BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

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) RESPONSE TO THE JOINT MOTION OF THE AGRICULTURAL ENERGY CONSUMERS ASSOCIATION, CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION, CALIFORNIA MANUFACTURERS & TECHNOLOGY ASSOCIATION, CALIFORNIA CITY COUNTY STREET LIGHT ASSOCIATION, DIRECT ACCESS CUSTOMER COALITION, ENERGY PRODUCERS AND USERS COALITION, ENERGY USERS FORUM, FEDERAL EXECUTIVE AGENCIES, AND SOLAR ENERGY INDUSTRIES ASSOCIATION TO EXTEND THE PROCEDURAL SCHEDULE AND REQUEST TO SHORTEN TIME FOR REPLIES FADIA RAFEEDIE KHOURY JANE LEE COLE ROBIN MEIDHOF Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Jane.lee.cole@sce.com Dated: March 8, 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) RESPONSE TO THE JOINT MOTION OF THE AGRICULTURAL ENERGY CONSUMERS ASSOCIATION, CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION, CALIFORNIA MANUFACTURERS & TECHNOLOGY ASSOCIATION, CALIFORNIA CITY COUNTY STREET LIGHT ASSOCIATION, DIRECT ACCESS CUSTOMER COALITION, ENERGY PRODUCERS AND USERS COALITION, ENERGY USERS FORUM, FEDERAL EXECUTIVE AGENCIES, AND SOLAR ENERGY INDUSTRIES ASSOCIATION TO EXTEND THE PROCEDURAL SCHEDULE AND REQUEST TO SHORTEN TIME FOR REPLIES I. INTRODUCTION Pursuant to Rule 11.1(e) of the Rules of Practice and Procedure of the California Public Utilities Commission (Commission), Southern California Edison Company (SCE) hereby submits this Response to the Agricultural Energy Consumers Association (AECA), California Large Energy Consumers Association (CLECA), California Manufacturers & Technology Association (CMTA), California City County Street Light Association(CALSLA), Direct Access Customer Coalition (DACC), Energy Producers and Users Coalition (EPUC), Energy Users Forum (EUF), Federal Executive Agencies (FEA), and Solar Energy Industries Association s (SEIA) (collectively, the Joint Parties) motion for an extension of the procedural schedule set by the Scoping Memo and Ruling of the Assigned Commissioner, issued on November 22, 2017 (Joint Parties Motion). 1

3 II. DISCUSSION In their Motion, the Joint Parties seek an additional eight business days to review, explore and respond to the testimony of the Commission s Office of Ratepayer Advocates (ORA) because ORA s testimony was not made available to the parties until February 20, 2018 due to technical issues. 1 The Joint Parties also state that a delay is also warranted to provide intervenors adequate time to review ORA s work papers and seek clarifications and additional information using the data request process. 2 While SCE is sympathetic to the Joint Parties request for additional time to serve testimony, SCE also notes that ORA s testimony was served only one business day late (on February 20) due to technical difficulty since February 19 was a Commission-observed holiday. Thus, an eight-day extension is unwarranted in this case. Further, SCE would have preferred to meet and confer with the Joint Parties to develop a jointly agreed-upon schedule. However, since the Joint Parties request for a shortened three-day period for parties to reply to its Motion, SCE will not have the opportunity to meet and confer with the Joint Parties and instead proposes the following schedule: SCE s Proposed Procedural Schedule Revisions Event Original Schedule Date ORA Testimony served and submitted to 2/16/18 2/20/18 Supporting Documents Other Parties Testimony served and 3/16/18 3/23/18 submitted to Supporting Documents Public Participation Hearings March 2018 March 2018 Settlement Discussions March-June April-June 1 Joint Parties Motion at p Id. at p. 2. A SCE Response to Joint Motion.docx2

4 Given that ORA s testimony was served one day late, SCE believes a one-week extension for the Joint Parties to serve their testimony is reasonable. SCE does not take a position on the turn-around time needed for ORA to respond to data requests and defers to ORA on that issue. III. CONCLUSION SCE respectfully requests the Commission adopt its proposed schedule as set forth in this Response. Respectfully submitted, FADIA RAFEEDIE KHOURY JANE LEE COLE ROBIN MEIDHOF /s/ Jane Lee Cole By: Jane Lee Cole Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Jane.Lee.Cole@sce.com March 8, 2018 A SCE Response to Joint Motion.docx3

5 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) RESPONSE TO THE JOINT MOTION OF THE AGRICULTURAL ENERGY CONSUMERS ASSOCIATION, CALIFORNIA LARGE ENERGY CONSUMERS ASSOCIATION, CALIFORNIA MANUFACTURERS & TECHNOLOGY ASSOCIATION, CALIFORNIA CITY COUNTY STREET LIGHT ASSOCIATION, DIRECT ACCESS CUSTOMER COALITION, ENERGY PRODUCERS AND USERS COALITION, ENERGY USERS FORUM, FEDERAL EXECUTIVE AGENCIES, AND SOLAR ENERGY INDUSTRIES ASSOCIATION TO EXTEND THE PROCEDURAL SCHEDULE AND REQUEST TO SHORTEN TIME FOR REPLIES on all parties identified on the attached service list(s) A Service was effected by one or more means indicated below: Transmitting copies via to the Assigned ALJ and to all parties who have provided an address. ALJ Michelle Michelle.Cooke@cpuc.ca.gov 505 Van Ness Avenue San Francisco, CA Executed March 8, 2018, at Rosemead, California. /s/ Irene Gutierrez Irene Gutierrez Legal Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

6 Page 1 of 6 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - TO ESTABLIS FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: MARCH 5, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties 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 EVELYN KAHL COUNSEL - DEPT OF THE NAVY COUNSEL FEDERAL EXECUTIVE AGENCIES ALCANTAR & KAHL LLP NAVAL FACILITIES ENGINEERING COMMAND 345 CALIFORNIA ST., STE AVENUE OF THE PALMS, STE. 161 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ENERGY PRODUCERS AND USERS FOR: FEDERAL EXECUTIVE AGENCIES (FEA) COALITION (EPUC) JAMES BIRKELUND NORA SHERIFF PRESIDENT COUNSEL SMALL BUSINESS UTILITY ADVOCATES ALCANTAR & KAHL LLP 548 MARKET STREET, SUITE CALIFORNIA ST., STE. 2450

7 Page 2 of 6 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: SMALL BUSINESS UTILITY ADVOCATES FOR: CALIFORNIA LARGE ENERGY CONSUMERS (SBUA) ASSOCIATION 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 CALIFORNIA FARM BUREAU FEDERATION 2300 RIVER PLAZA DRIVE SACRAMENTO, CA FOR: CALIFORNIA FARM BUREAU FEDERATION Information Only

8 Page 3 of 6 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 DIRECTOR OF CA 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 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

9 Page 4 of 6 FOR: SMALL BUSINESS UTILITY ADVOCIATES (SBUA) SUE MARA KATY MORSONY CONSULTANT RTO ADVISORS, LLC ALCANTAR & KAHL LLP 164 SPRINGDALE WAY 345 CALIFORNIA STREET, STE REDWOOD CITY, CA SAN FRANCISCO, CA FOR: ENERGY PRODUCERS AND USERS COALITION (EPUC) LILLIAN RAFII MARC KOLB REGULATORY TESLA, INC. SMALL BUSINESS UTILITY ADVOCATES 3055 CLEARVIEW WAY 548 MARKET ST. SUITE SAN MATEO, CA SAN FRANCISCO, CA ALISON LECHOWICZ BARBARA R. BARKOVICH PRINCIPAL CONSULTANT LECHOWICZ & TSENG MUNICIPAL CONSULTANTS BARKOVICH & YAP, INC. PO BOX 3065 PO BOX OAKLAND, CA OAKLAND, CA FOR: CALIFORNIA STREETLIGHT ASSOC. FOR: CLECA CATHY YAP RACHEL BIRD BARKOVICH & YAP, INC. DIR - POLICY & BUS. DEVELOPMENT, WEST PO BOX BORREGO SOLAR SYSTEMS, INC. OAKLAND, CA ND STREET, SUITE 600 FOR: CLECA OAKLAND, CA R. THOMAS BEACH PHILLIP MULLER PRINCIPAL CONSULTANT PRESIDENT CROSSBORDER ENERGY SCD ENERGY SOLUTIONS TH ST., SUITE 213A 436 NOVA ALBION WAY BERKELEY, CA SAN RAFAEL, CA FOR: SOLAR ENERGY INDUSTRIES ASSOC WILLIAM MARCUS BETH OLHASSO MCPM ECONOMICS AGRICULTUAL ENERGY CONSUMERS ASSO. 618 COURT ST., STE. C 925 L STREET, SUITE 800 WOODLAND, CA SACRAMENTO, CA ANN L. TROWBRIDGE ANNE FALCON SR. ASSOCIATE DAY CARTER & MURPHY LLP EES CONSULTING, INC AMERICAN RIVER DR., STE KIRKLAND WAY, NO. 100 SACRAMENTO, CA KIRKLAND, CA FOR: AGRICULTURAL ENERGY CONSUMERS ASSOCIATION (AECA) State Service

10 Page 5 of 6 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 4209 EHREN SEYBERT ERIC DURAN COMMISSIONER PETERMAN ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5303 ROOM 4011 JUSTIN H. FONG LEE-WHEI TAN ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM AREA ROOM 4102 LOUIS M. IRWIN MASOUD FOUDEH ELECTRICITY PRICING AND CUSTOMER PROGRAM DEMAND RESPONSE, CUSTOMER GENERATION, AN ROOM 4209 AREA MATTHEW A. KARLE NATHAN CHAU ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4108 AREA PAUL S. PHILLIPS ROBERT LEVIN DEMAND RESPONSE, CUSTOMER GENERATION, AN ENERGY DIVISION AREA AREA BRIDGET SIEREN-SMITH DEMAND RESPONSE, CUSTOMER GENERATION, AN 180 Promenade Circle, Suite 115 Sacramento, CA 95834

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