BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Order Instituting Rulemaking to Continue
Implementation and Administration of
California Renewables Portfolio Standard
Program.
)
)
)
)
Rulemaking 11-05-005
(Filed May 5, 2011)
SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) COMMENTS ON THE
SECOND ASSIGNED COMMISSIONER’S RULING ISSUING PROCUREMENT
REFORM PROPOSALS AND ESTABLISHING A SCHEDULE FOR COMMENTS ON
PROPOSALS
JENNIFER TSAO SHIGEKAWA
CATHY A. KARLSTAD
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone:
(626) 302-1096
Facsimile:
(626) 302-6962
E-mail:
Cathy.Karlstad@sce.com
Dated: November 20, 2012
SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) COMMENTS ON THE SECOND
ASSIGNED COMMISSIONER’S RULING ISSUING PROCUREMENT REFORM
PROPOSALS AND ESTABLISHING A SCHEDULE FOR COMMENTS ON PROPOSALS
TABLE OF CONTENTS
Section
Title
Page
I. INTRODUCTION ....................................................................................................................................1 II. PROPOSAL – STANDARDS OF REVIEW FOR IOUS’ SHORTLISTS ............................................5 III. PROPOSAL – ESTABLISH DATE CERTAIN FOR REQUEST FOR
COMMISSION APPROVAL OF CONTRACTS ...........................................................................7 A. One-Year Deadline to Execute Contracts With Shortlisted Projects ...................................7 B. One-Month Deadline to File Executed Contracts for Commission
Approval ..............................................................................................................................9 IV. PROPOSAL – EXPEDITED REVIEW OF RPS PURCHASE AND SALES
CONTRACTS ................................................................................................................................10 V. PROPOSAL – IMPROVE RPS POWER PURCHASE AGREEMENT STANDARDS
OF REVIEW ..................................................................................................................................18 A. Proposed Standards of Review for Power Purchase Agreements from
Solicitations........................................................................................................................20 B. Proposed Standards of Review for Bilateral Power Purchase Agreements .......................22 C. Proposed Standards of Review for Amended Contracts ....................................................24 D. Proposed Standards of Review for Power Purchase Agreements that are
Beyond the Scope of the Commission’s Advice Letter Process ........................................28 E. Proposed Standards of Review for Unbundled Renewable Energy Credits ......................29 VI. PROPOSAL – RPS INDEPENDENT EVALUATOR REPORTS .....................................................30 VII. IMPLEMENTATION OF NEW LEAST-COST BEST-FIT REQUIREMENTS .............................30 VIII. GREEN ATTRIBUTES STANDARD TERM AND CONDITION ................................................34 IX. CONCLUSION....................................................................................................................................35 APPENDIX A - SOUTHERN CALIFORNIA EDISON COMPANY’S (“SCE”) LEASTCOST BEST-FIT METHODOLOGY -i-
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Order Instituting Rulemaking to Continue
Implementation and Administration of
California Renewables Portfolio Standard
Program.
)
)
)
)
Rulemaking 11-05-005
(Filed May 5, 2011)
SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) COMMENTS ON THE
SECOND ASSIGNED COMMISSIONER’S RULING ISSUING PROCUREMENT
REFORM PROPOSALS AND ESTABLISHING A SCHEDULE FOR COMMENTS ON
PROPOSALS
Pursuant to the Second Assigned Commissioner’s Ruling Issuing Procurement Reform
Proposals and Establishing a Schedule for Comments on Proposals (“ACR”) and Administrative
Law Judge Simon’s November 5, 2012 e-mail extending the due dates for opening and reply
comments, Southern California Edison Company (“SCE”) respectfully submits these comments
on the Renewables Portfolio Standard (“RPS”) procurement reform proposals set forth in the
ACR to the California Public Utilities Commission (“Commission”).
I.
INTRODUCTION
SCE generally agrees with the objectives identified in the ACR. In particular, SCE fully
supports streamlining the RPS contract review process, issuing Commission determinations on
contract reasonableness on a defined timeline, and increasing market certainty.1 An effective,
efficient, and timely renewable procurement and contract review process that minimizes costs to
customers and provides certainty to the market is critical given the preferred place of renewable
resources in the State’s energy policy. California has set a statewide goal of 33% renewable
1
ACR at 2.
-1-
energy and categorized renewables as a preferred resource in the State’s loading order above
conventional generation.2 In view of the State’s policy preference for renewable generation, it is
especially important that the Commission’s procedures for review and approval of RPS contracts
advance the procurement of such resources and avoid creating barriers that would make it more
difficult to procure renewables than other resources that are lower in the loading order.
For the most part, the existing renewable procurement and contract review process is
working effectively. The investor-owned utilities (“IOUs”) have aggressively procured
renewable resources in support of the State’s renewable energy goals in a way that minimizes
costs to their customers and preserves the value of customers’ investments in these resources. As
the ACR recognizes, the IOUs “have made significant progress in contracting for RPS-eligible
generation.”3 Since 2002, the Commission has approved more than 200 IOU contracts for over
18,500 MW of renewable capacity.4 In its last quarterly report to the Legislature, the
Commission forecasted that 5,611 MW of new renewable resources will have achieved
commercial operation under the RPS program by the end of 2012.5 Moreover, the response to
the IOUs’ RPS solicitations and the overall competitiveness of the renewables market have
increased dramatically.6
Additionally, the IOUs are already taking action to improve their renewable procurement
processes. For example, for future RPS solicitations, SCE intends to require potential sellers to
have a completed Phase I (or equivalent) interconnection study to bid into the solicitation and a
Phase II (or equivalent) interconnection study before entering into a contract.7 This will give
both SCE and the Commission more information about a potential project’s transmission costs,
2
3
4
5
6
7
See Cal. Pub. Util. Code § 399.11 et seq.; State of California, Energy Action Plan II, October 2005, at 2.
ACR at 3.
Renewables Portfolio Standard Quarterly Report, 1st and 2nd Quarter 2012, at 5.
Id. at 4.
See ACR at 3.
The Phase I study requirement was approved by the Commission in Decision (“D.”) 12-11-016. The
Commission stated that it would continue to consider the merits of the Phase II study requirement in a later part
of this proceeding. D.12-11-016 at 42.
-2-
interconnection risks, and overall value. Moreover, these requirements could minimize the risk
of project failure due to interconnection issues and the risk of executing a contract with a nonviable project. SCE is also considering implementing a solicitation structure whereby SCE
negotiates with shortlisted projects to completion based on a set timeline, and then requests that
each seller refresh its pricing and executes contracts with the projects that provide the most value
to SCE’s customers. This structure will reduce delays and allow SCE’s customers to take
advantage of price drops over the negotiation period. It would also eliminate the problem of
information becoming stale between shortlisting and contract execution.
There is room for improvement in the Commission’s practices and procedures for review
and approval of RPS contracts. It can take many months, and in several cases, more than a year,
to obtain Commission approval of renewable power purchase and sales contracts. This
prolonged review process can result in a variety of negative consequences including contract
pricing becoming stale, additional risk for renewable developers, and premiums added to the
prices the IOUs’ customers pay for renewable transactions to account for regulatory uncertainty.
For all these reasons, SCE supports reforms that will simplify and streamline the RPS contract
review process and expedite the timeliness of contract approvals. A workable process for
expedited review of renewable power purchase and sale agreements is an excellent step in this
direction.
However, SCE strongly urges the Commission not to make wholesale changes to a
process that is fundamentally sound. The current procedures for RPS procurement and contract
review have been developed over the 10-year history of the RPS program with significant input
from a diverse range of stakeholders through multiple rounds of comments, workshops, and
other proceedings and numerous Commission decisions. There is no evidence that major
reforms are needed. Indeed, SCE is very concerned that adoption of the ACR reform proposals
as currently drafted would be detrimental to the RPS program. Rather than streamlining the
contract review process, increasing the predictability of Commission action on contract
-3-
approvals, and enhancing market certainty, the overall effect of the proposals would be the exact
opposite.
Specifically, the proposals would introduce additional delay and uncertainty into the
approval of the IOUs’ RPS solicitation shortlists by requiring that the shortlists be approved via
Tier 3 advice letters without making any corresponding improvements to the rest of the
renewable procurement and contract review process. The new standards of review would
actually make it more difficult and time consuming to obtain approval of RPS power purchase
and sales agreements and amendments by shifting the review process for many contract
amendments from the Energy Resource Recovery Account (“ERRA”) process to Tier 3 advice
letters and shifting the review process for many other contracts from the Tier 3 advice letter
process to applications. Additionally, the one ACR proposal that is directly aimed at
streamlining the RPS contract review process – the expedited Tier 1 and 2 advice letter review
process – includes so many restrictions on eligibility for expedited review that few, if any,
contracts will be able to utilize the process.
The proposed standards of review would also make it highly undesirable and difficult for
the IOUs to execute a whole class of renewable contracts (including bilateral contracts that do
not meet stringent viability criteria and contracts for new renewable technologies) by requiring
that such contracts be reviewed via applications and mandating that the full terms and conditions
of these contracts, including contract pricing, be publicly disclosed.
In reviewing the IOUs’ renewable procurement efforts, the Commission has consistently
stated that it does not “micromanage” or “take over the procurement process.”8 As President
Peevey and Commissioner Simon recently noted, “[t]he utilities should have flexibility and the
opportunity to pursue the most cost-effective contracts.”9 Adoption of the ACR reform
proposals as currently drafted would be inconsistent with the Commission’s long-standing
8
9
See D.11-04-030 at 11; D.09-06-018 at 9; D.08-02-008 at 6. See also D.12-11-016, Concurrence of President
Peevey and Commissioner Simon.
D.12-11-016, Concurrence of President Peevey and Commissioner Simon.
-4-
commitment to give the IOUs the flexibility to run their own procurement processes and contrary
to the best interests of the IOUs’ customers.
Before undertaking any reforms to the RPS procurement and contract review process, the
Commission should carefully consider the benefits and costs of suggested reforms and make
certain that they will make the process better, not worse. As discussed below, the ACR reform
proposals should not be adopted unless they undergo significant modifications. SCE has
recommended changes to the proposals that will further the goals identified in the ACR and
result in overall improvements to the Commission’s process for review of renewable generation
procurement and sales.10
II.
PROPOSAL – STANDARDS OF REVIEW FOR IOUS’ SHORTLISTS
Instead of the existing procedure of submitting RPS solicitation shortlists through Tier 2
advice letters, the ACR proposes that the IOUs file their shortlists via Tier 3 advice letters to be
approved by Commission resolution.11 By putting more emphasis on the review of the shortlists,
the ACR states that this proposal could streamline the advice letter review process and minimize
regulatory uncertainty later in the RPS contract evaluation process.12
Approving the IOUs’ shortlists through a Commission resolution will not streamline the
overall process for renewable procurement and contract review. To the contrary, this proposal
lengthens the time in one process (review of the shortlist) and only potentially shortens the time
in another process (review of the advice letter). Indeed, as further detailed in Section IV below,
the proposed expedited contract review process discussed in the ACR will not work as currently
drafted. Unless significant changes are made to ensure that the IOUs can actually use the
expedited review process, the result of the ACR reform proposals will be a longer and more
10
11
12
SCE’s responses to the questions set forth in the ACR are included in its general discussion of each ACR
reform proposal in Sections II through VIII below. In some cases, SCE has included the questions in its
responses.
ACR at 9-10.
Id. at 9.
-5-
unpredictable timeframe for approval of the IOUs’ shortlists and a longer timeframe for contract
approvals.
By requiring full Commission approval of the IOUs’ RPS solicitation shortlists and
prohibiting the IOUs from executing contracts with shortlisted projects until the Commission
adopts the shortlists in a resolution, the proposal would add significant regulatory uncertainty
into the renewable procurement process. Neither the IOUs nor renewable developers would
know when the shortlists would be approved and the negotiation and contracting process could
be substantially delayed. In fact, this proposal would make it more difficult to procure higher
loading order renewable resources by adding a regulatory barrier – approval of solicitation
shortlists by Commission resolution – that has never proven to be necessary for prior
solicitations for renewable or conventional resources. Additionally, adoption of this proposal
could prejudice the IOUs’ renewable procurement efforts in favor of other load-serving entities
that are not subject to this restriction. Even if they did ultimately contract with the IOUs,
developers would likely price this added regulatory uncertainty into their bid prices, resulting in
higher costs for the IOUs’ customers.
Likewise, by requiring Tier 3 advice letters and a Commission resolution (and thus
delaying the approval of the shortlists), this proposal may actually increase the likelihood of the
analyses the IOUs used in making shortlisting decisions becoming stale by the time the
Commission reviews the signed contracts. The Commission would also be focusing its efforts
on reviewing shortlisted proposals that may be very different from the executed contracts. All of
these results are inconsistent with the Commission’s goals of streamlining the overall RPS
procurement process, minimizing regulatory uncertainty, and ensuring that the Commission
makes procurement review decisions based on the same market conditions that were relevant
when the IOUs make their procurement decisions.
Some increase in the time period for approval of the RPS solicitation shortlists may be
justified if there are corresponding decreases in the time period needed to obtain approval of
executed contracts. In that case, any additional burdens and regulatory uncertainty in the
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shortlisting and contract execution process would be outweighed by the decreased burdens and
uncertainty in the contract review process. Accordingly, SCE could support review and approval
of the shortlists through a Tier 3 advice letter if the Commission also adopts a reasonable and
workable expedited review process for RPS power purchase and sale contracts. The expedited
review process proposed in the ACR requires substantial changes to make it reasonable and
workable. Therefore, if the Commission were to require shortlists to be approved via Tier 3
advice letters, the Commission should, at the very least, adopt expedited review of renewable
power purchase and sale agreements via Tier 1 and Tier 2 advice letters as recommended by SCE
in Section IV below. Finally, SCE suggests that the Commission establish a defined timeline for
approval of the RPS solicitation shortlists to decrease the uncertainties and potential for delay in
that portion of the process. SCE believes that the Commission should approve the shortlists no
later than three months after submission of the shortlist advice letters.
III.
PROPOSAL – ESTABLISH DATE CERTAIN FOR REQUEST FOR COMMISSION
APPROVAL OF CONTRACTS
A.
One-Year Deadline to Execute Contracts With Shortlisted Projects
The ACR proposes that RPS solicitation contracts be executed within one year after the
approval of the IOU’s solicitation shortlist.13 The objective of this proposal is to avoid lag time
between the signing of a contract and Commission review of that contract that would result in the
analyses the IOU used to determine whether it should execute the contract becoming stale.14
SCE does not generally object to a requirement that the IOUs execute RPS solicitation
contracts within one year of Commission approval of the shortlists. Nonetheless, there should be
some flexibility to depart from this timeframe on a case-by-case basis. For example, in its
original 2012 RPS Procurement Plan, SCE proposed to require a Phase II (or equivalent)
13
14
ACR at 10.
Id.
-7-
interconnection study before entering into a contract. SCE believes this is a prudent precondition to executing agreements in RPS solicitations because it would give SCE more
information about a project’s transmission costs, interconnection risks, and overall value before
it signs a contract. The Commission would also have more information when it reviews the
resulting contracts.
In approving the 2012 RPS Procurement Plans, the Commission did not adopt a Phase II
study requirement because of concerns that the timelines to obtain Phase II studies may exceed
the one-year life of the solicitation shortlists.15 The Commission stated that it would continue to
examine the merits of a Phase II study requirement in a later part of this proceeding.16 Instead of
rejecting a Phase II study requirement that would provide the Commission with valuable
information for its contract review process because of the one-year time period to execute
contracts, the Commission should allow for extension of the one-year life of the shortlists in
cases where additional Phase II studies will be issued shortly after the end of the one-year period.
Moreover, even if a Phase II study is not a requirement for contract execution, it may be
appropriate to extend the contract execution timeline if a shortlisted project will be receiving an
interconnection study, a decision on key permits, or other important information that will affect
the value or viability of the project within a reasonable time period after the one-year deadline.
It would make little sense to stick to an arbitrary timeline in the name of preventing the IOUs’
contract evaluations from becoming stale in cases where extending that timeline would actually
provide better information to the IOUs and the Commission.
The Commission could also allow the IOUs to require shortlisted bidders to refresh their
pricing shortly before contract execution, which would alleviate the problem of information
becoming stale because of the time period between shortlisting and contract execution.
15
16
D.12-11-016 at 42.
Id.
-8-
B.
One-Month Deadline to File Executed Contracts for Commission Approval
The ACR also proposes a requirement that RPS contracts be filed with the Commission
for approval within one month from the execution date of the contract.17 Providing only one
month from contract execution to file an advice letter or application is an unreasonably short
amount of time. The RPS advice letter template requires that detailed information be included in
advice letters or applications that often takes more than one month to be developed. The amount
of information that must be included in advice letters or applications has also generally increased
over time. Not all of this information is in the possession of the IOUs. Some information must
be obtained from the seller. The Independent Evaluator (“IE”) must also complete its report
before the contract can be submitted for approval. In addition, if an IOU has more than one
advice letter or application that must be filed around the same time (which would be a very likely
scenario), it would be even more difficult to comply with this requirement. The same IE would
also be used for all of the contracts from a solicitation, potentially requiring the IE to develop
multiple reports in one month.
Further, the ACR’s proposal to require updating of a project’s net market value and the
net market value for all comparable bids using the most current forward curve information within
one week prior to filing of the advice letter or application further complicates the IOUs’ ability to
file an advice letter or application within one month of contract execution. As discussed in
Section V below, this requirement is inappropriate and unreasonably burdensome and should not
be adopted by the Commission. Such a requirement is unreasonably burdensome in part because
SCE’s price curve forecasts are driven by SCE’s long-term gas forecasts, which are only updated
on a quarterly basis. It takes SCE’s forecasting group approximately two weeks to generate an
updated blended price forecast from beginning to end. Additionally, there is a quality control
process in which these forecasts are vetted after the prices are generated and before they are used
in the valuation to ensure they are reasonable. After the price forecast is complete and has been
17
ACR at 10.
-9-
reviewed by the appropriate internal stakeholders, it then takes another two weeks to incorporate
the new price forecast into the bid evaluation model.
Accordingly, if the Commission adopts a requirement that the IOUs update a project’s net
market value and the net market value for all comparable bids using the most current forward
curve information before the filing of an advice letter or application, SCE requests 90 days from
contract execution to file the advice letter or application. If this requirement is not adopted, the
IOUs should have 60 days from the signing of a contract to submit the contract for Commission
approval. This small increase in the time period for filing RPS contract advice letters or
applications will not result in the analyses used in the contract selection and execution process
becoming stale. Moreover, allowing the IOUs to have sufficient time to prepare advice letters or
applications will ensure that such filings include all required information and minimize the need
for supplements and data requests.
IV.
PROPOSAL – EXPEDITED REVIEW OF RPS PURCHASE AND SALES CONTRACTS
SCE supports an expedited review process for RPS power purchase and sales contracts
and appreciates the Commission’s intent to develop such a process. The existing advice letter
process for the approval of renewable contracts typically takes several months, and can
sometimes take well over a year. The protracted approval process and the unpredictability of
determining how long it will take for the Commission to act on an advice letter add regulatory
uncertainty to the process. Renewable developers often increase their prices to address this
uncertainty, leading to higher prices for the IOUs’ customers. Additionally, the delays and
uncertainties in the approval process for IOU RPS contracts make it more desirable for
developers to contract with other load-serving entities who are not subject to the Commission’s
contract review process. These are particular problems for short-term transactions that begin
deliveries shortly after execution.
In addition to recognizing the preferred status of renewable resources in the loading
order, an expedited review process for RPS contracts will reduce regulatory uncertainty and
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delays in contract approvals and allow IOUs to compete on more equal footing with other loadserving entities. The IOUs, their customers, renewable developers, and the Commission will all
benefit from a more streamlined and certain contract review process, and expedited contract
review will also address the ACR’s concern over the analyses used to select contracts becoming
stale by substantially shortening the time between contract execution and Commission approval.
Despite all of the theoretical benefits of expedited review, however, the expedited review
process proposed in the ACR simply will not work. Indeed, the proposed expedited review
process suffers from the same fatal flaws as the current “fast-track” review process for short-term
renewable procurement contracts. As the ACR acknowledges, in the three years since it was
approved by the Commission, the fast-track process “has rarely been used and no contracts have
been approved pursuant to it.”18 This is because the Commission placed so many restrictions on
utilizing the fast-track process that it completely eliminated the usefulness of the process. Rather
than incorporating lessons learned from the failure of the fast-track review process, the proposed
expedited review process continues to include the same defects. Unless the Commission makes
major changes to the proposed expedited review process, it will not streamline the contract
review process or advance any of the other objectives discussed in the ACR because, just as with
the fast-track review process, the expedited review process will never be utilized.
First, one of the key problems with the fast-track review process is the requirement that
an eligible fast-track contract conform to the applicable pro forma contract with only minor
modifications to the modifiable terms of the approved pro forma contract allowed at the
discretion of the Director of the Energy Division.19 This requirement was not well received in
the market because almost all sellers who would have been eligible for fast-track review request
some changes to the pro forma contract.
18
19
ACR at 11.
D.09-06-050 at 38 (Ordering Paragraph 1.f), 39 (Ordering Paragraph 2.e).
- 11 -
The ACR’s proposed expedited review process is even more restrictive than the fast-track
review process which has never been used to approve a contract in its three-year lifespan. In
order to be eligible for expedited review, the contract terms must match the “[p]ro forma contract
without modifications per Commission-approved Bid Solicitation Protocol.”20 Based on its
market experience over the 10-year history of the RPS program, SCE expects that very few, if
any, sellers will sign a pro forma contract without a single modification.
Negotiation of pro forma contract terms is consistent with industry practice for both
renewable and non-renewable products. Changes to the pro forma contracts are usually
necessary due to evolving market issues, project or technology-specific issues, or specific risk
tolerance limits. In fact, negotiating contract terms is in the best interests of both IOU customers
and renewable developers. The IOUs and their counterparties are negotiating mutually
beneficial transactions. Many of these contracts are for 20-year terms and involve hundreds of
millions or even over a billion dollars. Negotiated terms allow parties to be responsive to market
needs and to allocate risk to the party in the best position to effectively mitigate the risk. Market
conditions move faster than the regulatory process and no model contract can keep up with the
movement of the market. This is especially true in the case of the IOUs’ pro forma renewable
contracts, which the IOUs submit for Commission approval several months before their
solicitations even begin.
In its recent decision approving the 2012 RPS Procurement Plans, the Commission
specifically noted that the “pro forma agreements serve as the starting point for negotiating a
final agreement between a seller and utility” and that “the Commission prefers, in most
instances, that the parties negotiate contract terms.”21 The Commission should not adopt an
expedited review process that ignores the market reality that almost all RPS contracts will
include modifications from the pro forma agreements.
20
21
ACR at 13.
D.12-11-016 at 29-30.
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In order to provide a workable expedited review process, SCE proposes that an RPS
purchase and sale contract should qualify for expedited review so long as: (1) the terms of the
contract are generally consistent with an approved pro forma renewable agreement or a
renewable agreement approved by the Commission within the prior 12 months, and (2) any
modifications to the terms of the approved pro forma or other renewable agreement are not
inconsistent with the IOU’s RPS procurement plan or Commission decisions.22 This standard
will ensure that a reasonable number of renewable contracts will be eligible for expedited
review, while also making certain that any contract approved under the expedited review process
is consistent with a pro forma or other renewable agreement already approved by the
Commission. It will also provide for expedited review of sales transactions that are generally
consistent with a sales agreement approved by the Commission within the prior 12 months,
rather than excluding all sales contracts from expedited review if the IOU has not had a
solicitation for sales transactions.
Alternatively, if SCE’s proposal is not acceptable to the Commission, SCE may be able
to support a requirement that a limited set of provisions from an approved pro forma agreement
or other renewable agreement approved by the Commission within the prior 12 months, rather
than the pro forma contract in its entirety, must be unchanged in order to qualify for expedited
review. For instance, the Commission could determine that an RPS power purchase agreement is
eligible for expedited review if it contains the following provisions from an approved pro forma
or other renewable contract: (1) performance assurance amounts; (2) development security
amounts; (3) seller’s energy delivery obligation; (4) settlement interval and annual energy caps;
(5) scheduling coordinator provisions; and (6) limitation of liabilities provisions. SCE selected
these specific provisions because they are material contract terms that provide protection for
22
The approved pro forma renewable agreement could include any approved pro forma agreement from the IOUs’
large-scale RPS solicitations or any other approved renewable pro forma agreements such as the pro forma
agreements for the Renewable Auction Mechanism program and the Solar Photovoltaic program. Similarly,
any relevant renewable power purchase or sale agreement approved by the Commission within the prior 12
months should be included.
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customers and ensure performance under the agreement. In addition, by limiting the number of
contractual terms and conditions that may not be modified for a contract to qualify for expedited
review, this approach is more consistent with the market reality that most, if not all, contracts
include some changes to pro forma contract terms.
Second, the ACR proposal also limits eligibility for expedited review by requiring that
projects meet restrictive viability screens such as a viability score of 10 for site control and a
viability score of 8 for transmission system upgrade requirements. SCE is concerned that these
viability screens will exclude most, if not all, transactions from qualifying for expedited review.
SCE agrees that reasonable viability screens for expedited review are appropriate. Nevertheless,
such screens should not be so stringent that no projects can satisfy them. SCE proposes the
following modifications to the viability screens:

Site Control: SCE does not object to requiring full site control for the project site.
However, requiring full site control of the gen-tie and a project viability calculator score of 10 is
unnecessary. Many projects initially gain control of the portion of the site where the generating
facility will be built and then later gain control of the land needed to build their gen-tie to
connect to the grid. A project could have 98% site control based on this circumstance but only
score a 6 for site control in the project viability calculator. A project viability calculator score of
6 is a much more reasonable expectation to be eligible for expedited review in order to account
for common gen-tie issues.

Permitting Status: SCE agrees that it is generally reasonable to require that the
appropriate permit applications be filed in order to be eligible for expedited review. However,
there should be some flexibility on this requirement for projects that have commercial on-line
dates that are five or more years into the future. In these cases, a project viability calculator
score of 2 for permitting (permitting not initiated, no fatal flaws have been identified) should be
sufficient as permits are only in effect for a specific amount of time. It would not make sense to
require developers to apply for a permit many years in advance of expected construction, without
any intent to initiate construction during that time.
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
Transmission System Upgrade Requirements: SCE recommends that the
Commission eliminate this requirement in its entirety as it would significantly limit the pool of
projects eligible for expedited review. For projects that require transmission system upgrades,
the Commission would effectively require the project to have an interconnection agreement in
place since a transmission provider is not likely to submit an application for a Certificate of
Public Convenience and Necessity, a Permit to Construct, or a Notice of Construction for
transmission upgrades for projects that have merely been studied. SCE believes this requirement
is too strict to provide a useful expedited review process.
Third, for the contract price, net market value, and viability reasonableness criteria for
expedited review, SCE agrees with the proposed criteria for short-term power purchase and sales
contracts, but suggests that two additional criteria be added. Bilateral contracts that have an
equivalent or better net market value than contracts for similar products approved by the
Commission within the prior 12 months should qualify for expedited review. This addresses a
situation where an IOU has not conducted a recent solicitation for a specific product (e.g., sales
or unbundled renewable energy credits (“RECs”)). A bilateral transaction for such products
should not be disqualified from expedited review if the transaction has an equivalent or better net
market value than a transaction for a similar product that was recently approved by the
Commission. Additionally, in the case of a changing market where prices are increasing, a
comparison to recently executed or approved contracts may no longer be appropriate. In those
situations, the Commission should consider whether a contract’s net market value is consistent
with current market trends for similar products.
The Commission should also apply the expedited review process more broadly. There is
no basis for excluding all long-term bilateral and sales agreements from expedited review, even
if their net market value is equivalent or better than solicitation contracts.
Finally, while SCE agrees with the proposal that the generation quantity contracted
should be consistent with the IOU’s renewable net short as approved in the IOU’s RPS
procurement plan, the Commission should clarify what happens when an IOU’s renewable net
- 15 -
short using its internal net short methodology is significantly different from its renewable net
short using the Commission’s methodology. The IOUs are ultimately responsible for satisfying
their procurement quantity requirements; therefore, a contract should be eligible for expedited
review if the generation quantity contracted is consistent with the IOU’s renewable net short
based on the IOU’s renewable net short methodology as approved in the IOU’s RPS procurement
plan.
SCE’s proposed changes to prerequisites to qualify for streamlined advice letter review
are set forth in Table 1 below.23 In order to develop a reasonable and workable expedited review
process that will meet the goals of streamlined advice letter review and increased market
certainty, the Commission should adopt an expedited review process with the changes
recommended by SCE. These modifications will ensure that the IOUs and other market
participants can actually use the expedited review process while also providing the Commission
with appropriate assurance that any contracts approved through the expedited review process
meet the Commission’s standards of review for RPS contract approval.
Table 1
Proposed Prerequisites to Qualify for Streamlined Advice Letter Review Process for
Purchase & Sale Contracts Less than Five-Years and Purchase & Sale Contracts of FiveYears or Greater in Term Length
Contract Term
Length
Need
Authorization
(GWh)
23
Purchase
Sales Contracts
Purchase and Sales Contracts ≥5 years
Contracts < 5
< 5 years
years
1 month to <5
1 month to <5
≥5 years
years
years
Generation quantity contracted must be consistent with RPS net short as
approved in the IOU’s most recently approved RPS procurement plan. In cases
where the RPS net short calculations based on the IOU’s RPS net short
methodology and the Commission’s RPS net short methodology as approved in
the IOU’s most recently approved RPS procurement plan significantly differ, the
generation quantity contracted must be consistent with the RPS net short based
on the IOU’s RPS net short methodology.
Additions are shown in underline and deletions are shown in strikethrough.
- 16 -
Contract Price,
Net Market
Value, and
Viability
Reasonableness
Contract terms
Delivery Start
Date
Viability Screens
(must meet all
screens)
Contract is selected from a competitive
(1) Contract is selected from a
competitive (minimum 5 bids)
solicitation(1) Contract is selected from a
solicitation with bids of comparable competitive (minimum 5 bids) solicitation
term length and portfolio category, with bids of comparable term length and
or (2) contract is from bilateral
portfolio category, (2) contract is from
negotiations and has an equivalent
bilateral negotiations and has an
equivalent or better net market value than
or better net market value than
contracts recently (prior 12 months) contracts recently (prior 12 months)
executed from a competitive
executed from a competitive solicitation
solicitation for similar products, (3) for similar products, (3) contract is from
contract is from bilateral
bilateral negotiations and has an
negotiations and has an equivalent
equivalent or better net market value than
or better net market value than
contracts for similar products recently
contracts for similar products
(prior 12 months) approved by the
recently (prior 12 months) approved Commission, or (4) the contract’s net
by the Commission, or (4) the
market value is consistent with current
contract’s net market value is
market trends for similar products.
consistent with current market
trends for similar products.
Pro forma contract without modifications per Commission-approved Bid
Solicitation ProtocolThe terms of the contract are generally consistent with an
approved pro forma renewable agreement or a renewable agreement approved
by the Commission within the prior 12 months, and (2) any modifications to the
terms of the approved pro forma or other renewable agreement are not
inconsistent with the IOU’s RPS Procurement Plan or Commission decisions.
Within 1 year of contract execution Must be consistent with RPS Procurement
Need as approved in RPS procurement
plan
None
None
 The developer must have full site
control for the project site. The
project must have a corresponding
viability score of 106 for site
control;
- 17 -

All necessary permit applications
have been filed. The project must
have a corresponding viability
score of 5 or above for permitting
status. (For projects that do not
have commercial online dates for
5 or more years, a viability score
of 2 or above for permitting status
is sufficient to meet this screen.);
and

A Phase II Study or Facilities
Study (or equivalent) is
completed. The project must have
a corresponding viability score of
9 or above for Interconnection
Progress; and.

Consistency with
Commission
Decisions
Independent
Evaluator and
Procurement
Review Group
Transmission system upgrades
required for the project pursuant to
the most recent interconnection
study (or equivalent) require a
Permit to Construct or an
approved Notice of Construction
from the Commission, and an
application or Advice Letter, as
applicable, has been filed. (For
upgrades that do not require
Commission approval for
construction, an equivalent status
has been obtained.) The project
must have a corresponding
viability score of 8 or above for
Transmission System Upgrade
Requirements.
Power purchase agreements must be consistent with relevant Commission
decisions. Relevant decisions include, but are not limited to, D.02-08-071,
D.04-07-029, D.06-05-039, D.07-01-039, D.08-04-009, D.08-08-28, D.10-03021, as modified by D.11-01-025, D.11-12-020, D.11-12-052.
Contract selection, negotiation, and execution process reviewed by IE and
Procurement Review Group (PRG).
V.
PROPOSAL – IMPROVE RPS POWER PURCHASE AGREEMENT STANDARDS OF
REVIEW
SCE does not believe there is a need to improve the standards of review for RPS power
purchase agreements or amendments. The existing standards of review are effective and there is
no need to make substantial changes to the current process. In particular, the Commission
should not institute the ACR’s proposed requirements that additional contract administration
amendments be reviewed via advice letters and additional contracts be reviewed via applications.
- 18 -
Contrary to the goals of streamlining the contract review process and enhancing market certainty,
these modifications to the standards of review will increase regulatory uncertainty and make it
more difficult and time consuming to obtain approval of RPS contracts and capture costs savings
for customers.
The ACR reform proposals would create different standards of review for solicitation
agreements, bilateral agreements, amendments, agreements that are “beyond the scope of the
Commission’s advice letter process,” and unbundled REC transactions. SCE addresses the
standards of review for each type of agreement below. In general, SCE sees neither a need nor a
benefit from establishing separate standards of review for solicitation agreements, bilateral
agreements, and agreements that are “beyond the scope of the Commission’s advice letter
process.” Accordingly, SCE recommends that all of these contracts have the same standards of
review.
Further, the Commission should reject the “Updated Information” and “Monthly
Information Updates” requirements included in most of the proposed standards of review.
Specifically, while SCE does not object to updating its renewable net short or the project’s
viability score prior to the filing of an advice letter or application, the IOUs should not be
required to update the project’s net market value and the net market values of all comparable
bids using the most current forward curve information within one week prior to filing the advice
letter or application. Such an update is inappropriate, burdensome, and unnecessary. The
Commission should review contracts based on the net market value information the IOUs used in
selecting the contracts. Relative ranking within a group of offers is also more important that
absolute levels of valuation. To the extent the Commission is concerned that the net market
value information used in the IOUs’ shortlisting decisions has become stale, the solution is to
allow the IOUs to require shortlisted bidders to refresh their pricing shortly before contract
execution, rather than directing the IOUs to provide updated price curve data that was not
utilized by the IOUs in making contracting decisions.
- 19 -
Moreover, as discussed in Section III above, providing updated net market value
information within one week prior to the filing of the contract for Commission approval is
unreasonably burdensome. SCE’s price curve forecast is driven by SCE’s long-term gas
forecasts, which are only updated on a quarterly basis. It takes SCE’s forecasting group
approximately two weeks to generate an updated blended price forecast from beginning to end.
In addition, there is a quality control process in which these forecasts are vetted after the prices
are generated and before they are used in the valuation. After the price forecast is complete and
has been reviewed by the appropriate internal stakeholders, it then takes another two weeks to
incorporate the new price forecast into the bid evaluation model. SCE could not complete this
work in one week. Further, it would be an undue and costly burden to require the IOUs to
update their price curve forecasts and net market value calculations for every contract.
Similarly, the monthly information updates are unnecessary and duplicative given that
SCE already invites both Energy Division and Division of Ratepayer Advocates’ Staff to
monthly meetings where SCE discusses the detailed project status for every RPS project it has
under contract that is in development (including those with contracts pending Commission
approval). If Commission Staff would like to request additional details that are not currently
addressed in these monthly status update meetings, they could ask that this information be
provided in these meetings. Commission Staff can also ask questions about any project pending
Commission approval at these meetings. It would be unreasonably burdensome for the
Commission to require the IOUs to provide monthly reports providing the same information that
SCE has already taken the initiative to provide to Commission Staff.
A.
Proposed Standards of Review for Power Purchase Agreements from Solicitations
With the exception of the changes to the updated information and monthly information
requirements discussed above, SCE generally agrees with the proposed standards of review for
renewable power purchase agreements from solicitations. As explained in Section V.B below,
the same standards of review should apply to both solicitation and bilateral agreements.
- 20 -
Additionally, as discussed in Section IV above with respect to the expedited review
process, the Commission should clarify that a contract will meet the standards of review if the
generation quantity contracted is consistent with the IOU’s renewable net short based on its own
renewable net short methodology if that result is significantly different from its renewable net
short using the Commission’s methodology.
Further, as discussed in Section IV above, the contract price, net market value, and
project viability criteria do not seem to take into account evaluation of transactions in a changing
market environment. For example, in a situation where prices are increasing, the comparison to
the solicitation shortlist and all power purchase agreements executed in the prior 12 months may
not be appropriate and could require that every transaction be submitted for Commission
approval via an application. As such, Commission should also consider whether a contract’s net
market value is consistent with current market trends.
SCE’s proposed changes to the standards of review for RPS power purchase agreements
from solicitations are set forth in Table 2 below.24 SCE recommends that the same standards of
review also apply to bilateral power purchase agreements.
Table 2
Proposed Standards of Review for Power Purchase Agreements from Solicitations and
Bilateral Power Purchase Agreements
Reasonableness
Review Criterion
Need
Authorization
(GWh)
24
Standards of Review / Requirements
Generation quantity must be consistent with the IOU’s internal
analysis on its RPS net short as included and approved in the IOU’s
most recently approved RPS procurement plan. In cases where the
RPS net short calculations based on the IOU’s RPS net short
methodology and the Commission’s RPS net short methodology as
approved in the IOU’s most recently approved RPS procurement
plan significantly differ, the generation quantity contracted must be
consistent with the RPS net short based on the IOU’s RPS net short
methodology.
Additions are shown in underline and deletions are shown in strikethrough.
- 21 -
Contract Price,
Net Market
Value, and
Project Viability
Consistency with
Commission
Decisions
Updated
Information
Monthly
Information
Updates
B.
To the extent such data is available, Rreasonableness of the PPA’s
price, net market value and viability will be assessed relative to 1)
shortlisted bids from the annual RPS Solicitation from which the
contract originated or shortlisted bids from the most recent annual
RPS Solicitation; and 2) all PPAs that were executed in the 12
months prior to contract execution; and 3) current market trends.
Power purchase agreements must be consistent with relevant
Commission decisions. Relevant decisions include, but are not
limited to, D.02-08-071, D.04-07-029, D.06-05-039, D.07-01-039,
D.08-04-009, D.08-08-28, D.10-03-021, as modified by D.11-01025, D.11-12-020, D.11-12-052.
The IOU’s renewable net short, the project’s net market value, and the project’s
viability score must be updated within one week prior to filing the Advice Letter
(or application) with the Commission. Similarly, net market value calculations
for all comparable bids (as identified above) must be updated using the most
current forward curve information within one week prior to filing the Advice
Letter (or application) with the Commission.
For PPAs pending Commission approval, utilities must provide monthly updates
on project development milestones, potential compliance delays, updated project
viability scores, an updated assessment of project risk, and an updated
assessment of RPS net short. Utilities will work with Energy Division Staff to
formulate a monthly reporting template to be submitted to the Director of
Energy Division at the end of every calendar month.
Proposed Standards of Review for Bilateral Power Purchase Agreements
In view of the Commission’s preference for solicitation contracts, the ACR proposes that
bilateral renewable power purchase agreements must meet minimum development milestones in
order to satisfy the standards of review.25 The ACR reasons that such milestones “will be
required because the rationale for a bilateral transaction is that the transaction represents a unique
fleeting procurement opportunity and that it would be detrimental to ratepayers to wait until a
solicitation is held.”26
As explained in Section IV above, the proposed development milestones (which are also
included in the eligibility criteria for expedited review) are extremely stringent and it is unlikely
that many bilateral contracts would satisfy all of the milestones. Consequently, the ACR’s
25
26
ACR at 21.
Id.
- 22 -
proposed standards of review for bilateral contracts would effectively limit the IOUs’ ability to
enter into bilateral RPS agreements since any bilateral contracts that do not meet the standards of
review would have to be submitted for approval via application and the terms and conditions of
such contracts would have to be publicly disclosed. Given these restrictions, it is unlikely that
the IOUs or renewable developers would be interested in executing bilateral transactions that do
not satisfy the standards of review.
A different standard of review for bilateral RPS contracts is not justified. The
Commission previously determined that bilateral RPS contracts are subject to the same standards
as contracts that come through a solicitation.27 There is no basis for departing from the
Commission’s prior determination here. It is in the best interests of the IOUs’ customers to
allow the IOUs to consider compelling bilateral offers for renewable resources. Such bilateral
contracts may provide unique value to the IOUs’ customers and it would put the IOUs at a
competitive disadvantage if they were not able to pursue the same bilateral offers as other loadserving entities.
Moreover, as noted in the ACR, in their advice letters requesting approval of a bilateral
RPS contract, the IOUs are already required to explain: (1) the IOU’s procurement and/or RPS
portfolio needs that require the utility to procure bilaterally as opposed to through a solicitation;
(2) a description of the reasons the seller did not participate in a solicitation; and (3) why the
benefits of the bilateral contract cannot be procured through a subsequent solicitation.28 There is
no need for additional development milestone criteria. An IOU may have a compelling
justification for entering into a bilateral contract aside from the high viability of the project. For
instance, an IOU might enter into a competitive bilateral RPS contract with a Disadvantaged
Business Enterprise. Thus, there is no basis for applying viability criteria to bilateral that are not
27
28
D.09-06-050 at 28.
ACR at 21.
- 23 -
applicable to solicitation contracts, particularly when few, if any, bilateral agreements could
meet such criteria.
The proposed development milestones for bilateral RPS contracts are inconsistent with
the ACR’s stated intent to streamline the RPS procurement process and contrary to the State’s
preference for renewables as evidenced by the loading order. The Commission should apply the
same standards of review to bilateral agreements that it applies to agreements resulting from
solicitations.
C.
Proposed Standards of Review for Amended Contracts
SCE disagrees with the ACR’s requirement that any contract amendment that changes the
project’s technology or makes major modifications to the existing technology that potentially
change the economics of the project (such as the incorporation of storage) must be re-bid into the
next solicitation.29 Forcing projects to bid into the next solicitation rather than amending a
contract to accommodate a change in technology may not be appropriate in all situations. For
instance, if there is a unique opportunity to amend an approved power purchase agreement that
would result in commensurate customer value, the IOU should have the ability to amend the
agreement to the benefit of its customers. The only other alternative in that case would be to
leave the contract as is and it would not make sense to prohibit all amendments to a project’s
technology regardless of the benefit to customers. In other cases where the existing power
purchase agreement has not yet been approved by the Commission or the IOU has the option to
terminate the existing contract, it may be reasonable to require the project to re-bid into the next
solicitation.
In addition, SCE is concerned with the ACR’s proposal to require a Tier 3 advice letter to
seek Commission approval for “substantial amendments” such as “a contract price change; an
increase or decrease in contract capacity not previously approved by the Commission; a change
to the project’s commercial online date by more than three months; a change in project location;
29
Id. at 25-26.
- 24 -
or a change in interconnection point.”30 Although some of these types of amendments such as
increases in contract price are currently reviewed via Tier 3 advice letters, many amendments
that fall into this definition are currently reviewed in the ERRA proceeding as part of contract
administration.
For example, decreases in contract price or contract capacity that benefit customers have
been reviewed in ERRA and are not substantial amendments that should require Tier 3 advice
letter review. Similarly, a minor change in project location or interconnection point should not
necessitate the filing of a Tier 3 advice letter. Changes in a project’s commercial online date by
more than three months are also commonly reviewed in ERRA and the ACR provides no
justification why such amendments should always require Tier 3 advice letter review.
In D.02-10-062, the Commission established the ERRA to track utility retained
generation activities, procurement activities, and purchased power expenses in order to provide
for the recovery of all payments made pursuant to power purchase agreements, subject to the
Commission’s review of the reasonableness of the IOUs’ contract administration. In ERRA, the
IOU holds the risk for disallowance, and, as required by D.88-10-032, the IOUs must seek
commensurate customer value when executing contract amendments.31 The Commission, the
Division of Ratepayer Advocates, and other stakeholders have a full opportunity to review the
IOUs’ ERRA applications.
The ERRA process has been working effectively. SCE has not had any disallowances
related to RPS contract amendments in recent years. The ACR offers no explanation why the
Commission should depart from the current process. Redirecting amendments that are currently
being reviewed in ERRA into the Tier 3 advice letter process would not only create market
uncertainty, which raises costs for customers, but it would also result in a significant increase in
the number of advice letters filed with the Commission. In SCE’s 2012 ERRA filing alone, SCE
30
31
Id. at 26.
D.88-10-032 at 45 (Conclusion of Law 45).
- 25 -
included over 20 amendments that would now, under this proposal, be filed as individual advice
letters. Instead of streamlining the contract review process, filing these amendments by Tier 3
advice letters would make the contract review process more complicated, time consuming, and
burdensome. This outcome would be bad for the IOUs, bad for customers, bad for renewable
developers, and bad for the Commission. SCE strongly urges the Commission to reject this
portion of the ACR and continue to give the IOUs the flexibility to determine which contract
administration amendments belong in the ERRA process and which amendments should be filed
by advice letter.
With respect to the other standards of review for amended contracts, SCE suggests the
same modifications discussed above to the need authorization, updated information, and monthly
information update criteria. Moreover, for the contract price, net market value, and project
viability criteria, the Commission should also consider current market trends as explained above.
Furthermore, the Commission should recognize that the evaluation of contract price, net market
value, and project viability for amendments is a case-by-case analysis. In particular, the
Commission must consider any amendments in comparison to the existing power purchase
agreement. If an IOU with a binding, Commission-approved power purchase agreement is
offered an amendment that would decrease the price of such contract, that amendment would
benefit customers, even if the amended contract price does not compare favorably to shortlisted
bids from the most recent RPS solicitation or other executed contracts. The Commission should
consider other market data in evaluating amendments but it should not reject amendments that
benefit customers when the alternative is the higher priced contract without the amendment.
SCE’s proposed changes to the standards of review for amended contracts are set forth in
Table 3 below.32
32
Additions are shown in underline and deletions are shown in strikethrough.
- 26 -
Table 3
Proposed Standards of Review for Amended Contracts
Reasonableness
Review Criterion
Need
Authorization
(GWh)
Contract Price,
Net Market
Value, and
Project Viability
Technology
Change
Consistency with
Commission
Decisions
Updated
Information
Monthly
Information
Updates
Standards of Review / Requirements
Generation quantity must be consistent with RPS net short approved
in IOU’s most recently approved RPS procurement plan. In cases
where the RPS net short calculations based on the IOU’s RPS net
short methodology and the Commission’s RPS net short
methodology as approved in the IOU’s most recently approved RPS
procurement plan significantly differ, the generation quantity
contracted must be consistent with the RPS net short based on the
IOU’s RPS net short methodology.
To the extent such data is available, Rreasonableness of the
amended PPA’s price, net market value and viability will be
assessed relative to: 1) shortlisted bids from the most recent annual
RPS Solicitation; and 2) all PPAs that were executed in the 12
months prior to contract execution; 3) current market trends; and 4)
the original PPA.
An amended PPA must be re-bid into the next RPS solicitation if
the project will be utilizing a different technology than is stated in
the original PPA.
Amended power purchase agreements must be consistent with relevant
Commission decisions. Relevant decisions include, but are not limited to, D.0208-071, D.04-07-029, D.06-05-039, D.07-01-039, D.08-04-009, D.08-08-28,
D.10-03-021, as modified by D.11-01-025, D.11-12-020, D.11-12-052.
The IOU’s renewable net short, the project’s net market value, and the project’s
viability score must be updated within one week prior to filing the Advice Letter
with the Commission. Similarly, net market value calculations for all
comparable bids (as identified above) must be updated using the most current
forward curve information within one week prior to filing the Advice Letter with
the Commission.
For Amended PPAs awaiting approval by California Public Utilities
Commission (CPUC), utilities must provide monthly updates on project
development milestones, potential compliance delays, updated project viability
scores, an updated assessment of project risk an updated assessment of portfolio
net short. Utilities will work with Energy Division Staff to formulate a monthly
reporting template to be submitted to the Commission at the end of every
calendar month.
- 27 -
D.
Proposed Standards of Review for Power Purchase Agreements that are Beyond the
Scope of the Commission’s Advice Letter Process
The proposed standards of review for power purchase agreements that are beyond the
scope of the advice letter process (i.e., contracts that do not meet other standards of review,
contracts with a technology that is not commercially proven, and contracts that will annually
provide more than 1% of the IOUs’ total bundled sales) should be eliminated. The ACR offers
no basis for concluding that the existing advice letter process is inadequate for review of these
agreements. The IOUs’ advice letters include the same detailed information that would be
included in an application and the Commission considers the same factors regardless of whether
a contract is filed via advice letter or application. The Commission should continue to review
these contracts in the same manner as other contracts that have been executed bilaterally or as the
result of a solicitation.
SCE is particularly concerned with the proposed requirement that these contracts should
be disclosed publicly. This proposal is contrary to the Commission’s existing decisions on
confidentiality.33 Moreover, combined with the requirement that these contracts be filed by
application, this approach will not only shrink the market for bilateral agreements and new
technologies by limiting the number of offers for such projects, but it will also significantly
decrease both buyers’ and sellers’ desire to enter into such transactions, even if they provide a
good value to customers. Indeed, it is likely that few, if any, of these agreements will be
executed.
Further, the Commission should realize that many of the projects that have helped SCE
contribute to the State’s renewable energy goals are large projects whose deliveries constituted
more than 1% of SCE’s bundled retail sales. Making it more difficult and burdensome to
contract with projects that make significant contributions to California’s RPS targets is contrary
to the goals of the RPS program and the State’s preference for renewable resources.
33
See D.06-06-066; D.08-04-023.
- 28 -
E.
Proposed Standards of Review for Unbundled Renewable Energy Credits
SCE’s comments on the proposed standards of review for unbundled REC transactions
generally mirror SCE’s comments on the other standards of review. Additionally, SCE notes
that the evaluation of the contract price should not be limited to unbundled REC bids from the
most recent RPS solicitation and unbundled REC contracts that were executed in the prior 12
months. An IOU may utilize unbundled RECs to meet short-term requirements and balance its
renewable portfolio without having solicited unbundled RECs or executed other unbundled REC
transactions in the past 12 months. In those cases, it is appropriate to consider other market data
regarding the price of unbundled RECs, as well as current market trends. SCE’s proposed
changes to the standards of review for unbundled REC contracts are set forth in Table 4 below.34
Table 4
Proposed Standards of Review for Unbundled Renewable Energy Credit Transactions
Reasonableness
Review Criterion
Need
Authorization
(GWh)
Contract Price
Updated
Renewable Net
Short
Consistency with
34
Standards of Review / Requirements
REC quantity must be consistent with RPS net short approved in
IOU’s most recently approved RPS procurement plan. In cases
where the RPS net short calculations based on the IOU’s RPS net
short methodology and the Commission’s RPS net short
methodology as approved in the IOU’s most recently approved RPS
procurement plan significantly differ, the REC quantity contracted
must be consistent with the RPS net short based on the IOU’s RPS
net short methodology.
To the extent such data is available, Rreasonableness of contract’s
price will be assessed relative to: 1) shortlisted unbundled REC bids
from the most recent annual RPS Solicitation; and 2) all unbundled
REC contracts that were executed in the 12 months prior to contract
execution; 3) other market data regarding the price of unbundled
RECs; and 4) current market trends.
The IOU’s renewable net short must be updated within one week
prior to filing the Advice Letter with the Commission.
Purchase agreements must be consistent with relevant Commission decisions.
Additions are shown in underline and deletions are shown in strikethrough.
- 29 -
Commission
Decisions
Relevant decisions include, but are not limited to, D.02-08-071, D.04-07-029,
D.06-05-039, D.07-01-039, D.08-04-009, D.08-08-28, D.10-03-021, as modified
by D.11-01-025, D.11-12-020, D.11-12-052.
VI.
PROPOSAL – RPS INDEPENDENT EVALUATOR REPORTS
The ACR proposes that the IE must provide supplemental calculations of the capacity
and ancillary services values in addition to providing findings regarding the reasonableness and
accuracy of the IOUs’ calculations.35 The ACR provides no information about why such
independent calculations are needed. The role of the IE is to oversee the solicitation and
negotiations process, not to run the analytics independently. Not all IEs are skilled to do this
work. The IOUs have experienced analysts to perform these calculations, but the IEs may not.
Indeed, imposing these requirements may unnecessarily limit the pool of IEs and increase IErelated costs to customers. These requirements would be even more burdensome if the IE has to
update these calculations as part of its IE report for the advice letter seeking contract approval,
especially if the Commission adopts the ACR’s proposed one-month deadline for filing advice
letters. For all these reasons, the Commission should not require the IEs to provide independent
calculations of capacity and ancillary services values.
VII.
IMPLEMENTATION OF NEW LEAST-COST BEST-FIT REQUIREMENTS
The ACR asks several questions regarding how the Commission should implement the
statutory requirements related to least-cost best-fit (“LCBF”) included in Senate Bill (“SB”) 2
(1x).36 SCE responds to those questions below. Additionally, SCE notes that the IOUs have
been implementing their LCBF evaluation processes over the 10-year history of the RPS
program and that such evaluation criteria have worked effectively. SCE and the other IOUs
35
36
ACR at 36.
Id. at 37-38.
- 30 -
include a public description of their LCBF methodologies in their RPS procurement plans and
SCE also describes its LCBF evaluation process in detail at the various bidding conferences it
holds prior to launching a solicitation.37
For the most part, SCE’s LCBF evaluation methodology already incorporates all of the
statutory provisions enacted through SB 2 (1x). Therefore, a wholesale review of the LCBF
criteria is unnecessary. The only issue the Commission needs to address is its restriction on the
IOUs’ ability to include an integration cost adder (other than zero) into the evaluation
methodology. Rather than the entire LCBF methodology, the Commission should instead focus
its resources on implementing an integration cost adder that complies with statutory
requirements.38 If the Commission believes further stakeholder processes are needed before an
integration cost adder can be utilized, then the Commission should expeditiously hold a
workshop so that the parties can come together to determine how the integration cost adder
should be developed.

Please describe how the Commission should implement each of the four specific
topics listed in Section 399.13(a)(4)(A). Please include quantitative examples where
relevant.
SCE already takes most of these requirements into consideration in its LCBF
methodology. Specifically, for Section 399.13(a)(4)(A)(i) – “[e]stimates of indirect costs
associated with needed transmission investments and ongoing electrical corporation expenses
resulting from integration and operating eligible renewable energy resources,” SCE includes
transmission costs in its quantitative analysis and bases the transmission cost on the estimated
cost of reimbursable network upgrades attributable to individual projects.39 SCE derives this
estimate from the applicable completed interconnection study or interconnection agreement. For
37
38
39
The description of SCE’s LCBF methodology filed with SCE’s original 2012 RPS Procurement Plan on May
23, 2012 is included as Appendix A to these comments.
See Cal. Pub. Util. Code § 399.13(a)(4)(A)(i).
Appendix A at 6, Section II.A.1.a under “Transmission Cost” and Section II.A.1.b.
- 31 -
those projects outside SCE’s service area, the Transmission Ranking Cost Reports of other IOUs
are used as appropriate. SCE applies the required upgrade costs to get the project delivered to
the nearest defined market (e.g., NP15, SP15, ZP 26 generation trading hubs, etc.). For projects
with an assumed delivery point outside the California Independent System Operator (e.g., liquid
power trading hub), SCE applies a power swapping methodology, where the power is assumed to
be sold into the local market.
SCE does not currently incorporate an integration cost adder into its LCBF methodology
because the Commission has declined to allow a non-zero adder.40 The Commission should
expeditiously adopt a real integration cost adder as noted above.
For Section 399.13(a)(4)(A)(ii) – “[t]he cost impact of procuring the eligible renewable
energy resources on the electrical corporation’s electricity portfolio,” SCE performs a
quantitative assessment of each proposal individually and subsequently ranks them based on the
proposal’s benefit and cost relationship.41 Specifically, the total benefits and total costs are used
to calculate the net levelized cost or “Renewable Premium” per each complete and conforming
proposal. Benefits are comprised of separate capacity and energy components, while costs
include the contract payments, debt equivalence, congestion cost, and transmission cost. SCE
discounts the monthly benefit and cost streams to a common base date. The result of the
quantitative analysis is a merit-order ranking of all complete and conforming proposals’
Renewable Premiums that help define the preliminary short list.
For Section 399.13(a)(4)(A)(iii) related to project viability, SCE addresses these factors
through the use of the Project Viability Calculator.42
Lastly, for Section 399.13(a)(4)(A)(iv) – “[w]orkforce recruitment, training, and retention
efforts, including the employment growth associated with the construction and operation of
eligible renewable energy resources and goals for recruitment and training of women, minorities,
40
41
42
Id. at 5, Section II.A.1.a under “Integration Cost.”
Id. at 2, Section II.
Id. at 7, Section II.A.1.e.
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and disabled veterans,” SCE includes in its qualitative criteria that determine advancement onto
the short list or tie-breakers, if any, whether an entity is certified as a California woman, minority
or disabled veteran business enterprise (“WMDVBE”) as set forth in Commission General Order
156 and benefits to minority and low income communities.43 In order to implement Section
399.13(a)(4)(A)(iv), SCE proposes to add to this list of qualitative criteria the language in the
statute: “Workforce recruitment, training, and retention efforts, including the employment
growth associated with the construction and operation of eligible renewable resources and goals
for recruitment and training of women, minorities, and disabled veterans.”

For each of these four topics, please compare your implementation proposal with
the existing LCBF methodology as set out in D.04-07-029 and applied in the 2011
RPS Procurement Plans approved in D.11-04-030.
Since SCE’s LCBF methodology already addresses most of the requirements in the
statute, the only changes from SCE’s current methodology would be adding to the list of
qualitative criteria to implement Section 399.13(a)(4)(A)(iv) and incorporation of a non-zero
integration adder when permitted by the Commission.

For each of these four topics, and for your LCBF proposal as a whole, please explain
how your proposal would affect costs ultimately paid by ratepayers for RPS-eligible
energy, using quantitative examples where relevant.
Since SCE’s LCBF methodology already addresses most of the requirements in the
statute, the only changes from SCE’s current methodology would be adding to the list of
qualitative criteria to implement Section 399.13(a)(4)(A)(iv) and incorporation of a non-zero
integration adder when permitted by the Commission. There would be benefit to customers if
integration costs are accounted for in LCBF evaluation process because the IOUs could more
accurately account for all of the costs associated with RPS procurement in the evaluation
process.
43
Id. at 8, Section II.A.1.f.
- 33 -

For each of the four topics, and for your LCBF proposal as a whole, please explain
how your proposed criteria would contribute to the efficiency of the RPS
procurement process.
Since SCE’s LCBF methodology already addresses most of the requirements in the
statute, the only changes from SCE’s current methodology would be adding to the list of
qualitative criteria to implement Section 399.13(a)(4)(A)(iv) and incorporation of a non-zero
integration adder when permitted by the Commission. Implementing the qualitative criteria as
proposed by SCE would not require an additional review process for stakeholders or the
Commission, thus efficiently resolving any questions as to whether or not the Commission is
required to implement additional requirements to meet the new statutory requirements.
Including a non-zero integration adder in the evaluation process would also contribute to the
efficiency of the RPS procurement process by providing for a more accurate accounting of all of
the costs associated with RPS procurement.

What additional topics, if any, should be part of the LCBF process? Please provide
a detailed discussion of each topic, using quantitative examples where relevant.
Other than the issues discussed above, SCE has not seen any evidence that its LCBF
methodology requires modification.
VIII.
GREEN ATTRIBUTES STANDARD TERM AND CONDITION
SCE believes the “Green Attributes” non-modifiable standard term and condition remains
necessary from both a commercial and regulatory perspective. The term ensures that the IOUs’
customers receive both RECs and all other green attributes that they are paying for under RPS
contracts. Further, because the term has been fully vetted by stakeholders and the Commission
and is not modifiable, it increases efficiency by avoiding protracted negotiation over what green
attributes are conveyed.
Assembly Bill 2196 may require revisions to the Green Attributes term. It added Public
Utilities Code Section 399.12.6(c), which provides that:
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For all electricity products generated using biomethane that are credited toward
the renewables portfolio standard procurement obligations established pursuant to
this article, sufficient renewable and environmental attributes of biomethane
production and capture shall be transferred to the retail seller or local publicly
owned electric utility that uses that biomethane to ensure that there are zero net
emissions associated with the production of electricity from the generating facility
using the biomethane. The provisions of this subdivision shall be applied in a
manner consistent with the definition of “green attributes” as specified by the
commission in Decision 08-08-028, Decision on Definition and Attributes of
Renewable Energy Credits for Compliance with the California Renewables
Portfolio Standard (August 21, 2008), as may be modified by subsequent decision
of the commission.
Although some modification to the Green Attributes term may be needed, SCE believes
the term continues to have value and that any modifications should be limited to those necessary
to implement new statutory requirements.
IX.
CONCLUSION
For all the foregoing reasons, the Commission should incorporate SCE’s proposed
modifications to the ACR reform proposals and implement the LCBF provisions in SB 2 (1x) as
discussed herein. The Commission should also retain the Green Attributes standard term and
condition.
Respectfully submitted,
JENNIFER TSAO SHIGEKAWA
CATHY A. KARLSTAD
/s/ Cathy A. Karlstad
By: Cathy A. Karlstad
Attorneys for
SOUTHERN CALIFORNIA EDISON COMPANY
November 20, 2012
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Telephone:
(626) 302-1096
Facsimile:
(626) 302-6962
E-mail:
Cathy.Karlstad@sce.com
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VERIFICATION
I am a Manager in the Renewable and Alternative Power Department of Southern
California Edison Company and am authorized to make this verification on its behalf. I am
informed and believe that the matters stated in the foregoing pleading are true.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 20th day of November, 2012, at Rosemead, California.
/s/ Kathleen M. Sloan
By: Kathleen M. Sloan
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
Appendix A
Southern California Edison Company’s (“SCE”) Least-Cost Best-Fit Methodology
I.
Introduction
A.
Note relevant language in statute and CPUC decisions approving LCBF
process and requiring LCBF Reports
Under the direction of the California Public Utilities Commission (the “Commission” or
“CPUC”), SCE conducts solicitations for the purpose of procuring power from eligible
renewable energy resources to meet California’s Renewables Portfolio Standard (“RPS”). SCE
evaluates and ranks proposals based on least-cost best-fit (“LCBF”) principles that comply with
criteria set forth by the Commission in Decision (“D.”) 03-06-071 and D.04-07-029 (the “LCBF
Decisions”).1
B.
Describe goals of IOU’s bid evaluation and selection criteria and processes
The goal of SCE’s evaluation and selection criteria and processes is to provide decision
metrics so that SCE can procure renewable energy economically, while providing the most value
to its customers. The LCBF analysis evaluates both quantitative and qualitative aspects of each
proposal to estimate its value to SCE’s customers and its relative value in comparison to other
proposals.
1.
Describe how “need” will be determined for this solicitation.
Comment specifically on whether, and to what extent, you considered
other procurement options (e.g. UOG, solar PV program, feed-in
tariffs, RAM, etc.) to meet IOU’s overall need stated in its
Procurement Plan.
In determining need, SCE plans to examine the time period between 2012 and 2022. The
renewable energy goals under Senate Bill (“SB”) 2 (1x), as implemented by the Commission in
D.11-12-020 are: (1) 20% of overall retail sales for the first compliance period from 2011-2013;
(2) 21.7% of 2014 retail sales plus 23.3% of 2015 retail sales plus 25% of 2016 retail sales for
the second compliance period from 2014-2016; (3) 27% of 2017 retail sales plus 29% of 2018
retail sales plus 31% of 2019 retail sales plus 33% of 2020 retail sales for the third compliance
period from 2017-2020; and (4) 33% of retail sales in each year thereafter. SCE’s forecast of its
goals will be based on its most recent bundled sales forecast.
These goals will be measured against SCE’s forecast of renewable generation. SCE’s
projected renewable generation will assume 100% delivered energy from executed contracts that
are already on-line and 60% delivered energy from executed contracts not yet on-line,
recontracting of expiring renewable projects less than or equal to 20 MW at a 100% success rate,
and a forecast to meet goals for generic feed-in tariff programs (i.e., the Renewable Auction
Mechanism (“RAM”) program, the Solar Photovoltaic Program (“SPVP”), and the Public
Utilities Code Section 399.20 feed-in tariff program). Projects under negotiation will not be
1
The Commission has also made rulings on various evaluation criteria in its decisions on the investor-owned
utilities’ (“IOUs’”) RPS procurement plans. See also Cal. Pub. Util. Code § 399.13(a)(4)(A).
-1-
included in the forecast. Moreover, expiring renewable projects greater than 20 MW will have
an assumed recontracting rate of 0%.
Based on a comparison of the goals from 2012 through 2022 against forecasted
renewable generation, SCE will arrive at a final “need” number by determining how much
renewable energy SCE would have to procure to close SCE’s short position for that time period
by procuring ratably from now through 2022.
II.
Bid Evaluation and Selection Criteria
While assumptions and methodologies have evolved slightly over time, the basic
components of SCE’s evaluation and selection criteria and process for RPS contracts were
established by the Commission’s LCBF Decisions. Consistent with those LCBF Decisions, the
three main steps to be undertaken by SCE are: (i) initial data gathering and validation, (ii) a
quantitative assessment of proposals, and (iii) adjustments to selection based on proposals’
qualitative attributes.
Prior to receiving proposals, SCE will finalize criteria with the Independent Evaluator
(“IE”) to determine which attributes could make proposals clear outliers. SCE will then finalize
the major assumptions and methodologies that drive valuation, including power and gas price
forecasts, existing and forecast resource portfolio, and firm capacity value forecast. Other
assumptions, such as the Transmission Ranking Cost Report (“TRCR”), will be filed with the
Commission for approval prior to the release of solicitation materials.
Once proposals are received, SCE will begin an initial review for completeness and
conformity with the solicitation protocol. The review included an initial screen for required
submission criteria such as a conforming delivery point, minimum project size, and the
submission of particular proposal package elements. Sellers lacking any of these items will be
allowed a reasonable cure period to remedy any deficiencies. Following this check for
conformity, SCE will determine which proposals are clear outliers. For proposals deemed clear
outliers, SCE concludes any further review. For the remaining proposals, SCE will conduct an
additional review to determine the reasonableness of proposal parameters such as generation
profiles and capacity factors. SCE will work directly with sellers to resolve any issues and
ensure the data was ready for evaluation.
After these reviews, SCE will perform a quantitative assessment of each proposal
individually and subsequently rank them based on the proposal’s benefit and cost relationship.
Specifically, the total benefits and total costs are used to calculate the net levelized cost or
“Renewable Premium” per each complete and conforming proposal. Benefits are comprised of
separate capacity and energy components, while costs include the contract payments, debt
equivalence, congestion cost, and transmission cost. SCE discounts the monthly benefit and cost
streams to a common base date. The result of the quantitative analysis is a merit-order ranking
of all complete and conforming proposals’ Renewable Premiums that help define the preliminary
short list.
-2-
In parallel with the quantitative analysis, SCE will conduct an in-depth assessment of the
top proposals’ qualitative attributes. This analysis utilizes the Project Viability Calculator to
assess certain factors including the company/development team, technology, and development
milestones. Additional attributes such as transmission area/cluster, generating facility location,
seller concentration, portfolio fit of commercial on-line date, project size, and dispatchability are
also considered in the qualitative analysis. These qualitative attributes are considered to either
eliminate non-viable proposals or add projects with high viability to the final short list of
proposals, or to determine tie-breakers, if any.
Following its analysis, SCE will consult with its Procurement Review Group (“PRG”)
regarding the final short list and specific evaluation criteria. SCE may then negotiate with the
shortlisted sellers for a period of approximately 8 months after notification of shortlisting. At the
end of the negotiation period, all sellers that were able to complete negotiations may have a onetime opportunity to submit new pricing. SCE may then make final selections and enter into final
agreements based on the new pricing. SCE, in its sole discretion, reserves the right to enter into
final agreements with as many sellers as SCE chooses, including the right to not enter into any
final agreements at all. Whether a proposal selected through this process results in an executed
contract depends on the outcome of negotiations between SCE and sellers. Periodically, SCE
updates the PRG regarding the progress of negotiations. SCE also consults with its PRG prior to
the execution of any successfully negotiated contracts. Subsequently, SCE executes contracts
and submits them to the Commission for approval via advice letter filings.
A.
Description of Criteria
1.
List and discuss the quantitative and qualitative criteria that will be
used to evaluate and select bids.
a.
Market valuation
SCE will evaluate the quantifiable attributes of each proposal individually and
subsequently rank them based on the proposal’s benefit and cost relationship, specifically the net
levelized cost of the project or Renewable Premium. These individual quantitative components
include: capacity benefits, energy benefits, contract payments, debt equivalence mitigation cost,
transmission cost, and congestion cost. In developing its relative merit order ranking of
proposals, SCE’s evaluation methodology incorporates information provided by sellers and
assumptions prescribed and set by the Commission with its internal methodologies and forecasts
of market conditions. The objective of the quantitative assessment and relative Renewable
Premium ranking is to develop a preliminary short list that is further refined based on the nonquantifiable attributes discussed below. Each of the elements for the RPS quantitative analysis is
described briefly below.
-3-
Benefits

Capacity Benefit
Each proposal is assigned capacity benefits, if applicable, based on SCE’s forecast of net
capacity value and the quantity of resource adequacy derived by SCE based on the seller’s offer
capped at the generating facility’s peak capacity contribution factor.
Peak capacity contribution factors are calculated in a manner consistent with the
Commission’s Resource Adequacy accounting rules (D.09-06-028) utilizing a 70% exceedance
factor methodology. Peak capacity contribution factors are both technology and locationspecific. Technological differentiation does not refer to the fuel source, but rather the method of
converting other energy sources into electricity (e.g., solar trough, solar photovoltaic). For
proposals with dispatchable capabilities at SCE’s control, the peak capacity contribution factor is
based on the availability of the proposed project.
Monthly capacity benefits include the product of SCE’s net capacity value forecast and
the quantity of resource adequacy determined for each month of the year. Capacity benefits are
only given for those months the seller’s offer indicates that the seller will provide such benefits.

Energy Benefit
SCE measures the energy benefits, as applicable, of a proposal by evaluating the
estimated market value of energy. The evaluation of energy benefits is performed with a base
portfolio and system that is consistent with Track II of SCE’s most recent Long-Term
Procurement Plan (“LTPP”), with some updates to account for the latest gas price and the results
of recent procurement activities. In the event that a proposal provides additional value to SCE
from the provision of one or more ancillary services (regulation, spin, or non-spin), SCE may use
an internal forecast for ancillary service prices as a means of evaluating any incremental benefit.
For proposals with must-take energy, SCE calculates the energy benefits of a proposal
based on the estimated market value of energy assessed through the use of Ventyx’s ProSym
model. The ProSym runs consist of an hourly, least-cost dispatch of the base resource portfolio
against SCE’s current demand and price forecasts. The hourly energy benefit for the proposal is
the resulting market price multiplied by the hourly seller-provided generation profile.
For proposals with dispatchable capabilities at SCE’s control, SCE calculates the net
energy benefits based on the market value of the energy when the proposed resource dispatches.
ProSym determines the dispatch economics for the proposed resource according to the unit
characteristics provided by the seller.
SCE’s resource portfolio is dispatched against an SCE area power price forecast. SCE’s
gas price and power price forecasts are based on a blend of a near-term market view and a
longer-term fundamental view of prices.
-4-
The simulation model, and hence the energy benefit calculation, captures additional
quantitative effects that SCE has been asked to consider by the Commission, including
dispatchability. The dispatchability benefits of these characteristics are implied in the energy
benefit and are not addressed separately.
Costs

Debt Equivalence
“Debt equivalence” is the term used by credit rating agencies to describe the fixed
financial obligation resulting from long-term power purchase agreements (“PPAs”). Pursuant to
D.04-12-048, the Commission permitted the IOUs to recognize costs associated with the effect
debt equivalence has on the IOUs’ credit quality and cost of borrowing in their evaluation
process. In D.07-12-052, the Commission reversed this position. SCE, however, filed a petition
for modification of D.07-12-052. In November 2008, the Commission issued D.08-11-008,
which authorized the IOUs to recognize the effects of debt equivalence when comparing PPAs in
their bid evaluations, but not when the IOUs are considering a utility-owned generation project.
As such, SCE considers debt equivalence in the evaluation process.

Contract Payments
The primary costs associated with each proposal are the contract payments that SCE
makes to sellers for the expected renewable energy deliveries.
Proposals typically include an all-in price for delivered renewable energy, which is
adjusted in each time-of-delivery period by energy payment allocation factors (“TOD factors”).
Total payments are determined by multiplying the generation by the contract price, adjusted for
each TOD period. For projects that include a capacity-related payment in addition to an energy
price, the total payments are determined by using the TOD-adjusted generation based on the
generation profile provided in the proposal, the energy price, and the capacity payment.

Integration Cost
Integration costs, where applicable, are the additional system costs required to provide
sufficient ancillary service capability including load following and frequency regulation to
integrate renewable resources. As California continues to procure additional intermittent
renewable resources, SCE believes that current levels of intermittent renewable resources will
require an increase in the provision of the ancillary services mentioned above, and that an
integration study that reflects updated regulatory and procurement expectations should be used as
a basis for integration costs. Moreover, new Public Utilities Code Section 399.13(a)(4)(A)(i)
provides that the Commission shall adopt LCBF criteria that take into account “[e]stimates of
indirect costs associated with needed transmission investments and ongoing electrical
corporation expenses resulting from integrating and operating eligible renewable energy
resources.” However, in D.11-04-030, the Commission declined to allow the use of non-zero
integration cost adders for the 2011 RPS solicitation. SCE will consider integration costs in its
next RPS solicitation to the extent allowed by the Commission.
-5-

Congestion Cost
Localized congestion may cause a reduction in (or negative) prices at a particular
locational marginal price (“LMP”) in the California Independent System Operator’s (“CAISO”)
Market Redesign and Technology Upgrade (“MRTU”) market. In D.11-04-030, the Commission
held that the IOUs must incorporate an assessment of these congestion costs in their 2011 LCBF
evaluation.
Those projects that select an “Energy-Only” interconnection do not fund the
deliverability upgrades a project needs to ensure its energy can serve load and avoid localized
congestion. As such, these projects increase the risk of congestion in these locations to a degree
greater than those projects that do fund these upgrades. In order to capture this difference, SCE
will apply a congestion cost adder to all CAISO projects that selected an Energy-Only
interconnection. The adder is based on LMPs in the MRTU market in the location that the seller
plans to interconnect.

Transmission Cost
Transmission costs are based on the estimated cost of reimbursable network upgrades
attributable to individual projects. To participate in the 2012 Request for Proposals (“RFP”),
SCE requires seller to have an existing Phase I interconnection study, a Phase II study, or a
signed interconnection agreement. Transmissions costs applicable to the project will be based on
the applicable completed interconnection study or interconnection agreement.
Finally, for those projects being studied in Queue Cluster 5, and to the extent applicable,
transmission costs will be derived from cost estimates for network upgrades identified in the
CAISO’s Transmission Plan as part of its annual Transmission Planning Process.
b.
Transmission Cost Adders
Discuss how much detailed transmission cost information the IOU
requires for each project.
SCE requires all sellers to have a Phase I interconnection study, a Phase II
interconnection study, or a signed interconnection agreement. The seller must provide copies of
all interconnection studies and/or agreements as part of seller’s proposal.
Discuss whether cost adders are always imputed for projects in
transmission-constrained areas, or whether and how costs for
alternative commercial transactions (i.e. swapping, remarketing) are
substituted.
SCE uses the best available information it can find when determining the cost of potential
upgrades for projects in transmission-constrained areas. For those projects outside SCE’s service
area, the TRCRs of Pacific Gas and Electric Company or San Diego Gas & Electric Company
are used as appropriate. SCE applies the required upgrade costs to get the project delivered to
-6-
the nearest defined market (e.g., NP15, SP15, ZP 26 Generation Trading Hubs). For projects
with an assumed delivery point outside the CAISO (e.g., liquid power trading hub), SCE applies
a power swapping methodology, where the power is assumed to be sold into the local market.
c.
Portfolio fit
SCE’s LCBF quantitative evaluation process inherently captures the impact of portfolio
fit. For example, as different proposals are added to the overall portfolio, the resultant residual
net short or net long position is impacted. Projects that more often increase SCE’s net long
capacity positions are assigned less capacity benefits than those projects that are more often
filling net short positions.
SCE also considers portfolio fit in its qualitative analysis. Specifically, when assessing
additional qualitative characteristics to determine advancement onto the short list or tie-breakers,
SCE’s preference is for those projects that have commercial operation dates that match periods
of SCE’s need for renewable energy.
d.
Credit and collateral requirements
In order to ensure comparable pricing for ranking, SCE requires sellers to bid conforming
proposals committing to posting SCE’s pro forma performance assurance amount. SCE accepts
lesser performance assurance to be bid as long as a conforming proposal is also submitted.
Performance assurance is the collateral posted by the seller during the operating period.
e.
Project Viability
SCE assesses the following attributes using the Project Viability Calculator:















Company/Development Team
Project Development Experience
Ownership/O&M Experience
Technology
Technical Feasibility
Resource Quality
Manufacturing Supply Chain
Development Milestones
Site Control
Permitting Status
Project Financing Status
Interconnection Progress
Transmission Requirements
Reasonableness of Commercial Operation Date (“COD”)
Additional Qualitative Attributes
-7-
f.
Other qualitative criteria / preferences
Following the Project Viability Calculator qualitative assessment, SCE considers
additional qualitative characteristics to determine advancement onto the short list or tie-breakers,
if any. These additional characteristics may include:
















B.
Certified as California woman, minority or disabled veteran business enterprise
(“WMDVBE”) as set forth in Commission General Order 156
Transmission area (e.g., Tehachapi, Sunrise, within SCE’s load pocket)
Congestion, negative price, and curtailment considerations not captured in the
quantitative valuation
Energy-Only concentration
Facility interconnection process progress
Portfolio fit of COD
Seller concentration
Expected generation (GWh/year)
Dispatchability
Contract price
Alternative Renewable Premium (i.e., Renewable Premium including integration
costs)
Environmental impacts of seller’s proposed project on California’s water quality and
use
Resource diversity
Benefits to minority and low income communities
Local reliability
Environmental stewardship
If a weighting system is used, please describe how each LCBF component is
assigned a quantitative or qualitative weighting compared to other
components. Discuss the rationale for the weightings.
SCE does not apply a weighting system in its LCBF evaluation.
C.
Describe role of quantitative and qualitative factors on the LCBF ranking
process.
SCE’s LCBF quantitative evaluation of the proposals incorporates energy and capacity
benefits with contract payments, transmission cost, debt equivalence, and congestion cost to
create individual benefit and cost relationships, namely, the Renewable Premium. It is the
Renewable Premium that is used to rank and compare each project. Qualitative attributes of each
proposal are then considered to further screen the short list and determine tie-breakers to arrive at
a final short list of proposals.
-8-
D.
Discuss how the evaluation process differs, if at all, for out-of-state projects
(e.g. incorporating costs of delivering energy from out-of-state facilities).
The overall evaluation methodology is applied consistently to projects regardless of
location. Energy benefits for those projects outside of the CAISO is based on the pricing at the
seller-elected liquid power trading hub or CAISO intertie (subject to SCE’s approval in its sole
discretion) according to SCE’s fundamental price forecast for hubs across the Western Electricity
Coordinating Council (“WECC”).
For those projects within or connected directly to the CAISO, SCE applies the cost to
customers of new CAISO network upgrades required for the new project. SCE customers are not
liable for any network upgrades outside of the CAISO (outside of any costs that may be
imbedded within the contract pricing) so transmission cost adders are zero for out-of-state
projects.
E.
Evaluation of utility-owned, turnkey, buyouts, and utility-affiliate projects
1.
Describe how utility-owned projects are evaluated against PPAs.
SCE views utility-owned cost-of-service generation as a necessary and good option for
customers to have. SCE does not evaluate proposed utility-owned projects against PPAs, as
utility-owned generation and contracted-for generation are fundamentally different products. As
such, any attempt to do a numerical comparison of them is unworkable. This topic is discussed
in detail in the Supplemental Testimony to SCE’s 2010 LTPP. Moreover, approval of a utilityowned project would not be submitted through the solicitation process, but through a formal
application.
2.
Describe how turnkey projects are evaluated against PPAs.
Turnkey projects are similar to utility-owned projects. Refer to the response to II.E.1
above.
3.
Describe how buyout projects are evaluated against PPAs
Project buyout options are essentially a hybrid of utility-owned projects and PPAs. Refer
to the response to II.E.1 above.
4.
Describe how utility-affiliate projects are evaluated against nonaffiliate projects.
Utility-affiliate projects are evaluated in the same manner as non-affiliate projects. In
addition, evaluation of utility-affiliate projects would be subject to review by the IE, the PRG,
the Commission, and the Federal Energy Regulatory Commission (“FERC”) through the
approval process.
-9-
III.
Bid Evaluation and Selection Process
A.
What is the process by which bids are received and evaluated, selected or
rejected for shortlist inclusion, and further evaluated once on the shortlist?
B.
What is the typical amount of time required for each part of the process?
The typical amount of time required for the shortlisting process depends on the volume of
proposals received by SCE during a solicitation. Historically, it has taken SCE no more than
eight weeks to complete the LCBF evaluation process, which includes quality control of sellers’
information, transmission assessment, quantitative assessment, qualitative assessment,
management review, and PRG meetings. Going forward, given the large volume and complexity
of proposals received in the 2011 RFP and overlapping procurement programs (e.g., RAM and
SPVP), SCE believes it would be prudent to allow additional time to complete this process. SCE
believes that 12 weeks would provide a more reasonable timeframe to complete this process. In
addition, many of the components in the overall process overlap and may require additional time
if clarification from sellers is needed.
-10-
C.
Describe involvement of the Independent Evaluator.
The IE monitors SCE’s RPS solicitations, provides an independent review of SCE’s
process, models, assumptions, and the proposals it may receive, and helps the Commission and
SCE’s PRG participants by providing them with information and assessments to ensure that the
solicitation was conducted fairly and that the most appropriate resources were shortlisted. The
IE also provides an assessment of SCE’s RPS solicitation from the initial phase of the
solicitation (i.e., the publicizing of the issuance of the RFP) through the development of a short
list of proposals with whom SCE has commenced negotiations. Further, the IE monitors the
negotiation process to ensure that all shortlisted bidders are treated consistently and files reports
on each final executed contract.
D.
Describe involvement of the Procurement Review Group.
SCE consults with its PRG during each step of the renewable procurement process.
Among other things, SCE provides access to the solicitation materials and pro forma contracts to
the PRG for review and comment before commencing the RFP; informs the PRG of the initial
results of the RFP; explains the evaluation process; and updates the PRG periodically concerning
the status of contract formation.
E.
Discuss whether and how feedback on the solicitation process is requested
from bidders (both successful and unsuccessful) after the solicitation is
complete.
SCE regularly receives feedback during the normal course of its solicitation process.
Shortly after the 2011 RPS RFP Bidders’ Conference, SCE solicited feedback from participants
via a web based survey. In addition, SCE solicited feedback from participants via a web based
survey after the completion of the 2011 RFP. Finally, SCE fields dozens of informal requests
from sellers for feedback on their proposals.
-11-
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 THE SECOND ASSIGNED
COMMISSIONER’S RULING ISSUING PROCUREMENT REFORM
PROPOSALS AND ESTABLISHING A SCHEDULE FOR COMMENTS ON
PROPOSALS on all parties identified on the attached service list(s) R.11-05-005.
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 hand or by overnight courier to the offices of the
Commissioner(s) or other addressee(s).
ALJ DeAngelis
CPUC
505 Van Ness Ave.
San Francisco, CA 94102
ALJ Simon
CPUC
505 Van Ness Ave.
San Francisco, CA 94102
 Placing copies in properly addressed sealed envelopes and depositing such
copies in the United States mail with first-class postage prepaid to all parties
for those listed on the attached non-email list.
 Directing Prographics to place the copies in properly addressed sealed
envelopes and to deposit such envelopes in the United States mail with firstclass postage prepaid to all parties.
Executed this 20th day of November, 2012, at Rosemead, California.
/S/ Melissa Hernandez
Melissa Hernandez
Project Analyst
SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue
Post Office Box 800
Rosemead, California 91770
CPUC - Service Lists - R1105005
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Parties
BRYAN CRABB
EXECUTIVE DIRECTOR
CALIFORNIA SOLAR ENERGY INDUSTRIES ASSN
EMAIL ONLY
EMAIL ONY, CA 00000
FOR: CALIFORNIA SOLAR ENERGY INDUSTRIES
ASSOCIATION
CARRIE A. DOWNEY
LAW OFFICES OF CARRIE ANNE DOWNEY
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: IMPERIAL IRRIGATION DISTRICT
CHRIS LEVERIZA
GLACIAL ENERGY
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: GLACIAL ENERGY
CRAIG LEWIS
RIGHTCYCLE ENTERPRISES
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: RIGHTCYCLE
DANIEL W. DOUGLASS
DOUGLASS & LIDDELL
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: DIRECT ACCESS CUSTOMER
COALITION/WESTERN POWER TRADING
FORUM/ENXCO, INC./RECURRENT ENERGY/EDF
INDUSTRIAL POWER SERVICES (CA), LLC
ELIZABETH WRIGHT
OCCIDENTAL POWER SERVICES, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: OCCIDENTAL POWER SERVICES, INC.
JEAN-CALUDE BERTET
DEPUTY CITY ATTORNEY
LOS ANGELES DEPT. OF WATER AND POWER
EMAIL ONLY
JESSICA NELSON
PLUMAS-SIERRA RURAL ELECTRIC CO-OP
EMAIL ONLY
EMAIL ONLY, CA 00000
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EMAIL ONLY, CA 00000
FOR: LOS ANGELES DEPARTMENT OF WATER &
POWER
JODY LONDON
JODY LONDON CONSULTING
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: SUSTAINABLE CONSERVATION AND RCM
INTERNATIONAL
JOHN W. LESLIE, ESQ
MCKENNA LONG & ELDRIDGE LLP
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: SHELL ENERGY NORTH AMERICA (U.S.),
L.P.
JUSTIN C. WYNNE
ATTORNEY AT LAW
BRAUN BLAISING MCLAUGHLIN, P.C.
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: CALIFORNIA MUNICIPAL UTILITIES
ASSOCIATION
M. GRADY MATHAI-JACKSON
PACIFIC GAS & ELECTRIC COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: PACIFIC GAS & ELECTRIC COMPANY
MATTHEW FREEDMAN
THE UTILITY REFORM NETWORK
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: THE UTILITY REFORM NETWORK
RICK NOGER
PRAXAIR PLAINFIELD, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: PRAXAIR PLAINFIELD, INC.
SCOTT BLAISING
BRAUN BLAISING MCLAUGHLIN, P.C.
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: CITY OF CERRITOS
STEPHEN BURNAGE
SOLAR EXPRESS TRANSMISSION, LLC
EMAIL ONLY
EMAIL ONLY, NV 00000
FOR: SOLAR EXPRESS TRANSMISSION, LLC
TAM HUNT
ATTORNEY
HUNT CONSULTING
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: RIGHTCYCLE
TAM HUNT
HUNT CONSULTING
EMAIL ONLY
EMAIL ONL Y, CA 00000
FOR: CLEAN COALITION (FORMERLY FIT)
TOM KIRK
EXECUTIVE DIRECTOR
COACHELLA VALLEY ASSN. OF GOVERNMENTS
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: COACHELLA VALLEY ASSOCIATION OF
GOVERNMENTS
TRACY PHILLIPS
TIGER NATURAL GAS
EMAIL ONLY
EMAIL ONLY, TX 00000
FOR: TIGER NATURAL GAS
WILL PLAXICO
PROJECT DEVELOPMENT MGR
AXIO POWER, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: AXIO POWER, INC.
LAURA WISLAND
UNION OF CONCERNED SCIENTISTS
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
FOR: UNION OF CONCERNED SCIENTISTS
RANDALL W. HARDY
ANDREW LUSCZ
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HARDY ENERGY CONSULTING
EMAIL ONLY
EMAIL ONLY, WA 00000-0000
FOR: RANDALL W. HARDY
GLACIAL ENERGY OF CALIFORNIA
5326 YACHT HAVEN GRANDE BOX 36
ST THOMAS, VI 00802
FOR: GLACIAL ENERGY OF CALIFORNIA
DANIEL V. GULINO
RIDGEWOOD POWER MANAGEMENT, LLC
14 PHILIPS PKWY
MONTVALE, NJ 07645-1811
FOR: RIDGEWOOD POWER MANAGEMENT, LLC
ABRAHAM SILVERMAN
SR. COUNSEL, REGULATORY
NRG ENERGY, INC.
211 CARNEGIE CENTER DRIVE
PRINCETON, NJ 08540
FOR: NRG COMPANIES, INC. (CABRILLO
POWER I, LLC/CABRILLO POWER II, LLC/EL
SEGUNDO POWER, LLC/LONG BEACH
GENERATION, LLC/NRG SOLAR BLYTHE, LLC
JAMES MUELLER
CONSOLIDATED EDISON SOLUTIONS, INC.
100 SUMMIT LAKE DRIVE, STE. 410
VALHALLA, NY 10595
FOR: CONSOLIDATED EDISON SOLUTIONS, INC.
RHONE RESCH
SOLAR ENERGY INDUSTRIES ASSOCIATION
575 7TH ST., NW, STE. 400
WASHINGTON, DC 20004-1612
FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION
KEITH MCCREA
ATTORNEY AT LAW
SUTHERLAND, ASBILL & BRENNAN
1275 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20004-2415
FOR: CA MANUFACTURERS & TECHNOLOGY
ASSN./LS POWER ASSOCIATES, L.P.
JAMES P. WHITE
TRANSCANADA CORPORATION
4547 RINCON PLACE
MONTCLAIR, VA 22025
FOR: CHINOOK POWER TRANSMISSION,
LLC/ZEPHYR POWER TRANSMISSION, LLC
JEFF MEYER
PATHFINDER RENEWABLE WIND ENERGY, LLC
2720 PARK STREET, STE. 222
JACKSONVILLE, FL 32205
FOR: PATHFINDER RENEWABLE WIND ENERGY,
LLC
ALRINE WILLIAMS
LEGAL COUNSEL
LIBERTY POWER HOLDINGS, LLC (1371)
1901 W. CYPRESS CREEK ROAD, STE. 600
FORT LAUDERDALE, FL 33309
FOR: LIBERTY POWER DELAWARE, LLC AND
LIBERTY POWER HOLDINGS, LLC
JOHN CASADONT
GENERAL COUNSEL
BLUE STAR ENERGY SOLUTIONS
363 WEST ERIE ST., STE. 700
CHICAGO, IL 60654
FOR: BLUE STAR ENERGY
JOHN KERN
BLUESTAR ENERGY SERVICES
363 ERDY ERIE STREET, 7TH FLOOR
CHICAGO, IL 60654
FOR: BLUESTAR ENERGY SERVICES
MADELON A. KUCHERA
ASSOC. GEN. COUNSEL - VP REGULATORY
BLUESTAR ENERGY SOLUTIONS
363 WEST ERIE STREET, SUITE 700
CHICAGO, IL 60654
FOR: BLUESTAR ENERGY SOLUTIONS
ERIN SZALSKOWSKI
CORPORATE COUNSEL
CLEAN LINE ENERGY PARTNERS, LLC
1001 MCKINNEY ST., STE. 700
HOUSTON, TX 77002
FOR: CENTENNIAL WEST CLEAN LINE, LLC
GRETCHEN SCHOTT
BP WIND ENERGY NORTH AMERICA INC.
700 LOUSIANA STREET, 33RD FLOOR
HOUSTON, TX 77002
ANGELA GREGORY
DIR - WHOLESALE COMPLIANCE, U.S.
DIRECT ENERGY BUSINESS
12 GREENWAY PLAZA, STE. 600
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FOR: BP WIND ENERGY NORTH AMERICA, INC.
HOUSTON, TX 77046
FOR: DIRECT ENERGY BUSINESS
KEVIN BOUDREAUX
ENERCAL USA
7660 WOODWAY DRIVE, STE 471A
HOUSTON, TX 77063
FOR: ENERCAL USA
GARSON KNAPP
GEXA ENERGY CALIFORNIA, LLC
20455 STATE HIGHWAY 249, STE. 200
HOUSTON, TX 77070
FOR: GEXA ENERGY CALIFORNIA, LLC
KARA MORGAN
TRANSWEST EXPRESS LLC
555 SEVENTEENTH STREET, STE. 2400
DENVER, CO 80202
FOR: TRANSWEST EXPRESS, LLC
THOMAS LOQUVAM
SENIOR ATTORNEY
PINNACLE WEST CAPITAL CORPORATION
400 N. FIFTH STREET, MS 8695
PHOENIX, AZ 85004
FOR: ARIZONA PUBLIC SERVICE COMPANY
ADRIENNE SMITH
VP - ADMINISTRATION
TRES AMIGAS, LLC
119 EAST MARCY ST., STE. 104
SANTA FE, NM 87501
FOR: TRES AMIGAS, LLC
DAVID SAUL
PACIFIC SOLAR & POWER CORPORATION
2850 W. HORIZON RIDGE PKWY, SUITE 200
HENDERSON, NV 89052
FOR: SOLEL, INC.
PAUL THOMSEN
DIR. - POLICY & BUSINESS DEVELOPMENT
ORMAT TECHNOLOGIES INC.
6225 NEIL ROAD
RENO, NV 89511
FOR: ORMAT TECHNOLOGIES INC.
CAMILLE A. GOULET
GENERAL COUNSEL
LOS ANGELES COMMUNITY COLLEGE DISTRICT
770 WILSHIRE BOULEVARD
LOS ANGELES, CA 90017
FOR: LOS ANGELES COMMUNITY COLLEGE
DISTRICT
KELLY CAUVEL
BUILD-LACCD
915 WILSHIRE BOULEVARD
LOS ANGELES, CA 90017
FOR: LOS ANGELES COMMUNITY COLLEGE
DISTRICT
TOM HALL
INTERIM EXEC. DIR.-FACILITIES PLANNING
LOS ANGELES COMMUNITY COLLEGE DISTRICT
770 WILSHIRE BOULEVARD
LOS ANGELES, CA 90017
FOR: LOS ANGELES COMMUNITY COLLEGE
DISTRICT
NORMAN A. PEDERSEN
HANNA AND MORTON LLP
444 S FLOWER ST., SUITE 1500
LOS ANGELES, CA 90071-2916
FOR: SOUTHERN CALIFORNIA GENERATION
COALITION / SOUTHERN CALIFORNIA PUBLIC
POWER AUTHORITY
DIANE MOSS
FOUNDER, SECRETARY OF THE BOARD
RENEWABLES 100 POLICY INSTITUTE
35316 MULHOLLAND HWY
MALIBU, CA 90265
FOR: RENEWABLES 100 POLICY INSTITUTE
MICHAEL MAZUR
PRINCIPAL
3 PHASES RENEWABLES, LLC
2100 SEPULVEDA BLVD, SUITE 38
MANHATTAN BEACH, CA 90266
FOR: 3 PHASES RENEWABLES/3 PHASES
ELECTRICAL CONSULTING
SUSAN MUNVES
ENERGY AND GREEN BLDG. PROG. ADMIN.
CITY OF SANTA MONICA
1212 5TH STREET, FIRST FLOOR
SANTA MONICA, CA 90401
FOR: CITY OF SANTA MONICA
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ADAM GREEN
SOLARRESERVE
2425 OLYMPIC BLVD., STE. 500E
SANTA MONICA, CA 90404
FOR: SOLARRESERVE, LLC
MARK MCDANNEL
COUNTY SANITATION DISTRICT OF L.A.
1955 WORKMAN MILL ROAD
WHITTIER, CA 90601
FOR: COUNTY SANITATION DISTRICT OF LOS
ANGELES (LOS ANGELES COUNTY SANITATION
DISTRICTS)
INGER GOODMAN
COMMERCE ENERGY INC
1 CENTERPOINTE DRIVE, SUITE 350
LA PALMA, CA 90623-2520
FOR: COMMERCE ENERGY, INC.
ANGEL AYALA
AMONIX, INC.
1709 APOLLO COURT
SEAL BEACH, CA 90740
FOR: AMONIX, INC.
PAUL DELANEY
V.P.
AMERICAN UTILITY NETWORK (A.U.N.)
10705 DEER CANYON DRIVE
ALTA LOMA, CA 91737
FOR: AMERICAN UTILITY NETWORK
CATHY A. KARLSTAD
ATTORNEY
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE.
ROSEMEAD, CA 91770
FOR: SOUTHERN CALIFORNIA EDISON COMPANY
KEITH SWITZER
VP REGULATORY AFFAIRS
GOLDEN STATE WATER COMPANY
630 EAST FOOTHILL BLVD.
SAN DIMAS, CA 91773-9016
FOR: GOLDEN STATE WATER COMPANY
CHERYL PONDS
OFFICE OF THE CITY ATTORNEY
276 FOURTH AVENUE
CHULA VISTA, CA 91910
FOR: THE CITY OF CHULA VISTA
MARY C. HOFFMAN
PRESIDENT
SOLUTIONS FOR UTILITIES, INC.
1192 SUNSET DRIVE
VISTA, CA 92081
FOR: SOLUTIONS FOR UTILITIES, INC.
AIMEE M. SMITH
SEMPRA ENERGY
101 ASH STREET, HQ-12
SAN DIEGO, CA 92101
FOR: SAN DIEGO GAS AND ELECTRIC CO.
DANIEL A. KING
SEMPRA GENERATION
101 ASH STREET, HQ 14
SAN DIEGO, CA 92101
FOR: SEMPRA GENERATION
FREDERICK M. ORTLIEB
DEPUTY CITY ATTORNEY
CITY OF SAN DIEGO
1200 THIRD AVENUE, SUITE 1100
SAN DIEGO, CA 92101
FOR: CITY OF SAN DIEGO
DONALD C. LIDDELL
DOUGLASS & LIDDELL
2928 2ND AVENUE
SAN DIEGO, CA 92103
FOR: CALIF. ENERGY STORAGE ALLIANCE /
WALMART STORES, INC. AND SAM'S WEST,
INC. / AGPOWER GROUP, LLC / CLEAN
ENERGY RENEWABLE FUELS, LLC.
THOMAS CORR
LAW OFFICE OF THOMAS CORR
618 W. LEWIS STREET
SAN DIEGO, CA 92103
FOR: NOBLE AMERICAS ENERGY SOLUTIONS,
LLC
THOMAS R. DARTON
PILOT POWER GROUP, INC. (1365)
8910 UNIVERSITY CENTER LANE, STE. 520
JAMES TURNER
ENERGYSOURCE, LLC
321 SOUTH WATERMAN AVE., STE. 200
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SAN DIEGO, CA 92122
FOR: PILOT POWER GROUP, INC.
EL CENTRO, CA 92243
FOR: ENERGYSOURCE, LLC
MARK S. SHIRILAU, PH.D, PE
PRESIDENT & CEO
ALOHA SYSTEMS, INCORPORATED
8539 BARNWOOD LANE
RIVERSIDE, CA 92508-7126
FOR: ALOHA SYSTEMS, INCORPORATED
GLORIA BRITTON
ANZA ELECTRIC COOPERATIVE, INC. (909)
PO BOX 391909 / 58470 HWY 371
ANZA, CA 92539
FOR: ANZA ELECTRIC COOPERATIVE
MICHAEL LEVIN
DIRECTOR - GOVERNMENT AFFAIRS
FLEXENERGY, INC.
9400 TOLEDO WAY
IRVINE, CA 92618
FOR: FLEXENERGY, INC.
PHILLIP REESE
C/O REESE-CHAMBERS SYSTEMS CONSULTANTS,
PO BOX 8
3379 SOMIS ROAD
SOMIS, CA 93066
FOR: THE CALIFORNIA BIOMASS ENERGY
ALLIANCE
TAM HUNT
ATTORNEY
124 W. ALAMAR AVE., NO. 3
SANTA BARBARA, CA 93105
FOR: COMMUNITY ENVIRONMENTAL COUNCIL
ANDREA MORRISON
MARKET DEVELOPMENT REGIONAL DIR.
DIRECT ENERGY SERVICES, LLC
415 DIXON STREET
ARROYO GRANDE, CA 93420
FOR: DIRECT ENERGY SERVICES, LLC
TOM WHEELER
SUPERVISOR - DISTRICT 5
MADERA COUNTY BOARD OF SUPERVISORS
200 W. FOURTH STREET
MADERA, CA 93637
FOR: COUNTY OF MADERA
JOSEPH LANGENBERG
CENTRAL CALIFORNIA POWER
5125 NORTH MARTY AVENUE, NO.324
FRESNO, CA 93711
DAVID ORTH
SAN JOAQUIN VALLEY POWER AUTHORITY
ADMIN OFF @KINGS RIVER CONSERV DISTRICT
4886 EAST JENSEN AVENUE
FRESNO, CA 93725
FOR: SAN JOAQUIN VALLEY POWER
AUTHORITY/KING'S RIVER CONSERVATION
DISTRICT
SUE MARA
PRINCIPAL
RTO ADVISORS, LLC
164 SPRINGDALE WAY
REDWOOD CITY, CA 94062
FOR: RETAIL ENERGY SUPPLY ASSOCIATION
(RESA)
MARC D. JOSEPH
ADAMS, BROADWELL, JOSEPH & CARDOZO
601 GATEWAY BLVD., STE. 1000
SOUTH SAN FRANCISCO, CA 94080
FOR: COALITION OF CALIFORNIA UTILITY
EMPLOYEES
DIANA L. LEE
CALIF PUBLIC UTILITIES COMMISSION
LEGAL DIVISION
ROOM 4107
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
JEANNE M. SOLE
DEPUTY CITY ATTORNEY
CITY AND COUNTY OF SAN FRANCISCO
1 DR. CARLTON B. GOODLETT PLACE, RM. 234
SAN FRANCISCO, CA 94102-4682
FOR: CITY AND COUNTY OF SAN FRANCISCO
NORMAN J. FURUTA
ASSOC. COUNSEL - REG LAW
FEDERAL EXECUTIVE AGENCIES
DEPT OF THE NAVY
1455 MARKET ST., SUITE 1744
SAN FRANCISCO, CA 94103-1399
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FOR: FEDERAL EXECUTIVE AGENCIES
NORA SHERIFF
ALCANTAR & KAHL
33 NEW MONTGOMERY STREET, SUITE 1850
SAN FRANCISCO, CA 94105
FOR: ENERGY PRODUCERS AND USERS
COALITION.
WILLIAM H. BOOTH
ATTORNEY AT LAW
ALCANTAR & KAHL
33 NEW MONTGOMERY ST., STE. 1850
SAN FRANCISCO, CA 94105
FOR: RIDGEWOOD RENEWABLE POWER, LLC AND
RIDGEWOOD OLINDA, LLC/CALIFORNIA LARGE
ENERGY CONSUMERS ASSOCIATION (CLECA)
BRIAN T. CRAGG
GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY
505 SANSOME STREET, SUITE 900
SAN FRANCISCO, CA 94111
FOR: INDEPENDENT ENERGY PRODUCERS
ASSOCIATION (IEPA)/CAITHNESS CORPORATION
JAMES D. SQUERI
ATTORNEY AT LAW
GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY
505 SANSOME STREET, SUITE 900
SAN FRANCISCO, CA 94111
FOR: POWEREX CORPORATION
JEANNE B. ARMSTRONG
ATTORNEY
GOODIN MACBRIDE SQUERI DAY & LAMPREY LLP
505 SANSOME STREET, SUITE 900
SAN FRANCISCO, CA 94111
FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION
MICHAEL DAY
GOODIN MACBRIDE SQUERI DAY & LAMPREY LLP
505 SANSOME STREET, STE. 900
SAN FRANCISCO, CA 94111
FOR: ABENGOA SOLAR, INC.
NANCY L. MURRAY
ATTORNEY AT LAW
NATURENER USA, LLC.
394 PACIFIC AVENUE, SUITE 300
SAN FRANCISCO, CA 94111
FOR: NATURENER USA, LLC
RACHEL MCMAHON
FIRST SOLAR
353 SACRAMENTO ST., STE. 2100
SAN FRANCISCO, CA 94111
FOR: FIRST SOLAR
SETH D. HILTON
STOEL RIVES, LLP
555 MONTGOMERY ST., SUITE 1288
SAN FRANCISCO, CA 94111
FOR: DUKE ENERGY
SUZY HONG
ATTORNEY AT LAW
GOODIN MACBRIDE SQUERI DAY & LAMPREY
505 SANSOME STREET, SUITE 900
SAN FRANCISCO, CA 94111
FOR: TERRA-GEN POWER, LLC
VIDHYA PRABHAKARAN
DAVIS WRIGHT & TREMAINE LLP
505 MONTGOMERY STREET, SUITE 800
SAN FRANCISCO, CA 94111
FOR: THE LEAF EXCHANGE, LLC
MICHAEL B. DAY
ATTORNEY
GOODIN MACBRIDE SQUERI DAY & LAMPREY LLP
505 SANSOME STREET, STE 900
SAN FRANCISCO, CA 94111-3133
FOR: CALENERGY GENERATION
DAVID L. HUARD
MANATT, PHELPS & PHILLIPS, LLP
ONE EMBARCADERO CENTER, STE 2900
SAN FRANCISCO, CA 94111-3736
FOR: COUNTY OF LOS ANGELES
TODD EDMISTER
ATTORNEY AT LAW
BINGHAM MCCUTCHEN LLP
THREE EMBARCADERO CENTER
SAN FRANCISCO, CA 94111-4067
FOR: STIRLING ENERGY SYSTEMS, INC. (SES)
NICOLE SHAUGHNESSY
JOSEPH M. KARP
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MANAGING DIR.
EVOLUTION MARKETS
101 CALIFORNIA STREET, STE. 2750
SAN FRANCISCO, CA 94111-5802
FOR: EVOLUTION MARKETS, INC.
ATTORNEY AT LAW
WINSTON & STRAWN LLP
101 CALIFORNIA STREET, 39TH FLOOR
SAN FRANCISCO, CA 94111-5894
FOR: CALIFORNIA WIND ENERGY
ASSN./ABENGOA SOLAR INC./AUSRA INC AND
BRIGHTSOURCE ENERGY INC.
EDWARD W. O'NEILL
ATTORNEY AT LAW
DAVIS WRIGHT TREMAINE LLP
505 MONTGOMERY STREET, SUITE 800
SAN FRANCISCO, CA 94111-6533
FOR: CALIFORNIA LARGE ENERGY CONSUMERS
ASSOCIATION
JEFFREY P. GRAY
DAVIS WRIGHT TREMAINE, LLP
505 MONTGOMERY STREET, SUITE 800
SAN FRANCISCO, CA 94111-6533
FOR: CALPINE POWER AMERICA-CA, LLC
ROBERT B. GEX
ATTORNEY AT LAW,
DAVIS WRIGHT TREMAINE LLP
505 MONTGOMERY STREET, SUITE 800
SAN FRANCISCO, CA 94111-6533
FOR: REPUBLIC CLOVERLEAF SOLAR LLC
STEVEN F. GREENWALD
ATTORNEY AT LAW
DAVIS WRIGHT TREMAINE LLP
505 MONTGOMERY STREET, SUITE 800
SAN FRANCISCO, CA 94111-6533
FOR: NEWBERRY GEOTHERMAL LLC /
DAVENPORT NEWBERRY HOLDINGS, LLC /
NORTHWEST ENERGY SYSTEMS CO./IDAHO WIND
PARTNERS 1, LLC/CAPITAL POWER
CORPORATION
SARA STECK MYERS
ATTORNEY AT LAW
122 28TH AVE.
SAN FRANCISCO, CA 94121
FOR: CENTER FOR ENERGY EFFICIENCY AND
RENEWABLE TECHNOLOGIES
GABE PETLIN
3DEGREES
38 KEYES AVE., STE. 300
SAN FRANCISCO, CA 94129-1757
KERRY HATTEVIK
DIR - WEST MARKET AFFAIRS
NEXTERA ENERGY RESOURCES
829 ARLINGTON BLVD.
EL CERRITO, CA 94530
FOR: NEXTERA ENERGY RESOURCES
JASON B. KEYES
KEYES FOX & WIEDMAN, LLP
436 14TH STREET, STE. 1305
OAKLAND, CA 94612
FOR: SUNEDISON
JOSEPH F. WIEDMAN
COUNSEL
KEYES, FOX & WIEDMAN LLP
436 14TH STREET, SUITE 1305
OAKLAND, CA 94612
FOR: SUNPOWER CORPORATION
KEVIN T. FOX
KEYES FOX & WIEDMAN, LLP
436 14TH STREET, SUITE 1305
OAKLAND, CA 94612
FOR: SILVERADO POWER, LLC
LAURENCE G. CHASET
KEYES FOX & WIEDMAN, LLP
436 14TH STREET, STE. 1305
OAKLAND, CA 94612
FOR: TENASKA SOLAR VENTURES
SKY STANFIELD
KEYES, FOX & WIEDMAN LLP
436 14TH ST., STE. 1305
OAKLAND, CA 94612
FOR: INTERSTATE RENEWABLE ENERGY COUNCIL
ZEYNEP ERDAL
PATRICK VAN BEEK
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CAL. WASTEWATER CLIMATE CHANGE GROUP
155 GRAND AVE., STE. 800
OAKLAND, CA 94612
FOR: CALIFORNIA WASTEWATER CLIMATE
CHANGE GROUP
COMMERCIAL ENERGY OF CALIFORNIA
7677 OAKPORT STREET, STE. 525
OAKLAND, CA 94621
FOR: COMMERCIAL ENERGY OF CALIFORNIA
DBA COMMERCIAL ENERGY OF MONTANA
GREGG MORRIS
DIRECTOR
GREEN POWER INSTITUTE
2039 SHATTUCK AVE., SUITE 402
BERKELEY, CA 94704
FOR: GREEN POWER INSTITUTE
NEAL DE SNOO
CITY OF BERKELEY
2180 MILVIA STREET, 2ND FLOOR
BERKELEY, CA 94704
FOR: EAST BAY POWER AUTHORITY/CITY OF
BERKELEY
CLYDE MURLEY
CONSULTANT TO NRDC
1031 ORDWAY STREET
ALBANY, CA 94706
FOR: THE COMMUNITY COLLEGE LEAGUE OF
CALIFORNIA
R. THOMAS BEACH
PRINCIPAL CONSULTANT
CROSSBORDER ENERGY
2560 NINTH STREET, SUITE 213A
BERKELEY, CA 94710-2557
FOR: THE CALIFORNIA COGENERATION COUNCIL
ELIZABETH KELLY
REG. AND LEGAL COUNSEL
MARIN ENERGY AUTHORITY
781 LINCOLN AVENUE, SUITE 320
SAN RAFAEL, CA 94901
FOR: MARIN ENERGY AUTHORITY
ROY PHILLIPS
PRESIDENT / CEO
REP ENERGY, INC.
40 MARK DRIVE
SAN RAFAEL, CA 94903
FOR: REP ENERGY, INC.
JAMES WEIL
DIRECTOR
AGLET CONSUMER ALLIANCE
PO BOX 866
NOVATO, CA 94948
FOR: AGLET CONSUMER ALLIANCE
MAHLON ALDRIDGE
VP - STRATEGIC DEVELOPMENT
ECOLOGY ACTION
877 CEDAR STREET, STE. 240
SANTA CRUZ, CA 95060-3938
FOR: ECOLOGY ACTION
L. JAN REID
COAST ECONOMIC CONSULTING
3185 GROSS ROAD
SANTA CRUZ, CA 95062
FOR: L. JAN REID
MICHAEL E. BOYD
PRESIDENT
CALIFORNIANS FOR RENEWABLE ENERGY, INC.
5439 SOQUEL DRIVE
SOQUEL, CA 95073
FOR: CALIFORNIANS FOR RENEWABLE
ENERGY, INC.
JOHN R. REDDING
ARCTURUS ENERGY CONSULTING
44810 ROSEWOOD TERRACE
MENDOCINO, CA 95460
FOR: SILICON VALLEY MANUFACTURERS GROUP
CHRISTIANA DARLINGTON
GENERAL COUNSEL
PLACER COUNTY AIR POLLUTION CONTROL DIST
175 FULWEILER AVE.
AUBURN, CA 95603
FOR: PLACER COUNTY AIR POLLUTION
CONTROL DISTRICT
JUDITH SANDERS
CALIFORNIA ISO
250 OUTCROPPING WAY
FOLSOM, CA 95630
FOR: CALIFORNIA INDEPENDENT SYSTEM
KELLY M. FOLEY
ATTORNEY
THE VOTE SOLAR INITIATIVE
2089 TRACY COURT
FOLSOM, CA 95630
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OPERATORS
FOR: THE VOTE SOLAR INITIATIVE
MARTIN HERMANN
8MINUTENERGY RENEWABLES, LLC
111 WOODMERE ROAD, STE. 190
FOLSOM, CA 95630
FOR: 8MINUTENERGY RENEWABLES, LLC
CAROLYN KEHREIN
ENERGY MANAGEMENT SERVICES
2602 CELEBRATION WAY
WOODLAND, CA 95776
FOR: ENERGY USERS FORUM
JAN MCFARLAND
CAEATFA
915 CAPITOL MALL, RM. 468
SACRAMENTO, CA 95814
FOR: AMERICANS FOR SOLAR POWER
JIM METROPULOS
SR. ADVOCATE
SIERRA CLUB CALIFORNIA
801 K STREET, SUITE 2700
SACRAMENTO, CA 95814
FOR: SIERRA CLUB CALIFORNIA
JEDEDIAH J. GIBSON
ATTORNEY
ELLISON, SCHNEIDER & HARRIS, L.L.P.
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816
FOR: BEAR VALLEY ELECTRIC SERVICE
RONALD LIEBERT
ATTORNEY AT LAW
ELLISON SCHNEIDER & HARRIS LLP
2600 CAPITOL AVENUE, STE. 400
SACRAMENTO, CA 95816
FOR: NV ENERGY, INC.
SAMANTHA G. POTTENGER
ELLISON, SCHNEIDER AND HARRIS L.L.P.
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816
FOR: FORTISTAR METHANE GROUP
ANDREW B. BROWN
ELLISON SCHNEIDER & HARRIS, L.L.P.
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816-5905
FOR: CONSTELLATION NEWENERGY,
INC./ALLIANCE FOR RETAIL ENERGY MARKETS
DOUGLAS K. KERNER
ATTORNEY AT LAW
ELLISON, SCHNEIDER & HARRIS, LLP
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816-5905
FOR: SIERRA PACIFIC INDUSTRIES
JEDEDIAH J. GIBSON
ATTORNEY AT LAW
ELLISON SCHNEIDER & HARRIS LLP
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816-5905
FOR: SIERRA PACIFIC POWER COMPANY
LYNN M. HAUG
ELLISON, SCHNEIDER & HARRIS, L.L.P.
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816-5931
FOR: FUELCELL ENERGY, INC.
WILLIAM W. WESTERFIELD III
SR. ATTORNEY - OFF. OF GEN. COUNSEL
SACRAMENTO MUNICIPAL UTILITY DISTRICT
6201 S STREET, M.S. B402
SACRAMENTO, CA 95817
FOR: SACRAMENTO MUNICIPAL UTILITY
DISTRICT
RACHEL GOLD
LARGE SCALE SOLAR ASSOCIATION
2501 PORTOLA WAY
SACRAMENTO, CA 95818
FOR: LARGE SCALE SOLAR ASSOCIATION
MARK HENWOOD
HENWOOD ASSOCIATES, INC.
7311 GREENHAVEN DRIVE, STE. 275
SACRAMENTO, CA 95831
FOR: HENWOOD ASSOCIATES, INC.
KAREN NORENE MILLS
ATTORNEY AT LAW
CALIFORNIA FARM BUREAU FEDERATION
2300 RIVER PLAZA DRIVE
ROB NEENAN
CALIFORNIA LEAGUE OF FOOD PROCESSORS
1755 CREEKSIDE OAKS DRIVE, SUITE 250
SACRAMENTO, CA 95833
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SACRAMENTO, CA 95833
FOR: CALIFORNIA FARM BUREAU FEDERATION
FOR: CALIFORNIA LEAGUE OF FOOD
PROCESSORS
ANN L. TROWBRIDGE
DAY CARTER & MURPHY LLP
3620 AMERICAN RIVER DRIVE, SUITE 205
SACRAMENTO, CA 95864
FOR: AGRICULTURAL ENERGY CONSUMERS
ASSOCIATION
PETER EICHLER
CALIFORNIA PACIFIC ELECTRIC COMPANY
933 ELOISE AVENUE
SOUTH LAKE TAHOE, CA 96150
FOR: CALIFORNIA PACIFIC ELECTRIC
COMPANY (CALPECO)
KEVIN A. LYNCH
IBERDROLA RENEWABLES INC
1125 NW COUCH ST., SUITE 700
PORTLAND, OR 97209
FOR: IBERDROLA RENEWABLES, INC.
MARY WIENCKE
PACIFICORP
825 N. E. MULTNOMAH, SUITE 1800
PORTLAND, OR 97232
FOR: PACIFICORP
THOM A. FISCHER
PRESIDENT
TOLLHOUSE ENERGY COMPANY
3633 ALDERWOOD AVENUE
BELLINGHAM, WA 98225
FOR: TOLLHOUSE ENERGY COMPANY
PAUL BRACHVOGEL
GEN. COUNSEL
PU DISTRICT NO.1 OF COWLITZ COUNTY
961 12TH AVENUE / PO BOX 3007
LONGVIEW, WA 98632
FOR: PUBLIC UTILITY DISTRICT NO.1 OF
COWLITZ COUNTY
Information Only
KIM MOORE
ARGUS MEDIA
EMAIL ONLY
EMAIL ONLY, UK
UNITED KINGDOM
000 000
NANCY NORRIS
POWEREX CORPORATION
EMAIL ONLY
EMAIL ONLY, BC 000 000
CANADA
ADAM ATKINSON-LEWIS
NATEL ENERGY
EMAIL ONLY
EMAIL ONLY, CA 00000
ALEX MARTIN
NEXTLIGHT RENEWABLE POWER, LLC
EMAIL ONL Y
EMAIL ONLY, CA 00000
AMBER RIESENHUBER
ENERGY ANALYST
INDEPENDENT ENERGY PRODUCERS ASSOC.
EMAIL ONLY
EMAIL ONLY, CA 00000
ANDRA
FIRST
EMAIL
EMAIL
ANDREW WANG
SOLARRESERVE, LLC
EMAIL ONLY
EMAIL ONL Y, CA 00000
ARI CITRIN
PROSOLIA SOLAR, CFO NORTH AMERICA
EMAIL ONLY
EMAIL ONLY, CA 00000
BARBARA R. BARKOVICH
BARKOVICH & YAP, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
BEN REES
EVOLUTION MARKETS, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
PLIGAVKO
SOLAR DEVELOPMENT, INC.
ONLY
ONLY, CA 00000
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FOR: .
BILLY BLATTNER
SAN DIEGO GAS & ELECTRIC COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000
BRADLEY A. ANDERSON
EMAIL ONLY
EMAIL ONLY, CA 00000
BRENDON CUSSIO
EMAIL ONLY
EMAIL ONLY, CA
BRUCE MCLAUGHLIN
ATTORNEY AT LAW
BRAUN & BLAISING P.C.
EMAIL ONLY
EMAIL ONLY, CA 00000
00000
BRYAN MILLER
CONSTELLATION ENERGY
EMAIL ONLY
EMAIL ONLY, CA 00000
CAITLIN COLLINS LIOTIRIS
ENERGY STRATEGIES, LLC
EMAIL ONLY
EMAIL ONLY, UT 00000
CARLOS LAMAS-BABBINI
PROGRAM MGR.
COMVERGE, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
CASE COORDINATION
PACIFIC GAS AND ELECTRIC COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000
CATHIE ALLEN
REGULATORY MGR.
PACIFICORP
EMAIL ONLY
EMAIL ONLY, OR 00000
CHASE
CLEAN
EMAIL
EMAIL
CHUCK GILFOY
DIR. - MARKETING & ASSET OPTIMIZATION
CALENERGY OPERATING CORPORATION
EMAIL ONLY
EMAIL ONLY, CA 00000
DAN CHIA
DEP. DIR. - GOVERNMENT AFFAIRS
SOLARCITY
EMAIL ONLY
EMAIL ONLY, CA 00000
DANIELLE OSBORN-MILLS
REGULATORY AFFAIRS COORDINATOR
CEERT
EMAIL ONLY
EMAIL ONLY, CA 00000
DAVE OMINSKY
EMAIL ONLY
EMAIL ONLY, CA
DAVID E. MORSE
EMAIL ONLY
EMAIL ONLY, CA
DAVID TOWNLEY
US SALES & MARKETING
INFINIA CORPORATION
EMAIL ONLY
EMAIL ONLY, WA 00000
00000
DIANE I. FELLMAN
DIRECTOR, REGULATORY & GOV'T AFFAIRS
NRG WEST & SOLAR
EMAIL ONLY
EMAIL ONLY, CA 00000
ADAMS
COALITION
ONLY
ONLY, CA 00000
00000
DOCKET COORDINATOR
KEYS AND FOX
EMAIL ONLY
EMAIL ONLY, CA 00000
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DONALD E. OSBORN
SPECTRUM ENERGY DEVELOPMENT INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
DOUG DAVIE
WELLHEAD ELECTRIC
EMAIL ONLY
EMAIL ONLY, CA 00000
ELAINE SISON-LEBRILLA
SACRAMENTO MUNICIPAL UTIILITY DISTRICT
EMAIL ONLY
EMAIL ONLY, CA 00000
ELIZABETH HADLEY
REDDING ELECTRIC UTILITY
EMAIL ONLY
EMAIL ONLY, CA 00000
ERIC THOMPSON
NATELENERGY
EMAIL ONLY
EMAIL ONLY, CA
ERIN GRIZARD
BLOOM ENERGY, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
00000
FRANK DE ROSA
NEXTLIGHT RENEWABLE POWER, LLC
EMAIL ONLY
EMAIL ONLY, CA 00000
FREEMAN S. HALL
SOLAR ELECTRIC SOLUTIONS, LLC
EMAIL ONLY
EMAIL ONLY, CA 00000
GENE THOMAS
ECOLOGY ACTION
EMAIL ONLY
EMAIL ONLY, CA
GREGG FISHMAN
ECOLOGY ACTION
EMAIL ONLY
EMAIL ONLY, CA
00000
00000
GREGORY S.G. KLATT
DOUGLASS & LIDDELL
EMAIL ONLY
EMAIL ONLY, CA 00000
GUINNESS MCFADDEN
EMAIL ONLY
EMAIL ONLY, CA 00000
GWENNETH O'HARA
CALIFORNIA POWER LAW GROUP
EMAIL ONLY
EMAIL ONLY, CA 00000
HARRY SINGH
GOLDMAN SACHS & CO.
EMAIL ONLY
EMAIL ONLY, CA 00000
HUGH YAO
SOUTHERN CALIFORNIA GAS COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000
JAMES B. WOODRUFF
ATTORNEY AT LAW
NEXTLIGHT RENEWABLE POWER, LLC
EMAIL ONLY
EMAIL ONLY, CA 00000
JAMIE
ADAMS
EMAIL
EMAIL
JAN MCFAR
EMAIL ONLY
EMAIL ONLY, CA
L. MAULDIN
BROADWELL JOSEPH & CARDOZO, PC
ONLY
ONLY, CA 00000
JAN MCFARLAND
SONIC
EMAIL ONLY
EMAIL O NLY, CA
00000
00000
JAN PEPPER
ELECTRIC DIV., MGR.
SILICON VALLEY POWER
EMAIL ONLY
EMAIL ONLY, CA 00000
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JANICE LIN
MANAGING PARTNER
STRATEGEN CONSULTING LLC
EMAIL ONLY
EMAIL ONLY, CA 00000
JASON YAN
PACIFIC GAS AND ELECTRIC COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000
JAY CORRALES
TURNER REAL ESTATE
EMAIL ONLY
EMAIL ONLY, CA 00000
JIAN ZHANG
GRIDX, INC.
EMAIL ONLY
EMAIL ONLY, CA
JOHN BARNES
PRESIDENT / CEO
SOLAR LAND PARTNERS, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
JOSH RICHMAN
BLOOM ENERGY CORPORATION
EMAIL ONLY
EMAIL ONLY, CA 00000
JULIANNE SPEARS
ORRICK HERRINGTON & SUTCLIFFE, LLP
EMAIL ONLY
EMAIL ONLY, CA 00000
KELLY GIDDENS
ORRICK HERINTON & SUTCLIFFE
EMAIL ONLY
EMAIL ONLY, CA 00000
KENNETH SAHM WHITE
CLEAN COALITION
EMAIL ONLY
EMAIL ONLY, CA 00000
KEVIN
TRINA
EMAIL
EMAIL
LAUREN ROHDE
PACIFIC GAS AND ELECTRIC COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000
LESLIE E. SHERMAN
ORRICK, HERRINGTON & SUTCLIFFE LLP
EMAIL ONLY
EMAIL ONLY, CA 00000
LON W. HOUSE, PH.D
WEC
EMAIL ONLY
EMAIL ONLY, CA 00000
LUKE SOULE
KOMODO ENTERPRISES, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
MARCO LOPEZ
EMAIL ONLY
EMAIL ONLY, CA
00000
MARCUS V. DA CUNHA
EMAIL ONLY
EMAIL ONLY, CA 00000
00000
MARJORIE OXSEN
CALPINE CORPORATION
EMAIL ONLY
EMAIL ONLY, CA 00000
MARGARET BRUCE
ECOLOGY ACTION
EMAIL ONLY
EMAIL ONLY, CA
MARK CHEDIAK
ENERGY REPORTER
BLOOMBERG NEWS
EMAIL ONLY
EMAIL ONLY, CA 00000
CHEN
SOLAR
ONLY
ONLY, CA
00000
00000
MARK FRAZEE
CITY OF ANAHEIM-PUBLIC UTILITIES DEPT.
EMAIL ONLY
EMAIL ONLY, CA 00000
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MARK ROBERTS
DIR - PROGRAM DEVELOPMENT
SUNLIGHT PARTNERS, LLC
EMAIL ONLY
EMAIL ONLY, AZ 00000
MATT SUHR
CALPINE
EMAIL ONLY
EMAIL ONLY, CA
MEGAN COX
CALIFORNIA POWER LAW GROUP
EMAIL ONLY
EMAIL ONLY, CA 00000
MELISSA P. MARTIN
STATESIDE ASSOCIATES
EMAIL ONLY
EMAIL ONLY, CA 00000
MEREDITH CONNOLLY
NATURAL RESOURCES DEFENSE COUNCIL
EMAIL ONLY
EMAIL ONLY, CA 00000
MICHAEL BASS
ESOLAR, INC.
EMAIL ONLY
EMAIL ONLY, CA
MICHAEL DEANGELIS
SACRAMENTO MUNICIPAL UTILITY DISTRICT
EMAIL ONLY
EMAIL ONLY, CA 00000
MICHAEL WHEELER
RECURRENT ENERGY
EMAIL ONLY
EMAIL ONLY, CA 00000
NEDRA YOUNG
WINTEC ENERGY, LTD
EMAIL ONLY
EMAIL ONLY, CA 00000
NEIL BLACK
CALIFORNIA BIOENERGY LLC
EMAIL ONLY
EMAIL ONLY, NY 00000
NICHOLAS WEBER
EMAIL ONLY
EMAIL ONLY, CA
OBADIAH BARTHOLOMY
SACRAMENTO MUNICIPAL UTILITY DISTRICT
EMAIL ONLY
EMAIL ONLY, CA 00000
PAMELA BARBER
EMAIL ONLY
EMAIL ONLY, CA
00000
00000
00000
00000
RANDY KELLER
DIRECTOR OF DEVELOPMENT
CALENERGY OPERATING CORPORATION
EMAIL ONLY
EMAIL ONLY, CA 00000
RICHARD SMITH
SAN FRANCISCO WATER, POWER & SEWER
EMAIL ONLY
EMAIL ONLY, CA 00000
ROB LONGNECKER
CLEAN COALITION
EMAIL ONLY
EMAIL ONLY, CA 00000
ROSS BUCKENHAM
CALIFORNIA BIOENERGY LLC
EMAIL ONLY
EMAIL ONLY, TX 00000
RYAN BERNARDO
BRAUN BLAISING MCLAUGHLIN, P.C.
EMAIL ONLY
EMAIL ONLY, CA 00000
RYAN HEIDARI
ENDIMENSIONS LLC
EMAIL ONLY
EMAIL ONLY, CA 00000
SARA BIRMINGHAM
DIRECTOR - WESTERN POLICY
SOLAR ENERGY INDUSTRIES ASSOCIATION
EMAIL ONLY
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Page 16 of 36
EMAIL ONLY, CA
00000
SEAN GALLAGHER
MANAGING DIRECTOR-GOV'T RELATIONS
K ROAD POWER
EMAIL ONLY
EMAIL ONLY, CA 00000
SEAN P. BEATTY
DIRECTOR-WEST REGULATORY AFFAIRS
GENON ENERGY, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
SEPHRA NINOW
CALIFORNIA CENTER FOR SUSTAINABLE ENERGY
EMAIL ONLY
EMAIL ONLY, CA 00000
SHANNON EDDY
LARGE-SCALE SOLAR ASSOCIATION
EMAIL ONLY
EMAIL ONLY, CA 00000
SHIVANI BALLESTEROS
SAN DIEGO GAS & ELECTRIC COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000
SIOBHAN DOHERTY
FRV, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
SNULLER PRICE
ENERGY AND ENVIRONMENTAL ECONOMICS
EMAIL ONLY
EMAIL ONLY, CA 00000
STEPHEN SMITH
SOLVIDA ENERGY GROUP
EMAIL ONLY
EMAIL ONLY, CA 00000
STEVEN KELLY
INDEPENDENT ENERGY PRODUCERS ASSOCIATION
EMAIL ONLY
EMAIL ONLY, CA 00000
STEVEN ZHU
TRINA SOLAR
EMAIL ONLY
EMAIL ONLY, CA
THADEUS B. CULLEY
KEYES FOX & WIEDMAN LLP
EMAIL ONLY
EMAIL ONLY, CA 00000
TIMOTHY N. TUTT
SACRAMENTO MUNICIPAL UTILITIES DISTRICT
EMAIL ONLY
EMAIL ONLY, CA 00000
TODD JOHANSEN
DEVELOPMENT ANALYST
RECURRENT ENERGY
EMAIL ONLY
EMAIL ONLY, CA 00000
TONY BRAUN
BRAUN BALISING MCLAUGHLIN PC
EMAIL ONLY
EMAIL ONLY, CA 00000
TONY D. PASTORE
EMAIL ONLY
EMAIL ONLY, CA 00000
VALERIE J. WINN
PACIFIC GAS & ELECTRIC COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000
VALERIE SEYMOUR
POLICY ASSOCIATE
CLEAN COALITION
EMAIL ONLY
EMAIL ONLY, CA 00000
VENKAT SURAVARAPU
IHS CERA
EMAIL ONLY
EMAIL ONLY, CA 00000
WILLIAM BUSCH
EMAIL ONLY
SILVERADO POWER LLC
EMAIL ONLY
http://www.cpuc.ca.gov/service_lists/R1105005_79864.htm
00000
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EMAIL ONLY, CA
CPUC
EMAIL ONLY
EMAIL ONLY, CA
Page 17 of 36
00000
EMAIL ONLY, CA
00000
00000
MRW & ASSOCIATES, LLC
EMAIL ONLY
EMAIL ONLY, CA 00000
SPECTRUM ENERGY DEVELOPMENT INC.
EMAIL ONLY
EMAIL ONLY, CA 00000
CURTIS KEBLER
SEMPRA GENERATION
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
DEREK DENNISTON
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
G. PATRICK STONER
PROGRAM DIRECTOR
LOCAL GOVERNMENT COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
IAN MCGOWAN
MANAGER - REGULATORY AFFAIRS
3DEGREES
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
JAMIE NAGEL
ZGLOBAL, INC
EMAIL ONLY
EMAIL ONLY, CA
JENNIFER BARNES
NAVIGANT CONSULTING, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
JIM STACK, PH.D.
RESOURCE PLANNER
CITY OF PALO ALTO UTILITIES
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
JUDY PAU
DAVIS WRIGHT TREMAINE LLP
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
LILY M. MITCHELL
HANNA AND MORTON LLP
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
MARK STOUT
MERIDIAN ENERGY USA, INC
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
MARTIN HOMEC
REDWOOD RENEWABLES/CARE
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
MOHAN
CALIF
EMAIL
EMAIL
NANCY RADER
EXECUTIVE DIRECTOR
CALIFORNIA WIND ENERGY ASSOCIATION
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
FOR: CALIFORNIA WIND ENERGY ASSOCIATION
NIROULA
DEPT OF WATER RESOURCES
ONLY
ONLY, CA 00000-0000
00000-0000
PETER BLOOD
COLUMBIA ENERGY PARTNERS, LLC
EMAIL ONLY
EMAIL ONLY, WA 00000-0000
POLLY SHAW
SUNTECH AMERICA, INC.
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
RICHARD F. CHANDLER
RICHARD W. RAUSHENBUSH
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BP SOLAR
EMAIL ONLY
EMAIL ONLY, MA
Page 18 of 36
EMAIL ONLY
EMAIL ONLY, CA
00000-0000
00000-0000
ROBIN J. WALTHER
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
RYAN PLETKA
RENEWABLE ENERGY PROJECT MANAGER
BLACK & VEATCH
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
SHAUN HALVERSON
PACIFIC GAS AND ELECTRIC COMPANY
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
SHERIDAN J. PAUKER
WILSON SONSINI GOODRICH & ROSATI
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
TED KO
ASSOCIATE EXECUTIVE DIRECTOR
CLEAN COALITION (FORMERLY FIT)
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
THOMAS HOBSON
GE ENERGY
EMAIL ONLY
EMAIL ONLY, CA
COOL EARTH SOLAR
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
DAVIS WRIGHT TREMAINE, LLC
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
JAMES MCMAHON
29 DANBURY ROAD
NASHUA, NH 03064
TRACY REID
FUELCELL ENERGY, INC.
3 GREAT PASTURE ROAD
DANBURY, CT 06810
KAREN KOCHONIES
MORGAN STANLEY
2000 WESTCHESTER AVE., 1ST FLOOR
PURCHASE, NY 10577
MORGAN HANSEN
MORGAN STANLEY - COMMODITIES
2000 WESTCHESTER AVE., 1ST FLOOR
PURCHASE, NY 10577
NICHOLE FABRI ZANDOLI
PRESIDENT
CLEAR ENERGY BROKERAGE & CONSULTING LLC
403 PARKSIDE AVENUE
BROOKLYN, NY 11226
ARIEL LAGER
CUSTOMIZED ENERGY SOLUTIONS
1528 WALNUT STREET
PHILADELPHIA, PA 19102
ERIKA SCHMITT
CUSTOMIZED ENERGY SOLUTIONS
1528 WALNUT STREET, 22ND FL.
PHILADELPHIA, PA 19102
CATHERINE M. KRUPKA
LS POWER ASSOCIATES, L.P.
1275 PENNSYLVANIA AVE., NW
WASHINGTON, DC 20004
ALEXANDRA KONIECZNY
SUTHERLAND ASHBILL & BRENNAN
1275 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20004-2415
PAUL ACKERMAN
SENIOR COUNSEL
CONSTELLATION ENERGY RESOURCES, INC.
111 MARKET PLACE
BALTIMORE, MD 21202
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MICHAEL E. CARBOY
SIGNAL HILL CAPITAL LLC
300 D. LOMBARD ST., STE. 1700
BALTIMORE, MD 21202-3243
TODD JAFFE
ENERGY BUSINESS BROKERS AND CONSULTANTS
3420 KEYSER ROAD
BALTIMORE, MD 21208
RONALD M. CERNIGLIA
DIRECTOR- NATIONAL ADVOCACY
DIRECT ENERGY SERVICES, LLC
7240 RYEHILL DR.
CARY, NC 27519-1570
ALRINE WILLIAMS
LEGAL COUNSEL
LIBERTY POWER HOLDINGS LLC
1901 W. CYPRESS CREEK ROAD, STE. 600
FORT LAUDERDALE, FL 33309
YANIRA M. GOMEZ
LIBERTY POWER CORP.
1901 W. CYPRESS CREEK RD., STE. 600
FORT LAUDERDALE, FL 33309
SAMARA M. RASSI
REGULATORY AFFAIRS ANALYST
FELLON-MCCORD & ASSOCIATES
10200 FOREST GREEN BLVD., STE. 601
LOUISVILLE, KY 40223-5183
CATHY S. WOOLLUMS
MIDAMERICAN ENERGY HOLDINGS COMPANY
106 EAST SECOND STREET
DAVENPORT, IA 52801
JASON ABIECUNAS
BLACK & BEATCH GLOBAL RENEWABLE ENERGY
RENEWABLE ENERGY CONSULTANT
11401 LAMAR
OVERLAND PARK, KS 66211
ERIC OSBORN
CALPINE POWER AMERICA-CA, LLC
717 TEXAS AVENUE, STE 100
HOUSTON, TX 77002
FOR: CALPINE POWER AMERICA - CA,LLC
MICHAEL D. HANSEN
CHAIRMAN
IGNITE SOLAR
811 DALLAS ST., SUITE 1422
HOUSTON, TX 77002
PETER MATHEY
PRESIDENT & CEO
IGNITE SOLAR
811 DALLAS STREET, STE. 1422
HOUSTON, TX 77002
ED CHIANG
ELEMENT MARKETS, LLC
3555 TIMMONS LANE, STE. 900
HOUSTON, TX 77027-6453
COMMERCE ENERGY, INC.
5251 WESTHEIMER RD., STE. 1000
HOUSTON, TX 77056-5414
EDWIN DEARMAN
GEXA ENERGY CALIFORNIA , LLC
20455 STATE HIGHWAY 249, STE. 200
HOUSTON, TX 77070
JONATHAN JACOBS
PA CONSULTING GROUP
1700 LINCOLN ST STE 4600
DENVER, CO 80203-4509
KEVIN J. SIMONSEN
ENERGY MANAGEMENT SERVICES
1537 FLORIDA RD., STE. 108
DURANGO, CO 81301-5792
JEFF GULDNER
ARIZONA PUBLIC SERVICE COMPANY
400 N 5TH STREET, MS 9040
PHOENIX, AZ 85004
JENINE SCHENK
APS ENERGY SERVICES
400 E. VAN BUREN STREET, SUITE 750
PHOENIX, AZ 85004
MARK ETHERTON
PDS CONSULTING
3231 S. COUNTRY CLUB WAY, STE. 103
TIMOTHY CASTILLE
LANDS ENERGY CONSULTING, INC.
1050 CRACKER BARREL CIRCLE
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TEMPE, AZ
85283
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MESQAUITE, NV
89034-1017
CHRISTOPHER A. HILEN
NV ENERGY
6100 NEIL ROAD, MS A35
RENO, NV 89511
ELENA MELLO
SIERRA PACIFIC POWER COMPANY
6100 NEIL ROAD
RENO, NV 89520
TREVOR DILLARD
RATE REGULATORY RELATIONS
SIERRA PACIFIC POWER COMPANY
6100 NEAL ROAD, MS S4A50 / PO BOX 10100
RENO, NV 89520-0026
JOE GRECO
TERRA-GEN POWER LLC
9590 PROTOTYPE COURT, SUITE 200
RENO, NV 89521-5916
BRYAN SCHWEICKERT
ENVIRONMENTAL SUPERVISOR
LOS ANGELES DEPT. OF WATER & POWER
111 N. HOPE ST.
LOS ANGELES, CA 90012
RANDY HOWARD
POWER ENGINEERING MGR.
LOS ANGELES DEPT. OF WATER & POWER
111 N HOPE STREET, STE. 921
LOS ANGELES, CA 90012
SARAH FRIEDMAN
SIERRA CLUB
714 W. OLYMPIC BLVD., STE. 1000
LOS ANGELES, CA 90015
JEFF NEWMAN
TRANSPORTATION AND HOUSING AGENCY
7080 HOLLYWOOD BLVD., SUITE 900
LOS ANGELES, CA 90028
AL ROSEN
ABSOLUTELY SOLAR INC.
PO BOX 491878
LOS ANGELES, CA 90049-8878
LEILANI JOHNSON KOWAL
LOS ANGELES DEPT. OF WATER AND POWER
PO BOX 51111, ROOM 1541
LOS ANGELES, CA 90051-0100
RANDALL W. KEEN
ATTORNEY AT LAW
MANATT PHELPS & PHILLIPS, LLP
11355 WEST OLYMPIC BLVD.
LOS ANGELES, CA 90064
CARL STEEN
FULBRIGHT & JAWORSKI L.L.P.
555 SOUTH FLOWER STREET, 41ST FLOOR
LOS ANGELES, CA 90071
FRED G. YANNEY
FULBRIGHT & JAWORSKI L.L.P.
555 SOUTH FLOWER STREET, 41ST FLOOR
LOS ANGELES, CA 90071-2571
ANGELINA GALITEVA
FOUNDER, CHAIR OF THE BOARD
RENEWABLES 100 POLICY INSTITUTE
35316 MULHOLLAND HWY
MALIBU, CA 90265
3 PHASES RENEWABLES LLC
2100 SEPULVEDA BLVD, SUITE 37
MANHATTAN BEACH, CA 90266
HARVEY M. EDER
PUBLIC SOLAR POWER COALITION
1218 12TH STREET, NO. 25
SANTA MONICA, CA 90401
GURCHARAN BAWA
PASADENA WATER AND POWER
150 S. LOS ROBLES, SUITE 200
PASADENA, CA 91101
CHARLES CHANG
ENGINEER-EVIRONMENTAL PROGRAMS
PASADENA WATER & POWER
85 EAST STATE STREET
PASADENA, CA 91105
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VALERIE PUFFER
POWER CONTRACTS MANAGER
GLENDALE WATER & POWER
700 N. BRAND BLVD., STE. 590
GLENDALE, CA 91203
JACK MCNAMARA
ATTORNEY AT LAW
MACK ENERGY COMPANY
PO BOX 1380
AGOURA HILLS, CA 91376-1380
BRUNO JEIDER
BURANK WATER & POWER
164 W. MAGNOLIA BLVD.
BURBANK, CA 91502
YAREK LEHR
AZUSA LIGHT & WATER
729 N. AZUSA AVENUE
AZUSA, CA 91702
KENYON HOLMES
TRANE
17748 ROWLAND STREET
CITY OF INDUSTRY, CA
CASE ADMINISTRATION
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVENUE
ROSEMEAD, CA 91770
91748
CURT RONEY
SOUTHERN CALIFORNIA EDISON
2244 WALNUT GROVE, G01-C
ROSEMEAD, CA 91770
GEORGE WILTSEE
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVENUE
ROSEMEAD, CA 91770
JANICE WANG
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE.
ROSEMEAD, CA 91770
JONI A. TEMPLETON
ATTORNEY AT LAW
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVENUE, PO BOX 800
ROSEMEAD, CA 91770
LAURA I. GENAO
SOUTHERN CALIFORNIA EDISON COMPANY
PO BOX 800, 2244 WALNUT GROVE AVENUE
ROSEMEAD, CA 91770
MELISSA A. HOVSEPIAN
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE. / PO BOX 800
ROSEMEAD, CA 91770
REBECCA MEIERS-DE PASTINO
SR. ATTORNEY
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE.
ROSEMEAD, CA 91770
JENNIFER TSAO SHIGEKAWA
SR. ATTORNEY, CUSTOMER & TARIFF LAW
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE. / PO BOX 800
ROSEMEAD, CA 91770-3714
NGUYEN QUAN
MGR - REGULATORY AFFAIRS
GOLDEN STATE WATER CO. - ELECTRIC OP.
630 EAST FOOTHILL BOULEVARD
SAN DIMAS, CA 91773
SOCAL WATER/BEAR VALLEY ELECTRIC
630 EAST FOOTHILL BLVD.
SAN DIMAS, CA 91773
CHAD CHAHBAZI
BAP POWER CORPORATION D/B/A CENERGY
3176 LIONSHEAD AVENUE, STE. 1
CARLSBAD, CA 92010-4708
ROBERT J. GILLESKIE
LIGHTPOINT CONSULTING SERVICES
2570 PINEWOOD STREET
DEL MAR, CA 92014
ARLEN BARKSDALE, PHD
CEO / CTO
DESMON ENERGY, LLC
1538 ENCINITAS BLVD.
HAROLD M. ROMANOWITZ
OAK CREEK ENERGY SYSTEMS, INC.
150 LA TERRAZA BLVD.
ESCONDIDO, CA 92025
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ENCINITAS, CA
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92024
JEFF COX
1557 MANDEVILLE PLACE
ESCONDIDO, CA 92029
GEOREG GISEL
INDEPENDENT ENERGY SOLUTIONS, INC.
1090 JOSHUA WAY
VISTA, CA 92081
CHRISTOPHER SUMMERS
SAN DIEGO GAS & ELECTRIC COMPANY
8326 CENTURY PARK COURT
SAN DIEGO, CA 92101
GREG BASS
NOBLE AMERICAS ENERGY SOLUTIONS LLC
401 WEST A STREET, SUITE 500
SAN DIEGO, CA 92101-3017
SHAWN BAILEY
DIRECTOR - PLANNING & ANALYSIS
SEMPRA US GAS AND POWER
101 ASH STREET
SAN DIEGO, CA 92101-3017
STEVEN C. NELSON
ATTORNEY
SEMPRA ENERGY
101 ASH STREET HQ-12B
SAN DIEGO, CA 92101-3017
THEODORE E. ROBERTS
SEMPRA GENERATION / SEMPRA BROADBAND
101 ASH STREET, HQ 12B
SAN DIEGO, CA 92101-3017
NOBLE AMERICAS ENERGY SOLUTIONS LLC
101 ASH STREET, HQ09
SAN DIEGO, CA 92101-3017
TERRY FARRELLY
269 G AVENUE
CORONADO, CA 92118
MARCIE MILNER
SHELL ENERGY NORTH AMERICA
4445 EASTGATE MALL, SUITE 100
SAN DIEGO, CA 92121
SARAH TOMEC
SR. ADVISOR, REGULATORY AFFAIRS WEST
CAPITAL POWER CORPORATION
9255 TOWNE CENTRE DRIVE, STE. 900
SAN DIEGO, CA 92121
JENNIFER PIERCE
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK CT
SAN DIEGO, CA 92123
DESPINA NIEHAUS
SAN DIEGO GAS AND ELECTRIC COMPANY
8330 CENTURY PARK COURT, CP32H
SAN DIEGO, CA 92123-1530
CENTRAL FILES
SDG&E AND SOCALGAS
8330 CENTURY PARK COURT, CP31-E
SAN DIEGO, CA 92123-1550
SCOTT HARDING
ENERGY RESOURCE PLANNER, SR.
IMPERIAL IRRIGATION DISTRICT
333 E. BARIONI BLVD.
IMPERIAL, CA 92251
FRED W. NOBLE
PRESIDENT
WINTEC ENERGY, LTD
1090 N. PALM CANYON DR., SUITE A
PALM SPRINGS, CA 92260
JIM FERGUSON
FERGUSON LAW FIRM
73101 HIGHWAY 111, STE. 1
PALM DESERT, CA 92260
ROGER KROPKE
BEAR VALLEY ELECTRIC SERVICE
PO BOX 1547
BIG BEAR LAKE, CA 92315
FOR: BEAR VALLEY ELECTRIC SERVICE
PETER T. PEARSON
CHARLES J. BLACK
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ENERGY SUPPLY SPECIALIST
BEAR VALLEY ELECTRIC SERVICE
42020 GARSTIN DRIVE, PO BOX 1547
BIG BEAR LAKE, CA 92315-1547
RIVERSIDE PUBLIC UTILITIES
3435 14TH STREET
RIVERSIDE, CA 92501
JOHN DEWEY
THE DEWEY GROUP
PO BOX 12913
NEWPORT BEACH, CA
CARRIE THOMPSON
CITY OF ANAHEIM
201 S. ANAHEIM BLVD., STE. 802
ANAHEIM, CA 92805
92658-5079
CARRIE TOMPSON
CITY OF ANAHEIM
201 S. ANAHEIM BLVD., STE. 802
ANAHEIM, CA 92805
JANIS LEHMAN
CHIEF RISK OFFICER
CITY OF ANAHEIM-PUBLIC UTILITIES DEPT.
201 S. ANAHEIM BLVD., STE.802
ANAHEIM, CA 92805
MANDIP KAUR SAMRA
INTEGRATED RESOURCES PLANNER
CITY OF ANAHEIM-PUBLIC UTILITIES DEPT.
201 S. ANAHEIM BLVD., SUITE 802
ANAHEIM, CA 92805
PETER MORITZBURKE
3 ECHO AVENUE
CORTE MADERA, CA 92925
JEFF HIRSCH
JAMES J. HIRSCH & ASSOCIATES
12185 PRESILLA ROAD
CAMARILLO, CA 93012-9243
CURTIS SEYMOUR
SR. MANAGER - GOVERNMENT AFFAIRS
SUNEDISON LLC
600 CLIPPER DR.
BELMONT, CA 94002
EVELYN KAHL
ATTORNEY AT LAW
ALCANTAR & KAHL, LLP
33 NEW MONTGOMERY STREET, SUITE 1850
SAN FRANCISCO, CA 94015
FOR: OCCIDENTAL POWER SERVICES,
INC./ENERGY PRODUCERS AND USERS
COALITION.
ELIZABETH KLEBANER
ADAMS BROADWELL JOSEPH & CARDOZO
601 GATEWAY BLVD., STE. 1000
SOUTH SAN FRANCISCO, CA 94080
FOR: INTERNATIONAL BROTHERHOOD OF
ELECTRICAL WORKERS LOCAL 569
SOLAR SEMICONDUCTOR INC.
1292 KIFER ROAD, SUITE 808
SUNNYVALE, CA 94086
NOEL OBIORA
CALIF PUBLIC UTILITIES COMMISSION
LEGAL DIVISION
ROOM 5121
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
AUSTIN M. YANG
CITY AND COUNTY OF SAN FRANCISCO
OFFICE OF THE CITY ATTORNEY, RM. 234
1 DR. CARLTON B. GODDLETT PLACE
SAN FRANCISCO, CA 94102-4682
DAN ADLER
DIRECTOR, TECH AND POLICY DEVELOPMENT
CALIFORNIA CLEAN ENERGY FUND
5 THIRD STREET, SUITE 1125
SAN FRANCISCO, CA 94103
MICHAEL A. HYAMS
POWER ENTERPRISE-REGULATORY AFFAIRS
SAN FRANCISCO PUBLIC UTILITIES COMM
1155 MARKET ST., 4TH FLOOR
SUSAN PRESTON
CALCEF CLEAN ENERGY ANGEL FUND
5 THIRD STREET, STE. 1125
SAN FRANCISCO, CA 94103
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SAN FRANCISCO, CA
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94103
THERESA BURKE
SAN FRANCISCO PUC
1155 MARKET STREET, 4TH FLOOR
SAN FRANCISCO, CA 94103
ANDRE DEVILBISS
ASSOCIATE, DEVELOPMENT
RECURRENT ENERGY
300 CALIFORNIA STREET, 8TH FLOOR
SAN FRANCISCO, CA 94104
HANS ISERN
VP - ENGINEERING
SILVERADO POWER LLC
44 MONTGOMERY STREET, SUITE 3065
SAN FRANCISCO, CA 94104
LUKE DUNNINGTON
ASSOCIATE, DEVELOPMENT
RECURRENT ENERGY
300 CALIFORNIA STREET, 8TH FL
SAN FRANCISCO, CA 94104
MARCEL HAWIGER
ENERGY ATTY
THE UTILITY REFORM NETWORK
115 SANSOME STREET, SUITE 900
SAN FRANCISCO, CA 94104
PETER MILLER
NATURAL RESOURCES DEFENSE COUNCIL
111 SUTTER STREET, 20TH FLOOR
SAN FRANCISCO, CA 94104
TANDY MCMANNES
ABENGOA SOLAR, INC.
235 PINE STREET, STE. 1800
SAN FRANCISCO, CA 94104
FOR: ABENGOA SOLAR, INC.
ARNO HARRIS
RECURRENT ENERGY, INC.
300 CALIFORNIA ST., 8TH FL.
SAN FRANCISCO, CA 94104-1416
NOAH LONG
NATURAL RESOURCES DEFENSE COUNCIL
111 SUTTER ST., 20TH FLOOR
SAN FRANCISCO, CA 94104-4540
ANUPAMA VEGE
FIRST WIND
2 SHAW ALLEY, SUITE 500
SAN FRANCISCO, CA 94105
BRUCE PERLSTEIN, PH.D.
NAVIGANT CONSULTING, INC.
SPEAR STREET TOWER
ONE MARKET ST., STE. 1200
SAN FRANCISCO, CA 94105
CARLOS M. ABREU
PACIFIC GAS & ELECTRIC COMPANY
RENEWABLE TRANSACTIONS DEPT.
77 BEALE ST., RM. 2597F
SAN FRANCISCO, CA 94105
CHARLES R. MIDDLEKAUFF
PACIFIC GAS AND ELECTRIC COMPANY
LAW DEPT.
77 BEALE STREET, B30A / PO BOX 7442
SAN FRANCISCO, CA 94105
ED LUCHA
CASE COORDINATOR
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, MC B9A, ROOM 991
SAN FRANCISCO, CA 94105
ERICA BRAND
THE NATURE CONSERVANCY CALIFORNIA
201 MISSION STREET, 4TH FLOOR
SAN FRANCISCO, CA 94105
JOHN PAPPAS
UTILITY ELECTRIC PORTFOLIO MANAGEMENT
PACIFIC GAS AND ELECTRIC COMPANY
245 MARKET STREET, MC N12G
SAN FRANCISCO, CA 94105
KAREN TERRANOVA
ALCANTAR & KAHL, LLP
33 NEW MONTGOMERY STREET, SUITE 1850
SAN FRANCISCO, CA 94105
MARIA VANKO
LAW DEPARTMENT
PACIFIC GAS & ELECTRIC COMPANY
77 BEALE ST., MCB30A
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SAN FRANCISCO, CA
94105
MICHAEL P. GINSBURG
ATTORNEY AT LAW
ORRICK, HERRINGTON & SUTCLIFFE LLP
405 HOWARD STREET
SAN FRANCISCO, CA 94105
PETER W. HANSCHEN
ATTORNEY AT LAW
MORRISON & FOERSTER, LLP
425 MARKET STREET
SAN FRANCISCO, CA 94105
SEEMA SRINIVASAN
ALCANTAR & KAHL, LLP
33 NEW MONTGOMERY STREET, SUITE 1850
SAN FRANCISCO, CA 94105
CORY M. MASON
ATTORNEY
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, MC B30A
SAN FRANCISCO, CA 94105-1814
NIELS KJELLUND
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, MAIL CODE B9A
SAN FRANCISCO, CA 94105-1814
ADAM BROWNING
THE VOTE SOLAR INITIATIVE
300 BRANNAN STREET, SUITE 609
SAN FRANCISCO, CA 94107
SUSANNAH CHURCHILL
ADVOCATE
THE VOTE SOLAR INITIATIVE
300 BRANNAN ST., SUITE 609
SAN FRANCISCO, CA 94107
BRIAN ORION
LAWYERS FOR CLEAN ENERGY
1156 FLORIDA STREET
SAN FRANCISCO, CA 94110
ASHIANNA T. ESMAIL
LATHAM & WATKINS
505 MONTGOMERY STREET, STE. 2000
SAN FRANCISCO, CA 94111
JACK STODDARD
MANATT PHELPS & PHILLIPS, LLP
ONE EMBARCADERO CENTER, 30TH FL.
SANFRANCISCO, CA 94111
JANINE L. SCANCARELLI
ATTORNEY AT LAW
CROWELL & MORING LLP
275 BATTERY STREET, 23RD FLOOR
SAN FRANCISCO, CA 94111
JARED W. JOHNSON
LATHAM & WATKINS, LLP
505 MONTGOMERY ST., SUITE 2000
SAN FRANCISCO, CA 94111
FOR: TRANSWEST EXPRESS, LLC/TRANSALTA
CORP.
JOE PAUL
NATURENER USA
394 PACIFIC AVENUE, STE. 300
SAN FRANCISCO, CA 94111
JONATHAN MALTA-WEINGARD
NATURENER USA, INC.
394 PACIFIC AVENUE, STE. 300
SAN FRANCISCO, CA 94111
MARK FUMIA
DAVIS WRIGHT TREMAINE LLP
505 MONTGOMERY STREET, SUITE 800
SAN FRANCISCO, CA 94111
FOR: NORTHWEST ENERGY SYSTEMS CO.
RAFI HASSAN
SUSQUEHANNA FINANCIAL GROUP, LLLP
101 CALIFORNIA STREET, SUITE 3250
SAN FRANCISCO, CA 94111
SARAH BARKER-BALL
BINGHAM MCCUTCHEN LLP
3 EMBARCADERO CENTER
SAN FRANCISCO, CA 94111
TARA S. KAUSHIK
ATTORNEY
MANATT, PHELPS & PHILLIPS, LLP
ONE EMBARCADERO CENTER, 30TH FLOOR
SAN FRANCISCO, CA 94111
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MONICA SCHWEBS
BINGHAM MCCUTCHEN LLP
THREE EMBARCADERO CENTER
SAN FRANCISCO, CA 94111-4067
FOR: SOLAR RESERVE, LLC
KATHERINE RYZHAYA
VP
EVOLUTION MARKETS INC.
101 CALIFORNIA ST., STE. 2750
SAN FRANCISCO, CA 94111-5802
FOR: EVOLUTION MARKETS INC.
LISA A. COTTLE
ATTORNEY AT LAW
WINSTON & STRAWN LLP
101 CALIFORNIA STREET, 39TH FLOOR
SAN FRANCISCO, CA 94111-5802
NOELLE R. FORMOSA
WINSTON & STRAWN, LLP
101 CALIFORNIA STREET, 39TH FLOOR
SAN FRANCISCO, CA 94111-5894
THOMAS W. SOLOMON
ATTORNEY AT LAW
WINSTON & STRAWN LLP
101 CALIFORNIA STREET, 39TH FLOOR
SAN FRANCISCO, CA 94111-5894
HILARY CORRIGAN
CALIFORNIA ENERGY MARKETS
425 DIVISADERO ST. SUITE 303
SAN FRANCISCO, CA 94117-2242
LISA WEINZIMER
PLATTS MCGRAW-HILL
695 NINTH AVENUE, NO. 2
SAN FRANCISCO, CA 94118
ALYSSA T. KOO
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, B30A / PO BOX 7442
SAN FRANCISCO, CA 94120
REGULATORY FILE ROOM
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 7442
SAN FRANCISCO, CA 94120
OLIVER N. MYERS
LAW OFFICES OF SARA STECK MYERS
122 - 28TH AVENUE
SAN FRANCISCO, CA 94121
ROBIN QUARRIER
COUNSEL
CENTER FOR RESOURCE SOLUTIONS
1012 TORNEY AVENUE, 2ND FL.
SAN FRANCISCO, CA 94129
BRIAN K. CHERRY
PACIFIC GAS AND ELECTRIC COMPANY
77N BEALE ST., PO BOX 770000, MC B10C
SAN FRANCISCO, CA 94177
BROOKE A. REILLY
PACIFIC GAS & ELECTRIC COMPANY
245 MARKET STREET, RM. 1251, MC N12G
SAN FRANCISCO, CA 94177
MAGGIE CHAN
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 770000, MAIL CODE B9A
SAN FRANCISCO, CA 94177
MARK HUFFMAN
ATTORNEY AT LAW
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 770000, MC B30A
SAN FRANCISCO, CA 94177
MIYUKI IWAHASHI
PACIFIC GAS & ELECTRIC COMPANY
PO BOX 770000
SAN FRANCISCO, CA 94177
SAIPRIYA CHOUDHURI
PACIFIC GAS & ELECTRIC COMPANY
PO BOX 770000, MAIL CODE B9A
SAN FRANCISCO, CA 94177
KAREN KHAMOU
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 770000, MC B9A
SAN FRANCISCO, CA 94177-0001
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CHRIS KING
CHIEF REGULATORY OFFICER
EMETER CORPORATION
2215 BRIDGEPOINTE PARKWAY, STE. 300
SAN MATEO, CA 94404
BETH VAUGHAN
CALIFORNIA COGENERATION COUNCIL
4391 NORTH MARSH ELDER CT.
CONCORD, CA 94521
TONY CHEN
SR. MANGER, BUSINESS DEVEL.
COOL EARTH SOLAR
4659 LAS POSITAS RD., STE. 94551
LIVERMORE, CA 94551
ANDREW J. VAN HORN
VAN HORN CONSULTING
12 LIND COURT
ORINDA, CA 94563
AVIS KOWALEWSKI
CALPINE CORPORATION
4160 DUBLIN BLVD., SUITE 100
DUBLIN, CA 94568
FOR: CALPINEPOWERAMERICA-CA,LLC
JILL VAN DALEN
CALPINE CORPORATION
4160 DUBLIN BLVD., STE. 100
DUBLIN, CA 94568
MATTHEW BARMACK
CALPINE CORPORATION
4160 DUBLIN BLVD., STE. 100
DUBLIN, CA 94568
JENNIFER CHAMBERLIN
LS POWER DEVELOPMENT, LLC
5000 HOPYARD ROAD, SUITE 480
PLEASANTON, CA 94588
TIM MASON
BLACK & VEATCH CORP.
2999 OAK ROAD, SUITE 490
WALNUT CREEK, CA 94597
ALEX KANG
ITRON, INC.
1111 BROADWAY, STE. 1800
OAKLAND, CA 94607
RAMONA GONZALEZ
EAST BAY MUNICIPAL UTILITY DISTRICT
375 ELEVENTH STREET, M/S NO. 205
OAKLAND, CA 94607
BARRY H. EPSTEIN
FITZGERALD,ABBOTT & BEARDSLEY, LLP
1221 BROADWAY, 21ST FLOOR
OAKLAND, CA 94612
ERICA SCHROEDER
KEYES FOX & WIEDMAN, LLP
436 14TH ST., STE. 1305
OAKLAND, CA 94612
TIM LINDL
KEYES FOX & WIEDMAN LLP
436 14TH STREET,STE. 1305
OAKLAND, CA 94612
MATTHEW SCHAFER
NEXTERA ENERGY RESOURCES
505 14TH STREET, SUITE 300
OAKLAND, CA 94612-1935
NELLIE TONG
SENIOR ANALYST
KEMA, INC.
155 GRAND AVE., STE. 500
OAKLAND, CA 94612-3747
RAMESH RAMCHANDANI
COMMERCIAL ENERGY
7677 OAKPORT ST., STE. 525
OAKLAND, CA 94621
RON PERRY
CEO
COMMERCIAL ENERGY
7677 OAKPORT ST., STE. 525
OAKLAND, CA 94621
CYNTHIA WOOTEN
LUMENX CONSULTING, INC.
1126 DELAWARE STREET
REED V. SCHMIDT
BARTLE WELLS ASSOCIATES
1889 ALCATRAZ AVENUE
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CPUC - Service Lists - R1105005
BERKELEY, CA
94702
Page 28 of 36
BERKELEY, CA
94703-2714
ANDY KATZ
SIERRA CLUB CALIFORNIA
2150 ALLSTON WAY, STE. 400
BERKELEY, CA 94704
JOSHUA BAR-LEV
BAR-LEV ASSOCIATES
84 GYPSY LANE
BERKELEY, CA 94705
LINDA AGERTER
LARGE-SCALE SOLAR ASSOCIATION
51 PARKSIDE DRIVE
BERKELEY, CA 94705
GERALD T. ROBINSON
LAWRENCE BERKLEY NATIONAL LABS
ONE CYCLOTRON ROAD
BERKLEY, CA 94720
ED SMELOFF
SENIOR MANAGER
SUNPOWER CORPORATION
1414 HARBOUR WAY SOUTH
RICHMOND, CA 94804
JEREMY WAEN
REGULATORY ANALYST
MARIN ENERGY AUTHORITY
781 LINCOLN AVENUE, STE. 320
SAN RAFAEL, CA 94901
LYNN M. ALEXANDER
LMA CONSULTING
129 REDWOOD AVENUE
CORTE MADERA, CA 94925
TOM FAUST
REDWOOD RENEWABLES LLC
6 ENDEAVOR DRIVE
CORTE MADERA, CA 94925
PAUL FENN
LOCAL POWER
22888 HIGHWAY 1 / PO BOX 744
MARSHALL, CA 94940-9701
ANDERS GLADER
SVP, ORIGINATION
IBERDROLA RENEWABLES
114 MORNING SUN AVENUE
MILL VALLEY, CA 94941
JOHN NIMMONS
COUNSEL
JOHN NIMMONS & ASSOCIATES, INC.
175 ELINOR AVE., STE. G
MILL VALLEY, CA 94941
FOR: RECURRENT ENERGY
TIM ROSENFELD
MARIN ENERGY MANAGEMENT TEAM
131 CAMINO ALTO, SUITE D
MILL VALLEY, CA 94941
JOHN M. SPILMAN
LAW OFFICE OF JOHN M. SPILMAN
22 FAIRWAY DRIVE
MILL VALLEY, CA 94941-1309
EDWARD A. MAINLAND
CO-CHAIR, ENERGY-CLIMATE COMMITTEE
CNRCC SIERRA CLUB CALIFORNIA
1017 BEL MARIN KEYS BLVD.
NOVATO, CA 94949
KEITH WHITE
312 KELLER ST
PETALUMA, CA 94952
BARBARA GEORGE
WOMEN'S ENERGY MATTERS
PO BOX 548
FAIRFAX, CA 94978-0548
ERIC CHERNISS
SOLARGEN ENERGY
20400 STEVENS CREEK BLVD, SUITE 700
CUPERTINO, CA 95014
SHANI KLEINHAUS
SANTA CLARA VALLEY AUDUBON SOCIETY
22221 MCLELLAN ROAD
CUPERTINO, CA 95014
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CPUC - Service Lists - R1105005
Page 29 of 36
JERRY MIX
PRESIDENT
WATTSTOPPER
2800 DE LA CRUZ BLVD.
SANTA CLARA, CA 95050
MARY TUCKER
MARY TUCKER CONSULTING
359 N. 5TH STREET
SAN JOSE, CA 95112
C. SUSIE BERLIN
ATTORNEY AT LAW
MC CARTHY & BERLIN, LLP
100 W SAN FERNANDO ST., STE 501
SAN JOSE, CA 95113
THOMAS J. VICTORINE
SAN JOSE WATER COMPANY
1221 S. BASCOM AVENUE
SAN JOSE, CA 95128
MIKE JENSEN
MERCED IRRIGATION DISTRICT
PO BOX 2288
MERCED, CA 95344-0288
DAVID OLIVARES
ELECTRIC RESOURCE
MODESTO IRRIGATION DISTRICT
PO BOX 4060
MODESTO, CA 95352
JOY A. WARREN
REGULATORY ADMINISTRATOR
MODESTO IRRIGATION DISTRICT
1231 11TH STREET
MODESTO, CA 95354
LINDA FISCHER
LEGAL DEPARTMENT
MODESTO IRRIGATION DISTRICT
1231 11TH STREET
MODESTO, CA 95354
NORMAN ROSS BURGESS
PO BOX 200
ZENIA, CA 95595
DOUGLAS M. GRANDY, P.E.
CALIFORNIA ONSITE GENERATION
DG TECHNOLOGIES
1220 MACAULAY CIRCLE
CARMICHAEL, CA 95608
MARK BERMAN
DAVIS ENERGY GROUP
123 C STREET
DAVIS, CA 95616
RICHARD MCCANN
M.CUBED
2655 PORTAGE BAY ROAD, SUITE 3
DAVIS, CA 95616
TOBIN RICHARDSON
RICHARDSON GROUP
1416 VIGO COURT
DAVIS, CA 95618
DAN AUSTIN
ZGLOBAL, INC.
604 SUTTER STREET, STE. 250
FOLSOM, CA 95630
LEGAL AND REGULATORY DEPARTMENT
CALIFORNIA ISO
151 BLUE RAVINE ROAD
FOLSOM, CA 95630
SAEED FARROKHPAY
FEDERAL ENERGY REGULATORY COMMISSION
1835 IRON POINT RD., SUITE 160
FOLSOM, CA 95630-8771
C. RICHARD WYLIE
BEUTLER CORPORATION
4700 LANG AVE.
MCCLELLAN, CA 95652
DAVID BRANCHCOMB
BRANCHCOMB ASSOCIATES, LLC
9360 OAKTREE LANE
ORANGEVILLE, CA 95662
BRIAN THEAKER
NRG ENERGY
3161 KEN DEREK LANE
RICK A. LIND
SIERRA ECOSYSTEM ASSOCIATES
PO BOX 2260
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CPUC - Service Lists - R1105005
PLACERVILLE, CA
95667
Page 30 of 36
PLACERVILLE, CA
95667
ART RIVERA
RENEWABLE TECHCOM
10923 PROGRESS COURT, NO. 2011
RANCHO CORDOVA, CA 95670
KENNY SWAIN
NAVIGANT CONSULTING
3100 ZINFANDEL DRIVE, SUITE 600
RANCHO CORDOVA, CA 95670
PAUL D. MAXWELL
NAVIGANT CONSULTING, INC.
3100 ZINFANDEL DRIVE, SUITE 600
RANCHO CORDOVA, CA 95670-6078
DANIEL KIM
WESTLANDS SOLAR PARK
PO BOX 582844
ELK GROVE, CA 95757
JACQUELINE M. DEROSA
DIRECTOR OF REGULATORY AFFAIRS - CA
CUSTOMIZED ENERGY SOLUTIONS
101 PARKSHORE DRIVE SUITE 100
FOLSOM, CA 95762
MARGARET MILLER
DIR - REGULATORY AFFAIRS
BROOKFIELD ENERGY MARKETING
513 SAN MARCO PLACE
EL DORADO HILLS, CA 95762
TOM POMALES
CALIFORNIA AIR RESOURCES BOARD
1001 I STREET
SACRAMENTO, CA 95812
ALLISON C. SMITH
ATTORNEY
STOEL RIVES LLP
500 CAPITOL MALL, SUITE 1600
SACRAMENTO, CA 95814
ANTHONY BRUNELLO
CALIFORNIA STRATEGIES LLC
980 NINTH STREET, SUITE 2000
SACRAMENTO, CA 95814
AUTUMN BERNSTEIN
CLIMATE PLAN
717 K STREET, SUITE 330
SACRAMENTO, CA 95814
CURT BARRY
SENIOR WRITER
CLEAN ENERGY REPORT
717 K STREET, SUITE 503
SACRAMENTO, CA 95814
DOROTHY ROTHROCK
VP - GOVERNMENT RELATIONS
CALIFORNIA MANUFACTURERS & TECHNO. ASSN.
1115 11TH STREET
SACRAMENTO, CA 95814
FOR: CALIFORNIA MANUFACTURERS &
TECHNOLOGY ASSOCIATION
JANE E. LUCKHARDT
ATTORNEY AT LAW
DOWNEY BRAND LLP
621CAPITOL MALL, 18TH FLOOR
SACRAMENTO, CA 95814
KEVIN WOODRUFF
WOODRUFF EXPERT SERVICES
1100 K STREET, SUITE 204
SACRAMENTO, CA 95814
MARK A. LOWDER
DIR - HOUSING FINANCE
CRHMFA HOMEBUYERS FUND
1215 K STREET, STE. 1650
SACRAMENTO, CA 95814
NICOLE WRIGHT
BRAUN BLAISING MCLAUGHLIN & SMITH
915 L STREET, SUITE 1270
SACRAMENTO, CA 95814
STEVEN A. BRINK
VP - PUBLIC RESOURCES
CALIFORNIA FORESTRY ASSOCIATION
1215 K STREET, SUITE 1830
TIFFANY K. ROBERTS
CALIFORNIA LEGISLATURE
LEGISLATIVE ANALYST'S OFFICE
925 L STREET, SUITE 1000
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CPUC - Service Lists - R1105005
SACRAMENTO, CA
95814
Page 31 of 36
SACRAMENTO, CA
95814
MICHAEL BOCCADORO
AGRICULTURAL ENERGY CONSUMERS ASSN
925 L STREET, SUITE 800
SACRAMENTO, CA 95814-3704
FOR: AGRICULTURAL ENERGY CONSUMERS
ASSOCIATION
GREGGORY L. WHEATLAND
ELLISON SCHNEIDER & HARRIS, L.L.P.
2600 CAPTIOL AVENYE, SUITE 400
SACRAMENTO, CA 95816
FOR: ENERGYSOURCE, LLC
CHRISTOPHER T. ELLISON
ATTORNEY
ELLISON, SCHNEIDER & HARRIS, L.L.P
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816-5905
ROB ROTH
SACRAMENTO MUNICIPAL UTILITY DISTRICT
6201 S STREET MS 75
SACRAMENTO, CA 95817
VIKKI WOOD
SACRAMENTO MUNICIPAL UTILITY DISTRICT
6301 S STREET, MS A204
SACRAMENTO, CA 95817-1899
MICHAEL S. DAY
PRINCIPAL
ROCKWOOD CONSULTING
2701 2ND AVE.
SACRAMENTO, CA 95818
CAROL J. HURLOCK
CALIFORNIA DEPT. OF WATER RESOURCES
JOINT OPERATIONS CENTER
2033 HOWE AVE., STE. 220
SACRAMENTO, CA 95825-0181
LEE TERRY
CALIFORNIA DEPARTMENT OF WATER RESOURCES
2033 HOWE AVE., STE. 220
SACRAMENTO, CA 95825-0181
EMILIO E. VARANINI, III
4660 NATOMAS BLVD.
SACRAMENTO, CA 95835
STEVEN A. LIPMAN
STEVEN LIPMAN CONSULTING
5350 DUNLAY DRIVE, STE. 811
SACRAMENTO, CA 95835-1570
KAREN LINDH
CALIFORNIA ONSITE GENERATION
7909 WALERGA ROAD, NO. 112, PMB 119
ANTELOPE, CA 95843
JAMES L. BYARD PH.D.
11693 PHELPS HILL ROAD
NEVADA CITY, CA 95959-9150
CALIFORNIA PACIFIC ELECTRIC COMPANY, LLC
933 ELOISE AVENUE
SOUTH LAKE TAHOE, CA 96150
CHRISTIAN MENTZEL
CEM LLC
619 KUPULAU DR
KIHEI, HI 96753
MICHAEL ALCANTAR
ATTORNEY AT LAW
ALCANTAR & KAHL LLP
1300 SW 5TH AVE., STE 1750
PORTLAND, OR 97201
ROSS VAN NESS
ALCANTAR & KAHL LLP
1300 SW FIFTH AVENUE, SUITE 1750
PORTLAND, OR 97201
VARNER SEAMAN
CONSULTANT
EDP RENEWABLES NORTH AMERICA, LLC
53 SW YAMHILL
PORTLAND, OR 97204
TASHIANA WANGLER
PACIFICORP
825 NE MULTNOMAH SREET, SUITE
PORTLAND, OR 97232
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2000
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Page 32 of 36
TERI IKEDA
RENEWABLE COMPLIANCE OFFICER
PACIFICORP
825 NE MULTNOMAH, STE. 600
PORTLAND, OR 97232
DONALD SCHOENBECK
RCS, INC.
900 WASHINGTON STREET, SUITE 780
VANCOUVER, WA 98660
JOHN DUNN
TRANSCANADA CORPORATION
450 1ST ST. S.W.
CALGARY, AB T2P 5H1
CANADA
MEREDITH LAMEY
TRANSCANADA CORPORATION
450 1ST STREET S.W.
CALGARY, AB T2P 5H1
CANADA
DANIEL JURIJEW
CAPITAL POWER CORPORATION
12TH FLOOR EPCOR TOWER
1200 - 10423 101 ST. NW
EDMONTON, AB T5H 0E9
CANADA
LISA CHERKAS
MORGAN STANLEY CAPITAL GROUP, INC.
200 BURRAND ST., STE. 610
VANCOUVER, BC V6C 3L6
CANADA
State Service
CHERYL LEE
CALIFORNIA PUBLIC UTILITIES COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000
DAVID PECK
CALIFORNIA PUBLIC UTILITIES COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000
JACLYN MARKS
CALIFORNIA PUBLIC UTILITIES COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000
MATT MILEY
CPUC
LEGAL DIVISION
EMAIL ONLY
EMAIL ONLY, CA
FOR: DRA
ROBERT BLACKNEY
CALIFORNIA PUBLIC UTILITIES COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000
SARA KAMINS
CALIFORNIA PUBLIC UTILITIES COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000
WILLIAM DIETRICH
CALIFORNIA PUBLIC UTILITIES COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000
LORRAINE GONZALES
CALIFORNIA ENERGY COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000-0000
ADAM SCHULTZ
CALIF PUBLIC UTILITIES COMMISSION
PROCUREMENT STRATEGY AND OVERSIGHT BRANC
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
ANDREW KOTCH
CALIF PUBLIC UTILITIES COMMISSION
EXECUTIVE DIVISION
ROOM 5301
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
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00000
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Page 33 of 36
ANDREW SCHWARTZ
CALIF PUBLIC UTILITIES COMMISSION
PROCUREMENT STRATEGY AND OVERSIGHT BRANC
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
ANNE E. SIMON
CALIF PUBLIC UTILITIES COMMISSION
DIVISION OF ADMINISTRATIVE LAW JUDGES
ROOM 5104
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
CHLOE LUKINS
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4101
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
CHRISTOPHER DANFORTH
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
ROOM 4209
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
CHRISTOPHER MYERS
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4104
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
DAVID SIAO
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4101
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
DEVLA SINGH
CALIF PUBLIC UTILITIES COMMISSION
POLICY & PLANNING DIVISION
ROOM 5119
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
IRYNA KWASNY
CALIF PUBLIC UTILITIES COMMISSION
LEGAL DIVISION
ROOM 4107
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
JASON SIMON
CALIF PUBLIC UTILITIES COMMISSION
PROCUREMENT STRATEGY AND OVERSIGHT BRANC
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
JONATHAN J. REIGER
CALIF PUBLIC UTILITIES COMMISSION
LEGAL DIVISION
ROOM 5035
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
JORDAN PARRILLO
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4104
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
JOSEPH A. ABHULIMEN
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4209
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
JULIE A. FITCH
CALIF PUBLIC UTILITIES COMMISSION
DIVISION OF ADMINISTRATIVE LAW JUDGES
ROOM 5043
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
JULIE HALLIGAN
CALIF PUBLIC UTILITIES COMMISSION
CONSUMER PROTECTION AND SAFETY DIVISION
ROOM 2203
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: CPSD
JUNAID RAHMAN
CALIF PUBLIC UTILITIES COMMISSION
KARIN M. HIETA
CALIF PUBLIC UTILITIES COMMISSION
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Page 34 of 36
ELECTRICITY PRICING AND CUSTOMER PROGRAM
ROOM 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4102
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
KE HAO OUYANG
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4104
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
KEITH D WHITE
CALIF PUBLIC UTILITIES COMMISSION
INFRASTRUCTURE PLANNING AND PERMITTING B
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
MARCELO POIRIER
CALIF PUBLIC UTILITIES COMMISSION
LEGAL DIVISION
ROOM 5025
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
MARK R. LOY
CALIF PUBLIC UTILITIES COMMISSION
ENERGY COST OF SERVICE & NATURAL GAS BRA
ROOM 4205
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: DRA
MICHAEL COLVIN
CALIF PUBLIC UTILITIES COMMISSION
EXECUTIVE DIVISION
ROOM 5212
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
NIKA ROGERS
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4101
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
NILGUN ATAMTURK
CALIF PUBLIC UTILITIES COMMISSION
POLICY & PLANNING DIVISION
ROOM 5119
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
PAUL DOUGLAS
CALIF PUBLIC UTILITIES COMMISSION
PROCUREMENT STRATEGY AND OVERSIGHT BRANC
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
RAHMON MOMOH
CALIF PUBLIC UTILITIES COMMISSION
EXECUTIVE DIVISION
ROOM 5206
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
REGINA DEANGELIS
CALIF PUBLIC UTILITIES COMMISSION
DIVISION OF ADMINISTRATIVE LAW JUDGES
ROOM 5105
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
SEAN A. SIMON
CALIF PUBLIC UTILITIES COMMISSION
PROCUREMENT STRATEGY AND OVERSIGHT BRANC
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
TRACI BONE
CALIF PUBLIC UTILITIES COMMISSION
LEGAL DIVISION
ROOM 5027
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
XIAO SELENA HUANG
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4102
505 VAN NESS AVENUE
YULIYA SHMIDT
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PLANNING & POLICY BRANCH
ROOM 4108
505 VAN NESS AVENUE
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11/20/2012
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SAN FRANCISCO, CA
94102-3214
Page 35 of 36
SAN FRANCISCO, CA
94102-3214
CLARE LAUFENBER GALLARDO
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS-46
SACRAMENTO, CA 95814
CONSTANCE LENI
CALIFORNIA ENERGY COMMISSION
MS-20
1516 NINTH STREET
SACRAMENTO, CA 95814
GINA BARKALOW
CALIFORNIA ENERGY COMMISSION (CEC)
1516 NINTH STREET MS-45
SACRAMENTO, CA 95814
HEATHER RAITT
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET, MS 45
SACRAMENTO, CA 95814
KATE ZOCCHETTI
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET, MS-45
SACRAMENTO, CA 95814
MARC PRYOR
CALIFORNIA ENERGY COMMISSION
1516 9TH ST, MS 20
SACRAMENTO, CA 95814
MICHAEL JASKE
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET, MS-20
SACRAMENTO, CA 95814
PAMELA DOUGHMAN
CALIFORNIA ENERGY COMMISSION
TECHNOLOGY SYSTEMS DIVISION
1516 9TH STREET, MS 45
SACRAMENTO, CA 95814
REBECCA TSAI-WEI LEE
CALIF PUBLIC UTILITIES COMMISSION
DRA - ADMINISTRATIVE BRANCH
770 L Street, Suite 1250
Sacramento, CA 95814
DAVID VIDAVER
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS-20
SACRAMENTO, CA 95814-5512
GABRIEL HERRERA
OFFICE OF CHIEF COUNSEL
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS 14
SACRAMENTO, CA 95814-5512
JAMES HAILE
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS 45
SACRAMENTO, CA 95814-5512
JIM WOODWARD
ELECTRICITY SUPPLY ANALYSIS DIVISION
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS 20
SACRAMENTO, CA 95814-5512
KEVIN CHOU
ANALYST - ENERGY
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS 45
SACRAMENTO, CA 95814-5512
ROSS A. MILLER
ELECTRICITY ANALYSIS OFFICE
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET MS 20
SACRAMENTO, CA 96814-5512
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CPUC - Service Lists - R1105005
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BACK TO INDEX OF SERVICE LISTS
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11/20/2012
Non-Email Parties
Angel Ayala
Amonix, Inc.
1709 Apollo Ct.
Seal Beach, CA 90740