BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Authority, Among Other Things, to Increase Rates and Charges for Electric and Gas Service Effective on January 1, 2020. (U39M) Application 18-12-009 RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO TEST YEAR 2020 GENERAL RATE CASE APPLICATION OF PACIFIC GAS AND ELECTRIC COMPANY I. INTRODUCTION Pursuant to Rule 2.6 of the California Public Utilities Commission s (Commission) Rules of Practice and Procedure (Rules), Southern California Edison Company (SCE) respectfully files this response to the application of Pacific Gas and Electric Company (PG&E) for a 2020 General Rate Case (GRC). II. DISCUSSION Rule 1.4 states that a person may become a party to a proceeding by, among other methods, filing a protest or response to an application. Via this response to PG&E s application for a 2020 GRC, SCE asks for party status in the proceeding. Responses to applications are governed by Rule 2.6. Rule 2.6(a) states: Unless otherwise provided by rule, decision, or General Order, a protest or response must be filed within 30 days of the date the notice of the filing of the application first appears in the Daily Calendar. 1

Notice of the filing of this application first appeared on the Commission s Daily Calendar on December 18, 2018. Accordingly, this response is timely filed. Rule 2.6(c) states: Any person may file a response that does not object to the authority sought in an application, but nevertheless presents information that the person tendering the response believes would be useful to the Commission in acting on the application. SCE has actively participated in numerous prior PG&E GRCs by submitting rebuttal testimony, briefs, and comments on proposed decisions. In prior PG&E GRCs to which SCE was a party, the legal and factual contentions SCE made were based on the positions taken by other intervenors. At this early juncture in the proceeding, SCE has not identified any specific issues regarding PG&E s application. SCE notes that issues surrounding cost recovery for activities and efforts to address wildfire risks are of common interest (and are of crucial importance) to both SCE and PG&E. In addition, SCE has recently filed its Risk Assessment Mitigation Phase (RAMP) showing, 1 and in 2019 SCE will be preparing and filing its own risk-informed GRC application. Thus, issues raised in PG&E s GRC risk showing, such as utilizing risk quantification to justify cost recovery requests, are of common interest to SCE and PG&E. This is particularly true because RAMP is an evolving process for all three large electric investor-owned utilities; each utility s RAMP showing to an extent builds off of the other utilities most recent RAMP showings. Based on its experience with prior PG&E GRCs, SCE expects to submit rebuttal testimony or briefs on issues raised by other intervenors. Thus, SCE believes it will be able to present information that would be useful to the Commission in acting on the application. Finally, Rule 2.6(d) states: Any person protesting or responding to an application shall state in the protest or response any comments or objections regarding the applicant s statement on the proposed category, need for hearing, issues to be considered, and proposed 1 See I.18-11-006. 2

schedule. Any alternative proposed schedule shall be consistent with the proposed category, including a deadline for resolving the proceeding within 12 months or less (adjudicatory proceeding) or 18 months or less (ratesetting or quasilegislative proceeding). SCE has no comments or objections regarding PG&E s proposed category, need for hearings, issues to be considered, or proposed schedule, and is not proposing any alternative schedule. III. CONCLUSION By virtue of this response, pursuant to Rule 1.4, SCE asks to become a party to this proceeding. Respectfully submitted, FADIA RAFEEDIE KHOURY KRIS G. VYAS January 17, 2019 /s/ Kris G. Vyas By: Kris G. Vyas Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6613 Facsimile: (626) 302-1910 E-mail: Kris.Vyas@sce.com 3

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Pacific Gas and Electric Company for Authority, Among Other Things, to Increase Rates and Charges for Electric and Gas Service Effective on January 1, 2020. (U39M) Application 18-12-009 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 RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO TEST YEAR 2020 GENERAL RATE CASE APPLICATION OF PACIFIC GAS AND ELECTRIC COMPANY on all parties identified on the attached service list(s) A.18-12-009. Service was effected by one or more means indicated below: Transmitting the copies via e-mail to all parties who have provided an e-mail address. Placing the copies in sealed envelopes and causing such envelopes to be delivered by U.S. Mail to the offices of the ALJ(s) or other addressee(s). ALJ Elaine Lau California Public Utilities Commission Division of ALJs 505 Van Ness Avenue San Francisco, CA 94102 ALJ Rafael L. Lirag California Public Utilities Commission Division of ALJs, Room 5010 505 Van Ness Avenue San Francisco, CA 94102-3214 Executed on January 17, 2019, at Rosemead, California. /s/ Regina Coburn Regina Coburn Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

CPUC - Service Lists - A1812009 https://ia.cpuc.ca.gov/servicelists/a1812009_86236.htm Page 1 of 3 1/17/2019 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A1812009 - PG&E - TO INCREASE R FILER: PACIFIC GAS AND ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: JANUARY 11, 2019 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties MARY A. GANDESBERY PACIFIC GAS AND ELECTRIC COMPANY 77 BEALE STREET, B30A / PO BOX 7442 SAN FRANCISCO, CA 94120 FOR: PACIFIC GAS AND ELECTRIC COMPANY Information Only CONOR SKELDING JESSIE CROZIER REORG LUMINUS MANAGEMENT 11 E 26TH STREET, 12TH FL. 1700 BROADWAY, 26TH FL. NEW YORK, NY 10010 NEW YORK, NY 10019 EDWIN GUYANDI BLAKE ELDER NEWTYN MANAGEMENT POLICY RESEARCH ANALYST 405 PARK AVENUE, SUITE 1104 EQ RESEARCH NEW YORK, NY 10022 1155 KILDAIRE FARM ROAD, SUITE 203 CARY, NC 27511 JENNY AU JOAN WEBER OFFICE OF THE SAFETY ADVOCATE OFFICE OF THE SAFETY ADVOCATE 320 West 4th Street Suite 500 320 West 4th Street Suite 500 Los Angeles, CA 90013 Los Angeles, CA 90013

CPUC - Service Lists - A1812009 https://ia.cpuc.ca.gov/servicelists/a1812009_86236.htm Page 2 of 3 1/17/2019 JEREMY WAEN SUE MARA MGR. - REGULATORY AFFAIRS CONSULTANT PENINSULA CLEAN ENERGY RTO ADVISORS, L.L.C. 2075 WOODSIDE RD. 164 SPRINGDALE WAY REDWOOD CITY, CA 94061 REDWOOD CITY, CA 94062 MILES MAURINO DANIEL WILLIS ADAMS BROADWELL JOSEPH & CARDOZO SR. ANALYST 601 GATEWAY BLVD., STE. 1000 SAN FRANCISCO PUC SOUTH SAN FRANCISCO, CA 94080 525 GOLDEN STATE AVE. SAN FRANCISCO, CA 94102 ROSS NAKASONE CHRISTOPHER PARKES PLANNING & REGULATORY COMPLIANCE SAN FRANCISCO PUBLIC UTILITES COMMISSION OFFICE OF THE SAFETY ADVOCATE 525 GOLDEN GATE AVE., 7TH FL. AREA 2-D SAN FRANCISCO, CA 94102 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 JULIA ENDE PUI-WA LI MARKET STRUCTURE, COSTS AND NATURAL GAS ENERGY SAFETY & INFRASTRUCTURE BRANCH ROOM 4011 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 RAFAEL L. LIRAG YAKOV LASKO DIVISION OF ADMINISTRATIVE LAW JUDGES ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 5010 ROOM 4101 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 ELIZABETH KELLY IVAN R. JIMENEZ REGULATORY BRISCOE IVESTER & BAZEL, LLP SMALL BUSINESS UTILITY ADVOCATES 155 SANSOME STREET, 7TH FL. 548 MARKET STREET, STE. 11200 SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104 KENNETH ARNOLD MICHAEL CADE SR CASE MGR BUCHALTER, A PROFESSIONAL CORPORATION PACIFIC GAS AND ELECTRIC COMPANY 55 SECOND STREET, SUITE 1700 77 BEALE STREET, B23A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 SHILPA RAMAIYA CASE COORDINATION DIR - REGULATORY AFFAIRS PACIFIC GAS AND ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY 77 BEALE STREET, B9A EMAIL ONLY, CA 94105-4159 SAN FRANCISCO, CA 94105 JEANNE B. ARMSTRONG GOODIN MACBRIDE SQUERI & DAY LLP MEGAN SOMOGYI GOODIN, MACBRIDE, SQUERI & DAY, LLP

CPUC - Service Lists - A1812009 https://ia.cpuc.ca.gov/servicelists/a1812009_86236.htm Page 3 of 3 1/17/2019 505 SANSOME STREET, SUITE 900 505 SANSOME STREET, STE. 900 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111 ALISON LECHOWICZ TIM LINDL PRINCIPAL PARTNER LECHOWICZ & TSENG MUNICIPAL CONSULTANTS KEYES & FOX LLP PO BOX 3065 436 14TH STREET, SUITE 1305 OAKLAND, CA 94609 OAKLAND, CA 94612 PHILLIP MULLER MICHAEL ZELAZO SCD ENERGY SOLUTIONS 436 NOVA ALBION WAY MARKET STRUCTURE, COSTS AND NATURAL GAS SAN RAFAEL, CA 94903 770 L Street, Suite 1250 Sacramento, CA 95814 REGULATORY CLERK SCOTT BLAISING BRAUN BLAISING SMITH WYNNE, PC 915 L STREET, STE. 1480 BRAUN BLAISING SMITH WYNNE, PC SACRAMENTO, CA 95814 915 L STREET, STE. 1480 SACRAMENTO, CA 95814 LYNN HAUG ANDREW B. BROWN AT LAW ELLISON SCHNEIDER HARRIS & DONLAN LLP ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVE., STE. 400 2600 CAPITAL AVENUE, SUITE 400 SACRAMENTO, CA 95816 SACRAMENTO, CA 95816-5905 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS