BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902E) for Approval of its 2018 Energy Storage Procurement and Investment Plan. And Related Matters. A (Filed February 28, 2018) A A (Consolidated) OPENING BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) JANET S. COMBS REBECCA MEIERS-DE PASTINO Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: July 11, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902E) for Approval of its 2018 Energy Storage Procurement and Investment Plan. A (Filed February 28, 2018) And Related Matters. A A (Consolidated) OPENING BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) Pursuant to Rule of the California Public Utilities Commission s (Commission s) Rules of Practice and Procedure and the Assigned Commissioner s Scoping Memo and Ruling (Scoping Ruling) issued on May 24, 2018, Southern California Edison Company (SCE) respectfully submits its concurrent Opening Brief on the portion of the above captioned Application in which SCE seeks Approval of SCE s 2018 Biennial Solicitation Procurement Plan pursuant to Assembly Bill (AB) 2514 (AB 2514 Plan). 1 I. INTRODUCTION AND BACKGROUND SCE s AB 2514 target for the 2018 procurement cycle is 160 MW across the three grid domains, and its cumulative target (accounting for the 2014, 2016, and 2018 procurement cycles) 1 Given the variation in the scope and substance between the AB 2514 procurement and AB 2868 investment and programs, the Commission bifurcated the proceeding. SCE s Opening Brief pertains only to its 2018 Biennial Solicitation Procurement Plan pursuant to AB

3 is 370 MW across the three grid domains. 2 Currently, SCE s planned and existing energy storage consists of: 120 MW in the transmission-connected domain, 73.5 MW in the distributionconnected domain, and MW in customer-connected domain, 3 for a total of MW. The flexibility rules adopted in the Track 1 Decision in R allow SCE to apply up to 85 MW of customer-connected storage toward meeting the targets in the transmission and distribution domains. After applying this flexibility provision, SCE s total eligible procurement through the 2018 procurement cycle is MW, which is 6.5 MW short of the 2018 cumulative energy storage target. 5 Thus, SCE s existing procurement has met all but 6.5 MW of its target. SCE s AB 2514 Plan proposes to satisfy its 6.5 MW deficit by conducting a Senate Bill (SB) 801 solicitation to procure a minimum of 20 MW of energy storage. SB 801 requires the Commission to order a solicitation to procure a minimum aggregate total of 20 MW of costeffective energy storage solutions to help address the Los Angeles Basin s electrical system operational limitations resulting from reduced gas deliverability from the Aliso Canyon natural gas storage facility 6 by June 1, SCE s AB 2514 Plan proposes to hold an energy storage solicitation to address the reliability concerns associated with the partial shutdown of the Aliso Canyon natural gas storage facility consistent with SB 801. Given the timing and minimum 2 D , Appendix A, p This number accounts for the rule established in D that credit for SGIP-funded energy storage projects installed by Direct Access (DA) and Community Choice Aggregation (CCA) customers should be split evenly between an unbundled customer s IOU and the DA/CCA service provider. See D , pp SCE estimates that, of its MW of forecasted customerconnected energy storage under SGIP, approximately 20% could be attributable to projects that will be installed by DA/CCA customers. Of that 20%, half of the MW should be credited to DA/CCA providers. SCE thus provides a very conservative estimate that approximately 96 MW of the forecasted MW of SGIP energy storage projects would be counted towards SCE s customerconnected domain. See Section III.D.1.b of SCE s Direct Testimony for additional details. 4 D , pp SCE Testimony at p. 5: Cal. Pub. Util. Code (b). 2

4 procurement requirements of SB 801, this procurement will also satisfy the remaining 6.5 MW necessary for SCE to meet its 2018 target. SCE s AB 2514 Plan also describes other procurement opportunities for energy storage, as well as SCE s ongoing efforts to pursue reasonable and cost-effective energy storage solutions that will facilitate system reliability, and provide the grid with additional operational flexibility, while achieving the guiding principles of AB The AB 2514 Plan also addresses the safety of its energy storage facilities. For the reasons explained in greater detail below, SCE has met its initial burden of coming forward with evidence, 7 as well as its burden to prove the Commission should adopt SCE s AB 2514 Plan. SCE s AB 2514 Plan is virtually unchallenged. No party other than the Office of Ratepayer Advocates (ORA) has contested any aspect of SCE s AB 2514 Plan. ORA s challenge is narrow and discrete. Specifically, ORA does not object to SCE s plan to satisfy its residual 6.5 MW need through its SB 801 procurement obligation, 8 but rather argues the Commission should require SCE to count: (1) 6.5 MW of transmission or distribution-sided storage from SCE s SB 801 procurement1 towards SCE s AB 2514 target; (2) the remaining 13.5 MW towards its AB 2868 investment plan; and (3) all of its SB 801- driven customer side energy storage procurement towards its AB 2868 plan. 9 As SCE explains below, there are sound legal and policy reasons why the Commission should reject ORA s position. On the basis of the policy arguments alone, the Commission should refuse to count SB 801 procurement of distributed customer-side energy storage toward SCE s future AB 2868 MW investments and customer programs. SCE concedes, however, it is lawful for the Commission to 7 Decision (Analogizing to and relying upon Southern California Edison Company and San Diego Gas and Electric Company, FERC Docket No. EC , 50 FERC P 63,012, p. 65,065.) 8 ORA Intervenor Test. at p. 2:32-35; Likewise, the Coalition of California Utility Employees (CUE) Response to SCE s Application at p. 5 states, This procurement will count towards SCE s energy storage targets in accordance with D , and will satisfy SCE s 2018 cumulative target net short of 6.5 MW. This portion of SCE s application demonstrates compliance with AB 2514 and should be approved by the Commission. 9 Id. at p. 3:

5 count SB 801 procurement of distributed customer-side energy storage toward SCE s future AB 2868 MW customer programs, but not investments SCE therefore respectfully requests the Commission grant SCE s Application with respect to its AB 2514 Plan without modification, finding it complies with (1) Decision (D.) and other relevant energy storage decisions to transform the energy storage market to overcome barriers hindering adoption of emerging storage technologies, (2) the energy storage requirements set forth in California Public Utilities Code Sections 2835, , and 2837, (3) the Multiple Use-Case Application (MUA) rules set forth in Ordering Paragraph 2 and Appendix A of D , and (4) the counting rules set forth in D and D II. THE COMMISSION SHOULD ADOPT SCE S AB 2514 PLAN A. The Commission Should Find in SCE s Favor on All Uncontested Matters SCE s Direct Testimony is uncontested on the issues the Scoping Ruling identifies as in the scope of this portion of the proceeding. In other words, no intervening party has challenged that SCE has met its burden to prove that it has complied with (1) D and other relevant energy storage decisions to transform the energy storage market to overcome barriers hindering adoption of emerging storage technologies, (2) the energy storage requirements set forth in California Public Utilities Code Sections 2835 (defining procurement), (requiring cost effectiveness), and 2837 (establishing procurement plan requirements), (3) the MUA rules 10 California Choice Energy Authority s (CCEA s) Response to SCE s Application stated CCEA was unclear how costs would be recovered for AB 2514/SB 801 procurement. See CCEA Response at pp. 2, 4. The Scoping Ruling, however, states, Cost recovery will not be revisited for the AB 2514 portion of the proceeding, but will follow the framework already adopted by prior decisions D and D Because the Scoping Ruling indicates the Commission finds cost recovery to be a clear and settled matter outside the scope of SCEs Application, SCE s opening brief does not address cost recovery. 4

6 set forth in Ordering Paragraph 2 and Appendix A of D , and (4) the legal requirements for counting. The same is true of the reasonableness of the safety protocols. SCE therefore submits it has met its burden to prove the Commission should grant the AB 2514 Plan portion of SCE s Application as reasonable and in customers best interest. More specifically, Chapter III of SCE s Direct Testimony establishes that SCE s AB 2514 Plan, which identifies a 6.5 MW residual procurement target, complies with the legal requirements for counting. 11 Chapter IV of SCE s testimony establishes that the in-front-of-themeter procurement from the SB 801 Solicitation will count towards SCE s energy storage targets in accordance with D , which provides that energy storage projects procured through other Commission proceedings may count towards the IOU s procurement targets once approved by the Commission. 12 Given that SB 801 requires a minimum procurement of 20 MW, this solicitation will satisfy SCE s 2018 cumulative target net short of 6.5 MW. Chapter IV of SCE s direct testimony also establishes that SCE has procured energy storage resources through competitive, cost-effective, stand-alone energy storage RFOs for the 2014 and 2016 biennial cycles to maintain momentum in transforming the energy storage market, which is consistent with the Commission s Energy Storage Procurement Program Design. In this biennial cycle, SCE s Direct Testimony explains that SCE will again competitively solicit energy storage resources to help address the reliability issues caused by the partial shutdown of the Aliso Canyon Natural Gas Storage Facility, pursuant to SB SCE s Direct Testimony also explains that there are other competitive solicitation opportunities 11 SCE Direct Testimony, Chapter II at p. 5; Chapter III, Table III See D , Appendix A, pp SB 801 provides that the utility may elect to count distribution connected energy storage towards the programs and investment target adopted in AB SCE intends to count SB 801 procurement towards its Energy Storage Procurement Framework target because the SB 801 Solicitation is limited to third-party owned procurement, while AB 2868 is intended for utility-owned investments. SCE concedes, however, that SB 801 procurement of distributed customer side energy storage can count toward AB 2868 customer programs. 13 SCE Direct Testimony at Chapter IV, pp

7 for Energy Storage procurement during the 2018 biennial cycle. 14 With regard to the reasonableness of the SB 801 solicitation, consistent with Commission direction, in April 2018 filed an Advice Letter with its proposed solicitation parameters and timeline. 15 Once SCE receives approval of its proposed solicitation, it will work expeditiously to issue its solicitation and procure the minimum aggregate 20 MW as required by the statute and directed by the Commission. SCE s approach to the safety of energy storage resources is detailed in Chapter VII of SCE s Direct Testimony. 16 With respect to utility procurement of energy storage resources, responsibility of safe operations falls on the owner/operator of the facility. However, SCE includes provisions in its contracts to require third-party sellers to engage in safe practices and comply with all applicable laws, permit requirements, and applicable California utility industry standards. Additionally, safety standards and certifications are incorporated into applicable interconnection tariffs, which allow SCE to review energy storage equipment prior to installation, and during pre- and post- commercial testing. SCE has also participated in a Commission-sponsored energy storage safety working group to develop a Commission energy storage safety inspection protocol for the Commission s Safety and Enforcement Division inspectors to use based on expertise from the utilities, codes and standards development organizations, energy storage developers, and other interested parties Id. at Chapter IV, pp Id at. Chapter IV, pp. 24:17-25:2. 16 Rule 2.1(c) of the Commission s Rules of Practice and Procedure requires SCE to include a discussion of relevant safety considerations in SCE s application. 17 For additional details regarding the Commission s energy storage safety checklist, please see the link provided below: %20Inspection%20Guidelines.doc. 6

8 B. The Commission Should Reject ORA s Position on Counting SB 801 Procurement Toward AB 2868 Investments The sole contested issue is ORA s objection to counting all SB 801 procurement toward SCE s AB 2514 targets given that the SB 801 procurement will exceed the target. ORA does not object to SCE s plan to satisfy its residual 6.5 MW need through its SB 801 procurement obligation, 18 and concedes that there is no legal prohibition on SCE counting energy storage procurement pursuant to SB 801 toward its AB 2514 target. 19 Instead, ORA argues the Commission should require SCE to count: (1) 6.5 MW of transmission or distribution-sided storage from SCE s SB 801 procurement1 towards SCE s AB 2514 target; (2) the remaining 13.5 MW towards its AB 2868 investment plan; and (3) all of its SB 801-driven customer side energy storage procurement towards its AB 2868 plan. 20 There are sound legal and policy reasons why the Commission should reject ORA s position to attributing the remaining 13.5 MW towards SCE s AB 2868 investment plan or transmission energy storage resources. First, as ORA acknowledges, D does not prohibit SCE from counting energy storage procurement conducted pursuant to SB 801 toward SCE s AB 2514 target. In addition to there being no statute or Commission precedent prohibiting SCE from counting SB 801 procurement toward its AB 2514 target, D s list of procurement that counts toward the energy storage targets includes projects procured in other Commission proceedings, such as the SB 801 procurement at issue here. The Commission should not depart from that precedent when, as is the case here, SCE s Direct Testimony provides a comprehensive assessment of SCE s energy storage procurement and establishes that it remains short of its overall 580 MW target. 18 ORA Intervenor Test. at p. 2: Id. at p. 2: Id. at p. 3:

