BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) )

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Policies, Procedures and Rules for Reliability Reporting Pursuant to Public Utilities Code Section R (Filed December 18, 2014 SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E REPLY TO OTHER PARTIES COMMENTS FRANK A. MCNULTY ROBERT F. LEMOINE Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( Dated: February 6, 2015 LIMS

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Policies, Procedures and Rules for Reliability Reporting Pursuant to Public Utilities Code Section R (Filed December 18, 2014 SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E REPLY TO OTHER PARTIES COMMENTS I. INTRODUCTION Pursuant to Ordering Paragraph 4 of Rulemaking (R , Southern California Edison Company (SCE respectfully files this reply to the comments submitted by other parties on January 23, SCE s reply addresses comments filed by Pacific Gas and Electric Company (PG&E, San Diego Gas & Electric Company (SDG&E, the California Association of Small and Multijurisdictional Utilities (CASMU, and the Coalition of California Utility Employees (CUE. II. REPLY A. SCE Supports Parties Proposals For A Workshop In This Proceeding The comments of PG&E (at page 18, SDG&E (at page 2 and CASMU (at page 2 recommend that the Commission hold a workshop to further vet the issues raised in this rulemaking. SCE supports the proposals for a workshop. 1

3 B. The Commission Has Decided That Reliability Is Outside The Scope Of The RAMP CUE comments: the Commission should require the annual reports of circuit-level reliability data to be included in the IOU s RAMP phase of its GRC. 1 This proposal is contrary to the Commission s recent decision in the Rate Case Plan rulemaking. In that rulemaking, R , the Commission considered revisions to its Rate Case Plan for energy utilities. Among other things, D in that proceeding requires a new Risk Assessment and Mitigation Phase (RAMP be included as part of the major electric utilities GRC proceedings. However, the Commission also considered and rejected proposals that reliability be addressed in the RAMP: Some of the parties raised the issue that the S-MAP and RAMP process should also make reliability, along with safety, a top priority of the Commission and the energy utilities. We do not believe that we need to expand the methods and methodologies being developed in this proceeding to include an assessment of making reliability a top priority. We base that on three reasons. First, the concept of reliable service is already included in 451 which states in part that Every public utility shall furnish and maintain such adequate, efficient, just, and reasonable service, instrumentalities, equipment, and facilities... as are necessary to promote the safety, health, comfort, and convenience of its patrons, employees, and the public. 451 has been interpreted by the California Supreme Court to mean that a public utility has a general duty to exercise reasonable care in operating its system to avoid unreasonable risks of harm to the persons and property of its customers. (Langley v. PG&E ( Cal.2d 655, at 660. As recognized in Barnett v. Delta Lines, Inc. ( Cal.App.3d 674, at 683, 451 sets forth the guidelines a utility must follow in relation to its customers. Thus, 451 already provides that the utility has the duty to provide and maintain adequate, efficient, just, and reasonable service... Second, SB 705 only refers to making safety a top priority. To expand it to include reliability opens up new considerations about the quality of service, what constitutes reliability, and events that may be outside the utility's control which affect reliability. Those new considerations about what reliability entails leads [sic] to the third reason for not expanding the S-MAP to include reliability. The energy utilities have tariff provisions in place that limit liability under certain circumstances. To open up the S-MAP to ensure reliability could affect those liability limitations, 1 CUE Comments, p. 3. 2

4 which in turn could significantly expand the intended scope of the S-MAP process and SB 705. Accordingly, we conclude that expanding SB 705's policy of prioritizing safety to include reliability is outside the scope of this proceeding and the S- MAP and RAMP processes adopted in this decision. We recognize, however, that reliability-related issues can affect safety. In such situations, those reliability issues should be included in the assessment of safety. 2 CUE s recommendation that circuit-level reliability data be included in the RAMP is contrary to the Commission s decision in D ORDER INSTITUTING RULEMAKING TO DEVELOP A RISK-BASED DECISION-MAKING FRAMEWORK TO EVALUATE SAFETY AND RELIABILITY IMPROVEMENTS AND REVISE THE GENERAL RATE CASE PLAN FOR ENERGY UTILITIES, D , pp , 2014 Cal. PUC LEXIS 589, *at (emphasis added. 3

5 III. CONCLUSION SCE appreciates the opportunity to submit this reply to other parties comments and looks forward to participating further in this proceeding. Respectfully submitted, FRANK A. MCNULTY ROBERT F. LEMOINE /s/ FRANK A. MCNULTY By: Frank A. McNulty Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( February 6,

6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking Regarding Policies, Procedures and Rules for Reliability Reporting Pursuant to Public Utilities Code Section R (Filed December 18, 2014 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 REPLY TO OTHER PARTIES COMMENTS on all parties identified on the attached service list(s R Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an e- mail address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Commissioner(s or other addressee(s. ALJ Hazlyn Fortune CPUC - DIV of ALJ's 505 Van Ness Ave, Room 5115 San Francisco, CA Comm. Michael Picker CPUC 505 Van Ness Ave San Francisco, CA Executed this February 6, 2015 at Rosemead, California. _/s/ David Balandran David Balandran Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

7 CPUC Service Lists R Page 1 of 4 2/6/2015 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R CPUC - OIR REGARDING FILER: CPUC LIST NAME: LIST LAST CHANGED: JANUARY 29, 2015 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties MARC D. JOSEPH FRANCIS MCNULTY ADAMS BROADWELL JOSEPH & CARDOZO ATTORNEY AT LAW SOUTHERN CALIFORNIA EDISON COMPANY, CA WALNUT GROVE AVENUE, ROOM 370 FOR: COALITION OF CALIFORNIA UTILITY ROSEMEAD, CA EMPLOYEES (CCUE FOR: SOUTHERN CALIFORNNIA EDISON COMPANY NGUYEN QUAN KEN DEREMER BEAR VALLEY ELECTRIC SERVICE DIRECTOR, TARIFF & REGULATORY ACCOUNTS 630 EAST FOOTHILL BLVD. SAN DIEGO GAS & ELECTRIC COMPANY SAND IMAS, CA CENURY PARK COURT, CP32C FOR: BEAR VALLEY ELETRIC SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY ELISE TORRES CHRISTOPHER P. JOHNS STAFF ATTORNEY PRESIDENT THE UTILITY REFORM NETWORK PACIFIC GAS AND ELECTRIC COMPANY 785 MARKET STREET, SUITE BEALE STREET SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: TURN FOR: PACIFIC GAS AND ELECTREIC COMPANY VIDHYA PRABHAKARAN MICHELLE R. MISHOE DAVIS WRIGHT & TREMAINE LLP SR. COUNSEL 505 MONTGOMERY STREET, SUITE 800 PACIFICORP SAN FRANCISCO, CA NE MULTNOMAH STREET, SUITE 1800 FOR: LIBERTY UTILITIES (FORMERLY PORTLAND, OR CALPECO ELECTRIC LLC FOR: PACIFICORP

8 CPUC Service Lists R Page 2 of 4 2/6/2015 Information Only ALANA VOLSKAYA BARBARA H. CLEMENT PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY, CA 00000, CA BRUCE SMITH CASE ADMINISTRATION PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS & ELECTRIC COMPANY, CA 00000, CA CASE COORDINATION DAVID MARCUS PACIFIC GAS AND ELECTRIC COMPANY ADAMS BROADWELL & JOSEPH, CA 00000, CA EMILY SANGI JAMIE L MAULDIN DAVIS WRIGHT TREMAINE ADAMS BROADWELL JOSEPH & CARDOZO, CA 00000, CA FOR: COALITION OF CALIFORNIA UTILITY EMPLOYEES (CCUE KATY MORSONY ALCANTAR & KAHL, CA RACHEL GOLD POLICY DIRECTOR LARGE-SCALE SOLAR ASSOCIATION, CA UDI HELMAN MRW & ASSOCIATES, LLC HELMAN ANALYTICS, CA 00000, CA KAREN TERRANOVA DAVIS WRIGHT TREMAINE, LLC ALCANTAR & KAHL, CA , CA LENA LUNA CASE ADMINISTRATION SO. BAY CITIES COUNCIL OF GOVERNMENTS SOUTHERN CALIFORNIA EDISON COMPANY S. WESTERN AVE., STE WALNUT GROVE AVENUE / PO BOX 800 TORRANCE, CA ROSEMEAD, CA MICHAEL MOORE RONALD MOORE SOUTHERN CALIFORNIA EDISON COMPANY SR ANALYST, REGULATORY AFFAIRS 2244 WALNUT GROVE AVENUE BEAR VALLEY ELECTRIC ROSEMEAD, CA EAST FOOTHILL BOULEVARD SAN DIMAS, CA 91773

9 CPUC Service Lists R Page 3 of 4 2/6/2015 REBECCA W. GILES CENTRAL FILES REGULATORY CASE MANAGER SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK CT, CP31-E 8330 CENTURY PARK COURT, CP32-D SAN DIEGO, CA SAN DIEGO, CA PHILLIP MULLER SCOTT BLAISING PRESIDENT ATTORNEY SCD ENERGY SOLUTIONS BRAUN BLAISING MCLAUGHLIN & SMITH, P.C. 436 NOVA ALBION WAY 915 L STREET, STE SAN RAFAEL, CA SACRAMENTO, CA ANDREW B. BROWN CHRISTA LIM ELLISON SCHNEIDER & HARRIS L.L.P. ELLISON SCHNEIDER & HARRIS, LLP 2600 CAPITOL AVENUE, STE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA RONALD LIEBERT JEDEDIAH J. GIBSON ATTORNEY AT LAW ATTORNEY AT LAW ELLISON SCHNEIDER & HARRIS LLP ELLISON SCHNEIDER & HARRIS LLP 2600 CAPITOL AVENUE, STE CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA SACRAMENTO, CA JEFFREY D. HARRIS LYNN M. HAUG ATTORNEY AT LAW ELLISON, SCHNEIDER & HARRIS LLP ELLISON & SCHNEIDER 2600 CAPITOL AVENUE, SUITE CAPITOL AVENUE, SUITE 400 SACRMENTO, CA SACRAMENTO, CA CATHIE ALLEN HEIDE CASWELL REGULATORY AFFAIRS MGR. PACIFICORP PACIFICORP 825 NE MULTNOMAH, STE NE MULTNOMAH ST., STE 2000 PORTLAND, OR PORTLAND, OR State Service HAZLYN FORTUNE RYAN YAMAMOTO CALIFORNIA PUBLIC UTILITIES COMMISSION CALIFORNIA PUBLIC UTILITIES COMMISSION, CA 00000, CA JOHN D. ERICKSON OGEONYE ENYINWA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION INFRASTRUCTURE PLANNING AND PERMITTING B ENERGY COST OF SERVICE & NATURAL GAS BRA AREA 4-A ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA

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