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Erik Jacobson
Director
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

March 24, 2020

Advice 5792-E
(Pacific Gas and Electric Company ID U 39 E)
Public Utilities Commission of the State of California
Subject: Update to Residential Electric Vehicle Charging Rate Transition Plan
Approved in Advice Letter 5546-E
Purpose
PG&E provides an update to the Residential Electric Vehicle (EV) Charging Rate
Transition plan previously approved in Advice Letter 5546-E.
Background
On May 17, 2019 PG&E received approval of Advice Letter 5546-E, which outlined the
transition plan for Electric Schedule EV, Rate A, to Schedule EV2. After the completion of
the first annual transition in 2019, PG&E has outlined minor changes to transition
timelines to mitigate potential delays due to Public Safety Power Shutoff (PSPS) events
as well as updates to the NEM2 tariff with clarification regarding grandfathering eligibility.
The EV-A rate closed to new enrollments on July 1, 2019, at the same time that the EV2A rate launched. All customers who were not eligible to remain on the rate were to be
transitioned to EV2-A as part of an annual process that began in 2019 and will conclude
in 2025.
Summary of 2019 Transition:
Customers were identified as eligible to transition to EV2-A if they met the following
conditions:
•
•
•

Had an active account on the EV-A rate
The account was not pending removal from EV-A due to exceeding the 800% of
baseline eligibility criteria
Customer did not meet Net Energy Metering (NEM) grandfathering criteria





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Advice 5792-E -2- March 24, 2020 Transition Status Total # of Customers Total customers on EV-A rate on July 2, 2019 58,271 Customers transitioned to EV2-A in 2019 41,325 NEM customers eligible for grandfathering on EV-A 10,246 NEM customers waiting to transition in 20201 6,700 PG&E discovered inadvertent errors in identifying customers for transition during the initial process of communicating the November rate transition to eligible customers. This led to miscommunications to some NEM grandfathered customers2. As a result, in order to prevent an erroneous transition from EV-A to EV2-A, PG&E placed NEM customer transitions on hold as of November 2019 while corrections were made to the internal processes of identifying which customers are eligible for remaining on the EV-A rate. Additionally, due to the timing of communications and transitions taking place during the months of September through December of 2019 which coincided with wildfire and PSPS events, there were delays to the transition start date due to internal PG&E resource constraints and PG&E’s desire to limit customer communications not directly tied to wildfire and PSPS. Transition of Customers from Electric Schedule EV, Rate A, to Electric Schedule EV2 Taking into consideration lessons learned from the execution of its first annual EV-A rate transition, PG&E is rescheduling the timing of future transitions, including the 2020 transition, to take place in Spring instead of Fall to avoid overlap with potential future PSPS events. Transitions will take place over a 6-week period with a target start date in April of each year. Current customers on Electric Schedule EV, Rate A will receive a notification approximately 30 days prior to their transition date. The messaging will emphasize the need to adjust their charging time to start at 12:00 AM instead of 11:00 PM to align with the off-peak period of the EV2-A rate and will also include information for how customers can determine the exact date of their transition based on their billing cycle. 1 PG&E analysis found that most NEM customers who experienced a delay in transitioning from EV-A to EV2-A in the Fall of 2019 did not experience a negative financial impact. PG&E is conducting bill analysis for the small percentage of customers negatively impacted and will issue bill credits to those customers. 2 PG&E identified 1,734 NEM customers who received a miscommunication.
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Advice 5792-E -3- March 24, 2020 Transition of Customers without a Smart Meter Customers who do not have a smart meter will be transitioned via a separate process since their meters cannot be updated remotely. These customers will also receive a transition notice and will be contacted during the month transitions start to schedule an appointment for a PG&E field employee to update their meters with the new rate peak periods. Summary of NEM Grandfathering eligibility process Determining NEM grandfathering is a complex process that requires lengthy analysis across different billing systems and databases that weren’t designed to house dynamic fields. This process also involves layering different data sets to apply criteria associated with each NEM tariff and referencing multiple data fields including Permission to Operate date, who the original interconnection customer of record is, current account holder, and date of EV-A enrollment. PG&E has modified its analysis to include all of these data points and has now finalized its list of customers who are eligible to remain on EV-A as a grandfathered NEM customer for up to 5 years. This list will be used to identify all customers to be transitioned to EV2A during the 2020 – 2025 transitions based on their grandfathering expiration date. NEM grandfathered customers will also receive a notification informing them of their grandfathered status, its expiration date, and what to expect during their future transition to EV2-A. Grandfathering eligibility for customers who move into a home with existing Solar During this analysis PG&E found that there was ambiguity in the NEM2 tariff that it will now clarify. PG&E’s position is that EV-A TOU grandfathering does not apply to a residential customer who moved into a home with existing NEM2 generation and thereafter became a NEM2 customer (New Occupant). This is true even where the prior occupant of the home took service under the EV-A TOU rate and NEM2. Accordingly, PG&E proposes to modify its Rate Schedule NEM2 to reflect this understanding. Decision 15-07-0019, issued prior to the NEM2 decision, noted that “rates and rate structures change periodically” and while the CPUC was “endeavoring to avoid abrupt changes…individual hardships may occur.” In providing a five-year TOU grandfathering period for solar customers in that decision, the CPUC emphasized that grandfathering was appropriate because the customer who had made the investment in solar had an expectation that the TOU rate would not change: “We are sympathetic to the challenges faced by individual customers who have elected to install rooftop solar. As Vote Solar and others point out, these individual TOU customers may have made the investment in solar assuming that the TOU rate would not change. Rooftop solar installations are often designed to maximize generation during the
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Advice 5792-E -4- March 24, 2020 TOU rate peak periods that were in place at the time of installation. In keeping with the RDPs of customer acceptance and energy efficiency, we believe the impact of changing or closing TOU tariffs should be mitigated. This is consistent with Section 745’s recommendation that the Commission strive to set default TOU periods that are appropriate for at least five years.” Based on the cited record noted above: (1) the Commission prefers more narrowly tailored measures than grandfathering as a policy matter; and (2) New Occupant did not invest in the system and thus would not have had a reasonable expectation that the existing TOU rate would continue. Tariff Revisions PG&E seeks the following updates and clarifications to the NEM2 tariff. Modify Rate Schedule NEM2 in the Rates Section (Sheet 5): A. Residential Customers on this tariff, who are: i) the first customer who installs the REGF (that is, second or subsequent owners are not eligible) and ii) required to take TOU rates prior to the implementation of default TOU rates for all residential customers, and iii) on any TOU rate (including a TOU pilot rate) prior to the implementation of default residential TOU rates, have the option to stay on that TOU rate for a period of five years from the date the customer commences the TOU rate. This advice letter focuses on EV-A TOU rate, since most if not all of the customers that will be affected are on EV-A rate schedule; but this clarification would also apply to any customer on a residential TOU rate, who seek TOU grandfathering based on NEM2 tariff language. Protests Anyone wishing to protest this submittal may do so by letter sent via U.S. mail, facsimile or E-mail, no later than April 13, 2020, which is 20 days after the date of this submittal. Protests must be submitted to: CPUC Energy Division ED Tariff Unit 505 Van Ness Avenue, 4th Floor San Francisco, California 94102
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Advice 5792-E -5- March 24, 2020 Facsimile: (415) 703-2200 E-mail: EDTariffUnit@cpuc.ca.gov Copies of protests also should be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. The protest shall also be sent to PG&E either via E-mail or U.S. mail (and by facsimile, if possible) at the address shown below on the same date it is mailed or delivered to the Commission: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: PGETariffs@pge.com Any person (including individuals, groups, or organizations) may protest or respond to an advice letter (General Order 96-B, Section 7.4). The protest shall contain the following information: specification of the advice letter protested; grounds for the protest; supporting factual information or legal argument; name, telephone number, postal address, and (where appropriate) e-mail address of the protestant; and statement that the protest was sent to the utility no later than the day on which the protest was submitted to the reviewing Industry Division (General Order 96-B, Section 3.11). Effective Date PG&E requests that this Tier 1 advice submittal become effective the date of submittal, which is March 24, 2020. Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service list for R.18-12-006, R.14-07-002 and A.16-06-013. Address changes to the General Order 96-B service list should be directed to PG&E at email address PGETariffs@pge.com. For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Process_Office@cpuc.ca.gov. Send all electronic approvals to PGETariffs@pge.com. Advice letter submittals can also be accessed electronically at: http://www.pge.com/tariffs/.
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Advice 5792-E -6- /S/ Erik Jacobson Director, Regulatory Relations Attachments Attachment 1: Tariffs Attachment 2: Redline Tariff cc: Service List R.18-12-006, R.14-07-002 and A.16-06-013 March 24, 2020
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Kimberly Loo Phone #: (415)973-4587 E-mail: PGETariffs@pge.com E-mail Disposition Notice to: KELM@pge.com EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 1 Advice Letter (AL) #: 5792-E Subject of AL: Update to Residential Electric Vehicle Charging Rate Transition Plan Approved in Advice Letter 5546-E Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: 3/24/20 No. of tariff sheets: 0 Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: See Attachment 1 Service affected and changes proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: EDTariffUnit@cpuc.ca.gov Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: PGETariffs@pge.com Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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Attachment 1 Advice 5792-E Cal P.U.C. Sheet No. Title of Sheet Cancelling Cal P.U.C. Sheet No. 46378-E ELECTRIC SCHEDULE NEM2 NET ENERGY METERING SERVICE Sheet 5 44460-E 46379-E ELECTRIC TABLE OF CONTENTS Sheet 1 46344-E 46380-E ELECTRIC TABLE OF CONTENTS Sheet 6 46270-E Page 1 of 1
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Cancelling U 39 Revised Revised Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 46378-E 44460-E San Francisco, California ELECTRIC SCHEDULE NEM2 NET ENERGY METERING SERVICE RATES: (Cont’d.) Sheet 5 Customer-generators eligible for service under this schedule are exempt from the requirements of Schedule S—Standby Service except Multiple Tariff Facilities interconnected under the terms of Special Condition 4, may be subject to the requirements of Schedule S. The charges and credits for Multiple Tariff Facilities taking service on this rate schedule under the provisions of Special Condition 4, will be calculated using the applicable OAS identified by the customer-generator in its application for interconnection and its interconnection agreement with PG&E or as subsequently changed by the customer-generator in accordance with PG&E’s electric Rule 12. Existing customer-generators being billed under sub-schedules NEM2S, NEM2EXP, NEM2EXPM, or NEM2A who only add storage and are eligible to use the estimation methodology described in Special Condition 9 (“NEM Paired Storage”) will be billed using the estimation methodology as of their scheduled True-Up, provided that a True-Up is not required for any other reason. All other customer-generators with Multiple Tariff Facilities or NEM Paired Storage with existing NEM2 eligible generators or storage interconnecting additional generators, will receive a bill true-up prior to taking service under Special Condition 4. This ensures that all NEM2 accounts have the same Relevant Period, as defined in Special Condition 2, going forward. (T) Residential Customers on this tariff, who are: i. the first customer who installs the REGF (that is, second or subsequent owners are not eligible) and ii. required to take TOU rates prior to the implementation of default TOU rates for all residential customers, and iii. on any TOU rate (including a TOU pilot rate) prior to the implementation of default residential TOU rates, have the option to stay on that TOU rate for a period of five years from the date the customer commences the TOU rate. (N) | | | | | (N) (T) PG&E rates and rate design, including the rates and rate design reflected in this Tariff, are subject to change from time to time. Customers should take this into consideration when making any long term decisions based on rate structures that are currently in place. (Continued) Advice Decision 5792-E Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution March 24, 2020
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Cancelling U 39 Revised Revised Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 46379-E 46344-E San Francisco, California ELECTRIC TABLE OF CONTENTS Sheet 1 TABLE OF CONTENTS SCHEDULE CAL P.U.C. SHEET NO. TITLE OF SHEET Title Page ............................................................................................................................... 46379-E Rate Schedules ......................................... 46267,46268,46269,45403,46380,46266,43935,44177-E Preliminary Statements ........................... 45406,44687,42856*,46219,41723,40591,44724,46345-E Rules ................................................................................................................ 46346,43023,46109-E Maps, Contracts and Deviations ............................................................................................ 37960-E Sample Forms .... 40925*,37631,45743,41573*, 37632,41152*,41153,37769,44035,40671,37169-E (T) (T) (Continued) Advice Decision 5792-E Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution March 24, 2020
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Cancelling U 39 Revised Revised Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 46380-E 46270-E San Francisco, California ELECTRIC TABLE OF CONTENTS SCHEDULE Sheet 6 CAL P.U.C. SHEET NO. TITLE OF SHEET Rate Schedules Other S SB E-BioMAT E-CHP E-CHPS E-CHPSA E-DCG E-DEPART E-DRP E-ECR E-GT E-NMDL E-NWDL E-LORMS E-SDL E-STORE E-TMDL NEM NEM2 NEMFC NEMBIO NEMCCSF NEMV NEM2V Standby Service ................40243,45231,40245,44675,40247,40248,40249,40250,40251,40252, ............................................... 40253,40254,44832,40256,44676,40258,40259,40260,40261-E Standby Service ...........................45639,45640,45641,45642,46265,45644,45645,45646,45647, ............................................................. 45648,45649,45650,45651,45652,45653,45654,45655 Bioenergy Market Adjusting Tariff ............................... 43634,43635,41023,43636,43637,43638*, .................................................................................. 43639,37749,37750,37751,41026,37753, .................................................................................. 37754,37755,37756,41027,41028,41029, ........................................................................................... 43640,41030,37762,37763,43641-E Combined Heat and Power PPA .......................................... 30809,30810,30811,30812, 30813-E Combined Heat and Power Simplified PPA.....................................30814,30815,30816, 30817-E Combined Heat And Power Simplified 500 kW PPA .. 30825,30826,31679,31680,31681,31682-E DCG Departing Customer Generation, CG ................................................... 36593,36594,37148, ........................................................... 37794,3251436595,36596,23252,23253,28405,23255-E Departing Customers ....................................................................................................... 28859-E Demand Response Provider Services................................................................... 35430,37017-E Enhanced Community Renewables (ECR) Program ..................................... 40854,35739,44588, .................................................................................................................44589,35742,35743-E Green Tariff (GT) Program .................................................... 40858,44595,44596,37964,37965-E New Municipal Departing Load ....................... 27453,32097,32098,32099, 29557,29558-,29559, ........................................................................................... 29560,29561,29562,29563,29564-E New WAPA Departing Load ............................................................... 28581,28582,28862,28863, .......................................................................................... 27448,27449,27450,27451, 27452-E Limited Optional Remote Metering Services .................................................................... 20194-E Split-Wheeling Departing Load ................................................ 28588,28589,28867,28868,27459, .......................................................................................... 27460,27461,27462,27463, 27464-E Station Service For Storage Devices..................................... 40238,40239,40240,40241,40242-E Transferred Municipal Departing Load .......................................................... 27465,28869,28870, ............................................... 35227,28961,30659,28608,25887,25888,25889,25890,25891-E Net Energy Metering Service ............................................................ 35635*,36352,36353,35636, .............................. 33901*,35637*,35638*,33904*,36562,36563,36564,35753,33909*,33910*, ............ 33911*,33912*,33913*,35643,33915*,35276,35644,36599,35704,35705,45716,45717 ................................................................................ 45718,45719,45720,45721,45722,45723-E Net Energy Metering Service ................. 42929,45724,42930,37798,46378,42931,42932,42933, (T) .......................................42934,42435,42436,42437,45725,42938,37809,37810,42939,37812, .......................................37813,42940,45726,37816,42941,37818,37819,42942,45727,45728, ............ 45729,45730,45731,45732,45733,45734,45735,45736,45737, 45738, 45739,45740-E Net Energy Metering Service For Fuel Cell Customer-Generators .... 37770,38187,37772,37773, ................................................................................ 37774,37775,32446,32447,37824,38231-E Net Energy Metering Service for Biogas Customer-Generators .................... 30791,27254,27255, ................................................................................ 26140,27256,26142,27257,26144,37823-E Net Energy Metering Service for City and County of San Francisco ........................ 28176,28177, ........................................................................................................................... 28178,28179-E Virtual Net Metering for a Multi-Tenant or Multi-Meter Property Served at the Same Service Delivery Point............................. 42055,42056,42057,31549,32806, .......................................31551,33921,31553,42058,42059,31556,31557,31558,31559,31560, .......................................................... 42060,36566,32807,42061,31565,42062,33216,42063-E Virtual Net Energy Metering Service ............................ 42044,37826,37827,37828,42045,37890, ............................................................ 37831,37832,42046,42047,37835,37836,37837,37838, ........................................................ 42048,37840,42049,37842,37843,37844,37845,42050*-E (Continued) Advice Decision 5792-E Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution March 24, 2020
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Advice 5792-E March 24, 2020 Attachment 2 Redline Tariff
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Cancelling U 39 Revised Original Cal. P.U.C. Sheet No. Cal. P.U.C. Sheet No. 44460-E 37799-E San Francisco, California ELECTRIC SCHEDULE NEM2 NET ENERGY METERING SERVICE RATES: (Cont’d.) Sheet 5 Customer-generators eligible for service under this schedule are exempt from the requirements of Schedule S—Standby Service except Multiple Tariff Facilities interconnected under the terms of Special Condition 4, may be subject to the requirements of Schedule S. The charges and credits for Multiple Tariff Facilities taking service on this rate schedule under the provisions of Special Condition 4, will be calculated using the applicable OAS identified by the customer-generator in its application for interconnection and its interconnection agreement with PG&E or as subsequently changed by the customer-generator in accordance with PG&E’s electric Rule 12. Existing customer-generators being billed under sub-schedules NEM2S, NEM2EXP, NEM2EXPM, or NEM2A who only add storage and are eligible to use the estimation methodology described in Special Condition 9 (“NEM Paired Storage”) will be billed using the estimation methodology as of their scheduled True-Up, provided that a True-Up is not required for any other reason. All other customer-generators with Multiple Tariff Facilities or NEM Paired Storage with existing NEM2 eligible generators or storage interconnecting additional generators, will receive a bill true-up prior to taking service under Special Condition 4. This ensures that all NEM2 accounts have the same Relevant Period, as defined in Special Condition 2, going forward. Residential Customers on this tariff, who are: i. the first customer who installs the REGF (that is, second or subsequent owners are not eligible) and ii. required to take TOU rates prior to the implementation of default TOU rates for all residential customers, and iii. on any TOU rate (including a TOU pilot rate) prior to the implementation of default residential TOU rates, on this tariff, who are required to take TOU rates prior to the implementation of default TOU rates for all residential customers, and who are on any TOU rate (including a TOU pilot rate) prior to the implementation of default residential TOU rates, have the option to stay on that TOU rate for a period of five years from the date the customer commences the TOU rate. PG&E rates and rate design, including the rates and rate design reflected in this Tariff, are subject to change from time to time. Customers should take this into consideration when making any long term decisions based on rate structures that are currently in place. (Continued) Advice Decision 5559-E Issued by Robert S. Kenney Vice President, Regulatory Affairs Submitted Effective Resolution June 14, 2019 July 14, 2019
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PG&E Gas and Electric Advice Submittal List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Cameron-Daniel, P.C. Casner, Steve Cenergy Power Center for Biological Diversity Chevron Pipeline and Power City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Engineers and Scientists of California Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Power Institute Hanna & Morton ICF IGS Energy International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Los Angeles County Integrated Waste Management Task Force MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Peninsula Clean Energy Pioneer Community Energy Redwood Coast Energy Authority Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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