BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Staff Proposal Concerning Revision or Repeal of General Orders and Utility Reporting Requirements. R.15-12-006 (Filed December 03, 2015 SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E REPLY COMMENTS FRANK A. MCNULTY ALLAN D. JOHNSON Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626 302-1499 Facsimile: (626 302-6693 E-mail: mcnultfa@sce.com Dated: January 25, 2016 LIMS-253-11872
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Staff Proposal Concerning Revision or Repeal of General Orders and Utility Reporting Requirements. R.15-12-006 (Filed December 03, 2015 SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E REPLY COMMENTS I INTRODUCTION Pursuant to the schedule adopted in this Rulemaking, Southern California Edison Company (SCE respectfully submits this reply to comments filed by the Office of Ratepayer Advocates (ORA and the Utility Reform Network (TURN on January 11, 2016, regarding the Solicitation for Input process. 1 II REPLY COMMENTS ORA acknowledges that there are benefits to eliminating or streamlining certain utility reporting requirements which may place unnecessary burdens on both utility and Commission resources, and that the OIR should be lauded for identifying opportunities for streamlining and/or eliminating utility reporting requirements which are outdated, duplicative, or could be met in a more 1 The OIR s schedule provides for initial comments to be filed 30 days from the date the Commission mailed the OIR and reply comments 45 days after mailing. The OIR was issued on December 11, 2015, making comments due on January 11, 2016 and reply comments due January 25, 2016. 1
efficient manner. 2 With those statements SCE is in complete agreement. The Commission should be commended for its efforts to streamline its regulation, particularly Commissioner Picker for spearheading this SFI process. However, ORA then states: the short term procedural savings arguably realized by the SFI process could be dwarfed by the long term problems the SFI process presents particularly if the SFI process is used to address more substantive issues. 3 TURN is less critical of the SFI than ORA, but submits that the SFI process should be evaluated so that the Commission can reap the benefits of this pilot program. 4 ORA s and TURN s concerns with the SFI process are exaggerated. First, the Solicitation for Input did nothing more than that solicit input. No changes to decisional requirements, General Orders, or other Commission rules were made based on the SFI alone. As noted in this OIR s Background section, after receiving responses to the SFI, the Commission first opened R.15-07-025 to consider repeal of three outdated General Orders that no party believed to be any longer relevant. R.15-07-025 was electronically sent to several service lists and posted on the Commission s website. Only after an opportunity for parties to comment did the Commission adopt D.15-08-034, which repealed the three outdated General Orders. The Commission followed R.15-07-034 with the present OIR, which proposed further updates and streamlining of Commission reporting requirements. This OIR was also widely served and several parties filed comments on it. Only after consideration of those comments and any replies on this OIR does the Commission plan to act. So the SFI itself made no changes and did not affect anyone s rights. ORA also complains that it was not served with the SFI. 5 SCE agrees that ORA should have been served with the SFI. However, ORA neglects to mention that: the SFI was published on the Commission website, 6 so was available to anyone with internet access. The additional examination of the SFI process proposed by ORA and TURN is unnecessary and would only consume more time and resources of the Commission and parties, which would be counter to the very purpose of the SFI streamlining Commission regulation. The SFI itself makes no 2 ORA comments, p. 2. 3 ORA comments, p. 2. 4 TURN comments, p. 2. 5 ORA comments, p. 2. 6 ORA comments, p. 2. 2
changes, it merely gathers information. The Commission can, if it chooses to, use that input to open a proceeding, but nothing about the SFI process compels that result. III CONCLUSION SCE commends the Commission and President Picker for initiating the Solicitation for Input (SFI process. Based on the first two OIRs that stemmed from the SFI, it has already improved and streamlined the Commission s regulatory process. The SFI process harms no one s substantive or procedural rights and should be retained as is. Respectfully submitted, FRANK A. MCNULTY ALLAN D. JOHNSON /s/ FRANK A. MCNULTY By: Frank A. McNulty Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626 302-1499 Facsimile: (626 302-6693 E-mail: mcnultfa@sce.com January 25, 2016 3
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Consider Staff Proposal Concerning Revision or Repeal of General Orders and Utility Reporting Requirements. R.15-12-006 (Filed December 03, 2015 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 COMMENTS on all parties identified on the attached service list(s R.15-12- 006. 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 copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to all parties for those listed on the attached non-email list. Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s or other addressee(s. ALJ Sophia Park CPUC 505 Van Ness Ave. San Francisco, CA 94102 Executed January 25, 2016, at Rosemead, California. /S/ Laura Velarde Laura Velarde SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770
CPUC - Service Lists - R1512006 https://ia.cpuc.ca.gov/servicelists/r1512006_83417.htm Page 1 of 3 1/25/2016 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: R1512006 - CPUC - OIR TO CONSID FILER: CPUC LIST NAME: LIST LAST CHANGED: JANUARY 15, 2016 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties JOHN R. ELLIS JESUS G. ROMAN ATTORNEY ASSISTANT GEN. COUNSEL - WEST REGION SOUTHERN CALIFORNIA GAS COMPANY VERIZON CALIFORNIA, INC. 555 WEST FIFTH STREET, GT14E7 2535 W. HILLCREST DRIVE, CAM21LB LOS ANGELES, CA 90013 NEWBURY PARK, CA 91320 FOR: SOUTHERN CALIFORNIA GAS COMPANY FOR: VERIZON ALLAN D. JOHNSON THOMAS R. BRILL SOUTHERN CALIFORNIA EDISON COMPANY SR COUNSEL & DIRECTOR PO BOX 800 SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE. 8330 CENTURTY PARK CT., CP32E ROSEMEAD, CA 91770 SAN DIEGO, CA 92123-1530 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: SAN DIEGO GAS & ELECTRIC COMPANY ERIC G. WOLFE DAVE CLARK EXE VP REGULATORY MANAGER DUCOR TELEPHONE COMPANY (1007 KERMAN TELEPHONE COMPANY PO BOX 42230 811 SOUTH MADERA AVENUE BAKERSFIELD, CA 93384-2230 KERMAN, CA 93630 FOR: DUCOR TELEPHONE COMPANY FOR: KERMAN TELEPHONE COMPANY DAVID CLARK LINDA BURTON REGULATORY MGR. SIERRA TELEPHONE COMPANY, INC. FORESTHILL TELEPHONE CO. PO BOX 219 811 S. MADERA AVE. OAKHURST, CA 93644-0219 KERMAN, CA 93630 FOR: SIERRA TELEPHONE COMPANY FOR: FORESTHILL TELEPHONE COMPANY DAN DOUGLAS JACK K. HAWKS MGR - REGULATORY CALIFORNIA WATER ASSOCIATION THE PONDEROSA TELEPHONE CO. (1014 601 VAN NESS AVE., STE. 2047, MC E3-608 47034 ROAD 201 / PO BOX 21 SAN FRANCISCO, CA 94102-3200 O'NEALS, CA 93645-0021 FOR: CALIFORNIA WATER ASSOCIATION FOR: THE PONDEROSA TELEPHONE COMPANY
CPUC - Service Lists - R1512006 https://ia.cpuc.ca.gov/servicelists/r1512006_83417.htm Page 2 of 3 1/25/2016 HAYLEY GOODSON NICOLE JOHNSON STAFF ATTORNEY STAFF ATTORNEY THE UTILITY REFORM NETWORK CONSUMER FEDERATION OF CALIFORNIA 785 MARKET ST., STE. 1400 150 POST ST., STE. 442 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94108 FOR: TURN FOR: CONSUMER FEDERATION OF CALIFORNIA STEVEN W. FRANK LORRIE BERNSTEIN LAW DEPARTMENT REGULATORY CONTACT PACIFIC GAS AND ELECTRIC COMPANY PINNACLES TELEPHONE COMPANY (1013 77 BEALE ST., B30A / PO BOXX 7442 3121 WEST MARCH LANE, SUITE 100 SAN FRANCISCO, CA 94120 STOCKTON, CA 95219-2303 FOR: PACIFIC GAS AND ELECTRIC COMPANY FOR: PINNACLES TELEPHONE COMPANY YVONNE SMYTHE EARL BISHOP CALAVERAS TELEPHONE COMPANY CHIEF FINANCIAL OFFICER PO BOX 37 VOLCANO TELEPHONE COMPANY (1019 COPPEROPOLIS, CA 95228 PO BOX 1070 FOR: CALAVERAS TELEPHONE COMPANY PINE GROVE, CA 95665 FOR: VOCANO TELEPHONE COMPANY WAIHUN YEE JAMES LOWERS CONTROLLER PRESIDENT CAL-ORE TELEPHONE COMPANY THE SISKIYOU TELEPHONE COMPANY (1017 PO BOX 847 PO BOX 157 DORRIS, CA 96023-0847 ETNA, CA 96027 FOR: CAL-ORE TELEPHONE FOR: THE SISKIYOU TELEPHONE GAIL LONG TELEPHONE COMPANY HAPPY VALLEY/HORNITOS/WINTERHAVEN PO BOX 1566 OREGON CITY, OR 97045 FOR: HAPPY VALLEY TELEPHONE COMPANY / HORNITOS TELEPHONE COMPANY / WINTERHAVEN TELEPHONE COMPANY Information Only BARBARA BARKOVICH JEAN HAWLEY CONSULTANT FRIEND, HUDAK& HARRIS, LLP BARKOVICH & YAP 3 RAVINIA DRIVE, SUITE. 1700 EMAIL ONLY ATLANTA, GA 30346-2131 EMAIL ONLY, CA 00000 KENNARD B. WOODS SHARON YANG FRIEND, HUDAK & HARRIS, LLP SR. COUNSEL 3 RAVINIA DRIVE, STE. 1700 SOUTHERN CALIFORNIA GAS COMPANY ATLANTA, GA 30346-2131 555 WEST FIFTH ST., STE. 1400, GT-14E7 LOS ANGELES, CA 90013 FRANCIS A. MCNULTY KELLEN C. GILL MANAGING ATTORNEY REGULATORY CASE ADMIN. SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 2244 WALNUT GROVE AVE. / PO BOX 800 8330 CENTURY PARK COURT, CP31D ROSEMEAD, CA 91770 SAN DIEGO, CA 92123 STEVEN LANGO PHILIP S. WEISMEHL REGULATORY AFFAIRS SAN DIEGO GAS & ELECTRIC COMPANY ORA - ADMINISTRATIVE BRANCH 8330 CENTURY PARK CT. AREA SAN DIEGO, CA 92123 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 TRACI BONE CHRISTINE A. MAILLOUX ATTORNEY AT LAW LEGAL DIVISION THE UTILITY REFORM NETWORK ROOM 5027 785 MARKET ST., STE. 1400 505 VAN NESS AVENUE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-3214
CPUC - Service Lists - R1512006 https://ia.cpuc.ca.gov/servicelists/r1512006_83417.htm Page 3 of 3 1/25/2016 MARGARET L. TOBIAS ADELA CHAN TOBIAS LAW OFFICE AT&T SERVICES, INC. 460 PENNSYLVANIA AVE 430 BUSH ST., ROOM 105, CUBE NO. 1 SAN FRANCISCO, CA 94107 SAN FRANCISCO, CA 94108 FOR: AT&T CALIFORNIA BRENDA J. CLARK ROGER MOFFITT DIR - REGULATORY RELATIONS AT&T SERVICES, INC. AT&T SERVICES, INC. 430 BUSH STREET, 1ST FLOOR 430 BUSH STREET, RM. 105 SAN FRANCISCO, CA 94108 SAN FRANCISCO, CA 94108 KATIE JORRIE LORI ANNE DOLQUEIST, ESQ DAVIS WRIGHT TREMAINE, LLP ATTORNEY AT LAW 505 MONTGOMERY STREET, SUITE 800 NOSSAMAN LLP SAN FRANCISCO, CA 94111 50 CALIFORNIA STREET, 34TH FLR SAN FRANCISCO, CA 94111 VIDHYA PRABHAKARAN ZEB ZANKEL DAVIS WRIGHT TREMAINE LLP ATTORNEY 505 MONTGOMERY STREET, STE. 800 DAVIS WRIGHT TREMAINE, LLP SAN FRANCISCO, CA 94111 505 MONTGOMERY ST., STE. 800 SAN FRANCISCO, CA 94111 DAVIS WRIGHT TREMAINE LLP MARTIN A. MATTES 505 MONTGOMERY STREE, SUITE 800 ATTORNEY SAN FRANCISCO, CA 94111 NOSSAMAN, LLP 50 CALIFORNIA STREET, 34TH FL. SAN FRANCISCO, CA 94111-4799 SUZANNE TOLLER THOMAS SELHORST ATTORNEY AT LAW SENIOR PARALEGAL DAVIS WRIGHT TREMAINE LLP AT&T SERVICES, INC. 505 MONTGOMERY STREET, SUITE 800 2150 WEBSTER STREET, 8TH FLOOR SAN FRANCISCO, CA 94111-6533 OAKLAND, CA 94612 State Service APRIL MULQUEEN KAYODE KAJOPAIYE POLICY & PLANNING DIVISION UTILITY AUDIT, FINANCE & COMPLIANCE BRAN AREA 5-A ROOM 3105 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 SOPHIA PARK DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 5130 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS
Kayode Kajopaiye UTILITY AUDIT, FINANCE & COMPLIANCE BRANCH 505 VAN NESS AVENUE, ROOM 3105 SAN FRANCISCO, CA 94102-3214 List of Non Email Recipients