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 PHASE 2 & 3 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: November 19, 2018

2 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) AND SAN DIEGO GAS & ELECTRIC COMPANY S (U 902-E) JOINT OPENING COMMENTS ON PHASE 2 & 3 PROPOSED DECISION TABLE OF CONTENTS Section Page I. INTRODUCTION AND SUMMARY OF PHASE 2 & 3 PROPOSED DECISION...1 II. DISCUSSION...3 A. The Commission s Final Decision Should Approve The $35.7 Million Included In The 2016 SONGS 1 DCE For Removing The SONGS 1 Conduits...3 B. The Commission s Final Decision Should Approve The $112.2 Million Adjustment Included In The 2016 PVNGS DCE For LLRW Disposal...6 C. Other Comments Certain Requirements Should Not Apply In 2018 NDCTP The 45-Day Time Period For Parties To Meet Regarding The Content Of Advice Letters Should Be Extended Other Corrections to PD...8 III. CONCLUSION...9 APPENDIX A PROPOSED CONCLUSIONS OF LAW AND FINDINGS OF FACT i-

3 SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) AND SAN DIEGO GAS & ELECTRIC COMPANY S (U 902-E) JOINT OPENING COMMENTS ON PHASE 2 & 3 PROPOSED DECISION TABLE OF AUTHORITIES Authority Page CPUC Decisions D D D D , 6 D CPUC Rules of Practice and Procedure Rule , 3 Rule 14.3(c) ii-

4 Subject Index of Recommended Changes SCE and SDG&E respectfully recommend that the Commission adopt the following changes in its final decision: Approve the $35.7 million included in the 2016 San Onofre Nuclear Generating Station (SONGS) 1 Decommissioning Cost Estimate (DCE) for removing the SONGS 1 intake / discharge conduits. Approve the $112.2 million adjustment included in the 2016 Palo Verde Nuclear Generating Station (PVNGS) DCE for Low Level Radioactive Waste (LLRW) disposal. * Clarify that the following requirements do not apply in the 2018 NDCTP: o Requirement for the Utilities to compare updated DCEs that will be submitted in future NDCTPs to the DCEs that were approved in the two prior NDCTPs o Requirement for SCE to update its cost categorization structure for tracking expenditures and submit testimony on the revised cost categorization as testimony in the 2018 NDCTP. Eliminate the 45-day time period for the parties to meet with Energy Division and interested parties regarding the content of advice letters, and replace it with an April 1, 2019 deadlines for the parties to complete discussions. The final decision also should direct SCE to provide a summary of the resolution or status of discussions in an advice letter filing or other submittal, as directed by Energy Division. Correct various typographical errors listed in Section II.C.3 of these comments. Adopt the proposed Findings of Fact and Conclusions of Law provided in Appendix A. Note: * The recommendation regarding the PVNGS DCE is provided by SCE only, and does not pertain to SDG&E, which does not own an interest in the Palo Verde Nuclear Generating Station. -iii-

5 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 PHASE 2 & 3 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 (SDG&E) (collectively referred to as the Utilities ) respectfully submit the following comments on Administrative Law Judge (ALJ) Darcie L. Houck s Phase 2 and 3 proposed decision (PD) for the above-referenced proceeding. I. INTRODUCTION AND SUMMARY OF PHASE 2 & 3 PROPOSED DECISION The issues addressed in Phases 2 & 3 included the Commission s reviews of: Phase 2 (1) 2016 San Onofre Nuclear Generating Station Unit No. 1 (SONGS 1) decommissioning cost estimate (DCE) of $239.4 million (100% Share, 2014$); and the Utilities request to maintain annual contributions to their respective SONGS 1 nuclear decommissioning trusts (NDTs) at $0.00 (zero); (2) 2016 Palo Verde Nuclear Generating Station (PVNGS) DCE of $608.3 million (SCE Share, 2016$); and the SCE s request to maintain annual contributions to its respective PVNGS NDT at $0.00 (zero); and 1

6 (3) Major project / milestone reasonableness review framework for SONGS decommissioning costs. Phase 3 (1) SONGS Unit Nos. 2&3 (SONGS 2&3) decommissioning costs of $136.1 million and $221.6 million (100% Share, Nominal $), respectively; and (2) Utilities compliance with prior Commission decisions. For Phase 2 issues, the PD determines that the 2016 SONGS 1 DCE and 2016 PVNGS DCE were generally reasonable with certain reductions, and approves maintaining annual contributions for the Utilities respective NDTs at $0.00. For the SONGS 1 DCE, the PD proposes excluding $35.7 million included for fully removing the SONGS 1 intake/discharge conduits. For the 2016 PVNGS DCE, the PD proposes excluding a $112.2 million adjustment for Low Level Radioactive Waste (LLRW) disposal that SCE included to the PVNGS decommissioning cost report prepared by TLG. In addition, the PD adopts the milestone framework jointly proposed by the parties for governing the scope and timing of reasonableness reviews of SONGS 2&3 decommissioning activities and costs in future Nuclear Decommissioning Costs Triennial Proceedings (NDCTPs). For Phase 3 issues, the PD finds as reasonable the SONGS 2&3 decommissioning costs of $136.1 million and $221.6 million submitted for review, respectively. The PD also determines that the Utilities have complied with prior Commission decisions. In addition to these findings, the PD directs the Utilities to compare updated DCEs that will be submitted in future NDCTPs with the DCEs approved in the two prior NDCTPs. Finally, the PD also directs the Utilities to meet with Energy Division and interested parties to discuss the following issues: (1) potential modifications to the annual Tier 2 advice letter process for requesting NDT disbursements and reporting recorded decommissioning costs; and (2) SCE s practices of recording SONGS staff to undistributed activities versus distributed activities. The Utilities generally support the PD. 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. In these comments, the Utilities respectfully request the Commission correct legal errors in the following two PD findings: (1) exclusion of SONGS 1 conduit removal costs from the 2016 SONGS 1 2

7 DCE; and (2) exclusion of the LLRW adjustment from the 2016 PVNGS DCE. 1 The Utilities also identify various corrections to the PD; request that certain requirements not apply in the 2018 NDCTP; and request that the Commission extend the deadline for meeting with Energy Division and interested parties regarding possible modifications to the Tier 2 advice letter process. The Utilities discuss these issues in further detail below. II. DISCUSSION Rule 14.3 provides that comments shall focus on factual, legal, or technical errors in the proposed or alternate decision and in citing such errors shall make specific references to the record or applicable law. 2 The Utilities comments adhere to this requirement. A. The Commission s Final Decision Should Approve The $35.7 Million Included In The 2016 SONGS 1 DCE For Removing The SONGS 1 Conduits The PD proposes excluding $35.7 million from the 2016 SONGS 1 DCE for the cost of fully removing the SONGS 1 conduits. 3 The PD finds that the the Utilities do not sufficiently explain why this item was not included in prior DCEs,... nor the basis for the amount given it is speculative as to whether the conduit will or will not have to be removed. 4 This finding is based on factual and legal error that should be corrected in the Commission s final decision. The basis for including estimated SONGS 1 conduit removal costs in the 2016 SONGS 1 DCE should not depend on whether or not the costs were included in prior DCEs; nor should it depend on whether the conduits will or will not actually have to be removed. Both Decision (2015 NDCTP Phase 1 Decision) and the pending PD confirm the principle that the mere failure to include costs in prior DCEs should not serve as a basis for disallowing costs included in an updated DCE correcting the prior omissions. 5 Adhering to this principle, the PD correctly determines that it is 1 The comments made regarding the PVNGS DCE are provided by SCE only, and do not pertain to SDG&E, which does not own an interest in the Palo Verde Nuclear Generating Station. 2 Commission Rule 14.3(c). 3 PD, p PD, p D , p. 42 (noting that the 2016 SONGS 1 DCE corrects errors in prior DCE templates); PD, p. 26 (noting the circular nature of TURN s argument that certain expenses in Phase 1 should have been disallowed 3

8 appropriate to approve costs (e.g., NRC fees, insurance fees, groundwater protection costs) omitted in prior DCEs because the costs were necessary to meet regulatory requirements. 6 The Commission also should follow that established principle in regard to the SONGS 1 conduits. Accordingly, the basis for including SONGS 1 conduit removal costs in the 2016 SONGS 1 DCE should be whether the Utilities have a continuing financial obligation to remove the SONGS 1 conduits under existing regulatory requirements. Because the Utilities have such an obligation under its lease with the California State Lands Commission (CSLC), the costs should appropriately be included in the SONGS 1 DCE. The evidentiary record supports this conclusion. 7 Exhibit SCE-13 attaches copies of the 2005 and 2015 lease amendments confirming the obligation. Both amendments indicate that the Utilities will be required to either: (1) remove the conduits at any point in the future, if deemed to become a public safety hazard by CSLC, and (2) provide sufficient financial assurance to guarantee faithful performance of the Lease Termination Agreement (which will also include removal of the conduits if directed to do so): 8 The termination of PRC and permanent disposition of the authorized facilities will be pursuant to a future Lease Termination Agreement that will detail Lessee s obligations and responsibilities for any abandoned facilities, including but not limited to, Lessee s commitment to respond to any claims arising from the abandoned facilities; removal of any remaining facilities to the extent they become a public safety hazard at any time in the future; and Lessee s obligation to provide sufficient financial assurance to guarantee faithful performance of the Lease Termination Agreement (emphasis added). For either circumstance, the Utilities must maintain adequate funds to cover full removal of the conduits for so long as the conduits remain in place. Whether or not the conduits will or will not actually need to be removed based upon a future determination by the CSLC has no bearing on the Utilities legal obligation to maintain sufficient funds to cover the cost of full removal. Nor does the fact that the Lease Termination Agreement remains to be negotiated. The Utilities have a legal obligation to remove the conduits if the CSLC requires them to be removed and that requirement will continue in any new Lease Termination Agreement to be negotiated. Therefore, it is appropriate to include estimated removal costs in the SONGS 1 DCE. because they were omitted from the DCE, but arguing that the same items should be excluded from an updated DCE because they were not included in the prior DCE). 6 PD, p Exhibit SCE-4, p. 4; SCE-13, p. 6; see also SCE Opening Brief at p. 16; SDG&E Opening Brief at pp Exhibit SCE-13, Appendix 4, pp. 4-5 and

9 The PD defers including SONGS 1 conduit-removal costs in the SONGS 1 DCE until the Utilities and CSLC have reached final terms on either a new lease extension or a lease termination agreement regarding the conduits. The PD contradicts established Commission precedent, as the Commission has historically approved including costs in DCEs for activities that remain subject to future landowner determinations. For example, the estimated costs included in the 2016 SONGS 1 DCE for removing the SONGS 1 conduits (subject to the CSLC s future determination) is fundamentally no different than the estimated costs included in the approved 2014 SONGS 2&3 DCE for full removal of all SONGS 2&3 subsurface structures (subject to the Navy s future determination). 9 In D , the Commission considered TURN s recommendations that the SONGS 2&3 DCE could be reduced based upon the renegotiation of the site termination (subsurface structure removal) requirements in SCE s lease with the U.S. Navy. 10 The Commission rejected adopting any reductions, stating that while known and quantifiable decommissioning cost reductions should be promptly incorporated into the Decommissioning Cost Estimate..., the potential sources of such reductions offered by TURN are not sufficiently certain to be incorporated into the Estimate. The same reasoning should apply here in regard to the SONGS 1 conduits. While there is some uncertainty as to what the final removal cost will be, and indeed, whether it will ultimately be incurred, there is no uncertainty as to the Utilities continuing obligation to incur the costs if required by the landowner. In such cases, the Commission has expressly rejected reducing DCEs based on postulated cost reductions, and has approved including the costs in the DCE so as to avoid the risk of the NDTs being underfunded. 11 Based on this precedent, it would be error for the Commission to exclude from the 2016 SONGS 1 DCE the costs to fully remove the SONGS 1 conduits. For these reasons, the Utilities request that final decision not exclude $35.7 million included in the 2016 SONGS 1 DCE for removing the SONGS 1 intake/discharge conduits. As explained above, the Utilities established that they remain obligated for removing the SONGS 1 conduits under their lease with the CSLC. In addition, the removal costs should be included in the SONGS 1 DCE, consistent with 9 D (approving the 2014 SONGS 2&3 DCE that included costs to fully remove all subsurface structures, pending the U.S. Navy s final site restoration requirements). 10 In D , the Commission also declined to reduce the 2014 SONGS 2&3 DCE to reflect additional speculative cost reductions suggested by TURN, including those resulting from damage payments from the U.S. government for delay in removal of the spent nuclear fuel from the site and the possibility of relief from the California Coastal Commission (CCC). 11 D , p

10 Commission precedent in prior NDCTP decisions in which the Commission has approved including other similar removal costs (i.e., SONGS 2&3 conduits, SONGS 1 and 2&3 substructures). 12 B. The Commission s Final Decision Should Approve The $112.2 Million Adjustment Included In The 2016 PVNGS DCE For LLRW Disposal The PD proposes excluding a $112.2 million adjustment that SCE included in the 2016 PVNGS DCE. 13 The PD concludes that SCE did not meet its burden to support the adjustment because SCE: (1) failed to sufficiently address its recent experience with packaging and shipping SONGS 2&3 legacy waste; (2) relied exclusively on prior experience at SONGS 1; (3) only argued that the new adjustment should be approved because prior adjustments have been approved; and (4) relied solely on a comparison with the last SONGS 2&3. 14 The PD errs in reaching these conclusions, as the evidentiary record establishes that SCE appropriately considered and addressed each of the four issues highlighted in the PD. SCE explained in Exhibit SCE-05 how the LLRW adjustment was determined. 15 The adjustment was based on a factor developed by ABZ to correct for LLRW estimating errors. 16 In Exhibit SCE-13, SCE further explained that its decision to apply the adjustment to the 2016 PVNGS DCE was not based solely on any single factor, and instead was based on engineering judgment that considered, among other things, SONGS 1 decommissioning experience and the estimated LLRW volumes included in the Commission-approved SONGS 2&3 DCE. 17 SCE explained that because Palo Verde and SONGS 2&3 12 D , pp (approving 2014 SONGS 2&3 DCE and rejecting TURN s recommendation for cost reductions); D (2012 NDCTP Decision), p. 53 (approving the SONGS 1 DCE, including costs accounting for the unknown extent of U.S. Navy-required remediation and future environmental requirements for final site restoration ), and p. 53 (approving the SONGS 2&3 DCE while noting in Finding of Fact No. 11 that the U.S. Navy final site restoration requirements remain undecided); D , p. 25, fn. 21 (2009 NDCTP Decision) (approving SONGS 1 and SONGS 2&3 DCEs that included conservative assumptions regarding the amount of material that would need to be removed in light of existing uncertainties regarding the U.S. Navy s final standards for site restoration); see also D , (approving PG&E s addition of costs in the Humboldt DCE for full removal of the Humboldt caisson to reflect the most current site information and address future liability risks). 13 PD, pp The PD does not include an ordering paragraph expressly adopting the PVNGS DCE. The Commission should add a paragraph (similar to OP 1). 14 Id. 15 Exhibit SCE-05, pp Id. ABZ is an independent, third-party decommissioning expert. Id.; see also D , p. 58 (acknowledging that ABZ is a recognized expert in nuclear decommissioning costs). 17 Exhibit SCE-13, p

11 are similarly sized, the estimated LLRW waste volumes for each unit should also be similar. 18 SCE further explained why it was inappropriate to reduce the adjustment based on SONGS 2&3 legacy waste volumes. The legacy waste volume was small and utilizing this experience would have been extremely flawed. 19 SCE requests that the final decision not exclude the $112.2 million adjustment to the 2016 PVNGS DCE for LLRW disposal. Contrary to the PD s findings, SCE considered and addressed the appropriate factors in making the adjustment. The adjustment is supported by an expert, third-party decommissioning estimator, ABZ. 20 In addition, excluding the adjustment would be inconsistent with the LLRW volumes the Commission approved as a reasonable estimate in the 2014 SONGS 2&3 DCE. To correct these errors and inconsistency, the Commission should approve the LLRW adjustment that SCE made in the 2016 Palo Verde DCE. C. Other Comments 1. Certain Requirements Should Not Apply In 2018 NDCTP The PD requires the Utilities to compare updated DCEs that will be submitted in future NDCTPs to the DCEs that were approved in the two prior NDCTPs (e.g., compare a DCE submitted in the 2021 NDCTP to the DCEs approved in the 2015 and 2018 NDCTPs). 21 In addition, the PD requires SCE to update its cost categorization structure for tracking expenditures and submit testimony on the revised cost categorization as testimony in the 2018 NDCTP. 22 The Utilities jointly request that the Commission clarify in its final decision that these requirements do not apply to the 2018 NDCTP. Applying these requirements in the 2018 NDCTP would require the Utilities to submit new testimony providing the DCE comparisons and revised cost categorizations, and would substantially delay the 2018 NDCTP. In addition, in regard to comparing DCEs, the Utilities would also be required to compare the current DCEs (prepared by the Kenrich Group) to DCEs with a different format (prepared by ABZ). Such comparisons will create undue confusion. 18 Id. 19 Id. 20 Exhibit SCE-05, pp PD, p. 59, Section H. 22 PD, OP #11. 7

12 The Utilities will be able to submit testimony providing DCE comparisons in the 2021 and future NDCTPs. After the Utilities meet with Energy Division and interested parties to discuss cost categorization issues, the Utilities will be able to submit a summary of the resolution or status of discussions in an advice letter or other filing, as directed by Energy Division. 2. The 45-Day Time Period For Parties To Meet Regarding The Content Of Advice Letters Should Be Extended The PD requires the parties to meet with Energy Division and interested parties within 45 days of the issuance of a final decision to discuss what if any modifications to the Tier 2 Advice Letter process should be made. The Utilities respectfully request that the final decision not specify a 45-day time period for the meeting, given anticipated schedule issues (SONGS tour, and intervenor and utility testimony in the 2018 NDCTP) and the challenges of scheduling a meeting with multiple parties during the December-January holiday period. The Utilities recommend that the final decision instead direct that the meetings should be completed by April 1, 2019, which will allow any modifications to be incorporated before the Utilities submit their Tier 2 advice letter in April 2019 reporting recorded costs for The final decision also should direct SCE to provide a summary of the resolution or status of discussions in an advice letter filing or other submittal, as directed by Energy Division. 3. Other Corrections to PD The Utilities have identified the following small typographical, grammatical, and other miscellaneous errors that should be corrected in the final decision: Page Number Pages 2 and 3 -- The PD provides an incorrect amount for removing the SONGS 1 intake/discharge conduits on page 3. The correct amount is in the remainder of the PD. Page 3 -- The PD provides an incorrect amount for the amount of 2014 SONGS 2&3 decommissioning costs found reasonable. The correct amount is provided in footnote 64. Pages 5 and 6 The PD states the Utilities stated that they would provide additional testimony. The PD, however, does not note the testimony was actually served. Proposed Revisions Proposed revision to pages 2 and 3 (consistent with Utilities comment that the removal costs should be allowed) We disallow the cost estimate for full removal of the SONGS 1 intake/discharge conduits in the amount of $37.4 million$35.7 million. Proposed revision to page 3 This decision finds $ million. Proposed insert to page 8 following paragraph 4 On February 17, 2017, the Utilities served supplemental testimony. On March 3, 2017, SDG&E filed an updated Application to 8

13 Page Number Page 12 Footnote 17 misstates the amount reviewed for the ISFSI Pad Study. The correct amount is noted on page 40, footnote 94. Page 30 and 31 The comparison of the market and net liquidation value of SCE s SONGS 1 nuclear decommissioning trusts (NDTs) to the SONGS 1 DCE amount is incorrect because it compares SCE share to 100% share. Footnote 7 notes SCE s share of SONGS 1 costs is 80%. Page The text of the PD on page 43 should be corrected so as to clarify the Commission s expectations: Page 45 There is a typographical error in Paragraph 1. Page 68 There is a typographical error in Finding of Fact (FOF) No. 4. Page 69 There is a typographical error in FOF No. 13. Page 75 The PD does not expressly adopt the 2016 PVNGS DCE. Pages 76 and 77 Ordering Paragraphs (OP) Nos. 4-5 duplicate OP Nos. 9 and 10. Proposed Revisions provide an updated relief section in the form of a slip sheet. Proposed revision to footnote 17 review of $ million. Proposed revision on pages 30 and 31 SCE s current estimate (including conduit removal) for its share of decommissioning SONGS 1 is $ million. Proposed revision on page 43 The Commission therefore directs SCE to meet with Energy Division Staff and interested parties to address how it SCE will in the future provide more detailed directions and instructions to its staff so that record keeping will directly and transparently be reflected in the appropriate location, and with the appropriate detail, support for Distributed activities. Proposed revision to page 45, paragraph through roughly Proposed revision to FOF No. 4 On January 30, Proposed revision to FOF No. 13 $ million. Proposed insert of additional OP on page 75 The 2016 PVNGS DCE is adopted consistent with the findings set forth in this decision. Proposed revision to pages 76 Consolidate duplicative ordering paragraphs utilizing OP Nos. 9 and 10. III. CONCLUSION For the reasons discussed above, the Utilities respectfully urge the Commission to adopt the proposed revisions, as listed in the Subject Index of Recommended Changes. 9

14 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) Attorney for: SAN DIEGO GAS & ELECTRIC COMPANY 8330 Century Park Court, CP32D San Diego, CA Telephone: (858) Facsimile: (619) Dated: November 19,

15 Appendix A Proposed Conclusions of Law and Findings of Fact

16 Pursuant to Rule 14.3, Appendix A sets forth Utilities proposed revisions to the Findings of Fact and Conclusions of Law, consistent with the comments provided above. SCE also separately proposes a new ordering paragraph to address the PVNGS DCE. Proposed Revisions to Findings of Fact 4. On January 30, SDG&E filed Application for a reasonableness determination and recovery of 2014 operations and maintenance (O&M) and non-o&m SONGS costs. 13. It is reasonable to allow $ million (100% share) of SONGS 2&3 decommissioning expenses for activities completed between January 1, 2014 and December 31, Proposed Revisions to Conclusions of Law 8. It is reasonable to reduce SCE s 2015 DCE for SONGS Unit 1 by $35.7 million on the grounds that the request lacked adequate support to demonstrate the request is reasonable in nature and amount at this time.the Utilities provided adequate support to demonstrate the reasonableness of the SONGS 1 DCE. 10. It is reasonable to reduce SCE s 2015 DCE for SONGS Unit 2 by $35.7 million on the grounds that the request lacked adequate support to demonstrate the request is reasonable in nature and amount at this time.sce provided adequate support to demonstrate the reasonableness of the PVNGS DCE. Proposed New Ordering Paragraph Following OP No. 1 The 2016 PVNGS DCE is adopted consistent with the findings set forth in this decision. A-1

17 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 SAN DIEGO GAS & ELECTRIC COMPANY S (U 902-E) JOINT OPENING COMMENTS ON PHASE 2 & 3 PROPOSED DECISION on all parties identified on the attached service list(s) A , et al. 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 November 19, 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

18 CPUC - Service Lists - A Page 1 of 4 11/19/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON AND SDG&E - A FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: NOVEMBER 15, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties WALKER A. MATTHEWS III RAYMOND LUTZ SENIOR ATTORNEY 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. ATTORNEY UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY 3405 KENYON STREET, STE CENTURY PARK COURT SAN DIEGO, CA SAN DIEGO, CA FOR: UTILITY CONSUMERS' ACTION NETWORK FOR: SAN DIEGO GAS & ELECTRIC COMPANY (UCAN) MATTHEW FREEDMAN LINDSEY HOW-DOWNING STAFF ATTORNEY ATTORNEY 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 ATTORNEY CALIF PUBLIC UTILITIES COMMISSION DICKSON GEESMAN LLP LEGAL DIVISION ONLY 180 Promenade Circle, Suite 115 ONLY, CA Sacramento, CA 95834

