BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 327
                                                                  Page  1

          Date of Hearing:   April 15, 2013

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
                   AB 327 (Perea) - As Amended:  February 13, 2013
           
          SUBJECT  :   Electricity: natural gas: rates.

           SUMMARY  :   This bill modifies statutory requirements specific to  
          residential rate design applicable to the customers of Investor  
          Owned Utilities (IOUs).  Specifically,  this bill  :  

          a)Requires the California Public Utilities Commission (PUC),  
            when it approves changes to electric service rates charged to  
            residential customers, to determine that the changes are  
            reasonable, including that the changes are necessary in order  
            to ensure that the rates paid by residential customers are  
            fair, equitable, and reflect the costs to serve those  
            customers. 

          b)Requires the PUC to consider specified principles in approving  
            any changes to electric service rates.

          c)Requires the PUC to report to the Legislature its findings and  
            recommendations relating to tiered residential electric  
            service rates in a specified rulemaking by January 31, 2014. 

          d)Recasts and revises limitations on electric and natural gas  
            service rates of residential customers, including the rate  
            increase limitations applicable to electric service provided  
            to California Alternate Rates for Energy (CARE) customers. 

           EXISTING LAW  

          1)Requires the PUC to allocate a 'baseline quantity of  
            electricity based on 50% to 60% of average residential  
            electricity consumption for customers served with both gas and  
            electricity or 60% to 70% for all electric residential  
            customers and to take climatic and seasonal variations into  
            account. (Public Utilities Code 739(a)(1)

          2)Requires the PUC to set rates for the baseline quantity to be  
            the lowest rate and to allow increasing rates for usage in  
            excess of the baseline quantify. (Public Utilities Code  
            739(d)(1))








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          3)Requires the PUC to avoid excessive rate increases for  
            residential customers and to establish an appropriate gradual  
            differential between the rates for the respective blocks of  
            usage (Public Utilities Code 739(d)(1))

          4)Requires the PUC to retain an appropriate inverted rate  
            structure for residential customers and that if the PUC  
            increases baseline rates revenues resulting from those  
            increases they are to be used exclusively to reduce  
            nonbaseline residential rates. (Public Utilities Code 739.7)


          5)Allows the PUC to make higher allocations for persons with  
            medical needs, such as emphysema, pulmonary patients, or  
            persons on life-support equipment. (Public Utilities Code  
            739(c))


          6)Restricts the PUC from approving IOU rates that increase the  
            residential rates for electricity usage up to 130 percent of  
            the baseline quantities, by the annual percentage change in  
            the Consumer Price Index from the prior year plus 1 percent,  
            but not less than 3 percent and not more than 5 percent per  
            year. The annual percentage change in the Consumer Price Index  
            is calculated using the same formula that was used to  
            determine the annual Social Security Cost of Living Adjustment  
            on January 1, 2008. This restriction sunsets January 1, 2019.   
            (Public Utilities Code 739.9(a))


          7)Restricts approval of mandatory or default time-variant or  
            real time pricing, or critical peak pricing for residential  
            customers and establishes these as opt-in programs only. In  
            addition, requires that customers be provided with one year of  
            data and one year of bill protection and caps billings to no  
            more than they would otherwise have been under the customer's  
            previous rate schedule. Also exempts medical baseline  
            customers. (Public Utilities Code 745)


          8)Further restricts rates charged residential customers for  
            electricity usage up to the baseline quantities, including any  
            customer charge revenues, to not exceed 90 percent of the  
            system average rate prior to January 1, 2019, and not exceed  








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            92.5 percent after that date. (Public Utilities Code 739.9(b))


          9)Establishes a program of assistance to low-income residential  
            customers with annual household incomes no greater than 200%  
            of federal poverty guidelines which reflects discounts based  
            on level of need and allows limited rate increase of up to 3%  
            annually, subject to limitations. CARE rates cannot exceed 80%  
            of the corresponding rates charged to non-CARE customers  
            (excluding non-bypassable charges). (Public Utilities Code  
            739.1(b)(4)


          10)Allows low income customers to be exempt from paying  
            Department of Water Resources bond charge imposed pursuant to  
            Division 27 (commencing with Section 80000) of the Water Code,  
            the CARE surcharge portion of the public goods charge, any  
            charge imposed pursuant to the California Solar Initiative,  
            and any charge imposed to fund any other program that exempts  
            CARE participants from paying the charge. (Public Utilities  
            Code 739.1(g), 2851(d)(3), 379.6(h)

