BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF ... · 2 I. INTRODUCTION Senate Bill (“SB”) 350 requires the Commission to approve, or modify and approve, IOU programs

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of San Diego Gas & Electric Company (U 902E) for Approval of SB 350 Transportation Electrification Proposals.

Application 17-01-020 (Filed January 20, 2017)

And Related Matters. Application 17-01-021 Application 17-01-022

SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) REPLY BRIEF

FADIA RAFEEDIE KHOURY ANDREA L. TOZER

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6713 Facsimile: (626) 302-6693 E-mail: [email protected]

Dated: July 10, 2017


Table of Contents

Section Page

-i-

I. INTRODUCTION ...........................................................................................................................2

II. SCE’S PORTFOLIO PROVIDES SIGNIFICANT BENEFITS TO

DISADVANTAGED COMMUNITIES ..........................................................................................3

III. SCE’S PROPOSALS CONTAIN APPROPRIATE MEASURABLE

MONITORING AND EVALUATION CRITERIA ........................................................................5

A. Urban DCFC Clusters Pilot ............................................................................................................ 8

B. Residential Make-Ready Rebate Pilot ............................................................................................ 9

C. EV Driver Rideshare Reward Pilot ............................................................................................... 10

IV. SCE’S COST RECOVERY PROPOSAL IS APPROPRIATE, CONSISTENT

WITH ACCOUNTING RULES AND REGULATORY DECISIONS AND WILL

REASONABLY COMPENSATE SCE FOR ITS INNOVATIVE EFFORTS TO

ACCELERATE WIDESPREAD TE ADOPTION .......................................................................11

A. The Charging Station Rebate Should be Capitalized Consistent with the Treatment of Other

Utility Regulatory Assets ...................................................................................................................... 11

1. Regulatory Asset Treatment of the Charging Station Rebate Results in Equitable

Ratemaking ....................................................................................................................................... 11

2. Regulatory Asset Treatment is Consistent with GAAP ............................................................ 11

3. Commission Precedent in Mobile Home Park Order Instituting Rulemaking (MHP OIR)

Supports Regulatory Asset Treatment .............................................................................................. 12


Table Of Contents (Continued)

Section Page

-ii-

B. After-the-Fact Reasonableness Review is Not Required .............................................................. 14

C. SCE’s Proposed Cost Cap Is Consistent with the ACR ................................................................ 14

D. SCE’s Proposed Allocation of Costs to Distribution Rates is Consistent with Commission

Precedent and Avoids the Inequitable Result of the CCA Parties’ Proposal ........................................ 15

V. CONCLUSION ..............................................................................................................................17

APPENDIX

Appendix A ED-SCE-01-28

Appendix B ED-SCE-01-32

Appendix C City of Lancaster-SCE 002, Question 01

Appendix D SCE Charge Ready Pilot Program Quarterly Report for First Quarter 2017


Table of Authorities

Page

-iii-

Statutes

Cal. Pub. Util. Code § 365.2 ..................................................................................................................... 16

Cal. Pub. Util. Code § 366.(3) .................................................................................................................. 16

Cal. Pub. Util. Code § 366.2(a)(4) ............................................................................................................ 16

Cal. Pub. Util. Code § 366.2(d)(1) ............................................................................................................ 16

Cal. Pub. Util. Code § 740.12(a)(1). ........................................................................................................... 2

Cal. Pub. Util. Code § 740.12(b). ........................................................................................................... 2, 5

Cal. Pub. Util. Code §740.8 ........................................................................................................................ 6

Legislation

Cal. Senate Bill (“SB”) 350 .................................................................................................................... 2, 7

CPUC Decisions

D.14-03-021 .............................................................................................................................................. 13

D.14-12-024 .............................................................................................................................................. 16

D.16-12-065. ....................................................................................................................................... 11, 15

CPUC Rules

Rule 13.11 ................................................................................................................................................... 1

Other Authorities

Accounting Standards Codification ("ASC") 980 .................................................................................... 12

1


STATE OF CALIFORNIA



And Related Matters. Application 17-01-021 Application 17-01-022


In accordance with Rule 13.11 of the California Public Utilities Commission’s (“Commission’s”)

Rules of Practice and Procedure, and the April 13, 2017 “Scoping Memo and Ruling of Assigned

Commissioner and Administrative Law Judges,” Southern California Edison Company (“SCE”) submits this

reply to parties’ opening briefs on the priority-review proposals filed by the investor-owned utilities

(“IOUs”) in A.17-01-021 et al.1

1 Opening briefs were filed by Santa Clara Valley Transportation Authority; eMeter, a Siemens Business

(“Siemens”); Utility Consumers’ Action Network; East Yard Communities for Environmental Justice, Center for Community Action and Environmental Justice, Sierra Club, and Union of Concerned Scientists (collectively, “EYCEJ”); Small Business Utility Advocates (“SBUA”); City of Long Beach, California, a municipal corporation, acting by and through its Board of Harbor Commissioners (“Port of Long Beach” or “POLB”); San Diego Gas & Electric Company; Marin Clean Energy, Sonoma Clean Power, City of Lancaster, and Silicon Valley Clean Energy (collectively, “CCA Parties”); California Energy Storage Alliance (“CESA”); Environmental Defense Fund (“EDF”); National Diversity Coalition (“NDC”); Pacific Gas and Electric Company; Office of Ratepayer Advocates (“ORA”); California Transit Association (“CTA”); EVgo Services LLC (“EVgo”); ChargePoint, Inc. (“ChargePoint”); The Utility Reform Network (“TURN”); Natural Resources Defense Council, Coalition of California Utility Employees, and Plug In America (collectively, “NRDC”); Green Power Institute and Community Environmental Council (“GPI/CEC”); Greenlining Institute (“Greenlining”); and San Diego Airport Parking Company.

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I.

INTRODUCTION

Senate Bill (“SB”) 350 requires the Commission to approve, or modify and approve, IOU programs

and investments in transportation electrification (“TE”) that meet certain statutory criteria.2 The California

legislature set this policy because it sees utilities having a fundamental role in increasing access to the use of

electricity as a transportation fuel, which is necessary for the state to meet its ambitious greenhouse gas

(“GHG”) reduction goals.3 SCE’s proposed portfolio of priority-review projects is an important step to

facilitate transportation electrification, consistent with the state’s goals.

As demonstrated in its opening brief, SCE’s proposed portfolio of priority-review projects satisfies

the applicable statutory requirements and regulatory guidance. Many parties filed briefs supporting SCE’s

proposed portfolio of priority-review projects.4 In this reply brief, SCE responds to the critiques raised by

certain parties’ opening briefs. As this reply demonstrates, no party has raised issues sufficient to

demonstrate that SCE’s proposed portfolio fails to satisfy the applicable statutory requirements or regulatory

guidance. Therefore, the Commission should approve SCE’s proposed portfolio without modification.

2 Public Utilities (“P.U.”) Code § 740.12(b). Unless otherwise designated, all other statutory references in this

Reply Brief are to the California Public Utilities Code. 3 See P.U. Code § 740.12(a)(1). 4 See, e.g., Siemens Brief; EYCEJ Brief; SBUA Brief; POLB Brief; CESA Brief; EDF Brief; CTA Brief;

ChargePoint Brief; NRDC Brief; GPI/CEC Brief; Greenlining Brief.

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II.

SCE’S PORTFOLIO PROVIDES SIGNIFICANT BENEFITS TO DISADVANTAGED

COMMUNITIES

ORA5 and EDF6 assert that SCE’s testimony does not include specific plans for how its priority-

review projects will benefit or target disadvantaged communities.7 ORA proposes to modify SCE’s priority

review projects to require at least a 10 percent carve-out for disadvantaged communities.8 NDC asserts that

SCE should set aside half of the residential make-ready rebates for customers located in disadvantaged

communities.9 TURN recommends that two out of the five proposed DCFC sites be located in

disadvantaged communities.10 In contrast, East Yard Communities for Environmental Justice, Center for

Community Action and Environmental Justice, Sierra Club, and Union of Concerned Scientists note the

“critical importance” of SCE’s proposed investments “to address the sources of higher pollution faced by

[disadvantaged communities].”11 TURN also notes that “most of the projects in SCE’s portfolio will likely

provide air quality and other benefits to [disadvantaged communities].”12

SCE’s service territory includes about 45 percent of California’s disadvantaged communities.13 SCE

intends to develop specific messaging and leverage geo-targeting to ensure awareness of the proposed pilots

5 ORA Brief, p. 3. 6 EDF Brief, p. 6. 7 Disadvantaged communities are census tracts that scored at or above the 75th percentile of environmental and

economic burden, as evaluated and ranked by the California Environmental Protection Agency (“CalEPA”), using CalEnviroScreen (“CES”) 3.0.

8 ORA Brief, p. 3. 9 NDC Brief, p. 12. 10 TURN Brief, p. 14. 11 EYCEJ Brief, p. 12. 12 TURN Brief, p. 14. 13 SCE-01, p. 13, fn. 25. Pursuant to Administrative Law Judge (“ALJ”) Wong’s email ruling, dated May 24, 2017,

parties’ briefs may cite to discussions during the workshop, responses to data requests, and reports from earlier EV proceedings. SCE assumes that testimony served in this proceeding may likewise be cited in these briefs.

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by customers residing in disadvantaged communities; in fact SCE anticipates that the proposed programs

will primarily benefit disadvantaged communities. 14 SCE also intends to collaborate with government

agencies, such as the California Air Resources Board or the California Pollution Control Financing

Authority, as SCE has done for its Charge Ready Pilot Program. SCE may also participate in public events

held in disadvantaged communities (e.g., “Smog-less Saturday events”) or other activities to promote

electric vehicle (“EV”) adoption.15

Certain parties also argue that the Rideshare Reward Pilot does not benefit disadvantaged

communities. NDC asserts that with low EV adoption among low-income and minority groups,

disadvantaged community residents could be effectively excluded from participation.16 Meanwhile, TURN

recommends that at least 50% of the rideshare reward incentives be targeted to low-income rideshare drivers

or drivers living in disadvantaged communities.17 Disadvantaged communities are defined using

environmental and population characteristics. SCE cannot predict any impact that the Rideshare Reward

Pilot will have on the environment in disadvantaged communities because the rides may take place outside

of disadvantaged communities. However, many rideshare drivers are low-income and could benefit if they

participate in the program.18 Restricting participation to disadvantaged community residents could

potentially prevent other low-income drivers from participating in the program. Further, SCE does not

intend to request income information from participating customers, as such requests could deter

participation.

SCE requested in its opening brief that its testimony be marked as Exhibit SCE-01 and moved into the record of this proceeding. SCE Brief, p. 3, fn. 3.

14 Id. at 13. 15 See ED-SCE-01-28, attached hereto as Appendix A. Pursuant to ALJ Wong’s email ruling, dated May 24, 2017,

parties’ briefs may cite to data request responses, and should attach a copy of the data request and the response. 16 NDC Brief, p. 12. 17 TURN Brief, p. 14. 18 See ED-SCE-01-32, attached hereto as Appendix B.

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Mandating minimum commitments to disadvantaged communities will inevitably delay pilot

deployment and may be difficult to achieve. None of the parties offers any explanation of how it calculated

these arbitrary disadvantaged community targets. Further, as the Green Power Institute and Community

Environmental Council note, for programs like the Residential Make-Ready Pilot, SCE should not focus

solely on disadvantaged communities because that is a relatively small part of the potential market for EVs

in the near and mid-term.19 Ultimately, the fundamental purpose of conducting pilot studies is to examine

the feasibility of an approach that may be used on a larger scale. The desired result of these pilot programs

is to improve upon the pilot design, which will maximize benefits to all communities and customers,

including disadvantaged communities.

III.

SCE’S PROPOSALS CONTAIN APPROPRIATE MEASURABLE MONITORING AND

EVALUATION CRITERIA

TURN asserts that SCE’s proposed measures “do not constitute performance accountability

measures as contemplated in §740.12 or in the ACR.”20 In fact, SCE’s portfolio proposes measurable

monitoring and evaluation criteria that are adequate to evaluate the performance of the proposed initiatives,

consistent with the statute’s requirements and the ACR’s guidance.

Section 740.12(b) states that transportation electrification programs should be approved, or modified

and approved, if they “include performance accountability measures,” among other requirements. The

statute does not define or interpret “performance accountability measures,” but the ACR provides some

relevant guidance. The ACR states:

Consistent with Pub. Util. Code §740.12(b), each of the proposed TE projects and investments shall include performance accountability measures. Such measures are needed in order to track the progress of the proposed projects and investments in order to ensure that they are timely contributing to the adoption of TE.21

19 GPI/CEC Brief, p. 18. 20 TURN Brief, p. 22. 21 ACR, p. 15 (emphasis added).

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TURN states that the IOUs’ proposed measures “are insufficient performance accountability

measures because they lack any accountability for the utility” and that the measures should act as “a form of

ratepayer protection” by holding the utility “responsible for failure to meet…specific goals or targets.”22

Neither §740.12(b) nor the ACR mention holding the utility responsible for failing to meet goals or targets.

Instead, the ACR explains that the measures are needed to “track the progress” of the projects to “ensure

that they are timely contributing to the adoption of TE.”23 SCE’s proposed measures do exactly this. In

addition to providing information to track and measure the implementation, status, and success of each pilot,

SCE’s proposed reporting will provide useful information on important transportation issues that will

provide valuable customer and market information such as customer acceptance of new technology or

functionality (e.g., vehicle-grid integration, time-of-use (“TOU”) pricing) and customer data (e.g.,

identification, usage, location, preference) that will be used to inform future utility investments and

programs.

TURN’s ultimate (and legitimate) concern appears to be protecting customers by ensuring that the

expenditures are prudent.24 SCE agrees that this is an important concern, and has designed its portfolio to

balance the need to accelerate transportation electrification with the need to keep rates affordable for

customers. As discussed in its opening brief, SCE’s proposed portfolio will facilitate transportation

electrification that provides direct ratepayer benefits, including putting downward pressure on rates.25

Providing direct ratepayer benefits is the standard established by §740.8, against which the Commission

should measure SCE’s portfolio. TURN’s recommendation to establish “minimum cost-effectiveness

thresholds, EV adoption per dollar spent, etc.”26 is not supported by the language in §740.8 or the ACR.

These additional requirements would create unacceptable new restrictions that exceed what the legislature

22 TURN Brief, p. 23. 23 ACR, p. 15. 24 TURN Brief, p. 23. 25 SCE Brief, pp. 16-21. 26 TURN Brief, p. 23.

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has already clearly defined in §740.8 as the list of benefits necessary to justify investment in transportation

electrification programs.

Furthermore, the ACR set specific criteria for priority-review projects, acknowledging the need to

“expedite the authorization of certain non-controversial projects and investments to accelerate the adoption

of TE and to meet the goals of SB 350.”27 SCE’s proposed measures allow the Commission and interested

stakeholders to learn whether these projects meet their proposed goals and whether they should be scaled up

in the future.

NDC proposes a specific formula to calculate a proposed amount of carbon dioxide reduction that

should be achieved by each priority-review project; otherwise NDC recommends that the utility refund a

portion of the project costs to customers.28 For all the reasons discussed above in response to TURN’s

argument, NDC’s request is unnecessary and inappropriate. Furthermore, the formula proposed by NDC

uses flawed assumptions that incorrectly calculate GHG and program costs.29 Even if the assumptions in

NDC’s formula are corrected, the proposal stretches to compare the trade-offs between providing charging

infrastructure, operating a program, and providing vehicle incentives. All of these factors are important to

increase and accelerate TE. NDC’s sole focus on GHG reduction fails to recognize the purpose and benefits

of SCE’s proposed portfolio, including, in addition to GHG emissions reductions, testing assumptions,

collecting data, and supporting TE that can create downward pressure on rates and improve integration of

renewables.

27 ACR, p. 31. 28 NDC Brief, p. 17. 29 NDC uses the gross emissions from a gasoline-fueled vehicle, as calculated by EPA, instead of the net reductions

of replacing a gasoline-fueled vehicle with an electric vehicle. Using CARB’s Low Carbon Fuel Standard methodology, the net GHG reduction is approximately 2.5 metric tons per vehicle as opposed to NDC’s proposed 4.7 metric tons. Similarly, NDC assumes $4 million gross program costs without accounting for the administrative, IT, and operations cost of administering any type of program.

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TURN and other parties recommend several specific changes to SCE’s data collection proposal.

SCE will incorporate the recommendations to the extent possible, but some of the recommendations are not

feasible, for the reasons described below.

A. Urban DCFC Clusters Pilot

TURN recommends that SCE conduct research into the number of EVs in the areas evaluated for the

DCFC clusters to determine how many are likely to use the charging stations.30 TURN also recommends

that SCE conduct a comparative analysis between the utilization rates in the SCE program and the

utilization rates at other DCFC sites in SCE’s service territory.31 EYCEJ recommends that SCE provide

information on electricity prices paid by EV drivers, including average and peak prices and any additional

fees.32 EYCEJ and TURN also recommend that SCE survey users of the charging stations to collect

qualitative information about the users.33 TURN recommends that SCE report on survey results, EV

adoption, increases in use of alternative fuels, air quality impacts, and GHG emissions reductions.34

As stated in SCE’s testimony, the objective of the pilot is to determine interest in DCFC in urban

areas and evaluate charging behaviors of end-users.35 SCE anticipates that the charging stations deployed

through the pilot may be used by local residents and by commuters from other areas. As such, SCE will not

be able to determine how many EVs may use the charging stations before they are deployed. Rather, SCE

will rely on the interest of business customers to participate in the pilot and offer DCFC charging services.

These customers will have significant “skin in the game” to operate and maintain DCFC charging stations in

accordance with the terms and conditions of the proposed pilot.

30 TURN Brief, p. 35. 31 Id. 32 EYCEJ Brief, p. 22. 33 Id.; TURN Brief, p. 35. 34 TURN Brief, p. 35. 35 SCE-01, p. 39.

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SCE plans to track and report information on utilization of the pilot charging stations. This

information can be compared to other publicly-available information on other DCFC sites in SCE’s service

territory, but SCE is unlikely to have access to the utilization rates for DCFC sites that are not part of SCE’s

pilot, and such information may be confidential. SCE also plans to track prices paid and survey users of the

pilot charging stations,36 and will report the results of those surveys. Based on the amount of electricity

used by the charging stations participating in SCE’s pilot, SCE can calculate and report on associated air

quality impacts and GHG emissions reduction. Unfortunately, it is not possible to know the number of

incremental EVs adopted solely based on this SCE pilot because many factors beside the availability of

charging infrastructure contribute to purchasing or leasing an EV. Survey results can only help inform

whether the pilot’s charging stations factored into a driver’s decision to adopt an EV or facilitated that

driver’s ability to drive more electric miles.

B. Residential Make-Ready Rebate Pilot

TURN and NDC recommend collecting data and reporting on the incremental EV adoption and

electric miles driven from this program.37 As discussed above, it is not possible to determine the number of

incremental EVs adopted solely as a result of an infrastructure pilot.

SCE has proposed that eligible customers be required to provide proof of a recent EV purchase or

lease of a light-duty EV.38 As such, all pilot participants should be considered recent EV adopters, but no

baseline exists to determine the incremental nature of such EV adoptions.

Similarly, the energy dispensed through meters dedicated to EV charging installed through the

proposed pilot could be converted to electric miles and reported to the Commission and stakeholders using

industry-accepted assumptions.39 However, the absence of a baseline prevents clear determination that

36 Survey information could include but may not be limited to customer data such as address, income level, vehicle

make/model and miles driven, pricing sensitivity preferences, preferred charging location, and knowledge of utility offerings/programs.

37 TURN Brief, p. 34; NDC Brief, pp. 19-20. 38 SCE-01, p. 32. 39 Electric load specific to EV charging cannot be differentiated from other residential load for those customers

electing to take service on a whole-house TOU rate schedule because only one meter serves their residence.

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these electric miles are incremental. SCE will provide participating customers with a survey to gather

information about how the pilot influenced their decisions to acquire an EV or increased electric miles they

drive, and will include survey results in its reporting.

C. EV Driver Rideshare Reward Pilot

EYCEJ recommends that SCE report data on how many rides are provided with the EVs, miles

traveled by the electric vehicles both in-service and out-of-service, and where vehicles are picking up and

dropping off riders.40 ORA also requests that SCE collect and report on several types of data, including

surveys showing whether customers would be likely to participate in the pilot, a quantitative analysis of the

cost-effectiveness of varying incentives to increase EV rideshare vehicle miles traveled, rideshare miles

from conventional internal-combustion-engine vehicles displaced by electric miles traveled as a result of the

pilot, and whether rideshare customers’ awareness of EVs and interest in adoption are influenced by using a

rideshare EV.41

SCE plans to work with participating rideshare companies to provide aggregated, anonymized data,

but may not have access to all requested data. SCE will also not be able to test different reward amounts

because of the limited duration of the proposed pilot. SCE will track the total number of rideshare miles as

well as the total number of battery-electric-vehicle (“BEV”) miles. However, SCE cannot determine the

electric miles driven by EVs that may also rely on an internal combustion engine (i.e., plug-in hybrid

electric vehicles). SCE will collect and report survey information from participating rideshare drivers and

plans to work with rideshare companies to offer riders a voluntary survey to identify how the pilot

influenced rideshare drivers and riders to use or consider using EVs.

40 EYCEJ Brief, p. 23. 41 ORA Brief, pp. 2-3.

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IV.

SCE’S COST RECOVERY PROPOSAL IS APPROPRIATE, CONSISTENT WITH

ACCOUNTING RULES AND REGULATORY DECISIONS AND WILL REASONABLY

COMPENSATE SCE FOR ITS INNOVATIVE EFFORTS TO ACCELERATE WIDESPREAD TE

ADOPTION

A. The Charging Station Rebate Should be Capitalized Consistent with the Treatment of Other

Utility Regulatory Assets

1. Regulatory Asset42 Treatment of the Charging Station Rebate Results in Equitable

Ratemaking

Depreciation accounting is the process of systematically and rationally allocating the costs of

an asset over its useful life. This treatment ensures that customers who receive the benefits of an asset’s

service bear an equitable portion of its costs. In its brief, TURN argues that rebate costs should be treated as

expense, regardless of the 10-year service life of the asset.43 TURN’s proposal to expense the cost of the

rebates would result in customers today being burdened by the cost of developing a market whose benefits

will accrue to future customers. Treating charging station rebates as a regulatory asset and depreciating

them over a 10-year life allocates their cost equitably to both current and future customers.

2. Regulatory Asset Treatment is Consistent with GAAP

TURN questions the appropriateness of capitalizing the costs of the rebate under Generally

Accepted Accounting Principles (“GAAP”). TURN asserts that SCE is obligated to follow GAAP rules

requiring the expensing of such costs as incurred, citing SCE’s agreement to expense similar costs in the

Charge Ready settlement approved by the Commission.44 TURN’s assertion is incorrect.

42 A regulatory asset or liability is defined as specific costs or revenues that a regulatory agency permits a utility to

defer to the balance sheet (can be a regulatory liability or asset depending on whether the spend is an over- or under-collection). These amounts would otherwise be required to appear on the company's income statement and would be charged against current expenses or revenues.

43 TURN Brief, p. 19. 44 TURN Brief, p. 21.

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TURN’s representation of GAAP accounting is incomplete. The Financial Accounting

Standards Board (“FASB”) recognizes that cost flows that may otherwise be expensed according to GAAP

can become assets or liabilities as the result of a Commission decision. The FASB addresses this fact

specifically:

Rate actions of a regulator can provide reasonable assurance of the existence of an asset. An entity shall capitalize all or part of an incurred cost that would otherwise be charged to expense if both of the following criteria are met:

a. It is probable (as defined in Topic 450) that future revenue in an amount at least equal to the capitalized cost will result from inclusion of that cost in allowable costs for rate-making purposes.

b. Based on available evidence, the future revenue will be provided to permit recovery of the previously incurred cost rather than to provide for expected levels of similar future costs. If the revenue will be provided through an automatic rate-adjustment clause, this criterion requires that the regulator’s intent clearly be to permit recovery of the previously incurred cost.45

Should the Commission decide that the rebate cost be allocated to customers over the

charging stations’ useful life, ASC 980 requires the costs to be capitalized. TURN’s argument to expense

the cost of the rebate ignores the Commission’s ability to approve the charging station rebates as regulatory

assets.

3. Commission Precedent in Mobile Home Park Order Instituting Rulemaking (MHP

OIR) Supports Regulatory Asset Treatment

SCE’s reliance on the Commission’s decision in the MHP OIR is appropriate because in that

situation, like here, the Commission was addressing a proposal to use ratepayer funding to achieve public

purposes intertwined with basic utility service.46 TURN, however asserts that the Commission’s decision in

45 Accounting Standards Codification (“ASC”), Section 980, “Regulated Operations,” paragraph ASC 980-340-25-1

(emphasis added), available at ftp://law.resource.org/pub/us/code/bean/fasb.html/fasb.980.2011.html [as of June 5, 2015].

46 D.14-03-021.

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the MHP OIR is not precedential to the treatment of the rebate costs in SCE’s proposed TE program for

several reasons, including:

• The Commission was primarily addressing issues preventing agreement between park

owners and utilities in the MHP OIR; 47

• The MHP OIR dealt with ensuring delivery of safe electric service;48 and

• The charging station rebates are similar to Energy Efficiency program expenditures.49

D.14-03-021, however, acknowledges the Commission’s authority to allow cost recovery of

“behind-the-meter” assets not owned by the utility, capitalized as a regulatory asset, particularly when this

furthers goals and objectives of the state of California. TURN reiterates this rationale stating “the

Commission was faced with whether and how ratepayer funding should be used to support broad public

purposes intertwined with basic utility service.”50 As explained in SCE’s testimony, the rebate is a crucial

component of the system that will help reduce barriers to achieving California’s ambitious goals of

expanding the adoption of transportation electrification to meet the state’s climate goals and air quality

requirements.51 The Mobile Home Park decision’s authorization to create a regulatory asset for behind-the-

meter, non-SCE owned assets is directly relevant to SCE’s proposal to create a ten-year regulatory asset for

non-SCE-owned charging infrastructure. Finally, the TE charging station rebates support investment in

long-lived assets that are directly related to the delivery of electric service. Energy Efficiency rebates

(which are expensed) are distinguishable, however, because they typically support customer-side investment

in HVAC systems and home improvements that have no direct relation to the delivery of electric service.

47 TURN Brief, p. 20. 48 Id., p. 21. 49 Id., p. 19. 50 Id., p. 20. 51 SCE-01, p. 107.

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B. After-the-Fact Reasonableness Review is Not Required

ORA asserts that SCE should be subject to an after-the-fact reasonableness review for costs incurred

related to the priority-review projects.52 SCE disagrees. SCE intends to spend no more than the authorized

cost for each pilot. If SCE does not exceed the cost cap for each pilot, an after-the-fact reasonableness

review is not necessary or appropriate. Indeed, as ORA acknowledges,53 these proposed pilot programs

have uncertain outcomes and therefore after-the-fact reasonableness reviews would be hindsight-based,

subjective exercises. Any proposal to tie program outcomes to cost recovery would be onerous and unfair.

SCE has managed many pilots within Commission-approved cost caps. A particularly relevant example of

SCE’s ongoing management of costs within a Commission-approved cost cap is SCE’s Charge Ready

program, as demonstrated by its quarterly progress reports.54

C. SCE’s Proposed Cost Cap Is Consistent with the ACR

TURN recommends that SCE establish a one-way balancing account with a cost cap for each

project, or at a minimum a $20 million limit for the portfolio of projects.55 SCE’s proposal satisfies

TURN’s recommendation. SCE’s determination that after-the-fact reasonableness review is unnecessary for

direct capital expenditures incurred within the cap in no way changes the type of balancing account

proposed or implies that SCE will exceed those limits, as explained above.

ORA states that it is unclear56 whether SCE’s proposals include overhead loader costs, and that SCE

should be required to demonstrate that its proposal does not result in costs that exceed the ACR’s

requirement that each priority-review project individually be less than $4 million, with an aggregate limit of

52 ORA Brief, p. 17. 53 ORA Protest, pp. 4-5. 54 Charge Ready Pilot Program Quarterly Report, filed June 1, 2017, in A.14-10-014, attached hereto as Appendix

D. Pursuant to ALJ Wong’s email ruling, dated May 24, 2017, parties’ briefs may cite to reports from earlier EV proceedings, and should attach a copy of the report.

55 TURN Brief, p. 18. 56 To resolve any questions related to SCE’s financial forecasting of costs and revenue requirements, SCE would

propose focused discussions with interested parties to review the modeling and assumptions.

15

$20 million.57 SCE will separately record the TE pilot program revenue requirements associated with up to

$4 million in direct capital expenditures and/or operations and maintenance (“O&M”) expense for each

pilot. All recorded incremental costs will include provisions for applicable overhead loadings on direct

labor dollars, to appropriately account for items such as employee benefits and payroll taxes. Overhead

loading factors will be based on authorized rates. However, to the extent a particular labor loading is

currently accounted for in another balancing account (e.g, Pensions, Post-employment Benefits Other Than

Pensions, Medical), SCE will not include these labor loadings in the recorded operation of the TE balancing

account.

SCE’s TE balancing account proposal is consistent with the operation of other SCE balancing

accounts that are reviewed annually in SCE’s ERRA Review filings. SCE proposes to spend no more than

$4 million for each pilot in nominal direct capital and O&M expenditures,58 which are costs controllable by

TE program managers. SCE is proposing a cost cap in this application that is consistent with prior decisions

involving cost caps for capital projects, including D.16-12-065, which authorized SCE’s Charge Ready

program. Similarly, the TE balancing account will record the revenue requirements associated with direct

expenditures that remain under the $4 million individual cap per pilot and $20 million aggregate limit, until

a Commission decision authorizes the inclusion of TE-related revenue requirements in a future general rate

case (“GRC”).

D. SCE’s Proposed Allocation of Costs to Distribution Rates is Consistent with Commission

Precedent and Avoids the Inequitable Result of the CCA Parties’ Proposal

The CCA Parties question whether it is appropriate to allocate all costs related to the TE applications

to the distribution rate component function.59 They assert that some undefined portion of the costs should

57 ORA Brief, p. 36. 58 The $4 million cap per pilot includes direct capital expenditures and O&M expenses and applicable division

overheads, for example T&D Engineering, but not labor loaders including 401K, pensions, medical and other benefits.

59 CCA Parties Brief, p. 10.

16

be allocated to the generation rate component function (and therefore borne only by SCE’s bundled service

customers), because they allege that “TE efforts are closely associated with goals and costs that are

generation-related in nature.”60 Allocating the costs for the TE portfolio to generation rates is contrary to

Commission precedent and would lead to inequitable results that are in tension with statutory prohibitions

against cost shifting between departing load and bundled service customers.61 Commission precedent shows

that costs for programs that are open to all customers, including CCA customers, should be funded by all

customers.62 SCE’s proposed programs are open to CCA customers, DA customers, and bundled service

customers, and therefore allocating costs to SCE’s distribution rate component, which all customers pay, is

appropriate.63 Furthermore, TE assets are infrastructure-related, both on the utility side and the customer

side, and include transformers, conduit and wiring, meters, easements, and the “make-ready stub.” SCE’s

testimony demonstrates that these are distribution-related assets; cost recovery solely from bundled service

customers is contrary to statute, inherently unfair, and contrary to Commission precedent.64

The CCA Parties’ allege that “TE programs have the potential to significantly benefit the IOUs in

terms of generation service.”65 SCE does not dispute that increased TE can provide benefits to SCE’s

customers by facilitating integration of renewables, addressing solar overgeneration, and providing grid

benefits, especially with TE customers on time-of-use rates.66 But these are not the only benefits of SCE’s

proposed portfolio. These and other benefits, including downward pressure on rates and reduced local air

60 Id., pp. 10-11. 61 If the CCA Parties’ position is adopted, it would result in costs being shifted to bundled service customers in

contravention to P.U. Code Sections 366.2(a)(4), 366.2(d)(1), 365.2, and 366.(3). 62 See D.14-12-024, p. 48, which states: “We find it equally reasonable that tariffs and programs, including pilots,

available to all customers should be paid for by all customers.” See also the California Solar Initiative (“CSI”) and Self Generation Incentive (“SGIP”) programs, which are funded through distribution rates, and the state’s Energy Efficiency and California Alternate Rates for Energy (“CARE”) programs, which are funded through Public Purpose Program rates that are paid for by all customers.

63 City of Lancaster-SCE-002, Question 01, attached hereto as Appendix C. 64 SCE-01, p. 106; City of Lancaster-SCE-002, Question 01, attached hereto as Appendix C. 65 CCA Parties Brief, p. 12. 66 See Id., p. 11.

17

pollution and greenhouse gas emissions, accrue to the benefit of all SCE distribution customers, including

CCA customers. Allocating the costs of the TE portfolio to generation rates, as the CCA Parties

recommend, would lead to the unjust result where CCA customers could participate in the TE programs and

receive the benefits from them (whether they chose to participate or not), without paying the costs

associated with the programs.

V.

CONCLUSION

For the foregoing reasons, SCE respectfully requests that the Commission approve SCE’s portfolio

of priority-review projects without modification.

Respectfully submitted, FADIA RAFEEDIE KHOURY ANDREA L. TOZER

/s/ Andrea L. Tozer By:

Andrea L. Tozer


2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6713 Facsimile: (626) 302-6693 E-mail: [email protected]

Dated: July 10, 2017

Appendix A

ED-SCE-01-28

Southern California Edison2017 TE Application A.17-01-021

DATA REQUEST SET A.17-01-021 ED-SCE-001

To: ENERGY DIVISIONPrepared by: Arnaud Duteil

Title: Consultant Dated: 03/29/2017

Question 28:

Residential Make-Ready Rebate Pilot

28. SCE states that it will specifically target disadvantaged communities for this pilot. How will this occur?

Response to Question 28:

SCE intends to develop specific messaging and leverage geo-targeting to develop awareness of customers residing in disadvantaged communities about the proposed pilot. In addition, SCE intends to collaborate with government agencies, such as the California Air Resource Board or the California Pollution Control Financing Authority, as SCE has done for the Charge Ready Pilot Program. SCE may also participate in public events held in disadvantaged communities (e.g., “Smog-less Saturday events") or other activities to promote EV adoption.

Appendix B

ED-SCE-01-32


DATA REQUEST SET A.17-01-021 ED-SCE-001

To: ENERGY DIVISIONPrepared by: Eric SeiloTitle: Project Manager

Dated: 03/29/2017

Question 32:

EV Driver Rideshare Reward Pilot

32. How will the rideshare reward program specifically target disadvantaged communities?

Response to Question 32:

Because drivers and vehicles participating in rideshare programs are subject to the destinations of their passengers, it is not feasible to limit a reward program payout or benefits to a specific geography. However, rideshare drivers skew closer to lower income demographics, which is one of the socio-economic variables in defining a disadvantaged community. According to research conducted by Entrepreneur Magazine (https://assets.entrepreneur.com/static/1421949314-uber-demographics.jpg), 50% of drivers are over 40, 86% are male, 64% are non-white and only half have a college degree, while 75% are supporting children or a parent at home.

Appendix C

City of Lancaster-SCE 002, Question 01


DATA REQUEST SET A.17-01-021 City of Lancaster-SCE-002

To: CITY OF LANCASTERPrepared by: Matt Sheriff

Title: Senior Project Manager Dated: 05/02/2017

Question 01.a-b:

1. Lancaster understands that SCE proposes to recover Transportation Electrification (“TE”) program costs entirely through distribution rates (see SCE response to Lancaster Data request set 1 and Chapter V.A of SCE’s direct testimony). a. Please explain the rationale for allocating all TE program costs entirely to the distribution

function.b. Please explain why no portion of the costs of the TE program should be allocated to

generation rates.

Response to Question 01.a-b:

a) As explained in SCE-01, Section II, SCE's Transportation Electrification (TE) program is intended to support California's ambitious goal to reduce GHG emissions to 40% below 1990 levels by 2030, which not only benefits all of SCE's customers, but also benefits all residents of California. SCE's TE program is also intended to reduce ground level air pollution, which benefits all Southern California residents. Finally, the increase in sales from the electrification of transportation can benefit all of SCE's distribution customers by spreading fixed costs across additional sales, which can put downward pressure on rates. For all these reasons, cost recovery through distribution rates, which is paid by all of SCE's customers, is the appropriate rate component for recovery of SCE's TE program costs.

b) Participation in SCE's program is open to CCA customers, DA customers, and SCE's bundled service customers and therefore the distribution rate component is the appropriate means for cost recovery. Also, as explained in SCE-01, Section V.D, Transportation Electrification assets are infrastructure-related, both on the utility side and the customer side, and include transformers, conduit and wiring, meters, easements and the "make-ready stub." As shown in SCE-01, Table V-8 (FERC accounts), these assets are distribution-related; and recovery from SCE bundled generation customers alone would not be appropriate.

Appendix D

SCE Charge Ready Pilot Program Quarterly Report for First Quarter 2017


STATE OF CALIFORNIA

Application of Southern California Edison Company (U 338-E) for Approval of its Charge Ready and Market Education Programs.

) ) ) ) )

A.14-10-014 (Filed October 30, 2014)

SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) CHARGE READY PILOT PROGRAM QUARTERLY REPORT

FADIA RAFEEDIE KHOURY ANDREA L. TOZER


2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302- 6713 Facsimile: (626) 302- 6693 E-mail: [email protected]

Dated: May 31, 2017

1


STATE OF CALIFORNIA


A.14-10-014

(Filed October 30, 2014)

SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) CHARGE READY PILOT PROGRAM QUARTERLY REPORT

Southern California Edison Company (SCE) hereby submits its Charge Ready Pilot

Program Quarterly Report for First Quarter 2017, attached hereto as Attachment A. The

information contained in this report supersedes all prior reports submitted by SCE.

Respectfully submitted, FADIA RAFEEDIE KHOURY ANDREA L. TOZER /s/ Andrea Tozer By: Andrea Tozer


2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302- 6713 Facsimile: (626) 302- 6693 E-mail: [email protected]

Dated: May 31, 2017

Attachment A

Charge Ready Pilot Program Quarterly Report for First Quarter 2017

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IIsIIsIIssussusuuuusuuuusuuuusss eded MMMMayayayy 33331,1,11, 201177

Get Started

Table Of ContentsBackground

Background................................................................................................................................... 5

1 Executive Summary1.1 Pilot Summary for Quarter ............................................................................................................ 6

2 Customer Outreach and Enrollment2.1 Charge Ready Education & Outreach ................................................................................................ 9

2.2 Market Education & TE Advisory Services ........................................................................................ 10

2.3 Outreach Events ...................................................................................................................... 11

3 Electric Vehicle Supply Equipment Qualification3.1 Requirements ......................................................................................................................... 12

4 Electric Vehicle Charging Load4.1 EV Charging Load..................................................................................................................... 13

5 Operations5.1 Charge Ready Pilot Operations ..................................................................................................... 14

5.2 Supplier Diversity ..................................................................................................................... 22

5.3 Collaboration Efforts with Complementary EV Programs ....................................................................... 22

5.4 Disadvantaged Communities Outreach Events................................................................................... 22

6 Conclusion6.1 Conclusion............................................................................................................................. 23

AppendixAppendix.................................................................................................................................... 24

Table of Tables

– 2 –

Table Of Tables1 Executive Summary

Table 1.1 – Pilot Summary for Quarter 1, 2017..........................................................................................................................7

Table 1.2 – Pilot Challenges and Resolutions ............................................................................................................................8

2 Customer Outreach and EnrollmentTable 2.1 – Charge Ready Landing Page Traffic Metrics ..........................................................................................................10

Table 2.2 – Summary of Account Manager Interactions with MUD Customers ......................................................................10

Table 2.3 – Summary of Account Manager Interactions with Customers ...............................................................................10

Table 2.4 – Customer’s Source of Knowledge of Pilot .............................................................................................................11

Table 2.5 – Charge Ready EV Awareness Website Metrics ....................................................................................................11

Table 2.6 – CAT Survey Results ...............................................................................................................................................12

Table 2.7 – Charge Ready Education & Outreach and Market Education & TE Advisory Services Outreach Events ..............12

3 Electric Vehicle Supply Equipment QualificationTable 3.2 – EVSE Model Summary ..........................................................................................................................................13

Table 3.3 – Base Cost of Charging Systems ............................................................................................................................13

5 OperationsTable 5.1 – Pilot Operational Metrics for Quarter ....................................................................................................................17

Percentage of total applications received ................................................................................................................................17

Number of approved and confirmed sites (Step 2 Agreement signed) ...................................................................................17

Percentage of applicants rejected ...........................................................................................................................................17

Percentage of applicants withdrawn .......................................................................................................................................17

Number of applicants withdrawn after signing Step 2 - Agreement .......................................................................................18

Total number of charge ports installed ....................................................................................................................................18

Average number of charge ports installed per site ..................................................................................................................18

Percentage of completed projects ..........................................................................................................................................18

– 3 –

Table 5.2 – Customer Participant Request...............................................................................................................................19

Table 5.3 – Pilot Costs .............................................................................................................................................................20

Table 5.4 – Pilot Cycle Times ...................................................................................................................................................21

Table 5.3 – Disadvantaged Community Outreach Events........................................................................................................23

AppendixPercentage of total applications received ................................................................................................................................25

Percentage of charging stations requested .............................................................................................................................25

Number of approved and confirmed sites (Step 2 Agreement signed) ...................................................................................26

Percentage of applicants rejected ...........................................................................................................................................26

Percentage of applicants withdrawn .......................................................................................................................................26

Number of applicants withdrawn after signing Step 2 - Agreement .......................................................................................27

Total number of charge ports installed ....................................................................................................................................27

Average number of charge ports installed per site ..................................................................................................................27

Percentage of completed projects ..........................................................................................................................................28

Average number of total parking spaces per site ...................................................................................................................28

Percentage of total number of parking spaces located in parking structures ..........................................................................28

Average number of charge ports requested per site ...............................................................................................................29

Pilot Costs ...............................................................................................................................................................................30

Total estimated Pilot costs.......................................................................................................................................................30

Total amount of rebate reserved..............................................................................................................................................30

Total amount of rebate paid .....................................................................................................................................................31

Average amount of rebate reserved per site ...........................................................................................................................31

Total actual construction costs for SCE infrastructure .............................................................................................................31

Average actual construction cost for SCE infrastructure per site ............................................................................................32

Pilot Cycle Times .....................................................................................................................................................................33

Charging Station Request & Rebate ........................................................................................................................................34

– 4 –

Executive

Summary

Customer

Outreach and

Enrollment

Electric Vehicle

Supply Equipment

Qualification

Electric Vehicle

Charging LoadOperations Conclusion

Background

Background

SCE’s Charge Ready Program Pilot (Pilot) seeks to increase the availability of long dwell-time electric vehicle (EV) charging infrastructure.

As part of the Pilot, SCE deploys, owns, and maintains the electric infrastructure needed to serve EV charging stations, or Electric Vehicle

Supply Equipment (EVSE), at participating customer locations. The Pilot also offers participating customers (Customer Participants)

a rebate applicable against the cost of acquiring and installing qualified EVSEs. Customer Participants must procure, operate, and

maintain the charging stations in accordance with the terms and conditions of Schedule Charge Ready Program Pilot (Schedule CRPP).

Customer Participants may determine their own policy about the use of the charging stations (e.g., access, financial contribution from

EV drivers).

In conjunction with the Pilot, SCE has launched a complementary EV Market Education effort to increase customer awareness about EVs

and the benefits of fueling from the grid, including supporting California’s carbon-reduction goals and improving air quality. The EV Market

Education effort includes a Transportation Electrification (TE) Advisory Services program to provide a “one-stop shop” for customers to

receive specialized education and support on a broad array of TE issues.

The Pilot targets key market segments for deployment, including workplaces, multi-unit dwellings (MUDs), fleet parking, and destination

locations where vehicles are usually parked for at least four hours. In particular, SCE focuses some of its efforts on disadvantaged

communities1, which are disproportionately affected by low EV adoption and negative environmental impacts of gasoline- and diesel-

powered vehicles.

The Pilot’s objectives are to inform and refine the program’s design and cost estimates and develop success measures for a subsequent

Phase 2. The Pilot’s quarterly reports include key metrics and updates about progress, achievements, and lessons learned. The quarterly

reports may also include recommendations from the Advisory Board that SCE will consider incorporating in its Phase 2 proposal.

1 http://oehha.maps.arcgis.com/apps/Viewer/index.html?appid=112d915348834263ab8ecd5c6da67f68

Background | 5

Executive

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1 Executive Summary

1.1 Pilot Summary for Quarter

SCE achieved several milestones in Q1 2017. SCE completed the first site in the Charge Ready Program. The deployment was located in

a disadvantaged community and included six charge ports to support the customer’s new electric vehicle fleet. Additionally, SCE received

significant interest in the Pilot and a large number of applications; as a result, SCE stopped accepting new applications into the program

on January 3, 2017. SCE also received executed program agreements from 58 Customer Participants, totaling 919 charge ports. 50%

of the 919 committed charge ports are located in disadvantaged communities, which is considerably higher than the Pilot’s requirement

to deploy 10% of charge ports in disadvantaged communities.

During the quarter, projects with executed agreements continued forward through the planning and design process. SCE efforts included

design preparation, and obtaining customer approval of designs and execution of easements. In parallel, customers continued procuring

qualified charging stations.

The table below summarizes the Pilot’s expenses to date.

Table 1.1 – Pilot Summary for Quarter 1, 2017

VariablesAuthorized/Planning Assumptions

Year-to-date Remaining% Remaining

Capital

Utility Side Infrastructure Costs $3,353,532 $101,653 $3,251,879 97%

Customer Side Infrastructure Costs $7,586,387 $1,156,403 $6,429,984 85%

Easement $115,942 $46,569 $69,373 60%

Station Testing $30,000 $34,680 $(4,680) 0%

Business Customer Division Labor $103,500 $10,611 $92,889 90%

Program Management Office Labor $460,003 $401,886 $58,117 13%

Operations & Maintenance

Rebate $5,850,000 $0 $5,850,000 100%

Business Customer Division Labor $51,750 $23,344 $28,406 55%

Transportation Electrification Advisory Services $316,800 $113,514 $203,286 64%

PMO Labor & Non-Labor $232,340 $143,010 $109,330 43%

Charge Ready ME&O, Market Reporting, SAP $665,000 $394,218 $250,782 39%

EV Awareness $2,830,600 $1,589,834 $1,240,766 44%

$21,595,853 $4,015,722 $17,580,132 81%

At the end of Q1 2017, SCE continued learning from the applications in the Planning and Design and charging station procurement stages

of the application process. Table 1.2 lists the main operational issues encountered during Q1 2017 and their resolutions.

Pilot Summary for Quarter | 6

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Table 1.2 – Pilot Challenges and Resolutions

Issue Resolution

SCE observed customers needing longer than 30 calendar days to select vendors and procure charging stations (Step 3 Proof of Procurement). The initial Procurement Period is 30 calendar days from SCE notifying Customer Participant that funding has been reserved for their application. At the end of Q1 2017, 62% of customers submitted their proof of procurement within 30 average business days, and 38% of customers are still pending submission and are averaging 71 business days. Common reasons for extension requests include:

• Customer difficulties finding charging station models that were close to the base cost rebate

• Change in customer decision maker; need to reevaluate program requirements

• Request For Proposal process and/or executive signature process requires longer than 30 days for some customers; government and institution customers require longer procurement cycle times

• Change in vendor quotes after customer signs program agreement

For the Pilot, SCE will be placing customers on waitlist who have exceeded procurement deadlines, including extension deadlines. For a future phase of the program, SCE recommends reevaluating base cost levels based on actual equipment and installation costs in the Pilot. SCE will also consider process improvements for customer procurement of charging stations.

SCE will also continue to learn from government and institution customer participants to identify if different program requirements are needed to accommodate for these customers’ unique, internal processes.

For some applications, SCE discovered that a customer’s point of contact would change mid-stream due to employee turnover. A change of contact caused delays in advancing the application forward because of the new contact’s lack of history of the project and knowledge of the program process.

SCE held in-person meetings with new points of contact to ensure their understanding of program requirements and next steps.


Executive

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Outreach and

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Electric Vehicle

Supply Equipment

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Supply Equipment

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Executive

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Issue Resolution

SCE experienced construction delays due to delays in meter panel assembly and delivery for the first sites under construction. Panels were custom ordered for each site’s load from one manufacturer. Additional lead time is required for the manufacturer to build and fully test for warranty purposes.

SCE expanded meter panel resources. SCE also orders panels earlier in the design process to minimize project delays.

By the end of Q1 2017, the dropout rate of customers withdrawing from the program after receiving a proposed defined plan was 10%. SCE also observed two customers drop out of program after execution of Step 2 Agreements.

SCE will account for the learned dropout rates in future program policies.


Executive

Summary

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Supply Equipment

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Enrollment

2 A unique visitor is a person who visits the landing page at least once within the reporting period. 3 A repeat visitor is a person with multiple sessions of the landing page within the reporting period. 4 A page view refers to an instance of the landing page being loaded in a web browser. 5 The bounce rate is the percentage of visitors to a particular website who navigate away from the site after viewing only one page. 6 This bounce rate is expected; for customers to enroll in the Pilot, they must enter the Charge Ready Enrollment Portal, which means they would have effectively “navigated away from” the landing page; this registers as a “bounce,” even though the customer has taken a positive step toward enrollment. 7 This bounce rate is expected; for customers to enroll in the Pilot, they must enter the Charge Ready Enrollment Portal, which means they would have effectively “navigated away from” the landing page; this registers as a “bounce,” even though the customer has taken a positive step toward enrollment. 8 These are incremental, follow-up emails to the email invitations originally sent to customers at the launch of the Program. 9 Presentations provided by BCD Account Managers to industry or civic events.10 These are incremental, follow-up emails to the email invitations originally sent to customers at the launch of the Program.11 Presentations provided by BCD Account Managers to industry or civic events.

2 Customer Outreach and Enrollment

2.1 Charge Ready Education & Outreach

Charge Ready education and outreach efforts are designed to

promote the Pilot to SCE customers. SCE is also testing and refining

its tactics and marketing channels in preparation for a subsequent

phase of Charge Ready, including email, website, social media,

collateral, and account manager interaction.

Table 2.1 presents the data collected for the Charge Ready Landing

Page to measure the traffic of the website. A decrease in website

activity was expected in Q1 2017 since marketing and outreach for

new applicants ceased on January 3, 2017.

Table 2.1 – Charge Ready Landing Page Traffic Metrics

Metric Q4 2016 Q1 2017% Change

Unique Visitor Count2 940 939 -0.11%

Repeat Visitor Count3 458 381 -16.81%

Page Views4 1,703 1,477 -13.27%

Bounce Rate5 54.87%6 51.01%7 -3.86%

The Q4 2016 quarterly report described SCE’s targeted outreach

efforts to the multi-unit dwelling (MUD) segment. As a result of

that effort, SCE received two commitments in Q4 2016 and another

commitment in Q1 2017, totaling 35 charge ports in MUDs. SCE is

continuing to work with and reserve funds for one additional MUD

customer. SCE’s interactions with these four MUD customers are

described in Table 2.2.

Table 2.2 – Summary of Account Manager Interactions with

MUD Customers

Activity No. Interactions Q1 2017

Cumulative Interactions

Emails8 10 119

Group Presentations 0 19

In-Person Visits 1 16

Positioning Event9 0 0

Telephone Calls 8 162

Total 28 316

In addition to supporting MUD customers, SCE continued to

support active applicants through the application process. Table

2.3 summarizes all account manager interactions for all segments

during Q1 2017.

Table 2.3 – Summary of Account Manager Interactions with

Customers

ActivityNo. Interactions Q1 2017

Cumulative Interactions

Emails10 803 2,437

Group Presentations 0 39

In-Person Visits 75 619

Letter 0 6

Positioning Event11 0 16

Telephone Calls 77 887

Total 955 3,097

Charge Ready Education & Outreach | 9

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Enrollment

SCE captures how applicants heard about the Pilot through the

enrollment form. A majority of customers became aware of the

Pilot through SCE’s account managers, the Charge Ready landing

page, or other sources. The source of the customer’s knowledge

is detailed in Table 2.4. As no new applications were accepted in

Q1 2017, there is no change in the distribution from last quarter.

Table 2.4 – Customer’s Source of Knowledge of Pilot

2.2 Market Education & TE Advisory

Services

Separately from its education and outreach efforts to support

enrollment in Charge Ready, SCE also communicates about EVs

and the benefits of fueling from the grid to a broad audience

through a variety of complementary channels. These channels

include:

• Paid Media: Digital banners, search engine marketing

(SEM), sponsored social media ads, radio.

• Local Sponsorship: Booth sponsorship at EV-related

events.

• Direct Messaging: Direct mail or email to targeted

customer populations.

• Other channels: bill inserts, messaging on SCE.com, and

organic social media..

To track engagement, customers exposed to the above channels

are driven to relevant content on the updated sce.com EV website.

During Q1 2017, SCE continued digital banner ads, radio ads, and

paid social media to support market education efforts. These

marketing activities, the EV Overview Page on SCE.com, and the

EV Campaign Landing Page on SCE.com included translations in

English, Spanish, Korean, Chinese, and Vietnamese languages.

The following table includes metrics capturing traffic for key

campaign pages within the site. SCE is continuing to observe

increases in web traffic as the “EV IQ” campaign continued

through Q1 2017.

Table 2.5 – Charge Ready EV Awareness Website Metrics

EV Awareness Q4 2016 Q1 2017

Electric Vehicle Overview Page on SCE.com

Unique Visitor Count 6,162 7,010

Repeat Visitor Count 2,124 2,325

Page Views 8,988 10,414

Bounce Rate 33.99% 38.30%

Multi-page Visits 5,137 5,679

Electric Vehicle Campaign Landing Page on SCE.com

Unique Visitor Count 6,524 7,417

Repeat Visitor Count 281 598

Page Views 7,934 8,983

Bounce Rate 92.38% 90.83%

Multi-page Visits 629 878

9%Email

9%Email

9%9%Email

41%SCE Account Manager41%SCE Account Manager

23%Other23%Other23%23%Other

20%SCE.com (Charge Ready landing page)

20%SCE.com (Charge Ready landing page)

20%20%SCE.com(Charge Ready landing page)

7%EVSE Vendor

7%EVSE Vendor

7%7%EVSE Vendor

Q4 2016 - Q1 2017Applications

Market Education & TE Advisory Services | 10

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For SCE’s Market Education efforts, customer awareness of

electric vehicle benefits and messaging will be tracked using

SCE’s Customer Attitude Tracking (CAT) survey. The CAT survey

is a quarterly tool designed to assess and track attitudes, brand

favorability, and awareness of relevant marketing messages

among SCE customers. This telephone survey is conducted with

450 randomly-selected SCE households and 250 small businesses

by an independent marketing research firm. Customers are

asked to recall and rate messaging around the benefits of electric

vehicles and preparing to buy or lease an electric vehicle, as well

as SCE’s role in supporting and advancing electric transportation.

Since the campaign fully launched in late August 2016, the data

collected from the 2016 Q1, Q2, and Q3 CAT surveys was used

to establish a baseline around message recall. In Q1 2017, SCE

continued with similar frequency of digital, video, and radio ads

as in late 2016. The Q1 2017 survey results continued to show

levels of EV awareness consistent with the baseline.

Table 2.6 summarizes the CAT survey baseline data. Respondents

were asked, “In the past three months, do you recall seeing,

hearing, or reading about any ads about SCE and the benefits of

electric vehicles?”

Table 2.6 – CAT Survey Results

ResponseBaseline (Q1-Q3 2016)

Q4 2016 Q1 2017

Total

Respondents

1,354 450 450

Yes 189

14%

58

13%

57

13%

No 1,147

85%

383

85%

384

85%

No Response 18

1%

9

2%

8

2%

Transportation Electrification (TE) Advisory Services – In

Development

SCE proposed TE Advisory Services to provide business

customers with a dedicated “one-stop shop” for specialized

education, awareness, and support on such TE issues as federal,

state, and local incentives, vehicle/charging equipment financing

opportunities, vehicle types, and charging installation programs.

Progress to date includes identification of self-service and limited

full-service offerings to be implemented, web design/architecture,

and service offering content development. TE Advisory service

offerings is planned to include education & outreach on TE

technologies and benefits, assessment of fleet conversion return-

on-investment, charging infrastructure planning, rate analysis, and

financial incentive opportunities.

Account Manager training on TE Advisory Services will be

completed in Q2 2017, with full services launching in Q3 2017.

2.3 Outreach Events

SCE conducted two outreach events in Q1 2017 to increase

customers’ EV awareness and gauge interest in future enrollment

in the Charge Ready Program. In these presentations, SCE

provided customers with an overview of the program and an

update on application progress, and tracked potential customer

interest for future phases of the program. SCE employees who

attend the events provide an estimate of the number of customer

communications completed during the event. These outreach

events are shown in Table 2.7.

Table 2.7 – Charge Ready Education & Outreach and Market

Education & TE Advisory Services Outreach Events

Mar. 1, 2017 | Downey | Charge Ready Education & Outreach

Local Government Kickoff Workshop: 200 estimated customer

interactions.

Feb. 24, 2017 | Bakersfield | Charge Ready Education & Outreach

San Joaquin Valley EV Partnership - Workplace Charging Workshop: 50

estimated customer interactions.

Outreach Events | 11

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Summary

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Outreach and

Enrollment

Electric Vehicle

Supply Equipment

Qualification

Electric Vehicle


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Electric Vehicle

Supply Equipment

Qualification

3 Electric Vehicle Supply Equipment Qualification

3.1 Requirements

The Pilot qualifies three different types of charging system

profiles:

• Level 1 charging system, without network capability,

• Level 2 “A” charging system, with network capability

integrated into the EVSE, and

• Level 2 “B” charging system, with network capability

provided by an external device (such as a kiosk or

gateway) shared among multiple stations.

Through a Request for Information (RFI) process, SCE conducts

technical tests on proposed charging systems. In accordance

with the terms and conditions of the RFI, qualified vendors

(manufacturers, distributors) for the Pilot are required to offer

Customer Participants:

• Qualified charging systems that meet SCE’s technical

requirements

• Networking services, including transactional data

reporting and demand response (DR) services

Following four rounds of the RFI process held through 2017, SCE

is currently evaluating 131 submitted charging systems.

The Pilot’s Approved Package List12 summarizes the vendors

and EVSE models available to Customer Participants as of Q1

2017. The Pilot offerings stayed the same since Q4 2016; the

Pilot currently offers 32 models from 8 vendors. Tables 3.1 and

3.2 provide a summary of the different charging system types and

features of EVSE models that have been approved to date.

Graph 3.1 – Number of Approved Charging System Models

Table 3.2 – EVSE Model Summary

Average number of circuits per EVSE 1.4

Average number of ports per circuit 1.4

Number of wall EVSE units 1

Number of pedestal units 11

Number of both wall and pedestal units 13

Number of both wall and pedestal units 8

The base cost of qualified EVSE for the Charge Ready Pilot is

defined as “the best value offered for a charging station and

its installation within each defined profile [of EVSE]13.” SCE

determines a price per port for each of the qualified models and

configurations. SCE then selects the lowest price per port within

each charging system type (using only those EVSE models that

passed SCE’s technical evaluation) to determine the base costs.

The base cost values as of Q1 2017 are shown in Table 3.3. The

base cost values have not changed from the prior reporting period.

Table 3.3 – Base Cost of Charging Systems

Charging System Type Base Cost

Level 1 $1,396

Level 2 “A” $2,188

Level 2 “B” $1,611

44

Level 1Level 1

22

Level 2 “A”Level 2 “A”

26

Level 2 “B”

32Total

12 The Pilot’s Approved Package List can be found on the landing page at https://on.sce.com/chargeready.13 Charge Ready Program Testimony, Vol. 2, p. 9.

Requirements | 12

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Electric Vehicle

Charging Load

4 Electric Vehicle Charging Load

4.1 EV Charging Load

After completing deployment at participating sites, SCE will collect transactional and utility-meter data to inform EV load-related metrics,

greenhouse gas (GHG) metrics, and air quality metrics. Prices paid by EV drivers and pricing strategies implemented by Customer

Participants will also be collected and reported in this quarterly report, if available. The Pilot will eventually incorporate a Demand

Response program to address general load-shaping capabilities. The Pilot report will analyze different Customer Participants’ load shape

profiles, at the grid and local capacity areas, and load management strategies.

In addition to requiring that all Customer Participants take service under a time-of-use rate plan, the Pilot will also incorporate a Demand

Response (DR) program for Customer Participants with Level 2 charging stations. SCE filed a DR Pilot proposal for Commission approval

as part of SCE’s 2018-2022 DR program application. The DR Pilot will inform the Charge Ready Demand Response program, which will

be identified in 2019. Additional load-management strategies, including prices paid by EV drivers and pricing strategies implemented by

the Customer Participants, will also be collected and reported where available.

One project site was completed in Q1 2017. However, since the EV load data reflected only a limited number of days, SCE is not reporting

EV Charging Load in this quarterly report.

EV Charging Load | 13

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Charging LoadOperations ConclusionOperations

5 Operations

5.1 Charge Ready Pilot Operations

Process Overview

The Pilot’s end-to-end process can be described in six stages:

Engagement, Evaluation, Confirmation, Planning and Design,

Construction, and Verification.

• Engagement begins with a customer submitting an

application indicating their interest in participating in the

Pilot. The application the customer submits is called the

Step 1 – Notice of Intent.

• Evaluation follows the application submission. SCE

conducts on-site assessments to evaluate the feasibility

of deploying charging stations through the Pilot.

• Confirmation of the customer’s participation includes

approval by the customer of the number of charging

stations and deployment location at each site (as

proposed by SCE). SCE reserves funding (if available)

upon receipt of Step 2 – Agreement signed by the

customer and property owner.

• SCE then conducts Planning and Design for the

approved site while the Customer Participant procures

qualified charging stations. At the end of the procurement

period, Customer Participants must provide the required

proof of purchase using Step 3 – Certification.

• SCE then conducts Construction for the approved site.

A pre-construction meeting is held with the Customer

Participant before construction begins. Once the

infrastructure is completed and passes inspection, the

Customer Participant’s selected charging station vendor

installs the charging stations.

• Finally, Verification takes place to ensure that electric

infrastructure and charging systems were deployed in

accordance with approved plans (using Step 4 – Walk-

Through Report and Step 5 – Rebate Confirmation);

SCE then issues the rebate.

Status Overview

During Q1 2017, SCE continued to reserved funds for projects

signing Step 2 – Agreement. An additional 12 applications executed

program agreements in Q1 2017, totaling 232 charge ports. The

cumulative committed charge ports by the end of Q1 2017 were 919

charge ports. Once infrastructure and rebate funds are fully reserved,

SCE will begin placing applicants submitting executed agreements

on a waitlist.

Another focus of Q1 2017 was supporting customers in their

procurement of charging stations. To ensure charging stations are

available at the time of infrastructure completion, the Pilot requires

customers to procure charging stations before construction can

begin. The procurement period begins once a customer executes

the program agreement and funds are reserved for the customer’s

application. The initial procurement period is 30 calendar days

from funds reservation, and customers are allowed an additional

15 days if they submit an extension request to SCE. SCE also

allows, at its discretion, extensions beyond 45 days, provided the

customer is actively procuring its charging stations. Early in the

application process, SCE Account Representatives encourage

customers to begin their procurement process due to the

Pilot’s procurement period deadlines. SCE is learning that most

customers require longer than 30 calendar days. Customers that

submitted proof of purchase by the end of Q1 2017 are averaging

42 calendar days (or 30 business days). Majority of customers

submit the maximum allowed two extension requests. At the end

of the quarter, several applications have not yet submitted proof

of purchase for their sites; these applications are averaging 98

calendar days (or 70 business days). Many of these applicants are

government and institution customers. These customers typically

require a competitive bid, which requires longer lead times for the

request for proposal (RFP) process. Further, these customers

have structured approval processes and typically must wait for

their next board meeting to approve procurement of charging

stations. As a result of longer procurement timelines, SCE is

currently experiencing delays in starting construction for these

customers’ sites.

Charge Ready Pilot Operations | 14

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Electric Vehicle


As customers procured their charging stations, SCE’s parallel

efforts included preparing and requesting customer approval of

preliminary designs, preparing and requesting customer execution

of easements, and coordination of permit issuance with the

Authority Having Jurisdiction (AHJ).

• SCE’s current challenge with site designs is obtaining

customer approvals before moving forward with AHJ plan

check review. Applicants who provided approvals in Q1

2017 had an average approval cycle time of 8.8 business

days. However, average cycle time for site designs

pending customer approval at the end of Q1 2017 is 37.5

business days. In many cases, the Customer Participant

is not the authorized personnel to approve designs.

Identifying the appropriate customer contact is the main

challenge in acquiring site design approvals. SCE is

continuing to hold regular check-in meetings with these

customers to drive next steps.

• Based on initial projects with executed final easements,

easement cycle times are not presenting a significant

delay in the infrastructure deployment timeline. By the

end of Q1 2017, SCE executed easements for 7 sites.

The average cycle time is 23.7 business days. SCE will

continue to learn from additional executed easements.

• Based on initial projects with issued permits, permit

cycle times are not presenting a significant delay in

the infrastructure deployment timeline. Average cycle

time for permit issuance for the first 16 projects is 15.6

business days. Since a majority of the first projects are

local governments, SCE will continue to learn about

actual AHJ cycle times from other, future project permits.

Another challenge was customers withdrawing from the Pilot after

signing the Step 2 Program Agreement. Two applicants notified

SCE of their withdrawal from the program due to loss of funding

or management support or challenges with easements. The Pilot

incurred design costs for these withdrawn projects which reduced

the funding available to other customers requesting to participate

in the program. SCE will evaluate current Pilot processes and

future program design improvements that minimize the design

costs until customers confirm procurement of charging stations.

Infrastructure construction was completed for one site in Q1

2017, and several others were scheduled for construction. SCE

experienced construction delays in the manufacturing and delivery

of meter panels. For the Pilot, panels are custom ordered for each

site, and the manufacturer must build and fully test the panels for

warranty purposes. The delay in meter panels delayed the first

sites in construction, but SCE now orders meter panels early in

the design process to avoid construction delays at other sites.

SCE has also expanded the number of meter panel manufacturers

to ensure all sites can be supported. For a future phase of the

program, SCE may evaluate the possibility of bulk ordering

standardized meter panels to eliminate construction delays.


Executive

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Outreach and

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Electric Vehicle

Supply Equipment

Qualification

Electric Vehicle


Executive

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Customer

Outreach and

Enrollment

Electric Vehicle

Supply Equipment

Qualification

Electric Vehicle


Table 5.1 summarizes the Pilot’s operational metrics about customer applications in Charge Ready. The metrics in the table capture

the project activity from the launch of the Pilot on May 27, 2016, to March 31, 2017. Where applicable, the distribution across market

segments, as well as the total number in disadvantaged communities, is provided.

Table 5.1 – Pilot Operational Metrics for Quarter

Percentage of total applications received

Planning Assumptions Quarter 1, 2017 Year-to-Date Actual Toward Goal

58 sites,1,500 charge ports

0 sites,0 charge ports


576%,136%

Number of approved and confirmed sites (Step 2 Agreement signed)


58 sites, 1,500 charge ports

15 sites, 232 charge ports


100%,61%

Disadvantaged Communities N/A 18 sites,264 chargers

35 sites,458 chargers

N/A

Destination Centers N/A 6 sites,67 chargers


N/A

Workplaces N/A 5 site,101 chargers


N/A

Fleet N/A 3 site,52 chargers

6 sites,77 chargers

N/A

Multi-Unit Dwellings N/A 1 sites,12 chargers

3 sites,35 chargers

N/A

Percentage of applicants rejected


N/A 32 sites119 requested

chargers

108 sites483 requested chargers

N/A

Percentage of applicants withdrawn


N/A 31 sites,247 chargers


N/A


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Number of applicants withdrawn after signing Step 2 - Agreement


N/A 2 2 N/A

Total number of charge ports installed


N/A 6 6 N/A

Average number of charge ports installed per site


N/A 6 6 N/A

Percentage of completed projects



1 site6 charge ports


N/A

Disadvantaged Communities N/A 100% 100% N/A

Destination Centers N/A 0% 0% N/A

Workplaces N/A 0% 0% N/A

Fleet N/A 100% 100% N/A

Multi-Unit Dwellings N/A 0% 0% N/A


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Table 5.2 – Customer Participant Request

Customer Participant Request Planning Assumptions Year-to-Date Actual

Average number of total parking spaces per site N/A 621 parking spaces/site

Percentage of total number of parking spaces located in parking structures

N/A 12%

Average fleet size14 N/A 6 (Fleet Segment Only)4 (All Segments)

Percentage of applications received with charging systems already installed at the site

N/A 15%

Average number of charging systems already installed at the site

N/A 10

Average number of charge ports requested per site 26 7.6

14 Applicants from all segment categories may indicate the number of fleet vehicles at their site (All Segments). Applicants in the fleet category intend to use the new charging station for their EV fleet (Fleet Segment Only).


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Table 5.3 – Pilot Costs

Planning Assumptions Year-to-Date Actual Toward Goal

Total estimated Pilot costs (SCE infrastructure plus rebate paid)15

$16,792,136 $12,674,566919 charge ports

72%

Average estimated cost per site (T&D + Customer infrastructure + rebate)16

$291,070($11,195 * 26 chargers)

Average Cost per Site: $218,527Average No. Charge Ports per

Site:16

N/A

Average estimated cost per port (T&D + Customer infrastructure + rebate)17

$11,195 $13,792 N/A

Total amount of rebate reserved

$5,850,000 $1,127,358 19%

Average amount of rebate reserved per site

$101,400($3,900 * 26 chargers)

$19,437 N/A

Total amount of rebate paid $5,850,000 $11,748 N/A

Average amount of rebate paid per site

$101,400($3,900 * 26 chargers)

$11,748 N/A

Total actual construction costs for SCE infrastructure

$10,942,136 $101,653 9%

Average actual construction cost for SCE infrastructure per site

$7,295 $5,050 N/A

Level 1 charging systems N/A $0 N/A

Level 2 charging systems N/A $5,050 N/A

Hybrid charging systems (both Level 1 and Level 2)

N/A $0 N/A

Total actual SCE site

assessment cost incurred by withdrawn applicants (prior to signing Step2)

N/A $298,770 N/A

Average actual SCE site


N/A $3,689 N/A


assessment, design, permit,

and easement cost incurred by withdrawn applicants (after signing Step2)

N/A $20,720 N/A

15 Estimated program costs are based on initial site assessment. Costs are subject to customer’s Step 2 Agreement.16 Estimated program costs are based on initial site assessment. Costs are subject to customer’s Step 2 Agreement.17 Estimated program costs are based on initial site assessment. Costs are subject to customer’s Step 2 Agreement.


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Planning Assumptions Year-to-Date Actual Toward Goal




N/A $6,907 N/A

Total actual SCE construction cost incurred by withdrawn applicants

N/A $0 N/A

Average actual SCE construction cost incurred by withdrawn applicants

N/A $0 N/A

Table 5.4 – Pilot Cycle Times

Pilot Cycle Times

Average Customer "End to End" Cycle time by segment Available once rebates issued

Minimum Customer “End to End” Cycle time by segment Available once rebates issued

Maximum Customer “End to End” Cycle time by segment Available once rebates issued

% of customer under/above average cycle time by segment

Available once rebates issued

% of customer under/above target cycle time by segment Available once rebates issued

Average time for EVSE to be Purchased by Customer by segment18

29.7 business days

Average time for the Customer to execute Step 2 Agreement

28.7 business days

Average time for the Customer to confirm Site Visit date 2.7 business days

Average time to complete Site Visit 11.5 business days

Average time to complete Site Assessment 23.9 business days

Average time from EVSEs purchased by Customer to chargers installed19

56.0 business days

Average time for T&D to complete base map 7.3 business days

Average time to complete T&D preliminary design 16.6 business days

Average time from preliminary design sent to customer to preliminary design approved

8.8 business days

18 Time from applicant completing Step 2 Agreement form to completing Step 3 Certification form.19 Time from Step 3 Certification form completion to chargers installed by vendors.


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Pilot Cycle Times

Average time for Customer to execute contingent easement

30.4 business days

Average time for Customer to execute final easement 14.3 business days

Average time to complete T&D final design 9.3 business days

Average time to complete utility-infrastructure permits 5.7 business days

Average time to complete customer-infrastructure permits 15.6 business days

Average time from ready to break ground to final inspection completed

28.0 business days

Average time from final inspection completed to Rebate Check Issued


Table 5.5 – Charging Station Request & Rebate

Charging Station Request & Rebate

Number of Level 1 charge ports requested20 25


Number of total charge ports approved 919

Average Number of Level 1 charge ports approved per site 8


Number of Level 1 EVSE bought 12

Average number of ports per Level 1 EVSE 1.0

Number of Level 2A EVSE bought 135

Average number of ports per Level 2A EVSE 1.7

Number of Level 2B EVSE bought 265

Average number of ports per Level 2B EVSE 1.4

Number of Level 1 EVSE installed 0

Number of Level 2A EVSE installed 0

Number of Level 2B EVSE installed 3

Rebate amount reserved for Level 1 ports $19,356

Rebate amount reserved for Level 2A ports $240,941

20 In the Step 2 Agreement, the applicant indicates the requested number of Level 1 EVSE to be approved and installed under the Program. The number of installed Level 1 EVSE must match the number of Level 1 EVSE requested in Step 2 Agreement.21 IIn the Step 2 Agreement, the applicant indicates the requested number of Level 2 EVSE to be approved and installed under the Program. The number of installed Level 2 EVSE must match the number of Level 2 EVSE requested in Step 2 Agreement.


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Rebate amount reserved for Level 2B ports $449,626

Rebate amount paid for Level 1 ports $0

Rebate amount paid for Level 2A ports $0

Rebate amount paid for Level 2B ports $0

5.2 Supplier Diversity

The architecture and engineering firm and general contractors

selected for Charge Ready are 100% diverse business enterprises

(DBEs).

5.3 Collaboration Efforts with

Complementary EV Programs

SCE is engaging with federal, state, and local government agencies

to identify collaboration opportunities in connection with Charge

Ready. In Q1 2017, SCE supported a ride and drive with Plug-in

America in Long Beach at the Alpert Jewish Community Center’s

annual Purim Festival on March 12, 2017. The purpose was to

provide hands-on experiential education and raise awareness

about plug-in electric vehicles and charging in low-to-moderate

income or disadvantaged communities.

SCE also began planning efforts for a ribbon-cutting ceremony for

the first site complete in the Pilot; the customer event is planned

to include other complimentary programs. SCE will report out on

this event in the Q2 2017 report.

5.4 Disadvantaged Communities Outreach

Events

SCE’s outreach events for Disadvantaged Communities in

Q1 2017 are summarized in the table below. SCE employees

who attend the events provide an estimate of the number of

communications with a customer in a disadvantaged community

during the event.

Table 5.3 – Disadvantaged Community Outreach Events

Feb. 24, 2017 | Bakersfield

San Joaquin Valley EV Partnership - Workplace Charging Workshop:

50 estimated customer interactions.

Mar. 9, 2017 | Costa Mesa Orange County

Apartment Association of Orange County Trade Show:

1,200 estimated customer interactions.

Mar. 17, 2017 | Anaheim

California Association of Community Managers Trade Show (for Property

Managers):

625 estimated customer interactions.

Supplier Diversity | 22

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Charging LoadOperations ConclusionConclusion

6 Conclusion

6.1 Conclusion

In this quarterly report, SCE provided data and updates on progress in implementing and executing the Charge Ready and Market

Education Pilot, including the challenges we encountered and the solutions we are developing to mitigate them.

During Q1 2017, SCE completed the first operational site in the Charge Ready program. Several other applicants also reached the

planning, design, and construction stages of the Pilot. SCE learned about the charging station procurement process, customer design

approval timelines, actual dropout rates, lead times for construction materials, Authority Having Jurisdiction (AHJ) permit timelines and

processes, and easement execution. In the next quarter, SCE will be able to learn from more constructed sites and identify additional

program improvements. SCE will also be able to learn from the energy usage of the first charging stations deployed under the Pilot.

Conclusion | 23

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Appendix

Appendix

Pilot Operational Metrics for Quarter

Percentage of total applications received





576%,136%




Fleet N/A 0% 5% N/A


Percentage of charging stations requested





576%,136%

Disadvantaged Communities 10% 0% 37% 368%



Fleet N/A 0% 8% N/A


Appendix | 24

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Number of approved and confirmed sites (Step 2 Agreement signed)



15 sites, 232 charge ports


100%,61%

Disadvantaged Communities N/A 18 sites,264 chargers


N/A

Destination Centers N/A 6 sites,67 chargers


N/A

Workplaces N/A 5 site,101 chargers


N/A

Fleet N/A 3 site,52 chargers

6 sites,77 chargers

N/A

Multi-Unit Dwellings N/A 1 sites,12 chargers

3 sites,35 chargers

N/A

Percentage of applicants rejected


N/A 32 sites119 requested

chargers

108 sites483 requested chargers

N/A




Fleet N/A 0% 1% N/A


Percentage of applicants withdrawn


N/A 31 sites,247 chargers


N/A




Fleet N/A 2% 5% N/A


Appendix | 25

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Number of applicants withdrawn after signing Step 2 - Agreement


N/A 2 2 N/A

Disadvantaged Communities N/A 1 1 N/A

Destination Centers N/A 0 0 N/A

Workplaces N/A 2 2 N/A

Fleet N/A 0 0 N/A

Multi-Unit Dwellings N/A 0 0 N/A

Total number of charge ports installed


N/A 6 6 N/A




Fleet N/A 6 6 N/A


Average number of charge ports installed per site


N/A 6 6 N/A




Fleet N/A 0 0 N/A


Appendix | 26

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Percentage of completed projects





N/A




Fleet N/A 100% 100% N/A


Average number of total parking spaces per site


N/A 621 parking spaces/site

Disadvantaged Communities N/A 375 parking spaces/site

Destination Centers N/A 931 parking spaces/site

Workplaces N/A 523 parking spaces/site

Fleet N/A 404 parking spaces/site

Multi-Unit Dwellings N/A 636 parking spaces/site

Percentage of total number of parking spaces located in parking structures


N/A 12%

Disadvantaged Communities N/A 1,040

Destination Centers N/A 12,100

Workplaces N/A 43,982

Fleet N/A 3,764

Multi-Unit Dwellings N/A 3,134

Appendix | 27

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Average fleet size22 N/A 6 (Fleet Segment Only)4 (All Segments)

Percentage of applications received with charging systems already installed at the site

N/A 15%

Average number of charging systems already installed at the site

N/A 10

Average number of charge ports requested per site


26 7.6

Disadvantaged Communities N/A 8.3

Destination Centers N/A 9.2

Workplaces N/A 9.8

Fleet N/A 13.1

Multi-Unit Dwellings N/A 8.0

FN22

22 Applicants from all segment categories may indicate the number of fleet vehicles at their site (All Segments). Applicants in the fleet category intend to use the new charging station for their EV fleet (Fleet Segment Only).

Appendix | 28

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Pilot Costs

Pilot Costs

Planning Assumptions Year-to-Date Towards Goal

Total estimated Pilot costs (SCE infrastructure plus rebate paid)23

$16,792,136 $12,674,566919 charge ports

72%

Average estimated cost per site (T&D + Customer infrastructure + rebate)24

$291,070($11,195 * 26 chargers)

Average Cost per Site: $218,527

Average No. Charge Ports per Site:16

N/A

Average estimated cost per port (T&D + Customer infrastructure + rebate)25

$11,195 $13,792 N/A

Total estimated Pilot costs

Pilot Cost

Disadvantaged Communities N/A $5,175,891 N/A

Destination Centers N/A $4,150,474 N/A

Workplaces N/A $6,970,317 N/A

Fleet N/A $1,038,259 N/A

Multi-Unit Dwellings N/A $515,516 N/A

Total amount of rebate reserved

Pilot Cost

$5,850,000 $1,127,358 19%


$101,400($3,900 * 26 chargers)

$19,437 N/A

Disadvantaged Communities N/A $887,086 N/A

Destination Centers N/A $284,966 N/A

Workplaces N/A $735,536 N/A

Fleet N/A $72,591 N/A

Multi-Unit Dwellings N/A $34,265 N/A

23 Estimated program costs are based on initial site assessment. Costs are subject to customer’s Step 2 Agreement.24 Estimated program costs are based on initial site assessment. Costs are subject to customer’s Step 2 Agreement.25 Estimated program costs are based on initial site assessment. Costs are subject to customer’s Step 2 Agreement.

Appendix | 29

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Total amount of rebate paid

Pilot Cost

$5,850,000 $11,748 N/A


Destination Centers N/A $0 N/A

Workplaces N/A $0 N/A


Multi-Unit Dwellings N/A $0 N/A


Pilot Cost

$101,400($3,900 * 26 chargers)

$11,748 N/A






Total actual construction costs for SCE infrastructure

Pilot Cost

$10,942,136 $93,575 1%






Appendix | 30

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Average actual construction cost for SCE infrastructure per site

Pilot Cost

$7,295 $5,050 N/A

Average actual construction cost for SCE infrastructure for sites with all Level 1 charging systems

N/A $0 N/A

Average actual construction cost for SCE infrastructure for sites with all Level 2 charging systems

N/A $5,050 N/A

Average actual construction cost for SCE infrastructure for sites with hybrid charging systems (both Level 1 and Level 2)

N/A $0 N/A



N/A $298,770 N/A



N/A $3,689 N/A




N/A $20,720 N/A




N/A $6,907 N/A

Total actual SCE construction cost incurred by withdrawn applicants

N/A $0 N/A

Average actual SCE construction cost incurred by withdrawn applicants

N/A $0 N/A

Appendix | 31

Executive

Summary

Customer

Outreach and

Enrollment

Electric Vehicle

Supply Equipment

Qualification

Electric Vehicle


Pilot Cycle Times

Pilot Cycle Times

Average Customer "End to End" Cycle time by segment Available once rebates issued

Minimum Customer “End to End” Cycle time by segment Available once rebates issued

Maximum Customer “End to End” Cycle time by segment Available once rebates issued

% of customer under/above average cycle time by segment Available once rebates issued

% of customer under/above target cycle time by segment Available once rebates issued

Average time for EVSE to be Purchased by Customer by segment26

29.7 business days

Average time for the Customer to execute Step 2 Agreement 28.7 business days

Average time for the Customer to confirm Site Visit date 2.7 business days

Average time to complete Site Visit 11.5 business days

Average time to complete Site Assessment 23.9 business days

Average time from EVSEs purchased by Customer to chargers installed27

56.0 business days

Average time for T&D to complete base map 7.3 business days

Average time to complete T&D preliminary design 16.6 business days

Average time from preliminary design sent to customer to preliminary design approved

8.8 business days

Average time for Customer to execute contingent easement 30.4 business days

Average time for Customer to execute final easement 14.3 business days

Average time to complete T&D final design 9.3 business days

Average time to complete utility-infrastructure permits 5.7 business days

Average time to complete customer-infrastructure permits 15.6 business days

Average time from ready to break ground to final inspection completed

28.0 business days

Average time for from final inspection completed to Rebate Check Issued


26 Time from applicant completing Step 2 Agreement form to completing Step 3 Certification form.27 Time from Step 3 Certification form completion to chargers installed by vendors.

Appendix | 32

Executive

Summary

Customer

Outreach and

Enrollment

Electric Vehicle

Supply Equipment

Qualification

Electric Vehicle






Number of total charge ports approved 919



Number of Level 1 EVSE bought 12

Average number of ports per Level 1 EVSE 1.0

Number of Level 2A EVSE bought 135

Average number of ports per Level 2A EVSE 1.7

Number of Level 2B EVSE bought 265

Average number of ports per Level 2B EVSE 1.4

Number of Level 1 EVSE installed 0

Number of Level 2A EVSE installed 0

Number of Level 2B EVSE installed 3

Rebate amount reserved for Level 1 ports $19,356

Rebate amount reserved for Level 2A ports $240,941

Rebate amount reserved for Level 2B ports $449,626

Rebate amount paid for Level 1 ports $0

Rebate amount paid for Level 2A ports $0

Rebate amount paid for Level 2B ports $0

28 In the Step 2 Agreement, the applicant indicates the requested number of Level 1 EVSE to be approved and installed under the Program. The number of installed Level 1 EVSE must match the number of Level 1 EVSE requested in Step 2 Agreement.29 In the Step 2 Agreement, the applicant indicates the requested number of Level 2 EVSE to be approved and installed under the Program. The number of installed Level 2 EVSE must match the number of Level 2 EVSE requested in Step 2 Agreement.

Appendix | 33


STATE OF CALIFORNIA


) ) ) )

A.14-10-014 (Filed October 30, 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 SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) CHARGE READY PILOT PROGRAM QUARTERLY REPORT on all parties identified on the attached service list(s) for A.14-10-014. 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 by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s).

ALJ Darwin Farrar CPUC 505 Van Ness Avenue San Francisco, CA 94102

Executed this day May 31, 2017, at Rosemead, California.

/s/ Sandra Sedano Sandra Sedano Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

PROCEEDING: A1410014 - EDISON - FOR APPROVA FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: MAY 17, 2017

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C.C. SONG CHRISTOPHER WARNER REGULATORY ANALYST PACIFIC GAS AND ELECTRIC COMPANY MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: MARIN CLEAN ENERGY

JAY FRIEDLAND JOHN BOESEL ZERO MOTORCYCLES CALSTART EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: PLUG IN AMERICA FOR: CALSTART

KEVIN LEE FORREST NORTH ATTORNEY CHIEF OPERATING OFFICER NRG ENERGY, INC. RECARGO, INC. 11390 W. OLYMPIC BLVD., STE. 250 1015 ABBOT KINNEY BLVD. LOS ANGELES, CA 90064 VENICE, CA 90291 FOR: NRG ENERGY, INC. FOR: RECARGO, INC.

JESSALYN ISHIGO ALEXANDER KEROS ENVIRONMENTAL BUSINESS DEVELOPMENT OFF. ADVANCED VEHICLE & INFRASTRUCTURE POLICYAMERICAN HONDA MOTOR CO., INC. GENERAL MOTORS, LLC 1919 TORRANCE BLVD. 3050 LOMITA BLVD. TORRANCE, CA 90501 TORRANCE, CA 90505 FOR: AMERICAN HONDA MOTOR CO., INC. FOR: GENERAL MOTORS LLC

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MAX BAUMHEFNER ANDREA L. TOZER LEGAL FELLOW ATTORNEY NATURAL RESOURCES DEFENSE COUNCIL SOUTHERN CALIFORNIA EDISON COMPANY 111 SUTTER ST., 21ST FLOOR 2244 WALNUT GROVE AVE. / PO BOX 800 SAN FRANCISCO, CA 91404 ROSEMEAD, CA 91770 FOR: THE CHARGE AHEAD CALIFORNIA FOR: SOUTHERN CALIFORNIA EDISON COMPANY CAMPAIGN (MEMBERS: NRDC, COMMUNITIES FOR A BETTER ENVIRONMENT , ENVIRONMENT CALIFORNIA RESEARCH & POLICY CENTER, COALITION FO CLEAN AIR, AND THE GREENLINING INSTITUTE)

DONALD C. LIDDELL JOHN W. LESLIE, ESQ ATTORNEY ATTORNEY DOUGLASS & LIDDELL DENTONS US LLP 2928 SECOND AVE. 4655 EXECUTIVE DRIVE, SUITE 700 SAN DIEGO, CA 92103 SAN DIEGO, CA 92121 FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: SHELL ENERGY NORTH AMERICA (US), (CESA) L.P.

E. GREGORY BARNES SACHU CONSTANTINE ATTORNEY DIR. OF POLICY SAN DIEGO GAS & ELECTRIC COMPANY CENTER FOR SUSTAINABLE ENERGY 8330 CENTURY PARK COURT, BLDG 3. CP32D 9325 SKY PARK COURT, SUITE 100 SAN DIEGO, CA 92123 SAN DIEGO, CA 92123 FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: CENTER FOR SUSTAINABLE ENERGY

MICHAEL CHIACOS MARC D JOSEPH ENERGY PROGRAM DIR. ADAMS BROADWELL JOSEPH & CARDOZO, PC COMMUNITY ENVIRONMENTAL COUNCIL 601 GATEWAY BLVD., STE. 1000 26 W. ANAPAMU ST., 2ND FLR. SOUTH SAN FRANCISCO, CA 94080 SANTA BARBARA, CA 93101 FOR: COALITION OF CALIFORNIA UTILITY FOR: COMMUNITY ENVIRONMENTAL COUNCIL EMPLOYESS (CCUE)

IRYNA KWASNY ELISE TORRES CALIF PUBLIC UTILITIES COMMISSION STAFF ATTORNEY LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM 4107 785 MARKET STREET, SUITE 1400 505 VAN NESS AVENUE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-3214 FOR: THE UTILITY REFORM NETWORK (TURN) FOR: ORA

LARISSA KOEHLER JIM BAAK SENIOR ATTORNEY PROGRAM DIR - GRID INTEGRATION ENVIRONMENTAL DEFENSE FUND VOTE SOLAR 123 MISSION STREET, 28TH FLOOR 360 22ND FLOOR, SUITE 730 SAN FRANCISCO, CA 94105 OAKLAND, CA 94612 FOR: ENVIRONMENTAL DEFENSE FUND FOR: VOTE SOLAR

GREGORY MORRIS COLLEEN C. QUINN DIRECTOR VP - GOV'T. RELATIONS AND PUBLIC POLICY GREEN POWER INSTITUTE CHARGEPOINT, INC. 2039 SHATTUCK AVE., SUITE 402 254 EAST HACIENDA AVENUE BERKELEY, CA 94704 CAMPBELL, CA 95008



FOR: GREEN POWER INSTITUTE FOR: CHARGEPOINT

ABEGAIL TINKER ANGIE BOAKES PACIFIC GAS AND ELECTRIC COMPANY ELECTRIC MOBILITY GENERAL MGR. EMAIL ONLY SHELL INT'L. PETROLEUM CO., LIMITED EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

ANNE SMART CASE COORDINATION CHARGEPOINT, INC. PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

CATHERINE BUCKLEY DAVE PACKARD PACIFIC GAS AND ELECTRIC COMPANY CHARGEPOINT, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

DESPINA NIEHAUS JAMES ELLIS CALIFORNIA REGULATORY AFAIRS DIR. - ELECTRIFICATION & EVS SAN DIEGO GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

JAMES HALL JORDAN RAMER MGR.- ADVANCED VEHICLE AND INFRA. POLICY EV CONNECT, INC. GENERAL MOTORS LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: EV CONNECT, INC.

LAUREN DUKE PAUL D. HERNANDEZ DEUTSCHE BANK SECURITIES INC. ENERGY & TRANSPORTATION POLICY MANAGER EMAIL ONLY CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY, NY 00000 EMAIL ONLY EMAIL ONLY, CA 00000

SARAH VAN CLEVE SEPHRA A. NINOW, J.D. SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY AFFAIRS MGR. EMAIL ONLY CENTER FOR SUSTAINABLE ENERGY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

SUBID WAGLEY MRW & ASSOCIATES, LLC PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

CROWELL & MORING TAM HUNT EMAIL ONLY COMMUNITY RENEWABLES SOLUTIONS, LLC

Information Only



EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000-0000

MICHAEL DANDURAND CONSTANTINE LEDNEV LNZ CAPTIAL, LP ASSOCIATE-US UTILITIES & POWER RESEARCH 411 LAFAYETTE STREET DEUTSCHE BANK SECURITIES INC. NEW YORK, NY 10003 60 WALL STREET NEW YORK CITY, NY 10005

ARMAN TABATABAI JIM KOBUS RESEARCH RESEARCH MORGAN STANLEY MORGAN STANLEY 1585 BROADWAY, 38TH FL. 1585 BROADWAY, 38TH FLOOR NEW YORK, NY 10036 NEW YORK, NY 10036

JOSEPH HALSO THOMAS ASHLEY LEGAL FELOOW DIR - GOVN'T AFFAIRS & PUBLIC POLICY SIERRA CLUB GREENLOTS 50 F STREET, NW, 8TH FLR. 925 N. LA BREA AVENUE, 6TH FLOOR WASHINGTON, DC 20001 LOS ANGELES, CA 90038

ALEC BROOKS CASE ADMINISTRATION AEROVIRONMENT, INC. SOUTHERN CALIFORNIA EDISON COMPANY 181 W. HUNTINGTON DRIVE, SUITE 202 2244 WALNUT GROVE AVENUE, ROOM 370 MONROVIA, CA 91016 ROSEMEAD, CA 91770 FOR: AEROVIRONMENT, INC.

HANNON RASOOL JENNIFER WRIGHT ADMIN. - CALIF. REGULATORY AFFAIRS REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT. CP32D 8330 CENTURY PARK COURT, CP32F SAN DIEGO, CA 92123 SAN DIEGO, CA 92123

PARINA P. PARIKH CENTRAL FILES REGULATORY CASE MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK COURT, CP 32F SAN DIEGO, CA 92123-1530 SAN DIEGO, CA 92123

MARC D. JOSEPH ERIC BORDEN ATTORNEY AT LAW ENERGY POLICY ANALYST ADAMS BROADWELL JOSEPH & CARDOZO THE UTILITY REFORM NETWORK 601 GATEWAY BLVD. STE 1000 785 MARKET STREET, STE. 1400 SOUTH SAN FRANCISCO, CA 94080 SAN FRANCISCO, CA 94103

MARCEL HAWIGER SHIRLEY WOO STAFF ATTORNEY PACIFIC GAS & ELECTRIC COMPANY THE UTILITY REFORM NETWORK 77 BEALE STREET, B30A 785 MARKET ST., STE. 1400 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94103

FRANCESCA WAHL NICOLE JOHNSON SR. ASSOCIATE, BUS. DEVELOPMENT REGULATORY ATTORNEY



TESLA CONSUMER FEDERATION OF CALIFORNIA 444 DE HARO STREET, STE. 101 150 POST ST., STE. 442 SAN FRANCISCO, CA 94107 SAN FRANCISCO, CA 94108

LISA QI DIANE FELLMAN CROWELL & MORIN, LLP VP - REGULATORY & GOVERNMENT AFFAIRS 3 EMBARCADERO CENTER, 26TH FL. NRG WEST REGION SAN FRANCISCO, CA 94111 100 CALIFORNIA ST., STE. 650 SAN FRANCISCO, CA 94111-4505

CALIFORNIA ENERGY MARKETS RYAN SCHUCHARD 425 DIVISADERO ST. STE 303 POLICY DIR. SAN FRANCISCO, CA 94117-2242 CALSTART 501 CANAL BLVD., NO. G RICHMOND, CA 94804

MCE REGULATORY SHALINI SWAROOP MARIN CLEAN ENERGY REGULATORY & LEGISLATIVE COUNSEL 1125 TAMALPAIS AVENUE MARIN CLEAN ENERGY SAN RAFAEL, CA 94901 1125 TAMALPAIS AVENUE SAN RAFAEL, CA 94901

PHILLIP MULLER DAVID PETERSON PRESIDENT CHARGEPOINT, INC. SCD ENERGY SOLUTIONS 254 EAST HACIENDA AVENUE 436 NOVA ALBION WAY CAMPBELL, CA 95008 SAN RAFAEL, CA 94903

NEWONDA NICHOLS CAMILLE STOUGH, ESQ. PROGRAM MGR., UTILITY SOLUTIONS BRAUN BLAISING MCLAUGHLIN & SMITH PC CHARGEPOINT 915 L STREET, STE. 1480 254 EAST HACIENDA AVE. SACRAMENTO, CA 95814 CAMPBELL, CA 95008

JIM HAWLEY JIM HAWLEY PRINCIPAL ELECTRIC VEHICLE CHARGING ASSN. DEWEY SQUARE GROUP, LLC 455 CAPITOL MALL, STE. 600 1020 16TH STREET, SUITE 20 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: ELECTRIC VEHICLE CHARGING ASSOCIATION

JOHN SHEARS SCOTT BLAISING CEERT COUNSEL 1100 11TH STREET, SUITE 311 BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. SACRAMENTO, CA 95814 915 L STREET, SUITE 1480 SACRAMENTO, CA 95814

LYNN HAUG ELLISON, SCHNEIDER & HARRIS L.L.P. 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA 95816-5931



CHLOE LUKINS JOSE ALIAGA-CARO ORA DIV. UTILITIES ENGINEER CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

KARIN HIETA SANDY GOLDBERG A.L.J. PRO TEM SR. COUNSEL CALIFORNIA PUBLIC UTILITIES COMMISSION GOVERNOR'S OFF. OF PLANING & RESEARCH EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

AMY E. MESROBIAN ANA M. GONZALEZ CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM 2106 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

ANAND DURVASULA DARWIN FARRAR CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 4107 ROOM 5009 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JENNIFER KALAFUT JOSEPH A. ABHULIMEN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER PETERMAN ENERGY SAFETY & INFRASTRUCTURE BRANCH ROOM 5303 ROOM 4209 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

MELICIA CHARLES SARAH R. THOMAS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC LEGAL DIVISION AREA ROOM 5033 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

THOMAS GARIFFO NOEL CRISOSTOMO CALIF PUBLIC UTILITIES COMMISSION AIR POLUTION SPECIALIST ELECTRICITY PLANNING & POLICY BRANCH CALIFORNIA ENERGY COMMISSION AREA 1516 9TH STREET 505 VAN NESS AVENUE SACRAMENTO, CA 95814 SAN FRANCISCO, CA 94102-3214

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STATE OF CALIFORNIA


_______________________________________

And Related Matters.


Application 17-01-021 Application 17-01-022

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 (U 338-E) REPLY BRIEF on all parties identified on the attached service list A.17-01-020, et al. 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 John S. Wong ALJ Sasha Goldberg California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102

Executed this July 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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PROCEEDING: A1701020 - SDG&E - FOR APPROVAL FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: JULY 7, 2017

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JAY FRIEDLAND NORMAN HAJJA ZERO MOTORCYCLES RECARGO, INC. EMAIL ONLY EMAIL EMAIL ONLY, CA 00000 EMAIL, CA 00000 FOR: ZERO MOTORCYCLES FOR: REGARCO, INC.

JOE HALSO JOHNNY Q. TRAN ASSOCIATE ATTORNEY SR. COUNSEL SIERRA CLUB SOUTHERN CALIFORNIA GAS COMPANY 1536 WYNKOOP ST., STE. 312 555 W. FIFTH STREET, GT-14E7 DENVER, CO 80202 LOS ANGELES, CA 90013 FOR: SIERRA CLUB FOR: SOUTHERN CALIFORNIA GAS COMPANY

MELISSA A. HOVSEPIAN ADRIANO MARTINEZ SR COUNSEL ATTORNEY AT LAW SOUTHERN CALIFORNIA GAS COMPANY EARTHJUSTICE 555 WEST FIFTH STREET, GT-14E7 800 WILSHIRE BLVD., SUITE 1000 LOS ANGELES, CA 90013 LOS ANGELES, CA 90017 FOR: SOUTHERN CALIFORNIA GAS COMPANY FOR: EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE AND CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE

THOMAS ASHLEY KATHERINE STAINKEN DIR - GOVN'T AFFAIRS & PUBLIC POLICY POLICY DIR. GREENLOTS PLUG IN AMERICA 925 N. LA BREA AVENUE, 6TH FLOOR 6380 WILSHIRE BLVD., STE. 1010 LOS ANGELES, CA 90038 LOS ANGELES, CA 90048



FOR: GREENLOTS FOR: PLUG IN AMERICA

DEMETRA J. MCBRIDE TERRY O'DAY ENVIRONMENTAL INITIATIVES DIVISION MGR VP COUNTY OF LOS ANGELES EVGO SERVICES LLC 1100 NORTH EASTERN AVENUE 11390 WEST OLYMPIC BLVD LOS ANGELES, CA 90063-3200 LOS ANGELES, CA 90064 FOR: COUNTY OF LOS ANGELES (LA COUNTY) FOR: EVGO SERVICES LLC

JESSALYN ISHIGO MAX BAUMHEFNER ENVIRONMENTAL BUSINESS DEVELOPMENT OFF. LEGAL FELLOW AMERICAN HONDA MOTOR CO., INC. NATURAL RESOURCES DEFENSE COUNCIL 1919 TORRANCE BLVD. 111 SUTTER ST., 21ST FLOOR TORRANCE, CA 90501 SAN FRANCISCO, CA 91404 FOR: AMERICAN HONDA MOTOR CO., INC. FOR: NATURAL RESOURCES DEFENSE COUNCIL

WAYNE NASTRI ANDREA TOZER EO - MANAGEMENT DISTRICT SR. ATTORNEY SOUTH COAST AIR QUALITY SOUTHERN CALIFORNIA EDISON COMPANY 21865 COPLEY DRIVE 2244 WALNUT GROVE AVE / PO BOX 800 DIAMOND BAR, CA 91765-0940 ROSEMEAD, CA 91770 FOR: SOUTH COAST AIR QUALITY MANAGEMENT FOR: SOUTHERN CALIFORNIA EDISON COMPANY DISTRICT

DONALD C. LIDDELL DONALD KELLY ATTORNEY EXE. DIRECTOR DOUGLASS & LIDDELL UTILITY CONSUMERS' ACTION NETWORK 2928 2ND AVENUE 3405 KENYON ST., STE. 401 SAN DIEGO, CA 92103 SAN DIEGO, CA 92110 FOR: CALIFORNIA ENERGY STORAGE ALLIANCE FOR: UTILITY CONSUMERS' ACTION NETWORK (UCAN)

LISA MCGHEE DESMOND WHEATLEY OPERATIONS MGR. CEO SAN DIEGO AIRPORT PARKING CO. ENVISION SOLAR INTRERNATIONAL, INC. 2771 KURTZ ST. 5660 EASTGATE DRIVE SAN DIEGO, CA 92110 SAN DIEGO, CA 92121 FOR: SAN DIEGO AIRPORT PARKING COMPANY FOR: ENVISION SOLAR INTERNATIONAL, INC.

JOHN W. LESLIE, ESQ JOHN A. PACHECO ATTORNEY ATTORNEY DENTONS US LLP SAN DIEGO GAS & ELECTRIC COMPANY 4655 EXECUTIVE DRIVE, SUITE 700 8330 CENTURY PARK CT., CP32 SAN DIEGO, CA 92121 SAN DIEGO, CA 92123 FOR: SHELL ENERGY NORTH AMERICA (US), FOR: SAN DIEGO GAS & ELECTRIC COMPANY L.P.

SACHU CONSTANTINE STEPHEN G. DAVIS DIR. OF POLICY CEO CENTER FOR SUSTAINABLE ENERGY OXYGEN INITIATIVE 9325 SKY PARK COURT, SUITE 100 65 ENTERPRISE SAN DIEGO, CA 92123 ALISO VIEJO, CA 92656 FOR: CENTER FOR SUSTAINABLE ENERGY (CSE) FOR: EXYGEN INITIATIVE (FORMERLY KNGRID)



MICHAEL CHIACOS TADASHI GONDAI ENERGY PROGRAM DIR. DIR OF LEGAL AFFAIRS COMMUNITY ENVIRONMENTAL COUNCIL NATIONAL ASIAN AMERICAN COALITION 26 W. ANAPAMU ST., 2ND FLR. 15 SOUTHGATE AVE., STE. 200 SANTA BARBARA, CA 93101 DALY CITY, CA 94015 FOR: COMMUNITY ENVIRONMENTAL COUNCIL FOR: THE NATIONAL ASIAN AMERICAN COALITION AND THE NATIONAL DIVERSITY COALITION

DAVID SCHLOSBERG MILA A. BUCKNER DIR - ENERGY MARKET OPER ATTORNEY EMOTORWERKS ADAMS BROADWELL JOSEPH & CARDOZO 846 BRANSTEN ROAD 601 GATEWAY BLVD., STE. 1000 SAN CARLOS, CA 94070 SOUTH SAN FRANCISCO, CA 94080 FOR: ELECTRIC MOTORWERKS, INC. FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES

TOVAH TRIMMING AUSTIN M. YANG CALIF PUBLIC UTILITIES COMMISSION DEPUTY CITY ATTORNEY LEGAL DIVISION CITY AND COUNTY OF SAN FRANCISCO ROOM 4107 OFFICE OF CITY ATTY DENNIS J.HERRERA 505 VAN NESS AVENUE 1 DR. CARLTON B. GOODLETT PL, RM 234 SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-4682 FOR: ORA FOR: CITY & COUNTY OF SAN FRANCISCO

ELISE TORRES EVELYN KAHL STAFF ATTORNEY COUNSEL THE UTILITY REFORM NETWORK ALCANTAR & KAHL LLP 785 MARKET STREET, SUITE 1400 345 CALIFORNIA ST., STE. 2450 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94104 FOR: TURN FOR: CLEAN ENERGY FUELS

JAMES BIRKELUND CHRISTOPHER WARNER PRESIDENT PACIFIC GAS AND ELECTRIC COMPANY SMALL BUSINESS UTILITY ADVOCATES 77 BEALE STREET, B30A 548 MARKET STREET, SUITE 11200 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94104 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: SMALL BUSINESS UTILITY ADVOCATES

LARISSA KOEHLER HOWARD V. GOLUB SENIOR ATTORNEY ATTORNEY ENVIRONMENTAL DEFENSE FUND NIXON PEABODY LLP 123 MISSION STREET, 28TH FLOOR 1 EMBARCADERO CENTER, STE. 1800 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94111 FOR: ENVIRONMENTAL DEFENSE FUND FOR: CITY OF LONG BEACH CALIFORNIA, A MUNICIPAL CORPORATION, ACTING BY AND THROUGH ITS BOARD OF HARBOR COMMISSIONERS

IRENE K. MOOSEN BEAU WHITEMAN ATTORNEY AT LAW SR. MGR., EV INFRASTRUCTURE LAW OFFICE OF IRENE K. MOOSEN TESLA MOTORS, INC. 53 SANTA YNEZ AVENUE 3500 DEER CREEK ROAD SAN FRANCISCO, CA 94112 PALSO ALTO, CA 94304 FOR: LOCAL GOVERNMENT SUSTAINABLE FOR: TESLA, INC. ENERGY COALITION (LGSEC)



CHRIS KING AJ HOWARD GLOBAL CHIEF REGULATORY OFFICER OLIVINE, INC. SIEMENS SMART GIRD SOLUTIONS 2010 CROW CANYON PLACE, STE. 100 4000 E 3RD AVE., STE. 400 SAN RAMO, CA 94583 FOSTER CITY, CA 94404 FOR: OLIVINE, INC. FOR: SIEMENS

JIMMY O'DEA, PH.D JOEL ESPINO VEHICLES ANALYST LEGAL COUNSEL UNION OF CONCERNED SCIENTISTS THE GREENLINING INSTITUTE 500 12TH STREET, STE. 340 360 14TH STREET, 2ND FL. OAKLAND, CA 94607 OAKLAND, CA 94612 FOR: UNION OF CONCERNED SCIENTISTS FOR: THE GREENLINING INSTITUTE

GREGORY MORRIS RYAN SCHUCHARD DIRECTOR POLICY DIR. GREEN POWER INSTITUTE CALSTART 2039 SHATTUCK AVENUE, STE 402 501 CANAL BLVD., NO. G BERKELEY, CA 94704 RICHMOND, CA 94804 FOR: THE GREEN POWER INSTITUTE FOR: CALSTART

JAMES HALL MICHAEL PIMENTEL GENERAL MOTORS LLC LEGISLATIVE / REGULATORY ADVOCATE 1115 11TH STREET CALIFORNIA TRANSIT ASSOCIATION SACRAMENTO, CA 95814 1415 L STREET FOR: GENERAL MOTORS LLC SACRAMENTO, CA 95814 FOR: CALIFORNIA TRANSIT ASSOCIATION

SCOTT BLAISING STEVEN P. DOUGLAS COUNSEL SR. DIR - ENVIRONMENTAL AFFAIRS BRAUN BLAISING SMITH WYNNE P.C. ALLIANCE OF AUTOMOBILE MANUFACTURERS 915 L STREET, SUITE 1480 1415 L STREET, STE. 1190 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CITY OF LANCASTER FOR: ALLIANCE OF AUTOMOBILE MANUFACTURERS

TANNER KELLY LYNN HAUG DEWEY SQUARE GROUP, LLC ATTORNEY 1020 16TH STREET, SUITE 20 ELLISON SCHNEIDER HARRIS & DONLAN LLP SACRAMENTO, CA 95814 2600 CAPITOL AVE., STE. 400 FOR: ELECTRIC VEHICLE CHARGING SACRAMENTO, CA 95816 ASSOCIATION (EVCA) FOR: CHARGEPOINT, INC.

LAURA TAYLOR ATTORNEY BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 915 L STREET, STE. 1480 SACRAMENTO, CA 95822 FOR: SILICON VALLEY CLEAN ENERGY AUTHORITY



Information Only

ANGIE BOAKES BARBARA R. BARKOVICH ELECTRIC MOBILITY GENERAL MGR. CONSULTANT SHELL INT'L. PETROLEUM CO., LIMITED BARKOVICH & YAP, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

BONNIE DATTA CASE COORDINATION SR. DIR - AMERICAS & ASIA PACIFIC PACIFIC GAS AND ELECTRIC COMPANY SIEMENS EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

DAVE PACKARD DIANE I. FELLMAN CHARGEPOINT, INC. VP - REGULATORY / GOV'T AFFAIRS EMAIL ONLY NRG WEST EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000

JANE KRIKORIAN SEPHRA NINOW SUPERVISOR, ADVOCACY & ADMINISTRATION ASSOCIATE DIR - REGULATORY UTILITY CONSUMERS' ACTION NETWORK CENTER SUSTAINABLE ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000

MRW & ASSOCIATES, LLC EDWARD LOVELACE, PH.D EMAIL ONLY CHIEF TECHNOLOGY OFFICER EMAIL ONLY, CA 00000 XL HYBRIDS 145 NEWTON STREET BOSTON, MA 02135

KAY DAVOODI LARRY ALLEN ACQ-UTILITY RATES AND STUDIES OFFICE DEPARTMENT OF THE NAVY NAVAL FACILITIES ENGINEERING COMMAND HQ 1322 PATTERSON AVE., SE 1322 PATTERSON AVE., SE - BLDG. 33 WASHINGTON, DC 20374-5018 WASHINGTON, DC 20374-5018

BLAKE ELDER JOE MOCK CLEAN ENERGY SPECIALIST SOUTHERN CALIFORNIA GAS COMPANY EQ RESEARCH 555 W. FIFTH ST., GT14D6 401 HARRISON OAKS BLVD., STE. 100 LOS ANGELES, CA 90013 CARY, NC 27513

IDALMIS VAQUERO SARA GERSEN EARTHJUSTICE ASSOC. ATTORNEY 800 WILSHIRE BLVD., SUITE 1000 EARTHJUSTICE LOS ANGELES, CA 90017 800 WILSHIRE BLVD., STE. 1000 LOS ANGELES, CA 90017

CLAIRE DOOLEY CASE ADMINISTRATION EVGO SERVICES LLC SOUTHERN CALIFORNIA EDISON COMPANY 11390 WEST OLYMPIC BLVD. 8631 RUSH STREET LOS ANGELES, CA 90064 ROSEMEAD, CA 91770



CASE ADMINISTRATION ANNETTE TRAN SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY AFFAIRS 2244 WALNUT GROVE AVENUE, PO BOX 800 SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA 91770 2244 WALNUT GROVE AVE. ROSEMEAD, CA 91773

DAVID CROYLE MARCIE MILNER EXECUTIVE DIRECTOR VP - REGULATORY AFFAIRS UTILITY CONSUMERS' ACTION NETWORK SHELL ENERGY NORTH AMERICA (US), L.P. 3405 KENYON STREET, STE. 401 4445 EASTGATE MALL, SUITE 100 SAN DIEGO, CA 92110 SAN DIEGO, CA 92121

JENNIFER WRIGHT SUE MARA REGULATORY CASE MGR. CONSULTANT SAN DIEGO GAS & ELECTRIC COMPANY RTO ADVISORS, LLC 8330 CENTURY PARK COURT, CP32F 164 SPRINGDALE WAY SAN DIEGO, CA 92123 REDWOOD CITY, CA 94062

STEVE TABER MARC D. JOSEPH ENERGY MARKETS ATTORNEY AT LAW EMOTORWERKS ADAMS, BROADWELL, JOSEPH & CARDOZO 846 BRANSTEN ROAD 601 GATEWAY BLVD., STE. 1000 SAN CARLOS, CA 94070 SOUTH SAN FRANCISCO, CA 94080 FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES

MATTHEW YUNGE ERIC BORDEN CALIF PUBLIC UTILITIES COMMISSION ENERGY POLICY ANALYST ENERGY SAFETY & INFRASTRUCTURE BRANCH THE UTILITY REFORM NETWORK AREA 785 MARKET STREET, STE. 1400 505 VAN NESS AVENUE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-3214

JOHANNA FORS KAREN SHEA REGULATORY AFFAIRS CASE MGR., CUSTOMER PROGRAM PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, B10A 77 BEALE STREET, B9A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

STEVE CHADIMA FRANCESCA WAHL SVP - EXTERNAL AFFAIRS SR. ASSOCIATE, BUS. DEVELOPMENT ADVANCED ENERGY ECONOMY TESLA, INC. 135 MAIN ST., STE. 1320 444 DE HARO STREET, STE. 101 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94107

ADENIKE ADEYEYE HOWARD GOLUB SR. RESEARCH & POLICY ANALYST NIXON PEABODY LLP EARTHJUSTICE ONE EMBARCADERO CENTER, 18TH FLR 50 CALIFORNIA ST., STE. 500 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 FOR: CITY OF OAKLAND, CALIFORNIA, A MUNICIPAL CORPORATION, ACTING BY AND THROUGH ITS BOARD OF PORT OF HARBOR COMMISSIONERS



PAUL R. CORT RITA LIOTTA EARTHJUSTICE FEDERAL EXECUTIVE AGENCIES 50 CALIFORNIA ST., STE. 500 1 AVENUE OF THE PALMS, STE. 161 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94130

SARAH VAN CLEVE DONNELL CHOY ENERGY POLICY ADVISOR DEPUTY PORT ATTORNEY TESLA, INC. PORT OF OAKLAND 3500 DEER CREEK ROAD 530 WATER STREET, 4TH FL. PALO ALTO, CA 94304 OAKLAND, CA 94607

PAUL D. HERNANDEZ RACHEL GOLDEN POLICY MGR. SR. CAMPAIGN REP. CENTER FOR SUSTAINABLE ENERGY SIERRA CLUB 426 17TH STREET, STE. 700 2101 WEBSTER, STE. 1300 OAKLAND, CA 94612 OAKLAND, CA 94612

DAVID MARCUS TAM HUNT 1541 JUANITA WAY CONSULTING ATTORNEY BERKELEY, CA 94702 2039 SHATTUCK AVENUE, SUITE 402 FOR: COALITION OF CALIFORNIA UTILITY BERKELEY, CA 94704 EMPLOYEES FOR: THE GREEN POWER INSTITUTE

JIN NOH C. C. SONG SR. CONSULTANT REGULATORY ANALYST STRATEGEN CONSULTING MARIN CLEAN ENERGY 2150 ALLSTON WAY, STE.210 1125 TAMALPAIS AVE. BERKELEY, CA 94709 SAN RAFAEL, CA 94901 FOR: MCE

PHILLIP MULLER JOHN NIMMONS SCD ENERGY SOLUTIONS COUNSEL 436 NOVA ALBION WAY JOHN NIMMONS & ASSOCIATES, INC. SAN RAFAEL, CA 94903 175 ELINOR AVE., STE. G MILL VALLEY, CA 94941

ANNE SMART ANTHONY HARRISON VP, PUBLIC POLICY DIR - PUBLIC POLICY CHARGEPOINT, INC. CHARGEPOINT 254 EAST HACIENDA AVENUE 254 E. HACIENDA AVENUE CAMPBELL, CA 95008 CAMPBELL, CA 95008

NEWONDA NICHOLS RENEE SAMSON PROGRAM MGR., UTILITY SOLUTIONS DIR - UTILITY SOLUTIONS CHARGEPOINT CHARGEPOINT, INC. 254 EAST HACIENDA AVE. 245 HACIENDA AVENUE CAMPBELL, CA 95008 CAMPBELL, CA 95008

ART DOUWES CHRISTINA JAWORSKI OPERATIONS MGR. SR. ENVIRONMENTAL PLANNER VTA BUS MAINTENANCE ENGINEERING VTA ENVIRONMENTAL PROGRAMS 3331 NORTH FIRST STREET, BUILDING B-1 3331 NORTH FIRST ST., BLDG B-2



SAN JOSE, CA 95134 SAN JOSE, CA 95134 FOR: SANTA CLARA VALLEY TRANSPORTATION

JAMES WILHELM STEVEN S. SHUPE SR. MECHANICAL ENGINEER GENERAL COUNSEL VTA BUS MAINTENANCE ENGINEERING SONOMA CLEAN POWER AUTHORITY 3331 NORTH FIRST STREET, BUILDING B-1 50 SANTA ROSA AVE., 5TH FL. SAN JOSE, CA 95134 SANTA ROSA, CA 95404

AUDRA HARTMANN DAN GRIFFITHS PRINCIPAL BRAUN BLAISING SMITH & WYNNE, P.C. SMITH, WATTS & HARTMANN 915 L STREET, STE. 1480 925 L STREET, SUITE 220 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814

DELANEY L. HUNTER JOHN SHEARS MANAGING PARTNER RENEWABLE TECHNOLOGIES GONZALEZ, QUINTANA, HUNTER & CRUZ, LLC THE CENTER FOR ENERGY EFFICIENCY AND 915 L STREET, STE. 1270 1100 11TH ST., SUTE. 311 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: SANTA CLARA VALLEY TRANSPORTATION FOR: CEERT AUTHORITY

ANDREW B. BROWN MIKE CADE ATTORNEY INDUSTRY SPECIALIST ELLISON SCHNEIDER HARRIS & DONLAN LLP ALCANTAR & KAHL 2600 CAPITOL AVE., STE. 400 121 SW SALMON STREET, SUITE 1100 SACRAMENTO, CA 95816 PORTLAND, OR 97204

CATHIE ALLEN ELI MORRIS REGULATORY AFFAIRS MGR. PACIFICORP PACIFICORP 825 NE MULTNOMAH, STE. 1500 825 NE MULTNOMAH ST., STE 2000 PORTLAND, OR 97232 PORTLAND, OR 97232

ETTA LOCKEY SR. COUNSEL PACIFICORP 825 NE MULTNOMAH ST., STE. 1500 PORTLAND, OR 97232

State Service

MICHELLE COOKE AMY E. MESROBIAN ADMINISTRATIVE LAW JUDGE CALIF PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC EMAIL ONLY AREA EMAIL ONLY, CA 00000 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

AUDREY NEUMAN BENJAMIN GUTIERREZ CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ELECTRICITY PRICING AND CUSTOMER PROGRAM



ROOM 4-A AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA

CAROLYN SISTO CHLOE LUKINS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION PROCUREMENT STRATEGY AND OVERSIGHT BRANC ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA ROOM 4102 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA

JENNIFER KALAFUT JOHN S. WONG CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER PETERMAN DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 5303 ROOM 5106 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

JOSEPH A. ABHULIMEN JUNAID RAHMAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY SAFETY & INFRASTRUCTURE BRANCH RISK ASSESSMENT AND ENFORCEMENT ROOM 4209 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA

NATHAN CHAU QUANG PHAM CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM COMMUNICATIONS AND WATER POLICY BRANCH AREA AREA 2-D 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA

RICK TSE SARAH R. THOMAS CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY SAFETY & INFRASTRUCTURE BRANCH LEGAL DIVISION AREA 2-D ROOM 5033 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA

SASHA GOLDBERG NOEL CRISOSTOMO CALIF PUBLIC UTILITIES COMMISSION AIR POLUTION SPECIALIST DIVISION OF ADMINISTRATIVE LAW JUDGES CALIFORNIA ENERGY COMMISSION ROOM 2000 1516 9TH STREET 505 VAN NESS AVENUE SACRAMENTO, CA 95814 SAN FRANCISCO, CA 94102-3214

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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF ... · 2 I. INTRODUCTION Senate Bill (“SB”) 350 requires the Commission to approve, or modify and approve, IOU programs