VII. Assignment of Proceeding

Commissioner Michael R. Peevey is the Assigned Commissioner and Carol A. Brown is the Assigned Administrative Law Judge (ALJ) in this proceeding.

Findings of Fact

1. The purpose of this decision is to adopt a policy, on a limited and interim basis, to support new generation and long-term contracts for California which can ensure investment in construction in a timely fashion so new generation can begin to come on-line in 2009.

2. This decision must work in concert to coordinate and incorporate Commission and legislative efforts from other proceedings, and in particular R.05-12-013 that is addressing competitive market mechanisms in Phase II of that proceeding.

3. The State's energy policy uniformly points to the need for the State to invest in new generation in both northern and southern California in order to assure continued reliable service at reasonable cost.

4. We previously found in D.04-12-048 that PG&E had a need for 2,200 MW and SCE had a need for 1,500 MW.

5. We intend to examine in Phase II of this proceeding whether there is any additional system need for new capacity in the service territories of SCE, PG&E and SDG&E.

6. We find that long-term contracts are necessary to solicit investment in new generation in California.

7. We previously implemented RAR for each LSE requiring it to be responsible for acquiring its own reserves to meet its own RA obligation.

8. In D.04-12-048, we approved the IOUs' LTPPs and associated rate-making treatment, and authorized the IOUs to enter into short, medium, and long-term contracts.

9. In D.04-12-048, we allowed the IOUs to recover any stranded costs from all customers for a period of either the life of the contract, or 10 years, whichever is less.

10. Despite our removal of barriers to long-term contracting by approving the IOUs' LTPP and cost recovery, establishing RAR year-ahead obligations and allowing for stranded cost recovery, neither PG&E nor SCE have entered into any long-term contracts or built new generation themselves.

11. PG&E and SCE have indicated that they are reluctant to take procurement steps that would leave the cost-recovery for new generation with their respective bundled customers alone, and they have requested cost-recovery for above-market costs from all customers.

12. Since our decision in D.04-12-048 in December 2004 there has not been sufficient investment in new generation in California from non-utility sources.

13. We find that we need an additional transitional policy to encourage investment in new generation resources now while we continue to pursue competition and customer choice by establishing a functioning market based institution.

14. We find given the urgent need for new capacity and the lengthy lead-times required both for new construction and to develop and implement new market institutions, it is necessary and prudent for us to take proactive steps now to support investment in new generation.

15. The only complete solution for this transitional policy presented to the Commission was the Joint Parties' proposal which proposed making the IOUs the procurement entities for bundled and unbundled customers alike.

16. Many parties critiqued the JP, but only proffered the alternative solution of "staying the course" which translates into continuing with ongoing market reforms and hoping that new capacity will get built.

17. Other parties constructively analyzed the JP, including the Indicated Parties, and offered modifications that limited the procurement role of the IOUs.

18. We find that it is reasonable to adopt a cost allocation mechanism on a limited and transitional basis that will only apply until we decide upon, develop and put in place new market based institutions in Phase II of R.05-12-013.

19. The cost allocation mechanism, that is set forth with particulars herein, will allow the advantages and costs of new generation to be shared by all benefiting customers in an IOU's service territory. We designate the IOUs to procure this new generation and benefiting customers are to receive resource adequacy credits and only pay for the net cost of capacity, determined as a net of the total cost of the contract minus the energy revenues associated with dispatch of the contract.

20. As set forth with particularity herein, each IOU must conduct a periodic auction for the energy rights to all resources acquired under this interim proposal.

21. This mechanism disaggregates the energy and capacity components of the newly acquired generation, so that the only nonbypassable charge levied on the ESPs is for capacity, and the ESPs retain the ability to manage their energy purchases.

22. We are not adopting this mechanism enthusiastically, but because it is necessary to assure grid reliability for the state as a whole that we remove any risk or barrier, real or perceived, that impedes investment in new generation.

23. Nothing we do in this decision prohibits IOUs or ESPs from contracting with other new resources that come online without the aid of long-term contracts with the IOUs.

24. We do not find that it is necessary or helpful for the cost allocation mechanism we adopt herein to label the new resources as a "public good."

25. We will review in Phase II of this proceeding the need for new system resources in each IOU's territory, as well as to examine each IOU's bundled customer need.

26. We do not adopt an opt-out mechanism to this cost allocation methodology today, but defer further consideration to Phase II of R.05-12-013, so it can be considered in concert with capacity markets and multi-year RAR.

27. We find it is reasonable to use the need determination numbers from our last LTPP decision, D.04-12-048, and those numbers are further supported by the CEC's 2005 IEPR. Based on those findings, PG&E's need is 2,200 MW, SCE's need is 1,500 MW and SDG&E has no need for additional capacity from the need numbers we are using.

28. New need determination numbers will be established following the development of a record in Phase II of this proceeding.

29. PG&E has already brought the Commission over 2,200 MW of contracts in A.06-04-012, following the completion of its RFO for the need authorized in D.04-12-048. We will allow PG&E to apply the cost allocation methodology to contracts with qualifying new generation that is not utility owned.

30. PG&E can not apply the cost allocation methodology to CC8 or to its contracts with E&L Westcoast Colusa or with Wartsila Humboldt.

31. SCE has indicated a willingness to procure up to 1,500 MW of new long-term contracts and can launch a "fast track" RFO as early as February 2007. While we anticipate a decision in Phase II of this proceeding prior to the final contract selection in SCE's "fast track" RFO, we find it reasonable for SCE to procure up to 1,500 MW in its February 2007 RFO.

32. We find it reasonable for the IOUs, when they procure resources on behalf of all customers, to give high priority to resources that meet local RA obligations as established in R.05-12-013.

33. We find that AB Section 380, as codified in Pub. Util. Code § 380 clearly authorizes the Commission to adopt the cost allocation methodology set forth herein that supports new generating capacity and equitably allocates the costs.

34. We do not find it necessary or advisable at this time to limit this cost mechanism to non-affiliate transactions, as long as the contract evaluation and selection procedures are above reproach.

35. We find that it is consistent with existing statutes and Commission precedent that POU parties outside of the CAISO control area are not subject to the cost allocation methodology adopted herein.

36. We do not adopt CAC/EPUC's request to exempt cogeneration from departing load charges.

37. We find it is consistent with the OIR issued on February 14, 2006, initiating this proceeding and the ALJ ruling on March 29, 2006, that the record that supports this decision is fully developed without evidentiary hearings. A separate determination will be made in Phase II of this rulemaking whether evidentiary hearings are necessary for the development of the record in that phase.

Conclusions of Law

1. AB 380, as codified in Pub. Util. Code § 380 directs the Commission, in establishing resource adequacy requirements, to facilitate the development of new generating capacity and to equitably allocate the cost of generating capacity. It is consistent with AB 380 for the Commission to adopt the cost allocation methodology set forth herein.

2. AB 380, as codified in Pub. Util. Code § 380 also allows the costs an IOU incurs to sustain system reliability and local area reliability from all customers on whose behalf the costs are incurred. It is consistent with AB 380 for the Commission to adopt the cost allocation methodology set forth herein so that the IOUs' bundled customers are not alone responsible for the cost of new generation to retain system reliability.

3. We previously found in December 2004 in D.04-12-048 that SCE and PG&E had a combined need of 3,700 MW, and the state's energy policies point in the direction of increased need. However, since December 2004 neither PG&E nor SCE have entered into any long-term contracts.

4. We have found that long-term contracts are necessary to solicit investment in new generation in California, and both the ESPs and the IOUs are unwilling to sign long-term contracts. The ESPs' customers are on short time contracts and the ESPs cannot recruit new customers with the suspension of DA. The IOUs are concerned that without some cost allocation provision to assure that their bundled customers are not left paying for new generation in the face of departing load, that long-term contracts are too risky.

5. It is necessary for the Commission to take some proactive step now in order to assure continued reliable electricity service at a reasonable cost.

6. It is reasonable, and consistent with law, for the Commission to adopt this limited and transitional cost allocation mechanism to support the development of new generation by having the costs and benefits shared by all customers.

7. We designate the IOUs to procure new generation, and as set forth more fully herein, the energy and capacity from the new resources should be unbundled. All benefiting customers shall receive resource adequacy credits and only pay for the net cost of capacity, determined as a net of the total cost of the contract minus the energy revenues associated with dispatch of the contract.

8. Pursuant to the plan adopted herein, each IOU is to conduct a periodic auction for the energy rights to all resources acquired pursuant to this plan.

9. It is reasonable to defer many of the implementation details of this cost allocation mechanism to Phase II of this proceeding along with associated ratemaking issues.

10. It is consistent with our commitment to competition and customer choice to adopt this interim and transitional plan to assure investment in and construction of new generation capacity while we are deciding, developing and implementing a market based institutional infrastructure.

ORDER

IT IS ORDERED that:

1. The cost allocation plan set forth with specificity herein is adopted. The investor-owned utilities (IOU) are to procure new generation, and the energy and capacity from the new resources should be unbundled. All benefiting customers shall receive resource adequacy credits and only pay for the net cost of capacity, determined as a net of the total cost of the contract minus the energy revenues associated with dispatch of the contract.

2. Pursuant to the plan adopted herein, each IOU is to conduct a periodic auction for the energy rights to all resources acquired pursuant to this plan.

3. The IOUs are to follow the guidelines set forth herein in order to have the cost allocation plan applicable to their new generation resources.

4. It is reasonable to defer many of the implementation details of this cost allocation mechanism (to Phase II of this proceeding) along with associated ratemaking issues.

5. Pacific Gas and Electric Company is ordered to expeditiously sign the long-term contracts for 2,200 megawatts. Non-utility owned generation will be eligible for this newly adopted cost allocation plan.

6. Southern California Edison Company is to forthwith conduct a "fast track" request for proposal for 1,500 megawatts and bring long-term contracts to the Commission for approval no later than February 2007, or be asked to justify its non-compliance with this order. Non-utility owned generation will be eligible for this newly adopted cost allocation plan.

7. Nothing in this Order is to be read to prevent any Load Serving Entity, including the IOUs, from entering into any long-term contracts, from investing in new generation, or from building new generation that is not eligible for the cost allocation treatment established herein.

