BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE …



COM/LML/jeh/abw** Mailed 10/10/2000

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

|Order Instituting Rulemaking into the operation of interruptible load programs offered | |

|by Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern |FILED |

|California Edison Company and the effect of these programs on energy prices, other |PUBLIC UTILITIES COMMISSION |

|demand responsiveness programs, and the reliability of the electric system. |OCTOBER 5, 2000 |

| |SAN FRANCISCO OFFICE |

| |RULEMAKING 00-10-002 |

| | |

Order Instituting Rulemaking into the operation of interruptible LOAD PROGRAMS

SUMMARY

By this order, the Commission institutes a rulemaking to 1) examine the role of customers on a utility’s interruptible tariffs to ensure reliable and reasonably-priced electric service within California, especially for the Summer of 2001; 2) coordinate the variety of interruptible, curtailable and demand responsiveness programs being offered and proposed; 3) identify alternative means for customers to reduce their energy usage during periods of peak demand; and 4) revise and update our priorities for curtailing customers during times of energy shortages.

This Rulemaking proposes the temporary suspension of the tariff provisions of Southern California Edison (Edison), Pacific Gas and Electric (PG&E), and San Diego Gas & Electric (SDG&E) that allow customers to opt-out of their interruptible program contracts for the 30-day window commencing November 1. The request of Edison in Advice Letter 1457-E and of PG&E in Advice Letter 2008-E to allow interruptible customers to participate in the Independent System Operators’ (ISO) Ancillary Services Market are now consolidated into this proceeding. The Commission will address these Advice Letters either in this proceeding or through Commission Resolution. Edison and PG&E shall file in this proceeding all of the reports required of them in Resolution E-3650 regarding the operation of their respective demand responsiveness programs. If Edison and/or PG&E seek to extend these or similar programs for the Summer of 2001, they shall file their proposals in this proceeding.

Background on Existing Utility Interruptible Programs

California’s investor-owned utilities have operated interruptible load programs since the mid-1980’s. Under these programs, customers received a discount off of their electric rates in exchange for the ability of the utility to curtail these customers for a certain number of hours per year.[1] The current cost of these programs, through reduced rates offered to program participants, is over $220 million per year.[2] Program participants receive a discount of about $60,000 to $70,000 per year for each megawatt (MW) that they agree to curtail.[3] This is equivalent to about a 15% reduction in that customer’s electric bill compared to the otherwise applicable rate for firm service. Over the past ten years, California ratepayers may have paid close to $2 billion for the operation of this program.

In return for this expenditure, California ratepayers expected to be able to rely upon these customers to curtail when needed in order to meet reliability and/or price criteria. Previous Commission decisions treated interruptible customers the same as any other energy resource (such as a power plant) for purposes of resource planning. Prior to 1998, customers on an interruptible tariff were required to sign three to five year contracts in order to participate in the program. The length of the contract was designed to give the utilities sufficient lead-time to acquire alternative generating resources if a customer left the interruptible rate schedule.

Because California utilities possessed sufficient energy resources to meet demand throughout much of the 1990’s, the utilities’ interruptible programs were seldom if ever used until the Summers of 1998 and 2000. Edison for example did not need to curtail its interruptible industrial customers for almost 14 years (from 1986 until June of this year)[4] PG&E also has needed to make few, if any, curtailments throughout the 1990’s, until it issued five curtailments in 1998 and two in 1999.

In 2000, however, the growth in electric energy usage combined with tight

energy supplies resulted in the ISO calling 15 Stage I events (when operating reserves are expected to fall below 7%) and 10 Stage II events(operating reserves less than 5%). One method to address tight energy supplies, and the subject of this Rulemaking, is to utilize and develop interruptible, curtailable and demand responsiveness programs that encourage consumers to utilize less energy during periods of high energy demand.

The stated[5] ability to reduce peak-demand of the utilities’ interruptible program was previously estimated by the ISO at approximately 2,800 MW. Actual operation of these programs over the past Summer, however, shows that some customers (800-1,000 MW) on these rate schedules are not curtailing when called upon to do so and instead are choosing to pay non-compliance rates[6] rather than curtail.

PG&E’s interruptible program has been closed to all customers as of February, 1993,[7] other than new customers locating in the PG&E service territory and existing customers who have added new load. Edison’s interruptible program has been closed as of November 26, 1996.[8] Therefore, almost all interruptible customers (other than new load entering the service territory) have enjoyed the benefits of lower interruptible rates for at least eight years in the case of PG&E and almost four years in the case of Edison.

In Resolution E-3689 and E-3696 (August 3, 2000), the Commission allowed Edison and PG&E respectively to reopen their interruptible program to new loads, subject to certain conditions.[9] As a result of these conditions Edison chose to implement its program while PG&E declined to do so.

In Resolution E-3650 (April 6, 2000), the Commission approved demand responsiveness programs for PG&E (E-BID) and Edison (Voluntary Power Reduction Credit). The purpose of these programs is to allow customers to voluntarily curtail their energy usage anytime the Power Exchange (PX) day-ahead price is greater than $250/hour.[10]

With the Commission’s restructuring of the electric industry effective on April 1, 1998, the utilities continue to operate and administer the program but the decision to decide when to curtail interruptible customers was transferred from the utilities to the ISO.[11]

Statutory Requirements

The industrial interruptible programs of the utilities are covered in part by the requirements of Public Utilities Code Sections 743 and 743.1.

PU Code Section 743, adopted in 1991,[12] allows that:

The commission may approve contracts between an electrical corporation and its heavy industrial customers as determined by the electrical corporation, of not more than ten years' duration, in which the electrical corporation buys from the heavy industrial customer the right to interrupt the customer's service on short notice, as determined by the commission. The payment mechanism may include a discounted rate for service.

* * *

Throughout the term of any of these contracts, the commission shall have the right to amend the contract. Every contract subject to this subdivision shall include a provision indicating that the contract is subject to amendment by the commission as provided in this subdivision.

PU Code Section 743.1, effective January 1, 1997[13] required that:

Electrical corporations shall continue the availability to qualified heavy industrial customers of optional interruptible or curtailable service. The effective rate for interruptible or curtailable service to qualifying customers shall reflect a pricing incentive for electing to operate under the interruptible or curtailable service option.

* * *

The commission shall continue the availability of optional interruptible or curtailable service at least until March 31, 2002. In no event shall the level of the pricing incentive for interruptible or curtailable service be altered from the levels in effect on June 10, 1996, until March 31, 2002. (Emphasis added.)

Issues Associated with Utility-run Interruptible Programs

One of the major purposes of this rulemaking is to examine the role of customers on a utility’s interruptible tariffs in ensuring reliable and reasonably-priced electric service within California, especially for the Summer of 2001. The goal should be to retain existing interruptible customers as well as to attract new customers to the program.

This goal can be accomplished in a number of ways including;

• Providing incentives for customers to reduce their energy usage;

• Encouraging customers to voluntarily reduce usage;

• Requiring customers to reduce energy usage; or

• Some combination of all of the above.

One option to increase program participation may be to increase the financial payments to interruptible customers. In crafting such a program the Commission should ensure that it is not overpaying for demand reductions and that it is adequately evaluating supply-side options (such as paying for new incremental generation) against the incentives paid for customers to curtail.

How customers should be paid for their participation may also affect program participation. The existing interruptible program is similar to an insurance policy in that it pays customers monthly (through reduced rates) in exchange for the ability to curtail these customers for a certain number of hours. The ISO’s programs, by contrast, are based more on an auction approach (either through an RFP process in the case of its Emergency Demand Responsiveness (EDR) program or through hourly ancillary service prices for its Participating Load program. In D.92-11-049 the Commission examined the possibility of changing PG&E’s interruptible program from a monthly “insurance” program to a bidding approach.

The Commission will also consider whether interruptible customers with certain attributes should be paid more than other program participants.[14]

A factor that must be considered in evaluating these changes is the ability of the Commission to alter the pricing incentives paid to interruptible customers.[15]

A second option to retain existing interruptible customers, or to attract new customers willing to be interrupted, is to offer non-pricing incentives such as changes in the timing, length, or frequency of curtailment. PU Code Section 743 reserves to the Commission the “right to amend [interruptible] contract[s]” and states that “Every contract subject to this subdivision shall include a provision indicating that the contract is subject to amendment by the commission.” In Resolution E-3650, establishing the demand responsiveness program, the Commission utilized this authority to allow interruptible customers to participate in the utilities’ demand responsiveness program.

A third option available to the Commission would be to utilize its authority under PU Code Section 743 to modify the existing interruptible contracts and restore them back to the same terms and conditions which existed when customers signed these contracts. Existing interruptible customers entered into these contracts with the understanding that they were contracting for 5-year terms.[16] Enforcing the original terms of the contract would help ensure that these customers are available to help California meet its peak demands for the Summer of 2001. Requiring interruptible customers to fulfill their original contractual obligations would also appear equitable in that it ensures that these customers, who have received over $2 billion in reduced rates, are actually available when needed.

In order for the Commission to have adequate time to determine the role of existing interruptible customers in meeting reliability needs for the Summer of 2001, this Rulemaking is proposing to temporarily suspend the tariff provisions of Edison, PG&E, and SDG&E that allow customers to opt-out of their interruptible programs for the 30-day window commencing November 1. Extending the contract terms, as was originally envisioned, should minimally inconvenience existing interruptible customers because they will continue to enjoy the lower rates that interruptible customers receive. Moreover, curtailments during the winter season are unlikely. Interested parties who wish to comment on the proposed suspension of these tariffs may do so by filing comments in this docket. The comments must be received by the Assigned Commissioner within 7 days of this decision.

Finally, the need for voluntary incentives should not be overlooked. Organizations such as the California Retailers Association, state Department of General Services, and the Silicon Valley Manufacturer’s Group have taken the lead in developing voluntary load reduction programs.

Review and Coordination of Interruptible/Demand Responsiveness Programs Offered by the Utilities, the ISO, and Others

The Commission intends to use this Rulemaking to coordinate the operation of all of the various programs being offered to ensure that duplication is minimized, ratepayers benefit, and reliability is increased. The Commission will also use this Rulemaking to determine the respective roles of the Commission and the ISO to operate and offer demand responsiveness and curtailable programs. To ensure coordination, the requests of Edison in Advice Letter 1457-E and of PG&E in Advice Letter 2008-E to allow interruptible customers to participate in the ISO’s Ancillary Services Market are now consolidated into this proceeding. The Commission will address these Advice Letters either in this proceeding or through Commission Resolution. Edison and PG&E should also file in this proceeding all of the reports required of them in Resolution E-3650 regarding the operation of their respective demand responsiveness programs. This proceeding will serve as the forum for Edison and/or PG&E to if they seek to extend their demand responsiveness programs for the Summer of 2001.

As the Commission concluded in Resolution E-3689:

The ISO notes that its EDR and Ancillary Services Load programs are quite likely competing for the same load. Reopening of Edison’s interruptible tariff to new customers is likely to take away some customers who otherwise would have participated in these programs. While a variety of programs might increase overall participation, it appears that many of these programs may just be signing up customers from other programs. The overall cost to ratepayers, and effect on system reliability, is unclear. As more programs develop, the ability of either the Commission or the ISO to prevent customers from receiving more than one payment for the same reduced load becomes more difficult.

Issues Associated with Participation of Smaller Customers

As the Commission stated in Resolution E-3689:

[I]nclusion of smaller customers into interruptible programs could provide a large additional source of untapped new load capable of being curtailed.

The activities of both the utilities and the ISO appear to be focusing almost exclusively upon the larger customers[17] who possess the metering (and to a lesser extent the telemetry) equipment needed to participate in curtailable programs. This may have led to duplication of effort and a chasing of a limited amount of load by a number of programs. One purpose of this rulemaking is to identify if and how smaller customers can participate in curtailable programs. Issues that we need to examine are the ability of smaller customers to participate; development of rate design and incentive policies of such participation; a cost/benefit analysis of such programs; and the marketing of any such programs. We are also interested in examining if PG&E and SDG&E should develop an Air Conditioning Cycling program similar to those already operated by both Edison and the Sacramento Municipal Utility District (SMUD)[18].

Issues Associated with Post-2002 Operation of Utility Interruptible Programs

The provisions of PU Code Section 743 that require that the Commission continue to offer an interruptible program for heavy industrial customers and that the level of pricing incentives be maintained at the level in effect on June 10, 1996 will both statutorily expire on March 31, 2002. This rulemaking will serve as the forum to begin developing policies for the need, role, and structure of interruptible programs for all customer classes for this post-2002 period.

Review of Curtailment Priorities

If successful, the results of this Rulemaking, combined with the efforts of this Commission and other state agencies to promote increased electric generation and energy efficiency will help to ensure a reliable electric system for California. If needed, however, this Rulemaking will also serve as the forum for revising and updating our priorities for curtailing customers during times of energy shortages.

PU Code Sections 2771 and 2772 provide that:

The commission shall establish priorities among the types or categories of customers of every electrical corporation and every gas corporation, and among the uses of electricity or gas by such customers. The commission shall determine which of such customers and uses provide the most important public benefits and serve the greatest public need and shall categorize all other customers and uses in order of descending priority based upon these standards…

* * *

In establishing the priorities pursuant to Section 2771, the commission shall include, but not be limited to, a consideration of all the following: (a) A determination of the customers and uses of electricity and gas, in descending order of priority, which provide the most important public benefits and serve the greatest public need. (b) A determination of the customers and uses of electricity and gas which are not included under subdivision (a). (c) A determination of the economic, social, and other effects of a temporary discontinuance in electrical or gas service to the customers or for the uses determined in accordance with subdivision(a) or (b). (d) Any curtailment or allocation rules, orders, or regulations issued by any agency of the federal government.

Our existing curtailment policies were developed during the early 1980’s after a lengthy, multi-year effort.[19] As part of our review of the utilities’ interruptible programs, and as we prepare to address energy needs for the Summer of 2001, the Commission may wish to make modifications to its decades-old curtailment rules. This Rulemaking will serve as the forum to address proposed changes on the Commission’s own initiative.

Preliminary Scoping Memo

The rules and procedures implementing many of the reforms contained in Senate Bill (SB) 960 are found in Article 2.5 of Practice and Procedure (Rules), which are posted on the Commission's web site. Pursuant to Rule 4(a), the rules in Article 2.5 shall apply to this proceeding. As per the provisions of SB 960, the present rulemaking is classified as a quasi-legislative proceeding and is expected to require hearings. In the preceding sections, we have listed the issues to be considered in this investigation. This is a preliminary list of issues. The scope of this investigation may be expanded once we take comments from parties and conduct the initial Prehearing Conference (PHC) and formal hearings.

President Loretta M. Lynch shall be the Assigned Commissioner and shall designate an assigned ALJ. The assigned Commissioner and ALJ shall convene a PHC, inform respondents and other interested parties when to file PHC statements, develop a service list for this proceeding, and further delineate issues related to scope and schedule for this proceeding. The date of the PHC will be set by the assigned Commissioner and the ALJ. Any person who objects to the categorization of this investigation must file an appeal 10 days after the date of this OIR, pursuant to Rule 6.4(a).

The temporary service list is attached to this order and shall be used for service until a service list for this proceeding is established at the PHC. Persons who want to become a "party" to this proceeding shall appear at the PHC, or subsequent hearings, and fill out the "Notice of Party/Non-Party Status" form (appearance form).

Those persons who do not want to be parties, and only want notice of the hearings, rulings, proposed decisions, and decisions may either fill out an appearance form at hearing, or they may mail a written request to the Process Office requesting that they be added to the service list for information only.

Those persons employed by the State of California who are interested in this proceeding may request that they be added to the "state service" section of the service list either by appearing at the PHC or at the formal hearing and filling out an appearance form, or by mailing a written request for "state service" status to the Process Office. Parties are obligated to serve all documents they may submit or file in this proceeding on all names appearing on the state service list.

The Process Office shall develop an initial service list based on the appearances at the first PHC. This initial service list shall be posted on the Commission's web site, , as soon as is practicable.

Any party interested in participating in this investigation who is unfamiliar with the Commission's procedures should contact the Commission's Public Advisor Office in Los Angeles (213) 576-7055, or in San Francisco (415) 703-2074 for assistance.

Consistent with Rule 6(e), we expect this proceeding to be concluded within 18 months.

Ex Parte Communications

This proceeding is subject to Rule 7, which specifies standards for engaging in ex parte communications and the reporting of such communications. Pursuant to Rules 7(a)(3) and 7(d), ex parte communications will be allowed in this proceeding without any restrictions or reporting requirements unless and until the Commission modifies this determination of category.

Therefore, IT IS ORDERED that:

1. A rulemaking is instituted on the Commission's own motion to: a) examine the role of customers on a utility’s interruptible tariffs to ensure reliable and reasonably-priced electric service within California, especially for the Summer of 2001; b) coordinate the variety of interruptible, curtailable and demand responsiveness programs being offered and proposed in California; c) identify alternative means for customers to reduce their energy usage during periods of peak demand; and 4) to revise and update the Commission’s priorities for curtailing customers during times of energy shortages.

2. Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Southern California Edison Company (Edison) and the California Independent System Operators (ISO) are made respondents to this proceeding.

3. The Executive Director shall cause this Order Instituting Rulemaking (OIR) to be served on the respondents and on the service list in Rulemaking R.94-04-031 et al, Case 9884, Edison Advice Letter 1263-E, and PG&E Advice Letter 1711-E.

4. President Loretta M. Lynch shall be the Assigned Commissioner and shall designate an assigned ALJ. The assigned Commissioner and ALJ shall convene a PHC, inform respondents and other interested parties when to file PHC statements, develop a service list for this proceeding and further delineate issues related to scope and schedule for this proceeding.

5. The tariff provisions of Edison, PG&E, and SDG&E that allow customers to opt-out of their interruptible program contracts for the 30-day window commencing November 1 are proposed for temporary suspension by the Commission. Interested parties who wish to comment on the proposed suspension of these tariffs may do so by filing comments in this docket. The comments must be received by the Assigned Commissioner within 7 days of this decision.

6. The request of Edison in Advice Letter 1457-E and of PG&E in Advice Letter 2008-E to allow interruptible customers to participate in the ISO’s Ancillary Services Market are now consolidated into this proceeding. The Commission will address these Advice Letters either in this proceeding or through Commission Resolution.

7. Edison and PG&E shall file in this proceeding all of the reports required of them in Resolution E-3650 regarding the operation of their respective demand responsiveness programs. If Edison and/or PG&E seek to extend these or similar programs for the Summer of 2001, they shall file their proposals in this proceeding.

8. The temporary service list is attached and shall be used for service of all pleadings until a service list for this proceeding is established. The official service list for this proceeding shall be created by the Process Office and posted on the Commission's web site ( cpuc.) as soon as practicable after the first PHC. Parties may also obtain the service list by contacting the Commission's Process Office at (415) 703-2021.

9. This rulemaking is categorized as quasi-legislative as that term is defined in Rule 5(d) of the Commission's Rules of Practice and Procedure. Any person who objects to the categorization of this rulemaking must file an appeal 10 days after the date of this OIR, pursuant to Rule 6.4(a).

10. Persons interested in having their names added to the service list for this proceeding shall follow the procedures described in this order.

This order is effective today.

Dated October 5, 2000, at San Francisco, California.

LORETTA M. LYNCH

President

HENRY M. DUQUE

JOSIAH L. NEEPER

RICHARD A. BILAS

CARL W. WOOD

Commissioners

ATTACHMENT

************ SERVICE LIST ***********

Last Update on 10-OCT-2000 by: SMJ

R0010002 NO POST

|************ APPEARANCES ************ | |

| | |

|Charles F. Robinson | |

|V.P. And General Counsel | |

|CALIFORNIA ISO | |

|PO BOX 639014 | |

|FOLSOM CA 95630-9014 | |

| | |

|********** STATE EMPLOYEE *********** | |

| | |

|Maria E. Stevens | |

|Executive Division | |

|RM. 5109 | |

|320 WEST 4TH STREET SUITE 500 | |

|Los Angeles CA 90013 | |

|(213) 576-7012 | |

|mer@cpuc. | |

| | |

|********* INFORMATION ONLY ********** | |

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|Don Fuller | |

|CALIFORNIA ISO | |

|PO BOX 639014 | |

|FOLSOM CA 95630-9014 | |

| | |

|Robert Finkelstein | |

|Attorney At Law | |

|THE UTILITY REFORM NETWORK | |

|711 VAN NESS AVENUE, SUITE 350 | |

|SAN FRANCISCO CA 94102 | |

|(415) 929-8876 | |

|bfinkelstein@ | |

| | |

|Michael Shames | |

|Attorney At Law | |

|UTILITY CONSUMERS' ACTION NETWORK | |

|1717 KETTNER BLVD., SUITE 105 | |

|SAN DIEGO CA 92101-2532 | |

|(619) 696-6966 | |

|mshames@ | |

| | |

|************ SERVICE LIST *********** |

|Last Update on 03-OCT-2000 by: SMJ |

|R9404031 ELECTRIC RESTRUCTURING |

|I9404032 |

|************ APPEARANCES ************ |Reed V. Schmidt |

|David Marcus |BARTLE WELLS ASSOCIATES |

|ADAMS BROADWELL JOSEPH & CARDOZO |1636 BUSH STREET |

|PO BOX 1287 |SAN FRANCISCO CA 94109 |

|BERKELEY CA 94701-1287 |(415) 775-3113 X111 |

|(510) 528-0728 |rschmidt@ |

|dmarcus@ | |

| |Marco Gomez |

|Marc D. Joseph |Office Of The General Counsel |

|Attorney At Law |BAY AREA RAPID TRANSIT DISTRICT |

|ADAMS BROADWELL JOSEPH & CARDOZO |800 MADISON STREET, 5TH FLOOR |

|651 GATEWAY BOULEVARD, SUITE 900 |OAKLAND CA 94607 |

|SOUTH SAN FRANCISCO CA 94080 |(510) 464-6058 |

|(650) 589-1660 |mgomez1@ |

|mdjoseph@ | |

| |John Burkholder |

|Dick Ely |BETA CONSULTING |

|Director Marketing |2023 TUDOR LANE |

|ADM ASSOCIATES INC. |FALLBROOK CA 92028 |

|3239 RAMOS CIRCLE |(760) 723-1831 |

|SACRAMENTO CA 95827-2501 |burkee@ |

|(916) 363-8383 |For: City of Long Beach Gas & Electric Dept/Southern California Edison Company.|

| | |

|Michael Boccadoro | |

|Executive Director |John Jimison |

|AGRICULTURAL ENERGY CONSUMERS ASSN |Attorney At Law |

|925 L STREET, SUITE 800 |BRADY & BERLINER |

|SACRAMENTO CA 95814 |1225 19TH STREET, N.W. STE 800 |

|(916) 441-4383 |WASHINGTON DC 20036 |

|mboccadoro@ |(202) 955-6067 |

| |johnj@ |

|Daniel W. Douglass | |

|Attorney At Law |Thomas Beach |

|ARTER & HADDEN LLP |BRADY & BERLINER |

|5959 TOPANGA CANYON BLVD. SUITE 244 |2560 9TH ST., SUITE 316 |

|WOODLAND HILLS CA 91367 |BERKELEY CA 94710 |

|(818) 596-2201 |(510) 649-9790 |

|douglass@ |tomb@ |

| |For: Watson Cogeneration Company |

|Lon W. House | |

|ASSOCIATION OF CALIF. WATER AGENCIES | |

|4901 FLYING C ROAD |Maurice Brubaker |

|CAMERON PARK CA 95682-9615 |BRUBAKER & ASSOCIATES, INC. |

|(530) 676-8956 |1215 FERN RIDGE PARKWAY, SUITE 208 |

|lwhouse@el-dorado.ca.us |ST. LOUIS MO 63141 |

| |(314) 275-7007 |

|Barbara R. Barkovich |mbrubaker@ |

|BARKOVICH AND YAP, INC. | |

|31 EUCALYPTUS LANE |Douglas M. Grandy |

|SAN RAFAEL CA 94901 |Chief |

|(415) 457-5537 |CALIF. DEPT. OF GENERAL SERVICES |

|brbarkovich@ |717 K STREET STE 409 |

| |SACRAMENTO CA 95814 |

|Karen Norene Mills |David X. Kolk |

|Attorney At Law |Ph.D. |

|CALIFORNIA FARM BUREAU FEDERATION |COMPLETE ENERGY SERVICES INC |

|2300 RIVER PLAZA DRIVE |SUITE 120 |

|SACRAMENTO CA 95833 |650 E. PARKRIDGE AVENUE, UNIT 110 |

|(916) 561-5655 |CORONA CA 92879 |

|kmills@ |(909) 283-1097 |

| |dkolk@ |

|Neal A. Johnson | |

|CALIFORNIA INTEGRATED WASTE MGMT BOARD |Virginia Jarrow |

|8800 CAL CENTER DRIVE |President |

|SACRAMENTO CA 95826-3268 |CONSUMERS COALITION OF CALIFORNIA |

|(916) 255-2580 |1109 BARBARA STREET RM A |

|njohnson@ciwmb. |REDONDO BEACH CA 90277 |

| |(310) 316-3346 |

|E.D. Yates | |

|Senior Vice President |Peter W. Michaels |

|CALIFORNIA LEAGUE OF FOOD PROCESSORS |SEAN P. BEATTY |

|980 NINTH STREET, SUITE 230 |COOPER WHITE & COOPER |

|SACRAMENTO CA 95814 |201 CALIFORNIA ST., 17TH FLOOR |

|(916) 444-9260 |SAN FRANCISCO CA 94111 |

|ed@ |(415) 433-1900 |

| |spbl@ |

|Chris S. King | |

|Vice President |Edward B. Lozowicki |

|CELLNET DATA SYSTEMS, INC. |Attorney At Law |

|125 SHOREWAY ROAD |COUDERT BROTHERS |

|SAN CARLOS CA 94070 |303 ALMADEN BLVD, FIFTH FLOOR |

|chrisk@ |SAN JOSE CA 95110-2721 |

| |(408) 297-9982 |

|Deborah L. Berger |elozowicki@sjo. |

|Deputy City Attorney | |

|CITY OF SAN DIEGO |Carl K. Oshiro |

|1200 THIRD AVENUE, SUITE 1100 |Attorney At Law |

|SAN DIEGO CA 92101 |CSBRT/CSBA |

|(619) 533-5800 |100 FIRST STREET, SUITE 2540 |

|dbb@sdcity. |SAN FRANCISCO CA 94105 |

|For: THE CITY OF SAN DIEGO |(415) 927-0158 |

| |oshirock@ |

| |For: California Small Business Association |

|Michael Pretto | |

|CITY OF SANTA CLARA/SILICON VALLEY POWER | |

|1500 WARBURTON AVENUE |Lindsey How-Downing |

|SANTA CLARA CA 95050 |LINDSEY HOW-DOWNING |

|(408) 261-5085 |Attorney At Law |

|mpretto@ci.santa-clara.ca.us |DAVIS WRIGHT TREMAINE LLP |

|For: Silicon Valley Power |ONE EMBARCADERO CENTER, STE 600 |

| |SAN FRANCISCO CA 94111-3834 |

| |(415) 276-6528 |

|William C. Prentice |lindseyhowdowning@ |

|Ceo | |

|COMPETISYS LLC | |

|2402 MICHELSON, SUITE 232 | |

|IRVINE CA 92714 | |

|(949) 417-2800 | |

|information@ | |

| | |

|Dennis W. De Cuir |Dani Jo Merryman |

|DE CUIR & SOMACH |Attorney At Law |

|2999 DOUGLAS BLVD., SUITE 325 |EDISON SOURCE |

|ROSEVILLE CA 95661 |955 OVERLAND COURT |

|(916) 788-1022 |SAN DIMAS CA 91773 |

| |(909) 450-6035 |

|Sam De Frawi |For: EDISON SOURCE |

|BUILDING 212, 4TH FLOOR | |

|1314 HARWOOD STREET, SE | |

|WASHINGTON NAVY YARD DC 20374-5018 |Renee H. Guild |

|(202) 685-0130 |ELECTRIC POWER RESEARCH INSTITUTE |

|defrawis@efaches.navfac.navy.mil |PO BOX 10412 |

| |3412 HILLVIEW AVENUE |

|Norman J. Furuta |PALO ALTO CA 94304-1395 |

|Associate Counsel |(650) 855-2000 |

|DEPARTMENT OF THE NAVY | |

|900 COMMODORE DRIVE |Christopher T. Ellison |

|SAN BRUNO CA 94066-5006 |Attorney At Law |

|(650) 244-2100 |ELLISON & SCHNEIDER |

|furutanj@efawest.navfac.navy.mil |2015 H STREET |

| |SACRAMENTO CA 95814-3109 |

|Timothy M. Dayonot |(916) 447-2166 |

|DEPT. OF COMMUNITY SERVICES AND DEV. |abb@ |

|700 NORTH TENTH STREET RM 258 | |

|SACRAMENTO CA 95814-0338 |Diane I. Fellman |

|(916) 322-2940 |Attorney At Law |

| |ENERGY LAW GROUP LLP |

|James M. Day, Jr. |1999 HARRISON ST. SUITE 2700 |

|Attorney At Law |OAKLAND CA 94612-3572 |

|DOWNEY BRAND SEYMOUR & ROHWER LLP |(510) 874-4301 |

|555 CAPITOL MALL 10TH FLOOR |difellman@energy-law- |

|SACRAMENTO CA 95814-4686 |For: NRG Energy, Inc. |

|(916) 441-0131 | |

|For: Merced Irrigation District | |

| |Andrew J. Skaff |

| |Attorney At Law |

|Philip A. Stohr |ENERGY LAW GROUP, LLP |

|Attorney At Law |1999 HARRISON STREET, 27TH FLOOR |

|DOWNEY, BRAND, SEYMOUR & ROHWER |OAKLAND CA 94612 |

|555 CAPITOL MALL, 10TH FLOOR |(510) 874-4370 |

|SACRAMENTO CA 95814-4686 |askaff@energy-law- |

|(916) 441-0131 | |

|pstohr@ |Carolyn Kehrein |

| |ENERGY MANAGEMENT SERVICES |

|Carolyn A. Baker |1505 DUNLAP COURT |

|DUKE ENERGY NORTH AMERICA |DIXON CA 95620-4208 |

|980 NINTH STREET, 16TH FLOOR |(707) 678-9586 |

|SACRAMENTO CA 95814 |cmkehrein@ems- |

|(916) 449-9623 | |

|cabaker@duke- |Robert T. Boyd |

| |ENRON WIND CORP. |

| |13000 JAMESON ROAD |

| |TEHACHAPI CA 93561 |

| |(661) 823-6734 |

| |rboyd@ |

| | |

| | |

|Richard P. Felak |Steven Kelly |

|P.E. |INDEPENDENT ENERGY PRODUCERS ASSN |

|27 NORWOOD WAY |1112 I STREET, SUITE 380 |

|SCHENECTADY NY 12309-4856 |SACRAMENTO CA 95814-2823 |

|(518) 374-3855 |(916) 448-9499 |

| | |

|Faramarz M. Yazdani |Robert E. Burt |

|FMY ASSOCIATES, INC. |INSULATION CONTRACTORS ASSN/RESCUE |

|146 MAIN STREET, SUITE 404 |1911 F STREET |

|LOS ALTOS CA 94022 |SACRAMENTO CA 95814 |

|(650) 941-3850 |(916) 444-2950 |

| |bob.burt@ |

|Gregg Morris | |

|FUTURE RESOURCES ASSOCIATES, INC. |Bob Tang |

|2039 SHATTUCK AVENUE, STE 402 |Manager |

|BERKELEY CA 94704 |INTEGRATED RESOURCE PLANNING |

|gmorris@ |CITY OF AZUSA |

| |729 NORTH AZUSA AVE./PO BOX 9500 |

|Margaret A. Rostker |AZUSA CA 91702-9522 |

|Attorney At Law |(626) 812-5208 |

|GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP |utilities@azusa. |

|505 SANSOME STREET, SUITE 900 | |

|SAN FRANCISCO CA 94111 |Mark A. Baldwin |

|(415) 392-7900 |President |

|mrostker@ |INTERSTATE GAS SERVICES, INC. |

| |2600 KITTYHAWK ROAD, SUITE 101 |

|Michael B. Day |LIVERMORE CA 94550 |

|Attorney At Law |(925) 243-0350 |

|GOODIN MACBRIDE SQUERI RITCHIE & DAY LLP |igsinc@ |

|505 SANSOME STREET, SUITE 900 | |

|SAN FRANCISCO CA 94111-3133 |William B. Marcus |

|(415) 392-7900 |JBS ENERGY, INC. |

|mday@ |311 D STREET, SUITE A |

| |WEST SACRAMENTO CA 95605 |

|Julie Blunden |(916) 372-0534 |

|GREEN MOUNTAIN ENERGY RESOURCES L.L.C. |bill@ |

|SUITE 1500 | |

|50 CALIFORNIA STREET |Norman A. Pedersen |

|SAN FRANCISCO CA 94111 |Attorney At Law |

|(415) 613-8362 |JONES DAY REAVIS & POGUE |

|blunden@ |555 WEST FIFTH ST., STE. 4600 |

| |LOS ANGELES CA 90013-1025 |

|Beth Dunlop |napedersen@ |

|GRUENEICH RESOURCE ADVOCATES | |

|582 MARKET STREET, SUITE 1020 |Kirk T. Morgan |

|SAN FRANCISCO CA 94104-5305 |KERN RIVER GAS TRANSMISSION COMPANY |

|(415) 834-2300 |MAILSTOP 303 |

|bdunlop@ |295 CHIPETA WAY |

|For: University of California/California State University |SALT LAKE CITY UT 84158-0900 |

| |(801) 584-7061 |

| | |

| | |

| | |

| | |

| | |

|Yvonne Ladson Webb |John W. Leslie |

|LADSON ASSOCIATES |Attorney At Law |

|870 MARKET STREET, SUITE 765 |LUCE FORWARD HAMILTON & SCRIPPS, LLP |

|SAN FRANCISCO CA 94102 |600 WEST BROADWAY, SUITE 2600 |

|(415) 296-8387 |SAN DIEGO CA 92101 |

|yladso19@ |(619) 236-1414 |

| |jleslie@ |

|Susan E. Brown | |

|Attorney At Law |Donald H. Maynor |

|LATINO ISSUES FORUM |Attorney At Law |

|785 MARKET STREET, 3RD FLOOR |235 CATALPA DRIVE |

|SAN FRANCISCO CA 94103-2003 |ATHERTON CA 94027 |

|(415) 284-7224 |(650) 327-2894 |

|susan.brown@ |dhmaynor@worldnet. |

| |For: Municipal Resource Consultants |

|Richard L. Hamilton | |

|Attorney At Law | |

|LAW OFFICE OF RICHARD L. HAMILTON |David J. Byers |

|100 HOWE AVE. SUITE 230N |Attorney At Law |

|SACRAMENTO CA 95825 |MCCRACKEN, BYERS & HAESLOOP |

|(916) 484-7646 |840 MALCOLM ROAD, SUITE 100 |

|hylaw@ |BURLINGAME CA 94010 |

|For: Western Mobilehome Parkowners Association |(650) 259-5979 |

| |btenney@. |

| |For: California City-County Street Light Assn. |

|Barry F. Mccarthy | |

|Attorney At Law | |

|LAW OFFICES OF BARRY F. MCCARTHY |Ann T. Finley |

|2105 HAMILTON AVENUE, STE 140 |METROPOLITAN WATER DIST OF SO. CALIF |

|SAN JOSE CA 95125 |PO BOX 54153 |

|(408) 558-0950 |LOS ANGELES CA 90054-0153 |

|bmcc@ |(213) 217-7136 |

| |afinley@mwd.dst.ca.us |

|William H. Booth | |

|Attorney At Law |Christopher J. Mayer |

|LAW OFFICES OF WILLIAM H. BOOTH |MODESTO IRRIGATION DISTRICT |

|1500 NEWELL AVENUE, SUITE 500 |PO BOX 4060 |

|WALNUT CREEK CA 94596 |MODESTO CA 95352-4060 |

|(925) 296-2460 |(209) 526-7430 |

|wbooth@booth- |chrism@ |

|For: California Large Energy Consumers Association | |

| |Peter W. Hanschen |

| |Attorney At Law |

|Christopher A. Hilen |MORRISON & FOERSTER LLP |

|Attorney At Law |425 MARKET STREET |

|LEBOEUF LAMB GREENE & MACRAE LLP |SAN FRANCISCO CA 94105 |

|ONE EMBARCADERO CENTER, STE 400 |(415) 268-7214 |

|SAN FRANCISCO CA 94111 |phanschen@ |

|(415) 951-1100 |For: New West Energy Corporation |

|chilen@ | |

| | |

|Emilio E. Varanini, I I I |Robert B. Weisenmiller |

|LIVINGSTON & MATTESICH |Phd |

|1201 K STREET, STE 1100 |MRW & ASSOCIATES, INC. |

|SACRAMENTO CA 95814 |1999 HARRISON STREET, STE 1440 |

|(916) 442-1111 |OAKLAND CA 94612-3517 |

| |(510) 834-1999 |

| |rbw@ |

|Sara Steck Myers |Sharon Arceneaux |

|Attorney At Law |PACIFICORP |

|122 28TH AVENUE |800 LLOYD CENTER TOWER |

|SAN FRANCISCO CA 94121 |825 N.E. MULTNOMAH STREET |

|(415) 387-1904 |PORTLAND OR 97232 |

|ssmyers@ |(503) 464-5000 |

| | |

|Michele Wynne |Ward Camp |

|MZA GRID SERVICES |Director, Regulatory Strategy |

|SUITE 200 |PNM ENERGY SERVICES |

|5230 PACIFIC CONCOURSE DRIVE |PUBLIC SERVICE COMPANY OF NEW MEXICO |

|LOS ANGELES CA 90045 |ALVARADO SQUARE - MS SIM9 |

|(310) 643-4416 |ALBUQUERQUE NM 87158 |

|MWYNNE@ |(505) 541-4251 |

| |wcamp@mail. |

|Sheryl Carter | |

|NATURAL RESOURCES DEFENSE COUNCIL |Patrick J. Power |

|71 STEVENSON STREET, SUITE 1825 |Attorney At Law |

|SAN FRANCISCO CA 94105 |1300 CLAY ST. RM. 600 |

|(415) 777-0220 |OAKLAND CA 94612 |

|scarter@ |(510) 446-7742 |

| |pjpowerlaw@ |

|Aaron Thomas |For: City of Long Beach |

|NEWENERGY, INC. | |

|1000 WILSHIRE BOULEVARD, SUITE 1900 | |

|LOS ANGELES CA 90017 |Richard M. Hairston |

|(213) 996-6136 |R.M. HAIRSTON COMPANY |

|athomas@ |1112 LA GRANDE AVENUE |

| |NAPA CA 94558-2168 |

|Stan Marks |(707) 257-7077 |

|PHIL KRUMPOS | |

|Phil Krumpos |Don Schoenbeck |

|NRG ENERGY, INC. |RCS, INC |

|SYMPHONY TOWERS, SUITE 2740 |900 WASHINGTON STREET, SUITE 1000 |

|750 B STREET |VANCOUVER WA 98660 |

|SAN DIEGO CA 92101 |(360) 737-3877 |

|stan.marks@ |dws@ |

| | |

|Peter Ouborg |James A. Ross |

|Attorney At Law |RCS, INC |

|PACIFIC GAS AND ELECTRIC COMPANY |500 CHESTERFIELD CENTER, SUITE 320 |

|LAW DEPARTMENT B30A |CHESTERFIELD MO 63017 |

|77 BEALE STREET, ROOM 3163 |(636) 530-9544 |

|SAN FRANCISCO CA 94105 |rcsstl@ |

|(415) 973-2286 | |

|pxo2@ |Daniel W. Meek |

| |Attorney At Law |

|Roger J. Peters |RESIDENTIAL ENERGY SVCS COMPANIES.... |

|PACIFIC GAS AND ELECTRIC COMPANY |10949 S.W. 4TH AVENUE |

|LAW DEPARTMENT B30A |PORTLAND OR 97219 |

|PO BOX 7442 |(503) 293-9021 |

|SAN FRANCISCO CA 94120-7442 |danmeek@ |

|(415) 973-9271 |For: Attorney for RESCUE |

| | |

| | |

| | |

| | |

|Don Wolven |Steven R. Schiller |

|RESOURCE MANAGEMENT INTERNATIONAL,INC. |Principal |

|3100 ZINFANDEL DRIVE, SUITE 600 |SCHILLER ASSOCIATES |

|RANCHO CORDOVA CA 95670 |1333 BROADWAY, SUITE 1015 |

|(916) 852-1300 |OAKLAND CA 94612 |

| |(510) 444-6500 |

|Mohamed M. El-Gasseir |steves@ |

|Ph.D | |

|RUMLA, INC. |Lisa Hubbard |

|3243 GLORIA TERRACE |SEMPRA ENERGY |

|LAFAYETTE CA 94549 |601 VAN NESS AVENUE, SUITE 2060 |

|(925) 938-2535 |SAN FRANCISCO CA 94102 |

|rumla@ |(415) 202-9986 |

| |lhubbard@ |

|Jim Parks | |

|Supervisor, Energy Services Planning |Paul A. Szymanski |

|SACRAMENTO MUNICIPAL UTILITY DIST. |Attorney |

|PO BOX 15830 |SEMPRA ENERGY |

|SACRAMENTO CA 95852-1830 |101 ASH STREET |

| |SAN DIEGO CA 92101 |

|Rob Roth |(619) 699-5078 |

|SACRAMENTO MUNICIPAL UTILITY DISTRICT |pszymanski@ |

|6301 S STREET | |

|SACRAMENTO CA 95817-1899 |Richard Esteves |

| |SESCO, INC. |

|Byford E. Hoffman |77 YACHT CLUB DRIVE, RM 1000 |

|SALT RIVER PROJECT |LAKE FOREST NJ 07849 |

|PO BOX 52025 ISB666 |(973) 663-5125 |

|PHOENIX AZ 85072-2025 |sesco-lf@ |

|(602) 236-5900 | |

| |Robert B. Gex |

|Lee Schavrien |SKJERVEN MORRILL MACPHERSON LLP |

|Attorney At Law |SUITE 2800 |

|SAN DIEGO GAS & ELECTRIC CO. |THREE EMBARCADERO CENTER |

|PO BOX 1831 |SAN FRANCISCO CA 94111 |

|SAN DIEGO CA 92112 |(415) 217-6000 |

|(619) 696-4050 |gex_rb@ |

| | |

|James F. Walsh |Ann P. Cohn |

|Attorney At Law |Assistant General Counsel |

|SAN DIEGO GAS & ELECTRIC COMPANY |SOUTHERN CALIFORNIA EDISON COMPANY |

|PO BOX 1831 |PO BOX 800 |

|SAN DIEGO CA 92112 |ROSEMEAD CA 91770 |

|(619) 699-5039 |(626) 302-2863 |

|jwalsh@ | |

| |Bruce Foster |

|John Light |Regulatory Affairs |

|General Counsel |SOUTHERN CALIFORNIA EDISON COMPANY |

|SAN DIEGO GAS & ELECTRIC COMPANY |601 VAN NESS AVENUE, SUITE 2040 |

|101 ASH STREET |SAN FRANCISCO CA 94102 |

|SAN DIEGO CA 92101 |(415) 775-1856 |

| |fosterbc@ |

| | |

| | |

| | |

|Julie A Miller |James E. Scarff |

|Attorney At Law |Legal Division |

|SOUTHERN CALIFORNIA EDISON COMPANY |RM. 5121 |

|2244 WALNUT GROVE AVE |505 VAN NESS AVE |

|ROSEMEAD CA 91770 |San Francisco CA 94102 |

|(818) 302-4017 |(415) 703-1440 |

|julie.miller@ |jes@cpuc. |

| | |

|Frank A. Spasaro |Christopher Witteman |

|Dsm Transition Manager |General Counsel/Policy Director |

|SOUTHERN CALIFORNIA GAS COMPANY |THE GREENLINING INSTITUTE |

|555 WEST FIFTH STREET, ML-22E2 |785 MARKET STREET, 3RD FLOOR |

|LOS ANGELES CA 90013-1011 |SAN FRANCISCO CA 94103-2003 |

|(213) 244-3648 |(415) 284-7202 |

|fspasaro@ |chrisw@ |

| | |

|Raymond P. Juels |Robert Finkelstein |

|Regulatory Affairs |Attorney At Law |

|SOUTHERN CALIFORNIA WATER COMPANY |THE UTILITY REFORM NETWORK |

|630 EAST FOOTHILL BOULEVARD |711 VAN NESS AVENUE, SUITE 350 |

|SAN DIMAS CA 91773 |SAN FRANCISCO CA 94102 |

|(909) 394-3600 |(415) 929-8876 |

|rjuels@ |bfinkelstein@ |

|For: BEAR VALLEY ELECTRIC SERVICE | |

| |Patrick Mcdonell |

| |TXU ENERGY SERVICES, INC. |

|Claudia Cancilla |SUITE 240 |

|Administrative Assistant |900 LARKSPUR LANDING CIRCLE |

|SPURR |LARKSPUR CA 94939 |

|1430 WILLOW PASS RD., SUITE 240 |(415) 461-5820 |

|CONCORD CA 94520-7929 |pmcdonnell@ |

| | |

|Michael Rochman |Roger L. Conkling |

|Managing Director |Adjunct Professor |

|SPURR |UNIVERSITY OF PORTLAND |

|1430 WILLOW PASS ROAD, SUITE 240 |2539 S.W. HILL CREST DRIVE |

|CONCORD CA 94520 |PORTLAND OR 97201 |

|(925) 743-1292 |(503) 283-7224 |

|rochmanm@ |conkling@up.edu |

| | |

|James C. Paine |Michael Shames |

|Attorney At Law |Attorney At Law |

|STOEL RIVES LLP |UTILITY CONSUMERS' ACTION NETWORK |

|900 S.W. FIFTH AVENUE, STE 2600 |1717 KETTNER BLVD., SUITE 105 |

|PORTLAND OR 97204-1268 |SAN DIEGO CA 92101-2532 |

|(503) 294-9246 |(619) 696-6966 |

|jcpaine@ |mshames@ |

| |For: Utility Consumers' Action Network |

|Keith R. Mccrea | |

|Attorney At Law | |

|SUTHERLAND, ASBILL & BRENNAN LLP |Philip M. Vermeulen |

|1275 PENNSYLVANIA AVE., N.W., SUITE 800 |3457 CASTLE CREEK CT. |

|WASHINGTON DC 20004-2415 |ROSEVILLE CA 95661-7354 |

|(202) 383-0705 |(916) 784-7055 |

|kmccrea@ |pmvgov@ |

|For: California Manufacturers Association | |

| | |

|Tom Lu |Docket 95-Er-96 |

|WATSON COGENERATION COMPANY |CALIFORNIA ENERGY COMMISSION |

|22850 SOUTH WILMINGTON AVE. |MS-4 |

|CARSON CA 90749 |1516 9TH STREET |

| |SACRAMENTO CA 95184 |

|Jerry R. Bloom | |

|Attorney At Law |Jennifer Tachera |

|WHITE & CASE LLP |Attorney At Law |

|TWO EMBARCADERO CENTER, SUITE 650 |CALIFORNIA ENERGY COMMISSION |

|SAN FRANCISCO CA 94111 |1516 9TH STREET, MS-14 |

|(415) 544-1100 |SACRAMENTO CA 95814-5504 |

|bloomje@la. |(916) 654-3870 |

| |jtachera@energy.state.ca.us |

|********** STATE EMPLOYEE *********** | |

| |Karen Griffin |

|Jonathan Bromson |CALIFORNIA ENERGY COMMISSION |

|Legal Division |MS-20 |

|RM. 5131 |1516 9TH STREET |

|505 VAN NESS AVE |SACRAMENTO CA 95184 |

|San Francisco CA 94102 | |

|(415) 703-2362 |Lorenzo Kristov |

|jab@cpuc. |CALIFORNIA ENERGY COMMISSION |

| |1516 9TH ST., MS-22 |

|Caryn J. Hough |SACRAMENTO CA 95814 |

|CALIFORNIA ENERGY COMMISSION |(916) 654-4773 |

|OFFICE OF CHIEF COUNSEL |LKristov@energy.state.ca.us |

|1516 NINTH STREET, MS-14 | |

|SACRAMENTO CA 95814 |Michael Jaske |

|(916) 654-4178 |CALIFORNIA ENERGY COMMISSION |

| |1516 9TH STREET, MS-22 |

|David Abelson |SACRAMENTO CA 95814 |

|Attorney At Law |(916) 654-4777 |

|CALIFORNIA ENERGY COMMISSION |mjaske@energy.state.ca.us |

|1516 9TH STREET, MS-14 | |

|SACRAMENTO CA 95814 |Michael Messenger |

|(916) 654-3951 |CALIFORNIA ENERGY COMMISSION |

| |1516 9TH STREET, MS-22 |

|David Hungerford |SACRAMENTO CA 95184 |

|CALIFORNIA ENERGY COMMISSION |(916) 654-4774 |

|1516 NINTH STREET, MS-22 |mmesseng@energy.state.ca.us |

|SACRAMENTO CA 95814 | |

|(916) 654-4906 |Susan Bakker |

|dhungerf@energy.state.ca.us |Atty At Law |

| |CALIFORNIA ENERGY COMMISSION |

|Dennis Fukumoto |1516 NINTH STREET, MS 20 |

|CALIFORNIA ENERGY COMMISSION |SACRAMENTO CA 95814 |

|MS-26 | |

|1516 9TH STREET |Energy Consultant |

|SACRAMENTO CA 95184 |Office Of Governmental Affairs |

| |CALIFORNIA PUBLIC UTILITIES COMMISSION |

| |770 L STREET, STE 1050 |

| |SACRAMENTO CA 95814 |

| | |

| | |

| | |

|Sean F. Casey |Sean Gallagher |

|Office of Ratepayer Advocates |Legal Division |

|RM. 4102 |RM. 5035 |

|505 VAN NESS AVE |505 VAN NESS AVE |

|San Francisco CA 94102 |San Francisco CA 94102 |

|(415) 703-1667 |(415) 703-2059 |

|sfc@cpuc. |shg@cpuc. |

| | |

|Scott Cauchois |David M. Gamson |

|Office of Ratepayer Advocates |Executive Division |

|RM. 4205 |RM. 5214 |

|505 VAN NESS AVE |505 VAN NESS AVE |

|San Francisco CA 94102 |San Francisco CA 94102 |

|(415) 703-1525 |(415) 703-1997 |

|wsc@cpuc. |dmg@cpuc. |

| | |

|Michelle Cooke |Judith Ikle |

|Administrative Law Judge Division |Energy Division |

|RM. 5012 |AREA 4-A |

|505 VAN NESS AVE |505 VAN NESS AVE |

|San Francisco CA 94102 |San Francisco CA 94102 |

|(415) 703-2637 |(415) 703-1486 |

|mlc@cpuc. |jci@cpuc. |

| | |

|Christopher Danforth |David E. Morse |

|Office of Ratepayer Advocates |770 L STREET, SUITE 1050 |

|RM. 4101 |SACARMENTO CA 95814 |

|505 VAN NESS AVE | |

|San Francisco CA 94102 |Wade McCartney |

|(415) 703-1481 |Energy Division |

|ctd@cpuc. |AREA 4-A |

| |505 VAN NESS AVE |

|Dorothy Duda |San Francisco CA 94102 |

|Administrative Law Judge Division |(415) 703-2167 |

|RM. 5012 |wsm@cpuc. |

|505 VAN NESS AVE | |

|San Francisco CA 94102 |Angela K. Minkin |

|(415) 703-2800 |Administrative Law Judge Division |

|dot@cpuc. |RM. 5116 |

| |505 VAN NESS AVE |

|Janet A. Econome |San Francisco CA 94102 |

|Administrative Law Judge Division |(415) 703-1573 |

|RM. 5113 |ang@cpuc. |

|505 VAN NESS AVE | |

|San Francisco CA 94102 |Maurice Monson |

|(415) 703-1494 |Energy Division |

|jjj@cpuc. |AREA 4-A |

| |505 VAN NESS AVE |

|Darwin Farrar |San Francisco CA 94102 |

|Legal Division |(415) 703-3072 |

|RM. 5039 |mdm@cpuc. |

|505 VAN NESS AVE | |

|San Francisco CA 94102 | |

|(415) 703-1599 | |

|edf@cpuc. | |

|Steve Roscow |********* INFORMATION ONLY ********** |

|Energy Division | |

|AREA 4-A |Evelyn Kahl Elsesser |

|505 VAN NESS AVE |Attorney At Law |

|San Francisco CA 94102 |ALCANTAR & ELSESSER LLP |

|(415) 703-1189 |ONE EMBARCADERO CENTER, STE 2420 |

|scr@cpuc. |SAN FRANCISCO CA 94111 |

| |(415) 421-4143 |

|Ulla Maija Wait |eke@ |

|ROBERT CASTANEDA, JR. |For: ENERGY PRODUCERS AND USERS COALITION |

|Dept. Of Community Svcs & Dev. | |

|STATE OF CALIFORNIA | |

|700 NORTH 10TH ST., ROOM 258 |Michael Alcantar |

|SACRAMENTO CA 95814-0338 |Attorney At Law |

| |ALCANTAR & ELSESSER LLP |

|Linda Serizawa |1300 SW 5TH AVENUE., SUITE 1750 |

|Executive Division |PORTLAND OR 97201 |

|RM. 5119 |(503) 402-9900 |

|505 VAN NESS AVE |mpa@ |

|San Francisco CA 94102 |For: COGENERATION ASSOCIATION OF CALIFORNIA |

|(415) 703-1383 | |

|lss@cpuc. | |

| |David W. Penn |

|Howard Shryock |Deputy Executive Director |

|Energy Division |AMERICAN PUBLIC POWER ASSOCIATION |

|AREA 4-A |2301 M STREET, N.W., 3RD FLOOR |

|505 VAN NESS AVE |WASHINGTON DC 20037-1484 |

|San Francisco CA 94102 |(202) 467-2900 |

|(415) 703-2255 | |

|hms@cpuc. |Edward G. Poole |

| |Attorney At Law |

|Ourania M. Vlahos |ANDERSON, DONOVAN & POOLE |

|Legal Division |601 CALIFORNIA ST., SUITE 1300 |

|RM. 5125 |SAN FRANCISCO CA 94108-2818 |

|505 VAN NESS AVE |(415) 956-6413 |

|San Francisco CA 94102 |epoole@ |

|(415) 703-2387 | |

|omv@cpuc. |Scott Wakefield |

| |Chief Counsel |

|John S. Wong |ARIZONA RESIDENTIAL UTILITY CONSUMER OFF |

|Administrative Law Judge Division |2828 NORTH CENTRAL AVE., STE 1200 |

|RM. 5019 |PHOENIX AZ 85004 |

|505 VAN NESS AVE |(602) 279-5659 |

|San Francisco CA 94102 | |

|(415) 703-3130 |Denise Cazalet |

|jsw@cpuc. |AUTOMATED POWER EXCHANGE |

| |26340 ALEXANDER PLACE |

|Helen W. Yee |LOS ALTOS HILLS CA 94022 |

|Legal Division |(650) 949-1672 |

|RM. 5031 | |

|505 VAN NESS AVE |Tom Dukich |

|San Francisco CA 94102 |AVISTA CORP |

|(415) 703-2474 |PO BOX 3727 |

|yee@cpuc. |SPOKANE WA 99220-3727 |

| |(509) 482-4724 |

| |josterberg@ |

| | |

|Scott Blaising |Jesse D. Frederick |

|Attorney At Law |President |

|8980 MOONEY ROAD |CONSUMERS UTILITY BROKERAGE, INC. |

|ELK GROVE CA 95624 |C/O WZI, INC |

|(916) 682-9702 |4700 STOCKDALE HWY, SUITE 120 |

|blaising@ |BAKERSFIELD CA 93309 |

| |(805) 326-1495 |

|Jonathan M. Teague | |

|CALIFORNIA DEPARTMENT OF GENERAL SERVICE |Arthur W. Pearson |

|OFFICE OF ENERGY ASSESSMENTS |Cem |

|717 K STREET, SUITE 409 |CORPORATE PROPERTY MANAGEMENT METLIFE |

|SACRAMENTO CA 95814-3406 |ONE MADISON AVE., AREA 19A |

|(916) 322-8808 |NEW YORK NY 10010-3690 |

|jonathan.teague@dgs. |(212) 578-6212 |

| | |

|J. A. Savage |Eric Wills |

|CALIFORNIA ENERGY MARKETS |DAGGETT LEASING CORPORATION |

|3006 SHEFFIELD AVENUE |20668 PASEO DE LA CUMBRE |

|OAKLAND CA 94602-1545 |YORBA LINDA CA 92687-3335 |

|(510) 534-9109 | |

|honest@ |Mark J. Berman |

| |Director Of Business Development |

|Jason Mihos |DAVIS ENERGY GROUP |

|Regulatory Correspondent |123 C STREET |

|CALIFORNIA ENERGY MARKETS |DAVIS CA 95616 |

|9 ROSCOE STREET |(530) 753-1100 |

|SAN FRANCISCO CA 94110-5921 | |

|(415) 824-3222 |Linda J. Dondanville |

|jasonm@ |Consultant |

| |5342 WINDING VIEW TRAIL |

|Christine Henning |SANTA ROSA CA 95404 |

|CALIFORNIA INDEPENDENT SYSTEM OPERATOR |(707) 528-8151 |

|151 BLUE RAVINE ROAD | |

|FOLSOM CA 95630 |Wallace L. Duncan |

|(916) 351-2365 |Attorney At Law |

| |DUNCAN WEINBERG MILLER PERMBROKE |

|Gerald L. Jordan |1615 M STREET, N.W., STE 800 |

|Executive Director |WASHINGTON DC 20036 |

|CALIFORNIA MUNICIPAL UTILITIES ASSN |(202) 467-6370 |

|915 L STREET SUITE 1460 |dwmp@ |

|SACRAMENTO CA 95814-3705 | |

|(916) 441-1733 |Edward Duncan |

|braun@ |4149 RAYA WAY |

| |SAN DIEGO CA 92122-3603 |

|John A. Barthrop | |

|General Counsel |Gregory T. Blue |

|COMMONWEALTH ENERGY CORP. |Manager, State Regulatory Affairs |

|15991 RED HILL AVENUE, NO. 201 |DYNEGY, INC. |

|TUSTIN CA 92780 |5976 W. LAS POSITAS BLVD., STE. 200 |

|(714) 258-0470 |PLEASANTON CA 94588 |

|jbarthrop@ |(925) 469-2355 |

| |gtbl@ |

| | |

| | |

| | |

|Anthony W. Wayne |Donald M. Johnson |

|President |Chief Operating Officer |

|EASTERN PACIFIC ENERGY |FULL POWER CORPORATION |

|2913 SATURN STREET, SUITE G |4155 E. JEWELL AVENUE, STE 805 |

|BREA CA 92821 |DENVER CO 80222-4512 |

|(714) 524-9848 |(310) 258-0488 |

| |fpc_ca@ |

|Martha A. Spikes | |

|EDISON MISSION ENERGY |Matthew W. White |

|SUITE 1750 |Assistant Professor Of Economics |

|18101 VON KARMAN AVENUE |GRADUATE SCHOOL OF BUSINESS |

|IRVINE CA 92715-1007 |STANFORD UNIVERSITY |

|(714) 798-7895 |STANFORD CA 94305-5015 |

| |(650) 725-5854 |

|Jon S. Silva |white@gsb.stanford.edu |

|Government Affairs Associate | |

|EDISON SOURCE |Douglas E. Davie |

|955 OVERLAND COURT |HENWOOD ENERGY SERVICES, INC. |

|SAN DIMAS CA 91773 |2710 GATEWAY OAKS DRIVE, STE. 300 NORTH |

|(909) 450-6035 |SACRAMENTO CA 95833 |

|jsilva@ |(916) 569-0985 |

| |ddavie@ |

|Jeffery D. Harris | |

|Attorney At Law |Bernays T. Barclay |

|ELLISON & SCHNEIDER |Esquire |

|2015 H STREET |KING & SPALDING |

|SACRAMENTO CA 95814-3109 |1185 AVENUE OF THE AMERICAS |

|(916) 447-2166 |NEW YORK NY 10036-4003 |

|jdh@ |(212) 556-2181 |

| |bbarclay@ |

|Albert K. Davies | |

|Director Of Project Development |John Howard |

|ENRON WIND DEVELOPMENT CORP. |KW AWARE LLC |

|1710 HAPPY VALLEY ROAD |1559 SPINNAKER DRIVE SUITE 201 |

|SANTA ROSA CA 95409 |VENTURA CA 93001 |

| |(805) 642-7933 |

|Barney Ugarte |ppejh@ |

|Senior Administrative Assistant | |

|ENVIRONMENTAL SCIENCE ASSOCIATES |Ryan Wiser |

|225 BUSH STREET, STE 1700 |LBNL |

|SAN FRANCISCO CA 94104 |MS-90-4000 |

|(415) 896-5900 |ONE CYCLOTRON ROAD |

|esa.sf@ |BERKELEY CA 94720 |

| | |

|Dennis Scott |Roger Levy |

|President |LEVY AND ASSOCIATES |

|FAIRHAVEN POWER COMPANY |2805 HUNTINGTON ROAD |

|1053 NORTHWESTERN AVENUE |SACRAMENTO CA 95864 |

|FORTUNA CA 95540 |(916) 487-8559 |

|(707) 725-6911 | |

| | |

| | |

| | |

| | |

| | |

|Richard A. Shortz |Peter Hindley |

|Esquire |POWER SYSTEMS SERVICES |

|MORGAN, LEWIS & BOCKIUS LLP |600 PANORAMIC HIGHWAY |

|300 SOUTH GRAND AVE., 22ND FLOOR |MILL VALLEY CA 94941 |

|LOS ANGELES CA 90071-3132 |(415) 398-4919 |

|(213) 612-2500 | |

|RASHORTZ@ |Blueley I. Anderson |

| |POWER VALUE INCORPORATED |

|Scott Andreson |877 YGNACIO VALLEY ROAD, STE 105 |

