before the public utilities commission of the state …...lims 314-6642 before the public utilities...

LIMS 314-6642

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Order Instituting Rulemaking to consider Alternative-Fueled Vehicle Programs, Tariffs, and Policies

Rulemaking 13-11-007 (Filed November 14, 2013)

SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) COMMENTS ON

ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING

JANET S. COMBS ANDREA L. TOZER

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1524 Facsimile: (626) 302-6693 E-mail: [email protected]

Dated: August 29, 2014

SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) COMMENTS ON ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING

TABLE OF CONTENTS

Section Page

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I. INTRODUCTION AND EXECUTIVE SUMMARY .............................................................................1

II. SCE’S RESPONSES TO THE FIRST FIVE QUESTIONS IN THE SCOPING RULING ..........................................................................................................................................3

1. Should the Commission adopt the proposed AFV Guiding Principles? What modifications, if any, are appropriate? .......................................................................3

2. Should the Commission consider an increased role for the utilities in PEV infrastructure deployment and, if so, what should that role be? If the Commission should consider utility ownership of PEV charging infrastructure, how should the Commission evaluate "underserved markets" or a "market failure" pursuant to D.11-07-029? What else should the Commission consider when evaluating an increased role for utilities in EV infrastructure deployment? ............................................................................................4

A. Acceleration Of Transportation Electrification Is Necessary To Achieve State And Federal Goals ............................................................................5

B. Markets Outside Single-Family Homes Should Be Considered “Underserved”..........................................................................................................9

C. Utilities Can Play A Vital Role In Accelerating EV Infrastructure Deployment ............................................................................................................10

D. The Commission Should Allow Utility Investment In EV Infrastructure That Satisfies Statutory Requirements ............................................13

E. SCE Plans To Propose A Charging Infrastructure Program ..................................17

3. What education and outreach activities must the utilities provide to support further customer PEV adoption? What existing resources are available for these activities and what additional resources are needed? ..........................18

A. SCE’s Current Education And Outreach Is Effective Within The Limited Framework Previously Authorized By The Commission ........................18

B. The Current Restrictions Limit SCE’s Ability To Conduct Broad Education And Outreach To Support EV Adoption ..............................................19

C. Improving Awareness About EVs Is Critical To Sustainable And Widespread Adoption ............................................................................................20

SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) COMMENTS ON ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING

TABLE OF CONTENTS (CONTINUED)

Section Page

ii

4. How should the Commission mitigate the impact of demand charges, if at all, on entities pursuing transportation electrification? ......................................................21

A. Demand Charges Align With Rate Design Principles And Prior Commission Guidance. ..........................................................................................21

B. Many Technologies And Business Models Allow Entities Pursuing Transportation Electrification To Lower Their Peak Demand. The Commission Should Allow The Market To Respond To Demand Charges. .................................................................................................................23

C. The Commission May Need A Workshop Or A Study Regarding Use Cases On Demand Charges To Determine If Any New Demand Charge Strategies Are Needed. ...............................................................24

5. How should the Commission identify and consider in this proceeding best practices achieved and lessons learned from current AFV pilot project results? ...............................................................................................................................24

III. CONCLUSION ....................................................................................................................................25

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STATE OF CALIFORNIA

Order Instituting Rulemaking to consider Alternative-Fueled Vehicle Programs, Tariffs, and Policies

Rulemaking 13-11-007

(Filed November 14, 2013)

SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) COMMENTS ON

ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING

Pursuant to the Assigned Commissioner’s Scoping Memo and Ruling, issued July 16,

2014 (Scoping Ruling), Southern California Edison Company (SCE) respectfully submits the

following responses to the questions raised.

I.

INTRODUCTION AND EXECUTIVE SUMMARY

Commissioner Peterman issued the Scoping Ruling for the Order Instituting Rulemaking

to Consider Alternative-Fueled Vehicle Programs, Tariffs, and Policies (AFV OIR) requesting

that stakeholders respond to the first five questions by August 29, 2014. SCE provides detailed

responses to the individual questions in Section II of these comments and emphasizes the

following:

Despite some progress as a result of state and California Public Utilities Commission

(Commission) policies to facilitate the adoption of plug-in electric vehicles (PEVs),

the current electric vehicle (EV) infrastructure market (e.g., charging stations,

catenaries) is not developing at a pace sufficient to support state and national goals

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and requirements. Further steps to accelerate this market are necessary and

appropriate at this time.

SCE urges this Commission to authorize the investor-owned electric utilities (IOUs or

utilities) to submit proposals to invest in EV infrastructure that can provide ratepayer

benefits and increase the adoption of EVs. SCE envisions that such investments (e.g.,

charging stations and supporting infrastructure) would involve collaboration with

third-party charging station providers and would be authorized to the extent they can

facilitate acceleration of EV penetration and use EV load to provide grid stability,

make better use of utility assets, assist with integration of intermittent generation

resources, and accomplish accelerated net greenhouse gas reductions, among other

benefits.

SCE expects the need for IOU EV infrastructure investments to be temporary. As the

business case for EV infrastructure improves and/or as the state meets its goals to

transform the transportation sector, utility involvement can and should scale back.

SCE recommends that the Commission provide flexibility to the utilities so that they

can develop EV infrastructure proposals to the Commission that reflect regional

differences (e.g., different grid needs, air quality needs, mixes of battery EVs and

plug-in hybrid EVs, and varying driver behaviors).

Utilities are in a unique position to educate customers EVs and the benefits of fueling

from the electric grid. SCE urges the Commission to broaden its existing policies

around utility EV education and outreach to allow IOUs to propose new EV

awareness campaigns, including broad media outreach.

Demand charges align with cost-of-service principles and prior Commission

guidance. Many technologies and business models allow entities pursuing

transportation electrification to lower their peak demands. The Commission should

allow the market to respond through technology solutions and incenting customers to

shift charging patterns in a way that is beneficial for the grid.

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II.

SCE’S RESPONSES TO THE FIRST FIVE QUESTIONS IN THE SCOPING RULING

Pursuant to the Scoping Ruling, SCE responds below to Questions 1 through 5.1 SCE

agrees that Questions 6 through 13 would be best addressed through an iterative process, and will

respond to these questions through workshops and comments, as envisioned by the Scoping

Memo.2 It is premature to address Questions 6 through 13 prior to developing the issues through

a collaborative process with all interested stakeholders.

1. Should the Commission adopt the proposed AFV Guiding Principles? What

modifications, if any, are appropriate?

SCE supports the Commission’s decision to “develop and adopt guiding principles to

direct and focus policy development for AFVs,”3 and supports the Commission’s proposed

guiding principles. SCE, consistent with its prior comments to other state agencies, recommends

a few edits to the Commission’s proposed principles. We also recommend that the Commission

clarify that these principles apply to programs to accelerate adoption of EVs and programs to

optimize EV load with vehicle-grid integration (VGI) programs (except for guiding principle

number 4, which applies only to VGI programs).

SCE proposes the following modifications to the Commission’s principles:4

1) Promote the accelerated deployment and adoption of safe and reliable AFV

equipment and grid infrastructure5 designed to meet transportation and energy

service needs while maximizing ratepayer benefits, and minimizing costs to all utility

1 Scoping Ruling, p. 16. 2 Scoping Ruling, p. 16. 3 Scoping Ruling, p. 6. 4 Recommended additions shown in bolded, underlined, italics and deletions shown in strikethough. 5 The terminology “AFV equipment and infrastructure” originates from Cal. Pub. Util. Code § 740.3.

SCE recommends consistency with the statutory terminology.

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customers in the long term, and supporting state and national policies including the

Governor’s Interagency Zero Emission Vehicle (ZEV) Action Plan.

2) Target near-term solutions that complement the use of preferred energy resources and

utilize the grid efficiently.

3) Incorporate and enhance policies from other, related Commission proceedings to

promote efficient program implementation and use of ratepayer funding.

4) In the long term, enable and incorporate the full range of values from VGI in a new

program as part of the Commission’s overall AFV efforts while remaining technology

and business model neutral and allowing for business model innovation and

customer choice.

2. Should the Commission consider an increased role for the utilities in PEV

infrastructure deployment and, if so, what should that role be? If the Commission should

consider utility ownership of PEV charging infrastructure, how should the Commission

evaluate "underserved markets" or a "market failure" pursuant to D.11-07-029? What

else should the Commission consider when evaluating an increased role for utilities in EV

infrastructure deployment?

The Commission should support policies and actions by the utilities to accelerate EV

market penetration in a manner that contributes to efficient grid management, particularly where

existing market solutions are not yet being widely adopted. SCE recommends that the

Commission allow utilities to play a temporary increased role in facilitating EV charging

infrastructure by deploying utility-owned EV charging equipment at customer locations in

underserved markets. Such deployment could transform EV charging access for customers and

assist third-party business models, which should lead to greater adoption of EVs. By doing so,

utilities can play a key role in the state’s ability to meet its climate policy goals and national and

state air quality requirements. SCE explains in detail below why increased utility involvement is

necessary and appropriate at this time.

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A. Acceleration Of Transportation Electrification Is Necessary To Achieve State

And Federal Goals

Accelerating transportation electrification to achieve large-scale adoption by 2030

is essential to meet California’s 2050 carbon reduction goals,6 national ambient air quality

requirements,7 state petroleum reduction goals,8 and other state goals.9 Figure 1 below shows six

to fifteen million light-duty PEVs are needed in California by 2030 to achieve the steep 35 year

adoption trajectory to obtain sufficient PEV penetration to meet the state’s 2050 greenhouse gas

reduction goal, according to studies from Lawrence Berkeley National Laboratory (LBNL), ICF

International, and Energy+Environmental Economics (E3). The scope and magnitude of this

6 Executive Order S-03-05 sets emission targets that require the state to reduce emissions to 80% below 1990 levels by 2050. Exec. Order No. S-03-05 (June 1, 2005), available at http://gov.ca.gov/news.php?id=1861 [as of August 29, 2014].

7 The National Ambient Air Quality Standards for criteria air pollutants have attainment deadlines of 2023 and 2032 for key pollutants. See Southern California Association of Governments summary report, “On The Move: Southern California Delivers The Goods,” December 2012, p. 27 (NOx emissions must decline from 758 tons per day in 2008 to about 78 tons per day by 2032), available at http://www.freightworks.org/DocumentLibrary/CRGMPIS_Summary_Report_Final.pdf [as of August 29, 2014].

8 State petroleum reduction goals were proposed in 2003 by CEC and CARB in response to AB 2076 (increase non-petroleum fuel to 20% of on-road demand by 2020 and 30% in 2030). See Joint Agency Report of CEC and CARB, Reducing California’s Petroleum Dependence, August 2003, p. 17, Recommendation #3, available at http://www.energy.ca.gov/reports/2003-08-14_600-03-005.PDF [as of August 29, 2014]. The State Alternative Fuels Plan in 2007 called for surpassing these earlier goals in response to AB 1007. See Commission Report of CEC and CARB, State Alternative Fuels Plan, December 2007, available at http://www.energy.ca.gov/2007publications/CEC-600-2007-011/CEC-600-2007-011-CMF.PDF [as of August 29, 2014].

9 Numerous studies released by academic institutions, governmental agencies, and non-profit organizations agree that the single most important piece of California’s greenhouse gas reduction strategy is electrification of the transportation sector because it is not feasible to achieve our reduction goals without a dramatic shift away from fossil fuel vehicles. One prominent report concludes that even “after other emission reduction measures were employed to the maximum feasible extent, there was no alternative to widespread switching of direct fuel uses (e.g., gasoline in cars) to electricity in order to achieve the reduction target.” James H. Williams, et al. “The Technology Path to Deep Greenhouse Gas Emissions Cuts by 2050: The Pivotal Role of Electricity,” Science Magazine, Vol. 335, January 2012, p. 53, available at http://www.sciencemagazinedigital.org/sciencemagazine/20120106?pg=54#pg52 [as of August 29, 2014].

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adoption challenge is daunting, and achieving the recommended six to fifteen million light-duty

PEVs by 2030 will require active participation from all stakeholders, including utilities. A slow

adoption rate (shown by the dashed line in Figure 1) would require such rapid acceleration of

PEV adoption from 2030 to 2050 that it would be too costly or simply not feasible to achieve.

Figure 1 Potential light-duty PEV adoption to meet California’s 2050 climate goals

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The scenario shown in Figure 1 is supported by other stakeholders. According to

the California Air Resources Board (CARB), “reaching the longer-term 2032 ozone air quality

10 Figure adapted from supplementary material for Max Wei et al., Lawrence Berkeley National Laboratory (LBNL), “Deep Carbon Reductions in California Require Electrification and Integration Across Economic Sectors,” Environ. Res. Lett., vol. 8, no. 1, January-March 2013, available at http://iopscience.iop.org/1748-9326/8/1/014038/article [as of August 29, 2014]; and “California Transportation Electrification Assessment, Phase 1: Final Report,” prepared by ICF International and Energy+Environmental Economics, August 2014, available at http://www.caletc.com/wp-content/uploads/2014/08/CalETC_TEA_Phase_1-FINAL.pdf [as of August 29, 2014]. The need to meet the NAAQS or the state petroleum reduction goals are not factored into the figure.

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standard and the 2050 climate goal will require an even greater transformation [of the market]. In

addition to the nearly complete transformation of passenger vehicles to zero-emission

technologies, approximately 80 percent of the truck fleet would need to be zero- or

near-zero-emission technology, and nearly all locomotives operating in the South Coast air basin

would need to be using some form of zero-emission technology.”11 The AB 32 Scoping Plan

update gives a comprehensive list of the other state requirements including the Governor’s

Interagency ZEV Action Plan, CARB’s ZEV program, other CARB regulations, and the state

ambient air quality standards.12

An accompanying significant expansion of infrastructure is needed to support the

rapid acceleration of EVs. Currently, the market is not on track to develop the necessary

infrastructure because of barriers faced by third-party providers and site hosts in multi-unit

residential locations and non-residential locations. One of the most robust studies on 2050

greenhouse gas reductions was published by LBNL and estimates that the number of light-duty

EVs required to achieve emission reductions to meet the state’s 2050 climate goal could be as

high as 90% of state-wide fleets or up to 50 million vehicles (see Figure 1).13 To serve tens of

millions of EVs in California, a significant investment in infrastructure will be required over the

long term. Near-term accelerated investment in key segments of the EV charging infrastructure

11 “Vision for Clean Air: A Framework for Air Quality and Climate Planning,” joint study by CARB, SCAQMD and SJAQMD, June 27, 2012, p. 4, available at http://www.arb.ca.gov/planning/vision/docs/vision_for_clean_air_public_review_draft.pdf [as of August 29, 2014].

12 First Update to the Climate Change Scoping Plan: Building on the Framework, Pursuant to AB 32 The California Global Warming Solutions Act of 2006, joint report of Governor Edmund G. Brown, Jr., the California EPA, and CARB, May 2014, p. 32 and Appendix C, available at http://www.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_scoping_plan.pdf [as of August 29, 2014]. See also SCAG Regional Transportation Plan for an overview of Southern California’s need to electrify, available at http://rtpscs.scag.ca.gov/Documents/2012/final/2012fRTP_ExecSummary.pdf [as of August 29, 2014].

13 See supplementary material for Max Wei et al., “Deep Carbon Reductions in California Require Electrification and Integration Across Economic Sectors,” supra.

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by utilities are expected to increase EV penetration and enable more robust third-party EV

charging market opportunities.

Residential charging in single-family homes is the main charging location for EVs

today.14 After single-family residential charging, the most useful place for charging is at long-

dwell locations (mainly workplaces, but also including multi-unit dwellings, fleets, etc.). To

measure the market need for away-from-single-family-home installations, the industry has

developed a metric called an “attach rate” that measures the number of plugs deployed relative to

the number of PEVs in the market. This metric is useful because it is relevant regardless of the

forecasted number of vehicles in the market. Forecasts of away-from-single-family-home

charging needs vary between attach rates of roughly 20% to 50% (representing a range from two

to five charge ports for every PEV, excluding charge ports at single-family homes).15 To achieve

the trajectory shown by the red line in Figure 1 above, approximately 260,000 to 650,000

charging ports outside of single-family homes would be required in California by 2020,16 and

three to eight million charging ports outside of single-family homes in California by 2030.17

This kind of growth will be nothing short of transformational, and requires overcoming multiple

challenges.

Third-party providers and site hosts interested in installing infrastructure face

several barriers -- high cost, complexity, and revenue risk -- to away-from-single-family-home

14 Southern California Association of Governments and the Luskin School of Public Affairs at UCLA, Southern California Plug-in Electric Vehicle Readiness Plan, December 2012, p. 90, available at http://www.scag.ca.gov/Documents/SCAG_PEV_Plan-Buildings_and_Retail_Owners.pdf [as of August 29, 2014].

15 An SCE assessment of several forecasts concluded that low estimates for attach rates are between 15% and 25% while high estimates are between 46% and 53%. Forecasts analyzed were: NREL: CA Statewide PEV Infrastructure Assessment (June 2014); EPRI: Guidelines for Infrastructure Planning “RedLine/BlueLine Method” (December 2012); UC Davis: Away from Home Charging (May 2014); and ChargePoint: Long-Term Vehicle Charging Plans (April 2014).

16 LBNL “High” scenario (red line in Figure 1) assumes roughly 1.3 million PEVs by 2020. 17 Alternatively, the “Aggressive Case” shown in Figure 1 (Green Line – seven million EVs in 2030)

would require 1.4 to 3.5 million charging stations outside of single-family homes by 2030.

