PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
I.D.# 8212
ENERGY DIVISION RESOLUTION E-4220
January 29, 2009
Resolution E-4220. Pacific Gas & Electric (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric (SDG&E) are authorized to modify the trigger condition for the Base Interruptible Program (BIP).
By Advice Letter (AL) 3360-E filed on November 12, 2008 by PG&E, AL 2288-E filed on November 12, 2008 by SCE, and AL 2040-E filed on November 12, 2008 by SDG&E.
__________________________________________________________
SUMMARY
This Resolution approves PG&E's, SCE's, and SDG&E's proposal to modify the BIP by adding a new trigger condition for the program: a Warning notice issued by the California Independent System Operator (CAISO) along with a determination by the CAISO that a Stage 1 emergency is imminent consistent with its operating procedure E-508B. Other triggers for the program will remain in effect, and no changes will be made to program incentives.
A one-time thirty day adjustment period is also authorized to give BIP participants the opportunity to adjust their Firm Service Level (FSL) or to opt-out of the program after they have been informed of the additional trigger condition.
The trigger condition change adopted here is an interim solution to a long-standing debate on how to best align emergency-triggered programs with CAISO operational practices. Further refinements to emergency-triggered programs are expected to occur in Phase 3 Order Instituting Rulemaking (OIR)1.
This resolution does not require a mandatory test event for BIP, but instead directs SCE to modify its BIP tariff to include an option to call a test event, consistent with PG&E's and SDG&E's BIP tariffs.
This Resolution also directs PG&E, SCE and SDG&E to make efforts to retain BIP participants in demand response programs, not just the BIP.
BACKGROUND
BIP is a demand response program that provides load reductions during emergency situations
The BIP is an emergency-triggered demand response program that the CAISO can dispatch for system emergencies, and the utilities (PG&E, SCE, and SDG&E) can dispatch for local emergencies to provide load relief. Customers enrolled in BIP receive incentive payments in exchange for committing to reduce their electrical usage to a contractually-established amount of kW, also called their Firm Service Level (FSL). Participants who fail to reduce their load to their FSL are subject to a financial penalty assessed on a kW per hour basis. Participants in the BIP program statewide are able to provide approximately 880 MWs of load drop in the event the program is triggered.
Currently, the BIP is triggered when the CAISO declares a Stage 2 Emergency (when operating reserves are less than 5 percent). CAISO has expressed opposition to current Commission policy that allows the utilities to count the BIP towards meeting their Resource Adequacy (RA) requirement on the grounds that BIP can only be called after an emergency has been declared, and thus do not contribute to the CAISO's operating reserve requirements. The utilities have asserted that BIP should continue to count for RA because it allows the utilities to avoid procuring additional generation capacity. Representatives of the large customers who participate in BIP have asserted that not counting BIP for RA will substantially reduce the incentives offered for the program, and thereby risk customer migration from the program and the loss of reliable MWs for emergencies. The issue of aligning emergency-triggered demand response programs (like BIP) with CAISO operational practices has been raised in the DR OIR Phase 3 Assigned Commissioner's Ruling dated July 18, 20082.
The Utilities Propose to Trigger the BIP Prior to a Stage 1 Emergency
The utilities, the CAISO, and the large customer representatives - the California Manufactures and Technology Association (CMTA) and the California Large Energy Consumers Association (CLECA) - met to discuss these issues and negotiate a revision to the BIP. The aforementioned parties reached an agreement to modify BIP by adding a new trigger condition: a Warning notice issued by the CAISO and when Stage 1 is imminent. Specifically the following steps would be followed for the new trigger:
· CAISO forecasts a Stage 1 emergency and issues a Warning.
· CAISO will then take all necessary steps to prevent the further degradation of its operating reserves as outlined in CAISO's emergency operating procedure E-508B.
· If CAISO still determines that a Stage 1 emergency is imminent, it may then dispatch the BIP resource.
To effectuate the new trigger conditions as outlined above, the utilities filed advice letters on November 12, 2008. The proposed changes in the tariff will effectively allow the CAISO to call BIP before a Stage 1 emergency once it has exhausted all other options to prevent further degradation of its operating reserves. The other triggering conditions for the BIP (local emergencies, Stage 2 alerts or test events) will remain. No change is proposed for the BIP incentive.
Upon approval of the BIP tariff modification, the utilities also proposed a one-time thirty day adjustment period to allow participants the opportunity to adjust their FSLs or to opt-out of the program. The utilities requested that this adjustment period (or opt-out window) commence 15 days after approval of the advice letter filings.
Upon the modification of BIP in accordance with the above proposal, CAISO has agreed to support the continued inclusion of BIP capacity as RA capacity. The aforementioned parties have also agreed to continue to engage in meaningful discussions to promote the voluntary transition of large customers to a forward-bid paradigm that incorporates an option for large customers to participate in a viable, price-responsive DR program during the 2010 to 2011 timeframe.
NOTICE
Notice of PG&E AL 3360-E, SCE AL 2288-E, and SDG&E AL 2040-E were made by publication in the Commission's Daily Calendar. PG&E, SCE and SDG&E state that a copy of its Advice Letter was mailed and distributed in accordance with Section 3.14 of General Order 96-B. The Utilities also notified the service lists of R.07-01-041 and A.08-06-001 et al. by email.
PROTESTS
Responses to PG&E's AL 3360-E and SCE's AL 2288-E were filed by EnerNOC, Inc (EnerNOC) on December 1, 2008. The CAISO filed comments on all three advice letters on December 2, 2008. Replies to EnerNOC's response were filed by PG&E on December 8, 2008 and by SCE on December 9, 2008.
DISCUSSION
The new BIP trigger will resolve CAISO's concern about counting BIP for RA purposes and should be approved.
CAISO and EnerNOC support the proposed BIP trigger condition as described above. The proposed BIP trigger will result in the CAISO counting BIP for RA purposes which is important because CAISO will then avoid procurement of redundant supply-side resources, at least for the time being. We appreciate the collaborative efforts among the parties and support the proposed additional BIP trigger condition. The new trigger is an interim solution, as the DR Phase 3 of the OIR3 will make final determinations regarding emergency-triggered demand response program policy and the ultimate design of these programs.
Requiring mandatory annual test events for BIP should be deferred to Phase 3 of R.07-01-041. SCE should however amend its BIP tariff so that it has the discretion to test its BIP program.
For both of PG&E's and SCE's BIP programs, EnerNOC encourages the Commission to require at least one test event per year because it will 1) increase the level of assurance that BIP resources are firm resources and should continue to qualify for RA purposes, 2) provide more information on how much actual load reduction is likely to be available in the event of a real emergency, and 3) ensure that only performing customers remain in the program.
SCE argues that EnerNOC's request for annual testing is unnecessary because the program's performance in the past has proven BIP to be a reliable resource. SCE claims that it has already determined the likely load impact from BIP based on the difference between each participant's average maximum demand and their respective FSL given the fact that a financial penalty is applied if a participant fails to reduce load to their FSL. Based on two events that had occurred in the past, SCE states that its participants' compliance rates were 98.5 percent for August 25, 2005 and 96 percent for July 24, 2006. In addition, SCE also tests the Remote Terminal Unit notification devices and phone system on a monthly basis and believes this is sufficient enough to remind customers of their responsibility to perform.
In its reply comments, PG&E argued that it has the option to call up to two test events per year and believes that it should retain the flexibility to avoid calling a test event when an actual event had been called for that year.
Through a data request, Energy Division found out that in the last five years, PG&E and SDG&E operated the BIP three times while SCE triggered the program twice4. EnerNOC's position implies that triggering BIP on an average of once every other year is not enough to determine the firmness of the resource for either RA or day-to-day operational purposes. EnerNOC also believes that mandatory test events will ferret out customers who do not perform.
The issue of mandatory test events for the BIP program is a technical question (how many data points are considered sufficient to determine the firmness of a resource for RA and/or day-to-day operational needs) as well as a policy question (eg. does the absence of mandatory test events in IOU-operated DR programs impact the integration of emergency-triggered demand response with the CAISO's Market Redesign and Technology Upgrade (MRTU)?). Phase 3 of the Demand Response OIR (R.07-01-041) is the appropriate forum to further evaluate and vet this issue as that proceeding is reviewing our policies with respect to emergency-triggered demand response programs, their potential alignment with the CAISO's wholesale markets, and their design. Furthermore the advice letter process is limited to just the utilities and parties who have filed comments on the advice letters, and we believe formal input from other stakeholders would be appropriate. For example more information is needed from the CAISO as to what it believes is necessary to evaluate the firmness of these programs and if mandatory test events have an impact on MRTU integration. Therefore at this time, we decline to adopt a mandatory test event for the BIP program as recommended by EnerNOC, but we will take up this issue in Phase 3 of R.07-01-041.
Currently both PG&E and SDG&E have the discretion to call test events for BIP. SCE's BIP tariff does not provide a test event option. While we decline to adopt a mandatory annual test event for BIP at this time, we believe that SCE should have at least the discretion to test the program just as PG&E and SDG&E does. We will direct SCE to modify its BIP tariff so that it has the discretion to test the program.
The 30 day adjustment period is sufficient time for BIP customers to adjust their FSL or to opt-out of the program.
EnerNOC requested the proposed one-time 30-day adjustment period be changed from 30 days to 60 days, because 30 days is not sufficient time for all customers to make an informed decision. In its reply comments, PG&E and SCE argue that a period of 30 days, starting 15 days after final approval of the advice letter, is sufficient and is the standard norm. PG&E and SCE claim that customers have been notified that the proposed new trigger for BIP was being considered. We approve the one-time adjustment period for BIP customers to adjust their FSLs or opt-out of the program and we agree with the utilities that 30 days is a sufficient amount of time for BIP customers to understand the new trigger and make decisions on their participation in the program.
The Utilities should use the 30 day adjustment period to inform their BIP participants of other DR options.
EnerNOC takes issue with PG&E's statement that it "will make a strong effort to retain all customers in the (BIP) program" when it contacts participants about the trigger modification. EnerNOC argues that during the BIP opt-out period, PG&E should be focused on retaining customers in DR programs, not just in BIP. EnerNOC believes PG&E should devote its sales and service representatives to be indifferent as to whether an existing BIP customer stays in BIP, or join other PG&E DR programs such as Peak Choice, AMP contract portfolios, and etc. In its reply comment, PG&E states that its primary goal is to retain existing customers in BIP and offer customers other DR options if customers feel BIP is not a viable option. We see the one-time adjustment period for BIP participants as an opportunity to inform these customers of other DR opportunities that may be better suited for them. While EnerNOC's recommendation was directed specifically at PG&E, we direct all three utilities to make a reasonable effort to educate current BIP participants of all DR opportunities during the 30 day adjustment period.
COMMENTS
Public Utilities Code section 311(g)(1) provides that this resolution must be served on all parties and subject to at least 30 days of public review and comment prior to a vote of the Commission. Section 311(g)(2) provides that this 30-day period may be reduced or waived upon the stipulation of all parties in the proceeding.
The 30-day comment period for the draft of this resolution was neither waived or reduced. Accordingly, this draft resolution was mailed to parties for comments, and will be placed on the Commission's agenda no earlier than 30 days from today.
FINDINGS
1. The BIP is an emergency-triggered demand response program that the CAISO can dispatch for system emergencies, and the utilities (PG&E, SCE, and SDG&E) can dispatch for local emergencies to provide load relief.
2. Customers enrolled in BIP receive incentive payments in exchange for committing to reduce their electrical usage to a contractually-established amount of kW, also called their Firm Service Level (FSL).
3. The utilities propose to modify BIP by adding a new trigger condition: a Warning notice issued by the CAISO and when Stage 1 is imminent.
4. If the new BIP trigger is approved, CAISO has agreed to support the continued inclusion of BIP capacity as RA capacity.
5. The parties who support the new BIP trigger have also agreed to continue to engage in meaningful discussions to promote the voluntary transition of large customers to a forward-bid paradigm that incorporates an option for large customers to participate in a viable, price-responsive DR program during the 2010 to 2011 timeframe.
6. The proposed BIP trigger should be approved as it will result in the CAISO counting BIP for RA purposes which is important because CAISO will then avoid procurement of redundant supply-side resources.
7. The issue of requiring mandatory annual test events for BIP should be deferred to Phase 3 of R.07-01-041.
8. Unlike PG&E and SDG&E, SCE does not have the discretion to call a BIP test event.
9. SCE should modify its BIP tariff so that it has the discretion to test the program.
10. A 30 day adjustment period is sufficient time for BIP customers to adjust their FSL or to opt-out of the program.
11. The utilities shall make a reasonable effort to educate current BIP participants of all DR opportunities during the 30 day adjustment period.
THEREFORE IT IS ORDERED THAT:
1. The requests of Pacific Gas & Electric, Southern California Edison, and San Diego Gas & Electric to add a new trigger condition for BIP as requested by Advice Letter 3360-E filed by PG&E, Advice Letter 2288-E filed by SCE, and Advice Letter 2040-E filed by SDG&E, are approved.
2. Southern California Edison shall modify its BIP tariff to include an option to call a test event at its discretion.
3. The utilities shall make a reasonable effort to educate current BIP participants of all DR opportunities during the 30 day adjustment period.
4. Southern California Edison shall file a supplemental advice letter in compliance with this resolution within 3 business days of the effective date of this resolution.
This Resolution is effective today.
I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on January 29, 2009; the following Commissioners voting favorably thereon:
_______________
Paul Clanon
Executive Director
STATE OF CALIFORNIA ARNOLD SCHWARZENEGGER, Governor
PUBLIC UTILITIES COMMISSION
505 VAN NESS AVENUE
SAN FRANCISCO, CA 94102-3298
I.D.# 8212
December 23, 2008 RESOLUTION E-4220
Commission Meeting Date: January 29, 2009
TO: PARTIES TO PG&E AL 3360-E; SCE AL 2288-E; SDG&E AL 2040-E; and SERVICE LISTS FOR R.07-01-041 and A.08-06-001 et al.
Enclosed is draft Resolution Number E-4220 of the Energy Division. It is in response to PG&E AL 3360-E, SCE AL 2288-E, and SDG&E AL 2040-E and it will appear on the agenda at the next Commission meeting held 37 days after the date of this letter. The Commission may vote on this Resolution at that time or it may postpone a vote until a later meeting. When the Commission votes on a draft Resolution, it may adopt all or part of it as written, amend, modify or set it aside and prepare a different Resolution. Only when the Commission acts does the Resolution become binding on the parties.
All comments on the draft Resolution are due by January 14, 2009. Comments shall be served on parties, as outlined below.
1) An original and two copies, along with a certificate of service to:
Honesto Gatchalian
Energy Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Email: JNJ@cpuc.ca.gov
2) Parties described above (attached).
3) Dorris Lam
Energy Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Email: DNL@cpuc.ca.gov
Comments shall be limited to five pages in length plus a subject index listing the recommended changes to the draft Resolution, a table of authorities and an appendix setting forth the proposed findings and ordering paragraphs.
Comments shall focus on factual, legal or technical errors in the proposed draft Resolution.
Replies to comments on the draft resolution may be filed (i.e., received by the Energy Division) on January 20, 2009, and shall be limited to identifying misrepresentations of law or fact contained in the comments of other parties. Replies shall not exceed five pages in length, and shall be filed and served as set forth above for comments.
Late submitted comments or replies will not be considered.
An accompanying declaration under penalty of perjury shall be submitted setting forth all the reasons for the late submission.
Please contact Dorris Lam at 415-703-5284 if you have questions or need assistance.
Sincerely,
Bruce Kaneshiro
Program Supervisor
Energy Division
Enclosure: Service List
Certificate of Service
CERTIFICATE OF SERVICE
I certify that I have by electronic mail this day served a true copy of Draft Resolution E-4220 on all parties on the service list for PG&E Advice Letter 3360-E; SCE Advice Letter 2288-E; SDG&E Advice Letter 2040-E; and Service List for R.07-01-041 and A.08-06-001 et al.; or their attorneys as shown on the attached list.
Dated December 23, 2008 at San Francisco, California.
____________________
Dorris Lam
NOTICE
Parties should notify the Energy Division, Public Utilities
Commission, 505 Van Ness Avenue, Room 4002
San Francisco, CA 94102, of any change of address to
insure that they continue to receive documents. You
must indicate the Resolution number on the service list
on which your name appears.
Parties to PG&E Advice Letter 3360-E, SCE Advice Letter 2288-E; and SDG&E Advice Letter 2040-E
| Pacific Gas and Electric Company Attn: Brian K. Cherry Vice President, Regulatory Relations 77 Beale Street, Mail Code B10C P.O. Box 770000 San Francisco, CA 94177 FAX: (415) 973-7226 Email: PGETariffs@pge.com |
EnerNOC, Inc. Attn: Richard H. Counihan Vice President Regulatory Affairs- Western Region 594 Howard Street, Suite 400 San Francisco, CA 94105 FAX: (415)227-1645 Email: rcounihan@enernoc.com |
| Southern California Edison Company Attn: Akbar Jazayeri Vice President of Regulatory Operations 2244 Walnut Grove Avenue Rosemead, CA 91770 FAX: (626) 302-4829 Email: AdviceTariffManager@sce.com |
EnerNOC, Inc. Attn: Sara Steck Myers Attorney at Law 122 - 28th Avenue San Francisco, CA 94121 FAX: (415)387-1904 Email: ssmyers@att.net |
| Southern California Edison Company Attn: Bruce Foster Senior Vice President, Regulatory Affairs c/o Karyn Gansecki 601 Van Ness Avenue, Suite 2040 San Francisco, CA 94102 FAX: (415) 673-1116 Email: Karyn.Gansecki@sce.com |
California Independent System Operator Corporation Attn: Baldassaro "Bill" Di Capo Counsel 151 Blue Ravine Road Folsom, California 95630 FAX: (916)608-7222 Email: bdicapo@caiso.com |
| San Diego Gas & Electric Company Attn: Todd Cahill Regulatory Tariff Manager 8330 Century Park Court, Room 32C San Diego, CA 92123-1548 FAX: (858)654-1788 Email: tcahill@semprautilities.com |
Parties to A. 08-06-001 et al
STEVEN D. |
PATRICK | |
DANIEL W. |
DOUGLASS | |
STACIE |
SCHAFFER | |
DONALD C. |
LIDDELL | |
DOUGLAS A. |
AMES | |
MARCEL |
HAWIGER | |
Lisa-Marie |
Salvacion | |
MARY A. |
GANDESBERY | |
EDWARD G. |
POOLE | |
BRIAN T. |
CRAGG | |
SALLE |
YOO | |
SARA STECK |
MYERS | |
WILLIAM H. |
BOOTH | |
BALDASSARO |
DI CAPO | |
CAROLYN |
KEHREIN | |
B.MARIE |
PIENIAZEK | |
DARA |
BILTEKOFF | |
DENISE |
SERIO | |
GLEN |
SMITH | |
PAUL |
TYNO | |
PAM |
MELTON | |
KEVIN J. |
SIMONSEN | |
GREGORY |
KLATT | |
CASE |
ADMINISTRATION | |
JANET |