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   


           1)Author's Statement  . "The energy crisis is long over, but laws  
            meant to protect residential rate users are now preventing the  
            CPUC from governing the rate structure and making necessary  
            changes for the thousands of middle to low income families  
            struggling to pay high energy costs. For example, the gap  
            between Tier 2 and Tier 5 increased from 5 cents per kWh to 15  
            cents per kWh today.  Absent rate reform, the gap between Tier  
            2 and Tier 5 will double to nearly 29 cents per kWh by 2022  
            causing tens of thousands of customers to pay rates  
            significantly higher than the actual cost of electricity.   
            Without legislative changes, the CPUC has only very limited  
            ability to fix this unfair residential electric rate  
            structure."

           2)Energy Crisis of 2000-2001.  During the energy crisis, AB1 x1  
            (Keeley, 2001) protected ratepayers from rampant price  
            fluctuations due to a dysfunctional wholesale electricity  
            market.  AB1 x1 authorized the Department of Water Resources  








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            (DWR) to issue revenue bonds to purchase power on behalf of  
            the cash-strapped investor-owned utilities who couldn't keep  
            up with the volatile wholesale prices. Among other stabilizing  
            efforts, AB1 x1 prohibited the PUC from increasing rates for  
            usage under 130% of baseline until DWR bond charges are paid  
            off. These restrictions did not apply to customers of publicly  
            owned utilities, about 25% of electricity customers in  
            California.

            SB 695 (Kehoe, 2009) was intended to minimize spikes in  
            electricity rates and provide relative stability and  
            predictability. Among its provisions, the bill removed the  
            freeze on Tier 1 and Tier 2 rates and replaced it with  
            formulas intended to allow gradual rate increases through 2018  
            at which time the caps for  those increases would sunset.   
            Different formulas were created for CARE and non-CARE  
            customers.

            SB 743 (Steinberg & Padilla, 2013) would eliminate CalWorks as  
            the index for CARE rate increases and in its place tie  
            increases to the annual percentage change in the Consumer  
            Price Index with a maximum cap of 4% per year. SB 743 does not  
            currently address the restrictions applicable to non-CARE  
            customers.
           
             Instead of the approach used by SB 743, AB 327 removes the  
            prescriptive statutes that restrict rate design, establishes  
            principles of rate design for the PUC to follow, and directs  
            the PUC to develop the rates. Prior to the energy crisis, this  
            is how the PUC designed and implemented IOU rate structures.
           
            3)PUC Residential Rate Design Proceeding Underway.  On June 28,  
            2012, the PUC initiated a proceeding to examine current  
            residential electric rate design, including the tier structure  
            in effect for residential customers, the state of time variant  
            and dynamic pricing, potential pathways from tiers to time  
            variant and dynamic pricing, and preferable residential rate  
            design. This PUC proceeding is open to the public and allows  
            interested parties opportunities to participate by making  
            comments on PUC rulings, making rate design proposals,  
            commenting on proposals made by others, commenting on  
            proposals made by staff, and commenting on any decision made  
            by the PUC. According to the public schedule, final rounds of  
            comments are due mid-summer 2013. This would be followed by a  
            draft decision, which is also open to comments.








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            In the PUC's decision to open the residential rate design  
            rulemaking, it noted the following:

            "For example, in Southern California Edison's (SCE's) service  
            territory, 66 percent of residential sales are in Tiers 1 and  
            2.As a result, the remaining revenue requirement is borne by  
            the remaining 34 percent of their sales. However, currently 51  
            percent of their non-CARE, non-coastal customers end up in  
            Tier 4 or above, compared to 37 percent of their non-CARE,  
            coastal customers. The end-result is that non-coastal  
            customers are responsible for a greater portion of the  
            residential revenue requirement not recovered from Tiers 1 and  
            2 than coastal customers, although adjustments to the baseline  
            quantities for the various climate zones could alter this  
            relationship?

            "Without being able to exceed the statutory limits on the  
            rates in Tiers 1 and 2, a greater percentage of a utility's  
            revenue requirement must be borne by customers in Tiers 3 and  
            4, especially those that do not participate in NEM [Net Energy  
            Metering]. This results in a subsidy as customers in Tiers 3  
            and 4 pay a higher average price for the same kilowatt-hour of  
            electricity than Tiers 1 and 2, regardless of when or where  
            that kWh is consumed.

            "As evidenced by SCE's experience, it appears that customers  
            living away from the coast who tend to use more electricity  
            have borne the brunt of rate increases to meet utilities'  
            revenue requirements, even accounting for the use of  
            baselines."

            According to the PUC testimony provided to the Assembly Rural  
            Caucus, IOU electricity rates have roughly tracked inflation  
            since 2003 and average between $0.14 and $0.16 among SCE, San  
            Diego Gas & Electric (SDG&E), and Pacific Gas and Electric  
            (PG&E). Yet some ratepayers, because they use more than their  
            Tier 1 and 2 allocations, will pay more than double this  
            because of current restrictions on rate design.

            In testimony provided to the Assembly Rural Caucus, SCE showed  
            that residential rates are currently deviating significantly  
            from cost and that a customer who uses 1,200 kilowatt-hours  
            per month is paying more than $1,000 over cost each year to  
            subsidize low-usage customers.








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            SCE also provided historical rate data showing the percent  
            change in rates for each of its 5 rate tiers. While Tier 1 and  
            Tier 2 rates have increased 7% and 12.8% between 2000 and  
            2013, Tiers 3, 4, and 5 have increased 107%, 132% and 156%  
            over the same period.

            For SCE CARE customers, Tier 1 and 2 rates have  decreased  16%  
            and 11 percent, respectively.

           4)The Subject is Residential Electricity Rate Design  . According  
            to the author this bill is intended to address limitations  
            that impact residential electricity rate structures. In other  
            words, residential gas rates and general provisions that  
            ensure affordable energy bills for low income ratepayers were  
            not intentionally included in the revisions to the rate design  
            statutes. To the extent that rate design applicable to CARE  
            customers is included, it is specific to rate design: AB 327  
            includes language to maintain protections for low income  
            ratepayers to ensure affordable energy bills. It is important  
            to make a distinction between  rate design  and the customer's  
             bill  . Redesigning rates does not necessarily result in a  
            change in the customer's bill. 

            AB 327 specifies that the PUC should approve rates that are  
            "reasonable, including determining that the changes are  
            necessary in order to ensure that the rates and charges paid  
            by residential customers are fair, equitable, and reflect the  
            costs to serve those customers."

            AB 327 places responsibility for rate design outcomes,  
            consistent with specified principles, on the PUC.

           5)Rate Reform Impacts on Low Income households.  AB 327 does not  
            alter existing residential rates. Rather, AB 327 provides the  
            PUC the authority and principles to design and set residential  
            electricity rates, including providing protection and  
            affordability for low income households. Currently, CARE  
            customers receive a 20% discount off of their electric and gas  
            bills. However, because of the cap on Tiers 1 and 2, the  
            effective discount can be much higher if the CARE customer is  
            using more than 130% of the baseline allocation. In some  
            instances, PG&E has reported providing discounts in the range  
            of 60% off of the otherwise applicable bill.









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            In addition to the CARE discount, federal energy assistance  
            programs fund the local Home Energy Assistance Programs  
            (HEAP), and provide free weatherization and up to $300 per  
            year to assist with energy bills if they meet the income  
            qualifications, have a high energy burden, or have a resident  
            in the household that is part of a vulnerable population (i.e.  
            seniors over 60 years of age, disable persons, and children  
            under 5 years of age).


           6)AB 327 specifies Rate Design Principles  . AB 327 includes 'rate  
            design principles' to direct the PUC's development of new  
            residential rate designs. These include protections for  
            low-income customers, encouraging energy conservation,  
            clarity, simplicity, avoidance of cross-subsidization, and  
            transparency if those cross-subsidies are to advance  
            residential electricity policy goals.

            In the PUC's March 19, 2013 ruling in its rate design  
            proceeding, the PUC adopted rate design principles based on  
            the PUC's consideration of stakeholder suggestions and  
            comments. The PUC's principles are similar to the principles  
            in AB 327:

             a)   Low-income and medical baseline customers should have  
               access to enough electricity to ensure basic needs (such as  
               health and comfort) are met at an affordable cost;
             b)   Rates should be based on marginal cost;
             c)   Rates should be based on cost-causation principles;
             d)   Rates should encourage conservation and energy  
               efficiency;
             e)   Rates should encourage reduction of both coincident and  
               non-coincident peak demand;
             f)   Rates should be stable and understandable and provide  
               customer choice;
             g)   Rates should generally avoid cross-subsidies, unless the  
               cross-subsidies appropriately support explicit state policy  
               goals;
             h)   Incentives should be explicit and transparent;
             i)   Rates should encourage economically efficient  
               decisionmaking;
             j)   Transitions to new rate structures should emphasize  
               customer education and outreach that enhances customer  
               understanding and acceptance of new rates, and minimizes  








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               and appropriately considers the bill impacts associated  
               with such transitions.

           1)Spiking the bill.  The result of changing rate design could be  
            that some individual household energy bills would be lower and  
            some could be higher. For a household receiving significant  
            discounts it might be the more significant impact. AB 327  
            provides that the PUC would address the bill impacts of  
            transitioning to a new rate design.

           2)No action is action.  Every three years the IOUs file their  
            General Rate Cases and request authority to recover expenses  
            and collect revenues to cover those expenses. In these rate  
            cases the costs are separated by each customer class  
            (residential, commercial, agriculture, industrial, and street  
            lighting) so that no class subsidizes the other, with the  
            exception of CARE expenses. These expenses include the cost of  
            generation (utilities do not earn a rate of return from energy  
            sales) and the cost of building and maintaining the  
            transmission and distribution system and emergency response.  
            Additional expenses include public purpose programs, such as  
            the CARE program, energy efficiency incentives, the California  
            Solar Initiative, the Self Generation Incentive Program  
            (SGIP), and charges related to the 2000-2001 energy crisis  
            (the Department of Water Resources Bond Charge and the  
            Competitive Transaction Charge).
             
            Each year the IOUs must file requests to recover their  
            expenses. For those expenses related to serving residential  
            customers, the majority of those expenses must be placed on  
            the price paid for electricity by residential customers whose  
            usage exceeds their Tier 2 allocation. Until the statute  
            restricting rate design is modified, this will continue.
             
             One of the growing expenses for utility customers are support  
            for CARE customers. CARE support has grown, particularly  
            during the recent recession, from which California is  
            beginning to emerge. In SCE service area, CARE participation  
            represented 32% of all SCE residential customers. Together,  
            they received $342 million in discounts from their energy  
            bills. For PG&E and SDG&E, CARE participation represents 30%  
            and 25% of their residential customers.

            In addition to CARE, the Legislature has authorized several  
            programs to develop new technologies and business models.  








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            These include the SGIP, the California Solar Initiative (CSI),  
            Energy Efficiency Incentive Programs (EEIP), the Energy  
            Savings Assistance Program (ESAP, free weatherization and  
            appliances for qualified low-income homes), and Net Energy  
            Metering. These programs are funded by California IOU  
            ratepayers. In addition to these Legislatively-authorized  
            programs, the PUC has authorized ratepayer funding for an  
            energy research center at Lawrence Livermore Nuclear  
            Laboratory and the Electric Program Investment Program (energy  
            research and development).

            As more customers elect to reduce electricity consumption  
            through energy efficiency measures or on-site self-generation,  
            fewer customers will remain to recover service costs. This  
            will result in even higher rates for those customers in the  
            higher tier usage.

            Those customers who are not CARE customer, or have usage  
            within 130% of baseline, or who do not have self-generation  
            must then cover PUC approved utility expenses.

           3)Rate protections for low income customers, monthly charges,  
            and time of use rates  . Opponents to AB 327 voice several  
            concerns:

              a)   Discounts for low-income families could be substantially  
               reduced and monthly bills for many CARE customers could  
               skyrocket.  AB 327 provides direction to the PUC that  
               discounts for low income and medical households should have  
               sufficient affordable electricity.
              b)   AB 327 imposes large monthly fixed charges with no  
               limitations.  AB 327 does not have a provision regarding  
               monthly fixed charges.
              c)   Customers could be forced onto default "Time of Use"  
               rates.  AB 327 does not modify the current statutory  
               requirements that restrict approval of mandatory or default  
               time-variant or real time pricing, or critical peak pricing  
               for residential customers nor does AB 327 require time of  
               use rates.

           1)Current rate design isn't working.  According to supporters of  
            AB 327 they suggest that:
               a)     Current rate designs create "punitive,  
                 discriminatory rates that at the top tier rate exceed  
                 PG&E's cost by over 200%, for "normal" power  








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                 consumption." 
               b)     Families of all incomes who live in hotter, inland  
                 are being penalized
               c)     Current rate design results in subsidies for Coastal  
                 households that are paid for by Central Valley  
                 households.
               d)     Reforms adopted in 2009 (SB 695, Kehoe) allowed  
                 limited rate reforms and continued restrictions on the  
                 PUC to implement rate design reforms.

           2)Suggested amendments  . The author may want to consider the  
            following amendments to clarify the intent to address  
            electricity rates rather than both gas and electric, reinforce  
            existing provisions in AB 327 that provide low-income  
            ratepayer protection, and, the author may wish to revise AB  
            327's principles so that they are identical to the principles  
            in the PUC's March 13, 2013 rate design ruling.

            On Page 3, beginning at line 34 through line 4 on Page 4:
            (3)  Beginning January 1, 2019,   the commission shall  may,  
            subject to the limitation in paragraph (4),  establish rates  
            for CARE program participants that  pursuant to this section  
            and Sections 739 and 739.9, subject to both of the following  :
            (A) The requirements of subdivision (b) of Section 382 that  
            the commission ensure that low-income ratepayers are not  
            jeopardized or overburdened by monthly energy expenditures.
            (B) The requirement that the level of the discount for  
            low-income electricity and gas ratepayers correctly reflects  
            the level of need as determined by the needs assessment  
              conducted pursuant to subdivision (d) of Section 382.
             
            Page 6, line 22 through 25:
            (g) It is the intent of the Legislature that the commission  
            ensure CARE program participants  are afforded the lowest  
            possible   receive  affordable electric and gas  rates   service  
            that does not impose an unfair economic burden    and  , to the  
            extent possible, are exempt from additional surcharges  
            attributable to the energy crisis of 2000-01  .

            Beginning on Page 8, line 30: 
            739.9. (a) In approving changes to the rates and charges to  
            residential customers for electricity usage pursuant to this  
            part, the commission shall determine that the changes are  
            reasonable, including determining that the changes are  
            necessary in order to ensure that the rates and charges paid  








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            by residential customers are fair, equitable, and reflect the  
            costs to serve those customers.
            (b) In approving any changes to the rates and charges to  
            residential customers for electricity usage pursuant to this  
            part, the commission shall  consider   be consistent with  the  
            following principles:
             (1) Low income and medical baseline customers should have  
            access to a supply of electricity that is sufficient to ensure  
            basic needs at an affordable cost, including a reasonable  
            implementation schedule for changes in rates to ensure that  
            the implementation of rate changes to residential customers do  
            not unfairly burden low income customers and that sufficient  
            outreach and education is provided to the customers affected  
            by the changes.
            (2) Rates should be based on marginal cost and cost causation.
            (3) Rates should encourage conservation and energy efficiency,  
            including reduction of both coincident and noncoincident peak  
            demand.
            (4) Rates should be understandable to consumers and provide  
            stability, simplicity, and customer choice.
            (5) Rates should avoid cross-subsidies, unless the  
            cross-subsidies are reasonable, transparent to customers, and  
            support explicit state residential electricity policy goals.
              (1)  Low-income and medical baseline customers should have  
               access to enough electricity to ensure basic needs (such as  
               health and comfort) are met at an affordable cost;
             (2)  Rates should be based on marginal cost;
             (3)  Rates should be based on cost-causation principles;
             (4)  Rates should encourage conservation and energy  
               efficiency;
             (5)  Rates should encourage reduction of both coincident and  
               non-coincident peak demand;
             (6)  Rates should be stable and understandable and provide  
               customer choice;
             (7)  Rates should generally avoid cross-subsidies, unless the  
               cross-subsidies appropriately support explicit state policy  
               goals;
             (8)  Incentives should be explicit and transparent;
             (9)  Rates should encourage economically efficient  
               decisionmaking;
             (10) Transitions to new rate structures should emphasize  
               customer education and outreach that enhances customer  
               understanding and acceptance of new rates, and minimizes  
               and appropriately considers the bill impacts associated  
               with such transitions.








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           1)Related Legislation.
           
            AB 1755 (Perea, 2012) authorized the PUC to approved fixed  
            per-customer charges for residential customers beyond the  
            statutory caps on rate increases for tier 1 and 2 customers to  
            cover the fixed costs of electric service if commission finds  
            the charges are just and reasonable and will provide rate  
            relief to upper tier customers.

            SB 743 (Steinberg and Padilla, 2013) would eliminate CalWorks  
            as the index for CARE rate increases and in its place tie  
            increases to the annual percentage change in the Consumer  
            Price Index with a maximum cap of 4% per year. Status: Passed  
            from Senate Energy Utilities & Communications Committee.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          100 Black Men of Long Beach
          1st Guaranty Mortgage and Realty
          Age Well Senior Services
          American Family Housing
          Antelope Valley Board of Trade
          Assured Coin and Loan
          Barstow Community Hospital Auxiliary
          Barstow Unified School District
          Blong Xiong, Councilmember, City of Fresno
          Border Transportation Council
          Building Industry Association of Fresno/Madera Counties
          Building Industry Association of the Greater Valley
          Business Resource Group
          C&C Development (Affordable Housing)
          California Asian Pacific Chamber of Commerce
          California Black Chamber of Commerce
          California League of Food Processors
          California Manufacturers & Technology Association (CMTA)
          California Retailers Association (CRA)
          CAPC, Inc.
          Cement Masons (Local 500)
          Central Valley Opportunity Center, Inc.
          City Fabric (Business)
          City of Coalinga
          City of Livingston








                                                                  AB 327
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          City of Mendota
          City of Reedley
          Community Advocates for People with Choices (CAPC), Inc.
          Community Women of San Gabriel Valley
          Congress of California Seniors
          Cortez Communications, LLC.
          Costa Mesa Chamber of Commerce
          County of Tulare Board of Supervisors
          CTI Environmental, Inc.
          Cyber Risk Insurance Brokers
          Delhi Center
          Donald Garcia, Former Mayor and Councilmember, City of Aliso  
          Viejo
          Ed Gallo, Council Member, City of Escondido
          El Concilio
          Ernest Ewin, Council Member, City of La Mesa
          FOCUSCOM, Inc.
          Fresno Barrios Unidos
          Fresno Metro Black Chamber of Commerce
          Gardena Valley Chamber of Commerce
          Gary Kendrick, City Council, City of El Cajon
          Gi and Associates
          GRCN Connecting Communities, Inc. (Child and Youth Services)
          H.O.P.E. of the Mountain Empire
          Harvey L. Hall, Mayor, City of Bakersfield
          Hawthorne Chamber of Commerce
          Helpline Youth Counseling (HYC)
          Hilltop Group, Inc.
          Hispanic Outreach Task Force
          Independent Energy Producers Association (IEP)
          Individual Letters- 9
          International Brotherhood of Electrical Workers (IBEW Local 465)
          International Brotherhood of Electrical Workers (IBEW Local 47)
          International Brotherhood of Electrical Workers (IBEW Local 569)
          James Dahl, Former Mayor and Councilmember, City of San Clemente
          Jess E. Van Deventer, Sweetwater Authority Board
          John F. Simon, Lumber Estimating Service
          Kern County Taxpayers Association
          Ledford Enterprises (LE) 
          Leticia Perez, Supervisor, Kern County
          LifeHOUSE Management Services
          Mark Muir, Council Member, City of Encinitas
          Martinez Supply
          Mary England, Former Councilmember, City of Lemon Grove
          Meals on Wheels West (Los Angeles)








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          Mercado Business Association
          Mike Murphy, Council Member, City of Merced
          Mountain Health & Community Services
          Oliver L. Baines, Council Member, City of Fresno
          Orange County Hispanic Chamber of Commerce
          Orange Senior Center
          Pacific Gas and Electric Company (PG&E)
          Pringle Insurance Services, Inc. 
          Saddleback College Foundation
          Sam Abed, Mayor, City of Escondido
          San Diego Gas & Electric Company (SDG&E)
          San Diego Habitat for Humanity
          San Diego Regional Minority Supplier Development Council
          San Joaquin Valley Clean Energy Organization
          Santa Ana College Foundation
          Save our Rural Community (S.O.R.E.)
          SELAC Educational Foundation
          Senior Advocates of the Desert
          Sepulveda Group Enterprises, Inc.
          Shirley Horton, Former Assemblymember 78th AD, and Mayor of  
          Chula Vista
          Sierra Dawn Estates (Mobile Home Park)
          Southern California Edison (SCE)
          Stalwart Communications
          The Center Long Beach
          The San Fernando Valley Green Team
          Thomas W. Amend Drywall Contractor
          Trilogy PR Group
          United Association of Food Trucks of San Diego
          United Association of Plumbers and Steamfitters, Local Union 230
          United Cambodian Community (UCC)
          United Communities Network
          Whittier Uptown Association

           Opposition 
           
          AARP California 
          Division of Ratepayer Advocates (DRA)
          The Greenlining Institute
          The Utility Reform Network (TURN)
           
          Analysis Prepared by  :    Susan Kateley / U. & C. / (916)  
          319-2083 `                                    










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