|MORRISON & FOERSTER |WALNUT CREEK CA 94596 |

|425 MARKET STREET |(510) 938-8735 |

|SAN FRANCISCO CA 94105-2482 |sia2@ |

|(415) 269-6390 | |

|sandreson@ |Pete Price |

| |PRICE CONSULTING |

|Jay Morse |1029 K STREET, SUITE 38 |

|Office of Ratepayer Advocates |SACRAMENTO CA 95814 |

|RM. 4101 |(916) 448-1015 |

|505 VAN NESS AVE |pprice@ |

|San Francisco CA 94102 | |

|(415) 703-1587 |Terrence J. Moran |

|jxm@cpuc. |PUBLIC SERVICE ELECTRIC & GAS COMPANY |

| |80 PARK PLAZA T25A |

|Steven A. Shrader |NEWARK NJ 07102 |

|ONSITE ENERGY CORPORATION |(973) 430-7105 |

|701 PALOMAR AIRPORT ROAD, STE 200 |terrence.moran@ |

|CARLSBAD CA 92009 | |

| |Pamela T. Johnson |

|John Prevost |REMAC |

|PACIFIC LUMBER CO |9300 IMPERIAL HIGHWAY |

|PO BOX 37 |DOWNEY CA 90242-2890 |

|SCOTIA CA 95565 |(562) 922-6336 |

|(707) 764-2222 |JOHNSONPAMELA@LACOE.EDU |

| | |

|Nancy Towne-Smith |Bryan W. Griess |

|Regulatory Operations Coordinator |RESOURCE MANAGEMENT INTERNATIONAL, INC. |

|PACIFICORP |3100 ZINFANDEL DRIVE, STE 600 |

|825 NE MULTNOMAH, STE 800 |RANCHO CORDOVA CA 95670 |

|PORTLAND OR 97232 |(916) 852-1300 |

|(503) 813-6068 | |

|nancy.towne_smith@ |Roxanne Figueroa |

|For: PACIFICORP |RICHARD HEATH AND ASSOCIATES, INC. |

| |1420 HARBOR BAY PKWY STE 145 |

| |ALAMEDA CA 94502-7088 |

|Ed Lucha |(510) 748-4330 |

|PG&E |rfigueroa@ |

|MAIL CODE: B9A | |

|PO BOX 770000 |C. Anthony Braun |

|SAN FRANCISCO CA 94177 |Special Counsel |

|(415) 973-3872 |SACRAMENTO MUNICIPAL UTILITIES ASSN |

|ell5@ |915 L STREET, SUITE 1460 |

| |SACRAMENTO CA 95814-3705 |

| |(916) 441-1733 |

| | |

| | |

|Timothy J. Haines |Steven A. Weissman |

|SACRAMENTO MUNICIPAL UTILITY DISTRICT |Executive Division |

|KEY ACCOUNT SERVICES |RM. 4103 |

|PO BOX 15830, MAIL STOP A453 |505 VAN NESS AVE |

|SACRAMENTO CA 95852-1830 |San Francisco CA 94102 |

|(916) 452-3211 |(415) 703-5173 |

| |saw@cpuc. |

|David M. Norris | |

|Attorney At Law | |

|SIERRA PACIFIC POWER COMPANY | |

|6100 NEIL ROAD | |

|RENO NV 89520-0024 | |

|(775) 834-3939 | |

|dnorris@ | |

| | |

|Duane Nelson | |

|SIERRA PACIFIC POWER COMPANY | |

|6100 NEIL ROAD, PO BOX 10100 | |

|RENO NV 89520-0024 | |

|(775) 834-4711 | |

|dnelson@ | |

| | |

|James Caldwell | |

|T G A L, INC. | |

|PO BOX 26 | |

|TRACY'S LANDING MD 20779 | |

|(410) 257-3195 | |

|tgaljhc@ | |

| | |

|Tony Wetzel | |

|THERMO ECOTEK CORPORATION | |

|735 SUNRISE AVE., 160 | |

|ROSEVILLE CA 95661 | |

|(916) 773-2940 | |

|TWETZEL@ | |

| | |

|Alicia Torre | |

|775 BUCKLAND AVENUE | |

|BELMONT CA 94002 | |

|(415) 591-6869 | |

|aliciato@ | |

| | |

|Mathew Trask | |

|TRASK & ASSOCIATES | |

|239 BRODERICK STREET | |

|SAN FRANCISCO CA 94117 | |

|mathewtrask@ | |

| | |

|Elsie Cardona | |

|UTILITY DESIGN, INC. | |

|5528 PACHECO BLVD. | |

|PACHECO CA 94553 | |

|(510) 674-0218 | |

(END OF ATTACHMENT)

-----------------------

[1] In the case of Edison customers can be interrupted up to 25 times for a maximum of 6 hours or a total of 150 hours per year. For PG&E customers can be curtailed up to 30 times, no more than 6 hours per time, and for no more than 100 hours per year.

[2] $180 million/year for Southern California Edison and $40 million/year for PG&E. Latest figures for SDG&E were not available.

[3] See for example D.92-06-020 (44 CPUC2d 471, 526) and D.96-04-050 (65 CPUC2d 362, 444). The level of the discount depends upon the voltage level at which service is taken. For an illustrative 1 MW baseload customer (70% capacity factor) the level of the discount is about $60,000/year.

[4] As Edison noted in Advice Letter 1163-E filed in June 1996: Edison has not interrupted customers on these schedules in the last ten years.” As noted in Resolution E-3689, Edison stated it that it curtailed industrial customers for the first time in June 2000. (Resolution E-3689, p. 5.)

[5] The “stated ability” is the amount of curtailment a utility expects to occur assuming that every customer who is operating when a curtailment occurs actually curtails. Because not all interruptible customers are expected to be operating when a curtailment occurs, the amount of load under contract is actually higher. For example, Edison currently has about 3,000 MW of industrial load signed up on interruptible tariffs but expects that only about 1,900 MW of this load will be operating, and hence available to be curtailed, during peak hours

[6] For Edison, this rate is 70 cents/kWh.

[7] See PG&E Advice Letter 1424-E (effective February 8, 1993) which implemented D.92-11-049.

[8] See Resolution E-3474.

[9] The programs were approved subject to certain modifications designed to: 1) increase program participation; 2) allow the Commission and the ISO to develop coordinated demand relief programs for the Summer of 2001; 3) address equity concerns between new and existing interruptible customers; 4) ensure that new customers signing-up for the program will actually curtail when called upon to do so; and 5) minimize duplication with other programs.

[10] Subsequently lowered to $100/MWH for PG&E in Resolution E-3700 (September 21, 2000).

[11] PG&E Advice Letter 1711-E and Edison Advice Letter 1163-E.

[12] Stats. 1991, Ch. 878, Sec. 1.

[13] Stats. 1996, Ch. 780, Sec. 1; Effective January 1, 1997.

[14] Under this approach, for example, new interruptible customers who are located in transmission constrained areas could be paid more than customers located in unconstrained areas.

[15] PU Code Section 743.1 states in relevant part that: “In no event shall the level of the pricing incentive for interruptible or curtailable service be altered from the levels in effect on June 10, 1996, until March 31, 2002.

[16] The contracts are renewed automatically (i.e., “evergreen”) unless the customer gives notice. Under the pre-existing tariffs a customer would have to have given notice in June 1996 in order not to participate in the program for the Summer of 2001.

[17] Generally those with demand above 500 kW.

[18] Edison’s program is designed to provide approximately 350 MW of demand relief. SMUD’s program, which is triggered to avoid rotating outages, is designed to provide approximately 200 MW of demand relief.

[19] D.90247, D.91548 and D.82-06-021

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