BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA JOINT APPLICANTS OPENING BRIEF

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E), San Diego Gas & Electric Company (U 902-E) and the Natural Resources Defense Council for Rehearing of Resolution E-4792 Application (Filed July 25, 2016) JOINT APPLICANTS OPENING BRIEF Ellen N. Adler 8330 Century Park Court, CP32D San Diego, CA Telephone: (858) (Adler) Facsimile: (619) Attorney for San Diego Gas & Electric Company Janet S. Combs Rebecca Meiers-De Pastino 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, CA Telephone: (626) Facsimile: (626) Attorneys for Southern California Edison Company Peter Miller 111 Sutter St., 20 th Floor San Francisco, CA Telephone: (415) Senior Scientist for Natural Resources Defense Council June 15, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E), San Diego Gas & Electric Company (U 902-E) and the Natural Resources Defense Council for Rehearing of Resolution E Application (Filed July 25, 2016) JOINT APPLICANTS OPENING BRIEF Pursuant to Rule of the Rules of Practice and Procedure of the California Public Utilities Commission (the Commission ) and the Administrative Law Judge s Ruling Setting Schedule for Briefs on Issues in Scope of Application for Rehearing issued April 18, 2018, Southern California Edison Company ( SCE ), San Diego Gas & Electric Company ( SDG&E ), and Natural Resources Defense Council ( NRDC ) (collectively, Joint Applicants ) submit this Opening Brief. I. BACKGROUND AND SUMMARY The Commission issued D (the Decision ) with the general policy goal for the net energy metering ( NEM ) successor tariff to move the economic contribution of NEM customers toward being more consistent with the contribution of other customers. 1 The NEM successor tariff moved in that direction through three new mandates for NEM customers: [1] paying interconnection fees; [2] paying the nonbypassable charges identified by this decision for all energy consumed from the grid; and [3] using the default residential TOU rate, or using any other available TOU rate D at 86. Id.

3 This Application only concerns the second mandate, the change in the assessment of nonbypassable charges ( NBCs ). The Decision clearly explained what it meant by paying for all energy consumed from the grid, 3 contrasting the then-current NEM tariff, which assessed NBC charges based on the netted-out volume of electricity consumed from the grid, with the successor NEM tariff, which would mandate payment on the full amount of electricity consumed from the grid: Under the current NEM tariff, NEM customers pay the nonbypassable charges embedded in their volumetric rates. They do so, however, only on the netted-out quantity of energy consumed from the grid, after subtracting any excess energy they supply to the grid. Since the prior statutory direction to calculate charges on a net consumption basis has been eliminated in AB 327, it is possible for the NEM successor tariff to align more closely with the way customers not using the NEM successor tariff pay for nonbypassable charges. NEM successor tariff customers must pay nonbypassable charges on each kwh of electricity they consume from the grid in each metered interval. This will eliminate the reduction in available kwh on which to pay the nonbypassable charges that now occurs when such charges are assessed only on the netted-out volume of electricity consumed from the grid, by mandating payment of nonbypassable charges on the full amount of electricity the NEM successor tariff customer receives from the grid, as with other customers. 4 On May 17, 2016, the Commission s Energy Division issued Draft Resolution E-4792, which erroneously interpreted D as requiring NBCs to be calculated based on nettedout volume of electricity in each metered interval, rather than on each kwh of electricity consumed from the grid in each metered interval. Over the utilities objections to the Draft Resolution, 5 the Commission adopted it on June 23, Id. (emphasis added) D at (emphasis added). See Comments of Southern California Edison Company (U 338-E) on Draft Resolution E-4792 Adopting PG&E s, SCE s, and SDG&E s Net Energy Metering Successor Tariffs as Directed by Decision , dated June 7, 2016; Pacific Gas & Electric Company s Comments on Draft 2

4 On July 25, 2016, Joint Applicants applied for rehearing of Resolution E-4792 because its interpretation of NBCs violated the plain language and intent of the Decision, was not supported by the evidentiary record, and violated Commission precedent and relevant statutes. On August 9, 2016, the Solar Energy Industries Association and the California Solar Energy Industries Association filed a response, opposing Joint Applicants Application for Rehearing. On May 26, 2017, the Commission issued D , the Order Granting Limited Rehearing of Resolution E-4792 ( Rehearing Order ). The Rehearing Order acknowledged that Resolution E-4792 s finding of an implicit netting requirement was inconsistent with the Decision s language that NBCs should be calculated based on total consumption. 6 The Order granted rehearing to address the question of how best to interpret D s language with respect to the calculation of NBCs, and to consider whether this language should be modified for the sake of clarity. Joint Applicants accept the Commission s direction in the Rehearing Order that the Commission has granted limited rehearing of Res. E-4792, not D , which is final and the holdings of which are not subject to re-litigation. 7 Joint Applicants firmly stand by their reading of D related to the assessment of NBCs, as expressed in their Comments on Resolution E-4792, filed June 7, 2016, and their Application for Rehearing of Resolution E- 4792, A , filed July 25, Joint Applicants respectfully contend that the Decision is clear in its direction to eliminate all netting from the calculation of NBCs, such that NBCs are assessed based on total Resolution E-4792, dated June 7, 2016; and SDG&E s Comments on Draft Resolution E-4792, dated June 7, Order Granting Limited Rehearing of Resolution E-4792 ( Rehearing Order ), dated May 25, 2017, at 7-8. Id. at 11. 3

5 consumption from the grid. Joint Applicants believe modification of D is not necessary to clarify this point, nor are hearings or workshops on this subject needed. Joint Applicants contend there are no safety issues raised by the Application. II. D REQUIRES CALCULATION OF NBCS BASED ON TOTAL USAGE CONSUMED FROM THE GRID, NOT USAGE NETTED WITH EXPORTS A. D s Plain Language Requires That NBCs Be Calculated Based on Total Consumption, Without Any Netting Resolution E-4792 incorrectly construed D to require that NBCs be assessed on a NEM successor tariff customer s net consumption of electricity in each metered interval, rather than the total imports from the grid in each metered interval (without netting imports from and exports to the grid). Importantly, while verbiage such as net, netting, and netted-out are used elsewhere in D to describe the predecessor tariff, the Decision never uses any variation of the term net to explain how NBCs should be calculated for the NEM successor tariff. As Joint Applicants explained in the Rehearing Application, [n]ot only does the Decision make no reference to netting within the metered interval, it explains precisely why billing must not be on the net kwh, stating, [t]his will eliminate the reduction in available kwh on which to pay the nonbypassable charges that now occurs when such charges are assessed only on the netted-out volume of electricity consumed from the grid. 8 Making the intended elimination of netting for the successor tariff even more clear, this passage elaborates that the new methodology will mandate[e] payment of nonbypassable charges on the full amount of 8 Application of Southern California Edison Company (U 338-E), San Diego Gas & Electric Company (U 902-E) and the Natural Resources Defense Council for Rehearing of Resolution E-4792 ( Rehearing Application ), dated July 25, 2016, at 7 (emphasis added). 4

6 electricity the NEM successor tariff customer receives from the grid, as with other customers. 9 In other words, under the successor NEM tariff, nonbypassable means precisely that NEM customers cannot bypass such charges by reducing them through a netting calculation. In adopting D , the Commission knew how to use netting terms when it so intended, particularly because netting was part and parcel of the original NEM tariff, as set forth in Section 2827 of the Public Utilities Code. This is not a case of the Commission meaning to use (and implicitly intending to incorporate) the term netting in the Decision, but inadvertently leaving it out. The Decision s plain language demonstrates an opposite intent. In addition to the key passage from page 89 of the Decision, cited above, the Decision states, in numerous different ways, that the NEM successor tariff should be based on total consumption without any subtraction for exports: In this Decision, the Commission... [c]ontinues the basic features of the current NEM tariff into the NEM tariff, but makes changes that... [r]equire customers on the NEM successor tariff to pay nonbypassable charges that are levied on each kilowatt-hour (kwh) of electricity the customer obtains from the IOU in each metered time interval, regardless of the monthly netting of the kwh obtained from the IOU and exported to the grid by the customer ); 10 To make the contribution of NEM successor tariff customers more consistent with the contribution of other customers, the tariff requires 9 10 D at 89 (emphasis added). Id. at 2-3 (emphasis added). 5

7 payment of the nonbypassable charges identified by this decision for all energy consumed from the grid; 11 Changing the NEM tariff regime so that NEM successor customers must pay NEM successor tariff nonbypassable charges on each kwh of electricity they consume from the grid in each metered interval will recover costs that all customers pay in a fairer and more transparent way than under the current NEM tariff. 12 Continuing net energy metering with NEM successor tariff customers paying reasonable charges for interconnection and paying nonbypassable charges for all electricity consumed from the grid, as well as being on an applicable TOU rate, is likely to allow customer-sited renewable DG to continue to grow sustainably. ) 13 The Order Granting Rehearing acknowledged that passages in the Decision, such as some of those referenced above, which do not include the phrase in each metered interval, appear[] to determine that NBCs should be calculated based on total consumption 14 i.e., sans netting. For those passages that do contain the phrase in each metered interval, the Joint Applicants proffered a plausible reading of the phrase in the Rehearing Application, and continue to stand by this reading. D refers to metered intervals incidentally, as a result of cautious drafting. The language is a perfunctory and high level instruction on practical and Id. at 86 (emphasis added) (no reference to metered interval). Id. at (emphasis added). Id. at 110 (Finding of Fact 32) (emphasis added) (no reference to metered interval); see also id. at 111 (Finding of Fact 40) (similar language with no reference to metered interval). Rehearing Orderat 7. 6

8 operational matters relating to utility tracking of consumption: electricity imports are tracked for each customer using a meter and consumption is reflected on a metered interval basis. For non- NEM customers, the volume of electricity imported by a customer within each metered interval is used to calculate the NBCs owed by that customer. 15 This reading harmonizes the references to the metered interval with the numerous passages not using the term netting or metered interval, but rather language solely reflective of total consumption from the grid. This reading is also consistent with Joint Applicant s interpretation of this language in the Proposed Decision (which did not change in the Final Decision). 16 The Joint Applicants are not the only parties who read the in each metered interval language in this manner parties such as the Office of Ratepayer Advocates ( ORA ), California Farm Bureau Federation, Brightline Defense Project, and even the The Alliance For Solar Choice, Solar Energy Industries Association, California Solar Energy Industries Association, and Vote Solar ( Joint Solar Parties ) interpreted this language in the Proposed Decision to mean that there would no longer be any netting for NBCs for NEM customers: Rehearing Application at 7. San Diego Gas & Electric Company (U 902 E) Comments On Proposed Decision, dated January 7, 2016, at 9-10 n.31 ( The PD recognizes that since NBCs support important programs that are used by and benefit all ratepayers, including NEM customers, NEM customers should pay nonbypassable charges on each kwh of electricity they consume from the grid in each metered interval rather than only on the netted out quantity of energy consumed from the grid. ); Southern California Edison Company s (U 338-E) Amended Comments On Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 11, 2016, at 10 ( The PD recommends that all energy deliveries to successor tariff customers should be billed for NBCs that are partially avoided with full retail netting of deliveries and exports. The PD concludes that future successor tariff customers should pay nonbypassable charges on each kwh of electricity they consume from the grid in each metered interval [each hour], (but not on their own generation consumed on site)[.] ); Comments Of The Natural Resources Defense Council (NRDC) On Proposed Decision, dated January 7, 2016, at 1 ( NRDC strongly supports the change in the residential NEM successor tariff to require NEM customers to pay the nonbypassable charges that are levied on each kilowatt-hour (kwh) of electricity the customer obtains from their utility (IOU) in each metered time interval, regardless of the monthly netting of the kwh obtained from the IOU and exported to the grid by the customer. ). 7

9 ORA commented that the PD changed the NEM tariff by requiring NEM customers to pay nonbypassable charges that are levied on each kilowatthour (kwh) of electricity the customer obtains from the Investor-Owned Utility (IOU) regardless of the monthly netting of the kwh obtained from the IOU and exported to the grid by the customer. 17 The California Farm Bureau Federation commented that the length of the metering intervals should not be at issue because it is total usage, the sum of all intervals, which will be subject to the nonbypassable charges. The reference to each metered interval is therefore understood to mean that all metering intervals will be billed for nonbypassable charges, not just the net-metered intervals. 18 Brightline Defense Project commented, We Support the Commission s Proposed Decision to Include Nonbypassable Charges on the Full Opening Comments Of The Office Of Ratepayer Advocates On The Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 7, 2016, at 1 (emphasis added). See also Reply Comments Of The Office Of Ratepayer Advocates On The Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 15, 2016, at 3 ( [T]he PD is correct to mandate payment of nonbypassable charges on the full amount of electricity the NEM successor tariff customer receives from the grid, as it is with other customers. In addition, the PD does not specify that it is changing which NBCs are charged to NEM customers. On the contrary, the PD only specifies that under the current NEM tariff, NEM customers pay nonbypassable charges embedded in their volumetric rates. The PD is now requiring those same NBCs currently paid by NEM customers on a net consumption to be paid on gross consumption. The Commission should retain the requirement that all currently assessed NBCs be charged on each kwh of electricity that NEM successor tariff customers consume from the grid. ) (emphasis added). Comments Of California Farm Bureau Federation Supporting The Proposed Decision Of Administrative Law Judge Anne E. Simon, dated January 7, 2016, at 3-4 (emphasis added). 8

10 Amount of Non-Self Generated Energy that NEM Customers Draw From The Grid. 19 In commenting on the Proposed Decision, the Joint Solar Parties did not argue against the finding that NEM customers should pay NBCs in each metered interval for each kilowatt-hour of electricity they consume from the grid. 20 Rather, their sole dispute with respect to NBCs was the inclusion of certain charges within the NBC bucket they requested modifications to make clear that NBC charges are limited to public purpose program (PPP) charges, nuclear decommissioning (ND) charges, competition transition charges (CTC), and the Department of Water Resources (DWR) bond costs and, second, that NEM customers will not be assessed transmission charges or New System Generation charges. 21 Unlike for undisputed NBCs such as PPP, ND, CTC and DWR, the Joint Solar Parties opposed NEM customers being charged for transmission and New System Generation based on their full delivered volumes. 22 And, they made clear that full delivered volumes would be in direct contrast Opening Comments of Brightline Defense Project and the Salvadoran American Leadership and Educational Fund on the Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 7, 2016, at 3 (emphasis added). Comments Of The Alliance For Solar Choice, Solar Energy Industries Association, California Solar Energy Industries Association And Vote Solar On The Proposed Decision Adopting Successor To Net Energy Metering Tariff ( Joint Solar Parties Comments on PD ), dated January 7, 2016, at 6. Id. at 6-7. Id. at 8. 9

11 to (or instead of ) on just the net usage from the grid (as is the practice today). 23 The Joint Solar Parties further showed agreement with the PD s calculation of NBCs based on the full amount of power they receive from the grid, rather than net usage, in the following request for clarification: The PD should be modified to make clear that the additional contribution of NEM customers to NBCs should be presented on the customer s bill as an additional line item charge. This line item would be calculated each month as the sum of the applicable NBC charges (PPP, ND, CTC, and DWR) times the difference between (1) the customer s total metered consumption (as stated in the PD on page 89, the full amount of electricity the NEM successor tariff customer receives from the grid ) and (2) its net usage ( the total metered consumption minus the energy sent to the grid ). As NEM customers already pay for NBCs on their net usage, this additional charge will ensure that NEM successor tariff customers pay NBCs on the full amount of power they receive from the grid. 24 Notably, parties who either opposed the PD s treatment of NBCs, or wanted an exemption from it, also interpreted the PD s plain language to eliminate any netting for NBCs: The Federal Executive Agencies ( FEA ) opposed the PD s elimination of netting for NBCs as follows: The PD would terminate the existing method of assessing nonbypassable charges to NEM customers based on the netted-out volume of electricity they consume from the grid. Instead, the PD would require NEM customers to pay nonbypassable charges on each kwh of electricity they consume from the grid, thereby eliminating the netting of the customer s energy exports back to the grid for the purpose of assessing nonbypassable charges. The FEA objects to this provision of the PD and urges the Commission to maintain the current method of assessing nonbypassable charges to NEM customers in the NEM successor tariff Id. Id. at 10 (emphasis added). Comments Of The Federal Executive Agencies On The Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 7, 2016, at 1-2 (emphasis added). 10

12 Foundation Windpower, in requesting an exemption from the PD s treatment of nonbypassable charges, found that the Commission intended to eliminate netting for NBCs for all NEM customers: Specifically, the proposed expansion of nonbypassable charges ( NBCs ) to all kwhs of electricity consumed from the grid in each metered interval, without regard to the export of electricity to the grid by the NEM generator, would impose a massive and unfair new tax on the LC&I class of ratepayers that will render their use of wind generation under NEM economically infeasible and eliminate any chance for its sustainable growth. Foundation urges that the PD be revised so that LC&I customers on LC&I tariffs deploying wind energy under NEM continue to pay NBCs on the netted-out quantity of energy they actually consume from the grid after subtracting any excess energy they supply to the grid. 26 The Net Energy Metering Public Agency Coalition 2.0 parties opposing the PD s treatment on nonbypassable charges with respect to public agencies had the identical interpretation of the PD: [T]he PD should be modified to exempt public agencies from the requirement that nonbypassable charges be paid on all energy drawn from the grid.... Given the unique circumstances of public projects, they should not be subject to this change and instead should be allowed to continue the current system of paying nonbypassable charges only on net energy Opening Comments Of Foundation Windpower, LLC On Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 7, 2016, at 2 (citations omitted) (emphasis added). Of note, NLine Energy, WalMart Stores, and Sam s West agreed with Foundation Windpower s comments, showing an identical interpretation of the PD s treatment of NBCs. See Reply Comments Of NLine Energy, Inc. On The Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 15, 2016, at 4 ( Like Foundation Windpower, NLine Energy urges the Commission to revise the PD so that commercial and industrial customers continue to pay NBCs on the netted out quantity of energy they consume from the grid. ); and Reply Comments Of Wal-Mart Stores, Inc. And Sam s West, Inc. On Proposed Decision, dated January 12, 2016, at 3 ( Walmart agrees with Foundation Windpower s contention that, due to the highly intermittent nature of wind resources, the PD s exclusion of nonbypassable charges ( NBCs ) from the export credits available under the NEM successor tariff will have a significantly detrimental impact on the economics of future wind generation deployments by large C&I customers. ) (emphasis added). 27 Comments On The Proposed Decision By Inland Empire Utilities Agency, Padre Dam Municipal Water District, Rancho California Water District, San Bernardino Valley Municipal Water District, Sweetwater Authority, Terraverde Renewable Partners And Valley Center Municipal Water District, 11

13 The Multifamily Affordable Solar Homes Coalition ( MASH Coalition ) requested an exemption from the NBC holding with respect to low-income multi-family VNM customers: Imposing the nonbypassable charges on all electricity used by NEM customers, regardless of net generation, is a fair idea to fund important public-purpose programs. However, the PD errs in not providing a discount to low-income multifamily VNM customers[.] 28 B. No Party Advocated Basing NBCs on Net Usage at the Metered Interval No party in the proceeding below mentioned, proposed, discussed or considered, let alone advocated NBCs to be calculated based on net usage within each metered interval. Indeed, as the Decision notes, [t]he majority of parties support[ed] changing the way NEM successor tariff customers pay for nonbypassable charges (or at least the public purpose program portion of the charges) to align with payment of such charges by customers not using the NEM successor tariff. 29 dated January 7, 2016, at 4 (emphasis added). Of note, the Local Government Sustainable Energy Coalition agreed with these comments with respect to NBCs. See Reply Comments Of The Local Government Sustainable Energy Coalition On Proposed Decision For Successor To Net Energy Metering Tariff, dated January 15, 2016, at 3 ( The LGSEC concurs with the NEM-PAC that the Proposed Decision should be modified to continue the current system of paying non-bypassable charges on net energy only for public projects. ) (emphasis added) Comments of the Multifamily Affordable Solar Homes Coalition on the Proposed Decision Adopting Successor To Net Energy Metering Tariff, issued December 15, 2015, dated January 7, 2016, at 2 (emphasis added). D at 90. For support for this statement, see, e.g., Opening Brief of the Utility Reform Network, dated October 19, 2015, at 4-6 (arguing nonbypassable, Public Purpose Program costs should be recovered through usage-based charges ); Reply Brief of the Utility Reform Network, dated October 26, 2015, at 15 ( TURN s VODE tariff would continue the practice of charging all customers, including those with onsite generation, for PPP costs on the basis of total onsite usage. As a result, the addition of onsite generation would have no impact on the customer s PPP contributions. ); Opening Brief of the Natural Resources Defense Council (NRDC), dated October 19, 2015, at 2 ( NRDC recommends the Commission adopt a residential NEM successor tariff that includes: 1. A non-bypassable Public Purpose Program (PPP) charge based on grid import consumption of electricity[.] ); Opening Comments Of The Greenlining Institute On The Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 7, 2016, at 5 (citations omitted) ( Greenlining supports the PD s requirement that NEM customers pay a nonbypassable 12

14 Because no parties advocated netting at the metered interval for NBCs, whether in testimony or briefing, there is simply no record on the economic effects or policy implications of such netting although, there is ample record evidence that netting, in general, under the predecessor tariff results in a considerable cost shift from NEM customers to non-nem customers. 30 Joint Applicants respectfully submit that the D could not have meant to implement a netting methodology based on zero record evidence and, without even using the word netting with respect to nonbypassable charges for the successor tariff. III. D DOES NOT NEED TO BE MODIFIED Joint Applicants contend that D does not need to be modified, as it clearly expressed the intent to make nonbypassable charges not bypassable that is, not subject to any netting calculation. However, to the extent the phrase at the metered interval has caused confusion in interpreting the Decision, Joint Applicants propose deleting this language throughout the Decision in all sections referring to NBCs for the successor tariff. charge for each kwh they consume, as these charges support critical programs that provide significant social benefits. ); Opening Comments of Brightline Defense Project and the Salvadoran American Leadership and Educational Fund on the Proposed Decision Adopting Successor To Net Energy Metering Tariff, dated January 7, 2016, at 3 ( We Support the Commission s Proposed Decision to Include Nonbypassable Charges on the Full Amount of Non-Self Generated Energy that NEM Customers Draw From The Grid. ). 30 See, e.g., Opening Brief of San Diego Gas & Electric Company (U 902 E), dated October 19, 2015, at 25 (citations omitted): The current NEM program collects the PPP surcharge from all customers on a volumetric, per-kwh basis through the customer s otherwise applicable tariff ( OAT ). This has resulted in a significant undercollection of PPP charges from NEM customers. Indeed, the Commission has estimated that under the current rate design, with a complete deployment of systems to the NEM cap, NEM customers would avoid approximately $142 million in PPP charges in

15 IV. THE APPLICATION FOR REHEARING DOES NOT RAISE ANY SAFETY ISSUES Joint Applicants do not believe that the Application for Rehearing raises any safety issues. V. NEITHER WORKSHOPS NOR HEARINGS ARE NECESSARY As stated in the Order Granting Limited Rehearing of Resolution E-4792, D resolved the issue of how the successor NEM tariff would assess NBCs. 31 Joint Applicants do not seek to relitigate the hotly contested proceedings culminating in the adoption of D Rather, the issue at hand is simply the correct interpretation of D Thus, it is not necessary or even appropriate to take new evidence in the form of written testimony or hearings. As the Rehearing Order stated, the purpose of rehearing is to identify and resolve legal error, not to receive and evaluate new evidence. 32 Similarly, no workshops are necessary or appropriate. The record is complete, and the Commission has before it all that it needs to decide what D meant with respect to the assessment of NBCs. Respectfully submitted, /s/ Ellen N. Adler Ellen N. Adler 8330 Century Park Court, CP32D San Diego, CA Telephone: (858) Facsimile: (619) Attorney for San Diego Gas & Electric Company June 15, 2018 And on behalf of: Southern California Edison Company Natural Resources Defense Council Rehearing Order at 3. Rehearing Order at

16 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E), San Diego Gas & Electric Company (U 902-E) and the Natural Resources Defense Council for Rehearing of Resolution E-4792 Application (Filed July 25, 2016) CERTIFICATE OF SERVICE I hereby certify that a copy of JOINT APPLICANTS OPENING BRIEF has been electronically mailed to each party of record of the service list in A Any party on the service list who has not provided an electronic mail address was served by placing copies in properly addressed and sealed envelopes and by depositing such envelopes in the United States Mail with first-class postage prepaid. Copies were also sent via Federal Express to the Administrative Law Judges. Executed June 15, 2018 at San Diego, California. /s/ Tamara Grabowski Tamara Grabowski

17 CPUC - Service Lists - A Page 1 of 3 6/15/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISION, SDG&E, AND FILER: NATURAL RESOURCES DEFENSE COUNCIL LIST NAME: LIST LAST CHANGED: MAY 25, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties REBECCA MEIERS-DE PASTINO ELLEN N. ADLER SR. ATTORNEY SR. COUNSEL SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVENUE / PO BOX CENTURY PARK COURT, CP32D ROSEMEAD, CA SAN DIEGO, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY PETER MILLER JEANNE B. ARMSTRONG SR. SCIENTIST ATTORNEY NATURAL RESOURCES DEFENSE COUNCIL GOODIN MACBRIDE SQUERI & DAY LLP 111 SUTTER STREET, 20TH FL. 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: NATURAL RESOURCES DEFENSE COUNCIL FOR: SOLAR ENERGY INDUSTRIES BRAD HEAVNER POLICY DIRECTOR CALIFORNIA SOLAR & STORAGE ASSCIATION TH ST., SUITE 820 SACRMENTO, CA FOR: CALIFORNIA SOLAR & STORAGE ASSICATION (CALSSA) F/K/A CALIFORNIA SOLAR ENERGY INDUSTRIES ASSOCIATION

18 CPUC - Service Lists - A Page 2 of 3 6/15/2018 Information Only MRW & ASSOCIATES LLC ONLY ONLY, CA CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY 8631 RUSH STREET ROSEMEAD, CA MARISSA BLUNSCHI AIMEE M. SMITH REGULATORY POLICY ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE / PO BOX CENTURY PARK CT., CP32D ROSEMEAD, CA SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY MICHELLE SOMERVILLE MIKE CADE REGULATORY CASE MGR. BUCHALTER, A PROFESSIONAL CORPORATION SAN DIEGO GAS & ELECTRIC COMPANY 55 SECOND STREET, SUITE CENTURY PARK COURT SAN FRANCISCO, CA SAN DIEGO, CA CASE COORDINATION CAROLYN KEHREIN PACIFIC GAS AND ELECTRIC COMPANY ENERGY MANAGEMENT SERVICES PO BOX : MC B9A 2602 CELEBRATION WAY SAN FRANCISCO, CA WOODLAND, CA ANDREW B. BROWN ATTORNEY AT LAW ELLISON SCHNEIDER & HARRIS LLP 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA State Service ENRIQUE GALLARDO LEGAL DIVISION STAFF COUNSEL CPUC CALIFORNIA PUBLIC UTILITIES COMMISSION ONLY ONLY ONLY, CA ONLY, CA FOR: ORA AROCLES AGUILAR JESSICA T. HECHT CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 5138 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA VALERIE KAO CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES

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