BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA · 2014-11-25 · BEFORE THE...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Order Instituting Rulemaking to Develop a Risk-Based Decision-Making Framework to Evaluate Safety and Reliability Improvements and Revise the General Rate Case Plan for Energy Utilities

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R.13-11-006 (Filed November 14, 2013)

COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) AND PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) ON THE PROPOSED DECISION

OF ASSIGNED COMMISSIONER PEEVEY

FRANK A. McNULTY JANE LEE COLE

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-3860 Facsimile: (626) 302-2610 E-mail: [email protected]

Dated: November 24, 2014

SUMMARY OF RECOMMENDED CHANGES

The utilities should have a minimum of 120 days following the S-MAP decision to

prepare the RAMP.

The RAMP should be a phase of the GRC proceeding, not a separate proceeding, and the utilities should proceed with their GRCs on November 1 regardless of whether the RAMP has concluded.

At least 45 days should be provided in all proceedings for serving rebuttal testimony.

The Prehearing Conference for GRCs should be scheduled on November 15.

The Proposed Decision should acknowledge the possible need for confidentiality in data

and models provided during the S-MAP, RAMP and GRC proceedings.

The Commission should assign two ALJs for the major rate cases.

The Proposed Decision should clarify that SED staff, or its consultants, will be subject to discovery and made available to testify about their reports if the reports are to be made part of the record.

The Proposed Decision should clarify that the new reporting requirements will take effect

after the conclusion of the first GRC following the first S-MAP and RAMP proceedings for a given utility.

The Proposed Decision should clarify that SCE’s 2018 GRC will not include a formal RAMP process and that the GRC application would be submitted on November 1, 2016.

PG&E’s 2017 GRC and Gas Transmission and Storage cases should follow the schedule proposed herein.

Comments of SCE and PG&E on the Proposed Decision of Assigned Commissioner Peevey

Table Of Contents

Section Page

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I. AREAS THAT WARRANT MODIFICATION .............................................................................2

A. The Interplay Between the S-MAP and the RAMP .............................................................2

B. The Design of the RAMP ....................................................................................................3

C. The Timing of the Specific Events in the GRC ...................................................................4

1. Rebuttal Testimony Needs at Least 45 Days ...........................................................4

2. The Prehearing Conference Should Be Held in 15 Days .........................................5

D. Treatment of Confidential Information in the S-MAP and RAMP .....................................5

E. The Assignment of Two ALJs .............................................................................................5

F. The Role of SED ..................................................................................................................6

G. The New Reporting Requirements.......................................................................................6

II. SCE-SPECIFIC ISSUES .................................................................................................................7

III. PG&E-SPECIFIC ISSUES ..............................................................................................................8

A. 2017 GRC ............................................................................................................................8

B. GT&S Rate Cases ..............................................................................................................10

IV. CONCLUSION ..............................................................................................................................10

Appendix A Proposed Revisions To Findings Of Fact, Conclusion Of Law And Order ..............................

COMMENTS OF SCE AND PG&E ON THE PROPOSED DECISION OF ASSIGNED COMMISSIONER PEEVEY

Table of Authorities

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Page(s)

Federal Case Law

Goldberg v. Kelly,

397 U.S. 254 (1970) .......................................................................................................6

California Statutes

Cal. Admin. Code, Title 20,

Commission’s Rules of Practice and Procedure

Rule 14.3 ..............................................................................................................................1

Public Utilities Code

§583......................................................................................................................................5

General Orders

GO 66-c ................................................................................................................................5

Commission Decisions

D.11-05-018 6

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STATE OF CALIFORNIA


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R.13-11-006 (Filed November 14, 2013)

COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) AND PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) ON THE PROPOSED DECISION

OF ASSIGNED COMMISSIONER PEEVEY

Pursuant to Rule 14.3 of the Rules of Practice and Procedure of the California Public

Utilities Commission (Commission), Southern California Edison Company (SCE) and Pacific

Gas and Electric Company (PG&E) submit these opening comments on the November 3, 2014

Proposed Decision of Commissioner Peevey in the above-captioned matter.

SCE and PG&E appreciate the progress in the Proposed Decision toward better

incorporating risk-based decision-making into General Rate Cases (GRCs) and we support the

Commission’s efforts. Today’s comments further that objective. These comments seek to:

(i) eliminate or revise new administrative procedures that are likely to have adverse

consequences;

(ii) clarify open issues; and,

(iii) propose specific schedules for rate cases during the transition to the Safety Model

Assessment Proceeding (S-MAP) and Risk Assessment Mitigation Phase (RAMP)

process described in the Proposed Decision.

These comments are organized as follows: Section I identifies areas (common to all

utilities) where modifications to the Proposed Decision are warranted. Section II addresses

issues specific to the schedule of SCE’s upcoming GRC. Section III addresses scheduling issues

specific to PG&E. Proposed changes to the Findings of Fact. Conclusions of Law, and Order

are set forth in Appendix A to these comments.

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I. AREAS THAT WARRANT MODIFICATION

The following areas warrant modification: (i) the interplay between the S-MAP and the

RAMP, (ii) the design of the RAMP, (iii) the timing of specific events in the GRC, (iv) treatment

of confidential models and information in the S-MAP and RAMP, (v) the use of two

Administrative Law Judges (ALJs) to facilitate the issuance of timely decisions, (vi) the role of

analysts and consultants from the Safety and Enforcement Division (SED), and (vii) the effective

date for the new reporting requirements.

A. The Interplay Between the S-MAP and the RAMP

SCE and PG&E understand that no utility will be required to file a RAMP until the initial

S-MAP decision is issued.1 We agree with this. However, the Proposed Decision needs to be

modified to ensure that the utilities have adequate time to prepare a RAMP filing once the S-

MAP decision is issued.

The Proposed Decision calls for the first S-MAP filing on May 1, 2015, and sets forth a

schedule comprising as much as 260 days, not including briefing and the time necessary to

prepare a proposed decision.2 Taking these other activities into account, the S-MAP is likely to

last over one year. The first S-MAP decision may issue late in 2016.3

Regardless of when the S-MAP decision issues, the utilities will need some time to

incorporate the results of the S-MAP into its RAMP. Depending on whether the S-MAP requires

material changes to a utility’s models and methodologies, the time needed may be substantial.

Therefore, SCE and PG&E recommend that the Proposed Decision be modified to state that the

utilities shall have a minimum of 120 days following the S-MAP decision to prepare the RAMP.

Absent sufficient time to incorporate the results of the S-MAP, the advantages of the Proposed

Decision’s staged-design of the S-MAP, RAMP, and GRC proceedings could be lost.

1 Proposed Decision, p. 53 (Ordering Paragraph 6). 2 Proposed Decision, pp. 29-30. 3 If delayed, the first S-MAP may not issue in time to affect Sempra’s 2019 GRC, which would

ordinarily call for submission of the RAMP on October 1, 2016. If the S-MAP is not issued in time for Sempra’s 2019 GRC, the first applicant to file a RAMP would likely be PG&E in October 2017 for its 2020 GRC.

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B. The Design of the RAMP

The RAMP, as currently designed, is likely to frustrate one of the purposes of this

rulemaking, which is “to promote more efficient and effective management of the overall rate

case process.”4 This is because the RAMP design promises to delay GRC decisions further.

The design problem relates to the Proposed Decision’s choice to make the RAMP a

separate application, not an earlier phase in the GRC as recommended in the Refined Straw

Proposal.5 The “phase” approach removed the dependency on issuing of a formal Commission

decision to conclude the RAMP. The need for a formal decision could add months to the process

and slow the start of a subsequent GRC. For these reasons, SCE and PG&E continue to support

the RAMP as a phase, not a separate proceeding.

Regardless of whether the Commission keeps the RAMP as the first phase of the GRC

proceeding or as a separate application, the Proposed Decision should clarify that the RAMP

need not formally conclude before the utilities file their GRC. Otherwise, any delays in the

RAMP could translate directly into delays in the GRC.

Many aspects of GRCs are independent of the content of the RAMP. The utilities should

file their GRC applications on November 1 regardless of whether the RAMP phase or proceeding

has concluded or not. Otherwise, the current schedule will exacerbate the serious problem of

delays in GRC proceedings. Utilities’ showings on administrative and general (A&G) costs,

compensation, depreciation, taxes and corporate items, for example, can, and should, proceed

independently of the RAMP. If the RAMP findings warrants modification of certain aspects of

the utility’s GRC filing, the utility should be able to do so though supplemental testimony,

provided 120 days after the conclusion of the RAMP. GRC applications are complex filings that

involve months of preparation including management review and approval of long term project

plans and budgets. If the RAMP is going to have meaningful impact to the utility plans, then

adequate time must be allowed to accommodate any RAMP findings into the application.

Accordingly, SCE and PG&E recommend that the Proposed Decision revert the RAMP

back into a phase of the GRC proceeding, not a separate application, as recommended by the 4 Order Instituting Rulemaking to Develop a Risk-Based Decision-Making Framework to Evaluate

Safety and Reliability Improvements and Revise the General Rate Case Plan for Energy Utilities, p. 1 (November 22, 2013).

5 Proposed Decision, pp. 35-36.

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Refined Straw Proposal. Absent that change, SCE and PG&E recommend that the Proposed

Decision be modified to state that (i) utilities shall be expected to take the RAMP findings into

account in its subsequent GRC filing no later than 120 days after the RAMP phase concludes,

and (ii) utilities are expected to file their applications on November 1 regardless of the timing of

when the RAMP phase concludes, taking appropriate account of the RAMP findings through

supplemental testimony as appropriate.

C. The Timing of the Specific Events in the GRC

The proposed schedule for the GRC should be revised in two areas: (i) it does not allow

sufficient time for rebuttal testimony and (ii) it allows too much time for the pre-hearing

conference (PHC).

1. Rebuttal Testimony Needs at Least 45 Days

The proposed GRC schedule allows only 30 days for the utilities and other parties

to prepare concurrent rebuttal testimony to the concurrent opening testimony of ORA and

all intervenors.6 This time is insufficient.

Twenty or more parties commonly participate in GRCs. Their opening testimony

is voluminous. Discovery on such testimony — under current Commission rules — can

take 10 business days or more, not including the advance time required to digest the

others’ testimony and formulate the discovery requests. A 30-day deadline, as proposed

in the Proposed Decision, effectively eliminates the ability to do discovery on such

testimony.

Accordingly, at least 45 days should be provided in all proceedings for serving

rebuttal testimony.7 Absent the additional time, rebuttal testimony is likely to be

disorganized and incomplete, leading to confusion in the record and less efficient,

potentially prolonged, evidentiary hearings. 6 Proposed Decision, pp. 39-40 (Table 4). 7 This is of particular concern in the GRC given the number of issues and parties, but also applies to the

S-MAP, which also calls for a 30-day rebuttal period. (Proposed Decision, p. 29 (Table 2).)

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2. The Prehearing Conference Should Be Held in 15 Days

The proposed schedule allows about 70 days for the scheduling of the prehearing

conference (PHC).8 This is too much time. There is no reason that the proceeding need

start so slowly given the fixed filing dates specified for the GRC. SCE and PG&E

recommend that the PHC should be scheduled on November 15. Getting the proceeding

off to a prompt start will create additional time to allow for the modest extension in

rebuttal time recommended above.

D. Treatment of Confidential Information in the S-MAP and RAMP

The Proposed Decision cites the Refined Straw Proposal, which says that models, data

sources, and assumptions should be fully available for review.9 Assuming this would be the case

for the S-MAP and RAMP, SCE and PG&E note that the Commission has just opened a new

Order Instituting Rulemaking (OIR) that may affect the treatment of confidential data provided

by utilities to the Commission.10

At the time the Refined Straw Proposal was issued and discussed by stakeholders, SCE

and PG&E assumed continuation of the longstanding practice of providing confidential data to

the Commission pursuant to the protections of Public Utilities Code Section 583 and General

Order 66-C. The Commission’s new OIR may change that longstanding practice. SCE and

PG&E will be filing separate comments on the new OIR, but the outcome of the OIR could

affect the types of information used for risk analytics unless the appropriate protection is

provided for confidential data and models. For this reason, SCE and PG&E recommend that the

Proposed Decision be modified to acknowledge the possible need for confidentiality in data and

models provided during the S-MAP, RAMP and GRC proceedings.

E. The Assignment of Two ALJs

The Proposed Decision provides a schedule for GRCs that, while improved slightly from

recent schedules, would not likely produce a final decision prior to the test year absent other

8 Proposed Decision, p. 39. 9 Proposed Decision, p. 20.

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changes in Commission procedures. One change widely recommended by parties in this

rulemaking, which was also supported by Commissioner Florio from the dais during voting for

PG&E’s 2014 GRC, is to assign two ALJs for the processing of major rate cases. Without such a

change, there is little reason to hope that the schedule put forth in the Proposed Decision will

promote more timely decisions. Accordingly, the Proposed Decision should commit now to the

assignment of two ALJs for the major rate cases.

F. The Role of SED

The Proposed Decision needs to clarify that SED staff, or its consultants, will be subject

to discovery and made available to testify about their reports if the reports are to be made part of

the record. The Proposed Decision states, “On the issue of whether SED should have a witness

to sponsor and testify about the staff report if hearings are held in the RAMP application, that

issue should be left to the RAMP proceeding to decide.”11 This language wrongly suggests that

it may be appropriate to deny parties the ability to cross-examine SED staff or its consultants

about the contents of their reports. Any such suggestion would be incorrect.

As a matter of due process, persons sponsoring reports to be entered into the record as

evidence should be made available to testify and to respond to discovery. The United States

Supreme Court has found that, “[i]n almost every setting where important decisions turn on

questions of fact, due process requires an opportunity to confront and cross-examine adverse

witnesses.”12 Accordingly, the Proposed Decision should be modified to remove any suggestion

to the contrary.

G. The New Reporting Requirements

SCE and PG&E understand that the new reporting requirements will take effect after the

conclusion of the first GRC following the first S-MAP and RAMP proceedings for a given

Continued from the previous page 10 R.14-11-001. 11 Proposed Decision, pp. 36-37. Presumably, the same logic would apply to SED’s reports in the S-

MAP, and the SED and Energy Division reports in the GRC proceeding. Proposed Decision, pp. 26-27, and 45.

12 Goldberg v. Kelly, 397 U.S. 254, 269 (1970) (upholding the right to cross-examine witnesses in administrative proceeding concerning public assistance benefits).

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utility. This is consistent with the Proposed Decision’s acknowledgment that the “S-MAP and

RAMP proceedings [should] hold workshops on the types of information that needs to be

reported in these two reports, and the methodology that can be used to quantify and measure the

benefits of such mitigation plans and safety activities.”13 SCE and PG&E support such timing

for these new reports.

In the meantime, PG&E would expect to continue its annual budget reports and semi-

annual gas transmission and distribution safety reports, which were imposed in PG&E’s 2011

GRC and 2011 Gas Transmission and Storage (GT&S) proceeding.14 If the Proposed Decision

wishes to accelerate the timing of the new reports, the Commission should only do so after

replacing similar requirements already imposed upon the utilities such as those reports for PG&E

mentioned above.

II.

SCE-SPECIFIC ISSUES

SCE seeks clarification and guidance regarding the schedule of its first RAMP

Application. The Proposed Decision requires the utilities to file their GRC Applications on

November 1 and their RAMP Applications on October 1 of the preceding year.15 For SCE’s next

(2018) GRC, this would require that SCE file its RAMP on October 1, 2015. Further, Ordering

Paragraph 6 of the Proposed Decision would require that a RAMP be filed after a decision in the

S-MAP proceeding. As noted in Section I.A above, the first S-MAP proceeding, which begins

on May 1, 2015, would not complete in time for SCE to be able to submit its first RAMP

Application just five months later on October 1, 2015, as it may take over a year to reach a

decision in the initial S-MAP proceeding. Accordingly, SCE interprets the Proposed Decision as

not requiring SCE to submit its first RAMP in SCE’s 2018 GRC but, instead, requires that SCE

include in its 2018 GRC descriptions of the risk assessment and mitigation plans used in its GRC

13 Proposed Decision, p. 44. 14 D.11-05-018, Ordering Paragraphs 42 and 44. 15 Proposed Decision, p. 39.

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application.16 SCE’s 2018 GRC application would be submitted on November 1, 2016 under the

terms of the Proposed Decision.

III.

PG&E-SPECIFIC ISSUES

PG&E seeks guidance in the schedule to be used for its 2017 GRC, as well as the

schedule to be followed in its GT&S rate cases.

A. 2017 GRC

The Proposed Decision recognizes that PG&E’s 2014 GRC was improved through the

involvement of technical consultants, hired by SED, to review PG&E’s showing.17 PG&E hopes

that SED will do the same for PG&E’s 2017 GRC. To the extent that the Commission is unable

to manage the costs of similar consultants for the 2017 case, PG&E would be amenable to

covering the costs of such consultants within previously authorized rates.

It is important to note, however, that in the 2014 GRC, the SED consultants began their

review prior in time to when the Proposed Decision would have PG&E filing its 2017 GRC.

Therefore, for the period of transition prior to when the S-MAP and RAMP procedures can be

fully implemented,18 PG&E recommends that the Commission adopt the schedule in the Table

below.

16 Id. at pp. 40-41. 17 Proposed Decision, pp. 15-16. 18 See discussion at pp. 40-41 of the Proposed Decision.

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Table III-1 Proposed Schedule for PG&E 2017 GRC

Showing Changes from Table 4 in the Proposed Decision Date ActivitySeptember 1November 1

Utility files GRC application, and serves prepared testimony includingchanges resulting from the RAMP decision.

Per Rule 2.6(a). Protests and responses filed to GRC application.By October 15December 15

Utility holds public workshop on overall GRC application.

By September 15January 10

PHC held.

By April 15 ORA and Intervenors serve opening testimony; SED Consultant(s) submitreport(s).

May 30May 15

Concurrent rebuttal testimony served.

April/May Public Participation Hearings.May/June/July (Three orfour weeks ofevidentiary hearings.)

Evidentiary hearings held, if needed.

To be decided. Opening briefs filed.To be decided. Reply briefs filed.AugustJune/July

Update testimony and hearings, if necessary.

October/November Proposed decision.December Final decision.In accordance withVerification schedulediscussed in thisdecision.

Utility files annual Risk Mitigation Accountability Report and Risk SpendingAccountability Report.

This schedule will allow for earlier involvement of SED consultants and is modeled after the

approach successfully followed by all parties in PG&E’s 2014 GRC. This schedule increases the

likelihood of a timely final decision, while also expanding the time for the preparation of SED’s,

ORA’s and the intervenors’ reports.

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B. GT&S Rate Cases

The Proposed Decision is silent on the schedule to be followed for the submission of

PG&E’s Gas Transmission and Storage (GT&S) rate cases.19 PG&E recommends that the

Commission offer guidance in this area.

The S-MAP proceeding can address models and methodologies used for the work

covered in both the GRC and GT&S rate cases. Similarly, PG&E proposes that the RAMP –

filed prior to PG&E’s GRC – would address planned mitigation in the GT&S area. Then, PG&E

proposes to follow a schedule like that presented in the Table above for PG&E’s GT&S case.

The earlier start (in September compared to November) would better allow for a “refresh” on

mitigation covered by the RAMP, as well as SED review of the technical measures in the GT&S

filing.

IV.

CONCLUSION

For the foregoing reasons, SCE and PG&E respectfully recommend that the Proposed

Decision be modified as described above.

PG&E has authorized SCE to sign this document on PG&E’s behalf.

19 The only reference to the GT&S rate case is to reaffirm the separation of the two cases. (Proposed

Decision, p. 38.)

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Respectfully submitted, FRANK A. McNULTY JANE LEE COLE

/s/ Jane Lee Cole By: Jane Lee Cole

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone:(626) 302-3860 Facsimile: (626) 302-2610 E-mail: [email protected]

Dated: November 24, 2014

Appendix A Proposed Revisions To Findings Of Fact, Conclusion Of Law And Order

A-1

PROPOSED REVISIONS TO FINDINGS OF FACT, CONCLUSION OF LAW AND ORDER

Findings of Fact

26. The purpose of the RAMP phase application filing will be to review the utility’s RAMP submission for consistency and compliance with its prior S-MAP, and to determine whether the elements contained in the RAMP submission can be used in the utility’s GRC filing to support its position on the assessment of its safety risks, and its plans to manage, mitigate and minimize those risks in the context of the utility’s upcoming GRC application filing. Conclusions of Law

6. PG&E, SDG&E, SoCalGas Company, and SCE, should transition to the use of the S-MAP, the RAMP proceeding, and adhere to the modified RCP schedule in all future GRC application filings. 10. A RAMP application process, as described in the Refined Straw Proposal and as clarified by this decision, should be adopted. 11. Revisions to the RAMP process recommended in the Refined Straw Proposal are necessary to conform to the Commission’s processes. 14. Today’s decision, which describes and adopts the parameters of the S-MAP and RAMP processes, does not prevent the assigned ALJs in either of those proceedings, from taking any other action to adjudicate the S-MAP application or the RAMP application. 16. The issue of whether the Commission needs to adopt certain terms and definitions in order to carry out the activities associated with the S-MAP and RAMP proceedings should be addressed in the S-MAP. Order 9. PG&E shall submit its 2017 GRC application on September 1, 2015. SCE shall submit its 2018 GRC application on November 1, 2016. Each subsequent GRC application will be submitted on November 1st of the year following the GRC base year and shall incorporate findings from the RAMP to the extent those findings are issued 120 or more days prior to the GRC application date.

1


STATE OF CALIFORNIA


R.13-11-006

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 COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) AND PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) ON THE PROPOSED DECISION OF ASSIGNED COMMISSIONER PEEVEY on all parties identified on the attached service list(s) R.13-11-006. Service was effected by one or more means indicated below: [X] Transmitting the copies via e-mail to all parties who have provided an e-mail address. [X] Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s).

ALJ John S. Wong CPUC 505 Van Ness Avenue San Francisco, CA 94102

[ ] 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-email list.

[ ] Directing Prographics to place the copies in properly addressed sealed envelopes and to deposit such envelopes in the United States mail with first-class postage prepaid to all parties.

Executed this Monday, November 24, 2014 at Rosemead, CA.

/s/ Christopher A. Stephens Christopher A. Stephens Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

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(SCE) KEITH MELVILLE DONALD KELLY ATTORNEY EXE. DIR. SAN DIEGO GAS & ELECTRIC COMPANY UTILITY CONSUMERS' ACTION NETWORK 101 ASH STREET, HQ-12B 3405 KENYON STREET, SUITE 401 SAN DIEGO, CA 92101 SAN DIEGO, CA 92110 FOR: SOUTHERN CALIFORNIA GAS COMPANY / FOR: UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY (UCAN) MICHAEL SHAMES EVELYN KAHL SAN DIEGO CONSUMERS' ACTION NETWORK COUNSEL 6975 CAMINO AMERO ALCANTAR & KAHL, LLP SAN DIEGO, CA 92111 33 NEW MONTGOMERY STREET, SUITE 1850 FOR: SAN DIEGO CONSUMERS' ACTION SAN FRANCISCO, CA 94015 NETWORK (SDCAN) FOR: ENERGY PRODUCERS AND USERS COALITION MARC D. JOSEPH LAURA J. TUDISCO ATTORNEY CALIF PUBLIC UTILITIES COMMISSION ADAMS BROADWELL JOSEPH & CORDOZO LEGAL DIVISION 601 GATEWAY BLVD., STE. 1000 ROOM 5032 SOUTH SAN FRANCISCO, CA 94080 505 VAN NESS AVENUE FOR: COALITION OF CALIFORNIA UTILITY SAN FRANCISCO, CA 94102-3214 EMPLOYEES (CCUE) FOR: ORA HAYLEY GOODSON DAVID L. HUARD STAFF ATTORNEY MANATT, PHELPS & PHILLIPS, LLP THE UTILITY REFORM NETWORK ONE EMBARCADERO CENTER, 30TH FL. 785 MARKET ST., STE. 1400 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94103 FOR: TESORO REFINING & MARKETING FOR: THE UTILITY REFORM NETWORK (TURN) COMPANY LLC TARA S. KAUSHIK ROGER LIN HOLLAND & KNIGHT, LLP STAFF ATTORNEY 50 CALIFORNIA STREET, 28TH FLOOR COMMUNITIES FOR A BETTER ENVIRONMENT SAN FRANCISCO, CA 94111 1904 FRANKLIN ST., STE. 600 FOR: EXXONMOBIL POWER & GAS SERVICES, OAKLAND, CA 94612 INC. FOR: COMMUNITIES FOR A BETTER ENVIRONMENT WILLIAM JULIAN II RONALD LIEBERT UTILITY WORKERS UNION OF AMERICA ATTORNEY AT LAW 43556 ALMOND LANE ELLISON SCHNEIDER & HARRIS LLP DAVIS, CA 95618 2600 CAPITOL AVENUE, STE. 400 FOR: UTILITY WORKERS UNION OF AMERICA SACRAMENTO, CA 95816 (UWUA) FOR: CALIFORNIA MANUFACTURERS & TECHNOLOGY ASSOCIATION JEDEDIAH J. GIBSON KAREN NORENE MILLS ATTORNEY AT LAW ASSOC. COUNSEL - LEGAL SVCS. DIV. ELLISON SCHNEIDER & HARRIS LLP CALIFORNIA FARM BUREAU FEDERATION 2600 CAPITOL AVENUE, SUITE 400 2300 RIVER PLAZA DRIVE SACRAMENTO, CA 95816-5905 SACRAMENTO, CA 95833 FOR: BEAR VALLEY ELECTRIC SERVICE FOR: CALIFORNIA FARM BUREAU FEDERATION



CATHIE ALLEN REGULATORY AFFAIRS MGR. PACIFICORP 825 NE MULTNOMAH ST., STE 2000 PORTLAND, OR 97232 FOR: PACIFICORP

ANDREW GAY CASE ADMINSTRATION CARLSON CAPITAL L.P. SOUTHERN CALIFORNIA EDISON COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 CASE COORDINATION ELIZABETH KELLY PACIFIC GAS AND ELECTRIC COMPANY LEGAL DIRECTOR EMAIL ONLY MARIN CLEAN ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 JAMES BIRKELUND JAMIE L MAULDIN PRESIDENT ADAMS BROADWELL JOSEPH & CARDOZO SMALL BUSINESS UTILITY ADVOCATES EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: SMALL BUSINESS UTILITY ADVOCATES JEREMY WAEN JOSEPH MITCHELL REGULATORY ANALYST EMAIL ONLY MARIN CLEAN ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 KATY MORSONY MARTHA SERIANZ ALCANTAR & KAHL CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 MARTIN HOMEC MCE REGULATORY EMAIL ONLY MARIN CLEAN ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 RICHARD LO SHALINI SWAROOP DIRECTOR MARIN CLEAN ENERGY UTILITYCONSULTING GROUP, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 VIDHYA PRABHAKARAN DAVIS WRIGHT TREMAINE LLP

Information Only



ATTORNEY EMAIL ONLY DAVIS WRIGHT & TREMAINE, LLP EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 FOR: LIBERTY UTILITIES (CALPECO ELECTRIC) LLC MRW & ASSOCIATES, LLC JUDY PAU EMAIL ONLY DAVIS WRIGHT TREMAINE LLP EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000-0000 KAREN TERRANOVA JIM O'REILLY ALCANTAR & KAHL MCKINSEY & COMPANY EMAIL ONLY 1200 19TH ST., N.W. EMAIL ONLY, CA 00000-0000 WASHINTON, DC 20036 PAUL J. WOOD DOUGLAS E. MILLER CONSULTANT VP - STRATEGY & BUSINESS DEVELOPMENT CYCLA CORP. TESORO COMPANIES, INC. 211 SOMERVELLE ST. 19100 RIDGEWOOD PARKWAY ALEXANDRIA, VA 22304 SAN ANTONIO, TX 78259 EDWARD B. GIESEKING VALERIE J. ONTIVEROZ DIR - PRICING AND TARIFFS REGULATORY MANAGER/CA SOUTHWEST GAS CORPORATION SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD, LVB-100 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89150 LAS VEGAS, NV 89150 JEFFREY SALAZAR MIKE FRANCO SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 WEST FIFTH STREET, GT14D6 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013 RASHA PRINCE SHARON TOMKINS SAN DIEGO GAS & ELECTRIC COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 WEST 5TH STREET, GT14D6 555 W. FIFTH ST., GT14E7 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013 JOHNNY J. PONG HUBERT SHEN SOUTHERN CALIFORNIA GAS COMPANY MANAGER 555 W. 5TH ST. GT14E7, SUITE 1400 BAIN & COMPANY LOS ANGELES, CA 90013-1034 1901 AVENUE OF THE STARS, STE. 200 LOS ANGELES, CA 90067 MAYA GOLDEN-KRASNER FRED YANNEY COMMUNITIES FOR A BETTER ENVIRONMENT YANNEY LAW OFFICE 6325 PACIFIC BLVD., STE. 300 17409 MARQUARDT AVE., UNIT 4-C HUNTINGTON PARK, CA 90255 CERRITOS, CA 90703 DANIEL A. DELL'OSA MIKE MARELLI DIR - RATES & REVENUE DIRECTOR SAN GABRIEL VALLEY WATER COMPAANY SOUTHERN CALIFORNIA EDISON COMPANY



11142 GARVEY AVENUE 2244 WALNUT GROVE AVE./PO BOX 800 EL MONTE, CA 91733-2425 ROASEMEAD, CA 91770 MILISSA MARONA KEITH SWITZER PINCIPAL ADV.-REG AFFAIRS & COMPLIANCE VP - REGULATORY AFFAIRS SOUTHERN CALIFORNIA EDISON COMPANY GOLDEN STATE WATER COMPANY PO BOX 800 / 2244 WALNUT GROVE AVENUE 630 EAST FOOTHILL BOULEVARD ROSEMEAD, CA 91770 SAN DIMAS, CA 91773-9016 CARL WOOD JOHN W. LESLIE NATIONAL REGULATORY AFFAIRS DIRECTOR ATTORNEY UTILITY WORKERS UNION OF AMERICA MCKENNA LONG & ALDRIDGE LLP 2021 S. NEVADA ST 600 WEST BROADWAY, STE. 2600 OCEANSIDE, CA 92054 SAN DIEGO, CA 92101 CENTRAL FILES PETE GIRARD SDG&E/SOCALGAS SAN DIEGO GAS & ELECTRIC 8330 CENTURY PARK COURT, CP31-E 8330 CENTURY PARK CT., CP 32C SAN DIEGO, CA 92123 SAN DIEGO, CA 92123 CHARLES R. MANZUK LAURA J. MANZ DIR. - RATES & REVENUE REQUIREMENTS LJ MANZ CONSULTING SAN DIEGO GAS & ELECTRIC COMPANY 12372 AVENIDA CONSENTIDO 8330 CENTURY PARK CT, CP32D SAN DIEGO, CA 92128 SAN DIEGO, CA 92123-1530 SUE MARA ROBERT FINKELSTEIN CONSULTANT GENERAL COUNSEL RTO ADVISORS, LLC THE UTILITY REFORM NETWORK 164 SPRINGDALE WAY 785 MARKET ST., STE. 1400 REDWOOD CITY, CA 94062 SAN FRANCISCO, CA 94103 THOMAS LONG JOHN MCINTYRE LEGAL DIR. ALCANTAR & KAHL THE UTILITY REFORM NETWORK 33 NEW MONTGOMERY STREET, SUITE 1850 785 MARKET ST., STE. 1400 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94103 PATTY COOK STEVEN W. FRANK ICF INTERNATIONAL ATTORNEY 620 FOLSOM ST., STE. 200 PACIFIC GAS AND ELECTRIC CO SAN FRANCISCO, CA 94105 77 BEALE STREET, B30A SAN FRANCISCO, CA 94105 F. JACKSON STODDARD CALIFORNIA ENERGY MARKETS MANATT, PHELPS & PHILLIPS, LLP 425 DIVISADERO, STE. 303 ONE EMBARCADERO CENTER, 30THE FL SAN FRANCISCO, CA 94117 SAN FRANCISCO, CA 94111 SHELLY SHARP AMRIT SINGH PACIFIC GAS AND ELECTRIC COMPANY SATVICK 77 BEALE STREET, MAIL CODE B9A 526 WYCOMBE COURT SAN FRANCISCO, CA 94177 SAN RAMON, CA 94583



JOYCE STEINGASS CARMELITA L. MILLER GAS TRANSMISSION SYSTEMS, INC. LEGAL FELLOW 575 LENNON LN, SUITE 250 THE GREENLINING INSTITUTE WALNUT CREEK, CA 94598 1918 UNIVERSITY AVENUE, 2ND FLOOR BERKELEY, CA 94704 C. SUSIE BERLIN SCOTT BLAISING LAW OFFICES OF SUSIE BERLIN ATTORNEY 1346 THE ALAMEDA, STE. 7, NO. 141 BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. SAN JOSE, CA 95126 915 L STREET, STE. 1270 SACRAMENTO, CA 95814 TANYA DERIVI ANDREW BROWN SO. CALIFORNIA PUBLIC POWER AUTHORITY ATTORNEY AT LAW 915 L STREET, STE. 1410 ELLISON & SCHNEIDER SACRAMENTO, CA 95814 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA 95816-5905 LYNN HAUG ANN L. TROWBRIDGE ELLISON, SCHNEIDER & HARRIS L.L.P. ATTORNEY AT LAW 2600 CAPITOL AVENUE, SUITE 400 DAY CARTER & MURPHY LLC SACRAMENTO, CA 95816-5931 3620 AMERICAN RIVER DRIVE, SUITE 205 SACRAMENTO, CA 95864 MIKE LONG MIKE CADE DIR - FINANCE & MGR ALCANTAR & KAHL LIBERTY UTILITIES 1300 SW 5TH AVENUE, STE. 1750 933 ELOISE AVE. PORTLAND, OR 97201 SO. LAKE TAHOE, CA 96150 FOR: LIBERTY UTILITIES DAVE WEBER ETTA LOCKEY GILL RANCH STORAGE, LLC ATTORNEY 220 NW SECOND AVENUE PACIFICORP PORTLAND, OR 97209 825 NE MULTNOMAH ST., STE. 1800 PORTLAND, OR 97232 MICHELLE R. MISHOE CHARLES MAGEE SR. COUNSEL VP / GEN. COUNSEL PACIFICORP TESORO REFINING & MARKETING COMPANY LLC 825 NE MULTNOMAH STREET, SUITE 1800 3450 S. 344TH WAY, STE. 201 PORTLAND, OR 97232 AUBURN, WA 98001

CAROLINA CONTRERAS, P.E. MARC MONBOUQUETTE CPUC CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY ENERGY DIVISION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

State Service



MICHAEL COLVIN NANCY GONZALES ADVISOR CALIFORNIA PUBLIC UTILITIES COMMISSION CPUC - ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 RICHARD MYERS SCOTT MURTISHAW ENERGY CPUC CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 TONY MARINO ARTHUR J. O'DONNELL OFFICE OF SENATOR JERRY HILL CALIF PUBLIC UTILITIES COMMISSION EMAIL ONLY INFRASTRUCTURE PLANNING AND PERMITTING B EMAIL ONLY, CA 00000 ROOM 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 BELINDA GATTI BISHU CHATTERJEE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION MARKET STRUCTURE, COSTS AND NATURAL GAS GAS SAFETY AND RELIABILITY BRANCH AREA 4-A AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 CHRISTOPHER PARKES CLAYTON K. TANG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION GAS SAFETY AND RELIABILITY BRANCH ENERGY COST OF SERVICE & NATURAL GAS BRA AREA 2-D ROOM 4205 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 DONALD J. LAFRENZ ELAINE LAU CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION MARKET STRUCTURE, COSTS AND NATURAL GAS MARKET STRUCTURE, COSTS AND NATURAL GAS AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 ELIZAVETA I. MALASHENKO JOHN S. WONG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION SAFETY AND ENFORCEMENT DIVISION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 455 ROOM 5106 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 KENNETH BRUNO MARZIA ZAFAR CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION GAS SAFETY AND RELIABILITY BRANCH POLICY & PLANNING DIVISION AREA 2-D ROOM 5119 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214



NATHANIEL SKINNER NIKI BAWA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B EXECUTIVE DIVISION AREA 4-A ROOM 5038 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 RICHARD WHITE ROBERT M. POCTA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION POLICY & PLANNING DIVISION ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 5-A ROOM 4205 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 TRACI BONE ZHEN ZHANG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION EXECUTIVE DIVISION ROOM 5027 ROOM 5102 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 LYNN MARSHALL CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS-20 SACRAMENTO, CA 95814

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