BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Assess Peak Electricity Usage Patterns and Consider Appropriate Time Periods for Future Time-of-Use Rates and Energy Resource Contract Payments. Rulemaking (Filed December 17, 2015) JOINT RESPONSE OF SAN DIEGO GAS AND ELECTRIC COMPANY (U 902 M), SOUTHERN CALIFORNIA EDISON (U 338 E), AND PACIFIC GAS AND ELECTRIC COMPANY (U 39 E) TO PETITION TO MODIFY D RANDALL J. LITTENEKER GAIL L. SLOCUM Pacific Gas and Electric Company 77 Beale Street, B30A San Francisco, CA Telephone: (415) Facsimile: (415) Attorneys for PACIFIC GAS AND ELECTRIC COMPANY FADIA RAFEEDIE KHOURY R. OLIVIA SAMAD Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA Telephone: (626) Facsimile: (626) Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY JOHN A. PACHECO San Diego Gas & Electric Company 8330 Century Park Court San Diego, CA Telephone: (858) Facsimile: (619) Attorneys for SAN DIEGO GAS & ELECTRIC COMPANY Dated: April 3, 2017

2 TABLE OF CONTENTS Page I. INTRODUCTION... 1 II. DISCUSSION... 3 A. The Decision Correctly Concluded that the Shifts in TOU Periods Are Bounded And A Range Of Outcomes Is Known; Indeed SEIA Itself Already Agreed To Move The Peak Period To 4-9 pm... 3 B. If the PTM Were Granted It Would Have Significant Impact On The Grid And Potentially Have A Large Amount Of Load On The Wrong Hours... 6 C. Granting The PTM Would Adversely Affect The Development of the Energy Storage Market... 8 D. Granting The PTM Would Undermine The State s Goals To Reduce GHG Emissions Because Customers On Non-Economic Price Signals Will Be Less Likely To Shift Their Load... 9 E. Claims of A Market Collapse Are Unsupported III. CONCLUSION i -

3 I. INTRODUCTION Pursuant to Rule 16.4, San Diego Gas & Electric Company (SDG&E), Southern California Edison Company (SCE) and Pacific Gas and Electric Company (PG&E), referred to collectively as the Joint Utilities, file this Response to the Petition For Modification of Decision (D.) , which was filed by the Solar Energy Industries Association (SEIA) and the California Solar Energy Industries Association (CalSIEA) on March 2, 2017 (Petition or PTM). 1 Decision (the Decision) adopted Guidelines to Assess Time Period for Future Time of Use (TOU) Rates. It included provisions permitting certain customers with existing on-site solar systems to stay on old, outdated TOU periods ( legacy TOU rates ) for five years for residential customers, or ten years for non-residential customers. In addition, D allowed certain customers in the process of installing solar to similarly qualify to remain on legacy TOU period hours if their systems are brought on line during a grace period for eligibility. 2 To be eligible, the projects must be a solar system for which (i) an initial interconnection application was submitted no later than January 31, 2017 and (ii) the interconnection applications, including final building inspection, are completed prior to the Grace Period End Date. The Eligibility Grace Period End Date for Schools is December 31, 2017, and for all other customers is July 31, The PTM seeks to extend the eligibility for grandfathering outdated TOU period by several years. It argues that until the new TOU periods are determined (which for PG&E and SCE may take over a year), solar providers are unable to define reliably the economic value of planned solar projects, claiming: The Decision creates a significant gap between when customers are eligible for grandfathering on the current periods and when new periods are expected in the aforementioned rate cases. 4 Accordingly, the Petition seeks to extend the 1 Under Commission Rules of Practice and Procedure, Rule 1, SDG&E and SCE have authorized to PG&E file this Joint Response on their behalf. 2 D , p. 50, and fn D , p. 63; see also D , correcting errors in D Petition at p

4 eligibility for grandfathering to all projects that submit the necessary documentation for interconnection within six months to one year after the final decision for each Utility approving the new TOU periods, potentially extending grandfathering eligibility by two years or more. This Petition should be rejected for the following reasons: The Decision correctly concluded that TOU period shifts and rate outcomes are bounded and a range of outcomes is known; SEIA itself agreed, in A , to move the peak period for PG&E residential customers to 4-9 p.m. If the PTM were granted, it would significantly increase the amount of customer load on the wrong hours for many more years. The PTM is a re-argument of the issue of a longer grandfathering grace period, that the Decision already expressly considered and rejected. The California Independent System Operator (CAISO) opposed a longer grace period because it would hamper its goal of reducing loads in the true high-cost periods. Charging TOU customers rates under inappropriate peak periods would also lead to higher costs and rates for all customers, than if customers were on TOU rates with appropriate hours. Granting the PTM would adversely affect the development of the energy storage market. Granting the PTM would undermine the state s goals to reduce GHG emissions because customers on rates with the wrong TOU periods will continue to see a price signal that incentivizes them to use more during the now high-cost (and high-emission) early evening hours. 5 Claims of a market collapse are unsupported. 5 For example, PG&E s non-residential legacy TOU rates have a peak period that currently ends at 6 p.m., precisely at the time when costs and marginal GHG emissions are high and getting higher

5 II. DISCUSSION A. The Decision Correctly Concluded that the Shifts in TOU Periods Are Bounded And A Range Of Outcomes Is Known; Indeed SEIA Itself Already Agreed To Move The Peak Period To 4-9 pm SEIA and CalSEIA argue that solar providers are unable to define reliably the economic value of these planned solar projects. 6 They further state that customers can only speculate as to the periods under which they will ultimately receive service. 7 But the Decision considered and rejected this very argument. It stated: Today, customers should be aware of the reality of changing rate designs and TOU periods. All three utilities have made changes to TOU periods and rate designs in recent years. Proposals to significantly change TOU periods date back to at least 2013 with the filing of SCE s RDW. Although it is clear that customer education and awareness campaigns must be expanded, we believe that at this time there is sufficient information available about changing rates for customers to consider these changes when making investment decisions. 8 The PTM argues that [w]hile the IOUs have proposed TOU period changes in their rate case filings, other parties have (or will) make alternative proposals. There is no way for solar providers to handicap for customers the odds of one proposal being adopted over another. 9 This is simply not true. SEIA itself signed a Settlement in PG&E s 2015 Rate Design Window (RDW) case during the summer of 2015, which provided for a change in residential peak periods to 4 to 9 p.m. 10 That Settlement was adopted by the CPUC in late 2015 by Decision Subsequently, the CAISO in this TOU Periods OIR proceeding presented data supporting a 4 to 9 p.m. peak, and noting that, for PG&E s system the peak hours are about one hour later. Thus, 6 Petition p Petition p D p Petition p The all-party settlement agreement that was signed by SEIA in PG&E s 2015 RDW (A ) is attached to D as Appendix A. Schedule E-TOU-B adopted by the Commission has 4-9 p.m. peak hours. Schedule E-TOU-A starts with 3-8 p.m. peak hours, but only through Beginning January 1, 2020, Schedule E-TOU-A will have 4-9 p.m. peak hours identical to Schedule E-TOU-B

6 the solar parties have a very good idea where peak hours are heading, since they have already, themselves, agreed to evening peak hours. Solar parties also argue that new hours have been proposed in other cases, and that competing alternatives are also pending. While it is correct that there are competing proposals, the range of possible outcomes is nevertheless quite limited, and there is no doubt that the peak period hours will be moving to the late afternoon and evening hours. For example, in PG&E s 2017 GRC Phase 2 case, PG&E has proposed that the current noon-6 p.m. peak hours on its nonresidential TOU rate schedules move to 5 to10 p.m. SEIA itself has argued for later 3-8 p.m. peak hours. 11 Similarly, the range of proposed TOU time period changes are bounded and known now in the SCE and SDG&E rate cases. 12 Moreover, one thing is perfectly clear: the new peak period will be significantly different from the current hours of noon-6 p.m. The Commission was exactly right when it concluded that there is sufficient information available about changing rates for customers to consider these changes when making investment decisions. 13 To address this alleged uncertainty, solar providers in PG&E s service territory can give their prospective non-residential customers a cost-benefit analysis using PG&E s proposed rates and TOU periods (5 10 p.m. peak and 4-month summer). 14 If the project makes financial 11 See Testimony of Tom Beach on behalf of SEIA served March 15, 2017 in Application CalSEIA s witnesses served testimony arguing that a menu of TOU rate options should be developed and should include one with a 2 to 7 p.m. summer peak period and one with a peak period closer to what PG&E has proposed. Prepared Testimony of Tom Williard and Nick Soleil on behalf of CalSEIA, March 15, 2017, p SCE filed Application (A.) , Application of Southern California Edison Company (U 338-E) for Approval of its 2016 Rate Design Window Proposals, on September 1, 2016 in which it proposed revised TOU periods for non-residential customers (i.e., 4-9 p.m. summer on-peak). Similarly, SDG&E proposed updated TOU periods for all time variant rates in its General Rate Case Phase 2 application, A , which is presently awaiting the issuance of a draft decision. 13 D , p Solar providers can do the same for the proposed TOU rates filed in SCE s 2016 RDW application

7 sense using these parameters customers can comfortably proceed. 15 Solar providers can also give their prospective customers a cost-benefit analysis using SEIA s or CalSEIA s proposed TOU periods and rates. If the project makes financial sense using these parameters, customers can decide to proceed or not to proceed, but they will have been informed of the risk. Thus, customers will have made an informed decision. PG&E is happy to provide updated rates for its proposed TOU periods to other interested parties, who can do bill impact calculations under a range of possible outcomes. While there may be some customer uncertainty as to the exact hour and rate outcome, this has always been the case, since rates do change from time to time. In the context of proposals for new hours at the CPUC, the industry has known about TOU peak periods shifting later since 2013 for SCE, and since 2014 for both PG&E and SDG&E, when both filed their RDWs, and one likely outcome has been clear since PG&E s 2015 RDW Settlement was approved by the Commission. Moreover, solar companies have had clear signals for many years now that the TOU periods were changing. The changing net load curve, termed the duck curve by the CAISO and its likely effect on the TOU periods, has been known as far back as 2013, and has been an issue in many rate and regulatory cases since then. The Joint Utilities urge the Commission to reject the SEIA/CalSEIA request to adopt a ten year grandfathering for future solar customers. Rather, the Commission should uphold as reasonable its prior Decision s grace period provisions. The policy decision to keep the number of systems eligible to be on the wrong TOU periods limited and narrowly tailored 16 was correct, as this protects all other customers from needlessly higher rates due to higher generation costs and artificially high generation credits, as further discussed below. 15 In December 2016, SCE specifically responded to a data request from CalSEIA in which illustrative rates under the new TOU periods were provided for Option R on Schedules TOU-GS-2, TOU-GS-3 and TOU-8 (secondary). PG&E has also responded to detailed data requests related to these various rate proposals. 16 D , p

8 B. If the PTM Were Granted It Would Have Significant Impact On The Grid And Potentially Have A Large Amount Of Load On The Wrong Hours The Decision correctly sought to reduce the amount of load grandfathered on outdated TOU periods by implementing a near-term eligibility cutoff and limited the grandfathering provision to existing customers. As the Commission explained: We are not persuaded that grandfathering of TOU periods is an appropriate long-term mitigation measure to reduce the negative impacts that solar and other investors in DERs may face. Unreasonably long grandfathering prolongs the period during which such customers receive less accurate, and less cost-based, TOU pricing signals. As a result, the intended goals of setting more accurate TOU pricing signals will not be achieved. 17 Granting the PTM would guarantee (for PG&E and SCE) about two years of additional time for customers to be granted access to decade-long out of date and inaccurate TOU periods. The high potential for a continued gold rush of interconnections in this period makes estimating the scope of load that would be grandfathered highly uncertain. However, if recent adoption patterns continue over that time frame, the PG&E load remaining on outdated TOU periods in 2019 would increase from about 2,230 GWh to 2,650 GWh. If during the longer, 2-year plus grace period the PTM would allow for PG&E, there were a gold rush in which adoption were doubled, 18 the grandfathered load for PG&E would be about 3,100 GWh. 19 All 17 D , p PG&E believes this assumed doubling of the typical rate of applications due to extended grandfathering grace period may even be conservative. During the period between the issuance of D and its deadline of January 31, 2017, PG&E received over 100 MW of non-residential initial solar interconnection applications from customers hurrying to lock in the outdated, legacy TOU periods. This is nearly 7 times what was received in the same period in January Based on current net load and estimated generation of existing non-residential PG&E solar customers as of Sept Additional grandfathering-eligible load estimated to increase at 30 GWh per month, consistent with the last three months of readily available data. The base case assumes this continues until 7/2017, while if the PTM is granted eligibility continues until 9/2018. Gold rush assumes doubling of adoption starting 7/2017. See appendix A for a prior calculation by PG&E, updated to also include gross load, which PG&E has determined to be more relevant for evaluating load shifting potential. As noted in fn. 4 of the Jan. 13 Joint Ex parte: similarly, SCE estimates that over 1,800 gigawatt-hours of its nonresidential load will be subject to outdated TOU periods under the Original PD. That value increases to 3,300 gigawatthours under the RPD

9 of this additional load would continue to face and respond to outdated and misaligned price signals for an entire decade, past If the PTM were granted, it would cause a distorted economic signal for customers. The Decision stated: By varying retail price signals in relation to utility costs, TOU rates better reflect cost causation and motivate customers to shift their usage to periods that promote more efficient use of the electrical system. This shift should assist in reaching state energy goals by minimizing costs, encouraging energy conservation at appropriate times, and increasing electric supply at times that best serve the needs of the electric grid.. The benefit of TOU rates, however, is that a large number of customers making small adjustments in time of energy use will have a significant impact on the load curve, which in turn benefit the grid and reduce system costs overall. 20 The CAISO expressed similar concern. In its reply comments on the proposed decision, the CAISO recommended that the Commission adopt PG&E s Alternative Proposal and clarify that the five year sunset date begin six months from the date the final decision in the TOU OIR is issued. The CAISO stated: Without a timely sunset date on grandfathering eligibility, the clock starting the five-year grandfathering period would not begin until new TOU rates are implemented, which in PG&E s case may be two and half years from now. If the grandfathering eligibility period is available for five years, but does not start until two and half years from now, rates for certain customers would remain misaligned up until This is an unacceptably long period given how rapidly the system load profile is changing. 21 Here, since the Decision granted ten years of grandfathering for non-residential customers, the PTM would further push out the actual end date of the new ten-year grandfathering which the CAISO already found to be an unacceptably long period by another two and a half years due to the longer grace period the PTM reargues. 20 D , pp CAISO Reply Comments dated November 28, 2016 on Proposed Decision, p

10 C. Granting The PTM Would Adversely Affect The Development of the Energy Storage Market The Decision emphasized the importance of putting customers on rates with the correct peak hours, in order to encourage the development of the storage market. It stated: Going forward, in recognition of shifting resource availability patterns, as noted below, TOU rates should encourage customers to configure their systems to generate energy at times that better align with the later-shifted peak periods, e.g., via installation of co-located energy storage. 22 We encourage the Commission to continue to look forward, not backward as proposed by SEIA and CalSEIA. Tesla has built a battery gigafactory that became operational in January The largest and most obvious market for batteries are solar installations on rate schedules with a 4 to 9 p.m. or 5 to 10 p.m. peak period. The batteries could transform low value electricity into high value electricity. However, the grandfathering proposed by SEIA and CalSEIA would impede progress toward this goal by removing the incentive for members of the largest potential battery market to install this needed infrastructure. D. Granting The PTM Would Undermine The State s Goals To Reduce GHG Emissions Because Customers On Non-Economic Price Signals Will Be Less Likely To Shift Their Load The CPUC concluded that by varying retail price signals in relation to utility costs, TOU rates better reflect cost causation and motivate customers to shift their usage to periods that promote more efficient use of the electrical system. This shift should assist in reaching state energy goals by minimizing costs, encouraging energy conservation at appropriate times, and increasing electric supply at times that best serve the needs of the electric grid. 23 Exempting large numbers of customers with significant loads from the correct hours is at odds with the 22 D , p. 5. Similarly, Findings of Fact 4 stated: TOU peak periods have shifted to later in the day, several hours beyond the time of maximum solar energy production, suggesting the need for co-located solar generation and storage to provide the best configuration to maximize energy supply during periods of peak energy use on the grid. P. 70 (emphasis added). 23 D , p

11 state s climate change goals, and will also lead to higher cost of service and, therefore, higher rates for all customers. In particular, the Decision noted that on spring days with low demand and high solar generation, there is a risk that there will be an excess of generation available, leading to curtailment of renewables and other resources. 24 It also stated The CAISO has been particularly concerned with times when the available renewable generation is high but load is low. This situation has forced CAISO to curtail a small percentage of renewable generation. CAISO argues that in addition to peak periods, matinee rates ([also known as] reverse demand response) with super-off peak periods during spring days may be necessary. 25 Even at times of the year when curtailment of renewables is insignificant, shifting load from high-cost hours to lower-cost hours reduces GHG emissions because marginal GHG emissions per megawatt-hour are highest at exactly the same times that marginal costs are highest. 26 Every customer that is grandfathered on an outdated TOU period with an early peak receives an economic signal to consume electricity when doing so will increase both costs and GHG emissions for all. Leaving a larger amount of load on rates with outdated TOU peak period hours for over a decade not only conflicts with, but interferes with achievement of the State s GHG and other energy goals. E. Claims of A Market Collapse Are Unsupported The Petition claims that The solar industry serving commercial customers is already experiencing a halt in new sales. 27 Attached to the Petition are declarations from several solar 24 D , p D , p. 6, footnote omitted. 26 For example, PG&E uses the GHG allowance cost as an adder to the gas cost (to be multiplied by a marginal heat rate) in the Marginal Energy Cost model used in their 2017 GRC Phase II application (as they did in their 2015 RDW). Since both gas and GHG costs are constant throughout the day, in any day the hours with high marginal energy costs are also the hours with high marginal GHG emissions. 27 Petition to Modify, p

