services. Sites where hosts choose to have PG&E own the EVSE will be able to select their equipment from the vendors that PG&E contracts with through the RFP. Supplemental Advice Letter 5020-E-A On April 14, 2017, PG&E filed a supplemental Advice Letter 5020-E-A, to modify Advice Letter 5020-E to incorporate the clarification and editorial changes ChargePoint had requested. In response to ChargePoint s protest regarding its procurement of EVSE, PG&E still intends to conduct a one-time RFP to procure the EVSE and associated services and software to install at sites where it will be the EVSE owner and operator. PG&E added that it may conduct an additional RFP if consultation with the PAC and Energy Division staff reveals that significant cost savings or technological improvements could be achieved through a new round of procurement. Protest of Advice Letter 5020-E-A On May 4, 2017, ChargePoint filed a protest to PG&E s supplemental Advice Letter 5020-E-A, again contesting PG&E s intent to conduct a one-time RFP process for the EVSE and associated systems and services to be installed at sites where the utility will own and operate the EVSE. PG&E has elected not to respond to ChargePoint s protest. Discussion Energy Division notes that these Tier 1 advice letters are not intended to be an opportunity to reopen issues that were decided in D , but instead intended to serve as a summary of the program approved in that decision. Utility Procurement of EVSE D requires PG&E to conduct a rolling qualification process for vendors and EVSE models for site hosts that choose to own their equipment, and directs the utility to update its list of qualified vendors at least quarterly. The decision does not directly address how PG&E will procure the EVSE for sites where it will own and operate the equipment. Utility procurement processes are administratively time consuming and can be costly for the utility, and participating in multiple utility procurement RFPs for a three-year, limited budget pilot program is not the best use of stakeholders time and finances. PG&E will select multiple vendors to contract with through its RFP, so site hosts will still have choices on EVSE model and associated services even in cases where the utility owns and operates the EVSE. Site hosts that seek a larger variety of EVSE make or vendor to choose from can elect to own the equipment themselves and receive a rebate from the utility for most of the cost of the equipment. If the technology for EVSE progresses, or if the cost of EVSE decreases, significantly over the three-year period of the pilot program, PG&E may be directed by the PAC and the Energy Division to conduct another RFP to ensure it is installing the best available technology at sites where the utility owns the EVSE.

5 Erik Jacobson May 19, 2017 Page 5 PAC non-market members advisory review and confidentiality D also approved PG&E s proposal for a PAC with only four modifications, none of which addressed the proposal to make PG&E s procurement of EV charging equipment and services to be subject to advisory review by non-market participants of the PAC. 11 Therefore, review of PG&E s procurement of EV charging equipment and services by non-market participants is authorized by D , and this issue will not be revisited through this advice letter. Disposition Energy Division approves Advice Letters 5020-E and 5020-E-A. Sincerely, Edward Randolph Director, Energy Division cc: ChargePoint 11 D , pgs

6 Erik Jacobson Director Regulatory Relations Pacific Gas and Electric Company 77 Beale St., Mail Code B10C P.O. Box San Francisco, CA Fax: April 14, 2017 Advice 5020-E-A (Pacific Gas and Electric Company ID U 39 E) Public Utilities Commission of the State of California Subject: Supplemental: Summary of the Approved Electric Vehicle Infrastructure and Education Program and Details of the Rate Options to Site Hosts Pursuant to Decision Purpose Pacific Gas and Electric Company (PG&E) submits this supplemental advice letter to modify Advice Letter 5020-E, dated February 13, 2017 with the modifications described below. Background On February 13, 2017, PG&E filed Advice Letter 5020-E to summarize its approved Electric Vehicle Infrastructure Program (Charge Smart and Save Program) incorporating modifications as approved by Decision (D.) and provide details on the rate options to site hosts under the program established by the D (the Decision). On March 6, 2017, ChargePoint submitted a Protest of Advice Letter 5020-E. PG&E responded to ChargePoint s protest on March 13, PG&E hereby submits its Supplement to Advice Letter 5020-E with modifications to its original advice letter. Summary of Modifications to Advice 5020-E Section 2. Guiding Principles PG&E modifies Section 2 to remove the strikethrough text below: Charge Smart and Save implementation will be guided by the Guiding Principles provided in Section 2 of the Settlement Agreement. which are comparable to those approved for the San Diego Gas & Electric Company and Southern California Edison Phase 1 programs.

7 Advice 5020-E-A April 14, 2017 Section 3. Definitions PG&E modifies Section 3 to include the underlined text and remove the strikethrough text below: Charge Smart and Save implementation will use the definitions used in Section 3 of the Settlement Agreement, to the extent that they are relevant to the program as approved in Decision which are comparable to those used for the San Diego Gas & Electric Company and Southern California Edison Phase 1 programs. Section 5. Number of Level 2 and DCFC Charging Stations PG&E modifies Section 5 to include the underlined text and remove the strikethrough text below: Charge Smart and Save will aim to deploy infrastructure to support up to 7,500 Electric Vehicle Level 2 charging ports. including PG&E may ownership of up to 35 percent of total EVSE ports projected to be installed through the pilot. Section 6. Fuel Savings, Load Management, & Renewables Integration PG&E modifies Section 6 to remove the strikethrough text below: The Decision provides that the site host will be PG&E s customer of record in all instances. Pricing for EV drivers at each site will be determined by the site host using load management strategies in PG&E s Rate-to-Driver or Rate-to-Host pricing options. Site hosts can select to participate in the default Rate-to-Driver option, in which the site host utilizes time-of-use (TOU) price signals as a load management tactic, or the Rate-to-Host option, in which the site host determines alternative pricing for EV drivers and develops its own load management plan. PG&E will consult with the Program Advisory Council to develop guidelines for appropriate load management plans for site hosts that choose the Rate-to-Host option. Additional details on the rate options are provided below in the Rate Options section of this Advice Letter. Section 7. Site Selection Criteria PG&E modifies Section 7 to include the underlined text and remove the strikethrough text below: The Decision provides for baseline site selection criteria, as listed below. PG&E will work with the Program Advisory Council to finalize the site selection criteria consistent with the Decision: Date of indicated interest (first-in-line priority); Current and expected volume of EV drivers; Number of charging stations desired; Segment (MUD, workplace, disadvantaged community); Nearby transformer available capacity; Distance between transformer and new service point;

8 Advice 5020-E-A April 14, 2017 Site conditions related to construction feasibility (i.e., trenching surface, EVSE mounting surface, condition of facility); Land and property ownership; If leasing, term and conditions of lease; Existing/available Americans with Disabilities Act accessible parking and compliance; Distribution Resources Plan Integration Capacity Analysis; and Identified sites that not only meet the CalEnviroScreen definition of Disadvantaged, but also meet the spirit of the definition. PG&E should identify sites that not only meet the latest version of the CalEnviroScreen definition of disadvantaged, but are also in the spirit of the definition. Section 11. Competitive Pre-Qualification of Equipment and Service Providers PG&E modifies Section 11 to include the underlined text and remove the strikethrough text below: PG&E will contract with qualify third parties to provide EVSE operating systems, network services, related hardware, and operations and maintenance (O&M) to implement Charge Smart and Save. The Decision directs PG&E to qualify vendors and EVSE models through a quarterly Request for Qualification (RFQ) process that will remain open on a rolling basis, with qualification completed at least quarterly. PG&E will not restrict the number of vendors or models that may be qualified through this process. PG&E will and make a list of qualified vendors and models available to all site hosts. For the charging stations that will be owned by PG&E, there will be a one-time Request for Proposal (RFP) process consistent with Appendix C of the Settlement Agreement to select the PG&E-owned equipment. For the RFP and RFQ processes, it is PG&E s aim to specify what is required to be achieved per the objectives of Charge Smart and Save, and not how these requirements are met. This approach is intended to leverage the EVSP market expertise and foster innovation. PG&E will incorporate any lessons learned to date from the SDG&E Power Your Drive pilot or the SCE Charge Ready pilot. PG&E s procurement of EV charging equipment shall be subject to advisory review by plans to work in conjunction with the non-market participants of the PAC in the procurement process. PG&E may hold an additional RFP for PG&E owned equipment if, through consultation with the PAC and Energy Division, it appears there could be significant cost savings or technologically improved equipment available. The price of the lowest qualified EVSE bid selected through the RFQ process will be the base cost used to determine participation payment and rebate amounts. Rate Options PG&E modifies the Rate Options section to include the underlined text and remove the strikethrough text below:

9 Advice 5020-E-A April 14, 2017 Pursuant to OP 19 of D , PG&E provides additional details on the rate options that will be available for site hosts. PG&E will serve electricity to site hosts, who will be PG&E s customer of record in all instances on either Schedule A-6 (if less than 75 kilowatts) or Schedule A-10, which are commercial, TOU rates. Site hosts will pay each monthly bill to PG&E, and the electric vehicle service provider (EVSP) will collect payment from EV drivers for the site host. Pricing at each site will be determined by the site host using TOU price signals or other load management strategies. Site hosts can select to participate in the default Rate-to- Driver option, in which the site host utilizes TOU price signals as a load management tactic, or the Rate-to-Host option, in which the site host determines alternative pricing for EV drivers and develops its own load management plan consistent with the program Guiding Principles adopted by the Commission in D as described in Section 2 of the Settlement Agreement. PG&E will work with the PAC to develop guidelines for appropriate load management plans for site hosts that choose the Rateto-Host option. In the event that ownership or control of a site changes, the new site host shall have the option to select its own billing (Rate-to-Driver or Rate-to-Host) and rate plan. Under the default Rate-to-Driver option, PG&E s TOU price signals will serve as a load management plan that has already been approved by PG&E. PG&E will serve electricity to site hosts, who will then pass the TOU energy rate directly to EV drivers. The use of TOU price signals will encourage charging when there is spare capacity in the grid and provide the opportunity to realize fuel savings relative to gasoline. In order to recover any additional charges associated with the TOU rate schedule, the site host will have the option to include a Rate Adder with the energy price per kilowatt-hour (kwh) passed on to EV drivers. The Adder should represent the non-energy additional charges associated with the applicable rate (i.e. the customer charge for Schedule A-6, or the customer charge and the demand charge for Schedule A-10) converted into a volumetric price per kwh by distributing the charges among all EV charging projected for the given billing period. If a site host decides to use an Adder to recover the additional charges on their rate schedule, then EV drivers will pay the applicable TOU price per kwh for their energy use, plus the Adder (an additional price per kwh) to cover their contribution to the site host rate schedule s non-energy charges. PG&E will provide a tool that site hosts can use as a guideline for estimating the appropriate Adder as a price per kwh based on the projected utilization of the chargers at that site. An example of the information used in the tool is provided in Attachment B. It is the responsibility of the site host to recalculate the Adder periodically to ensure the additional charges associated with the applicable rate are not over or under collected. Usage patterns and site host determined fees will be tracked and used to inform Commission policy. Alternatively, site hosts in the Rate-to-Driver option do not have to

10 Advice 5020-E-A April 14, 2017 pass on the non-energy charges to drivers with an Adder and can instead cover these costs themselves. If a site host does not select the Rate-to-Driver option, the site host will develop alternative pricing for its charging stations using other load management strategies in the Rate-to-Host option. Consistent with D , where the site host selects the Rate-to-Host pricing plan, the site host will be required to submit to PG&E the load management tactics it will implement at its charging stations, including the prices or fees that it intends to levy on EV drivers, and any communication methods to be used to implement the load management tactics. Site hosts that do not submit load management plans consistent with the Guiding Principles and guidelines established by PG&E in consultation with the PAC, will be asked by PG&E to revise accordingly and will be ineligible to participate in the program until PG&E determines that the load management plan is consistent with the Guiding Principles. Load management tactics may include, but are not limited to, charging curtailment during peak system usage, communications with drivers to voluntarily avoid or limit charging during peak system usage, or integration with other demand-management technologies (such as stationary energy storage). PG&E expects this will foster innovative approaches by site hosts and service providers to develop and propose load management plans under the Rate-to-Host option. Participation in the Rate-to-Host option will not be unreasonably withheld. As with site hosts that opt for the Rate-to-Driver pricing plan, site usage patterns will be monitored and site host determined prices or fees will be tracked and reported. These data will be used to inform Commission policy and will be available to the Commission to resolve any customer complaints regarding the pricing. Program network and equipment solicitation requirements will include system load management capability. EV load management will focus on facilitating the integration of variable renewables and supporting the electric distribution system. Tier Designation Pursuant to Ordering Paragraph 19 of D , this advice filing is submitted with a Tier 1 designation as designated in original Advice 5020-E. The filing would not increase any current rate or charge, cause the withdrawal of service, or conflict with any rate schedule or rule. Effective Date This tier 1 advice letter will become effective concurrent with original Advice 5020-E, which was filed on February 13, 2017.

11 Advice 5020-E-A April 14, 2017 Protests Pursuant to CPUC General Order 96-B, Section 7.5.1, PG&E hereby requests the protest period be waived. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service list for A Address changes to the General Order 96-B service list should be directed to PG&E at address PGETariffs@pge.com. For changes to any other service list, please contact the Commission s Process Office at (415) or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter filings can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations cc: Service List A

12 CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/cpuc Utility No. Pacific Gas and Electric Company (ID U39 E) Utility type: Contact Person: Annie Ho ELC GAS Phone #: (415) PLC HEAT WATER and EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water (Date Filed/ Received Stamp by CPUC) Advice Letter (AL) #: 5020-E-A Tier: 1 Subject of AL: Supplemental: Summary of the Approved Electric Vehicle Infrastructure and Education Program and Details of the Rate Options to Site Hosts Pursuant to Decision Keywords (choose from CPUC listing): Compliance, Agreements AL filing type: Monthly Quarterly Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: D Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: Is AL requesting confidential treatment? If so, what information is the utility seeking confidential treatment for: No Confidential information will be made available to those who have executed a nondisclosure agreement: N/A Name(s) and contact information of the person(s) who will provide the nondisclosure agreement and access to the confidential information: Resolution Required? Yes No Requested effective date: February 13, 2017 Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A No. of tariff sheets: N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed: N/A Pending advice letters that revise the same tariff sheets: N/A Pursuant to CPUC General Order 96-B, Section 7.5.1, PG&E hereby requests the protest period be waived. California Public Utilities Commission Energy Division EDTariffUnit 505 Van Ness Ave., 4 th Flr. San Francisco, CA EDTariffUnit@cpuc.ca.gov Pacific Gas and Electric Company Attn: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson 77 Beale Street, Mail Code B10C P.O. Box San Francisco, CA PGETariffs@pge.com

13 PG&E Gas and Electric Advice Filing List AT&T Don Pickett & Associates, Inc. OnGrid Solar Albion Power Company Douglass & Liddell Pacific Gas and Electric Company Alcantar & Kahl LLP Downey & Brand Praxair Anderson & Poole Ellison Schneider & Harris LLP Regulatory & Cogeneration Service, Inc. Atlas ReFuel Evaluation + Strategy for Social SCD Energy Solutions Innovation BART G. A. Krause & Assoc. SCE Barkovich & Yap, Inc. GenOn Energy Inc. SDG&E and SoCalGas Bartle Wells Associates GenOn Energy, Inc. SPURR Braun Blaising McLaughlin & Smith, P.C. Goodin, MacBride, Squeri, Schlotz & San Francisco Water Power and Sewer Ritchie Braun Blaising McLaughlin, P.C. Green Charge Networks Seattle City Light CENERGY POWER Green Power Institute Sempra Energy (Socal Gas) CPUC Hanna & Morton Sempra Utilities California Cotton Ginners & Growers Assn ICF SoCalGas California Energy Commission International Power Technology Southern California Edison Company California Public Utilities Commission Intestate Gas Services, Inc. Southern California Gas Company (SoCalGas) California State Association of Counties Kelly Group Spark Energy Calpine Ken Bohn Consulting Sun Light & Power Casner, Steve Leviton Manufacturing Co., Inc. Sunshine Design Center for Biological Diversity Linde Tecogen, Inc. City of Palo Alto Los Angeles County Integrated Waste TerraVerde Renewable Partners Management Task Force City of San Jose Los Angeles Dept of Water & Power TerraVerde Renewable Partners, LLC Clean Power MRW & Associates Tiger Natural Gas, Inc. Clean Power Research Manatt Phelps Phillips TransCanada Coast Economic Consulting Marin Energy Authority Troutman Sanders LLP Commercial Energy McKenna Long & Aldridge LLP Utility Cost Management Cool Earth Solar, Inc. McKenzie & Associates Utility Power Solutions County of Tehama - Department of Public Modesto Irrigation District Utility Specialists Works Crossborder Energy Morgan Stanley Verizon Crown Road Energy, LLC NLine Energy, Inc. Water and Energy Consulting Davis Wright Tremaine LLP NRG Solar Wellhead Electric Company Day Carter Murphy Nexant, Inc. Western Manufactured Housing Communities Association (WMA) Defense Energy Support Center ORA YEP Energy Dept of General Services Office of Ratepayer Advocates Yelp Energy Division of Ratepayer Advocates Office of Ratepayer Advocates, Electricity Planning and Policy B