BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF ... · 4 #2 (“PRP 2”).10 As a tariffed...

LIMS-416-1177

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of San Diego Gas & Electric Company (U902E) for Authority to Implement Optional Pilot Program to Increase Customer Access to Solar Generated Electricity.

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Application 12-01-008 (Filed January 17, 2012)

In the Matter of the Application of Pacific Gas and Electric Company (U39E) to Establish a Green Option Tariff.

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Application 12-04-020 (Filed April 24, 2012)

In the Matter of the Application of Southern California Edison Company (U338E) for Approval of Optional Green Rate.

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SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E)

PHASE IV TRACK B REPLY COMMENTS

WILLIAM V. WALSH ROBERT F. LeMOINE

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-4476 Facsimile: (626) 302-6693 E-mail:[email protected]

Dated: December 9, 2015

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STATE OF CALIFORNIA


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SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E)

PHASE IV TRACK B REPLY COMMENTS

I.

INTRODUCTION

Pursuant to Rule 6.2 of the Rules of Practice and Procedure of the California Public Utilities

Commission (“Commission”) and the Assigned Commissioner and Administrative Law Judge’s

“(ALJ’s”) Scoping Memo and Ruling for Phase IV of Consolidated Proceeding (“Scoping Memo”),1

1 The “Administrative Law Judge Ruling (1) Adopting Comment Schedule on Senate Bill 793 and Renewables Auction Mechanism as an Enhanced Community Renewables Procurement Tool and (2) Revising the Schedule for Phase 4 Track B,” issued on October 26, 2015, revised the schedule for Track B opening and reply comments and motions for evidentiary hearings.

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Southern California Edison Company (“SCE”) respectfully submits its Track B Reply Comments in

Phase IV of this Green Tariff Shared Renewables (“GTSR”) proceeding.

II. COMMENTS

A. ReMAT Is Intended by Senate Bill (“SB”) 32 to Provide a Streamlined Procurement Mechanism; No Additional GTSR Modifications Should be Made to ReMAT

In its comments, Clean Coalition proposed a modified Renewable Market Adjusting Tariff

(“ReMAT”) procurement mechanism for Enhanced Community Renewables procurement (“ReMAT-

ECR”), including: (1) a doubled bi-monthly program period capacity cap; and (2) delayed

interconnection requirements.2 The Solar Energy Industries Association (“SEIA”) has also proposed

modifications to ReMAT to increase the size of allowable ReMAT-ECR projects to 20 megawatts

(“MW”).3 SCE does not support modifications to ReMAT beyond those already required by Decision

(“D.”) 15-01-051 and implemented through Resolution E-4734, because modifications will inhibit

ReMAT’s effectiveness as a streamlined procurement mechanism for small projects. As described

herein, SCE also opposes Clean Coalition and SEIA’s specific recommended modifications, which are

based on flawed or inadequate analysis, and that would require either statutory modifications or a formal

study to be properly implemented.

First and foremost, the ReMAT program is statutorily intended to be a streamlined procurement

mechanism for small projects sized 3 MW and less. Additional rules and/or exemptions for the ECR

program could create barriers to entry for the smaller market players that the program is intended to

serve.4 In the past 12 months, the Commission has already authorized modifications to ReMAT to

2 See Clean Coalition Opening Comments on the GTSR Program Phase IV Track B Issues, pp.4-5. 3 See Comments of SEIA in Response to the ALJ Ruling of October 26, 2015, pp.26-28. 4 SB 32 (2009, Negrete McLeod), which amended the Feed-in-Tariff (“FiT”) program and established the

ReMAT procurement mechanisms as it operates today, describes the following barrier that existed prior to the ReMAT procurement mechanism: “Some tariff structures and regulatory structures are presenting a barrier to meeting the requirements and goals of the California Renewables Portfolio Standard Program…Small projects of less than three megawatts…may face difficulties in participating in competitive solicitations…” See http://leginfo.ca.gov/pub/09-10/bill/sen/sb_0001-0050/sb_32_bill_20091011_chaptered.html. Further, D.13-05-034, which adopted the FiT joint standard contract for the ReMAT procurement mechanism stated

Continued on the next page

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incorporate the GTSR and Bioenergy Feed-in-Tariff (“BioMAT”) programs.5 These changes have not

yet been fully implemented. Further changes will increase administrative costs associated with the

ReMAT program and lessen clarity around rules for smaller market players.

Second, ReMAT is a statutorily-defined program. Certain changes to the ReMAT program

structure require legislative approval, including SEIA’s proposal to increase project size to 20 MW.

Public Utilities Code Section 399.20(b)(1) limits ReMAT projects to those with “an effective capacity of

not more than three megawatts.” Increasing the size of the project eligible to participate in ReMAT

would be contrary to the legislative requirements of the program as well as the drafters’ intent to target

smaller projects.

Third, certain changes that are within the Commission’s purview, such as changes to the bi-

monthly program period capacity caps and other changes that impact ReMAT’s pricing mechanism,6

should not be undertaken without a formal Commission or consultant study related to the specific

change. Commission staff and investor-owned utilities (“IOUs”) issued formal proposals when

implementing ReMAT in accordance with SB 32.7 Similarly, the Commission engaged a consultant to

recommend implementation of the BioMAT Program, including its pricing mechanism.8 Changing the

mechanics of the pricing mechanism for Re-MAT-ECR without appropriate evaluation could result in

unanticipated movements in price that do not reflect the market.9

Fourth, SCE opposes Clean Coalition’s recommendation to delay and model interconnection

requirements after those established in SCE’s current Preferred Resources Pilot Request for Proposals

Continued from the previous page

the following as one of five policy guidelines for the FiT program: “Ensure administrative ease and lower transaction costs for the buyer, seller, and regulator” (See D.13-05-034, p. 8).

5 See D.15-01-051 and D.14-12-081, which were developed in accordance with SB 43 (Wolk, 2013) and SB 1122 (Rubio, 2012), respectively.

6 See D.12-05-035, p. 40. 7 See Recent Developments in the ReMAT Program, including workshop materials, at this link:

http://www.cpuc.ca.gov/PUC/energy/Renewables/hot/fit_recentdevelopments.htm. 8 See BioMAT background and status, including consultant study at this link:

http://www.cpuc.ca.gov/PUC/energy/Renewables/hot/SB_1122_Bioenergy_Feed-in_Tariff.htm. 9 A discussion of the Re-MAT pricing mechanism is found in D.12-05-035, pp. 42-50. The Commission also

maintained the ReMAT market-based price adjustments mechanism in line for the BioMAT program. See D.14-12-081, p. 50 and SCE’s Comments on Proposed Decision Implementing SB 1112, p. 1.

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#2 (“PRP 2”).10 As a tariffed program open to projects throughout SCE’s service territory, the ReMAT-

ECR program is fundamentally different from SCE’s current PRP 2, which is a pilot program and

competitive solicitation limited to just two substations within SCE’s service territory.11 Interconnection

requirements help IOUs ensure project viability before signing power purchase agreements (“PPAs”).

Viability is especially important for ECR projects, as customers may look to whether a developer has a

PPA with the IOU before agreeing to support the project. Having minimum interconnection

requirements will help to ensure that customers are signing up for projects that will be developed.

Under ReMAT, interconnection requirements are one of several measures the Commission has

established to ensure projects are viable.12 Because the ReMAT-ECR program is part of tariff-based

ReMAT, IOUs do not have the ability to consider most qualitative factors,13 including project viability,

when signing PPAs; therefore, maintaining upfront project viability criteria, including minimum

interconnection requirements, is reasonable for the ReMAT-ECR program.

SCE urges the Commission to reject a modified ReMAT-ECR program. ReMAT is statutorily

intended to remove barriers to entry for small projects. The Commission has already prioritized making

minimal modifications to existing procurement tools for the GTSR Program. Extensively modifying the

ReMAT program to incorporate GTSR is counter to the legislature’s intent for the program and the

Commission’s prior directive.

10 See Clean Coalition Opening Comments on the GTSR Program Phase IV Track B Issues, pp.4-5. 11 Additional information about PRP 2 can be found at this link:

https://sceprprfo.accionpower.com/_scedgpr_1501/documents.asp?Col=DateDown. 12 See D.12-05-035, pp. 69-70. Interconnection requirements are listed as one of six approved project viability

criteria for ReMAT projects. 13 Pursuant to the ECR Developer Tariff, the IOUs have the ability to select projects out of queue order in order

to meet environmental justice (“EJ”) and residential subscription targets only. See SCE Schedule GTSR-CR-PDT, Section I.8 and I.9.

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B. SCE Prefers the AmLaw 100 Securities Opinion Standard (“AmLaw 100 Standard”), But Is Open to Other Objective Standards that Protect Customer Interests and Limit the Risk to the IOUs of Securities Litigation

As noted in SCE’s Track B Opening Comments, the AmLaw 100 Standard ensures that (1) firms

representing developers are financially sound, with sufficient malpractice insurance to protect bundled

customers and the IOUs in the event of securities litigation and (2) firms representing developers have

sufficient securities law expertise to evaluate ECR projects to ensure compliance with California and

federal securities laws. Other parties have expressed that the AmLaw 100 Standard is financially

prohibitive.14 SCE acknowledges this concern.

Alternatives offered by San Diego Gas & Electric (“SDG&E”), the Sustainable Economies Law

Center (“SELC”), and the Solar Energy Industries Association (“SEIA”) would reduce the cost of

securities opinions; 15 however, none would protect customers or the IOUs in the event of a claim of

securities law violation. While SCE prefers the AmLaw 100 Standard, SCE is open to other objective

standards, as long as they include financial protections for customers and the IOUs. An objective

standard serving in lieu of the AmLaw 100 Standard should ensure that firms have both sufficient

financial resources to protect customers and the IOUs in the event of securities litigation, as well as

sufficient expertise to evaluate ECR project structures to ensure compliance with securities laws. SELC

and SDG&E’s recommendation to rely on expertise alone, or even just good standing with the California

Bar as noted in SELC’s Opening Comments, fails to recognize the importance of financial backing in

the event of securities litigation arising out of a securities law violation. In general, solo practitioners do

not have the financial viability to compensate an IOU in a securities law case. In addition, legal

opinions are issued by the law firm as a whole and are signed on behalf of the law firm, not particular

attorneys within the firm, so requiring attorneys with a certain peer-review rating to sign the opinion

goes against typical law firm practice.

14 See Opening Comments of SELC on the GTSR Program Phase IV Track B Issues, p. 5. 15 See Opening Comments of SELC on the GTSR Program Phase IV Track B Issues, p. 5-10; Opening

Comments of SEIA on Track B Issues, pp.6-9; and Opening Comments of SDG&E (U902 E) On Phase IV Track B Scope, pp. 13-14.

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SCE offers the following alternative to the AmLaw 100 Standard to meet both the expertise and

financial viability criteria:

1. The firm should have partners or shareholders with 10 or more years of securities law experience and be sufficiently qualified in securities law in the IOU’s reasonable discretion.

2. The firm must have at least 10 equity partners.

3. The firm must have adequate malpractice insurance in light of securities litigation risk.

While this alternative does not offer the same protection as the AmLaw 100 Standard, it appropriately

balances the need for reduced securities opinion costs with adequate customer and IOU protection.

SEIA made a number of securities opinion recommendations in its Opening Comments. First,

SEIA indicated that the Commission should only require developers to obtain a “point-in-time”

securities law opinion. This is unnecessary. Legal opinions are always “point-in-time”, i.e. only valid

as of the date they are signed. Legal opinions do not cover future behavior. For this reason, the ECR

Rider to the ReMAT power purchase agreement (“PPA”) requires developers to provide an attestation

that the developer’s business model with customers is, and throughout the Delivery Term will be, as

described in the legal opinion.16 In other words, the developer covenants that it will maintain the ECR

project structure that the law firm opined on, but the law firm is not liable under the legal opinion if the

developer fails to do so.

Second, SEIA and SELC indicate that the Commission should require developers to include

statements in the Customer-Developer Agreement (“CDA”) indemnifying the utility against any

securities risk and indicating that all securities issues fall on the developer. The IOUs already included

language to this effect in the ECR Rider to the ReMAT PPA, adding the developer indemnity to the

direct agreement between the IOU and the developer, not the CDA, to which the IOU is not a party.17

No further action is required to address SEIA’s concern.

16 ECR Rider Section 9, adding new Section 3.5.16 to the ReMAT PPA. 17 ECR Rider Section 32, adding new Section 7.4 to the ReMAT PPA.

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Third, both SEIA and SELC noted that no law firm will sign a securities opinion to the extent

required in D.15-01-051. SCE agrees and recommends that the Commission permit the IOUs to delete

the following section of the ECR Rider, which contains a requirement that no firm is likely to accept:

“(a) comply with securities law, and that Buyer and its ratepayers are not at risk for securities claims

associated with the Project, and (b)”.18

SELC suggested that the language contained in the description that “…the legal opinion may not

contain any exceptions or qualifications unacceptable to Buyer in its reasonable discretion…”19 be

deleted. SCE strongly objects to this suggestion. The suggestion reflects a lack of understanding about

legal opinions. All legal opinions contain exceptions and qualifications, particularly so-called “reasoned

opinions” which state facts upon which the opinion is based, which are likely to be the case for ECR

project structure opinions. However, a law firm may occasionally include exceptions or qualifications

that are so extreme that they essentially render the opinion itself moot. If a developer’s law firm adds

exceptions or qualifications to the point that the opinion is meaningless, the IOU needs the right to reject

such exceptions and qualifications to protect itself and its customers.

C. SCE Supports Procurement of Additional Renewable Resources

As described in SCE’s Opening Comment, SCE supports procurement of renewable resources

other than solar for the GTSR program, but only through the Renewables Portfolio Standard (“RPS”)

solicitation.20 Several parties supported solar with energy storage capabilities in their opening

comments. If the Commission decides to allow a solar with storage option, the IOUs would need to

amend their non-negotiable PPAs to incorporate this option. This does not currently exist in non-

negotiable PPAs and would be difficult to incorporate today given limited experience with hybrid

facilities. The scope of amendments needed to accommodate an energy storage option is also

18 ECR Rider Section 9, adding new Section 3.5.16 to the ReMAT PPA. 19 Id. 20 See SCE’s Phase IV Track B Opening Comments, pp. 3-4.

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dependent on how a hybrid facility intends to use storage, which may vary significantly between

different hybrid facilities.

D. Extra Cost of Sub-500 kW Projects is Not “De Minimis”21

Clean Coalition states: “Extending GTSR program eligibility to sub-500 kW resources will not

have a significant effect on costs...”22 SCE disagrees. As described in SCE’s Opening Comments, SCE

incurs additional costs that are passed on to customers in order to aggregate projects under CAISO,23

including an incremental cost of approximately $30,000 per project.24 Further, SCE believes smaller

projects are likely to be prohibitively expensive for customers, because the fixed telemetry costs borne

by project developers that are associated with generating facilities interconnected to CAISO represent a

significant portion of total expected lifetime revenues for sub-500 kW projects.

SCE estimates that the fixed telemetry costs alone are nearly 10% of the total expected net

present value of lifetime revenues for a 500 kW project and upwards of 47% for a 100 kW project. By

comparison, SCE estimates that telemetry costs are only about 3% of total expected lifetime revenues

for a 1.5 MW project. 25 Because developers of sub-500 kW projects have such high fixed costs as

compared to total expected lifetime project revenues, developers would likely need to charge customers

more for associated energy output in order to make the project financially viable.

E. Re-Evaluation of EJ Benefits Is Not in Scope or Necessary to Ensure EJ Project Selection

The California Environmental Justice Alliance (“CEJA”) requested that the Commission revisit

the cost-benefit analysis of the GTSR proceeding surrounding EJ projects to ensure adequate

21 See Clean Coalition Opening Comments on GTSR Program Phase IV, Track B Issues, p. 3. 22 Id. 23 See SCE’s Phase IV Track B Opening Comments, pp. 2-3. 24 Costs are associated with setting up SCE Generation Management System and other systems to communicate

with generating facilities and CAISO. 25 This estimate is based on aggregated SCE contract data for solar ReMAT projects and SCE’s internal estimate

of fixed telemetry costs.

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consideration has been given to EJ Project non-quantifiable benefits or avoided external costs.26 As

noted in SCE’s Opening Comments, SCE supports the prioritization of EJ projects.27 Re-evaluation of

costs and benefits of EJ projects is not in scope in Phase IV, however, and is also unnecessary given the

prioritization language already implemented in ReMAT-ECR. SCE also included a qualitative criteria

within its 2015 RPS Solicitation Least Cost-Best Fit (“LCBF”) methodology. EJ preference within

solicitations eliminates the need for alternative cost-benefit analyses, as an IOU can select a project out

of queue or rank-order. Additionally a cost-benefit analysis would create unnecessary complexity as a

solicitation such as the RPS solicitation will provide all of the required information to compare costs and

benefits of multiple projects.

F. The Commission Should Wait until the Outcome of Assembly Bill (“AB”) 1110 is Known before Considering a Greenhouse Gas (“GHG”) Emissions Rate

SCE supports a uniform and consistent GHG emissions rate methodology for use by all retail

sellers across proceedings and technologies. As noted by The Utility Reform Network (“TURN”),

however, this issue is already under discussion in the State Legislature through Assembly Bill 1110.28

SCE agrees that the Commission should wait until the outcome of AB 1110 is known before considering

a uniform GHG emissions rate methodology, in order to ensure consistency with statute.

III.

CONCLUSION

SCE urges the Commission to consider and support the issues identified in these Phase IV Track

B Reply Comments.

26 See Phase IV Track B Opening Comments of CEJA, pp. 5-6. 27 See SCE’s Phase IV Track B Opening Comments, p. 6. 28 See Opening Comments of TURN on the Phase IV Track B Issues, p. 8.

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Respectfully submitted, WILLIAM V. WALSH ROBERT F. LeMOINE

/s/ Robert F. LeMoine By: Robert F. LeMoine

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-4476 Facsimile: (626) 302-6693 E-mail:[email protected]

December 9, 2015


STATE OF CALIFORNIA


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CERTIFICATE OF SERVICE

I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) PHASE IV TRACK B REPLY COMMENTS on all parties identified on the attached service list(s) A.12-01-008 et al. Service was effected by one or more means indicated below:

☒ Transmitting the copies via e-mail to all parties who have provided an e-mail address.

☒ 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.

☒ 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 Regina DeAngelis CPUC 505 Van Ness Ave. San Francisco, CA 94102

Executed December 9, 2015, at Rosemead, California.

/S/ Laura Velarde Laura Velarde SOUTHERN CALIFORNIA EDISON COMPANY

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

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BRAD HEAVNER DIANE I. FELLMAN POLICY DIRECTOR DIR - REGULATORY & GOV'T AFFAIRS CALIFORNIA SOLAR ENERGY INDUSTRIES ASSN NRG WEST & SOLAR EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: CALLIFORNIA SOLAR ENERGY FOR: NRG HOME SOLAR INDUSTRIES ASSOCIATION (CALSEIA) JAMIE L. MAULDIN JOHN W. LESLIE, ESQ. ATTORNEY ATTORNEY ADAMS BROADWELL JOSEPH & CARDOZO, PC DENTONS US LLP EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: CCUE FOR: SHELL ENERGY NORTH AMERICA (U.S.), L.P. MATTHEW FREEDMAN SUSANNAH CHURCHILL THE UTILITY REFORM NETWORK SOLAR POLICY ADVOCATE EMAIL ONLY VOTE SOLAR EMAIL ONLY, CA 00000 EMAIL ONLY FOR: THE UTILITY REFORM NETWORK EMAIL ONLY, CA 00000 FOR: VOTE SOLAR CHAIRMAN / PRESIDENT MAYA GOLDEN-KRASNER LAT. BUS. CHAMBER OF GREATER L.A. COMMUNITIES FOR A BETTER ENVIRONMENT 634 S. SPRING STREET, STE 600 6325 PACIFIC BLVD., STE. 300 LOS ANGELES, CA 90014 HUNTINGTON PARK, CA 90255 FOR: LATINO BUSINEES CHAMBER OF GREATER FOR: CALIFORNIA ENVIRONMENTAL JUSTICE L.A. ALLIANCE (CEJA) DANIEL W. DOUGLASS ROBERT F. LEMOINE DOUGLASS & LIDDELL SOUTHERN CALIFORNIA EDISON COMPANY 4766 PARK GRANADA, STE. 209 2244 WALNUT GROVE AVE./ PO BOX 800 CALABASAS, CA 91302 ROSEMEAD, CA 91770 FOR: 3 PHASES RENEWABLES/DIRECT ACCESS FOR: SOUTHERN CALFIORNIA EDISON COMPANY

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CUSTOMER COALITION/ALLIANCE FOR RETAIL ENERGY MARKETS (AREM) TY TOSDAL E. GREGORY BARNES TOSDAL LAW FIRM SENIOR COUNSEL 777 S. HIGHWAY 101, SUITE 215 SAN DIEGO GAS & ELECTRIC COMPANY SOLANA BEACH, CA 92075 8330 CENTURY PARK CT., 2ND FLOOR FOR: MARIN CLEAN ENERGY SAN DIEGO, CA 92123 FOR: SAN DIEGO GAS & ELECTRIC COMPANY AARON LEWIS FAITH BAUTISTA COUNSEL PRESIDENT & CEO NATIONAL ASIAN AMERICAN COALITION NATIONAL ASIAN AMERICAN COALITION 15 SOUTHGATE AVENUE, SUITE 200 15 SOUTHGATE AVE., STE. 200 DALY CITY, CA 94015 DALY CITY, CA 94015 FOR: NATIONAL ASIAN AMERICAN COALITION; FOR: NATIONAL ASIAN AMERICAN COALITION LOS ANGELES LATINO CHAMBER OF COMMERCE; ECUMENICAL CTR. FOR BLACK CHURCH STUDIES BRIAN KORPICS MARC D. JOSEPH POLICY MANAGER ATTORNEY AT LAW THE CLEAN COALITION ADAMS BROADWELL JOSEPH & CARDOZO 16 PALM ST. 601 GATEWAY BLVD. STE 1000 MENLO PARK, CA 94025 SOUTH SAN FRANCISCO, CA 94080 FOR: CLEAN COALITION FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES (CCUE) SARAH R. THOMAS WILLIAM SANDERS CALIF PUBLIC UTILITIES COMMISSION DEPUTY CITY ATTORNEY LEGAL DIVISION CITY AND COUNTY OF SAN FRANCISCO ROOM 5033 CITY HALL, RM. 234 505 VAN NESS AVENUE 1 DR. CARLTON B. GOODLETT PLACE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-4682 FOR: ORA FOR: CITY & COUNTY OF SAN FRANCISCO JOHN GORMAN MICHAEL WHEELER CEO DIRECTOR OF POLICY INITIATIVES ECOPLEXUS INC RECURRENT ENERGY 650 TOWNSEND STREET, SUITE 310 300 CALIFORNIA STREET, 8TH FLOOR SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94104 FOR: ECOPLEXUS INC. FOR: RECURRENT ENERGY JEANNE B. ARMSTRONG CHRISTOPHER J. WARNER ATTORNEY ATTORNEY GOODIN MACBRIDE SQUERI DAY & LAMPREY LLP PACIFIC GAS AND ELECTRIC COMPANY 505 SANSOME STREET, SUITE 900 77 BEALE STREET B30A / PO BOX 7442 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94120 FOR: SOLAR ENERGY INDUSTRIES FOR: PACIFIC GAS & ELECTRIC COMPANY ASSOCIATION (SEIA) JOSEPH F. WIEDMAN SUBIN G. VARGHESE ATTORNEY SUSTAINABLE ECONOMIES LAW CENTER KEYES FOX & WIEDMAN LLP 2323 BROADWAY , SUITE 203 436 - 14TH STREET, SUITE 1305 OAKLAND, CA 94612 OAKLAND, CA 94612 FOR: SUSTAINABLE ECONOMIES LAW CENTER FOR: INTERSTATE RENEWABLE ENERGY COUNCIL, INC. (IREC) CARMELITA L. MILLER EUGENE S. WILSON LEGAL COUNSEL LAW OFFICE OF EUGENE WILSON THE GREENLINING INSTITUTE 3502 TANAGER AVENUE 1918 UNIVERSITY AVENUE, 2ND FLOOR DAVIS, CA 95616-7531 BERKELEY, CA 94704 FOR: SIERRA CLUB (SIERRA) / CALIFORNIA FOR: THE GREENLINING INSTITUTE CLEAN ENERGY COMMITTEE (CCEC) HARRIET A. STEINER KAREN NORENE MILLS BEST BEST & KRIEGER LLP ATTORNEY 500 CAPITOL MALL, STE. 1700 CALIFORNIA FARM BUREAU FEDERATION SACRAMENTO, CA 95814-4704 2300 RIVER PLAZA DRIVE FOR: CITY OF DAVIS SACRAMENTO, CA 95833 FOR: CALIFORNIA FARM BUREAU FEDERATION



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ANDREW BROWN BARBARA BARKOVICH ELLISON SCHNEIDER & HARRIS LLP CONSULTANT EMAIL ONLY BARKOVICH & YAP EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 CAROLINE PAULSEN CASE COORDINATION RESEARCH AND POLICY ANALYST PACIFIC GAS AND ELECTRIC COMPANY CLEAN ENERGY COLLECTIVE EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 CASSANDRA YAMASAKI CHARLIE COGGESHALL NATIONAL ASIAN AMERICAN COALITION POLICY ANALYST EMAIL ONLY CLEAN ENERGY COLLECTIVE EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 CLAY FABER DAMON FRANZ SEMPRA UTILITIES DIRECTOR - POLICY & ELECTRICITY MARKETS EMAIL ONLY SOLARCITY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 DAVID HUANG DAVID MARCUS LEGAL FELLOW EMAIL ONLY THE GREENLINING INSTITUTE EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 JENNIFER W. SUMMERS JEREMY WAEN REGULATORY CASE ADMINISTRATOR REGULATORY ANALYST SAN DIEGO GAS & ELECTRIC COMPANY MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 JESSICA TAM JIM METROPULOS SPECIAL COUNSEL OFFICE OF SENATOR LOIS WOLK NATIONAL ASIAN AMERICAN COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 KAREN KHAMOU KERRY HATTEVIK PACIFIC GAS & ELECTRIC COMPANY DIRECTOR - WEST GOV'T. AFFAIRS EMAIL ONLY NEXTERA ENERGY RESOURCES EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 MARY HOFFMAN NINA SUETAKE SOLUTIONS FOR UTILITIES, INC. STAFF ATTORNEY EMAIL ONLY THE UTILITY REFORM NETWORK EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 PETER BANNER RACHEL GOLD SCIENTIA ENERGY, INC. POLICY DIR EMAIL O NLY CONSCIOUS VENTURES GROUP EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 SACHU CONSTANTINE SEPHRA A. NINOW, J.D. DIR - POLICY REGULATORY AFFAIRS MGR. CENTER FOR SUSTAINABLE ENERGY CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 SHALINI SWAROOP STEPHANIE CHEN REGULATORY COUNSEL POLICY DIR. - ENERGY / TELECOM MARIN CLEAN ENERGY THE GREENLINING INSTITUTE EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000



STEVE HAERTLE SUE MARA PACIFIC GAS AND ELECTRIC COMPANY PRINCIPAL EMAIL ONLY RTO ADVISORS, LLC EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 FOR: ALLIANCE FOR RETAIL ENERGY MARKETS (AREM) TADASHI GONDAI TOM HUNT SR. ATTORNEY DIRECTOR, RESEARCH & GOVERNEMNT AFFAIRS NATIONAL ASIAN AMERICAN COALITION CLEAN ENERGY COLLECTIVE EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL O NLY, CA 00000 MRW & ASSOCIATES, LLC IAN MCGOWAN EMAIL ONLY 3DEGREES INC EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000-0000 KENNETH SAHM WHITE JAMES (JIM) VON RIESEMANN DIRECTOR, ECONOMIC & POLICY ANALYSIS MIZUHO SECURITIES USA, INC. CLEAN COALITION 320 PARK AVENUE, 12TH FLOOR EMAIL ONLY NEW YORK, NY 10022 EMAIL ONLY, CA 00000-0000 PETER OLMSTED BRANDON SMITHWOOD VOTE SOLAR SOLAR ENERGY INDUSTRIES ASSOCIATION 1315 CLAYTON RD 600 41TH STREET, NW, SUITE 400 LANCASTER, PA 17603-2401 WASHINGTON, DC 20005 KELLY CRANDALL KAREY CHRIST-JANER KEYES FOX & WIEDMAN LLP 130 E. TURNER AVENUE 1400 16TH ST., 16 MARKET SQR., STE. 400 BERTHOUD, CO 80513 DENVER, CO 80202 JOHN DOYLE AMBER WYATT CORONAL GROUP/PANASONIC SENIOR ATTORNEY 330 NORTH BRAND BLVD., SUITE 1170 SOUTHERN CALIFORNIA EDISON COMPANY GLENDALE, CA 91203 2244 WALNUT GROVE AVE./PO BOX 800 ROSEMEAD, CA 91770 CASE ADMINISTRATION NATHANAEL GONZALEZ SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. / PO BOX 800 8631 RUSH STREET ROSEMEAD, CA 91770 ROSEMEAD, CA 91770 CHAD CHAHBAZI DONALD C. LIDDELL, PC BAP POWER CORPORATION D/B/A CENERGY COUNSEL 3176 LIONSHEAD AVE., STE. 11 DOUGLASS & LIDDELL CARLSBAD, CA 92010-4708 2928 2ND AVENUE SAN DIEGO, CA 92103 MARCIE A. MILNER CENTRAL FILES VP - REG AFFAIRS SDG&E/SOCALGAS SHELL ENERGY NORTH AMERICA (US), L.P. 8330 CENTURY PARK COURT, CP31-E 4445 EASTGATE MALL, STE. 100 SAN DIEGO, CA 92123 SAN DIEGO, CA 92121 TODD CAHILL WILLIAM FULLER SAN DIEGO GAS & ELECTRIC COMPANY CALIF. REGULATORY AFFAIRS 8330 CENTURY PARK COURT SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA 92123 8330 CENTURY PARK COURT, 32CH SAN DIEGO, CA 92123-1548 KAY CADENA ROBERT GNAIZDA SENIOR POLICY AND LEGAL ANALYST OF COUNSEL NATIONAL ASIAN AMERICAN COALITION 15 SOUTHGATE AVE., STE. 200 15 SOUTHGATE AVE., STE. 200 DALY CITY, CA 94015 DALY CITY, CA 94015 RACHAEL KOSS ERICA M. SCHROEDER ADAMS BROADWELL JOSEPH & CORDOZO SHUTE, MIHALY AND WEINBERGER, LLP 601 GATEWAY BLVD., STE. 1000 396 HAYES STREET SOUTH SAN FRANCISCO, CA 94080 SAN FRANCISCO, CA 94102



ERICA SCHROEDER MCCONNELL SHAIBYA DALAL SHUTE, MIHALY AND WEIBERGER, LLP SAN FRANCISCO PUBLIC UTILITIES COMM. 396 HAYES STREET 525 GOLDEN GATE AVE., 7TH FLOOR SAN FRANCISCO, CA 94102 SAN FRANCISCO, CA 94102-3220 FOR: INTERSTATE RENEWABLE ENERGY COUNCIL, INC. (IREC) AUSTIN M. YANG CARLOS VALDIVIA DEPUTY CITY ATTORNEY ECOPLEXUS CITY AND COUNTY OF SAN FRANCISCO 650 TOWNSEND STREET, STE. 310 OFFICE OF CITY ATTORNEY DENNIS J.HERRERA SAN FRANCISCO, CA 94103 1 DR. CARLTON B. GOODLETT PL, RM 234 SAN FRANCISCO, CA 94102-4682 CHARLES R. MIDDLEKAUFF GAREN GRIGORYAN PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY LAW DEPT. 245 MARKET STREET, RM. 1255D 77 BEALE STREET, B30A / PO BOX 7442 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 JENNY CHEU SHERIDAN J. PAUKER, ESQ. PACIFIC GAS AND ELECTRIC COMPANY REGULATORY COUNSEL 77 BEALE STREET, MC B9A WILSON SONSINI GOODRICH & ROSATI SAN FRANCISCO, CA 94105 ONE MARKET PLAZA, SPEAR TOWER, STE 3300 SAN FRANCISCO, CA 94105 CASSANDRA SWEET MOLLY DERINGER REPORTER CALIFORNIA ENVIRONMENTAL ASSOCIATES DOW JONES NEWSWIRES 423 WASHINGTON ST. 201 CALIFORNIA ST. SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 HAWARD V. GOLUB STEPHEN BJORGAN NIXON PEABODY LLP NETZERO ENERGY LLC ONE EMBARCADERO CENTER, 18TH FLR. PO BOX 14247 SAN FRANCISCO, CA 94111-3600 SAN FRANCISCO, CA 94114 FOR: CITY OF DAVIS POLLY SHAW CALIFORNIA ENERGY MARKETS 1162 STANYAN ST. 425 DIVISADERO ST STE 303 SAN FRANCISCO, CA 94117 SAN FRANCISCO, CA 94117-2242 ROBIN QUARRIER CASE ADMINISTRATION CHIEF COUNSEL PACIFIC GAS AND ELECTRIC COMPANY CENTER FOR RESOURCE SOLUTIONS 77 BEALE STREET, MC B9A 1012 TORNEY AVENUE, 2ND FL. SAN FRANCISCO, CA 94177 SAN FRANCISCO, CA 94129 NITZAN GOLDBERGER DAVID SIMPSON PACIFIC GAS AND ELECTRIC COMPANY VILLAGE POWER FINANCE 245 MARKET STREET, MC N12G 3221 PORTER DRIVE SAN FRANCISCO, CA 94177 PALO ALTO, CA 94304 DANIEL CHIA CAROLINE LEE DIR. THE SUSTAINABLE ECONOMIES LAW CENTER SOLARCITY 436 14TH ST., STE. 1120 3055 CLEARVIEW WAY OAKLAND, CA 94612 SAN MATEO, CA 94402 NITZAN GOLDBERGER ROGER LIN DIR.-POLICY & BUSINESS DEVELOPMENT STAFF ATTORNEY BORREGO SOLAR SYSTEM, INC. COMMUNITIES FOR A BETTER ENVIRONMENT 360 22ND STREET, STE. 600 1904 FRANKLIN ST., STE. 600 OAKLAND, CA 94612 OAKLAND, CA 94612 FOR: CALIFORNIA EVIRONMENTAL JUSTICE ALLIANCE (CEJA) TIM LINDL YASSI ESKANDARI-QAJAR COUNSEL CITY POLICIES PROGRAM DIRECTOR KEYES FOX & WIEDMAN LLP SUSTAINABLE ECONOMIES LAW CENTER 436 14TH STREET, STE. 1305 2323 BROADWAY AVE. OAKLAND, CA 94612 OAKLAND, CA 94612 R. THOMAS BEACH JOHN NIMMONS



PRINCIPAL CONSULTANT COUNSEL CROSSBORDER ENERGY JOHN NIMMONS & ASSOCIATES, INC. 2560 NINTH STREET, SUITE 213A 175 ELINOR AVE., STE. G BERKELEY, CA 94710 MILL VALLEY, CA 94941 FOR: RECURRENT ENERGY DONALD M. BRAY KELLY FOLEY JOINT VENTURE SILICON VALLEY GENERAL COUNSEL 100 W. SAN FERNANDO STREET, SUITE 310 CALIFORNIA CLEAN POWER SAN JOSE, CA 95113 50 SANTA ROSA AVE. SUITE 420 SANTA ROSA, CA 95404 LEE KOSLA DOUGLAS M. GRANDY, P.E. COLEMKO, LLC CALIFORNIA ONSITE GENERATION 1535 WESTLAKE DRIVE 1220 MACAULAY CIRCLE KELSEYVILLE, CA 95451 CARMICHAEL, CA 95608 MARTIN HOMEC BERNADETTE DEL CHIARO PO BOX 4471 CAL. SOLAR ENERGY INDUSTRIES ASSOCIATION DAVIS, CA 95617 1107 9TH ST., STE. 820 SACRAMENTO, CA 95814 CURT BARRY SCOTT BLAISING SENIOR WRITER ATTORNEY CLEAN ENERGY REPORT BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 717 K STREET, SUITE 503 915 L STREET, STE. 1270 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 RONALD LIEBERT ANN L. TROWBRIDGE ATTORNEY AT LAW ATTORNEY ELLISON SCHNEIDER & HARRIS LLP DAY CARTER & MURPHY LLP 2600 CAPITOL AVENUE, STE. 400 3620 AMERICAN RIVER DR., STE. 205 SACRAMENTO, CA 95816 SACRAMENTO, CA 95864 ROBIN SMUTNY-JONES SARA BIRMINGHAM DIR., CALIFORNIA POLICY & REGULATION SOLAR ENERGY INDUSTRIES ASSOCIATION IBERDROLA RENEWABLES, LLC 3300 NE 157TH PLACE 1125 NW COUCH ST., STE. 700 PORTLAND, OR 97230 PORTLAND, OR 97209

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CHRIS UNGSON DAVID PECK CPUC - ORA CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 HELENA OH MITCHELL SHAPSON CPUC STAFF ATTORNEY EMAIL ONLY CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 SCOTT MURTISHAW STEPHEN RICKERT CPUC - EXEC DIV RETAIL RATES EMAIL ONLY CPUC - ENERGY DIV. EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 TIM DREW VALERIE KAO CALIFORNIA PUBLIC UTILITIES COMMISSION SED EMAIL ONLY CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 ALICE GLASNER CHRISTOPHER CLAY CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMUNICATIONS DIVISION LEGAL DIVISION ROOM 4102 ROOM 4300 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA



GABRIEL PETLIN JAMIE ORMOND CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B EXECUTIVE DIVISION AREA 4-A ROOM 5206 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 LEWIS BICHKOFF MEGHA LAKHCHAURA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN PROCUREMENT STRATEGY AND OVERSIGHT BRANC AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 PATRICK DOHERTY REBECCA TSAI-WEI LEE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DEMAND RESPONSE, CUSTOMER GENERATION, AN POLICY & PLANNING DIVISION AREA ROOM 1250 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 REGINA DEANGELIS SHANNON O'ROURKE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES DEMAND RESPONSE, CUSTOMER GENERATION, AN ROOM 5105 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 VALERIE KAO XIAN "CINDY" LI CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION TRANSPORTATION ENFORCEMENT BRANCH ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM 4104 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

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Xian Cindy"" Li CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAMS BRANCH, ROOM 4104 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102‐3214

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