12 vendors stating that they have been trying to sell solar systems to customers, but that they think some of those sales will not go forward unless those customers qualify for grandfathering. 28 No quantification of expected lost sales is provided, and no comparison with the number of ongoing successful sales is provided. In fact, solar vendors continue to sell panels, and many new nonresidential customers who do not qualify for grandfathering under the Decision have, since January 31, 2017, continued to request interconnections. No showing of market collapse due to regulatory uncertainty has been made. Indeed, many customers who could not meet the deadlines in the Decision still benefit from receiving large bill savings under the net energy metering (NEM) tariffs and would continue to benefit under the rates proposed in pending rate cases. 29 Thus, there is no new basis for the Commission to apply a different determination with respect to grandfathering prospective solar customers than what the Commission has already applied in its original Decision. In approving a limited grandfathering eligibility pool and associated cutoff dates, the Commission explicitly acknowledged and accepted the exact uncertainty highlighted by solar parties in their original comments and retread in their PTM: One downside to this [eligibility end date] proposal is that it leaves a gap of uncertain TOU periods for prospective solar customers. This gap would start at the end date for grandfathering eligibility and continue until new TOU periods are approved by the Commission. However, at this time, with new TOU periods pending for all three IOUs, we believe there is sufficient information regarding likely changes to TOU periods for customers to make reasonable decisions on investments. While we acknowledge that [the] proposal is not a perfect solution, we find that it sets the right balance of mitigation and certainty for customers and the IOUs. We therefore adopt this approach for all three IOUs Appendix B to Petition to Modify. None of these declarations are from actual customers. 29 They also continue to receive other rate subsidies like being exempt from various nonbypassable charges, having standby charges and incremental property taxes waived, and receiving tax credits. 30 D , p

13 Moreover, although the Petitioners advocate for absolute rate certainty, this certainty should not result in additional uncertainty for IOU customers. As previously mentioned, PG&E and SCE could see significant increases in their eligible pool of grandfathered customers if the Petitioner s modifications are adopted. Additionally, all three IOUs have recently submitted their grandfathering administration advice letters 31 and SDG&E in particular is already preparing for the December 1, 2017 implementation of TOU updates and associated grandfathering. Adjusting the eligibility pool for TOU grandfathering at this point, could significantly impact the number of customers receiving incorrect price signals and the manner in which the IOUs intend to administer and message TOU grandfathering. As the Commission concluded in the Decision, grandfathering should not be used as tool to maximize future solar sales. 32 Other parties agreed. TURN explained in comments on the original Proposed Decision that to the extent that customers possess the ability to deploy their onsite investments to assist with load shifting, this capability should be harnessed to respond to evolving system needs rather than dedicated to maximizing private customer benefits under legacy TOU periods. 33 Moreover, rates will change for reasons beyond just changes in TOU periods, and it is important not to impede every rate change simply because it might reduce or delay a few solar sales. Currently, business customers on PG&E s Rate Schedule A-6 pay 55.5 cents per kwh for consumption during the noon to 6 p.m. period, and receive an identical bill credit for NEM exports during the same period. If customers were certain that this rate (which grossly exceeds 31 PG&E Advice 5039-E and SCE Advice 3582-E were both filed on March 30, As required by the Decision, these advice letters proposed administrative procedures to implement D SDG&E s advice letter will be filed on April 3, The Decision concluded that [W]e are not persuaded that grandfathering of TOU periods is an appropriate long-term mitigation measure to reduce the negative impacts that solar and other investors in DERs may face. Unreasonably long grandfathering prolongs the period during which such customers receive less accurate, and less cost-based, TOU pricing signals. As a result, the intended goals of setting more accurate TOU pricing signals will not be achieved. D , p TURN Opening Comments on Proposed Decision dated November 21, 2016, p

14 the market value of electricity generated between noon and 6 p.m.) and these time periods would remain unchanged for decades, that would create large incentives to sell solar panels, since they are available with no money down for 15 cents per kwh or less. However, rates change, and many proposals in pending rate design applications would change those rates beyond just the change in TOU periods. The Decision is expressly clear that the grandfathering protection only applies to the TOU time periods; rates [charged during each of those legacy periods] should still be adjusted to reflect changes in revenue requirement and cost allocation. 34 The Solar Parties could do a much better job describing the current regulatory status to their clients and customers. In a newsletter sent a month after the Decision, CalSEIA stated: The challenge is to guess what length of transition period the CPUC will grant and to convince customers we are right. CALSEIA believes it is reasonable to expect that customers will get a transition to the new TOU periods that is equivalent to five years of grandfathering. The other challenge is to know what rates to model for customer savings. The only thing we have in writing is the rates that the utilities have proposed. We have summarized those rates and time periods here. We should certainly model those for customers as a worst case scenario. But it would also be reasonable to model a middle ground scenario. CALSEIA is working to get the utilities to produce what the rates would be under a 2-7 pm peak period. Until they do, you can get close by using the proposed rate numbers and shifting peak to 2-7 pm. To summarize, you can model the proposed rates under the proposed TOU periods and a second scenario with a summer peak period of 2-7 pm. Those are the bookends for years six through thirty. For years one through five, use the current rates. 35 Strong consumer protections are needed, so that vendors do not assure customers that they can keep the current rates and time periods for five years, despite the fact that the 34 D , p. 59, emphasis added. 35 CalSEIA Weekly Newsletter dated January 23, 2017 (excerpt attached as Appendix B)(emphasis added). As noted previously, SCE has already provided CALSEIA forecasted rates via responses to data requests submitted in SCE s 2016 Rate Design Window Application

15 Commission concluded that Although it is clear that customer education and awareness campaigns must be expanded, we believe that at this time there is sufficient information available about changing rates for customers to consider these changes when making investment decisions. 36 III. CONCLUSION For all of these reasons, the Commission should deny the Petition to Modify. Respectfully submitted, By: /s/ RANDALL J. LITTENEKER Pacific Gas and Electric Company 77 Beale Street, B30A San Francisco, CA Telephone: (415) Facsimile: (415) Dated: April 3, 2017 Attorneys for PACIFIC GAS AND ELECTRIC COMPANY 36 D , p

16 Appendix A Customer Group Table 1: Load and PV Capacity Potentially Subject to Grandfathering Overall Load (GWh) Solar Customer Net Load (GWh) % of Load Current Installed Solar MW Est. Solar Customer Gross Load (GWh) Non- 55,550 2,732 5% 968 Residential 4,343 Agricultural 7, % 179 Class 443 Industrial Class 15,832 1,398 9% 96 1,558 Education 2, % 195 Sector 769 RES-BCT N/A 8 N/A Source: Internal PG&E Analysis, with solar adoption as of September 30, Solar Customer load only includes generating accounts and therefore significantly underestimates AG and RES-BCT load.

17 Appendix B CalSEIA California Solar Energy Industries Association Weekly Update Newsletter More Details on TOU Grandfathering January 23, 2017

18 3/8/2017 Weekly Update: More details on TOU decision Subscribe Share Past Issues Translate Making heads or tails of TOU View this in your browser More Details on TOU Grandfathering JANUARY 23, 2017 Last Thursday, the CPUC finalized a decision that sets terms and conditions for grandfathering customers on current TOU time periods after the peak period shifts toward the evening hours at the conclusion of pending rate cases. First, let s be clear that the decision does not cover residential NEM-2 customers. Those customers were granted five years of grandfathering against future TOU changes in the NEM-2 decision. For SCE residential customers installing between now and June 30, who will be on NEM-1, the decision is not crystal clear but it is CALSEIA s interpretation that the decision does not change a previous decision that granted these customers five years of TOU grandfathering. Plus, SCE has already shifted peak for residential tariffs, so any changes in a future rate case would be minor. The biggest impact of the decision is to grant ten years of TOU grandfathering for commercial and agricultural customers that already have solar. The decision also includes a limited grace period for customers that submit initial interconnection applications by January 31 and submit post-installation AHJ approval before July 31. Schools have a later deadline of December 31. This chart may help clarify what the grandfathering is for different types of customers. For future customers, the decision makes no guarantee of grandfathering against TOU period changes that happen after a customer installs. However, the decision envisioned 1/8

19 3/8/2017 Weekly Update: More details on TOU decision that such protection will be given after the fact. The decision recommends that transition Subscribe Share Past Issues Translate measures other than grandfathering be part of the development of TOU rates in the future. This should be done in utility-specific rate proceedings. For most customers, this is the same approach that would occur in the absence of today s decision. In other words, rates have always been subject to change, and we presume that if they are changed dramatically customers will not be forced onto the new rate structure immediately. The preference for transition measures other than grandfathering refers to proposals to create a Rate Transition Bill Credit. The way this would work is that when rate structure changes, the utility would determine what each NEM customer s bill would be under the old and the new rate structures, and the customer would get a bill credit equal to the difference for a set period of time. It would have the same economic impact as grandfathering, except that customers would be shifted to the new TOU periods immediately. This keeps customers whole (for a period) while getting them on updated price signals. It is somewhat nonsensical to give someone certainty after they have already made a decision based on uncertainty. But the CPUC is right that this is basically how it works now. The challenge is to guess what length of transition period the CPUC will grant and to convince customers we are right. CALSEIA believes it is reasonable to expect that customers will get a transition to the new TOU periods that is equivalent to five years of grandfathering. The other challenge is to know what rates to model for customer savings. The only thing we have in writing is the rates that the utilities have proposed. We have summarized those rates and time periods here. We should certainly model those for customers as a worst case scenario. But it would also be reasonable to model a middle ground scenario. CALSEIA is working to get the utilities to produce what the rates would be under a 2-7 pm peak period. Until they do, you can get close by using the proposed rate numbers and shifting peak to 2-7 pm. To summarize, you can model the proposed rates under the proposed TOU periods and a second scenario with a summer peak period of 2-7 pm. Those are the bookends for years six through thirty. For years one through five, use the current rates. CALSEIA will host a brief webinar to go over this decision and answer your questions on January 31 at 10:00 am. Bernadette Del Chiaro Executive Director, CALSEIA 2/8

20 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Assess Peak Electricity Usage Patterns and Consider Appropriate Time Periods for Future Time-of-Use Rates and Energy Resource Contract Payments. Rulemaking (Filed December 17, 2015) CERTIFICATE OF SERVICE I, the undersigned, state that I am a citizen of the United States and am employed in the City and County of San Francisco; that I am over the age of eighteen (18) years and not a party to the within cause; and that my business address is Pacific Gas and Electric Company, Law Department, B30A, 77 Beale Street, San Francisco, California On April 3, 2017, I served a true copy of: JOINT RESPONSE OF SAN DIEGO GAS AND ELECTRIC COMPANY (U 902 M), SOUTHERN CALIFORNIA EDISON (U 338 E), AND PACIFIC GAS AND ELECTRIC COMPANY (U 39 E) TO PETITION TO MODIFY D on the official service lists for R by electronic mail for those who have provided an address and by U.S. mail for those who have not. Additionally, true copies will be delivered to Administrative Law Judge Jeanne McKinney, California Public Utilities Commission, 505 Van Ness Avenue, San Francisco, CA I certify and declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on April 3, 2017 in San Francisco, California. /s/ Wanda M. Low