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EV infrastructure being installed at scale.18 For example, even though site hosts recognize the

benefits of charging infrastructure ownership, chargers do not fit the classic pay-back/return on

investment paradigm.19 The high costs of infrastructure and installation to provide non-

residential charging capability,20 coupled with relatively low volumes and an inexpensive

commodity (electricity) being sold, make a sustainable business model challenging. Additional

challenges arise in multi-unit dwellings, where shared costs of installation and electricity bills

between tenants, property owners, and homeowners’ associations (HOAs) can become

complicated. Market participants have proposed that California could mitigate risks that the

market is not capable of absorbing today by installing basic charging infrastructure.21 In the

recent Transportation Electrification Assessment (TEA Study), ICF International and E3

reviewed studies by various experts on the charging market gaps in single-family homes, multi-

unit dwellings, workplaces, and other charging locations and concluded that the cost, complexity

and business model challenges outside of single-family homes are significant barriers.22

B. Markets Outside Single-Family Homes Should Be Considered

“Underserved”

SCE recommends that all markets for EV charging outside of single-family

homes be considered “underserved” because they are not growing as needed to support the EV

adoption required to achieve California’s environmental goals. As discussed above, the

18 “California Transportation Electrification Assessment, Phase 1: Final Report” supra, Section 5.2.1., pp. 46-48.

19 John Rhow, “Public Private Partnerships for California EVSE Market,” Kleiner Perkins Caufield & Byers, April 2014, available at http://www.energy.ca.gov/2014_energypolicy/documents/2014-04-23_workshop/presentations/07_CEC_Panel_John_Rhow_Kleiner_Advisor.pdf [as of August 29, 2014].

20 Installed charging stations can range in price $10,000 for Level 2 EVSE to over $100,000 for a DC Fast Charger.

21 John Rhow, “Public Private Partnerships for California EVSE Market” supra. 22 “California Transportation Electrification Assessment, Phase 1: Final Report” supra, Section 5.2., pp.

46-50.

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infrastructure for these markets is far below what is needed and the barriers are challenging.

Contributing to this slow transformation is the so-called chicken or egg problem: consumers are

reluctant to purchase EVs because they are worried about insufficient charging infrastructure, but

third parties are reluctant to build EV charging infrastructure before a demonstrated demand

exists. This results in a challenging business case for EV manufacturers and infrastructure

providers.

Disadvantaged communities are another type of underserved or underdeveloped

market. Several state laws focus on disadvantaged communities as they relate to adoption of

alternative-fuel, low-carbon transportation, and this issue received a lot of attention at the recent

Governor’s office workshop on updating the 2012 Governor’s Interagency ZEV Action Plan.23

The costs of continuing on the current slow rate of adoption are high. As Figure 1

above shows, if only 1 million ZEVs are adopted by 2030 (lowest line in Figure 1), then the

dashed line will need to be followed to achieve the state goals: over 40 million EVs in two

decades. A well-conceived program to accelerate the EV market today can succeed and help

avoid the costs of not meeting the state’s goals.

C. Utilities Can Play A Vital Role In Accelerating EV Infrastructure

Deployment

Many parties have called for or supported an increased utility role in accelerating

EV infrastructure deployment, including Los Angeles Department of Water and Power

(LADWP),24 eVgo/NRG,25 C2SE26, NRDC,27 General Motors,28 and ChargePoint, Inc.29 The

23 Pub. Util. Code § 2827, Cal Health & Saf. Code §§ 39711, 39712, and SB 1204 and SB 1275 currently pending before the California legislature. See also March 2014 Governor’s Office Summit on Zero Emissions Vehicles, information available at http://gov.ca.gov/s_zevsummitagenda.php [as of August 29, 2014].

24 See CEC Docket No. 14-IEP-1B, 2014 Integrated Energy Policy Report (IEPR) Update, Statewide Plug-In Electric Vehicle (PEV) Infrastructure Workshop, June 5, 2014, Tr. LADWP/Briasco 92:15-24 (“Another thing is I think it’s important for the utilities obviously to be very active in this space. We don’t have some of the restrictions I think that some of the investor-owned utilities have in the state,

Continued on the next page

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State Alternative Fuels Plan jointly published by CARB and the California Energy Commission

(CEC) in 2007 also calls for utility ownership of EV infrastructure as a way to speed up adoption

of low carbon transportation to meet the 2050 goals.30 The TEA Study explicitly calls for an

increased utility role in EV infrastructure development.31 ICF International goes on to

recommend that utilities be afforded flexibility in their ability to engage in the charging

Continued from the previous page

so if they could become more active, I think it would do a lot to help facilitate this market. So it’s customer education, awareness, and ….the installation of these charging stations. I think it’s important.”). Transcript available at http://www.energy.ca.gov/2014_energypolicy/documents/2014-06-05_workshop/2014-06-05_iepr_transcript.pdf [as of August 29, 2014].

25 See Statewide PEV Infrastructure Workshop, supra, Tr. NRG/O’Day 129:1-7 (“[T]here was a suggestion that utilities invest more and I think that there are proposals out there, particularly on funding, what we’ve called Make Readies and it’s that infrastructure to get over the barrier of the transformer conduit to parking spaces, I think that’s something that could be a meaningful stimulus.”).

26 See Nick Nigro, The Role of Electric Utilities in Enabling a Robust EV Charging Network, Center for Climate and Energy Solutions (C2ES), July 24 2014, p. 6 (“Electric utilities are a critical partner in enabling a robust EV charging network.”). Available at http://evroadmapconference.com/program/presentations/NickNigro.pdf [as of August 29, 2014].

27 See A.14-04-014, Response of NRDC Response to the Electric Vehicle Grid Integration Application of SDG&E, dated May 19, 2014.

28 See A.14-04-014, Prehearing Conference Statement of General Motors, dated August 8, 2014. 29 See A.14-04-014, Prehearing Conference Statement of ChargePoint, Inc., dated August 8, 2014, p. 5

(“ChargePoint supports SDG&E’s proposal to invest in upgrades and interconnection infrastructure at pilot charging locations. Allowing SDG&E to invest in “made-ready” facilities as described in Chapter 2 of the testimony would be a very good, measurable, first step in expanding SDG&E’s current involvement in EV infrastructure development. ChargePoint intends to provide expert testimony supporting this aspect of the SDG&E proposal, and ChargePoint will also advocate in the OIR for utility participation in the construction and installation of much-needed “make-ready” facilities.”).

30 See Commission Report of CEC and CARB, State Alternative Fuels Plan, supra, pp. 8, 22. 31 “California Transportation Electrification Assessment, Phase 1: Final Report” supra, Section 5.3.2.,

p. 57 (“Based on ICF’s research as part of our light-duty PEV market assessment, the answer to the first part of the first question is ‘yes.’ We arrive at that answer by considering, for instance, that California utilities have a history of forwarding services to society that are not typically cost-effective, such as early renewable energy installations and energy efficiency measures. There are analogous concerns with the nascent PEV charging infrastructure market that utilities should be able to help address.”).

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infrastructure market and that the Energy Division’s recent vehicle-grid integration (VGI) white

paper influenced their recommendation.32

SCE recommends that the Commission allow utilities to propose discrete

programs to help accelerate the away-from-single-family home charging market by owning EV

infrastructure up to and including the charging station. Such investments should involve

collaboration with third-party charging station providers and be designed to run for a limited

duration to facilitate acceleration of EV penetration and use of EV load to provide grid stability,

make better use of utility assets, assist with integration of intermittent generation resources, and

accomplish accelerated net greenhouse gas reductions, among other benefits. A recent global

study that examined the relationship between key variables (financial incentives, charging

infrastructure, and presence of production facilities) and 30 national electric vehicle markets

concluded that, of those variables, charging infrastructure was the best predictor of a country’s

EV market penetration.33

The relationship between infrastructure availability and EV adoption has been

understood by businesses and original equipment manufacturers (OEMs) alike for quite a while.

The “if you build it, they will come” mentality has proven itself for businesses like Google,

which has expanded from an initially oversized installation of 100 charging ports for workplace

charging needs in 2011 to over 880 charging ports today because of a surge in ownership.34

32 “California Transportation Electrification Assessment, Phase 1: Final Report” supra, Section 5.3.2., pp. 57-58.

33 William Sierzchula, et al., “The influence of financial incentives and other socio-economic factors on electric vehicle adoption,” Energy Policy, vol. 68, May 2014, pp. 183-194 (“For charging infrastructure, holding all other factors constant, each additional station per 100,000 residents that a country added would increase its EV market share by 0.12 percent. This suggests that each charging station (per 100,000 residents) could have twice the impact on a country’s EV market share than $1,000 in consumer financial incentives, albeit with different bearings on a nation’s budget.”). Abstract available at http://www.sciencedirect.com/science/article/pii/S0301421514000822 [as of August 29, 2014].

34 Rolf Schreiber, “Workplace Charging @ Google,” Breakout Session A2: Taking the “Work” Out of Workplace Charging, Plug-in 2014, San Jose, CA, July 29, 2014 (“Google’s new mindset is “we built it and they came – like a locust swarm!”). Presentation available at

Continued on the next page

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OEMs like Nissan are trying to capitalize on the connection between adoption and public

charging infrastructure, premising that customers need to have reliable and convenient charging

at two of three locations (home, work, public) to increase EV adoption.35

Utilities can and should be allowed to facilitate the acceleration of EV

infrastructure deployment on a discrete basis to help the state meet its goals and requirements.

As the business case for third-party infrastructure deployment improves or as the state meets its

goals to transform the transportation sector, utility involvement can scale back. The Commission

can address the duration of utility involvement through utility applications and regular review of

the state of the market and the achievement of state policy goals and requirements.

D. The Commission Should Allow Utility Investment In EV Infrastructure That

Satisfies Statutory Requirements

SCE recommends that the Commission allow utility investment in EV

infrastructure where the investments satisfy the requirements of P.U. Code sections 740.2, 740.3,

and 740.8. P.U. Code section 740.2 calls for “infrastructure sufficient to overcome any barriers

to the widespread adoption of PEVs,” and P.U. Code section 740.3 calls for the Commission to

“implement policies to promote the development of equipment and infrastructure needed to

facilitate the use of electric power and natural gas to fuel low-emission vehicles.” However,

these policies must be in the ratepayer’s interests as defined in P.U. Code section 740.8: “direct

benefits that are specific to ratepayers in the form of safer, more reliable, or less costly …

electrical service … and activities that benefit ratepayers and that promote energy efficiency,

Continued from the previous page

http://www.slideshare.net/CALSTART/workplace-charging-google-by-rolf-schreiber-technical-program-manager-electric-transportation-initiatives-july-31-2012 [as of August 29, 2014].

35 Brandon White for Nissan, presentation for Breakout Session A2: Taking the “Work” Out of Workplace Charging, Plug-in 2014, San Jose, CA, July 29, 2014.

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reduction of health and environmental impacts from air pollution, and greenhouse gas emissions

related to electricity … production and use, and increased use of alternative fuels.”36

Ways that ratepayers can benefit from an acceleration of EV adoption include:

PEVs and other types of AFVs are very flexible loads that can address

existing grid issues as well as future issues regarding integrating large

amounts of intermittent renewable energy into the grid.37 As a result, EV

market acceleration can provide a more reliable electric service, enhance

resource utilization, and optimize grid operation.

EV load also provides a downward pressure on electric rates for all ratepayers

by contributing net revenue as shown by ICF International and E3 in the

recent California Transportation Electrification Assessment (TEA study).38

PEV and other types of AFV load provide substantial reductions in

greenhouse gases, criteria air pollutants and petroleum as shown in the many

tables in the TEA study. These benefits also provide economic value to all

ratepayers and to individual vehicle owners.39

36 Pub. Util. Code § 740.8. 37 Energy Division Staff White Paper, “Vehicle-Grid Integration: A Vision for Zero-Emission

Transportation Interconnected throughout California's Electricity System,” October 2013. See also “California Vehicle-Grid Integration (VGI) Roadmap: Enabling vehicle-based grid services,” February 2014, available at http://www.caiso.com/Documents/Vehicle-GridIntegrationRoadmap.pdf [as of August 29, 2014].

38 “California Transportation Electrification Assessment, Phase 1: Final Report” supra, Section 4, p. 39 (“Volumetric rates include both fixed and variable utility costs for delivering electricity to retail customers. The analysis in Phase 2 will show the revenue from PEV charging will exceed the marginal cost of generation to serve the load and the additional costs incurred by the utility to serve PEV load even under the ‘worst-case’ assumptions for grid impacts. We also will show that the GHG reductions from reduced gasoline consumption exceed the emissions associated with increased electricity generation. With the shift to off-peak, retail rate revenue is reduced as compared to an unmanaged scenario. The cost of supplying and delivering electricity is also reduced. Across a wide range of scenarios studied, net revenues are still positive with managed charging, but tend to be lower than the unmanaged scenario. Managed charging also reduces the costs to the state as a whole of serving PEV load.”).

39 Id., Sections 2 and 3, and related appendices.

15

The Commission has concluded that it is essential to accelerate EV adoption

to support reduction of greenhouse gas emissions and meet other state and

national goals.40 The task of EV market transformation to meet the state and

national goals is daunting and temporary utility involvement to accelerate

charging infrastructure deployment outside of single-family homes is needed.

Utilities are in a unique position to provide EV infrastructure to facilitate

acceleration of EV adoption, including the charging station or electricity delivery system:

Utilities have proven experience in facilitating market transformation to

support state policies (e.g., energy efficiency and other demand-side

management, renewables) by providing the scale needed to improve the

situation in the short term, especially where the nascent market suffered from

high costs, market barriers, and other issues.

Because utilities operate the distribution grid and enable or provide demand-

side management, utilities can help deploy EV infrastructure to the best

locations with optimal utilization. Utilities are already exploring these issues

in response to AB 327, which requires planning for EVs as a distributed

resource.41

Utilities, as a fuel distributor for EVs, are a natural fit for this role and our

customers have looked to us for advice and solutions regarding EV charging.

Limited utility involvement to accelerate the EV infrastructure market can

improve the business case for third parties. Through competitive solicitations, utilities can use

third parties to provide services such as installation, maintenance, or equipment. The scale of a

utility program to accelerate infrastructure development in underserved markets would provide

revenue streams to third parties. In addition, utility involvement over a few years would provide

40 See D.11-07-029, p. 68. 41 Pub. Util. Code § 769 (a) includes electric vehicles in the definition of distributed resources.

16

important stability to the market, which would benefit third-party participants. Finally, the

Commission has the authority to determine when and how to scale back utility involvement over

time.42

The definition of “EV infrastructure” should not stop at the “make-ready stub,”

but should also include the entire charging station or energy delivery system. The Scoping

Ruling considers this when it refers to both “make-ready stub” installation and “other proposals

for how the utility may better serve [the charging] market segments.”43 SCE recommends that

the Commission broadly define “EV infrastructure” to encourage creative proposals from the

utilities that not only enable accelerated penetration of EVs in California, but also seek to use EV

charging load to better integrate intermittent resources and enable demand response. The

Commission can decide the merits of specific applications for programs and funding in those

separate application proceedings.

“EV infrastructure” should also include fleet44 charging sites and other charging

locations where vehicles are parked for long periods (long-dwell-time charging locations), and

not just infrastructure at multi-unit dwellings and workplaces.45 As discussed above, all long-

dwell-time locations outside of single-family residences are vital markets that are not developing

at the needed pace.46

42 “California Transportation Electrification Assessment, Phase 1: Final Report” supra, Section 5.3.2, p. 58 (“If utilities were authorized to undertake and committed to implementing initiatives that help bridge critical gaps and barriers, competiveness in the marketplace could not only be preserved, but even encouraged by the resulting increased demand for charging products and services. This would probably be welcome news for a sector that has seen several prominent players file for bankruptcy in recent months.”).

43 Scoping Ruling, p. 9. 44 Including light-, medium-, and heavy-duty electric vehicles. 45 Scoping Ruling, pp. 8-9, focuses on multi-unit dwellings and workplace market segments. 46 Decisions addressing utility involvement in EV infrastructure should clarify that they are not limited

to particular technologies, and apply broadly to light-, medium-, and heavy-duty electric vehicles, as well as non-road vehicles and equipment. The Commission should allow utilities to provide infrastructure to serve all types of charging needs without creating a complex situation with potentially conflicting requirements or restrictions for different types of EVs.

17

E. SCE Plans To Propose A Charging Infrastructure Program

SCE is currently developing a proposal to install SCE-owned charging

infrastructure at long-dwell-time locations outside of single-family homes (e.g., workplaces,

campuses, fleets, multi-unit dwellings, destination centers).47 SCE plans to file an application in

October 2014 to request Commission approval of the proposal. The upcoming application will

describe SCE’s plan to install utility-owned charging stations and supporting infrastructure

through a limited-duration program aimed at rapidly improving customers’ ability to charge EVs

away from a single-family home. SCE plans to select multiple electric vehicle supply equipment

(EVSE) providers to participate in the program through a competitive solicitation process to

supply Level 1 and Level 2 stations with a variety of features. To preserve customer choice,

SCE anticipates offering multiple types of charging stations and features to the site host. SCE

anticipates that customers will engage third-party services to operate the stations. SCE also

plans to require some level of demand-side management as a condition for participation in this

program.

SCE requests that the Commission clarify in the November proposed decision that

utilities are allowed to submit proposals to deploy and own charging infrastructure, up to and

including the charging station, at underserved locations outside of single-family homes.

Authorization for specific deployment programs should come through separate utility

applications, such as the one SCE intends to file soon, or through future General Rate Cases.

47 Customers or third parties would be responsible for operating and maintaining the charging stations in SCE’s proposal.

18

3. What education and outreach activities must the utilities provide to support

further customer PEV adoption? What existing resources are available for these activities

and what additional resources are needed?

A. SCE’s Current Education And Outreach Is Effective Within The Limited

Framework Previously Authorized By The Commission

In accordance with Decision 11-07-029,48 SCE provides residential and non-

residential customers with useful information about PEV readiness, including available rates and

metering arrangements through its website. SCE has developed a number of tools and content to

assist its customers, including an online rate assistant, a new decision tool for multi-family

dwellings, and guides for electricians to install PEV charging stations at residential, commercial,

and multi-family properties. SCE also uses online advertising through display banners on third

party websites and search engines to target potential PEV buyers in its service territory.49

In 2013, SCE hired an independent vendor to conduct a survey of residential

customers who owned a PEV, but who had not contacted SCE to switch to a PEV time-of-use

(TOU) rate. The survey showed that 74% of the respondents had become aware of SCE’s PEV

TOU rates through SCE’s website or an SCE customer representative (call center), with the

balance of respondents becoming aware of the rates through PEV dealers and manufacturers.50

SCE also conducts a number of other education and outreach activities, including

supporting non-residential customers interested in deploying charging infrastructure through its

48 D.11-07-029, p. 68. 49 For instance, a customer who searches for information about PEVs within SCE’s service territory

may be exposed to an SCE ad about the availability of special rates for charging PEVs. The ad directs the internet user to the relevant content on SCE’s website. The same individual would not see any ads if running the same search outside of the service territory or if looking for information pertaining to vehicles with an internal combustion engine (ICE).

50 The findings from the survey also contributed to improving attractiveness of the current Schedule TOU-D-TEV with the proposed whole-house Schedule TOU-D rate included in SCE's Application for Approval of its 2013 Rate Design Window Proposals filed with the Commission on December 24, 2013 (A.13-12-015).

19

PEV Center of Expertise, or participating at targeted events, such as National Plug-In Week.

Finally, through an arrangement with the Center for Sustainable Energy, SCE provides an

opportunity for applicants to the Clean Vehicle Rebate Project to learn more about PEV rates and

notify the utility about the residential charging location of their new PEV.

Accordingly, SCE recommends that the Commission continue to approve on-

going PEV education and outreach efforts, as requested through SCE’s General Rate Case, Phase

1. In addition, educating its customers on the benefits provided by the new TOU rates under the

Commission’s review in SCE’s unopposed settlement of its2013 Rate Design Window

application,51 once approved, will be critical to increasing TOU adoption by EV owners and

other residential customers.

B. The Current Restrictions Limit SCE’s Ability To Conduct Broad Education

And Outreach To Support EV Adoption

In Decision 11-07-029, the Commission directed the IOUs to communicate

environmental and societal benefits of EVs as a result of “the state’s policy goals related to the

reduction of greenhouse gas emissions set forth in AB 32.”52 SCE provides such communication

to its customers through a dedicated section of its website.53 The Commission, however,

restricted the ability of the IOUs to communicate these messages to the so-called “upper

purchase funnel” customers (when awareness about a product or service is developed) and

instead “target customers with an interest in Electric Vehicles.”54 Similarly, the IOUs may not

conduct “mass marketing efforts.”55 As a result, IOUs are currently precluded from launching

broad awareness campaigns about EVs and the benefits of fueling from the grid. SCE, like other

51 A.13-12-015. 52 D.11-07-029, p. 68. 53 See www.sce.com >> Your Home >> Electric Vehicles >> Benefits, available at http://goo.gl/7kJeNo

[as of August 29, 2014]. 54 D.11-07-029, p. 65. 55 D.11-07-029, p. 65.

20

IOUs, can only communicate the benefits of EVs to potential EV buyers who are already

interested in EVs, rather than to the larger group of potential vehicle buyers who may not yet

have considered buying an EV and may not know about the many benefits provided by EVs.

We commend the Commission for revisiting these issues in this proceeding, now

that we know more about market conditions, four years after the launch of the first PEVs. SCE

believes that it is now time for the Commission to “revisit the parameters of utility Electric

Vehicle education programs in response to new market conditions and revise these guiding

principles and requirements accordingly,” as anticipated in Decision 11-07-029.

C. Improving Awareness About EVs Is Critical To Sustainable And

Widespread Adoption

Many studies have demonstrated that developing broad awareness about EVs and

the benefits of fueling from the grid constitutes one of the most important drivers to increasing

EV adoption and growing the EV market significantly.56 Unfortunately, surveys have shown

low awareness about all types of EV benefits (individual, societal, and environmental) and the

difference between a battery EV and a plug-in hybrid EV.57

As proposed by SCE in its response to Question 2 above, achieving state policy

goals will require more education and outreach efforts from all stakeholders. The major

decarbonization efforts under way in California require an uncompromised and unequivocal

support of PEVs and other ultra-low-carbon AFVs. As discussed above, expanded utility efforts

56 E.g., “Overcoming Barriers to Electric-Vehicle Deployment: Interim Report,” National Research Council, The National Academies Press, 2013, p. 15.

57 See “California Transportation Electrification Assessment, Phase 1: Final Report” supra, p. 59 (“Navigant reports that the awareness for EVs other than the LEAF and Volt among survey respondents is less than 25%. Even with the Volt and LEAF, only 44% and 31% were extremely familiar or somewhat familiar with these vehicles, respectively. Disappointingly, the numbers from Navigant’s 2013 survey are not too dissimilar from those reported in a 2010 survey by Ernst & Young. Ernst & Young found that 62% of respondents had never heard of PHEV technology or have heard of it but don’t know what it is. Similarly, 40% of respondents have never heard of PEV technology or have heard of it but don’t know what it is.”).

21

to accelerate EV market transformation such as expanded education and outreach programs need

to go beyond light-duty PEVs. The utilities are in a unique position to further education and

outreach efforts about EVs and the benefits of fueling from the grid.

SCE makes the following recommendations and urges the Commission to adopt

revised rules accordingly:

- The Commission should authorize the IOUs to launch new EV education

campaigns, coordinated among stakeholders, to improve awareness of

"Electricity as Fuel, The Vehicle Battery and Charging, Driving and

Ownership Experience," as recommended by the National Research Council.

- The Commission should remove any prior prohibition of using "mass

marketing" and authorize IOUs to use any relevant communication channels,

including broad reach media, to develop EV awareness.

- The Commission should adopt a consistent policy for education and outreach

for all types and sizes of transportation electrification.

- Finally, the Commission should allow for incremental education and outreach

funding for the new awareness campaigns, as the IOUs may request in

separate filings or through their General Rate Cases.

SCE believes that the foregoing recommendations are essential to support the

growth of the EV market and achieve California’s greenhouse gas policy objectives.

4. How should the Commission mitigate the impact of demand charges, if at all,

on entities pursuing transportation electrification?

A. Demand Charges Align With Rate Design Principles And Prior Commission

Guidance.

SCE cautions the Commission not to pre-judge demand charges as a barrier to

transportation electrification. Demand charges are a method to appropriately recover capacity

22

and demand components of utility costs to help align rates with cost-causation and marginal cost

principles, which the Commission has long promoted in rate design proceedings, including in

D.96-04-050.58

According to the VGI White Paper, achieving the Governor’s state target of 1.5

million zero-emission vehicles by 2025 may mean up to 10GW of additional load for the

California system.59 If this load were to occur simultaneously on peak, then it would be costly to

provide sufficient generation and transmission and distribution (T&D) capacity to meet this

need.60 To manage ratepayer costs, the Commission should strive to encourage technologies and

business models that would be viable under existing cost-based price constructs, which send

technology- and business-model-neutral signals to the market to facilitate load shifting that

benefits the grid.

58 D.96-04-050, mimeo, p. 17 (“Since 1981, this Commission has used marginal cost principles to allocate the revenue requirement and to guide the design of specific rates. ‘Marginal cost’ is an economic concept which refers to the change in total costs resulting from a change in unit output. A unit of output may be a kilowatt (kW), a kWh, or a customer month. Marginal costs are forward looking and include estimates of future operation or investment costs due to load growth. The marginal costs of electricity are divided into three components: energy, capacity or demand, and customer-related. This Commission has relied on marginal cost principles in order to simulate, to the extent possible, the pricing structure and resulting efficient resource allocation of a competitive market. As described in Attachment 3, the cost of the last (or marginal) unit exchanged in a competitive market sets the welfare-maximizing level of price and output in the market. At that price, buyers and sellers will make the most efficient tradeoffs between the consumption of electricity and other goods and services.”).

