BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO PROTESTS

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application Of Southern California Edison Company (U 338-E) For Approval Of Its Forecast 2019 ERRA Proceeding Revenue Requirement. Application No (Filed May 1, 2018) RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO PROTESTS FADIA R. KHOURY RUSSELL A. ARCHER Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Dated: June 22, 2018

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application Of Southern California Edison Company (U 338-E) For Approval Of Its Forecast 2019 ERRA Proceeding Revenue Requirement. Application No (Filed May 1, 2018) RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO PROTESTS Pursuant to California Public Utilities Commission (CPUC or Commission) Rule of Practice and Procedure 2.6(e), Southern California Edison Company (SCE) respectfully submits this Reply to the Protests to SCE s Application filed by the Office of Ratepayer Advocates (ORA), the Direct Access Customer Coalition (DACC) and the California Choice Energy Authority (CCEA). I. SCHEDULING ISSUES Over the last two SCE ERRA Forecast cycles, the Commission has gone to great lengths to successfully ensure a year-end final decision, so that new rates can be timely implemented on January 1 st of the following year. SCE appreciates the Commission s diligence, and acknowledges that it takes material effort by both the Commission and parties to achieve such a result. But ensuring that result is important, and DACC s proposed delays should not be accepted. Although the delays in DACC s proposed schedule on their face appear rather modest, it is undeniable that they would preclude a January 1 st rate change. SCE implements several 1

3 revenue requirement changes on January 1 st in a consolidated fashion (including ERRA rate changes), and it would be neither efficient for SCE, nor desirable for customers, to be forced into unnecessary, serial short-term rate changes. Nor is such a result necessary. DACC offers four reasons that it contends support its delay request. Only the fourth is relevant here, as SCE does not materially disagree with any DACC proposed changes up through the November Update deadline. In support of delays starting with the November Update, DACC maintains that any revisions to the current PCIA methodology are likely to be quite contentious and will need careful review and verification and that [t]he update testimony will likely contain information that is extremely relevant to the issues of concerns to DACC and other departing load customers. 1 While it is true that the Commission is considering comprehensive reforms to the Power Charge Indifference Adjustment (PCIA) methodology in Rulemaking (R.) (PCIA OIR), a proposed decision is scheduled in that proceeding for late July, Recently, assigned Administrative Law Judge (ALJ) Roscow confirmed meeting that deadline is the Commission s continuing intent. 3 In other words, the Commission will have likely issued a final decision in the PCIA OIR several months before SCE s November Update testimony is due in this proceeding. Presumably, that final decision will provide clear guidance to the utilities about how the Commission expects the PCIA replacement or reform methodology to work. So while DACC may think the information in the ERRA November Update on this subject will be extremely relevant and contentious, that information will simply be of the implementation-andcompliance variety, because the substantive issues will have already been decided in the PCIA 1 DACC Protest, p See R , March 2, 2018 Amended Scoping Memo and Ruling of Assigned Commissioner, p See R , Evidentiary Hearing Transcript, Vol. 5, p. 1124: (ALJ Roscow: And I believe pursuant to the March 2nd amended scoping memo Commissioner Peterman s intent is, remains to mail the PD in, quote, late July 2018, unquote. ). 2

4 OIR (and any potential implementing advice letters resulting from a final decision therein). Accordingly, similar to how the ERRA November Update currently works to mechanically apply the existing PCIA, this proceeding s November Update will simply mechanically apply any replacement or reformed PCIA methodology. No additional delay is necessary or appropriate in this proceeding for parties to further litigate what will have been substantively decided in another. After considering the scheduling proposals made by both DACC and ORA, and reviewing the Commission s adopted schedule from last year s ERRA Forecast proceeding, SCE proposes a revised compromise schedule. That proposed schedule, which appears below, largely adopts DACC-proposed dates (yellow highlights), ORA-proposed dates (green highlights), and dates that have already been set by the Commission (blue highlights). Adopting it will both allow sufficient time for the Commission and interested parties to fully vet the issues, but also ensure a year-end final decision so that a timely rate change can be made on January 1 st. Event SCE (original) ORA DACC 2018 ERRA SCE (revised) Prehearing Conference June 28 N/A June 28 June 29 July 9 Scoping Memo N/A N/A July 6 August 5 July 16 SCE Workshop N/A N/A N/A June 30 July 19 ORA/Intervenor Testimony July 6 July 17 July 20 August 19 July 20 SCE Rebuttal July 27 August 7 August 3 August 26 August 3 Evidentiary Hearings August August 8-10 August October 21 August Opening Briefs N/A September 14 November 16 November 18 September 14 SCE November Update November 9 November 7 November 2 November 10 November 7 Comments on Update N/A November 15 N/A N/A November 15 Reply Comments on Update N/A November 19 N/A N/A November 19 Proposed Decision November 16 November 27 November 30 December 2 November 27 3

5 Comment Shorten. Deadline N/A N/A N/A November 14 November 30 Comments on PD November 30 December 3 December 14 N/A December 3 Reply Comments on PD December 5 December 6 December 19 N/A December 6 Final Decision December 13 December 13 January 2019 December 15 December 13 II. SCOPING ISSUES SCE agrees that the issues identified by ORA, DACC and CCEA in their Protests are appropriately within the scope of this proceeding. III. CONCLUSION For all the reasons stated herein, SCE s revised compromise schedule should be adopted, and this proceeding should be scoped in accordance with SCE s Application, supporting testimony, and the issues identified by ORA, DACC, and CCEA in their respective Protests. Respectfully submitted, /s/ Russell A. Archer By: Russell A. Archer Attorney for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) Russell.Archer@sce.com Dated: June 22,

6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application Of Southern California Edison Company (U 338-E) For Approval Of Its Forecast 2019 ERRA Proceeding Revenue Requirement. Application No (Filed May 1, 2018) 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 PROTESTS 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 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 the offices of the Commissioner(s) or other addressee(s). ALJ Zita Kline CPUC - Division of ALJs 505 Van Ness Avenue San Francisco, CA Executed on June 22, 2018, at Rosemead, California. /s/ Angelica Gamboa Angelica Gamboa Legal Administrative Assistant SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

7 CPUC - Service Lists - A Page 1 of 2 6/22/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - FOR APPROVA FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: JUNE 20, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties DANIEL W. DOUGLASS RUSSELL A. ARCHER ATTORNEY AT LAW SR. ATTORNEY DOUGLASS & LIDDELL SOUTHERN CALIFORNIA EDISON COMPANY 4766 PARK GRANADA, SUITE WALNUT GROVE AVE. / PO BOX 800 CALABASAS, CA ROSEMEAD, CA FOR: DIRECT ACCESS CUSTOMER COALITION FOR: SOUTHERN CALIFORNIA EDISON COMPANY ZHEN ZHANG SCOTT BLAISING COUNSEL LEGAL DIVISION BRAUN BLAISING SMITH WYNNE P.C. ROOM L STREET, SUITE VAN NESS AVENUE SACRAMENTO, CA SAN FRANCISCO, CA FOR: CALIFORNIA CHOICE ENERGY AUTHORITY FOR: ORA (CCEA) Information Only CASE COORDINATION MICHAEL CADE PACIFIC GAS AND ELECTRIC COMPANY BUCHALTER ONLY ONLY ONLY, CA ONLY, CA SUE MARA MRW & ASSOCIATES, LLC PRINCIPAL ONLY RTO ADVISORS, LLC ONLY, CA ONLY ONLY, CA 00000

8 CPUC - Service Lists - A Page 2 of 2 6/22/2018 MATTHEW H. LANGER NATASHA KEEFER COO DIR - PWR PLANNING & PROCUREMENT CLEAN POWER ALLIANCE CLEAN POWER ALLIANCE 555 WEST 5TH ST., 35TH FL. 555 WEST 5TH ST., 35TH FL. LOS ANGELES, CA LOS ANGELES, CA CASE ADMINISTRATION REGULATORY CLERK SOUTHERN CALIFORNIA EDISON COMPANY BRAUN BLAISING SMITH WYNNE, PC 8631 RUSH STREET 915 L STREET, STE ROSEMEAD, CA SACRAMENTO, CA State Service BRIAN LUI MITCHELL SHAPSON ELECTRICITY PLANNING & POLICY BRANCH LEGAL DIVISION AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA RADU CIUPAGEA THOMAS GARIFFO ELECTRICITY PLANNING & POLICY BRANCH ELECTRICITY PLANNING & POLICY BRANCH ROOM 4104 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA YULIYA SHMIDT ZITA KLINE COMMISSIONER RECHTSCHAFFEN DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 4209 ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA DRUCILLA DUNTON MARKET STRUCTURE, COSTS AND NATURAL GAS 300 Capitol Mall Sacramento, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS