BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Joint Application of Southern California Edison Company (U 338-E) and San Diego Gas & Electric Company (U 902-E) For the 2015 Nuclear Decommissioning Cost Triennial Proceedings. And Related Matters. Application No (Filed March 1, 2016) Application No Application No SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) AND SAN DIEGO GAS & ELECTRIC COMPANY S (U 902-E) JOINT OPENING COMMENTS ON PROPOSED DECISION FADIA KHOURY WALKER A. MATTHEWS III Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) walker.matthews@sce.com ALLEN K. TRIAL Attorney for SAN DIEGO GAS & ELECTRIC COMPANY 8330 Century Park Court, CP32a San Diego, CA Telephone: (858) Facsimile: (619) Atrial@semprautilities.com Dated: October 1, 2018

2 Subject Index of Recommended Changes SCE respectfully recommends that the Commission adopt the following changes to the Proposed Decision: Finding of Fact No. 1 should be corrected to reflect the ownership of SONGS as follows: SCE holds an 80% interest and SDG&E holds a 20% interest in SONGS 1 decommissioning liability. SCE holds an approximately 75.74% interest, SDG&E holds a 20% interest, the City of Anaheim holds an approximately 2.47% interest, and the City of Riverside holds a 1.79% interest in SONGS 2&3 decommissioning liability, respectively.

3 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Joint Application of Southern California Edison Company (U 338-E) and San Diego Gas & Electric Company (U 902-E) For the 2015 Nuclear Decommissioning Cost Triennial Proceedings. And Related Matters. Application No (Filed March 1, 2016) Application No Application No SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) AND SAN DIEGO GAS & ELECTRIC COMPANY S (U 902-E) JOINT OPENING COMMENTS ON PROPOSED DECISION Pursuant to Rule 14.3 of the California Public Utilities Commission s (Commission) Rules of Practice and Procedure, Southern California Edison Company (SCE) and San Diego Gas & Electric Company s (SDG&E) (collectively referred to as the Utilities ) respectfully submit the following comments on Administrative Law Judge (ALJ) Darcie L. Houck s proposed decision (PD) for Phase 1 of the above-referenced proceeding. I. INTRODUCTION AND SUMMARY OF PHASE 1 PROPOSED DECISION The issues addressed in Phase 1 included the Commission s reasonable reviews of: (1) San Onofre Nuclear Generating Station Unit No. 1 (SONGS 1) decommissioning costs of $13.9 million (100% Share, 2011$); 1

4 (2) SONGS 1 decommissioning costs of $6.2 million (100% Share, 2011$); and (3) SONGS Unit Nos 2&3 (SONGS 2&3) nuclear fuel contract cancelation costs of $55.2 million (100% Share, Nominal $). The PD determined that the and SONGS 1 decommissioning costs were reasonable. The PD, however, deferred the reasonableness review of SONGS 2&3 nuclear fuel contract cancellation costs to the 2018 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP), and directed the parties to submit additional testimony regarding whether and to what extent Decision (D.) (SONGS OII Decision) may impact the reasonableness of the costs being recovered from the Utilities customer-funded nuclear decommissioning trusts (NDTs). As discussed below, the Utilities support the PD, and request that the Commission adopt only one minor correction to proposed Finding of Fact No. 1 regarding SONGS ownership interests. II. DISCUSSION The Utilities respectfully acknowledge the importance of the Commission completing SONGS decommissioning reasonableness reviews under the California Nuclear Decommissioning Act of 1985, and greatly appreciate the PD s thoroughness in considering the evidence submitted by the parties and reaching well-reasoned findings and conclusions. A. SONGS 1 Decommissioning Costs In this proceeding, TURN was the only party in Phase 1 to oppose certain SONGS 1 decommissioning costs. In particular, TURN argued that various omissions in the 2009 and 2012 SONGS 1 DCEs warranted the disallowance of decommissioning costs incurred for the omitted items. The PD correctly rejected this argument, confirming that the Commission must look to the reasonableness of any expenses incurred that were omitted from any prior DCE and 2

5 that all decommissioning expenditures are subject to a reasonableness review. 1 The PD s determination on this issue is consistent with established precedent articulated several times by the Commissions in prior NDCTPs, including in Decision (D.) Importantly, the PD further expressly adopted the correct review standard for such omitted costs, determining that [t]he Commission reviews the reasonableness of a utility s action based on what the utility knew or should have known at the time the utility took the actions, not based on what the utility may have inadvertently omitted from a cost estimate or the results of the utility s actions based on hindsight. 2 The PD further found that the omitted costs at issue in this proceeding were reasonable, because they were necessary, among other things, for safety, reliability, compliance with the law, and/or restoring the SONGS site for future uses. 3 The Utilities strongly support this review standard and factors for determining reasonableness, which is consistent with established Commission precedent, as noted in the PD. 4 While approving the omitted costs as reasonable, the PD noted that it was important for the Utilities to submit accurate DCEs, and indicated that in future NDCTPs, the Commission would consider disallowing the costs incurred to prepare a DCE to the extent that omissions are numerous, on-going, and without justification. 5 The Utilities acknowledge the importance of preparing accurate DCEs and will endeavor to correct and avoid errors in future updates to DCEs. The Utilities respectfully note, however, that estimating costs for a complex engineering project that will span decades presents several challenges, and that errors and omissions do not necessarily indicate imprudence by the Utilities. The Utilities agree that in the event this issue arises in future NDCTPs, important factors to consider in disallowing DCE preparation costs 1 Proposed Decision, pp Id., p. 31 (emphasis added). 3 Id., pp. 31, 34, D , p. 9; see also In re San Diego Gas & Electric Company, D , pp. 9-11, In the Matter of the Application of Golden State Water Company, D , p Proposed Decision, p

6 should include the number and frequency of such errors, and the reasons why the errors were made. B. Nuclear Fuel Contract Cancellation Costs The PD determined that the record is incomplete for purposes of assessing the reasonableness of SONGS 2&3 nuclear fuel contract cancellation costs, and deferred the review of these costs to the 2018 NDCTP to allow parties to submit limited supplemental testimony and briefing as to whether and how D (SONGS OII Decision) impacts the reasonableness determination. The Utilities believe they have submitted sufficient information to support a reasonableness finding, but accept the Commission s request for additional information regarding how D impacts the review of the cancellation costs. The Utilities will submit additional information in accordance with the scoping memo and schedule issued for the 2018 NDCTP. C. Corrections to PD The Utilities have identified one small error in Finding of Fact No. 1 regarding SONGS ownership interests that requires correction. Finding of Fact No. 1 states that SCE and SDG&E own approximately 78% and 20%, respectively, interests in SONGS. 6 This is not accurate. The correct SONGS ownership interests are provided on page 14 of the PD: (1) Footnote No. 33 SCE holds an 80% interest and SDG&E holds a 20% interest in SONGS 1 decommissioning liability; and (2) Footnote No. 35 SCE holds an approximately 75.74% interest, SDG&E holds a 20% interest, the City of Anaheim holds an approximately 2.47% interest, and the City of Riverside holds a 1.79% interest in SONGS 2&3 decommissioning liability, respectively. 7 Finding of Fact No. 1 should be changed to reflect the correct SONGS ownership interests reflected on page Proposed Decision, Finding of Fact No Proposed Decision, p. 14, fn. 33 and 35. 4

7 III. CONCLUSION For the reasons discussed above, the Utilities respectfully urge the Commission to adopt the PD as issued, with the exception of the one recommended change to Finding of Fact No. 1 listed in the Subject Index of Recommended Changes. FADIA KHOURY WALKER A. MATTHEWS III ALLEN K. TRIAL /s/ Walker A. Matthews By: Walker A. Matthews III /s/ Allen K. Trial By: Allen K. Trial Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) walker.matthews@sce.com Attorney for: SAN DIEGO GAS & ELECTRIC COMPANY 8330 Century Park Court, CP32D San Diego, CA Telephone: (858) Facsimile: (619) Atrial@semprautilities.com Dated: October 1,

8 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Joint Application of Southern California Edison Company (U 338-E) and San Diego Gas & Electric Company (U 902-E) For the 2015 Nuclear Decommissioning Cost Triennial Proceeding And Related Matters A (Filed March 1, 2016) A A 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) AND S (U 902-E) JOINT OPENING COMMENTS ON PROPOSED DECISION 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 specified parties who have provided an address. Placing the copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to the offices of the Commissioner(s) or other addressee(s).. ALJ Darcie Houck CPUC - Div of ALJs 300 Capitol Mall, Suite 518 Sacramento, CA Executed on October 1, 2018, at Rosemead, California. /s/ Edith Leon Edith Leon Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

9 CPUC - Service Lists - A Page 1 of 4 10/1/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON AND SDG&E - A FILER: LIST NAME: LIST LAST CHANGED: SEPTEMBER 10, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties WALKER A. MATTHEWS III RAYMOND LUTZ SENIOR NATIONAL COORDINATOR SOUTHERN CALIFORNIA EDISON COMPANY CITIZENS OVERSIGHT, INC WALNUT GROVE AVENUE, ROOM JAMACHA RD., NO. 148 ROSEMEAD, CA EL CAJON, CA FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: CITIZENS OVERSIGHT, INC. (AKA "CITIZENS OVERSIGHT PROJECTS" COPS) JANE KRIKORIAN, J.D. ALLEN K. TRIAL SUPERVISOR, ADV. & ADMIN. UTILITY CONSUMERS' ACTION NETWORK 3405 KENYON STREET, STE CENTURY PARK COURT SAN DIEGO, CA SAN DIEGO, CA FOR: UTILITY CONSUMERS' ACTION NETWORK FOR: (UCAN) MATTHEW FREEDMAN LINDSEY HOW-DOWNING STAFF THE UTILITY REFORM NETWORK LAW OFFICES OF LINDSEY HOW-DOWNING 785 MARKET STREET, 14TH FL 3060 EL CERRITO PLAZA, NO. 175 SAN FRANCISCO, CA EL CERRITO, CA FOR: TURN FOR: PACIFIC GAS AND ELECTRIC COMPANY JOHN L. GEESMAN WILLIAM MAGUIRE DICKSON GEESMAN LLP LEGAL DIVISION ONLY 180 Promenade Circle, Suite 115 ONLY, CA Sacramento, CA 95834

10 CPUC - Service Lists - A Page 2 of 4 10/1/2018 FOR: ALLIANCE FOR NUCLEAR RESPONSIBILITY FOR: ORA Information Only MARC D. JOSEPH ADAMS BROADWELL JOSEPH & CARDOZO ONLY ONLY, CA MARTHA GUZMAN ACEVES OFFICE OF COMMISSIONER GUZMAN ACEVES CPUC - EXEC. DIV. ONLY ONLY, CA MIKE CADE MRW & ASSOCIATES, LLC ALCANTAR & KAHL ONLY ONLY ONLY, CA ONLY, CA JAMES (JIM) VON RIESEMANN ARMAN TABATABAI MIZUHO SECURITIES USA, INC. RESEARCH 320 PARK AVENUE, 12TH FLOOR MORGAN STANLEY NEW YORK, NY BROADWAY, 38TH FL. NEW YORK, NY JIM KOBUS DANIEL W. DOUGLASS RESEARCH MORGAN STANLEY DOUGLASS & LIDDELL 1585 BROADWAY, 38TH FLOOR 4766 PARK GRANADA, STE. 209 NEW YORK, NY CALABASAS, CA FOR: ALLIANCE FOR RETAIL ENERGY MARKETS (AREM)/DIRECT ACCESS CUSTOMER COALITION (DACC)/WESTERN POWER TRADING FORUM (WPTF) CASE ADMINISTRATION GARY STERN SOUTHERN CALIFORNIA EDISON COMPANY MANAGING DIR WALNUT GROVE AVE. / PO BOX 800 SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA RUSH STREET ROSEMEAD, CA PAUL T. HUNT MARIA BYRNES DIRECTOR- REGULATORY FINANCE & ECONOMICS LEGAL ASSISTANT SOUTHERN CALIFORNIA EDISON COMPANY AGUIRRE & SEVERSON LLP 2244 WALNUT GROVE AVENUE 501 WEST BROADWAY, STE ROSEMEAD, CA SAN DIEGO, CA FOR: R. HENRICKS MARIA C. SEVERSON, ESQ. MICHAEL J. AGUIRRE, ESQ. AGUIRRE & SEVERSON LLP AGUIRRE & SEVERSON LLP 501 WEST BROADWAY, STE W. BROADWAY, STE SAN DIEGO, CA SAN DIEGO, CA FOR: RUTH HENRICKS FOR: R. HENDRICKS STEVEN C. NELSON COURTNEY COOK PARALEGAL

11 CPUC - Service Lists - A Page 3 of 4 10/1/2018 UTILITY CONSUMERS' ACTION NETWORK 488 8TH AVENUE, 9TH FLOOR 3405 KENYON STREET, SUITE 401 SAN DIEGO, CA SAN DIEGO, CA EMMA D. SALUSTRO JOHN F. WALSH 8330 CENTURY PARK COURT, CP32D 8330 CENTURY PARK COURT, CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: SHIVANI SIDHAR WENDY D. JOHNSON REGULATORY CASE MGR. REGULATORY BUSINESS MGR CENTURY PARK COURT, CP32F 8330 CENTURY PARK CT., CP32F SAN DIEGO, CA SAN DIEGO, CA REGULATORY CASE ANALYST CENTRAL FILES 8330 CENTURY PARK COURT, CP13E 8330 CENTURY PARK CT, CP31-E SAN DIEGO, CA SAN DIEGO, CA DONALD H. KORN JOE LOYA PRINCIPAL PACIFIC GAS AND ELECTRIC COMPANY DHK ASSOCIATES 77 BEALE STREET, RM. 1069, MC B10C 355 N SAN ANTONIO ROAD SAN FRANCISCO, CA LOS ALTOS, CA CALIFORNIA ENERGY MARKETS CASE COORDINATION 425 DIVISADERO ST. SUITE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA ONLY ONLY, CA State Service ERIC GREENE RACHEL PETERSON MARKET STRUCTURE, COSTS AND NATURAL GAS COMMISSIONER RANDOLPH AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA SCOTT LOGAN TRUMAN L. BURNS ENERGY COST OF SERVICE & NATURAL GAS BRA ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 4108 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA YAKOV LASKO DARCIE HOUCK ENERGY COST OF SERVICE & NATURAL GAS BRA DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM Capitol Mall

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