BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking on the Commission s Own Motion to Conduct a Comprehensive Examination of Investor Owned Electric Utilities Residential Rate Structures, the Transition Time to Varying and Dynamic Rates, and Other Statutory Obligations. Rulemaking (Filed June 21, 2012) OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E), AND PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) ON THE PROPOSED DECISION ADDRESSING STATEWIDE MARKETING, EDUCATION, AND OUTREACH FOR RESIDENTIAL RATE REFORM FADIA RAFEEDIE KHOURY CONNOR FLANIGAN Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Connor.Flanigan@sce.com JOHN A. PACHECO Attorney for SAN DIEGO GAS & ELECTRIC COMPANY 8330 Century Park Court San Diego, California Telephone: (858) Facsimile: (619) jpacheco@semprautilities.com MARY A. GANDESBERRY SHIRLEY A. WOO Attorneys for PACIFIC GAS AND ELECTRIC COMPANY 77 Beale Street, B30A San Francisco, California Telephone: (415) Facsimile: (415) Shirley.Woo@pge.com Dated: December 4, 2017

2 SUMMARY OF RECOMMENDATIONS Southern California Edison Company (SCE), San Diego Gas and Electric Company (SDG&E), and Pacific Gas and Electric Company (PG&E) (collectively, the Joint Investor Owned Utilities or Joint IOUs) respectfully request that the Commission make the following changes to the Proposed Decision (PD) of Administrative Law Judges (ALJs) Sophia J. Park, Jeanne M. McKinney, and S. Pat Tsen Addressing Statewide Marketing, Education, and Outreach for Residential Rate Reform: 1. The Joint IOUs agree with the PD that the statewide rate reform and Energy Upgrade California (EUC) campaigns must be integrated. However, although the PD indicates that DDB San Francisco (DDB) should pursue integrating rate reform and EUC campaigns, there is no such requirement contained within the associated statement of work. The statement of work, Attachment A to the PD, currently goes no further than to require coordination between EUC and rate reform, and must therefore be revised to require DDB to pursue integration to ensure these campaigns are effectively and efficiently executed. 2. The PD errs in authorizing DDB s $20.7 million budget for updates and maintenance work. It is imprudent to authorize this significant expenditure based on DDB s preliminary estimate, especially considering that this work will not take place until approximately the fourth quarter of 2018 in connection with SDG&E s expected transition to residential default time-of-use (TOU) rates. The PD should be changed to defer consideration of this budget item until DDB s Blueprint update and revised budget are submitted in an advice letter within 90 days of the contract amendment date. 3. The PD should be modified to require DDB and the Marketing, Education, and Outreach Working Group (ME&O WG) to agree on a set of key performance metrics to be included in DDB s amended contract. Such metrics are often included in vendor contracts to help ensure acceptable performance, and are appropriate for inclusion in DDB s amended contract considering the scope of responsibilities and magnitude of potential costs. 4. The PD should clarify that there will be two competitive solicitations for Implementation and Evaluation Work, as opposed to one, and that DDB is precluded from bidding on Evaluation Work. This clarification is necessary to guarantee that the Evaluation Work is performed by an independent party and to avoid potential conflicts of interest. 5. The PD should also clarify that the EUC governance structure will be applied to the statewide rate reform campaign, but not the Joint IOUs default TOU campaigns. The Joint IOUs, not DDB, remain accountable for performing local ME&O related to default TOU rollout. 6. The PD should be modified to allow the Joint IOUs to conduct a targeted competitive solicitation for a Coordinating ME&O Consultant. A targeted solicitation, focused on approximately three-to-five qualified candidates, is necessary if the Joint IOUs are to meet the PD s deadline for selecting a successful candidate by January 31, 2018.

3 OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E), AND PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) ON THE PROPOSED DECISION ADDRESSING STATEWIDE MARKETING, EDUCATION, AND OUTREACH FOR RESIDENTIAL RATE REFORM Table of Contents Section Title Page I. INTRODUCTION...2 II. DISCUSSION...3 A. The Commission Should Require DDB to Pursue Integrating the Rate Reform and EUC Campaigns... 3 B. The PD Should Defer Authorizing the Budget for Updates and Maintenance Work Until After DDB Finishes the Blueprint Update... 4 C. The PD Should Require That DDB s Amended Contract Include Metrics for Tracking and Evaluating DDB s Performance... 6 D. The PD Should Require That the Evaluation Work Will Be Performed by a Separate Vendor and Independent of the Implementation Work... 6 E. The PD Should Clarify That the EUC Governance Structure Applies to the Statewide Rate Reform Campaign, and Not the Joint IOUs Default TOU Campaigns... 7 F. The PD Should Be Modified to Allow for a Targeted RFP Process for Selecting the Coordinating ME&O Consultant by January 31, III. CONCLUSION...8 APPENDIX A RECOMMENDED CHANGES TO FINDINGS OF FACT AND CONCLUSIONS OF LAW APPENDIX B PROPOSED CHANGES TO STATEMENT OF WORK -i-

4 OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E), AND PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) ON THE PROPOSED DECISION ADDRESSING STATEWIDE MARKETING, EDUCATION, AND OUTREACH FOR RESIDENTIAL RATE REFORM Table of Authorities CPUC Rules of Practice and Procedure Rule 1.8(d)... 1 Rule Page -ii-

5 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking on the Commission s Own Motion to Conduct a Comprehensive Examination of Investor Owned Electric Utilities Residential Rate Structures, the Transition Time to Varying and Dynamic Rates, and Other Statutory Obligations. Rulemaking (Filed June 21, 2012) OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E), AND PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) ON THE PROPOSED DECISION ADDRESSING STATEWIDE MARKETING, EDUCATION, AND OUTREACH FOR RESIDENTIAL RATE REFORM Pursuant to Rule 14.3, San Diego Gas & Electric Company, and Pacific Gas and Electric Company (together the Joint Investor-Owned Utilities or Joint IOUs) hereby submit these comments on the proposed decision (PD) of Administrative Law Judges (ALJs) Sophia J. Park, Jeanne M. McKinney, and S. Pat Tsen addressing statewide marketing, education, and outreach for residential rate reform. 1 1 Pursuant to Rule 1.8(d), counsel for SDG&E and PG&E have given counsel for SCE authorization to file these comments on their behalf. 1

6 I. INTRODUCTION The Joint IOUs agree with the PD s conclusion that the rate reform campaign should be coordinated and integrated with the statewide Energy Upgrade California (EUC) campaign, and that DDB San Francisco (DDB) should serve as the consultant for both campaigns. The rate reform and EUC campaigns have common goals and similar visions, and the PD correctly determines that integrating the two campaigns allows for more efficient and effective messaging and avoids the risk of sending duplicative or unsynchronized messaging that might confuse or alienate customers. Both efforts are designed to help meet California s climate goals, and both need to provide the rationale and context for why customers should care and pay attention to their energy usage. Establishing and conveying this background is critical, because home energy is a service with which customers are generally unengaged. Messages about managing energy use, changes in rate plans, and the implications of when energy is consumed must be carefully crafted and deployed in order to ensure that customers not only pay attention and comprehend the information being relayed, but act on it. As the contractor for both the existing statewide EUC and residential rate design reform Phase 1 work, which will be added to DDB s EUC contract by amendment, DDB is well-positioned to achieve the integrated implementation of both campaigns. Although the Joint IOUs agree with the PD s advancing the statewide rate reform effort, we respectfully submit that the PD requires certain clarifications and corrections to ensure this effort is managed in a customer friendly, efficient, and cost effective manner. To begin, the Commission should modify the draft statement of work, Attachment A to the PD, to specifically require DDB to evaluate integrating rate reform and EUC into a jointly-developed, comprehensive campaign supported by a common plan, brand, and marketing infrastructure. The PD also should be revised to defer considering DDB s budget estimate for updates and maintenance work until DDB submits its update to the Greenberg Blueprint and its revised budget in an advice letter filing within 90 days of the contract amendment date. The PD errs by prematurely authorizing DDB s preliminary budget of $20.7 2

7 million for updates and maintenance when this work is not scheduled to take place until after the statewide campaign begins in late 2018 in connection with SDG&E s expected transition to residential default time-of-use (TOU) rates. Finally, the Joint IOUs also request that the PD be changed to require the inclusion of key performance indicators in DDB s amended contract to track and evaluate DDB s performance, and that DDB be precluded from bidding on evaluation work in order to avoid creating conflict of interest concerns. II. DISCUSSION A. The Commission Should Require DDB to Pursue Integrating the Rate Reform and EUC Campaigns The Joint IOUs support the PD s determination that statewide education and outreach for rate reform and EUC should be more fully integrated. However, we are concerned that the current draft statement of work, Attachment A to the PD, does not actually require DDB to integrate these two campaigns. Although the draft statement of work discusses DDB s coordination efforts, it includes very little regarding integration activities. Indeed, it goes no further than to require coordination between the EUC and statewide residential rate reform efforts. This is insufficient, and the Joint IOUs therefore request that the draft statement of work be modified to make integration of the residential rate reform and EUC campaigns part of the work for DDB s contract. 2 We have included proposed revisions to the statement of work in Appendix B to these comments for the Commission s consideration and adoption. There are several compelling reasons for requiring integration of DDB s work on both EUC and residential rate reform. First, by integrating the two efforts there will be a significant opportunity 2 The required integration would be for the residential aspects of EUC and residential rate reform. DDB s existing EUC contract includes statewide ME&O for certain non-residential customer classes, which would not be a required part of the integration effort. 3

8 for greater cost-effectiveness and more powerful, less confusing messaging about the customer s ability to manage its energy usage. By leveraging the ongoing EUC campaign, employing a greater focus on the context-setting for why TOU rates and energy management are critical, both statewide visions for customer engagement in managing their energy usage may be pursued simultaneously without the need to dedicate duplicative resources, create a separate marketing infrastructure, or develop a second marketing program or brand. Second, a joint campaign could be more easily and expeditiously designed by incorporating statewide rate reform components into DDB s Five-year Strategic Roadmap and Consumer Joint Action Plan. This would avoid both the time and resources required to create two separate plans. And third, an integrated, joint campaign would also avoid the need for the administrative overhead to coordinate the two campaigns timing of social, broadcast, print and other media, events, and the topics that will be addressed through those media and events. B. The PD Should Defer Authorizing the Budget for Updates and Maintenance Work Until After DDB Finishes the Blueprint Update The Joint IOUs do not disagree with the PD s statement that the Strategy and Content Development Work (Deliverables 1-3) should not be broken down into smaller pieces as this relates to having a single consultant, DDB, execute this work. 3 And although the Joint IOUs continue to have reservations about DDB s $10 million budget for Deliverables 1 and 2 (concerning, respectively, updating the Greenberg Blueprint and content development, testing, etc.), 4 we are not challenging the 3 PD, p See Joint IOUs Comments on DDB s Workshop Presentation and Additional Budget Submission, filed October 10, 2017, pp As noted in the Joint IOUs comments, Deliverable 1 proposes $1.3 million to update the Blueprint, where the cost of developing the original Blueprint was the same amount ($1.3 million, inclusive of statewide research). Additionally, the $9.5 million proposed cost for content development, testing, and creative design in Deliverable 2 is not only higher than anticipated, but includes a line item of $409,000 which is not defined. 4

9 PD s authorization of this amount. The Joint IOUs agree with the PD that there is a need to move forward expeditiously with this particular work. 5 However, the Joint IOUs strongly disagree with the PD s recommendation to authorize DDB s requested $20.7 million budget for Deliverable 3, for updates and maintenance work. The PD states that is approving this amount because it is concerned that time is of the essence in terms of moving this work forward. 6 The PD s timing concerns are vastly overstated, however, because this work is not expected to commence until after the statewide campaign launches regionally in the fourth quarter of Assuming the PD is voted out at the Commission s upcoming December 14, 2017 Business Meeting, the Joint IOUs anticipate that DDB s updated budget would be filed in approximately April It is therefore unnecessary, and indeed imprudent, to authorize such a significant preliminary expenditure now and in the absence of more detailed cost information from DDB. Rather than approve such a large amount at this stage, the PD should instead be modified to reserve consideration of an appropriate budget for Deliverable 3 work until after DDB completes its update of the Greenberg Blueprint. When the Deliverable 3 budget is approved via the anticipated advice letter with the Blueprint update, PG&E would execute another amendment to the DDB contract, to add the finally approved Deliverable 3 description and budget. This will allow DDB additional time to review the Blueprint and thoughtfully plan and provide the necessary budget justification for this longer-term project deliverable. The Joint IOUs respectfully submit that this process represents a no 5 The Joint IOUs also note that DDB is expected to include a revised budget with its Blueprint update, to be submitted via an advice letter filing within 90 days of the contract amendment date. PD, p. 48. The Joint IOUs reserve the right to comment on DDB s revised budget at the time of this advice letter filing. 6 PD, p To most effectively support local ME&O efforts, the overarching statewide campaign should ideally launch six months in advance of local mass TOU default, but no shorter than three months beforehand. A regionally phased approach to the campaign means the statewide message can roll out in IOU service areas separately, as opposed to simultaneously, and connect to the timing of different default TOU communication schedules. SDG&E will start transitioning mass default customers in March The statewide campaign can therefore start with its messaging in the September/October 2018 timeframe to meet the six months advance requirement. 5

10 regrets approach considering the longer lead time for the commencement of this work and is in the best interests of ratepayers. C. The PD Should Require That DDB s Amended Contract Include Metrics for Tracking and Evaluating DDB s Performance The Joint IOUs also request that the PD be modified to include a requirement for DDB and the ME&O Working Group to agree to a set of key performance indicators (KPIs) that will be used to track and evaluate DDB s performance under the amended statewide ME&O contract. The agreedupon KPIs should be included in PG&E s Tier 1 advice letter filing, approved by the Commission, and used to hold DDB accountable for the efficient use of ratepayer dollars. More specifically, the amended contract should specify that the IOUs, at the direction of Energy Division, are entitled to withhold funds from DDB if it fails to achieve these performance metrics. KPIs are often included in vendor contracts as a means of ensuring adequate performance and are absolutely essential here. D. The PD Should Require That the Evaluation Work Will Be Performed by a Separate Vendor and Independent of the Implementation Work The Joint IOUs agree with the PD that a competitive solicitation (or similar procedure) must be used for awarding the Implementation and Evaluation Work. But we note that the PD as presently worded suggests that these roles will be performed by a single consultant, as opposed to separate consultants. 8 This is problematic, and could create a potential conflict of interest. To avoid a potential conflict, the Joint IOUs recommend that the PD should be modified to require that the Evaluation Work will be separated from the Implementation Work. 9 Ideally, the Evaluation Work should be outsourced to an independent evaluation, measurement, and verification consultant to help guarantee impartiality and provide assurances regarding the trustworthiness and quality of the final 8 PD, p Indeed, it is possible that the Implementation Work may require multiple competitive solicitations for a dedicated consultant assigned to each IOU s respective TOU rollout plan. 6

11 evaluation results. The Joint IOUs also request that the PD specify that DDB is only allowed to bid on the Implementation Work. If DDB were to serve in in the evaluator role, it would essentially be tasked with evaluating its own performance. Without question, this would create a conflict of interest that risks depriving the evaluation of its independence and credibility and represents an unacceptable result. The Joint IOUs also note that the draft statement of work should be changed to remove the Implementation and Evaluation Work (Phase 2), consistent with the PD s recommendation to award this work via a competitive solicitation. E. The PD Should Clarify That the EUC Governance Structure Applies to the Statewide Rate Reform Campaign, and Not the Joint IOUs Default TOU Campaigns The Joint IOUs agree with the PDs determination to apply the EUC campaign governance structure to the Rate Reform campaign statewide governance. 10 However, the Joint IOUs recommend modifying Finding of Fact (FOF) 29 to clarify that the governance structure is for the statewide rate reform campaign only, and does not apply to the Joint IOUs local default TOU campaigns. The Joint IOUs, not DDB, remain accountable for performing local ME&O related to default TOU rollout. Accordingly, the Joint IOUs recommend changing FOF 29 to state that [t]he EUC contract includes an appropriate governance structure that can be applied to the statewide rate reform campaign. 11 F. The PD Should Be Modified to Allow for a Targeted RFP Process for Selecting the Coordinating ME&O Consultant by January 31, 2018 The Joint IOUs agree with the need to hire a Coordinating ME&O Consultant to handle operational logistics between the IOUs, Commission, parties, and residential rate reform ME&O consultants. The Joint IOUs note that the PD requires the Joint IOUs to hire the Coordinating ME&O Consultant by no later than January 31, 2018, which is just over a month after the PD is expected to be voted out by the Commission at its December 15, 2017 Business Meeting. 10 PD, pp See Appendix A for a list of the Joint IOUs specific redlined changes to the PD. 7

12 The Joint IOUs believe that this deadline, while very aggressive, is nonetheless achievable provided the PD allows for a targeted request for proposal (RFP) process. Specifically, in order to complete this process no later than January 31, 2018, SDG&E will take the lead (working in conjunction with the other IOUs) to finalize an appropriate scope of work with input from the Energy Division. In the interest of time, the Joint IOUs will develop a short list of approximately three-to-five qualified candidates to participate in a targeted RFP with a recommended not to exceed budget allocation. The Joint IOUs agree that the duties of the Coordinating ME&O Consultant would be facilitating workshops and coordinating logistics between the IOUs, Commission, the ME&O Working Group, other parties, and the EUC or other statewide marketing consultants, 12 and should include scheduling and facilitating working group meetings and the annual Electric Rate Summit, obtaining and organizing information for the working groups, interfacing with the various stakeholders to the ME&O process, and organizing and publicizing quarterly PRRR presentations. The Joint IOUs request that the Commission authorize the cost of the Coordinating ME&O Consultant to be recovered as part of the statewide ME&O residential rate reform budget. The cost of the consultant could be included in an appropriate advice letter. III. CONCLUSION The Joint IOUs appreciate the Commission s consideration of these joint comments and look forward to continuing to work with DDB, Commission staff, and stakeholders on the development and // // // 12 PD OP 10, p

13 implementation of an efficient and effective statewide campaign that advances rate reform and other state policy objectives. Respectfully submitted on behalf of Southern California Edison Company, San Diego Gas & Electric Company, and Pacific Gas and Electric Company FADIA RAFEEDIE KHOURY CONNOR FLANIGAN /s/ Connor Flanigan By: Connor Flanigan Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) December 4,

14 Appendix A Recommended Changes to Findings of Fact and Conclusions of Law

15 Recommended Changes to Findings of Fact 27. In order to ensure the best value to ratepayers and prevent potential conflicts of interest, the Implementation and Evaluation Work should be awarded in an separate RFPs; DDB may bid for the Implementation Work but not the Evaluation Work. 29. The EUC contract includes an appropriate governance structure that can be applied to the statewide rate reform campaign. 22. Although the foundational, and branding, strategy, content and implementation aspects of both the EUC campaign ME&O to residential customers, and the statewide residential rate reform campaign, need to be integrated can be the same, much of the EUC strategy, content, implementation and evaluation for non-residential customers may need to must be different. Evaluation for residential customer programs versus non-residential customer programs may also need to be separate and different. 37. Given the goals of the statewide rate reform ME&O campaign and the Blueprint s budget estimate, DDB s preliminary budget of $10 million for Deliverables 1 and 2 is within a reasonable range for successful execution of a statewide campaign; the Commission will address the reasonableness of DDB s preliminary budget for Deliverable 3 after DDB has completed the Blueprint update and submitted a revised budget. Recommended Changes to Conclusions of Law 2. The residential rate reform ME&O campaign should be coordinated and integrated, and potentially consolidated, with the EUC campaign with the EUC brand serving as the statewide messenger for rate reform. 5. The IOUs should be directed to issue a competitive RFPs for the Implementation and Evaluation Work. 7. DDB s preliminary budget of approximately $31.7 $10 million for Deliverables 1 and 2 of the Strategy and Content Development Work should be approved with the understanding that this budget will be refined once the strategic and creative deliverables are confirmed. A-1

16 Appendix B Proposed Changes to Statement of Work

17 APPENDIX B DRAFT SCOPE OF WORK FOR STATEWIDE RESIDENTIAL RATE REFORM MARKETING, EDUCATION AND OUTREACH, Phase I Phase 1: Strategy and Content Development Work 1 Deliverable 1 MEO Blueprint Update Under the California Public Utilities Commission s mandate to transition residential electricity customers through a series of rate changes, the DDB Contractor will develop a statewide Marketing, Education, and Outreach (ME&O) campaign that is coordinated, and aligned and integrated with the Energy Upgrade California (EUC) Do Your Thing campaign under DDB s contract for EUC to increase Californians understanding of their energy use and the benefits of taking action to manage that energy use. The Contractor DDB will coordinate with EUC administrative staff 2 and the rate reform ME&O Working Group to refine the statewide campaign portions of the current ME&O Blueprint. 3 The Contractor DDB will provide written feedback and specific suggested improvements on the Blueprint within thirty (30) days of the contract date. DDB The Contractor will collaborate with the EUC administrative staff and the rate reform ME&O Working Group to incorporate changes within sixty (60) days from the receipt of the feedback and comments. The updated Blueprint must support the following goals and objectives: Develop a complementary, and coordinated and integrated statewide marketing communications plan based on the existing research in the Blueprint that will be integrated with statewide will also leverage EUC ME&O under DDB s EUC contract; including the following items: o Detailed EUC and rate reform integrated marketing strategy including how strategies, segmentation, tactics and messages can be combined o Final statewide campaign metrics, including integration with EUC metrics, showing how both EUC goals and rate reform Vision metrics (as revised in this Decision) will be employed and their underlying goals achieved. 1 Phase 1 is to be completed by DDB San Francisco, the current implementer of the Energy Upgrade California campaign. 2 EUC administrative staff refers to Commission staff from Executive Division and Energy Division who oversee the EUC contract and operations and guide the EUC regulatory and stakeholder processes, respectively. 3 The consultant Greenberg, Inc. delivered a comprehensive ME&O plan, the RROIR ME&O Blueprint (Blueprint), on August 20, A copy of the Blueprint can be found at: B-3

18 o Numerical values for statewide rate reform Vision metrics. Identify additional targeted residential populations and refine strategies to be inclusive of diverse and hard-to-reach residential populations. Targeted markets will include language specific, culturally specific, disproportionately affected, low-to-moderate income populations, disabled populations and other hard-to-reach communities; Coordinate with EUC administrative staff and the rate reform ME&O Working Group to coordinate and integrate strategies across all partner channels, including IOUs and Community Based Organizations (CBOs); Recommend and develop alternative outreach strategies, including but not limited to digital media, social networking, and grassroots community outreach tactics to leverage alternative platforms outside of traditional paid media to extend the reach of campaigns; Provide a Public Relations plan that is coordinated and integrated with public relations work under DDB s EUC contract; Thorough analysis, based on benchmarking of risks and mitigation strategies, for plan/campaign. Thorough analysis and recommendation of optimal campaign timing, balancing customer experience and costs and taking into account campaign goals, individual IOU rollout dates, and benchmarking/best practices. Budgets for Deliverables 2 and 3, including detailed assumptions, including how existing EUC Campaign assets will be leveraged for the integrated campaign to offset costs. The Contractor DDB will provide the first update within ninety (90) days of the amendment of its EUC contract to add the scope of work for its award for SW ME&O residential rate design reform under Commission Decision XXX. The Joint IOUs propose to defer the addition of a scope of work for Deliverable 2 until the Commission has reviewed and approved DDB s updated Blueprint and budget which is required approximately 90 days after amendment of the DDB EUC contract for residential rate reform SW ME&O. Finalization of this scope of work will depend on final approval of the updated Blueprint and budget. Deliverable 2 Content Development, Content Testing and Creative Design DDB The Contractor is expected to conceptualize, develop, and produce creative campaigns and contents. The Contractor DDB may will develop a research plan to test creative concepts using methods such as focus groups and surveys, if the EUC administrative B-4

19 staff and rate reform ME&O Working Group agree that the research is needed to augment comparable research that is already available. The advertising campaigns will complement the current EUC strategies and advertisements (ads) while adding new and original content that will continue to improve on the updated ME&O Blueprint. The advertising will leverage current EUC content, themes, messages, and advertisements (ads), while adding new and original content for rate reform. DDB The Contractor may produce intellectual capital that includes: Creative brief(s) that align with the identified campaign strategies, messages, and target populations in the updated Blueprint to educate and increase awareness of the target audience; Background research and calculations; Focus groups and surveys to validate concepts before content production; Creative content to align with the updated Blueprint including but not limited to: o Social media creative content across social media platforms; o Community outreach fairs and events; o Traditional print media; and o Other alternative media channels. Translation, adaptation, and localization of ad content and marketing collateral. The Contractor must coordinate with service providers to produce in-language materials that are appropriate for the identified populations; Public Relations content; and Additional marketing collateral upon request by PG&E to support program needs. The Contractor DDB must obtain the approval of the EUC administrative staff prior to submission and will submit the final content creation no more than five (5) months from the contract date of the amendment to add the SW ME&O residential rate design reform scope of work to its EUC contract. Deliverable 3 Updates and Maintenance The contractor DDB will is expected to provide two updates to the integrated rate reform and EUC ME&O Blueprint, in 2018 and again in 2019, provide updates to the ME&O Blueprint at least annually through 2019 and as requested by the EUC administrative staff to adapt to changes according to the needs of the program. These updates should be provided to the EUC administrative staff, the rate reform ME&O Working Group, and the Phase II contractor. Updates may include but are not limited to: B-5

20 Updates to the Public Relations plan; Social media creative content; and Campaign updates. The Contractor DDB will create an update schedule with EUC administrative staff following the conclusion of Deliverable 2, no more than six (6) months from the contract date. B-6

21 DRAFT SCOPE OF WORK FOR STATEWIDE RESIDENTIAL RATE REFORM MARKETING, EDUCATION AND OUTREACH, Phase II Phase II: Implementation and Evaluation Work 4 Deliverable 1 Paid Media Implementation The Contractor will create a cost-effective paid media strategy that aligns with the Blueprint to engage different target market segments. The Contractor will coordinate and integrate its work for placement and management of all paid media to be purchased in the marketplace, including integration of purchase and management of paid media with similar paid media placement and management for EUC. The Contractor will and ensure that they paid media meet the following objective and program needs: Identify most cost-effective media placement to maximize exposure with specified media channels and mediums; Coordinate media plan with Phase I contractor DDB and integrate the media plan with the media plan for EUC; Consult best practices, lessons learned, and interim outcomes of current or previous campaign efforts when developing paid media plan; Disseminate ads through channels specifically targeted to the low- income, linguistically and culturally specific, geographically isolated, disabled and other hard-to-reach residential audiences; Track monthly media placement in a detailed log, including but not limited to: o Implementation timeline of each ad; o Expected outcomes; o Budget; o Media monitoring updates; o Media buy reports, including; Target demographic segments; Vendor, network, or stations for each media; Days aired and time(s) of day, if applicable; o Post-analysis, including Total impressions delivered, as applicable; Actual ratings delivered, as applicable; and 4 The work for Phase II will be awarded to a contractor based on an open and competitive request for proposals process. B-7

22 Digital Key performance indicators, such as click-through rates, cost per clicks, etc.; and o Interim evaluation of strategy effectiveness based on metrics defined by EUC administrative staff and ME&O Working Group, including but not limited to the following:. Final statewide campaign metrics, including integration with EUC metrics, showing how both EUC goals and rate reform Vision metrics (as revised in this Decision) will be employed and their underlying goals achieved. Deliverable 2 Alternative Outreach Efforts The Contractor will implement new strategies developed in the content development phase for alternative outreach platforms to ensure full coverage of residential market segments with various preferences. Alternative outreach efforts shall align with the goals and objectives of the updated Blueprint, and must include but are not limited to the following: Purchase media placement in alternative platforms that align with new strategies that will be developed in Phase I; Develop and curate social media and digital media content to increase online presence and improve user s experience with the current EUC online platform and website; and Coordinate with IOU community partners and CBOs to disseminate creative content and materials customized for the low-income, linguistically and culturally specific, geographically isolated, disabled and/or other hard-to-reach populations. B-8

23 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking on the Commission s Own Motion to Conduct a Comprehensive Examination of Investor Owned Electric Utilities Residential Rate Structures, the Transition to Time Varying and Dynamic Rates, and Other Statutory Obligations. R (Filed June 21, 2012) 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 OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E), SAN DIEGO GAS & ELECTRIC COMPANY (U 902-E), AND PACIFIC GAS AND ELECTRIC COMPANY (U 39-E) ON THE PROPOSED DECISION ADDRESSING STATEWIDE MARKETING, EDUCATION, AND OUTREACH FOR RESIDENTIAL RATE REFORM on all parties identified on the attached service list for R Service was effected by transmitting copies via to all parties who have provided an address and by placing copies in sealed envelopes and causing such envelopes to be delivered via United States mail with first-class postage prepaid to the offices of the Assigned ALJ(s) or other addressee(s). ALJ Jeanne McKinney California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue, Room 5113 San Francisco, CA ALJ Sophia J. Park California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue, Room 5024 San Francisco, CA ALJ S. Pat Tsen California Public Utilities Commission Division of Administrative Law Judges 505 Van Ness Avenue, Room 5005 San Francisco, CA Executed on December 4, 2017, at Rosemead, California. /s/ Olivia Gutierrez Olivia Gutierrez Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

24 CPUC - Service Lists - R Page 1 of 17 12/4/2017 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO CONDUC FILER: CPUC LIST NAME: LIST LAST CHANGED: DECEMBER 1, 2017 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties BRAD HEAVNER C.C. SONG CALIFORNIA SOLAR ENERGY INDUSTRIES ASSN. REGULATORY ANALYST MARIN CLEAN ENERGY, CA FOR: CALIFORNIA SOLAR ENERGY INDUSTRIES, CA ASSOCIATION (CALSEIA) FOR: MARIN CLEAN ENERGY MARGIE GARDNER NORA SHERIFF CAL. ENERGY EFFICIENCY INDUSTRY COUNCIL ATTORNEY ALCANTAR & KAHL, CA FOR: CALIFORNIA ENERGY EFFICIENCY, CA INDUSTRY COUNCIL FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOC./ENERGY PRODUCERS USERS COALITION SACHU CONSTANTINE SCOTT BLAISING DIR - POLICY BRAUN BLAISING MCLAUGHLIN P.C. CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA FOR: LOCAL ENERGY AGGREGATION NETWORK FOR: CENTER FOR SUSTAINABLE ENERGY STEPHANIE C. CHEN KEVIN T. FOX THE GREENLINING INSTITUTE KEYS & FOX LLP 1580 LINCOLN STREET, STE. 880, CA DENVER, CO FOR: THE GREENLINING INSTITUTE FOR: SUNRUN, INC.

25 CPUC - Service Lists - R Page 2 of 17 12/4/2017 CHAIRMAN / PRESIDENT DANIEL W. DOUGLASS LAT. BUS. CHAMBER OF GREATER L.A. ATTORNEY 634 S. SPRING STREET, STE 600 DOUGLASS & LIDDELL LOS ANGELES, CA PARK GRANADA, SUITE 209 FOR: LATINO BUSINESS CHAMBER OF GREATER CALABASAS, CA LOS ANGELES FOR: WESTERN POWER TRADING FORUM/ALLIANCE FOR RETAIL ENERGY MARKETS/DIRECT ACCESSS CUSTONER COALITION DANIEL W. DOULGASS CONNOR FLANIGAN DOUGLASS & LIDDELL ATTORNEY 4766 PARK GRANADA, STE. 209 SOUTHERN CALIFORNIA EDISON COMPANY CALABASAS, CA WALNUT GROVE AVE. FOR: NEST LABS, INC. ROSEMEAD, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY DONALD C. LIDDELL DON KELLY ATTORNEY EXE. DIR. DOUGLASS & LIDDELL UTILITY CONSUMERS' ACTION NETWORK ND AVENUE 3405 KENYON STREET, SUITE 401 SAN DIEGO, CA SAN DIEGO, CA FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: UTILITY CONSUMERS' ACTION NETWORK (CESA) (UCAN) MICHAEL SHAMES, ESQ. STEVEN C. NELSON SAN DIEGO CONSUMERS' ACTION NETWORK CHIEF REGULATORY COUNSEL 6975 CAMINO AMERO SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA CENTURY PARK COURT, CP32D FOR: SAN DIEGO CONSUMERS' ACTION NETWORK SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY (SDG&E) MARK E. WHITLOCK, JR. CATHY ZHANG EXE. DIR. EXECUTIVE DIRECTOR ECUMENICAL CTR. FOR BLACK CHURCH STUDIES CHINESE AM. INSTITUTE FOR EMPOWERMENT 46 MAXWELL ST 15 SOUTHGATE AVE., STE. 200 IRVINE, CA DALY CITY, CA FOR: ECUMENICAL CENTER FOR BLACK CHURCH FOR: CHINESE AMERICAN INSTITUTE FOR STUDIES (JT. PARTY) EMPOWERMENT (JT. PARTY) FAITH BAUTISTA JOSEPH F. WIEDMAN PRESIDENT / CEO SR. REGULATORY & LEGISLATIVE ANALYST NATIONAL ASIAN AMERICAN COALITION PENINSULA CLEAN ENERGY AUTHORITY 15 SOUTHGATE AVE, STE COUNTY CENTER, SIXTH FL. DALY CITY, CA REDWOOD CITY, CA FOR: NATIONAL ASIAN AMERICAN COALITION FOR: PENINSULA CLEAN ENERGY AUTHORITY (PCE) MARC D JOSEPH ERICA SCHROEDER MCCONNELL ADAMS BROADWELL JOSEPH & CARDOZO, PC SHUTE, MIHALY AND WEINBERGER, LLP 601 GATEWAY BLVD., STE HAYES STREET SOUTH SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: COALITION OF CALIFORNIA UTILITY FOR: INTERSTATE RENEWABLE ENERGY EMPLOYEES (CCUE) COUNCIL, INC.

26 CPUC - Service Lists - R Page 3 of 17 12/4/2017 WILLIAM MAGUIRE HAYLEY GOODSON STAFF ATTORNEY LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM MARKET ST., STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: ORA SHERYL CARTER CHRISTOPHER J. WARNER NATURAL RESOURCES DEFENSE COUNCIL ATTORNEY 111 SUTTTER ST., 20TH FLR. PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE STREET, MC B30A, RM 3145 FOR: NATURAL RESOURCES DEFENSE COUNCIL SAN FRANCISCO, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY LARISSA KOEHLER NICOLE JOHNSON SENIOR ATTORNEY REGULATORY ATTORNEY ENVIRONMENTAL DEFENSE FUND CONSUMER FEDERATION OF CALIFORNIA 123 MISSION STREET, 28TH FLOOR 150 POST ST., STE. 442 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ENVIRONMENTAL DEFENSE FUND FOR: CONSUMER FEDERATION OF CALIFORNIA BRIAN CRAGG JEANNE ARMSTRONG ATTORNEY ATTORNEY AT LAW GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY GOODIN, MACBRIDE, SQUERI & DAY, LLP 505 SANSOME STREET, SUITE SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: INDEPENDENT ENERGY PRODUCERS FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION ASSOCIATION SARA STECK MYERS CHRIS S. KING ATTORNEY AT LAW CHIEF POLICY OFFICER TH AVENUE EMETER, A SIEMENS BUSINESS SAN FRANCISCO, CA E. THIRD AVE., 4TH FLOOR FOR: CENTER FOR ENERGY EFFICIENCY AND FOSTER CITY, CA RENEWABLE TECHNOLOGY FOR: EMETER, A SIEMENS BUSINESS CHRIS CONE DAVID WOOLEY POLICY MANAGER OF COUNSEL EFFICIENCY FIRST CALIFORNIA KEYES & FOX LLP 1000 BROADWAY, STE TH STREET, STE OAKLAND, CA OAKLAND, CA FOR: EFFICIENCY FIRST CALIFORNIA FOR: SOLARCITY CORPORATION MARK FULMER TIM LINDL MRW & ASSOCIATES, LLC COUNSEL 1814 FRANKLIN STREET, SUITE 720 KEYES & FOX LLP OAKLAND, CA TH STREET, STE FOR: MRW & ASSOCIATES, LLC OAKLAND, CA FOR: THE ALLIANCE FOR SOLAR CHOICE MELISSA W. KASNITZ CENTER FOR ACCESSIBLE TECHNOLOGY ANDY KATZ LAW OFFICES OF ANDY KATZ

27 CPUC - Service Lists - R Page 4 of 17 12/4/ ADELINE STREET, SUITE ALLSTON WAY, STE. 400 BERKELEY, CA BERKELEY, CA FOR: CENTER FOR ACCESSIBLE TECHNOLOGY FOR: SIERRA CLUB BRAD BORDINE TIM MCRAE DISTRIBUTED ENERGY CONSUMER ADVOCATES SILICON VALLEY LEADERSHIP GROUP 516 WHITEWOOD DRIVE 2001 GATEWAY PLACE, STE. 101E SAN RAFAEL, CA SAN JOSE, CA FOR: DISTRIBUTED ENERGY CONSUMER FOR: SILICON VALLEY LEADERSHIP GROUP ADVOCATES STEVEN S. SHUPE JORDAN PINJUV GENERAL COUNSEL COUNSEL SONOMA CLEAN POWER AUTHORITY CALIFORNIA INDEPENDENT SYSTEM OPERATOR 50 SANTA ROSA AVE., 5TH FL. 250 OUTCROPPING WAY SANTA ROSA, CA FOLSOM, CA FOR: SONOMA CLEAN POWER AUTHORITY (SCPA) FOR: CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION (CAISO) WAYNE AMER ERIC EISENHAMMER PRESIDENT COALITION OF ENERGY USERS MOUNTAIN UTILITIES (906) 4010 FOOTHILLS BLVD., STE 103 NO. 115 PO BOX 205 ROSEVILLE, CA KIRKWOOD, CA FOR: COALITION OF ENERGY USERS FOR: MOUNTAIN UTILITIES ROBERT CASTANEDA SCOTT BLAISING PROTEUS, INC. ATTORNEY 1830 N. DINUBA BLVD. BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. VISALIA, CA L STREET, STE FOR: PROTEUS, INC. SACRAMENTO, CA FOR: CITY OF LANCASTER CHASE KAPPEL LAURA TAYLOR ELLISON SCHNEIDER HARRIS & DONLAN LLP ATTORNEY 2600 CAPITOL AVE., SUITE 400 BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. SACRAMENTO, CA L STREET, STE FOR: VOTE SOLAR SACRAMENTO, CA FOR: SILICON VALLEY CLEAN ENERGY AUTHORITY KAREN NORENE MILLS ATTORNEY CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO, CA FOR: CALIFORNIA FARM BUREAU FEDERATION Information Only AARON (YICHEN) LU AHMAD FARUQUI PROGRAM COORDINATOR THE BRATTLE GROUP CITY OF SAN DIEGO, CA 00000

28 CPUC - Service Lists - R Page 5 of 17 12/4/2017, CA ANDREW BROWN ANDY BLAUVELT ELLISON SCHNEIDER HARRIS & DONLAN LLP MULTIFAMILY AFFORDABLE SOLAR HOMES, CA 00000, CA FOR: THE MULTIFAMILY AFFORDABLE SOLAR HOMES COALITION BARBARA BARKOVICH BRIAN GEISER CONSULTANT BARKOVICH & YAP, CA 00000, CA CARMELITA L. MILLER CASE COORDINATION LEGAL COUNSEL PACIFIC GAS AND ELECTRIC COMPANY THE GREENLINING INSTITUTE, CA 00000, CA DAMON FRANZ DAVID HUANG DIRECTOR - POLICY & ELECTRICITY MARKETS LEGAL FELLOW TESLA, INC. THE GREENLINING INSTITUTE, CA 00000, CA ELI HARLAND EVELYN KAHL CALIFORNIA ENERGY COMMISSION COUNSEL ENERGY RESEARCH & DEVELOPMENT DIV. ALCANTAR & KAHL LLP, CA 00000, CA FRANCOIS CARLIER GAIL L. SLOCUM CODA STRATEGIES PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA GEOFF MCLENNAN, CA HANNA GRENE CENTER FOR SUSTAINBLE ENERGY, CA JACK F. PARKHILL, CA JEREMY WAEN SR. REGULATORY ANALYST MARIN CLEAN ENERGY, CA JOELLE STEWARD JOHN W. LESLIE, ESQ. PACIFICORP DENTONS US LLP, OR 00000, CA 00000

29 CPUC - Service Lists - R Page 6 of 17 12/4/2017 JOSH BODE KAREN SHEA NEXANT PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA MARCUS COLE MARY HOFFMAN ZIMMER PARTNERS SOLUTIONS FOR UTILITIES, INC., CA 00000, CA MATTHEW FREEDMAN MCE REGULATORY THE UTILITY REFORM NETWORK MARIN CLEAN ENERGY, CA 00000, CA MELISSA P. MARTIN NAT TREADWAY SENIOR REGULATORY COUNSEL DISTRIBUTED ENERGY FINANCIAL GROUP STATESIDE ASSOCIATES, TX 00000, VA OWEN SANFORD TESLA, INC., CA PATTI LANDRY REGULATORY ANALYST PACIFIC GAS & ELECTRIC COMPANY, CA PAUL D. HERNANDEZ RICK AS. WALTMAN CENTER FOR SUSTAINABLE ENERGY UNIVERSITY OF SAN DIEGO SCHOOL OF LAW, CA 00000, CA ROGER LEVY SCOTT ENGSTROM LEVY ASSOCIATES, CA 00000, CA SEAN P. BEATTY SEPHRA A. NINOW, J.D. DIRECTOR - WEST REGULATORY AFFAIRS REGULATORY AFFAIRS MGR. NRG WEST CENTER FOR SUSTAINABLE ENERGY, CA 00000, CA SHALINI SWAROOP STEPHEN GEORGE REGULATORY COUNSEL NEXANT MARIN CLEAN ENERGY, CA 00000, CA STEPHEN LUDWICK ZIMMER PARTNERS SUSANNAH CHURCHILL SOLAR POLICY ADVOCATE

30 CPUC - Service Lists - R Page 7 of 17 12/4/2017, CA VOTE SOLAR, CA TADASHI GONDAI MRW & ASSOCIATES, LLC SR. ATTORNEY / DIR OF LEGAL AFFAIRS NATIONAL ASIAN AMERICAN COALITION, CA 00000, CA BENJAMIN AIRTH DAVID MARCUS CENTER FOR SUSTAINABLE ENERGY, CA EAMIL ONLY, CA KAREN TERRANOVA NANCY BROCKWAY ALCANTAR & KAHL NBROCKWAY & ASSOCIATES 10 ALLEN STREET, CA BOSTON, MA PAUL CHERNICK SUSAN GELLER RESOURCE INSIGHT SENIOR RESEARCH ASSOCIATE 5 WATER ST. RESOURCE INSIGHT ARLINGTON, MA WATER ST. ARLINGTON, MA ABRAHAM SILVERMAN MICHAEL PANFIL ASSIST. GEN. COUNSEL - REGULATORY ENVIRONMENTAL DEFENSE FUND NRG ENERGY, INC. 257 PARK AVENUE SOUTH, FLOOR CARNEGIE CENTER DRIVE NEW YORK, NY PRINCETON, NJ FOR: NRG HOME PATRICK JOBIN JAMES (JIM) VON RIESEMANN CREDIT SUISSE SECURITIES (USA) LLC MIZUHO SECURITIES USA, INC. ONE MADISON AVENUE 320 PARK AVENUE, 12TH FLOOR NEW YORK, NY NEW YORK, NY ARMAN TABATABAI GREGORY REISS RESEARCH MILLENNIUM MANAGEMENT LLC MORGAN STANLEY 666 FIFTH AVENUE, 8TH FLOOR 1585 BROADWAY, 38TH FL. NEW YORK, NY NEW YORK, NY DAN DELUREY PAUL M. PIETSCH DEMAND RESPONSE AND SMART GRID COALITION RESEARCH COORDINATOR 1301 CONNECTICUT AVE., NW, STE. 350 DRSG COALITION WASHINGTON, DC CONNECTICUT AVE., NW, STE. 350 FOR: DEMAND RESPONSE AND SMART GRID WASHINGTON, DC COALITION RUTH HUPART SOLAR ELECTRIC POWER ASSOCIATION KATHERINE HOFFMASTER SR. REGULATORY AFFAIRS ANALYST

31 CPUC - Service Lists - R Page 8 of 17 12/4/ TH STREET, NW, STE. 800 NEXTERA ENERGY RESOURCES WASHINGTON, DC UNIVERSE BLVD., FEJ/JB JUNO BEACH, FL DAVID P. LOWREY KELLY CRANDALL DIRECTOR, REGULATORY STRATEGY EQ RESEARCH, LLC COMVERGE, INC TH ST., 16 MARKET SQR., STE TH STREET, SUITE 2300 DENVER, CO DENVER, CO RICK GILLIAM EDWARD JACKSON VOTE SOLAR DIR - REVENUE REQUIREMENTS 1120 PEARL STREET LIBERTY UTILITIES (CALIFORNIA) BOULDER, CO WASHBURN ROAD / PO BOX 7002 DOWNEY, CA SHEILA LEE CASE ADMINISTRATION REGULATORY, CONTROLS AND SOLICITATIONS SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE, PO BOX N. IRWINDALE AVENUE, SUITE A ROSEMEAD, CA IRWINDALE, CA RAQUEL IPPOLITI RUSSELL GARWACKI PROJECT ANALYST SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE WANUT GROVE AVENUE ROSEMEAD, CA ROSEMED, CA SPENCER EDMISTON NGUYEN QUAN CORPORATE FINANCIAL PLANNING MGR - REGULATORY AFFAIRS EDISON INTERNATIONAL GOLDEN STATE WATER CO. - ELECTRIC OP WALNUT GROVE AVENUE 630 EAST FOOTHILL BOULEVARD ROSEMEAD, CA SAN DIMAS, CA FOR: GOLDEN STATE WATER COMPANY / BEAR VALLEY ELECTRIC DAVID CROYLE ANNLYN FAUSTINO EXECUTIVE DIRECTOR REGULATORY & COMPLIANCE UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY 3405 KENYON STREET, STE CENTURY PARK COURT, CP32F SAN DIEGO, CA SAN DIEGO, CA CENTRAL FILES HORACE TANTUM SDG&E / SOCALGAS MARKETING MGR., RESCH & ANALYTICS 8330 CENTURY PARK COURT, CP31-E SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA CENTURY PARK CT., CP62E SAN DIEGO, CA MICHELLE SOMERVILLE ROLAND MULLEN REGULATORY BUSINESS MGR MARKETING MGR. AND RESEARCH SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT 8690 BALBOA AVENUE, CPA03 SAN DIEGO, CA SAN DIEGO, CA 92123