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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company to Defer Consideration of Default Residential Time-Variant Pricing Until Its Next General Rate Case Phase 2 Proceeding, or in the Alternative for Approval of its Proposal for Default Residential Time-Variant Pricing and For Recovery of Incremental Expenditures Required for Implementation Application of Pacific Gas and Electric Company for Approval of its 2010 Rate Design Window Proposal for 2-Part Peak Time Rebate and Recovery of Incremental Expenditures Required for Implementation A (filed August 9, A (filed February 26, 2010 OPENING BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E IN RESPONSE TO FEBRUARY 7, 2012 RULING PART TWO OF TWO RESIDENTIAL RATE DESIGN BRUCE A. REED Attorney for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( bruce.reed@sce.com Dated: March 30, 2012 LIMS

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company to Defer Consideration of Default Residential Time-Variant Pricing Until Its Next General Rate Case Phase 2 Proceeding, or in the Alternative for Approval of its Proposal for Default Residential Time-Variant Pricing and For Recovery of Incremental Expenditures Required for Implementation Application of Pacific Gas and Electric Company for Approval of its 2010 Rate Design Window Proposal for 2-Part Peak Time Rebate and Recovery of Incremental Expenditures Required for Implementation A (filed August 9, A (filed February 26, 2010 OPENING BRIEF OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E IN RESPONSE TO FEBRUARY 7, 2012 RULING PART TWO OF TWO RESIDENTIAL RATE DESIGN Southern California Edison Company (SCE, a party to these consolidated Pacific Gas and Electric Company (PG&E proceedings, has a strong interest in the Commission s resolution of issues related to potential implementation of default time-variant pricing 1 for residential customers. 2 While the resolution of these issues will directly affect residential customers of 1 Time-variant pricing, as defined by Public Utilities Code Section 745(a(2 includes time-of-use (TOU rates, critical peak pricing, and real-time pricing but does not include programs that provide customers with discounts from standard tariff rates as an incentive to reduce consumption as certain times, including peak time rebates. TOU rates do not change from day to day, but instead divide a 24-hour period in each season into two or three periods with different rates applying to each period. 2 SCE has more than four million residential customers and is subject to requirements similar to PG&E s with respect to filing an application for default residential time-variant pricing pursuant to D

3 PG&E, the Commission s decision in this proceeding could be applied to modify Decision (D , which addressed the transition of SCE s residential customers to optional, mandatory, or default time-variant rate structures. The February 7, 2012 Joint Ruling of the Assigned Commissioner and Presiding Administrative Law Judges (Ruling posed questions to parties concerning (1 the Commission s authority to adopt default time-variant pricing for residential customers, and (2 the parties views of recommended future residential rate designs from 2012 through This brief provides SCE s comments on issue (2. SCE appreciates the opportunity to present its views on longer-term residential rate design and discuss the necessary means to achieve that vision. Because of current statutory restrictions, including the Commission s interpretation of restrictions imposed by Senate Bill (SB 695, SCE believes that any approach to changes in residential rate design must include statutory changes that are necessary to remedy the existing inequities and limitations on residential rate design. As such, SCE believes a residential rate design rulemaking may be an appropriate forum to provide long-term rate design guidance and to develop a roadmap to effectively achieve the benefits of dynamic pricing. Only then will the Commission be able to move toward implementation of residential time-variant pricing that will be voluntary, premised on well-informed choices among rate options that are understandable, fair, efficient and stable and that will provide incentives for demand response and energy conservation. Thus, while the Commission has the authority and could implement default time-variant residential rates, the Commission should not implement such rates at any point in the near future. I. VISION FOR FUTURE RESIDENTIAL RATE DESIGN Based on the response to Question 1, parties are to provide the following in response to Question 2 (to be filed separately per March 28, from ALJ Roscow: a. A table or matrix showing recommended residential rate designs for each year from 2012 through 2020, inclusive. Separate recommendations should be shown for every 2

4 currently available or proposed default, mandatory, or optional rate option for each year. b. Detailed support for each of the recommendations provided in response 2.a. Without significant relief from current policy and legal constraints, SCE does not anticipate recommending any major residential rate design structural changes over the period from 2012 until SCE s recommendation is to continue to offer as an overlay to the standard residential rate structure its Peak-Time Rebate (PTR, with time-variant TOU and dynamic pricing rates made available as optional rate structures. 3 SCE has proposed to reduce the baseline percentage allowance from 55 percent to 50 percent in Phase 2 of SCE s 2012 General Rate Case (GRC, Application In addition, SCE has proposed to collapse its five-tiered structure into 4 tiers and to implement separate baseline allowances for single-family and multi-family dwellings in that same proceeding. With respect to the standard residential rate structure, SCE will periodically revise baseline allowances in its future GRC proceedings based on changes in average residential consumption by climate zone. Moreover, SCE would plan to increase non-care usage rates for Tiers 1 and 2 and its existing residential customer charge by the percentage increase permitted under Section 739.9(a, subject to the limit in Section 739.9(b for the Tier 1 volumetric rate plus customer charge. 4 Unless statutory changes or changes to the Commission s interpretation of statutes are made, it is unlikely that an effective and meaningful default time-variant rate can be implemented. The current standard residential rate structure which must remain available as an optional rate under a default time-variant structure must be revised as part of an integrated review of the feasibility and reasonableness of mandatory or time-variant pricing. Given current 3 If the Commission finds that certain rate restrictions that led to a Peak Time Rebate (PTR structure do not apply to dynamic pricing rates, then a simple Critical Peak Pricing (aka PG&E s Peak Day Pricing overlay rate structure would be more effective. This PDP rate structure has a distinct advantage over the PTR rate structure in that it is easier rate customers to understand and it can be implemented with relatively little regard to the inefficiencies associated with the existing tiered rate structures. 4 While SB 695 permits increases to CARE Tier 1 and Tier 2 rates pursuant to annual percentage increases in benefits under the CalWORKS program, no such increases have been authorized since the enactment of SB 695. SCE does not anticipate any such future increases in its forecasts. 3

5 constraints on residential rate structures, upper-tiered rates unfairly absorb much of the cost increases assigned to the residential rate group. These constraints prevent the adoption of costbased rates in the standard residential rate structure. Until the current default residential rate structure is remedied, the Commission should not implement default or mandatory time-variant rates for residential customers because doing so would exacerbate the current rate design defects and result in further disproportionate increases to the upper-tiered rates. SCE believes an effective default TOU rate structure cannot be implemented any earlier than 2019 when certain restrictions on Tier 1 and Tier 2 rates created by SB 695 will expire. 5 At this time, to maintain customer choice, SCE supports an opt-in, tiered, TOU rate structure instead of a default time-variant rate structure. A. A Residential TOU Rate Structure Should Be Simple and Understandable The primary objective of a time-variant (TOU or dynamic pricing rate structure is to provide more accurate price signals to customers so as to affect and to inform customers use of electricity. As discussed below, the combination of required baseline quantities and increasing tiered rate structures has resulted in rates that are far from cost-of-service, which is the fundamental principle applied to rate design for all other non-residential customers. The Commission should first work to reduce the inequities resulting from the combination of tiered rate structures and statutory restrictions on increases to rates for usage in Tiers 1 and 2. Reducing or collapsing the tier differentials could allow for a non-tiered TOU rate that will be simpler for customers to understand and accept and will provide an equitable rate structure. Until that occurs, only complex, tiered TOU rates are available as options. Unfortunately, mass 5 See e.g., Section 739.9(a, which provides that [t]his subdivision shall become inoperative on January 1, 2019, unless a later enacted statute deletes or extends that date. 4

6 transfers of customers to these complex, tiered TOU structures would cause a great deal of customer confusion or even outrage regardless of the availability of bill protection. 6 B. A Non-Tiered, TOU Rate Structure Would Risk The Creation Of Significant Revenue Deficiencies In The Residential Rate Group In terms of customer understanding and acceptance, which the Commission has recognized as an important factor in the adoption of rate structures, typical TOU rates (such as those applied to generally more sophisticated non-residential customers avoid the complexity associated with residential tiered rate structures. Prior to the 2001 energy crisis, the residential rate structure was less complex than it is today with just two rate tiers, baseline and non-baseline, with a tier differential of only about 15 percent. As more tiers were adopted and the tiered rate differential expanded enormously with Tiers 4 and 5 rates becoming 200 to 300 percent above baseline rates, a non-tiered TOU rate structure became problematic. A non-tiered TOU rate structure designed to be revenue neutral to the residential rate group as a whole would provide sharply disparate bill impacts to customers previously served on a steeply tiered rate schedule, particularly when the ratio of upper tier to baseline rate levels are more than 2:1. Lower-usage customers would opt-out of the non-tiered TOU rate structure, preferring the tiered rate protections offered under the standard rate structure. The much smaller number of higher-usage customers, on the other hand, would realize significant bill reductions through migration to the non-tiered TOU rate structure without making any modifications to their load patterns. These bill reductions would result in a significant deficiency in revenues collected from residential customers as a whole. This deficiency would need to be recovered by increasing upper-tiered rates and to some extent Tiers 1 and 2 (subject to SB 695 constraints and 6 SCE has proposed an optional, two-tiered, TOU rate structure for residential customers in A that is designed to somewhat reduce these complexities. 5

7 by increasing the overall TOU rate levels. 7 These migrations and rate adjustments would require significant time and effort on the part of the customers and utilities alike and should be avoided. In an attempt to merge the cost-based seasonal and TOU pricing signals with the tiered rate conservation price signal and to address the structural benefit issue described above, utilities have had to develop tiered TOU rates that are quite complex. Forced migration to residential TOU rate structures with this level of complexity (default or otherwise concerns SCE and should simply not be implemented by the Commission. C. Current Rate Inequities and Policy Conflicts Should Be Resolved Before Implementing Default TOU Pricing The current default residential rate structure attempts to achieve several policy goals, including the following: a. Provide bill stability via increased baseline allowances in higher usage weather zones and summer periods; b. Promote conservation via a steeply tiered rate structure; c. Redistribute income via rate subsidies funding the CARE program and steeply tiered rates; and d. Subsidize and provide incentive to install solar generation via steeply-tiered rates. Commission policies and statutory requirements have created a large disparity between cost to serve and the rates actually paid by the highest and lowest usage residential customers. These policies and statutory requirements have resulted in a rate structure that is contrary to the Commission s own rate design guidance, which is to (1 to promote economically efficient decision-making by basing rates on marginal cost, and (2 provide stability, simplicity, and 7 For inter-class equity considerations, these deficiencies would necessarily have to be recovered through increases in residential rates only. 6

8 customer choice. 8 SCE estimates that its current five-tiered rate structure creates more than $600 million per year in intraclass subsidies compared to actual costs of service. This result has occurred because rates for Tiers 1 and 2 have been capped or constrained since 2001 and non-care rates for Tiers 3, 4 and 5 have received most of the revenue increasess for residential ratepayers over the period from 2001 to the present. This subsidy is illustrated in Figure I-1, below, which shows that customers with usage above approximately 600 kwh per month pay rates far above cost while lower usage customers pay rates far below cost. Figure I-1 Inequities Of The Current Tiered Residential Rate Structure The problem caused by the tiered rate structure will get worse in the future. Table I-1, below, forecasts residential rate levels as a result of the rate restrictions in SB 695 under assumed revenue requirement changes and annual rate changes in compliance with SB 695. Until 2019, the non-care tiered rate differentials continue to grow, as does the CARE discount. Beginning in 2019, certain rate restrictions currently applied to Tierr 1 and Tier 2 rates (both non-care and 8 See, e.g., Attachment H, Rate Design Guidance, D

9 CARE under SB 695 will be relaxed and that could result in a significant rate changes. 9 Thus, while the Commission is focused on how to implement dynamic rates for the residential rate group, it is far more important to address the standard residential rate structure that affects all residential customers. Table I-1 Example Residential Rates Non-CARE Tier CARE Tier As shown by Figure I-1 and Table I-1, above, the current residential rate structure is unsustainable. It will only get worse if cost-based TOU pricing is implemented, either by making such pricing mandatory or by making it the default rate structure. Some residential customers with usage in higher tiers would likely choose service under time-variant rates that could result in bill reductions while most residential customers whose usage remains in Tiers 1 and 2, would benefit by remaining on the current tiered rate structure. This would create a revenue deficiency within the residential rate group, requiring the deficiency to be recovered primarily from the customers paying the upper-tiered rates in the non-time-variant rate structure. This would further increase upper-tiered rates and increase the incentives for remaining uppertiered customers to choose TOU rates. 9 For example, the non-care Tier 1 rate may climb to 92.5% of the system average rate, non-care and CARE Tier 1 and Tier 2 rate levels are no longer tied to external indices, etc. 8

10 To adopt TOU pricing for residential customers on a large scale would add another layer of complexity if it also comports with the existing policy and statutory requirements as well as rate design objectives. For example, TOU rates should increase during the summer on-peak period when system demands are higher and cost to serve rises. However, Section 739 increases baseline allowances in the summer months due to higher average customer usage. Thus, while there is clearly more residential usage in the summer, the increased summer baseline allowance tends to reduce the rates paid by residential customers and promotes bill stability and affordability at the same time that the utility s cost to serve increases. These affordability concerns have also created a CARE program that also provides significant rate discounts that work against the policy of encouraging conservation. II. RECOMMENDATIONS SCE provides the following recommendations for the Commission s consideration and guidance in this and other future proceedings related to residential rate design. A. The Commission Should Focus On Achieving Meaningful Modifications To The Current Residential Rate Structure Before Implementing Any Significant Migration of Residential Customers to Time-Variant Pricing SCE recommends that the Commission continue indefinitely the default Peak Time Rebate (PTR structure and to make optional, tiered TOU rates available to residential customers until some progress is made to modify the current, flawed, tiered rate structures. Given the existing legal and policy restrictions which mandate a default tiered residential rate structure, any effort to migrate significant numbers of residential customers to an opt-in, time-variant TOU or dynamic pricing rate structure must be carefully scrutinized. A massive transfer of customers to a non-tiered TOU rate structures could result in significant revenue deficiencies, an overly 9

11 complex rate structure that would be difficult to implement, and would not be understood or accepted by customers. B. The Commission Should Continue To Place A Premium On Maintaining Customer Choice To achieve the goals outlined in D , significant participation and acceptance by residential customers of time-variant rates will be required. While the adoption of a default time-variant rate would move many residential customers in the direction intended by the Commission, it would also require significantly more marketing and operational resources to mitigate adverse impacts to customer-facing operations because a significant number of residential customers would opt-out of the default rate structure to return to their previous nontime-variant rate. 10 SCE recommends keeping time-variant rate structures optional for residential customers. By building tools enabled by smart meters and providing targeted campaigns and advertising to encourage customers to migrate onto a TOU rate, SCE can identify customers that would likely remain on the default time-variant rate without the unnecessary burdens and costs associated with moving all customers many of whom would not benefit by taking service on a timevariant rate structure. Theoretically, whether or not a program is default or opt-in, it should yield the same end-state adoption levels. An opt-in program with significant marketing, education and outreach will entice customers to join the program, rather than force them to do so. While an opt-in program will likely result in a lesser amount of adoption and load shift than a default or a mandatory program, there appears to be little or no near term need for additional demand response resources. This provides the opportunity for the Commission to take a holistic and 10 About 60 percent of the >200 kw commercial customers who were placed on a default CPP rate in October 2009 have opted out to a mandatory TOU rate schedule. 10

12 longer-term approach to implementation of reasonable and effective residential time-variant rate structures. In Phase 2 of SCE s 2012 GRC, SCE recommends an opt-in TOU rate structure for residential customers as best suited to the deployment of time-variant pricing. SCE also proposes an optional residential CPP rate structure with bill protection. SCE s existing residential default PTR rate structure will be evaluated in the summer of The deployment of smart meters has enabled the development of opt-in bill analysis tools that are scheduled to be deployed in As discussed above, because the current tiered rate structure does not correlate to cost to serve, lower-usage residential customers may not be able to reduce their bills under a time-variant pricing structure. It would not be a productive exercise to implement default time-variant residential rate structures which would cause masses of residential customers to then opt-out to the standard residential rate structure. C. A Broader Proceeding with Appropriate Stakeholders Creating a Roadmap Is Required to Effectively Achieve the Benefits of Dynamic Pricing Given the current stage of development, the Commission should first focus its efforts on attempting to modify the statutory restrictions and policies that underlie current tiered residential rates so that time-variant pricing structures can be properly implemented. To guide future GRC s and to bring California to a sustainable residential rate structure, the Commission should provide its guidance on how residential rate structures should be modified to create the possibility to implement effective time-variant pricing programs in the future. 11

13 SCE believes a broader proceeding dedicated to residential rate design involving all interested parties is appropriate at this time. Through this collaborative process, the Commission should develop long-range residential rate design guidance and produce a roadmap outlining the requirements necessary to reach the goals adopted by the Commission. Respectfully submitted, BRUCE A. REED /s/ Bruce A. Reed By: Bruce A. Reed Attorney for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( bruce.reed@sce.com March 30,

14 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 IN RESPONSE TO FEBRUARY 7, 2012 RULING - PART TWO OF TWO - RESIDENTIAL RATE DESIGN on all parties identified on the attached service list(s A & A Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an e- mail address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Commissioner(s or other addressee(s. ALJ Stephen Roscow 505 Van Ness Ave San Francisco, CA Commissioner Michael Peevey 505 Van Ness Ave San Francisco, CA Placing copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to all parties for those listed on the attached non- list. Directing Prographics to place the copies in properly addressed sealed envelopes and to deposit such envelopes in the United States mail with first-class postage prepaid to all parties. Executed this March 30, 2012, at Rosemead, California. /s/ Christina Andrea Sanchez Christina Andrea Sanchez Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

15 CPUC - Service Lists - A Page 1 of 4 3/30/2012 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR APPROVAL FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: MARCH 28, 2012 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties STEPHANIE CHEN BRUCE A. REED ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY THE GREENLINING INSTITUTE 2244 WALNUT GROVE AVENUE / PO BOX 800 ONLY ROSEMEAD, CA ONLY, CA FOR: SOUTHERN CALIFORNIA EDISON FOR: THE GREENLINING INSTITUTE DONALD C. LIDDELL GREGORY HEIDEN COUNSEL DOUGLASS & LIDDELL LEGAL DIVISION ND AVENUE ROOM 5039 SAN DIEGO, CA VAN NESS AVENUE FOR: CALIFORNIA ENERGY STORAGE SAN FRANCISCO, CA ALLIANCE; ICE ENERGY, INC.; DEBENHAM FOR: DRA ENERGY, LLC NORMAN J. FURUTA NINA SUETAKE ATTORNEY AT LAW THE UTILITY REFORM NETWORK FEDERAL EXECUTIVE AGENCIES 115 SANSOME STREET, SUITE MARKET STREET, ROOM 1744 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: FEDERAL EXECUTIVE AGENCIES THOMAS LONG NORA SHERIFF THE UTILITY REFORM NETWORK ALCANTAR & KAHL 115 SANSOME ST., STE NEW MONTGOMERY STREET, SUITE 1850 SAN FRANCISCO, CA SAN FRANCISCO, CA 94105

16 CPUC - Service Lists - A Page 2 of 4 3/30/2012 FOR: TURN FOR: ENERGY PRODUCERS AND USERS COALITION SHIRLEY A. WOO WILLIAM H. BOOTH PACIFIC GAS AND ELECTRIC COMPANY ALCANTAR & KAHL 77 BEALE STREET, MC B30A, PO BOX NEW MONTGOMERY STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION NORMAN J. FURUTA MELISSA W. KASNITZ FEDERAL EXECUTIVE AGENCIES CENTER FOR ACCESSIBLE TECHNOLOGY 1455 MARKET STREET, SUITE ADELINE STREET, STE. 220 SAN FRANCISCO, CA BERKELEY, CA FOR: FEDERAL EXECUTIVE AGENCIES FOR: CENTER FOR ACCESSIBLE TECHNOLOGY JAMIE MAULDIN DISABILITY RIGHTS ADVOCATES 2001 CNETER STREET, 3RD FLOOR BERKELEY, CA FOR: DISABILITY RIGHTS ADVOCATES Information Only MRW & ASSOCIATES, LLC ONLY ONLY, CA KHOJASTEH DAVOODI NAVY UTILITY RATES AND STUDIES OFFICE DEPARTMENT OF THE NAVY 1322 PATTERSON AVENUE SE WASHINGTON NAVY YARD, DC KEVIN SIMONSEN TODD CAHILL ENERGY MANAGEMENT SERVICES SAN DIEGO GAS & ELECTRIC COMPANY 646 E. 3RD AVENUE 8306 CENTURY PARK COURT, CP32D DURANGO, CO SAN DIEGO, CA CENTRAL FILES SUE MARA SAN DIEGO GAS AND ELECTRIC COMPANY CONSULTANT 8330 CENTURY PARK CT, CP32D, RM CP31-E RTO ADVISORS, LLC SAN DIEGO, CA SPRINGDALE WAY REDWOOD CITY, CA KASIA CRAIN KEITH COYNE CASE MGR - OPERATIONS PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B10B PO BOX , MC B10A SAN FRANCISCO, CA SAN FRANCISCO, CA MARILYN WALKER CALIFORNIA ENERGY MARKETS PACIFIC GAS AND ELECTRIC COMPANY 425 DIVISADERO STREET, SUITE BEALE STREET, B30A SAN FRANCISCO, CA SAN FRANCISCO, CA 94105

17 CPUC - Service Lists - A Page 3 of 4 3/30/2012 CASE ADMINISTRATION CHRIS KING PACIFIC GAS AND ELECTRIC COMPANY CHIEF REGULATORY OFFICER PO BOX : MC B9A EMETER CORPORATION SAN FRANCISCO, CA BRIDGEPOINTE PARKWAY, STE. 300 SAN MATEO, CA FOR: EMETER CORPORATION RYAN BRISCOE YOUNG ELIZABETH RASMUSSEN THE GREENLINING INSTITUTE REG. AND LEGAL COUNSEL 1918 UNIVERSITY AVENUE, 2ND FLOOR MARIN ENERGY AUTHORITY BERKELEY, CA LINCOLN AVENUE, SUITE 320 SAN RAFAEL, CA BARBARA R. BARKOVICH GAYATRI SCHILBERG BARKOVICH & YAP, INC. JBS ENERGY ROSEWOOD TERRACE 311 D STREET, SUITE A MENDOCINO, CA WEST SACRAMENTO, CA FOR: THE UTILITY REFORM NETWORK CAROLYN KEHREIN ANDREW B. BROWN ENERGY MANAGEMENT SERVICES ELLISON SCHNEIDER & HARRIS, L.L.P CELEBRATION WAY 2600 CAPITOL AVENUE, SUITE 400 WOODLAND, CA SACRAMENTO, CA RICHARD MCCANN KAREN NORENE MILLS ASPEN ENVIRONMENTAL GROUP ASSOC. COUNSEL 8801 FOLSOM BOULEVARD, SUITE 290 CALIFORNIA FARM BUREAU FEDERATION SACRAMENTO, CA RIVER PLAZA DRIVE SACRAMENTO, CA State Service NIKI BAWA CHRISTOPHER DANFORTH CALIFORNIA PUBLIC UTILITIES COMMISSION ONLY ELECTRICITY PRICING AND CUSTOMER PROGRAM ONLY, CA ROOM VAN NESS AVENUE SAN FRANCISCO, CA DEXTER E. KHOURY LEE-WHEI TAN ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4209 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA LOUIS M. IRWIN ROBERT LEVIN ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4209 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA

18 CPUC - Service Lists - A Page 4 of 4 3/30/2012 STEPHEN C. ROSCOW DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM VAN NESS AVENUE SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

19 CPUC - Service Lists - A Page 1 of 3 3/30/2012 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR APPROVAL FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: MARCH 28, 2012 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties STEPHANIE CHEN BRUCE A. REED ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY THE GREENLINING INSTITUTE 2244 WALNUT GROVE AVENUE / PO BOX 800 ONLY ROSEMEAD, CA ONLY, CA FOR: SOUTHERN CALIFORNIA EDISON FOR: THE GREENLINING INSTITUTE DONALD C. LIDDELL GREGORY HEIDEN COUNSEL DOUGLASS & LIDDELL LEGAL DIVISION ND AVENUE ROOM 5039 SAN DIEGO, CA VAN NESS AVENUE FOR: CALIFORNIA ENERGY STORAGE SAN FRANCISCO, CA ALLIANCE; ICE ENERGY, INC.; DEBENHAM FOR: DRA - DIVISION OF RATEPAYER ENERGY, LLC ADVOCATES THOMAS LONG NORA SHERIFF THE UTILITY REFORM NETWORK ALCANTAR & KAHL 115 SANSOME ST., STE NEW MONTGOMERY STREET, SUITE 1850 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: ENERGY PRODUCES AND USERS COALITION WILLIAM H. BOOTH NORMAN J. FURUTA ALCANTAR & KAHL FEDERAL EXECUTIVE AGENCIES 33 NEW MONTGOMERY STREET, STE MARKET STREET, SUITE 1744 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: FEDERAL EXECUTIVE AGENCIES

20 CPUC - Service Lists - A Page 2 of 3 3/30/2012 ASSOCIATION SHIRLEY A. WOO JAMIE MAULDIN ATTORNEY AT LAW DISABILITY RIGHTS ADVOCATES PACIFIC GAS AND ELECTRIC COMPANY 2001 CNETER STREET, 3RD FLOOR PO BOX 7442, MC B30A BERKELEY, CA SAN FRANCISCO, CA FOR: DISABILITY RIGHTS ADVOCATES FOR: PACIFIC GAS AND ELECTRIC COMPANY Information Only MRW & ASSOCIATES, LLC ONLY ONLY, CA KHOJASTEH DAVOODI NAVY UTILITY RATES AND STUDIES OFFICE DEPARTMENT OF THE NAVY 1322 PATTERSON AVENUE SE WASHINGTON NAVY YARD, DC KEVIN SIMONSEN TODD CAHILL ENERGY MANAGEMENT SERVICES SAN DIEGO GAS & ELECTRIC COMPANY 646 E. 3RD AVENUE 8306 CENTURY PARK COURT, CP32D DURANGO, CO SAN DIEGO, CA CENTRAL FILES KASIA CRAIN SAN DIEGO GAS AND ELECTRIC COMPANY CASE MGR - OPERATIONS 8330 CENTURY PARK CT, CP32D, RM CP31-E PACIFIC GAS AND ELECTRIC COMPANY SAN DIEGO, CA PO BOX , MC B10A SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS CASE ADMINISTRATION 425 DIVISADERO STREET, SUITE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA PO BOX : MC B9A SAN FRANCISCO, CA JANET LIU RYAN B. YOUNG PACIFIC GAS AND ELECTRIC COMPANY THE GREENLINING INSTITUTE PO BOX ; MC B9A 1918 UNIVERSITY AVENUE, SECOND FLOOR SAN FRANCISCO, CA BERKELEY, CA BARBARA R. BARKOVICH CAROLYN KEHREIN BARKOVICH & YAP, INC. ENERGY MANAGEMENT SERVICES ROSEWOOD TERRACE 2602 CELEBRATION WAY MENDOCINO, CA WOODLAND, CA KAREN NORENE MILLS ASSOC. COUNSEL CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO, CA State Service

21 CPUC - Service Lists - A Page 3 of 3 3/30/2012 NIKI BAWA DEXTER E. KHOURY CALIFORNIA PUBLIC UTILITIES COMMISSION ONLY ELECTRICITY PRICING AND CUSTOMER PROGRAM ONLY, CA ROOM VAN NESS AVENUE SAN FRANCISCO, CA DONALD J. LAFRENZ LEE-WHEI TAN MARKET STRUCTURE, COSTS AND NATURAL GAS ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA LOUIS M. IRWIN STEPHEN C. ROSCOW ELECTRICITY PRICING AND CUSTOMER PROGRAM DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 4209 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

22 CPUC - Service Lists - A Page 1 of 4 3/30/2012 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - TO DEFER CONS FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: MARCH 28, 2012 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties STEPHANIE CHEN BRUCE A. REED ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY THE GREENLINING INSTITUTE 2244 WALNUT GROVE AVENUE / PO BOX 800 ONLY ROSEMEAD, CA ONLY, CA FOR: SOUTHERN CALIFORNIA EDISON FOR: THE GREENLINING INSTITUTE DONALD C. LIDDELL GREGORY HEIDEN COUNSEL DOUGLASS & LIDDELL LEGAL DIVISION ND AVENUE ROOM 5039 SAN DIEGO, CA VAN NESS AVENUE FOR: CALIFORNIA ENERGY STORAGE SAN FRANCISCO, CA ALLIANCE; ICE ENERGY, INC.; DEBENHAM FOR: DRA ENERGY, LLC NORMAN J. FURUTA NINA SUETAKE ATTORNEY AT LAW THE UTILITY REFORM NETWORK FEDERAL EXECUTIVE AGENCIES 115 SANSOME STREET, SUITE MARKET STREET, ROOM 1744 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: FEDERAL EXECUTIVE AGENCIES THOMAS LONG NORA SHERIFF THE UTILITY REFORM NETWORK ALCANTAR & KAHL 115 SANSOME ST., STE NEW MONTGOMERY STREET, SUITE 1850 SAN FRANCISCO, CA SAN FRANCISCO, CA 94105

23 CPUC - Service Lists - A Page 2 of 4 3/30/2012 FOR: TURN FOR: ENERGY PRODUCERS AND USERS COALITION SHIRLEY A. WOO WILLIAM H. BOOTH PACIFIC GAS AND ELECTRIC COMPANY ALCANTAR & KAHL 77 BEALE STREET, MC B30A, PO BOX NEW MONTGOMERY STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION NORMAN J. FURUTA MELISSA W. KASNITZ FEDERAL EXECUTIVE AGENCIES CENTER FOR ACCESSIBLE TECHNOLOGY 1455 MARKET STREET, SUITE ADELINE STREET, STE. 220 SAN FRANCISCO, CA BERKELEY, CA FOR: FEDERAL EXECUTIVE AGENCIES FOR: CENTER FOR ACCESSIBLE TECHNOLOGY JAMIE MAULDIN DISABILITY RIGHTS ADVOCATES 2001 CNETER STREET, 3RD FLOOR BERKELEY, CA FOR: DISABILITY RIGHTS ADVOCATES Information Only MRW & ASSOCIATES, LLC ONLY ONLY, CA KHOJASTEH DAVOODI NAVY UTILITY RATES AND STUDIES OFFICE DEPARTMENT OF THE NAVY 1322 PATTERSON AVENUE SE WASHINGTON NAVY YARD, DC KEVIN SIMONSEN TODD CAHILL ENERGY MANAGEMENT SERVICES SAN DIEGO GAS & ELECTRIC COMPANY 646 E. 3RD AVENUE 8306 CENTURY PARK COURT, CP32D DURANGO, CO SAN DIEGO, CA CENTRAL FILES SUE MARA SAN DIEGO GAS AND ELECTRIC COMPANY CONSULTANT 8330 CENTURY PARK CT, CP32D, RM CP31-E RTO ADVISORS, LLC SAN DIEGO, CA SPRINGDALE WAY REDWOOD CITY, CA KASIA CRAIN KEITH COYNE CASE MGR - OPERATIONS PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B10B PO BOX , MC B10A SAN FRANCISCO, CA SAN FRANCISCO, CA MARILYN WALKER CALIFORNIA ENERGY MARKETS PACIFIC GAS AND ELECTRIC COMPANY 425 DIVISADERO STREET, SUITE BEALE STREET, B30A SAN FRANCISCO, CA SAN FRANCISCO, CA 94105

24 CPUC - Service Lists - A Page 3 of 4 3/30/2012 CASE ADMINISTRATION CHRIS KING PACIFIC GAS AND ELECTRIC COMPANY CHIEF REGULATORY OFFICER PO BOX : MC B9A EMETER CORPORATION SAN FRANCISCO, CA BRIDGEPOINTE PARKWAY, STE. 300 SAN MATEO, CA FOR: EMETER CORPORATION RYAN BRISCOE YOUNG ELIZABETH RASMUSSEN THE GREENLINING INSTITUTE REG. AND LEGAL COUNSEL 1918 UNIVERSITY AVENUE, 2ND FLOOR MARIN ENERGY AUTHORITY BERKELEY, CA LINCOLN AVENUE, SUITE 320 SAN RAFAEL, CA BARBARA R. BARKOVICH GAYATRI SCHILBERG BARKOVICH & YAP, INC. JBS ENERGY ROSEWOOD TERRACE 311 D STREET, SUITE A MENDOCINO, CA WEST SACRAMENTO, CA FOR: THE UTILITY REFORM NETWORK CAROLYN KEHREIN ANDREW B. BROWN ENERGY MANAGEMENT SERVICES ELLISON SCHNEIDER & HARRIS, L.L.P CELEBRATION WAY 2600 CAPITOL AVENUE, SUITE 400 WOODLAND, CA SACRAMENTO, CA RICHARD MCCANN KAREN NORENE MILLS ASPEN ENVIRONMENTAL GROUP ASSOC. COUNSEL 8801 FOLSOM BOULEVARD, SUITE 290 CALIFORNIA FARM BUREAU FEDERATION SACRAMENTO, CA RIVER PLAZA DRIVE SACRAMENTO, CA State Service NIKI BAWA CHRISTOPHER DANFORTH CALIFORNIA PUBLIC UTILITIES COMMISSION ONLY ELECTRICITY PRICING AND CUSTOMER PROGRAM ONLY, CA ROOM VAN NESS AVENUE SAN FRANCISCO, CA DEXTER E. KHOURY LEE-WHEI TAN ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4209 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA LOUIS M. IRWIN ROBERT LEVIN ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4209 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA

25 CPUC - Service Lists - A Page 4 of 4 3/30/2012 STEPHEN C. ROSCOW DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM VAN NESS AVENUE SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

26 CPUC - Service Lists - A Page 1 of 3 3/30/2012 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - TO DEFER CONS FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: MARCH 28, 2012 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties STEPHANIE CHEN BRUCE A. REED ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY THE GREENLINING INSTITUTE 2244 WALNUT GROVE AVENUE / PO BOX 800 ONLY ROSEMEAD, CA ONLY, CA FOR: SOUTHERN CALIFORNIA EDISON FOR: THE GREENLINING INSTITUTE DONALD C. LIDDELL GREGORY HEIDEN COUNSEL DOUGLASS & LIDDELL LEGAL DIVISION ND AVENUE ROOM 5039 SAN DIEGO, CA VAN NESS AVENUE FOR: CALIFORNIA ENERGY STORAGE SAN FRANCISCO, CA ALLIANCE; ICE ENERGY, INC.; DEBENHAM FOR: DRA - DIVISION OF RATEPAYER ENERGY, LLC ADVOCATES THOMAS LONG NORA SHERIFF THE UTILITY REFORM NETWORK ALCANTAR & KAHL 115 SANSOME ST., STE NEW MONTGOMERY STREET, SUITE 1850 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: ENERGY PRODUCES AND USERS COALITION WILLIAM H. BOOTH NORMAN J. FURUTA ALCANTAR & KAHL FEDERAL EXECUTIVE AGENCIES 33 NEW MONTGOMERY STREET, STE MARKET STREET, SUITE 1744 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: FEDERAL EXECUTIVE AGENCIES

27 CPUC - Service Lists - A Page 2 of 3 3/30/2012 ASSOCIATION SHIRLEY A. WOO JAMIE MAULDIN ATTORNEY AT LAW DISABILITY RIGHTS ADVOCATES PACIFIC GAS AND ELECTRIC COMPANY 2001 CNETER STREET, 3RD FLOOR PO BOX 7442, MC B30A BERKELEY, CA SAN FRANCISCO, CA FOR: DISABILITY RIGHTS ADVOCATES FOR: PACIFIC GAS AND ELECTRIC COMPANY Information Only MRW & ASSOCIATES, LLC ONLY ONLY, CA KHOJASTEH DAVOODI NAVY UTILITY RATES AND STUDIES OFFICE DEPARTMENT OF THE NAVY 1322 PATTERSON AVENUE SE WASHINGTON NAVY YARD, DC KEVIN SIMONSEN TODD CAHILL ENERGY MANAGEMENT SERVICES SAN DIEGO GAS & ELECTRIC COMPANY 646 E. 3RD AVENUE 8306 CENTURY PARK COURT, CP32D DURANGO, CO SAN DIEGO, CA CENTRAL FILES KASIA CRAIN SAN DIEGO GAS AND ELECTRIC COMPANY CASE MGR - OPERATIONS 8330 CENTURY PARK CT, CP32D, RM CP31-E PACIFIC GAS AND ELECTRIC COMPANY SAN DIEGO, CA PO BOX , MC B10A SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS CASE ADMINISTRATION 425 DIVISADERO STREET, SUITE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA PO BOX : MC B9A SAN FRANCISCO, CA JANET LIU RYAN B. YOUNG PACIFIC GAS AND ELECTRIC COMPANY THE GREENLINING INSTITUTE PO BOX ; MC B9A 1918 UNIVERSITY AVENUE, SECOND FLOOR SAN FRANCISCO, CA BERKELEY, CA BARBARA R. BARKOVICH CAROLYN KEHREIN BARKOVICH & YAP, INC. ENERGY MANAGEMENT SERVICES ROSEWOOD TERRACE 2602 CELEBRATION WAY MENDOCINO, CA WOODLAND, CA KAREN NORENE MILLS ASSOC. COUNSEL CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO, CA State Service

28 CPUC - Service Lists - A Page 3 of 3 3/30/2012 NIKI BAWA DEXTER E. KHOURY CALIFORNIA PUBLIC UTILITIES COMMISSION ONLY ELECTRICITY PRICING AND CUSTOMER PROGRAM ONLY, CA ROOM VAN NESS AVENUE SAN FRANCISCO, CA DONALD J. LAFRENZ LEE-WHEI TAN MARKET STRUCTURE, COSTS AND NATURAL GAS ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA LOUIS M. IRWIN STEPHEN C. ROSCOW ELECTRICITY PRICING AND CUSTOMER PROGRAM DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 4209 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS