BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Revisions to Electric Rule 20 and Related Matters. Rulemaking (Filed May 11, 2017) SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) OPENING COMMENTS ON ORDER INSTITUTING RULEMAKING TO CONSIDER REVISIONS TO ELECTRIC RULE 20 AND RELATED MATTERS JANET S. COMBS TRISTAN REYES CLOSE MARGARITA GEVONDYAN Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) margarita.gevondyan@sce.com Dated: June 30, 2017

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Revisions to Electric Rule 20 and Related Matters. Rulemaking (Filed May 11, 2017) SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) OPENING COMMENTS ON ORDER INSTITUTING RULEMAKING TO CONSIDER REVISIONS TO ELECTRIC RULE 20 AND RELATED MATTERS In accordance with Rule 6.2 of the California Public Utilities Commission s (the Commission s ) Rules of Practice and Procedure, Southern California Edison Company ( SCE ) hereby submits these comments in response to the May 19, 2017 Order Instituting Rulemaking to Consider Revisions to Electric Rule 20 and Related Matters (the OIR or Order ) in the above-captioned proceeding. I. INTRODUCTION On May 19, 2017, the Commission issued an OIR to enhance the fair and efficient allocation of ratepayer funds used to replace overhead with underground facilities under utilityadministered Rule 20 programs. 1 As part of the OIR, the Commission included a preliminary list of information and questions and asked parties to file comments evaluating the appropriateness of the wording of the questions and the validity of the data sources identified. 2 The Commission encouraged parties to recommend additional questions or data that may facilitate its review of the 1 OIR at 2. 2 Id. at

3 Rule 20A program. 3 Additionally, the Commission ordered each electric utility to file and serve a programmatic and financial audit of its administration of its Rule 20A program, conducted by an independent firm. Following the receipt of comments, the Commission will hold a workshop and prehearing conference to discuss and refine the list of data and the initial questions and will thereafter issue a final list of questions for comment. 4 II. DISCUSSION A. SCE Does Not Object to the Initial Scoping Questions The OIR grouped the initial scoping questions into five categories to accomplish the goals of this rulemaking: (1) Rule 20A Work Credits, (2) Public Interest Criteria, (3) Allocation Methodology/Funding, (4) Outreach Strategies, and (5) Additional Rule 20 Concerns. Overall, SCE does not object to any of the initial scoping questions or the proposed scope of review. SCE believes the questions and information outlined in the OIR are appropriate. SCE further believes that the scope should be expanded to consider revisions to the Rule 20 Annual Completion Report. B. SCE Recommends Narrowing the Timeframe of Requested Information As part of the OIR, the Commission anticipates directing each electric utility to file and serve certain data for the calendar years as a common baseline on issues identified in the rulemaking. 5 The Commission also directed the electric investor-owned utilities (IOUs) to produce the data sixty days after the pre-hearing conference. While SCE does not object to the preliminary data requested or to the schedule for production, the Commission should reduce the calendar years for the requested information. As the Commission noted, in the early 2000s, the 3 Id. at Id. at Id. at 17. 2

4 Commission expanded the use of Rule 20A funds by allowing cities to leverage funds with Rule 20B funds and mortgage Rule 20A funds by borrowing up to five years worth of credits ahead of time. 6 Consequently, Rule 20A data following the rule expansion led to irregular activity. The Rule 20A data during the Commission-proposed timeframe will simply be outdated, overly burdensome to produce, and irrelevant. Accordingly, SCE respectfully requests that the Commission narrow the scope of the preliminary information from to for more robust data reflecting the current Rule 20A landscape. Moreover, SCE requests further clarification on certain requested data. On page 17 of the OIR, the Commission asks for Rule 20A project details in disadvantaged communities ( DACs ). SCE recommends using a common definition for DACs across all utilities when providing program details. On page 17 of the OIR, the Commission requests the CalEnviroScreen Score of the locations with completed projects. Since the scores may fluctuate, for example when the project was completed rather than the current score, SCE requests clarification on the timing on which score to use to complete the information request. Lastly, on page 18 of the OIR, the Commission requests a list of communities that have never completed a Rule 20A project nor utilized Rule 20A work credit allocations for projects. SCE anticipates difficulty in responding to this data request. The Rule 20A program began in 1967; therefore, SCE may not have such historical data. Moreover, SCE believes that the data within the past five years will be more useful in understanding which communities have been more active in converting overhead power lines and other equipment to underground facilities. C. SCE Recommends Uniformity Across the Proposed Audits In accordance with the Order, SCE will submit its proposed Audit Scope within 60 days of the May 19, 2017 Order (on or by July 18, 2017). SCE, along with Pacific Gas and Electric ( PG&E) and San Diego Gas and Electric ( SDG&E ) (collectively, the Joint Electric IOUs ), 6 Id. at 8. 3

5 intend to work together to provide a joint audit scope. In order to facilitate this joint effort, SCE recommends that the Audit Scope be the same for the Joint Electric IOUs. SCE also proposes that the Joint Electric IOUs hire the same auditor. Hiring the same auditor would present a true apples-to-apples comparison across the Electric IOU programs and contribute to an equal evaluation of each utilities existing Rule 20A program. In addition, the resulting audit reports would contain similar content that allows for the information to be assimilated in a uniform manner. Moreover, hiring the same auditor will likely promote efficiency and be more costeffective. SCE will keep the Commission s Utility Audit, Finance & Compliance Branch of Energy Division apprised throughout the independent audit including the auditor selection, audit kickoff presentations, and major audit developments. 1. Proposed Audit Schedule The Order directs the Joint Electric IOUs to file and serve the Audit Scope within 60 days after the OIR is issued. (Id. at 26). The audit must be filed and served 180 days after the Joint Electric IOUs file their audit scope. (Id.) SCE recommends that the 180 days start after the Energy Division Director provides comments on the Audit Scope. These comments are integral to the audit scope of work for the audit solicitation. Also, SCE reserves the right to request additional time in the schedule once the final audit scope is determined, and SCE has had a chance to have discussions on timing of the audit phases with the independent auditor (e.g. initiate and access discovery and testing, validate, and report.) 2. Funding SCE respectfully requests an Assigned Commissioner Ruling giving the Joint Electric IOUs the authority to record the independent audit expenses in a ratepayer-funded balancing account. SCE proposes to revise its Preliminary Statement Part YY, Base Revenue Requirement Balancing Account ( BRRBA ) to allow for the recovery of its OIR Rule 20 independent audit costs through the operation of the distribution subaccount of the 4

6 BRRBA. The Commission has authorized SCE recovery of prior independent audit costs through the BRRBA. The Commission conducts its review of SCE s BRRBA in the annual Energy Resource Recovery Account ( ERRA ) Review proceeding. III. CONCLUSION SCE appreciates this opportunity to comment on the OIR s scope, schedule, questions and data filed and served presented in the Order. SCE respectfully requests that the Commission adopt the aforementioned recommendations. Respectfully submitted, JANET S. COMBS TRISTAN REYES CLOSE MARGARITA GEVONDYAN Margarita Gevondyan By: Margarita Gevondyan Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) margarita.gevondyan@sce.com June 30,

7 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Revisions to Electric Rule 20 and Related Matters. Rulemaking (Filed May 11, 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 S (U 338-E) OPENING COMMENTS ON ORDER INSTITUTING RULEMAKING TO CONSIDER REVISIONS TO ELECTRIC RULE 20 AND RELATED MATTERS on all parties identified on the attached service list for R Service was effected by transmitting copies via to all parties who have provided an address and by placing 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 Jessica T. Hecht CPUC 505 Van Ness Avenue San Francisco, CA Executed on June 30, 2017, at Rosemead, California. /s/ Olivia Gutierrez Olivia Gutierrez Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

8 CPUC - Service Lists - R Page 1 of 5 6/30/2017 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR TO CONSID FILER: CPUC LIST NAME: LIST LAST CHANGED: JUNE 27, 2017 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties ERIK B. JACOBSON TRISTAN REYES CLOSE PACIFIC GAS AND ELECTRIC COMPANY SR. ONLY SOUTHERN CALIFORNIA EDISON COMPANY ONLY, CA WALNUT GROVE AVE. / PO BOX 800 FOR: PACIFIC GAS AND ELECTRIC COMPANY ROSEMEAD, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY (SCE) NGUYEN QUAN JOSEPH KLOBERDANZ REGULATORY AFFAIRS REGULATORY AFFAIR MGR. BEAR VALLEY ELECTRIC SERVICE SAN DIEGO GAS & ELECTRIC COMPANY 630 EAST FOOTHILL BLVD. PO BOX 1831 SAN DIMAS, CA SAN DIEGO, CA FOR: BEAR VALLEY ELECTRIC SERVICE FOR: SAN DIEGO GAS & ELECTRIC COMPANY KEN DEREMER ERIC BATONGBACAL DIRECTOR, TARIFF & REGULATORY ACCOUNTS EXE DIR. - REGULATORY SAN DIEGO GAS & ELECTRIC COMPANY AT&T CALIFORNIA 8330 CENURY PARK COURT, CP32C 430 BUSH STREET, 5TH FL. SAN DIEGO, CA SAN FRANCISCO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: AT&T CALIFORNIA MARK P. SCHREIBER PATRICK ROSVALL COOPER WHITE & COOPER LLP COOPER WHITE AND COOPER 201 CALIFORNIA ST., 17TH FLOOR 201 CALIFORNIA ST., 17TH FLOOR SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: FORESTHILL TELEPHONE COMPANY /

9 CPUC - Service Lists - R Page 2 of 5 6/30/2017 FOR: CONSOLIDATED COMMUNICATIONS OF CALIFORNIA KERMAN TELEPHONE COMPANY / DUCOR TELEPHONE COMPANY / SIERRA TELEPHONE COMPANY / THE PONDEROSA TELEPHONE COMPANY / PINNACLES TELEPHONE COMPANY / CALAVERAS TELEPHONE COMPANY / VOLCANO TELEPHONE COMPANY / SISKIYOU TELEPHONE COMPANY / CAL-ORE TELEPHONE COMPANY / HAPPY VALLEY TELEPHONE COMPANY / HORNITOS TELEPHONE COMPANY / WINTERHAVEN TELEPHONE CHARLIE BORN PETER EICHLER MANAGER-STATE GOVERNMENTAL AFFAIRS LIBERTY UTILITIES LLC CITIZENS TELECOMMUNICATIONS CO.OF CA 933 ELOISE AVENUE 9260 E. STOCKTON BLVD SOUTH LAKE TAHOE, CA ELK GROVE, CA FOR: LIBERTY UTILITIES (CALPECO FOR: CITIZENS TELECOMMUNICATIONS ELECTRIC) COMPANY OF CALIFORNIA / FRONTIER CALIFORNIA CATHIE ALLEN REGULATORY AFFAIRS MGR. PACIFICORP 825 NE MULTNOMAH ST., STE 2000 PORTLAND, OR FOR: PACIFICORP Information Only MRW & ASSOCIATES, LLC COURTNEY FROH ONLY HAPPY VALLEY TELEPHONE COMPANY ONLY, CA GREENWAY BLVD., STE. 230 MIDDLETON, WI FOR: HAPPY VALLEY TELEPHONE COMPANY / HORNITOS TELEPHONE COMPANY / WINTERHAVEN TELEPHONE LANCE CASEY EDWARD N. JACKSON SR. REG. RELATIONS SPECIALIST DIR - REVENUE REQUIREMENTS CONSOLIDATED COMMUNICATIONS OF CALIF LIBERTY UTILITIES (PARK WATER) CORP. 350 S LOOP 336 WEST 9750 WASHBURN ROAD / PO BOX 7002 MM, TX DOWNEY, CA FOR: CONSOLIDATED COMMUNICATIONS OF CALIFORNIA I MARSH JOSEPH H. PARK MGR, RATES AND REGULATORY AFFAIRS DIR - LEGAL SERVICES LIBERTY UTILITIES (CALPECO) LIBERTY UTILITIES (PARK WATER) CORP WASHBURN ROAD 9750 WASHBURN ROAD / BOX 7002 DOWNEY, CA DOWNEY, CA FRED G. YANNEY YANNEY LAW OFFICE AKBAR JAZAYEIRI MGR - REGULATORY AFFAIRS SOUTHERN CALIFORNIA EDISON COMPANY

10 CPUC - Service Lists - R Page 3 of 5 6/30/ MARQUARDT AVE. UNIT C WALNUT GROVE AVE. / PO BOX 800 CERRITOS, CA ROSEMEAD, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY CASE ADMINISTRATION ANNETTE TRAN SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY AFFAIRS 2244 WALNUT GROVE AVE. / PO BOX 800 SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA WALNUT GROVE AVE. ROSEMEAD, CA RONALD MOORE BRADLEY CARTER SR ANALYST, REGULATORY AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY BEAR VALLEY ELECTRIC 8316 CENTURY PARK CT., CP32F 630 EAST FOOTHILL BOULEVARD SAN DIEGO, CA SAN DIMAS, CA CENTRAL FILES CAROL RODRIGUEZ SAN DIEGO GAS & ELECTRIC COMPANY SECRETARY 8330 CENTURY PARK CT, CP31-E DUCOR TELEPHONE COMPANY SAN DIEGO, CA PO BOX BAKERSFIELD, CA FOR: DUCOR TELEPHONE COMPANY DAVE CLARK DAVID CLARK REGULATORY MANAGER REGULATORY MGR. KERMAN TELEPHONE COMPANY FORESTHILL TELEPHONE CO. 811 SOUTH MADERA AVENUE 811 S. MADERA AVE. KERMAN, CA KERMAN, CA FOR: KERMAN TELEPHONE COMPANY FOR: FORESTHILL TELEPHONE COMPANY LINDA BURTON DAN DOUGLAS SIERRA TELEPHONE REGULATORY MGR. PO BOX 219 THE PONDEROSA TELEPHONE COMPANY OAKHURST, CA PO BOX 21 FOR: SIERRA TELEPHONE COMPANY O'NEALS, CA FOR: THE PONDEROSA TELEPHONE COMPANY MARC D. JOSEPH MILA A. BUCKNER AT LAW ADAMS, BROADWELL, JOSEPH & CARDOZO ADAMS BROADWELL JOSEPH & CARDOZO 601 GATEWAY BLVD., STE GATEWAY BLVD., STE SOUTH SAN FRANCISCO, CA SOUTH SAN FRANCISCO, CA THOMAS LONG AICHI N. DANIEL LEGAL DIRECTOR THE UTILITY REFORM NETWORK PACIFIC GAS AND ELECTRIC COMPANY 785 MARKET ST., STE BEALE STREET B30A SAN FRANCISCO, CA SAN FRANCISCO, CA CASE ADMINISTRATION ROSS JOHNSON PACIFIC GAS AND ELECTRIC COMPANY AREA MANAGER - REG. RELATIONS 77 BEALE STREET AT&T SERVICES SAN FRANCISCO, CA BUSH STREET, 5TH FL, STE 29 SAN FRANCISCO, CA 94108

11 CPUC - Service Lists - R Page 4 of 5 6/30/2017 EDWARD G. POOLE DEMETRO MARQUEZ MANATT, PHELPS & PHILLIPS, LLP ANDERSON & POOLE ONE EMBARCADERO CENTER, 30TH FLOOR 601 CALIFORNIA STREET, SUITE 1300 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: WESTERN MANUFACTURED HOUSING COMMUNITIES ASSOCIATION LILLY B. MCKENNA ZEB ZANKEL MANATT PHELPS & PHILLIPS, LLP ONE EMBARCADERO CENTER, 30TH FL. DAVIS WRIGHT TREMAINE LLP SAN FRANCISICO, CA MONTGOMERY STREET, STE. 800 SAN FRANCISCO, CA DAVID L. HUARD SUZANNE TOLLER MANATT, PHELPS & PHILLIPS, LLP DAVIS WRIGHT TREMAINE LLP ONE EMBARCADERO CENTER, 30TH FL. 505 MONTGOMERY STREET, STE. 800 SAN FRANCISCO, CA SAN FRANCISCO, CA STEVEN BRYAN, JR. YVONNE SMYTHE REGULATORY CONTACT CALAVERAS TELEPHONE COMPANY PINNACLES TELEPHONE COMPANY PO BOX LIVE OAK ROAD COPPEROPOLIS, CA PAICINES, CA FOR: CALAVERAS TELEPHONE COMPANY FOR: PINNACLES TELEPHONE COMPANY RICHARD MCCANN, PH.D BRENDA SHEPARD M. CUBED CFO 2655 PORTAGE BAY ROAD, SUITE 3 VOLCANO TELEHONE COMPANY DAVIS, CA PO BOX 1070 PRIME GROVE, CA FOR: VOLCANO TELEPHONE COMPANY SHELIA DEY ANN L. TROWBRIDGE EXECUTIVE DIRECTOR AT LAW WESTERN MANFACTURED HOUSING COMM. ASSOC DAY CARTER & MURPHY LLP 455 CAPITAL MALL, SUITE AMERICAN RIVER DRIVE, STE. 205 SACRAMENTO, CA SACRAMENTO, CA FOR: WESTERN MANUFACTURED HOUSING COMMUNITY ASSOCIATION WAIHUN YEE JAMES LOWERS CONTROLLER THE SISKIYOU TELEPHONE COMPANY CAL-ORE TELEPHONE COMPANY PO BOX 157 PO BOX 847 ETNA, CA DORRIS, CA FOR: SISKIYOU TELEPHONE COMPANY FOR: CAL-ORE TELEPHONE COMPANY State Service

12 CPUC - Service Lists - R Page 5 of 5 6/30/2017 CHRISTA SALO DAVID PECK CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION LEGAL DIVISION PRESIDENT PICKER ROOM 4107 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA JESSICA T. HECHT CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM VAN NESS AVENUE SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS