BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) PREHEARING CONFERENCE STATEMENT

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E for Authority to Implement and Recover in Rates the Cost of its Proposed Solar Photovoltaic (PV Program. Application No (Filed March 27, 2008 SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E PREHEARING CONFERENCE STATEMENT DOUGLAS K. PORTER CAROL A. SCHMID-FRAZEE ANNETTE GILLIAM Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( Carol Dated: July 7, 2008

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California Edison Company (U 338-E for Authority to Implement and Recover in Rates the Cost of its Proposed Solar Photovoltaic (PV Program. Application No (Filed March 27, 2008 SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E PREHEARING CONFERENCE STATEMENT I. BACKGROUND AND SUMMARY Pursuant to the Administrative Law Judge s Ruling Providing Guidance and Procedures for Participating in the Proceeding and Requesting Prehearing Conference Statements, dated June 26, 2008 (ALJ s Ruling, Southern California Edison Company (SCE hereby submits its Prehearing Conference (PHC statement on the issues described in the ALJ s ruling. SCE generally agrees with the preliminary scope of the proceeding set out in ALJ s ruling. However, SCE does not agree that the standard of review for evaluating the reasonableness of its proposal should include Whether the proposed Solar Photovoltaic (PV Program is cost-effective? Instead, the standard of review should be whether the proposed Solar PV Program will expand solar PV deployment at lower cost than is currently prevailing and whether it can improve efficiencies in the California PV market. In addition, in this PHC statement, SCE revises its proposed schedule from its Application because that schedule is no longer achievable due to the passage of time. SCE urges the Commission to adopt an aggressive schedule to rapidly resolve the issues in the Solar PV Program Application because SCE is moving forward with program implementation now with little assurance of rate recovery. 1

3 II. THE ALJ S RULING ON PRELIMINARY SCOPE SHOULD BE MODIFIED TO COMPARE SOLAR PV WITH APPROPRIATE ALTERNATIVES The ALJ s Ruling on pages 1 and 2 identifies the following preliminary scope for this proceeding: 1. Whether to approve Edison s proposed Solar Photovoltaic Program (SPVP and funding either as proposed in the application or with modifications? a What should be the standard for review for evaluating the reasonableness of this proposal? Whether the cost estimates are reasonable? Whether elements of Edison s plans are reasonable? Whether the proposed SPVP is cost-effective? What are the benefits to the ratepayers? 2. Whether to approve Edison s proposed cost recovery mechanism? SCE generally agrees that this should be the preliminary scope of the proceeding with one critically important modification. The ALJ s Ruling identifies the standard of review for evaluating the reasonableness of this proposal to include Whether the proposed SPVP is costeffective? The Commission should address cost effectiveness, in a manner that recognizes the purpose of this application, which is to jump start the market for rooftop solar PV in southern California. The appropriate standard of review would be to evaluate (i whether and how the program can reduce the cost of the rooftop solar PV and (ii the program s cost relative to other programs designed to help emerging technologies (e.g., California Solar Initiative. 2

4 The Commission should adopt the following more specific, two questions as part of the standard of review for evaluating the reasonableness of SCE s proposal: 1. Whether the Solar PV Program will reduce the cost of rooftop solar PV deployment? 2. Whether the Solar PV Program can improve efficiencies of elements of the California solar PV market to reduce overall costs on a going forward basis? III. SCE PROPOSES A REVISED SCHEDULE In SCE s Application, dated March 27, 2008, SCE proposed a schedule for this proceeding assuming that there would be evidentiary hearings and briefing. This schedule assumed that the Division of Ratepayer Advocates (DRA and intervenors would have filed opening testimony in June. Obviously, SCE s original schedule is outdated as the PHC will occur on July 10, Table III-1 below proposes a revised schedule ending with a Commission decision by March Table III-1 below contains SCE s proposed revised schedule. Table III-1 Proposed Revised Schedule SCE Files Application March 27, 2008 Daily Calendar Notice Appears March 27, 2008 Protests Due April 28, 2008 Reply to Protests May 8, 2008 Prehearing Conference July 10, 2008 DRA and Intervenors File Opening Testimony August 8, 2008 Rebuttal Testimony Due August 21, 2008 Hearings September 8-10, 2008 Concurrent Opening Briefs Due October 10, 2008 Concurrent Reply Briefs Due October 24, 2008 Commission Issues Proposed Decision January 23, 2009 Comments to Proposed Decision Due February 12, 2009 Replies to Comments to Proposed Decision February 17, 2009 Commission Issues Final Decision March 5,

5 Because of the delay in the schedule, SCE urges the Commission to establish the memorandum account requested in Advice Letter 2226-E as soon as possible. While the establishment of the memorandum account will not assure SCE rate recovery of the initial implementation costs of the Solar PV Program, it will allow the Commission to approve such rate recovery if it finds the amount recorded in the memorandum account to be reasonable. Without the memorandum account, the Commission may not be able to authorize rate recovery of base rate expenses associated with the initial implementation of this program. IV. CONCLUSION Wherefore, SCE urges the Commission to revise the proposed scope of the proceeding to delete the question: Whether the proposed SPVP is cost-effective? In its place, SCE recommends adding the following two questions: (1 Whether the proposed Solar PV Program is less costly than other Solar PV alternatives? and (2 Whether the proposed Solar PV Program can introduce efficiencies into the California Solar PV market? SCE urges the Commission to 4

6 adopt an aggressive schedule to assure a Commission decision no later than March 2009, and to immediately approve Advice Letter 2226-E to assure the establishment of a memorandum account for initial implementation costs that SCE is currently incurring. Respectfully submitted, DOUGLAS K. PORTER CAROL A. SCHMID-FRAZEE ANNETTE GILLIAM /s/carol A. SCHMID-FRAZEE By: Carol A. Schmid-Frazee Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( Carol Schmid-Frazee@sce.com July 7,

7 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 PREHEARING CONFERENCE STATEMENT on all parties identified on the attached service list(s. Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. First class mail will be used if electronic service cannot be effectuated. Executed this 7th day of July 2008, at Rosemead, California. /S/MELISSA SCHARY Melissa Schary Case Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

8 Monday, July 7, 2008 CASE ADMINISTRATION SOUTHERN CALIFORNIA EDISON COMPANY 2244 WALNUT GROVE AVENUE, ROOM 370 ROSEMEAD, CA MRW & ASSOCIATES INC 1814 FRANKLIN ST, STE 720 OAKLAND, CA MARK W. BACHMAN SENIOR EQUITY ANALYST PACIFIC CREST SECURITIES 111 SW FIFTH AVENUE, 42ND FL PORTLAND, OR RYAN BERNARDO BRAUN BLAISING MCLAUGHLIN, P.C. 915 L STREET, SUITE 1270 SACRAMENTO, CA SUNCHETH BHAT PACIFIC GAS AND ELECTRIC 77 BEALE STREET, MC B9A SAN FRANCISCO, CA SARA BIRMINGHAM DIRECTOR, CALIFORNIA POLICY SOLAR ALLIANCE TH AVE SAN FRANCISCO, CA SCOTT BLAISING BRAUN BLAISING MCLAUGHLIN P.C. 915 L STREET, STE SACRAMENTO, CA MICHAEL E. BOYD CALIFORNIANS FOR RENEWABLE ENERGY, INC 5439 SOQUEL DRIVE SOQUEL, CA ADAM BROWNING THE VOTE SOLAR INITIATIVE 300 BRANNAN STREET, SUITE 609 SAN FRANCISCO, CA LYNNE BROWN CALIFORNIANS FOR RENEWABLE ENERGY, INC. 24 HARBOR ROAD SAN FRANCISCO, CA MICHAEL E. CARBOY MANAGING DIRECTOR-EQUITY RESEARCH SIGNAL HILL CAPITAL LLC 343 SANSOME STREET, SUITE 950 SAN FRANCISCO, CA Christopher Clay ROOM 5138 HILARY CORRIGAN CALIFORNIA ENERGY MARKETS 425 DIVISADERO ST., SUITE 303 SAN FRANCISCO, CA EILEEN COTRONEO PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B9A SAN FRANCISCO, CA BRIAN T. CRAGG GOODIN, MAC BRIDE, SQUERI, DAY & LAMPREY 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA MICHAEL B. DAY GOODIN MACBRIDE SQUERI DAY & LAMPREY LLP 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA Maryam Ebke ROOM 5101 DIANE I. FELLMAN DIRECTOR, REGULATORY AFFAIRS FPL ENERGY PROJECT MANAGEMENT, INC. 234 VAN NESS AVENUE SAN FRANCISCO, CA Page 1 of 3

9 Monday, July 7, 2008 Damon A. Franz AREA 4-A HOWARD GREEN DIRECTOR UTILITY DEVELOPMENT WEST SUN EDISON 1130 CALLE CORDILLERA SAN CLEMENTE, CA ARNO HARRIS RECURRENT ENERGY, INC MONTGOMERY ST., SUITE 251 SAN FRANCISCO, CA MARCEL HAWIGER THE UTILITY REFORM NETWORK 711 VAN NESS AVENUE, SUITE 350 SAN FRANCISCO, CA JOE HENRI DIR. WEST COAST REG AFFAIRS SUN EDISON 31 MIRAMONTE RD. WALNUT CREEK, CA GARRETT HERING PHOTO INTERNATIONAL 55 NEW MONTGOMERY, SUITE SAN FRANCISCO, CA EVELYN KAHL ALCANTAR & KAHL, LLP 120 MONTGOMERY STREET, SUITE 2200 SAN FRANCISCO, CA SUE KATELEY EXECUTIVE DIRECTOR CALIFORNIA SOLAR ENERGY INDUSTRIES ASSN PO BOX 782 RIO VISTA, CA STEVEN KELLY POLICY DIRECTOR INDEPENDENT ENERGY PRODUCERS ASSN 1215 K STREET, SUITE 900 SACRAMENTO, CA DON LIDDELL DOUGLASS & LIDDELL ND AVENUE SAN DIEGO, CA RANDY LITTENEKER PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B30A SAN FRANCISCO, CA JODY S. LONDON JODY LONDON CONSULTING PO BOX 3629 OAKLAND, CA Jaclyn Marks ROOM 5306 Rahmon Momoh ROOM 4205 PHILLIP MULLER SCD ENERGY SOLUTIONS 436 NOVA ALBION WAY SAN RAFAEL, CA JOHN NIMMONS PRESIDENT JOHN NIMMONS & ASSOCIATES, INC. 175 ELINOR AVE., SUITE G MILL VALLEY, CA EDWARD W. O'NEILL DAVIS WRIGHT TREMAINE LLP 505 MONTGOMERY STREET, SUITE 800 SAN FRANCISCO, CA STEVEN D. PATRICK SAN DIEGO GAS & ELECTRIC COMPANY 555 WEST FIFTH STREET, SUITE 1400 LOS ANGELES, CA Page 2 of 3

10 Monday, July 7, 2008 David Peck ROOM 4103 DANIEL M. PELLEGRINI COOPERATIVE COMMUNITY ENERGY CORP. 534 FOURTH STREET, STE C SAN RAFAEL, CA KEVIN PORTER SENIOR ANALYST EXETER ASSOCIATES, INC STERRETT PLACE, SUITE 310 COLUMBIA, MD RASHA PRINCE SAN DIEGO GAS & ELECTRIC 555 WEST 5TH STREET, GT14D6 LOS ANGELES, CA CAROL SCHMID-FRAZEE SOUTHERN CALIFORNIA EDISON 2244 WALNUT GROVE AVE. ROSEMEAD, CA DAVID SCHNEIDER E5 CLEAN ENERGY AGOURA CT, STE. 208 AGOURA HILLS, CA NORA SHERIFF ALCANTAR & KAHL, LLP 120 MONTGOMERY STREET, SUITE 2200 SAN FRANCISCO, CA KELLIE SMITH SENATE ENERGY/UTILITIES & COMMUNICATION STATE CAPITOL, ROOM 4038 SACRAMENTO, CA Merideth Sterkel AREA 4-A ANNIE STANGE ALCANTAR & KAHL 1300 SW FIFTH AVE., SUITE 1750 PORTLAND, OR KAREN TERRANOVA ALCANTAR & KAHL, LLP 120 MONTGOMERY STREET, STE 2200 SAN FRANCISCO, CA STACY W. WALTER PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, MC B30A SAN FRANCISCO, CA JAMES WEIL DIRECTOR AGLET CONSUMER ALLIANCE PO BOX 37 COOL, CA JOSEPH F. WIEDMAN GOODIN MACBRIDE SQUERI DAY & LAMPREY LLP 505 SANSOME STREET, SUITE 900 SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS 425 DIVISADERO ST. SUITE 303 SAN FRANCISCO, CA Page 3 of 3