19 CPUC - Service Lists - A Page 2 of 4 11/19/2018 FOR: ALLIANCE FOR NUCLEAR RESPONSIBILITY FOR: CAL PA (PUBLIC ADVOCATES OFFICE) FORMERLY THE OFFICE OF RATEPAYER ADVOCATES (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 DANIEL W. DOUGLASS CASE ADMINISTRATION ATTORNEY SOUTHERN CALIFORNIA EDISON COMPANY DOUGLASS & LIDDELL 2244 WALNUT GROVE AVE. / PO BOX PARK GRANADA, STE. 209 ROSEMEAD, CA CALABASAS, CA FOR: ALLIANCE FOR RETAIL ENERGY MARKETS (AREM)/DIRECT ACCESS CUSTOMER COALITION (DACC)/WESTERN POWER TRADING FORUM (WPTF) GARY STERN PAUL T. HUNT MANAGING DIR. DIRECTOR- REGULATORY FINANCE & ECONOMICS SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 8631 RUSH STREET 2244 WALNUT GROVE AVENUE ROSEMEAD, CA ROSEMEAD, CA MARIA BYRNES MARIA C. SEVERSON, ESQ. LEGAL ASSISTANT ATTORNEY AGUIRRE & SEVERSON LLP AGUIRRE & SEVERSON LLP 501 WEST BROADWAY, STE WEST BROADWAY, STE SAN DIEGO, CA SAN DIEGO, CA FOR: R. HENRICKS FOR: RUTH HENRICKS MICHAEL J. AGUIRRE, ESQ. STEVEN C. NELSON ATTORNEY ATTORNEY AGUIRRE & SEVERSON LLP SAN DIEGO GAS & ELECTRIC COMPANY 501 W. BROADWAY, STE TH AVENUE, 9TH FLOOR SAN DIEGO, CA SAN DIEGO, CA FOR: R. HENRICKS COURTNEY COOK EMMA D. SALUSTRO PARALEGAL ATTORNEY UTILITY CONSUMERS' ACTION NETWORK SAN DIEGO GAS & ELECTRIC COMPANY 3405 KENYON STREET, SUITE CENTURY PARK COURT, CP32D SAN DIEGO, CA SAN DIEGO, CA FOR: SAN DIEGO GAS & ELECTRIC COMPANY

20 CPUC - Service Lists - A Page 3 of 4 11/19/2018 JOHN F. WALSH SHIVANI SIDHAR SAN DIEGO GAS & ELECTRIC COMPANY REGULATORY CASE MGR CENTURY PARK COURT, CP32D SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO, CA CENTURY PARK COURT, CP32F SAN DIEGO, CA WENDY D. JOHNSON REGULATORY CASE ANALYST REGULATORY BUSINESS MGR. SAN DIEGO GAS & ELECTRIC COMPANY SAN DIEGO GAS & ELECTRIC COMPANY 8330 CENTURY PARK COURT, CP13E 8330 CENTURY PARK CT., CP32F SAN DIEGO, CA SAN DIEGO, CA CENTRAL FILES DONALD H. KORN SAN DIEGO GAS & ELECTRIC COMPANY PRINCIPAL 8330 CENTURY PARK CT, CP31-E DHK ASSOCIATES SAN DIEGO, CA N SAN ANTONIO ROAD LOS ALTOS, CA JOE LOYA CALIFORNIA ENERGY MARKETS PACIFIC GAS AND ELECTRIC COMPANY 425 DIVISADERO ST. SUITE BEALE STREET, RM. 1069, MC B10C SAN FRANCISCO, CA SAN FRANCISCO, CA CASE COORDINATION PACIFIC GAS AND ELECTRIC COMPANY ONLY ONLY, CA State Service ERIC GREENE RACHEL PETERSON CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION 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 CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION 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 CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY COST OF SERVICE & NATURAL GAS BRA DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM Capitol Mall 505 VAN NESS AVENUE Sacramento, CA SAN FRANCISCO, CA

21 CPUC - Service Lists - A Page 4 of 4 11/19/2018 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS