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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Order Instituting Rulemaking to Improve Public Access to Public Records Pursuant to the California Public Records Act.
Rulemaking 14-11-001
(Filed November 6, 2014)
JOINT OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY
(U 338 E), SOUTHERN CALIFORNIA GAS COMPANY (U 904 G), SAN DIEGO GAS &
ELECTRIC COMPANY (U 902 M), PACIFIC GAS AND ELECTRIC COMPANY (U 39 E),
AND SOUTHWEST GAS CORPORATION (U 905 G) ON THE APRIL 2017 PROPOSED
GENERAL ORDER 66-D
JANET S. COMBS CAROL A. SCHMID-FRAZEE Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1337 Facsimile: (626) 302-1935 E-mail: [email protected]
MELISSA A. HOVSEPIAN Attorneys for SOUTHERN CALIFORNIA GAS COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 555 West Fifth Street, GT-14E7 Los Angeles, California 90013-1046 Telephone: (213) 244-3978 Facsimile: (213) 629-9620 E-mail: [email protected]
PETER VAN MIEGHEM CHRISTOPHER J. WARNER Attorneys for PACIFIC GAS AND ELECTRIC COMPANY 77 Beale Street San Francisco, California 94105 Telephone: (415) 973-2902 Facsimile: (415) 973-5520 E-mail: [email protected]
KYLE O. STEPHENS Attorney for SOUTHWEST GAS CORPORATION 5241 Spring Mountain Road Las Vegas, Nevada 89150-0002 Telephone: (702) 876-7293 Facsimile: (702) 252-7283 E-mail: [email protected]
Dated: May 10, 2017
1
I. EXECUTIVE SUMMARY AND OVERVIEW
Pursuant to the Assigned Commissioner’s Amended Scoping Memo and Ruling, dated April 28,
2017 (“AC’s Ruling”),1 Southern California Edison Company (“SCE”), Southern California Gas
Company (“SoCalGas”), San Diego Gas & Electric Company (“SDG&E”), Pacific Gas & Electric
Company (“PG&E”), and Southwest Gas Corporation (“Southwest Gas”) (collectively, “Joint Energy
Utilities”) hereby submit their opening comments on the Proposed General Order 66-D (“Proposed GO
66-D”). First and foremost, the Joint Energy Utilities strongly support the applicability of the rights of
administrative appeal in Section 6.0 to both information submitters and requestors, but do have some
concerns about Proposed GO 66-D.
II. SECTION 4.4 SHOULD BE REVISED TO ADEQUATELY PROTECT INFORMATION THAT SHOULD NOT BE PUBLICLY DISCLOSED
As written, Section 4.4 of Proposed GO 66-D, does not adequately protect information that is
confidential under law or California Public Utilities Commission (“Commission”) rules and therefore
should not be publicly disclosed. Section 4.4 provides that all information in the Commission’s
possession is “available for public inspection unless deemed to be exempt by the [California Public
Records Act or “CPRA”)], California Government Code Section 6254, et al, and/or an applicable
privilege.” However, the exemptions in Section 6254 and the CPRA itself are not an exhaustive list of
legally protected confidential information that should not be made public. Other statutes and
Commission rules and decisions protect certain categories of confidential data from disclosure even
where not necessarily subject to a categorical or discretionary exemption under CPRA. For example,
Public Utilities Code Section 454.5(g) requires the Commission to ensure the confidentiality of market-
sensitive energy procurement information. Likewise, Commission Decisions 11-07-056, 11-08-045 and
14-05-016 provide for specific protection of customer-specific data, including energy usage data, from
public disclosure pursuant to various statutory requirements, including Public Utilities Code Section
8380, Civil Code Section 1798 (California Information Practices Act) and numerous other Commission
decisions as well as the California Constitution.2 In addition to these additional statutory and regulatory
protections for confidential data, California Government Code Section 6255(a) gives the Commission
1 See, AC’s Ruling, p. 24. 2 See list of applicable Commission and statutory customer privacy rules and laws summarized at D.11-07-056,
Attachment B.
2
discretion to determine that the public interest in disclosing a record outweighs the public interest in not
disclosing it:
(a) The agency shall justify withholding any record by demonstrating that the record in question is exempt under express provisions of this chapter or that on the facts of the particular case the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record. (emphasis added)
The Commission should explicitly reference these additional statutes, rules and regulations,
including Government Code Section 6255 in Section 4.4 of Proposed GO 66-D. This would confirm
that under law and regulatory requirements in addition to the CPRA, the Commission has the authority
to not publicly release information that is confidential by law or regulation even when it is not subject to
a categorical exemption under CPRA.
As such, the Joint Energy Utilities recommend that the Commission revise the language in
Section 4.4 in Proposed GO 66-D as follows:
Exemptions to the CPRA: Information in possession of the Commission are is available for public inspection deemed to be exempt by the Commission from inspection per unless the Commission deems it to be exempt from inspection pursuant to (1) the exemptions in the CPRA, at Government Code Sections 6254, 6255 et al, (2) federal and/or state law and regulations and Commission decisions, and/or (3) an applicable privilege or attorney work product rules.
III. THE COMMISSION SHOULD REVISE PROPOSED GO 66-D TO BETTER ACCOUNT FOR BURDENS ASSOCIATED WITH VOLUMINOUS OR COMPLEX DOCUMENTS
Proposed GO 66-D does not address the need to provide a streamlined process for submission of
records or information that are unusually complex or voluminous. Joint Energy Utilities and other
parties have requested that the Commission adopt a streamlined process in such cases to avoid
unnecessary costs and some delays.3 The Commission previously acknowledged the need to consider
this issue:
Several parties note that certain types of records and information, such as those that are unusually complex or voluminous, may present difficulties in identifying and marking confidential information, and accordingly there may need to be exceptions to the confidentiality designation rules set forth in the proposed decision. (See, e.g. Joint Utilities Reply Comments on Proposed Decision at 2, citing to Comments of SCE/PG&E.)
3 See, e.g., Joint Energy Utilities’ Opening Comments on Phase 2A Draft Proposal, filed on March 3, 2017;
Joint Opening Comments of SCE and PG&E on Proposed Decision of President Picker, filed on July 18, 2016; and Reply Comments of Consolidated Communications of California Company, filed on March 24, 2017.
3
This would be an appropriate refinement to consider in this proceeding going forward. In the meantime, to the extent that such records or information are being presented in response to a Commission data request, the submitting entity can request additional time to comply with the request. D.16-08-024, pp. 24-25.
To be clear, Joint Energy Utilities are not requesting an outright exemption to the requirement to
mark documents confidential, but simply a provisional approach to voluminous or complex documents
and information that are not yet the subject of a CPRA request. A provisional approach in such cases is
crucial. As noted previously, since the issuance of D.16-08-024 on August 25, 2016, the Joint Energy
Utilities have repeatedly had to perform intensive and time-consuming reviews to identify and mark
confidential information in certain types of submissions. This has both required considerable utility
resources, and resulted in some delays in responding to Commission Staff. For example, the Safety and
Enforcement Division (“SED”) regularly requests that PG&E provide gas transmission “as-built”
construction packages. In 2016 alone, SED requested 79 of these packages. Each package is lengthy –
comprising multiple documents and hundreds of pages – and contains numerous instances of
confidential information, e.g., sensitive critical infrastructure information, throughout the documents,
including as-built drawings, GIS coordinates of facilities, and detailed maps. Identifying and marking
each instance of confidential information in such cases requires considerable time and expense.
Recently, PG&E provided a job file to SED that contained over 2000 pages and took over 5 days to
review, identify, and mark the confidential information. The time and effort required to mark each
package frequently results in delays in providing the requested materials to SED. The benefits of this
expenditure of resources are doubtful, considering these construction packages may never be the subject
of a CPRA request, and reasonable alternatives are available that meet the intent of D.16-08-024.
Moreover, information submitters cannot reasonably or readily mark certain types of information, such
as GIS mapping data or some electronically submitted forms that do not permit the submitting party to
mark individual fields or specific information as confidential.
To streamline the process and avoid undue cost and delay, the Joint Energy Utilities propose that
the Commission revise Section 3.2 as follows:
“Second, submission of information per Section 3.3 (submission in a formal proceeding) and Section 3.4 (submission consistent with a determination of confidentiality in a decision) of this GO are exempted from the requirements of this Section. Third, in extraordinary cases, such as a data response to Commission staff that includes a significant volume or complexity of records, information submitters may provisionally designate such material as confidential, consistent with the following:
4
(1) Commission Staff must agree with the information submitter that it would be too burdensome or impractical to individually identify and mark each instance of confidential information in response to a particular Commission request or routine category of requests.
(2) The information submitter may provisionally describe the categories of confidential information contained within the submission and designate the entire submission confidential instead of individually identifying and marking each instance of confidential information, provided that the description is sufficiently specific that a reviewer may readily identify the material claimed as confidential.
(3) The information submitter must provide a sample of each category of confidential information found in the submission.
(4) The information submitter shall specify that it has applied this process in the accompanying declaration or motion.
(5) Should the information be the subject of a future CPRA request, the Commission may require the information submitter to follow the standard approach under Section 3.2.”
Although the AC’s Ruling rejects a proposal for “not requiring identification of confidential
information before submission” (AC’s Ruling, p. 13), the AC’s Ruling does not directly address the
proposal presented herein by Joint Energy Utilities, who—it bears repeating—are not asking for an
outright exemption to the requirement to mark documents confidential, but simply for a provisional
approach for voluminous or complex documents and information that are not yet the subject of a CPRA
request. Such an approach is critical to avoid unnecessary cost and delay.
IV. SECTION 5.5(C) SHOULD BE REVISED TO LENGTHEN THE TIME FOR APPEAL
Section 5.5(c) of Proposed GO 66-D provides that, the information submitter may appeal to the
Commission for reconsideration by submitting a Public Information Appeal Form (“Appeal Form”)
within five days of receiving notice that a request for confidentiality has been denied in whole or part
per Section 6.4 Five days generally is not sufficient to prepare an appeal fully describing the reasons
why the Commission should disclose information the submitter has classified as confidential.
Information submitters need to provide legal arguments and the claim(s) of confidentiality may be
complex and depend on multiple legal bases for protection. In order for the Commission’s Legal
Division (“Legal Division”) to prepare a draft resolution that properly informs the Commission of the
4 Proposed GO 66-D, §5.5(c), p. 9.
5
confidentiality issues at stake before a vote, the Commission should provide a reasonable amount of
time for preparation of an appeal. The Joint Energy Utilities believe that 15 days would strike an
appropriate balance of timely processing of a CPRA request, due process for information submitters, and
serving the public interest in disclosing only such information that should not be maintained as
confidential. A five-day appeal period creates a heightened risk of an inadvertent disclosure by the
Commission of confidential information, which may be harmful not only to the information submitter,
but also the public interest. For example, disclosure of cyber security information, critical energy
infrastructure information, or private customer information would have broader negative implications
affecting the public interest. The Commission would find it more useful when considering an appeal if
the information submitters’ legal arguments provided in the Appeal Form are well-reasoned and
thoroughly researched. Indeed, with more time, information submitters may find that further legal
research persuades them to not submit an appeal, which would alleviate additional administrative burden
from Commission Staff. With only a short five days period, information submitters will be inclined to
err on the side of bringing an appeal to preserve their rights, where further research may have resulted in
a decision not to do so.
Further, 15 days for an appeal with legal arguments is consistent with the time permitted to
submit other pleadings before the Commission involving issues of law.5 For the same reason, 15 days is
appropriate for appeals submitted under Section 5.5(b) of Proposed GO 66-D.
The AC’s Ruling, at p.23, requests that parties specifically comment on the format for and
submission of an Appeal Form. The Joint Energy Utilities recommend use of a workshop to develop the
actual Appeal Form. Nonetheless, the Joint Energy Utilities strongly recommend that information
submitters are permitted to provide legal arguments for their claim(s) of confidentiality, including
citations to relevant statutory and case law in an attachment to the Appeal Form, or on the form itself
and space must not be unreasonably limited. Submission of the detailed basis for confidentiality by the
information submitter is key to preservation of the right of appeal. Joint Energy Utilities recommend
that the Commission accept appeals in any of the ways proposed—by email, online, or U.S. mail.
5 See, e.g., Commission Rules of Practice and Procedure, Rule 11.1(e)(“Responses to written motions must be
filed and served within 15 days of the date that the motion was served. . . .”); Rule 16.1(a)(“Application for rehearing of a Commission order or decision shall be filed within 30 days after the date the Commission mails the order or decision. . . .”).
6
V. SECTION 5.4(B) SHOULD BE REVISED TO EXTEND THE TIME TO MARK DOCUMENTS CONFIDENTIAL IN THE CONTEXT OF A CPRA REQUEST
Pursuant to Section 5.4(b) of Proposed GO 66-D, in the context of a CPRA request, information
submitters must provide a declaration and mark the confidential portions of documents within five (5)
days of notice by the Legal Division without any opportunity for an extension.6 This short time period
without an extension is unnecessarily inflexible, particularly when complex and/or voluminous records
are involved. While an initial response within five days may be possible if the confidentiality bases and
designations are straightforward, as noted by the Legal Division itself, there has been an upward trend of
CPRA requests to the Commission asking for complex and/or voluminous records, and it takes more
legal resources to process such requests.7 The requirements of Section 5.4(b) would likely involve
similar resources and time for the information submitters to comply. As noted in the Legal Division’s
Conference of California Public Utility Counsel (“CCPUC”) 2015 presentation on this subject and the
CPRA Guidelines on the Commission’s website, the Legal Division sends an initial response letter to
comply with Government Code Section 6253(c)’s 10-day notice to the information requestor.8 The
Legal Division notes that “’[i]n unusual circumstances’ we can take an additional 14 days to make that
initial response.”9 This is consistent with Government Code Section 6253(c), which provides an
extension for an additional 14 days in circumstances that include “[t]he need to search for, collect, and
appropriately examine a voluminous amount of separate and distinct records that are demanded in a
single request.”10 Moreover, the Legal Division emphasizes, “[t]his is just our initial response, not the
actual production of documents.”11
6 Proposed GO 66-D, §5.4(b). 7 See Commission Legal Division presentation at the 2015 CCPUC, “How the Commission Responds to PRA
Requests,” dated Oct. 19, 2015, p. 13 (“We have seen a marked increase in both the number of requests we receive and in their breadth.”); see also id. (“In 2010, we received 234 PRA requests and subpoenas. This year [(2015)] we are on track to receive 468 – exactly double.”); see also id. at p. 6 (noting that for complicated PRA requests, additional legal resources are necessary to process them, including at least one lawyer, an Assistant General Counsel, and in rare cases, the General Counsel).
8 Id. at p. 7; http://www.cpuc.ca.gov/General.aspx?id=2659. 9 Commission Legal Division presentation at the 2015 CCPUC, “How the Commission Responds to PRA
Requests,” dated Oct. 19, 2015, p. 7. 10 Gov’t. Code §6253(c)(2). 11 Commission Legal Division presentation at the 2015 CCPUC, “How the Commission Responds to PRA
Requests,” dated Oct. 19, 2015, p. 7.
7
Accordingly, information submitters should be allowed an extension if they cannot reasonably
meet the five-day response time in Section 5.4(b) of Proposed GO 66-D. Because the Legal Division
provides only an initial response–not the production–itself within a 10-day period, and the CPRA
already recognizes the need for a 14-day extension when voluminous records are at issue, the
Commission should apply similar considerations to information submitters responsible for declaring and
designating confidential information. Marking complex and/or voluminous records for confidentiality
has more relevance to the actual production of responsive CPRA records, not the initial response. The
CPRA does not specify a time period for production – only that the agency “shall make the records
promptly available”12 – so the marking of confidential information within a five-day period without the
possibility of an extension is unnecessary and onerous. The Legal Division recognizes that “[t]he length
of time a request takes depends on the complexity of the request and staff workload, among other
things.”13 These same considerations should be taken into account when setting deadlines for
information submitters under Proposed GO 66-D.
Therefore, the Commission should revise Section 5.4(b) to allow a 14-day extension for
information submitters to provide a confidentiality declaration if complex and/or voluminous records are
at issue, with the possibility of a longer extension for the marking of confidential information,
depending on the complexity and/or volume of records. Consistent with the CPRA, in such “unusual
circumstances,” 14 days is a reasonable amount of time for information submitters to sufficiently
analyze and claim confidentiality in a declaration so that the Legal Division can provide its initial
response letter in a timely manner. The possibility of a longer extension for the marking of complex
and/or voluminous records is also consistent with the CPRA’s distinction between the initial response
versus the actual production of documents, which depends on many factors (e.g., can the document in
fact be marked and redacted, such as mapping data, GIS shape file, etc.). Proposed GO 66-D should not
be so inflexible that it does not account for reasonable circumstances that may justifiably need more
12 Gov’t. Code §6253(b). See also Commission Legal Division presentation at the 2015 CCPUC, “How the
Commission Responds to PRA Requests,” dated Oct. 19, 2015, p. 10 (“The PRA ‘does not specify when records must be produced to a requesting party.’”)(quoting Motorola Communications & Electronics, Inc. v. Dept. of General Services, 55 Cal. App. 4th 1340, 1349 (1997)).
13 Commission Legal Division presentation at the 2015 CCPUC, “How the Commission Responds to PRA Requests,” dated Oct. 19, 2015, p. 10.
8
time for responses and production. The Joint Energy Utilities are not aware of any other state agency
that imposes such inflexible standards in complying with the CPRA.14
VI. THE COMMISSION SHOULD REVISE SECTION 3.4 TO ALLOW PARTIES SUBMITTING CONFIDENTIAL INFORMATION TO RELY ON THE EXCLUSIONS THAT ARE INCLUDED IN SECTION 2 OF GO 66-C AS AN INTERIM STEP
Section 7.1 of the Amended Scoping Memo indicates that the list of “exclusions” currently
included in Section 2 of GO 66-C will be not be included in GO 66-D.15 Many of the GO 66-C
exclusions are based on statutory provisions and are relied on by the Joint Energy Utilities, as well as
other utilities. Specifically, the Joint Energy Utilities rely on the GO 66-C exclusions, among other
legal bases, to address the confidentiality of information that is not included in D.06-06-066 as a result
of the passage of time.16 For example, since the issuance of D.06-06-066 more than eleven years ago,
there have been substantial changes in the California Independent System Operator (CAISO) markets
necessitating market-sensitive pricing and strategy information regarding products that did not exist at
that time. For example, the Joint Energy Utilities have confidential strategies for convergence bidding
in the CAISO markets, but because convergence bidding did not exist 11 years ago, the D.06-06-066
matrix does not mention it. Nonetheless, such strategies would be protected market-sensitive electric
procurement information, not only under Public Utilities Code Section 454.5(g), but also under GO 66-
C’s substantive exclusion under Section 2.2(b), which protects “[r]eports, records and information
requested or required by the Commission which, if revealed, would place the regulated company at an
unfair business disadvantage.” Similarly, for procurement cost information related to greenhouse gas
14 See, e.g., California Air Resources Board (CARB) Guidelines for Accessing Public Records, available at
https://www.arb.ca.gov/html/pubrecsguidelines.htm: ARB will determine within 10 days after receipt of the request, whether it has records responsive to the
request, and will inform you of its decision and the reasons for the decision. The initial 10-day period may be extended for up to an additional 14 days if the ARB needs to . . . inspect voluminous records. . . . Whenever possible, ARB will provide records at the time the determination is made to disclose them. If immediate disclosure is not possible, ARB will provide an estimated date when the records will be available, and will endeavor to provide the records within a reasonable period of time. (emphasis added)
See also Office of the Attorney General, California Department of Justice Guidelines for Access to Public Records (Mar. 2012), p. 2, available at https://oag.ca.gov/sites/all/files/agweb/pdfs/consumers/pra_guidelines.pdf.
15 Amended Scoping Memo at p. 18. 16 It should be noted that certain utilities were not parties to D.06-06-066, including SoCalGas and Southwest
Gas, because D.06-06-066 applies to electric utilities and service providers.
9
(“GHG”) allowances and offsets, in addition to Public Utilities Code Section 454.5(g) and relevant
Commission Decisions (e.g. D.14-10-033 and D.15-10-032), the Joint Energy Utilities may also rely on
GO 66-C, Section 2.2(b) as another basis for confidentiality. In these and many other cases, the Joint
Energy Utilities have relied on the broader exclusions in GO 66-C to protect information that is clearly
market sensitive, and the disclosure of which would harm customers.
The Joint Energy Utilities recognize that as a part of the process to implement Proposed GO 66-
D, the Commission intends to undertake an effort to develop new or additional confidentiality matrices,
similar to the matrix included with D.06-06-066.17 However, in the interim, the Commission should
continue to allow parties submitting confidential information to rely on the exclusions that are included
in Section 2 of GO 66-C. These exclusions are well known inside and outside the Commission, have
been in place for more than three decades, and, as is clear from the language, are primarily rooted in
statutory provisions. Once new confidentiality matrices are developed, the Commission can terminate
the GO 66-C exclusions. However, for the interim period, these well-established exclusions should
continue to be available to use as a basis for making a confidentiality claim. This is also consistent with
the rules in D.06-06-066, which the Proposed GO 66-D intends to preserve:
GO 66-C shall continue to apply to data not addressed in the Matrix. . . . Other portions of GO 66-C not related to electric procurement will remain in place unless and until we change them. Thus, for data not included in the Matrix, a party seeking confidential treatment should continue to file a motion [or submit a declaration where appropriate] seeking leave from the Commission to retain such material under seal. The filing [/submitting] party shall bear the burden of proving that its information deserves such treatment.18
The Joint Energy Utilities propose that the Commission revise the language Section 3.4 of
Proposed GO 66-D as follows:
c) Between the date of the issuance of this GO and the development and approval by the Commission of confidential matrices described in Section 3.4(a) above, the exclusions identified in Section 2 of GO 66-C shall remain in effect as a basis for designating certain information as confidential. The exclusions in Section 2 of GO 66-C shall no longer be a basis for asserting confidentiality after the Commission approves confidentiality matrices as described in Section 3.4(a).
17 Amended Scoping Memo at p. 16. 18 D.06-06-066, pp.21-22 (as modified by D.08-04-023, p. 21).
10
VII. CONCLUSION
For the reasons discussed above, the Joint Energy Utilities respectfully request that the
Commission revise Proposed GO 66-D as we recommend.
Respectfully submitted on behalf of the Joint Energy Utilities,
JANET S. COMBS CAROL A. SCHMID-FRAZEE
/s/ Carol A. Schmid-Frazee By: Carol A. Schmid-Frazee
Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY
2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-1337 Facsimile: (626) 302-6962 E-mail: [email protected]
DATE: May 10, 2017
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE
STATE OF CALIFORNIA
Order Instituting Rulemaking to Improve Public Access to Public Records Pursuant to the California Public Records Act.
Rulemaking 14-11-001 (Filed November 6, 2014)
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 JOINT OPENING COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338 E), SOUTHERN CALIFORNIA GAS COMPANY (U 904 G), SAN DIEGO GAS & ELECTRIC COMPANY (U 902 M), PACIFIC GAS AND ELECTRIC COMPANY (U 39 E), AND SOUTHWEST GAS CORPORATION (U 905 G) ON THE APRIL 2017 PROPOSED GENERAL ORDER 66-D on all parties identified on the attached service list(s) R.14-11-001. Service was effected by one or more means indicated below:
Transmitting the copies via e-mail to all parties who have provided an e-mail address.
Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or overnight courier to the offices of the commissioner(s) or other addressee(s).
ALJ: Rafael L. Lirag CPUC 505 Van Ness Avenue San Francisco, CA 94102
Executed this May 10, 2017, at Rosemead, California.
/s/ Mildred King Mildred King Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770
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C. ANTHONY BRAUN CANDICE TAYLOR BRAUN BLAISING MCLAUGHLIN, P.C. LYFT, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: IMPERIAL IRRIGATION DISTRICT (IID) FOR: LYFT, INC.
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KYLE O. STEPHENS MELISSA A. HOVSEPIAN ASSOCIATE GENERAL COUNSEL SR COUNSEL SOUTHWEST GAS CORPORATION SOUTHERN CALIFORNIA GAS COMPANY 5241 SPRING MOUNTAIN ROAD, LVA-110 555 WEST FIFTH STREET, GT-14E7 LAS VEGAS, NV 89150 LOS ANGELES, CA 90013 FOR: SOUTHWEST GAS CORPORATION FOR: SOUTHERN CALIFORNIA GAS COMPANY (SOCAL) AND SAN DIEGO GAS (SDG&E)
MELLISSA HOVSEPIAN JAVIER RIVERA SENIOR COUNSEL SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE. 555 WEST FIFTH STREET, SUITE 1400 ROSEMEAD, CA 91770 LOS ANGELES, CA 90013 FOR: SOUTHERN CALIFORNAI EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY
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MARIA C. SEVERSON, ESQ. JOHN W. LESLIE, ESQ ATTORNEY ATTORNEY AGUIRRE & SEVERSON LLP DENTONS US LLP 501 WEST BROADWAY, STE. 1050 4655 EXECUTIVE DRIVE, SUITE 700 SAN DIEGO, CA 92101-3591 SAN DIEGO, CA 92121 FOR: RUTH HENDRICKS FOR: SHELL ENERGY NORTH AMERICA (US), L.P.
JESUS G. ROMAN JESUS G. ROMAN ASSISTANT GEN. COUNSEL - WEST REGION ATTORNEY VERIZON VERIZON 15505 SAND CANYON AVE. D201 15505 SAND CANYON AVE. IRVINE, CA 92618 IRVINE, CA 92618 FOR: VERIZON CALIFORNIA, INC. (U1002C) FOR: CELLCO PARTNERSHIP DBA VERIZON WIRELESS / MCI COMMUNICATIONS SERVICES, INC.
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PETER VAN MIEGHEM DONALD P. HILLA ATTORNEY AT LAW SR. REGULATORY COUNSEL PACIFIC GAS AND ELECTRIC COMPANY CONSUMER FEDERATION OF CALIFORNIA 77 BEALE STREET, RM 3107, B30A 150 POST ST., STE. 442
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SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94108 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: CONSUMER FEDERATION OF CALIFORNIA
WALID ABDUL-RAHIM JEANNE B. ARMSTRONG AVP & SR. LEGAL COUNSEL ATTORNEY AT&T CALIFORNIA GOODIN MACBRIDE SQUERI & DAY LLP 430 BUSH STREET, 3RD FL. 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA 94108-2728 SAN FRANCISCO, CA 94111 FOR: AT&T SERVICES, INC. FOR: CTIA-THE WIRELESS ASSOCIATION, EXTENET SYSTEMS (CALIFORNIA) LLC AND TW TELECOM OF CALIFORNIA LP., WILD GOOSE STORAGE, LLC (INDEPENDENT STORAGE PROVIDERS)
JOHN L. CLARK JOHN MCINTYRE ATTORNEY ATTORNEY GOODIN MACBRIDE SQUERI & DAY LLP GOODIN, MACBRIDE, SQUERI & DAY, LLP 505 SANSOME STREET, STE. 900 505 SANSOME ST., STE. 900 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: CHARTER FIBERLINK CA-CCO, LLC FOR: INDEPENDENT ENERGY PRODUCERS (U6878C) ASSOCIATION (IEPA)
JOSEPH M. KARP, ESQ. MARI LANE ATTORNEY NOSSAMAN LLP WINSTON & STRAWN LLP 50 CALIFORNIA STREET, STE. 3400 101 CALIFORNIA STREET, STE 3500 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: SIDE.CR, LLC FOR: GOLDEN STATE WATER COMPANY
PATRICK J. FERGUSON PATRICK M. ROSVALL ATTORNEY ATTORNEY DAVIS WRIGHT TREMAINE LLP COOPER, WHITE & COOPER LLP 505 MONTGOMERY STREET, SUITE 800 201 CALIFORNIA STREET, 17TH FL. SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: LIBERTY UTILITIES (CALPECO) LLC / FOR: SUREWEST TELEPHONE & THE SMALL LECS CALPINE CORPORATION
SARAH DEYOUNG MARTIN MATTES EXECUTIVE DIRECTOR NOSSAMAN LLP CALTEL 50 CALIFORNIA STREET, STE. 3400 50 CALIFORNIA ST., STE. 1500 SAN FRANCISCO, CA 94111-4799 SAN FRANCISCO, CA 94111 FOR: CALIFORNIA WATER ASSOCIATION (CWA) FOR: CALIFORNIA ASSOCIATION OF COMPETITIVE TELECOMMUNICATIONS (CALTEL)
ONKI KWAN, ESQ. MEGAN M. MYERS BAYVIEW / HUNTERS POINT COMMUNITY LEGAL COUNSEL 4322 3RD STREET LAW OFFICES OF MEGAN M. MYERS SASN FRANCISCO, CA 94124 110 OXFORD STREET FOR: BAYVIEW/HUNTERS POINT COMMUNTIY SAN FRANCISCO, CA 94134 LEGAL FOR: CENTER FOR ENERGY EFFICIENCY AND RENEWABLE TECHNOLOGIES (CEERT)
ANITA TAFF-RICE STEVEN R. MYERS ATTORNEY ATTORNEY
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ICOMMLAW MEYERS, NAVE, RIBACK, SILVER & WILSON 1547 PALOS VERDES, NO. 298 555 12TH STREET, SUITE 1500 WALNUT CREEK, CA 94597 OAKLAND, CA 94607 FOR: EXTENET SYSTEMS (CALIFORNIA), LLC FOR: CITY OF SAN BRUNO AND TW TELECOM OF CALIFORNIA LP
LEON M. BLOOMFIELD CHARLIE BORN ATTORNEY MGR - GOVN'T & EXTERNAL AFFAIRS LAW OFFICES OF LEON M. BLOOMFIELD FRONTIER COMMUNICATIONS 1901 HARRISON ST., STE. 1400 9260 E. STOCKTON BLVD. OAKLAND, CA 94612 ELK GROVE, CA 95624-1456 FOR: T-MOBILE WEST LLC D/B/A T-MOBILE FOR: FRONTIER COMMUNICATIONS
LESLA LEHTONEN JEDEDIAH J. GIBSON SVP & GENERAL COUNSEL ATTORNEY AT LAW CALIF. CABLE & TELECOMM. ASSN. ELLISON SCHNEIDER HARRIS & DONLAN LLP 1001 K STREET, 2ND FLOOR 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA 95814-3832 SACRAMENTO, CA 95816-5905 FOR: CALIFORNIA CABLE & FOR: PACIFICORP TELECOMMUNICATIONS ASSOCIAITON (CALCABLE)
ANN L. TROWBRIDGE ATTORNEY AT LAW DAY CARTER & MURPHY LLP 3620 AMERICAN RIVER DRIVE, SUITE 205 SACRAMENTO, CA 95864 FOR: GILL RANCH STORAGE, LLC (INDEPENDENT STORAGE PROVIDERS)
Information Only
ANDREW BROWN BRUCE SMITH ELLISON SCHNEIDER HARRIS & DONLAN LLP GRC & REGULATORY SUPPORT EMAIL ONLY PACIFIC GAS & ELECTRIC COMPANY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000
CASE COORDINATION CATHIE ALLEN PACIFIC GAS AND ELECTRIC COMPANY PACIFICORP EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, OR 00000
EMILY SANGI ETTA LOCKEY DAVIS WRIGHT TREMAINE, LLP SENIOR ATTORNEY EMAIL ONLY PACIFICORP EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000
GREGORY S.G. KLATT INNA VINOGRADOV ATTORNEY AT LAW ICOMMLAW DOUGLASS & LIDDELL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000
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JANE WHANG JENNIFER W. SUMMERS DAVIS WRIGHT TREMAINE, LLP CALIFORNIA REGULATORY AFFAIRS EMAIL ONLY SAN DIEGO GAS & ELECTRIC COMPANY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000
JIM TOMLINSON JOSEPH W. MITCHELL, PH.D. DAVIS WRIGHT TREMAINE, LLP M-BAR TECHNOLOGIES AND CONSULTING, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000
LISA TSE MIKE CADE COUNSEL, REGULATORY ALCANTAR & KAHL UBER TECHNOLOGIES, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000
ROBERT A. LAURIE SARA STECK MYERS ASSISTANT GENERAL COUNSEL - ENERGY LAW OFFICES OF SARA STECK MYERS IMPERIAL IRRIGATION DISTRICT EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000
SUZANNE TOLLER VIDHYA PRABHAKARAN ATTORNEY ATTORNEY DAVIS WRIGHT TREMAINE LLP DAVIS WRIGHT & TREMAINE, LLP EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000
DAVIS WRIGHT TREMAINE LLP MRW & ASSOCIATES, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000
MELISSA SLAWSON CHRISTOPHER SCHINDLER GENERAL COUNSEL HOGAN LOVELLS US, LLP BLUE JAY WIRELESS, LLC COLUMBIA SQUARE EMAIL ONLY 555 THIRTEENTH STREET, N.W. EMAIL ONLY, CA 00000-0000 WASHINGTON, DC 20004
JEAN HAWLEY KENNARD B. WOODS FRIEND, HUDAK& HARRIS, LLP ATTORNEY 3 RAVINIA DRIVE, SUITE. 1700 FRIEND, HUDAK & HARRIS, LLP ATLANTA, GA 30346-2131 THREE RAVINIA DRIVE, SUITE. 1700 ATLANTA, GA 30346-2131
KELLY CRANDALL LINDA C. STINAR EQ RESEARCH, LLC DIR - REGULATORY AFFAIRS 1580 LINCOLN STEET, SUITE 880 CENTURYLINK DENVER, CO 80203 6700 VIA AUSTI PARKWAY LAS VEGAS, NV 89119
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CATHERINE MAZZEO VALERIE ONTIVEROZ ASSISTANT GENERAL COUNSEL REGULATORY MGR / CALIFORNIA SOUTHWEST GAS CORPORATION SOUTHWEST GAS CORPORATION 5241 SPRING MOUNTAIN ROAD 5241 SPRING MOUNTAIN ROAD, LVB-105 LAS VEGAS, NV 89150-0002 LAS VEGAS, NV 89150-0002
PRISCILA CASTILLO KASHA JACKSON D. MCNEILL DECPUTY CITY ATTORNEY SOUTHERN CALIFORNIA GAS COMPANY LOS ANGELES DEPT. OF WATER & POWER 555 WEST FIFTH AVENUE, SUITE 1400 111 NORTH HOPE ST., ROOM 340 LOS ANGELES, CA 90013 LOS ANGELES, CA 90012
JEFF SALAZAR KAREN LEE SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, GT14D6 555 W. 5TH STREET, SUITE 1400 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013
RONALD VAN DER LEEDEN JOHN A. BRIDGE DIR. - REGULATORY AFFAIRS HOGAN LOVELLS US LLP SOUTHERN CALIFORNIA GAS COMPANY 1999 AVENUE OF THE STARS, SUITE 1400 555 W. FIFTH STREET, GT14D6 LOS ANGELES, CA 90067 LOS ANGELES, CA 90013
NORMAN A. PEDERSEN EDWARD N. JACKSON ATTORNEY AT LAW DIR - REVENUE REQUIREMENTS HANNA AND MORTON LLP LIBERTY UTILITIES (PARK WATER) CORP. 444 SOUTH FLOWER ST., SUITE 1500 9750 WASHBURN ROAD / PO BOX 7002 LOS ANGELES, CA 90071-2916 DOWNEY, CA 90241-7002
DANIEL W. DOUGLASS CHARLES CARRATHERS, III ATTORNEY FRONTIER CALIFORNIA INC. DOUGLASS & LIDDELL 2535 W. HILLCREST DRIVE 4766 PARK GRANADA, SUITE 209 THOUSAND OAKS, CA 91320 CALABASAS, CA 91302 FOR: WESTERN POWER TRADING FORUM
DON C. EACHUS CAROL SCHMID-FRAZEE VERIZON CALIFORNIA, INC. ATTORNEY AT LAW 2535 W. HILLCREST DRIVE, CAM21LS SOUTHERN CALIFORNIA EDISON NEWBURY PARK, CA 91320 2244 WALNUT GROVE AVE./PO BOX 800 ROSEMEAD, CA 91770
CASE ADMINISTRATION PATRICIA A. CIRUCCI SOUTHERN CALIFORNIA EDISON COMPANY DIRECTOR & MANAGING ATTORNEY 2244 WALNUT GROVE AVENUE, PO BOX 800 SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA 91770 2244 WALNUT GROVE AVE./PO BOX 800 ROSEMEAD, CA 91770
MARIA BYRNES MICHAEL J. AGUIRRE LEGAL ASSISTANT AGUIRRE MORRIS & SEVERSON LLP AGUIRRE & SEVERSON LLP 501 W. BROADWAY, STE. 1050 501 WEST BROADWAY, STE. 1050 SAN DIEGO, CA 92101-3591 SAN DIEGO, CA 92101
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DONALD C. LIDDELL ESTHER NORTHRUP ATTORNEY STATE REGULATORY AFFAIRS DOUGLASS & LIDDELL COX COMMUNICATIONS 2928 2ND AVENUE 5651 COPLEY DRIVE SAN DIEGO, CA 92103 SAN DIEGO, CA 92111
BRITTNEY LEE CHRISTOPHER SUMMERS REGULATORY CASE ADMIN. REGULATORY AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 9305 LIGHTWAVE AVENUE SAN DIEGO, CA 92123 SAN DIEGO, CA 92123
STEVEN LANGO CENTRAL FILES REGULATORY CASE MGR - II SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK CT., CP-31H SAN DIEGO, CA 92123-1530 SAN DIEGO, CA 92123
KEN WITTMAN MARC ZAFFERANO SR. MGR., FINANCE ACCTNG. & REG. CITY ATTORNEY LIBERTY UTILITIES (CALPECO) LLC CITY OF SAN BRUNO 701 NATIONAL AVENUE 567 EL CAMINO REAL TAHOE VISTA, CA 93148 SAN BRUNO, CA 94066
JOHN K. HAWKS ANNA UHLS CALIFORNIA WATER ASSOCIATION UBER TECHNOLOGIES, INC. 601 VAN NESS AVE., STE. 2047, MC E3-608 1455 MARKET STREET, 4TH FL. SAN FRANCISCO, CA 94102-3200 SAN FRANCISCO, CA 94103
LEXI EATON NEVAREZ PATTY ROBBINS CORPORATE PARALEGAL - REGULATORY UBER TECHNOLOGIES, INC. UBER TECHNOLOGIES, INC. 1455 MARKET ST., 4TH FLOOR 1455 MARKET STREET, 4TH FL. SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94103
SELENE HAKOBYAN AMIE BURKHOLDER UBER TECHNOLOGIES, INC. ALCANTAR & KAHL, LLP 1455 MARKET STREET, 4TH FLOOR 345 CALIFORNIA STREET, SUITE 2450 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94104
BLAIRE STOKES MARGARET L. TOBIAS LYFT, INC. TOBIAS LAW OFFICE 185 BERRY STREET, STE. 5000 460 PENNSYLVANIA AVE SAN FRANCISCO, CA 94107 SAN FRANCISCO, CA 94107
BRENDA J. CLARK HUGH OSBORNE DIR - REGULATORY RELATIONS AT&T SERVICES, INC. AT&T SERVICES, INC. 430 BUSH STREET, 3RD FL. NO. 17 430 BUSH STREET, RM. 105 SAN FRANCISCO, CA 94108 SAN FRANCISCO, CA 94108
THOMAS SELHORST BRIAN CRAGG
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SENIOR PARALEGAL ATTORNEY AT&T CALIFORNIA, INC. GOODIN, MACBRIDE, SQUERI & DAY, LLP 430 BUSH STREET, 3RD FL, NO. 14 505 SANSOME ST., STE. 900 SAN FRANCISCO, CA 94108 SAN FRANCISCO, CA 94111 FOR: INDEPENDENT ENERGY PRODUCERS ASSOCIATION
CYNTHIA RUSSELL KATIE JORRIE CALIFORNIA AMERICAN WATER COMPANY DAVIS WRIGHT TREMAINE, LLP 555 MONTGOMERY ST., STE. 816 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111
LORI ANNE DOLQUEIST MARK P. SCHREIBER ATTORNEY ATTORNEY NOSSAMAN LLP COOPER, WHITE & COOPER, LLP 50 CALIFORNIA STREET, 34TH FLR. 201 CALIFORNIA STREET, 17TH FLOOR SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: SUREWEST / CONSOLIDATED COMMUNICATIONS
RACHELLE CHONG SARAH LEEPER SENIOR REGULATORY COUNSEL VP - LEGAL, REGULATORY SIDECAR TECHNOLOGIES, INC. CALIFORNIA-AMERICAN WATER COMPANY 360 PINE STREET, SUITE 700 555 MONTGOMERY ST., STE. 816 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: SIDECAR TECHNOLOGIES, INC.
ZEB ZANKEL CALIFORNIA ENERGY MARKETS ATTORNEY 425 DIVISADERO ST STE 303 DAVIS WRIGHT TREMAINE LLP SAN FRANCISCO, CA 94117-2242 505 MONTGOMERY STREET, STE. 800 SAN FRANCISCO, CA 94111
ANN H. KIM BRITT K. STROTTMAN PACIFIC GAS AND ELECTRIC COMPANY MEYERS NAVE LAW DEPT 555 12TH STREET, STE. 1500 77 BEALE STREET, RM 3105 / PO BOX 7442 OAKLAND, CA 94607 SAN FRANCISCO, CA 94120
EMILIE E. DE LA MOTTE NATALIE D. WALES ATTORNEY AT LAW REGULATORY COUNSEL MEYERS NAVE RIBACK SILVER & WILSON CALIFORNIA WATER SERVICE COMPANY 555 12TH STREET, STE. 1500 1720 N. FIRST STREET OAKLAND, CA 94607 SAN JOSE, CA 95112
RICHARD H. LEVIN STEVEN CROSBY ATTORNEY AT LAW FRONTIER COMMUNICATIONS 309 SOUTH MAIN STREET/PO BOX 240 9260 E. STOCKTON BLVD. SEBASTOPOL, CA 95473-0240 ELK GROVE, CA 95624
JOHN SPOMER JORDAN PINJUV CALIFORNIA ISO COUNSEL 250 OUTCROPPING WAY CALIFORNIA INDEPENDENT SYSTEM OPERATOR FOLSOM, CA 95630 250 OUTCROPPING WAY
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FOLSOM, CA 95630
LEGAL DEPARTMENT DAN GRIFFITHS CALIFORNIA ISO ATTORNEY 250 OUTCROPPING WAY BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. FOLSOM, CA 95630 915 L STREET, SUITE 1480 SACRAMENTO, CA 95814
JACQUELINE KINNEY JUSTIN WYNNE FRONTIER COMMUNICATIONS ATTORNEY 1201 K STREET, SUITE 1980 BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. SACRAMENTO, CA 95814 915 L STREET, SUITE 1480 SACRAMENTO, CA 95814
SCOTT BLAISING STEVEN KELLY ATTORNEY POLICY DIRECTOR BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. INDEPENDENT ENERGY PRODUCERS ASSCIATION 915 L STREET, STE. 1480 1215 K STREET, STE. 900 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814
LYNN HAUG JAMES W. EWERT ELLISON SCHNEIDER HARRIS & DONLAN LLP LEGAL COUNSEL 2600 CAPITOL AVENUE, SUITE 400 CALIFORNIA NEWSPAPER PUBLISHERS ASSN. SACRAMENTO, CA 95816 2701 K STREET SACRAMENTO, CA 95816-5131
GREGGORY L. WHEATLAND GEORGE THOMSON, JR. ATTORNEY FRONTIER COMMUNICATIONS ELLISON SCHNEIDER HARRIS & DONLAN LLP 1800 41ST STREET, SUITE N-100 2600 CAPITOL AVENUE, SUITE 400 EVERETT, WA 98201 SACRAMENTO, CA 95816-5905
State Service
MICHAEL MINKUS TONY MARINO CPUC - EXECUTIVE DIV. OGA OFFICE OF SENATOR JERRY HILL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000
VALERIE KAO AMY C. BAKER SED CALIF PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION RISK ASSESSMENT AND ENFORCEMENT EMAIL ONLY ROOM 5210 EMAIL ONLY, CA 00000 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214
ARTHUR J. O'DONNELL BREWSTER FONG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION RISK ASSESSMENT AND ENFORCEMENT TRANSPORTATION ENFORCEMENT BRANCH AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214
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CHRISTINE J. HAMMOND ED CHARKOWICZ CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION RISK ASSESSMENT AND ENFORCEMENT ROOM 5220 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214
JAMES RALPH JONATHAN KOLTZ CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PRESIDENT PICKER LEGAL DIVISION ROOM 5037 ROOM 5035 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214
JUNAID RAHMAN KE HAO OUYANG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION RISK ASSESSMENT AND ENFORCEMENT UTILITY & PAYPHONE ENFORCEMENT BRANCH AREA AREA 2-E 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214
MARTIN M. NAKAHARA RAFAEL L. LIRAG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 2001 ROOM 5010 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214
SARAH R. THOMAS CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION ROOM 5033 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214
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