21 4/3/2017 CPUC Service Lists R CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC OIR TO ASSESS FILER: CPUC LIST NAME: LIST LAST CHANGED: MARCH 30, 2017 Download the Comma delimited File About Comma delimited Files Back to Service Lists Index Parties DONALD KELLY MARC D JOSEPH EXE DIR ADAMS BROADWELL JOSEPH & CARDOZO UTILITY CONSUMERS ACTION NETWORK, CA 00000, CA FOR: COALITION OF CALIFORNIA UTILITY FOR: UCAN EMPLOYEE JOHN W. LESLIE, ESQ. DANIEL W. DOUGLASS PARTNER ATTORNEY DENTONS US LLP DOUGLASS & LIDDELL 4766 PARK GRANADA, SUITE 209, CA CALABASAS, CA FOR: SHELL ENERGY NORTH AMERICA (US), FOR: NEST LABS, INC. L.P. OLIVIA SAMAD DONALD C. LIDDELL SENIOR ATTORNEY ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVENUE / PO BOX SECOND AVE. ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: CALIFORNIA ENERGY STORAGE ALLIANCE (SCE) OLIVIA SAMAD IS REP JOHN A. PACHECO KATHERINE RAMSEY ATTORNEY CLEAN COALITION SAN DIEGO GAS & ELECTRIC COMPANY 16 PALM CT 8330 CENTURY PARK CT., CP32 MENLO PARK, CA SAN DIEGO, CA FOR: CLEAN COALITION FOR: SAN DIEGO GAS & ELECTRIC COMPANY MATTHEW FREEDMAN EVELYN KAHL STAFF ATTORNEY COUNSEL THE UTILITY REFORM NETWORK ALCANTAR & KAHL LLP 785 MARKET STREET, 14TH FL 345 CALIFORNIA ST., STE SAN FRANCISCO, CA SAN FRANCISCO, CA /8

22 4/3/2017 CPUC Service Lists R FOR: TURN FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION LARISSA KOEHLER JEANNE B. ARMSTRONG ATTORNEY ATTORNEY ENVIRONMENTAL DEFENSE FUND GOODIN MACBRIDE SQUERI & DAY LLP 123 MISSION STREET, 28TH FLOOR 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ENVIRONMENTAL DEFENSE FUND FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION SEAN P. BEATTY GAIL L. SLOCUM WEST REGION GEN. COUNSEL ATTORNEY AT LAW NRG ENERGY, INC, PACIFIC GAS AND ELECTRIC COMPANY 100 CALIFORNIA STREET, SUITE BEALE STREET, B30A / PO BOX 7442 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: NRG ENERGY, INC. FOR: PACIFIC GAS AND ELECTRIC COMPANY CHRIS S. KING JASON B. KEYES EMETER, A SIEMENS BUSINESS ATTORNEY 4000 E. THIRD AVE., 4TH FLOOR KEYES & FOX LLP FOSTER CITY, CA TH STREET, STE FOR: ON BEHALF OF EMETER, A SIEMENS OAKLAND, CA BUSINESS FOR: ENERGY FREEDOM COALITION OF AMERICA MELISSA W. KASNITZ GREGG MORRIS CENTER FOR ACCESSIBLE TECHNOLOGY DIR ADELINE STREET, STE. 220 THE GREEN POWER INSTITUTE BERKELEY, CA SHATTUCK AVE., SUTE. 402 FOR: CENTER FOR ACCESSIBLE TECHNOLOGY BERKELEY, CA FOR: THE GREEN POWER INSTITUTE C. C. SONG JORDAN PINJUV REGULATORY ANALYST GEN. COUNSEL MARIN CLEAN ENERGY CALIFORNIA INDEPENDENT SYSTEM OPERATOR 1125 TAMALPAIS AVE. 250 OUTCROPPING WAY SAN RAFAEL, CA FOLSOM, CA FOR: MARIN CLEAN ENERGY (MCE) FOR: CALIFORNIA ISO MATTHEW SWINDLE BRAD HEAVNER CEO & FOUNDER POLICY DIR. NLINE ENERGY, INC. CALIFORNIA SOLAR ENERGY INDUSTRIES 5170 GOLDEN FOOTHILL PARKWAY TH ST., NO.820 EL DORADO HILLS, CA SACRAMENTO, CA FOR: NLINE ENERGY, INC. FOR: CALIFORNIA SOLAR ENERGY INDUSTRIES ASSOCIATION REBECCA FRANKLIN ROBERT LIEBERT ASSOCIATION OF CALIFORNIA WATER AGENCIES ELLISON, SCHNEIDER & HARRIS LLP 910 K STREET, SUITE CAPITOL AVE., STE. 400 SACRAMENTO, CA SACRAMENTO, CA FOR: ASSOCIATION OF CALIFORNIA WATER FOR: CALIFORNIA MANUFACTURERS & AGENCIES TECHNOLOGY ASSN. KAREN N. MILLS ASSOCIATE COUNSEL CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO, CA FOR: CALIFORNIA FARM BUREAU FEDERATION Information Only 0 WAHL BARBARA R. BARKOVICH DEP. DIR. POLICY & ELECTRICITY MARKETS CONSULTANT 2/8

23 4/3/2017 CPUC Service Lists R SOLARCITY CORPORATION BARKOVICH & YAP, INC., CA 00000, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION DAVID MARCUS KA YING CHEU ADAMS BROADWELL JOSEPH & CARDOZO PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA KAREN SHEA MARC D. JOSEPH PACIFIC GAS AND ELECTRIC COMPANY ADAMS BROADWELL JOSEPH & CARDOZO, CA 00000, CA MERRIAN BORGESON NATURAL RESOURCES DEFENSE COUNCIL, CA NELLIE TONG SENIOR CONSULTANT DNV KEMA ENERGY & SUSTAINABILITY, CA NORA SHERIFF OWEN SANFORD ATTORNEY SOLARCITY ALCANTAR & KAHL, CA 00000, CA SEPHRA A. NINOW SUSAN GLICK REGULATORY AFFAIRS MGR. SENIOR MGR., PUBLIC POLICY CENTER FOR SUSTAINABLE ENERGY SUNRUN, INC., CA 00000, CA MRW & ASSOCIATES, LLC, CA KAREN TERRANOVA ALCANTAR & KAHL, CA BRANDON SMITHWOOD DAVID P. LOWREY SOLAR ENERGY INDUSTRIES ASSOCIATION DIRECTOR, REGULATORY STRATEGY TH STREET, NW, SUITE 400 COMVERGE, INC. WASHINGTON, DC TH STREET, SUITE 2300 DENVER, CO KELLY CRANDALL DANIEL RAMIREZ EQ RESEARCH, LLC ANALYST 1580 LINCOLN STEET, SUITE 880 ENERGY STRATEGIES, LLC DENVER, CO SOUTH STATE STREET, STE 200 SALT LAKE CITY, UT LON W. HOUSE, PH.D DANIEL DOUGLASS WATER AND ENERGY CONSULTING ATTORNEY N. ORACLE RD., STE DOUGLASS & LIDDELL ORO VALLEY, AZ PARK GRANADA, SUITE 209 CALABASAS, CA FOR: ALLIANCE FOR RETAIL ENERGY MARKETS / DIRECT ACCESS CUSTOMER COALITION / WESTERN POWER TRADING FORUM ANDRE RAMIREZ CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE WALNUT GROVE AVE. / PO BOX 800 ROSEMEAD, CA ROSEMEAD, CA /8

24 4/3/2017 CPUC Service Lists R FADIA RAFEEDIE KHOURY R. OLIVIA SAMAD, ESQ. DIR & MANAGING ATTORNEY SR. ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE 2244 WALNUT GROVE AVENUE ROSEMEAD, CA ROSEMEAD, CA FOR: OLIVIA SAMAD IS REP AT SCE STEVEN C. NELSON DAVID CROYLE SAN DIEGO GAS & ELECTRIC COMPANY EXECUTIVE DIRECTOR 488 8TH AVE., 9TH FL. UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO, CA KENYON STREET, STE. 401 SAN DIEGO, CA FOR: UCAN MARCIE A. MILNER CENTRAL FILES VP REG AFFAIRS SAN DIEGO GAS AND ELECTRIC COMPANY SHELL ENERGY NORTH AMERICA (US), L.P CENTURY PARK COURT CP31E 4445 EASTGATE MALL, STE. 100 SAN DIEGO, CA SAN DIEGO, CA FOR: SHELL ENERGY NORTH AMERICA (US), L.P. CYNTHIA FANG DANA GOLAN SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32E 8330 CENTURY PARK CT., CP421 SAN DIEGO, CA SAN DIEGO, CA WILLIAM FULLER JASON M. ACKERMAN CALIF. REGULATORY AFFAIRS ATTORNEY SAN DIEGO GAS & ELECTRIC COMPANY BEST BEST & KRIEGER, LLP 8330 CENTURY PARK COURT, 32CH 3390 UNIVERSITY AVENUE, 5TH FLOOR SAN DIEGO, CA RIVERSIDE, CA JEANNETTE OLKO ANDREW YIP CITY OF MORENO VALLEY MGR BUS. DEVELOPMENT (RBNA/PJ BGT) FREDERICK STREET ROBERT BOSCH LLC MORENO VALLEY, CA JEFFERSON DRIVE MENLO PARK, CA BRIAN KORPICS ANTHONY HARRISON STAFF ATTY & POLICY MGR. MGR. REGULATORY AFFAIRS THE CLEAN COALITION STEM, INC. 16 PALM CT. 100 ROLLINS RD. MENLO PARK, CA MILLBRAE, CA SUE MARA MILA A. BUCKNER CONSULTANT ATTORNEY RTO ADVISORS, LLC ADAMS BROADWELL JOSEPH & CARDOZO 164 SPRINGDALE WAY 601 GATEWAY BLVD., STE REDWOOD CITY, CA SOUTH SAN FRANCISCO, CA ERIC BORDEN KATY MORSONY ENERGY POLICY ANALYST ALCANTAR & KAHL THE UTILITY REFORM NETWORK 345 CALIFORNIA STREET, STE MARKET STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA CASE ADMINISTRATION JAMES FINE, PH.D PACIFIC GAS AND ELECTRIC COMPANY SR. ECONOMIST 77 BEALE STREET ENVIRONMENTAL DEFENSE FUND SAN FRANCISCO, CA MISSION ST., 28TH FL. SAN FRANCISCO, CA JOSEPHINE WU SHERIDAN PAUKER 4/8

25 4/3/2017 CPUC Service Lists R PACIFIC GAS & ELECTRIC COMPANY REGULATORY COUNSEL 77 BEALE STREET, RM 975, MCB9A WILSON SONSINI GOODRICH & ROSATI SAN FRANCISCO, CA ONE MARKET PLAZE, SPEAR TOWER, STE SAN FRANCISCO, CA ELIAH GILFENBAUM MARC KOLB DEPUTY DIR SOLARCITY SOLARCITY 444 DE HARO STREET, SUITE DE HARO STREET SAN FRANCISCO, CA SAN FRANCISCO, CA DAVID J. MILLER MICHELLE CHOO EXE DIR SR. LEGAL COUNSEL ASSISTANT AT&T SERVICES, INC. AT&T SERVICES, INC. 430 BUSH STREET, ROOM BUSH STREET, NO. 9 SAN FRANCISCO, CA SAN FRANCISCO, CA THOMAS SELHORST ANNA MURVEIT SENIOR PARALEGAL CALIFORNIA EMVIRONMENTAL ASSOCIATES AT&T CALIFORNIA, INC. 423 WASHINGTON ST. 4TH FL. 430 BUSH STREET, 3RD FLOOR, NO. 14 SAN FRANCISCO, CA SAN FRANCISCO, CA BRIAN CRAGG BRIAN THEAKER ATTORNEY DIR REGULATORY AFFAIRS GOODIN, MACBRIDE, SQUERI & DAY, LLP NRG ENERGY, INC. 505 SANSOME ST., STE CALIFORNIA, STE. 650 SAN FRANCISCO, CA SAN FRANCISCO, CA DIANE FELLMAN MEGHA LAKHCHAURA VP REGULATORY & GOVERNMENT AFFAIRS DIR. PUBLIC POLICY NRG WEST REGION SUNRUN INC 100 CALIFORNIA ST., STE MARKET STREET SAN FRANCISCO, CA SAN FRANCISOC, CA CALIFORNIA ENERGY MARKETS CHARLES R. MIDDLEKAUFF 425 DIVISADERO ST. SUITE 303 ATTORNEY SAN FRANCISCO, CA PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, B30A, PO BOX 7442 SAN FRANCISCO, CA MEGAN M. MYERS RICK COUNIHAN ATTORNEY NEST LABS, INC. LAW OFFICES OF SARA STECK MYERS 3400 HILLVIEW AVENUE TH AVENUE PALO ALTO, CA SAN FRANCISCO, CA BONNIE DATTA MICHAEL ROCHMAN SIEMENS USA MANAGING DIR E. THIRD AVENUE SCHOOL PROJECT UTILITY RATE REDUCTION FOSTER CITY, CA GATEWAY BLVD., STE. 235 CONCORD, CA FOR: SPURR MATTHEW BARMACK KATHY TRELEVEN DIR. MARKET & REGULATORY ANALYSIS KATHY TRELEVEN CONSULTING CALPINE CORPORATION 103 BANDOL CT DUBLIN BLVD., SUITE 100 SAN RAMON, CA DUBLIN, CA DAVE BEYER YAP CATHERINE SR. CIVIL ENGINEER ATTORNEY AT LAW EAST BAY MUNICIPAL UTILITY DISTRICT BARKOVICH & YAP, INC. 375 ELEVENTH STREET PO BOX OAKLAND, CA OAKLAND, CA /8

26 4/3/2017 CPUC Service Lists R ALISON SEEL TIM LINDL ASSOCIATE ATTORNEY COUNSEL SIERRA CLUB KEYES & FOX LLP 2101 WEBSTER ST., STE TH STREET, STE OAKLAND, CA OAKLAND, CA NANCY RADER TOM BEACH EXECUTIVE DIR. PRINCIPAL CALIFORNIA WIND ENERGY ASSOCIATION CROSSBORDER ENERGY 1700 SHATTUCK AVE., NO NINTH STREET, SUITE 213A BERKELEY, CA BERKELEY, CA CARLOS LAMAS BABBINI PHILLIP MULLER SR. PROGRAM EXE. PRESIDENT IPKEYS POWER PARTNERS, LLC SCD ENERGY SOLUTIONS 58 MOUNT TALLAC COURT 436 NOVA ALBION WAY SAN RAFAEL, CA SAN RAFAEL, CA JOHN NIMMONS C.SUSIE BERLIN COUNSEL LAW OFFICES OF SUSIE BERLIN JOHN NIMMONS & ASSOCIATES, INC THE ALAMEDA, SUITE 7 NO ELINOR AVE., STE. G SAN JOSE, CA MILL VALLEY, CA DELPHINE HOU JOHN GOODIN CALIF. INDEPENDENT SYSTEMS OPERATOR CALIFORNIA ISO 250 OUTCROPPING WAY 250 OUTCROPPING WAY FOLSOM, CA FOLSOM, CA CAROLYN KEHREIN DOUGLAS DAVIE ENERGY MANAGEMENT SERVICES VICE PRESIDENT ENERGY USERS FORUM WELLHEAD ELECTRIC COMPANY, INC CELEBRATION WAY 650 BERCUT DRIVE, STE. C WOODLAND, CA SACRAMENTO, CA CAMILLE STOUGH, ESQ. DAN GRIFFITHS BRAUN BLAISING MCLAUGHLIN & SMITH PC ATTORNEY 915 L STREET, STE BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. SACRAMENTO, CA L STREET, SUITE 1480 SACRAMENTO, CA JOSHUA NELSON JUSTIN WYNNE ASSOCIATE ATTORNEY BEST BEST & KRIEGER LLP BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 500 CAPITOL MALL, STE L STREET, SUITE 1480 SACRAMENTO, CA SACRAMENTO, CA KEVIN WOODRUFF MATTHEW KLOPFENSTEIN WOODRUFF EXPERT SERVICES ATTORNEY TH STREET, SUITE 514 GONZALEZ, QUINTANA & HUNTER, LLC SACRAMENTO, CA L STREET, STE FOR: TURN SACRAMENTO, CA FOR: NLINE INC. MICHAEL BOCCADORO RICK WALTMAN PRESIDENT ATTORNEY AT LAW WEST COAST ADVISORS BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 925 L STREET, SUITE L STREET, SUITE 1480 SACRAMENTO, CA SACRAMENTO, CA FOR: AGRICULTURAL ENERGY CONSUMERS ASSOCIATION SCOTT BLAISING STEVEN KELLY 6/8

27 4/3/2017 CPUC Service Lists R COUNSEL POLICY DIRECTOR BRAUN BLAISING MCLAUGHLIN & SMITH P.C. INDEPENDENT ENERGY PRODUCERS ASSCIATION 915 L STREET, SUITE K STREET, STE. 900 SACRAMENTO, CA SACRAMENTO, CA ANDREW B. BROWN LYNN HAUG ATTORNEY AT LAW ATTORNEY AT LAW ELLISON SCHNEIDER & HARRIS LLP ELLISON, SCHNEIDER & HARRIS, LLP 2600 CAPITOL AVENUE, SUITE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA ANN L. TROWBRIDGE MIKE CADE ATTORNEY AT LAW INDUSTRY SPECIALIST DAY CARTER & MURPHY LLP ALCANTAR & KAHL 3620 AMERICAN RIVER DR., STE SW SALMON STREET, SUITE 1100 SACRAMENTO, CA PORTLAND, OR FOR: AGRICULTURAL ENERGY CONSUMERS ASSOCIATION State Service SCOTT MURTISHAW ENERGY ADVISOR CPUC EXEC DIV, CA BENJAMIN GUTIERREZ CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA ERIC DURAN FOREST KASER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM INFRASTRUCTURE PLANNING AND PERMITTING B ROOM 4011 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA GREGORY HEIDEN JEANNE MCKINNEY CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 4300 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA LEE WHEI TAN MATTHEW A. KARLE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4102 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA NATHAN BARCIC NATHAN CHAU CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA PAUL DOUGLAS RAJAN MUTIALU CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B POLICY & PLANNING DIVISION AREA 4 A AREA 4 A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA ROBERT LEVIN SEAN A. SIMON 7/8