BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M) for Review of its Safety Model Assessment Proceeding Pursuant to Decision And Consolidated Matters. Application (Filed May 1, 2015) Application Application Application SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) OPENING COMMENTS ON PROPOSED PHASE TWO DECISION ADOPTING RISK SPENDING ACCOUNTABILITY REPORT REQUIREMENTS AND SAFETY PERFORMANCE METRICS FOR INVESTOR-OWNED UTILITIES AND ADOPTING A SAFETY MODEL APPROACH FOR SMALL AND MULTI-JURISDICTIONAL UTILITIES FADIA RAFEEDIE KHOURY WILLIAM BRIGGS Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) William.K.Briggs@sce.com Dated: April 15, 2019

2 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) OPENING COMMENTS ON PROPOSED PHASE TWO DECISION ADOPTING RISK SPENDING ACCOUNTABILITY REPORT REQUIREMENTS AND SAFETY PERFORMANCE METRICS FOR INVESTOR- OWNED UTILITIES AND ADOPTING A SAFETY MODEL APPROACH FOR SMALL AND MULTI-JURISDICTIONAL UTILITIES TABLE OF CONTENTS Section Page I. INTRODUCTION AND SUBJECT INDEX OF RECOMMENDED CHANGES...1 II. DISCUSSION...3 A. OP 6 Should be Modified to Remove the Out-of-Scope and Duplicative Financial Incentive and Risk Mitigation Reporting Requirements Proposed for the Safety Performance Metrics Report....3 B. The RSAR Schedule Set in OP 8 Should be Modified to Account for Potential Delays in the Issuance of Rate Case Decisions....5 III. CONCLUSION...6 -i-

3 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) OPENING COMMENTS ON PROPOSED PHASE TWO DECISION ADOPTING RISK SPENDING ACCOUNTABILITY REPORT REQUIREMENTS AND SAFETY PERFORMANCE METRICS FOR INVESTOR- OWNED UTILITIES AND ADOPTING A SAFETY MODEL APPROACH FOR SMALL AND MULTI-JURISDICTIONAL UTILITIES TABLE OF AUTHORITIES Authority Page CPUC Decisions D , 6 D CPUC Rules of Practice and Procedure Rule ii-

4 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M) for Review of its Safety Model Assessment Proceeding Pursuant to Decision And Consolidated Matters. Application (Filed May 1, 2015) Application Application Application SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) OPENING COMMENTS ON PROPOSED PHASE TWO DECISION ADOPTING RISK SPENDING ACCOUNTABILITY REPORT REQUIREMENTS AND SAFETY PERFORMANCE METRICS FOR INVESTOR-OWNED UTILITIES AND ADOPTING A SAFETY MODEL APPROACH FOR SMALL AND MULTI-JURISDICTIONAL UTILITIES I. INTRODUCTION AND SUBJECT INDEX OF RECOMMENDED CHANGES Pursuant to Rule 14.3 of the California Public Utilities Commission s (Commission s) Rules of Practice and Procedure, Southern California Edison Company (SCE) respectfully submits these opening comments on Commissioner Rechtschaffen s Proposed Phase Two Decision Adopting Risk Spending Accountability Report Requirements and Safety Performance Metrics for Investor-Owned Utilities and Adopting a Safety Model Approach for Small and Multi-Jurisdictional Utilities, issued on March 26, 2019 (Proposed Decision or PD). Among other things, the PD requires that SCE, Pacific Gas and Electric Company (PG&E), Southern California Gas Company (SoCalGas), and San Diego Gas & Electric Company (SDG&E) (collectively, the investor-owned utilities or IOUs) annually report on approved safety performance metrics in a Safety Performance Metrics Report. The PD also approves format 1

5 requirements for the annual IOU Risk Spending Accountability Reports (RSARs) required by Decision (D.) , in which the IOUs will report on deviations between authorized and actual IOU risk mitigation and maintenance spending. SCE generally supports the PD, and finds that most of the PD s proposed requirements and instructions for the Safety Performance Metrics Reports and RSARs are reasonable. SCE particularly agrees with the PD s rejection of The Utility Reform Network s (TURN s) proposal that reporting in the RSARs should occur at the work unit level. 1 TURN s proposal would have gone beyond the scope of those reports, as defined by D SCE also agrees with the PD that it is premature at this time to approve specific requirements for another report required by D , the Risk Mitigation Accountability Report (RMAR). 3 However, SCE asks that the Commission be mindful of the fact that the imposition of three new annual reports the IOUs will eventually have to submit, as well as the introduction of the Safety Model Assessment Proceeding (S-MAP) and Risk Assessment Mitigation Phase (RAMP) to the rate case cycle, result in a substantial burden on the IOUs. SCE supports the underlying goals of these new obligations, and agrees with the importance of devoting IOU resources to safety improvement and risk mitigation. But SCE respectfully urges the Commission to be deliberate in establishing additional reporting requirements, so that these requirements do not duplicate existing efforts, efficiently utilize utility and Commission resources, and directly support improving safety and mitigating risk. As the additional requirements around financial incentives and risk mitigation that the PD proposes to include in the Safety Performance Metrics Report do not serve those purposes, SCE requests that the Commission revise Ordering Paragraph (OP) 6 to remove these requirements. SCE further requests that the Commission adopt SCE s proposed clarifying language for OP 8 to account for the fact that the RSAR schedule, as proposed, does not take into account late-issued General Rate Case (GRC) decisions. 4 1 See PD, p See D , p. 44 ( The second report, the Risk Spending Accountability Report[,] would compare the utility s GRC projected spending for approved risk mitigation projects to the actual spending on those projects, and to explain any discrepancies between the two. ). 3 PD, Finding of Fact (FOF) Appendix A to these comments provides proposed language changes to the PD s FOFs, Conclusions of Law, and OPs conforming to these comments. SCE respectfully requests that Attachment 2 to the 2

6 II. DISCUSSION A. OP 6 Should be Modified to Remove the Out-of-Scope and Duplicative Financial Incentive and Risk Mitigation Reporting Requirements Proposed for the Safety Performance Metrics Report. OP 6 imposes additional reporting obligations on the IOUs for the annual Safety Performance Metrics Report that go beyond the reporting of approved safety metrics. While SCE supports the PD s requirement that the IOUs annually report ten years of data (if it exists) 5 for twenty-seven approved performance metrics and provide examples of how the IOUs have used that data to improve training, take corrective actions, and support risk-based decisionmaking, 6 SCE does not support the PD s requirement that the IOUs also report on financial incentives and risk mitigation in the Safety Performance Metrics Report. Specifically, SCE does not support the requirements in OP 6 that the IOUs: 1. identify all metrics that may be subject to unwitting or intentional bias for reasons of linkage to financial incentives, including by: a. identifying any metrics used for purposes of determining executive compensation levels and/or incentives, defined as positions at the Director level and higher; b. identifying the Director-level or higher executive positions to which the metric(s) is linked; c. summarizing the differential in compensation levels with and without the incentive; and d. describing the bias controls that the utility has in place to ensure that reporting of the metric(s) has not been gamed or skewed to support a financial incentive goal. 7 PD, Risk Spending Accountability Report Guidance for Investor-Owned Utilities, also be updated to conform with the proposed change to OP 8. 5 SCE will provide ten years of historical data for these metrics, where such data exists. See PD, p. 23 & OP 2. In cases where ten years of data does not exist, SCE will provide data back to when the metric was first created and tracked. 6 PD, p. 24 & OPs 2, 6.E. 7 PD, p. 23 & OP 6 (subsections A-D). 3

7 2. provide risk mitigation and risk spending information by: a. explaining how the utility s risk mitigation activities and risk spending are meeting the goals for managing and minimizing the risks that were identified in the utility s RAMP submissions and GRC applications; and b. providing a summary of their total estimated risk mitigation spending level as approved in their most recent GRC, using a methodology developed collaboratively with Safety and Enforcement Division (SED) staff. 8 The record in this proceeding has not established that these additional requirements are necessary or reasonable. The PD s justification for the proposed financial incentives reporting that this will enhance understanding of IOU progress on safety 9 is speculative at this time. The IOUs have yet to submit a single Safety Performance Metrics report and there is no evidence that when they do there will be insufficient understanding of safety progress in the absence of the proposed financial incentive reporting. Indeed, the PD admits that the Commission at this time has not identified any metrics that may be subject to this bias. 10 Moreover, the burden of this additional reporting is not justified, given that it duplicates existing efforts in the IOUs RAMP submissions. One of the ten major components of RAMP filings, as outlined by SED, is for the IOUs to describe the company s safety culture, executive engagement, and compensation policies, and show how compensation is tied to safety performance, board, and executive engagement in safety, and organizational structure related to safety. 11 It is inefficient for the IOUs and the Commission to require the IOUs to duplicate that effort here. Similarly, the proposed risk mitigation reporting requirements are also unsupported and duplicative of other efforts. SCE understands that this reporting is meant to capture, on an 8 PD, p. 27 & OP 6 (subsections F & H). 9 PD, p Id. 11 D , p

8 interim basis, some of the information originally envisioned as belonging in the RMARs. 12 But the requirements listed above explicitly go beyond the purpose of the Safety Performance Metrics Report; 13 these requirements instead overlap with requirements already imposed through the RSARs and the RAMP and GRC proceedings, all of which focus to a significant degree on risk mitigation and risk spending. For example, the PD states that these proposed risk mitigation requirements will allow parties to more easily verify IOU safety-related mitigation activities and understand the reasons for any changes in priority. 14 But that is the express purpose of the RSARs, which require the IOUs to compare authorized to recorded spending for safety, reliability, and maintenance programs and, in certain circumstances, to identify the redirection of authorized funds. 15 The Safety Performance Metrics Report should remain focused on safety metrics, not on risk mitigation items that are more appropriately addressed through the RSARs and RAMP (and eventually the RMARs). For these reasons, SCE requests that OP 6 of the PD be revised to remove these additional requirements around financial incentives and risk mitigation from the scope of the Safety Performance Metrics Report. B. The RSAR Schedule Set in OP 8 Should be Modified to Account for Potential Delays in the Issuance of Rate Case Decisions. The schedule set forth in OP 8 for the annual filing of RSARs on March 31 assumes timely issuance of rate case decisions, 16 which unfortunately has not occurred for SCE for the last three cycles. In each RSAR, the IOUs are required to compare the prior year s GRC- 12 The PD defers consideration of the RMAR given that the IOUs as a group will not complete the necessary cycles to allow for program-by-program comparisons of benefit-to-cost ratios until PD, p SCE does not oppose the requirement in OP 6.G that the IOUs explain how the safety metrics reflect progress against the utility s RAMP and GRC safety goals. 14 PD, p PD, pp See PD, OP 8 & Attachment 2. 5

9 authorized spending for safety, reliability, and maintenance programs to the recorded spending. It takes several months to compile a report meeting the numerous RSAR requirements, and to complete appropriate management review for quality and accuracy before filing. An IOU cannot complete that work by March 31 for test year spending if the GRC final decision authorizing that spending is issued late in the test year, or is issued after the test year has concluded. For example, although the PD does not require SCE to file a RSAR for 2018 spending, 17 if the PD s schedule did apply to 2018, then SCE would have been unable to file a RSAR on March 31, 2019 given the fact that SCE does yet have a final decision on its Test Year 2018 GRC (and did not receive a proposed decision until April 12, 2019). 18 In recognition of this reality, which SCE hopes will not be the normal going-forward state of affairs, SCE respectfully requests that OP 8 of the PD be modified to explicitly provide that requests for extensions of the filing deadline for RSARs be granted when a late-issued GRC decision prevents an IOU from having reasonable time to prepare the RSAR. SCE recommends incorporating the following clarifying language in OP 8 (as well as in Attachment 2 to the PD): If a final decision authorizing spending for the recorded period is not in place by October 1 of that year, the IOU may seek a reasonable extension of this March 31 filing date, and the request should be freely granted. III. CONCLUSION For all of the foregoing reasons, SCE respectfully requests that the Commission adopt the PD with the narrow changes requested herein. 17 SCE s first RSAR is due on March 31, 2022 and will cover 2021 spending. See, e.g., PD, Attachment 2, Table 2. See also generally D However, although the Commission has not ordered SCE to file a RSAR for 2018 spending, the Energy Division has requested that SCE file an interim RSAR for 2018 spending by May 31, See Letter from Edward Randolph to Caroline Choi, Southern California Edison 2016 and 2017 Interim Risk Spending Accountability Report, January 3, However, as indicated above, SCE did not receive a proposed decision on SCE s Test Year 2018 GRC until April 12, SCE s 2015 GRC decision was issued in November of the test year. D

10 Respectfully submitted, FADIA RAFEEDIE KHOURY WILLIAM BRIGGS /s/ William Briggs By: William Briggs Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Dated: April 15,

11 APPENDIX A SCE s Proposed Modifications to Findings of Fact, Conclusions of Law, and Ordering Paragraphs to Commissioner Rechtschaffen s Proposed Phase Two Decision Adopting Risk Spending Accountability Report Requirements and Safety Performance Metrics for Investor-Owned Utilities and Adopting a Safety Model Approach for Small and Multi-Jurisdictional Utilities Findings of Fact 17. IOU reporting on metrics tied to financial incentives such as employee compensation may be subject to unwitting or intentional bias. 18. It is reasonable to require additional information in the Safety Performance Metrics reports on metrics tied to financial incentives. Conclusions of Law 7. The IOUs should clearly identify all metrics that may be subject to unwitting or intentional bias for reasons of linkage to financial incentives in their annual Safety Performance Metrics reports. 11. The Commission should require the IOUs Safety Performance Metrics reports to explain how their risk spending is meeting the goals for managing and minimizing the risks identified in each IOU s RAMP and GRC submissions, summarize how the Safety Performance Metrics reflect progress against the safety goals identified in each IOU s RAMP and GRC submissions these goals, and provide a summary of total estimated risk mitigation spending as approved in the most recent GRC. Ordering Paragraphs 6. Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company, shall, in each Safety Performance Metrics report, clearly: A. Identify any metrics used for purposes of determining executive compensation levels and/or incentives, defined as positions at the Director level and higher; A-1

12 B. Identify the Director-level or higher executive positions to which the metric(s) is linked; C. Summarize the differential in compensation levels with and without the incentive; D. Describe the bias controls that the utility has in place to ensure that reporting of the metric(s) has not been gamed or skewed to support a financial incentive goal; E. Provide three to five examples of how the utility has used Safety Performance Metrics (metrics) data to improve staff and/or contractor training, and/or to take corrective actions to minimize top risks or risk drivers; and, provide three to five examples of how the utility is using metrics data to support risk-based decision-making as required in the Safety Model Assessment Proceeding and Risk Assessment Mitigation Phase (RAMP) processes; and, F. Explain how the utility s risk mitigation activities and risk spending are meeting the goals for managing and minimizing the risks that were identified in the utility s RAMP submissions and General Rate Case (GRC) applications; G. Explain how the safety metrics reflect progress against the utility s RAMP and GRC safety goals.; and, H. Provide a summary of their total estimated risk mitigation spending level as approved in their most recent GRC, using a methodology developed collaboratively with Safety and Enforcement Division staff. 8. We approve the Risk Spending Accountability Report (RSAR) requirements contained in Attachment 2 and included in this decision. Pacific Gas and Electric Company, Southern California Edison Company, Southern California Gas Company, and San Diego Gas & Electric Company shall comply with these requirements in each of their annual RSARs, shall file each annual RSAR in the utility s current or most recent Risk Assessment Mitigation Phase (RAMP) and General Rate Case (GRC) proceeding at the time of filing as well as the RAMP/GRC that approved the risk spending, shall serve each RSAR to the California Public Advocates and the Office of Safety Advocates, and shall file the RSARs according to the following schedule, continuing annually: A-2

13 RSAR Schedule Date March 31 April 10 Action All IOUs file RSARs* ED serves Annual Schedule May 10 Party Comment (GRC 1) June 19 ED Review (GRC 1) July 29 Party Comment (GRC 2) Sept 7 ED Review (GRC 2) Oct 17 Party Comment (GRC 3) Dec 3 ED Review (GRC 3) * If a final decision authorizing spending for the recorded period is not in place by October 1 of that year, the IOU may seek a reasonable extension of this March 31 filing date, and the request should be freely granted. A-3

14 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M) for Review of its Safety Model Assessment Proceeding Pursuant to Decision And Related Matters. Application (Filed May 1, 2015) Application Application Application 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) OPENING COMMENTS ON PROPOSED PHASE TWO DECISION ADOPTING RISK SPENDING ACCOUNTABILITY REPORT REQUIREMENTS AND SAFETY PERFORMANCE METRICS FOR INVESTOR-OWNED UTILITIES AND ADOPTING A SAFETY MODEL APPROACH FOR SMALL AND MULTI-JURISDICTIONAL UTILITIES on all parties identified on the attached service list(s) A , et al. Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to the offices of the Administrative Law Judge(s). ALJ Cathleen A. Fogel CPUC 505 Van Ness Avenue San Francisco, CA ALJ Colette Kersten CPUC 505 Van Ness Avenue San Francisco, CA Executed this April 15, 2019, at Rosemead, California. _/s/ Edith Leon Edith Leon Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

15 CPUC - Service Lists - A Page 1 of 7 4/15/2019 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A SDG&E Â FOR REVIEW FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: APRIL 8, 2019 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties MARC D JOSEPH CATHERINE M. MAZZEO ASSOCIATE GEN. COUNSEL ADAMS BROADWELL JOSEPH & CARDOZO, PC SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD, CA LAS VEGAS, NV FOR: COALITION OF CALIFORNIA UTILITY FOR: SOUTHWEST GAS CORPORATION EMPLOYEES (CCUE) NANCY S. WHANG NORMAN A. PEDERSEN, ESQ. SR. COUNSEL AT LAW SOUTHERN CALIFORNIA GAS COMPANY HANNA AND MORTON LLP 555 WEST FIFTH ST., GT-14E7, STE S. FLOWER STREET, SUITE 1500 LOS ANGELES, CA LOS ANGELES, CA FOR: SOUTHERN CALIFORNIA GAS COMPANY FOR: SOUTHERN CALIFORNIA GENERATION COALITION WILLIAM K. BRIGGS DIANE CONKLIN SPOKESPERSON SOUTHERN CALIFORNIA EDISON COMPANY MUSSEY GRADE ROAD ALLIANCE 2244 WALNUT GROVE AVE. / PO BOX 800 PO BOX 683 ROSEMEAD, CA RAMONA, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: MUSSEY GRADE ROAD ALLIANCE DONALD KELLY KEITH W. MELVILLE EXE. DIRECTOR SR. COUNSEL UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY 3405 KENYON ST., STE CENTURY PARK CT., CP32D SAN DIEGO, CA SAN DIEGO, CA 92123

16 CPUC - Service Lists - A Page 2 of 7 4/15/2019 FOR: UTILITY CONSUMERS' ACTION NETWORK FOR: SAN DIEGO GAS & ELECTRIC COMPANY CHRISTA SALO TRACI BONE LEGAL DIVISION LEGAL DIVISION ROOM 4107 ROOM 5027 FOR: OFFICE OF SAFETY ADVOCATE (OSA) FOR: CAL ADVOCATES (PUBLIC ADVOCATES OFFICE) FORMERLY THE OFFICE OF RATEPAYER ADVOCATES (ORA) THOMAS LONG LILLIAN RAFII LEGAL DIRECTOR THE UTILITY REFORM NETWORK BUCHALTER, A PROFESSIONAL CORPORATION 785 MARKET ST., STE SECOND STREET, STE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: ENERGY PRODUCERS AND USERS COALITION AND INDICATED SHIPPERS STEVEN W. FRANK WILLIAM JULIAN II UTILITY WORKERS UNION OF AMERICA PACIFIC GAS AND ELECTRIC COMPANY ALMOND LANE 77 BEALE ST., B30A / PO BOX 7442 DAVIS, CA SAN FRANCISCO, CA FOR: UTILITY WORKERS UNION OF AMERICA FOR: PACIFIC GAS AND ELECTRIC COMPANY Information Only ALICIA AGUILAR CASE COORDINATION LEGAL SECRETARY/PARALEGAL PACIFIC GAS AND ELECTRIC COMPANY HANNA AND MORTON LLP, CA 00000, CA FOR: SOUTHERN CALIFORNIA GENERATION COALITION (SCGC) GRANT DAVIES JORDAN ALEN ACCENTURE PROBABILITY MANAGEMENT, CA 00000, CA KAVYA BALARAMAN LESSLY WIKLE FIELD STAFF WRITER / REPORTER PACIFIC GAS AND ELECTRIC COMPANY CALIFORNIA ENERGY MARKETS, CA 00000, CA MINCI HAN PACIFIC GAS AND ELECTRIC COMPANY, CA RACHEL KELLER CASE COORDINATOR PACIFIC GAS AND ELECTRIC COMPLANY, CA 00000

17 CPUC - Service Lists - A Page 3 of 7 4/15/2019 SAM SAVAGE MRW & ASSOCIATES, LLC CONSULTING PROFESSOR STANFORD UNIVERSITY, CA 00000, CA PAUL J. WOOD ANDREW V. HALL CONSULTANT SR COUNSEL CYCLA CORP. SOUTHWEST GAS CORPORATION 211 SOMERVELLE ST SPRING MOUNTAIN ROAD ALEXANDRIA, VA LAS VEGAS, CA TASHIA GARRY VALERIE ONTIVEROZ LEGAL ASSISTANT REGULATORY MGR / CA SOUTHWEST GAS CORPORATION SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV LAS VEGAS, NV ELLIOTT S. HENRY GREG HEALY SR. COUNSEL SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH ST., GT14D6 555 WEST FIFTH STREET, GT14E7 LOS ANGELES, CA LOS ANGELES, CA JASON W. EGAN LAUREN GODINEZ GRC CASE MGR. SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, STE GT14E7 555 WEST 5TH ST LOS ANGELES, CA LOS ANGELES, CA MELISSA A. HOVSEPIAN YVONNE MEJIA PENA SR COUNSEL ENTERPRISE RISK MGT. SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 WEST FIFTH STREET, GT-14E7, STE W. FITH ST., GT14E7 LOS ANGELES, CA LOS ANGELES, CA FOR: SOUTHERN CALIFORNIA GAS COMPANY CASE ADMINISTRATION SHINJINI MENON SOUTHERN CALIFORNIA EDISON COMPANY DIRECTOR LAW DEPT. SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE., RM WALNUT GROVE AVENUE, PO BOX 800 ROSEMEAD, CA ROSEMEAD, CA CARL WOOD JOSEPH W. MITCHELL, PH.D NAT'L DIR. - REGULATORY AFFAIRS M-BAR TECHNOLOGIES AND CONSULTING, LLC UTILITY WORKERS UNION OF AMERICA KIMBALL VALLEY RD S. NEVADA ST RAMONA, CA OCEANSIDE, CA DAVID CHENG DONALD C. LIDDELL STAFF THE UTILITY REFORM NETWORK DOUGLASS & LIDDELL TH AVENUE, SUITE ND AVENUE

18 CPUC - Service Lists - A Page 4 of 7 4/15/2019 SAN DIEGO, CA SAN DIEGO, CA CHARLES MANZUK ELIZABETH A. PETERS SAN DIEGO GAS & ELECTRIC REGULATORY CASE MGR CENTURY PARK COURT, CP 32D SAN DIEGO GAS & ELECTRIC SAN DIEGO, CA CENTURY PARK COURT, CP31E SAN DIEGO, CA JAMIE K. YORK LAURA M. EARL REGULATORY CASE ADMIN. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32D 8330 CENTURY PARK CT, CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECRIC COMPANY CENTRAL FILES MILA A. BUCKNER SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E ADAMS BROADWELL JOSEPH & CARDOZO SAN DIEGO, CA GATEWAY BLVD., STE SOUTH SAN FRANCISCO, CA JEREMY BATTIS TALAL HARAHSHEH RISK ASSESSMENT AND ENFORCEMENT ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA AREA KATY MORSONY BENJAMIN ELLIS STAFF THE UTILITY REFORM NETWORK BUCHALTER, A PROFESSIONAL CORPORATION 785 MARKET STREET, SUITE SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA BUCHALTER DOCKET LISA M. RAYMOND BUCHALTER BUCHALTER 55 SECOND STREET, SUITE SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA MICHAEL ALCANTAR MICHAEL REIDENBACH AT LAW PACIFIC GAS AND ELECTRIC COMPANY BUCHALTER, A PROFESSIONAL CORPORATION 77 BEALE STREET 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA MIKE CADE PETER VAN MIEGHEM BUCHALTER, A PROFESSIONAL CORPORATION AT LAW 55 SECOND STREET, SUITE 1700 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE STREET, RM 3107, B30A SAN FRANCISCO, CA SHELLY J. SHARP SR. DIR EVELYN KAHL

19 CPUC - Service Lists - A Page 5 of 7 4/15/2019 PACIFIC GAS AND ELECTRIC COMPANY BUCHALTER, A PROFESSIONAL CORPORATION 77 BEALE ST., B9A 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS GABRIEL BRIGGS 425 DIVISADERO ST STE 303 EXPERT CASE MANAGER SAN FRANCISCO, CA PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MD 12H/ PO BOX SAN FRANCISCO, CA DAVID MARCUS PAUL SCHULMAN 1541 JUANITA WAY SR RESEARCH FELLOW BERKELEY, CA CTR FOR CATASTROPHIC RISK MGNT MILLS COLLEGE UNIVERSITY OF CALIFORNIA BERKELEY, CA MARTIN HOMEC PO BOX 4471 DAVIS, CA DRUCILLA DUNTON ENTERPRISE RISK AND COMPLIANCE OFFICE 300 Capitol Mall Sacramento, CA State Service CHLOE LUKINS DOROTHY DUDA MGR - PUBLIC ADVOCATES OFFICE OFFICE OF SAFETY ADVOCATE CALIFORNIA PUBLIC UTILITIES COMMISSION CPUC - OSA, CA 00000, CA FOR: OSA LEUWAM TESFAI NILS STANNIK ORA CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION, CA 00000, CA TONY MARINO AMY C. CHAMARTY OFFICE OF SENATOR JERRY HILL COMMISSIONER RECHTSCHAFFEN, CA ROOM VAN NESS AVENUE SAN FRANCISCO, CA ANA M. GONZALEZ CAROLINA CONTRERAS ADMINISTRATIVE LAW JUDGE DIVISION OFFICE OF THE SAFETY ADVOCATE ROOM 2106 AREA FOR: OSA

20 CPUC - Service Lists - A Page 6 of 7 4/15/2019 CATHLEEN A. FOGEL CHARLYN A. HOOK ADMINISTRATIVE LAW JUDGE DIVISION LEGAL DIVISION ROOM 5101 ROOM 5123 FOR: PUBLIC ADVOCATES OFFICE (FORMERLY ORA) CHRISTINE J. HAMMOND CHRISTOPHER PARKES LEGAL DIVISION OFFICE OF THE SAFETY ADVOCATE ROOM 5137 AREA 2-D COLETTE KERSTEN DAVID PECK ADMINISTRATIVE LAW JUDGE DIVISION PRESIDENT PICKER ROOM 5111 ROOM 4108 ED CHARKOWICZ ELIZABETH PODOLINSKY RISK ASSESSMENT AND ENFORCEMENT PRESIDENT PICKER AREA 4-A ROOM 5306 JUNAID RAHMAN KELLY C. LEE RISK ASSESSMENT AND ENFORCEMENT ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA ROOM 4108 KEVIN FLAHERTY MATTHEW A. KARLE MARKET STRUCTURE, COSTS AND NATURAL GAS ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM 4108 NATHANIEL SKINNER PUI-WA LI ENERGY SAFETY & INFRASTRUCTURE BRANCH ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA 4-A AREA RICHARD A. MYERS RICHARD WHITE MARKET STRUCTURE, COSTS AND NATURAL GAS POLICY & PLANNING DIVISION AREA 4-A ROOM 5-A

21 CPUC - Service Lists - A Page 7 of 7 4/15/2019 ROBERT M. POCTA SIMI ROSE GEORGE ENERGY COST OF SERVICE & NATURAL GAS BRA COMMISSIONER RECHTSCHAFFEN ROOM 4205 ROOM 5119 STEVEN K. HAINE TRAVIS FOSS RISK ASSESSMENT AND ENFORCEMENT LEGAL DIVISION AREA ROOM 5026 LAURA MCWILLIAMS MICHAEL ZELAZO STATE SENATOR JERRY HILL STATE CAPITOL, ROOM 5035 MARKET STRUCTURE, COSTS AND NATURAL GAS SACRAMENTO, CA L Street, Suite 1250 Sacramento, CA ARTHUR J. O'DONNELL RISK ASSESSMENT AND ENFORCEMENT 180 Promenade Circle, Suite 115 Sacramento, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS