opening comments (3-12-12) · opening comments on the proposed decision (pd) of administrative law...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Order Instituting Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term Procurement Plans.

)))

Rulemaking 10-05-006 (Filed May 6, 2010)

OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E) ON

PROPOSED DECISION OF ADMINISTRATIVE LAW JUDGE PETER ALLEN

JENNIFER TSAO SHIGEKAWA CAROL A. SCHMID-FRAZEE MELISSA A. HOVSEPIAN

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1337 Facsimile: (626) 302-1935 E-mail:Carol [email protected]

Dated: March 12, 2012

SUBJECT INDEX OF RECOMMENDATIONS Pursuant to the California Public Utilities Commission’s Rules of Practice and Procedure

14.3(b), Southern California Edison Company provides its index of recommended changes to the

Proposed Decision (PD) of Administrative Law Judge Peter Allen, dated February 21, 2012:

The PD adopts special rules for power purchases from Once Through Cooling (OTC) facilities that disadvantage Investor Owned Utilities’ (IOUs) customers in purchasing Resource Adequacy (RA) benefits contrary to the “equal rules” provisions of Senate Bill (SB) 695.

o The Commission should modify the PD to allow contracts with OTC facilities for terms of less than 5 years without pre-approval through Tier 3 Advice Letter, provided the contract term does not extend beyond the applicable State Water Resources Control Board (SWRCB) deadline.

The PD limits the IOUs’ ability to manage customer Greenhouse Gas (GHG) cost exposure inconsistent with current Commission rules for other energy-related procurement. The Commission should modify the PD:

o To provide for year-end positions limits for GHG compliance instruments based on the IOUs’ compliance obligation, contractual obligation, and electricity market exposure, and not just on the IOUs’ compliance obligation alone.

o To provide for either no minimum procurement limit or a minimum limit that applies only apply to the IOU’s compliance obligation (as opposed to the IOU’s total GHG exposure).

o To allow the IOUs to bilaterally transact for GHG allowances directly and through approved exchanges and brokers, instead of just formal Requests for Offers (RFOs).

o To allow IOUs to purchase GHG compliance instruments without a seller guarantee against invalidation and to sell GHG compliance instruments without Tier 2 Advice Letter approval.

o To eliminate the requirement that sellers assume the risk of GHG offset invalidation.

o To allow the IOUs to limit purchase of GHG offsets to 8% in each compliance period rather than annually.

o To eliminate the requirement that IOUs purchase only certified GHG offsets, and require instead that the IOUs’ GHG offset contracts provide for certification of the GHG offsets before the IOUs accept delivery and make payment.

The Commission should modify the PD to eliminate inappropriate limitations on future IOU Certificate of Public Convenience and Necessity (CPCN) Applications for generation resources.

The Commission should modify the PD to allow for a 14-day compliance period to submit Procurement Review Group (PRG) meeting summaries with a possible one-week extension.

The Commission should modify the PD to remove the inappropriate order to enter into contract negotiations to modify existing contracts to cover cost recovery of GHG compliance costs without clear evidence the sellers could not have anticipated the need to recover GHG compliance costs and will be significantly harmed without the contract amendment.

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TABLE OF AUTHORITIES (Sample)

State Statutes

California Public Utilities Code

§ 365.1(c)(1) ..............................................................................................................................2,3

§ 454.5(b)(7) ..............................................................................................................................3,8

California Administrative Regulations Title 20, California Code of Regulations,

Rule 14.3(b) .........................................................................................................................1

California Public Utilities Commission Decisions

D.12-01-033 .........................................................................................................................8

D.03-12-062 .........................................................................................................................8

D.02-10-062 .........................................................................................................................8

D.88-12-083 .......................................................................................................................13

California Legislation

AB 57 ...................................................................................................................................8

SB 695 ...............................................................................................................................2,3

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Order Instituting Rulemaking to Integrate and Refine Procurement Policies and Consider Long-Term Procurement Plans.

)))

Rulemaking 10-05-006 (Filed May 6, 2010)

OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E) ON

PROPOSED DECISION OF ADMINISTRATIVE LAW JUDGE PETER ALLEN

I. INTRODUCTION AND EXECUTIVE SUMMARY

Pursuant to Rule 14.3 of the California Public Utilities Commission’s (CPUC or Commission)

Rules of Practice and Procedure, Southern California Edison Company (SCE) hereby submits its

Opening Comments on the Proposed Decision (PD) of Administrative Law Judge (ALJ) Peter Allen,

dated February 21, 2012. SCE supports the PD’s adoption of the Track I Settlement Agreement, but

finds some legal, factual, and technical errors in the PD regarding certain Track III issues and, therefore,

urges the Commission to modify the PD as summarized in the Subject Index of Recommendations. Of

paramount importance to SCE, the Commission should modify the PD to allow Investor Owned Utilities

(IOUs) to enter into contracts of less than 5 years with Once Through Cooling (OTC) facilities ending

earlier than the State Water Resources Control Board (SWRCB) compliance deadline without

Commission pre-approval. Of critical importance to SCE, the Commission should modify the PD to

allow the IOUs to sell Greenhouse Gas (GHG) compliance instruments (allowances and offsets) without

Tier 2 Advice Letter approval and to transact for GHG compliance instruments within year-end position

limits based on the IOUs’ compliance obligation, contractual obligation, and electricity market

exposure, not just on the IOUs’ compliance obligation alone. In addition, the PD should be modified:

(1) to allow the IOUs to transact for GHG allowances through authorized exchanges and brokers, like

they do for other products, and (2) to purchase GHG offsets without a seller guarantee against

invalidation.

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II. THE COMMISSION SHOULD MODIFY THE PD TO PROVIDE FOR EQUAL TREATMENT

OF OTC POWER PURCHASE AGREEMENTS

The PD limits the IOUs’ ability to sign Power Purchase Agreements (PPAs) with OTC facilities,

including that all such PPAs for less than five years are subject to a Tier 3 Advice Letter review, and

PPAs of five years or more are subject to Application review.1 These limits also include requiring terms

ending no later than the SWRCB compliance deadline. SCE agrees that it should not commit to

purchase from OTC facilities beyond the SWRCB compliance deadline. SCE also does not object to

PPAs with OTC facilities with terms of five years or more being subject to Commission pre-approval.

However, the Commission should modify the PD to eliminate Tier 3 Advice Letter review of PPAs with

OTC facilities of less than 5 years ending no later than the SWRCB compliance deadline. SCE explains

below why this change is in its customers’ best interests.

OTC facilities constitute about 40% of the installed generating capacity in California.2 OTC

facilities located within SCE’s service territory play a crucial role in satisfying the California

Independent System Operator’s (CAISO) local area capacity requirements. In addition, these facilities

provide to CAISO much needed flexible capacity attributes such as ramping, load and intermittent

generation following, and regulation. While SCE supports State policy to phase-out OTC at non-nuclear

coastal facilities, restricting the IOUs’ ability to sign PPAs with OTC facilities before their SWRCB

compliance deadlines is contrary to SB 695 and will unnecessarily and adversely impact grid reliability,

competitive markets, and customer costs.

A. The PD Is Inconsistent With The SB 695 Equal Rules Requirement

The PD’s special rules for the IOUs’ PPAs with OTC facilities are inconsistent with the SB 695

requirement that all providers must have equal rules for procurement of RA benefits. Senate Bill (SB)

695, at Public Utilities Code Section 365.1(c)(1), states:

Once the commission has authorized additional direct transactions pursuant to subdivision (b), it shall do both of the following: (1) Ensure that other providers are

1 PD, pp.16-26. 2 Exhibit 211, p.9, lines 4-6.

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subject to the same requirements that are applicable to the state’s three largest electrical corporations under any programs or rules adopted by the commission to implement the resource adequacy provisions of Section 380,...

PPAs with OTC facilities would convey RA benefits, and, in the case of OTC facilities located within

the SCE service territory, local area RA capacity. The PD restricts the IOUs’ ability to enter into PPAs

with OTC facilities, including a Commission pre-approval requirement for PPAs that could increase

customers’ costs by introducing an unnecessary risk premium in the procurement process. Other

providers would benefit from this policy because their PPAs would not be subject to these restrictions,

and they could contract with OTC generators without the need for lengthy regulatory review. This gives

other providers an unfair competitive advantage in acquiring the RA benefits from these OTC facilities

to the detriment of the IOUs’ bundled customers. This is contrary to the meaning and intent of SB 695.

The Commission should eliminate the unnecessary restrictions on the IOUs’ ability to contract with

OTC generators for less than 5 years.

B. The PD Would Create Undue Risk for Customers, While Seriously Harming Competitive Markets And Grid Reliability

The PD inappropriately seeks to require pre-approval of PPAs with terms of less than five years

between the IOUs and OTC facilities.3 From a policy perspective, implementing such a requirement for

a large proportion of facilities which provide RA benefits in California is not practical, and is arguably

inconsistent with the intent that a procurement plan contain “upfront standards and criteria” for

procurement transactions.4 For OTC facilities which are presently operating in compliance with

applicable law, the PD should not impose procurement requirements different from those applicable to

other generating facilities, without clearly stating the value of doing so to SCE’s customers. Restrictions

on PPAs with OTC facilities negatively affect SCE’s ability to timely and cost-effectively enter into

PPAs for local area RA, as OTC facilities provide much of the local area RA in SCE’s service territory.

Moreover, because the PD does not define the scope of contractual arrangements that are captured under

a PPA, the PD’s OTC contracting restriction potentially precludes all market transactions with OTC

facilities (without pre-approval), including spot energy transactions, which is micro-management of the

utility procurement process in a manner that has not been justified.

3 PD, pp.16-26. 4 Public Utilities Code Section 454.5(b)(7).

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The PD also creates undue risks for IOU customers. Owners of OTC units, knowing that any

PPAs signed with IOUs would be subject to a lengthy pre-approval process, may place a risk premium

on their prices, because their prices would need to stay open and binding for an extended period. This

risk premium would compensate the seller for the risk that the Commission might not timely approve the

PPA or might ultimately reject it, as well as the opportunity cost of potentially selling the capacity at

higher prices if market prices increase by the time of final PPA approval. OTC facilities may also

choose not to contract with the IOUs because they do not want to keep their bids open for several

months waiting for Commission approval. Instead, they could petition the CAISO for an “at risk of

retirement” designation pursuant to the CAISO’s Capacity Procurement Mechanism (CPM) and try to

obtain a CPM award at a tariff-based rate, which might be substantially higher than what SCE could

have obtained through competitive solicitations.

SCE frequently conducts competitive solicitations to procure generating capacity it needs to meet

bundled customer energy requirements and system and local area RA requirements. SCE conducts

these competitive solicitations pursuant to SCE’s Commission-adopted AB 57 Bundled Procurement

Plan (Bundled PP). Given the volatile prices in the electricity markets, market participants generally

require SCE to select the winning bidders in its competitive solicitations very shortly after submission of

the binding final offers. The PD’s restrictions on PPAs with OTC facilities will largely prevent OTC

facilities from participating in SCE’s competitive solicitations because their bids cannot be awarded at

the same time as non-OTC generators whose PPAs do not require Commission approval. If a large

percentage of generating capacity within SCE’s service territory does not participate in SCE’s

competitive solicitations, the size of the “competitive market” from which SCE can procure capacity

will shrink to the detriment of its customers. Also, municipal utilities, Electric Service Providers,

Community Choice Aggregators, banks, merchant energy companies, and other potential off takers not

subject to these additional contracting restrictions or lengthy Commission review and approval of their

PPAs would gain a competitive advantage in obtaining contracts with these parties at the expense of

IOU customers.

Additionally, if the OTC units cannot fully recover their costs because of the limitations on

contracting with the IOUs, some may prematurely retire. “Their premature retirement would remove

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some supply of ancillary services and increase the cost and difficulty of integrating new and higher

levels of renewable generation.”5

The PD’s pre-approval requirement for the IOUs’ PPAs with OTC facilities is unnecessary and

imposes additional costs on IOUs’ bundled customers. It is sufficient to preclude IOUs from contracting

with OTC facilities not in compliance with SWRCB OTC policy. Also, contrary to PD

recommendations,6 the IOUs should not have to show how their PPAs with OTC facilities help facilitate

compliance with SWRCB policy and do not prolong OTC operation. SWRCB policy is binding on the

OTC facilities. The Commission should let SWRCB enforce its policies without relying on restrictions

on IOU procurement activities.

Finally, the PD’s limits are not likely to have the intended consequences for many OTC

facilities. In Exhibit 211, SCE highlighted that existing long-term contracts for significant amounts of

OTC capacity may negate some of the policy’s intent.7 For example, J.P. Morgan has a tolling contract

through May 2018 with roughly 4000 MW of OTC capacity owned by AES Southland.8 Although the

PD’s limits would make it more challenging for SCE to enter into contracts with OTC facilities, it would

not likely result in early compliance with OTC regulations for these facilities.

C. Pre-Approval Of OTC Facilities Contracts Is Inconsistent With RA Compliance Timelines

It is not feasible from a RA compliance timeline perspective that IOUs file Tier 3 Advice Letters

if they select OTC units through approved procurement processes to meet RA compliance obligations.

Current RA compliance rules require Load Serving Entities to submit compliance filings demonstrating

procurement of 90% of their System and 100% of their Local RA Requirements by October 31 of each

year. The IOUs receive final System and Local RA requirements for the compliance year in September.

This provides less than 2 months to complete any necessary RA procurement and receive Commission

approval of the advice letter by October 31. In addition, IOUs must file monthly RA compliance filings

demonstrating that they meet 100% of their System RA requirements and two Local true-up filings each

year to account for load migration under SB 695.

5 Exhibit 211, p.10, lines 18-20. 6 PD, p. 24. 7 Exhibit 211, p.11, lines 12-16. 8 See Capacity Sales and Tolling Agreement by and among AES Alamitos, LLC, AES Huntington Beach, LLC, AES

Redondo Beach LLC, and Williams Energy Service Company available at http://www.cers.water.ca.gov//pdf_files/power_contracts/williams/111902wllmsPPA.pdf.

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The PD’s proposed use of a Tier 3 Advice Letter process for contracts with OTC units would

impose a compliance burden far in excess of the IOUs’ available time to complete procurement to meet

RA compliance requirements and to manage any additional RA exposure resulting from Direct Access

migration and other load and supply updates. Under the PD, the IOUs could not use OTC units: (1) to

complete their Year Ahead procurement after receiving final RA requirements in September; (2) to

finalize procurement in order to meet Month Ahead RA requirements; and (3) to manage Standard

Capacity Product risks in the CAISO markets by procuring replacement RA capacity on short-notice.

Finally, OTC units are essential to meeting Local RA capacity requirements within the Los

Angeles Basin and San Diego Local Areas. OTC units represent over 70% and 55% of the total current

LA Basin and San Diego supply, respectively. The PD’s requirements could make IOUs unable to meet

Year Ahead Local RA requirements in some Local Areas. Therefore, the Commission should not require

the use of RFOs instead of other bilateral transactions.

III. THE PD IMPOSES UNREASONABLE LIMITATIONS ON GHG COMPLIANCE ACTIVITIES

A. Establishing Limits Based Solely On IOUs’ Compliance Obligation Potentially Puts Customers At Great Risk When GHG Prices Fluctuate

The PD at p. 54 erroneously establishes GHG procurement limits for the IOUs for the anticipated

compliance period obligations. This could limit the IOUs to obtaining GHG compliance instruments for

just utility-owned generation (UOG) and imported electricity for which SCE is the importer. As

described in SCE’s July 1, 2011 Greenhouse Gas Procurement Plan (GHG PP),9 SCE customers’ total

exposure to GHG prices includes SCE’s compliance obligation, contractual obligation (e.g., the GHG

obligation SCE takes on through tolling and other contracts), and electricity market price exposure

(essentially contracts for future customer electricity needs that have not yet been entered into). The

IOUs generally, and SCE specifically, have small direct GHG compliance obligations10. In particular,

SCE’s direct compliance obligation is very small relative to the sum of its contractual obligations and

9 Exhibit 210, pp.4-5. 10 As a result of electricity deregulation the IOUs sold most of their thermal generating resources. After the planned sale of

SCE’s share of the Four Corners Generating Station to Arizona Public Service in October. SCE will have only five GHG emitting UOG resources totaling approximately 1,260 MW to serve a peak bundled customer load of approximately 23,000 MW (Mountainview Generating Station (~1050 MW), four peakers (~200 MW total) and Pebbly Beach Generation Station (~10MW) on Catalina Island).

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electricity market price exposure from residual net short energy positions and QF contracts settling

monthly based on market heat rates. The Commission must modify the PD to apply the position limits

to the sum of these exposures and not just the compliance obligation portion. Without this procurement

ability, the IOUs will have no way of managing customer costs for a large portion of their GHG

exposure due to fluctuating GHG prices.

B. RFO Processes To Purchase GHG Compliance Instruments Are Unnecessary

The PD erroneously requires that “[t]o the extent that the utilities wish to procure authorized

compliance instruments via bilateral transactions (including brokers), the [IOUs} must utilize a

competitive RFO process, consult with their Procurement Review Group (PRG), apply their approved

procurement credit and collateral requirements, and apply the applicable affiliate transaction rules.”11

The PD’s RFO process requirement, in place of bilateral negotiations, to purchase GHG compliance

instruments outside of the California Air Resources Board (ARB) auction is costly and unnecessary.

Conducting RFOs for GHG compliance instruments adds bureaucracy and cost to procurement

processes. RFOs require the use of an Independent Evaluator, development of a web site, bidders’

conferences, stakeholder calls, and numerous communication requirements. RFOs are also very time-

consuming and do not allow the IOUs to transact in spot markets which may provide lower cost options.

The PD’s only rationale for requiring RFOs was that this process would be similar to generation

resource procurement.12 However, one of the main rationales for holding RFOs is to create liquidity for

products that are not traded, such as generation resources. Generation resources are not transacted in the

traded markets specifically because each generation resource has unique capabilities, efficiencies and

operating restrictions, all of which must be negotiated and valued. In contrast to these highly structured

products, commoditized products, like California GHG allowances of a given vintage, are only

distinguished by one attribute: price. This standardization makes them ideally suited to be efficiently

transacted in the traded markets. In fact, California GHG allowance forwards have been trading

bilaterally and through brokers since 2010 and through exchanges for over six months. Requiring an

RFO each time an IOU seeks to transact GHG compliance instruments outside of an ARB auction, or

through an approved exchange whether it is for Least Cost Dispatch, immediate compliance need, or

longer term customer risk mitigation, is an unnecessary use of resources and will not be feasible in many

11 PD, p. 51. 12 Id.

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instances due to the time required. It is also inconsistent with the existing, well-functioning AB 57

procurement framework and will only lead to increased customer cost and risk.

C. Limitations On Transactions Of GHG Compliance Instruments Are Inconsistent With

Existing Procurement Practice

1. AB 57 Upfront Standards And Criteria Apply For Transactions For Other Products

AB 57, at Public Utilities Code 454.5(b)(7), requires an IOU’s procurement plan to include

“upfront standards and criteria by which the acceptability and eligibility for rate recovery of a proposed

procurement transaction will be known by the electrical corporation prior to execution of the

transaction.” The Bundled PP, adopted in D.12-01-033 in Track II of this 2010 Long Term Procurement

Plan (LTPP) proceeding, adopted upfront standards and criteria for procurement transactions associated

with electrical energy and capacity, natural gas, and other related products in compliance with AB 57.

This Bundled PP has well-established limits and protocols for bilateral, brokered and exchange-traded

transactions. Without citing any issues around these existing frameworks, and also expressing a desire

that “…a liquid and transparent market in greenhouse gas compliance products”13” develops, the PD

unreasonably and inconsistent with the Bundled PP framework eliminates these methods as procurement

options for GHG compliance instruments.

The Bundled PPs allow the IOUs to use direct bilateral contracting subject to a “strong

showing14” requirement that these transactions represent a reasonable approximation of what a

transparent competitive market would produce.15 Direct bilateral transactions are a proven procurement

method and potentially provide the IOUs with lower cost procurement in certain circumstances. The

Commission should authorize this method of transaction for GHG compliance instruments, subject to

the existing strong showing standard.

The Bundled PPs also allow the IOUs to use reputable Over-the-Counter brokers,16 subject to a

showing that the identified OTC brokers provide prices equivalent to those of exchanges.17 Brokers

have been trading forwards on California GHG allowances since 2010 and have provided the most

13 PD at p. 50. 14 D.03-12-062 at 39. 15 D.02-10-062 at 34. 16 D.03-12-062 at 27. 17 D.03-12-062 at 27.

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liquid markets for offsets. The Commission should treat brokered transactions for GHG compliance

instruments exactly as it treats brokered transactions for power, natural gas, and SO2 allowances in the

IOUs’ Bundled PPs. There is no identified benefit to restricting the IOUs from using brokers for GHG

instruments. Several brokers, including Evolution, Amerex, Tradition Financial Services (TFS), among

others, are already well-established in emissions markets, and SCE is already approved to transact

power, natural gas and SO2 with these brokers.18 The Commission also previously authorized the use of

electronic trading exchanges for energy procurement. The PD inexplicably, and inconsistent with the

Bundled PPs, requires a separate Tier 2 Advice Letter filing to approve already Commission-approved

(for other energy procurement) GHG procurement processes.

In its GHG PP, SCE specifically asked the Commission to authorize the use of three new

exchanges for GHG products: Blue Next, GreenX, and the Pacific Carbon Exchange. The market for

GHG allowances has evolved substantially since submission of the GHG PP. Two exchanges have

come to the forefront and are actively trading California GHG allowance futures: Intercontinental

Exchange (ICE) and GreenX.19 ICE is already well-established in the energy markets, and as a

Commission authorized exchange under the Bundled PP. SCE uses ICE extensively for transacting

power, natural gas, and derivative products. GreenX is owned by a consortium of CME Group, banks

and emissions brokers. GreenX is well-established in the European Cap-and-Trade program. To help

fulfill the Commission’s hope that functional and liquid exchanges will develop quickly,20 the

Commission should authorize SCE to use these two exchanges to execute transactions of approved GHG

products. Requiring Tier 2 Advice Letter review of these exchanges from the GHG PP adds a new layer

of unnecessary bureaucracy that may impede the development of “liquid exchanges.”

2. The PD Unreasonably Constrains Selling Of GHG Compliance Instruments Putting

IOU Customers at Significant Financial Risk

The PD foresees occurrences when sales of GHG compliance instruments benefit customers,

stating: “…it may at times be beneficial to ratepayers and to the market for the utilities to sell

allowances or other compliance instruments, particularly if actual emissions turn out to be lower than

18 AB57 Bundled PP, Exhibit 200 (SCE-1), Rev. 1, April 20, 2011) p.44 referring to Exhibit 201 (SCE-2, Rev. 1, Apri20, 2011) p.E-1.

19 BlueNext and the Pacific Carbon Exchange do not appear to be currently active in California’s Cap-and-Trade program. 20 PD, p.51.

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forecast.”21 Inexplicably, the PD then limits the IOUs’ ability to sell GHG compliance instruments by

requiring a Tier 2 Advice Letter for such sales.22 This constraint puts IOU customers at significant risk.

Specifically, the PD’s limits on GHG compliance instrument sales could prevent the IOUs from

hedging the risk of electricity price spikes due to GHG price increases. Without this GHG compliance

instrument sales limitation, SCE could purchase GHG compliance instruments to lock in a GHG price

for a portion of its projected market price exposure. SCE could, then, sell GHG compliance instruments

when it procures energy products, thereby limiting the GHG cost component of the energy products to

SCE’s hedged GHG price (i.e., the sale of the GHG compliance instrument acts like a contract for

differences for the GHG cost component of the purchased energy product). Given SCE’s large

electricity market price exposure, a Tier 2 Advice Letter review for GHG compliance instrument sales

exposes SCE customers to a cost risk that SCE could otherwise manage effectively. The Commission

should avoid this unintended consequence and allow the IOUs to sell GHG compliance instruments

without Tier 2 Advice Letter review. Doing so would allow the IOUs to more cost effectively manage

the risks to bundled customers associated with the IOUs’ residual net short electrical positions. In

addition to this significant risk, there are other problems with this restriction.

The Tier 2 Advice Letter review requires a purchaser to hold its bid to purchase open until

Commission approval. Purchasers are highly unlikely to hold offers open for months at a time awaiting

such approval. No party can cost-effectively transact in a commodity subject to a lengthy approval

process. In effect, the PD precludes the IOUs from selling GHG compliance instruments.

Finally, the PD cites preventing speculation23 as a potential reason for requiring pre-approval of

GHG compliance instrument sales, but it is well-established that the IOUs are not permitted to speculate.

Indeed, under the Commission’s framework for energy procurement, IOU shareholders have no

opportunity to profit from these activities – whereas they are exposed to penalties (disallowances) if the

Commission finds the IOU’s actions to be non-compliant with its authorized Bundled PP. As a result,

this argument is specious at best. Without the ability to readily procure and sell GHG compliance

instruments, the IOUs will not be able to cost effectively manage their GHG obligations or their

customer’s risk to fluctuating GHG prices. It is not clear what risk the PD is trying to cover with this

costly and burdensome requirement that is not already addressed by existing requirements.

21 PD, p.52. 22 PD, p.51. 23 PD, p.52.

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3. Constraints On Transactions For GHG Offsets Limits Potential Customer Cost

Savings And Creates Opportunities For Third Parties

The PD unreasonably limits the purchase of GHG offsets to no more than 8% of annual

compliance requirements 24. This is inconsistent with ARB’s approach applying the limit to its approved

compliance period, which can be 2-3 years. The annual compliance period restricts potential customer

cost savings by reducing the IOUs’ flexibility to secure lower cost offsets over the longer ARB

compliance period. The Commission should remove this additional annual restriction, as unjustified.

Furthermore, the Commission should apply this limit to not only the IOU’s compliance obligation, but

also to its contractual obligation. This will allow the IOUs to transfer potentially less expensive offsets

to contractual counterparties to fulfill up to 8% of their contractual obligation per compliance period.

The Commission should modify the PD to eliminate the requirement that the IOUs can only

purchase certified GHG offsets and, instead, require the IOUs’ GHG offset contracts to provide for

certification of the GHG offsets before the IOUs accept delivery and make payment. This mitigates

customers’ risks while offering the IOUs the opportunity to sign forward contracts for GHG offsets,25

which will help promote the development of GHG emissions reduction projects. The PD constrains

procurement of GHG offsets because the hedging cost for the open-ended risk of subsequent

invalidation of a GHG offset may be greater than the invalidation risk itself. SCE’s proposed solution

mitigates customers’ risks while preserving the GHG offsets’ benefits of providing potentially lower

cost GHG compliance than GHG allowances.

The Commission should modify the PD to eliminate the requirement that the IOUs can only

purchase GHG offsets if the seller assumes the risk of invalidation. Such a requirement would transfer

the benefits of purchasing GHG offsets from the IOUs’ bundled customers to third parties such as banks

and traders who would purchase the GHG offsets and accept the risk of invalidation, but increase the

price of offsets accordingly. Furthermore, it is likely that a requirement for sellers to assume the risk of

invalidation will hinder the development of a robust and liquid offset market.

D. The PD Undermines Least Cost Dispatch Of Generation Resources

By precluding the IOUs from purchasing GHG compliance instruments on a spot basis, the PD

undermines Least Cost Dispatch of generation resources subject to the Cap-and-Trade program. The

24 PD, p.41. 25 GHG offsets are only certified by CARB after the fact .

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IOUs transact in the hour-ahead and day-ahead energy markets, pursuant to their Bundled PPs, to cost

effectively serve their bundled customers pursuant to Least Cost Dispatch principles. One element of

the cost of energy purchased in those spot energy markets will be the GHG compliance cost. As SCE

transacts in the energy market, it has to factor in and “lock in” GHG compliance costs. For example,

SCE regularly imports power as a cheaper alternative to generating it from SCE’s supply portfolio or

purchasing from the CAISO.26 Once Cap-and-Trade is implemented on January 1, 2013, SCE will, in

addition to incurring the cost of importing this power, such as lines losses, CAISO import fees and

congestion costs, also incur the GHG compliance cost for this power. Without the ability to purchase

GHG compliance instruments in the spot market to lock in SCE’s assumed GHG costs, SCE will be

unable to ensure a cost savings from import energy purchases and, therefore, will be unable to comply

with Commission-required Least Cost Dispatch, Precluding SCE from transacting GHG compliance

products in the spot market prevents SCE from locking in its GHG costs and will lead to inefficient

procurement because the actual settlement cost of GHG compliance will differ from SCE’s assumptions.

E. The PD Establishes Procurement Limits That May Create Compliance Conflicts With Both ARB And Commission Rules

The PD, at p. 53, implements a “band approach” to procurement limits for compliance

instruments. SCE does not oppose this approach, but cautions that, depending on the basis for the limits,

the minimum limit may conflict with ARB’s holding account limits, and the maximum limit may be in

sufficient for the IOUs to adequately manage their customers’ risk to fluctuating GHG prices. The

Commission should adopt either no minimum procurement limit or have the minimum limit only apply

to the IOU’s compliance obligation (as opposed to the IOU’s total GHG exposure). However, the

maximum limit should be applied to the IOU’s total forecasted GHG exposure, which includes the

compliance obligation, contractual obligation, and electricity residual net-short position exposure.