COMBS | |
JENNIFER |
SHIGEKAWA | |
JOY C. |
YAMAGATA | |
LINDA |
WRAZEN | |
NANCY |
PRIVITT | |
JOEL M. |
HVIDSTEN | |
SHAWN |
COX | |
MONA |
TIERNEY-LLOYD | |
PAUL |
KERKORIAN | |
JACK |
ELLIS | |
PETER |
MALTBECK | |
THERESA |
BURKE | |
HELEN |
ARRICK | |
JOSEPHINE |
WU | |
RICHARD H. |
COUNIHAN | |
STEVE |
HAERTLE | |
STEVEN |
MOSS | |
VIDHYA |
PRABHAKARAN | |
JUDY |
PAU | |
SHIRLEY A. |
WOO | |
ERIC |
WOYCHIK | |
DOCKET |
COORDINATOR | |
RICH |
QUATTRINI | |
THOMAS S. |
KIMBALL | |
JOY A. |
WARREN | |
BARBARA R. |
BARKOVICH | |
GAYATRI |
SCHILBERG | |
JEFF |
NAHIGIAN | |
JOHN |
GOODIN | |
MELANIE |
GILLETTE | |
ROBERT |
EMMERT | |
JAMES R. |
METTLING | |
RONALD |
LIEBERT | |
BENJAMIN |
SCHUMAN | |
TYLER J. |
BERGAN | |
Bruce |
Kaneshiro | |
David |
Peck | |
Dorris |
Lam | |
Hazlyn |
Fortune | |
Jennifer |
Caron | |
Jessica T. |
Hecht | |
Sudheer |
Gokhale | |
Yuliya |
Shmidt | |
Parties to R.07-01-041
SCOTT H. |
DEBROFF | |
KEITH R. |
MCCREA | |
KEN |
SKINNER | |
STEVEN D. |
PATRICK | |
GREGORY |
KLATT | |
DANIEL W. |
DOUGLASS | |
JANET |
COMBS | |
DONALD C. |
LIDDELL | |
DOUGLAS A. |
AMES | |
JACK |
ELLIS | |
PETER |
MALTBAEK | |
MARCEL |
HAWIGER | |
MICHEL PETER |
FLORIO | |
Lisa-Marie |
Salvacion | |
NORA |
SHERIFF | |
CARMEN |
BASKETTE | |
SHIRLEY |
WOO | |
VIDHYA |
PRABHAKARAN | |
JEFFREY P. |
GRAY | |
IRENE K. |
MOOSEN | |
SARA STECK |
MYERS | |
LYNNE |
BROWN | |
WILLIAM H. |
BOOTH | |
LINDA Y. |
SHERIF | |
ERIC C. |
WOYCHIK | |
JAMES |
BOOTHE | |
RICH |
QUATTRINI | |
BOB |
HINES | |
BARBARA R. |
BARKOVICH | |
BALDASSARO |
DI CAPO, ESQ. | |
DI CAPO |
BALDASSARO | |
JAMES R. |
METTLING | |
KAREN N. |
MILLS | |
CLARK E. |
PIERCE | |
NICHOLAS J. |
PLANSON | |
GLEN E. |
SMITH | |
ALICIA R. |
PETERSEN | |
MONICA S. |
IINO | |
CLINTON |
COLE | |
GRAYSON |
HEFFNER | |
STEPHEN D. |
BAKER | |
TRENT A. |
CARLSON | |
DANIEL M. |
VIOLETTE | |
KEVIN |
COONEY | |
STUART |
SCHARE | |
LARRY B. |
BARRETT | |
WILLIAM D. |
ROSS | |
DAVID |
NEMTZOW | |
DAVID |
REED | |
JOYCE |
LEUNG | |
MARIAN |
BROWN | |
MARK S. |
MARTINEZ | |
ANDREA |
HORWATT | |
CARL |
SILSBEE | |
CASE |
ADMINISTRATION | |
JENNIFER |
SHIGEKAWA | |
KA-WING MAGGIE |
POON | |
LARRY R. |
COPE | |
RUSS |
GARWACRD | |
STACIE |
SCHAFFER | |
DON |
WOOD | |
CARLOS F. |
PENA | |
JOHN |
LAUN | |
DAVID |
BARKER | |
JOY |
YAMAGATA | |
KATHRYN |
SMITH | |
LINDA |
WRAZEN | |
CENTRAL FILES | ||
DAVE |
HANNA | |
GEOFF |
AYRES | |
WARREN |
MITCHELL | |
DAVID M. |
WYLIE, PE | |
JOEL M. |
HVIDSTEN | |
SHAWN |
COX | |
MONA |
TIERNEY-LLOYD | |
PAUL |
KERKORIAN | |
SUE |
MARA | |
CHRIS |
KING | |
PAUL |
KARR | |
SHARON |
TALBOTT | |
THERESA |
MUELLER | |
Massis |
Galestan | |
Thomas |
Roberts | |
CHARLES |
MIDDLEKAUFF | |
SANDRA |
ROVETTI | |
THERESA |
BURKE | |
DANIEL C. |
ENGEL | |
ELAINE S. |
KWEI | |
KAREN |
TERRANOVA | |
SNULLER |
PRICE | |
STEVE |
GEORGE | |
ASHLEE M. |
BONDS | |
BRUCE |
PERLSTEIN | |
EDWARD V. |
KURZ | |
KEN |
ABREN | |
STEVEN R. |
HAERTLE | |
STEVEN |
MOSS | |
EDWARD G. |
POOLE | |
AHMAD |
FARUQUI | |
BRAD |
MANUILOW | |
BRIAN T. |
CRAGG | |
J. JOSHUA |
DAVIDSON | |
ROBERT |
GEX | |
TYLER |
HUEBNER | |
SALLE E. |
YOO | |
MARY A. |
GANDESBERY | |
LAW DEPARTMENT |
FILE ROOM | |
JOSEPHINE |
WU | |
MARK |
HUFFMAN | |
HELEN |
ARRICK | |
SUSAN |
MCNEILL | |
ROBIN J. |
WALTHER, PH.D. | |
JENNIFER |
CHAMBERLIN | |
MICHAEL |
ROCHMAN | |
JOE |
PRIJYANONDA | |
SEAN P. |
BEATTY | |
PATRICIA R. |
THOMPSON | |
PATRICIA |
THOMPSON | |
PHILIPPE |
AUCLAIR | |
ALEX |
KANG | |
JODY S. |
LONDON | |
TED |
POPE | |
DOCKET |
COORDINATOR | |
REED V. |
SCHMIDT | |
STEVE |
KROMER | |
EDWARD |
VINE | |
GALEN |
BARBOSE | |
JAY |
LUBOFF | |
ALAN |
GARTNER | |
L. JAN |
REID | |
ALAN |
GARTNER | |
JEFF |
SHIELDS | |
JOY A. |
WARREN | |
ROGER |
VAN HOY | |
THOMAS S. |
KIMBALL | |
JAMES |
WEIL | |
CLARK |
BERNIER | |
GAYATRI |
SCHILBERG | |
JEFF |
NAHIGIAN | |
RICHARD |
MCCANN | |
DAVID |
MORSE | |
JOHN |
GOODIN | |
MELANIE |
GILLETTE | |
MARY |
LYNCH | |
ANDREW B. |
BROWN | |
DAVID |
HUNGERFORD | |
MARGARET |
SHERIDAN | |
RYAN |
BERNARDO | |
VIKKI |
WOOD | |
BARB |
BOICE | |
KAREN |
LINDH | |
ROGER |
LEVY | |
ANNIE |
STANGE | |
BENJAMIN |
SCHUMAN | |
LAURA |
ROOKE | |
JENNIFER |
HOLMES | |
TYLER |
BERGAN | |
DENISE |
SERIO | |
Aloke |
Gupta | |
Andrew |
Campbell | |
Bruce |
Kaneshiro | |
Christopher |
Clay | |
Christopher R |
Villarreal | |
Dorris |
Lam | |
Elizabeth |
Dorman | |
Hazlyn |
Fortune | |
Jason R. |
Salmi Klotz | |
Jennifer |
Caron | |
Jessica T. |
Hecht | |
Joe |
Como | |
Joy |
Morgenstern | |
Matthew |
Deal | |
Rebecca |
Tsai-Wei Lee | |
Sudheer |
Gokhale | |
Timothy J. |
Sullivan | |
Yuliya |
Shmidt | |
CLARE |
LAUFENBERG | |
1 R.07-01-041
2 http://docs.cpuc.ca.gov/efile/RULC/85507.pdf
3 R.07-01-041
4 Only one of the utility events noted here was a test event.
