BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) NOTICE OF EX PARTE COMMUNICATION
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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) to Establish Marginal Costs, Allocate Revenues, Design Rates. A (Filed June 30, 2017) SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) NOTICE OF EX PARTE COMMUNICATION FADIA R. KHOURY RUSSELL A. ARCHER Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Russell.Archer@sce.com Dated: July 5, 2018
2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) to Establish Marginal Costs, Allocate Revenues, Design Rates. A (Filed June 30, 2017) SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) NOTICE OF EX PARTE COMMUNICATION Pursuant to Rule 8.4(a) of the Rules of Practice and Procedure of the California Public Utilities Commission (Commission or CPUC), Southern California Edison Company (SCE) hereby gives notice of the following ex parte communications. 1 The communications were a combination of oral and written communications, related primarily to SCE s pending application for approval of its 2016 Rate Design Window (RDW) proposals, 2 and took place as follows. (1) On Monday, July 2, 2018, at 10:30 a.m. with Yuliya Shmidt, advisor to Commissioner Rechtschaffen; Sean Simon, chief of staff to Commissioner Rechtschaffen; and Xuhua Sheila Gao, a CPUC intern in Commissioner Rechtschaffen s office (in person for approximately 30 minutes); (2) on Monday, July 2, 2018, at 1:30 p.m. with Ehren Seybert, advisor to Commissioner Carla J. Peterman (in person for approximately 30 minutes); and (3) on Tuesday, July 3, 2018, at 10:00 a.m. with Jason Houck, advisor to Commissioner Randolph (in person for approximately 30 minutes). 1 Pursuant to Rule 8.4(a), this notice combines timely reports for more than one ex parte communication. 2 A concurrent notice will be filed in that docket, A
3 The three meetings took place at the offices of the Commission located at 505 Van Ness Avenue, San Francisco, California. The first page of the attached written materials were distributed at each meeting. The last three pages were distributed only at the second two meetings. SCE initiated the communications, and in attendance for SCE were Laura Genao, Managing Director of Regulatory Affairs, and Russell Garwacki, Director of Pricing, Design and Research. SCE representatives stated that the PD adopts SCE s TOU proposals, which were largely unopposed by most parties. Those proposals adhered to the Commission s decision in the TOU OIR setting guidelines for establishment of TOU Periods (D ). For the meetings with Mr. Seybert and Mr. Houck, SCE presented Figure IV-28 from its direct testimony in this proceeding, which shows an aggregated 2024 cost view. As backup for this figure, SCE also presented Figures III-23 and Figure III-24 from its rebuttal testimony, which presents the contrast between SCE s 2021 and 2024 forecast hourly cost heat maps for both weekdays and weekends for each month. SCE explained that it is the difference between these years (i.e., the difference in Figure III-23 versus Figure III-24) that reflects the impact of growing RPS on reducing mid-day pricing in all winter months including October. The data demonstrates why SCE selected an extended super off-peak (SOP) period across the entire winter season, starting immediately. Setting the appropriate, stable long-term TOU periods is critical to customer outreach and understanding. In the near term, rate differentials within those periods could be narrower (as in SCE s pending 2018 GRC Phase 2 proposals). However, the TOU periods themselves should reflect a longer-term vision, enduring at least several GRC cycles consistent with the spirit of the Commission s guidance in the TOU OIR. This longerterm vision incorporates (rather than ignores) the movement from 33% to 40% RPS by 2024, which will drive down the midday costs. To the extent RPS targets increase even more, the differential will only grow. For these reasons, it is important to establish an extended SOP period now to avoid yet another change in TOU periods later. 2
4 SCE also discussed the negative impact that delaying or changing the proposed decision would have on SCE s customers and SCE s GRC Phase 2 proceeding. In the meeting with Mr. Houck, SCE also discussed its reasons for maintaining the cap on Option R. Respectfully submitted, FADIA R. KHOURY RUSSELL A. ARCHER /s/ Russell A. Archer By: Russell A. Archer Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Russell.Archer@sce.com July 5,
5 Appendix A SCE s Proposed TOU Periods
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10 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E) to Establish Marginal Costs, Allocate Revenues, and Design Rates. A (Filed June 30, 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) NOTICE OF EX PARTE COMMUNICATION on all parties identified on the attached service list(s) A Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address, including the addresses listed below: Rechtschaffen.exparte@cpuc.ca.gov Sean.simon@cpuc.ca.gov Ehren.seybert@cpuc.ca.gov Jason.houck@cpuc.ca.gov Yuliya.shmidt@cpuc.ca.gov Xuhua.gao@cpuc.ca.gov Peterman.exparte@cpuc.ca.gov Randolph.exparte@cpuc.ca.gov Placing the copies in sealed envelopes and causing such envelopes to be delivered by U.S. mail to the offices of the assigned ALJ(s) or other addressee(s). ALJ Michelle Cooke ( 505 Van Ness Avenue San Francisco, CA ALJ Patrick Doherty CPUC 505 Van Ness Avenue San Francisco, CA Executed on July 5, 2018, at Rosemead, California. /s/ Angelica Gamboa Angelica Gamboa Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770
11 CPUC - Service Lists - A Page 1 of 6 7/5/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - TO ESTABLIS FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: JUNE 19, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties MAX BAUMHEFNER LON W. HOUSE, PH.D. NATURAL RESOURCES DEFENSE COUNCIL WATER AND ENERGY CONSULTING ONLY N ORACLE, STE ONLY, CA ORO VALLEY, AZ FOR: NATURAL RESOURCES DEFENSE COUNCIL FOR: RENEWABLE ENERGY WATER DISTRICTS (REWD): CONSIST OF SANTA CLARITA VALLEY WATER AGENCY AND RANCHO CALIFORNIA WATER DISTRICT DANIEL W. DOUGLASS JANE LEE COLE, ESQ. SR. DOUGLASS & LIDDELL SOUTHERN CALIFORNIA EDISON COMPANY 4766 PARK GRANADA, STE WALNUT GROVE AVE. / PO BOX 800 CALABASAS, CA ROSEMEAD, CA FOR: ALLIANCE FOR RETAIL ENERGY MARKETS FOR: SOUTHERN CALIFORNIA EDISON COMPANY AND DIRECT ACCESS CUSTOMER COALITION (SCE) VANESSA YOUNG HAYLEY GOODSON STAFF LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM MARKET ST., STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: ORA RITA M. LIOTTA COUNSEL - DEPT OF THE NAVY FEDERAL EXECUTIVE AGENCIES JAMES BIRKELUND PRESIDENT & GEN. COUNSEL SMALL BUSINESS UTILITY ADVOCATES