The PD, at p. 54, erroneously establishes procurement limits for GHG compliance instruments

for the IOUs. The Commission should modify the PD to refer to year-end position limits. Establishing

procurement limits would limit the IOUs to the purchase of GHG compliance instruments only. The

Commission should modify the PD to refer to position limits (i.e., a net amount of GHG compliance

instrument purchases and sales) to accommodate sales of GHG compliance instruments. The

Commission should adopt a year-end position limit to determine that the IOUs’ trading activities over

26 It is well known that California is a large net importer of electricity.

-13-

the year do not result in a balance of GHG compliance instruments exceeding the year-end position

limits. Not doing so would also put the IOUs immediately out of compliance with any minimum

procurement requirements upon issuance of a final decision if the minimum requirement is not zero.

IV. THE PD ERRS BY ATTEMPTING TO IMPOSE LIMITATIONS ON IOUS’ FUTURE CPCN

APPLICATIONS

The PD proposes to: (1) require proof of a failed RFO before an IOU can file a CPCN; and (2)

adopt a cost cap for future CPCN application.27 First of all, no Commission can bind future

Commissions.28 So, to some extent, having the Commission create rules for future consideration of IOU

CPCN applications is not constructive. Second, these restrictions on future CPCN applications are

unprecedented and unnecessary, as the Commission can better determine for any future CPCN

application submitted whether to accept it, and if accepted, what the appropriate cost recovery

mechanisms should be in the context of that application. Trying to tie the hands of future Commissions

could harm the reliability of the electric grid if actions need to be taken quickly and are somehow

impeded by these rules. It is not possible to know today what circumstances may arise that would

benefit from a CPCN application for new generation capacity, notwithstanding the feasibility of an RFO.

A. Proof Of Failed RFO Before CPCN Is Filed Threatens The Ability To Meet Critical Needs

The PD errs by insisting on proof of a failed RFO before a CPCN can be filed.29 There are

certain instances in which a failed RFO simply doesn’t make sense before a CPCN can be filed. For

example, when action must be taken immediately to avoid extended rolling blackouts in a portion of the

system, requiring a failed RFO before a utility can file a CPCN increases the likelihood and length of

time of such blackouts. In that event, it does not make sense to have customers experience the rolling

blackouts in order to provide time for a failed RFO. Such a requirement unreasonably threatens the

ability of the state to meet critical needs, and it isn’t necessary for the Commission to adopt such a rule

in this 2010 LTPP. A more reasoned public policy is to allow future Commissions to consider future

CPCN applications on their own merits and require whatever prerequisites the Commission believes to

be reasonable at the time.

27 PD, pp. 27-37. 28 Application of PG&E re: Diablo Canyon, D.88-12-083, 30 CPUC 2d 189, 223. 29 PD, p.37.

-14-

B. Adoption Of Proposed Cost Cap For Future CPCNs Unnecessarily Prejudges Them

The PD proposes to adopt The Utility Reform Network’s (TURN) proposal that “critical cost

parameters” of the CPCN Application, including “initial capital costs, capital additions, fixed and

variable O&M, and heat rates,” be binding on the IOU for the first ten years of plant operation.30 This is

unnecessary and beyond the scope of this proceeding because the Commission’s review of CPCN

Applications was not at issue in this proceeding. The Commission has a well-established CPCN process

that includes parameters for UOG cost recovery. The Commission has not provided notice and

opportunity to be heard, pursuant to Public Utilities Code Section 1708, to all parties affected by the

CPCN process that it was intending to modify the CPCN process in this proceeding. As a result, it is

inappropriate and unnecessary for the Commission to make such a change in this docket.

V. SUBMISSION OF MEETING SUMMARIES HOURS BEFORE A PRG MEETING LIMITS

THE IOUS’ ABILITY TO CALL NECESSARY PRG MEETINGS ON SHORT NOTICE

The PD states that the meeting summary should be distributed on the earlier of 1) 14 days after

the PRG meeting, or 2) 48 hours before next PRG meeting. The PD also states that if due to unusual

circumstances, 14 days will be inadequate time to prepare a meeting summary, the utility may distribute

it 21 days after the PRG meeting, provided it sends an e-mail to the PRG participants seven days after

the PRG meeting informing them of the delay.

SCE supports the 14-day requirement, as well as the provision to seek a week-long extension of

this deadline if necessary. However, the “48 hours before next PRG meeting” requirement is very

problematic for several reasons and should be deleted. Typically, SCE schedules biweekly PRG

meetings throughout the year at the beginning of the year. In addition, when time-sensitive topics

warrant, SCE schedules additional ad-hoc PRG meetings in between these biweekly meetings. These ad

hoc meetings are sometimes scheduled with very little advance notice. If the Commission imposes a

requirement that PRG meeting summaries must be distributed the earlier of 1) 14 days after the subject

PRG meeting, or 2) 48 hours before the next PRG meeting, the clear implication would be that for SCE,

only the “48 hours before the next PRG meeting” deadline will be binding in all cases (because each of

SCE’s PRG meetings is scheduled 14 days after the previous PRG meeting) and furthermore, SCE will

face a crippling constraint in its ability to schedule ad hoc PRG meetings at short notice.

30 PD, pp.32-33.

-15-

SCE sees no reason why the Commission must adopt this dual set of deadlines, rather than

adopting a single 14-day deadline, with a provision to obtain a one-week extension if necessary. SCE

urges the Commission to limit the PRG summary requirement to a 14-day compliance period, with the

possibility of a one-week extension in certain circumstances.

VI. THE PD UNREASONABLY REQUIRES THE IOUS TO ENTER INTO NEGOTIATIONS TO

MODIFY EXISTING CONTRACTS

The PD grants IEP’s motion and orders IOUs to modify existing contracts. This order was based

solely on IEP’s assertion that the IOUs have non-QF contracts with generators entered into before cap-

and-trade was contemplated. No party has offered supporting testimony for IEP’s assertion and parties

have had no opportunity to test such testimony through cross-examination. Moreover, it has not been

established that insufficient “change of law” provisions do not exist in IOU contracts. It is unreasonable

for the Commission to order the IOUs to enter into negotiations to modify existing contracts without at

least tested record evidence that such negotiations are necessary. The Commission should modify the

PD to remove the inappropriate order to enter into contract negotiations to modify existing contracts to

cover cost recovery of GHG compliance costs without clear evidence that: (1) there are any such

existing contracts that warrant modifications, and (2) the sellers could not have anticipated the need to

recover GHG compliance costs and will be significantly harmed without the contract amendment.

VII. CONCLUSION

For all of the reasons stated above, SCE respectfully requests that the Commission modify the

PD as discussed in its Subject Index of Recommendations.

Respectfully submitted, JENNIFER TSAO SHIGEKAWA CAROL A. SCHMID-FRAZEE MELISSA A. HOVSEPIAN

/s/ Carol A. Schmid-Frazee By: Carol A. Schmid-Frazee

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

March 12, 2012

CERTIFICATE OF SERVICE

I hereby certify that, pursuant to the Commissioner’s Rules of Practice and Procedure, I have this

day served a true copy of OPENING COMMENTS OF SOUTHERN CALIFORNIA

EDISON COMPANY (U338-E) ON PROPOSED DECISION OF ADMINISTRATIVE

LAW JUDGE PETER ALLEN on all parties identified in the attached service list(s).

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

First class mail will be used if electronic service cannot be effectuated.

Executed this 12th day of March, 2012, at Rosemead, California.

/s/ Norma Perez____________________________ Norma Perez Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Ave. Post Office Box 800 Rosemead, California 91770

PROCEEDING: R1005006 - CPUC - OIR TO INTEGR FILER: CPUC LIST NAME: LIST LAST CHANGED: MARCH 8, 2012

DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES

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AUDREY CHANG DANIEL W. DOUGLASS EXE. DIR. DOUGLASS & LIDDELL CA ENERGY EFFICIENCY INDUSTRY COUNCIL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: WESTERN POWER TRADING FORUM / FOR: CALIFORNIA ENERGY EFFICIENCY DIRECT ACCESS CUSTOMER INDUSTRY COUNCIL COALITION/ALLIANCE FOR RETAIL ENERGY MARKETS/ MARIN ENERGY AUTHORITY DONALD C. LIDDELL JOSHUA ARCE DOUGLASS & LIDDELL BRIGHTLINE DEFENSE PROJECT EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: THE CALIFORNIA ENERGY STORAGE FOR: BRIGHTLINE DEFENSE PROJECT ALLIANCE/STARWOOD POWER MIDWAY, LLC JULIE GILL KENNETH SAHM WHITE AES SOUTHLAND FIT COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: AES FOR: FIT COALITION L. JAN REID ROBERT E. BURT EMAIL ONLY INSULATION CONTRACTORS ASSN. EMAIL ONLY, CA 00000 EMAIL ONLY FOR: L. JAN REID EMAIL ONLY, CA 00000 FOR: INSULATION CONTRACTORS ASSN.

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TAM HUNT LAURA WISLAND HUNT CONSULTING UNION OF CONCERNED SCIENTISTS EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000-0000 FOR: CLEAN COALITION FOR: UNION OF CONCERNED SCIENTISTS NANCY RADER JESSICA EVANS EXECUTIVE DIRECTOR DIR. - CUSTOMER CARE CALIFORNIA WIND ENERGY ASSOCIATION GLACIAL ENERGY OF CALIFORNIA, INC.(1377) EMAIL ONLY 24 ROUTE 6A EMAIL ONLY, CA 00000-0000 SANDWICH, MA 02563 FOR: CALIFORNIA WIND ENERGY ASSOCIATION FOR: GLACIAL ENERGY OF CALIFORNIA, INC. ABRAHAM SILVERMAN B. MARIE PIENIAZEK SR. COUNSEL, REGULATORY DEMAND RESPONSE & ENERGY CONSULTING, LLC NRG ENERGY, INC. 1328 BOZENKILL ROAD 211 CARNEGIE CENTER DRIVE DELANSON, NY 12053 PRINCETON, NJ 08540 FOR: ENERGY CURTAILMENT SPECIALISTS INC. FOR: NRG ENERGY, INC. KERRY HUGHES RICK C. NOGER DIRECT ENERGY BUSINESS, LLC (1351) PRAXAIR PLAINFIELD, INC. LIBERTY CENTER 2711 CENTERVILLE ROAD, SUITE 400 1001 LIBERTY AVENUE WILMINGTON, DE 19808 PITTSBURGH, PA 15222 FOR: PRAXAIR PLAINFIELD, INC. FOR: DIRECT ENERGY BUSINESS, LLC MELISSA DORN JAMES P. WHITE MCDERMOTT WILL & EMERY LLP TRANSCANADA CORPORATION 600 13TH ST. NW 4547 RINCON PLACE WASHINGTON, DC 20005 MONTCLAIR, VA 22025 FOR: MORGAN STANLEY CAPITAL GROUP INC. FOR: ZEPHYR POWER TRANSMISSION, LLC ANDREA SANTIAGO LORI NALLEY LIBERTY POWER HOLDINGS LLC (1371) CEO 1901 W. CYPRESS CREEK ROAD, SUITE 600 TIGER NATURAL GAS, INC. (1376) FORT LAUDERDALE, FL 33309 1422 E. 71ST, SUITE J FOR: LIBERTY POWER HOLDINGS, TULSA, OK 74136 LLC/LIBERTY POWER DELAWARE, LLC FOR: TIGER NATURAL GAS, INC. JASON ARMENTA MICHAEL J. RUFFATTO CALPINE POWERAMERICA-CA, LLC PRESIDENT 717 TEXAS AVENUE, SUITE 1000 ULTRAPOWER JASMIN, LP/ ULTRAPOWER POSO HOUSTON, TX 77002 8480 E. ORCHARD ROAD, STE. 4000 FOR: CALPINE POWERAMERICA-CA, LLC ENGLEWOOD, CO 80111 FOR: JASMIN RIO BRAVO & POSO RIO BRAVO BRIAN FICKETT BO BUCHYNSKY VALLEY ELECTRIC ASSOCIATION DIAMOND GENERATING CORPORATION 800 E. HWY 372 333 SOUTH GRAND AVE., SUITE 1570 PAHRUMP, NV 89048 LOS ANGELES, CA 90071 FOR: VALLEY ELECTRIC ASSOCIATION FOR: DIAMOND GENERATING CORPORATION



JERRY R. BLOOM MICHAEL MAZUR WINSTON & STRAWN, LLP 3 PHASES ELECTRICAL CONSULTING 333 SOUTH GRAND AVENUE, 38TH FLOOR 2100 SEPULVEDA BLVD., SUITE 37 LOS ANGELES, CA 90071-1543 MANHATTAN BEACH, CA 90266 FOR: CALIFORNIA COGENERATION COUNCIL FOR: 3 PHASES ELECTRICAL CONSULTING MICHAEL MAZUR INGER GOODMAN 3 PHASES RENEWABLES LLC (1373) COMMERCE ENERGY INC 2100 SEPULVEDA BLVD, SUITE 37 1 CENTERPOINTE DRIVE, SUITE 350 MANHATTAN BEACH, CA 90266 LA PALMA, CA 90623-2520 FOR: 3 PHASES RENEWABLES, LLC FOR: COMMERCE ENERGY AKBAR JAZAYEIRI CAROL SCHMID-FRAZEE DIR. REVENUE & TARIFFS, RM 390 SOUTHERN CALIFORNIA EDISON CO. SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE./PO BOX 800 PO BOX 800, 2241 WALNUT GROVE AVE ROSEMEAD, CA 91770 ROSEMEAD, CA 91770 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SOUTHERN CALIFORNIA EDISON COMPANY RONALD MOORE MARY C. HOFFMAN SR ANALYST, REGULATORY AFFAIRS PRESIDENT BEAR VALLEY ELECTRIC SOLUTIONS FOR UTILITIES, INC. 630 EAST FOOTHILL BOULEVARD 1192 SUNSET DRIVE SAN DIMAS, CA 91773 VISTA, CA 92081 FOR: GOLDEN STATE WATER/BEAR VALLEY FOR: SOLUTIONS FOR UTILITIES, INC. ELECTRIC AIMEE SMITH DANIEL A. KING SAN DIEGO GAS & ELECTRIC COMPANY SEMPRA GENERATION 101 ASH STREET, HQ-12 101 ASH STREET, HQ 14 SAN DIEGO, CA 92101 SAN DIEGO, CA 92101 FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: SEMPRA GENERATION DRAKE WELCH MARCIE MILNER SEMPRA ENERGY SOLUTIONS (1364) SHELL ENERGY NORTH AMERICA 401 WEST A STREET, SUITE 500 4445 EASTGATE MALL, SUITE 100 SAN DIEGO, CA 92101-3017 SAN DIEGO, CA 92121 FOR: SEMPRA ENERGY SOLUTIONS FOR: SHELL ENERGY NORTH AMERICA THOMAS R. DARTON GLORIA BRITTON PILOT POWER GROUP, INC. (1365) ANZA ELECTRIC CO-OPERATIVE, INC. 8910 UNIVERSITY CENTER LANE, STE. 520 58470 HIGHWAY 371 SAN DIEGO, CA 92122 ANZA, CA 92539-1909 FOR: PILOT POWER GROUP, INC. FOR: ANZA ELECTRIC CO-OPERATIVE, INC. TAM HUNT ANDREA MORRISON ATTORNEY DIRECT ENERGY SERVICES, LLC COMMUNITY ENVIRONMENTAL COUNCIL 415 DIXSON STREET 124 W. ALAMAR AVE., NO. 3 ARROYO GRANDE, CA 93420 SANTA BARBARA, CA 93105 FOR: DIRECT ENERGY SERVICES, INC, FOR: COMMUNITY ENVIRONMENTAL COUNCIL MONA TIERNEY-LLOYD DAVID ORTH



SENIOR MANAGER WESTERN REG. AFFAIRS SAN JOAQUIN VALLEY POWER AUTHORITY ENERNOC, INC. ADMIN OFF @KINGS RIVER CONSERV DISTRICT PO BOX 378 4886 EAST JENSEN AVENUE CAYUCOS, CA 93430 FRESNO, CA 93725 FOR: ENERNOC, INC. FOR: SAN JOAQAUIN VALLEY POWER AUTHORITY EVELYN KAHL SUE MARA ALCANTAR & KAHL, LLP CONSULTANT 33 NEW MONTGOMERY STREET, SUITE 1850 RTO ADVISORS, LLC SAN FRANCISCO, CA 94015 164 SPRINGDALE WAY FOR: ENERGY PRODUCERS AND USERS REDWOOD CITY, CA 94062 COALITION FOR: RTO ADVISORS, LLC MARC D. JOSEPH CHARLYN A. HOOK ADAMS BROADWELL JOSEPH & CARDOZO CALIF PUBLIC UTILITIES COMMISSION 601 GATEWAY BLVD. STE 1000 LEGAL DIVISION SOUTH SAN FRANCISCO, CA 94080 ROOM 5131 FOR: COALITION OF CALIFORNIA UTILITY 505 VAN NESS AVENUE EMPLOYEES SAN FRANCISCO, CA 94102-3214 FOR: DIVISION OF RATEPAYER ADVOCATES (DRA) MARYBELLE C. ANG SIERRA MARTINEZ STAFF ATTORNEY ATTORNEY THE UTILITY REFORM NETWORK NATURAL RESOURCES DEFENSE COUNCIL 115 SANSOME STREET, STE. 900 111 SUTTER STREET, 20TH FLOOR SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104 FOR: TURN FOR: NATURAL RESOURCES DEFENSE COUNCIL WILLIAM H. BOOTH DEBORAH N. BEHLES ALCANTAR & KAHL GOLDEN GATE UNIVERSITY SCHOOL OF LAW 33 NEW MONTGOMERY ST., STE. 1850 536 MISSION STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105-2968 FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: PACIFIC ENVIRONMENT ASSOCIATION (CLECA) BRIAN T. CRAGG VIDHYA PRABHAKARAN GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY DAVIS WRIGHT & TREMAINE LLP 505 SANSOME STREET, SUITE 900 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: INDEPENDENT ENERGY PRODUCERS FOR: CALIFORNIA PACIFIC ELECTRIC ASSOCIATION COMPANY LLC JEFFREY P. GRAY STEVEN F. GREENWALD DAVIS WRIGHT TREMAINE, LLP ATTORNEY AT LAW 505 MONTGOMERY STREET, SUITE 800 DAVIS WRIGHT TREMAINE LLP SAN FRANCISCO, CA 94111-6533 505 MONTGOMERY STREET, SUITE 800 FOR: CALPINE CORPORATION SAN FRANCISCO, CA 94111-6533 FOR: CAPITAL POWER CORPORATION LISA A. COTTLE CHARLES R. MIDDLEKAUFF WINSTON & STRAWN LLP PACIFIC GAS AND ELECTRIC COMPANY 101 CALIFORNIA STREET, 39TH FLOOR 77 BEALE STREET, B30A SAN FRANCISCO, CA 94114 SAN FRANCISCO, CA 94120 FOR: GENON CALIFORNIA NORTH, LLC FOR: PACIFIC GAS AND ELECTRIC COMPANY



(FORMERLY MIRANT CALIFORNIA, LLC) SARA STECK MYERS BRIAN CHERRY ATTORNEY AT LAW PACIFIC GAS AND ELECTRIC COMPANY 122 - 28TH AVENUE PO BOX 770000, B10C SAN FRANCISCO, CA 94121 SAN FRANCISCO, CA 94177 FOR: CENTER FOR ENERGY EFFICIENCY AND FOR: PACIFIC GAS & ELECTRIC COMPANY RENEWABLE TECHNOLOGIES (CEERT) MICHAEL ROCHMAN JENNIFER CHAMBERLIN MANAGING DIRECTOR LS POWER DEVELOPMENT, LLC SCHOOL PROJECT UTILITY RATE REDUCTION 5000 HOPYARD ROAD, SUITE 480 1850 GATEWAY BLVD., STE. 235 PLEASANTON, CA 94588 CONCORD, CA 94520 FOR: LS POWER ASSOCIATES, L.P. FOR: SCHOOL PROJECT FOR UTILITY RATE REDUCTION JOSEPH F. WIEDMAN PAUL CORT ATTORNEY EARTHJUSTICE KEYES & FOX LLP 426 17TH STREET, 5TH FLOOR 436 - 14TH STREET, SUITE 1305 OAKLAND, CA 94612 OAKLAND, CA 94612 FOR: SIERRA CLUB CALIFORNIA FOR: INTERSTATE RENEWABLE ENERGY COUNCIL SHANA LAZEROW WILLIAM B. ROSTOV ATTORNEY EARTHJUSTICE COMMUNITIES FOR BETTER ENVIRONMENT 426 17TH STREET, 5TH FLOOR 1904 FRANKLIN STREET, STE 600 OAKLAND, CA 94612 OAKLAND, CA 94612 FOR: SIERRA CLUB CALIFORNIA FOR: COMMUNITIES FOR A BETTER ENVIRONMENT GREGG MORRIS JASMIN ANSAR DIRECTOR UNION OF CONCERNED SCIENTISTS GREEN POWER INSTITUTE 2397 SHATTUCK AVENUE, SUITE 203 2039 SHATTUCK AVE., SUITE 402 BERKELEY, CA 94704 BERKELEY, CA 94704 FOR: UNION OF CONCERNED SCIENTISTS FOR: GREEN POWER INSTITUTE LINDA AGERTER R. THOMAS BEACH 51 PARKSIDE DRIVE CALIFORNIA COGENERATION COUNCIL BERKELEY, CA 94705 2560 NINTH STREET, SUITE 213A FOR: LARGE-SCALE SOLAR ASSOCIATION BERKELEY, CA 94710-2557 FOR: CALIFORNIA COGENERATION COUNCIL (CCC) / CALIFORNIA WIND ENERGY ASSOCIATION MICHAEL E. BOYD CORPORATE CREATIONS NETWORK, INC. PRESIDENT 131 - A STONY CIRCLE, NO. 500 CALIFORNIANS FOR RENEWABLE ENERGY, INC. SANTA ROSA, CA 95401 5439 SOQUEL DRIVE FOR: LIBERTY POWER DELAWARE, LLC SOQUEL, CA 95073-2659 FOR: CALIFORNIANS FOR RENEWABLE ENERGY



MARTIN HOMEC JUDITH B. SANDERS PO BOX 4471 SR. COUNSEL DAVIS, CA 95617 CALIF. INDEPENDENT SYSTEM OPERATOR CORP FOR: WOMEN'S ENERGY MATTERS 151 BLUE RAVINE ROAD FOLSOM, CA 95630 FOR: CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION KELLY M. FOLEY SYDNEY MANHEIM DAVIES ATTORNEY CALIFORNIA INDEPENDENT SYSTEM OPERATOR THE VOTE SOLAR INITIATIVE 151 BLUE RAVINE ROAD 2089 TRACY COURT FOLSOM, CA 95630 FOLSOM, CA 95630 FOR: CALIFORNIA INDEPENDENT SYSTEM FOR: THE VOTE SOLAR INITIATIVE OPERATOR CAROLYN M. KEHREIN DOUGLAS DAVIE ENERGY MANAGEMENT SERVICES WELLHEAD ELECTRIC COMPANY 2602 CELEBRATION WAY 650 BERCUT DRIVE, SUITE C WOODLAND, CA 95776 SACRAMENTO, CA 95811 FOR: ENERGY USERS FORUM FOR: WELLHEAD ELECTRIC COMPANY BETH TORO ANDREW B. BROWN GLACIAL ENERGY OF CALIFORNIA, INC.(1377) ELLISON SCHNEIDER & HARRIS, L.L.P. XL CORPORATE SERVICES, INC. 2600 CAPITOL AVENUE, SUITE 400 720 - 14TH STREET SACRAMENTO, CA 95816-5905 SACRAMENTO, CA 95814 FOR: CONSTELLATION NEWENERGY, INC. FOR: GLACIAL ENERGY OF CALIFORNIA, INC. ANDREW BROWN C/O ANDY BROWN ELLISON, SCHNEIDER & HARRIS L.L.P. ELLISON, SCHNEIDER & HARRIS, LLP 2600 CAPITOL AVE, SUITE 400 2600 CAPITAL AVENUE, SUITE 400 SACRAMENTO, CA 95816-5905 SACRAMENTO, CA 95816-5931 FOR: ACE COGENERATION COMPANY FOR: NV ENERGY/SIERRA PACIFIC POWER COMPANY KRISTIN BURFORD KAREN NORENE MILLS LARGE-SCALE SOLAR ASSOCIATION ASSOC. COUNSEL 2501 PORTOLA WAY CALIFORNIA FARM BUREAU FEDERATION SACRAMENTO, CA 95818 2300 RIVER PLAZA DRIVE FOR: LARGE SCALE SOLAR ASSOCIATION SACRAMENTO, CA 95833 FOR: CALIFORNIA FARM BUREAU FEDERATION DANIEL SILVERIA ROBERT MARSHALL GENERAL MANAGER GENERAL MANAGER SURPRISE VALLEY ELECTRIC CORP. PLUMAS SIERRA RURAL ELECTRIC COOP. (908) PO BOX 691 73233 STATE ROUTE 70 / PO BOX 2000 ALTURAS, CA 96101 PORTOLA, CA 96122-7069 FOR: SURPRISE VALLEY ELECTRIC CORP. FOR: PLUMAS SIERRA RURAL ELECTRIC COOP. JACK ELLIS DONALD E. BROOKHYSER 1425 ALPINE WAY / PO BOX 6600 ATTORNEY AT LAW TAHOE CITY, CA 96145 ALCANTAR & KAHL FOR: JACK ELLIS 1300 S.W. FIFTH AVENUE, SUITE 1750 PORTLAND, OR 97201 FOR: COGENERATION ASSN. OF CALIFORNIA



MARK TUCKER DRAKE WELCH REGULATORY MANAGER THE ROYAL BANK OF SCOTLAND (1375) PACIFICORP 36 ST. ANDREW SQUARE 825 NE MULTNOMAH STREET, STE. 2000 EDINBURG SCOTLAND, UK EH2 2YB PORTLAND, OR 97232 UNITED KINGDOM FOR: PACIFICORP FOR: SEMPRA SOLUTIONS DRAKE WELCH THE ROYAL BANK OF SCOTLAND 36 ST. ANDREW SQUARE EDINBURG, UK EH2 2YB UNITED KINGDOM FOR: THE ROYAL BANK OF SCOTLAND

AMBER MAHONE ANDRA PLIGAVKO ENERGY AND ENVIRONMENTAL ECONOMICS FIRST SOLAR DEVELOPMENT, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 ANDRES PACHECO BETH VAUGHAN RECURRENT ENERGY CALIFORNIA COGENERATION COUNCIL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 BRAD WETSTONE CASE COORDINATION PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 DANIEL CONSIE DANIEL PATRY CONSOLIDATED ASET MANAGEMENT SERVICES PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 DIANE I. FELLMAN ELIAH GILFENBAUM DIR - REGULATORY & GOV'T AFFAIRS PACIFIC GAS & ELECTRIC COMPANY NRG WEST & SOLAR EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 GEORGE ZAHARIUDAKIS JESSIE BAIRD INTEGRATED GENERATION PORTFOLIO EARTHJUSTICE PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 JOHN W. LESLIE, ESQ. LAKSHMI ALAGAPPAN LUCE, FORWARD, HAMILTON & SCRIPPS, LLP ENERGY AND ENVIRONMENTAL ECONOMICS, INC.

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EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: ENERGY AND ENVIRONMENTAL ECONOMICS, INC. (E3) MAGGIEN T. ESTRADA MALCOLM D. AINSPAN ENVIRONMENT DIRECTOR - WEST REGION ENERGY CURTAILMENT SPECIALISTS CONSTELLATION ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, NY 00000 EMAIL ONLY, CA 00000 FOR: ACE COGENERATION COMPANY MATTHEW FREEDMAN RYAN HEIDARI THE UTILITY REFORM NETWORK ENDIMENSIONS LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 STEVEN KELLY TOM STEPIEN INDEPENDENT ENERGY PRODUCERS ASSOCIATION PRIMUS POWER CORPORATION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 LEGAL & REGULATORY DEPARTMENT MRW & ASSOCIATES, LLC CALIFORNIA ISO EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 DAVIS WRIGHT TREMAINE LLP CURTIS KEBLER EMAIL ONLY SEMPRA GENERATION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000-0000 CYNTHIA BRADY DONALD GILLIGAN CONSTELLATION ENERGY RESOURCES, LLC NATIONAL ASSC. OF ENERGY SVC. COMPANIES EMAIL ONLY EMAIL ONLY EMAIL ONLY, IL 00000-0000 EMAIL ONLY, DC 00000-0000 FOR: NATIONAL ASSOCIATION OF ENERGY SERVICE COMPANIES IAN MCGOWAN JOHN NIMMONS MANAGER - REGULATORY AFFAIRS JOHN NIMMONS & ASSOCIATES, INC. 3DEGREES EMAIL ONLY EMAIL ONLY EMAIL ONLU, CA 00000-0000 EMAIL ONLY, CA 00000-0000 MELISSA SCHARY MICHAEL O'KEEFE EMAIL ONLY CAL. ENERGY EFFICIENCY INDUSTRY COUNCIL EMAIL ONLY, CA 00000-0000 EMAIL ONLY EMAIL ONLY, CA 00000-0000 MICHELLE GRANT SHERIDAN J. PAUKER DYNEGY, INC. WILSON SONSINI GOODRICH & ROSATI EMAIL ONLY EMAIL ONLY



EMAIL ONLY, TX 00000-0000 EMAIL ONLY, CA 00000-0000 HARRY SINGH STEVEN HUHMAN GOLDMAN, SACHS & CO. MORGAN STANLEY CAPITAL GROUP INC. 200 WEST STREET 2000 WESTCHESTER AVENUE NEW YORK, NY 10282-2198 PURCHASE, NY 10577 MICHAEL A. YUFFEE STEVEN A. WEILER HOGAN LOVELLS LEONARD STREET AND DEINARD, PA 555 13TH ST., N.W. 1350 I STREET, NW, STE. 800 WASHINGTON, DC 20004 WASHINGTON, DC 20005 FOR: ZEPHYR POWER TRANSMISSION, LLC LOUAY ELDADA KEVIN J. SIMONSEN SUNEDISON ENERGY MANAGEMENT SERVICES 3909 GAINES COURT 646 E. THIRD AVE. AUSTIN, TX 78735 DURANGO, CA 81301 CAITLIN COLLINS LIOTIRIS JUSTIN FARR ENERGY STRATEGIES, LLC ENERGY STRATEGIES, LLC 215 SOUTH STATE STREET, STE 200 215 SOUTH STATE ST., STE. 200 SALT LAKE CITY, UT 84111 SALT LAKE CITY, UT 84111 CYNTHIA K. MITCHELL HANS LAETZ, J.D. ENERGY ECONOMICS, INC. ZUMA IMPACT LLC 530 COLGATE COURT 6402 SURFSIDE WAY RENO, NV 89503 MALIBU, CA 90265 BILL BRAND DAVID NEMTZOW 415 DIAMOND ST. NEMTZOW & ASSOCIATES REDONDO BEACH, CA 90277 1254 9TH STREET, NO. 6 SANTA MONICA, CA 90401 HARVEY EDER FRED MOBASHERI PUBLIC SOLAR POWER COALITION CONSULTANT 1218 12TH ST., NO. 25 ELECTRIC POWER GROUP, LLC SANTA MONICA, CA 90401 201 SOUTH LAKE AVE., SUITE 400 PASADENA, CA 91101 MICHAEL D. CALLAGHAN KENYON HOLMES 2326 JAYMA LANE TRANE LA CRESCENTA, CA 91214 17748 ROWLAND STREET CITY OF INDUSTRY, CA 91748 CASE ADMINISTRATION MELISSA A. HOVSEPIAN 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 RICH METTLING JAY CORRALES SOUTHERN CALIFORNIA EDISON COMPANY TURNER REAL ESTATE 2244 WALNUT GROVE AVENUE 539 CARLSBAD VILLAGE DR., STE. 106



ROSEMEAD, CA 91770 CARLSBAD, CA 92008 GREG BASS JOHN A. PACHECO NOBLE AMERICAS ENERGY SOLUTIONS LLC ATTORNEY 401 WEST A STREET, SUITE 500 SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA 92101-3017 101 ASH STREET, HQ12B SAN DIEGO, CA 92101-3017 SARAH TOMEC REMEDIOS "MIMI" SANTOS SR. ADVISOR, REGULATORY AFFAIRS WEST SAN DIEGO GAS & ELECTRIC COMPANY CAPITAL POWER CORPORATION 8330 CENTURY PARK CT., CP31E 9255 TOWNE CENTRE DRIVE, STE. 900 SAN DIEGO, CA 92123 SAN DIEGO, CA 92121 WENDY KEILANI CENTRAL FILES REGULATORY CASE MGR SAN DIEGO GAS AND ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP32D, RM CP31-E 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA 92123-1530 SAN DIEGO, CA 92123 PAUL DONAHUE RORY COX IEEE RATEPAYERS FOR AFFORDABLE CLEAN ENERGY 21 SARACENO 251 KEARNY STREET, 2ND FLOOR NEWPORT COAST, CA 92657 SAN FRANCISCO, CA 94102 FOR: PACIFIC ENVIRONMENT SUSAN PRESTON MARCEL HAWIGER CALCEF CLEAN ENERGY ANGEL FUND ENERGY ATTY 5 THIRD STREET, STE. 1125 THE UTILITY REFORM NETWORK SAN FRANCISCO, CA 94103 115 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94104 ALICE GONG BARNEY SPECKMAN PACIFIC GAS AND ELECTRIC COMPANY VP - GRID MANAGEMENT 77 BEALE ST. MC B9A NEXANT SAN FRANCISCO, CA 94105 101 SECOND STREET, 11TH FLOOR SAN FRANCISCO, CA 94105 EVAN HOUSE GLORIA D. SMITH GOLDEN GATE UNIVERSITY SCHOOL OF LAW SIERRA CLUB ENVIRONMENTAL LAW PROGRAM 536 MISSION STREET 85 SECOND STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 KAREN TERRANOVA KEVIN HIETBRINK ALCANTAR & KAHL PACIFIC GAS AND ELECTRIC COMPANY 33 NEW MONTGOMERY STREET, SUITE 1850 77 BEALE ST., MC B9A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 KIMBERLY C. JONES LUCAS WILLIAMS PACIFIC GAS AND ELECTRIC COMPANY GOLDEN GATE UNIVERSITY SCHOOL OF LAW 77 BEALE STREET, MC B9A, ROOM 904 536 MISSION STREET SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: PACIFIC ENVIRONMENT



MATTHEW GONZALES MICHAEL P. ALCANTAR PACIFIC GAS AND ELECTRIC COMPANY ALCANTAR & KAHL LLP 77 BEALE STREET, ROOM 918 33 NEW MONTGOMERY STREET, SUITE 1850 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: COGENERATION ASSOCIATION OF CALIFORNIA WILLIAM MITCHELL ADAM BROWNING COMPETITIVE POWER VENTURES, INC. THE VOTE SOLAR INITIATIVE 55 2ND STREET, SUITE 525 300 BRANNAN STREET, SUITE 609 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94107 FOR: THE VOTE SOLAR INITIATIVE STEPHANIE WANG DEVIN MCDONELL ATTORNEY AT LAW BINGHAM MCCUTHCHEN PACIFIC ENVIRONMENT THREE EMBARCADERO CENTER 251 KEARNY STREET, 2ND FLOOR SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94108 FOR: PACIIFIC ENVIRONMENT JAMES D. SQUERI, ESQ. JAMES L. FILIPPI GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY NEXTLIGHT RENEWABLE POWER, LLC 505 SANSOME STREET, SUITE 900 353 SACRAMENTO STREET, SUITE 2100 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: POWEREX CORPORATION RAFI HASSAN ROBERT GEX SUSQUEHANNA FINANCIAL GROUP, LLLP DAVIS WRIGHT TREMAINE LLP 101 CALIFORNIA STREET, SUITE 3250 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 SETH HILTON TODD EDMISTER ATTORNEY AT LAW ATTORNEY AT LAW STOEL RIVES BINGHAM MCCUTCHEN LLP 555 MONTGOMERY STREET, SUITE 1288 THREE EMBARCADERO CENTER SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111-4067 FOR: PANOCHE ENERGY CENTER, LLC CALIFORNIA ENERGY MARKETS MARK HUFFMAN 425 DIVISADERO ST. STE 303 LAW DEPT SAN FRANCISCO, CA 94117-2242 PACIFIC GAS & ELECTRIC COMPANY PO BOX 7442, B30A SAN FRANCISCO, CA 94120 REGULATORY FILE ROOM DON BURKARD PACIFIC GAS AND ELECTRIC COMPANY PROJECTS GENERAL MANAGER PO BOX 7442 POWER PLANT MANAGEMENT SERVICES, LLC SAN FRANCISCO, CA 94120 1520 ST. CLAIR DR. ANTIOCH, CA 94509 FOR: PANOCHE ENERGY CENTER, LLC SEAN P. BEATTY AVIS KOWALEWSKI



GENON CALIFORNIA NORTH LLC CALPINE CORPORATION 696 WEST 10TH STREET 4160 DUBLIN BLVD., SUITE 100 PITTSBURG, CA 94565 DUBLIN, CA 94568 JILL VAN DALEN MATTHEW BARMACK CALPINE CORPORATION DIR 4160 DUBLIN BLVD., STE. 100 CALPINE CORPORATION DUBLIN, CA 94568 4360 DUBLIN BLVD., SUITE 100 DUBLIN, CA 94568 GOPAL SHANKER REN ORANS PRESIDENT E3 RECOLTE ENERGY 101 MONTGOMERY STREET, STE. 1600 410 LAFATA STREET, SUITE 102 SAN FRANCISCO, CA 94611 ST. HELENA, CA 94574 FOR: RECOLTE ENERGY DOCKET COORDINATOR DAVID MARCUS KEYES & FOX LLP ADAMS BROADWELL & JOSEPH 436 14TH STREET, SUITE 1305 PO BOX 1287 OAKLAND, CA 94612 BERKELEY, CA 94701-1287 REED V. SCHMIDT PATRICK G. MCGUIRE BARTLE WELLS ASSOCIATES CROSSBORDER ENERGY 1889 ALCATRAZ AVENUE 2560 NINTH STREET, SUITE 316 BERKELEY, CA 94703-2714 BERKELEY, CA 94710 FOR: CALIFORNIA CITY-COUNTY STREET LIGHT ASSOCIATION (CAL-SLA) ELIZABETH RASMUSSEN ARARM SHUMAVON REG. AND LEGAL COUNSEL DISTRIBUTED ENERGY CONSUMER ADVOCATES MARIN ENERGY AUTHORITY 135 NOVA ALBION WAY, NO. 5 781 LINCOLN AVENUE, SUITE 320 SAN RAFAEL, CA 94903 SAN RAFAEL, CA 94901 PHILLIP MULLER BRUCE PERLSTEIN, PH.D SCD ENERGY SOLUTIONS MANAGING DIRECTOR 436 NOVA ALBION WAY STRATEGY, FINANCE & ECONOMICS, LLC SAN RAFAEL, CA 94903 366 EDGEWOOD AVENUE MILL VALLEY, CA 94941 JAMES WEIL BARBARA GEORGE DIRECTOR WOMEN'S ENERGY MATTERS AGLET CONSUMER ALLIANCE PO BOX 548 PO BOX 866 FAIRFAX, CA 94978-0548 NOVATO, CA 94948 JERRY MIX PUSHKAR WAGLE, PH.D. PRESIDENT FLYNN RESOURCE CONSULTANTS INC. WATTSTOPPER 2900 GORDON AVENUE, SUITE 100-3 2800 DE LA CRUZ BLVD. SANTA CLARA, CA 95051 SANTA CLARA, CA 95050



GENE THOMAS DEVRA WANG ECOLOGY ACTION STAFF SCIENTIST PO BOX 1188 NATURAL RESOURCES DEFENSE COUNCIL SANTA CRUZ, CA 95061-1188 111 SUTTER STREET, 20TH FLOOR SAN FRANCISCO, CA 95104 BARRY F. MCCARTHY BARBARA R. BARKOVICH MCCARTHY & BERLIN, LLP BARKOVICH & YAP, INC. 100 WEST SAN FERNANDO ST., STE. 501 44810 ROSEWOOD TERRACE SAN JOSE, CA 95113 MENDOCINO, CA 95460 WILLIAM B. MARCUS MARK BERMAN CONSULTING ECONOMIST DAVIS ENERGY GROUP JBS ENERGY, INC. 123 C STREET 311 D STREET, SUITE A DAVIS, CA 95616 WEST SACRAMENTO, CA 95605 BETH ANN BURNS C. RICHARD WYLIE SR. COUNSEL - LEGAL & REGULATORY DEPT BEUTLER CORPORATION CALIFORNIA ISO 4700 LANG AVE. 250 OUTCROPPING WAY MCCLELLAN, CA 95652 FOLSOM, CA 95630 BRIAN THEAKER MARK ROTHLEDER NRG ENERGY CALIF. INDEPENDENT SYSTEM OPERATOR CORP. 3161 KEN DEREK LANE 151 BLUE RAVINE ROAD PLACERVILLE, CA 95667 FOLSOM, CA 95678 RAY PINGLE DANIEL KIM 7140 STEEPLE CHASE DR. THE ANTHEM GROUP SHINGLE SPRINGS, CA 95682 PO BOX 582844 ELK GROVE, CA 95758-0051 ALLISON C. SMITH AUTUMN BERNSTEIN ATTORNEY CLIMATE PLAN STOEL RIVES LLP 717 K STREET, SUITE 330 500 CAPITOL MALL, SUITE 1600 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 CURT BARRY DANIELLE OSBORN MILLS SENIOR WRITER POLICY DIRECTOR CLEAN ENERGY REPORT CEERT 717 K STREET, SUITE 503 1100 11TH STREET, SUITE 311 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE TECHNOLOGIES (CEERT) DAVID MILLER GWENNETH O'HARA CEERT CALIFORNIA POWER LAW GROUP 1100 ELEVENTH ST., SUITE 311 1215 K STREET, 17TH FLOOR SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 JIM METROPULOS KEVIN WOODRUFF



SR. ADVOCATE WOODRUFF EXPERT SERVICES SIERRA CLUB CALIFORNIA 1100 K STREET, SUITE 204 801 K STREET, SUITE 2700 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 MARK A. LOWDER MEGAN COX DIR - HOUSING FINANCE CALIFORNIA POWER LAW GROUP CRHMFA HOMEBUYERS FUND 1215 K STREET, 17TH FLOOR 1215 K STREET, STE. 1650 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 SCOTT BLAISING STEVEN A. BRINK BRAUN BLAISING MCLAUGHLIN, P.C. VP - PUBLIC RESOURCES 915 L STREET, SUITE 1270 CALIFORNIA FORESTRY ASSOCIATION SACRAMENTO, CA 95814 1215 K STREET, SUITE 1830 SACRAMENTO, CA 95814 BRIAN S. BIERING DOUGLAS K. KERNER ELLISON SCHNEIDER & HARRIS, LLP ATTORNEY AT LAW 2600 CAPITOL AVENUE, SUITE 400 ELLISON, SCHNEIDER & HARRIS, LLP SACRAMENTO, CA 95816-5905 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA 95816-5905 MICHAEL S. DAY SHANNON EDDY PRINCIPAL EXECUTIVE DIRECTOR ROCKWOOD CONSULTING LARGE SCALE SOLAR ASSOCIATION 2701 2ND AVE. 2501 PORTOLA WAY SACRAMENTO, CA 95818 SACRAMENTO, CA 95818 FOR: LARGE-SCALE SOLAR ASSOCIATION ASHLEY SPALDING CARL LINVILL ASPEN ENVIRONMENTAL GROUP ASPEN ENVIRONMENTAL GROUP 8801 FOLSOM BLVD., STE. 290 8801 FOLSOM BLVD., STE. 290 SACRAMENTO, CA 95826-3250 SACRAMENTO, CA 95826-3250 ANN L. TROWBRIDGE CALIFORNIA PACIFIC ELECTRIC COMPANY, LLC ATTORNEY AT LAW 933 ELOISE AVENUE DAY CARTER MURPHY LLC SOUTH LAKE TAHOE, CA 96150 3620 AMERICAN RIVER DRIVE, SUITE 205 SACRAMENTO, CA 95864 FOR: CALIFORNIA CLEAN DG COALITION. ROSS VAN NESS DONALD W. SCHOENBECK ALCANTAR & KAHL LLP RCS, INC. 1300 SW FIFTH AVE., SUITE 1750 900 WASHINGTON STREET, SUITE 780 PORTLAND, OR 97201 VANCOUVER, WA 98660 JOHN DUNN MEREDITH LAMEY TRANSCANADA CORPORATION TRANSCANADA CORPORATION 450 1ST ST. S.W. 450 1ST STREET S.W. CALGARY, AB T2P 5H1 CALGARY, AB T2P 5H1 CANADA CANADA



DANIEL JURIJEW SHAUN PILLOTT SR. MGR - REGULATORY AFFAIRS WEST REG. AFFAIRS WEST-SENIOR ADVISOR CAPITAL POWER CORPORATION CAPITAL POWER CORPORATION 10065 JASPER AVENUE 10065 JASPER AVENUE EDMONTON, AB T5J 3B1 EDMONTON, AB T5J 3B1 CANADA CANADA FOR: CAPITAL POWER CORPORATION GIFFORD JUNG POWEREX CORPORATION 666 BURRARD STREET, SUITE 1400 VANCOUVER, BC V5R 4Y2 CANADA FOR: POWEREX CORPORATION

CHERYL LEE DAVID B. PECK CALIFORNIA PUBLIC UTILITIES COMMISSION CPUC - DRA EMAIL ONLY ELECTRICITY PLANNING & POLICY BRANCH EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 LILY CHOW CONNIE LENI REGULATORY ANALYST CALIFORNIA ENERGY COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000-0000 EMAIL ONLY, CA 00000 MICHAEL COHEN JAMES ROSS CALIFORNIA PUBLIC UTILITIES COMMISSION RCS INC. EMAIL ONLY 500 CHESTERFIELD CENTER, SUITE 320 EMAIL ONLY, CA 00000-0000 CHESTERFIELD, MO 63017 BISHU CHATTERJEE CHLOE LUKINS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION ELECTRICITY PLANNING & POLICY BRANCH ROOM 5303 ROOM 4101 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 CHRIS UNGSON DAMON A. FRANZ CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH DEMAND SIDE PROGRAMS BRANCH ROOM 4104 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 DIANA L. LEE JASON SIMON CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ROOM 4107 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE

State Service



SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 JORDAN PARRILLO KAREN P. PAULL CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH DRA - ADMINISTRATIVE BRANCH ROOM 4104 ROOM 4300 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: DRA KE HAO OUYANG MEGHA LAKHCHAURA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH PROCUREMENT STRATEGY AND OVERSIGHT BRANC ROOM 4104 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 NATHANIEL SKINNER NIKA ROGERS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4101 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 PAUL DOUGLAS PETER SPENCER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4104 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 PETER V. ALLEN REBECCA TSAI-WEI LEE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ROOM 5031 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 ROBERT L. STRAUSS SARITA SARVATE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B PROCUREMENT STRATEGY AND OVERSIGHT BRANC AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 SEAN A. SIMON STEVEN K. HAINE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC GAS SAFETY AND RELIABILITY BRANCH AREA 4-A ROOM 2106 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 WILLIAM DIETRICH YULIYA SHMIDT DRA-ELECTRICITY PRICING & CUST. PROGRAMS CALIF PUBLIC UTILITIES COMMISSION



CPUC ELECTRICITY PLANNING & POLICY BRANCH RM. 4101 ROOM 4108 SAN FRANCISCO, CA 94102-3214 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 CLARE LAUFENBER GALLARDO JIM WOODWARD STRATEGIC TRANSMISSION INVESTMNT PROGRAM CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 NINTH STREET, MS 20 1516 NINTH STREET, MS 17 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 LISA DECARLO MARC PRYOR STAFF COUNSEL CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 NINTH ST. 1516 9TH STREET MS-14 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 MICHAEL JASKE IVIN RHYNE CALIFORNIA ENERGY COMMISSION CALIFORNIA ENERGY COMMISSION 1516 9TH STREET, MS-20 1516 9TH STREET, MS 20 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814-5512

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