59 See California Energy Commission Staff Final Report, “California Energy Demand 2012-2022 Final Forecast, Volume 1: Statewide Electricity Demand and Methods, End-User Natural Gas Demand, and Energy Efficiency,” May 2012. P. 39, Table 1-10, available at http://www.energy.ca.gov/2012publications/CEC-200-2012-001/CEC-200-2012-001-SF-V1.pdf [as of August 29, 2014].

60 For example, a recent SMUD paper found that the difference in T&D costs between charging at 1.4 kW and 9.6 kW in a residential setting was $1011. Jeff Berkheimer, et al., “Electric Grid Integration Costs for Plug-In Electric Vehicles,” SAE Int. J. Alt. Power., May 2014 3:1-11. This was also included in Deepak Aswani’s presentation for the seminar The Economics of Vehicle-Grid Integration – Costs, Benefits & the Evolving Market, Plug-in 2014, San Jose, CA, July 28, 2014.

23

B. Many Technologies And Business Models Allow Entities Pursuing

Transportation Electrification To Lower Their Peak Demand. The

Commission Should Allow The Market To Respond To Demand Charges.

The Commission should encourage the market to create innovative technologies

or business models that help facilities appropriately manage demand charges. Currently, entities

pursuing transportation electrification have many charging station options that help lower their

peak demand. For example, Level 1 chargers have a lower peak demand compared to Level 2,

and Level 2 chargers have a lower demand than DC fast chargers. Some multi-port (e.g., dual-

port or quad-port) charging stations, equipped with “smart” technology, can sequence the

charging between vehicles so that the load does not show up simultaneously or split and share

the load as more PEVs begin to use the multi-port charging station. Customers can install on-site

renewable electric generation facilities (e.g., carports mounted with solar PV) or storage

technologies to help reduce peak demand. Customers can also encourage charging before mid-

day peaks or have the charging stations managed as part of a facility’s energy management

system.

The Commission should allow different electric transportation technologies and

business models to respond to market needs in the transportation services industry. Various

electric technologies can actually provide the same transportation service. For example, electric

trucks and buses can use overhead wire (catenary), roadway power, battery switch, DC fast

charging, or evening nighttime charging (Level 2) to provide transportation services. However,

each of those technology options would have a different impact on the demand charge. Business

models also respond to demand charges in different ways. For example, some PEV businesses

offer free charging or the cost of charging is embedded within the purchase price of the PEV.61

These methods showcase a few of the many different ways in which businesses have adapted to

61 For example, Tesla superchargers.

24

demand charges. The Commission should continue to encourage the market to bring creative

new technologies and business models to customers to respond to demand charges.

C. The Commission May Need A Workshop Or A Study Regarding Use Cases

On Demand Charges To Determine If Any New Demand Charge Strategies

Are Needed.

The Scoping Ruling states that several parties have indicated that demand charges

are a barrier for EV adoption; however, evaluation of this issue requires development of a record

before determining what action, if any, is needed. For example, EPRI at a recent CARB

workshop illustrated the difference between low and high daily utilization in their very

informative Demand Charges 101 presentation.62 SCE discussed above a few examples of

options that enable customers to manage their demand charges (e.g., lower-level charging, multi-

port chargers). SCE recommends that the Commission host a workshop to discuss these issues

further in the broader context of the guiding principles discussed above.

5. How should the Commission identify and consider in this proceeding best

practices achieved and lessons learned from current AFV pilot project results?

The IOUs served a Joint Statement of Related Proceedings that identified current

pilots related to this proceeding and associated reporting requirements.63 SCE’s EV pilots are

still in planning or pre-launch mode and lessons learned and best practices cannot be analyzed

until implementation is completed. SCE recommends that the Commission use these reports

described in the Joint Statement of Related Proceedings to the extent best practices and lessons

learned can be used to inform the issues being addressed in this proceeding.

62 Marcus Alexander for the Electric Power Research Institute, presentation for Breakout Session B3: Environmental Impact: The Role of PEVs in a Changing Energy System, Plug-In 2014, San Jose, CA, July 30, 2014.

63 “Joint IOU Proceedings Inventory,” served on the service list for this proceeding on June 13, 2014.

25

III.

CONCLUSION

SCE appreciates the opportunity to provide these comments in response to the Scoping

Ruling and Memo.

Respectfully submitted, JANET S. COMBS ANDREA L. TOZER

/s/ Andrea L. Tozer By: Andrea L. Tozer

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1524 Facsimile: (626) 302-6693 E-mail: [email protected]

August 29, 2014


STATE OF CALIFORNIA

Order Instituting Rulemaking to Consider Alternative-Fueled Vehicle Programs, Tariffs, and Policies.

)) )

Rulemaking 13-11-007 (Filed November 14, 2013)

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 SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) COMMENTS ON ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING on all parties identified on the attached service list(s) R.13-11-007. 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 by

hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s).

ALJ Irene K. Moosen CPUC 505 Van Ness Avenue San Francisco, CA 94102

☐ Placing copies in properly addressed sealed envelopes and depositing such copies in the

United States mail with first-class postage prepaid to all parties for those listed on the attached non-email list.

Executed this August 29, 2014, at Rosemead, California.

/s/ Christopher A. Stephens_____________________ Christopher A. Stephens Project Analyst

SOUTHERN CALIFORNIA EDISON COMPANY

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

PROCEEDING: R1311007 - CPUC - OIR TO CONSID FILER: CPUC LIST NAME: LIST LAST CHANGED: AUGUST 28, 2014

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JAMIE HALL JEREMY WAEN CALSTART REGULATORY ANALYST EMAIL ONLY MARIN CLEAN ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY FOR: CALSTART EMAIL ONLY, CA 00000 FOR: MARIN ENERGY AUTHORITY JOHN W. LESLIE, ESQ. SEAN P. BEATTY ATTORNEY REGIONAL GENERAL COUNSEL - WEST MCKENNA LONG & ALDRIDGE LLP NRG ENERGY, INC, EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: SHELL ENERGY NORTH AMERICA FOR: NRG ENERGY, INC. KENNETH SAHM WHITE SCOTT FISHER DIRECTOR, ECONOMIC & POLICY ANALYSIS NRG EV2G LLC CLEAN COALITION 211 CARNEGIE CENTER EMAIL ONLY PRINCETON, NJ 08540 EMAIL ONLY, CA 00000-0000 FOR: NRG EV2G LLC FOR: CLEAN COALITION JULIA M. REGE KEVIN MATTHEWS DIR - ENVIRONMENTAL & ENERGY MANAGING DIRECTOR ASSOCIATION OF GLOBAL AUTOMAKERS, INC. NSI, LLC 1050 K ST., NW, STE. 650 1400 EYE ST., N.W., STE. 900 WASHINGTON, DC 20001 WASHINGTON, DC 20005 FOR: ASSOCIATION OF GLOBAL AUTOMAKERS, FOR: CLINTON GLOBAL INITIATIVE EV V2G/B

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INC. SCHOOL BUS DEMONSTRATIN PROJECT ERIC MCCARTHY STEVEN D. PATRICK PROTERRA INC. SENIOR COUNSEL 1 WHITLEE COURT SOUTHERN CALIFORNIA GAS COMPANY GREENVILLE, SC 29607 555 WEST 5TH STREET, GT14E7 FOR: PROTERRA INC. LOS ANGELES, CA 90013-1011 FOR: SOUTHERN CALIFORNIA GAS COMPANY ALEXANDER KEROS MAX BAUMHEFNER ADVANCED VEHICLE & INFRASTRUCTURE POLICY LEGAL FELLOW GENERAL MOTORS, LLC NATURAL RESOURCES DEFENSE COUNCIL 3050 LOMITA BLVD. 111 SUTTER ST., 20TH FLOOR TORRANCE, CA 90505 SAN FRANCISCO, CA 91404 FOR: GENERAL MOTORS FOR: NATURAL RESOURCES DEFENSE COUNCIL (NRDC) ANDREA TOZER DONALD C. LIDDELL, PC SOUTHERN CALIFORNIA EDISON COMPANY COUNSEL 2244 WALNUT GROVE AVE./PO BOX 800 DOUGLASS & LIDDELL ROSEMEAD, CA 91770 2928 2ND AVENUE FOR: SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO, CA 92103 FOR: CALIFORNIA ENERGY STORAGE ALLIANCE SACHU CONSTANTINE STEVE RAHON DIRECTOR OF POLICY DIR - TARIFF & REGULATORY ACCTS CENTER FOR SUSTAINABLE ENERGY SAN DIEGO GAS & ELECTRIC COMPANY 9325 SKY PARK COURT, SUITE 100 8330 CENTURY PARK COURT, CP32C SAN DIEGO, CA 92123 SAN DIEGO, CA 92123-1548 FOR: CENTER FOR SUSTAINABLE ENERGY FOR: SAN DIEGO GAS & ELECTRIC COMPANY MICHAEL CHIACOS ROBERT GNAIZDA ENERGY AND TRANSPORTATION MANAGER COUNSEL COMMUNTI ENVIRONMENTAL COUNCIL NATIONAL ASIAN AMERICAN COALITION 26 W. ANAPAMU ST., 2ND FLR. 15 SOUTHGATE AVE., STE 200 SANTA BARBARA, CA 93101 DALY CITY, CA 94015 FOR: COMMUNITY ENVIRONMENTAL COUNCIL FOR: JOINT MINORITY PARTIES: NATIONAL ASIAN AMERICAN COALITION, ECUMENICAL CENTER FOR BLACK CHURCH STUDIES, JESSE MIRANDA CENTER FOR HISPANIC LEADERSHIP, AND LOS ANGELES LATINO CHAMBER OF COMMERCE (FORMERLY THE LATINO BUSINESS CHAMBER OF GREATER LOS ANGELES). LISA-MARIE SALVACION MARCEL HAWIGER CALIF PUBLIC UTILITIES COMMISSION ENERGY ATTORNEY LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM 5029 785 MARKET ST., STE. 1400 505 VAN NESS AVENUE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-3214 FOR: THE UTILITY REFORM NETWORK (TURN) FOR: ORA NICOLE JOHNSON CHRISTOPHER J. WARNER REGULATORY ATTORNEY PACIFIC GAS AND ELECTRIC COMPANY CONSUMER FEDERATION OF CALIFORNIA LAW DEPT.



433 NATOMA ST., STE. 210 77 BEALE STREET, MC B30A, RM 3145 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94105 FOR: CONSUMER FEDERATION OF CALIFORNIA FOR: PACIFIC GAS & ELECTRIC EVELYN KAHL JILL E. YUNG ATTORNEY AT LAW PAUL HASTINGS, LLP ALCANTAR & KAHL, LLP 555 SECOND ST., 24TH FLR. 33 NEW MONTGOMERY ST., STE. 1850 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: VOTE SOLAR INIATIVE FOR: CLEAN ENERGY FUELS CORPORATION LARISSA KOEHLER PAUL STITH ATTORNEY LEGISLATIVE & POLICY ADVOCATE ENVIRONMENTAL DEFENSE FUND PLUG IN AMERICA 123 MISSION STREET, 28TH FLOOR 2370 MARKET ST., STE. 419 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94114 FOR: ENVIRONMENTAL DEFENSE FUND FOR: PLUG IN AMERICA SARA STECK MYERS JOHN M. CUMMINS ATTORNEY AT LAW FEDERAL EXECUTIVE AGENCIES LAW OFFICES OF SARA STECK MYERS 1 AVENUE OF THE PALMS, SUITE 161 122 - 28TH AVENUE SAN FRANCISCO, CA 94130 SAN FRANCISCO, CA 94121 FOR: FEDERAL EXECUTIVE AGENCIES (FEA) FOR: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE TECHNOLOGIES (CEERT) BRIAN CHERRY PAUL STITH PACIFIC GAS AND ELECTRIC COMPANY DIR., BUS. DEVELOPMENT & REG. AFFAIRS PO BOX 770000, B10C EV GRID, INC SAN FRANCISCO, CA 94177 809 SAN ANTONIO ROAD FOR: PACIFIC GAS AND ELECTRIC COMPANY PALO ALTO, CA 94303 FOR: EV GRID, INC. LAWRENCE G. CHASET ANDY KATZ ATTORNEY SIERRA CLUB CALIFORNIA KEYES FOX & WIEDMAN LLP 2150 ALLSTON WAY, STE. 400 416 14TH STREET, STE. 1305 BERKELEY, CA 94704 OAKLAND, CA 94612 FOR: SIERRA CLUB FOR: INTERSTATE RENEWABLE ENERGY COUNCIL (IREC) GREGORY MORRIS ROMAN PARTIDA DIRECTOR THE GREENLINING INSTITUTE GREEN POWER INSTITUTE 1918 UNIVERSITY AVENUE, 2ND FLOOR 2039 SHATTUCK AVE., SUITE 402 BERKELEY, CA 94704 BERKELEY, CA 94704 FOR: THE GREENLINING INSTITUTE FOR: THE GREEN POWER INSTITUTE COLLEEN QUINN JESSICA ZENK VP - GOV'T. RELATIONS AND PUBLIC POLICY SILICON VALLEY LEADERSHIP GROUP CHARGEPOINT, INC 2001 GATEWAY PLACE, SUITE 101E 1692 DELL AVENUE SAN JOSE, CA 95110 CAMPBELL, CA 95008 FOR: SILICON VALLEY LEADERSHIP GROUP FOR: CHARGEPOINT, INC.



ANDREW ULMER STEVEN P. DOUGLAS DIR - FED REGULATORY AFFAIRS ALLIANCE OF AUTOMOBILE MANUFACTURERS CALIFORNIA ISO 1415 L STREET, STE. 1190 250 OUTCROPPING WAY SACRAMENTO, CA 95814 FOLSOM, CA 95630-8773 FOR: ALLIANCE OF AUTOMOBILE FOR: CALIFORNIA INDEPENDENT SUSYTEM MANUFACTURERS OPERATOR (CAISO) WILLIAM W. WESTERFIELD, III SENIOR ATTORNEY SACRAMENTO MUNICIPAL UTILITY DISTRICT 6201 S STREET, MS B406 SACRAMENTO, CA 95817 FOR: SACRAMETNO MUNICIPAL UTILITY DISTRICT (SMUD)

BARBARA R. BARKOVICH CASE COORDINATION BARKOVICH & YAP, INC. PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 CASSANDRA YAMASAKI CATHERINE TARASOVA NATIONAL ASIAN AMERICAN COALITION SR. REGULATORY CASE MANAGER EMAIL ONLY PACIFIC GAS & ELECTRIC COMPANY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 DAVID REICHMUTH, PHD. DIANE FELLMAN SR. ENG'R. - CLEAN VEHICLES PROGRAM DIR - GOVERNMENTAL & REGULATORY AFFAIRS UNION OF CONCERNED SCIENTISTS NRG ENERGY, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 DON ANAIR ED PIKE EMAIL ONLY ENERGY SOLUTIONS EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 JESSICA TSANG KATY ROSENBERG SR. PRODUCT MANAGER, ELECTRIC VEHICLES ALCANTAR & KAHL PACIFIC GAS & ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 MATTHEW BARMACK MATTHEW PLUMMER DIRECTOR, MARKET & REGULATORY ANALYST STATE AGENCY REGULATIONS CALPINE CORPORATION PACIFIC GAS AND ELECTRIC COMPANY EMAIL ON LY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

Information Only



MCE REGULATORY MELISSA P. MARTIN MARIN CLEAN ENERGY SENIOR REGULATORY COUNSEL EMAIL ONLY STATESIDE ASSOCIATES EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, VA 00000 PAUL HERNANDEZ RACHEL GOLD CENTER FOR SUSTAINABLE ENERGY POLICY DIRECTOR EMAIL ONLY LARGE-SCALE SOLAR ASSOCIATION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 RENEE C. SAMSON SEPHRA A. NINOW PACIFIC GAS & ELECTRIC COMPANY REGULATORY AFFAIRS MGR. EMAIL ONLY CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 STEPHANIE WANG STEVE HAERTLE POLICY DIRECTOR & ATTORNEY PACIFIC GAS AND ELECTRIC COMPANY CLEAN COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 TAM HUNT TED KO ATTORNEY COMPLETE SOCIETY CONSULTING HUNT CONSULTING EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: THE GREEN POWER INSTITUTE VIDHYA PRABHAKARAN MRW & ASSOCIATES, LLC ATTORNEY EMAIL ONLY DAVIS WRIGHT & TREMAINE, LLP EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 DAVIS WRIGHT TREMAINE, LLP KAREN TERRANOVA EMAIL ONLY ALCANTAR & KAHL EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000-0000 TAM HUNT ANDREW LEVITT COMMUNITY RENEWABLES SOLUTIONS, LLC NRG EV2G EMAIL ONLY 211 CARNEGIE CENTER EMAIL ONLY, CA 00000-0000 PRINCETON, NJ 08540 ELLEN GLEBERMAN JULIE BECKER ASSOCIATION OF GLOBAL AUTOMAKERS, INC. ALLIANCE OF AUTOMOBILE MANUFACTURERS 1050 K ST. NW, SUITE 650 803 7TH STREET, N.W., STE. 300 WASHINGTON, DC 20001 WASHINGTON, DC 20001



KHOJASTEH DAVOODI JEFFREY SALAZAR NAVY ACQ-UTILITY RATES & STUDIES OFFICE SOUTHERN CALIFORNIA GAS COMPANY DEPT OF THE NAVY, FACILITIES ENGINEERING 555 WEST FIFTH STREET, GT14D6 1322 PATTERSON AVE., SE - BLDG NO. 33 LOS ANGELES, CA 90013 WASHINGTON NAVY YARD, DC 20374-5018 MIKE FRANCO RASHA PRINCE SOUTHERN CALIFORNIA GAS COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 555 W. FIFTH STREET, GT14D6 555 WEST 5TH STREET, GT14D6 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013 THERESA MARTINEZ BEAUDRY KOCK CEO VP - SMART GRID LOS ANGELES LATINO BUSINESS CHAMBER RECARGO INC. 634 S. SPRING STREET, SUITE 600 1015 ABBOT KINNEY BLVD. LOS ANGELES, CA 90014 VENICE, CA 90291 FOR: RECARGO INC. JESSALYN ISHIGO RYAN HARTY AMERICAN HONDA MOTOR CO., INC. AMERICAN HONDA MOTOR CO., INC.-EBD OFF. 1919 TORRANCE BLVD. 1919 TORRANCE BLVD., MS 100-3W-5E TORRANCE, CA 90501 TORRANCE, CA 90501 ANNA CHING CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. 2244 WALNUT GROVE AVENUE / PO BOX 800 ROSEMEAD, CA 91770 ROSEMEAD, CA 91770 JANET COMBS CENTRAL FILES SR. ATTORNEY SDG&E/SOCALGAS SOUTHERN CALIFORNIA EDISON COMPANY 8330 CENTURY PARK COURT, CP31-E 2244 WALNUT GROVE AVENUE SAN DIEGO, CA 92123 ROSEMEAD, CA 91770 PARINA P. PARIKH REBECCA W. GILES REGULATORY CASE MGR. REGULATORY CASE MANAGER SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP 32D 8330 CENTURY PARK COURT, CP32-D SAN DIEGO, CA 92123 SAN DIEGO, CA 92123 MARK E. WHITLOCK, JR. REV. FERNANDO TAMARA EXE. DIR. PASTOR ECUMENICAL CTR. FOR BLACK CHURCH STUDIES J. MIRANDA CTR. FOR HISPANIC LEADERSHIP 46 MAXWELL ST 55 FAIR DRIVE IRVINE, CA 92618 COSTA MESA, CA 92626 FOR: JESSE MIRANDA CENTER FOR HISPANIC LEADERSHIP GEORGE BELLINO STEPHEN G. DAVIS GENERAL MOTORS KNGRID, LLC 19071 CHANDON LANE 26602 DAPPLE GREY DRIVE HUNTINGTON BEACH, CA 92648 LAGUNA HILLS, CA 92653-5710 FOR: KNGRID, LLC



PAUL KERKORIAN AARON LEWIS ATTORNEY AT LAW COUNSEL 6475 N PALM AVE., STE. 105 NATIONAL ASIAN AMERICAN COALITION FRESNO, CA 93704 15 SOUTHGATE AVENUE, SUITE 200 DALY CITY, CA 94015 FAITH BAUTISTA IRYNA KWASNY PRESIDENT & CEO CALIF PUBLIC UTILITIES COMMISSION NATIONAL ASIAN AMERICAN COALITION LEGAL DIVISION 15 SOUTHGATE AVE., STE. 200 ROOM 4107 DALY CITY, CA 94015 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 AUSTIN M. YANG DONALD P. HILLA DEPUTY CITY ATTORNEY SR. REGULATORY COUNSEL CITY AND COUNTY OF SAN FRANCISCO CONSUMER FEDERATION OF CALIFORNIA OFFICE OF THE CITY ATTORNEY, RM. 234 433 NATOMA STREET, STE. 200 1 DR. CARLTON B. GODDLETT PLACE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-4682 JIM BAAK MATTHEW VESPA DIR - POLICY FOR UTILITY-SCALE SOLAR SR ATTORNEY THE VOTE SOLAR INITIATIVE SIERRA CLUB 101 MONTGOMERY ST., STE. 2600 85 SECOND ST,, 2ND FL SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94105 STEVE CHADIMA URIC KWAN ADVANCED ENERGY ECONOMY MANAGER 135 MAIN ST., STE. 1320 PACIFIC GAS & ELECTRIC COMPANY SAN FRANCISCO, CA 94105 245 MARKET STREET, MC N3F SAN FRANCISCO, CA 94105 ARTHUR L. HAUBENSTOCK ROBERT GEX PERKINS COIE LLP DAVIS WRIGHT TREMAINE LLP FOUR EMBARCADERO CENTER, STE. 2400 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 BRIAN ORION CALIFORNIA ENERGY MARKETS LAWYERS FOR CLEAN ENERGY 425 DIVISADERO ST STE 303 656A CLAYTON STREET SAN FRANCISCO, CA 94117-2242 SAN FRANCISCO, CA 94117 MEGAN M. MYERS RITA LIOTTA LAW OFFICES OF SARA STECK MYERS FEDERAL EXECUTIVE AGENCIES 122 - 28TH AVENUE 1 AVENUE OF THE PALMS, STE. 161 SAN FRANCISCO, CA 94121 SAN FRANCISCO, CA 94130 ERIC HUFFAKER SCOTT J. RAFFERTY OLIVINE, INC. 1913 WHITECLIFF CT. 2010 CROW CANYON ROAD, SUITE 100 WALNUT CREEK, CA 94596 SAN RAMON, CA 94583



GERALD LAHR SKY STANFIELD ENERGY PROGRAMS MGR. KEYES, FOX & WIEDMAN LLP ASSOCIATION OF BAY AREA GOVERNMENTS 436 14TH ST., STE. 1305 101 8TH ST. OAKLAND, CA 94612 OAKLAND, CA 94607 FOR: INTERSTATE RENEWABLE ENERGY COUNCIL (IREC) GREGG MORRIS VIEN TROUNG DIRECTOR ENVIRONMENTAL EQUITY DIRECTOR GREEN POWER INSTITUTE THE GREENLINING INSTITUTE 2039 SHATTUCK AVENUE, STE 402 1918 UNIVERSITY AVENUE, 2ND FLOOR BERKELEY, CA 94704 BERKELEY, CA 94704 PHILLIP MULLER PAUL STITH PRESIDENT SUM / PROJECT GREEN ONRAMP SCD ENERGY SOLUTIONS 5610 SCOTTS VALLEY DRIVE, NO. 454 436 NOVA ALBION WAY SCOTTS VALLEY, CA 95066 SAN RAFAEL, CA 94903 C. SUSIE BERLIN DOUGLAS M. GRANDY, P.E. LAW OFFICES OF SUSIE BERLIN CALIFORNIA ONSITE GENERATION 1346 THE ALAMEDA, STE. 7, NO. 141 1220 MACAULAY CIRCLE SAN JOSE, CA 95126 CARMICHAEL, CA 95608 EUGENE S WILSON PRAMOD KULKARNI CALIFORNIA CLEAN ENERGY COMMITTEE CUSTOMIZED ENERGY SOLUTIONS 3502 TANAGER AVE. 101 PARKSHORE DRIVE, SUITE 100 DAVIS, CA 95616-7531 FOLSOM, CA 95630 HEATHER SANDERS JOHN SHEARS CALIFORNIA ISO RENEWABLE TECHNOLOGIES 250 OUTCROPPING WAY THE CENTER FOR ENERGY EFFICIENCY AND FOLSOM, CA 95630-8773 1100 11TH ST., SUTE. 311 SACRAMENTO, CA 95814 ANDREW B. BROWN LYNN HAUG ELLISON SCHNEIDER & HARRIS L.L.P. ATTORNEY AT LAW 2600 CAPITOL AVENUE, STE. 400 ELLISON, SCHNEIDER & HARRIS, LLP SACRAMENTO, CA 95816 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA 95816-5905 MIKE CADE ALCANTAR & KAHL 1300 SW 5TH AVENUE, STE. 1750 PORTLAND, OR 97201

ELIZAVETA MALASHENKO ADAM LANGTON CPUC - SED CALIF PUBLIC UTILITIES COMMISSION EMAIL ONLY PROCUREMENT STRATEGY AND OVERSIGHT BRANC EMAIL ONLY, CA 00000 AREA 4-A

State Service



505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 DAMON A. FRANZ FARZAD GHAZZAGH CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ELECTRICITY PLANNING & POLICY BRANCH AREA 4-A ROOM 4102 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA FRANZ CHENG IRENE K. MOOSEN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION MARKET STRUCTURE, COSTS AND NATURAL GAS DIVISION OF ADMINISTRATIVE LAW JUDGES AREA 4-A ROOM 5103 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 JOSE ALIAGA-CARO NOEL CRISOSTOMO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PLANNING & POLICY BRANCH PROCUREMENT STRATEGY AND OVERSIGHT BRANC AREA AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 ROBERT LEVIN CALIF PUBLIC UTILITIES COMMISSION DEMAND SIDE ANALYSIS BRANCH ROOM 4102 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

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