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 consider policy and implementation refinements to the Energy Storage Procurement Framework and Design Program (D , D ) and related Action Plan of the California Energy Storage Roadmap. Rulemaking (Filed March 26, 2015) SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS ON ASSIGNED COMMISSIONER AND ASSIGNED ADMINISTRATIVE LAW JUDGE S SCOPING MEMO AND RULING SEEKING PARTY COMMENTS WILLIAM V. WALSH AMBER DEAN WYATT Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Amber.Wyatt@sce.com Dated: February 19, 2016 LIMS

2 SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS ON ASSIGNED COMMISSIONER AND ASSIGNED ADMINISTRATIVE LAW JUDGE S SCOPING MEMO AND RULING SEEKING PARTY COMMENTS TABLE OF CONTENTS Section Title Page I. INTRODUCTION...1 II. REPLY COMMENTS...3 A. The Commission Should Not Increase Energy Storage Procurement Targets The Current Procurement Targets Are Already Transforming the Energy Storage Market The Commission Has Opened a New Rulemaking with the Express Purpose of Addressing System Needs In Light of Senate Bill 350 and Developing an Integrated Resource Plan...4 B. A Set-Aside for Particular Eligible Technologies or Applications Is Inappropriate and Inconsistent With the Energy Storage Procurement Framework...5 C. Targets Must Be Equalized Amongst All LSEs Before Equitable Allocation of Energy Storage Credit Can Be Achieved The Commission Should Reject DACC/AReM s Flawed Proposal Once Targets Are Equalized Amongst All LSEs, Allocation of Credit for Storage Procured on Behalf of All Customers Is a Simple Matter Stranded Cost Recovery and PCIA is More Complex and Would Benefit from a Workshop...11 D. SCE Continues to Support a Broad Definition of Eligible Energy Storage Technologies...12 E. There Is Wide Agreement That Multi-Use and Community Storage Applications Raise Complex Issues Which Would Benefit From Workshops...12 F. The Commission Should Reject an Overly Broad Definition of Station Load...12 III. CONCLUSION...14 i

3 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to consider policy and implementation refinements to the Energy Storage Procurement Framework and Design Program (D , D ) and related Action Plan of the California Energy Storage Roadmap. Rulemaking (Filed March 26, 2015) SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS ON ASSIGNED COMMISSIONER AND ASSIGNED ADMINISTRATIVE LAW JUDGE S SCOPING MEMO AND RULING SEEKING PARTY COMMENTS I. INTRODUCTION Pursuant to the California Public Utilities Commission s ( Commission ) Rules of Practice and Procedure and the Assigned Commissioner and Assigned Administrative Law Judge s Scoping Memo and Ruling Seeking Comments dated January 5, 2016 ( Scoping Memo ), Southern California Edison Company ( SCE ) hereby submits its reply to comments on Track 2 Issues. 1 Consistent with its opening comments and its reply comments herein, SCE asks the Commission to: 1 Thirty parties filed opening comments in addition to SCE: Alliance of Automobile Manufacturers and American Honda Co. ( Alliance ); Alliance for Retail Energy Markets and the Direct Access Customer Coalition ( DACC/AReM ); Association of California Water Agencies; Bison Peak Pumped Storage; Brookfield; California Independent System Operator ( CAISO ); California Hydrogen Business Council; Calpine; Marin Clean Energy and City of Lancaster; California Energy Storage Alliance ( CESA ); Clean Coalition; California Large Energy Consumers Association ( CLECA ); Eagle Crest Energy; EDF Renewable Energy Inc.; Environmental Defense Fund Continued on the next page 1

4 Reject parties requests to increase energy storage procurement targets because the Commission s market transformation goals are being achieved, and no need determination has been made; Uphold the Commission s previous determination that procurement set-asides for particular technologies or applications are not compatible with the Commission s market transformation goals based on technology neutral procurement; Reject DACC/AReM s flawed proposal to track and allocate energy storage procurement costs; Adopt SCE s proposal to establish uniform targets for all Load Serving Entities ( LSEs ), including the investor-owned utilities ( IOUs ), Direct Access ( DA ) Energy Service Providers ( ESPs ) and Community Choice Aggregators ( CCAs ), and then equitably allocate the costs and benefits of IOU energy storage procurement done on behalf of the system; Hold workshops concerning: (1) the Power Charge Indifference Adjustment ( PCIA ) and the recovery of stranded costs of energy storage procurement on behalf of bundled customers; (2) multiple-use energy storage applications; and (3) community storage; Include V1G, or managed charging, as an eligible energy storage technology; and Reject parties overly broad definition of station load and ensure that similarly situated customers are treated similarly with respect to station power determinations. Continued from the previous page ( EDF ); Green Power Institute ( GPI ); Ice Energy; LS Power; Natural Resource Defense; Office of Ratepayer Advocates ( ORA ); Pacific Gas and Electric Company ( PG&E ); Powertree Services, Inc.; San Diego County Water Authority; San Diego Gas & Electric Company ( SDG&E ); Shell Energy North America; Sierra Club; Southern California Gas Company; The Utility Reform Network ( TURN ); and the Western Power Trading Forum ( WPTF ). 2

5 II. REPLY COMMENTS A. The Commission Should Not Increase Energy Storage Procurement Targets In their opening comments, Sierra Club and CESA argue for up to nearly a four-fold increase in the current energy storage procurement targets. 2 In contrast, San Diego Gas & Electric ( SDG&E ), Pacific Gas and Electric (PG&E), the Office of Ratepayer Advocates ( ORA ), The Utility Reform Network ( TURN ), Calpine, the California Large Energy Consumer Association ( CLECA ), and the Direct Access Customer Coalition and the Alliance for Retail Energy Markets ( DACC/AReM ) all maintain that it is premature to consider increasing or revising energy storage procurement targets at this time. 3 SCE agrees that it would be inappropriate to raise the energy storage procurement targets because (1) the Commission s goal of market transformation is already being achieved with current targets; and (2) this rulemaking is not the appropriate venue for determining least-cost, integrated resource planning solutions. SCE urges the Commission to reject CESA s and Sierra Club s proposals. 1. The Current Procurement Targets Are Already Transforming the Energy Storage Market As noted by SCE and other parties in Opening Comments, the Commission initially established procurement targets in Decision ( D. ) to support the goal of market transformation. 4 Therefore, in assessing targets, the Commission should first consider whether adequate progress is being made in transforming the energy storage market. As demonstrated by the IOUs successful progress to-date, the market is indeed transforming at a very rapid pace. 2 See Sierra Club Opening Comments at 2; CESA Opening Comments at See SDG&E Opening Comments at 2; PG&E Opening Comments at 1-2; ORA Opening Comments at 1-3; TURN Opening Comments at 5; Calpine Opening Comments at 1-2; CLECA Opening Comments at 2; DACC/AReM Opening Comments at See D at 7. 3

6 All IOUs are in compliance with their first biennial procurement targets, and SCE is well ahead of the pace required by those targets. Because market transformation is already underway, increasing or revising procurement targets is not necessary and should be avoided. 2. The Commission Has Opened a New Rulemaking with the Express Purpose of Addressing System Needs In Light of Senate Bill 350 and Developing an Integrated Resource Plan In arguing for higher targets, Sierra Club and CESA cite Senate Bill ( SB ) 350 and the benefits provided by storage for renewable integration and GHG reduction to further California s climate change goals. SCE supports the effort to accomplish the state s climate change goals, however, this proceeding is not the appropriate venue to determine which resources are needed to achieve state climate change goals, or integrate increased renewable generation due to SB 350, if such needs exist. Rather, the Commission recently opened a new Integrated Resource Plan ( IRP ) rulemaking with the express purpose of determining system needs in light of SB 350 and the most efficient and cost-effective means to achieve the State s GHG goals. 5 CESA and Sierra Club prejudge the outcome of that proceeding by presuming a specific resource need before the Commission has even held a prehearing conference in that proceeding much less undertaken any analysis. 6 Until the Commission has determined in the IRP proceeding that such needs exist, the Commission should not mandate additional need based procurement in the Energy Storage OIR. Further, while this proceeding should not presume a resource need in general, it should also not presume the need for energy storage in particular. Rather, identifying the types of resources needed to facilitate renewable integration and the State s GHG goals should be 5 On Feb. 11, 2016, the Commission approved R to establish the 2016 Long Term Procurement Plan (LTPP) proceeding, including to develop an electricity IRP framework in accordance with SB 350 and to coordinate and refine LTPP requirements. 6 Studies that have not been fully vetted by parties and the Commission are not sufficient grounds for an additional procurement mandate. 4

7 considered in the IRP OIR. In that proceeding, energy storage and all other resource technologies can be evaluated together for their ability to support and further California s climate goals in a cost-effective manner. Implementation of identified energy storage needs, if any, can then be coordinated with this proceeding. B. A Set-Aside for Particular Eligible Technologies or Applications Is Inappropriate and Inconsistent With the Energy Storage Procurement Framework A number of parties requested set-aside targets for particular technologies or energy storage applications. 7 SCE urges the Commission to reject such requests, which are contrary to the Commission s market transformation goals and technology neutrality. In establishing the Energy Storage Procurement Framework, the Commission specifically considered and rejected the creation of procurement set-asides or carve outs, stating: Adhering to strict targets or carve outs may inappropriately or unfairly advantage or disadvantage specific participants. For this reason, we do not find it appropriate to establish sub-buckets such as ancillary services and load duration. Such subbuckets are not compatible with market transformation goals based on technology neutral procurement. 8 The reasoning used by the Commission in that decision remains sound today: procurement carve outs are likely to only benefit specific developers and vendors. Conversely, flexible, technologyneutral procurement will encourage market transformation while maximizing customer value. 7 CAISO Opening Comments at 4 (recommending consideration of targets specifically for pumped storage); CESA Opening Comments at 15 and (supporting specific targets for pumped storage as well as community storage). 8 D at 39 (emphasis added). 5

8 C. Targets Must Be Equalized Amongst All LSEs Before Equitable Allocation of Energy Storage Credit Can Be Achieved 1. The Commission Should Reject DACC/AReM s Flawed Proposal DACC/AReM expresses concern about parity between customers of ESPs/CCAs and customers of IOUs. 9 SCE shares this concern. Indeed, SCE has consistently argued that all LSEs should have the same target expressed as a percentage of peak load. That said, DACC/AReM s proposal to address this concern does not ensure customer indifference at all, and instead perpetuates the discrepancy in storage mandates between customers of IOUs and customers of ESPs/CCAs. DACC/AReM proposes to leave unchanged the current discrepancy in nominal targets, in which customers of ESPs/CCAs have a target of 1% of peak load and customers of IOUs have a fixed MW target that equates to about 2.5% of their forecasted peak load. 10 Rather than align all LSEs targets to be the same percentage of peak load, DACC/AReM proposes to require all LSEs (and the Commission) to continuously track storage procurement for all LSEs against a common percentage of peak load metric. The ESPs/CCAs would then receive credit for tracking purposes for their share of storage procured by IOUs on behalf of all customers. If the tracking mechanism ever indicates parity has been achieved, i.e., the tracking mechanism indicates ESPs/CCAs have procured equal to or greater than the peak load percentage target faced by IOUs, DACC/AReM suggests that their customers no longer be required to pay for the costs of energy storage from which they continue to benefit. The Commission should reject DACC/AReM s self-serving proposal. Their proposal would allow inequity to exist, so long as that inequity favors customers of ESPs/CCAs. DACC/AReM s proposal maintains the discrepancy in targets when it favors customers of 9 DACC/AReM Opening Comments at This percentage would change should departing load levels increase. 6

9 ESPs/CCAs, but then switches to a methodology that mandates parity 11 when the discrepancy favors customers of IOUs. This heads I win, tails you lose approach to policymaking is patently unfair. Table II-1 below illustrates how DACC/AReM s proposal perpetuates non-parity rather than remedies it. This table contains data provided by DACC/AReM, 12 with an additional column added to reflect statewide values. Note that although DACC/AReM demands immediate mitigation for ESPs in SCE s territory, on a statewide basis, by DACC/AReM s own calculations, the statewide obligation of ESPs is only 2.02%, still well below that of the IOUs. Table II-1 PG&E SCE SDG&E Statewide 1 IOU Target As % 2020 Peak Load 2.30% 2.50% 2.50% 2 DA Cap in GWh 9,520 11,710 3,562 24,792 3 ESP 1% Target in GWh ESP 1% Target in MW Total MW Associated with Non-Bypassable Charges DA MW Share of Non-Bypassable Charges ESP Target Plus DA Non-Bypassable Charges (MW) Total DA Storage Obligation in Percent 1.10% 2.80% 1.80% 2.02% Additionally, if the DACC/AReM proposal is implemented to require SCE to allocate some storage credit to ESPs, the statewide ESP obligation would diminish even further. Under DACC/AReM s proposal, the statewide ESP obligation may remain well under the IOU target, and can never exceed it. Furthermore, DACC/AReM suggests that once parity as they have defined it has been achieved, ESP customers should no longer be required to pay for the costs of energy storage from which they continue to benefit. This is inappropriate. Energy storage projects that 11 As discussed in more detail below, allowing DA and CCA customers to cease paying for the energy storage that continues to benefit them also fails to achieve parity and swings the pendulum too far in the favor of DA/CCA customers. 12 See DACC/AReM Opening Comments at 4. 7

10 are eligible for recovery through delivery rates (i.e. Distribution, which also collects the costs of the Self Generation Incentive Program ( SGIP ) and Permanent Load Shifting ( PLS ) programs, and the New System Generation charges) are, by definition, projects that provide benefits to all delivery customers. The Commission reaffirmed this notion in D when authorizing additional Cost Allocation Mechanism ( CAM ) procurement to meet local capacity requirements in the West Los Angeles Basin and Moorpark regions, stating that because the newly procured generation, which included energy storage, is needed to meet local or system area reliability needs for the benefit of all customers in the IOU s service area, each customer must pay their fair share for the benefits that flow to them. 13 DACC/AReM s refusal to acknowledge those benefits 14 should not relieve DA customers from their legislatively-mandated obligation 15 to pay for their share of CAM-eligible energy storage costs. As such, DACC/AReM s proposal to eliminate the recovery of storage procurement costs through nonbypassable charges should be rejected. Stated simply, the target methodology established in D creates a discrepancy in nominal targets that is assumed to be mitigated by non-bypassable charges that accrue to unbundled customers to cover the costs of storage procured by the IOU on behalf of all customers. This method creates uncertainty as to whether parity will be achieved. If DACC/AReM believes the lower target for ESPs/CCAs in the current framework is appropriate, with its inherent uncertainty, DACC/AReM must also accept the uncertainty that the ultimate outcome may be less favorable than it predicted. Alternatively, if parity (and more specifically, certainty of parity) is the goal (as SCE has long argued), there is a simple and straightforward solution: establish uniform targets, and a system for allocating both cost and benefit to ESPs/CCAs for storage procured by IOUs on behalf of all customers. DACC/AReM invited the 13 D at 106 (emphasis added). 14 DACC/AReM Opening Comments at Public Utilities Code Section 365.1(c)(2)(A)-(B). 8

11 IOUs to propose an alternative to its proposal. 16 SCE details what it maintains is a simpler, and more equitable proposal below. 2. Once Targets Are Equalized Amongst All LSEs, Allocation of Credit for Storage Procured on Behalf of All Customers Is a Simple Matter With uniform targets established, a process could mirror the cost CAM, which applies to capacity procured by IOUs on behalf of all customers to meet a defined system need. This CAM-like process is possible only if uniform targets are established. The CAM process allocates RA credit, the cost of that capacity, and all net energy benefits. This proposed process would allocate storage credit, the cost of that storage capacity, and the net energy benefits. 17 Below, SCE clarifies the following details regarding its proposal. All Load Serving Entities would receive the same target (e.g., 2.5% of peak load). This is a critical, must-have component to this proposal. If the targets remain unequal between different classes of LSEs, this entire proposal no longer maintains indifference among customers. This proposal would apply to storage procured by IOUs on behalf of all customers. Examples of such procurement include the following: Capacity procured by IOUs to meet a defined system need (e.g. capacity procured by SCE through the LCR RFO). Storage procured by IOUs to provide a distribution reliability function 16 DACC/AReM Opening Comments at SCE and DACC/AReM have already agreed to a method for applying the CAM to energy storage resources in the context of the 2013 Local Capacity Requirements Request for Offers. See A , Joint Motion of Southern California Edison Company and Alliance for Retail Energy Markets and Direct Access Customer Coalition to Enter A Document Into the Record (March 27, 2015) (seeking to admit into the record the Memo of Understanding between SCE and DACC/AReM with respect to cost allocation mechanism issues in the LCR RFO proceedings, including application of the CAM to energy storage resources). 9

12 Storage funded through a program funded by all customers (e.g., SGIP). Any other situation in which the IOU is acting as a procurement agent on behalf of all customers. For storage procured through one of the above mechanisms, storage credit, storage costs and any net energy benefits from the storage would be allocated according to load share by service territory, much the way RA credit and capacity costs are allocated in the CAM process today. For allocation of credit: ESPs/CCAs would receive a percentage of the total storage credit equal to their percentage of load. (The specific percentages used for the CAM process would be used here as well.) For allocation of cost: cost allocation for these procurement activities already occurs today, and would continue to follow the appropriate Commission-approved process, either allocation via CAM or allocation via distribution rates. This allocation process should occur at the beginning of each biennial cycle, to inform the IOUs Storage Procurement Plan Applications. Because storage procurement and target compliance is organized around biennial cycles, there is no need to update the allocations more frequently. One goal of this proposal is to minimize additional administrative workload. SCE provides a numerical example below, based on values provided by DACC/AReM. This example assumes a uniform target of 2.5% of peak load for all LSEs. In this example, SCE would allocate a total of MW credit to the ESP customers, whose remaining obligation would be MW. 10

13 Table II-2 SCE SCE area ESPs 1 Uniform Target defined in terms of % of 2020 peak load 1 2.5% 2.5% 2 Target expressed in MW MW 52.5 MW 3 Storage procured to date by SCE on behalf of all customers MW 4 Percentage for purpose of credit and cost allocation % 12.9% 5 Allocated share of storage credit MW MW 6 Remaining 2020 procurement obligation MW MW 1 Approximately equivalent to SCE s current 2020 target of 580 MW ESP target calculated based on figures provided in DACC/AReM s comments: DACC/AReM indicated 21 MW as equivalent to 1% of Peak load. 21 * 2.5 = (See DACC/AReM Comments at 6, Table 3, line 4.) For consistency, this is also the number used in DACC/AREMs comments. (See DACC/AReM Comments at 4, Table 1.) SCE is using this number for illustrative purposes; it does not necessarily reflect current updates to SCE s procurement activities. Based on 12.9% DA load share, per DACC/AReM s comments (See DACC/AReM Comments at 5, Table 3, footnote 5.) Share in Line 4 multiplied by procurement in Line 3 Line 5 Line 2 Note that this process only applies to storage procured on behalf of all customers. Storage procured for bundled customers (e.g., SCE s contracts from the 2014 Energy Storage Request for Offers) would not have either credit or cost allocated to ESPs/CCAs. Conversely, programs funded by all customers such as the SGIP would go through this process. Thus, all SGIP projects, whether the host customer is an IOU customer or an ESP/CCA customer, would have the credit for that project allocated as described above, much as the cost of SGIP is allocated to all customers. 3. Stranded Cost Recovery and PCIA is More Complex and Would Benefit from a Workshop Numerous parties have advanced arguments related to PCIA implementation. Specific details of PCIA implementation are complex, and PCIA has remained a contentious issue for 11

14 energy storage. SCE therefore recommends the Commission host a workshop specifically to address PCIA issues and ensure that the principle of customer indifference remains upheld. D. SCE Continues to Support a Broad Definition of Eligible Energy Storage Technologies As a general policy, SCE is supportive of a technology-neutral, inclusive definition of energy storage. When determining whether to make new technologies or applications eligible within the Storage Procurement Framework, SCE recommends the Commission consider whether there is any reason (based on the Commission s goal of market transformation) to exclude a particular storage technology. SCE agrees with the many parties who supported including V1G or managed charging as eligible storage technology, and maintains that broadening the eligibility rules to include V1G would further the Commission s market transformation goals. 18 E. There Is Wide Agreement That Multi-Use and Community Storage Applications Raise Complex Issues Which Would Benefit From Workshops The responses to the questions contained in the Scoping Ruling illustrate the complexity of multiple-use applications. SCE agrees with numerous parties that one (or more likely, multiple) workshops will be necessary to resolve these issues. F. The Commission Should Reject an Overly Broad Definition of Station Load SCE and SDG&E s proposals for energy storage station power guidelines and rate implications are based on the principle that equitable rate treatment should apply for all generation resources regardless of technology such as wind, solar, energy storage, and other conventional generators. As stated in SCE s Opening Comments, all generation customers who 18 See NRDC Opening Comments at 4; EDF Opening Comments at 4-6; Alliance Opening Comments at

15 currently receive retail service are charged at retail rate levels for delivered end use load, including power required to start and cool inlet air for a combustion generator. Similarly, both SCE and SDG&E propose that any end-use loads delivered to the storage unit when it is neither charging nor discharging should also be treated as end-use load and billed at retail rates. This treatment for end-use load is consistent with the California Independent System Operator s ( CAISO s ) current tariff definition for station power: Energy for operating electric equipment, or portions thereof, located on the Generating Unit site owned by the same entity that owns the Generating Unit, which electrical equipment is used exclusively for the production of Energy and any useful thermal energy associated with the production of Energy by the Generation Unit. 19 Furthermore, the Federal Power Act 20 prohibits utilities from providing an unreasonable difference in rates for a similar class of service. Therefore, any loads required for the production of energy by energy storage should also be considered as retail charging. In order to ensure energy storage customers will be paying their fair share of cost, a separate retail meter should be required to distinguish this type of retail load. Several parties opposed SCE s proposed approach, stating that any power required to operate the energy storage device should be considered as wholesale charging. 21 Specifically, parties point out that thermal management system load, such as Heating, Ventilation, and Air Conditioning ( HVAC ) load, can be critical to maintain the optimal temperature of batteries and is essential to the operation of the system. However, treating HVAC load as wholesale charging is inconsistent with CAISO s station power definition. While CAISO points out the need to further evaluate methods to distinguish between wholesale and retail charging in its Opening Comments, it also emphasizes how any revision to the existing tariff definition will require 19 See CAISO Tariff, Appendix A. 20 See 16 USC 824d. 21 See, e.g., Calpine Opening Comments at 6; CESA Opening Comments at 21; Western Power Trading Forum Opening Comments at

16 FERC approval. Furthermore, justification would be needed to differentiate between energy storage and traditional generators auxiliary load if different rate treatments are to be applied in order to avoid violation of the Federal Power Act. III. CONCLUSION SCE appreciates the opportunity to provide these comments on the Scoping Memo. SCE looks forward to working with the Commission and other stakeholders to resolve these storage policy issues. Respectfully submitted, WILLIAM V. WALSH AMBER DEAN WYATT /s/ Amber Dean Wyatt By: Amber Dean Wyatt Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) February 19,

17 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to consider policy and implementation refinements to the Energy Storage Procurement Framework and Design Program (D , D ) and related Action Plan of the California Energy Storage Roadmap. Rulemaking (Filed March 26, 2015) 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 SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS ON ASSIGNED COMMISSIONER AND ASSIGNED ADMINISTRATIVE LAW JUDGE S SCOPING MEMO AND RULING SEEKING PARTY COMMENTS on all parties identified on the attached service list(s) R 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 hand or by overnight courier to the offices of the Commissioner(s) or other addressee(s). ALJ Regina DeAngelis CPUC 505 Van Ness Avenue San Francisco, CA Commissioner Carla Peterman CPUC 505 Van Ness Avenue 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. Executed on February 19, 2016, 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

18 CPUC - Service Lists - R Page 1 of 13 2/19/2016 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO CONSID FILER: CPUC LIST NAME: LIST LAST CHANGED: FEBRUARY 11, 2016 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties BRIAN KORPICS CC SONG STAFF ATTORNEY REGULATORY ANALYST THE CLEAN COALITION MARIN CLEAN ENERGY, CA 00000, CA FOR: CLEAN COALITION FOR: MARIN CLEAN ENERGY EVELYN LEE PATRICK FERGUSON PACIFIC GAS & ELECTRIC COMPANY DAVIS WRIGHT TREMAINE, LLP, CA 00000, CA FOR: PACIFIC GAS & ELECTRIC COMPANY FOR: CALPINE CORPORATION RACHEL GOLD TED KO POLICY DIRECTOR STEM. INC. LARGE-SCALE SOLAR ASSOCIATION, CA 00000, CA FOR: STEM, INC. FOR: LARGE-SCALE SOLAR ASSOCIATION SHARON YANG JEFFREY A. SERFASS SR. COUNSEL MANAGING DIRECTOR SOUTHERN CALIFORNIA GAS COMPANY CALIFORNIA HYDROGEN BUSINESS COUNCIL 555 WEST FIFTH ST., STE. 1400, GT-14E MERRIMAC ROAD LOS ANGELES, CA LOS ANGELES, CA FOR: SOUTHERN CALIFORNIA GAS COMPANY FOR: CALIFORNIA HYDROGEN BUSINESS

19 CPUC - Service Lists - R Page 2 of 13 2/19/2016 COUNCIL J. DOUGLAS DIVINE DANIEL W. DOUGLASS CHIEF EXECUTIVE OFFICER ATTORNEY EAGLE CREST ENERGY COMPANY DOUGLASS & LIDDELL 3000 OCEAN PARK BVLD., STE PARK GRANADA, SUITE 209 SANTA MONICA, CA CALABASAS, CA FOR: EAGLE CREST ENERGY COMPOANY FOR: ALLIANCE FOR RETAIL ENERGY MARKETS (AREM), DIRECT ACCESS CUSTOMER COALITION (DACC), WESTERN POWER TRADING FORUM (WPTF) AMBER WYATT JOHN W. LESLIE, ESQ SR. ATTORNEY ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY DENTONS US LLP 2244 WALNUT GROVE AVE. G.O.1, RM 345E 600 WEST BROADWAY, STE ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALFIORNIA EDISON COMPANY FOR: SHELL ENERGY NORTH AMERICA (US), L.P. GREG BASS DONALD C. LIDDELL DIR ATTORNEY NOBLE AMERICAS ENERGY SOLUTIONS LLC DOUGLASS & LIDDELL 401 WEST A STREET, SUITE ND AVENUE SAN DIEGO, CA SAN DIEGO, CA FOR: NOBLE AMERICAS ENERGY SOLUTIONS LLC FOR: CALIFORNIA ENERGY STORAGE ALLIANCE (CESA) KELLEY RODGERS PAUL A. SZYMANSKI ENERGY PROGRAM MANAGER SR. COUNSEL SAN DIEGO COUNTY WATER AUTHORITY SAN DIEGO GAS & ELECTRIC COMPANY 4677 OVERLAND AVENUE 8330 CENTURTY PARK CT., CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: SAN DIEGO COUNTY WATER AUTHORITY FOR: SAN DIEGO GAS & ELECTRIC COMPANY (SDCWA) SACHU CONSTANTINE GUSTAVO E. LUNA DIR. OF POLICY VP - ORIGINATION CENTER FOR SUSTAINABLE ENERGY TERRA-GEN POWER, LLC 9325 SKY PARK COURT, SUITE EL CAMINO REAL, SUITE 370 SAN DIEGO, CA SAN DIEGO, CA FOR: CENTER FOR SUSTAINABLE ENERGY FOR: TERRA-GEN POWER, LLC JOSHUA BLEDSOE CHRISTOPHER J. GRIECO LATHAM & WATKINS LLP EXECUTIVE V.P. 650 TOWN CENTER DRIVE, 20TH FLOOR GRAVITY POWER, LLC COSTA MESA, CA B HOLLISTER AVENUE, STE. B FOR: ALEVO ENERGY, INC. GOLETA, CA FOR: GRAVITY POWER, LLC

20 CPUC - Service Lists - R Page 3 of 13 2/19/2016 MARC D. JOSEPH LISA-MARIE G. CLARK ADAMS, BROADWELL, JOSEPH & CARDOZO LEGAL DIVISION 601 GATEWAY BLVD., STE CPUC SOUTH SAN FRANCISCO, CA VAN NESS AVE., RM FOR: COALITION OF CALIFORNIA UTILITY SAN FRANCISO, CA EMPLOYEES (CCUE) FOR: ORA HAYLEY GOODSON NORA SHERIFF STAFF ATTORNEY ALCANTAR & KAHL, LLP THE UTILITY REFORM NETWORK 345 CALIFORNIA ST., STE MARKET ST., STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: THE UTILITY REFORM NETWORK ASSOCIATION (CLECA) PIERRE BULL LARISSA KOEHLER NATURAL RESOURCES DEFENSE COUNCIL ATTORNEY 111 SUTTER STREET, 20TH FLOOR ENVIRONMENTAL DEFENSE FUND SAN FRANCISCO, CA MISSION STREET, 28TH FLOOR FOR: NATURAL RESOURCES DEFENSE COUNCIL SAN FRANCISCO, CA FOR: ENVIRONMENTAL DEFENSE FUND (EDF) SHERIDAN J. PAUKER, ESQ. MEGAN MATSON REGULATORY COUNSEL PARTNER WILSON SONSINI GOODRICH & ROSATI TABLE ROCK CAPITAL ONE MARKET PLAZA, SPEAR TOWER, STE CALIFORNIA ST., STE. 600 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ROBERT BOSCH LLC FOR: TABLE ROCK CAPITAL MICHAEL DAY SEAN P. BEATTY GOODIN MACBRIDE SQUERI & DAY LLP WEST REGION GEN. COUNSEL 505 SANSOME STREET, STE. 900 NRG ENERGY, INC, SAN FRANCISCO, CA CALIFORNIA STREET, SUITE 650 FOR: ABENGOA SOLAR SAN FRANCISCO, CA FOR: NRG ENERGY, INC. YANA GARCIA MEGAN M. MYERS EARTHJUSTICE ATTORNEY 50 CALIFORNIA STREET, SUITE 500 LAW OFFICES OF SARA STECK MYERS SAN FRANCISCO, CA TH AVENUE FOR: SIERRA CLUB SAN FRANCISCO, CA FOR: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE TECHNOLOGIES (CEERT) JASON B. KEYES GREGORY MORRIS ATTORNEY DIRECTOR KEYES FOX & WIEDMAN LLP GREEN POWER INSTITUTE TH STREET, STE SHATTUCK AVENUE, STE 402 OAKLAND, CA BERKELEY, CA FOR: SOLARCITY CORPORATION FOR: THE GREEN POWER INSTITUTE (A PROGRAM OF THE PACIFIC INSTITUTE)

21 CPUC - Service Lists - R Page 4 of 13 2/19/2016 DAVID KATES BILL WEAVER DAVID MARK & COMPANY CALIFORNIA ISO 3510 UNOCAL PLACE, SUITE OUTCROPPING WAY SANTA ROSA, CA FOLSOM, CA FOR: THE NEVADA HYDRO COMPANY FOR: CALIFORNIA INDEPENDENT SYSTEM OPERATOR TY TOSDAL VIRINDER SINGH OF COUNSEL DIR - REGULATORY & LEGISLATIVE AFFAIRS BRAUN BALISING MCLAUGHLIN & SMITH, P.C. EDF RENEWABLE ENERGY 915 L. STREET, SUITE SW BROADWAY, SUITE 1880 SACRAMENTO, CA PORTLAND, OR FOR: CITY OF LANCASTER FOR: EDF RENEWABLE ENERGY Information Only ANDREW CAMPBELL BARBARA BARKOVICH EXEC. DIR., ENERGY INSTITUTE AT HAAS CONSULTANT UNIVERSITY OF CALIFORNIA, BERKELEY BARKOVICH & YAP, CA 00000, CA BRIAN THEAKER CASE COORDINATION DIRECTOR - REGULATORY AFFAIRS PACIFIC GAS AND ELECTRIC COMPANY NRG ENERGY, INC., CA 00000, CA DANIELLE OSBORNE MILLS DIANE FELLMAN SENIOR POLICY ADVISOR DIR - GOVERNMENTAL & REGULATORY AFFAIRS LARGE-SCALE SOLAR ASSOCIATION NRG ENERGY, INC., CA 00000, CA ELI HARLAND JAMES HALL CALIFORNIA ENERGY COMMISSION MGR.- ADVANCED VEHICLE AND INFRA. POLICY ENERGY RESEARCH & DEVELOPMENT DIV. GENERAL MOTORS LLC, CA 00000, CA JAMIE HALL JAMIE L MAULDIN ADVANCED VEHICLE AND INFRASTRUCTURE ADAMS BROADWELL JOSEPH & CARDOZO GENERAL MOTORS, LLC, CA 00000, CA FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES JEFFREY P. GRAY JEREMY WAEN

22 CPUC - Service Lists - R Page 5 of 13 2/19/2016 DAVIS WRIGHT TREMAINE, LLP REGULATORY ANALYST MARIN CLEAN ENERGY, CA FOR: CALPINE CORPORATION, CA JONATHAN HART KATIE JORRIE CENTER FOR SJUSATINABLE ENERGY DAVIS WRIGHT TREMAINE, LLP, CA 00000, CA FOR: CALPINE CORPORATION KENNETH SAHM WHITE LORRAINE PASKETT CLEAN COALITION, CA 00000, CA FOR: CLEAN COALITION LORRAINE PASKETT, CA MARC COSTA ENERGY COALITION, CA MARK HUFFMAN MATTHEW BARMACK LAW DEPT DIRECTOR, MARKET & REGULATORY ANALYSIS PACIFIC GAS & ELECTRIC COMPANY CALPINE CORPORATION, CA 00000, CA MCE REGULATORY MICHAEL NGUYEN MARIN CLEAN ENERGY ENERGY COALITION, CA 00000, CA PETER T. PEARSON PRAMOD KULKARNI ENERGY SUPPLY SPECIALIST CUSTOMIZED ENERGY SOLUTIONS BEAR VALLEY ELECTRIC SERVICE, CA 00000, CA RACHEL GOLDEN REBECCA FEUERLICHT NATURAL RESOURCES DEFENSE COUNCIL CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA ROLA HALAWANJI SEPHRA A. NINOW PROJECT MANAGER REGULATORY AFFAIRS MGR. ENERGY COALITION CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA 00000

23 CPUC - Service Lists - R Page 6 of 13 2/19/2016 THOMAS ASHLEY TIM OLSEN DIRECTOR OF GOVERNMENT AFFAIRS ENERGY COALITION GREENLOTS, CA 00000, CA UDI HELMAN HELMAN ANALYTICS, CA WADE A. GREENACRE CASE MGR. PACIFIC GAS AND ELECTRIC COMPANY, CA REGULATORY DAVIS WRIGHT TREMAINE, LLP MARIN CLEAN ENERGY, CA 00000, CA MRW & ASSOCIATES, LLC, CA MIKE FERRY CENTER FOR SUSTAINABLE ENERGY, CA TAM HUNT SANDER K. COHAN COMMUNITY RENEWABLES SOLUTIONS, LLC DIRECTOR, INNOVATION ENEL GREEN POWER NORTH AMERICA, INC., CA TECH DRIVE, SUITE 220 ANDOVER, MA JIM KOBUS JEFF GATES RESEARCH DIRECTOR OF SALES & FIELD OPERATIONS MORGAN STANLEY ALEVO ENERGY, INC BROADWAY, 38TH FLOOR 2320 CONCORD PARKWAY SOUTH NEW YORK, NY CONCORD, NC KATHERINE HOFFMASTER CHRIS NEVERS SR. REGULATORY AFFAIRS ANALYST ALLIANCE OF AUTOMOBILE MANUFACTURERS NEXTERA ENERGY RESOURCES 2000 TOWN CENTER, STE UNIVERSE BLVD., FEJ/JB SOUTHFIELD, MI JUNO BEACH, FL TONY SIEBERT KELLY CRANDALL ZBB ENERGY CORPORATION KEYES FOX & WIEDMAN LLP N93 W14475 WHITTAKER WAY TH ST., 16 MARKET SQR., STE. 400 MENOMONEE FALLS, WI DENVER, CO LON W. HOUSE, PH.D WATER & ENERGY CONSULTING JOE GRECO SR. V.P.

24 CPUC - Service Lists - R Page 7 of 13 2/19/ N. ORACLE RD., STE TERRA-GEN POWER LLC TUCSON, AZ PROTOTYPE COURT, SUITE 200 FOR: WEC RENO, NV YVONNE MEJIA PENA STEVEN ZURETTI SOUTHERN CALIFORNIA GAS COMPANY DIR - REGULATORY AFFAIRS 555 W. FITH ST., GT14D6 BROOKFIELD ENERGY MARKETING INC. LOS ANGELES, CA RUBY PL LOS ANGELES, CA FOR: BROOKFIELD ENERGY MARKETING INC. JESSALYN ISHIGO MILISSA MARONA ENVIRONMENTAL BUSINESS DEVELOPMENT OFF. DIR - GOV'T & UTILITY RELATIONS AMERICAN HONDA MOTOR CO., INC. CODA ENERGY 1919 TORRANCE BLVD. 135 E. MAPLE AVE. TORRANCE, CA MONROVIA, CA FOR: AMERICAN HONDA MOTOR CO., INC. GREGORY S. G. KLATT CASE ADMINISTRATION ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVE., PO BOX PARK GRANADA, STE. 209 ROSEMEAD, CA CALABASAS, CA SHAWN BAILEY MARCIE MILNER DIRECTOR - PLANNING & ANALYSIS VP - REGULATORY AFFAIRS SEMPRA US GAS AND POWER SHELL ENERGY NORTH AMERICA (US), L.P TH STREET 4445 EASTGATE MALL, SUITE 100 SAN DIEGO, CA SAN DIEGO, CA STEVEN LANGO WILLIAM P. FULLER REGULATORY CASE MGR - II REGULATORY CASE MANAGER SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT., CP-31H 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA SAN DIEGO, CA ANTHONY HARRISON SUE MARA MGR. - REGULATORY AFFAIRS CONSULTANT STEM, INC. RTO ADVISORS, LLC 100 ROLLINS RD. 164 SPRINGDALE WAY MILLBRAE, CA REDWOOD CITY, CA FOR: ALLAINCE FOR RETAIL ENERGY MARKETS (AREM) ERIC BORDEN CANDICE YU ENERGY POLICY ANALYST ASSOCIATE, ADVANCED SOLUTIONS THE UTILITY REFORM NETWORK SUNEDISON 785 MARKET STREET, STE MONTGOMERY STREET, 2200 SAN FRANCISCO, CA SAN FRANCISCO, CA 94104

25 CPUC - Service Lists - R Page 8 of 13 2/19/2016 BILL KISSINGER DEVIN MCDONELL MORGAN LEWIS & BOCKIUS LLP MORGAN LEWIS BOCKIUS LLP ONE MARKET, SPEAR STREET TOWER ONE MARKET, SPEAR STREET TOWER SAN FRANCISCO, CA SAN FRANCISCO, CA DUSTIN ELLIOTT GRACE HSU MORGAN, LEWIS & BOCKIUS, LLP WILSON SONSINI GOODRICH & ROSATI ONE MARKET ST., SPEAR STREET TOWER ONE MARKET PLZ, SPEAR TWR,STE.3300 SAN FRANCISCO, CA SAN FRANCISCO, CA MATTHEW VESPA SARAH KEANE SR. ATTORNEY ATTORNEY SIERRA CLUB MORGAN LEWIS & BOCKIUS, LLP 85 SECOND ST,, 2ND FL ONE MARKET, SPEAR STREET TOWER SAN FRANCISCO, CA SAN FRANCISCO, CA MONICA SCHWEBS ADENIKE ADEYEYE MORGAN LEWIS BOCKIUS, LLP EARTHJUSTICE ONE MARKET, SPEAR STREET TOWER 50 CALIFORNIA ST., STE. 500 SAN FRANCISCO, CA SAN FRANCISCO, CA BRIAN T. CRAGG F. JACKSON STODDARD ATTORNEY ATTORNEY GOODIN, MACBRIDE, SQUERI & DAY, LLP CROWELL & MORING, LLP 505 SANSOME ST., STE BATTERY STREET, 23RD FL. SAN FRANCISCO, CA SAN FRANCISCO, CA LUISA F. ELKINS MICHAEL B. DAY GOODIN MACBRIDE SQUERI & DAY, LLP ATTORNEY 505 SANSOME ST., STE. 900 GOODIN, MACBRIDE, SQUERI & DAY, LLP SAN FRANCISCO, CA SANSOME ST., STE. 900 SAN FRANCISCO, CA FOR: COMMERCIAL ENERGY RIKKI WEBER WILLIAM ROSTOV LITIGATION ASSISTANT STAFF ATTORNEY EARTHJUSTICE EARTHJUSTICE 50 CALIFORNIA STREET, SUITE CALIFORNIA ST., STE. 500 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SIERRA CLUB CALIFORNIA ENERGY MARKETS CHARLES R. MIDDLEKAUFF 425 DIVISADERO ST., STE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE STREET, B30A, PO BOX 7442 SAN FRANCISCO, CA RANDALL J. LITTENEKER ATTORNEY AT LAW SARA STECK MYERS ATTORNEY AT LAW

26 CPUC - Service Lists - R Page 9 of 13 2/19/2016 PACIFIC GAS AND ELECTRIC COMPANY LAW OFFICES OF SARA STECK MYERS PO BOX 7442, B30A TH AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MATTHEW R. GONZALES ANDREW YIP MGR. - REGULATORY MGR - BUS. DEVELOPMENT (RBNA/PJ-BGT) PACIFIC GAS AND ELECTRIC COMPANY ROBERT BOSCH LLC PO BOX MIRANDA AVENUE, STE. 200 SAN FRANCISCO, CA PALO ALTO, CA SARAH VAN CLEVE SHARMILA RAVULA ENERGY POLICY ADVISOR DIR - BUS. DEVELOP. RBNA/PJ-DC MICROGRID TESLA MOTORS, INC. ROBERT BOSCH LLC 3500 DEER CREEK ROAD 4009 MIRANDA AVENUE, SUITE 200 PALO ALTO, CA PALO ALTO, CA ANDY SCHWARTZ GENEVIEVE DUFAU-MCCARTHY SOLARCITY SOLARCITY CORPORATION 3055 CLEARVIEW WAY 3055 CLEARVIEW WAY SAN MATEO, CA SAN MATEO, CA BONNIE DATTA EMMIE STENSTEDT SIEMENS USA ELSYS INC E. THIRD AVENUE 4966 HUMMINGBIRD ROAD FOSTER CITY, CA PLEASANTON, CA BEVIN HONG MARK STOUT UTILITY SALES DIRECTOR V.P.-PROJECT DEVELOPMENT ZBB ENERGY CORPORATION AMBER KINETICS, INC. 43 WOODLAND CT ALVARADO NILES RD., STE. 250 SAN RAMON, CA UNION CITY, CA CYNTHIA CLARK SAMUEL J. HARVEY MANAGER, WHOLESALE ELECTRICITY PROGRAM KEYES FOX & WIEDMAN LLP UNIVERSITY OF CALIF.-OFF. OF THE PRES TH STREET, SUITE BROADWAY. SUITE 1472 SAN FRANCISCO, CA OAKLAND, CA STEPHANIE WANG TIM LINDL SR. POLICY ATTORNEY COUNSEL CENTER FOR SUSTAINABLE ENERGY KEYES FOX & WIEDMAN LLP TH STREEET, SUITE TH STREET, STE OAKLAND, CA OAKLAND, CA FOR: SONOMA CLEAN POWER AUTHORITY TANDY MCMANNES RON PERRY ABENGOA SOLAR CEO I KAISER PLAZA, STE COMMERCIAL ENERGY OAKLAND, CA OAKPORT ST., STE. 525

27 CPUC - Service Lists - R Page 10 of 13 2/19/2016 OAKLAND, CA PHILLIP MULLER DEDRICK ROPER PRESIDENT CHARGEPOINT, INC. SCD ENERGY SOLUTIONS 254 EAST HACIENDA AVENUE 436 NOVA ALBION WAY CAMPBELL, CA SAN RAFAEL, CA C. SUSIE BERLIN DEBRA EMERSON LAW OFFICES OF SUSIE BERLIN SONOMA CLEAN POWER AUTHORITY 1346 THE ALAMEDA, STE. 7, NO SANTA ROSA AVE., 5TH FL. SAN JOSE, CA SANTA ROSA, CA JILL POWERS JORDAN PINJUV CALIFORNIA INDEPENDENT SYSTEM OPERATOR COUNSEL 250 OUTCROPPING WAY CALIFORNIA INDEPENDENT SYSTEM OPERATOR FOLSOM, CA OUTCROPPING WAY FOLSOM, CA LEGAL DEPARTMENT PETER KLAUER CALIFORNIA ISO CALIFORNIA INDEPENDENT SYSTEM OPERATOR 250 OUTCROPPING WAY 250 OUTCROPPING WAY FOLSOM, CA FOLSOM, CA TOM FLYNN HEATHER SANDERS CALIFORNIA INDEPENDENT SYSTEM OPERATOR CALIFORNIA ISO 250 OUTCROPPING WAY 250 OUTCROPPING WAY FOLSOM, CA FOLSOM, CA LORENZO KRISTOV DAN GRIFFITHS CALIFORNIA ISO ATTORNEY 250 OUTCROPPING WAY BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. FOLSOM, CA L STREET, SUITE 1480 SACRAMENTO, CA JUSTIN WYNNE KEVIN WOODRUFF ATTORNEY WOODRUFF EXPERT SERVICES BRAUN BLAISING MCLAUGHLIN & SMITH, P.C TH STREET, SUITE L STREET, SUITE 1480 SACRAMENTO, CA SACRAMENTO, CA OSTAP LOREDO-CONTRERAS REBECCA FRANKLIN ENERGY SYSTEM RESEARCH OFFICE REGULATORY ADVOCATE CALIFORNIA ENERGY COMMISSION ASSOCIATION OF CALIF. WATER AGENCIES TH STREET, MS K STREET, STE. 100 SACRAMENTO, CA SACRAMENTO, CA FOR: ASSOCIATION OF CALIFORNIA WATER AGENCIES (ACWA)

28 CPUC - Service Lists - R Page 11 of 13 2/19/2016 SCOTT BLAISING STEVEN KELLY COUNSEL POLICY DIR. BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. INDEPENDENT ENERGY PRODUCERS ASSCIATION 915 L STREET, SUITE K STREET, STE. 900 SACRAMENTO, CA SACRAMENTO, CA STEVEN P. DOUGLAS CHASE KAPPEL SR. DIR - ENVIRONMENTAL AFFAIRS ELLISON SCHNEIDER & HARRIS, LLP ALLIANCE OF AUTOMOBILE MANUFACTURERS 2600 CAPITOL AVE., SUITE L STREET, STE SACRAMENTO, CA SACRAMENTO, CA FOR: ALLIANCE OF AUTOMOBILE MANUFACTURERS ANDREW B. BROWN DOUGLAS K. KERNER ELLISON, SCHNEIDER & HARRIS L.L.P. ATTORNEY AT LAW 2600 CAPITOL AVE, SUITE 400 ELLISON, SCHNEIDER & HARRIS, LLP SACRAMENTO, CA CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA JEFFERY D. HARRIS LYNN M. HAUG ELLISON, SCHNEIDER & HARRIS LLP ELLISON, SCHNEIDER & HARRIS LLP 2600 CAPITOL AVENUE, SUITE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRMENTO, CA ANN L. TROWBRIDGE JACK ELLIS ATTORNEY AT LAW 1425 ALPINE WAY / PO BOX 6600 DAY CARTER & MURPHY LLP TAHOE CITY, CA AMERICAN RIVER DRIVE, SUITE 205 SACRAMENTO, CA FOR: GILL RANCH STORAGE, LLC SARAH ADAMS SHAUN LOGUE BUSINESS DEVELOPMENT BROOKFIELD ENERGY MARKETING, INC. NW NATURAL 480 BLVD. DE LA CITE 220 NW SECOND AVENUE GATINEAU, PQ J8T 8R3 PORTLAND, OR CANADA FOR: GILL RANCH STORAGE, LLC State Service HAL KANE MARC MONBOUQUETTE SR. ANALYST, RISK ASSESSMENT CALIFORNIA PUBLIC UTILITIES COMMISSION CPUC - SED DIV ENERGY DIVISION, CA 00000, CA AMY C. BAKER ARTHUR J. O'DONNELL

29 CPUC - Service Lists - R Page 12 of 13 2/19/2016 CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION RAILROAD OPERATIONS SAFETY BRANCH RISK ASSESSMENT AND ENFORCEMENT ROOM 5210 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA CHRISTOPHER MYERS EHREN SEYBERT CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH COMMISSIONER PETERMAN ROOM 4104 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA GABRIEL PETLIN JOSE ALIAGA-CARO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN INFRASTRUCTURE PLANNING AND PERMITTING B AREA 4-A AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA KARIN M. HIETA MANISHA LAKHANPAL CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH INFRASTRUCTURE PLANNING AND PERMITTING B ROOM 5010 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MARTIN JR. LIZARDE REGINA DEANGELIS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION OFFICE OF RATEPAYER ADVOCATES DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA ROSANNE O'HARA RYAN YAMAMOTO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH ELECTRIC SAFETY AND RELIABILITY BRANCH AREA AREA 2-D 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA XIAO SELENA HUANG LINDA KELLY CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY ANALYSIS OFFICE COMMUNICATIONS DIVISION CALIFORNIA ENERGY COMMISSION ROOM 3-D TH STREET, MS VAN NESS AVENUE SACRAMENTO, CA SAN FRANCISCO, CA JOHN MATHIAS ELECTRIC GENERATION SPECIALIST RYAN HUFT, P.E. MECHANICAL ENGINEER

30 CPUC - Service Lists - R Page 13 of 13 2/19/2016 CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS TH ST., MS-43 SACRAMENTO, CA SACRAMENTO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

31 MEGAN MATSON PARTNER TABLE ROCK CAPITAL 150 CALIFORNIA ST., STE. 600 SAN FRANCISCO CA List of Non- Recipients