R1812006-SCE OPENING COMMENTS ON SAFETY ......and Infrastructure for Vehicle Electrification....

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Order Instituting Rulemaking to Continue the Development of Rates and Infrastructure for Vehicle Electrification.

Rulemaking 18-12-006

SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON SAFETY, TECHNOLOGY, AND STANDARDS

ANNA VALDBERG ANDREA TOZER Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6713 Facsimile: (626) 302-6693 E-mail : [email protected]

Dated: July 14, 2020

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STATE OF CALIFORNIA



SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON SAFETY, TECHNOLOGY, AND STANDARDS

I.

INTRODUCTION

Pursuant to the Administrative Law Judge’s Ruling Adding Staff Proposal for a Draft

Transportation Electrification Framework to the Record and Inviting Party Comments, issued on

February 3, 2020 (Ruling), modified in an email ruling, issued on March 24, 2020, and pursuant

to the extension granted by Administrative Law Judge Goldberg via email on July 2, 2020,

Southern California Edison Company (SCE) respectfully submits these comments on the Safety,

Technology and Standards (Sections 7 and 8) of the Transportation Electrification Framework

(TEF).

Below are SCE’s responses to the “Questions for Stakeholders” identified in Sections 7

and 8 of the Draft TEF. SCE focuses its responses on those questions where its input will provide

the greatest value to the Commission. SCE also recommends, as discussed below, that the

Commission hold additional workshop(s) to further explore some concepts—such as the

treatment of utility distribution and service connection costs for commercial electric vehicle

charging infrastructure via tariffs or other mechanisms. SCE believes that this topic, as well as

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SCE’s recommended modifications to the draft TEF submitted in Reply Comments on April 27,

2020, warrant additional exploration through workshops, either as part of this round of

comments or separately.1 SCE looks forward to working with the Commission and parties to

address those issues in future workshops or comments.

II.

INVESTOR-OWNED UTILITY PROGRAM REQUIREMENTS (SECTION 7.1)

One of SCE’s core values is to protect public and employee safety, and SCE appreciates

the Commission’s attention in the TEF on evaluating current safety programs and workforce

training to ensure programs to accelerate TE infrastructure installation continue to remain

focused on consumer and installer safety.

1. What revisions, if any, are needed to improve the safety procedures and

implementation processes for the investor-owned utilities’ (IOU) transportation

electrification programs?

SCE believes that the Transportation Electrification (TE) Safety Requirements Checklist

adopted by the Commission in Decision (D.) 18-01-024 and D.18-01-05-040 and utilized by the

utilities establishes effective procedures and processes for ensuring safety, and SCE does not

have any proposed modifications or revisions at this time.

1 In Reply Comments submitted on April 27, 2020, SCE recommended, among other things, that the Commission recognize that providing the utility-side make-ready is a core utility function and authorize the IOUs to propose new utility-side make-ready tariffs. SCE also urged the Commission to adopt a near-term process that expands the “no regrets” priorities to include workplace Level 1 and 2 charging and avoid the potential for program starts and stops by allowing for continuous program support until the new TE Plan (TEP) programs can be implemented. The Commission should create a more durable framework to expedite decision making by requiring the IOUs to file five-year (rather than ten-year) TEPs and associated TE program proposals that are reviewed and approved simultaneously. Given that the market currently lacks maturity, the framework should simplify the process for determining the IOU role in accelerating electric vehicle adoption.

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3. What policies or procedures, if any, should be included in IOU program design to

ensure TE infrastructure is safely maintained or decommissioned once a program

period has ended?

The maintenance and decommissioning of utility TE infrastructure should follow existing

policies for utility infrastructure maintenance and decommissioning. TE infrastructure, similar

to non-TE utility infrastructure, is industrial in nature and built to last decades using the same

technology and components. In cases where the EV Supply Equipment (EVSE) is installed as

part of a TE program, the maintenance and decommissioning of that equipment is governed by

the program tariff and participation agreement, which is signed by the customer.

III.

SAFETY THROUGH WORKFORCE TRAINING (SECTION 7.2)

1. Should the investor-owned utilities (IOU) include workforce development plans in

their Transportation Electrification Plans?

SCE agrees that a continued focus on workforce development and training is an

important element of accelerating TE adoption and ensuring safety; however, IOUs should not be

required to include workforce development plans in their TEPs. Assessing and evaluating

workforce skills and gaps is an ongoing exercise the IOUs perform holistically across the

enterprise, with many established electrical contracting skills shared across IOU infrastructure

deployment activities, not just TE.

As noted by staff, coordination with the California Labor & Workforce Development

Agency can help the IOUs identify development needs and opportunities to create high-quality

jobs that support IOU TE programs. Specific needs of the IOUs’ planned TE programs can and

should be part of that ongoing coordination and evaluation, but workforce development does not

need to be evaluated or determined through the TEP process.

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IV.

ELECTRIC VEHICLE SUPPLY EQUIPMENT (EVSE) STANDARDS (SECTION 8.1)

5. What are the expected costs of requiring vehicle-grid integration (VGI)-enabled

electric vehicle supply equipment (EVSE) across all investor-owned utility (IOU)

EVSE investments?

SCE is unable to forecast the expected costs of requiring VGI-enabled EVSEs, as costs

will vary substantially depending on the technology used in the VGI-enabled EVSE. This issue

has been and continues to be debated in public forums such as the Vehicle Grid Integration

Working Group (VGIWG), in which SCE is an active participant. To determine costs in the

most reliable fashion, a demonstration(s) should be conducted that delivers VGI services, in

order to quantify costs and benefits.

a) What are the projected costs of requiring all ratepayer funded EVSE meet

International Organization for Standardization (ISO) standard 15118, and

aligning with the protocol updates currently underway?

Because EVSEs utilizing ISO standard 15118 do not exist in the domestic mass-

marketplace, SCE is not able to project the costs of requiring ISO 15118 for ratepayer-

funded EVSE at this time. However, since ISO 15118 requires communication-related

hardware and software on each EVSE and EV, it may be more expensive than other

networking solutions for EV charging.

SCE anticipates that a lower-cost solution may be IEEE 2030.5, because it can

utilize a gateway and that gateway can communicate with multiple EVs, unlike ISO

15118, which has a one-to-one relationship between the EV and EVSE for load

management. Additionally, as ISO 15118 is required to be implemented on each EVSE,

the EVSE would need to be replaced or updated and then recertified if the standard is

superseded and not compatible with previous versions. Depending on the configuration

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in the field, this might not be the case for IEEE 2030.5. SCE thinks that Telematics

would be the least costly solution, in which case existing networking would be leveraged

and dedicated EVSE hardware and software are not needed.

In terms of utility back-office support infrastructure, the costs for utilities to

manage load and perform VGI will be incremental to existing costs to load manage

Distributed Energy Resources (DERs) and Demand Response (DR) resources. To

provide VGI, utilities can leverage existing and future DER and DR systems with

associated incremental costs.

b) What are the projected costs of installing VGI-enabling hardware after

EVSE are deployed for existing and forecasted IOU-funded programs?

For managed charging (V1G), there may be no additional costs if utilizing

technology that does not depend on the EVSE for VGI services, such as IEEE 2030.5

pathways to EVs and EV original equipment manufacturer (OEM) telematics, as

additional VGI-enabling hardware is not needed. For technologies that utilize EVSE as a

communication link to the EVs, the cost is unknown as the EVSEs may need to be

replaced because once modified, it will not be in compliance with NRTL safety

certification. These units would need to be replaced with an EVSE capable of

communicating ISO 15118 (or IEEE 2030.5 if using EVSE communications), or a future

standard if not already compliant with current capabilities and certification requirements.

The incremental cost of this capability has been discussed in the VGI Working Group but

was not resolved. It may be possible to reduce upgrade costs if a site has multiple EVSE

that communicate through a gateway, and the gateway could be replaced (a scheme

allowed by IEEE 2030.5); however, the system would have to ensure safety and

cybersecurity compliance (end-to-end security) in a verifiable way.

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6. How can IOUs account for and/or project the scale of vehicle-to-grid enabled EVs in

their service territories within their Transportation Electrification Plans?

All current EVs that utilize the SAE J1772 standard are V1G compatible as that standard

provides for communication with the EV and control of charging. For overall vehicle-to-grid

integration, SCE anticipates it will develop its TE Plans using goals set by the state of California

and EV forecasts provided by the CEC, DMV, market research firms such as Bloomberg, and

other resources consistent with the TEF that is ultimately adopted by the Commission. As for

reverse power flow vehicle-to-grid (V2G), only Nissan is currently offering this function within

certain limits and only with special DC charging equipment. It is unknown when (or if) other

EV manufacturers will produce light-duty vehicles capable of V2G in the future. A small

number of medium- and heavy-duty vehicles with associated chargers claim to be V2G capable

but need progress on certification and interconnection. Since larger medium- and heavy-duty

vehicles are built to customer order, and they have not been demonstrated at scale, it is harder to

project the number and capabilities of VGI-enabled vehicles in this class. SCE will use

forecasting methods similar to those outlined above, as well as results from EPIC demonstration

projects on VGI, together with its Charge Ready projects, to help project the extent and effect of

vehicle-to-grid enabled EVs.

a) Without existing interconnection standards, how can vehicle-to-grid (V2G)

technology be tested and scaled?

Typically, services are tested before standards are developed. Testing includes

both laboratory and field work. Once the technology is safe and operational, additional

market testing is done to determine which features resonate with customers, the value to

customers, and the cost to deliver services. V2G can be developed the same way through

pilots and demonstrations informing standards development, and once the market is

tested, programs can be developed to scale V2G offerings. The LA Air Force Base V2G

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pilot is an example of this process.2 The lessons learned from this effort have been used

to inform OEMs, utilities, standards bodies and policy setting groups and efforts being

undertaken by them such as the Vehicle Grid Integration Working Group (VGIWG).

V2G offerings must comply with Rule 21 and associated state and local code

requirements. SCE participates in Rule 21 proceedings and working groups, and has a

dedicated V2G EPIC project focused on testing and demonstrating V2G technology, the

results of which can be used by industry focused on scaling up.

b) How should V2G electric vehicles (EV), which can serve power back onto the

grid, be forecasted differently than load-only EVs in IOU planning

processes?

SCE forecasts TE load growth for both light-duty and non-light-duty EV load.

Once the EV population is forecasted for each year, SCE calculates the total annual

energy by multiplying the number of forecasted EVs by the average KWh usage per

vehicle. Then, SCE establishes its EV charging load shape based on multiple factors,

such as exiting customer EV charging behavior, future flexible charging programs, TOU

rate structure, and duration of charging. Next, SCE applies EV charging load shapes to

the total annual EV energy to derive the hourly EV load forecast.

V2G EVs can serve different purposes compared to load-only EVs. For example,

V2G EVs can be used for shifting customer hourly demand and as a storage system. To

forecast V2G EV load based on the current EV forecasting process SCE described above,

the utilities will need to take into account a variety of factors, including policies,

technologies, market readiness, program participation, and customer rate structure, etc.

The IOUs will need to estimate the impacts that V2G capabilities may bring, and this

assessment is complex given uncertainty with market availability of V2G-capable

2 See US Department of Energy, Office of Scientific and Technical Information, available at https://www.osti.gov/servlets/purl/1171813.

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vehicles as a portion of total EV population and the aggregated EV load shapes given the

different purposes V2G EVs will serve.

V.

CYBERSECURITY (SECTION 8.2)

7. Are any cybersecurity standards beyond those described in the Transportation

Electrification Framework available to be deployed by IOU transportation

electrification (TE) infrastructure programs now?

SCE is partnering with the United States Department of Energy (DOE) on TE

infrastructure issues and standards, primarily through its membership in US DRIVE and its Grid

Integration Technical Team (GITT), and through a DOE-funded project on EV charging

cybersecurity. This project is one of three funded under DOE’s Funding Opportunity

Announcement 1919 that GITT is tracking. GITT intends to use these projects to develop or

recommend a standard scoring method for EV charging stations or certification scope that could

be used broadly in industry to attain some certainty of protection, similar to how UL safety

certification is used to assure safety levels of products today. As of now, no such cybersecurity

certification standard exists. In the meantime, SCE maintains technical requirements for EV

supply equipment in its Charge Ready program referring to National Institute of Standards and

Technology (NIST) and other cybersecurity practices and then relies on suppliers to meet those

requirements.

8. Do the existing cybersecurity standards leave any gaps? If so, how should the IOUs

endeavor to fill those gaps?

As noted above, the lack of a standard, a clear product label aligned with verifiable

cybersecurity certification for EVSE and related network controls remains a gap. Recent events

studied by the DOE teams, including privately and publicly funded hacking sessions have

exposed various levels of vulnerability. Some of these vulnerabilities have been or are being

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addressed by manufacturers and service providers, but enough uncertainty remains to warrant

continued effort. To help fill the gaps, experts with the national labs and research organizations

are helping design new physical and control architectures. For example, one DOE project that

SCE participates in has designed a secure network hardware interface. A new standard or

scoring system may require such new elements. Another effort, involving a nationwide

consortium of utility and other interests, is looking at establishing an EV charging equipment

qualification program. This type of independent program could provide a private, yet publicly

useful, standard rating system for EV charging cybersecurity performance in addition to safety,

function, and reliability. Strictly on the communication side, SCE focuses on IEEE 2030.5 for

DERs, and continues to be involved in the validation of that protocol and associated systems

through various avenues, including its EPIC demonstration projects.

9. Are any new, more effective cybersecurity standards under development?

As described above, SCE is involved with DOE in developing EV charging cybersecurity

standards. In addition, SCE is a member of EPRI’s Electric Vehicle Infrastructure Cybersecurity

Working Group (EVICWG), which brings together utility and industry experts to identify and act

on EV charging cybersecurity measures.

a) If so, when are the new standards expected to be adopted and available for

deployment?

It is not known when any new standard would be deployed, but it would

likely take several years to complete the process and have compliant products on

the market.

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b) Would the standards currently under development leave any remaining

gaps? If so, what is the best process to address those remaining gaps?

In cybersecurity, it is not considered possible to have an invulnerable

system, so SCE will continue to be involved with the organizations and activities

cited above.

VI.

ELECTRIC VEHICLE SUPPLY EQUIPMENT INTERCONNECTION (SECTION 8.3)

2. Should the CPUC direct the IOUs to meet specific connection deadlines or establish

clearer timeframes for electric vehicle supply equipment (EVSE) application and

energization processes?

The IOUs should ensure there is a clear and efficient processes to facilitate connection

and energization of an EVSE. For example, SCE developed a written process with sequential

steps that need to be followed for connection to the distribution system, which are appropriate for

customers who apply for support through a TE program or a standard customer-requested

connection. While the IOUs have direct control over some aspects of the process, timelines are

also influenced by the needs and responsiveness of the customer and the authority having

jurisdiction (AHJ). Mandating specific deadlines would be counterproductive, due to the

variability of project size, scope, AHJ permitting requirements, utility distribution upgrades,

customer engineering and design process timing, construction complexity, and other unknown

variables specific to each individual project.

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3. Should EVSE connection and application timelines be tiered based on the type of

upgrade required and/or the size of the incremental load?

All new service requests, regardless of size and scope, should be addressed equally and

processed by the IOUs via clearly documented process flows. Based on published sequential

steps, the service connection applicant should know where their project lies in the process flow.

6. What data is needed to determine whether utility distribution and service

connection costs for commercial electric vehicle charging infrastructure should be

treated as common costs for all ratepayers?

SCE supports further exploration of this issue to ensure that costs on the utility side of the

meter for non-residential electric vehicle customers are not a barrier to adoption. To facilitate

this exploration, SCE recommends that this issue be addressed within a Commission workshop.

Options that can be considered in that workshop include new tariffs or rules that would allow

IOUs to design, install, and maintain electrical infrastructure and perform associated work on the

utility side of the meter for all non-residential electric vehicle customers, and treat those costs as

common costs borne by all ratepayers. SCE anticipates that the process would likely examine

cost data related to EV infrastructure upgrades, including information available within various

IOU TE reports, such as the EV Charging Infrastructure Cost Report.

7. What data should be regularly reported by the IOUs to provide third-party EVSE

installers and site hosts information needed to assess projected installation costs?

Project installation costs are directly correlated to the deployment location, size, and

scope of the proposed project. Site conditions, including but not limited to existing distribution

facilities, existing customer facilities, AHJ requirements, and surface material of the intended

deployment location, will affect the project costs. Providing “average” cost information will

likely result in customer confusion and dissatisfaction. Thus, the IOUs should not be required to

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provide third-party EVSE installers and site hosts with cost data that does not reflect the specific

project requests from customers.

a) Should the EVSE installation data be incorporated in the existing IOU

interconnection reports or provided separately?

The Commission should consider establishing a separate report for EVSE

installation data that could be populated by both the IOUs and third-party providers.

EVSE installation data should not be included within the IOUs’ interconnection reports,

as the IOUs do not have data for all EVSE installations. Rather each IOU could provide

information separately on the known EVSEs installed within the IOU’s jurisdiction, such

as for the EVSEs installed as part of the IOU’s TE programs.

b) Should the data for IOU transportation electrification (TE) programs be

directly compared to EVSE installations not participating in the IOU TE

programs?

While SCE believes that greater transparency of EVSE installation costs—both in

and out of IOU TE programs—can help identify efficiencies and best practices, SCE does

not think that direct comparisons will yield valid or useful results. A complete picture of

costs for EVSE installations by customers not participating in IOU TE programs—

including costs covered by grants, incentives and IOU Rule 15/16 allowances—is not

currently available nor is it mandated as part of the State’s infrastructure incentive

programs, such as CALeVIP. Further, even if such cost data were available, simple cost

comparisons could fail to capture key differences in the objectives and policies of IOU

TE programs and other installations. While IOU programs seek to “minimize overall

costs and maximize overall benefits,” the programs also seek to support equity and

expand access in all communities and across use cases. Some EVSE installations outside

of IOU programs might share these objectives, but many will be focused on other

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business objectives including finding the lowest-cost sites that support their business

objectives.

VII.

EMERGING TECHNOLOGY (SECTION 8.5)

10. What additional evaluation would be necessary to determine whether a program

similar to the existing energy efficiency Emerging Technology Program is necessary

for TE and what the scope of such a program could be?

The Commission should consider adopting a program for TE similar to the Emerging

Markets and Technology (EMT) program under Demand Response rather than the Energy

Efficiency Emerging Technology Program (ET). While both programs cover developing

technologies, EMT also provides for research, with a focus on developing emerging markets.

The information gathered from market research is directly used for the development of programs

that will accelerate transportation electrification. For example, through the EMT program, SCE

developed and tested market acceptance for customers to participate in a smart thermostat

demand response program. Emerging market research allowed SCE to optimize incentive values

to maximize both the number of participating customers and cost effectiveness. This resulted in

a program ready to be immediately implemented and is currently one of the largest demand

response programs that leverages customer-owned thermostats in the country. Including market

research will allow SCE to keep up with advances in TE technology and offer programs to

leverage new technology in a timely manner to benefit the marketplace, customers, and the

utility.

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11. Are the type of activities addressed by the energy efficiency Emerging Technology

Programs currently addressed by other organization(s) for TE charging

technologies?

SCE does not currently have an authorized program or funding mechanism to support TE

charging technology research and development activities, similar to those addressed by the ET

programs. Rather, SCE relies on external entities such the CEC (through its EPIC program) and

the DOE to gain access to grants through competition to fund needed TE research. However, the

grant application process is unlikely to provide funding in a timely manner to enable SCE or its

TE programs to keep up with TE technology development.

12. Is it an appropriate IOU role to create an emerging technology program for TE and

leverage existing energy efficiency Emerging Technology Programs experience?

Why or why not? If not, is there any other role IOUs should play in identifying

emerging technology that may be needed for future TE programs?

Yes, developing an EMT program is appropriate as it helps the IOUs keep up with the

fast pace of TE technology development. An EMT program would support expedited

development of new programs and services for the TE marketplace. Relying on state and federal

government grant applications does not guarantee funding or ensure timely disbursement of

awarded funds. An EMT program would not only allow the utility to quickly demonstrate, test,

and bring into the market new programs, but it also would fill the gap that exists with EPIC and

DOE grants that target only technology development and not market development.

VIII.

CONCLUSION

SCE appreciates the opportunity to provide these comments to the Commission.

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Respectfully submitted, ANNA VALDBERG ANDREA TOZER

/s/ Andrea Tozer By: Andrea Tozer

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6713 Facsimile: (626) 302-6693 E-mail: [email protected]

July 14, 2020


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 SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON SAFETY, TECHNOLOGY, AND STANDARDS on all parties identified on the attached service list R.18-12-006. 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 the copies in sealed envelopes and causing such envelopes to be delivered via US Mail to the offices of the ALJ(s) or other addressee(s).

ALJ Patrick Doherty California Public Utilities Commission 505 Van Ness Ave. San Francisco, CA 94102

ALJ Sasha Goldberg California Public Utilities Commission 505 Van Ness Ave. San Francisco, CA 94102

Executed this July 14, 2020, at Rosemead, California.

/s/ Karen Abarca________________ Karen Abarca SOUTHERN CALIFORNIA EDISON COMPANY

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

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JAMIE HALL JOHN BOESEL ADVANCED VEHICLE AND INFRASTRUCTURE CALSTART GENERAL MOTORS, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: CALSTART FOR: GENERAL MOTORS, LLC

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CLAY FABER E. GREGORY BARNES DIR. CA & FEDERAL REGULATORY ATTORNEY SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 8330 CENTURY PARK CT., CP32 SAN DIEGO, CA 92123 SAN DIEGO, CA 92123 FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY (SDG&E)

ARAVIND KAILAS, PH.D. EMANUEL WAGNER DIR - ADVANCED TECHNOLOGY POLICY DEPUTY DIR VOLVO GROUP NORTH AMERICA CALIFORNIA HYDROGEN BUSINESS COUNCIL 575 ANTON BLVD, STE 860 18847 VIA SERENO COSTA MESA, CA 92626 YORBA LINDA, CA 92866 FOR: VOLVO GROUP NORTH AMERICA FOR: CALIFORNIA HYDROGEN BUSINESS COUNCIL

MICHAEL CHIACOS SIMON LONSDALE DIR - ENERGY PROGRAMS CO-FOUNDER, SALE & STRATEGY COMMUNITY ENVIRONMENTAL COUNCIL AMPLY POWER, INC. 26 W. ANAPAMU ST., 2ND FLR. 335 E. MIDDLEFIELD ROAD SANTA BARBARA, CA 93101 MOUNTAIN VIEW, CA 94043 FOR: COMMUNITY ENVIRONMENTAL COUNCIL FOR: AMPLY POWER, INC.

JEREMY WAEN DAVID SCHLOSBERG MGR. - REGULATORY AFFAIRS VP - ENERGY MARKET OPERATIONS PENINSULA CLEAN ENERGY ENEL X NORTH AMERICA, INC. 2075 WOODSIDE RD. 846 BRANSTEN ROAD REDWOOD CITY, CA 94061 SAN CARLOS, CA 94070 FOR: PENINSULA CLEAN ENERGY FOR: ENEL X NORTH AMERICA, INC. (FORMERLY ELECTRIC MOTOR WERKS, INC.)

RACHAEL E. KOSS HILARY STAVER ATTORNEY MGR - REGULATORY & LEGISLATIVE AFFAIRS ADAMS BROADWELL JOSEPH & CARDOZO SILICON VALLEY CLEAN ENERGY AUTHORITY 601 GATEWAY BLVD., SUITE 1000 333 W. EL CAMINO REAL, STE. 290 SOUTH SAN FRANCISCO, CA 94080 SUNNYVALE, CA 94087 FOR: COALITION OF CALIFORNIA UTILITY FOR: SILICON VALLEY CLEAN ENERGY EMPLOYEES AUTHORITY (SVCE)



WILLIAM K. SANDERS CANDICE PLOTKIN DEPUTY CITY ATTORNEY LEAD COUNSEL, REGULATORY CITY AND COUNTY OF SAN FRANCISCO CRUISE LLC CITY HALL RM 234 1201 BRYANT STREET 1 DR. CARLTON B. GOODLETT PLACE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-4682 FOR: CRUISE LLC FOR: CITY AND COUNTY OF SAN FRANCISCO

ELISE TORRES JANE Y. LEE STAFF ATTORNEY ATTORNEY THE UTILITY REFORM NETWORK UBER TECHNOLOGIES, INC. 785 MARKET STREET, SUITE 1400 1455 MARKET STREET, 4TH FL. SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94103 FOR: THE UTILITY REFORM NETWORK (â€œTURNâ€ ) FOR: UBER TECHNOLOGIES, INC.

MEGHA LAKHCHAURA JENNIFER L. WEBERSKI EVBOX INC LITIGATION SUPERVISOR 845 MARKET ST., STE 450A, LEVEL 4 SMALL BUSINESS UTILITY ADVOCATES SAN FRANCISCO, CA 94103 548 MARKET STREET, SUITE 11200 FOR: EVBOX SAN FRANCISCO, CA 94104 FOR: SMALL BUSINESS UTILITY ADVOCATES

PETER OKUROWSKI CHRISTOPHER J. WARNER PRINCIPAL ATTORNEY CEA CONSULTING PACIFIC GAS AND ELECTRIC COMPANY 235 MONTGOMERY STREET, SUITE 950 77 BEALE STREET, B30A / PO BOX 7442 SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94105 FOR: BNSF RAILWAY FOR: PACIFIC GAS AND ELECTRIC COMPANY

LARISSA KOEHLER NORA SHERIFF SENIOR ATTORNEY ATTORNEY ENVIRONMENTAL DEFENSE FUND BUCHALTER, A PROFESSIONAL CORPORATION 123 MISSION STREET, 28TH FL. 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: ENVIRONMENTAL DEFENSE FUND FOR: ENERGY PRODUCERS AND USERS COALITION

NORA SHERIFF, ESQ. MICHAEL B. DAY ATTORNEY ATTORNEY BUCHALTER, A PROFESSIONAL CORPORATION GOODIN, MACBRIDE, SQUERI, & DAY, LLP 55 SECOND STREET, SUITE 1700 505 SANSOME STREET, STE 900 SAN FRANCISCO, CA 94105-3493 SAN FRANCISCO, CA 94111-3133 FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: EVGO SERVICES LLC ASSOCIATION (CLECA)

STEVEN MOSS RACHELLE CHONG PARTNER COUNSEL M.CUBED LAW OFFICES OF RACHELLE CHONG 296 LIBERTY STREET 345 W. PORTAL AVENUE, STE. 110. SAN FRANCISCO, CA 94114 SAN FRANCISCO, CA 94127 FOR: LOCAL GOVERNMENT SUSTAINABLE FOR: LYFT, INC. ENERGY COALITION

CHRIS KING FRANCESCA WAHL



PRESIDENT SR. POLICY ADVISOR SIEMENS SMART GRID SOLUTIONS TESLA, INC. 4000 E. 3RD AVE., STE. 400 6800 DUMBARTON CIRCLE FOSTER CITY, CA 94404-4827 FREMONT, CA 94555 FOR: EMETER, A SIEMENS BUSINESS FOR: TESLA, INC.

HOWARD V. GOLUB STEVE CAMPBELL ATTORNEY MGR - POLICY & BUS. DEVELOP BEST BEST & KRIEGER LLP GRID ALTERNATIVES 2001 NORTH MAIN STREET, STE. 390 1171 OCEAN AVE SUITE 200 WALNUT CREEK, CA 94596 OAKLAND, CA 94608 FOR: CITY OF LONG BEACH CALIFORNIA, A FOR: GRID ALTERNATIVES MUNICIPAL CORPORATION, ACTING BY AND THROUGH ITS BOARD OF HARBOR COMMISSIONERS

MELISSA BRANDT ALEX J. MORRIS SR. DIR & DEPUTY GEN COUNSEL EXE. DIR. EAST BAY COMMUNITY ENERGY CALIFORNIA ENERGY STORAGE ALLIANCE 1999 HARRISON ST., STE. 800 2150 ALLSTON WAY, STE.400 OAKLAND, CA 94612 BERKELEY, CA 94704 FOR: EAST BAY COMMUNITY ENERGY (EBCE) FOR: CALIFORNIA ENERGY STORAGE ALLIANCE (CESA)

EDWARD BURGESS GREGORY MORRIS POLICY DIRECTOR DIRECTOR VEHICLE-GRID INTEGRATION COUNCIL GREEN POWER INSTITUTE 2150 ALLSTON WAY, SUITE 400 2039 SHATTUCK AVENUE, STE 402 BERKELEY, CA 94704 BERKELEY, CA 94704 FOR: VEHICLE-GRID INTEGRATION COUNCIL FOR: GREEN POWER INSTITUTE

LESLIE AGUAYO SHALINI SWAROOP MGR - PROGRAM - ENVIRONMENTAL REGULATORY & LEGISLATIVE COUNSEL THE GREENLINING INSTITUTE MARIN CLEAN ENERGY EMAIL ONLY 1125 TAMALPAIS AVENUE EMAIL ONLY, CA 94704 SAN RAFAEL, CA 94901 FOR: THE GREENLINING INSTITUTE FOR: MARIN CLEAN ENERGY

MAHLON ALDRIDGE HEIDI SICKLER VP - STRATEGY DIR - ENERGY AND ENVIRONMENT ECOLOGY ACTION SILICON VALLEY LEADERSHIP GROUP 877 CEDAR STREET, SUITE 240 2001 GATEWAY PLACE, SUITE 101E SANTA CRUZ, CA 95060 SAN JOSE, CA 95110 FOR: ECOLOGY ACTION FOR: SILICON VALLEY LEADERSHIP GROUP

STEVEN S. SHUPE WILLIAM H. WEAVER GENERAL COUNSEL SENIOR COUNSEL SONOMA CLEAN POWER AUTHORITY CALIFORNIA INDEPENDENT SYSTEM OPERATOR 50 SANTA ROSA AVE., 5TH FL. 250 OUTCROPPING WAY SANTA ROSA, CA 95404 FOLSOM, CA 95630 FOR: SONOMA CLEAN POWER AUTHORITY FOR: CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION (CAISO)

BRITTANY ILES LAURA FERNANDEZ ATTORNEY ATTORNEY



BRAUN BLAISING SMITH WYNNE, P.C. BRAUN BLAISING SMITH WYNNE, P.C. 915 L STREET, STE. 1480 555 CAPITOL MALL, SUITE 570 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: MONTEREY BAY COMMUNITY POWER FOR: CITY OF SAN JOSÃ‰

LAURA FERNANDEZ LAURA FERNANDEZ ATTORNEY ATTORNEY BRAUN BLAISING SMITH WYNNE, P.C. BRAUN BLAISING SMITH WYNNE, P.C. 555 CAPITOL MALL, STE. 570 915 L STREET, STE 1480 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: REDWOOD COAST ENERGY AUTHORITY FOR: CALIFORNIA CHOICE ENERGY AUTHORITY

MICHAEL PIMENTEL TOVAH TRIMMING LEGISLATIVE / REGULATORY ADVOCATE CALIF PUBLIC UTILITIES COMMISSION CALIFORNIA TRANSIT ASSOCIATION LEGAL DIVISION 1415 L STREET 300 Capitol Mall SACRAMENTO, CA 95814 Sacramento, CA 95814 FOR: CALIFORNIA TRANSIT ASSOCIATION FOR: PUBLIC ADVOCATES OFFICE

LYNN M. HAUG JOY MASTACHE ELLISON SCHNEIDER HARRIS & DONLAN LLP SR. ATTORNEY - OFF. OF GEN. COUNSEL 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO MUNICIPAL UTILITY DISTRICT SACRAMENTO, CA 95816 6201 S STREET, MS B406 FOR: CHARGEPOINT, INC. SACRAMENTO, CA 95817 FOR: SACRAMENTO MUNICIPAL UTILITY DISTRICT

DANIEL MARSH ROBERT D. SWEETIN MGR - RATES & REGULATORY AFFAIRS ATTORNEY LIBERTY UTILITIES (CALPECO ELECTRIC) LLC DAVISON VAN CLEVE, P.C. 933 ELOISE AVENUE 1750 SW HARBOR WAY, SUITE 450 SOUTH LAKE TAHOE, CA 96150 PORTLAND, OR 97201 FOR: LIBERTY UTILITIES (CALPECO FOR: ELECTRIFY AMERICA, LLC ELECTRIC) LLC

SEAN WATERS AJAY KUMAR DAIMLER TRUCKS NORTH AMERICA LLC ATTORNEY 4555 N CHANNEL AVE. PACIFICORP PORTLAND, OR 97217 825 NE MULTMOMAH STREET, STE. 1800 FOR: DAIMLER TRUCKS NORTH AMERICA LLC PORTLAND, OR 97232 FOR: PACIFICORP

PHILIP B. JONES EXE. DIR. ALLIANCE FOR TRANSPORT ELECTRIFICATION 1402 THIRD AVE., STE. 1315 SEATTLE, WA 98101 FOR: ALLIANCE FOR TRANSPORTATION ELECTRIFICATION

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AARON N. LU BO YANG SAN DIEGO GAS & ELECTRIC COMPANY AIR RESOURCES ENGINEER



EMAIL ONLY CALIFORNIA AIR RESOURCES BOARD EMAIL ONLY, CA 00000 MOBILE SOURCE CONTROL DIVISION EMAIL ONLY EMAIL ONLY, CA 00000

BONNIE DATTA BONNIE DATTA SR. DIR - AMERICAS & ASIA PACIFIC PLUG TO GRID STRATEGIES SIEMENS EMAIL ONLY EMAIL ONLY EMAIL ONLY, AA 00000 EMAIL ONLY, CA 00000

CAMILLE STOUGH ERIK ELLIS ASSOCIATE PRINCIPAL / FOUNDER ADAMS BROADWELL JOSEPH & CARDOZO GREEN MACHINE POWER, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

GERHARD ACHTELIK JANA KOPYCIOK-LANDE CALIFORNIA AIR RESOURCES BOARD SR. POLICY ANALYST EMAIL ONLY MARIN CLEAN ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

JENNIFER LEE JOHN BOWIE CALIFORNIA AIR RESOURCES BOARD KEARNS & WEST, INC. MOBILE SOURCE CONTROL DIVISION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

KATHERINE GARRISON KATHY PENICHE CALIFORNIA AIR RESOURCES BOARD CASE MGR - REGULATORY ADVANCED CLEAN CARS BRANCH SAN DIEGO GAS & ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

KINSHUK CHATTERJEE LEE KREVAT TRANSPORTATION POLICY ANALYST CO-FOUNDER AND CSO CENTER FOR SUSTAINABLE ENERGY CONNECT CALIFORNIA LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MARISSA WILLIAMS MATT ALEXANDER AIR POLLUTION SPECIALIST / ECARS CALIFORNIA ENERGY COMMISSION CALIFORNIA AIR RESOURCES BOARD EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

PHILLIP KOBERNICK RICHARD SCHORSKE PROGRAM MANAGER EXECUTIVE DIRECTOR PENINSULA CLEAN ENERGY ZNE ALLIANCE EV ALLIANCE EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000



ROSS GREEN SAMANTHA WEAVER ASSOCIATE PRINCIPAL REGULATORY ANALYST KEARNS & WEST, INC EAST BAY COMMUNITY ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MRW & ASSOCIATES, LLC TAM HUNT, J. D. EMAIL ONLY CONSULTING ATTORNEY EMAIL ONLY, CA 00000 COMMUNITY RENEWABLES SOLUTIONS, LLC EMAIL ONLY EMAIL ONLY, CA 00000-0000 FOR: GREEN POWER INSTITUTE

PAUL CHERNICK COLLEEN QUINN PRESIDENT EMOBILITY ADVISORS RESOURCE INSIGHT 5 RENFREW PARK 5 WATER ST. MIDDLETOWN, RI 02842 ARLINGTON, MA 02476

CATHERINE WILMARTH HOLMES HUMMEL ATTORNEY CLEAN ENERGY WORKS ALLIANCE FOR AUTOMOTIVE INNOVATION 925 FRENCH STREET NW 1050 K STREET NW, SUITE 650 WASHINGTON, DC 20001 WASHINGTON, DC 20001

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DAVID APPELBAUM JIGAR J. SHAH SENIOR COUNSEL MGR - ENERGY & GRID SERVICES ELECTRIFY AMERICA, LLC ELECTRIFY AMERICA 2003 EDMUND HALLEY DR., 2ND FL STE 200 2003 EDMUND HALLEY DR., 2ND FL, STE 200 RESTON, VA 20191 RESTON, VA 20191

KAY DAVOODI LARRY ALLEN FEDERAL EXECUTIVE AGENCIES UTILITY RATES & STUDIES OFFICE 1322 PATTERSON AVE SE, SUITE 1000 UNITED STATES NAVY / FED EXE. AGENCIES WASHINGTON NAVY YARD, DC 20374-5065 1322 PATTERSON AVE SE SUITE 1000 WASHINGTON NAVY YARD, CA 20374-5065 FOR: FEDERAL EXECUTIVE AGENCIES (FEA)

MAKDA SOLOMON SASHA GOLDBERG UTILITY RATES & STUDIES OFFICE CALIF PUBLIC UTILITIES COMMISSION UNITED STATES NAVY ADMINISTRATIVE LAW JUDGE DIVISION 1322 PATTERSON AVE SE BLDG 33, STE. 1000 320 West 4th Street Suite 500 WASHINGTON NAVY YARD, DC 20374-5065 Los Angeles, CA 90013 FOR: FEDERAL EXECUTIVE AGENCIES (FEA)



SULEKHA CHATTOPADHYAY ADRIANO MARTINEZ CALIF PUBLIC UTILITIES COMMISSION ATTORNEY AT LAW PROCUREMENT STRATEGY AND OVERSIGHT BRANC EARTHJUSTICE 320 West 4th Street Suite 500 800 WILSHIRE BLVD., SUITE 1000 Los Angeles, CA 90013 LOS ANGELES, CA 90017 FOR: CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE; EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

BREA CHILDS KATHERINE HOFF LITIGATION ASSISTANT CENTER FOR BIOLOGICAL DIVERSITY EARTHJUSTICE 660 S. FIGUEROA ST., STE. 1000 800 WILSHIRE BLVD., SUITE 1000 LOS ANGELES, CA 90017 LOS ANGELES, CA 90017 FOR: CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE; EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

SASAN SAADAT ERICK KARLEN EARTHJUSTICE POLICY ADVISOR 800 WILSHIRE BLVD., STE. 1000 GREENLOTS LOS ANGELES, CA 90017 767 S. ALAMEDA STREET, SUITE 200 FOR: CENTER FOR COMMUNITY ACTION AND LOS ANGELES, CA 90021 ENVIRONMENTAL JUSTICE; EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

JAY FRIEDLAND SARA RAFALSON PLUG IN AMERICA DIRECTOR, MARKET DEVELOPMENT 6380 WILSHIRE BLVD., STE. 1000 EVGO LOS ANGELES, CA 90048 11390 W. OLYMPIC BLVD., SUITE 250 LOS ANGELES, CA 90064

ANNMARIE LETT ALEXANDER KEROS COORDINATOR - RATES & REG AFFAIRS ADVANCED VEHICLE & INFRASTRUCTURE POLICY LIBERTY UTILITIES (CALIFORNIA) GENERAL MOTORS, LLC 9750 WASHBURN ROAD 3050 LOMITA BLVD. DOWNEY, CA 90241 TORRANCE, CA 90505 FOR: GENERAL MOTORS, LLC

CASE ADMINISTRATION LEGAL ADMIN SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. / PO BOX 800 2244 WALNUT GROVE AVE. / PO BOX 800 ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

LISA MAU MELODEE BLACK REGULATORY REGULATORY AFFAIRS ADVISOR SOUTHERN CALIFORNIA EDISON SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. 2244 WALNUT GROVE AVE. ROSEMEAD, CA 91773 ROSEMEAD, CA 91773

NGUYEN QUAN JOSH GERBER REGULATORY AFFAIRS FOUNDER & PRINCIPAL GOLDEN STATE WATER COMPANY 33 NORTH ENERGY LLC 630 EAST FOOTHILL BLVD. 661 MELBA ROAD SAN DIMAS, CA 91773 ENCINITAS, CA 92024



CHRISTINE BEVILACQUA DONALD C. LIDDELL LEGAL ASSIST. ATTORNEY AT LAW TOSDAL, APC DOUGLASS & LIDDELL 777 S. COAST HIGHWAY 101, STE. 215 2928 2ND AVENUE SOLANA BEACH, CA 92075 SAN DIEGO, CA 92103

COURTNEY COOK JANE KRIKORIAN, J.D. PARALEGAL / OFFICE ADMIN. SUPERVISOR, ADV. & ADMIN. UTILITY CONSUMERS' ACTION NETWORK UTILITY CONSUMERS' ACTION NETWORK 3405 KENYON STREET, SUITE 401 3405 KENYON STREET, STE. 401 SAN DIEGO, CA 92110 SAN DIEGO, CA 92110 FOR: UTILITY CONSUMERS' ACTION NETWORK (UCAN)

JOHN W. LESLIE, ESQ. CHRISTA M. LIM ATTORNEY REGULATORY CASE MGR. DENTONS US LLP SAN DIEGO GAS & ELECTRIC COMPANY 4655 EXECUTIVE DRIVE, SUITE 700 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92121 SAN DIEGO, CA 92123

JOHN A. PACHECO ROSS R. FULTON COUNSEL SENIOR COUNSEL SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT., CP32D 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92123 SAN DIEGO, CA 92123 FOR: SAN DIEGO GAS & ELECTRIC COMPANY

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DEAN A. KINPORTS STEPHEN KEEHN REGULATORY CASE ADMINISTRATOR MGR OF ENERGY REG & LEGISLATIVE AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY MONTEREY BAY COMMUNITY POWER 8330 CENTURY PARK CT., CP32D 70 GARDEN COURT, SUITE 300 SAN DIEGO, CA 92123-1530 MONTEREY, CA 93940

MARC MONBOUQUETTE MARC D JOSEPH SR.MGR - REG & GOV'T AFFAIRS ATTORNEY ENEL X NORTH AMERICA, INC. ADAMS BROADWELL JOSEPH & CARDOZO 846 BRANSTEN ROAD 601 GATEWAY BLVD., STE. 1000 SAN CARLOS, CA 94070 SO. SAN FRANCISCO, CA 94080 FOR: ENEL X NORTH AMERICA, INC. FOR: COALITION OF CALIFORNIA UTILITY (FORMERLY EMOTORWERKS) EMPLOYEES (CCUE)

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SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: PUBLIC ADVOCATES OFFICE

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YULIYA SHMIDT DAVID RUBIN CALIF PUBLIC UTILITIES COMMISSION CRUISE LLC COMMISSIONER RECHTSCHAFFEN 1201 BRYANT STREET ROOM 4209 SAN FRANCISCO, CA 94103 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

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STEPHANIE KUHLMAN TRACY CHEUNG PARALEGAL, REGULATORY CRUISE LLC



UBER TECHNOLOGIES, INC. 1201 BRYANT ST 1455 MARKET STREET, 4TH FL. SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94103

ITZEL BERRIO HAYWARD JAMES FALINO ATTORNEY - REGULATORY CEA CONSULTING SMALL BUSINESS UTILITY ADVOCATES 235 MONTGOMERY ST., STE. 950, 548 MARKT STREET, STE. 11200 SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104

JAMES M. BIRKELUND JULIA KANTOR PRESIDENT ATTORNEY SMALL BUSINESS UTILITY ADVOCATES KEYES & FOX LLP 548 MARKET STREET, STE. 11200 580 CALIFORNIA STREET, 12TH FL. SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104

MILES MULLER CATHERINE BUCKLEY ATTORNEY REGULATORY AFFAIRS NATURAL RESOURCES DEFENSE COUNCIL PACIFIC GAS AND ELECTRIC COMPANY 111 SUTTER STREET, 21ST FL. 77 BEALE STREET, B10A SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94105

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PATRICK HENNIGAN KARI CAMERON PACIFIC GAS AND ELECTRIC COMPANY LEGAL ADMIN. 77 BEALE STREET, MC B9A BUCHALTER SAN FRANCISCO, CA 94105 55 SECOND STREET, STE. 1700 SAN FRANCISCO, CA 94105-3493

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R1812006-SCE OPENING COMMENTS ON SAFETY ......and Infrastructure for Vehicle Electrification....

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