9 Second, it is not lawful to apply SCE s SB 801 third party procurement to SCE s AB 2868 investments. SB 801 is codified as California Public Utilities Code section AB 2868 is codified in Sections and SB 801/Section is statutorily limited to third party-owned procurement. 21 Subpart (b) of Section provides, An electrical corporation may count any cost-effective energy storage solution that it deploys pursuant to this subdivision towards the capacity requirement established pursuant to Section if the costeffective storage solution that it deploys is a distributed energy storage system, as defined in subdivision (a) of Section Subpart (d) of Section defines deploy as the procurement of third party owned energy storage system. 22 Likewise, both AB 2868 and SB 801 are expressly limited to distributed energy storage system[s]. 23 Given these statutory limitations, ORA s proposal violates well-settled rules of statutory construction. Those rules require the Commission to give words their plain meaning, to assume the Legislature says what it means and means what it says, and, when the Legislature consistently uses a word, to give it the same meaning each time it is used. Likewise, statutes that are in pari materia, meaning on the same subject matter, must be construed together. Unlike SB 801, which is limited to third party owned systems, AB 2868 is expressly limited to investments and programs. On its face, the only reasonable interpretation of the term 21 Cal. Pub. Util. Code ( (b) The commission shall, to the extent that doing so is cost effective and feasible and necessary to meet the reliability requirements of the electrical system in the Los Angeles Basin, direct an electrical corporation serving the Los Angeles Basin to deploy, pursuant to a competitive solicitation, a minimum aggregate total of 20 megawatts of cost-effective energy storage solutions to help address the Los Angeles Basin s electrical system operational limitations resulting from reduced gas deliverability from the Aliso Canyon natural gas storage facility. An electrical corporation may count any cost-effective energy storage solution that it deploys pursuant to this subdivision towards the capacity requirement established pursuant to Section if the costeffective storage solution that it deploys is a distributed energy storage system, as defined in subdivision (a) of Section ) (emphasis added); see also Cal. Pub. Util. Code (d)(2) ( To deploy means to procure a cost-effective energy storage solution on or after the effective date of this section that may be a third-party-owned solution, or a solution procured pursuant to a powerpurchase agreement or rebate program, or pursuant to any other third-party ownership structure.... ) 22 Id. 23 Id.; see also Cal. Pub. Util. Code

10 investment is as a term of art referencing utility ownership or capital improvements of utility owned infrastructure, not utility power procurement from facilities owned by third parties. 24 This view conforms to the everyday meaning of the word investment, which Merriam- Webster s Dictionary defines an investment as an asset intended to produce income or capital gains. 25 The Commission also recognized this unremarkable and obvious distinction in D , stating, In recognition that AB 2868 includes proposals for investments in storage, and not just procurement, the biennial 2018 and 2020 application cycles will now be referred to as the 2018 and 2020 energy storage procurement and investment plans. 26 If procurement and investment are one in the same, there would be no need for the Commission to have made a distinction between the two. ORA s request requires the Commission to construe investment as synonymous with procurement. The Legislature clearly understood these terms to have different meanings and decided not to use the term procurement when it passed AB 2868 even though it knew the meaning of the word. Instead, it opted to use a different term investment. The Legislature clearly understood the term procurement is distinguishable from the term investment because it broadly defined procurement in Section 2835 to encompass a wide suite of activities. 27 In addition, a search of the Public Utilities Code reveals the Legislature was more 24 A search of PUC sections governing the electric industry for the word investment supports this conclusion, which is not surprising given that utility investments are the cornerstone of the regulatory compact. The regulatory compact guarantees utilities will earn a reasonable rate of return as profits in exchange for taking the financial risk of investing private capital in the service of the greater societal good by building new facilities and infrastructure. See, e.g., The Binghampton Bridge, 70 U.S. 51 (3 Wall) 51 at 74 (1865) (describing the regulatory compact between private utilities, like SCE, and the government.) Power procurement from third parties does not and cannot mean utility investment. 25 Definition of Investment available at: 26 D at p Cal. Pub. Util. Code 2835(f) Procure and procurement means, in reference to the procurement of an energy storage system, to acquire by ownership or by a contractual right to use the energy from, or the capacity of, including ancillary services, an energy storage system owned by a load-serving entity, local publicly owned electric utility, customer, or third party. Nothing in this chapter, and no action by the commission, shall discourage or disadvantage development and ownership of an energy storage system by an electrical corporation. 9

11 than familiar with the words procure and procurement. These words appear on numerous occasions, but never as synonymous with the word investment, which also frequently appears in the Code, but in provisions governing utility infrastructure or other investments like employee pensions. Thus, the Legislature was clearly familiar with using both terms. If the Legislature had intended the AB 2868 investments to include all procurement, including third party owned resources, it would have used the term procurement, which it expressly defined in Section 2835 to encompass both. It did not because that is not what it intended. Further evidence that the Legislature did not intend procurement and investments to be construed as one in the same is the fact that it did not subject AB 2868 to the same requirements it mandates for utility procurement of third party owned resources. For instance, SB 801 requires a competitive solicitation consistent with the cost effectiveness standard. By contrast, AB 2868 requires SCE to minimize overall costs and maximize overall benefits of the utility programs and utility owned investments it proposes. These are markedly different standards, demonstrating that AB 2868 narrowly applies to utility owned investments and customer programs, not traditional power procurement from third party owned resources. Finally, allocating SB 801 procurement to AB 2868 investments may diminish SCE s capacity target for investments in violation of the Legislature s prohibition that no action by the commission, shall discourage or disadvantage development and ownership of an energy storage system by an electrical corporation. 28 In sum, it is not lawful to attribute SB 801 procurement to SCE s AB 2868 investments. Likewise, because AB 2868 and SB 801 are expressly limited to distributed energy resources, it is not lawful to count transmission resources procured pursuant to SB 801 toward AB 2868 targets. Setting aside the legal issues, from a policy perspective, applying SB 801 procurement to the AB 2868 requirement may frustrate AB 2868 by reducing the capacity target the Legislature 28 Cal. Pub. Util. Code

12 intended to use to bring energy storage systems to low-income and public sector customers. By contrast to SB 801 procurement, SCE s AB 2868 investments and programs are intended to serve a number of beneficial purposes, including, but not limited to, prioritizing storage for public sector and low-income customers, reducing dependence on petroleum, reducing greenhouse gas emissions, and minimizing costs and maximizing overall benefits to customers. 29 In addition, SCE s AB 2868 proposals have undergone extensive stakeholder oversight to ensure they meet the letter and spirit of the statute. The same is not true of SB 801 procurement. To date, procured customer connected energy storage resulting from the SB 801 solicitation has not received the equivalent stakeholder oversight and input. On the basis of these policy arguments alone, the Commission should refuse to count SB 801 procurement of energy storage toward SCE s future AB 2868 MW investments and customer programs. SCE concedes, however, it is lawful for the Commission to count SB 801 procurement of distributed customer-side energy storage toward SCE s future AB 2868 MW customer programs, but not investments for the reasons discussed above. 30 SCE therefore requests the Commission reject ORA s proposal to count SCE s SB 801 procurement toward AB 2868 investments, transmission resources, and programs. If the Commission disagrees, it should only allow SB 801 procurement of distributed customer side energy storage to count toward the AB 2868 capacity target for customer programs, not utility investments. 29 Cal. Pub. Util. Code , Pursuant to D at pp , the IOUs, in consultation with CPUC staff, hosted three workshops to discuss and develop consistent definitions of terms, proposals for how to evaluate projects against the statutory criteria, and their plans for incorporating the proposed programs and investments for distributed energy storage systems into their 2018 energy storage procurement and investment plans. 11

13 III. CONCLUSION For the foregoing reasons, the Commission should grant SCE s Application with regard to its AB 2514 Plan without modification and should not require SCE to count its SB 801 procurement toward transmission energy storage resources or AB 2868 investments and programs. Respectfully submitted, JANET S. COMBS REBECCA MEIERS-DE PASTINO /s/ Rebecca Meiers-De Pastino By: Rebecca Meiers-De Pastino Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY July 11, Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Rebecca.Meiers.Depastino@sce.com 12

14 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902E) for Approval of its 2018 Energy Storage Procurement and Investment Plan. A (Filed February 28, 2018) And Related Matters. A A (Consolidated) CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of OPENING BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) 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 sealed envelopes and causing such envelopes to be delivered by U.S. Mail to the offices of the ALJ(s) or other addressee(s). ALJ Brian Stevens California Public Utilities Commission Division of ALJs 505 Van Ness Avenue, Room 5023 San Francisco, CA Executed on July 11, 2018, at Rosemead, California. /s/ Regina Coburn Regina Coburn Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

15 CPUC - Service Lists - A Page 1 of 5 7/11/2018 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: JULY 2, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties REBECCA MEIERS-DE PASTINO E. GREGORY BARNES SR. ATTORNEY ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVENUE / PO BOX CENTURY PARK COURT, CP32D, 2ND FL. ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY SUE MARA MILA A. BUCKNER CONSULTANT ATTORNEY RTO ADVISORS L.L.C. ADAMS BROADWELL JOSEPH & CARDOZO 164 SPRINGDALE WAY 601 GATEWAY BLVD., STE REDWOOD CITY, CA SOUTH SAN FRANCISCO, CA FOR: ALLIANCE FOR RETAIL ENERGY MARKETS FOR: COALITION OF CALIFORNIA UTILITY (AREM) AND DIRECT ACCESS CUSTOMER EMPLOYEES (CUE) COALITION (DACC) ANAND DURVASULA HAYLEY GOODSON STAFF ATTORNEY LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM MARKET ST., STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: ORA STEPHANIE WANG ALEXANDER MCDONOUGH POLICY DIR VP - PUBLIC POLICY CALIFORNIA HOUSING PARTNERSHIP SUNRUN, INC. 369 PINE STREET, STE MARKET ST.

16 CPUC - Service Lists - A Page 2 of 5 7/11/2018 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE CALIFORNIA HOUSING PARTNERSHIP FOR: SUNRUN, INC. CORPORATION GRADY MATHAI-JACKSON BRIAN T. CRAGG PACIFIC GAS AND ELECTRIC COMPANY ATTORNEY 77 BEALE STREET, B30A GOODIN, MACBRIDE, SQUERI & DAY, LLP SAN FRANCISCO, CA SANSOME STREET, SUITE 900 FOR: PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA FOR: LS POWER DEVELOPMENT, LLC SARAH VAN CLEVE ELISE HUNTER ENERGY POLICY ADVISOR DIR - POLICY & REGULATORY AFFAIRS TESLA, INC. GRID ALTERNATIVES 3500 DEER CREEK ROAD 1171 OCEAN AVE., STE. 200 PALO ALTO, CA OAKLAND, CA FOR: TESLA, INC. FOR: GRID ALTERNATIVES LAURA GRAY ALEX J. MORRIS ENERGY STORAGE POLICY ADVISOR SR. DIR, POLICY & REG. AFFAIRS CALIFORNIA SOLAR & STORAGE ASSOCIATION CALIFORNIA ENERGY STORAGE ALLIANCE TH ST, SUITE ALLSTON WAY, SUITE 210 OAKLAND, CA BERKELEY, CA FOR: CALIFORNIA SOLAR & STORAGE FOR: CALIFORNIA ENERGY STORGE ALLIANCE ASSOCIATION (CESA) GREGORY MORRIS DIRECTOR GREEN POWER INSTITUTE 2039 SHATTUCK AVENUE, STE 402 BERKELEY, CA FOR: GREEN POWER INSTITUTE Information Only PASCHELLE WHITE MRW & ASSOCIATES, LLC REGULATORY CASE COORDINATOR ONLY PACIFIC GAS AND ELECTRIC COMPANY ONLY, CA ONLY ONLY, CA BLAKE ELDER DANIEL W. DOUGLASS CLEAN ENERGY SPECIALIST ATTORNEY AT LAW EQ RESEARCH DOUGLASS & LIDDELL 401 HARRISON OAKS BLVD., STE PARK GRANADA, SUITE 209 CARY, NC CALABASAS, CA FOR: ALLIANCE FOR RETAIL ENERGY MARKETS AND DIRECT ACCESS CUSTOMER COALITION AMBER WYATT CASE ADMINISTRATION SR. ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 8631 RUSH STREET 2244 WALNUT GROVE AVE. G.O.1, RM 345E ROSEMEAD, CA ROSEMEAD, CA 91770

17 CPUC - Service Lists - A Page 3 of 5 7/11/2018 DAVID BALANDRAN DONALD C. LIDDELL SOUTHERN CALIFORNIA EDISON ATTORNEY 8631 RUSH STREET DOUGLASS & LIDDELL ROSEMEAD, CA ND AVENUE SAN DIEGO, CA LISA MCGHEE CENTRAL FILES OPERATIONS MGR. SAN DIEGO GAS AND ELECTRIC COMPANY SAN DIEGO AIRPORT PARKING CO CENTURY PARK COURT, CP31-E 2771 KURTZ ST. SAN DIEGO, CA SAN DIEGO, CA JENNIFER WRIGHT KELLEN C. GILL REGULATORY CASE MGR. REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK COURT, CP 31A SAN DIEGO, CA SAN DIEGO, CA MARC D. JOSEPH RACHAEL E. KOSS ATTORNEY ATTORNEY ADAMS BROADWELL JOSEPH & CARDOZA ADAMS BROADWELL JOSEPH & CARDOZO 601 GATEWAY BOULEVARD, SUITE GATEWAY BOULEVARD, SUITE 1000 SO. SAN FRANCISCO, CA SOUTH SAN FRANCISCO, CA FOR: CUE FOR: CUE ERIC BORDEN PASCHELLE WHITE ENERGY POLICY ANALYST CASE COORDINATOR THE UTILITY REFORM NETWORK PACIFIC GAS AND ELECTRIC COMPANY 785 MARKET STREET, STE BEALE STREET, RM 945 SAN FRANCISCO, CA SAN FRANCISCO, CA ROBERT EARLE CASE ADMINISTRATION 1388 HAIGHT ST., APT. 49 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA ONLY FOR: CUE ONLY, CA JESSICA TELLEZ JOHN KING ENERGY SUPPLY PROCEEDINGS LS POWER DEVELOPMENT, LLC PACIFIC GAS AND ELECTRIC COMPANY 5000 HOPYARD ROAD, SUITE 480 PO BOX PLEASANTON, CA SAN FRANCISCO, CA SANDEEP ARORA RACHEL BIRD VICE PRESIDENT, TRANSMISSION DIR - POLICY & BUS. DEVELOPMENT, WEST LS POWER DEVELOPMENT, LLC BORREGO SOLAR SYSTEMS, INC HOPYARD, ROAD, SUIT E ND STREET, SUITE 600 PLEASANTON, CA OAKLAND, CA PHILLIP MULLER DAVID PEFFER PRESIDENT ATTORNEY AT LAW SCD ENERGY SOLUTIONS BRAUN BLAISING SMITH WYNNE, P.C. 436 NOVA ALBION WAY 915 L STREET, SUITE 1480

18 CPUC - Service Lists - A Page 4 of 5 7/11/2018 SAN RAFAEL, CA SACRAMENTO, CA KEVIN WOODRUFF REGULATORY CLERK WOODRUFF EXPERT SERVICES BRAUN BLAISING SMITH WYNNE, PC TH STREET, SUITE L STREET, STE SACRAMENTO, CA SACRAMENTO, CA SCOTT BLAISING TAM HUNT, J.D. ATTORNEY CONSULTING ATTORNEY BRAUN BLAISING SMITH WYNNE, PC COMMUNITY RENEWABLE SOLUTIONS, LLC 915 L STREET, STE MOKU ST SACRAMENTO, CA PAHOA, HI FOR: GREEN POWER INSTITUTE State Service AMIN NOJAN BRIAN STEVENS ELECTRICITY PLANNING & POLICY BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA DAVID PECK KAJ PETERSON PRESIDENT PICKER ELECTRICITY PLANNING & POLICY BRANCH ROOM 4108 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA KARI SMITH KARIN M. HIETA INFRASTRUCTURE PLANNING AND PERMITTING B ELECTRICITY PLANNING & POLICY BRANCH AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MEGHAN O'BRIEN SHANNON O'ROURKE ELECTRICITY PLANNING & POLICY BRANCH COMMISSIONER PETERMAN AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA SONJA ZIAJA ELECTRICITY PLANNING & POLICY BRANCH AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA

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