8. This cost allocation plan will stay in place until it is replaced by subsequent Commission directives.

This order is effective today.

Dated , at San Francisco, California.

APPENDIX A

Excerpt from Presentation of Kevin Kennedy, CEC's Integrated Energy Policy Report Coordinator, March 14, 2006.

(END OF APPENDIX A)

APPENDIX B

Excerpt from Presentation by Dave Ashuckian, California Energy Commission, Electricity Demand Office, March 14, 2006.

(END OF APPENDIX B)

APPENDIX C

Post-Workshop Comments

I. Comments Encouraging New Generation

A. Joint Parties

The Joint Parties argue that the Commission cannot simply "stay the course" of current regulatory policies and hope that new generation will develop. They explain that current policies have not induced sufficient investment and argue that the Commission cannot ensure the construction of new generation while relying on current policies that would unlawfully burden bundled-service customers with the cost of new generation.

Most of the opposition to the JP focuses on the cost allocation mechanism. The Joint Parties try to refute this opposition by reiterating that the JP is an interim concept only intended to be in place until there is a long-term solution, such as a functioning, centralized capacity market, and the JP is not a new paradigm for procurement that moves in the direction of more utility integration.

The Joint Parties stress that the cost allocation plan set forth in the JP fairly socializes the costs and benefits of new generation to all customers. The Joint Parties stress how unfair it would be to have their bundled-customers solely responsible for the long-term commitments necessary to encourage new generation that will benefit all customers and all LSEs within the IOU's service territory. In addition, the Joint Parties address other questions raised in the comments with the following clarifications: Debt equivalence will not be included in the socialized costs; the JP will not adversely affect the State's adopted loading order from EAP II since conventional resources are only added after preferred resources have been maximized; and the Joint Parties understand the need for transparency and will work with other parties on developing appropriate safeguards, but do not want to delay implementation of the process by attempting to resolve those issues now.

The Joint Parties had the opportunity to have their JP fully vetted at the workshop so they were able to support their proposal by addressing in their comments and reply the issues raised at the workshop. In particular, in response to concerns that the JP39 was moving in the direction of vertical integration of the IOUs, the Joint Parties explain how third-party investment companies can participate in future solicitations for new generation resources. The Joint Parties suggest that once the cost allocation principles in the JP are adopted, certain aspects of the Indicated Parties' plan can be folded into the JP structure, and details can be worked out in future solicitations. While the Joint Parties believe the Indicated Parties' plan is based on some faulty assumptions about the JP, the Joint Parties do not want the discussion of the Indicated Parties plan to delay implementation of the JP as they believe it is necessary to implement it now for system reliability.

B. Joint Parties' Separate Comments

In addition to joining in the JP, SCE, PG&E and TURN each filed an individual set of comments. SCE believes the JP will protect its bundled customers and states that SCE "will not enter into such contracts if its bundled-service customers alone are required to pay the full costs of new generation resources that will support system reliability for all customers."40 SCE also declares that it believes in the efficacy of a capacity market and that the JP should not hinder that market's development. Once a capacity market is functioning, the resources developed by the JP should be submitted to the capacity market.

SCE believes there is no merit to SDG&E's concerns that SCE is attempting to foist costs for new generation on to SDG&E customers by citing the needs as South of Path 15 (SP-15) area needs (instead of just SCE territory).

PG&E joins in SCE's interest of protecting bundled customers and states: "It would be inequitable to require only bundled customers to pay the higher cost associated with such new resources and allow direct access customers to reap the benefits of lower cost existing resources."41 From PG&E's perspective, Commission approval of the new cost allocation methodology is a condition precedent to PG&E finalizing the generation contracts from its recent long-term RFO and for the Contra Costa 8 (CC8) facility so that PG&E can "ensure that its bundled customers are not saddled with a disproportionate share of developing new resources for the region."42 PG&E restates that the JP should apply to utility-owned assets as well as PPAs.

TURN addressed the issue of how much new capacity might be necessary to assure reliable service, while balancing system cost and reliability. TURN argues that the Commission should find that there is a need to be met only if it finds that the resources available to serve its jurisdictional customers will fall short of the 15% to 17% Planning Reserve Margin (PRM) adopted in D.04-01-050. TURN is concerned that if a higher standard of need is adopted by the Commission, there will be additional costs on customers for a limited increase in reliability. In fact, from TURN's analysis of the data, PG&E does not have a need for additional resources through 2011 beyond what it has already committed to (including commitments from its recent RFO) but SCE does have a need before 2012.

If SDG&E is able to go forward with the Otay Mesa PPA with Calpine Corporation, as authorized in D.04-06-011 and on rehearing D.06-02-031, TURN does not anticipate SDG&E having any additional short-term need. Although SDG&E did not join in the JP, TURN suggests that the Otay Mesa Generating Plant (if it is built and comes on line), should also be subject to the JP. TURN also notes that SDG&E's example of having built some new generation shows the need for the JP because SDG&E was able to get Reliability Must Run (RMR) treatment for some portion of the new plants. RMR treatment spreads some of the fixed costs of the plant to all benefiting customers in the local reliability area. TURN notes that RMR treatment is simply not an adequate substitute for the JP since not all areas that need resources can qualify for RMR.

In its reply comments, TURN responds to the JP's opponents by reminding them that it is not in any LSE's or its customers' interest to take on the cost of new generation. Without the incentive that the JP offers for cost allocation, TURN is convinced that no new generation will be built. As TURN puts it, absent a multi-year RAR requirement, "there is an inherent hole in the Commission's RA[R] policy."43 TURN argues that telling IOUS to "just do it" and attempting to force IOUs to sign long-term contracts is unfair to bundled customers. The IOUs, TURN argues, are under no obligation to procure any particular percentage of their bundled customer needs from new capacity. Therefore, the Commission needs to figure out how to ensure new generation needed for system reliability gets built when it is not in the interest of any LSE or its customers to take on such an obligation. TURN states, "It is a major leap of faith for any party to assume that the current schedules in this case, and in R.05-12-013 will necessarily result in the timely development of new generation."44

C. AES

AES was an original member of the Joint Parties, and although no longer a sponsor of the JP, AES continues to support it. From AES' perspective, RAR and LTPP alone will not motivate investors to develop and construct the next wave of incremental generation in a timely fashion. AES, like other independent power producers (IPPs), will not make the capital investment without a stable revenue mechanism.

AES, however, does have a few concerns with the process set forth in the JP. Specifically, AES, questions whether the IOUs will design an RFO that does not favor the utility or its affiliate, especially vis-à-vis issues such as debt equivalence applicability to PPAs. AES offers suggestions to make the RFOs more open and competitive, a topic that will be further developed in Phase II of this rulemaking.

D. DRA

DRA is supportive of the Commission taking some steps to encourage new generation, but prefers certain aspects of the Distco model. However, DRA is very insistent that the Commission must do something now on the cost allocation issue since "relying on RAR as the sole regulatory measure for meeting the approaching resource gap for the 2008-2011 time frame might be ultimately be more costly than if the Commission adopted a limited cost allocation methodology now."45 DRA also supports of an interim cost allocation measure as some insurance against a hastly, and perhaps poorly designed, capacity market. However, DRA cautions the Commission to take the EAP II into consideration and only adopt the low end of the need range for this interim proposal.

E. CARE

CARE generally supports the JP, but would appreciate the opportunity to fairly consider other proposals.

F. CSBRT and CSBA

CSBRT and CSBA acknowledge that new generation is needed now in California and support the JP as an interim approach to achieve that goal.

II. Parties Primarily Preferring to Stay the Course, or Offering
Modifications to the JP

A. CAC/EPUC

CAC/EPUC acknowledge that there is a need for new generation in California now, but they do not support the JP because the cost allocation proposal would assess costs to departing load, which they fear could apply to new cogeneration. In summary, CAC/EPUC do not endorse the JP because they are not convinced it is an interim proposal, but one that could morph into a permanent one, and because it fosters traditional, fossil fuel generation, not cogeneration. The major concern of CAC/EPUC is preserving the place for cogeneration qualifying facilities (QF) in the loading order prescribed by EAP II, and not having the IOUs fill all of their need with traditional generation. However, CAC/EPUC ask that if the Commission adopts the JP, or a similar plan, that it apply the plan to new generation from any source, including new cogeneration facilities.

B. Mirant

Mirant believes that the wholesale power market in California does not produce adequate revenues to encourage and support investment in new generation. From Mirant's vantage point, the Commission's focus should be on fixing the wholesale market structure, but recognizes that an interim plan "may be needed while these market reforms are being implemented and given time to work."46 Therefore, Mirant reluctantly offers modifications to the JP to make it more in line with the Distco plan. Mirant believes this is necessary to signal that market stability is forthcoming and that California is a desirable environment for investment, without the need for "interim" solutions. Mirant does not support the JP as presented, because it perpetuates the existing dysfunction in the market. However, if the Commission adopts an interim measure, Mirant offers the following changes to the JP to create clear boundaries: limit the plan to a specific amount of new capacity for a specific time frame, consistent with moving towards the wholesale market; limit the cost allocation to the RAR portion; and have it apply to PPAs (not utility-owned generation).

In the meantime, Mirant advocates that the Commission continue to implement RAR, as well as reforms to the market redesign technology update (MRTU), and develop and implement a well-designed capacity market. "If a market structure is developed with the right components and allowed time to gain a foothold, it reasonably can be expected to encourage new investment on its own without the need for regulatory constructs being proposed."47

Constellation's favored position is that the Commission "stay the course" and allow the RAR to work. However, Constellation understands that the "reality of the California energy market is that it is not just the ESPs who are not investing in energy infrastructure in California--no one is investing, not ESPs, not generation developers, not the investment banks, not the IOUs, not customers--because market signals in California do not show a need for new capacity."48 From Constellation's perspective, it would be imprudent today to buy new generation unless investors can get a guarantee to charge "more that the current prevailing market price." Therefore, Constellation fears that investment backed by regulatory guarantees will remain the primary source of infrastructure investment in California, until and unless there is a competitive market.

Constellation urges the Commission to either reject the JP, or if it adopts the JP, to modify it so the Commission is taking steps consistent with where it ultimately wants to go. "To the extent the Commission determines that resources must be committed now to ensure reliable grid operations, there is a need for interim investment policies. The critical task, ..., is to ensure that the "fix" does not become an impediment to the success of the emerging wholesale market structure."49 Constellation would prefer that the Commission explore the Distco plan as an alternative to the JP, but in any event, advocates that the Commission should provide clear direction that any interim proposal will be replaced with a competitive market investment incentives supported by RAR and CAISO's MRTU.

D. Aglet

Aglet opposes the JP and the Distco plan from a concern that the IOU customers would not receive 100 % of the benefits from the new generation, but might get 100% of the costs. Aglet is concerned that there could be legal and administrative impediments to spreading the costs of new generation, and therefore the bundled IOU customers would be burdened with the cost. Aglet wants the IOUs to procure just for their bundled customers. As Aglet comments, "the Commission must determine whether the need for new generation is severe enough to eliminate a workable system and replace it with an experimental cost allocation method."50 Aglet points to PG&E's recent RFO for the proposition that mechanisms already exist to ensure that there are long-term contracts available. From its perspective, Aglet recommends that the Commission order each IOU to fill its required need, and new generation should be added only if it is cost effective.

E. AReM

AReM's comments focus mainly on opposing the JP. Instead of adopting a new program, AReM urges the Commission to direct the IOUs to procure for the needs of their bundled customers, just like SDG&E did two years ago when it held an RFO for grid reliability. AReM thinks the Commission should consider sanctions against PG&E and SCE for willfully avoiding filling their obligations to procure for their bundled customers.

AReM is concerned that the JP just adds to the regulatory uncertainty that investors find as an impediment to investment in California. AReM also questions whether the cost allocation mechanism in the JP is legally sustainable. If not, there would be further market distortions. Therefore, AReM advocates the policy of "staying the course" and allowing current policies to work. If the Commission is inclined to adopt a new policy, AReM recommends the following: clearly define the need for new capacity; decouple energy and capacity and have the IOUs procure energy only for their bundled customers, do not allow the JP for utility-owned generation, and limit the interim plan to five years.

F. POU Parties

Merced Irrigation District, Modesto Irrigation District, South San Joaquin Irrigation District, Northern California Power Agency and the California Municipal Utilities Association, herein referred to as the Joint POU Parties, oppose the JP. However, they are not against the concept that the Commission should adopt some other new measure to encourage new generation. A major concern of the Joint POUs is that costs may be shifted for generation that is consumed by IOU bundled customers to customers of Joint POU parties from the IOUs. In addition, the Joint POUs urge the Commission not to adopt a hastily drafted plan that was subject to workshops, but ask that any proposal be deferred to a proceeding where it can be more fully explored.

If, however, the Commission is considering the JP, the POU parties request the following modifications: clarify that POU parties outside of the CAISO control area will not be subject to the JP; require the IOUs to forecast customer movements from IOUs to POUs so that the IOU does not procure for those departing customers; clarify that "IOU nondistribution transmission customers" are not included; eliminate all suggestions that POU customers should have responsibility for future LTPP decisions of IOUs; and clarify that Assembly Bill (AB) 380 does not include POUs within the definition of an LSE.

G. Sempra Global

Sempra states that "[t]he Commission cannot create a stable regulatory environment, promote new investment in infrastructure, or even expect that its policies will be taken seriously if it continually suspends, overrides and tinkers with its programs before it has gone through even a single cycle of procurement."51 From Sempra's vantage point, if guidance is needed from the Commission, it is on how rules and policies will be enforced--not on how the rules and policies should be changed. In particular, Sempra blames PG&E and SCE for creating the alleged problem by refusing to procure the resources ordered in the last LTPP decision, D.04-12-048. In fact, only SDG&E carried through and met the needs of its service territory and sought to have the incremental benefits shared through RMR contract designation.

While urging the Commission to "stay the course," which to Sempra means implementing RAR rules and a capacity market, Sempra also alternatively provided input on modifications to the JP. Sempra's primary goal is to limit the impacts of any new proposal on the development of wholesale and retail markets. Therefore, Sempra recommends the following modifications to the JP: limit any interim mechanism to a one-time RFO; limit it to "urgent need"; do not retroactively apply the interim mechanism to PG&E; limit the cost allocation methodology to three to four years, subject to a revisit; allow LSEs to "opt out" if they can demonstrate they have sufficient resources; allow LSEs that procure new long-term resources to transfer fixed cost to the local IOU for recovery through the distribution-rate surcharges; do not permit cost allocation to apply to utility-owned generation or affiliate transactions; permit affiliate transactions and utility-owned generation so long as costs are recovered from bundled customers only; require the utilities to make public the winning contracts subject to cost allocation; make IOUs subject to reasonableness reviews for their procurement and dispatch of these resources; and design an interim plan which terminates once a centralized capacity market is functioning.

Sempra prefers the modifications it suggests to the Distco model as Sempra fears that despite its intentions, the Distco plan could be anticompetitive in the long term. Instead, the units subject to the cost allocation mechanism should be required to offer an energy option based on a heat-rate strike price to all customers paying the distribution charge. In its reply, Sempra counters arguments claiming that only the IOUs are willing or capable of making long-term resource commitments. Sempra submits that its nonutility LSE would be willing to undertake additional procurements if the Commission further requires that LSEs should procure a certain percentage of "new" resources as part of their RA obligation.

H. CLECA/CMTA

CLECA/CMTA urge the Commission to "stay the course." They do not find the JP interim, necessary or equitable and argue that adoption of the JP will "fundamentally alter the market structure in California, further eroding investor confidence in California's regulatory stability."52 In addition, CLECA/CMTA see the IOUs, in particular PG&E and SCE, as playing a game of "chicken," with their refusal to follow through with their approved LTPPs from D.04-12-048. CLECA/CMTA find no regulatory impediment to the IOUs signing long-term contracts, and claim that both IOUs are failing in their responsibilities as public utilities.

If however, the Commission does consider the JP, CLECA/CMTA urge that it be modified as follows. The JP should not (1) be applied retroactively to PG&E's recent long-term RFO and to Contra Costa 8; (2) be applied to utility owned generation; and (3) last longer than 10 years. Also, CLECA/CMTA argue that an IOU is not the only entity that can procure new generation. CLECA/CMTA are also concerned that if the JP is adopted, non-bundled customers will pay for above market costs of energy procured to serve bundled customers without having access to the energy. Finally, CLECA/CMTA posit that the JP does not address whether IOUs will seek to procure new generation in locations that solve local RA problems.

CLECA/CMTA also raise the issue of whether the JP would only be a transitional mechanism. CLECA/CMTA are concerned that it will become permanent, fundamentally altering the market structure of California.

I. Green Power Institute

On fundamental principles of fairness, Green Power opposes the JP as being "considerably more generous" than any cost mechanism available through the RPS program. Previously, TURN suggested using IOUs as a means of facilitating the procurement of renewable power by the smaller LSEs, and Green Power supports that concept if it could be implemented through the JP.

J. IEP

IEP opposes the JP primarily on the ground that "staying the course" will provide the regulatory certainty needed for new generation. IEP does not want the Commission giving the IOUs more control over procurement, because it fears that the JP is moving towards utility integration. However, if the Commission adopts the JP, IEP suggests that the Commission consider that the procurement entity be someone other than an IOU.

From IEP's perspective, the problem lies with the IOUs and the way the IOUs design the RFOs. If the solicitations were all-source, they could result in "the optimum mix of new generation, existing generation and repowering projects if [the solicitations were] given a chance to function as the Commission intended."53 According to IEP, the resource shortage problem is not the result of the current cost-allocation scheme, but a combination of the following: regulatory incentives that favor utility owned generation over PPAs; utilities being primary purchasers and sellers of power; IOUs finding unique-fleeting-opportunities (UFOs) to present to the Commission, rather than holding all-source competitive solicitations; the procurement process is lengthy and draped in excessive confidentiality; IOUs impose high credit requirements in their RFOs; and the debt equivalence adds to the cost of the PPAs.

K. WPTF

WPTF opposes the JP for the following reasons: the JP is not needed for reliability or to ensure RA compliance; it obstructs the long-term solution of all-source solicitations, capacity market and direct access; it creates a new stranded cost; it harms competitive markets by tasking the IOUs with the responsibility of procuring power for their competitors; bundled customers are already protected from stranded costs through the 10-year NBC authorized by D.04-12-048; and it will cause billing and price transparency problems. Instead, WPTF advocates that the Commission "stay the course" and not impose a temporary solution to address a scenario brought on by PG&E and SCE's refusal to procure sufficient resources. In the alternative, WPTF urges the Commission to order the IOUs to procure resources through all-source solicitations.

However, if the Commission chooses to adopt an interim plan, WPTF alternatively offers the following suggestions: require all-source solicitations; limit the number of MWs procured based on CEC and CAISO needs assessments; provide for an opt-out for non-utility LSEs upon a showing of RA; limit any IOU backstop procurement to RAR capacity only; make bids open and transparent; apply the policy only apply to PPAs, not utility owned generation and not to PGE's commitments from its recent RFO; do not extend the policy beyond 10 years; require that the entity procuring new capacity be anyone other than an IOU; and unbundle the energy and capacity components of the contract, as suggested in the Distco plan so as to maximize the energy rent.

L. SDG&E

SDG&E opposes the JP since the utility fears it will result in cross subsidies and potential stranded costs. SDG&E is particulary concerned that SCE might procure new resources, without first determining SDG&E's need for that capacity. SDG&E does not want SCE allocating 20% of the SP-15 shortfall to SDG&E regardless of SDG&E's resource position. Instead, SDG&E urges the Commission to focus on long-term solutions and move towards a capacity market, and not adopt the JP -- because it is really a long-term mechanism in disguise. If however, the Commission is considering the JP, SDG&E advocates having an opt-out provision for LSEs that are fully resourced.

M. SVLG

SVLG opposes the JP mainly on the ground that it represents a policy change toward returning IOUs to favored market position. SVLG does not believe that financing new power plants in California is difficult because of shifting customer bases, but rather because of the uncertainty of market rules. Instead, SVLG strongly supports "staying the course." However, if the Commission is considering an interim proposal, SVLG prefers aspects of the Distco plan to the JP, but only while the Commission is continuing to develop the LTPP and RAR framework. If SVLG urges that any interim proposal should only apply to peaking plants to secure reliability, that IOUs should procure base load or intermediate plants for their own growing energy needs, and that in no event, should the JP apply to utility ownership.

III. Parties Supporting Distco Plan or Who
Take No Position on the JP

A. CEC

The CEC is the drafter of the 2005 IEPR and as such, the CEC's role in this phase of the proceeding is to coordinate the transmittal of the information developed and analyzed in the preparation of the IEPR for use in the Commission's 2006 LTPP proceeding. Consistent with that role, the CEC did not take a position on the JP. Instead, the CEC advocates "staying the course" and does not see that there are any barriers to the IOUs obtaining long-term contracts, except for a need for "coming and going" rules to deal with the uncertainty of future departing and returning load. According to the CEC, if the Commission adopts "coming and going" rules by the end of 2006 as the CEC recommended in its 2005 IEPR, that should provide an alternative to the cost-sharing mechanisms in the JP and the other proposals.

The CEC established the range of need for the three IOUs in the IEPR and believes that its "contractually based range of need" numbers demonstrate that IOUs have sufficient need for new resources to (1) serve the demand for their bundled customers and (2) reduce dependence on old and inefficient power plants. The CEC is concerned that if the Commission wants to determine a separate "physical need" number for this proceeding, this process is likely to be contentious and require a significant expenditure of time and resources to resolve and will delay the issuance of this decision.

B. Indicated Parties

As discussed earlier in this decision, the Indicated Parties made modifications to the Investco proposal discussed at the workshop, produced their own proposal dubbed Distco, and urge the Commission to adopt the Distco model in lieu of the JP. In their reply comments, the Indicated Parties favor further consideration of proposals that will (1) unbundle the capacity and energy components of any new generation procured; (2) limit the need for cost allocation to the RA component; and (3) allow energy rights of new resources to be acquired and paid for by individual market participants through a forward auction. In addition, the Indicated Parties believe that their proposal can be implemented quickly.

C. FPL Energy, LLC

FPL Energy, LLC only filed reply comments that indicated support for the Indicated Parties' proposal.

IV. Other Comments

A. CAISO

CAISO does not comment on the JP or the Distco plan, but instead limits its response to the "needs" issue. In terms of need, CAISO reiterated the "Three R's" of RAR: (1) the right mix of resources; (2) resources that are in the right location; and (3) the right amount of resources. In summary, out of its concern for sufficient resources, CAISO recommends that the Commission periodically conduct cost/reliability analysis projected over the expected term of the LTPPs to reaffirm or adjust the level of resource insurance that is in the best interest of California consumers as the state's resource supply and demand projections evolve over time.

B. RCM Biothane

RCM's concern is that the JP must be adjusted to exempt net-metering customers from any non-bypassable charge.

C. Good Company Associates on Behalf of TAS

Good Company presents a proposal of its own: the Commission should utilize technology it has available, Turbine Inlet Cooling, to provide additional capacity in a more expeditious manner. Good Company's proposal is based on the premise that in the long run, market forces are generally superior to regulation. However, to resolve short-run reliability problems, TAS has technology available that may help provide a bridge until long-run solutions work.

D. Davis Hydro

Davis Hydro urges the Commission to utilize available small distributed renewable generation to increase RA.

E. CCDG

CCDG Coalition recommends that the integrated planning process should include the establishment of procurement targets for distributed generation (DG). In light of the IEPR and EAP II, the Commission should consider requiring the LSEs to have annual procurement targets for combined heat and power facilities.

F. WEM

WEM advocates that the Commission follow the EAP II priority and focus more on energy efficiency (EE) rather than building more fossil-fueled generation. WEM fears that the JP will block development of cleaner resources for the 30-year life of the new plants and condemn the state to uncontrolled global warming. Instead, WEM argues that the Commission could address the generation shortage issue by the following: acting though EE matters; making EE a local resource; and making EE show up in supply forecast.

(END OF APPENDIX C)

INFORMATION REGARDING SERVICE

I have provided notification of filing to the electronic mail addresses on the attached service list.

Upon confirmation of this document's acceptance for filing, I will cause a copy of the Notice of Availability to be served upon the service list to this proceeding by U.S. mail. The service list I will use to serve the Notice of Availability of the filed document is current as of today's date.

Dated June 20, 2006, San Francisco, California.

************ APPEARANCES ************

Marc D. Joseph
Attorney At Law
ADAMS, BROADWELL, JOSEPH & CARDOZO
601 GATEWAY BLVD., STE. 1000
SOUTH SAN FRANCISCO CA 94080
(650) 589-1660
mdjoseph@adamsbroadwell.com

For: Coalition of California Utility Employees and California Unions for Reliable Energy

James Weil
AGLET CONSUMER ALLIANCE
PO BOX 37
COOL CA 95614
(530) 885-5252
jweil@aglet.org


Evelyn Kahl
Attorney At Law
ALCANTAR & KAHL, LLP
120 MONTGOMERY STREET, SUITE 2200
SAN FRANCISCO CA 94104
(415) 421-4143
ek@a-klaw.com

For: Energy Producers & Users Coalition

Michael Alcantar
Attorney At Law
ALCANTAR & KAHL, LLP
1300 SW FIFTH AVENUE, SUITE 1750
PORTLAND OR 97201
(503) 402-9900
mpa@a-klaw.com

For: Cogeneration Association of California

Nora Sheriff
Attorney At Law
ALCANTAR & KAHL, LLP
120 MONTGOMERY STREET, SUITE 2200
SAN FRANCISCO CA 94104
(415) 421-4143
nes@a-klaw.com

For: Energy Producers & Users Coalition

Rod Aoki
Attorney At Law
ALCANTAR & KAHL, LLP
120 MONTGOMERY STREET, SUITE 2200
SAN FRANCISCO CA 94104
(415) 421-4143
rsa@a-klaw.com

For: Cogeneration Association of California

John R. Redding
ARCTURUS ENERGY CONSULTING, INC.
44810 ROSEWOOD TERRACE
MENDOCINO CA 95460-9525
(707) 937-0878
johnrredding@earthlink.net

For: Silicon Valley Leadership Group

Kris G. Chisholm
Staff Counsel
CALIFORNIA ELECTRICITY OVERSIGHT BOARD
770 L STREET, SUITE 1250
SACRAMENTO CA 95831
(916) 322-8633
kris.chisholm@eob.ca.gov


Caryn Holmes
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET, MS-14
SACRAMENTO CA 95814
(916) 654-4178
cholmes@energy.state.ca.us

For: California Energy Commission

Lisa Decarlo
Staff Counsel
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET MS-14
SACRAMENTO CA 95814
(916) 654-5195
ldecarlo@energy.state.ca.us

For: California Energy Commission

Grant A. Rosenblum
GEETA THOLAN
Staff Counsel
CALIFORNIA ISO
151 BLUE RAVINE ROAD
FOLSOM CA 95630
(916) 608-7138
grosenblum@caiso.com

For: California Independent System Operator Corp.

Lynne M. Brown
CALIFORNIANS FOR RENEWABLE ENERGY INC.
24 HARBOR ROAD
SAN FRANCISCO CA 94124
(415) 285-4628
l_brown123@hotmail.com







Michael E. Boyd
President
CALIFORNIANS FOR RENEWABLE ENERGY, INC.
5439 SOQUEL DRIVE
SOQUEL CA 95073
(408) 891-9677
michaelboyd@sbcglobal.net


Fritz Ortlieb
Attorney At Law
CITY OF SAN DIEGO
1200 THIRD AVENUE, SUITE 1200
SAN DIEGO CA 92101
(619) 236-6318
fortlieb@sandiego.gov

For: City of San Diego

Jan Reid
COAST ECONOMIC CONSULTING
3185 GROSS ROAD
SANTA CRUZ CA 95062
(831) 476-5700
janreid@coastecon.com


Mary Lynch
CONSTELLATION ENERGY COMMODITIES GROUP
2377 GOLD MEADOW WAY, STE. 100
GOLD RIVER CA 95670
(916) 526-2860
mary.lynch@constellation.com

For: CECG

Mona Tierney
CONSTELLATION NEW ENERGY, INC.
2175 N. CALIFORNIA BLVD., STE. 300
WALNUT CREEK CA 94596
(925) 287-4724
mona.tierney@constellation.com

For: Constellation New Energy, Inc.

William H. Chen
CONSTELLATION NEW ENERGY, INC.
2175 N. CALIFORNIA BLVD., SUITE 300
WALNUT CREEK CA 94596
(925) 287-4703
bill.chen@constellation.com

For: Constellation New Energy, Inc.

Clyde Murley, CONSULTANT
600 SAN CARLOS AVENUE
ALBANY CA 94706
(510) 528-8953
clyde.murley@comcast.net

For: Union of Concerned Scientists

R. Thomas Beach
CROSSBORDER ENERGY
2560 NINTH STREET, SUITE 213A
BERKELEY CA 94710
(510) 549-6922
tomb@crossborderenergy.com

For: California Cogeneration Council (CCC)

Carl K. Oshiro
Attorney At Law
CSBRT/CSBA
100 PINE STREET, SUITE 3110
SAN FRANCISCO CA 94111
(415) 927-0158
ckomail@pacbell.net


Richard D. Ely
DAVIS HYDRO
27264 MEADOWBROOK DRIVE
DAVIS CA 95616
(530) 753-8864
hydro@davis.com

For: Northern California Small Hydro Assn.

Jeffrey P. Gray
Attorney At Law
DAVIS WRIGHT TREMAINE, LLP
ONE EMBARCADERO CENTER, SUITE 600
SAN FRANCISCO CA 94111
(415) 276-6581
jeffgray@dwt.com

For: Calpine Corporation

Norman J. Furuta
Attorney At Law
DEPARTMENT OF THE NAVY
2001 JUNIPERO SERRA BLVD., SUITE 600
DALY CITY CA 94014-3890
(650) 746-7312
norman.furuta@navy.mil

For: Federal Executive Agencies

Daniel W. Douglass
Attorney At Law
DOUGLASS & LIDDELL
21700 OXNARD STREET, SUITE 1030
WOODLAND HILLS CA 91367
(818) 961-3001
douglass@energyattorney.com

For: Western Power Trading Forum





Gregory Klatt, Attorney At Law
DOUGLASS & LIDDELL
21700 OXNARD STREET, NO.1030
WOODLAND HILLS CA 91367
(818) 961-3002
klatt@energyattorney.com

For: Alliance for Retail Energy Markets

Jane E. Luckhardt, Attorney At Law
DOWNEY BRAND LLP
555 CAPITOL MALL, 10TH FLOOR
SACRAMENTO CA 95814
(916) 444-1000
jluckhardt@downeybrand.com


Ann L. Trowbridge
DOWNEY, BRAND, SEYMOUR & ROHWER, LLP
555 CAPITOL MALL, 10TH FLOOR
SACRAMENTO CA 95814
(916) 444-1000
atrowbridge@downeybrand.com

For: Merced Irrigation District/Sacramento Municipal Utility District/California Clean DG Coalition

John P. Mathis, Attorney At Law
EDISON MISSION ENERGY
555 12TH ST., NW STE. 640
WASHINGTON DC 20004
(202) 638-5408
jmathis@edisonmission.com


Andrew B. Brown, Attorney At Law
ELLISON, SCHNEIDER & HARRIS, LLP
2015 H STREET
SACRAMENTO CA 95814
(916) 447-2166
abb@eslawfirm.com

For: Constellation New Energy & Constellation Energy Commodities Group

Carolyn Kehrein
ENERGY MANAGEMENT SERVICES
1505 DUNLAP COURT
DIXON CA 95620-4208
(707) 678-9506
cmkehrein@ems-ca.com


Francisco Da Costa
ENVIRONMENTAL JUSTICE ADVOCACY
4909 3RD STREET
SAN FRANCISCO CA 94124
(415) 822-9602
frandacosta@att.net

For: Bayview Hunters Point Community

Steve Isser
Vp, General Counsel
GOOD COMPANY ASSOCIATES
816 CONGRESS AVE., SUITE 1400
AUSTIN TX 78701
(512) 279-0766
sisser@goodcompanyassociates.com

For: Good Company Associates

Michael B. Day
Attorney At Law
GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP
505 SANSOME STREET, SUITE 900
SAN FRANCISCO CA 94111-3133
(415) 765-8408
mday@gmssr.com

For: PacifiCorp

Joseph F. Wiedman
Attorney At Law
GOODIN MACBRIDE SQUERI RITCHIE & DAY,LLP
505 SANSOME STREET, SUITE 900
SAN FRANCISCO CA 94111
(415) 392-7900
jwiedman@gmssr.com

For: PacifiCorp

Brian T. Cragg
Attorney At Law
GOODIN, MACBRIDE, SQUERI, RITCHIE & DAY
505 SANSOME STREET, SUITE 900
SAN FRANCISCO CA 94111
(415) 392-7900
bcragg@gmssr.com

For: Independent Energy Producers Association

James D. Squeri
Attorney At Law
GOODIN, MACBRIDE, SQUERI, RITCHIE & DAY
505 SANSOME STREET, SUITE 900
SAN FRANCISCO CA 94111
(415) 392-7900
jsqueri@gmssr.com

For: Powerex Corp.

Jeanne Armstrong
Attorney At Law
GOODIN, MACBRIDE, SQUERI, RITCHIE & DAY
505 SANSOME STREET, SUITE 900
SAN FRANCISCO CA 94111
(415) 392-7900
jarmstrong@gmssr.com

For: South San Joaquin Irrigation District


Gregg Morris
GREEN POWER INSTITUTE
2039 SHATTUCK AVENUE, STE 402
BERKELEY CA 94704
(510) 644-2700
gmorris@emf.net

For: Green Power Institute

James A. Boothe
HOLLAND & KNIGHT LLP
50 CALIFORNIA STREET, 28TH FLOOR
SAN FRANCISCO CA 94111
(415) 743-6961
james.boothe@hklaw.com


Curtis Kebler
J. ARON & COMPANY(GOLDMAN SACHS)
2121 AVENUE OF THE STARS
LOS ANGELES CA 90067
(310) 407-5619
curtis.kebler@gs.com


William H. Booth
Attorney At Law
LAW OFFICES OF WILLIAM H. BOOTH
1500 NEWELL AVENUE, 5TH FLOOR
WALNUT CREEK CA 94596
(925) 296-2460
wbooth@booth-law.com

For: CA Large Energy Consumers Association

Ann G. Grimaldi
MCKENNA LONG & ALDRIDGE LLP
101 CALIFORNIA STREET, 41ST FLOOR
SAN FRANCISCO CA 94111
(415) 267-4000
agrimaldi@mckennalong.com

For: Center for Energy and Economic Development

Paul M. Seby
TIMOTHY R. ODIL
MCKENNA LONG & ALDRIDGE LLP
1875 LAWRENCE STREET, SUITE 200
DENVER CO 80202
(303) 634-4000
pseby@mckennalong.com


Sara Steck Myers
Attorney At Law
122 28TH AVENUE
SAN FRANCISCO CA 94121
(415) 387-1904
ssmyers@att.net

For: Center for Energy Efficiency and Renewable Technologies

Audrey Chang
NATURAL RESOURCES DEFENSE COUNCIL
111 SUTTER STREET, 20TH FLOOR
SAN FRANCISCO CA 94104
(415) 875-6100
achang@nrdc.org


Noel Obiora
Legal Division
RM. 4107
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-5987
nao@cpuc.ca.gov


Charles Middlekauff
Attorney At Law
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET
SAN FRANCISCO CA 94105
(415) 973-6971
crmd@pge.com

For: Pacific Gas and Electric Company

Douglas Larson
PACIFICORP
ONE UTAH CENTER, 23RD FLOOR
201 SOUTH MAIN
SALT LAKE CITY UT 84111
(801) 220-2190
doug.larson@pacifcorp.com


Eric Larsen
Environmental Scientist
RCM BIOTHANE
2850 POPLAR STREET
OAKLAND CA 94608
(510) 834-4568
e.larsen@rcmbiothane.com


Central Files
SAN DIEGO GAS & ELECTRIC
CP32B
8330 CENTURY PARK COURT
SAN DIEGO CA 92123-1530
(858) 654-1766
centralfiles@semprautilities.com


Wendy Keilani
SAN DIEGO GAS & ELECTRIC
8330 CENTURY PARK COURT, CP32D
SAN DIEGO CA 92123
(858) 654-1185
wkeilani@semprautilities.com

Lisa Urick
Attorney At Law
SAN DIEGO GAS & ELECTRIC COMPANY
101 ASH STREET
SAN DIEGO CA 92101
(619) 699-5070
lurick@sempra.com

For: San Diego Gas & Electric

Theodore Roberts
Attorney At Law
SEMPRA GLOBAL
101 ASH STREET, HQ 13D
SAN DIEGO CA 92101-3017
(619) 699-5111
troberts@sempra.com

For: Sempra Global

Beth A. Fox
LAURA I. GENAO
Attorney At Law
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVENUE, GO1, ROOM 351C
ROSEMEAD CA 91770
(626) 302-6897
beth.fox@sce.com

For: Southern California Edison Company

Case Administration
SOUTHERN CALIFORNIA EDISON COMPANY
ROOM 370
2244 WALNUT GROVE AVENUE
ROSEMEAD CA 91770
(626) 302-4875
case.admin@sce.com

For: SCE

Jennifer Chamberlin
STRATEGIC ENERGY, LLC
2633 WELLINGTON COURT
CLYDE CA 94520
(925) 969-1031
jchamberlin@sel.com

For: Strategic Energy, LLC

Keith R. Mccrea
Attorney At Law
SUTHERLAND, ASBILL & BRENNAN, LLP
1275 PENNSYLVANIA AVE., N.W. STE. 800
WASHINGTON DC 20004-2415
(202) 383-0705
keith.mccrea@sablaw.com

For: California Manufacturers & Technology Association

Michel Peter Florio
MATTHEW FREEDMAN
Attorney At Law
THE UTILITY REFORM NETWORK (TURN)
711 VAN NESS AVENUE, SUITE 350
SAN FRANCISCO CA 94102
(415) 929-8876
mflorio@turn.org

For: TURN

Michael Shames
Attorney At Law
UCAN
3100 FIFTH AVE., STE. B
SAN DIEGO CA 92103
(619) 696-6966
mshames@ucan.org

For: UCAN

John Galloway
Senior Energy Analyst
UNION OF CONCERNED SCIENTISTS
2397 SHATTUCK AVENUE, SUITE 203
BERKELEY CA 94704
(510) 843-1872
jgalloway@ucsusa.org


Alan Comnes
WEST COAST POWER
3934 SE ASH STREET
PORTLAND OR 97214
(503) 239-6913
alan.comnes@nrgenergy.com

For: West Coast Power

Maureen Lennon
WHITE & CASE
633 WEST 5TH STREET, SUITE 1900
LOS ANGELES CA 90071
(818) 802-1004
mlennon@whitecase.com

For: California Cogeneration Council (CCC)

Lisa A. Cottle
Attorney At Law
WHITE & CASE, LLP
4 EMBARCADERO CENTER, 24TH FLOOR
SAN FRANCISCO CA 94111
(415) 544-1105
lcottle@whitecase.com

For: Mirant California,LLC, Mirant Delta,LLC,and Mirant Potrero,LLC



********** STATE EMPLOYEE ***********

Kathryn Auriemma
Energy Division
RM. 4002
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-2072
kdw@cpuc.ca.gov


Donald J. Brooks
Energy Division
AREA 4-A
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-2626
dbr@cpuc.ca.gov

For: Energy Division

Carol A. Brown
Administrative Law Judge Division
RM. 5103, 505 VAN NESS AVE
San Francisco CA 94102
(415) 703-2971
cab@cpuc.ca.gov


Andrew Ulmer
CALIFORNIA DEPARTMENT OF WATER RESOURCE
1416 NINTH STREET, SUITE 1118
SACRAMENTO CA 95814
(916) 653-8826
aulmer@water.ca.gov

For: California Department of Water Resources

Chi Doan
CALIFORNIA DEPARTMENT OF WATER RESOURCES
3310 EL CAMINO AVE., ROOM LL94
SACRAMENTO CA 95821
(916) 574-0612
chi@water.ca.gov


Jeff Diamond
CALIFORNIA ELECTRICITY OVERSIGHT BOARD
770 L STREET, SUITE 1250
SACRAMENTO CA 95814
(916) 322-8629
jdiamond@eob.ca.gov


Clare Laufenberg
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS 46
SACRAMENTO CA 95814
(916) 654-4859
Claufenb@energy.state.ca.us

David Vidaver
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS-20
SACRAMENTO CA 95814
(916) 654-4656
dvidaver@energy.state.ca.us

For: California Energy Commission

Jim Woodward
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS 20
SACRAMENTO CA 95814-5504
(916) 654-5180
jwoodwar@energy.state.ca.us


Karen Griffin
Executive Office
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET, MS 39
SACRAMENTO CA 95814
(916) 654-4833
kgriffin@energy.state.ca.us

For: California Energy Commission

Kevin Kennedy
Supervisor, Special Projects
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET, MS-48
SACRAMENTO CA 95814
(916) 651-8836
kkennedy@energy.state.ca.us


Mike Ringer
CALIFORNIA ENERGY COMMISSION
1516 NINTH STREET, MS-20
SACRAMENTO CA 95814
(916) 654-4168
mringer@energy.state.ca.us

For: California Energy Commission

Nancy Tronaas
CALIFORNIA ENERGY COMMISSION
1516 9TH ST. MS-20
SACRAMENTO CA 95814-5512
(916) 654-3864
ntronaas@energy.state.ca.us


Ross Miller
CALIFORNIA ENERGY COMMISSION
1516 9TH STREET
SACRAMENTO CA 95814
(916) 654-4892
rmiller@energy.state.ca.us

For: California Energy Commission

Andrew Campbell
Executive Division
RM. 5304
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-2501
agc@cpuc.ca.gov


Matthew Deal
Energy Division
AREA 4-A
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-5649
mjd@cpuc.ca.gov


Donna J. Hines
Division of Ratepayer Advocates
RM. 4102
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-2520
djh@cpuc.ca.gov


Sepideh Khosrowjah
Division of Ratepayer Advocates
RM. 4101
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-1190
skh@cpuc.ca.gov


Ellen S. LeVine
Legal Division
RM. 5028
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-2047
esl@cpuc.ca.gov


Jerry Oh
Energy Division
AREA 4-D
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-5370
joh@cpuc.ca.gov


Nancy Ryan
Executive Division
RM. 5217, 505 VAN NESS AVE
San Francisco CA 94102
(415) 703-1823
ner@cpuc.ca.gov

Karen M. Shea
Energy Division
AREA 4-A
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-5404
kms@cpuc.ca.gov


Donald R. Smith
Division of Ratepayer Advocates
RM. 4209
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-1562
dsh@cpuc.ca.gov

For: Division of Ratepayer Advocates

Merideth Sterkel
Energy Division
AREA 4-A
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-1873
mts@cpuc.ca.gov

For: Energy Division

Robert L. Strauss
Energy Division
AREA 4-A
505 VAN NESS AVE
San Francisco CA 94102
(415) 703-5289
rls@cpuc.ca.gov

For: Energy Division

********* INFORMATION ONLY **********


Michael Mazur
3 PHASES ELECTRICAL CONSULTING
2100 SEPULVEDA BLVD., SUITE 15
MANHATTAN BEACH CA 90266
(310) 798-5275
mmazur@3phases.com


Kenneth E. Abreu
853 OVERLOOK COURT
SAN MATEO CA 94403
(925) 989-7912
k.abreu@sbcglobal.net






Vitaly Lee
AES ALAMITOS, LLC
690 N. STUDEBAKER ROAD
LONG BEACH CA 90803
(562) 493-7307
vitaly.lee@aes.com


Gustavo Luna
AES CORPORATION
690 N. STUDEBAKER RD.
LONG BEACH CA 90803
(562) 493-7307
gustavo.luna@aes.com


Karen Terranova
ALCANTAR & KAHL, LLP
120 MONTGOMERY STREET, STE 2200
SAN FRANCISCO CA 94104
(415) 421-4143
filings@a-klaw.com


Seema Srinivasan
Attorney At Law
ALCANTAR & KAHL, LLP
120 MONTGOMERY STREET, SUITE 2200
SAN FRANCISCO CA 94104
(415) 421-4143
sls@a-klaw.com


Frank Annunziato
President
AMERICAN UTILITY NETWORK INC.
10705 DEER CANYON DR.
ALTA LOMA CA 91737-2483
(909) 989-4000
allwazeready@aol.com


Edward G. Poole
Attorney At Law
ANDERSON & POOLE
601 CALIFORNIA STREET, SUITE 1300
SAN FRANCISCO CA 94108-2818
(415) 956-6413
epoole@adplaw.com


David J. Coyle
ANZA ELECTRIC COOPERATIVE, INC
58470 HIGHWAY 371
PO BOX 391090
ANZA CA 92539-1909

Stacy Aguayo
Manager Of Regulatory Affairs
APS ENERGY SERVICES
400 E. VAN BUREN STREET, SUITE 750
PHOENIX AZ 85004
(602) 744-5364
stacy.aguayo@apses.com


Philippe Auclair
353 SACRAMENTO STREET, SUITE 1700
SAN FRANCISCO CA 94111
(415) 391-5100
phil@ethree.com


Barbara R. Barkovich
BARKOVICH & YAP, INC.
44810 ROSEWOOD TERRACE
MENDOCINO CA 95460
(707) 937-6203
brbarkovich@earthlink.net


Reed V. Schmidt
BARTLE WELLS ASSOCIATES
1889 ALCATRAZ AVENUE
BERKELEY CA 94703-2714
(510) 653-3399
rschmidt@bartlewells.com


Tracey Drabant
Energy Resource Manager
BEAR VALLEY ELECTRIC SERVICE
PO BOX 1547
BIG BEAR LAKE CA 92315-1547
(909) 866-1666
traceydrabant@bves.com


Ryan Wiser
BERKELEY LAB
MS-90-4000
ONE CYCLOTRON ROAD
BERKELEY CA 94720
(510) 486-5474
rhwiser@lbl.gov


Bruce Mclaughlin
Attorney At Law
BRAUN & BLAISING, P.C.
915 L STREET SUITE 1420
SACRAMENTO CA 95814
(916) 326-5812
mclaughlin@braunlegal.com




Scott Blaising
Attorney At Law
BRAUN & BLAISING, P.C.
915 L STREET, STE. 1420
SACRAMENTO CA 95814
(916) 682-9702
blaising@braunlegal.com

For: CALIFORNIA MUNICIPAL UTILITIES ASSN.

Pierre H. Duvair, Ph.D
CALIFORNIA ENERGY COMISSION
1516 NINTH STREET
SACRAMENTO CA 95814
(916) 653-8685
pduvair@energy.state.ca.us



CALIFORNIA ENERGY MARKETS
517-B POTRERO AVENUE
SAN FRANCISCO CA 94110
(415) 552-1764
CEM@newsdata.com


Karen Mills
CALIFORNIA FARM BUREAU FEDERATION
2300 RIVER PLAZA DRIVE
SACRAMENTO CA 95833
(916) 561-5655
kmills@cfbf.com



CALIFORNIA ISO
151 BLUE RAVINE ROAD
FOLSOM CA 95630
e-recipient@caiso.com


Judith Sanders
CALIFORNIA ISO
151 BLUE RAVINE ROAD
FOLSOM CA 95630
jsanders@caiso.com

For: California ISO

Kevin Boudreaux
CALPINE CORPORATION
717 TEXAS AVE.
HOUSTON TX 77002
(713) 830-8935
boudreauxk@calpine.com

Steven S. Schleimer
CALPINE CORPORATION
3875 HOPYARD ROAD, SUITE 345
PLEASANTON CA 94588
(925) 479-6808
sschleimer@calpine.com


Bob Tang
Assistant Director
CITY OF AZUSA
729 NORTH AZUSA AVENUE
AZUSA CA 91702-9500
(626) 812-5214
btang@ci.azusa.ca.us


George Hanson
Assistant General Manager
CITY OF CORONA
730 CORPORATION YARD WAY
CORONA CA 92880
(951) 739-4967
george.hanson@ci.corona.ca.us


Thomas Blair
CITY OF SAN DIEGO
9601 RIDGEHAVEN COURT, STE. 120/MS1101B
SAN DIEGO CA 92123
(858) 492-6001
tblair@sandiego.gov


Ted Pope
Director
COHEN VENTURES, INC./ENERGY SOLUTIONS
1738 EXCELSIOR AVENUE
OAKLAND CA 94602
(510) 482-4420 X221
ted@energy-solution.com


Lynelle Lund
COMMERCE ENERGY, INC.
600 ANTON BLVD., SUITE 2000
COSTA MESA CA 92626
(714) 259-2536
llund@commerceenergy.com


David X. Kolk, Ph.D.
COMPLETE ENERGY SERVICE, INC.
41422 MAGNOLIA STREET
MURRIETA CA 92562
(512) 283-1097
Dkolk@compenergy.com




Lisa Decker
Counsel
CONSTELLATION ENERGY GROUP, INC.
111 MARKET PLACE, SUITE 500
BALTIMORE MD 21202
(410) 468-3792
lisa.decker@constellation.com

For: constellarion energy commodities , etc

Hank Harris
CORAL POWER, LLC
4445 EASTGATE MALL, SUITE 100
SAN DIEGO CA 92121
(858) 320-1505
hharris@coral-energy.com


Laurence Chaset
Legal Division
RM. 5131
505 VAN NESS AVE
San Francisco CA 94102
(415) 355-5595
lau@cpuc.ca.gov


Judy Pau
DAVIS WRIGHT TREMAINE LLP
ONE EMBARCADERO CENTER, SUITE 600
SAN FRANCISCO CA 94111-3834
(415) 276-6500
judypau@dwt.com


Robert B. Gex
Attorney At Law,
DAVIS WRIGHT TREMAINE LLP
ONE EMBARCADERO CENTER, SUITE 600
SAN FRANCISCO CA 94111-3611
(415) 276-6500
robertgex@dwt.com


Jennifer Porter
Policy Analyst
DIEGO REGIONAL ENERGY OFFICE
8520 TECH WAY SUITE 110
SAN DIEGO CA 92123
(858) 244-1180
jennifer.porter@sdenergy.org


Melanie Gillette
DUKE ENERGY NORTH AMERICA
980 NINTH STREET, SUITE 1420
SACRAMENTO CA 95814
(916) 441-6233
mlgillette@duke-energy.com

Gregory T. Blue
DYNEGY INC.
2420 CAMINO RAMON, SUITE 215
SAN RAMON CA 94583
(925) 866-4910
greg.blue@dynegy.com


Regina DeAngelis
Legal Division
RM. 4107
505 VAN NESS AVE
San Francisco CA 94102
(415) 355-5530
rmd@cpuc.ca.gov


Lawrence Kostrzewa
Regional Vp, Development
EDISON MISSION ENERGY
18101 VON KARMAN AVE., STE 1700
IRVINE CA 92612-1046
(949) 798-7922
lkostrzewa@edisonmission.com


Philip Herrington
Regional Vp, Business Management
EDISON MISSION ENERGY
18101 VON KARMAN AVENUE, STE 1700
IRVINE CA 92612-1046
(949) 798-7922
pherrington@edisonmission.com


Steve Koerner
Senior Consel
EL PASO CORPORATION
2 NORTH NEVADA AVENUE
COLORADO SPRINGS CO 80903
(719) 520-4443
steve.koerner@elpaso.com


Wayne Tomlinson
EL PASO CORPORATION
2 NORTH NEVADA AVENUE
COLORADO SPRINGS CO 80903
(719) 520-4579
william.tomlinson@elpaso.com


Lynn Haug
ELLISON, SCHNEIDER & HARRIS, LLP
2015 H STREET
SACRAMENTO CA 95814
(916) 447-2166
lmh@eslawfirm.com



Adrian Pye
ENERGY AMERICA, LLC
ONE STAMFORD PLAZA, EIGHTH FLOOR
263 TRESSER BLVD.
STAMFORD CT 06901
(416) 590-3290
adrian.pye@na.centrica.com


Kevin J. Simonsen
ENERGY MANAGEMENT SERVICES
646 EAST THIRD AVENUE
DURANGO CO 81301
(970) 259-1748
kjsimonsen@ems-ca.com


Saeed Farrokhpay
FEDERAL ENERGY REGULATORY COMMISSION
110 BLUE RAVINE RD., SUITE 107
FOLSOM CA 95630
(916) 294-0322
saeed.farrokhpay@ferc.gov


Eric Yussman
Regulatory Analyst
FELLON-MCCORD & ASSOCIATES
9960 CORPORATE CAMPUS DRIVE
LOUISVILLE KY 40223
(502) 214-6331
eyussman@knowledgeinenergy.com


Ralph Dennis
Director, Regulatory Affairs
FELLON-MCCORD & ASSOCIATES
9960 CORPORATE CAMPUS DRIVE, SUITE 2000
LOUISVILLE KY 40223
(502) 214-6378
ralph.dennis@constellation.com


Ed Chang
FLYNN RESOURCE CONSULTANTS, INC.
2165 MOONSTONE CIRCLE
EL DORADO HILLS CA 95762
(925) 634-7500
edchang@flynnrci.com


Janine L. Scancarelli
FOLGER LEVIN & KAHN LLP
275 BATTERY STREET, 23RD FLOOR
SAN FRANCISCO CA 94111
(415) 986-2800
jscancarelli@flk.com

Mark J. Smith
FPL ENERGY
383 DIABLO RD, SUITE 100
WALNUT CREEK CA 94526
(925) 831-0545
mark_j_smith@fpl.com


Diane I. Fellman
Attorney At Law
FPL ENERGY, LLC
234 VAN NESS AVENUE
SAN FRANCISCO CA 94102
(415) 703-6000
diane_fellman@fpl.com


J. Richard Lauckhart
GLOBAL ENERGY
2379 GATEWAY OAKS DRIVE, STE 200
SACRAMENTO CA 95833
(916) 609-7769
rlauckhart@globalenergy.com


Ronald Moore
GOLDEN STATE WATER/BEAR VALLEY ELECTRIC
630 EAST FOOTHILL BOULEVARD
SAN DIMAS CA 91773
(909) 394-3600 X 682
rkmoore@scwater.com


Isser Steve
Vice President/General Counsel
GOOD COMPANY ASSOCIATES
816 CONGRESS AVENUE, STE 1400
AUSTIN TX 78701
(512) 279-0766
sisser@goodcompanyassociates.com


Joseph F. Wiedman
Attorney At Law
GOODIN MACBRIDE SQUERI RITCHIE & DAY,LLP
505 SANSOME STREET, SUITE 900
SAN FRANCISCO CA 94111
(415) 392-7900
jwiedman@gmssr.com


Kimberly Kiener
IMPERIAL IRRIGATION DISTRICT
PO BOX 937
333 E. BARIONI BLVD.
IMPERIAL CA 92251
(760) 482-3354
kmkiener@iid.com



David Olsen
IMPERIAL VALLEY STUDY GROUP
3804 PACIFIC COAST HIGHWAY
VENTURA CA 93001
(805) 653-6881
olsen@avenuecable.com


Steven Kelly
INDEPENDENT ENERGY PRODUCERS ASSN
1215 K STREET, SUITE 900
SACRAMENTO CA 95814
(916) 448-9499
steven@iepa.com


Robert E. Burt
INSULATION CONTRACTORS ASSN.
4153 NORTHGATE BLVD., NO.6
SACRAMENTO CA 95834
(916) 568-1826
bburt@macnexus.org

For: Insulation Contractors Association

Jody S. London
JODY LONDON CONSULTING
PO BOX 3629
OAKLAND CA 94609
(510) 459-0667
jody_london_consulting@earthlink.net


Keith G. Johnson
Senior Market And Product Developer
151 BLUE RAVINE ROAD
FOLSOM CA 95630
(916) 608-7100
kjohnson@caiso.com


Dennis M.P. Ehling
Attorney At Law
KIRKPATRICK & LOCKHART NICHOLSON GRAHAM
10100 SANTA MONICA BLVD., 7TH FLOOR
LOS ANGELES CA 90067
(310) 552-5000
dehling@klng.com


Eileen Zorc
KIRKPATRICK & LOCKHART NICHOLSON GRAHAM
10100 SANTA MONICA BLVD.7TH FLOOR
LOS ANGELES CA 90067
(310) 552-5074
ezorc@klng.com

For: City of Vernon

Richard W. Raushenbush
Attorney At Law
LATHAM & WATKINS LLP
505 MONTGOMERY STREET, SUITE 2000
SAN FRANCISCO CA 94111
(415) 391-0600
Richard.Raushenbush@lw.com


Karen Lindh
LINDH & ASSOCIATES
7909 WALERGA ROAD, NO. 112, PMB119
ANTELOPE CA 95843
(916) 729-1562
karen@klindh.com


Lynne Mackey
LS POWER DEVELOPMENT
400 CHESTERFIELD CTR., SUITE 110
ST. LOUIS MO 63017
lmackey@lspower.com


Audra Hartmann
Regioinal Director, Gov'T Affairs
LS POWER GENERATION
980 NINTH STREET, SUITE 1420
SACRAMENTO CA 95814
(916) 441-6242
ahartmann@lspower.com


John W. Leslie
Attorney At Law
LUCE, FORWARD, HAMILTON & SCRIPPS, LLP
11988 EL CAMINO REAL, SUITE 200
SAN DIEGO CA 92130
(858) 720-6352
jleslie@luce.com


Richard Mccann Ph.D
M.CUBED
2655 PORTAGE BAY, SUITE 3
DAVIS CA 95616
(530) 757-6363
rmccann@umich.edu


David Marcus
PO BOX 1287
BERKELEY CA 94701
(510) 528-0728
dmarcus2@sbcglobal.net






C. Susie Berlin
MCCARTHY & BERLIN LLP
100 PARK CENTER PLAZA, STE. 501
SAN JOSE CA 95113
(408) 288-2080
sberlin@mccarthylaw.com


Barry F. Mccarthy
Attorney At Law
MCCARTHY & BERLIN, LLP
100 PARK CENTER PLAZA, SUITE 501
SAN JOSE CA 95113
(408) 288-2080
bmcc@mccarthylaw.com


Timothy R. Odil
MCKENNA LONG & ALDRIDGE LLP
1875 LAWRENCE STREET, SUITE 200
DENVER CO 80202
(303) 634-4000
todil@mckennalong.com


Douglas Mcfarlan
Vp, Public Affairs
MIDWEST GENERATION EME
440 SOUTH LASALLE ST., SUITE 3500
CHICAGO IL 60605
(312) 583-6024
dmcfarlan@mwgen.com


Christopher J. Mayer
MODESTO IRRIGATION DISTRICT
1231 11TH STREET
MODESTO CA 95354
(209) 526-7430
chrism@mid.org


Joy A. Warren
Attorney At Law
MODESTO IRRIGATION DISTRICT
1231 11TH STREET
MODESTO CA 95354
(209) 526-7389
joyw@mid.org


John Jensen
President
MOUNTAIN UTILITIES
PO BOX. 205
KIRKWOOD CA 95646
(209) 258-7444
jjensen@kirkwood.com


MRW & ASSOCIATES, INC.
1999 HARRISON STREET, SUITE 1440
OAKLAND CA 94612
(510) 834-1999
mrw@mrwasoc.com


William A. Monsen
MRW & ASSOCIATES, INC.
1999 HARRISON STREET, SUITE 1440
OAKLAND CA 94612
(510) 834-1999
mrw@mrwassoc.com


Devra Wang
NATURAL RESOURCES DEFENSE COUNCIL
111 SUTTER STREET, 20TH FLOOR
SAN FRANCISCO CA 94104
(415) 875-6100
dwang@nrdc.org


Eric Olson
NAVIGANT CONSULTING INC.
3100 ZINFANDEL DR., STE 600
RANCHO CORDOVA CA 95670-6078
(916) 631-3252
eolson@navigantconsulting.com


Robert S. Nichols
NEW WEST ENERGY
MAILING STATION ISB 665
PO BOX 61868
PHOENIX AZ 85082-1868
(888) 639-9674
rsnichol@srpnet.com


Scott Tomashefsky
NORTHERN CALIFORNIA POWER AGENCY
180 CIRBY WAY
ROSEVILLE CA 95678-6420
(916) 781-4291
scott.tomashefsky@ncpa.com


Jim Mayhew
NRG ENERGY
211 CARNEGIE CENTER
PRINCETON NJ 08540
(609) 524-4595
jim.mayhew@nrgenergy.com






Tim Hemig
Director
NRG ENERGY
4600 CARLSBAD BLVD.
CARLSBAD CA 99208
(760) 268-4069
tim.hemig@nrgenergy.com


Jesus Arredondo
NRG ENERGY INC.
4600 CARLSBAD BLVD.
CARLSBAD CA 99208
(916) 275-7493
jesus.arredondo@nrgenergy.com


E.J. Wright
OCCIDENTAL POWER SERVICES, INC.
5 GREENWAY PLAZA, SUITE 110
HOUSTON TX 77046
(562) 624-3309
ej_wright@oxy.com


Valerie Winn
Project Manager
PACIFIC GAS & ELECTRIC
PO BOX 770000 MAIL CODE B9A
SAN FRANCISCO CA 94177
(415) 973-3839
vjw3@pge.com


Brian K. Cherry
Regulatory Relations
PACIFIC GAS AND ELECTRIC COMPANY
MAIL CODE B10C
PO BOX 770000
SAN FRANCISCO CA 94177-0001
bkc7@pge.com


Ed Lucha
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE STREET, MAIL CODE B9A
SAN FRANCISCO CA 94105
ell5@pge.com


Edward V. Kurz
Attorney At Law
PACIFIC GAS AND ELECTRIC COMPANY
77 BEALE ST., MAIL CODE B30A
SAN FRANCISCO CA 94105
(415) 973-6669
evk1@pge.com

Grace Livingston-Nunley
Assistant Project Manager
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 770000 MAIL CODE B9A
SAN FRANCISCO CA 94177
(415) 973-4304
gxl2@pge.com


Nina Bubnova
Case Manager
PACIFIC GAS AND ELECTRIC COMPANY
PO BOX 770000, MAIL CODE B9A
SAN FRANCISCO CA 94177
nbb2@pge.com


Sebastien Csapo
Project Manager
PACIFIC GAS AND ELECTRIC COMPANY
MAIL CODE B9A
PO BOX 770000
SAN FRANCISCO CA 94177
sscb@pge.com


Soumya Sastry
PACIFIC GAS AND ELECTRIC COMPANY
MAIL CODE B9A
PO BOX 770000
SAN FRANCISCO CA 94177
(415) 973-3295
svs6@pge.com


Thomas Darton
PILOT POWER GROUP, INC.
9320 CHESAPEAKE DRIVE, SUITE 112
SAN DIEGO CA 92123
(858) 627-9577
tdarton@pilotpowergroup.com


Robert Marshall
PLUMAS-SIERRA RURAL ELECTRIC CO-OP
PO BOX 2000
73233 HIGHWAY 70 STE A
PORTOLA CA 96122-2000
(530) 832-0110

Laura Rooke
Sr. Project Manager
PORTLAND GENERAL ELECTRIC
121 SW SALMON ST.,
PORTLAND OR 97204
(503) 464-7017
laura.rooke@pgn.com



Rick C. Noger
PRAXAIR PLAINFIELD, INC.
2711 CENTERVILLE ROAD, SUITE 400
WILMINGTON DE 19808
(925) 866-6809
rick_noger@praxair.com


James Ross
RCS, INC.
500 CHESTERFIELD CENTER, SUITE 320
CHESTERFIELD MO 63017
(636) 530-9544
jimross@r-c-s-inc.com


Robert Ott
RELIANT ENERGY
PO BOX 148
HOUSTON TX 77001-0148
(713) 497-5117
rott@reliant.com


Trent A. Carlson
RELIANT ENERGY
1000 MAIN STREET
HOUSTON TX 77001
(713) 497-4386
tcarlson@reliant.com


Gary Hinners
RELIANT ENERGY, INC.
PO BOX 148
HOUSTON TX 77001-0148
(713) 497-4321
ghinners@reliant.com


Edward C. Remedios
33 TOLEDO WAY
SAN FRANCISCO CA 94123-2108
(415) 474-7253
ecrem@ix.netcom.com


Carlos F. Pena
Attorney At Law
SAN DIEGO GAS & ELECTRIC
101 ASH STREET, PQ 13
SAN DIEGO CA 92101
(619) 696-4320
cfpena@sempra.com


Steve Rahon
SAN DIEGO GAS & ELECTRIC COMPANY
8330 CENTURY PARK COURT, CP32C
SAN DIEGO CA 92123-1548

Kurt Kammerer, Director Of Programs
SAN DIEGO REGIONAL ENERGY OFFICE
PO BOX 60738
SAN DIEGO CA 92166-8738
(619) 546-6175
kjk@kjkammerer.com


Susan Freedman
SAN DIEGO REGIONAL ENERGY OFFICE
8520 TECH WAY, SUITE 110
SAN DIEGO CA 92123
(858) 244-1186
susan.freedman@sdenergy.org


Sean Casey
SAN FRANCISCO PUBLIC UTILITIES COMMISSIO
POWER ENTERPRISE
1155 MARKET STREET, 4TH FLOOR
SAN FRANCISCO CA 94103
(415) 554-1551
scasey@sfwater.org


Phillip J. Muller
SCD ENERGY SOLUTIONS
436 NOVA ALBION WAY
SAN RAFAEL CA 94903
(415) 479-1710
philm@scdenergy.com


Megan Saunders
SEMPRA ENERGY SOLUTIONS
101 ASH STREET, HQ09
SAN DIEGO CA 92101-3017

Sheridan J. Pauker
SHUTE, MIHALY & WEINBERGER LLP
396 HAYES ST.
SAN FRANCISCO CA 94102
pauker@smwlaw.com


Osa L. Wolff, Attorney At Law
SHUTE, MIHALY & WEINBERGER, LLC
396 HAYES STREET
SAN FRANCISCO CA 94102
(415) 552-7272
wolff@smwlaw.com


Mary O. Simmons
SIERRA PACIFIC POWER COMPANY
RATES & REGULATORY AFFAIRS
6100 NEIL ROAD, P.O. BOX 10100
RENO NV 89520
(775) 834-5870
msimmons@sierrapacific.com

Justin D. Bradley
SILICON VALLEY LEADERSHIP GROUP
224 AIRPORT PARKWAY, SUITE 620
SAN JOSE CA 95110
(408) 501-7864
jbradley@svlg.net


Laura Genao
Attorney At Law
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVENUE
ROSEMEAD CA 91770
(415) 929-5530
laura.genao@sce.com


Michael A. Backstrom
Attorney At Law
SOUTHERN CALIFORNIA EDISON COMPANY
2244 WALNUT GROVE AVENUE
ROSEMEAD CA 91770
(626) 302-6944
michael.backstrom@sce.com


Rasha Prince
SOUTHERN CALIFORNIA GAS COMPANY
555 WEST 5TH STREET, GT 14D6
LOS ANGELES CA 90013
(213) 244-5141
rprince@semprautilities.com


Seth D. Hilton
STOEL RIVES
111 SUTTER ST., SUITE 700
SAN FRANCISSCO CA 94104
(415) 617-8943
sdhilton@stoel.com


Janice Lin
Managing Partner
STRATEGEN CONSULTING LLC
146 VICENTE ROAD
BERKELEY CA 94705
(510) 665-7811
janice@strategenconsulting.com


Andrea Weller
STRATEGIC ENERGY, LTD
7220 AVENIDA ENCINAS, SUITE 120
CARLSBAD CA 92209
aweller@sel.com

Roger Pelote
THE WILLIAMS COMPANY, INC.
12736 CALIFA STREET
VALLEY VILLAGE CA 91607
(818) 761-5954
roger.pelote@williams.com


Steve Boyd
TURLOCK IRRIGATION DISTRICT
333 EAST CANAL DRIVE
TURLOCK CA 95381-0949
(209) 883-8364
seboyd@tid.org


Cliff Chen
UNION OF CONCERNED SCIENTIST
2397 SHATTUCK AVENUE, STE 203
BERKELEY CA 94704
(510) 843-1872
cchen@ucsusa.org


Andrew J. Van Horn
VAN HORN CONSULTING
12 LIND COURT
ORINDA CA 94563
(925) 254-3358
andy.vanhorn@vhcenergy.com


Robin J. Walther
1380 OAK CREEK DRIVE, NO. 316
PALO ALTO CA 94304-2016
(650) 793-7445
rwalther@pacbell.net


Barbara George
WOMEN'S ENERGY MATTERS
PO BOX 548
FAIRFAX CA 94978
(510) 915-6215
bgwem@igc.org


Kevin Woodruff
WOODRUFF EXPERT SERVICES, INC.
1100 K STREET, SUITE 204
SACRAMENTO CA 95814
(916) 442-4877
kdw@woodruff-expert-services.com


39 In post-workshop comments, the JP included SCE, PG&E, NRG, TURN, CURE, and CURE. Another party on the original proposal, AES, filed separate supportive comments.

40 SCE Comments, p. 3.

41 PG&E Comments, pp. 5-6.

42 PG&E Comments, p. 6.

43 TURN, Reply Comments, p. 4.

44 TURN, Reply Comments, p. 7.

45 DRA Comments, p. 7.

46 Mirant Comments, p. 5.

47 Mirant Comments, p. 10.

48 Id., p. 13.

49 Constellation Comments, p. 15.

50 Aglet Comments, p. 4.

51 Sempra Comments, p. 2.

52 CLECA/CMTA Comments, p. 3.

53 IEP Comments, p. 2.

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