HomeMy WebLinkAbout2020-07-16; Clean Energy Alliance JPA; ; Clean Energy Alliance Operational, Administrative and Regulatory Affairs UpdateStaff Report
DATE: July 16, 2020
TO: Clean Energy Alliance Board of Directors
FROM: Barbara Boswell, Interim Chief Executive Officer
ITEM 3: Clean Energy Alliance Operational, Administrative and Regulatory Affairs Update
RECOMMENDATION:
1) Receive and File Community Choice Aggregation Update Report from Interim CEO.
2) Receive Community Choice Aggregation Regulatory Affairs Report from Special Counsel.
BACKGROUND AND DISCUSSION:
This report provides an update to the Clean Energy Alliance (CEA) Board regarding the status of the
operational, administrative and regulatory affairs activities.
OPERATIONAL UPDATE
CEA is meeting its milestones for the implementation of its community choice aggregation (CCA)
program and is on track to begin serving customers in May 2021. (Attachment A - Clean Energy Alliance
Timeline of Implementation Action Items).
As you are aware, San Diego Gas & Electric (SDG&E) has been working diligently over the past several
years working on their Customer Information System replacement program, known as Envision. They
have been committed to, and on track, for a January 4, 2021 go live, despite the challenges of working
remote in the COVID-19 environment. With a January 2021 go live, SDG&E has been committed to
supporting the CEA launch of May 2021. On Friday July 10, CEA staff, its regulatory attorney Ty Tosdal
and data manager Calpine Energy Solutions participated in a call with San Diego Community Power and
SDG&E regarding the recently approved California Public Utilities Commission (CPUC) Decision D. 20-06-
003, which requires the Investor Owned Utilities (IOU) to adopt rules and policy changes designed to
reduce the number of residential disconnections, provide assistance with debt forgiveness and offer
extended payment plans. The decision is required to be implemented by the IOUs April 2021. This
timing has presented a challenge to SDG&E to keep its go live date of January 4, 2021 while also meeting
the requirements of the decision. As such, SDG&E has submitted a letter (Attachment B) to the CPUC
requesting an extension to September 30, 2021 for implementing the new procedures and policies
required by the decision. This extension would provide the ability for SDG&E to complete its new
system implementation and support the CEA May 2021 launch. SDG&E's letter has received protests
from The Utility Reform Network (Attachment C) and Utility Consumer's Action Network (Attachment
D). SDG&E is not optimistic that their request to extend the implementation of the decision will be
approved by the CPUC, as a result the May 2021 launch of CEA is now in jeopardy.
CEA and SDG&E are continuing to meet this week, and staff will provide a verbal update at the Board
meeting.
July 16, 2020 Item #3 Page 1 of 26
Expansion of Clean Energy Alliance
Staff has been in communication with community members in San Clemente interested in bringing CCA
to their city. Information was provided about the status of CEA and offer to meet with San Clemente
leadership to discuss CCA and the potential to join CEA.
Regulatory Compliance Filings
CEA's 2020 Renewable Portfolio Standards (RPS) Procurement Plan was filed on July 2, 2020. The Plan
amended the Initial RPS Procurement Plan to reflect additional information requested by the California
Public Utilities Commission.
The Integrated Resource Plan (IRP) provides the CPUC with CEA's 10-year projected electricity load as
part of the integrated resource planning process to ensure that California's electric sector meets its GHG
reduction goals while maintaining reliability at the lowest possible costs. The IRP was originally due in
April 2020, was pushed out to July 2020, and has now been further pushed out to September 2020. An
informational item is planned for the CEA Board at the special meeting July 23, 2020, and the IRP will be
brought for approval on August 20, 2020 followed by submittal by September 1.
Long-Term Renewable Procurement
As a load serving entity CEA will be required to procure 65% of its minimum required renewable
portfolio standards in contracts of 10-years or longer. To ensure compliance with this requirement,
work has begun in developing speCification for a long-term renewable solicitation. The process of the
solicitation process, from beginning through final execution can be lengthy, and in light of the impacts of
COVID-19 on the renewable development industry, the solicitation opened on July 1, 2020.
Request for Proposals
Request for Proposals for Credit Solution
At its June 18, 2020 meeting the Board received a report regarding offers from JP Morgan and River City
Bank (RCB) to provide funding for FY 20/21 budget, initial start-up repayment to Member Agencies and
operational reserves and cash flow needs. The RCB offer was the lower cost option, however, requires
security in the form of either a guaranty or cash collateral. The Board directed staff to reach out the
Member Agencies to request consideration of providing the security for the RCB option. The request
was scheduled for consideration by the Carlsbad City Council at its July 14, 2020 meeting, Del Mar at its
July 20, 2020 meeting and Solana Beach at its July 8, 2020 meeting. The CEA Board will hold a special
meeting on July 23, 2020 to receive a report on the results of the request made of the Member
Agencies.
Request for Qualifications 2020-004 for Portfolio Manager and Scheduling Coordinator
At its May 21, 2020 meeting the Board authorized issuance of RFQ 2020-004, Portfolio Manager and
Scheduling Coordinator Services with responses due June 17, 2020. CEA received five responses to the
RFQ. Staff is continuing to evaluate the responses and will bring a recommendation to the Board at its
August 20, 2020 meeting.
Request for Proposals 2020-005 for Communications and Marketing Services
At its May 21, 2020 meeting the Board authorized issuance of RFP 2020-005, Communications and
Marketing Services with responses due June 19, 2020. CEA received ten responses to the RFP. Staff is
continuing to evaluate the responses and will bring a recommendation to the Board at its August 20,
2020 meeting.
July 16, 2020 Item #3 Page 2 of 26
Administrative and Operational Policies
During the coming months as CEA prepares for its implementation and operation, policies will be
brought to the Board for consideration in future Board meetings. The policies as proposed will be based
on government code or regulatory requirements and best practices of successfully operational CCAs.
The policies and timeline as currently anticipated are:
August 20 Board Meeting
• Records Retention Policy
• Investment Policy
September 17 Board Meeting
• Energy Risk Management Policy
REGULATORY UPDATE
Attached is a regulatory report from Ty Tosdal, Special Counsel, providing a summary of key regulatory
proceedings (Attachment B - Tosdal APC Energy Regulatory Update).
FISCAL IMPACT
There is no fiscal impact by this action.
ATTACHMENTS:
Attachment A - Clean Energy Alliance Timeline of Implementation Action Items
Attachment B — San Diego Gas & Electric Letter to California Public Utilities Commission
Attachment C— Letter from The Utility Reform Network to California Public Utilities Commission
Attachment D — Letter from Utility Consumer's Action Network to California Public Utilities Commission
Attachment E —Tosdal APC Energy Regulatory Update
July 16, 2020 Item #3 Page 3 of 26
Attachment A
Mean Enenw Alliance
Timeline of Implementation Related Action Items
Date
Timin eted Dec-19 Jan-20 Feb-2D Mar.20 Apr-713 May-20 Jun-20 Jul-10 Aug-TA
12/19/19 12/19/19 Appoint Interim Executive Director
12/19/19
12/19/19 &
12/23/19
Approve & File Implementation Plan & Statement of
Intent
1/16/20 1/16/20 Direction on Banking and Great Solutions
1/16/20 1/16/20
Authorize RFP for Technical Consultant to Assist with
Regulatory Filings
1/16/20 1/16/20 Authorize RFP for Data Manager/Call Center
1/16/20 1/16/20 CEA Public Outreach and Marketing Kickoff
1/20/20 1/20/20 Issue RFP for Technical Consultant & Data Manager
2/20/20 2/20/20 Select Financial Institution & Approve Financing Plan
2/20/20 2/20/20
Select Technical Consultant to Assist with Regulatory
Filings
2/20/20 2/20/20 Select Data Manager
2/20/20 2/20/20 Staff Develop & Submit Draft Customer Notice to CPUC
2/20/20 2/20/20 Develop Renewable Portfolio Standards Procurement Plan
2/20/20 2/20/20 Authorize Execution of Service Agreement with SDG&E
4/20/20 4/23/20 Post CCA Bond with CPUC
4/20/20 4/23/20 Execute Service Agreement with SDG&E & Submit to CPUC
4/20/20 4/20/20 Year-Ahead Resource Adequacy Forecast Filing
6/30/20 Initial Resource Adequacy Solicitation
6/29/20 File 2020 Renewable Portfolio Slandards Procurement Plan
8/20/20 Approve Integrated Resource Plan
8/32/20 File Integrated Resource Plan
Key:
Administrative
Implementation Plan Related
Regulatory Compliance
July 16, 2020 Item #3 Page 4 of 26
Attachment B
SDG'i
A Sempra Energy utility®
Dan Skopec
Vice President, Regulatory Affairs
8330 Century Park Court
San Diego, CA 92123
dskopec@sdge.com
July 1,2020
Alice Stebbins, Executive Director
California Public Utilities Commission
505 Van Ness Ave, Room 4004
San Francisco, CA 94102
Re: REQUEST FOR EXTENSION TO IMPLEMENT RULES, CHANGES, AND CUSTOMER
PROGRAMS MANDATED IN DECISION (D.) 20-06-003, ADOPTING RULES AND POLICY
CHANGES TO REDUCE RESIDENTIAL CUSTOMER DISCONNECTIONS FOR THE
LARGER CALIFORNIA-JURISDICTIONAL ENERGY UTILITIES
Dear Ms. Stebbins:
Pursuant to Rule 16.6 of the California Public Utilities Commission Rules of Practice and Procedure,
San Diego Gas & Electric Company (SDG&E) respectfully requests an extension to implement
Decision (D.) 20-06-003 (or Decision), which requires Investor Owned Utilities (IOUs) to adopt rules
and policy changes designed to reduce the number of residential disconnections and to improve the
reconnection process for disconnected customers. As justified below, SDG&E respectfully requests
an extension to implement the customer protections required by D.20-06-003 from April 16, 2021 to
September 30, 2021. As required by Rule 16.6, a copy of this letter has been served upon all parties
to Rulemaking (R.) 18-07-005 and the Administrative Law Judge Division, and the certificate of
service is attached.
Background
On June 11, 2020, the Commission approved D.20-06-003, which makes permanent the interim
disconnection protections currently in place, including the existing cap on disconnections and other
vulnerable customer disconnection protections effected in D.18-12-013. The Decision also provides
additional customer disconnection protections by requiring the IOUs to enroll eligible customers in all
applicable benefit programs, offer 12-month payment plans, and to prohibit disconnections if there is
a Low-Income Energy Assistance Program (LIHEAP) pledge.
Among other things, D.20-06-003 prohibits IOUs from requiring establishment or reestablishment of
service deposits or charging connection fees, and requires improved disconnection notices so
customers are better informed about available financial assistance programs. It revises medical
baseline enrollment requirements. And to assist California Alternate Rates for Energy (CARE) and
Family Electric Rate Assistance (FERA) customers with unpaid arrearages, it creates an Arrearage
Management Payment (AMP) Plan for eligible customers. Finally, the decision mandates the creation
of an enforcement program to ensure compliance with decision requirements.
July 16, 2020 Item #3 Page 5 of 26
Notably, D.20-06-003 acknowledges the ongoing COVID-19 Pandemic Emergency Consumer
Protections in place for residential and small business customers, including the moratorium on
disconnections for eligible customers. Many of the Emergency Customer Protections are similar to or
overlap with programs mandated by the Decision. The Decision directs the IOUs to "immediately
implement the vulnerable customer protections required by this decision at the expiration of the
Emergency Customer Protections." (OP 3). It further provides that any protections set forth in the
Decision which were not implemented due to a conflict with the Emergency Customer Protections
must be implemented at the expiration of the Emergency Customer Protections period, or April 16,
2021. (OP 4). Additionally, customers eligible for the AMP must be allowed to opt into the AMP
program even if they are involved in a separate payment plan under the Emergency Customer
Protections. Given this direction, SDG&E understands that the effective date of many of the
disconnection protections implemented by the Decision will be April 16, 2021.
In opening comments, SDG&E addressed the ongoing implementation of its new Customer
Information System (CIS) upgrade, scheduled to go online on January 1, 2021. SDG&E noted that it
would not be able to add billing or process changes until after the system has been fully implemented
and a period of system stabilization occurs. In opening comments, Southern California Edison
Company (SCE) specifically requested to delay implementing the Decision requirements until 2022
for similar reasons. Like SDG&E, SCE is currently updating its Customer Service Re-Platform
implementation, scheduled for early 2021, and requires a six-month stabilization period after system
deployment, during which system changes will be focused on defect correction and other
stabilization needs. SCE requested up to 12 months after the stabilization period to implement the
changes in the proposed decision, the most significant of which was the AMP program.1 The
Commission rejected SCE's delay request.
Discussion
SDG&E recognizes the importance of reducing disconnections for residential customers and will take
all necessary steps to implement the programs and polices described in the Decision. The
requirements in the decision, however, are expansive and complex. They require extensive technical
analysis, design, and development work within the billing system and customer service technologies
in order to deliver the new functionality and programs.
SDG&E is unable to complete this work within its new CIS prior to deployment in January 2021.
Program scope is frozen, initial testing is nearly complete, and any substantive changes at this point
introduce significant risk to the entire CIS project.
SDG&E is very proud that is has remained on schedule and on budget for its new CIS system after
more than three years of effort. Yet in order to meet the implementation timeline required in the
Decision, SDG&E would need to delay its entire CIS program to April 2021 so the new functionality
could be added.
SDG&E strongly recommends against this option, as this months-long delay could increase program
costs by an estimated $20 million to $30 million. Additionally, SDG&E has worked in partnership with
newly established Community Choice Aggregators in its service territory to coordinate CIS
1 See Southern California Edison's Opening Comments to Phase I Proposed Decision Adopting Rules and
Policy Changes to Reduce Residential Customer Disconnections for the Larger California-Jurisdictional Energy
Utilities at p. 10-11 and Appendix B.
July 16, 2020 Item #3 Page 6 of 26
implementation and ensure that the Community Choice Aggregators (CCA) can begin transitioning
customers in spring of 2021. Any CIS delay may impact the ability to begin the CCA transition as
scheduled, an outcome both SDG&E and CCA partners want to avoid.
As an alternative to this costly and consequential outcome, SDG&E requests a short delay of the
Decision requirements from April 16, 2021 to September 30, 2021. This delay would enable SDG&E
to complete the estimated 4 to 6-month stabilization period following CIS deployment in January
2021, and subsequently develop and install the Decision requirements in the new system. The
overall objective of the stabilization period is to reduce the risk of potential customer impacts and
billing system issues. The five-month delay sought is substantially shorter than the delay previously
requested by SCE, provides a definitive timeframe, and minimizes customer risk and impact as
SDG&E's new CIS system is onboarded. SDG&E recognizes the importance of the provisions of the
Decision on eligible customers. A short delay of implementation of the Decision requirements,
however, is less costly to ratepayers, preserves stability of the CIS system, and helps ensure CCAs
can begin customer transition as scheduled.
SDG&E shares the goal of keeping customers energy on, and has historically taken cautious and
calculated measures around disconnections. As a result, SDG&E has consistently maintained the
lowest disconnection rate of the electric utilities at approximately 3.5%. SDG&E recognizes the intent
of the Commission to further reduce disconnections of residential customers, especially low-income
customers who may benefit by programs like AMP. If the Commission grants SDG&E's delay
request, SDG&E proposes to extend the current disconnection moratorium to CARE/FERA
customers until the Decision requirements are in place. This approach would ensure continued
protection of these customers following expiration of the Emergency Customer Protections, and
confirm that the Commission's goal of protecting eligible customers from disconnection is met.
In sum, implementation of the Decision's disconnection protections in April 2021 would interfere with
SDG&E's CIS Replacement Project, potentially resulting in a costly delay of the CIS project with
negative impacts on ratepayers and other stakeholders. A short delay of the Decision requirements
is warranted. Therefore, SDG&E respectfully requests an extension of implementation of D.20-06-
003 from April 16, 2021 to September 30, 2021.
Sincerely,
/s/ Dan Skopec
DAN SKOPEC
SDG&E Vice President Regulatory Affairs
Cc: Edward Randolph, Energy Division Director
Administrative Law Judge Gerald F. Kelly
CPUC Administrative Law Judge Division
Scott Crider, SDG&E Vice President Customer Services
All Parties of Record for R.18-07-005
July 16, 2020 Item #3 Page 7 of 26
BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking to Consider New
Approaches to Disconnections and
Reconnections to Improve Energy Access and
Contain Costs.
Rulemaking 18-07-005
(Filed July 12, 2018)
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a copy of the foregoing SAN DIEGO
GAS & ELECTRIC COMPANY'S REQUEST FOR EXTENSION TO IMPLEMENT
RULES, CHANGES, AND CUSTOMER PROGRAMS MANDATED IN DECISION
(D.) 20-06-003, ADOPTING RULES AND POLICY CHANGES TO REDUCE
RESIDENTIAL CUSTOMER DISCONNECTIONS FOR THE LARGER
CALIFORNIA-JURISDICTIONAL ENERGY UTILITIES parties of record by
electronic mail.
Due to the current Coronavirus (COVID-19) health crisis, our legal staff is working
from home. Accordingly, pursuant to CPUC COVID-19 Temporary Filing and Service
Protocol for Formal Proceedings, paper copies of e-filed documents will not be mailed to
the Administrative Law Judge or to parties on the service lists.
Executed this 1st day of July 2020 at San Diego, California.
Is! Darleen Evans
Darleen Evans
July 16, 2020 Item #3 Page 8 of 26
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MIKE LAMOND
CHIEF FINANCIAL OFFICER
ALPINE NATURAL GAS OPERATING CO. #1 LLC
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: ALPINE NATURAL GAS OPERATING CO.#1
LLC
OLIVIA B. WEIN
ATTORNEY AT LAW
NATIONAL CONSUMER LAW CENTER
1001 CONNECTICUT AVE., NW., STE. 510
WASHINGTON, DC 20036-5528
FOR: NATIONAL CONSUMER LAW CENTER (NCLC)
HOLLY A. JONES
SR. COUNSEL
SOUTHERN CALIFORNIA GAS COMPANY
555 W. FIFTH STREET, GT-14E7
LOS ANGELES, CA 90013
FOR: SOUTHERN CALIFORNIA GAS COMPANY
AND SAN DIEGO GAS & ELECTRIC COMPANY
MABEL TSUI
ATTORNEY
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE. / PO BOX 800
ROSEMEAD, CA 91770
July 16, 2020
TODD EDMISTER
DIR & DEPUTY GEN. COUNSEL
EAST BAY COMMUNITY ENERGY
EMAIL ONLY
EMAIL ONLY, CA 00000
FOR: EAST BAY COMMUNITY ENERGY
CARLA C. KOLEBUCK
ASSOC. GEN. COUNSEL
SOUTHWEST GAS CORPORATION
5241 SPRING MOUNTAIN ROAD
LAS VEGAS, NV 89150-0002
FOR: SOUTHWEST GAS CORPORATION
JOSH BUTLER
HOUSING LONG BEACH
525 E. 7TH STREET, STE. 111
LONG BEACH, CA 90813
FOR: HOUSING LONG BEACH
RONALD MOORE
SR ANALYST, REGULATORY AFFAIRS
BEAR VALLEY ELECTRIC SERVICE
630 EAST FOOTHILL BOULEVARD
SAN DIMAS, CA 91773
Item U3 Page 9 of 26
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FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: BEAR VALLEY ELECTRIC SERVICES
(GOLDEN STATE WATER COMPANY)
DAVID CHENG
STAFF ATTORNEY
THE UTILITY REFORM NETWORK
1620 5TH AVENUE, SUITE 810
SAN DIEGO, CA 92101
FOR: THE UTILITY REFORM NETWORK (TURN)
JANE KRIKORIAN
MGR - REGULATORY
UTILITY CONSUMERS' ACTION NETWORK
3405 KENYON STREET, STE. 401
SAN DIEGO, CA 92110
FOR: UCAN
ROBERT HUERTA
RESOURCE MGR.
POVERELLO HOUSE
412 F STREET
FRESNO, CA 93706
FOR: POVERELLO HOUSE
RACHAEL KOSS
ATTORNEY
ADAMS BROADWELL JOSEPH & CORDOZO
601 GATEWAY BLVD., STE. 1000
SOUTH SAN FRANCISCO, CA 94080
FOR: COALITION OF CALIFORNIA UTILITY
EMPLOYEES
VANESSA BALDWIN
CALIF PUBLIC UTILITIES COMMISSION
LEGAL DIVISION
ROOM 5029
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
FOR: PUBLIC ADVOCATES OFFICE (FORMERLY
THE OFFICE OF RATEPAYER ADVOCATES - OR
ELISE HUNTER
DIR - POLICY & REGULATORY AFFAIRS
GRID ALTERNATIVES
1171 OCEAN AVE., STE. 200
OAKLAND, CA 94608
FOR: GRID ALTERNATIVES
CARMELITA L. KELLY MILLER
LEGAL COUNSEL
THE GREENLINING INSTITUTE
360 14TH STREET, SECOND FLOOR
OAKLAND, CA 94612
FOR: THE GREENLINING INSTITUTE
ROSA SANCHEZ ULLOA
CITY HEIGHTS COMMUNITY DEVELOPMENT CORP
4001 EL CAJON BLVD., STE. 205
SAN DIEGO, CA 92105
FOR: CITY HEIGHTS COMMUNITY DEVELOPMENT
CORPORATION
MARIO A. GONZALEZ
CENTRO LA FAMILIA ADVOCACY SERVICES
302 FRESNO STREET, STE. 102
FRESNO, CA 93706
FOR: CENTRO LA FAMILIA ADVOCACY
SERVICES, INC.
ERIC PAYNE
FOUNDER
THE CENTRAL VALLEY URBAN INSTITUTE
700 VAN NESS
FRESNO, CA 93721
FOR: THE CENTRAL VALLEY URBAN INSTITUTE
IROSS NAKASONE
PLANNING & REGULATORY COMPLIANCE
SAN FRANCISCO PUBLIC UTILITES COMMISSION
525 GOLDEN GATE AVE., 7TH FL.
SAN FRANCISCO, CA 94102
FOR: CITY AND COUNTY OF SAN FRANCISCO
STEVEN W. FRANK
ATTORNEY
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, B30A
SAN FRANCISCO, CA 94105
FOR: PACIFIC GAS AND ELECTRIC COMPANY
LAURENCE VANHOCK
COMMUNITY CHURCK
1527 34TH STREET
OAKLAND, CA 94608
FOR: COMMUNITY CHURCH
MELISSA W. KASNITZ
ATTORNEY
CENTER FOR ACCESSIBLE TECHNOLOGY
3075 ADELINE STREET, STE. 220
BERKELEY, CA 94703
FOR: CENTER FOR ACCESSIBLE TECHNOLOGY
July 16, 2020 Item #3 Page 10 of 26
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ANDREA LUQUETTA-KERN
LUGUETTA SUPPORT AND ADVOCACY
1680 CYPRESS AVE
RICHMOND, CA 94805
FOR: CALIFORNIA LOW-INCOME CONSUMER
COALITION
DENNIS OSMER
EXE. DIR.
CENTRAL COAST ENERGY SERVICES, INC.
PO BOX 2707
WATSONVILLE, CA 95077
FOR: CENTRAL COAST ENERGY SERVICES, INC.
RAYMOND J. CZAHAR
CHIEF FINANCIAL OFFICER
WEST COAST GAS CO., INC.
9203 BEATTY DR.
SACRAMENTO, CA 95826-9702
FOR: WEST COAST GAS COMPANY, INC
DANIEL MARSH
MGR - RATES & REGULATORY AFFAIRS
LIBERTY UTILITIES (CALPECO ELECTRIC) LLC
933 ELOISE AVENUE
SOUTH LAKE TAHOE, CA 96150
FOR: LIBERTY UTILITIES (CALPECO
ELECTRIC) LLC
BETH VAUGHAN
EXECUTIVE DIR
CALIFORNIA COMMUNITY CHOICE ASSOCIATION
1125 TAMALPAIS AVE.
SAN RAFAEL, CA 94960
FOR: CALIFORNIA COMMUNITY CHOICE
ASSOCIATION
ANDRE BELION
FATHERS AND FAMILIES OF SAN JOAQUIN
338 E. MARKET STREET
STOCKTON, CA 95202
FOR: FATHERS AND FAMILIES OF SAN JOAQUIN
DAVID SCRIBNER
CHIEF COUNSEL
DEPT OF COMMUNITY SERVICES & DEVELOPMENT
2389 GATEWAY OAKS DR., STE. 100
SACRAMENTO, CA 95833
FOR: DEPARTMENT OF COMMUNITY SERVICES
AND DEVELOPMENT
POOJA KISHORE
MGR - REGULATORY AFFAIRS
PACIFICORP
825 NE MULTNOMAH, STE. 2000
PORTLAND, OR 97232
FOR: PACIFICORP
Information Only
CHRISTINE BEVILACQUA
ENERGY RESEARCH ASSOCIATE
TOSDAL, APC
EMAIL ONLY
EMAIL ONLY, CA 00000
FEBY BOEDIARTO
REGULATORY ANALYST
EAST BAY COMMUNITY ENERGY
EMAIL ONLY
EMAIL ONLY, AA 00000
IKAVYA BALARAMAN KAVYA BALARAMAN
REPORTER STAFF WRITER / REPORTER
UTILITY DIVE CALIFORNIA ENERGY MARKETS
EMAIL ONLY EMAIL ONLY
EMAIL ONLY, DC 00000 EMAIL ONLY, CA 00000
KE HAO OUYANG
PROGRAM & PROJECT SUPERVISOR - CPED
CALIFORNIA PUBLIC UTILITIES COMMISSION
EMAIL ONLY
EMAIL ONLY, CA 00000
MARTHA GUZMAN ACEVES
OFFICE OF COMMISSIONER GUZMAN ACEVES
CPUC - EXEC. DIV.
EMAIL ONLY
EMAIL ONLY, CA 00000
MELISSA NOTTINGHAM RACHAEL KOSS
MANGR. CUSTOMER ADVOCACY & TARIFF POLICY ADAM BROADWELL JOSEPH & CARDOZO
July 16, 2020 Item #3 Page 11 of 26
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PACIFICORP EMAIL ONLY
EMAIL ONLY EMAIL ONLY, CA 00000
EMAIL ONLY, OR 00000
SAMANTHA WEAVER
PRINCIPAL REGULATORY ANALYST
EAST BAY COMMUNITY ENERGY
EMAIL ONLY
EMAIL ONLY, CA 00000
CALIFORNIA COMMUNITY CHOICE ASSOCIATION
EMAIL ONLY
EMAIL ONLY, CA 00000
TED TARDIF
ENERGY RESOURCES MGR
CLEAN POWER ALLIANCE OF SOUTHERN CA
EMAIL ONLY
EMAIL ONLY, CA 00000
MRW & ASSOCIATES, LLC
EMAIL ONLY
EMAIL ONLY, CA 00000
TASHIA GARRY
LEGAL ASSISTANT
SOUTHWEST GAS CORPORATION
5241 SPRING MOUNTAIN ROAD
LAS VEGAS, NV 89150
ELLIOTT S. HENRY
SR. COUNSEL
SOUTHERN CALIFORNIA GAS COMPANY
555 WEST FIFTH STREET, GT14E7
LOS ANGELES, CA 90013
FOR: SOUTHERN CALIFORNIA GAS COMPANY
AND SAN DIEGO GAS & ELECTRIC COMPANY
JOSEPH MOCK
REGULATORY CASE MGR.
SOUTHERN CALIFORNIA GAS COMPANY
555 WEST 5TH ST., STE 1400, GT14D6
LOS ANGELES, CA 90013
PAMELA WU
REGULATORY CASE MGR.
SOUTHERN CALIFORNIA GAS COMPANY
555 W. FIFTH STREET, GT14D6
LOS ANGELES, CA 90013
ANNA VALDBERG
DIR - MANAGING ATTORNEY
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE. / PO BOX 800
ROSEMEAD, CA 91770
JAKE HUTTNER
SR. PROJECT MGR.
SOUTHERN CALIFORNIA EDISON COMPANY
8631 RUSH STREET
ROSEMEAD, CA 91770
VALERIE J. ONTIVEROZ
REGULATORY MGR / CA
SOUTHWEST GAS CORPORATION
5241 SPRING MOUNTAIN ROAD
LAS VEGAS, NV 89150
GERALD F. KELLY
CALIF PUBLIC UTILITIES COMMISSION
ADMINISTRATIVE LAW JUDGE DIVISION
320 West 4th Street Suite 500
Los Angeles, CA 90013
NANCY WHANG
GENERAL COUNSEL
CLEAN POWER ALLIANCE
EMAIL ONLY
EMAIL ONLY, CA 90013
RONALD VAN DER LEEDEN
DIR. - REGULATORY AFFAIRS
SOUTHERN CALIFORNIA GAS COMPANY
555 W. FIFTH STREET, GT14D6
LOS ANGELES, CA 90013
FOR: SOUTHERN CALIFORNIA GAS COMPANY
CASE ADMINISTRATION
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE. / PO BOX 800
ROSEMEAD, CA 91770
LAUREN P. GOSCHKE
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVE.
ROSEMEAD, CA 91770
July 16, 2020 Item #3 Page 12 of 26
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CPUC - Service Lists - R1807005 Page 5 of 10
PAUL KUBASEK
MGR.
SOUTHERN CALIFORNIA EDISON COMPANY
8631 RUSH STREET
ROSEMEAD, CA 91770
TY TOSDAL
ATTORNEY
TOSDAL, APC
777 S. COAST HIGHWAY 101, SUITE 215
SOLANA BEACH, CA 92075
EDWARD LOPEZ
EXECUTIVE DIR
UTILITY CONSUMERSae' ACTION NETWORK
3405 KENYON ST. SUITE 401
SAN DIEGO, CA 92110
ADOLFO MORENO
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK COURT
SAN DIEGO, CA 92123
CHRIS BENDER
SAN DIEGO GAS & ELECTRIC COMPANY
8690 BALBOA AVE., STE. 10 (CPA01)
SAN DIEGO, CA 92123
JOHN A. PACHECO
SR. COUNSEL
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK CT., CP32
SAN DIEGO, CA 92123
SIOBHAN MURILLO
CASE MGR - REGULATORY
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK COURT, CP32F
SAN DIEGO, CA 92123
SHEILA LEE
SR. POLICY ADVISOR
SAN DIEGO GAS & ELECTRIC COMPANY
8335 CENTURY PARK COURT, CP 12H
SAN DIEGO, CA 92123-1569
STEPHEN KEEHN
MGR OF ENERGY REG & LEGISLATIVE AFFAIRS
MONTEREY BAY COMMUNITY POWER
70 GARDEN COURT, SUITE 300
MONTEREY, CA 93940
NGUYEN QUAN
REGULATORY AFFAIRS MGR.
BEAR VALLEY ELECTRIC SERVICE
630 EAST FOOTHILL BLVD.
SAN DIMAS, CA 91773
COURTNEY COOK
PARALEGAL / OFFICE ADMIN.
UTILITY CONSUMERS' ACTION NETWORK
3405 KENYON STREET, SUITE 401
SAN DIEGO, CA 92110
JASON ZELLER
UTILITY CONSUMERSAeTm ACTION NETWORK
3405 KENYON STREET, SUITE 401
SAN DIEGO, CA 92110
ANNLYN FAUSTINO
REGULATORY & COMPLIANCE
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK COURT, CP32F
SAN DIEGO, CA 92123
CLAY FABER
DIR. CA & FEDERAL REGULATORY
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK COURT, CP32F
SAN DIEGO, CA 92123
FOR: SAN DIEGO GAS & ELECTRIC COMPANY
MICHELLE SOMERVILLE
REGULATORY CASE MGR.
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK COURT, CP32F
SAN DIEGO, CA 92123
CENTRAL FILES
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK CT, CP31-E
SAN DIEGO, CA 92123-1530
MARC STERN
BEAR VALLEY ELECTRIC SERVICE
42020 GARSTIN DR./ PO BOX 1547
BIG BEAR LAKE, CA 92315
DOUG KARPA
SR ANALYST - REGULATORY
PENINSULA CLEAN ENERGY
2075 WOODSIDE ROAD
REDWOOD CITY, CA 94061
July 16, 2020 Item #3 Page 13 of 26
https://ia.cpuc.ca.gov/servicelists/R1807005 85721.htm 7/1/2020
MILES F. MAURINO
ASSOCIATE ATTORNEY
ADAMS BROADWELL JOSEPH &
601 GATEWAY BLVD., SUITE
SOUTH SAN FRANCISCO, CA
CARDOZO
1000
94080
FOR: COALITION OF CALIFORNIA UTILITY
EMPLOYEES
CPUC - Service Lists - R1807005 Page 6 of 10
JOSEPH F. WIEDMAN
DIR - REGULATORY & LEGISLATIVE AFFAIRS
PENINSULA CLEAN ENERGY AUTHORITY
2075 WOODSIDE ROAD
REDWOOD CITY, CA 94061
ILANA PARMER MANDELBAUM
DEPUTY COUNTY COUNSEL
SAN MATEO COUNTY COUNSEL'S OFFICE
400 COUNTY CENTER, 6TH FLOOR
REDWOOD CITY, CA 94063
MATTHEW J. SANDERS
DEPUTY COUNTY COUNSEL
SAN MATEO COUNTY COUNSELâ€TMS OFFICE
400 COUNTY CENTER, 6TH FL
REDWOOD CITY, CA 94063
ANDREW J. GRAF
ASSOCIATE ATTORNEY
ADAMS BROADWELL JOSEPH & CARDOZO
601 GATEWAY BOULEVARD, SUITE 1000
SOUTH SAN FRANCISCO, CA 94080
MILES MAURINO
ASSOCIATE ATTORNEY
ADAMS BROADWELL JOSEPH & CARDOZO
601 GATEWAY BLVD., STE. 1000
SOUTH SAN FRANCISCO, CA 94080
LAURA GENAO
MANAGING DIR. - REG. AFFAIRS
SOUTHERN CALIFORNIA EDISON COMPANY
601 VAN NESS AVE., STE. 2030
SAN FRANCISCO, CA 94102
ADENIKE ADEYEYE
CALIF PUBLIC UTILITIES COMMISSION
COMMISSIONER GUZMAN ACEVES
ROOM 5214
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
ANKIT JAIN
CALIF PUBLIC UTILITIES COMMISSION
DEMAND RESPONSE, CUSTOMER GENERATION, AN
AREA
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
CHRISTOPHER HOGAN
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
AREA
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
EUGENE CADENASSO
CALIF PUBLIC UTILITIES COMMISSION
MARKET STRUCTURE, COSTS AND NATURAL GAS
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
HILARY STAVER
MGR - REG. & LEGISLATIVE AFFAIRS
SILICON VALLEY CLEAN ENERGY
333 W. EL CAMINO REAL, STE. 290
SUNNYVALE, CA 94087
THERESA CEO
DEPUTY CITY ATTORNEY
CITY AND COUNTY OF SAN FRANCISCO
OFFICE OF THE CITY ATTORNEY, CITY HALL
1 CARLTON GOODLETT PLACE, ROOM 234
SAN FRANCISCO, CA 94102
ANAND DURVASULA
CALIF PUBLIC UTILITIES COMMISSION
COMMISSIONER RANDOLPH
ROOM 5130
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
BRUCE KANESHIRO
CALIF PUBLIC UTILITIES COMMISSION
DEMAND RESPONSE, CUSTOMER GENERATION, AN
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
ERIC DURAN
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
ROOM 4011
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
July 16, 2020 Item #3 Page 14 of 26
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CPUC - Service Lists - R1807005 Page 7 of 10
JENNEILLE HSU
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
AREA
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
LEE-WHEI TAN
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
ROOM 4102
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
MARIA SOTERO
CALIF PUBLIC UTILITIES COMMISSION
COMMISSIONER GUZMAN ACEVES
AREA
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
MONICA PALMEIRA
CALIF PUBLIC UTILITIES COMMISSION
NEWS AND OUTREACH OFFICE
ROOM 3-90
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
NICOLE CROPPER
CALIF PUBLIC UTILITIES COMMISSION
COMMISSIONER RECHTSCHAFFEN
ROOM 5201
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
RYAN SARAIE
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
AREA
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
WHITNEY RICHARDSON
CALIF PUBLIC UTILITIES COMMISSION
DEMAND RESPONSE, CUSTOMER GENERATION, AN
AREA 4-A
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
YULIYA SHMIDT
CALIF PUBLIC UTILITIES COMMISSION
COMMISSIONER RECHTSCHAFFEN
ROOM 4209
JUSTIN H. FONG
CALIF PUBLIC UTILITIES COMMISSION
COMMISSIONER GUZMAN ACEVES
ROOM 5303
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
LOUIS M. IRWIN
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
ROOM 4209
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
MEA HALPERIN
CALIF PUBLIC UTILITIES COMMISSION
UTILITY & PAYPHONE ENFORCEMENT BRANCH
AREA
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
NATHAN CHRISTO
CALIF PUBLIC UTILITIES COMMISSION
UTILITY & PAYPHONE ENFORCEMENT BRANCH
AREA 2-E
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
RAVINDER MANGAT
CALIF PUBLIC UTILITIES COMMISSION
CONSUMER AFFAIRS BRANCH
AREA
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
SOPHIE BABKA
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
AREA
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
XIAN "CINDY" LI
CALIF PUBLIC UTILITIES COMMISSION
ELECTRICITY PRICING AND CUSTOMER PROGRAM
ROOM 4104
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
JENNIFER CAPITOLO
EXE DIR
CALIFORNIA WATER ASSOCIATION
601 VAN NESS AVENUE, STE. 2047
July 16, 2020 Item #3 Page 15 of 26
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CPUC - Service Lists - R1807005 Page 8 of 10
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3214
HAYLEY GOODSON
STAFF ATTORNEY
THE UTILITY REFORM NETWORK
•785 MARKET ST., STE. 1400
SAN FRANCISCO, CA 94103
CHRIS MCROBERTS
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, MC B23A
SAN FRANCISCO, CA 94105
MINCI HAN
MGR - REG. PROCEEDINGS
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE ST., MC BlOA
SAN FRANCISO, CA 94105
SAN FRANCISCO, CA 94102-6316
MARIA STAMAS
NATURAL RESOURCES DEFENSE COUNCIL
111 SUTTER STREET, 21ST FL.
SAN FRANCISCO, CA 94104
DARREN ROACH
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE ST.
SAN FRANCISCO, CA 94105
STACY W. WALTER, ESQ.
ATTORNEY
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, B30A
SAN FRANCISCO, CA 94105
IMEGHAN DEWEY
PACIFIC GAS AND ELECTRIC
245 MARKET STREET
SAN FRANCISCO, CA 94109
DEMETRIO A. MARQUEZ
PARALEGAL IV
CALIFORNIA AMERICAN WATER COMPANY
555 MONTGOMERY STREET, SUITE 816
SAN FRANCISCO, CA 94111
DAVID SIDDIQUI
SR. MGR, REG AFFAIRS
ORACLE - UTILITIES GLOBAL BUSINESS UNIT
475 SANSOME ST, 15TH FL
SAN FRANCISCO, CA 94111
LORI A. DOLQUEIST
NOSSAMAN LLP
50 CALIFORNIA STREET, 34TH FLR.
SAN FRANCISCO, CA 94111
MARTIN A. MATTES
ATTORNEY
NOSSAMAN LLP
50 CALIFORNIA STREET, 34TH FL.
SAN FRANCISCO, CA 94111
SARA STECK MYERS
ATTORNEY AT LAW
LAW OFFICES OF SARA STECK MYERS
122 - 28TH AVENUE
SAN FRANCISCO, CA 94121
MARI R. L. DAVIDSON, ESQ.
ATTORNEY
NOSSAMAN LLP
50 CALIFORNIA STREET, 34TH FL.
SAN FRANCISCO, CA 94111-4799
MEGAN M. MYERS
COUNSEL
LAW OFFICES OF MEGAN M. MYERS
110 OXFORD STREET
SAN FRANCISCO, CA 94134
CASE COORDINATION
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 770000; MC B23A
SAN FRANCISCO, CA 94177
ERIK JACOBSON
DIR - REGULATORY RELATIONS
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE ST., MD B23A / PO BOX 770000
SAN FRANCISCO, CA 94177
FOR: PACIFIC GAS & ELECTRIC COMPANY
AFP TRACKS AGGREGATE FILING
AGGREGATE FILINGS AFP TRACKS
July 16, 2020 Item #3 Page 16 of 26
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CPUC - Service Lists - R1807005 Page 9 of 10
950 TOWER LN, SUITE 2100
FOSTER CITY, CA 94404
CHRIS KING
CHIEF POLICY OFFICER
SIEMENS
4000 E. THIRD AVE.
FOSTER CITY, CA 94404
STEPHEN CAMPBELL
PROJECT MGR.
GRID ALTERNATIVES
1171 OCEAN AVE., SUITE 200
OAKLAND, CA 94608
ADRIAN SLIPSKI
LEGAL FELLOW
CENTER FOR ACCESSIBLE TECHNOLOGY
3075 ADELINE STREET, SUITE 220
BERKELEY, CA 94703
NATHANIEL MALCOLM
POLICY COUNSEL
MARIN CLEAN ENERGY
1125 TAMALPAIS AVENUE
SAN RAFAEL, CA 94901
JOHN GAINES
SONOMA COUNTY WORKERS BENEFITS
64 CHARLES ST.
COTATI, CA 94931
FOR: SONOMA COUNTY WORKERS BENEFIT
COUNCIL
RORY RAFFETY
PACIFIC GAS AND ELECTRIC COMPANY
3136 BOEING WAY
STOCKTON, CA 95206
MICHELLE VIGEN
SENIOR POLICY MGR.
CALIF. EFFICIENCY + DEMAND MGMT COUNCIL
1535 FARMERS LANE, SUITE 312
SANTA ROSA, CA 95405
REGULATORY CLERK
BRAUN BLAISING SMITH WYNNE, PC
915 L STREET, STE. 1480
SACRAMENTO, CA 95814
ANDREW B. BROWN
ATTORNEY AT LAW
950 TOWER LANE
FOSTER, CA 94404
EBCE REGULATORY
EAST BAY COMMUNITY ENERGY
1111 BROADWAY, 3RD FLOOR
OAKLAND, CA 94607
MELISSA BRANDT
SR. DIR & DEPUTY GEN COUNSEL
EAST BAY COMMUNITY ENERGY
1999 HARRISON ST., STE. 800
OAKLAND, CA 94612
REBECCA RUFF
CENTER FOR ACCESSIBLE TECHNOLOGY
3075 ADELINE STREET, SUITE 220
BERKELEY, CA 94703
STEPHANIE CHEN
SR. POLICY COUNSEL
MARIN CLEAN ENERGY
1125 TAMPALPAIS AVENUE
SAN RAFAEL, CA 94901
EDDIE GONZALES, JR.
PACIFIC GAS AND ELECTRIC COMPANY
3136 BOEING WAY
STOCKTON, CA 95206
TODD STREYLE
PACIFIC GAS AND ELECTRIC COMPANY
3136 BOEING WAY
STOCKTON, CA 95206
JULIA ENDE
CALIF PUBLIC UTILITIES COMMISSION
MARKET STRUCTURE, COSTS AND NATURAL GAS
300 Capitol Mall
Sacramento, CA 95814
SCOTT BLAISING
COUNSEL
BRAUN BLAISING SMITH WYNNE P.C.
915 L STREET, SUITE 1480
SACRAMENTO, CA 95814
JEDEDIAH J. GIBSON
ATTORNEY
July 16, 2020 Item #3 Page 17 of 26
httos://ia.cpuc.ca.gov/servicelists/R1807005 85721.htm 7/1/2020
CPUC - Service Lists - R1807005 Page 10 of 10
ELLISON SCHNEIDER HARRIS & DONLAN LLP
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816-5931
JOY MASTACHE
SR. ATTORNEY - OFF. OF GEN. COUNSEL
SACRAMENTO MUNICIPAL UTILITY DISTRICT
6201 S STREET, MS B406
SACRAMENTO, CA 95817
CARLA SCARSELLA
SR ATTORNEY - REGULATORY
PACIFICORP
825 NE MULTNOMAH ST, STE 2000
PORTLAND, OR 97232
ELLISON SCHNEIDER HARRIS & DONLAN LLP
2600 CAPITOL AVENUE, SUITE 400
SACRAMENTO, CA 95816-5931
LYNN WILEY
PROGRAM ANALYST
DEPT. OF COMMUNITY SERVICES & DEVELOP.
2389 GATEWAY OAKS DRIVE
SACRAMENTO, CA 95833
JAMES INGRAM
PACIFICORP
825 NE MULTNOMAH, SUITE 2000
PORTLAND, OR 97232
TOP OF PAGE
BACK TO INDEX OF SERVICE LISTS
July 16, 2020 Item #3 Page 18 of 26
https://ia.cpuc.ca.gov/servicelists/R1807005_85721.htm 7/1/2020
Lower bills. Livable planet.
July 6, 2020
Attachment C
Northern California
785 Market Street, Suite 1400
San Francisco, CA 94103
415 929-8876 • www.turn.org
Southern California
1620 Fifth Avenue, Suite 810
San Diego, CA 92101
619 398-3680 • www.turn.org
Alice Stebbins, Executive Director
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re: SDG&E Request for Extension to Implement Rules, Changes, and Customer Programs
Mandated in Decision (D.) 20-06-003, Adopting Rules and Policy Changes to Reduce
Residential Customer Disconnections for the Larger California-Jurisdictional Energy
Utilities
Dear Ms. Stebbins:
On July 1, 2020, San Diego Gas & Electric Company ("SDG&E") served a letter seeking to
defer implementation of rules, changes and customer programs mandated in D.20-06-003 from
April 16, 2021 to September 30, 2021. SDG&E claims that without this extension, its Customer
Information System ("CIS") upgrade, currently scheduled to be deployed in January 2021, would
not be implemented on schedule.
The Utility Reform Network ("TURN") urges the Commission to deny this request. First,
SDG&E should submit this request as a petition for modification, not as a request for extension.
Second, if the extension is to be considered, SDG&E must submit compelling evidence in
support of their request. Third, should this extension be granted, all rules, changes, and customer
programs mandated in decision D.20-06-003 that already exist in SDG&E's current CIS system
or that require minimal changes must be implemented without delay by April 16, 2021.
As part of its request for extension, SDG&E proposes to extend the current disconnection
moratorium for CARE/FERA customers until the requirements of D.20-06-003 are implemented.
Yet, SDG&E glaringly omits from its proposal a commitment to reduce its disconnection rate as
required by Senate Bill 598 and D.20-06-003. This omission is not surprising given that even in
the face of a statute requiring utilities to reduce disconnections, SDG&E repeatedly advocated
for the authority to increase its disconnection rate throughout the R.18-07-005 proceeding—
including in it comments on Commissioner Guzman Aceves's Proposed Decision of May 6,
2020) Granting SDG&E an extension to comply with D.20-06-003 would allow SDG&E to
disconnect as many customers as it desires from April 16, 2021 to September 30, 2021, since the
1 SDG&E Opening Comments on Proposed Decision, p. 11, fn 33.
July 16, 2020 Item #3 Page 19 of 26
1
temporary disconnection rate caps established by D.18-12-013 have expired.2 TURN urges the
Commission to keep this in mind as it evaluates SDG&E's request for extension.
The Commission should acknowledge the inappropriateness of SDG&E's attempt to seek this
kind of relief through a request for an "extension of time to comply" under Rule 16.6. That
administrative procedure is available where a utility needs more time to comply with a decision,
which is not the case here. Furthermore, substantive issues and crucial questions related to this
request should not be resolved through this procedure, such as the level of disconnection rate that
SDG&E shall maintain during the extension, or what protection mechanisms should be
implemented in the meantime. SDG&E's attempt demonstrates a lack of seriousness assigned to
the decision, customer protections, and the current COVID-19 pandemic. Instead, this request
should have been made via a petition for modification, which must provide clear and compelling
evidence to support SDG&E's request. Furthermore, SDG&E's proposal to extend the
disconnection moratorium to CARE/FERA customers through September 30, 2021 implicates
not only decision D.20-06-003, but also Resolution M-4842 (authorizing emergency customer
protections during the COVID-19 pandemic), such as SDG&E's ability to record costs to the
COVID-19 Pandemic Protections Memorandum Account beyond April 16, 2021.
There are simply too many important issues and facts at play for this request to be considered
through a letter. Should the Commission decide to consider the request without requiring a
petition for modification, it should at a minimum direct SDG&E to provide evidence to support
its claim that implementing the requirements of decision D.20-06-003 would cause a months-
long delay and increase the cost of the CIS system by $20 to $30 million. Granting this request
for extension would affect the lives of tens of thousands of Californians — the Commission
should, at the very least, order SDG&E to present compelling evidence to support its claim.
Lastly, SDG&E already has the capabilities to implement many of the protections required by
D.20-06-003 with minimal or no changes to the CIS. Yet, SDG&E fails to inform the
Commission of its ability to implement the vast majority of the protections ordered by D.20-06-
003, with a few exceptions such as the Arrearage Management Plan Program. This omission is
telling given that SDG&E seeks to delay all consumer protections, even those that can be easily
implemented. Should the Commission grant any extension, it should require at a minimum that
SDG&E implement the following requirements by April 16, 2021:
a. Reduce disconnections rate to 3%.
SB 598 required all the IOUs to reduce their disconnection rates. SDG&E
can easily control the number of disconnections in its systems, as it
currently does.
b. Prohibit disconnections during extreme weather conditions (above 100 degrees or
under 32 degrees Fahrenheit).
SDG&E already implemented this functionality previously.
c. Offer a 12-month payment plan to all customers at risk of disconnection.
SDG&E already offers payment plans of various lengths, and it simply
needs to stop offering the shorter-term payment plans.
2 Per D.18-12-013, these protections shall remain in effect until the issuance of a decision in Phase 1, which is D.20-
06-003.
July 16, 2020 Item #3 Page 20 of 26
2
d. Offer to enroll customers in all applicable benefit programs such as CARE,
FERA, or Medical Baseline.
This is an education, communication, and outreach effort, which is
unrelated to the CIS upgrade.
e. Eliminate all deposits.
SDG&E can disable this functionality or set the value to $0.
f. Eliminate reconnection fees.
SDG&E can disable this functionality or set the value to $0.
g. Benefit of service.
This is largely a manual process and not automated within the CIS system.
The new requirements are largely policy changes and not affected by the
system upgrade.
h. Nurse practitioners (in addition to physician assistants as required by SB 1338)
can certify customer eligibility for Medical Baseline.
Certification for Medical Baseline by nurse practitioners is not related to
the CIS system upgrade.
These requirements provide critical protections for Californians and require minimal or no
upgrades to the CIS system. Thus, SDG&E should be required to implement them on time.
For the reasons outlined above, TURN urges the Commission to deny SDG&E's request at this
time and order SDG&E to make a more complete presentation on the merits and implications of
their request via a petition for modification to the Commission. Should the Commission see fit
to accept SDG&E's request for extension, the Commission should at a minimum order SDG&E
to implement the protections discussed above that require minimal or no upgrade to the CIS
system.
Thank you for your attention to these matters. If you have any questions or wish to discuss this
further, please do not hesitate to contact me.
Yours truly,
/S/
David Cheng
Staff Attorney
Cc: Edward Randolph, Energy Division Director
Administrative Law Judge Gerald F. Kelly
CPUC Administrative Law Judge Division
All Parties of Record for R.18-07-005
July 16, 2020 Item #3 Page 21 of 26
3
Attachment D
UCAN
UTILITY CONSUMERS' ACTION NETWORK
San Diego's Utility Watchdog
3405 Kenyon St. Suite 401, San Diego, CA 92110
(619) 696-6966 • www.UCAN.org
July 9, 2020
Alice Stebbins, Executive Director
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re: TURN's July 6, 2020 Letter About San Diego Gas & Electric's Request for Extension to
Implement Rules, Changes, and Customer Programs Mandated in Decision (D.) 20-06-
003, Adopting Rules and Policy Changes to Reduce Customer Disconnections for the
Large California-Jurisdictional Energy Utilities
Dear Ms. Stebbins:
On July 6, 2020 The Utility Reform Network ("TURN") submitted a letter to you in response to
San Diego Gas & Electric Company's ("SDG&E") request to defer its implementation of the
rules, changes, and customer programs that the Commission mandated in D.20-06-003.
According to SDG&E, if it is required to comply with the provisions with D.20-06-003 it will be
unable to complete its deployment of its Customer Information System ("CIS") upgrade that is
currently scheduled to be completed in January of 2021.
In its letter TURN urged the Commission to deny SDG&E's request on a number of grounds
including the procedural impropriety of seeking this type of relief via a letter instead of using a
petition for modification as is provided for in Rule 16.4 of the Rules of Practice and Procedure of
the California Public Utilities Commission; the lack of evidentiary support for SDG&E's
request; TURN also contends that if SDG&E's extension is granted that SDG&E should be
required to complete its revision of its CIS (consistent with D.20-06-030) by April 16, 2021.
TURN's letter also discusses how the Covid-19 pandemic and the temporary moratorium on
disconnections will affect customers in the coming months and TURN argues that SDG&E's
request to delay implementation of D.20-06-003 will affect a variety of other aspects of
SDG&E's interactions with its customers, complications that are too involved and far-reaching
to be properly dealt with by simply granting SDG&E the relief it is seeking.
The Utility Consumer's Action Network ("UCAN") has been an active participant in this
proceeding from the outset and is familiar with the issues outlined in TURN's July 6, 2020 letter.
UCAN agrees that it is inappropriate to grant the type of relief SDG&E is seeking via a letter to
July 16, 2020 Item #3 Page 22 of 26
the Commission's Executive Director. Moreover, UCAN notes that SDG&E has been aware of
the direction R.18-07-005 was taking well in advance of the date the Proposed Decision was
issued. UCAN is disappointed that SDG&E was not more pro-active in dealing with the
customer protections established in D.20-06-003 in its design of its CIS upgrade. Other
jurisdictional energy utilities in California (including SDG&E's corporate cousin Southern
California Gas Company) have not sought this type of delay. While UCAN is aware that the
additional requirements for establishing an Affearage Management Program for SDG&E's
customers adds a degree of complexity to SDG&E's upgrade of its Customer Information
System, SDG&E needs to integrate the provisions of D.20-06-030 into the information portal
that its residential customers will use beginning in January of 2021 to avoid customer confusion.
TURN's letter states that if the Commission decides to grant SDG&E's request for delay it
should impose some additional consumer-protection conditions on SDG&E by April 21, 2021.
Similar to SDG&E's initial request for delay, these additional conditions TURN has proposed
would represent a modification of D.20-06-030 that would be more properly addressed in a
petition for modification. SDG&E should not be able to use its long-planned CIS upgrade to
delay the implementation of long-awaited and much needed customer protections in SDG&E's
service territory.
The Commission should not grant SDG&E's request to delay implementation of D.20-06-030
absent a thorough consideration of whether SDG&E's request is merited, how a delay in
implementing the decision will likely have a deleterious effect on SDG&E's residential electric
and gas customers, and whether the Commission will have de facto condoned SDG&E's dilatory
approach towards complying with an important Commission decision by granting the delay it
seeks. In considering SDG&E's request and TURN's response, the Commission should be
mindful that D.20-06-030 extends much needed customer relief during a period of unprecedented
economic uncertainty and genuine consumer hardship. SDG&E's customers have the right to
expect their energy utility to afford them the same type of consumer protections (delineated in
D.20-06-030) that other California utilities will be providing to their customers as soon as
reasonably possible.
Sincerely yours,
Jason Zeller
Senior Attorney
UCAN
Cc: Edward Randolph, Energy Division Director
Administrative Law Judge Gerald F. Kelly
CPUC Administrative Law Division
All Parties of Record for R.18-07-005
July 16, 2020 Item #3 Page 23 of 26
Attachment E
ENERGY REGULATORY UPDATE
To: Barbara Boswell, CEO, Clean Energy Alliance
From: Ty Tosdal, Regulatory Counsel, Tosdal APC
Re: Energy Regulatory Update
Date: July 9, 2020
The energy regulatory update summarizes important decisions, orders, notices and
other developments that have occurred at the California Public Utilities Commission
("Commission") and that may affect Clean Energy Alliance ("CEA"). The summary presented
here describes high priority developments and is not an exhaustive list of the regulatory
proceedings that are currently being monitored or the subject of active engagement by CEA. In
addition to the proceedings discussed below, Tosdal APC monitors a number of other regulatory
proceedings as well as related activity by San Diego Gas & Electric ("SDG&E") and other
Investor-Owned Utilities ("IOUs").
1. Disconnections, Reconnections and Energy Access (R.18-07-005)
The Commission adopted a final decision, D. 20-06-003, on June 11, 2020, establishing
limits on customer disconnections and instructing SDG&E and other utilities to take steps to
implement customer payment plans. The main purpose of the decision is to protect vulnerable
customers from disconnection and preserve access to electricity. The implementation of the
measures announced in the decision may have an impact on CEA's revenue, as it is unclear
how SDG&E will allocate partial payments collected from CCA program customers.
The decision adopts the following specific measures:
• Cap on disconnections of 3% per IOU through 2024 (based on 2017 disconnection
rate), and 30% per zip code.
o No disconnections allowed for customers on low-income plan, has a child
under 12 months old, or anyone over age 65, or when it is over 100 or below
32 degrees using a 72-hour look ahead.
o Deposits and reconnection fees eliminated for all IOU customers.
• Customers will be offered a payment plan:
July 16, 2020 Item #3 Page 24 of 26
o Arrearage Management Program (AMP) — AMP will address bill forgiveness
after on-time payments.
o Percentage of Income Payment Plan (PIPP) — PIPP is a pilot program with a
working group to include CCAs to evaluate the feasibility of participation.
• A separate phase established in this proceeding will evaluate PIPP implementation.
• IOUs must enter into NDAs and MOUs with CCAs to promote data sharing.
• Decision will go into effect when Resolution M-4842 (COVID-19 Protections) expires
in March 2021.
Please note that SDG&E has requested a delay in implementing these measures on grounds
that it is in the process of upgrading its billing system. As of the date of this memo, the request
has not been addressed by the Commission.
2. SDG&E ERRA Forecast Proceeding (A. 20-04-014)
SDG&E's ERRA Forecast proceeding continues to unfold. This is an annual process
designed to reconcile revenues and costs previously approved in rates with forecasts that are
informed by actual revenues and costs. PCIA rates for the following year are also approved as
part of the ERRA Forecast proceeding.
The Commission recently issued a scoping memo identifying the issues for the
proceeding and setting a schedule. Important dates are as follows:
• July 17 — Intervenor Testimony
• August 25-27 — Evidentiary Hearings
• September 25 — Opening Briefs
• November 6 — SDG&E November Testimony Update
• November 18 — Comments on November Testimony Update
• December 2 — Proposed Decision
• December 8 — Comments on Proposed Decision
• December 17— Final Decision Anticipated
3. Power Charge Indifference Adjustment — (R.17-06-026)
A local nonprofit association, Protect Our Communities Foundation (POC), has filed a
Petition for Review in the California Court of Appeal, challenging Commission Decision (D.) 18-
10-019. The central argument advanced by POC is that Commission failed to properly interpret
July 16, 2020 Item #3 Page 25 of 26
Public Utilities Code section 366.2, which identifies eligible costs that may be recovered as part
of the PCIA, and related statutes, and as a result, incorrectly included Utility Owned Generation
(UOG) costs as part of the PCIA. SDG&E estimates that its UOG costs that can be recovered
through PCIA charges range between $100 million and $200 million per year for the next 16
years. The Commission and several utilities, including SDG&E, opposed the petition in the
Court of Appeal. The California Community Choice Association and San Diego Community
Power, as well as another nonprofit, filed amicus curiae briefs in support of POC's Petition.
4. Renewables Portfolio Standard (R. 18-07-003)
CEA filed its 2020 Renewables Portfolio Standard Plan on July 6, 2020, and the filing
has been acknowledged by the Commission. The RPS Plan will now be reviewed by the
Commission for compliance with SB 350 and other applicable statutes. A decision is anticipated
in the fourth quarter of 2020.
July 16, 2020 Item #3 Page 26 of 26