12 CPUC - Service Lists - A Page 2 of 6 7/5/2018 NAVAL FACILITIES ENGINEERING COMMAND 548 MARKET STREET, STE AVENUE OF THE PALMS, STE. 161 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SMALL BUSINESS UTILITY ADVOCATES FOR: FEDERAL EXECUTIVE AGENCIES (FEA) (SBUA) NORA E. SHERIFF EVELYN KAHL BUCHALTER, A PROFESSIONAL CORPORATION BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, SUITE SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS FOR: ENERGY PRODUCERS AND USERS ASSOCIATION COALITION (EPUC) EDWARD G. POOLE JEANNE B. ARMSTRONG AT LAW ANDERSON, DONOVAN & POOLE GOODIN MACBRIDE SQUERI & DAY LLP 601 CALIFORNIA STREET, SUITE SANSOME STREET, SUITE 900 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: WESTERN MANUFACTURED HOUSING COMM. FOR: SOLAR ENERGY INDUSTRIES ASSOCIATION ASSOC. DANIEL DENEBEIM CAROLYN KEHREIN AT LAW PRINCIPAL CALIF. CITY COUNTY STREET LIGHT ASSOC. ENERGY MANAGEMENT SERVICES 825 SAN ANTONIO ROAD, SUITE CELEBRATION WAY PALO ALTO, CA WOODLAND, CA FOR: CALIFORNIA STREET LIGHT ASSOC. FOR: ENERGY USERS FORUM BRAD HEAVNER LAURA TAYLOR POLICY DIR. CALIFORNIA SOLAR & STORAGE ASSOCIATION BRAUN BLAISING SMITH WYNNE, P.C TH STREET, NO L STREET, STE SACRAMENTO, CA SACRAMENTO, CA FOR: CALIFORNIA SOLAR & STORAGE FOR: COALITION FOR AFFORDABLE STREET ASSOCIATION (CALSSA) F/K/A CALIFORNIA LIGHTS ( CASL) SOLAR ENERGY INDUSTRIES ASSOC. (CALSEIA) MICHAEL BOCCADORO SCOTT BLAISING PRESIDENT COUNSEL WEST COAST ADVISORS BRAUN BLAISING SMITH WYNNE P.C. 925 L STREET, SUITE L STREET, SUITE 1480 SACRAMENTO, CA SACRAMENTO, CA FOR: AGRICULTURAL ENERGY CONSUMERS FOR: CALIFORNIA CHOICE ENERGY AUTHORITY ASSOCIATION (AECA) SCOTT BLAISING ROBERT LIEBERT BRAUN BLAISING SMITH WYNNE P.C. 915 L STREET, SUITE 1480 ELLISON SCHNEIDER HARRIS & DONLAN LLP SACRAMENTO, CA CAPITOL AVENUE, SUITE 400 FOR: CITY OF LANCASTER SACRAMENTO, CA FOR: CALIFORNIA MANUFACTURERS & TECHNOLOGY ASSOCIATION (CMTA) KAREN NORENE MILLS
13 CPUC - Service Lists - A Page 3 of 6 7/5/2018 CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO, CA FOR: CALIFORNIA FARM BUREAU FEDERATION Information Only PAUL NELSON REGULATORY CLERK BARKOVICH & YAP BRAUN BLAISING SMITH WYNNE, PC ONLY ONLY ONLY, CA ONLY, CA FOR: CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION RICK UMOFF MRW & ASSOCIATES, LLC COUNSEL & DIR - STATE AFFAIRS ONLY SOLAR ENERGY INDUSTRIES ASSOCIATION ONLY, CA ONLY ONLY, CA BRANDON SMITHWOOD KAY DAVOODI MGR - CALIF STATE AFFAIRS UTILITY RATES & STUDIES OFFICE - US NAVY SOLAR ENERGY INDUSTRIES ASSOCIATION 1322 PATTERSON AVE SE SUITE TH STREET, NW, SUITE 400 WASHINGTON, DC WASHINGTON, DC FOR: FEA LARRY ALLEN BLAKE ELDER UTILITY RATES & STUDIES OFFICE - US NAVY CLEAN ENERGY SPECIALIST 1322 PATTERSON AVE SE SUITE 1000 EQ RESEARCH WASHINGTON, CA HARRISON OAKS BLVD., STE. 100 FOR: FEA CARY, NC MAURICE BRUBAKER HUY TRAN BRUBAKER & ASSOCIATES, INC. (BAI BRUBAKER & ASSOCIATES (FEA) PO BOX PO BOX ST LOUIS, MO ST. LOUIS, MO FOR: FEA CASE ADMINISTRATION ERIN PULGAR SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 8631 RUSH STREET 2244 WALNUT GROVE AVE. ROSEMEAD, CA ROSEMEAD, CA FADIA RAFEEDIE KHOURY RAQUEL IPPOLITI DIR & MANAGING PROJECT ANALYST SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. G.O.1, RM. 348H 2244 WANUT GROVE AVENUE ROSEMEAD, CA ROSEMED, CA RUSSELL A. ARCHER WALKER A. MATTHEWS III SR. SENIOR SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVE. / PO BOX WALNUT GROVE AVENUE, ROOM 390
14 CPUC - Service Lists - A Page 4 of 6 7/5/2018 ROSEMEAD, CA ROSEMEAD, CA DAVID CHENG MICHAEL BROWN STAFF CONSULTANT THE UTILITY REFORM NETWORK EHRLICH â PLEDGER LAW, LLP TH AVENUE, SUITE 810 CALIFORNIA PLAZA SAN DIEGO, CA CALIFORNIA AVENUE, SUITE 223 BAKERSFIELD, CA FOR: SMALL BUSINESS UTILITY ADVOCATES (SBUA) SUE MARA ALEJANDRA M. CUNNINGHAM CONSULTANT TRANSCENDENT ENERGY RTO ADVISORS, LLC ONLY 164 SPRINGDALE WAY ONLY, CA REDWOOD CITY, CA LILLIAN RAFII KATHERINE MORSONY REGULATORY SMALL BUSINESS UTILITY ADVOCATES BUCHALTER, A PROFESSIONAL CORPORATION 548 MARKET ST. SUITE SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ENERGY PRODUCERS AND USERS COALITION (EPUC) MICHAEL ALCANTAR MIKE CADE AT LAW BUCHALTER, A PROFESSIONAL CORPORATION BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, SUITE SECOND STREET, SUITE 1700 SAN FRANCISCO, CA SAN FRANCISCO, CA BUCHALTER BUCK ENDEMANN 55 SECOND STREET, SUITE 1700 SAN FRANCISCO, CA K&L GATES, LLP FOUR EMBARCADERO, STE 1200 SAN FRANCISCO, CA MARC KOLB ALISON LECHOWICZ TESLA, INC. PRINCIPAL 3055 CLEARVIEW WAY LECHOWICZ & TSENG MUNICIPAL CONSULTANTS SAN MATEO, CA PO BOX 3065 OAKLAND, CA FOR: CALIFORNIA STREETLIGHT ASSOC. BARBARA R. BARKOVICH CATHY YAP CONSULTANT BARKOVICH & YAP, INC. BARKOVICH & YAP, INC. PO BOX PO BOX OAKLAND, CA OAKLAND, CA FOR: CLECA FOR: CLECA RACHEL BIRD DIR - POLICY & BUS. DEVELOPMENT, WEST BORREGO SOLAR SYSTEMS, INC. R. THOMAS BEACH PRINCIPAL CONSULTANT CROSSBORDER ENERGY
15 CPUC - Service Lists - A Page 5 of 6 7/5/ ND STREET, SUITE TH ST., SUITE 213A OAKLAND, CA BERKELEY, CA FOR: SOLAR ENERGY INDUSTRIES ASSOC PHILLIP MULLER WILLIAM MARCUS PRESIDENT MCPM ECONOMICS SCD ENERGY SOLUTIONS 618 COURT ST., STE. C 436 NOVA ALBION WAY WOODLAND, CA SAN RAFAEL, CA BETH OLHASSO ANN L. TROWBRIDGE WEST COAST ADVISORS 925 L STREET, SUITE 800 DAY CARTER & MURPHY LLP SACRAMENTO, CA AMERICAN RIVER DR., STE. 205 SACRAMENTO, CA FOR: AGRICULTURAL ENERGY CONSUMERS ASSOCIATION (AECA) ANNE FALCON SR. ASSOCIATE EES CONSULTING, INC. 570 KIRKLAND WAY, NO. 100 KIRKLAND, CA State Service MICHELLE COOKE ADMINISTRATIVE LAW JUDGE CALIFORNIA PUBLIC UTILITIES COMMISSION ONLY ONLY, CA BENJAMIN GUTIERREZ ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA CHRISTOPHER HOGAN DEXTER E. KHOURY ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA EHREN SEYBERT ERIC DURAN COMMISSIONER PETERMAN ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5303 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA JUSTIN H. FONG LEE-WHEI TAN ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA
16 CPUC - Service Lists - A Page 6 of 6 7/5/2018 LOUIS M. IRWIN MASOUD FOUDEH ELECTRICITY PRICING AND CUSTOMER PROGRAM DEMAND RESPONSE, CUSTOMER GENERATION, AN ROOM 4209 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MATTHEW A. KARLE NATHAN CHAU ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4108 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA PATRICK DOHERTY PAUL S. PHILLIPS DIVISION OF ADMINISTRATIVE LAW JUDGES DEMAND RESPONSE, CUSTOMER GENERATION, AN ROOM 5044 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA ROBERT LEVIN BRIDGET SIEREN-SMITH ENERGY DIVISION DEMAND RESPONSE, CUSTOMER GENERATION, AN AREA 180 Promenade Circle, Suite VAN NESS AVENUE Sacramento, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS
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