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 For Approval Of Its Forecast 2019 ERRA Proceeding Revenue Requirement. A (Filed May 1, 2018 S (U 338-E RESPONSE TO CLEAN POWER ALLIANCE OF SOUTHERN CALIFORNIA MOTION FOR PARTY STATUS JANET S. COMBS RUSSELL A. ARCHER MARIO E. DOMINGUEZ Attorneys for 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Russell.Archer@sce.com Dated: September 17, 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. A (Filed May 1, 2018 S (U 338-E RESPONSE TO CLEAN POWER ALLIANCE OF SOUTHERN CALIFORNIA MOTION FOR PARTY STATUS I. INTRODUCTION Pursuant to California Public Utilities Commission (Commission Rule of Practice and Procedure 11.1(e, Southern California Edison Company (SCE respectfully submits this Response to Clean Power Alliance of Southern California (CPA Motion for Party Status (Motion. II. SCE RESPONSE SCE does not formally oppose CPA s Motion, but is submitting this Response to make certain clarifications and provide important context for the Commission s consideration. First, the Power Charge Indifference Adjustment (PCIA is not an exit fee, as CPA s Motion incorrectly characterizes it. Instead, the PCIA is a ratemaking mechanism that appropriately collects procurement costs from departing load customers, including those served by Community Choice Aggregators (CCAs, on whose behalf those costs were incurred. The - 1 -

3 PCIA is necessary to uphold the statutory requirement that procurement costs are not shifted to remaining bundled service customers as a result of CCA formation. Second, when ruling on CPA s Motion, which was not filed until September 13, 2018, the Commission should consider the following factors: (1 SCE filed this Application on May 1, 2018, some four-and-a-half months ago. CPA never protested SCE s Application or otherwise sought to intervene in this proceeding until it belatedly filed the Motion last week. (2 SCE submitted Supplemental Testimony on June 1, 2018, the sole purpose of which was to update its departing load forecast to account for many of the 31 cities and jurisdictions that CPA represents and prominently references in its Motion. CPA did not in any way respond to SCE s Supplemental Testimony, and the time for submitting Intervenor Testimony has long since passed. 1 (3 Despite not seeking party status until now, CPA actively participated in the July 19, 2018 Energy Division workshop in this proceeding. 2 (4 CPA notes that it is actively participating in Rulemaking (the PCIA OIR, and that PCIA rates for 2019 will be set in this ERRA proceeding. The PCIA OIR has been open since June 2017, almost a year before SCE filed this Application. (5 Regarding the PCIA, this proceeding will simply mechanistically apply the final Commission decision resulting from the PCIA OIR. This is not an appropriate venue to evaluate reasonable[ness] 3 issues regarding the PCIA. 4 1 See July 19, 2019 Assigned Commissioner s Scoping Memo and Ruling (Scoping Memo at p. 3 (setting deadline for Intervenors prepared direct testimony of August 6, During the workshop, CPA representative Matt Langer participated telephonically and asked several questions of SCE. SCE subsequently formally responded to CPA s questions via a written discovery response on July 25, CPA Motion at p See, e.g., SCE June 22, 2018 Reply to Protests at pp

4 (6 The Commission is well aware of the compressed nature of ERRA Forecast proceedings (including the abbreviated November-December work necessitated by the November Update testimony and associated filings and need for a timely decision to allow SCE to implement the authorized rates in January Consistent with its recent decisions for SCE and the other Investor-Owned Utilities ERRA Forecast proceedings, the Commission has adopted a schedule in this proceeding that provides for a January 1, 2019 rate change for both bundled service and departing load customers. 5 That determination was appropriate and important. If the Commission decides to grant the Motion, it should hold CPA strictly accountable to its stated commitment that it will not seek to delay the existing schedule [and that it] will not prejudice any other party or delay the proceeding. 6 Respectfully submitted, JANET S. COMBS RUSSELL A. ARCHER MARIO E. DOMINGUEZ /s/ Russell A. Archer By: Russell A. Archer Attorneys for 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Russell.Archer@sce.com September 17, See Scoping Memo at p CPA Motion at p

5 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 S (U 338-E RESPONSE TO CLEAN POWER ALLIANCE OF SOUTHERN CALIFORNIA MOTION FOR PARTY STATUS 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 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 September 17, 2018, at Rosemead, California. /s/ Edith Leon Edith Leon Legal Administrative Assistant 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

6 CPUC - Service Lists - A Page 1 of 3 9/17/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A EDISON - FOR APPROVA FILER: LIST NAME: LIST LAST CHANGED: AUGUST 28, 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 4766 PARK GRANADA, SUITE WALNUT GROVE AVE. / PO BOX 800 CALABASAS, CA ROSEMEAD, CA FOR: DIRECT ACCESS CUSTOMER COALITION FOR: ZHEN ZHANG SCOTT BLAISING COUNSEL DIVISION OF ADMINISTRATIVE LAW JUDGES 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 BARBARA BARKOVICH CASE COORDINATION CONSULTANT PACIFIC GAS AND ELECTRIC COMPANY BARKOVICH & YAP ONLY ONLY ONLY, CA ONLY, CA MICHAEL CADE BUCHALTER ONLY ONLY, CA SUE MARA PRINCIPAL RTO ADVISORS, LLC ONLY

7 CPUC - Service Lists - A Page 2 of 3 9/17/2018 ONLY, CA MRW & ASSOCIATES, LLC ONLY ONLY, CA MATTHEW H. LANGER COO CLEAN POWER ALLIANCE 555 WEST 5TH ST., 35TH FL. LOS ANGELES, CA NATASHA KEEFER CASE ADMINISTRATION DIR - PWR PLANNING & PROCUREMENT CLEAN POWER ALLIANCE 8631 RUSH STREET 555 WEST 5TH ST., 35TH FL. ROSEMEAD, CA LOS ANGELES, CA JOHN MONTANYE MARIO E. DOMINGUEZ MGR. - PROGRAM / CONTRACT ATTORNEY 8631 RUST STREET 8631 RUSH ST. ROSEMEAD, CA ROSEMEAD, CA DAVID ZIZMOR BUCK ENDEMANN ATTORNEY MARKET STRUCTURE, COSTS AND NATURAL GAS K&L GATES, LLP AREA FOUR EMBARCADERO, STE VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA CAROLYN KEHREIN REGULATORY CLERK PRINCIPAL BRAUN BLAISING SMITH WYNNE, PC ENERGY MANAGEMENT SERVICES 915 L STREET, STE CELEBRATION WAY SACRAMENTO, CA WOODLAND, CA COLIN CAMERON STRUCTURE & PRICING ANALYST THE ENERGY AUTHORITY TH AVENUE SE, STE. 100 BELLEVUE, WA 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 ELECTRICITY PLANNING & POLICY BRANCH ROOM 4104 THOMAS GARIFFO ELECTRICITY PLANNING & POLICY BRANCH AREA

8 CPUC - Service Lists - A Page 3 of 3 9/17/ 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 EXECUTIVE DIVISION 300 Capitol Mall Sacramento, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS