THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

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1 THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking on the Commission s Own Motion to Address the Issue of Customers Electric and Natural Gas Service Disconnection. Rulemaking SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) REPLY COMMENTS TO THE ADMINISTRATIVE LAW JUDGE S RULING PROVIDING OPPORTUNITY FOR COMMENTS AND ADDRESSING OTHER PHASE II ISSUES JENNIFER TSAO SHIGEKAWA MONICA GHATTAS Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) monica.ghattas@sce.com September 24, 2010 LAW-#

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking on the Commission s Own Motion to Address the Issue of Customers Electric and Natural Gas Service Disconnection. Rulemaking SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS TO THE ADMINISTRATIVE LAW JUDGE S RULING PROVIDING OPPORTUNITY FOR COMMENTS AND ADDRESSING OTHER PHASE II ISSUES I. INTRODUCTION Pursuant to the Administrative Law Judge s Ruling Providing Opportunity for Comments and Addressing Other Phase II Issues (the Ruling), issued on August 26, 2010, Southern California Edison Company (SCE) herein replies to parties comments on the Ruling

3 II. DISCUSSION A. There is No Historical or Factual Basis Establishing That Allowing Customers to Select A Bill Date Results in Improved Payment Rates and the IOUs Agree Implementation of this Option is Currently Impractical and Costly The intervenors provide a variety of speculative reasons to support their contention that allowing a customer to select their billing date will result in less late/non-payments. The reasons they provide include: 1) examples of utilities that offer such an option with no analysis of whether there was a resulting impact on customer payment rates; 2) anecdotal examples from customers; and 3) a recommendation from a study on water affordability programs. In contrast, the IOUs unanimously agree that implementation of a customer-selected bill date option is currently impractical and costly. Both TURN and NCLC refer to Entergy Corporation s Pick-A-Date program as support for the idea that customers should be allowed to select a bill date. 1 However, neither party mentions Entergy s policies surrounding the program, including that accounts on the Pick- A-Date program are not eligible for payment extensions or arrangements. 2 Moreover, SCE was not able to find, nor did any of the intervenors provide, an analysis of whether Entergy s program, or any other utility s customer-selected bill date program, has been successful in improving customer payment rates. Additionally, NCLC makes the incorrect assumption that because the press release it referenced about Entergy s Pick-A-Date program failed to identify costs to implement the program, such a program can be implemented in California at a reasonable cost. The failure to discuss the cost of a program in a press release is not evidence 1 TURN, p. 8; NCLC, pp

4 that costs do not exist. Instead, it is likely that Entergy would choose to discuss the costs associated with its Pick-A-Date program in a more appropriate forum, such as its rate case. Other intervenors point to anecdotal evidence that some customers feel they would be better able to pay their bill if they were able to align their bill date with the timing of their income. 3 Additionally, TURN references a water affordability study that suggests customers may be better able to pay their bills if they are allowed to select their bill date. Given the high operational costs and obstacles that all the IOUs mentioned in their comments, it would be risky to invest so much in such a program at this time without a data-driven indication that these programs actually improve customer payment rates. Finally, DRA suggests that the IOUs could address the operational and system issues related to offering such a program to customers by shifting the billing dates of the other customers. 4 This is currently an impractical option because SCE s smart meter deployment will not be complete until late Thus, any shifting of bill dates will have a significant impact on meter reading routes. This would also create problems for the IOUs in tracking customers that have been shifted based upon participating in the option. Presumably, if a customer is shifted based on his/her participation in the option, the utility cannot then later shift that customer to a different date to accommodate a new customer that desires that same date. This issue is just an example of the types of operational complexities that would arise in implementation of such a program. The IOUs unanimously agree that numerous system and operational obstacles would make it impractical for them to allow all customers to choose a monthly billing date at this time. 5 The IOUs also agree that the estimates for customer-selected bill date options whether for all customers or for customers at-risk of disconnection will result in significant costs being passed 3 TURN, pp. 2-3; DRA, p. 3; NCLC, p DRA, p SCE, pp. 3-4; Joint Utilities, pp.7-8; PG&E, pp

5 to ratepayers due to the constraints outlined above. 6 As SCE has stated, such a policy would have major impacts on meter reading, the call center, bill calculation, bill printing and insertion, the bill exceptions process and working capital. SCE agrees with the Sempra Utilities and PG&E in their assessment that any significant shifting in billing dates could result in spikes in billing volume which would result in additional costs. 7 Further, each IOU notes that its current payment policies allow for a minimum of 19 days between the issuance of a bill and the due date. 8 Such policies allow customers flexibility in selecting a payment date that accommodates their financial situation. For those customers who receive income less than twice per month or have challenges in paying their utility bills, the IOUs offer payment arrangements and other forms of assistance. Ultimately, SCE opposes this option at this time because of the operational obstacles that it will create. As technological and other solutions are developed to deal with these operational hurdles in the future, SCE plans to further explore this option for its customers. B. The Commission Should Allow Exceptions to the Waiver of Deposits in Circumstances of Fraud, Returned Checks and Bankruptcy In its response to the Commission, Greenlining lays out a number of proposed policies related to the IOUs deposit procedures. 9 SCE s current practice is to return deposits to customers upon the timely remittance of twelve consecutive, monthly payments. This policy is fair and reasonable to customers and provides adequate credit protection to all SCE customers. Greenlining also proposes standards for good standing. While SCE appreciates Greenlining s efforts in this regard, SCE has developed its policies over years of experience with its customer base. Additionally, SCE s procedures for establishing good standing are more 6 DRA notes that the ALJ previously requested that the IOUs provide estimates for a customer-selected bill date option for CARE customers. At that time SCE stated that it could provide an estimate within 30 days. However, after further review, SCE found that due to the operational obstacles outlined above and in its Comments, such an estimate is difficult to produce. 7 PG&E, p.7; Joint Utilities, p SCE, p. 3; Joint Utilities, p. 8; PG&E, pp Greenlining, pp

6 straightforward and easily understood and implemented. All SCE customers are considered in good standing until such time as they may be required to re-establish credit. Although new customers may be required to pay a deposit in order to establish initial credit with SCE, they are considered in good standing unless they engage in acts that can result in a re-establishment of credit. As described further in SCE s comments, a customer applying for new service after a break in service will not be charged a deposit if he/she had prior service with SCE within the past two years and was considered in good standing at the time that he/she voluntarily disconnected service. C. Inclusion as a Sensitive Customer Should be Based on Risks to Health and Safety Only and Those Customers are Covered by Existing Policies and Procedures As discussed in SCE s comments, providing special disconnection precautions for the majority of customers would create operational inefficiencies and increase costs for all customers. Thus, the definition of sensitive customers should focus on the minority of customers who need the precautions for reasons of health and safety. SCE currently provides special health and safety precautions to customers who are designated as critical care or who self-identify as elderly or disabled. D requires SCE to add all customers receiving a Medical Baseline allowance to this class of customers. This categorization of customers more than adequately protects customers who need extra precautions for disconnection, while maintaining the IOUs ability to track and maintain those customers. In its comments, NCLC recommends that CARE and FERA participants be included in the definition of sensitive customer. 10 TURN recommends the inclusion of all customers on an all-electric rate schedule during the months of December, January and February. 11 However, qualifying for a low-income program or relying on electric service for heat does not imply that a customer has extra sensitivity to the loss of electricity. Instead, regardless of his/her income 10 NCLC, p TURN, p

7 level or rate schedule, a customer should qualify as sensitive only if the customer will likely suffer a risk to health and safety if electricity is disconnected (e.g. self-identified elderly, selfidentified disabled, critical care or Medical Baseline). In their comments, several parties argue that individuals with a serious illness, which they define as a condition which would become life threatening if their service were disconnected, should be considered sensitive. 12 SCE has been protecting these customers for years. SCE currently includes in its Medical Baseline application the option of being designated by a doctor as critical care. Critical care customers are those customers that suffer a risk to health and safety if left without electricity for two hours or more. These customers are already protected by SCE s long-standing policies and procedures. In response to the ALJ s question regarding the definition of sensitive customers as it relates to customers with children under the age of 18, TURN recommends in its comments that the definition of sensitive customers should include those households containing an infant. 13 As described in SCE s opening comments, there are two challenges with including these groups as sensitive customers. First, 42% of households in the counties that SCE serves had children under the age of 18 in the 2000 U.S Census. 14 While TURN does not elaborate on its definition of infant, it is also likely a significant portion of SCE s customer population. Providing special precautions for such a large portion of our customers would be costly and result in rate increases to be borne by all customers. Second, most of the other conditions that qualify as sensitive are circumstances that will not likely change significantly with time (e.g. elderly or disabled). Tracking households with infants or children under the age of 18 would require the IOUs to keep track of the age of residents so that they would know when a household no longer qualifies as sensitive. Given the number of customers covered and the difficulty and cost associated with 12 NCLC, p. 4; TURN, p. 11; DRA, p. 5; DisabRA, p. 2; Greenlining, p TURN, p Calculated using 2000 census data from the counties of Fresno, Inyo, Kern, Kings, Los Angeles, Mono, Orange, Riverside, San Bernardino, Tulare, and Ventura

8 maintaining and tracking those customers, it will be too costly to customers to implement this for little, if any benefit. In sum, the customer groups the intervenors propose to include in the definition of sensitive customers are either unnecessary and/or too difficult to identify and track and would potentially result in more of SCE s customer base being deemed sensitive than non-sensitive. This result would be detrimental to all SCE customers by increasing rates and eroding the benefits of smart meters. III. CONCLUSION SCE appreciates this opportunity to reply to the parties comments on the Ruling. SCE urges the Commission to continue to take a deliberate and considered approach to the measures it orders throughout this proceeding

9 Respectfully submitted, JENNIFER TSAO SHIGEKAWA MONICA GHATTAS /s/ MONICA GHATTAS By: Monica Ghattas Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) September 24,

10 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 TO THE ADMINISTRATIVE LAW JUDGE'S RULING PROVIDING OPPORTUNITY FOR COMMENTS AND ADDRESSING OTHER PHASE II ISSUES on all parties identified on the attached service list(s). Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. First class mail will be used if electronic service cannot be effectuated. Executed this 24 th day of September, 2010, at Rosemead, California. /s/ RAQUEL IPPOLITI Raquel Ippoliti Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

11 CPUC - Service Lists - R Page 1 of 5 9/24/2010 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO ADDRES FILER: CPUC LIST NAME: LIST LAST CHANGED: AUGUST 31, 2010 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties STEPHANIE C. CHEN JOHN HOWAT THE GREENLINING INSTITUTE NATIONAL CONSUMER LAW CENTER ONLY 7 WINTHROP SQUARE, 4TH FLOOR ONLY, CA BOSTON, MA FOR: THE GREENLINING INSTITUTE FOR: NATIONAL CONSUMER LAW CENTER DARLENE R. WONG VALERIE J. ONTIVEROZ STAFF ATTORNEY SOUTHWEST GAS CORPORATION NATIONAL CONSUMER LAW CENTER 5241 SPRING MOUNTAIN ROAD 7 WINTHROP SQUARE, 4TH FLOOR LAS VEGAS, NV BOSTON, MA FOR: SOUTHWEST GAS CORPORATION FOR: NATIONAL CONSUMER LAW CENTER DONALD L. SODERBERG DEBI GALLO SOUTHWEST GAS CORPORATION SOUTHWEST GAS CORPORATION PO BOX PO BOX LAS VEGAS, NV LAS VEGAS, NV FOR: SOUTHWEST GAS CORPORATION FOR: SOUTHWEST GAS CORPORATION DEBRA BOSIEY ELENA MELLO SOUTHWEST GAS CORPORATION SIERRA PACIFIC POWER COMPANY PO BOX NEIL ROAD LAS VEGAS, NV RENO, NV FOR: SOUTHWEST GAS CORPORATION FOR: SIERRA PACIFIC POWER CO. TREVOR DILLARD AKBAR JAZAYEIRI RAE REGULATORY RELATIONS DIR OF REVENUE & TARIFFS SIERRA PACIFIC POWER COMPANY SOUTHERN CALIFORNIA EDISON COMPANY (338) 6100 NEAL ROAD, MS S4A50 / PO BOX WALNUT GROVE AVE. / PO BOX 800 RENO, NV ROSEMEAD, CA FOR: SIERRA PACIFIC POWER CO. FOR: SOUTHERN CALIFORNIA EDISON COMPANY

12 CPUC - Service Lists - R Page 2 of 5 9/24/2010 CHRIS DOMINSKI DOUG SNOW SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE, SUITE WALNUT GROVE AVENUE ROSEMEAD, CA ROSEMEAD, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SOUTHERN CALIFORNIA EDISON COMPANY JIM YEE JOHN MONTANYE SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON 2244 WALNUT GROVE AVE WALNUT GROVE AVE. ROSEMEAD, CA ROSEMEAD, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SOUTHERN CALIFORNIA EDISON COMPANY MARYBETH QUINLAN MONICA GHATTAS SOUTHERN CALIFORNIA EDISON CO. SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE 2244 WALNUT GROVE AVENUE ROSEMEAD, CA ROSEMEAD, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SOUTHERN CALIFORNIA EDISON COMPANY RONALD MOORE KIM F. HASSAN SR. REGULATROY ANALYST SAN DIEGO GAS & ELECTRIC COMPANY GOLDEN STATE WATER COMPANY 101 ASH STREET, HQ EAST FOOTHILL BLVD. SAN DIEGO, CA SAN DIMAS, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY, FOR: GOLDEN STATE WATER COMPANY SOUTHERN CALIFORNIA GAS (U-913-E) TODD J. CAHILL KATHY WICKWARE SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC CO CENTURY PARK COURT 8330 CENTURY PARK COURT, CP32C SAN DIEGO, CA SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: SAN DIEGO GAS & ELECTRIC CO. AUSTIN M. YANG DENNIS J. HERRERA CITY AND COUNTY OF SAN FRANCISCO CITY AND COUNTY OF SAN FRANCISCO OFFICE OF THE CITY ATTORNEY, RM. 234 CITY HALL, ROOM DR. CARLTON B. GODDLETT PLACE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CITY AND COUNTY OF SAN FRANCISCO FOR: CITY AND COUNTY OF SAN FRANCISCO JEANNE SMITH HARVEY Y. MORRIS SOUTHERN CALIFORNIA EDISON COMPANY 601 VAN NESS AVE. LEGAL DIVISION SAN FRANCISCO, CA ROOM 5036 FOR: SOUTHERN CALIFORNIA EDISON COMPANY 505 VAN NESS AVENUE SAN FRANCISCO, CA FOR: DRA MARION PELEO LEGAL DIVISION ROOM 4107 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE RASHID A. RASHID LEGAL DIVISION SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: DRA FOR: DRA SARAH J. SMITH HAYLEY GOODSON SOUTHERN CALIFORNIA EDISON COMPANY THE UTILITY REFORM NETWORK 601 VAN NESS AVENUE, STE SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: THE UTILITY REFORM NETWORK BERNARD LAM BRIAN CHERRY PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY (39) 77 BEALE STREET, MAIL CODE B10C 77 BEALE STREET ROOM 1087

13 CPUC - Service Lists - R Page 3 of 5 9/24/2010 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: PACIFIC GAS AND ELECTRIC COMPANY (U-39-E/G) DANIEL F. COOLEY DAVID POSTER ATTORNEY AT LAW PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B10A 77 BEALE STREET, B30A, PO BOX 7442 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: PACIFIC GAS AND ELECTRIC COMPANY SHILPA RAMAIYA MICHAEL B. DAY PACIFIC GAS & ELECTRIC COMPANY GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP 245 MARKET STREET, MAIL CODE N3C 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: WILD GOOSE STORAGE JOHN DUTCHER MELISSA W. KASNITZ MOUNTAIN UTILITIES DISABILITY RIGHTS ADVOCATES 3210 CORTE VALENCIA 2001 CENTER STREET, FOURTH FLOOR FAIRFIELD, CA BERKELEY, CA FOR: MOUNTAIN UTILITIES (U-906-E) FOR: DISABILITY RIGHTS ADVOCATES THOMAS R. DILL MICHAEL LAMOND PRESIDENT ALPINE NATURAL GAS OPERATING COMPANY LODI GAS STORAGE, LLC PO BOX N. STATE RT. 99 W. FRONTAGE RD 15 ST. ANDREWS ROAD, SUITE 7 ACAMPO, CA VALLEY SPRINGS, CA FOR: LODI GAS STORAGE, LLC (U-912-G) FOR: ALPINE NATURAL GAS OPERATING CO. NO. 1, LLC (U-909-G) WAYNE AMER JAMES HODGES PRESIDENT TH STREET MOUNTAIN UTILITIES (906) SACRAMENTO, CA PO BOX 205 FOR: ASSOCIATION OF CALIFORNIA KIRKWOOD, CA COMMUNITY AND ENERGY SERVICES (ACCES); FOR: MOUNTAIN UTILITIES (U-906-E) THE EAST L.A. COMMUNITY UNION; THE MARAVILLA FOUNDATION RAYMOND J. CZAHAR, C.P.A. ARIEL SON WEST COAST GAS COMPANY PACIFICORP 9203 BEATTY DRIVE 825 N.E. MULTNOMAH, SUITE 300 SACRAMENTO, CA PORTLAND, OR FOR: WEST COAST GAS COMPANY FOR: PACIFICORP CATHIE ALLEN JASON A. DUBCHAK DIR., REGULATORY AFFAIRS WILD GOOSE STORAGE LLC PACIFICORP 607 8TH AVENUE S.W., SUITE NE MULTNOMAH STREET, SUITE 2000 CALGARY, AB T2P OA7 PORTLAND, OR CANADA FOR: PACIFICORP FOR: WILD GOOSE STORAGE LLC Information Only CASSANDRA SWEET HOLLY LLOYD DOW JONES NEWSWIRES SOUTHWEST GAS CORPORATION ONLY 5241 SPRING MOUNTAIN ROAD ONLY, CA LAS VEGAS, NV KRISTIEN TARY CATHERINE MAZZEO STATE REGULATORY AFFAIRS SOUTHWEST GAS CORPORATION SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV

14 CPUC - Service Lists - R Page 4 of 5 9/24/2010 LAS VEGAS, NV GREGORY HEALY DANIEL A. DELL'OSA SOCALGAS/SDG&E SAN GABRIEL VALLEY WATER COMPANY 555 WEST FIFTH STREET, GT14D GARVEY AVE., PO BOX 6010 LOS ANGELES, CA EL MONTE, CA TIMOTHY J. RYAN CASE ADMINISTRATION SAN GABRIEL VALLEY WATER CO. SOUTHERN CALIFORNIA EDISON COMPANY GARVEY AVE., PO BOX WALNUT GROVE AVE. / PO BOX 800 EL MONTE, CA ROSEMEAD, CA JENNIFER M. TSAO SHIGEKAWA CENTRAL FILES SOUTHERN CALIFORNIA EDISON COMPANY SDG&E AND SOCALGAS 2244 WALNUT GROVE AVENUE 8330 CENTURY PARK COURT, CP31-E ROSEMEAD, CA SAN DIEGO, CA MICHAEL A. BAILEY JEANNE M. SOLE MARGUERITE PARKWAY, NO. 103 CITY AND COUNTY OF SAN FRANCISCO MISSION VIEJO, CA CITY HALL, RM DR. CARLTON B. GOODLET PLACE SAN FRANCISCO, CA THERESA BURKE BONNIE TAM SAN FRANCISCO PUC PACIFIC GAS AND ELECTRIC COMPANY 1155 MARKET STREET, 4TH FLOOR 77 BEALE STREET, MC B10A, PO BOX SAN FRANCISCO, CA SAN FRANCISCO, CA KAREN FORSGARD CALIFORNIA ENERGY MARKETS PACIFIC GAS AND ELECTRIC COMPANY 425 DIVISADERO ST., SUITE BEALE STREET, B10A / BOX B8Q SAN FRANCISCO, CA SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS MICHELLE L. WILSON 425 DIVISADERO ST., SUITE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA PO BOX 7442, LAW DEPT. SAN FRANCISCO, CA CASE ADMINISTRATION DAREN CHAN PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY PO BOX ; MC B9A PO BOX , MAIL CODE B9A SAN FRANCISCO, CA SAN FRANCISCO, CA ED LUCHA ALICIA MILLER PACIFIC GAS AND ELECTRIC COMPANY THE GREENLINING INSTITUTE PO BOX , MAIL CODE B9A 1918 UNIVERSITY AVENUE, 2ND FLOOR SAN FRANCISCO, CA BERKELEY, CA JEAN CHUNG SAMUEL S. KANG THE GREENLINING INSTITUTE THE GREENLINING INSTITUTE 1918 UNIVERSITY AVENUE, 2ND FLOOR 1918 UNIVERSITY AVENUE, SECOND FLOOR BERKELEY, CA BERKELEY, CA JACK KRIEG JOY A. WARREN MODESTO IRRIGATION DISTRICT MODESTO IRRIGATION DISTRICT TH STREET TH STREET MODESTO, CA MODESTO, CA LINDA FISHER LOU HAMPEL MODESTO IRRIGATION DISTRICT MODESTO IRRIGATION DISTICT TH STREET TH STREET MODESTO, CA MODESTO, CA 95354

15 CPUC - Service Lists - R Page 5 of 5 9/24/2010 LORENZON TRAN-HAGOS RON AKER 885 EMBARCADERO DR. PACIFIC GAS AND ELECTRIC COMPANY SACRAMENTO, CA EMBARCADERO DR., ROOM 1113 SACRAMENTO, CA BARB COUGHLIN MARISA DECRISTOFORO PACIFICORP PACIFICORP 825 NE MULTNOMAH, SUITE NE MULTNOMAH STREET, SUITE 800 PORTLAND, OR PORTLAND, OR MICHELLE R. MISHOE PACIFICORP 825 NE MULTNOMAH STREET, SUITE 1800 PORTLAND, OR State Service TORY FRANCISCO AVA N. TRAN CALIFORNIA PUBLIC UTILITIES COMMISSION ONLY ENERGY DIVISION ONLY, CA AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA BRUCE DEBERRY DONALD J. LAFRENZ DIVISION OF ADMINISTRATIVE LAW JUDGES ENERGY DIVISION ROOM 5043 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA KAREN WATTS-ZAGHA LEE-WHEI TAN ENERGY PRICING AND CUSTOMER PROGRAMS BRA ENERGY PRICING AND CUSTOMER PROGRAMS BRA ROOM 4104 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: DRA MATTHEW DEAL ZAIDA AMAYA-PINEDA POLICY & PLANNING DIVISION ENERGY DIVISION ROOM L STREET, SUITE VAN NESS AVENUE SACRAMENTO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS

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