BEFORE THE PUBLIC UTILITIES COMMISSION OF …docs.cpuc.ca.gov/word_pdf/FINAL_DECISION/2831.doc ·...

COM/LML/jeh/abw** Mailed 10/10/2000

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking into the operation of interruptible load programs offered by Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company and the effect of these programs on energy prices, other demand responsiveness programs, and the reliability of the electric system.

FILEDPUBLIC UTILITIES COMMISSION

OCTOBER 5, 2000SAN FRANCISCO OFFICERULEMAKING 00-10-002

ORDER INSTITUTING RULEMAKING INTO THE OPERATION OF INTERRUPTIBLE LOAD PROGRAMS

Summary By this order, the Commission institutes a rulemaking to

1) examine the role of customers on a utility’s interruptible tariffs to ensure reliable and reasonably-priced electric service within California, especially for the Summer of 2001; 2) coordinate the variety of interruptible, curtailable and demand responsiveness programs being offered and proposed; 3) identify alternative means for customers to reduce their energy usage during periods of peak demand; and 4) revise and update our priorities for curtailing customers during times of energy shortages.

This Rulemaking proposes the temporary suspension of the tariff provisions of Southern California Edison (Edison), Pacific Gas and Electric (PG&E), and San Diego Gas & Electric (SDG&E) that allow customers to opt-out of their interruptible program contracts for the

80911 - 1 -

R.00-10-002 COM/LML/jeh/abw**

30-day window commencing November 1. The request of Edison in Advice Letter 1457-E and of PG&E in Advice Letter 2008-E to allow interruptible customers to participate in the Independent System Operators’ (ISO) Ancillary Services Market are now consolidated into this proceeding. The Commission will address these Advice Letters either in this proceeding or through Commission Resolution. Edison and PG&E shall file in this proceeding all of the reports required of them in Resolution E-3650 regarding the operation of their respective demand responsiveness programs. If Edison and/or PG&E seek to extend these or similar programs for the Summer of 2001, they shall file their proposals in this proceeding.

Background on Existing Utility Interruptible Programs California’s investor-owned utilities have operated interruptible

load programs since the mid-1980’s. Under these programs, customers received a discount off of their electric rates in exchange for the ability of the utility to curtail these customers for a certain number of hours per year.1 The current cost of these programs, through reduced rates offered to program participants, is over $220 million per year.2 Program participants receive a discount of about $60,000 to $70,000 per year for each megawatt (MW) that they agree to curtail.3 This is equivalent to about a 15% reduction in that customer’s electric bill compared to the otherwise applicable rate for 1 In the case of Edison customers can be interrupted up to 25 times for a maximum of 6 hours or a total of 150 hours per year. For PG&E customers can be curtailed up to 30 times, no more than 6 hours per time, and for no more than 100 hours per year. 2 $180 million/year for Southern California Edison and $40 million/year for PG&E. Latest figures for SDG&E were not available.

- 2 -


firm service. Over the past ten years, California ratepayers may have paid close to $2 billion for the operation of this program.

In return for this expenditure, California ratepayers expected to be able to rely upon these customers to curtail when needed in order to meet reliability and/or price criteria. Previous Commission decisions treated interruptible customers the same as any other energy resource (such as a power plant) for purposes of resource planning. Prior to 1998, customers on an interruptible tariff were required to sign three to five year contracts in order to participate in the program. The length of the contract was designed to give the utilities sufficient lead-time to acquire alternative generating resources if a customer left the interruptible rate schedule.

Because California utilities possessed sufficient energy resources to meet demand throughout much of the 1990’s, the utilities’ interruptible programs were seldom if ever used until the Summers of 1998 and 2000. Edison for example did not need to curtail its interruptible industrial customers for almost 14 years (from 1986 until June of this year)4 PG&E also has needed to make few, if any, curtailments throughout the 1990’s, until it issued five curtailments in 1998 and two in 1999.

3 See for example D.92-06-020 (44 CPUC2d 471, 526) and D.96-04-050 (65 CPUC2d 362, 444). The level of the discount depends upon the voltage level at which service is taken. For an illustrative 1 MW baseload customer (70% capacity factor) the level of the discount is about $60,000/year.4 As Edison noted in Advice Letter 1163-E filed in June 1996: Edison has not interrupted customers on these schedules in the last ten years.” As noted in Resolution E-3689, Edison stated it that it curtailed industrial customers for the first time in June 2000. (Resolution E-3689, p. 5.)

- 3 -


In 2000, however, the growth in electric energy usage combined with tight

energy supplies resulted in the ISO calling 15 Stage I events (when operating reserves are expected to fall below 7%) and 10 Stage II events(operating reserves less than 5%). One method to address tight energy supplies, and the subject of this Rulemaking, is to utilize and develop interruptible, curtailable and demand responsiveness programs that encourage consumers to utilize less energy during periods of high energy demand.

The stated5 ability to reduce peak-demand of the utilities’ interruptible program was previously estimated by the ISO at approximately 2,800 MW. Actual operation of these programs over the past Summer, however, shows that some customers (800-1,000 MW) on these rate schedules are not curtailing when called upon to do so and instead are choosing to pay non-compliance rates6 rather than curtail.

PG&E’s interruptible program has been closed to all customers as of February, 1993,7 other than new customers locating in the PG&E

5 The “stated ability” is the amount of curtailment a utility expects to occur assuming that every customer who is operating when a curtailment occurs actually curtails. Because not all interruptible customers are expected to be operating when a curtailment occurs, the amount of load under contract is actually higher. For example, Edison currently has about 3,000 MW of industrial load signed up on interruptible tariffs but expects that only about 1,900 MW of this load will be operating, and hence available to be curtailed, during peak hours6 For Edison, this rate is 70 cents/kWh. 7 See PG&E Advice Letter 1424-E (effective February 8, 1993) which implemented D.92-11-049.

- 4 -


service territory and existing customers who have added new load. Edison’s interruptible program has been closed as of November 26, 1996.8 Therefore, almost all interruptible customers (other than new load entering the service territory) have enjoyed the benefits of lower interruptible rates for at least eight years in the case of PG&E and almost four years in the case of Edison.

In Resolution E-3689 and E-3696 (August 3, 2000), the Commission allowed Edison and PG&E respectively to reopen their interruptible program to new loads, subject to certain conditions.9 As a result of these conditions Edison chose to implement its program while PG&E declined to do so.

In Resolution E-3650 (April 6, 2000), the Commission approved demand responsiveness programs for PG&E (E-BID) and Edison (Voluntary Power Reduction Credit). The purpose of these programs is to allow customers to voluntarily curtail their energy usage anytime the Power Exchange (PX) day-ahead price is greater than $250/hour.10

With the Commission’s restructuring of the electric industry effective on April 1, 1998, the utilities continue to operate and

8 See Resolution E-3474.9 The programs were approved subject to certain modifications designed to: 1) increase program participation; 2) allow the Commission and the ISO to develop coordinated demand relief programs for the Summer of 2001; 3) address equity concerns between new and existing interruptible customers; 4) ensure that new customers signing-up for the program will actually curtail when called upon to do so; and 5) minimize duplication with other programs.

10 Subsequently lowered to $100/MWH for PG&E in Resolution E-3700 (September 21, 2000).

- 5 -


administer the program but the decision to decide when to curtail interruptible customers was transferred from the utilities to the ISO.11

Statutory Requirements The industrial interruptible programs of the utilities are covered

in part by the requirements of Public Utilities Code Sections 743 and 743.1.

PU Code Section 743, adopted in 1991,12 allows that:

The commission may approve contracts between an electrical corporation and its heavy industrial customers as determined by the electrical corporation, of not more than ten years' duration, in which the electrical corporation buys from the heavy industrial customer the right to interrupt the customer's service on short notice, as determined by the commission. The payment mechanism may include a discounted rate for service.

* * *Throughout the term of any of these contracts, the commission shall have the right to amend the contract. Every contract subject to this subdivision shall include a provision indicating that the contract is subject to amendment by the commission as provided in this subdivision.

PU Code Section 743.1, effective January 1, 199713 required that:

Electrical corporations shall continue the availability to qualified heavy industrial customers of optional interruptible or curtailable service. The effective rate for

11 PG&E Advice Letter 1711-E and Edison Advice Letter 1163-E.12 Stats. 1991, Ch. 878, Sec. 1.13 Stats. 1996, Ch. 780, Sec. 1; Effective January 1, 1997.

- 6 -


interruptible or curtailable service to qualifying customers shall reflect a pricing incentive for electing to operate under the interruptible or curtailable service option.

* * *The commission shall continue the availability of optional interruptible or curtailable service at least until March 31, 2002. In no event shall the level of the pricing incentive for interruptible or curtailable service be altered from the levels in effect on June 10, 1996, until March 31, 2002. (Emphasis added.)

Issues Associated with Utility-run Interruptible Programs One of the major purposes of this rulemaking is to examine the

role of customers on a utility’s interruptible tariffs in ensuring reliable and reasonably-priced electric service within California, especially for the Summer of 2001. The goal should be to retain existing interruptible customers as well as to attract new customers to the program.

This goal can be accomplished in a number of ways including; Providing incentives for customers to reduce their energy

usage; Encouraging customers to voluntarily reduce usage; Requiring customers to reduce energy usage; or Some combination of all of the above.One option to increase program participation may be to increase

the financial payments to interruptible customers. In crafting such a program the Commission should ensure that it is not overpaying for demand reductions and that it is adequately evaluating supply-side options (such as paying for new incremental generation) against the incentives paid for customers to curtail.

- 7 -


How customers should be paid for their participation may also affect program participation. The existing interruptible program is similar to an insurance policy in that it pays customers monthly (through reduced rates) in exchange for the ability to curtail these customers for a certain number of hours. The ISO’s programs, by contrast, are based more on an auction approach (either through an RFP process in the case of its Emergency Demand Responsiveness (EDR) program or through hourly ancillary service prices for its Participating Load program. In D.92-11-049 the Commission examined the possibility of changing PG&E’s interruptible program from a monthly “insurance” program to a bidding approach.

The Commission will also consider whether interruptible customers with certain attributes should be paid more than other program participants.14

A factor that must be considered in evaluating these changes is the ability of the Commission to alter the pricing incentives paid to interruptible customers.15

A second option to retain existing interruptible customers, or to attract new customers willing to be interrupted, is to offer non-pricing incentives such as changes in the timing, length, or frequency of curtailment. PU Code Section 743 reserves to the Commission the

14 Under this approach, for example, new interruptible customers who are located in transmission constrained areas could be paid more than customers located in unconstrained areas.

15 PU Code Section 743.1 states in relevant part that: “In no event shall the level of the pricing incentive for interruptible or curtailable service be altered from the levels in effect on June 10, 1996, until March 31, 2002.

- 8 -


“right to amend [interruptible] contract[s]” and states that “Every contract subject to this subdivision shall include a provision indicating that the contract is subject to amendment by the commission.” In Resolution E-3650, establishing the demand responsiveness program, the Commission utilized this authority to allow interruptible customers to participate in the utilities’ demand responsiveness program.

A third option available to the Commission would be to utilize its authority under PU Code Section 743 to modify the existing interruptible contracts and restore them back to the same terms and conditions which existed when customers signed these contracts. Existing interruptible customers entered into these contracts with the understanding that they were contracting for 5-year terms.16 Enforcing the original terms of the contract would help ensure that these customers are available to help California meet its peak demands for the Summer of 2001. Requiring interruptible customers to fulfill their original contractual obligations would also appear equitable in that it ensures that these customers, who have received over $2 billion in reduced rates, are actually available when needed.

In order for the Commission to have adequate time to determine the role of existing interruptible customers in meeting reliability needs for the Summer of 2001, this Rulemaking is proposing to temporarily suspend the tariff provisions of Edison, PG&E, and SDG&E that allow customers to opt-out of their interruptible 16 The contracts are renewed automatically (i.e., “evergreen”) unless the customer gives notice. Under the pre-existing tariffs a customer would have to have given notice in June 1996 in order not to participate in the program for the Summer of 2001.

- 9 -


programs for the 30-day window commencing November 1. Extending the contract terms, as was originally envisioned, should minimally inconvenience existing interruptible customers because they will continue to enjoy the lower rates that interruptible customers receive. Moreover, curtailments during the winter season are unlikely. Interested parties who wish to comment on the proposed suspension of these tariffs may do so by filing comments in this docket. The comments must be received by the Assigned Commissioner within 7 days of this decision.

Finally, the need for voluntary incentives should not be overlooked. Organizations such as the California Retailers Association, state Department of General Services, and the Silicon Valley Manufacturer’s Group have taken the lead in developing voluntary load reduction programs.

Review and Coordination of Interruptible/Demand Responsiveness Programs Offered by the Utilities, the ISO, and Others

The Commission intends to use this Rulemaking to coordinate the operation of all of the various programs being offered to ensure that duplication is minimized, ratepayers benefit, and reliability is increased. The Commission will also use this Rulemaking to determine the respective roles of the Commission and the ISO to operate and offer demand responsiveness and curtailable programs. To ensure coordination, the requests of Edison in Advice Letter 1457-E and of PG&E in Advice Letter 2008-E to allow interruptible customers to participate in the ISO’s Ancillary Services Market are now consolidated into this proceeding. The Commission will address these Advice Letters either in this proceeding or through Commission

- 10 -


Resolution. Edison and PG&E should also file in this proceeding all of the reports required of them in Resolution E-3650 regarding the operation of their respective demand responsiveness programs. This proceeding will serve as the forum for Edison and/or PG&E to if they seek to extend their demand responsiveness programs for the Summer of 2001.

As the Commission concluded in Resolution E-3689:The ISO notes that its EDR and Ancillary Services Load programs are quite likely competing for the same load. Reopening of Edison’s interruptible tariff to new customers is likely to take away some customers who otherwise would have participated in these programs. While a variety of programs might increase overall participation, it appears that many of these programs may just be signing up customers from other programs. The overall cost to ratepayers, and effect on system reliability, is unclear. As more programs develop, the ability of either the Commission or the ISO to prevent customers from receiving more than one payment for the same reduced load becomes more difficult.

Issues Associated with Participation of Smaller CustomersAs the Commission stated in Resolution E-3689:[I]nclusion of smaller customers into interruptible programs could provide a large additional source of untapped new load capable of being curtailed.

The activities of both the utilities and the ISO appear to be focusing almost exclusively upon the larger customers17 who possess the metering (and to a lesser extent the telemetry) equipment needed to participate in curtailable programs. This may have led to duplication of effort and a chasing of a limited amount of load by a

17 Generally those with demand above 500 kW.

- 11 -


number of programs. One purpose of this rulemaking is to identify if and how smaller customers can participate in curtailable programs. Issues that we need to examine are the ability of smaller customers to participate; development of rate design and incentive policies of such participation; a cost/benefit analysis of such programs; and the marketing of any such programs. We are also interested in examining if PG&E and SDG&E should develop an Air Conditioning Cycling program similar to those already operated by both Edison and the Sacramento Municipal Utility District (SMUD)18.

Issues Associated with Post-2002 Operation of Utility Interruptible Programs

The provisions of PU Code Section 743 that require that the Commission continue to offer an interruptible program for heavy industrial customers and that the level of pricing incentives be maintained at the level in effect on June 10, 1996 will both statutorily expire on March 31, 2002. This rulemaking will serve as the forum to begin developing policies for the need, role, and structure of interruptible programs for all customer classes for this post-2002 period.

Review of Curtailment PrioritiesIf successful, the results of this Rulemaking, combined with the

efforts of this Commission and other state agencies to promote increased electric generation and energy efficiency will help to ensure a reliable electric system for California. If needed, however, this

18 Edison’s program is designed to provide approximately 350 MW of demand relief. SMUD’s program, which is triggered to avoid rotating outages, is designed to provide approximately 200 MW of demand relief.

- 12 -


Rulemaking will also serve as the forum for revising and updating our priorities for curtailing customers during times of energy shortages.

PU Code Sections 2771 and 2772 provide that:The commission shall establish priorities among the types or categories of customers of every electrical corporation and every gas corporation, and among the uses of electricity or gas by such customers. The commission shall determine which of such customers and uses provide the most important public benefits and serve the greatest public need and shall categorize all other customers and uses in order of descending priority based upon these standards…

* * *In establishing the priorities pursuant to Section 2771, the commission shall include, but not be limited to, a consideration of all the following: (a) A determination of the customers and uses of electricity and gas, in descending order of priority, which provide the most important public benefits and serve the greatest public need. (b) A determination of the customers and uses of electricity and gas which are not included under subdivision (a). (c) A determination of the economic, social, and other effects of a temporary discontinuance in electrical or gas service to the customers or for the uses determined in accordance with subdivision(a) or (b). (d) Any curtailment or allocation rules, orders, or regulations issued by any agency of the federal government.

Our existing curtailment policies were developed during the early 1980’s after a lengthy, multi-year effort.19 As part of our review of the utilities’ interruptible programs, and as we prepare to address energy needs for the Summer of 2001, the Commission may wish to

19 D.90247, D.91548 and D.82-06-021

- 13 -


make modifications to its decades-old curtailment rules. This Rulemaking will serve as the forum to address proposed changes on the Commission’s own initiative.

Preliminary Scoping MemoThe rules and procedures implementing many of the reforms

contained in Senate Bill (SB) 960 are found in Article 2.5 of Practice and Procedure (Rules), which are posted on the Commission's web site. Pursuant to Rule 4(a), the rules in Article 2.5 shall apply to this proceeding. As per the provisions of SB 960, the present rulemaking is classified as a quasi-legislative proceeding and is expected to require hearings. In the preceding sections, we have listed the issues to be considered in this investigation. This is a preliminary list of issues. The scope of this investigation may be expanded once we take comments from parties and conduct the initial Prehearing Conference (PHC) and formal hearings.

President Loretta M. Lynch shall be the Assigned Commissioner and shall designate an assigned ALJ. The assigned Commissioner and ALJ shall convene a PHC, inform respondents and other interested parties when to file PHC statements, develop a service list for this proceeding, and further delineate issues related to scope and schedule for this proceeding. The date of the PHC will be set by the assigned Commissioner and the ALJ. Any person who objects to the categorization of this investigation must file an appeal 10 days after the date of this OIR, pursuant to Rule 6.4(a).

The temporary service list is attached to this order and shall be used for service until a service list for this proceeding is established

- 14 -


at the PHC. Persons who want to become a "party" to this proceeding shall appear at the PHC, or subsequent hearings, and fill out the "Notice of Party/Non-Party Status" form (appearance form).

Those persons who do not want to be parties, and only want notice of the hearings, rulings, proposed decisions, and decisions may either fill out an appearance form at hearing, or they may mail a written request to the Process Office requesting that they be added to the service list for information only.

Those persons employed by the State of California who are interested in this proceeding may request that they be added to the "state service" section of the service list either by appearing at the PHC or at the formal hearing and filling out an appearance form, or by mailing a written request for "state service" status to the Process Office. Parties are obligated to serve all documents they may submit or file in this proceeding on all names appearing on the state service list.

The Process Office shall develop an initial service list based on the appearances at the first PHC. This initial service list shall be posted on the Commission's web site, http://www.cpuc.ca.gov, as soon as is practicable.

Any party interested in participating in this investigation who is unfamiliar with the Commission's procedures should contact the Commission's Public Advisor Office in Los Angeles (213) 576-7055, or in San Francisco (415) 703-2074 for assistance.

Consistent with Rule 6(e), we expect this proceeding to be concluded within 18 months.

- 15 -


Ex Parte CommunicationsThis proceeding is subject to Rule 7, which specifies standards

for engaging in ex parte communications and the reporting of such communications. Pursuant to Rules 7(a)(3) and 7(d), ex parte communications will be allowed in this proceeding without any restrictions or reporting requirements unless and until the Commission modifies this determination of category.

Therefore, IT IS ORDERED that:1. A rulemaking is instituted on the Commission's own motion to:

a) examine the role of customers on a utility’s interruptible tariffs to ensure reliable and reasonably-priced electric service within California, especially for the Summer of 2001; b) coordinate the variety of interruptible, curtailable and demand responsiveness programs being offered and proposed in California; c) identify alternative means for customers to reduce their energy usage during periods of peak demand; and 4) to revise and update the Commission’s priorities for curtailing customers during times of energy shortages.

2. Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Southern California Edison Company (Edison) and the California Independent System Operators (ISO) are made respondents to this proceeding.

3. The Executive Director shall cause this Order Instituting Rulemaking (OIR) to be served on the respondents and on the service list in Rulemaking R.94-04-031 et al, Case 9884, Edison Advice Letter 1263-E, and PG&E Advice Letter 1711-E.

- 16 -


4. President Loretta M. Lynch shall be the Assigned Commissioner and shall designate an assigned ALJ. The assigned Commissioner and ALJ shall convene a PHC, inform respondents and other interested parties when to file PHC statements, develop a service list for this proceeding and further delineate issues related to scope and schedule for this proceeding.

5. The tariff provisions of Edison, PG&E, and SDG&E that allow customers to opt-out of their interruptible program contracts for the 30-day window commencing November 1 are proposed for temporary suspension by the Commission. Interested parties who wish to comment on the proposed suspension of these tariffs may do so by filing comments in this docket. The comments must be received by the Assigned Commissioner within 7 days of this decision.

6. The request of Edison in Advice Letter 1457-E and of PG&E in Advice Letter 2008-E to allow interruptible customers to participate in the ISO’s Ancillary Services Market are now consolidated into this proceeding. The Commission will address these Advice Letters either in this proceeding or through Commission Resolution.

7. Edison and PG&E shall file in this proceeding all of the reports required of them in Resolution E-3650 regarding the operation of their respective demand responsiveness programs. If Edison and/or PG&E seek to extend these or similar programs for the Summer of 2001, they shall file their proposals in this proceeding.

8. The temporary service list is attached and shall be used for service of all pleadings until a service list for this proceeding is established. The official service list for this proceeding shall be created by the Process Office and posted on the Commission's web

- 17 -


site ( www.cpuc.ca.gov ) as soon as practicable after the first PHC. Parties may also obtain the service list by contacting the Commission's Process Office at (415) 703-2021.

9. This rulemaking is categorized as quasi-legislative as that term is defined in Rule 5(d) of the Commission's Rules of Practice and Procedure. Any person who objects to the categorization of this rulemaking must file an appeal 10 days after the date of this OIR, pursuant to Rule 6.4(a).

10.Persons interested in having their names added to the service list for this proceeding shall follow the procedures described in this order.

This order is effective today.Dated October 5, 2000, at San Francisco, California.

LORETTA M. LYNCHPresident

HENRY M. DUQUEJOSIAH L. NEEPERRICHARD A. BILASCARL W. WOOD

Commissioners

- 18 -

http://www.cpuc.ca.gov/


ATTACHMENT

************ SERVICE LIST ***********Last Update on 10-OCT-2000 by: SMJ

R0010002 NO POST

************ APPEARANCES ************

Charles F. Robinson V.P. And General Counsel CALIFORNIA ISO PO BOX 639014 FOLSOM CA 95630-9014

********** STATE EMPLOYEE ***********

Maria E. Stevens Executive Division RM. 5109 320 WEST 4TH STREET SUITE 500 Los Angeles CA 90013 (213) 576-7012 [email protected]

********* INFORMATION ONLY **********

Don Fuller CALIFORNIA ISO PO BOX 639014 FOLSOM CA 95630-9014

Robert Finkelstein Attorney At Law THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO CA 94102 (415) 929-8876 [email protected]

Michael Shames Attorney At Law UTILITY CONSUMERS' ACTION NETWORK

1717 KETTNER BLVD., SUITE 105 SAN DIEGO CA 92101-2532 (619) 696-6966 [email protected]

- 19 -

mailto:[email protected]




R9404031 ELECTRIC RESTRUCTURINGI9404032

************ APPEARANCES ************ David Marcus ADAMS BROADWELL JOSEPH & CARDOZO

PO BOX 1287 BERKELEY CA 94701-1287 (510) 528-0728 [email protected]

Marc D. Joseph Attorney At Law ADAMS BROADWELL JOSEPH & CARDOZO

651 GATEWAY BOULEVARD, SUITE 900

SOUTH SAN FRANCISCO CA 94080 (650) 589-1660 [email protected]

Dick Ely Director Marketing ADM ASSOCIATES INC. 3239 RAMOS CIRCLE SACRAMENTO CA 95827-2501 (916) 363-8383

Michael Boccadoro Executive Director AGRICULTURAL ENERGY CONSUMERS ASSN 925 L STREET, SUITE 800 SACRAMENTO CA 95814 (916) 441-4383 [email protected]

Daniel W. Douglass Attorney At Law ARTER & HADDEN LLP 5959 TOPANGA CANYON BLVD. SUITE 244

WOODLAND HILLS CA 91367 (818) 596-2201 [email protected]

Lon W. House ASSOCIATION OF CALIF. WATER AGENCIES 4901 FLYING C ROAD CAMERON PARK CA 95682-9615 (530) 676-8956 [email protected]

Barbara R. Barkovich BARKOVICH AND YAP, INC. 31 EUCALYPTUS LANE SAN RAFAEL CA 94901 (415) 457-5537 [email protected]

Reed V. Schmidt BARTLE WELLS ASSOCIATES 1636 BUSH STREET SAN FRANCISCO CA 94109 (415) 775-3113 X111 [email protected]

Marco Gomez Office Of The General Counsel BAY AREA RAPID TRANSIT DISTRICT 800 MADISON STREET, 5TH FLOOR OAKLAND CA 94607 (510) 464-6058 [email protected]

John Burkholder BETA CONSULTING 2023 TUDOR LANE FALLBROOK CA 92028 (760) 723-1831 [email protected] For: City of Long Beach Gas & Electric Dept/Southern California Edison Company.

John Jimison Attorney At Law BRADY & BERLINER 1225 19TH STREET, N.W. STE 800 WASHINGTON DC 20036 (202) 955-6067 [email protected]

Thomas Beach BRADY & BERLINER 2560 9TH ST., SUITE 316 BERKELEY CA 94710 (510) 649-9790 [email protected] For: Watson Cogeneration Company

Maurice Brubaker BRUBAKER & ASSOCIATES, INC. 1215 FERN RIDGE PARKWAY, SUITE 208 ST. LOUIS MO 63141 (314) 275-7007 [email protected]

Douglas M. Grandy Chief CALIF. DEPT. OF GENERAL SERVICES 717 K STREET STE 409 SACRAMENTO CA 95814

- 1 -



Karen Norene Mills Attorney At Law CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO CA 95833 (916) 561-5655 [email protected]

Neal A. Johnson CALIFORNIA INTEGRATED WASTE MGMT BOARD 8800 CAL CENTER DRIVE SACRAMENTO CA 95826-3268 (916) 255-2580 [email protected]

E.D. Yates Senior Vice President CALIFORNIA LEAGUE OF FOOD PROCESSORS 980 NINTH STREET, SUITE 230 SACRAMENTO CA 95814 (916) 444-9260 [email protected]

Chris S. King Vice President CELLNET DATA SYSTEMS, INC. 125 SHOREWAY ROAD SAN CARLOS CA 94070 [email protected]

Deborah L. Berger Deputy City Attorney CITY OF SAN DIEGO 1200 THIRD AVENUE, SUITE 1100 SAN DIEGO CA 92101 (619) 533-5800 [email protected] For: THE CITY OF SAN DIEGO

Michael Pretto CITY OF SANTA CLARA/SILICON VALLEY POWER1500 WARBURTON AVENUE SANTA CLARA CA 95050 (408) 261-5085 [email protected] For: Silicon Valley Power

William C. Prentice Ceo COMPETISYS LLC 2402 MICHELSON, SUITE 232 IRVINE CA 92714

David X. Kolk Ph.D. COMPLETE ENERGY SERVICES INC SUITE 120 650 E. PARKRIDGE AVENUE, UNIT 110 CORONA CA 92879 (909) 283-1097 [email protected]

Virginia Jarrow President CONSUMERS COALITION OF CALIFORNIA 1109 BARBARA STREET RM A REDONDO BEACH CA 90277 (310) 316-3346

Peter W. Michaels SEAN P. BEATTY COOPER WHITE & COOPER 201 CALIFORNIA ST., 17TH FLOOR SAN FRANCISCO CA 94111 (415) 433-1900 [email protected]

Edward B. Lozowicki Attorney At Law COUDERT BROTHERS 303 ALMADEN BLVD, FIFTH FLOOR SAN JOSE CA 95110-2721 (408) 297-9982 [email protected]

Carl K. Oshiro Attorney At Law CSBRT/CSBA 100 FIRST STREET, SUITE 2540 SAN FRANCISCO CA 94105 (415) 927-0158 [email protected] For: California Small Business Association

Lindsey How-Downing LINDSEY HOW-DOWNING Attorney At Law DAVIS WRIGHT TREMAINE LLP ONE EMBARCADERO CENTER, STE 600 SAN FRANCISCO CA 94111-3834 (415) 276-6528 [email protected]

- 2 -



(949) 417-2800 [email protected]

Dennis W. De Cuir DE CUIR & SOMACH 2999 DOUGLAS BLVD., SUITE 325 ROSEVILLE CA 95661 (916) 788-1022

Sam De Frawi BUILDING 212, 4TH FLOOR 1314 HARWOOD STREET, SE WASHINGTON NAVY YARD DC 20374-5018


Norman J. Furuta Associate Counsel DEPARTMENT OF THE NAVY 900 COMMODORE DRIVE SAN BRUNO CA 94066-5006 (650) 244-2100 [email protected]

Timothy M. Dayonot DEPT. OF COMMUNITY SERVICES AND DEV. 700 NORTH TENTH STREET RM 258 SACRAMENTO CA 95814-0338 (916) 322-2940

James M. Day, Jr. Attorney At Law DOWNEY BRAND SEYMOUR & ROHWER LLP 555 CAPITOL MALL 10TH FLOOR SACRAMENTO CA 95814-4686 (916) 441-0131 For: Merced Irrigation District

Philip A. Stohr Attorney At Law DOWNEY, BRAND, SEYMOUR & ROHWER

555 CAPITOL MALL, 10TH FLOOR SACRAMENTO CA 95814-4686 (916) 441-0131 [email protected]

Carolyn A. Baker DUKE ENERGY NORTH AMERICA 980 NINTH STREET, 16TH FLOOR SACRAMENTO CA 95814 (916) 449-9623 [email protected]

Dani Jo Merryman Attorney At Law EDISON SOURCE 955 OVERLAND COURT SAN DIMAS CA 91773 (909) 450-6035 For: EDISON SOURCE

Renee H. Guild ELECTRIC POWER RESEARCH INSTITUTE PO BOX 10412 3412 HILLVIEW AVENUE PALO ALTO CA 94304-1395 (650) 855-2000

Christopher T. Ellison Attorney At Law ELLISON & SCHNEIDER 2015 H STREET SACRAMENTO CA 95814-3109 (916) 447-2166 [email protected]

Diane I. Fellman Attorney At Law ENERGY LAW GROUP LLP 1999 HARRISON ST. SUITE 2700 OAKLAND CA 94612-3572 (510) 874-4301 [email protected] For: NRG Energy, Inc.

Andrew J. Skaff Attorney At Law ENERGY LAW GROUP, LLP 1999 HARRISON STREET, 27TH FLOOR OAKLAND CA 94612 (510) 874-4370 [email protected]

Carolyn Kehrein ENERGY MANAGEMENT SERVICES 1505 DUNLAP COURT DIXON CA 95620-4208 (707) 678-9586 [email protected]

Robert T. Boyd ENRON WIND CORP. 13000 JAMESON ROAD TEHACHAPI CA 93561 (661) 823-6734 [email protected]

- 3 -



Richard P. Felak P.E. 27 NORWOOD WAY SCHENECTADY NY 12309-4856 (518) 374-3855

Faramarz M. Yazdani FMY ASSOCIATES, INC. 146 MAIN STREET, SUITE 404 LOS ALTOS CA 94022 (650) 941-3850

Gregg Morris FUTURE RESOURCES ASSOCIATES, INC.

2039 SHATTUCK AVENUE, STE 402 BERKELEY CA 94704 [email protected]

Margaret A. Rostker Attorney At Law GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP505 SANSOME STREET, SUITE 900 SAN FRANCISCO CA 94111 (415) 392-7900 [email protected]

Michael B. Day Attorney At Law GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP505 SANSOME STREET, SUITE 900 SAN FRANCISCO CA 94111-3133 (415) 392-7900 [email protected]

Julie Blunden GREEN MOUNTAIN ENERGY RESOURCES L.L.C. SUITE 1500 50 CALIFORNIA STREET SAN FRANCISCO CA 94111 (415) 613-8362 [email protected]

Beth Dunlop GRUENEICH RESOURCE ADVOCATES

582 MARKET STREET, SUITE 1020 SAN FRANCISCO CA 94104-5305 (415) 834-2300 [email protected] For: University of California/California State University

Steven Kelly INDEPENDENT ENERGY PRODUCERS ASSN 1112 I STREET, SUITE 380 SACRAMENTO CA 95814-2823 (916) 448-9499

Robert E. Burt INSULATION CONTRACTORS ASSN/RESCUE 1911 F STREET SACRAMENTO CA 95814 (916) 444-2950 [email protected]

Bob Tang Manager INTEGRATED RESOURCE PLANNING CITY OF AZUSA 729 NORTH AZUSA AVE./PO BOX 9500 AZUSA CA 91702-9522 (626) 812-5208 [email protected]

Mark A. Baldwin President INTERSTATE GAS SERVICES, INC. 2600 KITTYHAWK ROAD, SUITE 101 LIVERMORE CA 94550 (925) 243-0350 [email protected]

William B. Marcus JBS ENERGY, INC. 311 D STREET, SUITE A WEST SACRAMENTO CA 95605 (916) 372-0534 [email protected]

Norman A. Pedersen Attorney At Law JONES DAY REAVIS & POGUE 555 WEST FIFTH ST., STE. 4600 LOS ANGELES CA 90013-1025 [email protected]

Kirk T. Morgan KERN RIVER GAS TRANSMISSION COMPANY MAILSTOP 303 295 CHIPETA WAY SALT LAKE CITY UT 84158-0900 (801) 584-7061

- 4 -



Yvonne Ladson Webb LADSON ASSOCIATES 870 MARKET STREET, SUITE 765 SAN FRANCISCO CA 94102 (415) 296-8387 [email protected]

Susan E. Brown Attorney At Law LATINO ISSUES FORUM 785 MARKET STREET, 3RD FLOOR SAN FRANCISCO CA 94103-2003 (415) 284-7224 [email protected]

Richard L. Hamilton Attorney At Law LAW OFFICE OF RICHARD L. HAMILTON

100 HOWE AVE. SUITE 230N SACRAMENTO CA 95825 (916) 484-7646 [email protected] For: Western Mobilehome Parkowners Association

Barry F. Mccarthy Attorney At Law LAW OFFICES OF BARRY F. MCCARTHY

2105 HAMILTON AVENUE, STE 140 SAN JOSE CA 95125 (408) 558-0950 [email protected]

William H. Booth Attorney At Law LAW OFFICES OF WILLIAM H. BOOTH

1500 NEWELL AVENUE, SUITE 500 WALNUT CREEK CA 94596 (925) 296-2460 [email protected] For: California Large Energy Consumers Association

Christopher A. Hilen Attorney At Law LEBOEUF LAMB GREENE & MACRAE LLP

ONE EMBARCADERO CENTER, STE 400

SAN FRANCISCO CA 94111 (415) 951-1100 [email protected]

John W. Leslie Attorney At Law LUCE FORWARD HAMILTON & SCRIPPS, LLP 600 WEST BROADWAY, SUITE 2600 SAN DIEGO CA 92101 (619) 236-1414 [email protected]

Donald H. Maynor Attorney At Law 235 CATALPA DRIVE ATHERTON CA 94027 (650) 327-2894 [email protected] For: Municipal Resource Consultants

David J. Byers Attorney At Law MCCRACKEN, BYERS & HAESLOOP 840 MALCOLM ROAD, SUITE 100 BURLINGAME CA 94010 (650) 259-5979 [email protected]. For: California City-County Street Light Assn.

Ann T. Finley METROPOLITAN WATER DIST OF SO. CALIF PO BOX 54153 LOS ANGELES CA 90054-0153 (213) 217-7136 [email protected]

Christopher J. Mayer MODESTO IRRIGATION DISTRICT PO BOX 4060 MODESTO CA 95352-4060 (209) 526-7430 [email protected]

Peter W. Hanschen Attorney At Law MORRISON & FOERSTER LLP 425 MARKET STREET SAN FRANCISCO CA 94105 (415) 268-7214 [email protected] For: New West Energy Corporation

Robert B. Weisenmiller Phd MRW & ASSOCIATES, INC. 1999 HARRISON STREET, STE 1440 OAKLAND CA 94612-3517 (510) 834-1999

- 5 -



Emilio E. Varanini, I I I LIVINGSTON & MATTESICH 1201 K STREET, STE 1100 SACRAMENTO CA 95814 (916) 442-1111

[email protected]

Sara Steck Myers Attorney At Law 122 28TH AVENUE SAN FRANCISCO CA 94121 (415) 387-1904 [email protected]

Michele Wynne MZA GRID SERVICES SUITE 200 5230 PACIFIC CONCOURSE DRIVE LOS ANGELES CA 90045 (310) 643-4416 [email protected]

Sheryl Carter NATURAL RESOURCES DEFENSE COUNCIL 71 STEVENSON STREET, SUITE 1825 SAN FRANCISCO CA 94105 (415) 777-0220 [email protected]

Aaron Thomas NEWENERGY, INC. 1000 WILSHIRE BOULEVARD, SUITE 1900

LOS ANGELES CA 90017 (213) 996-6136 [email protected]

Stan Marks PHIL KRUMPOS Phil Krumpos NRG ENERGY, INC. SYMPHONY TOWERS, SUITE 2740 750 B STREET SAN DIEGO CA 92101 [email protected]

Peter Ouborg Attorney At Law PACIFIC GAS AND ELECTRIC COMPANY

LAW DEPARTMENT B30A 77 BEALE STREET, ROOM 3163 SAN FRANCISCO CA 94105 (415) 973-2286 [email protected]

Roger J. Peters PACIFIC GAS AND ELECTRIC COMPANY

Sharon Arceneaux PACIFICORP 800 LLOYD CENTER TOWER 825 N.E. MULTNOMAH STREET PORTLAND OR 97232 (503) 464-5000

Ward Camp Director, Regulatory Strategy PNM ENERGY SERVICES PUBLIC SERVICE COMPANY OF NEW MEXICO ALVARADO SQUARE - MS SIM9 ALBUQUERQUE NM 87158 (505) 541-4251 [email protected]

Patrick J. Power Attorney At Law 1300 CLAY ST. RM. 600 OAKLAND CA 94612 (510) 446-7742 [email protected] For: City of Long Beach

Richard M. Hairston R.M. HAIRSTON COMPANY 1112 LA GRANDE AVENUE NAPA CA 94558-2168 (707) 257-7077

Don Schoenbeck RCS, INC 900 WASHINGTON STREET, SUITE 1000 VANCOUVER WA 98660 (360) 737-3877 [email protected]

James A. Ross RCS, INC 500 CHESTERFIELD CENTER, SUITE 320 CHESTERFIELD MO 63017 (636) 530-9544 [email protected]

Daniel W. Meek Attorney At Law RESIDENTIAL ENERGY SVCS COMPANIES.... 10949 S.W. 4TH AVENUE PORTLAND OR 97219 (503) 293-9021 [email protected]

- 6 -



LAW DEPARTMENT B30A PO BOX 7442 SAN FRANCISCO CA 94120-7442 (415) 973-9271

For: Attorney for RESCUE

Don Wolven RESOURCE MANAGEMENT INTERNATIONAL,INC. 3100 ZINFANDEL DRIVE, SUITE 600 RANCHO CORDOVA CA 95670 (916) 852-1300

Mohamed M. El-Gasseir Ph.D RUMLA, INC. 3243 GLORIA TERRACE LAFAYETTE CA 94549 (925) 938-2535 [email protected]

Jim Parks Supervisor, Energy Services Planning SACRAMENTO MUNICIPAL UTILITY DIST.

PO BOX 15830 SACRAMENTO CA 95852-1830

Rob Roth SACRAMENTO MUNICIPAL UTILITY DISTRICT 6301 S STREET SACRAMENTO CA 95817-1899

Byford E. Hoffman SALT RIVER PROJECT PO BOX 52025 ISB666 PHOENIX AZ 85072-2025 (602) 236-5900

Lee Schavrien Attorney At Law SAN DIEGO GAS & ELECTRIC CO. PO BOX 1831 SAN DIEGO CA 92112 (619) 696-4050

James F. Walsh Attorney At Law SAN DIEGO GAS & ELECTRIC COMPANY

PO BOX 1831 SAN DIEGO CA 92112 (619) 699-5039 [email protected]

John Light General Counsel

Steven R. Schiller Principal SCHILLER ASSOCIATES 1333 BROADWAY, SUITE 1015 OAKLAND CA 94612 (510) 444-6500 [email protected]

Lisa Hubbard SEMPRA ENERGY 601 VAN NESS AVENUE, SUITE 2060 SAN FRANCISCO CA 94102 (415) 202-9986 [email protected]

Paul A. Szymanski Attorney SEMPRA ENERGY 101 ASH STREET SAN DIEGO CA 92101 (619) 699-5078 [email protected]

Richard Esteves SESCO, INC. 77 YACHT CLUB DRIVE, RM 1000 LAKE FOREST NJ 07849 (973) 663-5125 [email protected]

Robert B. Gex SKJERVEN MORRILL MACPHERSON LLP SUITE 2800 THREE EMBARCADERO CENTER SAN FRANCISCO CA 94111 (415) 217-6000 [email protected]

Ann P. Cohn Assistant General Counsel SOUTHERN CALIFORNIA EDISON COMPANY PO BOX 800 ROSEMEAD CA 91770 (626) 302-2863

Bruce Foster Regulatory Affairs SOUTHERN CALIFORNIA EDISON COMPANY 601 VAN NESS AVENUE, SUITE 2040 SAN FRANCISCO CA 94102 (415) 775-1856 [email protected]

- 7 -



SAN DIEGO GAS & ELECTRIC COMPANY

101 ASH STREET SAN DIEGO CA 92101

Julie A Miller Attorney At Law SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE ROSEMEAD CA 91770 (818) 302-4017 [email protected]

Frank A. Spasaro Dsm Transition Manager SOUTHERN CALIFORNIA GAS COMPANY

555 WEST FIFTH STREET, ML-22E2 LOS ANGELES CA 90013-1011 (213) 244-3648 [email protected]

Raymond P. Juels Regulatory Affairs SOUTHERN CALIFORNIA WATER COMPANY 630 EAST FOOTHILL BOULEVARD SAN DIMAS CA 91773 (909) 394-3600 [email protected] For: BEAR VALLEY ELECTRIC SERVICE

Claudia Cancilla Administrative Assistant SPURR 1430 WILLOW PASS RD., SUITE 240 CONCORD CA 94520-7929

Michael Rochman Managing Director SPURR 1430 WILLOW PASS ROAD, SUITE 240 CONCORD CA 94520 (925) 743-1292 [email protected]

James C. Paine Attorney At Law STOEL RIVES LLP 900 S.W. FIFTH AVENUE, STE 2600 PORTLAND OR 97204-1268 (503) 294-9246 [email protected]

Keith R. Mccrea Attorney At Law

James E. Scarff Legal Division RM. 5121 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1440 [email protected]

Christopher Witteman General Counsel/Policy Director THE GREENLINING INSTITUTE 785 MARKET STREET, 3RD FLOOR SAN FRANCISCO CA 94103-2003 (415) 284-7202 [email protected]

Robert Finkelstein Attorney At Law THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO CA 94102 (415) 929-8876 [email protected]

Patrick Mcdonell TXU ENERGY SERVICES, INC. SUITE 240 900 LARKSPUR LANDING CIRCLE LARKSPUR CA 94939 (415) 461-5820 [email protected]

Roger L. Conkling Adjunct Professor UNIVERSITY OF PORTLAND 2539 S.W. HILL CREST DRIVE PORTLAND OR 97201 (503) 283-7224 [email protected]

Michael Shames Attorney At Law UTILITY CONSUMERS' ACTION NETWORK 1717 KETTNER BLVD., SUITE 105 SAN DIEGO CA 92101-2532 (619) 696-6966 [email protected] For: Utility Consumers' Action Network

Philip M. Vermeulen 3457 CASTLE CREEK CT. ROSEVILLE CA 95661-7354

- 8 -



SUTHERLAND, ASBILL & BRENNAN LLP

1275 PENNSYLVANIA AVE., N.W., SUITE 800 WASHINGTON DC 20004-2415 (202) 383-0705 [email protected] For: California Manufacturers Association


Tom Lu WATSON COGENERATION COMPANY

22850 SOUTH WILMINGTON AVE. CARSON CA 90749

Jerry R. Bloom Attorney At Law WHITE & CASE LLP TWO EMBARCADERO CENTER, SUITE 650

SAN FRANCISCO CA 94111 (415) 544-1100 [email protected]

********** STATE EMPLOYEE ***********

Jonathan Bromson Legal Division RM. 5131 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2362 [email protected]

Caryn J. Hough CALIFORNIA ENERGY COMMISSION

OFFICE OF CHIEF COUNSEL 1516 NINTH STREET, MS-14 SACRAMENTO CA 95814 (916) 654-4178

David Abelson Attorney At Law CALIFORNIA ENERGY COMMISSION

1516 9TH STREET, MS-14 SACRAMENTO CA 95814 (916) 654-3951

David Hungerford CALIFORNIA ENERGY COMMISSION

1516 NINTH STREET, MS-22 SACRAMENTO CA 95814 (916) 654-4906 [email protected]

Docket 95-Er-96 CALIFORNIA ENERGY COMMISSION MS-4 1516 9TH STREET SACRAMENTO CA 95184

Jennifer Tachera Attorney At Law CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS-14 SACRAMENTO CA 95814-5504 (916) 654-3870 [email protected]

Karen Griffin CALIFORNIA ENERGY COMMISSION MS-20 1516 9TH STREET SACRAMENTO CA 95184

Lorenzo Kristov CALIFORNIA ENERGY COMMISSION 1516 9TH ST., MS-22 SACRAMENTO CA 95814 (916) 654-4773 [email protected]

Michael Jaske CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS-22 SACRAMENTO CA 95814 (916) 654-4777 [email protected]

Michael Messenger CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS-22 SACRAMENTO CA 95184 (916) 654-4774 [email protected]

Susan Bakker Atty At Law CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS 20 SACRAMENTO CA 95814

Energy Consultant - 9 -



Dennis Fukumoto CALIFORNIA ENERGY COMMISSION

MS-26 1516 9TH STREET SACRAMENTO CA 95184

Office Of Governmental Affairs CALIFORNIA PUBLIC UTILITIES COMMISSION 770 L STREET, STE 1050 SACRAMENTO CA 95814

Sean F. Casey Office of Ratepayer Advocates RM. 4102 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1667 [email protected]

Scott Cauchois Office of Ratepayer Advocates RM. 4205 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1525 [email protected]

Michelle Cooke Administrative Law Judge Division RM. 5012 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2637 [email protected]

Christopher Danforth Office of Ratepayer Advocates RM. 4101 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1481 [email protected]

Dorothy Duda Administrative Law Judge Division RM. 5012 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2800 [email protected]

Janet A. Econome Administrative Law Judge Division RM. 5113 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1494 [email protected]

Darwin Farrar

Sean Gallagher Legal Division RM. 5035 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2059 [email protected]

David M. Gamson Executive Division RM. 5214 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1997 [email protected]

Judith Ikle Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1486 [email protected]

David E. Morse 770 L STREET, SUITE 1050 SACARMENTO CA 95814

Wade McCartney Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2167 [email protected]

Angela K. Minkin Administrative Law Judge Division RM. 5116 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1573 [email protected]

Maurice Monson Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102

- 10 -



Legal Division RM. 5039 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1599 [email protected]


Steve Roscow Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1189 [email protected]

Ulla Maija Wait ROBERT CASTANEDA, JR. Dept. Of Community Svcs & Dev. STATE OF CALIFORNIA 700 NORTH 10TH ST., ROOM 258 SACRAMENTO CA 95814-0338

Linda Serizawa Executive Division RM. 5119 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1383 [email protected]

Howard Shryock Energy Division AREA 4-A 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2255 [email protected]

Ourania M. Vlahos Legal Division RM. 5125 505 VAN NESS AVE San Francisco CA 94102 (415) 703-2387 [email protected]

John S. Wong Administrative Law Judge Division RM. 5019 505 VAN NESS AVE San Francisco CA 94102 (415) 703-3130 [email protected]

Helen W. Yee Legal Division RM. 5031 505 VAN NESS AVE

********* INFORMATION ONLY **********

Evelyn Kahl Elsesser Attorney At Law ALCANTAR & ELSESSER LLP ONE EMBARCADERO CENTER, STE 2420 SAN FRANCISCO CA 94111 (415) 421-4143 [email protected] For: ENERGY PRODUCERS AND USERS COALITION

Michael Alcantar Attorney At Law ALCANTAR & ELSESSER LLP 1300 SW 5TH AVENUE., SUITE 1750 PORTLAND OR 97201 (503) 402-9900 [email protected] For: COGENERATION ASSOCIATION OF CALIFORNIA

David W. Penn Deputy Executive Director AMERICAN PUBLIC POWER ASSOCIATION 2301 M STREET, N.W., 3RD FLOOR WASHINGTON DC 20037-1484 (202) 467-2900

Edward G. Poole Attorney At Law ANDERSON, DONOVAN & POOLE 601 CALIFORNIA ST., SUITE 1300 SAN FRANCISCO CA 94108-2818 (415) 956-6413 [email protected]

Scott Wakefield Chief Counsel ARIZONA RESIDENTIAL UTILITY CONSUMER OFF2828 NORTH CENTRAL AVE., STE 1200 PHOENIX AZ 85004 (602) 279-5659

Denise Cazalet AUTOMATED POWER EXCHANGE 26340 ALEXANDER PLACE LOS ALTOS HILLS CA 94022 (650) 949-1672

Tom Dukich - 11 -



San Francisco CA 94102 (415) 703-2474 [email protected]

AVISTA CORP PO BOX 3727 SPOKANE WA 99220-3727 (509) 482-4724 [email protected]

Scott Blaising Attorney At Law 8980 MOONEY ROAD ELK GROVE CA 95624 (916) 682-9702 [email protected]

Jonathan M. Teague CALIFORNIA DEPARTMENT OF GENERAL SERVICEOFFICE OF ENERGY ASSESSMENTS

717 K STREET, SUITE 409 SACRAMENTO CA 95814-3406 (916) 322-8808 [email protected]

J. A. Savage CALIFORNIA ENERGY MARKETS 3006 SHEFFIELD AVENUE OAKLAND CA 94602-1545 (510) 534-9109 [email protected]

Jason Mihos Regulatory Correspondent CALIFORNIA ENERGY MARKETS 9 ROSCOE STREET SAN FRANCISCO CA 94110-5921 (415) 824-3222 [email protected]

Christine Henning CALIFORNIA INDEPENDENT SYSTEM OPERATOR 151 BLUE RAVINE ROAD FOLSOM CA 95630 (916) 351-2365

Gerald L. Jordan Executive Director CALIFORNIA MUNICIPAL UTILITIES ASSN

915 L STREET SUITE 1460 SACRAMENTO CA 95814-3705 (916) 441-1733 [email protected]

John A. Barthrop General Counsel

Jesse D. Frederick President CONSUMERS UTILITY BROKERAGE, INC. C/O WZI, INC 4700 STOCKDALE HWY, SUITE 120 BAKERSFIELD CA 93309 (805) 326-1495

Arthur W. Pearson Cem CORPORATE PROPERTY MANAGEMENT METLIFE ONE MADISON AVE., AREA 19A NEW YORK NY 10010-3690 (212) 578-6212

Eric Wills DAGGETT LEASING CORPORATION 20668 PASEO DE LA CUMBRE YORBA LINDA CA 92687-3335

Mark J. Berman Director Of Business Development DAVIS ENERGY GROUP 123 C STREET DAVIS CA 95616 (530) 753-1100

Linda J. Dondanville Consultant 5342 WINDING VIEW TRAIL SANTA ROSA CA 95404 (707) 528-8151

Wallace L. Duncan Attorney At Law DUNCAN WEINBERG MILLER PERMBROKE 1615 M STREET, N.W., STE 800 WASHINGTON DC 20036 (202) 467-6370 [email protected]

Edward Duncan 4149 RAYA WAY SAN DIEGO CA 92122-3603

Gregory T. Blue Manager, State Regulatory Affairs DYNEGY, INC. 5976 W. LAS POSITAS BLVD., STE. 200 PLEASANTON CA 94588

- 12 -



COMMONWEALTH ENERGY CORP.

15991 RED HILL AVENUE, NO. 201 TUSTIN CA 92780 (714) 258-0470 [email protected]


Anthony W. Wayne President EASTERN PACIFIC ENERGY 2913 SATURN STREET, SUITE G BREA CA 92821 (714) 524-9848

Martha A. Spikes EDISON MISSION ENERGY SUITE 1750 18101 VON KARMAN AVENUE IRVINE CA 92715-1007 (714) 798-7895

Jon S. Silva Government Affairs Associate EDISON SOURCE 955 OVERLAND COURT SAN DIMAS CA 91773 (909) 450-6035 [email protected]

Jeffery D. Harris Attorney At Law ELLISON & SCHNEIDER 2015 H STREET SACRAMENTO CA 95814-3109 (916) 447-2166 [email protected]

Albert K. Davies Director Of Project Development ENRON WIND DEVELOPMENT CORP.

1710 HAPPY VALLEY ROAD SANTA ROSA CA 95409

Barney Ugarte Senior Administrative Assistant ENVIRONMENTAL SCIENCE ASSOCIATES

225 BUSH STREET, STE 1700 SAN FRANCISCO CA 94104 (415) 896-5900 [email protected]

Dennis Scott President FAIRHAVEN POWER COMPANY 1053 NORTHWESTERN AVENUE FORTUNA CA 95540

Donald M. Johnson Chief Operating Officer FULL POWER CORPORATION 4155 E. JEWELL AVENUE, STE 805 DENVER CO 80222-4512 (310) 258-0488 [email protected]

Matthew W. White Assistant Professor Of Economics GRADUATE SCHOOL OF BUSINESS STANFORD UNIVERSITY STANFORD CA 94305-5015 (650) 725-5854 [email protected]

Douglas E. Davie HENWOOD ENERGY SERVICES, INC. 2710 GATEWAY OAKS DRIVE, STE. 300 NORTH SACRAMENTO CA 95833 (916) 569-0985 [email protected]

Bernays T. Barclay Esquire KING & SPALDING 1185 AVENUE OF THE AMERICAS NEW YORK NY 10036-4003 (212) 556-2181 [email protected]

John Howard KW AWARE LLC 1559 SPINNAKER DRIVE SUITE 201 VENTURA CA 93001 (805) 642-7933 [email protected]

Ryan Wiser LBNL MS-90-4000 ONE CYCLOTRON ROAD BERKELEY CA 94720

Roger Levy LEVY AND ASSOCIATES 2805 HUNTINGTON ROAD SACRAMENTO CA 95864 (916) 487-8559

- 13 -



(707) 725-6911

Richard A. Shortz Esquire MORGAN, LEWIS & BOCKIUS LLP 300 SOUTH GRAND AVE., 22ND FLOOR

LOS ANGELES CA 90071-3132 (213) 612-2500 [email protected]

Scott Andreson MORRISON & FOERSTER 425 MARKET STREET SAN FRANCISCO CA 94105-2482 (415) 269-6390 [email protected]

Jay Morse Office of Ratepayer Advocates RM. 4101 505 VAN NESS AVE San Francisco CA 94102 (415) 703-1587 [email protected]

Steven A. Shrader ONSITE ENERGY CORPORATION 701 PALOMAR AIRPORT ROAD, STE 200

CARLSBAD CA 92009

John Prevost PACIFIC LUMBER CO PO BOX 37 SCOTIA CA 95565 (707) 764-2222

Nancy Towne-Smith Regulatory Operations Coordinator PACIFICORP 825 NE MULTNOMAH, STE 800 PORTLAND OR 97232 (503) 813-6068 [email protected] For: PACIFICORP

Ed Lucha PG&E MAIL CODE: B9A PO BOX 770000 SAN FRANCISCO CA 94177 (415) 973-3872 [email protected]

Peter Hindley POWER SYSTEMS SERVICES 600 PANORAMIC HIGHWAY MILL VALLEY CA 94941 (415) 398-4919

Blueley I. Anderson POWER VALUE INCORPORATED 877 YGNACIO VALLEY ROAD, STE 105 WALNUT CREEK CA 94596 (510) 938-8735 [email protected]

Pete Price PRICE CONSULTING 1029 K STREET, SUITE 38 SACRAMENTO CA 95814 (916) 448-1015 [email protected]

Terrence J. Moran PUBLIC SERVICE ELECTRIC & GAS COMPANY 80 PARK PLAZA T25A NEWARK NJ 07102 (973) 430-7105 [email protected]

Pamela T. Johnson REMAC 9300 IMPERIAL HIGHWAY DOWNEY CA 90242-2890 (562) 922-6336 [email protected]

Bryan W. Griess RESOURCE MANAGEMENT INTERNATIONAL, INC. 3100 ZINFANDEL DRIVE, STE 600 RANCHO CORDOVA CA 95670 (916) 852-1300

Roxanne Figueroa RICHARD HEATH AND ASSOCIATES, INC. 1420 HARBOR BAY PKWY STE 145 ALAMEDA CA 94502-7088 (510) 748-4330 [email protected]

C. Anthony Braun Special Counsel SACRAMENTO MUNICIPAL UTILITIES ASSN 915 L STREET, SUITE 1460 SACRAMENTO CA 95814-3705 (916) 441-1733

- 14 -



Timothy J. Haines SACRAMENTO MUNICIPAL UTILITY DISTRICT KEY ACCOUNT SERVICES PO BOX 15830, MAIL STOP A453 SACRAMENTO CA 95852-1830 (916) 452-3211

David M. Norris Attorney At Law SIERRA PACIFIC POWER COMPANY

6100 NEIL ROAD RENO NV 89520-0024 (775) 834-3939 [email protected]

Duane Nelson SIERRA PACIFIC POWER COMPANY

6100 NEIL ROAD, PO BOX 10100 RENO NV 89520-0024 (775) 834-4711 [email protected]

James Caldwell T G A L, INC. PO BOX 26 TRACY'S LANDING MD 20779 (410) 257-3195 [email protected]

Tony Wetzel THERMO ECOTEK CORPORATION

735 SUNRISE AVE., 160 ROSEVILLE CA 95661 (916) 773-2940 [email protected]

Alicia Torre 775 BUCKLAND AVENUE BELMONT CA 94002 (415) 591-6869 [email protected]

Mathew Trask TRASK & ASSOCIATES 239 BRODERICK STREET SAN FRANCISCO CA 94117 [email protected]

Elsie Cardona UTILITY DESIGN, INC.

Steven A. Weissman Executive Division RM. 4103 505 VAN NESS AVE San Francisco CA 94102 (415) 703-5173 [email protected]

- 15 -



5528 PACHECO BLVD. PACHECO CA 94553 (510) 674-0218

(END OF ATTACHMENT)

- 16 -

BEFORE THE PUBLIC UTILITIES COMMISSION OF …docs.cpuc.ca.gov/word_pdf/FINAL_DECISION/2831.doc ·...

Documents

Transcript of BEFORE THE PUBLIC UTILITIES COMMISSION OF …docs.cpuc.ca.gov/word_pdf/FINAL_DECISION/2831.doc ·...