opening comments on scoped issues · edison company (sce) hereby submits its opening comments...

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Order Instituting Rulemaking to Consider Authorization of a Non-Bypassable Charge to Support California’s Wildfire Fund.

Rulemaking No. 19-07-017

SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS

ON ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING

FADIA RAFEEDIE KHOURY GARY Y. CHEN

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-7214 E-mail: [email protected]

Dated: August 29, 2019

SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS ON ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING

Table of Contents

Section Page

-i-

I. INTRODUCTION ....................................................................................................................................1

II. SCE’S COMMENTS ..............................................................................................................................1

A. Establishment of a non-bypassable charge to support the Wildfire Fund is appropriate ...........................................................................................................................1

B. Imposition of a Wildfire Fund Charge is just and reasonable .............................................2

C. It is reasonable for the Commission to establish the Wildfire Fund Charge using the values in the Revenue Requirement Ruling. ........................................................4

D. The Commission should not address the implications of PG&E’s potential nonparticipation in the Wildfire Fund at this time. ..............................................................5

E. The Commission has substantial discretion to interpret the phrase “in the same manner” in AB 1054 ...................................................................................................6

F. The Commission should adhere to the expedited schedule included in the proceeding as mandated by AB 1054. .................................................................................7

III. CONCLUSION ......................................................................................................................................8

APPENDIX A SOUTHERN CALIFORNIA EDISON COMPANY’S NOTICE OF INTENT TO PARTICIPATE IN CALIFORNIA’S WILDLIFE FUND ESTABLISHED BY ASSEMBLY BILL 1054

1


STATE OF CALIFORNIA



SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) OPENING COMMENTS

ON ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING

I.

INTRODUCTION

Pursuant to the California Public Utilities Commission’s (CPUC or Commission)

August14, 2019, Assigned Commissioner’s Scoping Memo and Ruling, Southern California

Edison Company (SCE) hereby submits its Opening Comments addressing the issues that are

within the scope of the proceeding (Section 2 of the Scoping Memo and Ruling) and the

Questions for Party Comments (Section 4 of the Scoping Memo and Ruling).

II.

SCE’S COMMENTS

A. Establishment of a non-bypassable charge to support the Wildfire Fund is

appropriate

It is appropriate for the Commission to exercise its authority under Public Utilities Code

§ 701 to require certain electrical corporations to impose a non-bypassable charge on customers

to support California’s Wildfire Fund (Wildfire Fund Charge). Section 701 states:

2

The commission may supervise and regulate every public utility in the State and may do all things, whether specifically designated in this part or in addition thereto, which are necessary and convenient in the exercise of such power and jurisdiction.

Section 701 provides the Commission with the authority to take necessary actions, such

as impose a Wildfire Fund Charge, that furthers the intent of the legislature. Here, AB 1054

expressly states that the Commission is to consider using its authority pursuant to Section 701 to

establish the Wildfire Fund Charge.1 As such, it is appropriate for the Commission to require

certain electrical corporations to impose the Wildfire Fund Charge.

B. Imposition of a Wildfire Fund Charge is just and reasonable

Wildfires are not simply a utility problem or a customer problem – they are a state

problem. Governor Newsom’s Strike Force Report on Wildfires and Climate Change (Strike

Force Report) states “No single stakeholder created this crisis, and no single stakeholder should

bear its full cost.”2 Accordingly, AB 1054 requires utilities in aggregate to provide over ten

billion dollars3 in non-recoverable contributions to the Wildfire Fund as well as forgo earning a

return on equity on five billion dollars in safety-related investments.4 The Wildfire Fund Charge

is the customer contribution to the costs of catastrophic wildfire. Contributions from

shareholders and customers to the Wildfire Fund are fair and equitable as utilities and customers

both benefit from its existence.

The Strike Force Report and the Commission Report on Catastrophic Wildfire Cost and

Recovery (Commission Report) took significant strides to address the wildfire crisis by

proposing holistic, equitable and reasonable recommendations, many of which were ultimately

adopted in AB 1054. Their recommendations are the product of extensive research and analysis

1 Public Utilities Code section 3289(a). 2 Strike Force Report at p. 27. 3 $7.5 billion of initial contributions and $3.0 billion of annual contributions ($300 million per year for

10 years). 4 AB 1054, Section 2(g).

3

to establish a balanced and sustainable framework for wildfire cost and recovery. Both

recommended creation of a fund to absorb a significant portion of wildfire liability costs.

The Wildfire Fund, for which the Wildfire Fund Charge is a crucial component, provides

several benefits to customers. It reduces the financial risks and uncertainty, increasing the

likelihood of utilities achieving and maintaining investment grade credit ratings, which in turn

provides the utilities access to funds at lower costs to perform work and procure energy, thus

reducing the costs to customers. Moody’s rating agency was poised to downgrade SCE, but after

SCE and SDG&E elected to contribute to the Wildfire Fund, Moody’s Investors Service stated

that “The passage of AB 1054 and the subsequent establishment of the insurance fund has had a

strong stabilizing effect on SCE and Edison's credit profiles.”5 Based on the establishment of the

Wildfire Fund, SCE revised its requested revenue requirement related to the required return on

equity on August 1st to reflect the impacts of the Wildfire Fund election, reducing the requested

revenue requirement by $1.0 billion.6

In addition, AB 1054 prescribes that if the Wildfire Fund is accessed to pay for costs after

a wildfire event, and these costs are subsequently determined not to be just and reasonable, only

shareholders have the obligation of reimbursing the Wildfire Fund. Customers will receive the

benefits from the Wildfire Fund covering claims and others costs regardless of a prudency

determination and will only have to repay the Wildfire Fund if the costs are found to be just and

reasonable, providing them greater benefits than the shareholders. Ultimately, the reduced risk

profile of the utilities, including the impact the Wildfire Fund Charge has on the investment

grade ratings of utilities in California, helps California achieve our shared environmental goals

through lower customer costs, more efficient capital market access, and improved

creditworthiness for parties who are advancing clean energy policies. This is particularly

important as SCE continues to invest in infrastructure to improve system safety, reliability and

5 https://www.moodys.com/research/Moodys-affirms-Edison-and-Southern-California-Edison-ratings-

outlooks-changed--PR_405760. 6 See Exhibit SCE-01-A at p.10 in A.19-04-014.

4

resiliency and to expand opportunities for efficient electrification of the transportation and

building sectors.

In sum, the proposed Wildfire Fund Charge is an essential element of the AB 1054

construct designed to equitably socialize costs and balance the risks and mitigations associated

with wildfires across stakeholder groups.

C. It is reasonable for the Commission to establish the Wildfire Fund Charge using the

values in the Revenue Requirement Ruling.

Per Section 80524 of the Water Code:

The revenue requirement for each year or, with respect to the first year and last year, the pro rata portion of the year, shall be equal to the average annual amount of collections by the department with respect to charges imposed pursuant to the revenue requirements established by the department under Section 80110 of Division 27 for the period from January 1, 2013, through December 31, 2018. (emphasis added)

The statute requires a new revenue requirement equal to the historical average amount

collected per Section 80110 of Division 27. On August 23, 2019, ALJ Doherty filed a Ruling

Soliciting Party Comment on Revenue Requirement Calculation (Revenue Requirement Ruling).

The Revenue Requirement Ruling provided a table summarizing the annual collections under the

DWR Bond Charges for the years 2013-2018 for each of the three large electrical corporations

(PG&E, SCE, and SDG&E). Comparing those amounts to SCE’s annual collections indicates the

averages across all six years (2013-2018) are essentially the same for both data sets. As they are

consistent with both AB 1054 and SCE’s own numbers, it is reasonable for the Commission to

establish the Wildfire Fund Charge using the numbers in the Revenue Requirement Ruling.

5

D. The Commission should not address the implications of PG&E’s potential

nonparticipation in the Wildfire Fund at this time.

SCE believes that whether it is reasonable to collect the Wildfire Fund Charge from

customers of an electrical corporation that is deemed ineligible to participate in the Wildfire

Fund is not ripe for a determination. On August 21, 2019, ALJ Doherty issued a Ruling

Soliciting Party Comment on the proposed Rate Agreement (Rate Agreement Ruling). The

proposed Rate Agreement and a memorandum from the Department addressing and supporting

the revenue requirement definition in the proposed Rate Agreement (DWR Memo) were attached

to the Rate Agreement Ruling. Section 4.1(a) of the proposed Rate Agreement states that the

revenue requirement “shall be equal to the average annual amount of collections by the

Department with respect to the DWR Bond Charges imposed for the period from January 1, 2013

through December 31, 2018 on customers of each Large Electrical Corporation that is eligible

and elects to participate in the Wildfire Fund.” (Emphasis added.) The DWR Memo explains:

The calculation of the revenue requirement based on prior bond charge collections only from the ratepayers of electrical corporations that participate in the fund achieves this legislative objective because the nonbypassable charges imposed on ratepayers to support the fund remain similar on a per kilowatt hour basis to DWR’s existing bond charge imposed on the same ratepayers. A calculation of the revenue requirement based on DWR’s total past collections, without regard to utility participation in the fund, would cause individual ratepayer’s charges to vary significantly if fewer than three large electric corporations participated in the fund.

This explanation and the proposed Rate Agreement assumes that PG&E ratepayers will

be exempt from the Wildfire Fund Charge if PG&E is ineligible to participate and that the

revenue requirement would be reduced accordingly. However, the issue of what, if any,

requirements should apply to its customers if PG&E is ultimately not eligible to participate is not

ripe for decision making at this time. PG&E has notified the Commission of its election to

6

participate in the Wildfire Fund,7 meeting the eligibility conditions as specified in AB 1054.

PG&E’s participation in the Wildfire Fund is in the best interest of stakeholders, including

customers, shareholders, and investors and is important to satisfy the state’s goals of mitigating

the physical and financial risks posed by wildfires. If PG&E cannot meet the statutory deadline

to participate in the Wildfire Fund, the Commission should take up the issue at that time.

E. The Commission has substantial discretion to interpret the phrase “in the same

manner” in AB 1054

Public Utilities Code § 3289(2) provides that if the Commission deems the Wildfire Fund

Charge as just and reasonable, “the charge shall be collected in the same manner as that for

payments made to reimburse the DWR for bond-related expenses pursuant to Division 27 of the

Water Code.”8 The prior process for determining and collecting the DWR bond charge can be

summarized as follows: 1) the DWR provided an annual revenue requirement for each

upcoming year to the Commission;9 2) the Commission determined the allocation of the

responsibility for paying the rate requirement among the IOUs;10 and 3) the Commission

determined which customers would be subject to the non-bypassable charge.11 In this context,

the term “in the same manner” appears to refer to how the charge will be collected generally, not

the amount of the charge itself or how the charge will be imposed on customers. As such, “in

the same manner” should not be interpreted as “exactly the same” as the current DWR bond

charge. For example, the current DWR bond charge is paid by utility customers on a volumetric

dollars per kilowatt-hour basis, including Net Energy Metering (NEM) customers. While a

volumetric charge is the historical practice for DWR bond costs, and should be applied at this

7 See

https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/News_Room/NewsUpdates/2019/PGELetter2ED2019.pdf.

8 Public Utilities Code § 3289(a)(2) (emphasis added). 9 D. 02-10-063 at pp. 9-12. 10 Id. at pp. 16-20. 11 Id. at pp. 36-42.

7

time, as the CPUC considers NEM in the future it may also wish to consider other ways to

collect bond charges from utility customers. SCE agrees with the OIR that rate design issues

should be resolved in a separate proceeding or in a later phase of the proceeding.12 Rate design

issues are not essential in determining the justness and reasonableness of establishing the

Wildfire Fund Charge as proposed in this proceeding.

F. The Commission should adhere to the expedited schedule included in the proceeding

as mandated by AB 1054.

The Wildfire Fund Charge is an important mechanism to provide a source of funds for

eligible claims resulting from covered wildfires while maintaining financially healthy utilities.

As highlighted in Section 4 of the OIR, AB 1054 mandates that the Commission adopt a decision

“no later than 90 days after the initiation of the rulemaking proceeding.”13 The schedule

established in the Commissioner’s Scoping Memo and Ruling includes the issuance of a final

decision in this proceeding on October 24, 2019.

Participating utilities are required to provide their initial contributions to the Wildfire

Fund by September 10, 2019,14 prior to a final decision in this proceeding. On July 25, 2019,

SCE notified the Commission of its intent to participate in the Wildfire Fund and provide the

initial contribution using the Wildfire Fund allocation metric as specified in Public Utilities Code

§ 3280(n). A copy of SCE’s notice of intent to participate in the Wildfire Fund is included in

Appendix A of this filing. Pacific Gas & Electric Company and San Diego Gas & Electric

Company similarly notified the Commission of their intent to participate in the AB 1054

Wildfire Fund on July 23, 2019 and July 18, 2019, respectively.15 This action by the IOUs is an

indication of their commitment to wildfire reform as outlined in AB 1054. In the

12 Order Instituting Rulemaking at p.3. 13 Public Utilities Code § 3289(b). 14 Participating utilities are required to provide their annual contributions within 60 days of the effective

date of AB 1054. 15 Electrical corporation opt-in letters are available at https://www.cpuc.ca.gov/wildfires/.

8

Commissioner’s Scoping Memo and Ruling, all electric corporations are required to serve and

file notice indicating whether they have submitted the initial contribution required to participate

in the Wildfire Fund.16 SCE has raised the required funds and fully intends to provide its initial

contribution by September 10, 2019. SCE respectfully requests that the Commission consider

this commitment in providing a final decision in this proceeding according to the timeline as

required by AB 1054.

III.

CONCLUSION

SCE appreciates the opportunity to provide its comments on the proceeding’s Scoping

Memo and Ruling and other issues.

Respectfully submitted, FADIA RAFEEDIE KHOURY GARY Y. CHEN

/s/ Gary Chen By: Gary Y. Chen

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-7214 E-mail: [email protected]

August 29, 2019

16 Commissioner’s Scoping Memo and Ruling, Section 3.

RULE 1.11 VERIFICATION

I am an officer of Southern California Edison Company and am authorized to make this

verification on its behalf. I have read the foregoing SOUTHERN CALIFORNIA EDISON

COMPANY'S (U 338-E) OPENING COMMENTS ON ASSIGNED COMMISSIONER’S

SCOPING MEMO AND RULING. I am informed and believe that the matters stated in the

foregoing document are true.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 29th day of August 2019, at Rosemead, California.

/s/ Tres Petmecky By: Tres Petmecky Chief Financial Officer and Senior Vice President, Finance

SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

Appendix A

Southern California Edison Company’s

Notice of Intent to Participate in California’s Wildlife Fund

Established by Assembly Bill 1054


STATE OF CALIFORNIA



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) OPENING COMMENTS ON ASSIGNED COMMISSIONER’S SCOPING MEMO AND RULING on all parties identified on the attached service list for R.19-07-017. Service was effected by transmitting copies via e-mail to all parties who have provided an e-mail address and by placing copies in sealed envelopes and causing such envelopes to be delivered via United States mail with first-class postage prepaid to the offices of the Assigned ALJ or other addressee(s).

ALJ Patrick Doherty California Public Utilities Commission Administrative Law Judge Division 505 Van Ness Avenue, Room 5044 San Francisco, CA 94102-3214

Executed on August 29, 2019, at Rosemead, California.

/s/ Sandra Sedano Sandra Sedano SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

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NATHAN POON NATHANIEL SKINNER CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ADMINISTRATIVE LAW JUDGE DIVISION SAFETY BRANCH ROOM 5013 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

PATRICK DOHERTY POUNEH GHAFFARIAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ADMINISTRATIVE LAW JUDGE DIVISION LEGAL DIVISION ROOM 5044 ROOM 5025 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

SEAN A. SIMON SHELBY CHASE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION COMMISSIONER RECHTSCHAFFEN SAFETY BRANCH ROOM 5201 AREA 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

TYLER HOLZSCHUH MATTHEW PLUMMER CALIF PUBLIC UTILITIES COMMISSION PACIFIC GAS AND ELECTRIC COMPANY SAFETY BRANCH 77 BEALE STREET, MC B23A AREA SAN FRANCISCO, CA 94105 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214

MICHAEL CADE RANDALL J. LITTENEKER, ESQ. ANALYST - ENERGY & NAT'L RESOURCES ATTORNEY BUCHALTER, A PROFESSIONAL CORPORATION PACIFIC GAS AND ELECTRIC COMPANY 55 SECOND STREET, SUITE 1700 77 BEALE STREET, MC B30A / PO BOX 7442 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105

KARI CAMERON LILLIAN RAFII LEGAL ADMIN. ATTORNEY BUCHALTER BUCHALTER, A PROFESSIONAL CORPORATION 55 SECOND STREET, STE. 1700 55 SECOND STREET, STE. 1700 SAN FRANCISCO, CA 94105-3493 SAN FRANCISCO, CA 94105-3493

ANNA FERO BRIAN T. CRAGG DAVIS WRIGHT TREMAINE LLP ATTORNEY 505 MONTGOMERY STREET, SUITE 800 GOODIN, MACBRIDE, SQUERI, DAY & LAMPREY, SAN FRANCISCO, CA 94111 505 SANSOME ST., STE 900 SAN FRANCISCO, CA 94111

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DAVIS WRIGHT TREMAINE LLP 2 EMBARCADERO CENTER SUITE 24 505 MONTGOMERY STREET, STE. 800 SF, CA 94111 SAN FRANCISCO, CA 94111

KEVIN J. ASHE MARJORY FINN HOLLAND & KNIGHT LLP DAVIS WRIGHT TREMAINE LLP 50 CALIFORNIA STREET, STE. 2800 505 MONTGOMERY STREET, STE 800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111

PATRICK FERGUSON TARA KAUSHIK ATTORNEY PARTNER DAVIS WRIGHT TREMAINE LLP HOLLAND & KNIGHT LLP 505 MONTGOMERY STREET, SUITE 800 50 CALIFORNIA STREET, SUITE 2800 SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94111

VIDHYA PRABHAKARAN VIDHYA PRABHAKARAN ATTORNEY DAVIS WRIGHT TREMAINE LLP DAVIS WRIGHT TREMAINE LLP 505 MONTGOMERY STREET STE 800 505 MONTGOMERY STREET, SUITE 800 SF, CA 94111 SAN FRANCISCO, CA 94111

STEVEN F. GREENWALD ALLIE DETRIO ATTORNEY REIMAGINE POWER DAVIS WRIGHT TREMAINE LLP 77 SALA TERRACE 505 MONTGOMERY STREET, STE. 800 SAN FRANCISCO, CA 94112 SAN FRANCISCO, CA 94111-6533

LENNEAL GARDNER CASE ADMINISTRATION CORPORATE COUNSEL PACIFIC GAS AND ELECTRIC COMPANY TRANS BAY CABLE LLC EMAIL ONLY ONE LETTERMAN DR. BLDG. C, 5TH FL. EMAIL ONLY, CA 94177 SAN FRANCISCO, CA 94129

BRIAN GRUBBS FRANK PERDUE-ROSSI ADVISORS ADVISORS MONTAGUE DEROSE AND ASSOCIATES, LLC MONTAGUE DEROSE AND ASSOCIATES, LLC 2175 NORTH CALIFORNIA BLVD., STE 422 2175 NORTH CALIFORNIA BLVD., STE. 422 WALNUT CREEK, CA 94596 WALNUT CREEK, CA 94596

THOMAS DEL MONTE RACHEL BIRD LAW OFFICE OF THOMAS R. DEL MONTE BORREGO SOLAR 1555 BOTELHO DRIVE, NO.172 1817 FRANKLIN ST., SUITE 700 WALNUT CREEK, CA 94596 OAKLAND, CA 94612

SHERIDAN PAUKER BETH OLHASSO PARTNER AGRICULTURAL ENERGY CONSUMERS ASSO KEYES & FOX LLP 925 L STREET, SUITE 800 436 14TH STREET, SUITE 1305 SACRAMENTO, CA 95814 OAKLAND, CA 94612

ELIZABETH BOJORQUEZ JACKIE KINNEY LEGISLATIVE ANALYST SR VP & GENERAL COUNSEL CA CABLE & TELECOMMUNICATIONS ASSâ€™N CA CABLE & TELECOMMUNICATIONS ASSâ€™N



1001 K STREET, 2ND FLOOR 1001 K STREET, 2ND FLOOR SACRAMENTO, CA 95814 SACRAMENTO, CA 95814 FOR: CA CABLE & TELECOMMUNICATIONS ASS'N FOR: CA CABLE & TELECOMMUNICATIONS ASSOCIATION

LAURA FERNANDEZ LAURA FERNANDEZ ATTORNEY ATTORNEY BRAUN BLAISING SMITH WYNNE, P.C. BRAUN BLAISING SMITH WYNNE, P.C. 915 L STREET, SUITE 1480 915 L STREET, STE 1480 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814

LAURA MCWILLIAMS REGULATORY CLERK STATE SENATOR JERRY HILL BRAUN BLAISING SMITH WYNNE, PC STATE CAPITOL, ROOM 5035 915 L STREET, STE. 1480 SACRAMENTO, CA 95814 SACRAMENTO, CA 95814

JEDEDIAH J. GIBSON JEFFERY D. HARRIS ATTORNEY ATTORNEY ELLISON, SCHNEIDER & HARRIS, L.L.P. ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVENUE, SUITE 400 2600 CAPITOL AVENUE, STE. 400 SACRAMENTO, CA 95816 SACRAMENTO, CA 95816

SAMANTHA G. NEUMYER LYNN M. HAUG ELLISON SCHNEIDER HARRIS & DONLAN LLP ELLISON, SCHNEIDER & HARRIS LLP 2600 CAPITOL AVE., STE. 400 2600 CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA 95816 SACRMENTO, CA 95816-5905

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