BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M) for Approval to Extend the Mobilehome Park Utility Upgrade Program. A.17-05-008 (Filed May 5, 2017) SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) MOTION FOR PARTY STATUS FADIA RAFEEDIE KHOURY Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY Post Office Box 800 Telephone: (626) 302-6008 Facsimile: (626) 302-3990 E-mail: Fadia.Khoury@sce.com July 5, 2017 1
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M) for Approval to Extend the Mobilehome Park Utility Upgrade Program. A.17-05-008 (Filed May 5, 2017) SOUTHERN CALIFORNIA EDISON COMPANY S (U 338-E) MOTION FOR PARTY STATUS Pursuant to Rule 1.4(a)(4) of the Rules of Practice and Procedure of the California Public Utilities Commission (Commission), Southern California Edison Company (SCE) hereby requests permission to become a party in the proceeding that will resolve Application No. 17-05- 008 (Application). SCE is an investor-owned utility organized and existing under the laws of the State of California. SCE is engaged in the business of generating, transmitting, and distributing electric energy in portions of Central and Southern California. On March 13, 2014, the Commission approved D.14-03-021 (Decision), which established the Mobilehome Park (MHP) Program. The Decision ordered SCE, San Diego Gas & Electric Company (SDG&E), and several other California investor-owned utilities (IOUs) 1 to implement a three-year (2015-2017) Pilot Program to convert 10 percent of mastermetered/ submetered services at mobilehome parks to direct utility service. The Decision also authorized the IOUs to file an advice letter after the end of the second program year to extend and expand the MHP Program, provided that the IOUs did not propose major modifications to their programs. 2 1 The IOUs are SDG&E, SCE, Bear Valley Electric Service, Liberty Utilities, PacifiCorp, Pacific Gas and Electric Company, Southern California Gas Company, and Southwest Gas Corporation. 2 Decision, at Ordering Paragraph (OP) 13. 1
On March 17, 2017, in compliance with OP 13 of the Decision, SDG&E filed Advice 3057-E/2563-G to, among other things, expand its MHP Program target by up to five percent. 3 In the advice letter filing, SDG&E anticipated also filing an application that proposed more substantial changes to the MHP Program, but stated that the advice letter was necessary to avoid potential delay or suspension of the MHP Program pending resolution of the Application. 4 Consistent with its representations in Advice 3057-E/2563-G, on May 5, 2017, SDG&E filed the Application to, among other things, make changes to and expand its MHP Program. Rule 1.4(b)(2) requires that the entity seeking party status shall state the factual and legal contentions that the person intends to make and show that the contentions will be reasonably pertinent to the issues already presented. SCE is interested in, and will be potentially impacted by, any Commission decision in this proceeding. As noted above, pursuant to the Decision, SCE implemented its own MHP Program. SCE also filed an advice letter on March 17, 2017 seeking a continuation and expansion of SCE s MHP Program, consistent with OP 13 of the Decision. 5 Because SCE has implemented an MHP Program in its service territory and is seeking to expand that program via advice letter, any Commission decision setting policy, interpreting the mandates of the Decision, altering tariffs, or determining rate methodologies for the MHP Program also may impact SCE. The extent of SCE s involvement will be to file a prehearing conference statement addressing procedural issues about the proper forum in which to seek extension of the MHP program, participate in the workshop process, serve direct and/or rebuttal testimony, and crossexamine witnesses during evidentiary hearings, as may be relevant and applicable, regarding SDG&E s MHP Program proposals set forth in its Application. 3 SDG&E Advice 3057-E/2563-G, Continuation of the Mobilehome Park Utility Upgrade Program Pursuant to Decision (D.)14-03-021 and Modification to the Master Meter Balancing Accounts and Rule 44, filed March 17, 2017. 4 Id., at p. 3. 5 Because SCE is not making any major modifications to its MHP Program, the continuation and expansion of its MHP Program should be approved via advice letter per OP 13 of the Decision; therefore, SCE has not filed, and does not intend to file, an application related to the MHP Program at this time. 2
SCE s participation will not expand the scope of this proceeding and no party would be prejudiced by the granting of this motion for party status at this stage, before a Scoping Memo has been issued. For the foregoing reasons, SCE requests that the Commission grant this motion for party status, and that SCE be included as a party on the service list as follows: Fadia Rafeedie Khoury Director and Managing Attorney Southern California Edison Company G.O.1, Room 348H Rosemead, CA 91770 Fadia.Khoury@sce.com (626) 302-6008 For Information Only, please include the following on the service list: Case Administration Southern California Edison Company Telephone: (626) 302-4875 Facsimile: (626) 302-3119 E-mail: case.admin@sce.com Dated: July 5, 2017 Respectfully submitted, FADIA RAFEEDIE KHOURY /s/ Fadia Rafeedie Khoury By: Fadia Rafeedie Khoury Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY Post Office Box 800 Telephone: (626) 302-6008 Facsimile: (626) 302-3990 E-mail: Fadia.Khoury@sce.com 3
BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of San Diego Gas & Electric Company (U902M) for Approval to Extend the Mobilehome Park Utility Upgrade Program. A.17-05-008 (Filed May 5, 2017) 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) MOTION FOR PARTY STATUS on all parties identified on the attached service list for the consolidated proceedings: A.17-05-008. 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 hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s), and by U.S. mail to those on the service list without an email address. ALJ Melissa K. Semcer CPUC 505 Van Ness Ave. San Francisco, CA 94102 Executed July 5, 2017, at Rosemead, California. /s/gina Leisure Gina Leisure SOUTHERN CALIFORNIA EDISON COMPANY Post Office Box 800
CPUC - Service Lists - A1705008 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A1705008 - SDG&E - FOR APPROVAL FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: JUNE 28, 2017 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties AVISHA A. PATEL NINA SUETAKE SR. COUNSEL STAFF ATTORNEY SOUTHERN CALIFORNIA GAS COMPANY THE UTILITIY REFORM NETWORK 555 WEST FIFTH STREET, GT-14E7 785 MARKET STREET, SUITE 1400 LOS ANGELES, CA 90013 SAN FRANCISCO, CA 94103 FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: THE UTILITY REFORM NETWORK (TURN) KERRIANN SHEPPARD LEGAL DIVISION 300 Capitol Mall Sacramento, CA 95814 FOR: OFFICE OF RATEPAYER ADVOCATES (ORA) Information Only JOSEPH MOCK RONALD S. CAVALLERI REGULATORY CASE MGR. SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, GT14D6 555 WEST 5TH ST., STE 1400, GT14D6 LOS ANGELES, CA 90013-1011 LOS ANGELES, CA 90013 FADIA KHOURY CENTRAL FILES SR. ATTORNEY SAN DIEGO GAS & ELECTRIC COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 8330 CENTURY PARK CT, CP31-E 2244 WALNUT GROVE AVENUE / PO BOX 800 SAN DIEGO, CA 92123-1530 ROSEMEAD, CA 91770 CASE COORDINATION PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY, CA 94105-4159 State Service CHRISTIAN LAMBERT CRYSTAL YEH ENERGY COST OF SERVICE & NATURAL GAS BRA ENERGY COST OF SERVICE & NATURAL GAS BRA AREA AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 https://ia.cpuc.ca.gov/servicelists/a1705008_84379.htm[7/5/2017 9:52:16 AM]
CPUC - Service Lists - A1705008 MELISSA K. SEMCER NIKA ROGERS DIVISION OF ADMINISTRATIVE LAW JUDGES ENERGY COST OF SERVICE & NATURAL GAS BRA ROOM 5041 ROOM 4101 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 FOR: ORA SEAN A. SIMON COMMISSIONER RECHTSCHAFFEN AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 TOP OF PAGE BACK TO INDEX OF SERVICE LISTS https://ia.cpuc.ca.gov/servicelists/a1705008_84379.htm[7/5/2017 9:52:16 AM]