BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) MOTION FOR PARTY STATUS

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Authority to Establish the Wildfire Expense Memorandum Account (U 39 E) Application (Filed July 26, 2017) SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) MOTION FOR PARTY STATUS J. ERIC ISKEN FRANK A. McNULTY MARGARITA GEVONDYAN Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Telephone: (626) Facsimile: (626) Dated: November 14, 2017

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Authority to Establish the Wildfire Expense Memorandum Account (U 39 E) Application (Filed July 26, 2017) SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) MOTION FOR PARTY STATUS I. INTRODUCTION Pursuant to Rule 1.4(a) of the California Public Utilities Commission (Commission) Rules of Practice and Procedure, Southern California Edison Company (SCE) hereby moves for party status in this proceeding. In this proceeding, Pacific Gas & Electric Company (PG&E) seeks authorization to establish a Wildfire Expense Memorandum Account. Issues SCE expects to arise in this proceeding will affect SCE. In order to contribute to the Commission s resolution of those issues, SCE moves to become a party. 1

3 II. MOTION On July 26, 2017, PG&E filed this application seeking authority to establish a wildfire expense memorandum account (Application), stating: relief sought in this application is consistent with the Commission s prior authorization for an ongoing memorandum account for account for [SDG&E] and Southern California Gas Company (SoCalGas) in Decision (D.) ). 1 PG&E also noted the heightened risk of wildfires in California and that California investor owned utilities may be held strictly liable under inverse condemnation for property damage resulting from wildfires linked to utility facilities. 2 The Superior Court for the County of Sacramento has ruled that plaintiffs in litigation related to the Butte Fire may assert claims of inverse condemnation against PG&E. This ruling was premised on the notion that investor owned utilities can spread liability costs through rates. 3 Liability under inverse condemnation has been and will likely continue to be an issue for SCE and other investor owned utilities. Granting SCE s motion for party status will allow SCE to monitor the issues as they develop and contribute substantively to the Commission s resolution of this and related issues in this proceeding. 1 Application at 2. 2 Id. at 3. 3 Id. 2

4 SCE requests that service of notices, orders and other correspondence in this proceeding be addressed to: Frank McNulty Southern California Edison Company Post Office Box Walnut Grove Avenue Telephone: (626) Facsimile: (626) Case Administration Southern California Edison Company 8631 Rush Street Telephone: (626) Facsimile: (626)

5 III. CONCLUSION For the reasons stated above, SCE respectfully moves for party status in this proceeding. J. ERIC ISKEN FRANK A. McNULTY MARGARITA GEVONDYAN /s/ Frank A. McNulty By: Frank A. McNulty Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Telephone: (626) Facsimile: (626) Dated: November 14,

6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Authority to Establish the Wildfire Expense Memorandum Account (U 39 E) Application (Filed July 26, 2017) 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) MOTION FOR PARTY STATUS on all parties identified on the attached service list for: A Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by U.S. Mail to the offices of the Assigned ALJ(s) or other addressee(s), and by U.S. mail to those on the service list without an address. ALJ Peter V. Allen CPUC 505 Van Ness Ave. San Francisco, CA Executed November 14, 2017 at Rosemead, California. /s/laura Velarde Laura Velarde Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800

7 CPUC - Service Lists - A Page 1 of 3 11/14/2017 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A PG&E - FOR AUTHORITY FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: NOVEMBER 13, 2017 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties DAVID CHENG CHRISTOPHER M. LYONS STAFF ATTORNEY SR. COUNSEL THE UTILITY REFORM NETWORK SAN DIEGO GAS & ELECTRIC COMPANY TH AVENUE, SUITE CENTURY PARK CT., CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: TURN FOR: SAN DIEGO GAS & ELECTRIC COMPANY (SDG&E) CHARLYN A. HOOK MICHAEL R. KLOTZ ATTORNEY LEGAL DIVISION PACIFIC GAS AND ELECTRIC COMPANY ROOM 5123 PO BOX 7442, MC B30A 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: OFFICE OF RATEPAYER ADVOCATES (ORA) Information Only GREGORY REISS MILLENNIUM MANAGEMENT LLC ONLY ONLY, NY KEVIN FALLON GLOBAL EQUITIES CITADEL ONLY ONLY, NY MRW ASSOCIATES JAMIESON WARD

8 CPUC - Service Lists - A Page 2 of 3 11/14/2017 MRW & ASSOCIATES ONLY ONLY, CA CFA MILLENNIUM PARTNERS LP 666 5TH AVE. 8TH FL. NEW YORK, NY FRANCIS MCNULTY MARGARITA GEVONDYAN DIRECTORY & MGMT ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE 2244 WALNUT GROVE AVENUE, ROOM 370 ROSEMEAD, CA ROSEMEAD, CA SHIVANI SIDHAR MAGGIE CHAN REGULATORY CASE MGR. REGULATORY AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP32F 77 BEALE ST., MC B9A / PO BOX SAN DIEGO, CA SAN FRANCISCO, CA MATTHEW PLUMMER MEREDITH ALLEN PACIFIC GAS AND ELECTRIC COMPANY SR. DIRECTOR, REGULATORY RELATIONS 77 BEALE STREET, MC B23A PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA BEALE STREET, B10C SAN FRANCISCO, CA State Service DAVID PECK ELAINE LAU CPUC - EXEC ONLY MARKET STRUCTURE, COSTS AND NATURAL GAS ONLY, CA AREA 3-F 505 VAN NESS AVENUE SAN FRANCISCO, CA NILS STANNIK PETER V. ALLEN ENERGY SAFETY & INFRASTRUCTURE BRANCH DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA ROBERT M. POCTA ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM VAN NESS AVENUE SAN FRANCISCO, CA FOR: OFFICE OF RATEPAYER ADVOCATES (ORA)

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