BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) )

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the matter of the Application of Southern California Edison Company (U338-E for Modification of Decision to Extend EDR-Retention Rates. Application of Pacific Gas and Electric Company (U 39E for Modification of Decision to Extend the Economic Development Rate Application (Filed October 13, 2009 (Amended February 3, 2010 Application (Filed November 13, 2009 (Amended January 27, 2010 REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E TO PROTESTS TO AMENDED APPLICATION JENNIFER TSAO SHIGEKAWA R. OLIVIA SAMAD Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( Dated: February 16,

2 REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E TO PROTESTS TO AMENDED APPLICATION TABLE OF CONTENTS Section Page I. INTRODUCTION...1 II. ISSUES TO BE ADDRESSED...2 A. SCE s EDR Program Produces Results...2 B. The EDR Application Process Addresses the Potential For Free Ridership EDR Incentives Can Be Effective Even For Customers With Low Electric Costs as a Percentage of Their Overall Operating Costs Other Safeguards Limit Ratepayer Exposure...8 C. Revising the Floor Price Calculation is Reasonable and Necessary...8 D. Urgency...10 E. Other Issues TAMCO s Eligibility for EDR is Not Relevant to the Assessment of SCE s EDR Application Shareholder Contribution is Inappropriate for EDRs...11 III. CONCLUSION i-

3 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the matter of the Application of Southern California Edison Company (U338-E for Modification of Decision to Extend EDR-Retention Rates. Application of Pacific Gas and Electric Company (U 39E for Modification of Decision to Extend the Economic Development Rate Application (Filed October 13, 2009 (Amended February 3, 2010 Application (Filed November 13, 2009 (Amended January 27, 2010 REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E TO PROTESTS TO AMENDED APPLICATION I. INTRODUCTION Pursuant to Rule 2.6 of the Rules of Practice and Procedure of the California Public Utilities Commission ( Commission and Administrative Law Judge ( ALJ Wilson s ruling at the January 29, 2010 prehearing conference ( PHC, Southern California Edison Company ( SCE submits this reply to protests filed on February 10, 2010 by the Division of Ratepayer Advocates ( DRA Protest and by The Utility Reform Network ( TURN Protest. SCE shares an interest in a fair and transparent process for assessing its EDR applicants and for its marginal distribution cost analysis. 1

4 II. ISSUES TO BE ADDRESSED A. SCE s EDR Program Produces Results Since the Commission approved SCE s last application for an Economic Development Rate ( EDR in Decision (D , SCE s EDR program has successfully retained a number customers in its service territory. The 19 currently active EDR-R contracts represent the retention of 4,004 direct jobs and 43.7 MW of load. 1 In addition, SCE has billed these customers $75.8 million under the EDR-R tariff, including approximately $12 million in contribution toward fixed costs that would otherwise have been borne by other customers. In D , the Commission found that SCE has established that its RIM test analysis provides a demonstration of ratepayer benefit. 2 Every three years, SCE evaluates its Economic Development Services (EDS program using the RIM test to verify a positive benefit cost ratio (BCR. The BCR was 1.13 in 2008 using 2007 factors and data. Thus, SCE s EDR contracts contribute to this overall result showing a clear benefit to ratepayers. In addition to the benefit of SCE s EDR program to ratepayers as described above, and to the regional economy, the success of SCE s EDR program is also reflected in the survival of the individual customers served under the EDR program. For example, in 2006, a struggling local plastics manufacturer was considering relocating out of state to reduce operating costs. Instead, the customer applied and qualified for the EDR-R rate. As a result of the reduced electric rates achieved under the EDR-R rate, this customer canceled its planned move out of state and continues to operate resulting in 662 saved direct jobs and 393 kwh of retained load. 1 On p. 3 of A , SCE stated that it served 15 customers with 22 service accounts on the EDR schedules, representing 47.5 MW, 385 GWh, and 4,525 direct jobs. Of these, all but one are served under the EDR-R tariff. See A , p. 10. Of the 22 service accounts cited, three are or will soon be off the rate because of falling below the 200kW threshold, filing bankruptcy or electing to participate in BIP. 2 D , p

5 None of the customers served under SCE s EDR program to date have gone out of business after signing up for and benefitting from the rate. One EDR customer, although still in business, has closed its service account associated with the EDR because it cannot meet the monthly minimum load requirement due to the economic downturn. Another EDR customer filed bankruptcy and did not assume the EDR contract in its reorganization. Participation in SCE s EDR program has prevented business failures, but cannot guarantee a customer s success, particularly in the current difficult economic environment. B. The EDR Application Process Addresses the Potential For Free Ridership In their protests, DRA and TURN express concern that the EDR application and screening process are insufficient to prevent free ridership. 3 DRA also questions the appropriateness of the independent reviewer, California Business Investment Services ( CalBIS. 4 Though the Commission found the procedure SCE follows in reviewing and approving EDR applications, including the independent review by CalBIS, 5 justified in D , SCE is amenable to enhancements in the process to address these concerns, welcomes constructive suggestions, and is willing to work with another reviewer if the Commission finds that it would be an improvement. In expressing its free ridership concerns, DRA acknowledges that it is likely impossible to guarantee no free riders while describing SCE s current EDR program as having a very low bar to entry. 6 In fact, SCE s application and screening procedure was designed to address the free ridership issue by establishing clear qualification criteria, implementing a review process to make certain that the customer-stated qualifications for discounted rates are clear and 3 DRA Protest, p. 3; TURN Protest, pp DRA Protest, p The Commission notes that [I]t is clear that CalBIS has the expertise and staff to identify and screen legitimate economic development candidates. See D , pp DRA Protest, p. 2. 3

6 convincing, and by making the customer liable for any misrepresentation made to receive discounted service. 7 Prior to considering any change to the current application process, however, it is necessary to understand the current process. EDR applicants must demonstrate in their business cases that but for the EDR, in combination with any other economic incentives, they would either relocate out of state or close operations (the but for test. The business cases must show in detail that the out-of-state alternative is more economically feasible (without the EDR and demonstrate that the EDR has a material impact on the financial condition of the customers which would afford them the opportunity to remain in California. The formal process begins when the customer provides SCE with a formal Letter of Intent (LOI that explains its circumstances and reasoning behind seeking the EDR. 8 Following submission of the LOI, the EDR-R applicant must then develop a business case containing the following: A detailed description of the options the customer is considering (e.g., relocation of all or a portion of the customer s operations including detailed facility plans, site information, contact information for third parties involved in the relocation process (e.g., realtors, relocation consultants, and an estimate of relocation costs (including capital costs for the new facility. In order to be eligible for the EDR-R, the alternative sites considered must be outside of California. A detailed comparison of the attributes of preferred alternative site to the existing location, including the cost and reliability of electricity, cost and availability of labor, material, real estate, insurance, proximity to target markets, supply chain logistics, transportation costs, and other costs of doing business. 7 A , p The formal process is typically preceded by an informal process that includes educating the customer on options to reduce its electricity costs through participation in Energy Efficiency and/or Demand Response programs, determining that the customer is on the most advantageous rate, and reviewing potential modification to the customer s process to reduce costs as appropriate. 4

7 A detailed financial analysis including the customer s electricity costs, total operating costs, a determination of the potential impact of the EDR-R savings, and a financial comparison of the alternatives being considered by the customer. SCE reviews the business case and supporting documentation to determine if the business case supports the customer s claim that but for the EDR-R incentive, the customer would relocate outside of California. In addition, SCE forwards the customer s business case and supporting materials to CalBIS to conduct its own independent review of the case. Applications are approved only if SCE and CalBIS agree that the customer has met the but for criteria. In addition, each customer is required to state in an affidavit, under penalty of perjury, that the customer's load would not have remained or would not have been created in California but for receipt of the discounted rate and that the load subject to the agreement is eligible load. The customer must also agree to maintain at least 200 kw of qualifying load and not less than 75% of its base period usage at the facility in question. If SCE finds a customer misrepresented its qualifications for the EDR, the customer's agreement is terminated and the customer is liable for liquidated damages. In its 2004 Economic Development Rate Application (A , SCE described the qualifying criteria for participation in the program, 9 and in approving A , the Commission found that proposed measures, including a mandatory affidavit, the imposition of liquidated damages for fraud, misrepresentation and early termination, and a third-party review by CalBIS will effectively curb the frequency of potential free-riders. 10 These measures continue to be important components of SCE s application and screening process. Instead of the low bar to entry alleged by DRA, the existing process serves as an effective deterrent to free ridership. Of the 190 Service Accounts for which customers submitted LOIs since 2006, only 22 have executed EDR contracts. Of the many applicants, there were 9 A , pp D , p. 28; Findings of Fact No. 6. 5

8 many SCE did not approve or recommend to CalBIS for various reasons, including that customers failed to answer SCE s questions in the review process to SCE s satisfaction. Though DRA and TURN did not raise concerns over free ridership in their protest of SCE s initial application 11 and are only now raising it in their protest to SCE s amended application, the concern over free ridership is not a new issue in EDR proceedings. In D , addressing concerns that even low levels of free ridership would adversely impact the benefit to ratepayers of economic development programs, the Commission found that for an economic development program not to benefit ratepayers instances of free ridership would have to be as high as 75%. 12 The Commission also found [t]he utilities past experience with the existing Schedule ED, in conjunction with the additional eligibility limitations proposed for the enhanced EDR, indicates that the actual level of free-ridership would be substantially below the 75% break even level. 13 Apart from their vague concerns over free ridership, DRA and TURN fail to point to any specifics from which to reasonably conclude either that a the threat of free ridership is greater, or b the mechanisms to deter free ridership are less effective than when the Commission issued D The Commission has already addressed free ridership. 1. EDR Incentives Can Be Effective Even For Customers With Low Electric Costs as a Percentage of Their Overall Operating Costs In its protest, DRA suggests changing the EDR criteria such that EDR customers must show that electricity makes up a threshold percentage of operating costs. 15 While this may appear to be a reasonable suggestion, it ignores many customer specific circumstances where an EDR incentive would provide the necessary but for benefits even for customers whose electricity costs are only a small fraction of their overall operating cost. To make an informed decision 11 TURN/DRA Joint Protest to A , filed November 16, D , p. 27; Findings of Fact No D , pp ; Findings of Fact No In such harsh economic times, the fact that SCE has not had a single EDR enrollee since 2006 shows that the existing screening process works and may in fact work too well. 15 DRA Protest, p. 3. 6

9 regarding the potential impact on a customer s decision to relocate, SCE considers a number of other factors including the customer s net margin, the nature of the other operating costs, revenues, and other economic incentives provided by local and state programs. For a customer struggling to remain in business in California with a near zero net margin, even a 25% reduction in electricity costs comprising 5% of the customers overall operating costs could prove to be a meaningful incentive. SCE s current application and screening process takes these factors into consideration in validating the customer s but for claim and, in practice, a low electricity cost can undermine that claim. In one instance, an EDR-A applicant was considering locating a facility in California near a major buyer of its products. SCE s review of this customer s business case found that its electricity costs were less than 2% of its total costs of goods sold and the impact of the potential EDR incentive was minimal within the overall context of its location decision. As a result of this detailed review, the customer s application was denied. In other circumstances, however, SCE and CalBIS have agreed that the EDR incentives in specific circumstances can be significant even when electricity comprised as little as 3.5% of a company s overall operating costs. For one EDR-R customer, the EDR savings, combined with savings achieved through energy efficiency and demand response programs, were enough to retain the customer in California. This customer reported that electricity comprised only 3.5% of its overall operating costs, demonstrating that the EDR-R program can positively impact the relocation decision of customers whose electricity costs are a relatively low fraction of their overall operating cost. Simply establishing a one-size-fits-all criterion ignores the specific circumstances driving each customer s decision making process and would reduce the effectiveness of the program. SCE already does a case by case analysis and is not looking to create shortcuts. If DRA is interested in making sure that the smallest discounts are used to the greatest effect, establishing a minimum threshold is incongruous with this goal. Establishing a threshold percentage would preclude customers with smaller absolute EDR discounts (due to their relatively lower electricity costs as a percentage of operating costs from being retained. 7

10 2. Other Safeguards Limit Ratepayer Exposure While the existing process addresses free-ridership issues, the program participation cap acts as a backstop against negative ratepayer impacts of free-ridership. In SCE s Response to Inquiries, 16 SCE provided an estimate of the 5-year total value of EDR discounts as being roughly $28 million. This estimate assumed that SCE successfully enrolled the full 250 MW onto the EDR program as requested in its amended application. Multiplying SCE s 2010 annual revenue requirement of roughly $11 billion by the 5-year proposed EDR period, the total maximum EDR discounts as a percentage of SCE s revenue requirement is only 5/100ths of one percent. Even if some small percentage of free riders made it through the enrollment process, the program participation limits would make any adverse customer rate impacts negligible. 17 DRA also suggests limiting the length of the discount from 5 years to 3 years as one way to limit risk to ratepayers. 18 The original intent of providing an EDR discount for five years was to allow the customer sufficient time to improve its business operations. Under the existing structure, the EDR discount declines, and is reduced to a maximum of 10% and 5% in years 4 and 5, respectively. The net effect limits ratepayer exposure as economic conditions improve either generally or for any specific customer. C. Revising the Floor Price Calculation is Reasonable and Necessary As DRA correctly points out that in D , the Commission authorized the use of customer specific marginal costs for use in determining floor prices, including the marginal cost of distribution. 19 In the last few years, SCE has been using rate group average unit marginal costs multiplied by the customer specific billing determinants to arrive at these customer specific 16 SCE filed its response on January 27, 2010, in response to the ALJ Ruling requesting information on the program cap. 17 The net overall ratepayer impact of EDR program are to lower rates as fixed costs are recovered from a larger sales base. 18 DRA Protest, p DRA Protest, p. 4. 8

11 floor bills. Determining the floor bills in this manner does provide a measure of customer specificity but is imprecise in that the average unit marginal costs are just that, averages. SCE agrees with DRA that the marginal distribution costs should not be simply eliminated from the contract floor price. Rather, SCE has proposed a specific methodology that identifies the circuit serving the prospective EDR customer and the forecasted investment on the circuit over a relevant period as a means of more precisely determining whether the customer-specific marginal distribution cost is zero. If the planned investment is zero, the marginal cost over the specified period is also zero and is thus excluded from the floor price calculation. If there is planned investment on the circuit the marginal cost is not zero and the marginal distribution cost component must be included in the floor price calculation. In this way, SCE s proposal is more closely aligned with the original decision requiring the use of customer-specific marginal costs. TURN also expresses its concern over SCE s proposal to use customer-specific marginal costs for determining floor prices, charging that SCE s proposal appears to be something the utility is creating out of whole cloth solely for purposes of this tariff. 20 In fact, SCE is proposing to leverage the results of the existing Distribution Substation Program in order to determine if the EDR applicant is served by a circuit that will require upgrades during the latest planning cycle. If the applicant is not served by one of these circuits, there is no near-term marginal distribution cost associated with retaining that customer and SCE s proposal to set the marginal distribution cost component of the floor price to zero for that applicant is justified. In opposing SCE s proposal, TURN argues that the current process is relatively straightforward and non-controversial; the numbers are in a public document that is the product of a public process, 21 seemingly without realizing that the Distribution Substation Program is described in detail in Phase 1 of SCE s general rate case with the distribution substations and circuits to be upgraded clearly identified TURN Protest, p TURN Protest, p For example, see SCE-03, Vol. 3, Pt. 2, in A , pp

12 Excluding the marginal distribution cost, where appropriate, from the calculation of the floor price is essential to creating a ratepayer benefit. The current process has effectively frozen program enrollment. It is why SCE has only enrolled 47 MW of the available 100 MW onto the EDR program and has had no new customers since That was when the marginal cost floors were raised to reflect a Hurricane Katrina-induced $8.81/MM-Btu gas price. 23 The reduction in headroom meant EDR discounts were and remain at a level too low for most customers to pass the but for test. Failure to change the floor price calculation would mean SCE would likely be unable to enroll new customers onto the EDR. If the Commission approved a new cap but no change to the floor price calculation process were made, SCE would have 47 MW enrolled with a 250 MW cap instead of a 100 MW cap. Retaining the current process for floor price calculation guarantees that ratepayers will see no incremental benefit from EDRs. D. Urgency TURN asserts that the extension granted by the Commission s Executive Director has eliminated the need for expedited review. 24 This is not true for two reasons. First, SCE has not been able to sign up a new customer on the EDR tariff since 2006, as described in Section C above. Instead of charging EDR-R customers their actual customer-specific floor price, SCE charges them the average marginal distribution cost and thereby reduces their already limited discounts. Only the largest customers, whose electricity cost is a large percentage of their operating costs could be eligible under these circumstances. One such customer, TAMCO, who could utilize the rate (assuming its business case is as it suggests cannot be placed on the EDR- R because its large load cannot be accommodated within the current 100 MW cap. Therefore, SCE urges the Commission to continue at the pace it has set and resolve the issues SCE raises in its Amended Application as soon as is possible. 23 The 2009 GRC Phase 2 settlement used a gas price of $7/MM-Btu which still reflects speculative levels compared to the existing market prices of roughly $5/MM-Btu. 24 TURN Protest, p

13 E. Other Issues 1. TAMCO s Eligibility for EDR is Not Relevant to the Assessment of SCE s EDR Application TAMCO s eligibility for SCE s EDR tariff is not within the scope of this proceeding, is premature and not appropriately addressed in this forum. 25 To analyze TAMCO s eligibility, SCE will use whatever process the Commission approves in this proceeding. Whichever group the Commission deems appropriate as a third party reviewer CalBIS or some other party to be determined will be the party with whom SCE will work. SCE cannot place TAMCO on the EDR-R tariff until and unless the Commission grants SCE relief from the 100 MW cap. Therefore, it is premature for SCE to judge TAMCO s eligibility. It is certainly premature for TURN to do so. It is not, as TURN says, that the Commission lacks sufficient record evidence to meaningfully assess TAMCO s eligibility, 26 it is that it is not the role the Commission has assigned for itself, nor is it one it should take on. 2. Shareholder Contribution is Inappropriate for EDRs Shareholder contribution is an issue that has been raised and decided numerous times, most recently in D Moreover, as Pub. Util. Code reads It is the intent of the Legislature that the Public Utilities Commission, in implementing this chapter, shall allow rate recovery of expenses and rate discounts supporting economic development programs within the geographic area served by any public utility to the extent the utility incurring or proposing to incur those expenses and rate discounts demonstrates that the ratepayers of the public utility will derive a benefit from those programs. 25 TURN Protest, p TURN Protest, p D , p. 27; Findings of Fact No

14 The Commission concluded that EDRs are in accord with the legislative precept to encourage economic development. 28 In reviewing the entirety of the joint EDR application, including zero shareholder contribution, 29 the Commission concluded that economic development rate reductions and procedures were justified. 30 SCE s EDR program provides rate payer benefits. There is no statutory requirement requiring shareholder contribution and SCE has no financial incentive to provide such contributions. The existing balancing account mechanisms protect SCE from financial harm due to reductions in sales. Thus, SCE s only motivation in offering this program is the overall reduction in customer rate levels that result from the EDR program. Should all of the customers at risk in fact close or relocate outside of California, neither SCE nor its shareholders are directly at risk, but our ratepayers are at risk for the full amount of the lost contributions to fixed cost recovery. 28 D , p. 28; Conclusions of Law No D , p D , p. 28; Conclusions of Law No

15 III. CONCLUSION SCE appreciates the cooperation of all parties in agreeing to an expedited schedule at the January 29, 2010 PHC and their continued engagement in these proceedings. SCE will continue to do what it can to address the questions parties have regarding its application through this reply and the discovery process. 31 With continued cooperation, SCE hopes that a settlement is possible and that hearings will not be necessary. Respectfully submitted, JENNIFER TSAO SHIGEKAWA R. OLIVIA SAMAD /s/ R. Olivia Samad By: R. Olivia Samad Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( olivia.samad@sce.com February 16, SCE has received and has responded, or is responding, to data requests from DRA, Energy Users Forum and TURN. 13

16 CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commissioner s Rules of Practice and Procedure, I have this day served a true copy of REPLY OF SOUTHERN CALIFORNIA EDISON COMPANY (U338-E TO PROTESTS TO AMENDED APPLICATION on all parties identified in the attached service list(s. Transmitting the copies via to all parties who have provided an address. First class mail will be used if electronic service cannot be effectuated. Executed this 16th day of February 2010, at Rosemead, California. /s/ Melissa Schary Melissa Schary Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Ave. Post Office Box 800 Rosemead, California

17 CPUC - Service Lists - A Page 1 of 2 2/16/2010 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - FOR MODIFIC FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: FEBRUARY 11, 2010 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties A. BRAD WILKINS R. OLIVIA SAMAD TAMCO SOUTHERN CALIFORNIA EDISON COMPANY PO BOX 325 PO BOX B ARROW RTE WALNUT GROVE AVENUE RANCHO CUCAMONGA, CA ROSEMEAD, CA FOR: TAMCO FOR: SOUTHERN CALIFORNIA EDISON COMPANY F. JACKSON STODDARD ROBERT FINKELSTEIN CALIF PUBLIC UTILITIES COMMISSION THE UTILITY REFORM NETWORK (TURN EXECUTIVE DIVISION 115 SANSOME STREET, SUITE 900 ROOM 5125 SAN FRANCISCO, CA VAN NESS AVENUE FOR: THE UTILITY REFORM NETWORK (TURN SAN FRANCISCO, CA FOR: DRA SHIRLEY A. WOO SAMUEL KANG ATTORNEY THE GREENLINING INSTITUTE PACIFIC GAS AND ELECTRIC COMPANY 1918 UNIVERSITY AVENUE, 2ND FLOOR 77 BEALE STREET / PO BOX 7442 BERKELEY, CA SAN FRANCISCO, CA FOR: THE GREENLINING INSTITUTE FOR: PACIFIC GAS AND ELECTRIC COMPANY CAROLYN KEHREIN ENERGY MANAGEMENT SERVICES 2602 CELEBRATION WAY WOODLAND, CA FOR: ENERGY USERS FORUM Information Only

18 CPUC - Service Lists - A Page 2 of 2 2/16/2010 KEVIN SIMONSEN CASE ADMINISTRATION ENERGY MANAGEMENT SERVICES SOUTHERN CALIFORNIA GAS COMPANY 646 E. 3RD AVENUE PO BOX 800 DURANGO, CO WALNUT GROVE AVENUE FOR: ENERGY USERS FORUM ROSEMEAD, CA ANTHEA LEE LISE H. JORDAN PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B9A, ROOM BEALE STREET, B30A SAN FRANCISCO, CA SAN FRANCISCO, CA STAN KATAOKA JOSE GUZMAN PACIFIC GAS AND ELECTRIC COMPANY NOSSAMAN LLP 245 MARKET STREET, MC N9P 50 CALIFORNIA STREET, 34TH FLOOR SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: JAZZ SEMICONDUCTOR CALIFORNIA ENERGY MARKETS CASE COORDINATION 425 DIVISADERO ST., SUITE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA PO BOX ; MC B9A SAN FRANCISCO, CA MRW & ASSOCIATES, LLC 1814 FRANKLIN STREET, SUITE 720 OAKLAND, CA State Service DEXTER E. KHOURY DONALD J. LAFRENZ CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY PRICING AND CUSTOMER PROGRAMS BRA ENERGY DIVISION ROOM 4209 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA LAURA A. MARTIN SEAN WILSON CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY DIVISION DIVISION OF ADMINISTRATIVE LAW JUDGES AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS