BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA SOUTHERN CALIFORNIA EDISON COMPANY S BRIEF ADDRESSING THE SCOPE OF THE PROCEEDING

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Amended Application of Southern California Edison Company (U 338-E) for Authorization to Recover Costs Related to the 2007 Southern California Wind and Firestorms Recorded in the Catastrophic Event Memorandum Account (CEMA) A (Filed April 22, 2010) SOUTHERN CALIFORNIA EDISON COMPANY S BRIEF ADDRESSING THE SCOPE OF THE PROCEEDING JAMES M. LEHRER JANE LEE COLE Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) jane.lee.cole@sce.com Dated: December 3, 2010

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Amended Application of Southern California Edison Company (U 338-E) for Authorization to Recover Costs Related to the 2007 Southern California Wind and Firestorms Recorded in the Catastrophic Event Memorandum Account (CEMA) A (Filed April 22, 2010) SOUTHERN CALIFORNIA EDISON COMPANY S BRIEF ADDRESSING THE SCOPE OF THE PROCEEDING I. INTRODUCTION On November 8, 2010, the Division of Ratepayer Advocates (DRA) and Southern California Edison (SCE) attended a Prehearing Conference in connection with SCE s application for authorization to recover incremental disaster-related expenses and capital costs incurred in responding to the 2007 southern California wind and firestorms recorded in its Catastrophic Event Memorandum Account (CEMA). Pursuant to the Administrative Law Judge (ALJ) s instructions, SCE timely files this brief addressing the proper scope of this CEMA proceeding. DRA contends that a CEMA applicant must prove not only that its response to a catastrophic event was reasonable, but also must show either: (1) that it was not the cause-in-fact of the event that resulted in the damage, or (2) that it was not at fault for causing the event, i.e., that the utility was in compliance with Commission rules. 2

3 DRA s position not only conflicts with the CEMA statute and Commission precedent, but also undermines the Legislature and the Commission s intent in creating CEMA in the first place: First, the CEMA statute directs the Commission to authorize recovery of costs incurred in responding to a declared disaster, provided only that those costs are reasonable. The plain language and legislative intent of the statute make clear that the reasonableness inquiry is limited to determining whether the utility s response to the disaster after it occurs was prudent. DRA s position that additional conditions be imposed on cost recovery is untenable in that it directly conflicts with the governing statute. Second, the CEMA statute requires the Commission to review the utility s costs of responding to a catastrophe on an expedited basis. 1 This focus on expedited review is central to the statutory objective of encouraging utilities to act quickly to restore service after catastrophic events. DRA s position is incompatible with this statutory directive of expedited review in that it would inject a complex series of determinations regarding causation and fault into the CEMA proceeding. Furthermore, that drawn out series would create an unworkable situation. Whether the utility caused a fire, and if so, whether it was in violation of a Commission rule, can involve technically complex and highly contested issues. For example, the Malibu Canyon fire OII proceeding, in which the inquiry concerns whether one or more of the respondents violated Commission rules with respect to the joint poles at issue in that investigation, has been pending for almost two years and is not expected to conclude soon. If causation and culpability were relevant, a CEMA proceeding would become a mega-oii an outcome that would be unfeasible. Third, DRA s position contradicts Commission precedent. In the context of CEMA, the Commission has consistently defined reasonable costs as those incurred prudently in response to a disaster. Reasonableness in this sense is not dependent on or related to events or actions 1 Cal. Pub. Util. Code 454.9(a). 3

4 prior to the disaster which would include issues of causation and culpability. 2 The Commission has confirmed the definition of reasonable, by stating that costs may be recoverable under CEMA even if they may have resulted from deferred maintenance, infrequent or faulty inspections, or reductions in employees who perform service and safety functions. 3 Fourth, expanding the scope of this CEMA proceeding as proposed by DRA would effectively turn this proceeding into one or more OIIs, except that it would shift the burden of proving that the utility violated one or more Commission rules from staff to the utility. That unprecedented shift would require the utility to prove the negative that it did not violate any rules. The Commission should not endorse such a radical change in the scope of this CEMA proceeding. If the Commission should decide to pursue the issue of causation, it has the authority to initiate one or more OIIs, where detailed investigations can be conducted and penalties can be assessed, if, in fact, Commission rules or regulations were violated. However, DRA should not be allowed to turn this CEMA proceeding into one or more OIIs and avoid altogether the required steps and burdens that it bears in acquiring an OII from the Commission. Finally, DRA s position involves an interpretation of the CEMA statute that would have major policy implications that would affect not just SCE, but also other utilities that may seek CEMA recovery in the future. Therefore, the statutory construction issue raised by DRA should be addressed in a separate rulemaking decided by the full Commission following an opportunity for all potential stakeholders to be heard not merely through briefing by the parties to this proceeding alone. 4 Accordingly, the Scoping Memo should rule that causation and culpability are outside the scope of this proceeding. However, if the decision is made to rule on these legal issues in this CEMA proceeding, then, at a minimum, the full Commission should be required to endorse in advance of any such broad policy change. 2 See Cal. Pub. Util. Code 454.9(b). See e.g. D ; D ; D (discussing the prudent manager standard for CEMA). 3 D , at p See D at p. 17 fn 16 ( We note that, due to important policy issues presented, the correct vehicle for PG&E to request a change to an industry-wide CEMA policy would be to file a petition for a rulemaking, and not in an informal advice letter. ). 4

5 II. BACKGROUND In its CEMA Application, SCE seeks recovery of the costs to repair the damage to its facilities caused by numerous firestorms and windstorms in October and November DRA filed a protest in which it argued that the costs associated with the Malibu Canyon fire should be either disallowed or held in abeyance pending the outcome of the Malibu Canyon fire OII. 5 DRA noted that in the OII, the Commission is investigating the linkage between SCE s facilities and the fire. 6 DRA argued that any finding that SCE violated any rules regarding facilities linked to the fire would be relevant to the reasonableness analysis under Public Utilities Code 454.9(b). 7 In addition, DRA argued that other fires, such as Grass Valley, are the subject of pending government investigations and lawsuits, which DRA claimed may be instructive as to the reasonableness of certain costs for which recovery is sought. 8 If SCE incurred costs from a fire that it started, DRA argued, that fact would argue strongly against SCE receiving any recovery for those specific costs. 9 Finally, DRA further informed SCE that it was conducting its own investigation as to the cause of all of the fires in SCE s CEMA Application, and if it finds any agency report that states that a power line was the cause of any of the fires, it would seek disallowance of SCE s CEMA costs based on those reports. 10 DRA s arguments thus suggest that CEMA recovery with respect to particular fires should be disallowed if two elements are present: (1) SCE caused the fire in question, and (2) SCE s facilities were in violation of Commission rules. DRA does not appear to argue that physical causation, standing alone, would justify denial of a CEMA request. For example, if SCE s facilities complied with the Commission s rules but nevertheless ignited a fire through no 5 Protest of the Division of Ratepayer Advocates (filed July 8, 2010) ( Protest ) at pp Id. at p.2. 7 Id. at pp Id. at p Id. at p Transcript of Prehearing Conference at pp

6 fault of SCE, there would be no reason to deny CEMA recovery. DRA s concern that the utility should not benefit from its own wrong 11 would not be implicated where the utility has not committed a wrong i.e., it was not at fault in causing the fire or SCE did not willfully cause damage to its facilities. In addition, DRA s theory that the reasonableness standard in Public Utilities Code 454.9(b) includes an inquiry into the reasonableness of the utility s conduct that is linked to the fire, 12 if accepted, would require a determination of whether the utility was at fault for causing the fire. The reasonableness standard, where it applies, requires an inquiry into whether a prudent manager would have acted differently. 13 If the utility acted in a prudent manner, but its facilities nevertheless caused the fire, there would be no basis for denying CEMA recovery, even under DRA s approach. Accordingly, DRA s position would require not only a showing that the utility was the cause-in-fact of the fire, but also that the utility was culpable, i.e., that its facilities that ignited the fire were in violation of the Commission s rules. III. DRA S POSITION CONFLICTS WITH THE CEMA STATUTE A. The CEMA Statute Authorizes Recovery Of Costs Of Responding To Catastrophic Events The CEMA statute authorizes the utility to recover the costs of responding to a catastrophic event. The authorization is not limited or qualified by reference to actions that occurred prior to the event. Public Utilities Code 454.9(a) directs the Commission to authorize utilities to establish a CEMA to record the costs of restoring service; of repairing, replacing, or restoring damaged utility facilities; and of complying with government orders. Public Utilities Code 454.9(b) states that the costs recorded pursuant to 454.9(a) shall be recoverable upon a finding of their reasonableness. The statute does not permit a free-ranging inquiry into the 11 Transcript of Prehearing Conference at p Protest at pp See e.g. D ; D ; D (discussing the prudent manager standard). 6

7 reasonableness of the utility s conduct generally. Instead, the only reasonableness inquiry that the Commission may undertake in this context is to evaluate the reasonableness of the costs recorded in the CEMA. The word their, which precedes reasonableness, refers to costs, which in turn refers to the costs recorded in CEMA. Hence, if the utility demonstrates that the costs incurred were reasonable in response to the catastrophic event, the Commission shall authorize their recovery. The Commission does not have discretion to deny recovery on any other basis. The focused inquiry mandated by the statute reflects its purpose: to provide streamlined recovery of costs of responding to declared disasters. Prior to CEMA, utilities had no mechanism for recovering such costs apart from including them as part of the showing in a future general rate case. This regime led to considerable delays and, at best, only partial recovery of costs. In creating CEMA, the Commission and the Legislature recognized that in order to ensure the quick and safe restoration of service to the public after a disaster, utilities needed to be assured that they would be able to recover the associated costs in a timely and focused manner. 14 As a result, the statute entitles the utility to recover its costs of responding to a declared disaster as long as those response costs are reasonable. 15 DRA s position conflicts with the statute by introducing additional conditions on cost recovery. The Commission lacks authority to override the statute in this manner. 16 B. The CEMA Statute Requires Expedited Proceedings DRA s position also conflicts with the statutory directive that CEMA proceedings be conducted in an expedited manner. 17 The Legislature specifically included this requirement because it recognized that the utilities needed a process by which they could recover disaster- 14 See SCE s Reply To Protest at See Public Utilities Code 454.9(b); Senate Bill 1456, Comments dated March 16, 1994, August 13, 1994 and August 16, Kidd v. California (1998) 62 Cal App. 4th 386, 402, quoting Agricultural Labor Relations Bd. v. Superior Court (1976) 16 Cal. 3d 392, Public Utilities Code 454.9(b). 7

8 related costs without delay and that the public would benefit from such prompt proceedings. 18 The legislative intent in passing Senate Bill (SB) 1456, which added Public Utilities Code after the Northridge earthquake in 1994, was primarily to address the utilities concern that the CPUC s special disaster account system was not sufficiently flexible to address the utilities emergency response expenditures, and did not ensure expeditious approval of rate recovery of those expenditures by the CPUC. 19 The California State Assembly s floor bill analysis for SB 1456, dated August 13, 1994, specifically noted that the bill responds to uncertainty and inconsistency in the CPUC decisions about cost recovery expenses incurred during and after the Loma Prieta and Northridge earthquakes. 20 All of the bill analyses emphasized the issue of speedy review of CEMA applications in order to provide maximum incentives to utilities to quickly repair, replace, or restore damaged facilities to minimize impact to customers after a disaster. The statute does not provide for or permit any exception to the requirement of expedited proceedings for certain types of disasters. If the Commission were to create an exception for wildfires, it would effectively be rewriting the CEMA statute and in the case of wildfires the utilities would face the same concerns they, and the Legislature, had before the CEMA statute was adopted: uncertainty, inconsistency, and untimely cost recovery of expenses incurred in quickly responding to declared disasters. The Commission has recognized and complied with the statutory requirement to conduct an expedited CEMA proceeding. For example, in D , the Commission denied a request by the DRA to hold a CEMA application in abeyance because the public interest lies in the timely resolution of this matter in a way that enables PG&E to respond to public emergencies while protecting the interest of ratepayers that all rates remain reasonable See SB 1456, Comments dated March 16, 1994, ( This measure is intended by the author... to ensure that the PUC and utilities have adequate authority to fully repair, replace or restore damaged utility facilities on an expedited basis. ) 19 See SB 1456; Senate s Bill Analysis dated August 16, 1994; D at pp See Senate s Bill Analysis dated August 13, D , at p. 10 (emphasis added). 8

9 DRA s position is incompatible with this statutory directive. Any inquiry into causation and culpability would necessarily inject considerable delay into the proceeding. Indeed, DRA s position would result in a CEMA proceeding that would encompass a full-blown investigation into the utility s conduct and compliance with Commission rules with respect to every fire in which there were even an allegation that the utility was the cause. This is the antithesis of the expedited proceeding mandated by the statute. C. DRA s Position Is Not Feasible DRA s position is also unfeasible. Under existing precedent, the utility has the burden of demonstrating that it acted prudently in response to a disaster. This inquiry is focused and precise, as it should be, given the expedited nature of CEMA recovery. 22 Under DRA s proposed standard, the parties would need to litigate and the Commission would need to adjudicate causation and culpability for each fire. In this Application alone, that could necessitate numerous extended inquiries. Within those inquiries, the parties would need to present detailed, and likely lengthy, testimony regarding complex issues of fire ignition. The parties may also need to solicit testimony from third parties, including experts, should there be contested issues of causation or contributory negligence. In short, the CEMA proceeding would exceed even an OII in the breadth of its consideration of complex causation evidence. In addition, the CEMA proceeding would encompass a determination of whether the utility s facilities were in compliance with Commission rules. This would not only duplicate the subject matter of an OII, but also would involve the Commission in extensive litigation about complex and highly controversial matters. It is simply not workable to turn this CEMA application into a mega-oii. SCE respectfully submits that this proceeding should not go down that untenable course. Instead, the Commission should adhere to its longstanding precedent and require SCE to prove 22 Cal. Pub. Util. Code 454.9(b) ( The commission shall hold expedited proceedings in response to utility applications to recover costs associated with catastrophic events. (emphasis added)). 9

10 only that its costs recorded into the CEMA account are reasonable as a response to the declared disaster. IV. DRA S POSITION CONFLICTS WITH COMMISSION PRECEDENT The Commission has long held that the reasonableness standard in a CEMA proceeding requires consideration of whether the utility acted in a prudent manner in responding to a disaster after it has struck. 23 Although the utility bears the burden of proving that the costs recorded in CEMA are reasonable, 24 that burden is met by showing that it properly managed its response to the disaster once it has occurred an issue entirely separate from whether the utility may have some culpability for the event in question. For example, in D , the Commission detailed the relevant reasonableness inquiries, all of which focused on the reasonableness of the management of the restoration of service and the reasonableness of the actual cost amounts recorded. 25 None of the reasonableness topics considered any conduct or actions that occurred before the start of the declared disaster. 26 Likewise, in D , the Commission made clear that SDG&E had the burden to demonstrate that in fact its responses to the 2003 Wildfires were prudent and consistent with the Commission's standard for prudent managerial action See e.g. D ; D ; D D at p. 5 ( It is the utility... that faces the burden of showing with clear and convincing evidence that its course of action was reasonable and therefore entitled to rate recovery. ) 25 D at p SCE notes that in D , the Commission considered a settlement of a CEMA application seeking recovery of costs associated with the 1998 El Nino storms. Id. at p. 1. The Commission stated that it might be relevant to consider whether some of the costs recorded to CEMA could have been avoided by actions that could have been taken before the start of the storms. Id. at p. 10. This decision is distinguishable on two primary bases. First, D involves the Commission s consideration of the propriety of a settlement, as opposed to a Commission determination of the reasonableness of costs recorded to CEMA. Thus, the posture of the Commission s review in D is not the same as a reasonableness review under 454.9(b). Second, in D , the Commission noted its skepticism about whether El Nino storms, which are predictable in advance, are properly the subject of CEMA, because CEMA is intended for truly unexpected catastrophic events. Id. at p Thus, the Commission likely decided that a reasonableness review that took into consideration the predictability of the El Nino event and the question whether the utility had planned appropriately for it was in order due to the specific nature of the relevant disaster. Here, it is undisputed that the 2007 wildfires, including the Canyon Fire, were true unexpected catastrophic events. 27 D at p. 9 (emphasis added). 10

11 DRA s position conflicts with this longstanding precedent. Further, the Commission specifically rejected DRA s position in D , where the Commission stated that costs may be recoverable under CEMA even if they may have resulted from deferred maintenance, infrequent or faulty inspections, or reductions in employees who perform service and safety functions. 28 Thus, the Commission has concluded that CEMA allows recovery even where a disaster resulted, in whole or in part, from negligence on the part of the utility. DRA provides no reasonable basis for the Commission to deviate from that controlling precedent. Finally, DRA s proposal, insofar as it relies upon mere allegations by civil litigants or fire agencies that a utility facility caused a fire, seeks to significantly broaden the reasonableness standard in a CEMA proceeding and is at odds with Commissioner Simon s Ruling and Scoping Memo in I the Malibu Canyon OII in which Commissioner Simon held the Commission neither determines nor resolves proximate cause issues. Those are matters that are within the jurisdiction of the civil courts, and the Commission s regulatory determinations appropriately do not presume to influence the courts findings on civil liability or damages. 29 By the same logic, actions in civil courts and other forums should not influence the Commission s regulatory determinations (except where official notice can be taken in accordance with the Commission s Rule 13.9 and Cal. Evid. Code 450 et seq.) Considering the purpose of CEMA expedited recovery for prudently managed disaster recovery costs an issue like causation should not be the focal point of this proceeding when it would not be an issue in an OII for the same fire. V. EXPANDING THE SCOPE OF THIS CEMA PROCEEDING WOULD EFFECTIVELY TURN IT INTO ONE OR MORE OIIS AND IMPROPERLY SHIFT THE BURDEN OF PROOF Expanding the scope of this CEMA proceeding as proposed by DRA, and requiring SCE to rebut any and all allegations regarding causation (whether raised by DRA or by plaintiffs in 28 D , at p Ruling and Scoping Memo, in I , at p

12 civil litigation or by fire agencies) would effectively turn this proceeding into one or more OIIs. Moreover, adding lack of causation as part of the utility s burden of proof in a CEMA application would shift the burden from the Commission staff (which in an OII has the burden to prove that the utility violated one or more Commission rules, directives, or statutes) to the utility. The utility would have to rebut any and all allegations (whether made on the record in the CEMA proceeding or originating elsewhere) that it may have caused the fire or that it may have been at fault for the fire. This radical change in the scope of CEMA proceedings is unwise and unwarranted. The proper forum to address the issue of causation, if the Commission decides to pursue it, is in an OII proceeding, where formal investigations can be conducted and penalties can be assessed, if, in fact, there has been a violation of Commission rules or regulations. However, DRA should not be allowed to turn this CEMA proceeding into one or more OIIs and avoid altogether the required steps and burdens that it bears in acquiring an OII from the Commission. The off-the-record suggestion that all that the utility applicant would have to do to recover the costs of restoring service following a wildfire disaster would be to include a declaration in its direct showing that, prior to the fire, its lines were in pristine condition, or declare that its facilities were in compliance with all relevant rules, would not alleviate this problem. The Commission has recognized that 100 percent compliance with the Commission s General Orders at all times is not realistic. 30 Hence, such compliance cannot and should not be a prerequisite for cost recovery. It is also unclear when and how the utility applicant would be responsible to make such a showing. The suggestion that CEMA proceedings generally do not involve showings of causation, but that an exception must be made when allegations of utility wrongdoing have been raised either at the Commission or elsewhere, implies that the utility s burden should be met in rebuttal, after the Commission staff and/or third parties have first raised such allegations following the filing of the application. On the other hand, if such allegations, 30 D , issued April 22, 2004 in I (SCE s Line Maintenance OII), at p. 31 (mimeo.). The Commission was referring to General Orders 95 and 128 in that decision. 12

13 i.e., third party claims in civil litigation or fire agency reports, are known when the CEMA application is filed, it could be the case that the utility would be expected to address those allegations in its direct showing accompanying the CEMA application. At that point, what would be the utility s burden? Must it show that its lines were in full compliance with all rules, despite the Commission s acknowledgement that this standard is not practically achievable? Or, must the utility engage in a full-blown litigation of the allegations in order to be assured of recovery for the costs of quickly restoring service to its customers, despite Commissioner Simon s Malibu Fire OII ruling that the Commission does not substitute its judgment for the civil courts in matters of causation? In short, any such requirement would be neither simple nor straightforward. VI. THE ISSUE OF WHETHER CAUSATION SHOULD BE ADDRESSED IN CEMA PROCEEDINGS SHOULD BE DECIDED IN A RULEMAKING PROCEEDING Because DRA s position involves a novel interpretation of the CEMA statute as well as a proposed major policy shift in the way CEMA cases have been handled, if implemented, it would affect not just SCE but other utilities that may seek CEMA recovery in the future. Therefore, the Commission should not adopt such a major policy change without providing an opportunity for all potential stakeholders to be heard. These broad legal and policy issues should be addressed, if at all, by the full Commission in a generic proceeding such as a rulemaking, and not through the Scoping Memo process in an individual utility proceeding. SCE does not believe the issues have been properly raised for full Commission consideration; however, if the decision is made to rule on these legal issues in this CEMA proceeding, then at a minimum the full Commission should establish any such broad policy changes. 13

14 VII. CONCLUSION DRA s position should be rejected and issues of causation and culpability should be declared outside the scope of this proceeding. Respectfully submitted, JAMES M. LEHRER JANE LEE COLE /s/ Jane Lee Cole By: Jane Lee Cole Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) jane.lee.cole@sce.com December 3,

15 CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY S BRIEF ADDRESSING THE SCOPE OF THE PROCEEDING on all parties identified on the attached service list(s). Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. First class mail will be used if electronic service cannot be effectuated. Executed this 3 rd day of December, 2010, at Rosemead, California. /s/ Melissa Schary By: Melissa Schary SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California

16 CPUC - Service Lists - A Page 1 of 2 12/3/2010 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - TO RECOVER FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: NOVEMBER 8, 2010 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties JANE LEE COLE, ESQ. ED MOLDAVSKY SOUTHERN CALIFORNIA EDISON COMPANY CALIF PUBLIC UTILITIES COMMISSION PO BOX 800 / 2244 WALNUT GROVE AVENUE LEGAL DIVISION ROSEMEAD, CA ROOM 5037 FOR: SOUTHERN CALIFORNIA EDISON COMPANY 505 VAN NESS AVENUE SAN FRANCISCO, CA FOR: DIVISION OF RATEPAYER ADVOCATES PETER VAN MIEGHEM ATTORNEY AT LAW PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, ROOM 3107 SAN FRANCISCO, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY Information Only MRW & ASSOCIATES, LLC ONLY ONLY, CA GREGORY HEALY SOCALGAS/SDG&E 555 WEST FIFTH STREET, GT14D6 LOS ANGELES, CA CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY ANTHEA LEE PACIFIC GAS AND ELECTRIC COMPANY

17 CPUC - Service Lists - A Page 2 of 2 12/3/ WALNUT GROVE AVENUE, PO BOX BEALE STREET, MC B9A, ROOM 904 ROSEMEAD, CA SAN FRANCISCO, CA CASE COORDINATION ERROL KISSINGER PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY PO BOX ; MC B9A, 77 BEALE STREET 77 BEALE STREET; MC B10A SAN FRANCISCO, CA SAN FRANCISCO, CA FRANCES YEE CALIFORNIA ENERGY MARKETS PACIFIC GAS AND ELECTRIC COMPANY 425 DIVISADERO ST. SUITE BEALE STREET, MC B10A SAN FRANCISCO, CA SAN FRANCISCO, CA State Service MARIBETH A. BUSHEY ROBERT M. POCTA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 5018 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA CLARE FRANK ROBIN HARRINGTON DEPUTY CHIEF - CIVIL COST RECOVERY CAL.DEPT OF FORESTRY AND FIRE PROTECTION OFFICE OF THE STATE FIRE MARSHAL PO BOX PO BOX SACRAMENTO, CA SACRAMENTO, CA MELODIE DURHAM OFFICE OF THE STATE FIRE MARSHAL WILDLAND FIRE PREVENTION 1131 S STREET SACRAMENTO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS