STATE OF CALIFORNIA · No, distribution automation must be safeguarded for security in order to...

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) COMMENTS ON

ADMINISTRATIVE LAW JUDGE’S RULING DIRECTING PACIFIC GAS AND

ELECTRIC COMPANY, SOUTHERN CALIFORNIA EDISON COMPANY, AND SAN

DIEGO GAS & ELECTRIC COMPANY TO RESPOND TO OUTSTANDING METER

QUESTIONS ON THE DEVELOPMENT OF A SUBMETERING PROTOCOL

ANNA VALDBERG ANDREA TOZER

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

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

Dated: February 12, 2020

1


STATE OF CALIFORNIA



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

ADMINISTRATIVE LAW JUDGE’S RULING DIRECTING PACIFIC GAS AND

ELECTRIC COMPANY, SOUTHERN CALIFORNIA EDISON COMPANY, AND SAN

DIEGO GAS & ELECTRIC COMPANY TO RESPOND TO OUTSTANDING METER

QUESTIONS ON THE DEVELOPMENT OF A SUBMETERING PROTOCOL

Pursuant to the Administrative Law Judge’s Ruling seeking party comments on questions

that are outstanding after a June 2019 workshop regarding development of a submetering

protocol for plug-in hybrid and plug-in electric vehicles (PEVs), Southern California Edison

Company (SCE) respectfully submits these responses to the questions in Attachments A and B.

I.

RESPONSES TO QUESTIONS IN ATTACHMENT A

Data Communication & Reliability

1. During the June 24, 2019, workshop, parties argued that the meter

data transfer process tested in the Plug-in Electric Vehicle (PEV)

submetering pilot is not a scalable path forward to communicate the meter

data recorded on the third-party submeter to the utility billing system. Do

you agree with this position? Why or why not?

2

SCE agrees. There are several reasons the process tested by SCE during the

submetering pilots (Pilots) is not scalable:

Submeter Accuracy: the (Meter Data Management Agent) MDMA

submeters used during the two Pilots were not calibrated and traceable

and, when tested by independent third parties at the conclusion of the

Phase 2 Pilot, did not meet utility revenue-grade meter requirements.

Submeters should be certified by an independent third-party lab to meet

utility revenue-grade meter accuracy requirements before being used for

billing purposes. In addition, appropriate quality control and testing

before and after submeter installation must be developed.

Submeter Differences: The submeters deployed by the three MDMAs

during Phase 1 and 2 were unique in design, performance, and software

used to collect and format the raw data to transmit to the investor-owned

utilities (IOUs). Independent lab submeter testing and more extensive

testing of each MDMA’s formatting software is necessary prior to

submeter deployment.

Customer Connectivity: Submeter data was uploaded to the MDMAs via

customers’ Wi-Fi. The reliability of Wi-Fi, provided by many different

companies, was another source of data unreliability impacting the ability

of the MDMAs to provide accurate and timely submeter data.

a. If yes, should the PEV Submetering Protocol adopt standards to align

the communication process between the third-party meters and the

utility billing system? What standards should be considered?

The PEV Submetering Protocol must adopt standards for uniform

communication processes between third-party meters and the IOUs’

billing systems, such as communication process standards used for IOU

billing meters. The Commission should require the following standards to

3

align communications between third-party meters and IOU billing

systems:

Standards:

ANSI C12.19 – Utility Industry End Device End Tables: This

standard defines a table structure for utility application data to be

passed between an end device (meter) and a computer (hand-held

device or meter communication module)

ANSI C12.22/IEEE Std 1703 – Protocol Specification for

Interfacing to Data Communication Networks: This Standard

describes communication of C12.19 tables over networks for the

purpose of interoperability among communications modules and

meters. Describes use of AES encryption to enable strong secure

communications and requirements for Advance Metering

Infrastructure (AMI) smart grids, Field Area Networks (FAN) and

Home/Premise Area Networks (HAN/PAN)

IEEE 1377 – IEEE Standard for Utility Industry Metering

Communication Protocol Application Layer (End Device Data

Tables)

IEC 61968 – Standards under development defining information

exchange between electrical distribution systems.

b. If no, are there steps that can be included in the PEV Submetering

Protocol to improve this process?

Not applicable.

2. Southern California Edison Company (SCE) and San Diego Gas & Electric

Company (SDG&E) were found to not have stored the PEV submeters raw

data sent over by the Meter Data Management Agent’s (MDMA) during the

PEV Submetering Phase II pilot, which prevented the utilities ability to

4

correct any meter data discrepancies. The Minnesota Public Utilities

Commission (MPUC) is requiring Xcel Energy store the raw meter data for

90-days for their PEV submetering pilot program14. Do you believe the PEV

Submetering Protocol should require the storage of raw meter data for a

predetermined period of time? Why or why not?

Yes, because it is a way to resolve a customer’s potential question about their bill

or potential data discrepancies between the IOU and the MDMA. However, it

should be noted that during the Phase 1 and 2 pilots, SCE stored the customer raw

submeter data for 39 months, the same number of days SCE stores all customers’

raw submeter data.

During the Phase 1 and 2 Pilots, the MDMAs could submit corrective submeter

data prior to three days after the end of the customer’s billing cycle. However, if

the MDMA submitted corrected data after that date, Schedule PEVSP Phase 2

(the governing tariff) did not require the IOUs to accept the corrected data and

rebill the customer due to the manual nature of the submeter billing process.

a. If yes, who should be responsible for storing and how long should the

raw meter data be stored?

SCE will continue to store all customer raw data, including submeter

data, for 39 months. MDMAs should also be directed to meet the same

storage requirement to facilitate any billing inquiries.

Who should bear responsibility to paying the costs to store this data?

SCE and any MDMA providing submeter services to SCE should be

responsible for their own costs to store the data.

How should these costs be recouped?

SCE recoups the cost of storing the raw meter data through its general

rate cases. SCE expresses no opinion on how MDMAs operate their

5

businesses or recover costs. However, ratepayers should not absorb the

cost of any inefficiencies for MDMAs to deliver data to the IOUs.

3. Pacific Gas and Electric Company’s (PG&E) Electric Program Investment

Charge (EPIC) 1.14 report discussed the use of the utility Smart Meter

Network or Distribution Automation (DA) Communication to relay a smart

device’s data to the utility billing system. The report’s conclusion was that

this option could potentially serve as a more efficient pathway to

communicate data from a device to the utility.

a. Is there an opportunity to use the DA Communication pathway to

relay the data from a PEV submeter to the utility billing network?

No, distribution automation must be safeguarded for security in order to

deliver safe and reliable control of the electrical distribution system.

Adding metering traffic to this system could compromise its security.

b. Will using the DA Communication pathway impact the accuracy or

quality of the data received by the utilities compared to the current

communication procedures used in the PEV submetering pilot?

Accuracy will not be affected by the transportation medium. Quality

impacts are unknown as the distribution system is designed to

communicate effectively with distribution equipment, which may not be

collocated within reception distance of individual service accounts.

Additionally, the physical (wired or wireless) interface must be designed

specifically for the distribution automation system, which is not designed

for mass market, low-cost technologies such as Wi-Fi. Thus, it may be

prohibitively expensive to use the distribution automation network.

6

4. Nexant’s evaluation report demonstrated that the customer’s Wi-Fi

connectivity could be a significant source for the data issues reported to the

Investor Owned Utilities (IOU).16 Do you agree with this position? Why

or why not?

SCE agrees with this position. As noted in the report, connectivity to the

submeters was not robust. Depending on the vendor and the product's customer

interface, the customer may not even be aware that its submeter was not

connected to its Wi-Fi system.

Additionally, several circumstances could adversely affect data integrity: the

location of the integrated submeter/charging system in relationship to the home

router (the submeter/EVSE is typically in the customer's garage and could be

quite a distance from the home router); the customer's home router may fail; the

customer may reconfigure the home network; the customer may cancel

broadband service.

a. Should the PEV Submetering Protocol pursue Wi-Fi as the pathway

to transmitting data from the PEV submeter to the IOU? Why or

why not?

No. Although Wi-Fi is a low-cost option for vendors by leveraging the

customer's broadband network, it can be unreliable. Thus, if Wi-Fi or a

similar type of network is used, vendors must have processes to monitor

and ensure connectivity at all times. Additionally, vendors must correct

data received prior to submitting it to the IOUs for billing. Because Wi-

Fi could still be a viable option for most customers, it could be

considered if robust MDMA data correction solutions are required and

enforced.

7

b. Should alternatives to WI-FI be pursued, such as the IOU’s Advance

Metering Infrastructure network or cellular connectivity? Why or

why not?

Yes. For third parties without Advanced Metering Infrastructure (AMI),

cellular connectivity using the upcoming 5G network promises to be low-

cost and reliable. However, this is an emerging technology and cost and

reliability must be evaluated prior to using this type of application.

The IOUs’ AMI is also a viable alternative if the devices are certified to

integrate with the IOUs’ AMI and pass all cybersecurity requirements.

This option would be most feasible for submeters owned by the IOUs. If

the devices are not owned by the IOU, third parties must compensate the

IOUs for the use of their network and back office systems.

c. Is there another preferable pathway available to transmit the PEV

submeter data to the IOUs?

No, not without additional buildout of network infrastructure to support

connectivity to the last mile of communications. There are several

emerging last-mile Wide Area Network (WAN) technologies. One

technology that is gaining traction in the marketplace is Long Range

(LoRa). However, the physical layer of this technology is proprietary,

and gateways must be placed to a traditional broadband interface within

the Radio Frequency range of the device to connect it to the cloud.

Another technology is IEEE 802.11ah, which is a long-range variation of

Wi-Fi operating in the 900Mhz band. However, like LoRa, gateways

must be deployed to gather the information broadcasted and delivered to

the cloud. Finally, HomePlug is a wired solution that doesn't need

infrastructure build out since it connects directly to the customer's router.

8

Thus interference, distance, or password issues are minimized. However,

HomePlug still suffers from the risk that customers will reconfigure their

network or discontinue service in favor of going mobile for internet

service and requires more hardware to deploy, which makes the option

more expensive.

As mentioned in response to Question 4.a, these solutions require robust

MDMA processes to ensure data integrity prior to submitting data to the

utility for billing purposes.

d. What are the benefits and limitations of each of the above

communication options?

Please see the benefits and limitations of the communications options in

the sections above.

5. The SmartPole Demonstration project in PG&E’s EPIC 1.1417 report

sought to find a pathway to meter municipal streetlight equipment that

previously required either a flat rate, no rate at all, or the installation of a

separate utility-grade meter at each light pole. The conclusion of the report

suggests the use of a utility-grade smart meter to perform as a submetering

which offers a successful and scalable metering option compared to the

installation of a separate meter for billing purposes.

a. Is the technology tested in this program is a viable alternative to

third party submetering? Why or why not?

Since the PG&E SmartPole Demonstration project uses a certified utility

revenue-grade meter, which is also certified to use the utility's AMI for

backhaul, it appears to be a viable alternative to third-party submetering.

b. Are there any learnings from this program that can inform the

development of the PEV Submetering Protocol?

9

Since the use case for the SmartPole functions as a primary meter and not

a submeter, the learnings would be limited to the robustness of the

metering hardware demonstrated in the field.

PEV Submetering Equipment Accuracy

6. Some parties argued at the June 24, 2019 workshop that the current state of

third-party submetering equipment can meet the 2% field testing and 1%

laboratory testing meter accuracy threshold requirements18, however,

there was agreement that it will be difficult to meet the current California

Independent System Operator (CAISO) and IOU required 0.2% accuracy

threshold for revenue grade meters. Do you agree with this statement?

Why or why not?

Yes, SCE agrees with this statement and per Energy Division guidance focuses

its responses on the requirements for residential meters. Any commercial

submeters should meet the applicable requirements for revenue-grade

commercial meters. SCE currently tests its residential meters to 0.5% of

indicated value in the lab and repairs or replaces meters in the field that are

found to be over 1% off of the indicated value in order to meet the required 2%

field accuracy required by the CPUC-approved Direct Access Standards for

Metering and Meter Data (DASMMD). Threshold accuracy of 0.2% versus

0.5% represents a factor of 2.5. Maintaining the more stringent 0.2% accuracy

standard requires more expensive sensors and design in the meter, more precise

and expensive test and calibration equipment, more rigid manufacturing

processes and controls, different skill level and equipment to calibrate the meters

both during manufacture and in the field, and more effort to maintain field

accuracy because of metering drift due to environmental effect in the field.

10

a. Is meeting the CAISO and IOU 0.2% accuracy threshold important

for enabling PEV submetering? Why or why not?

No, 0.5% is adequate and mandated in the DASMMD for residential

revenue-grade meters.

b. If the PEV Submetering Protocol were to include the 1%-2%-meter

accuracy threshold for PEV submetering, will this decision be

beneficial or detrimental to advancing the adoption of PEV

submetering equipment?

It would be detrimental to deviate from the 0.5% accuracy requirement

for lab testing of residential revenue-grade meters as specified in the

DASMMD, which is an appropriate standard to ensure proper customer

billing.

c. Will a 1%-2%-meter accuracy threshold have policy implications for

other applications of the PEV submeter? If so, what applications

will be affected?

Yes, it is not consistent with the requirement in the DASMMD, which

sets our meter accuracy requirements. Doubling the inaccuracy of the

meter (0.5% to 1%) will cause additional effort in troubleshooting with

the main meter. Also, it will make maintaining an overall 2% accuracy

of meters in the field difficult due to meter reading drift over time. The

lab accuracy of 0.5% has proven to minimize the existence of non-

conforming meters in the field.

d. Should the PEV Submetering Protocol pursue a temporary meter

accuracy threshold to allow the technology to catch up to the current

CAISO and IOU standards? If yes, what should the temporary

meter accuracy threshold be, and for how long should it be in effect?

11

No. Any meter or submeter used for customer billing must meet the

current accuracy requirements to ensure correct customer billing.

e. If the PEV Submetering Protocol were to allow a 1%-2%-meter

accuracy threshold, how should the IOUs allocate the added costs of

accepting the potential meter data errors?

There should not be any meter data errors as long as the field accuracy

can be maintained at 2% or better as required by the CPUC-approved

DASMMD.

7. Nexant expressed concern at the June 24, 2019 workshop20 that there were

five key drivers for the submeter equipment accuracy and data reliability

issues: (1) the submeter equipment, (2) the customer’s Wi-Fi connection, (3)

the data processing steps, (4) the IOUs process to manage and store data,

and (5) voltage errors and voltage drops. Do you agree with Nexant’s

position that these are the key drivers of data accuracy and reliability

issues? Why or why not?

SCE agrees as these are also the same issues experienced in the pilot.

a. Please identify any additional drivers that could have been the

source of the PEV submeter accuracy and data issues.

Utility privacy requirements complicated resolution of issues since the

utilities could not directly provide MDMAs with customer data without

first obtaining customer consent, which is time consuming for the

customer and MDMA. However, it should be noted that if MDMAs had

rigorous data integrity policies in place, data issues would have been

minimized.

b. How should the PEV Submetering Protocol address each of these key

issues?

See SCE’s recommendations above.

12

8. In responses to questions proposed by Energy Division (ED) Staff in June,

parties recommended the PEV Submetering Protocol adopt equipment

testing standards to determine the accuracy of the PEV submetering

equipment. Do you support this position? Why or why not?

SCE supports requiring all submeters used for utility billing to meet the

equipment standards required for utility revenue-grade meters.

a. Are there any equipment testing standards in place for similar

technologies that the PEV Submetering Protocol should consider to

adopt in lieu of developing new standards?

Please see the answer to question 6 for information on submeter

accuracy. Additionally, please see the answer to question 1 for

information on data integrity.

b. What standards should the PEV Submetering Protocol pursue to

ensure accurate PEV submetering equipment testing?

Please see the answer to question 6 for guidelines established by the

CPUC for direct access metering, which incorporate standards and

procedures required to maintain 2% accuracy of meters in the field.

c. If you do not agree with this position, who should be responsible to

the development of standards to test the PEV submetering

equipment?

Not applicable.

Standards Applicable to PEV Submetering

9. Responding to ED Staff questions on Nexant’s evaluation report, parties

suggested the PEV Submetering Protocol should pursue established

standards such as ANSI C12, Institute of Electrical and Electronics

Engineers (IEEE) 1547.1, IEEE 2030.5, and Public Utilities Commission

Rules of Practice and Procedure 21 Interconnection Requirements. Are

13

there any other standards that should be considered for the development of

a PEV Submetering Protocol? If yes, please list the additional standards to

consider.

Standards and processes that should be adopted are listed in the CPUC-approved

DASMMD.

a. Please explain what the suggested standards will address and the

benefits of pursuing them.

Adherence to the standards and processes defined in the DASMMD has

proven over time to maintain accurate utility meters for utility billing.

Additionally, SCE already has established processes to meet the

DASMMD requirements.

10. In January 2019, the Maryland Public Service Commission (PSC)

determined that PEV submetering was integral to enrolling residential

customers into EV TOU rates and approved three utilities’ proposal to

enable third party PEV submetering. The Maryland PSC instituted a 5-

year waiver of four submetering standards to permit PEV submetering

while a permanent pathway is explored. Should a similar model of allowing

a scalable PEV submetering program prior to a finalization of the PEV

Submetering Protocol be considered by the California Public Utilities

Commission (CPUC)? Why or why not?

No. Stakeholders have already had over four years since the pilots began to

improve accuracy to meet appropriate submeter standards for utility billing. The

Submetering Protocol must reflect the current requirements for revenue-grade

meters used for utility billing.

a. If you agree, what standards should be waived?

Not applicable.

14

Outstanding Concerns on Nexant’s Evaluation Report

11. The CPUC ordered the IOUs to test the application of PEV submetering for

Multiple Customers of Record (MCOR) in the PEV Submetering Phase II

Pilot24. Implementation of the pilot identified that too many barriers

existed to enroll and evaluate any MCORs.

Please identify the information we currently have that can help move

forward with the inclusion of MCORs in the PEV Submetering Protocol.

For the Phase 2 Pilot, the Energy Division directed the IOUs to reduce the 6-

month enrollment period to 3.5 months. Given that commercial customers

have more complicated planning, approval, and implementation processes,

SCE believes that the reduced enrollment period could not accommodate

their needs. The Submetering Protocol needs to accommodate the unique

needs of the commercial sector, separate from the residential sector, and

establish a commercial process that meets commercial customers’ timing

needs and business requirements.

a. Please identify the information needed to move forwards with

MCOR PEV submetering, and how the CPUC and IOUs should seek

to gather this information.

Stakeholders can study other successful commercial submeter programs

to identify best practices. The CPUC and IOUs should hold workshops

with potential commercial submetering customers to understand their

needs.

12. Decision 13-11-002 identified thirteen metrics to evaluate the customer

experience metrics that were to be addressed in the pilot evaluation report.

Do these thirteen metrics collectively encompass all the necessary issues that

need to be addressed in the PEV Submetering Protocol?

15

The Submetering Protocol focuses on the operational requirements to establish a

submetering program. Decision 13-11-002 included nine metrics designed

specifically to evaluate the Phase 2 Pilot customer experience. Consequently,

several of these metrics would not be applicable to a Submetering Protocol

including: #1 comparison of the total cost of metering services, #3 Multiple

Submeter MDMAs and PEVs operating behind a primary meter, and #5

customer satisfaction.

The remaining six metrics should be considered in developing the Submetering

Protocol. These include: #2 Access to PEV tariffs, #4 Utility disconnection

capability, #6 Reliability of Data, Technology, and Service, #7 Service and

Technology Innovations, #8 Technology Standardization, and #9 Cost

minimization.

a. If not, please identify what additional issues need to be addressed?

No additional metrics are necessary for the Submetering Protocol, which

focuses on the operational requirements to establish an ongoing

submetering program.

13. Is there a preferred PEV submeter ownership model that the PEV

Submetering Protocol should pursue (i.e., utility ownership, third-party

ownership, a hybrid model that offers customer choice)?

Based upon recent conversations with commercial customers, SCE proposes that

the Submetering Protocol pursue the utility-ownership model, using a revenue-

grade utility meter as the submeter.

a. What makes this model a better option than the alternative(s)?

The utility model discussed above would (1) significantly reduce

customers’ cost, (2) provide reliable and accurate data for analysis and

16

billing, and (3) provide a single entity (SCE) that is responsible for

customer satisfaction.

b. If multiple ownership models should be allowed, what steps, if any,

should be pursued to minimize the risk of customers selecting one

option over the other(s) due to an inherent favorability bias?

While a hybrid model offers residential and commercial customers a

submetering choice of a second utility meter or a third-party meter,

providing more choices for customers complicates customers’ decision

making and creates a more complex and costly process for the utilities to

serve this hybrid model.

To limit any possible favorability bias with the hybrid model, customers

should be provided clear information regarding costs, meter accuracy,

and ownership model so they can make an informed decision.

14. Do the IOU administered Demand Response (DR), Renewable Portfolio

Standard’s Western Renewable Energy Generation Information System

(RPS WREGIS), or any other programs share data accuracy, data

communication and reporting, technology requirements, or any other PEV

Submetering feature that can provide a basis for standards to include in a

PEV submetering protocol?

In IOU demand response programs, if the customer is compensated based on

metered performance, the customer's standard service meter can be used to

determine participation or compensation. Therefore, applicable revenue-grade

standards apply. The same standards for revenue-grade meters should apply to

submeters used for utility billing.

a. If yes, please explain how these requirements can apply to the PEV

Submetering Protocol and their benefits.

Not applicable.

17

15. Please identify any other outstanding issues or questions related to PEV

submetering that need to be addressed to further the development of the

PEV Submetering Protocol and the suggested pathway to attend to these

issues/questions.

Lessons Learned from the Submetering Phase 2 Pilot:

1) Lesson Learned: The Submeter MDMAs were not fully prepared to start

the Phase 2 Pilot on January 16, 2017.

Actions to Address Lesson:

Request that Energy Division provide enough time for MDMAs to apply

and qualify prior to the start of a possible future operational program, if

authorized by the CPUC.

Provide the Submetering MDMAs with more comprehensive, detailed

training prior to a possible future operational program, if authorized by

the CPUC, to help improve their performance and level of customer

satisfaction.

2) Lesson Learned: During the Pilot, SCE supported its customers with

manual subtractive billing to separately bill household and EV charging

on their respective rates. The three IOUs all experienced billing

problems due to various issues including data formatting, hardware

accuracy, server maintenance and NEM customers who charged their EV

during generation. These issues caused most of the recorded submeter

“failed intervals,” which occurred when the submeter kWh exceeded the

primary meter kWh. (See Section 3.3.4 Submeter MDMA Accuracy of

Customer Submeter Interval Usage Data for further details)


The MDMAs should be required to meet the same accuracy requirements

as the IOUs’ SmartMeters™ if the Submetering Protocol is authorized by

18

the CPUC. Testing of MDMA submeters should be done using the same

test requirements utilized by the IOUs when testing their SmartMeters™.

Require the submeter to be tested to demonstrate meter acceptance

accuracy of +/-.5% and maintain accuracy of +/- 2% while the submeter

is in service prior to the start of a possible future submetering operational

program. (The term “accuracy” is equivalent to the same term used in

the ANSI C-12 standard or equivalent to “tolerance” in NIST Handbook

44 Section 3.40 T.2.)

Require the submeter to be tested to demonstrate that the submeter’s time

is synchronized to the Universal Time Coordinate (UTC) time standard

prior to the start of a possible future submetering operational program.

The UTC is defined by the National Institute of Standards and

Technology (NIST), and the submeter must be within +/- two (2) minutes

of UTC while the EVSE is in service.

Require MDMAs to provide IOUs means to test the submeter while in

service. Work with the MDMAs to develop submeter field testing

including possibly adding a submeter optical probe or a display.

3) Lesson Learned: MDMA performance and SCE billing was negatively

impacted by “back office” issues including:

Software issues related to how the MDMAs received data from their

submeters, formatted the data, and maintained the software throughout

the Pilot contributing to MDMA data accuracy problems.

Hardware issues related to maintaining the server IP address resulted in

the SCE firewall rejecting MDMA submeter data and causing customers’

EV charging usage to be billed on their household rate.

These issues impacted the quality and timeliness of submeter data

transfer to SCE.

19


Provide the Submetering MDMAs with comprehensive, detailed training

focused on back office management issues prior to a possible future

operational program, if authorized by the CPUC, to help improve their

performance and level of customer satisfaction.

4) Lesson Learned: The manual customer Pilot processes were challenging

for our customers, Submeter MDMAs and SCE support organizations

(i.e., RSO/PSO, RSO/BOM, and RSO/Billing).


Automate the following manual Pilot processes for a future operational

Submetering Program, if authorized by the CPUC

Enroll customers in the EV submetering service

Set-up submeter service accounts including the creation and turn-on of

virtual submeters for single and multiple customers of record

Receive and process 15-minute interval submeter data from MDMA

Perform subtractive billing: Subtract the EV charging usage recorded on

the submeter from the customer’s primary meter household usage, which

includes the EV charging usage. Then provide a single bill that includes

the separate charges for the primary meter usage less the EV charging

usage on the customer’s existing primary meter rate and the EV charging

usage on the appropriate separately metered EV rate.

Close-out submeter service accounts and turn-off virtual submeters

Review MDMA invoices for accuracy and completeness before the PMO

approves invoice for payment.

5) Lesson Learned: NEM customers can inadvertently experience failed

intervals (i.e. submeter usage exceeds household usage) when charging

their EV while generating due to SCE’s system and manual subtractive

20

billing limitations that require using net usage kWh (i.e. total household

kWh including EV charging – generation kWh) instead of total

household usage. This limitation can sometimes result in customers’ EV

charging kWh exceeding their net kWh, resulting in a failed interval.

Action to Address Lesson:

In addition to automating the process listed in Lesson # 4 above, this

limitation of SCE’s systems and manual subtractive billing process must

be corrected if the CPUC authorizes the Submetering Protocol.

II.

RESPONSES TO ATTACHMENT B

1. Using an Excel spreadsheet that will be provided to the IOUs by the

Commission’s Energy Division staff (Utility Submetering Cost Estimate

Template), fill in all cells with the expected costs needed to upgrade the

current billing system to accept, analyze, and bill customer PEV

submetering data. Please indicate how each cost was derived, if the costs

are an estimate or precise figure, and if it is a one time or reoccurring

charge. Also detail if the expected upgrade costs are limited to PEV

submetering or if the upgrades can be used for other IOU programs (ex.,

Demand Response, Net-Energy Metering, Vehicle-to-Grid Integration).

SCE has provided all currently available data given the timeframe for preparing

these estimates. These are rough estimates based on SCE’s current

understanding of what a possible submetering program could involve. SCE

would need to refine these estimates based on the specific requirements of any

approved submetering program.

2. During the June 24, 2019 workshop, Southern California Edison Company

commented that the data received from the Meter Data Management Agent

(MDMA) cost 30x more to communicate, analyze, and store than data

21

received through the Advance Metering Infrastructure (AMI) network.

Please provide an excel file with a tab that details the individual costs to

communicate, analyze, and store meter data through the AMI network; a

tab that details the costs to communicate, analyze, and store the PEV

submetering from the MDMAs; and a summary tab that compares the two

networks.

In the attached spreadsheet, SCE's Over-the-Air (OTA) costs are $0.05 per meter

per month to deliver interval data to our back office for processing (see cells C8

and D8). In the PEV submetering pilot, SCE paid MDMAs $17.50 per month

per submeter for raw interval data. SCE then had to perform quality checks, fix

errors with the MDMA, and, if successful, run the customer data through SCE’s

billing system. These steps are typically is not required with SCE-owned meters

and therefore add incremental cost to the process.

3. During the June 24, 2019 workshop, the utilities mentioned that AMI

system upgrades are or will be occurring over the next one to three years for

each will prevent the IOUs from implementing upgrades specific to PEV

submetering over this time. Please provide information on what these

upgrade entail, such as what features will be affected, how much the

upgrades will costs, how long the upgrades will take to perform, what the

outcome of the upgrades will support (i.e., SmartMeter communication),

why PEV submetering upgrades cannot be included in the current process,

how long until the next round of upgrades will be needed, and any

additional information that will impact the ability to implement a PEV

Submetering protocol.

SCE will not have AMI upgrades in the next one to three years. However, SCE

is in the process of implementing its Customer Service Re-Platform project

(CSRP), which will replace SCE’s existing core customer service systems for

22

Customer Care, Billing and Payments, and Credit and Collections. CSRP is

scheduled to go live in late Q1 or early Q2 of 2021. With CSRP, SCE will have

the core ability to support a multi-meter scenario as well as subtractive billing.

However, this capability will not be set up at the launch of CSRP and

development work will be needed to implement the specific requirements to

support any future submetering program.

III.

CONCLUSION

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

Respectfully submitted,

ANNA VALDBERG ANDREA TOZER

/s/ Andrea Tozer By: Andrea Tozer

Attorney 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: February 12, 2020

Appendix A

Physical Equipment Capital ($) Expense ($) Total ($) Reoccurring Cost? (Y/N)

Is cost specific to submetering or does upgrade have additional uses? Comments Physical Equipment Capital ($) Expense ($) Total ($) Reoccurring Cost? (Y/N)

Is cost specific to submetering or does upgrade have additional uses? Comments Cost Difference Between Second Utility Meter and Submeter

Qualification Process Note 1 Note 1 Note 1 Note 1 Note 1 Note 1 Qualification Process Note 1,8 Note 1,8 Note 1,8 Note 1,8 Note 1,8 Note 1,8

Materials/ Meter $ 120.00 $ - $ 120.00 No NoEstimated meter cost Materials NA NA NA NA Yes

As this is owned by a 3rd party material cost is unknown

Engineering Design Note 1 Note 1 Note 1 Note 1 Note 1 Note 1 Engineering Design Note 1,8 Note 1,8 Note 1,8 Note 1,8 Note 1,8 Note 1,8

Construction/Installation/Meter $18.00 $ - $ 19.00 No No

MT4 Install and Drive time 15 min - Costs are loaded Construction/Installation Unknown Unknown Unknown No Yes Note 1,8, 9

Equipment Integration Note 3 Note 3 Note 3 Note 3 Note 3 Note 3 Equipment Integration Unknown Unknown Unknown Unknown Unknown

This depends onthe submeter design and intergration with EVSE

Network FeesOTA MR Cost $ - $ 0.05 $ 0.05 Yes No

Estimated cost to read meter Over the Air on a monthly basis Network Fees $ - $ 0.05 $ 0.05 Yes No

Cost to read meter Over the Air on a monthly basis

Maintenance $ - $ - $ - No No Maintenance Unknown Unknown Unknown Yes Yes

Costs are specific to submetering since this is a sebmeter by design

ME&O $0 $0 $0 No No Note 4 ME&O Unknown Unknown Unknown No Yes

3rd party would have to market the service - costs depend on their marketing strategy

Testing / Meter NA NA NA No No

Per MFO management no install test required for these meters Testing Unknown Unknown Unknown No Yes

Costs depend on the meter provided by the 3rd party - this is unknown at this time

Non-Direct Costs NA NA NA No No Non-Direct Costs Unknown Unknown Unknown No Yes

LaborRolled up into Cell B6

Rolled up into Cell C6

Rolled up into Cell D6 No No Labor Unknown Unknown Unknown No Yes

SafetyNo charges based on safety

No charges based on safety

No charges based on safety No No Safety Unknown Unknown Unknown No Yes

Misc. $17.00 NA $17.00 NA NA

Estimated supply expense and acceptance tests cost per meter Misc. Unknown Unknown Unknown No Yes

Other (Please explain costs in cell G) NA NA NA NA NA Other (Please explain costs in cell O) NA NA NA NA NATotal 155.00$ 0.05$ 156.05$ Total -$ 0.05$ 0.05$

IT Capital ($) Expense ($) Total ($) Reoccurring Cost? (Y/N)

Is cost specific to submetering or does upgrade have additional uses? Comments IT Capital ($) Expense ($) Total ($) Reoccurring Cost? (Y/N)

Is cost specific to submetering or does upgrade have additional uses? Comments

Design & Implementation (Utility Side) $ 2,000,050 $0 $ 2,000,050 No Yes

Note 5, Estimated submetering costs for all market sectors Design & Implementation (Utility Side) $ 2,000,050 $0 $ 2,000,050 No Yes

Note 5,7, Estimated submetering costs for all market sectors

Design & Implementation (Customer Side) NA NA NA NA Yes Note 6

Design & Implementation (Customer Side) NA NA NA NA Yes Note 6,7

Data Evaluation NA NA NA NA Yes Note 6 Data Evaluation NA NA NA NA Yes Note 6,7Customer Validation NA NA NA NA Yes Note 6 Customer Validation NA NA NA NA Yes Note 6,7Testing NA NA NA NA Yes Note 6 Testing NA NA NA NA Yes Note 6,7Non-Direct Costs NA NA NA NA Yes Note 6 Non-Direct Costs NA NA NA NA Yes Note 6,7Labor NA NA NA NA Yes Note 6 Labor NA NA NA NA Yes Note 6,7

Misc. $0 $ 100,000 $ 100,000 Yes YesEstimated annual reoccuring Misc. $0 $ 100,000 $ 100,000 Yes Yes

Estimated annual

Integrated/Planned IT Upgrades with submetering co-benefits NA NA NA NA Yes Note 6

Integrated/Planned IT Upgrades with submetering co-benefits NA NA NA NA Yes Note 6,7

Other (Please explain costs in cell G) NA NA NA NA Yes Note 6 Other (Please explain costs in cell O) NA NA NA NA Yes Note 6,7Total 2,000,050$ 100,000$ 2,100,050$ Total 2,000,050$ $100,000 2,100,050$ Note 10

Total Note 11 Total Note 11

Note 1: This process or product already exists so no costs are needed to develop itNote 3: As electrical meters exist, there are no integration costsNote 4: The utility meter is required for electrical service ME&O aren't applicableNote 5: These costs are needed for final set up of the sub-metering module in our back office systemsNote 6: SCE already planned for sub-metering in its CSRP refresh and costs are rolled up into this existing project - for details on CSRP see answer to question 3, under RESPONSES TO ATTACHMENT B Note 7: For IT costs submetering process should be the same between utility owned and 3rd party owned metersNote 8: A 3rd party owned submeter using our AMI backhaul must be compatible with the Itron Openway System, must meet all revenue grade meter accuracy durability specifications and must meet all utility cybersecurity requirements - with these items in mind costs should be similar to SCE owned metersNote 9: Costs for connecting an individual submeter and testing it with SCE AMI system depends on the 3rd party's process for doing this so we do not have costs for this item. SCE estimates that it will take 15 to 30 minutes time to accomplish this taskNote 10: The costs reported for the submeter section may be lower than expected as most costs are unknown for the submeter at this timeNote 11: Hardware (meter/submeter) costs are on a per account basis and IT costs are on a system wide basis

SubmeterSecond Utility Meter


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) COMMENTS ON ADMINISTRATIVE LAW JUDGE’S RULING DIRECTING PACIFIC GAS AND ELECTRIC COMPANY, SOUTHERN CALIFORNIA EDISON COMPANY, AND SAN DIEGO GAS & ELECTRIC COMPANY TO RESPOND TO OUTSTANDING METER QUESTIONS ON THE DEVELOPMENT OF A SUBMETERING PROTOCOL on all parties identified on the attached service list(s) for 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 by US Mail to the offices of the Commissioners(s) or other addresses(s).

ALJ Patrick Doherty CPUC 505 Van Ness Avenue San Francisco, CA 94102

ALJ Sasha Goldberg CPUC 505 Van Ness Avenue San Francisco, CA 94102

Executed this day, February 12, 2020, at Rosemead, California.

/s/ Sandra Sedano Sandra Sedano Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY

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

CPUC Home

CALIFORNIA PUBLIC UTILITIES COMMISSIONService Lists

PROCEEDING: R1812006 - CPUC - OIR TO CONTIN FILER: CPUC LIST NAME: LIST LAST CHANGED: FEBRUARY 12, 2020

Download the Comma-delimited File About Comma-delimited Files

Back to Service Lists Index

Parties

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

TADASHI GONDAI JOSEPH HALSO SR. ATTORNEY / DIR OF LEGAL AFFAIRS LEGAL FELLOW NATIONAL ASIAN AMERICAN COALITION SIERRA CLUB EMAIL ONLY 50 F STREET, NW, 8TH FLR. EMAIL ONLY, CA 00000 WASHINGTON, DC 20001 FOR: NATIONAL DIVERSITY COALITION & FOR: SIERRA CLUB NATIONAL ASIAN AMERICAN COALITION

JULIA M. REGE COLEY GIROUARD DIR - ENVIRONMENTAL & ENERGY PRINCIPAL ASSOCIATION OF GLOBAL AUTOMAKERS, INC. ADVANCED ENERGY ECONOMY 1050 K ST., NW, STE. 650 1000 VERMONT AVE NW, 3RD FL WASHINGTON, DC 20001 WASHINGTON, DC 20005 FOR: ASSOCIATION OF GLOBAL AUTOMAKERS, FOR: ADVANCED ENERGY ECONOMY INC.

SAMANTHA HOUSTON JOSHUA COHEN VEHICLES ANALYST DIR - POLICY & UTILITY PROGRAMS UNION OF CONCERNED SCIENTISTS SEMACONNECT 1825 K STREET NW, SUITE 800 4961 TESLA DRIVE, SUITE A WASHINGTON, DC 20006 BOWIE, MD 20715

Page 1 of 12CPUC - Service Lists - R1812006

2/12/2020https://ia.cpuc.ca.gov/servicelists/R1812006_86501.htm

FOR: UNION OF CONCERNED SCIENTISTS FOR: SEMACONNECT, INC.

DAN BOWERSON DAVID MCCREADIE ALLIANCE OF AUTOMOBILE MANUFACTURERS FORD MOTOR COMPANY 2000 TOWN CENTER, STE 625 ONE AMERICAN ROAD SOUTHFIELD, MI 48075 DEARBON, MI 48126 FOR: ALLIANCE OF AUTOMOBILE FOR: FORD MOTOR COMPANY MANUFACTURERS

REBECCA SHELBY SCOTT PICCO FORD MOTOR COMPANY BUSINESS DEVELOPMENT MANAGER, 1 AMERICAN ROAD UL LLC DEARBORN, MI 48126 ENERGY SYSTEMS & E-MOBILITY FOR: FORD MOTOR COMPANY 333 PFINGSTEN RD. NORTHBROOK, IL 60062 FOR: UL LLC

SARA GERSEN THOMAS ASHLEY STAFF ATTORNEY VP - GOVN'T AFFAIRS & PUBLIC POLICY EARTHJUSTICE GREENLOTS 800 WILSHIRE BLVD., STE. 1000 925 N. LA BREA AVE., 6TH FL LOS ANGELES, CA 90017 LOS ANGELES, CA 90038 FOR: CENTER FOR COMMUNITY ACTION AND FOR: GREENLOTS ENVIRONMENTAL JUSTICE; EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

PAUL D. HERNANDEZ MAX BAUMHEFNER HEAD OF POLICY & GOVN'T RELATIONS ATTORNEY ENVOY TECHNOLOGIES, INC. NATURAL RESOURCES DEFENSE COUNCIL 8575 WASHINGTON BLVD. 111 SUTTER ST., 21ST FL. CULVER CITY, CA 90232 SAN FRANCISCO, CA 91404 FOR: ENVOY TECHNOLOGIES, INC. FOR: NATURAL RESOURCES DEFENSE COUNCIL (NRDC)

ANDREA TOZER RONALD MOORE SR. ATTORNEY SR. REGULATORY ANALYST SOUTHERN CALIFORNIA EDISON COMPANY GOLDEN STATE WATER CO / BEAR VALLEY ELEC 2244 WALNUT GROVE AVE / PO BOX 800 630 EAST FOOTHILL BLVD. ROSEMEAD, CA 91770 SAN DIMAS, CA 91773-9016 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: BEAR VALLEY ELECTRIC SERVICE ( A DIVISION OF GOLDEN STATE WATER)

JULIE WILEY JACKIE PIERO SPECIAL COUNSEL DIR - POLICY SAN DIEGO ASSOCIATION OF GOVERNMENTS NUVVE CORPORATION 401 B STREET, SUITE 800 2468 HISTORIC DECATUR ROAD, STE. 200 SAN DIEGO, CA 92101 SAN DIEGO, CA 92106 FOR: SAN DIEGO ASSOCIATION OF FOR: NUVVE CORPORATION GOVERNMENTS

LISA MCGHEE CLAY FABER OPERATIONS MGR. DIR. CA & FEDERAL REGULATORY SAN DIEGO AIRPORT PARKING CO. SAN DIEGO GAS & ELECTRIC COMPANY 2771 KURTZ ST. 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA 92110 SAN DIEGO, CA 92123



FOR: SAN DIEGO AIRPORT PARKING CO. FOR: SAN DIEGO GAS & ELECTRIC COMPANY (SDG&E)

E. GREGORY BARNES EMANUEL WAGNER ATTORNEY DEPUTY DIR SAN DIEGO GAS & ELECTRIC COMPANY CALIFORNIA HYDROGEN BUSINESS COUNCIL 8330 CENTURY PARK CT., CP32 18847 VIA SERENO SAN DIEGO, CA 92123 YORBA LINDA, CA 92866 FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: CALIFORNIA HYDROGEN BUSINESS COUNCIL

MICHAEL CHIACOS JEREMY WAEN DIR - ENERGY PROGRAMS MGR. - REGULATORY AFFAIRS COMMUNITY ENVIRONMENTAL COUNCIL PENINSULA CLEAN ENERGY 26 W. ANAPAMU ST., 2ND FLR. 2075 WOODSIDE RD. SANTA BARBARA, CA 93101 REDWOOD CITY, CA 94061 FOR: COMMUNITY ENVIRONMENTAL COUNCIL FOR: PENINSULA CLEAN ENERGY

DAVID SCHLOSBERG MARC D JOSEPH VP - ENERGY MARKET OPERATIONS 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: ELECTRIC MOTOR WERKS, INC. FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES (CCUE)

HILARY STAVER CANDICE PLOTKIN MGR - REGULATORY & LEGISLATIVE AFFAIRS LEAD COUNSEL, REGULATORY SILICON VALLEY CLEAN ENERGY AUTHORITY CRUISE LLC 333 W. EL CAMINO REAL, STE. 290 1201 BRYANT STREET SUNNYVALE, CA 94087 SAN FRANCISCO, CA 94103 FOR: SILICON VALLEY CLEAN ENERGY FOR: CRUISE LLC AUTHORITY (SVCE)

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.

IVAN R. JIMENEZ PETER OKUROWSKI REGULATORY ATTORNEY PRINCIPAL SMALL BUSINESS UTILITY ADVOCATES CEA CONSULTING 548 MARKET STREET, STE. 11200 235 MONTGOMERY STREET, SUITE 950 SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104 FOR: SMALL BUSINESS UTILITY ADVOCATES FOR: BNSF RAILWAY

CHRISTOPHER J. WARNER EVELYN KAHL ATTORNEY ATTORNEY PACIFIC GAS AND ELECTRIC COMPANY BUCHALTER, A PROFESSIONAL CORPORATION 77 BEALE STREET, B30A / PO BOX 7442 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: ENERGY PRODUCERS AND USERS COALITION



LARISSA KOEHLER NORA SHERIFF, ESQ. 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 94105-3493 FOR: ENVIRONMENTAL DEFENSE FUND FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION (CLECA)

MICHAEL B. DAY RACHELLE CHONG ATTORNEY COUNSEL GOODIN, MACBRIDE, SQUERI, & DAY, LLP LAW OFFICES OF RACHELLE CHONG 505 SANSOME STREET, STE 900 345 W. PORTAL AVENUE, STE. 110. SAN FRANCISCO, CA 94111-3133 SAN FRANCISCO, CA 94127 FOR: EVGO SERVICES LLC FOR: LYFT, INC.

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 ALEX J. MORRIS ATTORNEY VP - POLICY & OPERS BEST BEST & KRIEGER LLP CALIFORNIA ENERGY STORAGE ALLIANCE 2001 NORTH MAIN STREET, STE. 390 2150 ALLSTON WAY, STE.400 WALNUT CREEK, CA 94596 BERKELEY, CA 94704 FOR: CITY OF LONG BEACH CALIFORNIA, A FOR: CALIFORNIA ENERGY STORAGE ALLIANCE MUNICIPAL CORPORATION, ACTING BY AND (CESA) THROUGH ITS BOARD OF HARBOR COMMISSIONERS

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

JOEL ESPINO SHALINI SWAROOP LEGAL COUNSEL 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

HEIDI SICKLER STEVEN S. SHUPE DIR - ENERGY AND ENVIRONMENT GENERAL COUNSEL SILICON VALLEY LEADERSHIP GROUP SONOMA CLEAN POWER AUTHORITY 2001 GATEWAY PLACE, SUITE 101E 50 SANTA ROSA AVE., 5TH FL. SAN JOSE, CA 95110 SANTA ROSA, CA 95404 FOR: SILICON VALLEY LEADERSHIP GROUP FOR: SONOMA CLEAN POWER AUTHORITY



BRITTANY ILES LAURA FERNANDEZ ATTORNEY ATTORNEY BRAUN BLAISING SMITH WYNNE, P.C. BRAUN BLAISING SMITH WYNNE, P.C. 915 L STREET, STE. 1480 915 L STREET, STE 1480 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: MONTEREY BAY COMMUNITY POWER FOR: CALIFORNIA CHOICE ENERGY AUTHORITY

MICHAEL PIMENTEL STEVEN P. DOUGLAS LEGISLATIVE / REGULATORY ADVOCATE SR. DIR - ENVIRONMENTAL AFFAIRS CALIFORNIA TRANSIT ASSOCIATION ALLIANCE OF AUTOMOBILE MANUFACTURERS 1415 L STREET 1415 L STREET, STE. 1190 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CALIFORNIA TRANSIT ASSOCIATION FOR: ALLIANCE OF AUTOMOBILE MANUFACTURERS

TOVAH TRIMMING LYNN M. HAUG CALIF PUBLIC UTILITIES COMMISSION ELLISON SCHNEIDER HARRIS & DONLAN LLP LEGAL DIVISION 2600 CAPITOL AVENUE, SUITE 400 300 Capitol Mall SACRAMENTO, CA 95816 Sacramento, CA 95814 FOR: CHARGEPOINT, INC. FOR: PUBLIC ADVOCATES OFFICE

DANIEL MARSH AJAY KUMAR MGR - RATES & REGULATORY AFFAIRS ATTORNEY LIBERTY UTILITIES (CALPECO ELECTRIC) LLC PACIFICORP 933 ELOISE AVENUE 825 NE MULTMOMAH STREET, STE. 1800 SOUTH LAKE TAHOE, CA 96150 PORTLAND, OR 97232 FOR: LIBERTY UTILITIES (CALPECO FOR: PACIFICORP ELECTRIC) LLC

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

Information Only

AARON N. LU BONNIE DATTA SAN DIEGO GAS & ELECTRIC COMPANY SR. DIR - AMERICAS & ASIA PACIFIC EMAIL ONLY SIEMENS EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

CAMILLE STOUGH CHRISTOPHER SUMMERS ASSOCIATE REGULATORY BUSINESS MANAGER ADAMS BROADWELL JOSEPH & CARDOZO SAN DIEGO GAS & ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

ERIK ELLIS GERHARD ACHTELIK PRINCIPAL / FOUNDER CALIFORNIA AIR RESOURCES BOARD



GREEN MACHINE POWER, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

JANA KOPYCIOK-LANDE JOHN BOWIE SR. POLICY ANALYST KEARNS & WEST, INC. MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

KATHY PENICHE MARISSA WILLIAMS CASE MGR - REGULATORY AIR POLLUTION SPECIALIST / ECARS SAN DIEGO GAS & ELECTRIC COMPANY 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 SEPHRA A. NINOW ASSOCIATE ASSOC. DIR - REGULATORY AFFAIRS KEARNS & WEST, INC CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

TAM HUNT, J. D. PAUL CHERNICK CONSULTING ATTORNEY PRESIDENT COMMUNITY RENEWABLES SOLUTIONS, LLC RESOURCE INSIGHT EMAIL ONLY 5 WATER ST. EMAIL ONLY, CA 00000-0000 ARLINGTON, MA 02476 FOR: GREEN POWER INSTITUTE

HOLMES HUMMEL AL LUNA CLEAN ENERGY WORKS LITIGATION ASSISTANT, CLEAN ENERGY TEAM 925 FRENCH STREET NW EARTHJUSTICE WASHINGTON, DC 20001 1625 MASSACHUSETTS AVE., N.W., STE 702 WASHINGTON, DC 20036-2243 FOR: CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE; EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

JIGAR J. SHAH KAY DAVOODI MGR - ENERGY & GRID SERVICES FEDERAL EXECUTIVE AGENCIES ELECTRIFY AMERICA 1322 PATTERSON AVE SE, SUITE 1000 2003 EDMUND HALLEY DR., 2ND FL, STE 200 WASHINGTON NAVY YARD, DC 20374-5065 RESTON, VA 20191

LARRY ALLEN MAKDA SOLOMON UTILITY RATES & STUDIES OFFICE UTILITY RATES & STUDIES OFFICE UNITED STATES NAVY / FED EXE. AGENCIES UNITED STATES NAVY 1322 PATTERSON AVE SE SUITE 1000 1322 PATTERSON AVE SE BLDG 33, STE. 1000



WASHINGTON NAVY YARD, CA 20374-5065 WASHINGTON NAVY YARD, DC 20374-5065 FOR: FEDERAL EXECUTIVE AGENCIES (FEA) FOR: FEDERAL EXECUTIVE AGENCIES (FEA)

SASHA GOLDBERG ADRIANO MARTINEZ CALIF PUBLIC UTILITIES COMMISSION ATTORNEY AT LAW ADMINISTRATIVE LAW JUDGE DIVISION 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 SASAN SAADAT LITIGATION ASSISTANT EARTHJUSTICE EARTHJUSTICE 800 WILSHIRE BLVD., STE. 1000 800 WILSHIRE BLVD., SUITE 1000 LOS ANGELES, CA 90017 LOS ANGELES, CA 90017 FOR: CENTER FOR COMMUNITY ACTION AND FOR: CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE; EAST YARD ENVIRONMENTAL JUSTICE; EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE COMMUNITIES FOR ENVIRONMENTAL JUSTICE

JESSALYN ISHIGO ALEXANDER KEROS ENVIRONMENTAL BUSINESS DEVELOPMENT OFF. ADVANCED VEHICLE & INFRASTRUCTURE POLICY AMERICAN HONDA MOTOR CO., INC. GENERAL MOTORS, LLC 1919 TORRANCE BLVD. 3050 LOMITA BLVD. TORRANCE, CA 90501 TORRANCE, CA 90505 FOR: AMERICAN HONDA MOTOR CO., INC. FOR: GENERAL MOTORS, LLC

CASE ADMINISTRATION LISA MAU SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY 2244 WALNUT GROVE AVE. / PO BOX 800 SOUTHERN CALIFORNIA EDISON ROSEMEAD, CA 91770 2244 WALNUT GROVE AVE. ROSEMEAD, CA 91773

MELODEE BLACK JOSH GERBER REGULATORY AFFAIRS ADVISOR FOUNDER & PRINCIPAL SOUTHERN CALIFORNIA EDISON COMPANY 33 NORTH ENERGY LLC 2244 WALNUT GROVE AVE. 661 MELBA ROAD ROSEMEAD, CA 91773 ENCINITAS, CA 92024

DONALD C. LIDDELL COURTNEY COOK ATTORNEY AT LAW PARALEGAL / OFFICE ADMIN. DOUGLASS & LIDDELL UTILITY CONSUMERS' ACTION NETWORK 2928 2ND AVENUE 3405 KENYON STREET, SUITE 401 SAN DIEGO, CA 92103 SAN DIEGO, CA 92110

JANE KRIKORIAN, J.D. JOHN W. LESLIE, ESQ. SUPERVISOR, ADV. & ADMIN. ATTORNEY UTILITY CONSUMERS' ACTION NETWORK DENTONS US LLP 3405 KENYON STREET, STE. 401 4655 EXECUTIVE DRIVE, SUITE 700 SAN DIEGO, CA 92110 SAN DIEGO, CA 92121 FOR: UTILITY CONSUMERS' ACTION NETWORK (UCAN)



CHRISTA M. LIM JOHN A. PACHECO REGULATORY CASE MGR. COUNSEL SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32D 8330 CENTURY PARK CT., CP32D SAN DIEGO, CA 92123 SAN DIEGO, CA 92123 FOR: SAN DIEGO GAS & ELECTRIC COMPANY

ROSS R. FULTON SHEWIT WOLDEGIORGIS SENIOR COUNSEL REGULATORY AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32D 8330 CENTURY PARK CT., CP32F SAN DIEGO, CA 92123 SAN DIEGO, CA 92123

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 BEN GUSTAFSON SR.MGR - REG & GOV'T AFFAIRS UTILITY ANALYST, CLEANPOWERSF ENEL X NORTH AMERICA, INC. SF PUBLIC UTILITIES COMMISSION 846 BRANSTEN ROAD 525 GOLDEN GATE AVE 7TH FL SAN CARLOS, CA 94070 SAN FRANCISCO, CA 94102

ALAN BACH AUDREY NEUMAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY INFRASTRUCTURE BRANCH PROCUREMENT STRATEGY AND OVERSIGHT BRANC AREA ROOM 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

CAROLYN SISTO CHLOE LUKINS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ENERGY INFRASTRUCTURE BRANCH AREA ROOM 4102 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

CODY NAYLOR DANIELLE DOOLEY CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION TRANSPORTATION ENFORCEMENT BRANCH ENERGY INFRASTRUCTURE BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

ED PIKE FIDEL LEON DIAZ CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ENERGY INFRASTRUCTURE BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JERRY MELCHER JOSE ALIAGA-CARO



CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY INFRASTRUCTURE BRANCH DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

MARC HUTTON MASOUD FOUDEH CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY INFRASTRUCTURE BRANCH DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

MICHAEL TRUAX PATRICK DOHERTY CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ADMINISTRATIVE LAW JUDGE DIVISION AREA ROOM 5044 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

RODERICK HILL SARA M. KAMINS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ROOM 4300 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: PUBLIC ADVOCATES OFFICE

SARAH OWENS SEAN A. SIMON CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER RECHTSCHAFFEN COMMISSIONER RECHTSCHAFFEN ROOM 5200 ROOM 5201 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

TIM G. DREW YULIYA SHMIDT CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY INFRASTRUCTURE BRANCH COMMISSIONER RECHTSCHAFFEN AREA 4-A ROOM 4209 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

ELIZABETH YATES LISA TSE UBER TECHNOLOGIES, INC. COUNSEL, REGULATORY 1455 MARKET STREEET, 4TH FL. UBER TECHNOLOGIES, INC. SAN FRANCISCO, CA 94103 1455 MARKET STREET, 4TH FL. SAN FRANCISCO, CA 94103

MARCEL HAWIGER MEGHA LAKHCHAURA STAFF ATTORNEY EVBOX INC THE UTILITY REFORM NETWORK BESPOKE COWORKING, LEVEL 4 785 MARKET ST., STE. 1400 845 MARKET ST STE 450 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94103 FOR: THE UTILITY REFORM NETWORK (TURN)



RITA M. LIOTTA SHIVANI SIDHAR COUNSEL - REGULATORY COUNSEL, REGULATORY UNITED STATES NAVY UBER TECHNOLOGIES, INC. NAVAL FACILITIES ENGINEERING COMMAND 1455 MARKET STREET, 4TH FL. 1 AVENUE OF THE PALMS, STE. 161 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94103 FOR: FEDERAL EXECUTIVE AGENCIES

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

JAMES M. BIRKELUND JENNIFER L. WEBERSKI PRESIDENT LITIGATION SUPERVISOR SMALL BUSINESS UTILITY ADVOCATES SMALL BUSINESS UTILITY ADVOCATES 548 MARKET STREET, STE. 11200 548 MARKET STREET, SUITE 11200 SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104

JULIA KANTOR MILES MULLER ATTORNEY ATTORNEY KEYES & FOX LLP NATURAL RESOURCES DEFENSE COUNCIL 580 CALIFORNIA STREET, 12TH FL. 111 SUTTER STREET, 21ST FL. SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104

CATHERINE BUCKLEY CASE COORDINATION REGULATORY AFFAIRS PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY 77 BEALE STREET, B10A EMAIL ONLY, CA 94105-4159 SAN FRANCISCO, CA 94105

PAUL R. CORT MEGAN M. MYERS EARTHJUSTICE COUNSEL 50 CALIFORNIA ST., STE. 500 LAW OFFICES OF MEGAN M. MYERS SAN FRANCISCO, CA 94111 110 OXFORD STREET FOR: CENTER FOR COMMUNITY ACTION AND SAN FRANCISCO, CA 94134 ENVIRONMENTAL JUSTICE; EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

DON ANAIR JIMMY O'DEA, PH.D UNION OF CONCERNED SCIENTISTS VEHICLES ANALYST 500 12TH ST. SUITE 340 UNION OF CONCERNED SCIENTISTS OAKLAND, CA 94607 500 12TH STREET, STE. 340 OAKLAND, CA 94607

MANAL YAMOUT STEVE CAMPBELL PARTNER MGR - POLICY & BUS. DEVELOP CALIBER STRATEGIES GRID ALTERNATIVES 1550 5TH ST. 1171 OCEAN AVE SUITE 200 OAKLAND, CA 94607 OAKLAND, CA 94608 FOR: GRID ALTERNATIVES



ZACH FRANKLIN PAUL NELSON CHIEF STRATEGY OFFICER CONSULTANT GRID ALTERNATIVES BARKOVICH & YAP, INC. 1171 OCEAN AVE., STE. 200 PO BOX 11031 OAKLAND, CA 94608-1147 OAKLAND, CA 94611 FOR: GRID ALTERNATIVES FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION

JESSICA YARNALL LOARIE SHERIDAN PAUKER SENIOR ATTORNEY PARTNER SIERRA CLUB KEYES & FOX LLP 2101 WEBSTER ST, SUITE 1300 436 14TH STREET, SUITE 1305 OAKLAND, CA 94612 OAKLAND, CA 94612

MEREDITH ALEXANDER, J. D. NATHANIEL MALCOLM DIR - POLICY POLICY COUNSEL CALSTART MARIN CLEAN ENERGY 2600 TENTH ST., SUITE 407 1125 TAMALPAIS AVENUE BERKELEY, CA 94710 SAN RAFAEL, CA 94901

PHILLIP MULLER ALEX LEUMER PRESIDENT DIR - PUBLIC POLICY SCD ENERGY SOLUTIONS CHARGEPOINT, INC. 436 NOVA ALBION WAY 254 EAST HACIENDA AVENUE SAN RAFAEL, CA 94903 CAMPBELL, CA 95008

ANNE SMART ANTHONY HARRISON VP, PUBLIC POLICY DIR - PUBLIC POLICY CHARGEPOINT, INC. CHARGEPOINT 254 EAST HACIENDA AVENUE 254 E. HACIENDA AVENUE CAMPBELL, CA 95008 CAMPBELL, CA 95008

DAVE PACKARD PRASANTH GOPALAKRISHNAN VICE PRESIDENT, UTILITY SOLUTIONS APPLIED SYSTEMS ENGINEERING INC CHARGEPOINT, INC. 1671 DELL AVE., SUITE 200 254 EAST HACIENDA AVENUE CAMPBELL, CA 95008 CAMPBELL, CA 95008

RENEE SAMSON CHRISTINA JAWORSKI DIR - UTILITY SOLUTIONS SR. ENVIRONMENTAL PLANNER CHARGEPOINT, INC. SANTA CLARA VALLEY TRANSPORT. AUTHORITY 245 E. HACIENDA AVENUE 3331 NORTH FIRST STREET, BLDG B-2 CAMPBELL, CA 95008 SAN JOSE, CA 95134

JEROME CARMAN SOPITSUDA TONGSOPIT SENIOR RESEARCH ENGINEER POLICY ANALYST SCHATZ ENERGY RESEARCH CENTER UNIVERSITY OF CALFIORNIA DAVIS 1 HARPST STREET 1715 TILIA STREET ARCATA, CA 95521 DAVIS, CA 95616

DELPHINE HOU KIM PEREZ CA INDEPENDENT SYSTEM OPERATOR CORP. CALIFORNIA ISO 250 OUTCROPPING WAY 250 OUTCROPPING WAY FOLSOM, CA 95630 FOLSOM, CA 95630



FOR: CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION

HANNAH GOLDSMITH LIET LE LEAD ADVISOR CALIFORNIA ENERGY COMMISSION CA GOV OFFICE OF BUSINESS & ECONIMIC DEV 1516 NINTH STREET ZERO EMISSION VEHICLE MARKET DEVELOPMENT SACRAMENTO, CA 95814 1325 J STREET, SUITE 1800 SACRAMENTO, CA 95814

MARISSA NAVA MATTHEW WILLIAMS BRAUN BLAISING SMITH WYNNE, PC CLEAN TRANSPORTATION INCENTIVES 915 L STREET, STE 1480 CALIFORNIA AIR RESOURCES BOARD SACRAMENTO, CA 95814 1001 I STREET SACRAMENTO, CA 95814

SCOTT BLAISING REGULATORY CLERK COUNSEL BRAUN BLAISING SMITH WYNNE, PC BRAUN BLAISING SMITH WYNNE P.C. 915 L STREET, STE. 1480 915 L STREET, SUITE 1480 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814

NOEL CRISOSTOMO ELI MORRIS AIR POLLUTION SPECIALIST PACIFICORP CALIFORNIA ENERGY COMMISSION 825 NE MULTNOMAH, STE. 2000 FUELS & TRANSPORTATION DIVISION PORTLAND, OR 97232 1516 9TH STREET MS-6 SACRAMENTO, CA 95874

POOJA KISHORE MGR - REGULATORY AFFAIRS PACIFICORP 825 NE MULTNOMAH, STE. 2000 PORTLAND, OR 97232

TOP OF PAGE BACK TO INDEX OF SERVICE LISTS



STATE OF CALIFORNIA · No, distribution automation must be safeguarded for security in order to...

Documents

Transcript of STATE OF CALIFORNIA · No, distribution automation must be safeguarded for security in order to...