state of california a.19-10-001 proof of rule 3.2 ......bonneville power administration...

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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) for Approval of Its Carbon- Free Surplus Energy Transaction with Bonneville Power Administration A.19-10-001 (Filed October 1, 2019) PROOF OF RULE 3.2 COMPLIANCE IN CONNECTION WITH APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR APPROVAL OF ITS CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION JANET S. COMBS ELLEN BERMAN Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1524 E-mail: [email protected] Dated: November 22, 2019

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Page 1: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration

A.19-10-001(Filed October 1, 2019)

PROOF OF RULE 3.2 COMPLIANCE IN CONNECTION WITH APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR APPROVAL OF ITS CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER

ADMINISTRATION

JANET S. COMBS ELLEN BERMAN

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1524 E-mail: [email protected]

Dated: November 22, 2019

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1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration.

A.19-10-001(Filed October 1, 2019)

PROOF OF RULE 3.2 COMPLIANCE IN CONNECTION WITH APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR APPROVAL OF ITS CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER

ADMINISTRATION

Pursuant to Rule 3.2(e) of the Rules of Practice and Procedure of the California Public

Utilities Commission (“Commission” or “CPUC”), Southern California Edison Company

(“SCE”) respectfully submits its Proof of Compliance with the notice requirements of Rules 3.2

(b), (c) and (d). This Proof of Compliance is submitted in connection with the October 1, 2019

filing of SCE’s Application for Approval of Its Carbon-Free Surplus Energy Transaction with

Bonneville Power Administration (A.19-10-001). SCE complied with the Rule 3.2 requirements.

The following exhibits are attached in support of this Proof of Compliance:

1. Exhibit A: Letter dated October 3, 2019 from attorney Janet S. Combs to all Cities

and Counties in SCE’s service territory regarding Notice of Application of Southern California

Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with

Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in

accordance with Rule 3.2(b).

2. Exhibit B: Declaration of SCE employee Javier Aguiniga dated November 19, 2019,

in support of proof of the newspaper publication of Notice of Application of Southern California

Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with

Page 3: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

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Bonneville Power Administration (A.19-10-001), in accordance with Rule 3.2(c). The following

documents are attached to this Declaration as required by Rule 3.2 (e): Attachment B-1, Sample

of the Notice provided to Newspapers for publication and Attachment B-2, Newspaper

Publication Schedule. Note that beginning in August 2019, SCE has begun circulating its notices

in newspapers under the umbrella of the Southern California News Group (SCNG), which is the

largest news content provider in the five-county Los Angeles metropolitan area. SCE is using

nine of SCNG’s local daily newspapers covering Los Angeles, Orange, Riverside, San

Bernardino, and Ventura Counties. Formerly, SCE had published its Los Angeles County

notices only in the Los Angeles Times. SCNG’s circulation covers more of SCE’s service

territory than the Los Angeles Times.

3. Exhibit C: Declaration of SCE employee Jonathan Kompara dated November 16,

2019, in support of proof of mailing the Notice of Application of Southern California Edison

Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with

Bonneville Power Administration (A.19-10-001), as a bill insert included with regular customer

bills, and of providing said Notice by electronically linking to the Notice for customers that

receive their bills electronically, in accordance with Rule 3.2(d). The following documents are

attached to this Declaration as required by Rule 3.2 (e): Attachment C-1, Sample of the Notice as

a bill insert and Attachment C-2, Sample of the electronic link to the Notice for customers that

receive their bills electronically.

4. Exhibit D: Declaration of SCE employee Javier Aguiniga dated November 19, 2019,

in support of proof of posting the Notice of Application of Southern California Edison Company

(U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power

Administration (A.19-10-001), on www.sce.com/notices. A sample of the Notice as posted on

www.sce.com/notices is attached to this Declaration as Attachment D-1 as required by Rule

3.2 (e).

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3

Respectfully submitted,

JANET S. COMBS ELLEN BERMAN

/s/ Janet S. Combs By: JANET S. COMBS

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1524 E-mail: [email protected]

November 22, 2019

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Exhibit A

Letter Dated October 3, 2019 to Cities and Counties, Customer Notice, and

Service List, with Certificate of Service

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Janet S. Combs Director and Managing Attorney

Resource Policy & Planning [email protected]

P.O. Box 800 2244 Walnut Grove Ave. Rosemead, California 91770 (626) 302-1524 Fax (626) 302-3990

October 3, 2019

Re: Southern California Edison’s Application for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration (Application A.19-10-001)

To Whom It May Concern:

Pursuant to California Public Utilities Commission (CPUC) Rule 3.2(b), Southern California Edison Company (SCE) is providing notice that on October 1, 2019, SCE filed its Application for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration. The CPUC has designated the application as Docket Number A.19-10-001.

SCE’s application is described in the enclosed notice. The notice will also be published in a newspaper of general circulation in every county within SCE’s service territory and included as a bill notice provided to every SCE customer. To obtain more detailed information, you may view and/or download a copy of SCE’s filing and supporting testimony on SCE’s website at https://on.sce.com/2LHkFrG or go directly to http://www.sce.com/applications (type “A.19-10-001” into the Search box and click “Go”).

You may also request a copy of these documents on CD-ROM from SCE at the address in the enclosed notice.

Sincerely,

/s/ Janet S. Combs

Janet S. Combs

JSC:kdl

Enclosure

Exhibit A, Page 1

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1

Los usuarios con acceso al Internet podrán leer y descargar esta notificación en español en el sitio Web de Southern California Edison (SCE) www.sce.com/avisos, o escriba a la atención de las Comunicaciones Corporativas.

Southern California Edison Company 2244 Walnut Grove Avenue

Rosemead, CA 91770

NOTICE OF SOUTHERN CALIFORNIA EDISON COMPANY’S REQUEST FOR APPROVAL OF ITS CARBON-FREE SURPLUS ENERGY TRANSACTION WITH

BONNEVILLE POWER ADMINISTRATION

APPLICATION NO. A.19-10-001

On October 1, 2019, Southern California Edison (SCE) filed its application with the California Public Utilities Commission (CPUC) requesting approval for a “proof of concept” carbon-free transaction to test a model of energy conservation transfer through the purchase in California of surplus carbon-free energy around the clock (ATC) hydropower from Bonneville Power Authority (BPA) and sourced from BPA’s energy efficiency achievements. The transaction is proposed for a three-year period through the end of 2021.

The “proof of concept” transaction seeks to explore whether there is a viable market for hydropower from the Pacific Northwest derived from incremental energy efficiency (EE) savings that can be imported without increasing emissions in other parts of the Western grid. The clean energy imported from BPA will be sold on the California Independent System Operator (CAISO) market, and therefore will be available to all market participants. Lessons learned from the transaction are expected to benefit all California load serving entities by providing information about how to potentially scale up and create a larger market for “non-traditional” energy supply. SCE will submit a final report that includes, but will not be limited to, information concerning the total megawatt hours of energy delivered by the transaction, (2) the total amount of incremental emissions reductions attributable to the transaction, and (3) information on BPA’s incremental EE savings based on BPA’s reported EM&V efforts; and (4) lessons learned.

ESTIMATED IMPACT OF THIS REQUEST ON ELECTRIC RATES

This “proof of concept” transaction is expected to cost a total of approximately $9 million in today’s dollars over a three-year period through the end of 2021. Some of the costs are expected to be offset by revenues SCE earns by bidding the hydropower into the CAISO market. The incremental cost of the transaction is expected to be approximately $2.989 million. The transaction could lead to a market in California for this type of product, thereby helping

Exhibit A, Page 2

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2

California meet its ambitious carbon-reduction goals without increasing emissions in the Pacific Northwest, as required by California law.1

If the CPUC approves this application, it will result in an estimated average rate increase of 0.03% over the three-year term of the transaction from 2019 through 2021.

The following table is representative of the estimated rate increase by customer group if this application is approved by the CPUC.

FOR FURTHER INFORMATION ABOUT SCE’S APPLICATION

You may review a copy of SCE’s application and related exhibits at SCE’s corporate headquarters: 2244 Walnut Grove Avenue, Rosemead, CA 91770.

Customers with internet access may view and download SCE’s application and related exhibits on SCE’s website at https://on.sce.com/2LHkFrG (for A.19-10-001), or by visiting www.sce.com/applications, typing “A.19-10-001” into the search box, and clicking “Go.” If you have technical issues accessing the documents through the website, please e-mail [email protected] for assistance (be sure to reference proceeding A.19-10-001 in your e-mail).

To request a hard copy of SCE’s application and related exhibits, or to obtain more information about this application from SCE, please write to:

Southern California Edison Company Attention: Robert Grimm A.19-10-001 – (Carbon Free Energy Transaction)P.O. Box 800Rosemead, CA 91770

1 See California Senate Bill (SB) 100 (2018) (100 Percent Clean Energy Act of 2018), codified as amendments to Public Utilities Code (PUC) Sections 399.11, 399.15, and 399.30 and the addition of PUC Section 454.5.

Exhibit A, Page 3

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3

In addition, a copy of this application may be reviewed at the CPUC’s Central Files Office, located in San Francisco, California, by appointment. For more information, please contact them at [email protected] or (415) 703-2045.

CPUC PROCESS

This application will be assigned to an Administrative Law Judge (Judge) who will determine how to receive evidence and other related documents necessary for the CPUC to establish a record upon which to base its decision. Evidentiary Hearings (EH) may be held where parties of record will present their testimony and may be subject to cross-examination by other parties. These EHs are open to the public, but only those who are parties of record can participate.

After considering all proposals and evidence presented during the formal hearing process, the assigned Judge will issue a proposed decision which may adopt SCE’s application as proposed, modify it, or deny it. Any of the five CPUC Commissioners may sponsor an alternate decision. The proposed decision, and any alternate decisions, will be discussed and voted upon at a scheduled CPUC Voting Meeting.

The Public Advocates Office (CalPA) may review this application on behalf of SCE’s customers. CalPA is the independent consumer advocate within the CPUC with a legislative mandate to represent investor-owned utility customers to obtain the lowest possible rate for service consistent with reliable and safe service levels. CalPA has a multi-disciplinary staff with expertise in economics, finance, accounting, and engineering. For more information about CalPA, please call (415) 703-1584, e-mail [email protected] or visit CalPA’s website at http://www.publicadvocates.cpuc.ca.gov/.

STAY INFORMED

If you would like to follow these proceedings, or any other issue before the CPUC, you may use the CPUC’s free subscription service. Sign up at: http://subscribecpuc.cpuc.ca.gov/. If you would like to learn how you can participate in these proceedings, provide public comments, or if you have questions about any CPUC processes, you may access the CPUC’s Public Advisor’s Office webpage at www.cpuc.ca.gov/pao/. You may also contact the Public Advisor’s Office as follows:

Phone: 1-866-849-8390 (toll-free) or 1-415-703-2074 TTY: 1-866-836-7825 (toll-free) or 1-415-703-5282

Or write to: CPUC Public Advisor’s Office 505 Van Ness Avenue San Francisco, CA 94102

Email: [email protected]

Please reference SCE’s Carbon-Free Energy Transaction Application No. A.19-10-001 in any communications you have with the CPUC regarding this matter. All public comments will become part of the public correspondence file for this proceeding and be made available for review to the assigned Judge(s), the Commissioners, and appropriate CPUC staff.

Exhibit A, Page 4

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Exhibit A, Page 5

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Exhibit A, Page 6

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Exhibit A, Page 7

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Exhibit A, Page 8

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Exhibit A, Page 9

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Exhibit A, Page 10

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Exhibit A, Page 11

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Exhibit A, Page 12

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Exhibit A, Page 13

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Exhibit A, Page 14

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Exhibit A, Page 15

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Exhibit B

Declaration of Javier Aguiniga Dated November 19, 2019

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B-1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration.

A.19-10-001(Filed October 1, 2019)

DECLARATION OF JAVIER AGUINIGA

I, Javier Aguiniga, declare as follows:

1. I am employed by Southern California Edison Company (“SCE”) as an

Advertising Specialist in SCE’s Corporate Communications organization.

2. In that capacity, I am responsible for SCE’s compliance with the newspaper

publication portion of the public notice requirements contained in Rule 3.2(c) of the California

Public Utilities Commission’s Rules of Practice and Procedure.

3. On or about October 3, 2019, I directed SCE’s vendor, the Daily Journal

Corporation, California Newspaper Service Bureau, to publish the Notice of Application of

Southern California Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus

Energy Transaction with Bonneville Power Administration (A.19-10-001), in newspapers within

SCE’s service territory.

4. Beginning in August 2019, SCE begun circulating its notices in newspapers under

the umbrella of the Southern California News Group (SCNG), which is the largest news content

provider in the five-county Los Angeles metropolitan area. SCE is using nine of SCNG’s local

daily newspapers covering Los Angeles, Orange, Riverside, San Bernardino and Ventura

Counties. Formerly, SCE had published its Los Angeles County notices only in the Los Angeles

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B-2

Times. SCNG’s circulation covers more of SCE’s service territory than the Los Angeles Times.

A sample of the Notice as published in the newspapers is attached hereto as “Attachment B-1.”

5. I subsequently received confirmation from the Daily Journal Corporation,

California Newspaper Service Bureau, that the newspapers ran the notice in accordance with the

Newspaper Publication Schedule. The Newspaper Publication Schedule is attached hereto as

“Attachment B-2.”

6. Additionally, I will be receiving the sworn affidavits of publication from each

newspaper that ran the notice in accordance with the attached Newspaper Publication

Schedule. SCE will maintain the original affidavits of publication provided by each newspaper,

and shall make them available to any person upon request.

I declare under penalty of perjury that the foregoing is true.

Executed on November 19, 2019 in Rosemead, California.

/s/ Javier Aguiniga By: Javier Aguiniga

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Attachment B-1

Sample of Notice as Published in Newspapers

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CNS-3301683#

sitio Web de Southern California Edison (SCE) www.sce.com/avisosde las Comunicaciones Corporativas.

Southern California Edison Company2244 Walnut Grove Avenue

Rosemead, CA 91770NOTICE OF SOUTHERN CALIFORNIA EDISON COMPANY’S REQUEST FOR APPROVAL

OF ITS CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION

APPLICATION NO. A.19-10-001

Public Utilities Commission (CPUC) requesting approval for a “proof of concept” carbon-free transaction to test a model of energy conservation transfer through the purchase in California of surplus carbon-free energy around the clock (ATC) hydropower from Bonneville Power

proposed for a three-year period through the end of 2021.The “proof of concept” transaction seeks to explore whether there is a viable market for

that can be imported without increasing emissions in other parts of the Western grid. The clean energy imported from BPA will be sold on the California Independent System Operator (CAISO) market, and therefore will be available to all market participants. Lessons learned from the

about how to potentially scale up and create a larger market for “non-traditional” energy supply.

total megawatt hours of energy delivered by the transaction, (2) the total amount of incremental emissions reductions attributable to the transaction, and (3) information on BPA’s incremental

ESTIMATED IMPACT OF THIS REQUEST ON ELECTRIC RATES This “proof of concept” transaction is expected to cost a total of approximately $9 million in today’s dollars over a three-year period through the end of 2021. Some of the costs are

market. The incremental cost of the transaction is expected to be approximately $2.989 million. The transaction could lead to a market in California for this type of product, thereby helping

1

If the CPUC approves this application, it will result in an estimated average rate increase of 0.03% over the three-year term of the transaction from 2019 through 2021.The following table is representative of the estimated rate increase by customer group if this application is approved by the CPUC. Bundled Average Rates (¢/kWh)Customer Group Current

Rates Proposed Increase Proposed Rates % Increase

Residential 18.26 0.01 18.27 0.03%Lighting - Small and Medium Power 16.74 0.00 16.75 0.03%Large Power 12.10 0.00 12.11 0.03%Agricultural and Pumping 13.43 0.00 13.44 0.03%Street and Area Lighting 18.92 0.00 18.93 0.02%Standby 10.49 0.00 10.49 0.03%Total 15.90 0.00 15.91 0.03%

Residentil Bill Impact ($/Month)Description Current Proposed Increase Proposed % Increase

$110.79 $0.03 $110.82 0.03%CARE residential bill $74.82 $0.02 $74.84 0.03%

FOR FURTHER INFORMATION ABOUT SCE’S APPLICATIONYou may review a copy of SCE’s application and related exhibits at SCE’s corporate headquarters: 2244 Walnut Grove Avenue, Rosemead, CA 91770.Customers with internet access may view and download SCE’s application and related exhibits on SCE’s website at https://on.sce.com/2LHkFrG (for A.19-10-001), or by visiting www.sce.com/applications, typing “A.19-10-001” into the search box, and clicking “Go.” If you have technical issues accessing the documents through the website, please e-mail [email protected] for assistance (be sure to reference proceeding A.19-10-001 in your email).To request a hard copy of SCE’s application and related exhibits, or to obtain more information about this application from SCE, please write to:Southern California Edison CompanyAttention: Robert GrimmA.19-10-001 – (Carbon Free Energy Transaction)P.O. Box 800Rosemead, CA 91770

located in San Francisco, California, by appointment. For more information, please contact them at or (415) 703-2045.CPUC PROCESSThis application will be assigned to an Administrative Law Judge (Judge) who will determine how to receive evidence and other related documents necessary for the CPUC to establish a record upon which to base its decision. Evidentiary Hearings (EH) may be held where parties of record will present their testimony and may be subject to cross-examination by other parties. These EHs are open to the public, but only those who are parties of record can participate. After considering all proposals and evidence presented during the formal hearing process, the assigned Judge will issue a proposed decision which may adopt SCE’s application as

decision. The proposed decision, and any alternate decisions, will be discussed and voted upon at a scheduled CPUC Voting Meeting.

CalPA is the independent consumer advocate within the CPUC with a legislative mandate to represent investor-owned utility customers to obtain the lowest possible rate for service

CalPA, please call (415) 703-1584, e-mail or visit CalPA’s website at .STAY INFORMEDIf you would like to follow these proceedings, or any other issue before the CPUC, you may use the CPUC’s free subscription service. Sign up at: .If you would like to learn how you can participate in these proceedings, provide public comments, or if you have questions about any CPUC processes, you may access the CPUC’s

. You may also contact the Public

Phone: 1-866-849-8390 (toll-free) or 1-415-703-2074 TTY: 1-866-836-7825 (toll-free) or 1-415-703-5282Or write to: CPUC

San Francisco, CA 94102Email: Please reference Application No. A.19-10-001 in any communications you have with the CPUC regarding this matter. All public comments will

1 See California Senate Bill (SB) 100 (2018) (100 Percent Clean Energy Act of 2018)399.11, 399.15, and 399.30 and the addition of PUC Section 454.5.

Attachment B-1, Page 1

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Attachment B-2

Newspaper Publication Schedule

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From: Liliana Moreno <[email protected]> Sent: Monday, October 7, 2019 3:29 PM To: Javier Aguiniga <[email protected]> Cc: Kathy Shubin <[email protected]> Subject: (External):RE: (External):Confirmation of Orders For APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION Importance: High

The orders listed below has been received and processed. If you have any questions regarding this order, please contact your ad coordinator or the phone number listed above.

Order details are as follows:

Order no Ad Description Newspaper Pubdates

3301683 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION DAILY REPORT 10/11/2019

3301684 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION

FRESNO BUSINESS JOURNAL 10/11/2019

3301685 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION HANFORD SENTINEL 10/11/2019

3301686 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION

IMPERIAL VALLEY PRESS 10/11/2019

3301687 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION INYO REGISTER 10/10/2019

3301688 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION MADERA TRIBUNE 10/09/2019

3301689 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION MAMMOTH TIMES 10/10/2019

3301690 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION PRESS-ENTERPRISE 10/11/2019

3301691 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION

SAN BERNARDINO COUNTY SUN 10/11/2019

3301692 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION

SANTA BARBARA NEWS-PRESS 10/11/2019

3301693 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION THE REGISTER 10/11/2019

3301694 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION

THE UNION DEMOCRAT 10/11/2019

3301695 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION^

VENTURA COUNTY STAR 10/11/2019

3301698 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION^

PORTERVILLE RECORDER 10/11/2019

3301699 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION^

SOUTHERN CAL NEWS GROUP DAILIES COMBO

10/11/2019

3302287 LLN19-012 3.2 APPLICATION NO. A.19-10-001 CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION^

LOS ANGELES DAILY NEWS 10/10/2019

Thank you, Liliana Moreno Supervisor Daily Journal Corporation California Newspaper Service Bureau Direct Line:213-229-5544 Fax: 213-229-5493 [email protected]

Attachment B-2, Page 1

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Exhibit C

Declaration of Jonathan Kompara Dated November 16, 2019

Page 29: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

C-1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration.

A.19-10-001(Filed October 1, 2019)

DECLARATION OF JONATHAN KOMPARA

I, Jonathan Kompara, declare as follows:

1. I am employed by Southern California Edison Company (“SCE”) as a Senior

Marketing Specialist, and work in the Customer Experience department in SCE’s Customer

Service organization.

2. In that capacity, I am responsible for SCE’s compliance with the portion of the

public notice requirements contained in Rule 3.2(d) of the California Public Utilities

Commission’s Rules of Practice and Procedure requiring SCE to provide notice of its application

by including such notice with regular customer bills or by electronically linking to such notice

for customers that receive their bills electronically.

3. For all SCE customers whose bills were generated from October 18, 2019 to

November 15, 2019, I oversaw the process of publishing the Notice of Application of Southern

California Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy

Transaction with Bonneville Power Administration (A.19-10-001), as a bill insert provided to

customers along with their regular bills as required by Rule 3.2(d).

4. I further verify that, for bills generated from October 18, 2019 to November 15,

2019, customers who receive their bills electronically can access a link to www.sce.com/notices

(where the Notice of Application of Southern California Edison Company (U 338-E) for

Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration

(A.19-10-001), is publicly available online), as authorized by Rule 3.2(d), in the automatic email

sent to such customers providing notification that their monthly SCE bill is ready to view online.

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C-2

5. A sample of the Notice as it appeared as a bill insert is attached hereto as

“Attachment C- 1.”

6. A sample of the referenced email including the link to www.sce.com/notices

is attached hereto as “Attachment C-2.”

I declare under penalty of perjury that the foregoing is true.

Executed on November 16, 2019, in Rosemead, California.

/s/ Jonathan Kompara By: Jonathan Kompara

Page 31: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

Attachment C-1

Sample of Notice as it Appeared as a Bill Insert

Page 32: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

NOTICE OF SOUTHERN CALIFORNIA EDISON

COMPANY’S REQUEST FOR APPROVAL

OF ITS CARBON-FREE SURPLUS ENERGY

TRANSACTION WITH BONNEVILLE POWER

ADMINISTRATION

Application A.19-10-001

On October 1, 2019, Southern California Edison (SCE) filed its

application with the California Public Utilities Commission (CPUC)

requesting approval for a “proof of concept” carbon-free transaction

to test a model of energy conservation transfer through the purchase

in California of surplus carbon-free energy around the clock (ATC)

hydropower from Bonneville Power Authority (BPA) and sourced from

BPA’s energy efficiency achievements. The transaction is proposed for

a three-year period through the end of 2021.

The “proof of concept” transaction seeks to explore whether there is

a viable market for hydropower from the Pacific Northwest derived

from incremental energy efficiency (EE) savings that can be imported

without increasing emissions in other parts of the Western grid.

The clean energy imported from BPA will be sold on the California

Independent System Operator (CAISO) market, and therefore will

be available to all market participants. Lessons learned from the

transaction are expected to benefit all California load-serving entities

by providing information about how to potentially scale up and create a

larger market for “non-traditional” energy supply. SCE will submit a final

report that includes, but will not be limited to, information concerning

the total megawatt hours of energy delivered by the transaction, (2) the

total amount of incremental emissions reductions attributable to the

transaction, and (3) information on BPA’s incremental EE savings based

on BPA’s reported EM&V efforts; and (4) lessons learned.

Multicultural services

Cambodian / 1-800-843-1309

Chinese / 1-800-843-8343

Korean / 1-800-628-3061

Vietnamese / 1-800-327-3031

Spanish / Español 1-800-441-2233

Attachment C-1, Page 1

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ESTIMATED IMPACT OF THIS REQUEST ON ELECTRIC RATES

This “proof of concept” transaction is expected to cost a total of

approximately $9 million in today’s dollars over a three-year period

through the end of 2021. Some of the costs are expected to be offset by

revenues SCE earns by bidding the hydropower into the CAISO market.

The incremental cost of the transaction is expected to be approximately

$2.989 million. The transaction could lead to a market in California for

this type of product, thereby helping California meet its ambitious carbon-

reduction goals without increasing emissions in the Pacific Northwest,

as required by California law.1

If the CPUC approves this application, it will result in an estimated

average rate increase of 0.03% over the three-year term of the

transaction from 2019 through 2021.

The following table is representative of the estimated rate increase by

customer group if this application is approved by the CPUC.

Bundled Average Rates (¢/kWh)

Customer GroupCurrent

Rates

Proposed

Increase

Proposed

Rates

%

Increase

Residential 18.26 0.01 18.27 0.03%

Lighting – Small

and Medium Power 16.74 0.00 16.75 0.03%

Large Power 12.10 0.00 12.11 0.03%

Agricultural and

Pumping13.43 0.00 13.44 0.03%

Street and Area

Lighting18.92 0.00 18.93 0.02%

Standby 10.49 0.00 10.49 0.03%

TOTAL 15.90 0.00 15.91 0.03%

Residential Bill Impact ($/Month)

Description CurrentProposed

IncreaseProposed

%

Increase

Non-CARE

residential bill $110.79 $0.03 $110.82 0.03%

CARE residential bill $74.82 $0.02 $74.84 0.03%

1 See California Senate Bill (SB) 100 (2018) (100 Percent Clean Energy Act of 2018), codified

as amendments to Public Utilities Code (PUC) Sections 399.11, 399.15, and 399.30 and the

addition of PUC Section 454.5.

Attachment C-1, Page 2

Page 34: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

FOR FURTHER INFORMATION ABOUT SCE’S APPLICATION

You may review a copy of SCE’s application and related exhibits at

SCE’s corporate headquarters: 2244 Walnut Grove Avenue, Rosemead,

CA 91770.

Customers with Internet access may view and download SCE’s application

and related exhibits on SCE’s website at https://on.sce.com/2LHkFrG

for A.19-10-001, or by visiting www.sce.com/applications, typing

“A.19-10-001” into the Search box, and clicking “Go.” If you have

technical issues accessing the documents through the website, please

email [email protected] for assistance (be sure to reference

proceeding A.19-10-001 in your email).

To request a hard copy of SCE’s application and related exhibits, or

to obtain more information about this application from SCE, please

write to:

Southern California Edison Company

Attention: Robert Grimm

A.19-10-001 – (Carbon-Free Energy Transaction)

P.O. Box 800

Rosemead, CA 91770

In addition, a copy of this application may be reviewed at the CPUC’s

Central Files Office, located in San Francisco, CA, by appointment.

For more information, please contact the CPUC at aljcentralfilesid@

cpuc.ca.gov or 1-415-703-2045.

Los usuarios con acceso al Internet podrán leer y descargar esta

notificación en español en el sitio Web de SCE www.sce.com/avisos o escriba a: Southern California Edison Company, P.O. Box 800, 2244

Walnut Grove Avenue, Rosemead, CA 91770. Atención: Comunicaciones

Corporativas. Para más detalles en español, llame al 1-800-441-2233

todos los días 8:00-20:00.

CPUC PROCESS

This application will be assigned to an Administrative Law Judge (Judge)

who will determine how to receive evidence and other related documents

necessary for the CPUC to establish a record upon which to base its

decision. Evidentiary Hearings (EH) may be held where parties of record

will present their testimony and may be subject to cross-examination by

other parties. These EHs are open to the public, but only those who are

parties of record can participate.

After considering all proposals and evidence presented during the formal

hearing process, the assigned Judge will issue a proposed decision

which may adopt SCE’s application as proposed, modify it, or deny it.

Any of the five CPUC Commissioners may sponsor an alternate decision.

The proposed decision, and any alternate decisions, will be discussed

and voted upon at a scheduled CPUC Voting Meeting.

Attachment C-1, Page 3

Page 35: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

The Public Advocates Office (CalPA) may review this application on

behalf of SCE’s customers. CalPA is the independent consumer

advocate within the CPUC with a legislative mandate to represent

investor-owned utility customers to obtain the lowest possible rate for

service consistent with reliable and safe service levels. CalPA has a

multi-disciplinary staff with expertise in economics, finance, accounting,

and engineering. For more information about CalPA, please call

1-415-703-1584, email [email protected] or

visit CalPA’s website at http://www.publicadvocates.cpuc.ca.gov/.

STAY INFORMED

If you would like to follow these proceedings, or any other issue before

the CPUC, you may use the CPUC’s free subscription service. Sign up at

http://subscribecpuc.cpuc.ca.gov/.

If you would like to learn how you can participate in these proceedings,

provide public comments, or if you have questions about any CPUC

processes, you may access the CPUC’s Public Advisor’s Office webpage

at www.cpuc.ca.gov/pao/. You may also contact the Public Advisor’s

Office as follows:

Phone: 1-866-849-8390 (toll-free) or 1-415-703-2074

TTY: 1-866-836-7825 (toll-free) or 1-415-703-5282

Or write to: CPUC

Public Advisor’s Office

505 Van Ness Avenue

San Francisco, CA 94102

Email: [email protected]

Please reference SCE’s Carbon-Free Energy Transaction Application

No. A.19-10-001 in any communications you have with the CPUC

regarding this matter. All public comments will become part of the public

correspondence file for this proceeding and be made available for

review to the assigned Judge(s), the Commissioners, and appropriate

CPUC staff.

Attachment C-1, Page 4

Page 36: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

Attachment C-2

Sample of Electronic Link to Notice Provided to Customers

Who Receive Their Bill Electronically

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Page 38: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

Exhibit D

Declaration of Javier Aguiniga Dated November 19, 2019

Page 39: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

D-1

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration.

A.19-10-001

(Filed October 1, 2019)

DECLARATION OF JAVIER AGUINIGA

I, Javier Aguiniga, declare as follows:

1. I am employed by Southern California Edison Company (SCE) as an Advertising

Specialist in SCE’s Corporate Communications organization.

2. In that capacity, I am responsible for SCE’s compliance with the portion of the

public notice requirements contained in Rule 3.2(d) of the California Public Utilities

Commission’s Rules of Practice and Procedure dealing with electronically posting the notice of

the application to increase rates for customers that receive their bills electronically.

3. Subsequent to the Notice of Application of Southern California Edison Company

(U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power

Administration (A.19-10-001), I oversaw the process of publishing the Notice of such filing on

SCE’s website, available at the following URL: www.sce.com/notices.

4. A sample of the Notice as posted on www.sce.com/notices is attached hereto as

“Attachment D-1.”

I declare under penalty of perjury that the foregoing is true.

Executed on November 19, 2019, in Rosemead, California.

/s/ Javier Aguiniga By: Javier Aguiniga

Page 40: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

Attachment D-1

Sample of Notice as Posted on www.sce.com/notices

Page 41: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

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Notices

On October 13, 2016, the California Public Utilities Commission (CPUC) issued Decision (D.)16-10-008, which approved aSettlement Agreement between Southern California Edison Company (SCE), The Office of Ratepayer Advocates (ORA), andThe Utility Reform Network (TURN). The Settlement Agreement resolves litigation regarding three previous CPUC Decisionsthat awarded SCE shareholder incentives for energy efficiency savings achieved during the 2006-2008 Energy Efficiencyprogram cycle. Pursuant to the Settlement Agreement, SCE agrees to return to its customers $13.5 million in equal amountsover a three year period. Alternatively, at its option SCE may accelerate the refund by crediting the present value, $12.38million, via a one-time credit to SCE's Base Revenue Requirement Balancing Account (BRRBA) within 30 days of CPUC'sapproval of the Settlement Agreement. SCE elected to accelerate the refund, and on November 11, 2016, SCE credited theBRBBA in the amount of $12.38 million, which offsets the rates SCE collects from its customers through the BRRBA. A copyof D.16-10-008 and the Settlement Agreement, may be accessed by visiting this link.

Below is a link to the most recent and past editions of SCE’s CPUC legal filings and mandated messages. This includescurrent and past editions of the Customer Connection and Business Connection bill onserts and final print-versions of billinserts by month. Go to the Customer & Business Connection Archive.

October 2019

NOTICE OF SOUTHERN CALIFORNIA EDISON COMPANY’S REQUEST FOR APPROVAL OF ITS CARBON-FREESURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION APPLICATION NO. A.19-10-001

September 2019

SOUTHERN CALIFORNIA EDISON COMPANY (SCE) NOTICE OF FILING OF GENERAL RATE CASE APPLICATIONIMPORTANT INFORMATION ABOUT SCE’S REQUESTED RATE INCREASE APPLICATION (A.) 19-08-013

August 2019

2018 Power Content Label

NOTICE OF EVIDENTIARY HEARINGS REGARDING SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E)APPLICATION FOR AUTHORITY TO ESTABLISH ITS AUTHORIZED COST OF CAPITAL FOR UTILITY OPERATIONSFOR 2020 AND TO RESET THE ANNUAL COST OF CAPITAL ADJUSTMENT MECHANISM APPLICATION A.19-04-014

SOUTHERN CALIFORNIA EDISON COMPANY’S (SCE) NOTICE OF TWO APPLICATIONS: FOR AUTHORIZATION TORECOVER COSTS RELATED TO 2018-2020 WILDFIRE INSURANCEPREMIUMS RECORDED IN ITS WILDFIREEXPENSE MEMORANDUM ACCOUNT APPLICATION NO. 19-07-020 REQUEST TO INCREASE RATES FOR THECATASTROPHIC EVENT MEMORANDUM ACCOUNT APPLICATION NO. A.19-07-021

NOTICE OF EVIDENTIARY HEARINGS REGARDING SOUTHERN CALIFORNIA EDISON COMPANY’S (SCE)REQUEST FOR AUTHORIZATION TO IMPLEMENT RESIDENTIAL DEFAULT TIME-OF-USE RATES AND INCREASEFIXED CHARGES (A.17-12-012)

Attachment D-1, Page 1

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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of Its Carbon-Free Surplus Energy Transaction with Bonneville Power Administration

A.19-10-001Filed October 1, 2019

CERTIFICATE OF SERVICE

I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I have this day served a true copy of PROOF OF RULE 3.2 COMPLIANCE IN CONNECTION WITH APPLICATION OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) FOR APPROVAL OF ITS CARBON-FREE SURPLUS ENERGY TRANSACTION WITH BONNEVILLE POWER ADMINISTRATION on all parties identified on the attached service list(s) A.19-10-001. Service was effected by one or more means indicated below:

☒ Transmitting the copies via e-mail to all parties who have provided an e-mail address.

☒ Placing the copies in sealed envelopes and causing such envelopes to be delivered byhand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s).

ALJ Scarlett Liang-UejioCPUC505 Van Ness Ave.San Francisco, CA 94102

Executed November 22, 2019 at Rosemead, California.

/S/ Laura Velarde_______ Laura Velarde, Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

Page 43: STATE OF CALIFORNIA A.19-10-001 PROOF OF RULE 3.2 ......Bonneville Power Administration (A.19-10-001), including the Certificate of Service, in accordance with Rule 3.2(b). 2.Exhibit

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CALIFORNIA PUBLIC UTILITIES COMMISSIONService Lists

PROCEEDING: A1910001 - EDISON - FOR APPROVA FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: NOVEMBER 15, 2019

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Parties

C.C. SONG DANIEL DOUGLASS DIR - REGULATORY ATTORNEY CLEAN POWER ALLIANCE DOUGLASS & LIDDELL 555 WEST 5TH STREET 4766 PARK GRANADA, SUITE 209 LOS ANGELES, CA 90013 CALABASAS, CA 91302 FOR: CLEAN POWER ALLIANCE OF SOUTHERN FOR: DIRECT ACCESS CUSTOMER COALITION CALIFORNIA (JOINT CCAS) AND ALLIANCE FOR RETAIL ENERGY MARKETS

JANET S. COMBS CATHY DEFALCO ATTORNEY CALIFORNIA CHOICE ENERGY AUTHORITY SOUTHERN CALIFORNIA EDISON COMPANY 44933 FERN AVENUE LAW DEPARTMENT LANCASTER, CA 93534 2244 WALNUT GROVE AVENUE / PO BOX 800 FOR: CALIFORNIA CHOICE ENERGY AUTHORITY ROSEMEAD, CA 91770 (JOINT CCAS) FOR: SOUTHERN CALIFORNIA EDISON COMPANY

RODERICK HILL MATTHEW FREEDMAN CALIF PUBLIC UTILITIES COMMISSION ATTORNEY LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM 4300 785 MARKET STREET, 14TH FL. 505 VAN NESS AVENUE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-3214 FOR: THE UTILITY REFORM NETWORK TURN FOR: PUBLIC ADVOCATES OFFICE

RALPH CAVANAGH COUNSEL NATURAL RESOURCES DEFENSE COUNCIL 111 SUTTER STREET, 21ST FL

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SAN FRANCISCO, CA 94104 FOR: NATURAL RESOURCES DEFENSE COUNCIL

Information Only

CASE COORDINATION MRW & ASSOCIATES PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MATTHEW LANGER NANCY WHANG ATTORNEY GENERAL COUNSEL CLEAN POWER ALLIANCE OF SOUTHERN CAL CLEAN POWER ALLIANCE 555 WEST 5TH STREET, 35TH FL 555 W. 5TH STREET, 35TH FL. LOS ANGELES, CA 90013 LOS ANGELES, CA 90013

ELLEN BERMAN SCE CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE 2244 WALNUT GROVE AVENUE / PO BOX 800 ROSEMEAD, CA 91770 ROSEMEAD, CA 91770

CENTRAL FILES SUE MARA SAN DIEGO GAS & ELECTRIC COMPANY CONSULTANT 8330 CENTURY PARK CT, CP31-E RTO ADVISORS, L.L.C. SAN DIEGO, CA 92123-1530 164 SPRINGDALE WAY REDWOOD CITY, CA 94062

ALEXANDER MERIGAN KARIN M. HIETA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH ELECTRICITY PLANNING & POLICY BRANCH AREA ROOM 5010 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

SCARLETT LIANG-UEJIO SONJA ZIAJA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ADMINISTRATIVE LAW JUDGE DIVISION ELECTRICITY PLANNING & POLICY BRANCH ROOM 5022 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JOSH STOOPS REGULATORY CLERK ATTORNEY BRAUN BLAISING SMITH WYNNE, PC BRAUN BLAISING SMITH WYNNE, PC 915 L STREET, STE. 1480 915 L STREET, SUITE 1480 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814

SCOTT BLAISING COUNSEL BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 915 L STREET, SUITE 1480 SACRAMENTO, CA 95814

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