BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF … · 2018-09-24 · BEFORE THE PUBLIC...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Order Instituting Rulemaking Regarding Continued Implementation of the Public Utility Regulatory Policies Act and Related Matters.

Rulemaking 18-07-017 (Filed July 26, 2018)

JOINT REPLY COMMENTS OF PACIFIC GAS AND ELECTRIC COMPANY (U 39-E),

SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), AND SAN DIEGO GAS &

ELECTRIC COMPANY (U 902-E)

WILLIAM V. MANHEIM JENNIFER K. POST Attorneys for PACIFIC GAS AND ELECTRIC COMPANY 77 Beale Street, B30A San Francisco, California 94105 Telephone: (415) 973-3744 Facsimile: (415) 973-5520 E-mail: [email protected]

JANET S. COMBS CAROL SCHMID-FRAZEE MARIO E. DOMINGUEZ Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6522 Facsimile: (626) 302-1935 E-mail: [email protected]

PAUL A. SZYMANSKI Senior Regulatory Counsel for SAN DIEGO GAS & ELECTRIC COMPANY 8330 Century Park Court, CP32D San Diego, California 92123 Telephone: (858) 654-1732 Facsimile: (619) 699-5027 E-mail: [email protected]

Dated: September 24, 2018

JOINT REPLY COMMENTS OF PACIFIC GAS AND ELECTRIC COMPANY (U 39-E), SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), AND SAN DIEGO GAS &

ELECTRIC COMPANY (U902-E)

TABLE OF CONTENTS

Section Title Page

-i-

I. INTRODUCTION AND OVERVIEW ...........................................................................................1

II. THE NEW QF SOC RECOMMENDED BY THE JOINT IOUS WILL ASSURE COMPLIANCE WITH PURPA REQUIREMENTS ......................................................................2

A. The QF SOC Was Not at Issue before the Federal District Court .......................................2

B. The New QF SOC Recommended by the Joint IOUs in Their Opening Comments Will Assure the Compliance of the QF SOC with PURPA Requirements .......................................................................................................................4

III. THE ISSUES CONCERNING THE FERC ORDER ELIMINATING THE MUST-TAKE OBLIGATION FOR QFS ABOVE 20 MW IN CALIFORNIA RAISED BY IEP IS BEYOND THE SCOPE OF THIS PROCEEDING .......................................5

IV. SEIA INCORRECTLY IMPLIES THAT NO SMALL QF NEEDS TO SELF-CERTIFY AT FERC........................................................................................................................5

V. RE-OPENING REMAT IS OUTSIDE THE SCOPE OF THIS PROCEEDING ...........................7

VI. FORWARD MARKET PRICES BEST REFLECT AVOIDED COST..........................................7

VII. CONTRARY TO GPI AND WCS, PURPA COMPLIANCE DOES NOT REQUIRE THE QF SOC TO OFFER A 20-YEAR TERM............................................................9

VIII. THE QF SOC IS NOT THE PRIMARY MEANS FOR ENCOURAGING QFS AND RENEWABLE RESOURCES .............................................................................................10

IX. ALL COMMISSION-JURISDICTIONAL UTILITIES SHOULD BE SUBJECT TO THE RESULTS OF THIS PROCEEDING .............................................................................10

X. CONCLUSION ..............................................................................................................................11

1


STATE OF CALIFORNIA



JOINT REPLY COMMENTS OF PACIFIC GAS AND ELECTRIC COMPANY (U 39-E),

SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), AND SAN DIEGO GAS &

ELECTRIC COMPANY (U 902-E)

I. INTRODUCTION AND OVERVIEW

Pacific Gas and Electric Company (“PG&E”), Southern California Edison Company

(“SCE”), and San Diego Gas & Electric Company (“SDG&E”) (collectively, the “Joint Investor

Owned Utilities” or “Joint IOUs”) hereby submit reply comments to the opening comments of

parties1 in response to the Order Instituting Rulemaking Regarding Continued Implementation of

the Public Utility Regulatory Policies Act (“PURPA”) and Related Matters, issued August 1,

2018, Ordering Paragraph No. 7 (“PURPA OIR”).

1 Parties submitting opening comments include: (1) Joint IOUs; (2) The Utility Reform Network (“TURN”); (3) Green Power Institute (“GPI”); (4) Winding Creek Solar LLC (“WCS”); (5) California Wind Energy Association (“CalWEA”); (6) Independent Energy Producers Association (“IEP”); (7) Clean Coalition; (8) Commission’s Public Advocates Office (“Cal PA”); (9) Solar Energy Industries Association (“SEIA”); (10) California Association of Small and Multi-Jurisdictional Utilities (“CASMU”); and (11) Solar Electric Solutions, LLC, APT Solar Company, Division Solar, LLC, Poco Power, LLC, and Immodo Development LLC (hereinafter collectively referred to as “ReMAT Developers”).

2

II. THE NEW QF SOC RECOMMENDED BY THE JOINT IOUS WILL ASSURE

COMPLIANCE WITH PURPA REQUIREMENTS

A. The QF SOC Was Not at Issue before the Federal District Court

In Winding Creek,2 the matter before the United States District Court for the Northern

District of California was whether the ReMAT program was compliant with PURPA and not

whether the Qualifying Facility (“QF”) Standard Offer Contract (“SOC”) was compliant with

PURPA.3 The issue of whether the QF SOC was compliant with PURPA arose because the

Commission argued before the Federal Energy Regulatory Commission (“FERC”) and the court

that the QF SOC satisfied PURPA implementing regulations at 18 C.F.R. Section 292.304(d)(2),

such that participation in the ReMAT program could be capped. So, the issue of the compliance

of the QF SOC with PURPA was considered indirectly in the Winding Creek case -- only as part

of the defense as to the appropriateness of the ReMAT cap.4

In examining the validity of the defense that the QF SOC satisfied PURPA (as FERC had

indicated it had),5 the court in Winding Creek, questioned whether the QF SOC could

simultaneously satisfy two different subsections of a FERC-issued regulation. 18 C.F.R.

292.304(d)(2) states that:

“(d) Purchases “as available” or pursuant to a legally enforceable obligation. Each qualifying facility shall have the option either:

…

2 Winding Creek Solar LLC v. Peevey, 293 F.Supp.3d 980 (N.D. Cal. 2015) (Winding Creek). 3 Id. at 989 (“Despite the complex regulatory and factual background here, the key legal issues turned

out to be straightforward, and the scope of the parties’ actual dispute quite narrow. As an initial matter, the Court concludes that the Re–MAT Program is not PURPA–compliant in at least two independent way”).

4 Certain Opening Comments imply that the QF SOC itself had been presented to FERC and then the court as non-compliant with PURPA. See ReMAT Developer’s Opening Comments, pp.1-2; SEIA’s Opening Comments, p.7. It was not.

5 Winding Creek Solar LLC, 151 FERC ¶ 61,103 at P 7 (2015) (“Given the availability of California's Standard Contract for QFs 20 MW or under, Winding Creek has not demonstrated that the California Commission's implementation of PURPA, specifically the 750 MW statewide cap on the obligation of utilities under the Re-MAT program, is inconsistent with PURPA and our regulations.”).

3

(2) To provide energy or capacity pursuant to a legally enforceable obligation for the delivery of energy or capacity over a specified term, in which case the rates for such purchases shall, at the option of the qualifying facility exercised prior to the beginning of the specified term, be based on either:

(i) The avoided costs calculated at the time of delivery; or

(ii) The avoided costs calculated at the time the obligation is incurred.”

The Winding Creek court concluded that the QF SOC did not offer both of these options, noting

that the Commission asserted that the QF SOC satisfied 18 C.F.R. §292.304(d)(2)(ii), but that the

Commission did not identify any contract that even arguably satisfies 18 C.F.R.

§ 292.304(d)(2)(i).6 Thus, the Commission’s defense failed.

The Joint IOUs agree with the Commission that “[t]he District Court was prepared ‘for

summary judgment purposes’ to ‘[accept] as true’ that should the CPUC have a [QF SOC] that

satisfies all foundational requirements of the PURPA Regulations, the CPUC is permitted to

have a separate program that does not satisfy all basic requirements of PURPA.”7 Thus, if the

Commission establishes a new QF SOC with the necessary pricing options, the Winding Creek

court’s concern will have been addressed and then as the Commission has stated, “Winding

Creek’s claim of injury should be rendered moot.”8 The Joint IOUs support the Commission’s

efforts in this docket to remedy the alleged defect in the QF SOC discussed by the court, but

expressed concern in the Joint IOUs Opening Comments about the Staff Pricing Proposal and

offered an alternative path for achieving the Commission’s desired result.

6 Winding Creek, p. 991. 7 Commission’s Fourth Brief on Cross-Appeal, p.27, 9th Cir. Case Nos. 17-17531 and 17-17532 (Aug.

22, 2018). 8 Id., p.28.

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B. The New QF SOC Recommended by the Joint IOUs in Their Opening Comments Will Assure the Compliance of the QF SOC with PURPA Requirements

In Opening Comments, the Joint IOUs recommended that the Commission continue to

offer the QF SOC adopted in D.10-12-035 to meet the 18 C.F.R Section 292.304(d)(2)(i)

requirement that QFs have the choice to sign a contract with energy priced at the time of

delivery. This approach would keep the QF/CHP Settlement Agreement intact through its

termination date on December 31, 2020. The Joint IOUs then recommended that the

Commission adopt a new QF SOC with a three-year term based on a three-year forward curve of

California energy pricing based on the Intercontinental Exchange (“ICE”) curves. The adoption

of this new QF SOC would assure that QFs have the choice to sign a contract with an energy

price fixed at the time of execution thereby meeting the requirements of 18 C.F.R. Section 292-

304(d)(2)(ii), using an approach that does not use a formula rate for the energy price. Although

the Joint IOUs believe that a formula rate can satisfy 18 C.F.R. Section 292.304(d)(2)(ii), their

proposed approach eliminates that controversy.

That said, if the energy pricing for the QF SOC priced at time of execution is not going to

use a formula rate, the length of the term of any such QF SOC, while renewable, must be fairly

short,9 as other states have come to recognize after their utilities were locked into QF contracts

that proved highly adverse to their customers because power prices trended downward for many

or most of the years after the contract was executed and were not reflective of actual avoided

cost. The adoption of this new QF SOC should 1) reasonably reflect avoided cost at the time of

execution; 2) ensure that future changes in actual avoided costs would be captured relatively

quickly; and 3) its renewability ensures that developers know that they will have an offtaker for

the indefinite future. If the price of generation continues to trend downward, customers will not

be locked into decades-long deals that prove grossly overpriced. In contrast, if generation costs

9 E.g., In the Matter of Idaho Power Company’s Petition to Modify Terms and Conditions of PURPA Purchase Agreements, Case No. IPC-E-15-O1 (Ida. PUC 2015) (shortening its standard contract term to two years).

5

rise, QFs will reap the benefit by being able to obtain a higher avoided cost price or opt to sell

into the market. The Joint IOUs also recommend cost allocation to all benefitting customers10

for this mandated program. The Joint IOUs’ Opening Comments describe this proposal at

length.

III. THE ISSUES CONCERNING THE FERC ORDER ELIMINATING THE MUST-TAKE

OBLIGATION FOR QFS ABOVE 20 MW IN CALIFORNIA RAISED BY IEP IS BEYOND THE SCOPE OF THIS PROCEEDING

IEP requests that the Commission re-assess the conditions that eliminated the must-take

provision for QFs sized greater than 20 MWs in this proceeding.11 The purpose of this

proceeding is to develop a new QF SOC for the reason described in Section II. Whether the

must-take requirement should be reinstated as to QFs greater than 20 MW has no relevance to

developing a new QF SOC for QFs sized 20 MW or below, and should play no role in this

proceeding as it is clearly beyond the scope of this OIR. Moreover, the procedure for re-

instatement of the must-take obligation is governed by FERC’s regulations (18 C.F.R.

§ 292.311.)

IV. SEIA INCORRECTLY IMPLIES THAT NO SMALL QF NEEDS TO SELF-CERTIFY

AT FERC

SEIA states that “customers who install on-site solar or wind generation are per se QFs

under FERC rules [,]”12 implying, incorrectly, that solar and wind QFs larger than 1 MW

installed on-site (i.e., by large customers) do not need to self-certify at FERC. For facilities

selling wholesale power under Commission-authorized programs, QF status can be vital for

avoiding FERC regulation, as they can take advantage of the exemption from regulation

10 All benefitting include all customers receiving service from IOUs’ transmission and distribution systems.

11 IEP’s Opening Comments, p.2. 12 SEIA Opening Comments, p.3, fn.3.

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provided by 18 C.F.R. § 292.601. In 2006, through Order No. 671,13 FERC modified its

regulations on how facilities can achieve QF status. The rule added self-certification

requirements for small power production facilities (i.e., renewables)14 and cogeneration facilities.

Self-certification is achieved by filing a Form 556 with the Commission. If no one objects to the

self-certification (including FERC), it is considered valid without any further action taken by

FERC. Thereafter, FERC Order No. 732 exempted from the self-certification requirement

facilities otherwise eligible to be QFs that are smaller than 1 MW.15 Such facilities 1 MW in size

or smaller that are otherwise eligible to be QFs are, in effect, automatically QFs. However,

facilities larger than 1 MW are not QFs unless they self-certify at FERC. Accordingly, if a non-

government-owned facility larger than 1 MW sells power to an IOU, under a Net Energy

Metering (“NEM”) program contract, or under programs such as ReMAT or Bio-MAT, it must

have QF status or market-based rate authority from FERC even if located “on-site”.16

13 Revised Regulations Governing Small Power Production and Cogeneration Facilities, 114 FERC ¶61,102 (Order No. 671), order on reh’g, Order No. 671-A, 115 FERC ¶ 61,225 (2006).

14 Prior to this order, most renewable (i.e., small power production) entities 80 MW of under, were automatically QFs without having to take any steps.

15 The relevant regulations now provide as follows, as relates to renewable facilities (which are the type of facilities eligible for various CPUC-crafted purchase programs):

§ 292.203 General requirements for qualification. (a) Small power production facilities. Except as provided in paragraph (c) of this section, a small power production facility is a qualifying facility if it: (1) Meets the maximum size criteria specified in § 292.204(a); (2) Meets the fuel use criteria specified in § 292.204(b); and (3) Unless exempted by paragraph (d), has filed with the Commission a notice of self-certification, pursuant to § 292.207(a); or has filed with the Commission an application for Commission certification, pursuant to § 292.207(b)(1), that has been granted. * * * (d) Exemptions and waivers from filing requirement. (1) Any facility with a net power production capacity of 1 MW or less is exempt from the filing requirements of paragraphs (a)(3) and (b)(2) of this section.

16 Government-owned entities may sell wholesale power while avoiding most FERC jurisdiction if they are over 1 MW and do not self-certify as QFs, but their QF status may impact jurisdiction over their interconnection.

7

V. RE-OPENING REMAT IS OUTSIDE THE SCOPE OF THIS PROCEEDING

The ReMAT Developers, CalWEA, and Clean Coalition each support the Staff Pricing

Proposal based largely on the fact that (in these parties’ view in their comments) adopting it

would allow the Commission to reopen the ReMAT program quickly.17 The Joint IOUs submit

that reopening ReMAT18 is beyond the scope of this proceeding. The purpose of this proceeding

is to develop a new QF SOC that may then dissuade future litigants from claiming to FERC or a

federal district court that it is not PURPA compliant. Whether and how to reopen ReMAT has

no relevance to developing a new QF SOC or how to calculate avoided cost for such contract and

thus should play no role in this proceeding.

VI. FORWARD MARKET PRICES BEST REFLECT AVOIDED COST

CalWEA and TURN support the Staff Pricing Proposal as a reasonable approximation of

avoided costs, but do so without meaningful explanation of how the proposal reflects avoided

cost.19 For example, CalWEA states that Day Ahead prices cannot be known with certainty at

the time a contract is executed20 while acknowledging that “to establish a price determined at the

time of contract execution, the avoided cost rate must be based on an estimate of future

California Independent System Operator (“CAISO”) Day-Ahead prices.”21 CalWEA proffers

that the Commission has flexibility in determining avoided cost and therefore the proposal is

reasonable.22 TURN, in its comments, “understands that forecasting future energy prices is quite

17 ReMAT Developers Opening Comments, p. 1; CalWEA Opening Comments, p. 2; Clean Coalition Opening Comments, p.3.

18 SDG&E’s ReMAT tariff was officially closed by the Commission effective December 15, 2016 (Advice Letter No. 3018-E). On December 15, 2017, the Commission’s Executive Director issued a letter suspending all ReMAT activity under the remaining programs.

19 CalWEA Opening Comments, p.3. 20 CalWEA Opening Comments, p.3. 21 CalWEA Opening Comments, p.3. 22 CalWEA Opening Comments, p.3.

8

challenging” and views Staff’s proposal as a “practical means for setting such prices.”23 TURN,

however, states that “it is open to other reasonable and practical approach to establishing such

prices.”24

The Joint IOU’s approach to setting energy prices at the time of execution, as supported

by SEIA’s comments, is both reasonable and practical. Three-year forward prices are available

and, if discounted appropriately beyond one year, provide a price that is reflective of the avoided

cost of future procurement by a utility. If the utility needs no additional energy in the future, the

avoided cost should be zero. At the very least, the avoided cost price should reflect the amount

the utility can recover from the market, as it would need to sell off any energy that it must

purchase in excess of its needs. As SEIA notes, energy prices are volatile and using historical

data does not necessarily reflect future prices, especially over the longer term.25 Forward prices

at the trading hub adjusted for the lack of delivery certainty and subject to a locational

adjustment offer the best opportunity to ensure that the price is reflective of what the utility

would otherwise procure (and/or obtain from the market if it has insufficient retail load to

consume the energy, but has not met the requirements under federal regulations that would

permit it to curtail purchases from QFs).

The Joint IOUs take issue with the various proposals set forth by SEIA regarding the

avoided cost of capacity. First, the market has evolved past capacity payments based on energy

deliveries during pre-specified time frames. Capacity, in the form of Resource Adequacy (RA),

is a bilaterally-traded product with specific market rules that define the amount and use. Basing

the capacity price on the proxy cost of a combustion turbine assumes that the RA resource is

flexibly available when needed and can be turned off when not needed, which is not true for

renewables or self-scheduled resources. For these reasons, the Joint IOUs support a market-

based payment of capacity for the QF resource’s actual monthly net qualifying capacity

23 TURN Opening Comments, p.3. 24 TURN Opening Comments, p.3. 25 SEIA Opening Comments, p.8.

9

(“NQC”), if the QF resource is incrementally needed by the IOU to meet its RA compliance

needs. On an annual basis, the CAISO publishes a list specifying the monthly NQCs available

by each resource eligible to satisfy RA compliance obligations in the CAISO footprint. The

QF’s capacity payment quantity should not exceed the resource’s monthly NQC. Because there

are no forward indices for capacity, the Joint IOUs support the use of historical market data

obtained from the CPUC RA Report as the basis for determining the capacity price applicable to

the QF resource with the caveat that, if the IOU has no actual compliance need for capacity in

any month, the QF SOC would not provide for a capacity payment for that month. Additionally,

the monthly capacity price should be based upon the midpoint contained in the CPUC’s RA

Report rather than the 85th percentile, as proposed by SEIA, as the midpoint is more reflective of

the cost of NQC that the IOU would otherwise procure, absent the mandatory, uncapped,

purchase obligation required by PURPA.

VII. CONTRARY TO GPI AND WCS, PURPA COMPLIANCE DOES NOT REQUIRE THE

QF SOC TO OFFER A 20-YEAR TERM

GPI recommends that QFs be provided the option of 12-, 20-, or 25-year contract terms

and states that “the Staff Proposal suggests a 12-year contract term”.26 WCS similarly states that

“the current SOC has a maximum of a 12-year term, which must be changed to 20 years.”27 The

Commission’s stated objective in the instant rulemaking is to provide QFs the option to enter in

to a PPA at an avoided cost price established at the time of execution. The Joint IOU proposal

meets this objective. As SEIA points out, California has a multitude of programs that support

and encourage renewable generation, some with 20-year standard contract terms, and the QF

SOC has not been the [only] means for renewable QFs to obtain long-term contracts with the

IOUs (whether under PURPA or as FERC-regulated sellers) as implied by SEIA.28

26 GPI Opening Comments, p.8. 27 Winding Creek Opening Comments, p.7. 28 SEIA Opening Comments, p.7.

10

VIII. THE QF SOC IS NOT THE PRIMARY MEANS FOR ENCOURAGING QFS AND

RENEWABLE RESOURCES

Several commenters claim that the very ability of California to meet its renewable

portfolio standard goals and its obligation to encourage QFs rests entirely on programs such as

the QF SOC or ReMAT.29 These commenters appear to forget that most NEM programs are

now actually PURPA programs that pay an avoided-cost price for excess annual generation (if

any) (in addition to retail bill credits). Even those NEM programs that pay no compensation

other than retail bill credits are still programs that strongly encourage QFs. NEM programs

encourage retail customers to install QFs because PURPA and FERC policies and regulations

exempt small 20 MW and under) renewable generators from almost all FERC regulation. NEM

programs also provide quick and inexpensive interconnections for under 1 MW QFs. To argue

that only a handful of QFs have come on line that sell power under the QF SOC ignores the fact

that hundreds of thousands of QFs have come on line under NEM and that number continues to

rapidly escalate.

As to those QFs that cannot take advantage of NEM, there is no PURPA obligation to

encourage the construction of under 20 MW renewable QFs if such generators cannot turn a

profit at the Joint IOUs’ avoided-cost. If utility-scale renewables and NEM more efficiently

meet the needs of IOUs to fulfill their RPS goals such that under 20 MW QFs that are not NEM-

eligible are economically non-viable, the state must find another way, other than an avoided-cost

price subsidy that raises customers’ overall rates, if it desires to support such generation.

IX. ALL COMMISSION-JURISDICTIONAL UTILITIES SHOULD BE SUBJECT TO THE

RESULTS OF THIS PROCEEDING

CASMU argues for removal as respondents because they are not parties to the QF/CHP

Settlement and because of the administrative burdens of complying with a state-mandated

29 See e.g., GPI Opening Comments, at pp.1, 7-8.

11

program that adds burdens not imposed by federal regulations. Absent removal, CASMU

proposes a second phase of the proceeding to more thoroughly discuss PURPA implementation

going forward.

The Joint IOUs understand CASMU’s concern about the administrative burdens of

complying with the requirements of a state-mandated program and that the CASMU utilities are

not currently subject to entirely the same set of requirements as the Joint IOUs with regard to

PURPA implementation. The Joint IOUs support establishing a second phase of the proceeding

to more thoroughly discuss CASMU utilities’ PURPA obligations.

X. CONCLUSION

For the reasons set forth above and in the Joint IOUs’ Opening Comments, the Joint

IOUs continue to recommend that the Commission adhere to the narrow scope of this OIR and

adopt a short-term QF SOC with fixed prices at the time of execution.

Respectfully submitted on behalf of Pacific Gas and Electric Company, San Diego Gas and Electric Company, and Southern California Edison Company JANET S. COMBS CAROL SCHMID-FRAZEE MARIO E. DOMINGUEZ

/s/ Mario E. Dominguez By: Mario E. Dominguez

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6522 Facsimile: (626) 302-1935 E-mail: [email protected]

September 24, 2018


STATE OF CALIFORNIA



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 the JOINT REPLY COMMENTS OF PACIFIC GAS AND ELECTRIC COMPANY (U 39-E), SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), AND SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E) on all parties identified on the attached service list for R.18-07-017. Service was effected by transmitting copies via e-mail to all parties who have provided an e-mail address and by placing copies in sealed envelopes and causing such envelopes to be delivered via United States mail with first-class postage prepaid to the offices of the Assigned ALJ or other addressee(s).

ALJ Peter V. Allen California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue, Room 5017 San Francisco, CA 94102

Executed on September 24, 2018, at Rosemead, California.

/s/ Olivia Gutierrez Olivia Gutierrez SOUTHERN CALIFORNIA EDISON COMPANY

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

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Parties

DOUG KARPA, J.D., PH.D THOMAS MELONE POLICY DIR. CEO CLEAN COALITION WINDING CREEK SOLAR LLC PO BOX 87 C/O ALLCO RENEWABLE ENERGY LIMITED MILL VALLEY, CA 00000 1740 BROADWAY, 15TH FL. FOR: CLEAN COALITION NEW YORK, NY 10019 FOR: WINDING CREEK SOLAR LLC

PHILIP HOOVER NEDA AGHVAMI PROJECT MGR. PRINCIPAL H & M ENGINEERING, INC. DIVISION SOLAR, LLC 4521 ALPINE ROSE BEND 1518 FEDERAL AVE., PH6 ELLICOTT CITY, MD 21042 LOS ANGELES, CA 90025 FOR: H & M ENGINEERING FOR: DIVISION SOLAR, LLC

MICHAEL STERN CAROL SCHMIDT-FRAZEE PRESIDENT SENIOR ATTORNEY POCO POWER, LLC SOUTHERN CALIFORNIA EDISON COMPANY 31584 FOXFIELD DRIVE 2244 WALNUT GROVE AVE WESTLAKE VILLAGE, CA 91361 ROSEMEAD, CA 91770 FOR: POCO POWER, LLC FOR: SOUTHERN CALIFORNIA EDISON COMPANY

CLAY FABER PAUL MARCONI DIR. CA & FEDERAL REGULATORY DIRECTOR SAN DIEGO GAS & ELECTRIC COMPANY BEAR VALLEY ELECTRIC SERVICE 8330 CENTURY CT CP32F 42020 GRASTIN DRIVE, PO BOX 1547 SAN DIEGO, CA 92123 BIG BEAR LAKE, CA 92315 FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: BEAR VALLEY ELECTRIC SERVICE

Page 1 of 6CPUC - Service Lists - R1807017

9/24/2018https://ia.cpuc.ca.gov/servicelists/R1807017_85746.htm

KEVIN MACKAMUL MATTHEW FREEDMAN CEO ATTORNEY APT SOLAR COMPANY THE UTILITY REFORM NETWORK 688 AZURE HILLS DRIVE 785 MARKET STREET, 14TH FLOOR SIMI VALLEY, CA 93065 SAN FRANCISCO, CA 94103 FOR: APT SOLAR COMPANY FOR: TURN

MICHAEL ALCANTAR JONATHAN RAPPE ATTORNEY AT LAW CEO BUCHALTER, A PROFESSIONAL CORPORATION IMMODO DEVELOPMENT LLC 55 SECOND STREET, SUITE 1700 300 BRANNAN ST., SUITE 305 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94107 FOR: COGENERATION ASSOCIATION OF FOR: IMMODO DEVELOPMENT LLC CALIFORNIA

JEANNE B. ARMSTRONG MEGAN M. MYERS ATTORNEY ATTORNEY GOODIN MACBRIDE SQUERI & DAY LLP LAW OFFICES OF SARA STECK MYERS 505 SANSOME STREET, SUITE 900 122 - 28TH AVENUE SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94121 FOR: SOLAR ENERGY INDUSTRIES FOR: CENTER FOR ENERGY EFFICIENCY AND ASSOCIATION (SEIA) RENEWABLE TECHNOLOGIES

ERIK B. JACOBSON JENNY SO REGULATORY RELATIONS HYPOWER, INC. PACIFIC GAS AND ELECTRIC COMPANY 2229 HARBOR BAY PARKWAY 77 BEALE ST., MC B23A ALAMEDA, CA 94502 SAN FRANCISCO, CA 94177 FOR: HYPOWER, INC. FOR: PACIFIC GAS AND ELECTRIC COMPANY

JASON B. KEYES NANCY RADER ATTORNEY EXECUTIVE DIRECTOR KEYES & FOX LLP CALIFORNIA WIND ENERGY ASSOCIATION 436 14TH STREET, STE. 1305 1700 SHATTUCK AVENUE, SUITE 17 OAKLAND, CA 94612 BERKELEY, CA 94709 FOR: SOLAR ELECTRIC SOLUTIONS, LLC FOR: CALIFORNIA WIND ENERGY ASSOCIATION

MICHAEL J. MINKLER STEVEN KELLY GENERAL MANAGER POLICY DIR UTICA WATER AND POWER ANTHORITY INDEPENDENT ENERGY PRODUCERS ASSN. 1168 BOOSTER WAY / PO BOX 358 PO BOX 1287 ANGELS CAMP, CA 95222 SLOUGHHOUSE, CA 95683 FOR: UTICA WATER & POWER AUTHORITY FOR: INDEPENDENT ENERGY PRODUCERS ASSOCIATION (IEP)

ANN L. TROWBRIDGE ANDREW J. MCCLURE, ESQ. ATTORNEY ATTORNEY AT LAW DAY CARTER & MURPHY LLP MINASIAN, MEITH, SOARES, SEXTON & COOPER 3620 AMERICAN RIVER DR., STE. 205 1681 BIRD STREET / PO BOX 1679 SACRAMENTO, CA 95864 OROVILLE, CA 95965-1679 FOR: AGRICULTURAL ENERGY CONSUMERS FOR: NEVADA IRRIGATION DISTRICT ASSOCIATION



DANIEL MARSH TAM HUNT, J.D. MGR - RATES & REGULATORY AFFAIRS CONSULTING ATTORNEY LIBERTY UTILITIES (CALPECO ELECTRIC) LLC COMMUNITY RENEWABLE SOLUTIONS, LLC 933 ELOISE AVENUE 13-3585 MOKU ST SOUTH LAKE TAHOE, CA 96150 PAHOA, HI 96778 FOR: LIBERTY UTILITIES (CALPECO FOR: GREEN POWER INSTITUTE ELECTRIC)

MARGARET MILLER JESSICA RALSTON DIR. OF REG. AFFAIRS & MARKET DEV. SR. ATTORNEY AVANGRID RENEWABLES PACFICORP 1125 NW COUCH STREET, SUITE 600 825 NE MULTNOMAH, SUITE 1800 PORTLAND, OR 97209 PORTLAND, OR 97232 FOR: AVANGRID RENEWABLES FOR: PACIFICORP

Information Only

CASE COORDINATION DON BROOKHYSER PACIFIC GAS AND ELECTRIC COMPANY BUCHALTER, A PROFESSIONAL CORPORATION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

JIM ROSS JOHN W. LESLIE, ESQ. EMAIL ONLY DENTONS US LLP EMAIL ONLY, AA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

KARI CAMERON KAVYA BALARAMAN LEGAL ADMINISTRATOR STAFF WRITER / REPORTER BUCHALTER CALIFORNIA ENERGY MARKETS EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

KAZEEM B. OMIDIJI MATTHEW PLUMMER REGULATORY CASE MANAGER STATE AGENCY REGULATIONS SAN DIEGO GAS & ELECTRIC PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MICHAEL CADE SAHM WHITE BUCHALTER CLEAN COALITION EMAIL ONLY PO BOX 87 EMAIL ONLY, CA 00000 MILL VALLEY, CA 00000

TIM MASON TOM JARMAN POLICY DIRECTOR REGULATORY CASE MGR. LARGE-SCALE SOLAR ASSOCIATION PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MRW & ASSOCIATES, LLC CAMERON-DANIEL, P.C. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000



RICK UMOFF FREEMAN S. HALL REGULATORY COUNSEL & DIR. SOLAR ELECTRIC SOLUTIONS, LLC SOLAR ENERGY INDUSTRIES ASSOCIATION 11726 SAN VICENTE BLVD., STE. 414 600 14TH NW SUITE 400 LOS ANGELES, CA 90049 WASHINGTON, DC 20005 FOR: SOLAR ELECTRIC SOLUTIONS, LLC

CASE ADMINISTRATION MARIO E. DOMINGUEZ SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 8631 RUSH STREET 2244 WALNUT GROVE AVENUE / PO BOX 800 ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

DONALD C. LIDDELL CHRISTOPHER A. SUMMERS ATTORNEY REGULATORY BUSINESS MANAGER DOUGLASS & LIDDELL SAN DIEGO GAS & ELECTRIC 2928 2ND AVENUE 8330 CENTURY PARK CT., CP32F SAN DIEGO, CA 92103 SAN DIEGO, CA 92123

DEAN A. KINPORTS CENTRAL FILES REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA 92123-1530 SAN DIEGO, CA 92123

VITALY LEE JEFF HIRSCH EXEC. VICE PRESIDENT OF DEVELOPMENT JAMES J. HIRSCH & ASSOCIATES BAYWA R.E. SOLAR PROJECTS LLC 12185 PRESILLA ROAD 17901 VON KARMAN AVENUE SUITE 1050 SANTA ROSA VALLEY, CA 93012-9243 IRVINE, CA 92614

JAMES P. (JIM) MOSHER CHRISTINE J. HAMMOND COPPER BEECH CONSULTING LLC CALIF PUBLIC UTILITIES COMMISSION 11600 FINSBURY COURT LEGAL DIVISION BAKERSFIELD, CA 93312 ROOM 5137 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

DAVID MATUSIAK DAVID PECK CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC PRESIDENT PICKER AREA ROOM 4108 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

KARIN M. HIETA MITCHELL SHAPSON CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH LEGAL DIVISION ROOM 5010 ROOM 5129 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

POUNEH GHAFFARIAN ROSANNE O'HARA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION



LEGAL DIVISION LEGAL DIVISION ROOM 5025 ROOM 5039 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

SEAN A. SIMON TRACI BONE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER RECHTSCHAFFEN LEGAL DIVISION AREA 4-A ROOM 5027 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

MARCEL HAWIGER CHARLES R. MIDDLEKAUFF ATTORNEY PACIFIC GAS AND ELECTRIC COMPANY THE UTILITY REFORM NETWORK 77 BEALE STREET, B30A 785 MARKET STREET, SUITE 1400 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94103

BRIAN CRAGG BUCK ENDEMANN ATTORNEY ATTORNEY GOODIN, MACBRIDE, SQUERI & DAY, LLP K&L GATES, LLP 505 SANSOME ST., STE. 900 FOUR EMBARCADERO, STE 1200 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111

LILLY B. MCKENNA PATRICK FERGUSON MANATT PHELPS & PHILLIPS, LLP ATTORNEY ONE EMBARCADERO CENTER, 30TH FL. DAVIS WRIGHT TREMAINE LLP SAN FRANCISICO, CA 94111 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94111

TAHIYA SULTAN THOMAS W. SOLOMON DAVIS WRIGHT TREMAINE LLP ATTORNEY AT LAW 505 MONTGOMERY STREET, STE. 800 WINSTON & STRAWN LLP SAN FRANCISCO, CA 94111 101 CALIFORNIA STREET SAN FRANCISCO, CA 94111

DAVIS WRIGHT TREMAINE LLP JENNIFER K. POST 505 MONTGOMERY STREET, STE. 800 ATTORNEY SAN FRANCISCO, CA 94111 PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE ST., RM 3065. B30A SAN FRANCISCO, CA 94120

SARA STECK MYERS MATTHEW R. GONZALES ATTORNEY AT LAW MGR. - REGULATORY LAW OFFICES OF SARA STECK MYERS PACIFIC GAS AND ELECTRIC COMPANY 122 28TH AVE. PO BOX 770000 SAN FRANCISCO, CA 94121 SAN FRANCISCO, CA 94177-0001

RACHEL BIRD TIM LINDL DIR - POLICY & BUS. DEVELOPMENT, WEST ATTORNEY BORREGO SOLAR SYSTEMS, INC. KEYES & FOX LLP 360 22ND STREET, SUITE 600 436 14TH STREET, SUITE 1305 OAKLAND, CA 94612 OAKLAND, CA 94612



GREGG MORRIS R. THOMAS BEACH DIRECTOR PRINCIPAL CONSULTANT THE GREEN POWER INSTITUTE CROSSBORDER ENERGY 2039 SHATTUCK AVE., SUTE. 402 2560 9TH ST., SUITE 213A BERKELEY, CA 94704 BERKELEY, CA 94710-2557 FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION

PHILLIP MULLER MICHAEL BOCCADORO SCD ENERGY SOLUTIONS PRESIDENT 436 NOVA ALBION WAY WEST COAST ADVISORS SAN RAFAEL, CA 94903 925 L STREET, SUITE 800 SACRAMENTO, CA 95814 FOR: AGRICULTURAL ENERGY CONSUMERS ASSOCIATION

MARK HENWOOD CATHIE ALLEN HENWOOD ASSOCIATES, INC. REGULATORY AFFAIRS MGR. 1026 FLORIN ROAD, SUITE 390 PACIFICORP SACRAMENTO, CA 95831 825 NE MULTNOMAH ST., STE 300 PORTLAND, OR 97232 FOR: PACIFICORP

State Service

PETER V. ALLEN CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 5017 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

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